Matan's Deposition: Evasive but generally pleasant deposition overshadowed by fantastically entertaining 'legal' antics

The Courts Apr 20, 2021

Matan Gavish April 20, 2021 NDT Assgn # 50508

Wow, what a $hit $how.  In this first few minutes of the Deposition, Mom states she is representing herself pro se and Frank S. Moore, is just there as attorney for Matan? Later in the depo Tara slips that he her lawyer too, but it is too late the two are already tag-teaming the witness in a way that will make you cringe. The two fed off each other, gobbling the time with insults of Ms. Llaguno.

Mom plays dumb and looks like a cat, for now. And because of the strong reaction to Mr. Moore's behavior, a full video content of their speeches will be made available to forward to an ethics board (along with his other depositions.) Mom knew exactly what she was doing. Obstructing the deposition and case while pretending to be an idiot so she wouldn't get in trouble. She stated to Joy that she does it all the time and doesn't get in trouble, and that is true.

[Update: The full Matan Gavish deposition video is now available for verified members after the transcript below.]


Members - The following is for members of the site only, so please sign up and verify your identity if you'd like to read more about Grumpa's deposition.


Matan Gavish April 20, 2021 NDT Assgn # 50508

THE VIDEOGRAPHER: We are on the record. The time is 12:03 p.m. The date is April 20th, 2021. This is the beginning of the deposition of Matan Gavish. The case caption is Russell versus Walsh. Will counsel introduce yourselves and state whom you represent?

MR. MOORE: Frank Moore and I'm here Matan for his deposition solely.

MS. LLAGUNO: And my name is Joy Llaguno, representing plaintiff, Stephen Russell.

MS. WALSH: And my name is Tara Walsh. I am a pro se litigant representing myself.

THE VIDEOGRAPHER: The court reporter will now swear in the witness.

MR. MOORE: I'm sorry. There -- there appears be someone still on, but not identified. I'm seeing a screen that's got an arrow on it. What is that?

MS. LLAGUNO: Steve, can you go ahead and state your name for the record

PLAINTIFF RUSSELL: Hi, this is Steve Russell.

THE VIDEOGRAPHER: The court reporter will now swear in the witness

THE REPORTER: All right. And just before I do swear in the witness, for all counsel present, I'd just like to stipulate for the record that the swearing in and testimony will be captured remotely by a professional digital reporter and that all present agree to this method of preserving today's record. The testimony will be transcribed and certified. Ms. Llaguno, do you agree?

MS. LLAGUNO: Yes.

THE REPORTER: And, Ms. Walsh and Mr. Moore, do you agree?

MR. MOORE: Are -- are you a California court reporter?

THE REPORTER: Counsel, I am a certified federally with the electronic reporter, sir. I am located in Portland, Oregon.

MR. MOORE: Okay. And you're -- but you're authorized to be the court reporter for California jurisdiction; correct?

THE REPORTER: Yes, sir.

MR. MOORE: Okay. With --

THE REPORTER: All right.

MR. MOORE: With -- with that representation, I agree.

THE REPORTER: Excellent.

Q. Have you speak -- spoken with Ms. Walsh your deposition today?

MS. WALSH: How -- how is that relevant?

MS. LLAGUNO: It's -- it's relevant as a basis for his deposition testimony.

MS. WALSH: That has nothing to do about the deposition, the time frame that you're deposing him for. How does any conversations with me have to do --

MS. LLAGUNO: -- of his testimony if you've talked to him, so I'm -- I'm entitled to ask him those questions.

MS. WALSH: I -- I think that those questions would lead to expanding the scope of your discovery, which is my fear and concern. So I -- I don't understand why it would be relevant as to why he talked to me about any matters --

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: -- preceding the time frame you're addressing.

MS. LLAGUNO: Ms. Walsh, you're not allowed to have speaking objections. You can only object as to form or if you believe it's privileged

MS. WALSH: Well, it has to do with me; right? And I'm a pro se litigant, so I believe it's privileged whether or not he spoke to me about the lawsuit.

[...]

MS. LLAGUNO: Q. Okay. And so I'm going to scroll down to -- did you go over this document with Ms. Walsh?

A. No.

Q. Did you contact Ms. Walsh after you received deposition subpoena?

A. No.

Q. And how many times have you spoken with her regarding this lawsuit?

MS. WALSH: Again, I think that that's a privacy concern, so I think that that's a privileged conversation.

MS. LLAGUNO: You can state your objection for the record, but he's still entitled to respond.

MS. WALSH: Okay. I object to that.

BY MS. LLAGUNO: Q. Mr. Gavish, can you please respond if you've spoken with Ms. Walsh about this lawsuit?

MS. WALSH: That has to do about my confidentiality. No. As a pro se litigant, whether or anybody's spoken to me about the lawsuit. Just like you have confidentiality with your client, I have confidentiality as a pro se litigant.

MS. LLAGUNO: You're not an attorney and you're not providing -- you don't -- there's no --

MS. WALSH: Well, I'm a pro se litigant, so -- and I have a restraining order against Mr. Russell, so anything that has to do with my communications with as per my restraining order, is confidential here in New York State.

MS. LLAGUNO: We are -- okay. You -- there's no attorney-client privilege between you and Mr. Gavish, Ms. Walsh.

MS. WALSH: Okay. But any communications -- any communications that I had -- Mr. Russell's on this phone all. Any communications that I have, email, anything, he's not privileged to know as per the restraining order. He cannot have any information having to do with me as per the restraining order in a deposition like this. And you can bring that up with the New York courts if you want to.

MS. LLAGUNO: Okay. Noted. We will.

Q. Okay. And I'm going to show you now what we're going to mark as Exhibit 38. Do you recognize this document?

A. No.

MS. WALSH: Sorry. I just --

MS. LLAGUNO: Okay.

MS. WALSH: -- have an objection. I don't know why this is in the scope of what you're deposing him. You're showing him --

THE DEPONENT: Oh.

MS. WALSH: -- legal documents that have been involved in proceedings --

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: -- that have --

MS. LLAGUNO: -- you cannot --

MS. WALSH: -- they're legal --

MS. LLAGUNO: -- make an objection. You - -

MR. MOORE: Well, I -- I'm going to join the objection. What -- what's the point of this? I mean, here, okay?

MS. LLAGUNO: I --

MR. MOORE: We -- we -- we -- we've gone past this whole issue of whether he can resist this. This – he's chosen to be here, so what's the point of all this?

MS. LLAGUNO: I'd like to know whether he prepared this document.

BY MS. LLAGUNO: Q. Mr. Gavish, did you prepare this document?

MS. WALSH: This document is completely irrelevant. It's a document that was submitted in order defend the order to show cause, I'm assuming. It has nothing to do with the scope of what you're deposing him for. You could be sitting here all day going through documents from the past three years --

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: -- and maybe that's why you think it would take seven hours.

BY MS. LLAGUNO: Q. Okay. Mr. Gavish, can you please respond? Did‌‌you prepare this document?

A. Ma'am, I'm sorry, I'm just really confused right now. We've been here an hour and we haven't talked about anything relating to --

Q. Okay.

A. -- Steve and Tara.

Q. Okay. So we will get to that.

MR. MOORE: Yeah. I -- I -- I agree with this. This is a -- a lot of just nonsense and -- and this is a deposition --

MS. LLAGUNO: Okay.

MR. MOORE: -- that was -- was -- was noticed preservation for trial testimony. None of this is going

MS. LLAGUNO: This is my --

MR. MOORE: -- to be admitted --

MS. LLAGUNO: This is my --

MR. MOORE: -- into a trial.

MS. LLAGUNO: This is --

MR. MOORE: And -- and --

MS. LLAGUNO: Mr. Moore, that is my decision to make and you cannot make speaking objections.

MR. MOORE: I -- I'm --

MS. LLAGUNO: Please --

MR. MOORE: I'm saying this is irrelevant. move on.

BY MS. LLAGUNO: Q. Mr. Gavish --

MR. MOORE: Let's get to the heart of --

MS. WALSH: I agree with that.

MR. MOORE: -- what this deposition's about.

MS. WALSH: This is -- this is some sort of baiting thing that you're doing to try and catch him up or something. This has -- this is about you trying to create additional issues for Matan. It has nothing to do with scope of --

BY MS. LLAGUNO: Q. Please respond to the question. Did you prepare this document?

A. Ma'am, I have a lot of things going on in my personal life right now. I would -- I'm here voluntarily. Can we please get to the actual questions that you need to help Stephen in his case?

Q. And this is relevant to this case.

MS. WALSH: Objection. Privacy concerns.

MR. MOORE: I'm going to ask for an order -- I'm going to ask for an offer of proof as to why it's

MS. LLAGUNO: I'd like to know if he produced this document -- if he prepared this document.

MR. MOORE: What you would like to know is -- is -- is irrelevant. What -- what's the --

MS. LLAGUNO: That is --

MR. MOORE: How is it relevant to --

MS. LLAGUNO: Okay.

MR. MOORE: -- the dispute --

MS. LLAGUNO: Ms. Walsh represented in this case that Mr. Gavish authorized and prepared this document. it is -- it goes to her credibility that he did not. He‌‌ said that he did not recognize this document and that goes to her credibility.

THE DEPONENT: I --

MS. WALSH: He said he did not --

MR. MOORE: Okay.

MS. WALSH: -- recognize the prior document. He‌‌ said he's overwhelmed with personal issues right now --

Q. Okay. So you and Ms. Walsh still have an amicable relationship then; is that correct?

A. Yeah.

Q. Okay. I understand you've helped care for her two dogs quite a bit; is that correct?

A. Yes.

Q. Do you still?

A. I help to take care of them, yes.

Q. What are their names?

A. Riley and Cooper.

Q. When did you first get involved with caring for them?

A. It was --

MS. WALSH: That is so creepy.

THE DEPONENT: -- when -- when she came back California.

BY MS. LLAGUNO: Q. Can you tell me the year?

A. I -- I don't recall what year that was. What that, three years ago? I --

Q. 2018 sound correct to you?

A. 2018's -- 20 -- I -- I mean, yeah, I'll -- I'll -- do you have papers in front of you that state that? I -- I -- I don't want to say anything that I don't know for sure, so --

[...]

MR. MOORE: -- deposition of Matan. So you – you -- she's not entitled to ask you questions. If you want to volunteer the date just so that we all know, but, you know, I can represent it's 2018, so let's just --

MS. LLAGUNO: And --

MR. MOORE: -- move on.

MS. LLAGUNO: -- I appreciate --

MS. WALSH: I don't think it was 2018. I don't recall. I was in a relationship. I had a daughter.

MR. MOORE: Oh, no, no, no.

MS. WALSH: And then my --

MR. MOORE: When you came back to New York. That's the -- that was the -- the -- the frame of reference, as I understand.

MS. WALSH: Oh, yeah. We weren't in any formal relationship. We've been friends primarily.

MR. MOORE: So --

THE DEPONENT: No, that's not what she was asking.

MR. MOORE: So -- so, Tara, refrain from -- from testifying in this -- in this deposition.

THE DEPONENT: Can -- Joy, can we just say it sometime around 2018? Does that --

BY MS. LLAGUNO Q. Yes.

MS. WALSH: I'm sorry -- I'm sorry, Frank, he's your client. I don't know why this stuff is relevant, to -- to get into all this history.

MR. MOORE: It -- it -- it just goes to -- it just goes to your relationship with them and as -- that – that goes to relevancy of his -- of his bias as a witness. That's all it is. So let's --

MS. WALSH: Okay.

MR. MOORE: -- let's move along.

MS. WALSH: Okay.

THE DEPONENT: I -- I -- I'll tell you right I had no bias, okay? I -- I am Switzerland, all right?

MS. LLAGUNO: Mr. Moore, as -- until there is a court order, for all intents and -

MR. MOORE: I don't care --

MS. LLAGUNO: -- purposes --

MR. MOORE: You can say all you want. I'm just telling you that's the position.

MS. WALSH: I think, Joy, if you don't agree this, I think you should reach out to the San Francisco court. You should reach out to the judges in the San Francisco Superior Court and tell them that you want to questions about the cross-complaint and see what they say. I think that that would -- before we proceed with any depositions, if you feel like that's something that you want to do, because I will not be addressing any of those issues. And I have formally revoked my cross-complaint. It was accepted by the clerk. It is formally revoked.

MS. LLAGUNO: Noted, Ms. Walsh. We are still entitled to take discovery into matters related to you, so --

THE DEPONENT: I mean, I'm -- I'm just trying to strike a middle ground between whatever I'm helping Steve with and whatever I'm helping Tara with. And I just, like -- like, it seems strange that, first of all, Steve is not showing his face and that we're not asking him questions.

MR. MOORE: Well, hold -- hold on a second. Counsel, represent whether your client is continuing to monitor this deposition because he's not appearing on the screen anymore.

MS. LLAGUNO: Yes, he's -- he's listening in via phone.

MS. WALSH: Is he -- is he asking --

MR. MOORE: And why -- why isn't he listed on – as a participant on the -- on the Zoom call?

MS. LLAGUNO: He is listed. We gave the court reporter his name.

MR. MOORE: No, no. He's not listed currently a box. That's how Zoom works. If you're on the phone --

MS. LLAGUNO: Can we -- can we --

MR. MOORE: -- or you're --

MS. LLAGUNO: -- go off the record --

MR. MOORE: -- you're --

MS. LLAGUNO: -- to discuss this --

MR. MOORE: -- engaged, you appear on the Is he on or not?

MS. LLAGUNO: Can -- would you like to go off -- we've taken so much time from this deposition.

MR. MOORE: No, no, no, no. He can -- if he's on, he can just pipe up and say he's on.

MS. LLAGUNO: Mr. Court Reporter, can you that Steve Russell is listed as a participant in this deposition?

MR. MOORE: That's not my question. My is he currently listening in on this deposition?

PLAINTIFF RUSSELL: I'm -- I'm currently listening into the deposition via Zoom. Zoom has an --

MR. MOORE: Okay.

PLAINTIFF RUSSELL: -- audio phone call --

MR. MOORE: Okay.

PLAINTIFF RUSSELL: -- that you can dial in. I‌‌don't --

MR. MOORE: Right.

PLAINTIFF RUSSELL: -- believe that there was an opportunity to type in my name. But I did give it to the court reporter. Is that sufficient?

MR. MOORE: Yeah. When -- when you -- when you speak, your name -- your -- your name appears. When it – when you're not speaking, it goes to the court reporter's emblem, so that's -- that's why we wanted to know. Thank -- thank you -

PLAINTIFF RUSSELL: Okay.

MR. MOORE: -- for clarifying.

PLAINTIFF RUSSELL: Well, I'm represented and not testifying today, so I won't be speaking.

MS. LLAGUNO: Thank you.

MR. MOORE: Great. Thank you. Thank you, Mr. Russell.

Q. Mr. Gavish, did Tara ever tell you she was drugging Steve without his knowledge or consent?

A. No. I learned about something to do with that after -- after some kind of litigation started in -- well, I guess in this -- this -- this case right now, I -- I think. So, yeah, I -- I learned after this whole thing started sometime.

Q. Okay. I'm going to present you with a few documents where Tara has admitted to giving drugs -- Steve drugs without his knowledge or consent. I'm going to with you now what we're going to mark as Exhibit 39. And --

MS. WALSH: Okay. First of -- I just need to --

MR. MOORE: No, let -- let -- Tara -- Tara, just -- let's just let her lay a foundation and let's – let's move on.

MS. WALSH: But this is a hacked text from my phone, Frank. I just got to --

MR. MOORE: But let --

MS. WALSH: -- say that --

MR. MOORE: And the -- the --

MS. WALSH: -- that he took.

MR. MOORE: Okay. Whatever. It's -- let's just-- let's just move on.

BY MS. LLAGUNO: Q. I'm sharing a document that is -- I'm marking as Exhibit 39, which Ms. Walsh produced in this litigation, Bates stamped Walsh_00168. This is a text message that Tara produced in this litigation from her phone in which she texted her doctor, Dr. Gopal. Mr. Gavish, can you please read the first text message?

MS. WALSH: So just one thing -- one last thing, Frank. Can you -- you said that I provided this in litigation; right? Correct? Can you -- can you tell me where in litigation I provided this text, just for the record?

MS. LLAGUNO: Yes. Bates Stamp Walsh 000168 in this action.

MS. WALSH: Okay.

BY MS. LLAGUNO: Q. Mr. Gavish, can you please read the text message out loud?

A. "So I came home and the nanny told Steve about another thing I'd told her in confidence. Sometimes when he was out of his mind on drugs and won't sleep, I have Seroquel in his wine because I don't know what to do. The nanny has been -- the nanny's been throwing me under the bus every night. Last night, she told him I wanted her to stay -- to say he was a bad dad. "I told Steve I was sick of the nanny throwing under the bus to him and didn't feel comfortable with her working -- working her" -- probably here -- "and sent her home."

Q. Thank you, Mr. Gavish. And I'm also going to show you now what we're going to mark as Exhibit 40.

MS. WALSH: Excuse me. You did -- just one thing. Can you -- can you please confirm who that text between and just confirm that it wasn't Mr. Gavish? Because it doesn't say Mr. Gavish, so can you confirm who this text was allegedly to?

BY MS. LLAGUNO: Q. And, Mr. Gavish, Ms. Walsh produced this in this litigation --

MS. WALSH: Who --

MS. LLAGUNO: -- after --

MS. WALSH: When I communicated this text, who was I communicating to? Because it wasn't Mr. Gavish. you say who I was --

MS. LLAGUNO: So --

MS. WALSH: -- allegedly communicating to?

MS. LLAGUNO: As stated prior, it was Dr. Gopal, as you can see in the text message.

MS. WALSH: And can you state on record who Dr. Gopal was?

MS. LLAGUNO: The -- I don't have to --

MR. MOORE: Well, can you represent -- who is Gopal?

MS. WALSH: Dr. Gopal was my psychiatrist in San Francisco, so this is, like, a complete violation --

MR. MOORE: How --

MS. WALSH: -- of HIPAA.

MR. MOORE: How -- how -- how -- how did -- how -- how did -- how did this get in the possession of you, Ms. Llaguno?

MS. LLAGUNO: Ms. Walsh produced it, as you can see with the Bates stamp, Walsh_00168, in this litigation. She produced it --

MS. WALSH: I'm not sure that it was, though, so I would need to look through the --

MS. LLAGUNO: I'm --

MS. WALSH: -- discovery.

MS. LLAGUNO: I'm representing to you that this was produced.

MS. WALSH: All of my texts were given to you in an Excel sheet.

MR. MOORE: All right. Well, look, I mean, there somewhere else that there's an admission of the same thing, somewhere else that's not a --

MS. LLAGUNO: I'll -- I'll move on to --

MR. MOORE: -- a -- a private document?

MS. LLAGUNO: Okay. I'll move on to another document.

MR. MOORE: Because, you know, if there is a privacy right and a HIPAA right and a California Medical Information Act right, it has not always been waived. You know, we -- it would be better to use something that doesn't have all that problems with it.

MS. LLAGUNO: Okay, Frank. But Ms. Walsh produced this specific document in this litigation. We are getting it from her own document production.

MS. WALSH: It --

MS. LLAGUNO: I'll move on to the next --

MS. WALSH: I do not -- I do not -- I am self-represented now. I do not recall providing this in any discovery document. I know that this is a text that Mr.‌‌Russell got from hacking into my phone that he used in family court. I don't even know if I sent it. I know written to my psychiatrist, but I --

MR. MOORE: Well --

MS. WALSH: -- but whatever.

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: I don't --

Q. And when she did speak with you about this drugging of Steve, what other information did she relay to you?

A. That's all that I recall. I think there was something about a stove being left on or something like that. Apparently, Mr. Russell, I think he -- he left on a stove or -- or something or was maybe sleepwalking or I -- I don't know what and something about the nanny – actually, I think the nanny, like, locked herself in a room with Evie. Yeah, something like that.

BY MS. LLAGUNO:Q. And did Ms. Walsh tell you if anyone helped her‌‌ give these drugs to Steve?

A. No. Oh --

Q. Do you --

A. -- actually -- actually, no. So I think the nanny and some of Steve's security were aware of it.

Q. Ms. Walsh explained that to you?

A. I mean, at some point, I got -- yeah. I mean, -- it -- it's not going to be Steve. I mean, Steve and I have never talked. So, yeah.

Q. So just to clarify, Ms. Walsh told you that the nanny and Steve's security guards had helped him -- her put drugs in Steve's drink; is that correct?

A. They were -- they were aware of it. They were encouraging it, yeah.

Q. Mr. Gavish, have you had a chance to review text messages? Do you want me to scroll --

A. I --

Q. Let me know if you'd like me to scroll or if you want me to zoom out.

A. Yeah, just the second page, please. Down there, yeah. And I -- I -- I -- I don't recall them -- no, I don't -- it doesn't refresh anything for me.

Q. So your testimony sitting here today under penalty of perjury is you do not recall these text messages?

A. Yes.

Q. Do you have any reason to believe that these are -- these -- this is not you texting Ms. Walsh in these messages?

A. It's possible. It's possible the entire thing was fabricated, but it's also possible that I sent. really couldn't tell you.

Q. Okay. Thank you. And I'm going to scroll further down. Could you also read this -- this February 21st, 2018 text message?

MS. WALSH: I -- I'm going to object to its – I'm -- I'm sorry, Frank, and I'm -

MR. MOORE: Tara --

MS. WALSH: -- sorry --

MR. MOORE: Tara -- Tara -- Tara, let -- there's no question pending, so let's just wait until we get --

MS. WALSH: Okay.

MR. MOORE: -- a question.

MS. WALSH: But this is completely fabricated stuff that Steve has used in family court.

MR. MOORE: Right. But --

MS. WALSH: All of this text stuff.

MR. MOORE: Regardless, you've already got a foundation and an authenticity objection --

MS. WALSH: Okay.

MR. MOORE: -- so let's -- let's have him -- him read it to see if it refreshes his recollection.

THE DEPONENT: Is the question that it – or not I remembered these messages or, like, the time surrounding it?

Q. Just remember the text messages.

A. I don't recall them.

Q. Do you remember the time frame surrounding them?

A. Well, it says 2018, but no.

Q. Okay. And so you no longer would have record of‌‌ these messages from 2018; is that correct?

A. Say again?

Q. You no longer have these text messages in your possession; is that --

MS. WALSH: Objection. You're stating that there's some factual basis to these texts when I've stated that there isn't. And they are -- would have been from my phone in conversation to Mr. Gavish. So, I mean, you're -- you're making it seem like this is -- these are, in fact, real texts when I can't even confirm that they're real texts. So --

MS. LLAGUNO: Ms. Walsh, this is --

MS. WALSH: -- just for the record.

MS. LLAGUNO: -- in discovery.

MS. WALSH: And you know what, I -- if they were in discovery, I just realized they were in discovery in proof of Mr. Russell's hacking into my phone. So you're also not giving context to what this discovery is because this actual document is something that Mr. Russell's provided to family court. It's not something I wrote or ever provided to any -- anything. So that's probably the context of it in discovery.

Note: Mom contradicts herself by saying the messages are fake and can't be verified AND that they are true and proof that Dad 'hacked' her. In reality, the police told Mom there was nothing wrong with the way the messages were obtained.


MR. MOORE: -- against any --

MS. LLAGUNO: Mr. Moore --

MR. MOORE: -- privacy interests.

MS. LLAGUNO: -- are you representing Ms. Walsh?

MR. MOORE: Sorry?

MS. LLAGUNO: Are you representing Ms. Walsh today?

MR. MOORE: Ms. Walsh is representing herself here.

MS. LLAGUNO: And you're only representing Mr. Gavish; correct?

MS. WALSH: In representing --

MR. MOORE: That's correct.

MS. WALSH: -- Mr. Gavish, he has to include me in that representation --

MR. MOORE: But -- but she --

MS. WALSH: -- because the --

MR. MOORE: But she --

MS. WALSH: -- the complaint is against me, not Mr. Gavish; right? So I'm the core of it.

MS. WALSH: And it's -- and it's compound – compounded by the fact I live in New York State and I have a full stay-away, me and my daughter, order protection against Mr. Russell. We've had it for almost three years. It extends until 2022.

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: It's the most -- the highest-level order protection that you can possibly have, which is indicative of the type of behavior that he's shown towards me. So --

NOTE: The order of protection was vacated a couple of weeks after this deposition. It was granted by default and the court later learned that Tara had admitted her allegation was false and that Dad had been granted a permanent restraining order over essentially the same facts after a long form hearing in San Francisco.


Q. Did Ms. Walsh ever communicate with you about benefiting from Ms. -- Mr. Russell's wealth because she's dating him?

A. No. Tara comes from tons of money. She doesn't need anybody's money, so, no.

Aunt Brie and Brendan knew that Mom moved to San Francisco to 'take [Dad's] money.' Excerpt from Brienne Walsh Deposition, p. 45, 9/28/2020

MS. LLAGUNO: Let me continue.

MR. MOORE: You're not a witness, Counselor. can't testify in this case. Sorry.

MS. LLAGUNO: Ms. Walsh has testified and I responded back to what she said.

MS. WALSH: You -- you -- you directly asked me questions, Joy, so that's on you.

MS. LLAGUNO: I didn't ask you a question directly.

MS. WALSH: Yes, you did. In the beginning of the deposition, you directly asked me a question.

MS. LLAGUNO: Ms. Walsh and Mr. Moore, please stop with these speaking objections. I'm trying to get through this deposition. And we're --

MS. WALSH: We have a right -- I have a right to defend myself, particularly when you're being inappropriate, invading my privacy and privacy of a stranger.

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: So, I mean --

MS. LLAGUNO: Ms. Walsh, you produced these documents, again, in discovery.


Q. What did she tell you?

A. I mean, obviously, I can't, you know, recall verbatim, but this was something that kind of alarmed me. So I remember -- and this stuck out because when you have somebody that's reportedly has -- or is not in the best state of mind that has a high-caliber weapon, then, I that's just not a good combination. So I -- I -- I recall her mentioning that he had  a high -- a -- a -- she said a sniper rifle, I think, or‌‌22 that it was a marksmanship rifle -- I don't remember exactly -- that had a computerized telescope. And, yeah,  that -- I do recall that and that was concerning.

Q. Ms. Walsh relayed that information to you?

A. Correct.

Q. When did she tell this to you?

A. I think that was early on in their relationship, but I'm -- yeah. I -- again, I -- I mean, I can't -- I  don't know what month or year precisely. That's -- I -- I -- I feel like it was earlier in their -- early on in relationship.

Q. But she eventually told you that he didn't actually have a gun; is that correct?

A. I don't recall that.

Q. She never told you that one of his security personnel told her there was no gun

A. No, I don't recall that.

Q. She -- Ms. Walsh never told you that she had imagined the gun; is that correct

A. Can you -- can you restate that question,

Q. Ms. Walsh never told you that she had imagined the gun that she thought was in Mr. Russell's possession; is that correct?

A. That never happened, correct.

Q. Ms. Walsh never explained that she was experiencing post-partum psychosis; is that accurate?

A. I've -- I have no knowledge about that.

Q. So Ms. Walsh never discussed any post-partum psychosis with you?

A. Correct.

Q. Okay. Were you aware that Tara called her mother, Maura Walsh, and Steve to get her an emergency psychiatric evaluation in May of 2018?

A. No, I'm not.

Q. Were you aware that -- or I'm sorry. Did Ms. Walsh ever tell you that her parents and Tara agreed that she should have emergency treatment with a doctor named Gopal in San Francisco?

A. I -- I don't recall.

Q. You've never discussed her -- that evaluation with Ms. Walsh?

A. Not that I can recall.

Q. Okay. Were you aware that Tara called her mother, Maura Walsh, and Steve to get her an emergency psychiatric evaluation in May of 2018?

A. No, I'm not.

Q. Were you aware that -- or I'm sorry. Did Ms. Walsh ever tell you that her parents and Tara agreed that she should have emergency treatment with a doctor named Gopal in San Francisco?

A. I -- I don't recall.

Q. You've never discussed her -- that evaluation with Ms. Walsh?

A. Not that I can recall.

Q. And Ms. Walsh never discussed with you her – diagnosis of borderline personality disorder; is that accurate?

A. So she's mentioned that in the past. She's mentioned it. I -- I -- it's not my opinion that it -- it -- so I recall some conversations around that, but it's -- I don't know. I -- I -- I think the two people in that house, that they shouldn't have been together. And it created, you know -- they did what they did, okay? I think they both -- I think they both got on each other's nerves a lot. That's what I -- that's my opinion.

Q. Okay. And so during this time, did Ms. Walsh speak with you about a diagnosis of borderline personality disorder?‌‌A. So I think there was a -- there was a tim again --

MS. WALSH: Sorry --

THE DEPONENT: -- I was --

MS. WALSH: -- sorry, sorry. I just wanted say you're completely leading. You're not a psychiatrist, Joy. You're diagnosing me with borderline personality disorder.

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: You're saying -- you're saying I was diagnosed with borderline. You're not saying, "Did she believe?" You're putting -- you're diagnosing me with something --

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: -- I've never been diagnosed with.

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: So just for the record, you're assuming the roles of a medical provider or psychiatrist

MR. MOORE: Yeah, Tara -- Tara, the -- the question is, did -- did -- the question is, did you tell him that you were diagnosed? So that's the question.

MS. WALSH: Okay.

THE DEPONENT: So -- so, no, I don't believe she ever said to me that she was diagnosed with -- what is it again? Borderline -- borderline personality disorder. And I think one of the reasons I'm struggling to answer this right now is that my understanding of it doesn't a good portrait of Steve. And I -- you know, I -- I'm -- I'm trying to be impartial here. I can't see Steve. You know, I've never met the guy. I don't know what he's doing. I don't want to say things that I've heard about him that are negative, okay? But that's where you're leading me.

BY MS. LLAGUNO: Q. Okay. Understood, Mr. Gavish. I'd like to note for the record that after -- after Mrs. Walsh's speaking objection, you changed your testimony as to what she discussed with you. But I'll on now. So what do you --

Q. This document was produced by Tara Walsh in this litigation and bears the Bates stamp Walsh 003441. Do you recognize this document?

A. Not particularly in detail, but, again, it looks like an email between me and Vital Branding.

Q. And there's no basis for you to believe that isn't an email between you and Vital Branding, is mean, sorry, Ms. Walsh; is that correct?

A. I -- I'm suspicious of everything, so -- but,

Q. Okay. And so this is an email that Tara sent on June 7th -- I'm sorry. That's June 7th, 2018; is that correct?

A. Yes.

[...]

MS. LLAGUNO: Mr. Moore, I do not appreciate the insults on the record. If you could please cease your speaking objections and maybe have a little drop of professional conduct, I'd really appreciate that so we can complete this deposition. Thank you.

BY MS. LLAGUNO: Q. Mr. Gavish, so did you have a chance to review this email? I'd like to just put on the record that your counsel, Mr. Moore, does not want you to read any exhibits into the record.

MS. WALSH: I -- I would like to also put on record that I do not verify that any of these are real either, so I don't know the context of what they were submitted to in the discovery, if they were at all, so I would also like to put that on record.

MS. LLAGUNO: So, Ms. Walsh, again, you produced this document in discovery. It has your Bates stamp at bottom right-hand corner.

MS. WALSH: A lot of the documents I provided in discovery were documents that Mr. Russell got in by fabricating or he obtained them by hacking into my I mean, how else would you have text conversations between me --

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: -- and a stranger from four years ago, which literally has nothing to do with anything? So the nature of all the documents in discovery, a lot of are, you know, demonstrating for us then, so --

MS. LLAGUNO: I'd like to --

MS. WALSH: -- that's -- that's very, very important.

MS. LLAGUNO: Ms. Walsh, I'd like to remind you that were sanctioned previously in this litigation for not producing documents and the Court ordered --

MS. WALSH: I was not sanctioned for not -- I sanctioned, I believe, for being late on producing documents. And that is only because I had maybe, like, four other court proceedings that were important about custody of my daughter. And --

MS. LLAGUNO: Okay.

[...]

MS. WALSH: So the -- the -- it needs to be – everything needs to be within context; right?

MS. LLAGUNO: Correct, Ms. Walsh. And I'd also like to remind you that I think it was within a week or of the Court's order sanctioning you and compelling you to produce documents. These are the documents you produced.

MS. WALSH: I -- I don't know that that's a but, again, you're making a lot of facts that I don't know are facts, so --

MS. LLAGUNO: Okay. Well, I'm going to to you that I have communications from your counsel producing these documents. Can I please continue --

MS. WALSH: Again, Joy, I have upmost respect the court system and judges and lawyers, but -- and I'm a respectful person in general, but your position and what‌‌21 you're doing here and not being honest and stuff, I -- I‌‌22 don't respect that, so I'm not trying to be disagreeable. It's just not a very respectable position.

MS. LLAGUNO: Well, it -- it's not appropriate for you to go on these diatribes on the record. You can please just lay your --

MS. WALSH: Oh, I go on these diatribes in court when I'm on the stands and the -- the judges allow it, I think we're good.

MS. LLAGUNO: But this is my deposition. I'm entitled to ask the questions. You are entitled to lay your objections and let the deponent respond or instruct him not to respond, but you're not allowed to take up the entire deposition time with these diatribes.

Q. Okay. Let me rephrase the question. So is it correct that Ms. Walsh communicated to you that she was planning on filing legal proceedings against Steve Russell while she was in San Francisco?

A. I don't know. I -- I know that, like, right before she came back, there was a lot of, I guess, chaos going on. But I -- I don't know what she was planning.

Q. When you respond to Ms. Walsh, "What is your nickname?" what was your intent with that response?

A. That would be to verify the sender.

Q. So you were trying to get Tara to confirm her identity?

A. Likely.

Q. Why? Why would you do that?

A. Maybe it was -- what -- what was the email sent it?

Q. What was it?

A. Can you pull up -- can you pull up the -- pull the document back up, please? So it's at Tara. Okay. So it must have been after all the hacking stuff. So somebody's devices get hacked, then it stands to reason that you can't be sure who's -- who's on the other end, you're talking to.

Q. Has someone emailed you from Tara's email that wasn't Tara before?

A. I don't know.

Q. Okay.

A. I don't know how you --

Q. I'm --

A. -- prove a negative.

[...]

Q. This document was produced by Tara Walsh in this litigation, bearing the Bates stamp 003634. Do you recognize this document?

A. Is there a way that you could rephrase instead saying "recognize"? Like, I don't know -- I don't know exactly, precisely what you mean by that and how you're going to use it.

Q. Is it -- is this an email between you and Ms.Walsh

A. Looks like it, yeah.

Q. Do you have any reason to believe this is not an email communication between you and Ms. Walsh?

A. It's possible.

Q. Okay. So I'm going to represent to you that Ms. Walsh produced this in her document production. And I believe this to be a continuation of the prior email. As you can see, "What is your nickname?" is on the bottom and there are further communications above. Do you agree with my understanding of this document, Ms. -- Matan?

A. Yes. Yeah.

Q. So after you asked Tara for her nickname, what does she say to you?

A. "Matan -- Matan, seriously, just see a number. Wtf, you can't see my email."

Q. Why didn't you respond to that?

A. That's a -- that's a personal question.

Q. Okay. So you --

A. You -- you -- you want to -- you want -- you to -- to get into things -- no. You know what, I'm sorry. No -- no -- I have nothing further to say.

Q. Okay. And in the following email, Tara says to you, "What do you think of my abuse journal? Spent all writing it." Do you recall receiving that email?

A. I do not.

Q. So you don't recall receiving an email with the attachment "SRabuselog.pdf"?

A. Correct.

Q. Have you ever seen a document titled from Tara Walsh?

A. Not that I recall.

Q. So you don't recall receiving an email with the attachment "SRabuselog.pdf"?

A. Correct.

Q. Okay. I'm going to show you now what we're to mark as Exhibit 49. This document was produced by Tara Walsh in this litigation, bearing the Bates stamp 003442 to 003443. Is this an email between you and Ms. Walsh, Matan?

A. Likely.

[...]

Q. So it looks like you never responded to Tara's email about the abuse log; is that accurate?

MR. MOORE: Assumes facts not in evidence, calls for speculation.

Q. You can respond.

A. Repeat the question.

Q. Did you ever respond to Tara's email about the abuse log?

A. I don't know.

Q. Can you tell me why you were so skeptical that this email was Tara emailing you?

MS. WALSH: Objection. Already asked that question. I was just gone for five minutes and you asked that question before I left. Sorry. Woo.

MS. LLAGUNO: This is a --

MS. WALSH: Keep on asking that same question, Joy.

MS. LLAGUNO: This is a different email, Ms. Walsh.

[...]

Q. Why were you so skeptical that these emails were not from Tara?

MS. WALSH: And just to -- you said "these emails," not this email, just to correct.

Q. Is this an email communication between you and Tara Walsh?

A. Can you -- can you enlarge it a little bit, please?

Q. I'm going to represent to you this is a document produced by Ms. Walsh bearing the Bates stamp Walsh 003448 to 3449.

A. Okay.

Q. And is this an email between you and Tara Walsh?

A. Likely.

Q. Do you need me to scroll down or did you finish reading it?

A. I mean, I -- I didn't read the entire other – the entire chain, no.

Q. Can you please make sure you've reviewed the entire document before I ask questions? Let me know if need me to scroll up or down.

A. No. I recognize some of the content in here.

Q. Okay. So in this document, Tara states that her dad has a very short fuse. Do you see that?

A. Yes.

Q. To your knowledge, do you know if that's true?

MS. WALSH: Objection. Relevancy. It has nothing to do with --

MR. MOORE: Yeah. What -- what does this have do with being drugged?

MS. LLAGUNO: You can lay your relevance objection and he has to respond.

MR. MOORE: Yeah. I'm going to -- I'm going to instruct him not to answer. It's not relevant. It's – it's -- it invades people's privacy. I don't know where you're going with it, so --

MS. LLAGUNO: We're going with Tara's She states that she has a --

MR. MOORE: That's not -- that has nothing to do with Tara's background. What -- what -- what does this have to do with --

MS. LLAGUNO: Ms. Walsh --

MR. MOORE: -- the drugging of Stephen Russell?

MS. LLAGUNO: Ms. Walsh states that she has a pattern of abuse and in other text messages that I'm – me ask my questions. You can lay your objection for the record and let him respond. Let me clarify. Are you directing him not to respond?

MR. MOORE: What's the question?

MS. LLAGUNO: In this communication, Ms. Walsh states that her father has a very short fuse. I'm asking him if -- does he have any knowledge if that's true.

MR. MOORE: You can answer.

MS. WALSH: You said, does her father have an anger problem? But --

MR. MOORE: Well, what -- if you have any knowledge, you can answer it. Your own --

THE DEPONENT: I have no --

MR. MOORE: -- observations.

THE DEPONENT: -- knowledge. I have no knowledge.

Q. Okay. Can you read this top-most email that you responded to Tara Walsh?

THE DEPONENT: It's okay that I read this,

MR. MOORE: Yeah. Yeah. You can read it to --

THE DEPONENT: Okay.

MR. MOORE: -- yourself or -- or you can even read it out loud. I don't -- I don't care about that

you -- you authored it. If that's you, then you can read it.

THE DEPONENT: Yeah. But I don't know -- I -- I don't know who provided them with this document, so --

BY MS. LLAGUNO:

Q. I'll represent to you that Ms. Walsh produced this email in discovery.

MR. MOORE: Yeah, I know. And there's all kinds of --

THE DEPONENT: All right.

MR. MOORE: -- questions about whether things authentic or not, but, I mean, if you -- if you have an independent recollection that you authored that, then that's fair game. You can -- you can testify that you did and -- and -- and then you can own the words if you want own the words. But if you don't, then you don't. But --

MS. LLAGUNO: Mr. Moore, again --

MR. MOORE: -- you know --

MS. LLAGUNO: -- I need -- this is numerous I've told you please don't lay speaking objections. You can clearly --

[...]

MR. MOORE: -- you would have to lay a for the kind of questions you're asking and you're not laying the proper foundation, so I'm having to do it for you. Unfortunately, you don't know how to do your job. MS. LLAGUNO: We're at --

MR. MOORE: So --

MS. LLAGUNO: -- deposition.

MR. MOORE: -- the question here is, if he wants to say, "Yes, that's my words," then he can read it. If says, "I don't know those are my words," then that's a different -- that's a different answer.

MS. LLAGUNO: His testimony is that this is an email communication between himself and Ms. Walsh.

THE DEPONENT: My -- my testimony is that I remember that I recall vaguely some of the -- of the subject. But I can't -- I can't sit here and tell you that's exactly the email that I wrote and that I sent. I don't know that.

Q. Okay. So you never told Ms. Walsh that, "I'd like to meet your dad and his short fuse"?

MS. WALSH: Objection. Rephrasing of the same question. He already stated that he doesn't know if these emails are actually from him. He can't verify them. He didn't submit them as discovery.

MS. LLAGUNO: I'm asking independently of this email.

Q. Mr. Gavish, you can respond.

A. Sorry, the question was, independent --

Q. Do you know if --

A. -- of the email, do I -- go ahead. Sorry.

Q. Did you ever state to Tara Walsh, "I'd like to meet your dad and his short fuse"

A. I don't recall.

Q. Thank you. In 2018, had you ever met Tara's father?

A. I don't -- I don't know.

Q. What is your understanding of why Ms. Walsh repeatedly sends you emails to revise?

A. What do you mean, repeatedly --

MR. MOORE: Lacks foundation, assumes facts no in evidence.‌‌7 BY MS. LLAGUNO:

Q. You can respond.

A. So what -- what is it that you want to know?

Q. What is your understanding of why Ms. Walsh you emails to revise?

A. So --

MR. MOORE: Same objections.

BY MS. LLAGUNO:

Q. You can respond.

MR. MOORE: I don't know if he can respond. not actually been able to recall any of these emails, so, you know, the -- the foundation for your -- your question is -- is missing.

MS. LLAGUNO: Mr. Moore, I'd, again, like to let you –

MR. MOORE: I'm making my objections. Move on, Counsel.

MS. LLAGUNO: I'd like to remind you to stop your speaking objections. They're --

MR. MOORE: I'd like to remind you that I've heard it enough and I'm not going to stop.

MS. LLAGUNO: And I've heard your objections enough. Are you directing him not to respond?

MR. MOORE: I'm directing him to respond to a question that is proper, so can you rephrase it, please?

MS. LLAGUNO: And I rephrased my question. He was about to answer and you laid another objection, speaking objection.

MS. WALSH: I object to your questions because they are completely without any scope. They're talking about a matter of years. You're talking about a friend. Literally is completely ridiculous and has nothing related to the complaint. I mean, let's be real here.

MS. LLAGUNO: Ms. Walsh --

MS. WALSH: So let's get that on record. You're asking him the most broad-stroke questions, like, "What is your favorite color?" Like, these aren't things that are specific to the -- the complaint at all, so I --

MS. LLAGUNO: Ms. --

MS. WALSH: -- object to them, too. I mean, we're just spinning wheels here and wasting --

MS. LLAGUNO: Okay.

MS. WALSH: -- time.

MS. LLAGUNO: I'd like to explain to you you cannot make speaking objections and narrations like that. You can lay your objection for the record, but you can't

MR. MOORE: We are making our record, so can you move on with the question?

MS. LLAGUNO: And please allow him to respond.

MR. MOORE: Do you know what the question is?

Q. Matan, what is your understanding of why Ms. Walsh sends you these emails?

MR. MOORE: Again, I'm going to -- lacks foundation, assumes facts not in evidence. If you have an opinion as to why there are documents that suggest that you were supposed to review them, go ahead.

THE DEPONENT: I -- I think that's a question Tara. I mean, you're asking me to speculate on what's inside of her head and that's not something I can do.

Q. I'm asking you what your understanding is. If you have no understanding, you can state -- state so.

A. If somebody's sending me a -- a piece of literature to review, they obviously want my opinion on

Q. So you believe Ms. Walsh sends these to you for your opinion?

A. I don't know. It could be -- it could be for an opinion. It could be for entertainment. It could be by accident. I don't know.

Q. Thank you. You testified earlier that you've known Tara for quite a while, since high school. Are you aware that Ms. Walsh sought emancipation from her parents as a teenager?

MR. MOORE: Objection. Relevance and privacy. What's the point?

MS. LLAGUNO: We're able to conduct discovery into her mental --

MR. MOORE: No, you're not.

MS. LLAGUNO: Yes, we are.

MR. MOORE: You're absolutely not able to do that.

MS. WALSH: An emancipation isn't a mental for the record, and we're talking about when I was in high school. And I'm --

MR. MOORE: Yeah.

MS. WALSH: -- 36 years old.

MR. MOORE: This is --

MS. WALSH: So two --

MR. MOORE: -- way off --

MS. WALSH: -- decades.

MR. MOORE: -- out of bounds. Way out of --

MS. WALSH: Two decades.

MR. MOORE: -- bounds, Counsel. Instruct him to answer. You can bring a motion.

MS. LLAGUNO: Okay. I'd like to note that they're both instructing the deponent not to answer.

Q. Has Ms. Walsh ever spoken to you about a history of abuse in her household?

MR. MOORE: Same objection.

THE DEPONENT: Not that I recall.

MR. MOORE: Instruct him not to answer.

Q. Did Tara ever send you videotapes -- or, sorry, did Tara ever -- scratch that. Did Tara ever send you video recordings of Steve Russell?

A. No.

Q. Thank you. Did Tara communicate with you her belief that Steve had -- was crazy?

A. Yeah. I think towards -- I -- I don't know what -- what point of the relationship, but at some point, she believed that he started to evidence or show very strange behavior.

MR. MOORE: Exactly. So you -- do you know anything about the -- the evidence

MS. LLAGUNO: Mr. Moore, can you please stop these insults? Will you let me continue my --

MR. MOORE: Well, I mean, look -- look, man, is just --

MS. LLAGUNO: You can lay --

MR. MOORE: -- this is, like, basic stuff. This is, like, you know, Law School 101, you know, first year. Come on, man. You don't get into character. Criminal cases, you can get into character if it's put at issue. I need to read the evidence code to you, I will, but, you know, let's get something that's specific, concrete, an example of something that he -- he witnessed. And then he can give his -- his personal knowledge and -- of observation of that incident.

MS. LLAGUNO: Mr. Moore --

MS. WALSH: It's not -- you might as well just you might as well just start interviewing me and Frank if this is where the questions are or the people that are recording the deposition because that's essentially what you're doing. I mean, you're just literally throwing things at the ceiling.

MS. LLAGUNO: That is --

MS. WALSH: Maybe you should ask somebody to come in and ask them the questions.

MS. LLAGUNO: This is how discovery is We're entitled to conduct discovery until --

MS. WALSH: You can't just -- you can't conduct discovery and just ask people what they had for lunch and what they thought about pop music five years ago. That's essentially what you're doing. It literally has nothing do with -- with your case. It's --

MS. LLAGUNO: Ms. Walsh, that's exactly what discovery is. So are -- you can either concisely lay out your objection for the record or --

MS. WALSH: I concisely lay out my objection to your questions that I assume are going to be moving like this. It's a privacy concern. It's not relevant to the case. It's repetitive. It's redundant. It's accusatory. It's harassment. It's ambiguous. It's leading. It's completely pointless, so I'm not going to say anything else.

MS. LLAGUNO: Are you instructing him not to answer or are you laying your objection?

MR. MOORE: I'm laying my objection. I'm -- I'm asking for an offer of proof.

MS. WALSH: I'm objecting as well.

MR. MOORE: You know what an offer of proof is; right?

MS. LLAGUNO: Mr. Moore, if you insult me on the record one more time, we'll end the deposition and I will compel Mr. Gavish to appear a second time and seek sanctions.

MR. MOORE: No, you won't. You won't get an order for it, so -- so why don't you give me an offer of proof as to why this is relevant?

MS. LLAGUNO: Ms. Walsh, are you done with your speaking objections? This is -- I've repeated numerous times you can't go on --

MS. WALSH: Are you done --

MR. MOORE: You know what --

MS. WALSH: -- harassing me --

MR. MOORE: -- just move on. Get --

MS. WALSH: -- and my --

MR. MOORE: Get done with the --

MS. WALSH: -- my friend?

MR. MOORE: Get done with the deposition because you're -- you're just now wasting --

MS. LLAGUNO: No.

MR. MOORE: -- time.

MS. LLAGUNO: No, Mr. Moore. You've been -- you've been obstructing my deposition.

MR. MOORE: Move on. Move on. Ask a question.

MS. LLAGUNO: Every step of the way, you've been obstructing my --

MR. MOORE: Ask a question.

MS. LLAGUNO: Speak to me like that again, I'm going to seek sanctions against you. That's –

MR. MOORE: Ask a question.

MS. LLAGUNO: Let me state for the record that I am ending this deposition based on counsel's -- both counsel and defendant's conduct. I will –

MR. MOORE: Ask a question. He's here. He's ready to answer.

MS. LLAGUNO: I have --

MR. MOORE: Give him a question. Quit fighting over this ridiculousness. Ask him valid question.

MS. LLAGUNO: I've already laid out what I'm going to do. I'm ending this deposition.

MR. MOORE: That's your choice. He's here ready to ask -- answer questions. But they got to be germane. They got to be material and not just the character --

MS. LLAGUNO: If you --

MR. MOORE: -- assassinations, so --

MS. LLAGUNO: You aren't the -- you aren't the one --

MR. MOORE: -- get with it.

MS. LLAGUNO: -- to decide whether it's Mr. Moore.

MR. MOORE: Get with it. Ask a question.

MS. WALSH: I can tell you right now there's no judge in New York State that's going to sign an order for him to give a second -- second deposition. No judge in York State. A, because I will get him a lawyer and, B, because there's no reason to get him to give a subpoena.

MR. MOORE: Yeah. And -- and --

MS. WALSH: So you can make those threats, but this is your last chance, Joy.

MR. MOORE: Tara --

MS. WALSH: Okay?

MR. MOORE: -- let's -- let's just let her ask a question and proceed and end this deposition.

MS. LLAGUNO: No. Thank you so much. I agree, Tara. Court Reporter, we are ending this deposition. Did you have any follow-up questions, Mr. Moore?

MR. MOORE: No. I'm demanding that you finish this deposition.

MS. LLAGUNO: Ms. Walsh, did you have any up questions?

MS. WALSH: I demand that you finish the deposition. Stop wasting his time because he's a victim here.

MS. LLAGUNO: So neither of you have any follow- up questions; am I correct?

MS. WALSH: I have a follow-up --

MR. MOORE: I do.

MS. WALSH: -- question.

MR. MOORE: I --

MS. WALSH: Why --

MR. MOORE: Yeah, I do.

MS. WALSH: -- are you ending the deposition?

MR. MOORE: Are -- are you ending this deposition? Are you done?

MS. LLAGUNO: No. I'm ending it due to your continued obstruction.

MR. MOORE: No. I -- I'm asking whether you're done.

MS. LLAGUNO: Did you not understand what I just said?

MR. MOORE: I'm asking whether you're done with this deposition.

MS. LLAGUNO: No, I am not.

MR. MOORE: I mean, this guy -- this guy's harassing her. You know it. So let's just finish this deposition so Matan doesn't have to come back. Get on your questions.

MS. LLAGUNO: Court Reporter, I'm stating for record that I'm ending the deposition due to defendant's conduct and deponent's counsel's conduct. I believe they are obstructing the deposition. Every single question asked, he's laid baseless objections stating that this is trial testimony when this is obviously a deposition. That is my --

MR. MOORE: No. It's -- you -- you -- you are wrong there. You have noticed this for preservation of trial testimony. That's what you've done. So you -- you have to follow the rules of evidence. So let's do it.

MS. LLAGUNO: Please --

MR. MOORE: Get done with the -- with the depo.

MS. LLAGUNO: Please state your -- would – I'm going to end it now. Could you please state your objection? Otherwise, I'm going to end it.

MR. MOORE: That is my objection.

MS. LLAGUNO: Thank you.

MS. WALSH: My objection is that you're just continuing the pattern of harassment and intimidation by not completing this deposition when you've been -- you're -- you're free to ask questions. We're just not asking you to ask inappropriate questions. So you're ending this deposition. We're both telling you you can ask questions. You're ending this, which I interpret as a continuation of harassment and intimidation. So the -- I mean, that's -- that's, frankly, what it is or else you would ask the remaining questions, no?

MS. LLAGUNO: Thank you. Court Reporter, I believe we've made the objections for the record and we can go ahead and end this deposition.

MR. MOORE: That's fine. Mr. Court Reporter, you can now end the deposition.

THE VIDEOGRAPHER: Please stand by. This is the end of the deposition of Matan Gavish. The court reporter will now take the orders for the transcript.

THE REPORTER: At this time, Ms. Llaguno, would you like to order this transcript?

MS. LLAGUNO: Yes, please.

THE REPORTER: Understood. And would you like a copy, sir, Mr. Moore?

MS. LLAGUNO: I think he's gone, so I suppose not.

THE REPORTER: Ah, I see. Okay.

MS. WALSH: I would like a copy. I would like a copy, please.

THE REPORTER: I was going to get -- okay. And Ms. Walsh would like a copy. Okay.

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