Grumpa's Deposition: His family is super-duper honest...except when they are talking about him

The Evidence Apr 26, 2021

This is not Grumpa's first rodeo. The SEC and DOJ indicted his junk bond firm with multiple felony counts of fraud years ago. In addition to the hundreds of millions of dollars in criminal sanctions paid by the firm, Grumpa was personally penalized with an extremely large fine, as well. Up until that time he was known to some as "the best bond trader on Wall Street," only to be revealed as a fraudster and the kind practiced manipulator other trading desks didn't see coming.

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.

Grumpa drops some bombshells, though.

  • He met Dad exactly twice during the three years that Mom and Dad dated. Once on Easter 2016, and then at Evie's birth. That and a few emails and texts and phone calls are all he knows of Dad. Grumpa "didn't form an impression" of the man when they met.
  • He admits to deceiving Dad when he and Grimma helped Mom kidnap Evie. They never "supported" Mom's move to San Francisco, or her return.
  • He STILL keeps Evie and Mom at his home.

In other news, he doesn't think Dad is an abuser. Three years to say that?

He didn't come to San Francisco when Dad begged him and Mom was diagnosed BPD, because it's like a six hour flight, or something. And he took Mom's accusations with "a grain of salt," but, er, helped her kidnap Evie anyway.

The top SF Psych he and Grimma insisted on, recommended by Mom's doctor, is a quack because he shared "private information" in communications to GRUMPA about Mom's illness and Evie's safety.

Everything is "private information." And he knows 'nothing...nothing' about Mom drugging Dad.

More interesting take aways:

  • The subpoenas he ignored for years and delivered by the town Sherrif under Court Order were "harrassment." Harumph, bristle, harumph, and how dare more Court Orders come again, when those before were 'thrown in the trash.'
  • And the ongoing attempts by Dad to get justice and reunite with his daughter? Well, they are indications of Dad's mental instability of course. Why can't he just let Grimma and Grampa keep and raise Evie? Doesn't he get they are helping and the bestest?
  • Mom's an adult, she can make her own decisions. She buys her own food. She is free to move out, totally free. Evie, 'precious my precious,' not so much.

Grumpa tells you exactly the kind of family he plays patriarch to. He's in charge. He's got this.  He and Grimma would never abandon a baby in need... babies taste best.

Stephen Walsh April 26, 2021 NDT Assgn # 50631                                    

Stephen Walsh April 26, 2021 NDT Assgn # 50631

THE VIDEOGRAPHER: We are on the record. The time is 12:03 p.m., East Coast Time. The date is April 26, 2021. This is the beginning of the deposition of Stephen Walsh. The case caption is Stephen Russell versus Tara Walsh. Will counsel introduce yourselves and state whom you represent.

MS. LLAGUNO: Good afternoon. My name is Joy Llaguno, and I represent Plaintiff Stephen Russell with the law firm Hook & Hook.

MR. MOORE: Yeah. This is Frank Moore, Law Offices of Frank S. Moore. I'm representing Mr. Walsh for purposes of this deposition only.

THE VIDEOGRAPHER: The court reporter will now swear in the witness. (p.5)  

Q. Okay. Thank you. And have you ever been deposed before, Mr. Walsh?

A. Yes.

Q. How many times?

A. Twice, I believe.

A. Yes.

Q. How many times?

A. Twice, I believe.

Q. Okay. When were those times?

A. I -- I -- I -- I don't recall. It was so long ago. I have no idea.

Q. What was the nature of the lawsuit?

A. Do I have to answer that? I mean, I -- I don't see what -- what connection it has to this case.

Q. It's just general, basic questions we ask at most depositions.

A. I -- I -- I'm not going to answer it.

Before Grumpa was Grumpa he sold ‘junk’ with a bunch of criminals
Before Stephen Walsh of Chappaqua was Grumpa, he sold junk bonds with Michael Milken.

Q. -- review all of the requests for production listed here?

A. They didn't apply. [...]

Q. Okay. And so your position is you did not have any responsive documents in your possession; is that correct?

A. That is correct.

Q. Where did you search for documents?

A. I -- I -- I didn't search for documents because I didn't know that any existed.

Q. How are you able to confirm that nothing existed if you didn't do any searches for documents?

A. What -- what -- I -- I don't understand your question. What would I have searched for? I didn't have emails with Russell. I didn't have text messages with Russell. I didn't create any documents to send to Russell. So what -- what exactly are you implying or asking for?

Q. So sitting here today, you did not search your email for responsive documents; is that accurate?

A. That is correct.

Q. You accepted service of the subpoena for your testimony today in September, and you also accepted subpoenas to Maura Walsh, Brendan Walsh, and Matan Gavish. Did you speak with any of them about the subpoenas?

A: No

Q. Did you provide them with the subpoenas you accepted --

A. No.

Q. Brienne has also written about her and the rest of your family receiving subpoenas in this litigation and that you screamed at her for responding to the subpoena and that she should just throw out the paperwork and ignore the subpoena; do you recall this?

A. No.

Q. Were you angry with Brienne for suggesting at any time that she might respond-

A. No.

Q. -- to a subpoena --

A. No

Q. -- from Steve Russell?

A. No, no.

Q. Did you tell Brienne that she should throw out any paperwork pertaining to this proceeding?

A. I have no recollection of doing that, no.

Q. Did you tell her husband, Caleb, the same thing?

A. I have no recollection, no.

Grumpa throws subpoenas into the trash; Rages at Aunt Brie to do the same
“They wanted to have a quorum so that they could scream at us for betraying the family. My family called me multiple times to scream at me that I didn’t know what I was talking about, I could just throw out the paperwork, and ignore the subpoena.”

Q. Okay. So during this deposition, you're not allowed to receive any off-screen guidance or instruction. And I'm going to trust that you're not going to do that. Is that agreed?

A. Agreed. Is Stephen Russell participating? Is he in your office, by any chance?

Q. No. It's just me in the room.

A. So he's not -- he's not tuned in anywhere?

Q. No, I don't believe so. He may join in later, but currently --

A. Well, I -- I think it -- I think that should be clear.

Q. Okay. I will -- you will --

MR. MOORE: Yeah --

BY MS. LLAGUNO: Q. -- you will know when -- if he comes on. He's not on --

A. I -- I'm sure he's on right now, but whatever.

THE REPORTER: Stop. Please -- please do speak one at a time, or the record won't be clear. Please restate your statement you were in the middle of, Ms. Llaguno. Thank you.

MS. LLAGUNO: Thank you. I was just telling Mr. Moore, reminding him, I let you finish your speaking objection even -- although it was improper. Please let me finish my statements before interrupting me, as the court reporter has pointed out. You continue to do that. I'd really appreciate it if you refrain from doing that for the remainder of this deposition.

MR. MOORE: I'm not going to argue with you, so stop arguing.

MS. LLAGUNO: The court reporter pointed it out, Mr. Moore. But thank you.

Mr. Frank Moore

Q. Okay. You mentioned that Tara Walsh and your granddaughter, Evie, are living with you. How long have they been living there?

A. Since, roughly, June of 2018 -- no, since June of 2018, not roughly -- early June. I don't know the exact date. But ...

Q. And from June of 2018, they lived with you consistently?

A. That is correct.

Q. Does Tara pay you any rent?

A. She does not.

Q. Does she help with any house expenses such as groceries?

A. She buys her own groceries.

Q. Do you talk about this legal proceeding with Tara Walsh?

A. We have -- yeah, I mean, we -- we -- of course we talk about the legal cases because they seem to be numerous and ongoing and forever and because we have strange people knocking on our doors at all hours of the night. We have police here. We've had a sheriff with a gun, who I didn't know was a sheriff, knocking on our back door. So there's -- yes. Do we talk about it? Yes because it's constant and it's -- and they've tormented our family for three years. And Russell has knowingly done this, and -- and that's -- so do we talk about the case? It's impossible not to talk about the case.

Q. And do you know if Tara Walsh gave Steve Russell Seroquel in New York?

A. Absolutely not.

Q. And do you know if Tara Walsh gave Steve Russell Seroquel in San Francisco?

A. No. Absolutely not. [...]

Q. Do you know if Tara Walsh was able to get access to lithium from her mother, Maura Walsh?

A. Absolutely not. I -- it -- I -- I don't recall ever seeing lithium in -- in our household. [...]

Q. Do you have an understanding of why Tara Walsh would drug Stephen Russell?

A. No.

MR. MOORE: Assumes facts not in evidence.

BY MS. LLAGUNO: Q. You can respond, Mr. Walsh.

A. I do not, no.

Q. Has Tara Walsh ever told you that she drugged Stephen Russell because she wanted him to go to sleep?

A. No.

Q. Do you have any knowledge of Tara Russell-- I'm sorry. Scratch that. Do you have any knowledge of Tara Walsh explaining that she drugged Stephen Russell because of self-defense?

A. No. Who -- what -- where -- where are you reading from? You're not reading for -- are you reading from a screen, or are you being fed these questions as we speak

Q. I'm sorry. What was that?

A. You appear to be looking at something when you -- when you ask the questions. Are you being fed these questions from another source like Stephen Russell, or are these questions you have prepared? Because it looks to me as if you're reading the questions before you ask me the questions.

Q. I do have an outline of categories that I prepared of questioning for you. No one is feeding me questions live, if that's your question.

A. Yeah. That is my question.

Q. So you do not have an idea from -- or -- or -- sorry. Let me rephrase. You do not have an idea of where Tara got the idea to give Steve Russell prescription drugs --

A. I have --

Q. -- without his knowledge.

A. -- no idea whatsoever. I -- I have no knowledge of Tara Walsh ever drugging Steve Russell in any manner, shape, or form.

MS. LLAGUNO: Mr. Moore, I'm asking him to review the text messages so we can establish that foundation. Please stop interrupting, and please stop with your improper speaking objections. [...]

THE REPORTER: Again, stop. Stop. We can go off the record if you cannot speak one at a time, or the record will not be clear. Please, again --

MR. MOORE: Lacks --

THE REPORTER: -- refrain from speaking over each other.

MR. MOORE: Lacks foundation; assumes facts not in evidence.

THE REPORTER: All right. And Ms. –

MR. MOORE: You have not predicated this.

THE REPORTER: All right. Great. Ms. Llaguno, can you please repeat your question?

‌Q. Mr. Walsh, do you recognize these text messages?

A. No.

Q. These text messages are between you and Steve Russell from Steve Russell's phone.

MR. MOORE: I will object as mischaracterizing the evidence. There's no foundation for it. There's no foundation for this document. You cannot state what it is without a witness actually establishing the foundation of what it is.

MS. LLAGUNO: At deposition, I am able to state what it is and ask him questions about the document.

MR. MOORE: Again -- again, this is a deposition to preserve trial testimony. I'm making objections on foundational basis. This has not been properly authenticated.

MS. LLAGUNO: And again, I've explained to you this is a deposition, and I am able to ask questions about documents regardless of their admissibility at this --

MR. MOORE: But you're -- but you're just wrong on the law. So that's just a problem. You – you seem not to get it in your head that you're wrong on the law.

MS. LLAGUNO: Mr. Moore, again, I'll ask you then state your objections succinctly. You don't have to attack me on the record.

Ms. Joy Llaguno

BY MS. LLAGUNO: Q. Mr. Walsh, would you agree that you and Steve Russell communicated frequently while Tara Walsh was in San Francisco in 2018?

A. Frequently? No, definitely not frequently.

Q. Did you -- but you did communicate; is that correct?

A. Yes, I did. [...]

Q. Okay. And so these text messages, would you agree that Steve gave you routine updates on Tara Walsh during her time in San Francisco in 20- --

A. No. I -- I -- I wouldn't say that. No. No. I -- I think there were times of crisis. And you know -- and -- and that's when he would communicate, when he believed there was crisis. But you know, I was also communicating with Tara, and she was telling me some pretty horrific things about Russell. So I -- I -- I -- I -- quite frankly, I – I took both sides with a grain of salt. I wasn't sure what was accurate and what was not accurate. But I certainly didn't take Stephen Russell's correspondences as -- as factual or accurate either.

Q. And did you ever tell that to Stephen Russell?

A. No.

Grimma recommends emergency psychiatric care for Mom
Mom texts friend that she is suffering from postpartum psychosis. Grimma and Dad are getting her help.

Q. So I am going to point you to this text message where it says you state, "Excellent. Thank you Steve, we appreciate your assistance and understanding. And thank you for the timely updates."

A. Yes.

Q. Would you say you were not being genuine when you thanked Steve Russell for the timely updates then?

A. I would say –

MR. MOORE: Objection --

A. -- I -- I would be less than 100 percent genuine, yes."

Q. And you stated that you also took Tara Walsh's statements during this time with a grain of salt. What was your reason for doing so?

A. Well, Tara had, you know, against our wishes, gone out to San Francisco even after we had witnessed, you know, the situation with Stephen Russell. So I was -- you know, we -- we -- we were disappointed and -- and angry with her for -- for going out there in the first place. So I wasn't going to allow her to play the victim by telling me that, you know, this or that was happening. So I -- I -- I -- I -- I didn't necessarily pay a lot of attention to -- to that stuff either. I -- I started to pay more attention when things seemed to get worse.

Q. And do you believe Tara Walsh plays the victim regularly?

A. No, no. But I think people, like, on occasion, make bad decisions and then try to justify them.

BY MS. LLAGUNO: Q. Sorry, Mr. Walsh. I don't want to be rude. But for the court reporter's sake, just try to let me finish the -- until the end of the state -- the question before you answer. And during this time Tara Walsh was in San Francisco, did you believe Steve Russell was genuinely concerned about Tara Walsh's wellbeing?

A. No.

Q. And why do you think that?

A. Because I -- I don't think Steve Russell is an honest or sincere person.

Q. Do you believe Tara to be an honest and sincere person?

A. Yes.

Q. Although you've stated that you take her statements with a grain of salt; is that accurate?

A. I -- I -- I did say that, and I believe I also explained why I said that.

Q. Tara never discussed with you that she was seeing psychiatric doctors in San Francisco?

A. I -- I -- I don't recall whether she did or not.

Q. Did Tara ever state to you that she had fired her psychiatrist in San Francisco?

A. No.

Q. In these text messages, Steve Russell also states that, "Absent you coming to get her, I don't think it's safe for her to fly or be alone with the  baby right now." Did you believe that to be true?

A. I didn't believe anything he said to be true.

Mom fears doctor recommended in-patient treatment; Grumpa confirms that fear
Mom to Grandma Linda: “I’m not ready to get inpatient treatment. It could be used against me.”

Q. So Tara texted Matan Gavish in February of 2018 that, if she sued Steve for child support, she would "get, like, 2-K a month, which is not enough to live off of." And she said, "I'm better pretending I want to be with him and getting the most while I can than leaving him for good." Did she ever express similar thoughts about Steve Russell to you?

MR. MOORE: Objection --


A. No.

Q. Do you believe Tara was dating Steve Russell for his money?

A. No.

Mom and boyfriend conspire to get money and exact the “sweetest revenge” on Dad
Mom and boyfriend conspire to get money and exact the “sweetest revenge on Dad.
"If I sue him for child support I will get like $2k a month... I'm better off pretending I want to be with him and getting the most while I can - then leaving him for good... I think he will marry me... then I can just divorce him."

Q. Why did you believe Tara wanted to go to San Francisco to be with Steve Russell against your wishes?

A. I'm not really sure, quite frankly. I – I -- I -- I was at a loss for why she wanted to go to San Francisco.

Brienne Walsh's deposition, p. 51, 9/28/2020

Q. Okay. The question -- going back, I asked: Were you speaking with Tara while she was in San Francisco after Evie's birth?

A. Infrequently.

Q. How often would you say you two spoke?

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

Q. Do you know the basis for his statement?

A. I -- I -- I would just say it was, you know, there were -- there were numerous things that Russell was doing that -- that -- that led him -- and -- and -- and I think he was also trying to basically kind of force Gopal to say and do whatever he wanted him to as long as he kept paying him his fees. Russell has a history of using money to get people to do his bidding. And -- and, unfortunately, Joyce (sic), I -- I kind of -- I -- I -- I view you the same way. You are -- you're not doing this case because it's ethically the right thing to do or because your client has a very valid charge and needs to be defended. I believe you're doing this because he's writing checks. And he had no lawyers in -- in San Francisco that would -- he -- he had lawyers, and – and they basically -- I think that they realized they were pushing the ethical line, and -- and -- and that is why you in Pennsylvania are representing Russell in a case in California that has nothing to do with people who are in New York because he couldn't find any other lawyers to do it, thankfully.

[Note: Ms. Llaguno has worked on Dad's case since the beginning. She moved from California to Pennsylvania during that time.]

Q. Did Tara ever share the same to you?

A. There were times -- and -- and I don't have a very full recollection -- where she would just call and -- you know, and say that things were pretty crazy out there. And you know, again, I would say it was a decision you made to go out there that we didn't support, and -- and we emphasized that again and again. And we also emphasized that, you know, if -- if the baby, if she needed to -- to come back, that we would -- you know, we would provide a safe haven and -- and atmosphere for -- for the baby. We were very concerned about the baby.

Q. So would it be fair to say you encouraged Tara Walsh to return to New York with the baby?

A. I -- I -- no. It -- it wouldn't be fair to say that. Tara is an adult. She made her own decision. She made her own decision to go to San Francisco. And when she returned, for the record, it was her decision. She's an adult. We could not force her to do anything. She -- you know, she knows the type of people we are. She knows the type of family we are. And we would never turn our backs on someone in distress, particularly an infant.

Q. And so did you encourage Tara to return with Evie to New York from San Francisco?

A. I -- I -- I did not.

Q. Steve Russell asked you to, quote, support me in getting her into a facility or fly out here and talk/meet with everyone before deciding to help her back to New York if that ends up being what's best. Could you read your response to that text message?

A. Where is it, exactly?

Q. This first column. I can zoom in.

A. "I will do my best"?

Q. Yes.

A. Yeah, okay.

Q. Would it -- would it be fair to say that Steve Russell was depending on you to work with him to get the help Tara needed?

MR. MOORE: Objection.

A. No.

Q. During this time in early June, were you speaking to Tara about leaving?

A. I -- I really don't recall. I don't recall.

Q. And -- sorry. This same text message, you state that -- you texted Steve Russell, "Hopefully some solutions exist." What did you mean by that?

A. I -- I don't know. I don't know. Again, in -- in many of these interactions and -- and correspondences, I would -- I would -- I would humor him because I -- I -- you know, I viewed him as unstable and dangerous.

Q. So you -- with your responses, you wouldn't be completely genuine so as to humor him; is that --

MR. MOORE: Object -- objection; misstates the testimony; argumentative.

BY MS. LLAGUNO: Q. You can respond, Mr. Walsh.

A. No response.

Q. You do not want to respond to that question?

A. That is correct.

Grumpa worked with Dad and Mom's Psychiatrist to get Mom back home in SF after she disappeared with Evie during a psychotic episode.

MS. LLAGUNO: Mr. Moore, please do not coach the witness. I'm asking --

MR. MOORE: I'm not coaching. I'm instructing him not to answer. He's already decided not to answer. So move on.

MS. LLAGUNO: So you are instructing him not to answer that question? I just wanted to clarify.

MR. MOORE: He -- he -- I -- well, I will clarify that he himself decided not to answer the question, and -- and for -- there was a good basis for it. When you tried to put words in his mouth that misstate what he testified to, that's a problem. So he's a very competent witness here, and he can make these decisions himself. But I tend to agree with his -- the basis for which he's refusing to answer your argumentative question.

MS. LLAGUNO: Mr. Moore, he was actually in the middle of responding before you interrupted him --

MR. MOORE: No, you're wrong. Just move on.


MS. LLAGUNO: Again, Mr. Moore --

THE DEPONENT: -- I am making the decision myself not to respond. It has nothing to do --


THE DEPONENT: -- with Frank.

MS. LLAGUNO: Got it. Mr. Moore, again, can you let me finish my statement before you interrupt? [...]

BY MS. LLAGUNO: Q. So you do not remember, Mr. Walsh, the solutions you were referring to in this text message?

A. No.

Q. Do you remember solutions to what exactly you're referring to?

A. No.

Q. And in this same text message string, Steve Russell texted you his belief that, quote, I think the first order of business is simply to fix the difficult living situation and get Tara to agree to allow you to act as her advocate. I am happy to be very flexible in where she lives, nanny, type of care, et cetera, end quote. Could you read your response to this text message?

A. "I agree -- let me know how and when I need to be involved." [...]

Q. So when you said you were in agreement that you should allow to act as her advocate, would you say you were being genuine in your response to that text message, or were you again humoring him?

A. I was not -- I would say I was not entirely genuine. And again, I -- I was trying to defray what -- what I viewed as a caustic situation.

Q. So was your understanding of why Steve Russell believed Tara needed an advocate was because Tara was going through mental health episodes?

A. No.

Q. So what is your understanding of why Steve Russell wanted you to be involved as an advocate for Tara?

A. I have no idea.

Q. And do you believe Tara to have mental health issues?

A. I don't. I -- like I said, I -- I -- I'm -- I -- I -- I have -- I do not believe that, and I could not diagnose her.

Q. And you do not know if Tara is seeking mental health treatment for mental health issues; is that --

A. No. That's her business. It's her business, not mine.

Q. So you do -- you don't know.

A. I don't know.

MS. LLAGUNO: Mr. Moore, you are allowed t0 to make your objections at deposition. But I please  --

MR. MOORE: And I just did. So you don't need to argue with me about it.

THE REPORTER: Counsel, again, I understand you are attempting to do this. But please speak one at a time, or your record will not be clear. So please -- please restate your statement, Ms. Llaguno. My apologies.

MS. LLAGUNO: Thank you, Monica. Mr. Moore, again, while I am speaking, I give you the chance to do your improper speaking objections and do not interrupt you. Please stop interrupting me, and let me finish my statement. I am allowed you to make your objection, albeit improper. I'd like to ask you again to refrain from these long winded speaking objections. You're allowed to make very succinct objections to my questions, but you cannot take up my deposition time to make these long, improper speaking objections, going in about the procedural history of another case that's not in front of us here.

MR. MOORE: I am going to make my record, and I will do it as -- on your dime as long as I want. You are improperly using and abusing the court system, and the record will reflect that that is such the case. It will be potentially before a court, and that is why I'm making my record. Thank you.

MS. LLAGUNO: You can make your record with a succinct objection and not --

MR. MOORE: No. I have to explain your improper conduct.

MS. LLAGUNO: Mr. Moore, again, you're interrupting me.

MR. MOORE: Why do you insist on arguing with me? And just get to the task at hand, and finish this deposition.

MS. LLAGUNO: The court has noted four or five times now that you are the one interrupting me. I have not once interrupted you in the middle of one of your statements. So I want to make that clear.

MR. MOORE: There's no court in session, so I don't know what you're talking about. But just move on.

Q. So you wrote that quote, "She's seeing doctors and maintaining a healthy lifestyle;" is that correct?

A. Yeah. Yeah. I -- I did write that. Absolutely.

Q. And you were referring to psychiatrists; is that correct?

A. I'm not sure I was. I'm not sure I was. [...]

A. But I don't know the specific doctors I was referring to.

Q. So you do believe around this time in July of 2018 that Tara was seeking mental health treatment; is that correct?

A. Yeah. I -- I -- I -- I guess it's correct. But yeah, I mean, again, I'm not -- I'm --I'm not fully recollecting exactly what that would be or who it was with.

Q. Do you know if Tara was seeking --

A. Certainly -- certainly didn't imply that she needed to be institutionalized, or anything like that.

Q. Do you know if Tara was seeking for her – her borderline personality disorder

A. That -- that's kind of a silly question because I don't know if she -- I don't know that she was ever diagnosed with borderline personality deficit, or whatever you call it.

Q. Did you speak with Steve Russell's security personnel?

A. I did, yes.

Q. What were the names of the guards?

A. I don't remember, and -- and I wouldn't – I wouldn't -- if I did, I wouldn't give you the names. And -- and, you know, of anything they told me in confidence I -- I wouldn't share with you.

Q. Did any of the security guards inform you that they reported to Steve Russell that they had, indeed, found a listening device in Steve Russell's walls?

A. Absolutely not.

Q. If they had reported that to you, would that change your understanding of the situation?

MR. MOORE: Incomplete hypothetical; misstates the record; lacks foundation.

BY MS. LLAGUNO: Q. You can respond, Mr. Walsh.

A. I agree with Frank.

Q. I don't believe -- Frank can state his objections. But unless he directs you not to respond, you're able to respond.


MS. LLAGUNO: -- proper objection. Again, please let me finish my statement before interrupting me. Just please uphold the rules of civility at this deposition. Because the court reporter did not get my last statement due to your interruption, I'd like to remind you again to refrain from improper speaking objections. Please --

MR. MOORE: Stop arguing.

MS. LLAGUNO: Mr. Moore, please keep your objections succinct, and refrain from improper coaching and speaking objections. Thank you.

MR. MOORE: Stop arguing.

MS. LLAGUNO: Would you like to say that one more time?

MR. MOORE: Stop arguing.

THE REPORTER: And counsel, when we are at a good stopping point, could we go off the record? We've been going for an hour and 40 minutes on the record.

MS. LLAGUNO: Okay. We can take a break. Let me - yeah, we can. That's fine. We can take a break right now.

THE REPORTER: Okay – THE VIDEOGRAPHER: Okay. The time is 1:39 p.m., and we are off the record. (WHEREUPON, a recess was taken.)

THE VIDEOGRAPHER: The time is 1:53 p.m., and we are on the record.

BY MS. LLAGUNO: Q. Mr. Walsh, I'm going to have the court reporter repeat the last question that was asked.

THE REPORTER: And the last question that was asked was, "If they had reported that to you, would that change your understanding of the situation?

‌‌‌‌A. Not necessarily, no.

Q. And do you have personal knowledge --

A. I don't.

Q. -- of --

A. I don't. Has he joined us on the call, by the way, Joy?

Q. No. No, Mr. Walsh, he has not.

A. Okay. And you -- you stated that you will let us all know if he does.

Q. Yes, I will. I believe we'll be able to see if he joins as well.

A. Okay.

Q. So you've never discussed with Tara about Steve Russell being conned by his security team.

A. No, not specifically. And -- and if it – if we did discuss it -- and -- and I'm trying to recall -- it would have been empathetically whereas she was concerned that they were taking advantage of him. But I -- I don't remember specifics, no.

Q. Did you help Tara with her move back to New York from San Francisco?

A. No.

Q. Were you aware there was a restraining order preventing either her or Steve Russell from removing Evie from the State of California without each other's written consent?

A. No.

Q. And you do not know what the serious acts are that he's referring to in this email?

A. I have no idea. You know, we -- we live in Chappaqua, and Hillary Clinton lives in Chappaqua. And as you know from QAnon, which I imagine that Russell is a big fan of, you know, she kills babies and eats them. So maybe Steve was concerned that her being -- Evie being in Chappaqua, she could be subject to the same cobble of, you know, these people. So now -- now I can sort of understand his -- his concern more.

MR. MOORE: Yeah. I was going to say the whole --


A. (Audio disruption) yourself, Joy, because conspiracy theories seem to run through this testimony.

MR. MOORE: Exactly. It sounded lik QAnon --


MR. MOORE: -- as a -- as a basis of the question, it sounds QAnon-ish. Can -- do you have more? I mean, let – this is real far afield from what the case is about. So where -- where are we going with this?

MS. LLAGUNO: Yes. Mr. Moore, again, I'd like to remind you to stop with your improper speaking objections and insults on the record --

MR. MOORE: I'm -- I'm -- you know, you're -- you're -- you -- it sounds like you're out of questions. Do you have something for this witness that is relevant?

MS. LLAGUNO: Yes. We -- our position is it's all relevant.

MR. MOORE: No, it's not. You know it's not. So let -- let's get to the task at hand of what the case --

THE DEPONENT: Yeah. Let's --

MR. MOORE: -- is about.


A. Let's -- ask me some real questions, Joy, and -- and let's get -- you know, if there's answers I can provide that have anything to do with the case, I will do that. But if you're just going to keep going around in circles and make ridiculous presumptions or ask me to answer questions that I couldn't possibly answer, let's -- let's finish it up.

Q. In this email, Steve Russell emailed to you that, "She's threatened suicide on multiple occasions, has unpredictable reactions to her meds and alcohol, and recently suffered a full-blown delusion that led to an unavoidable accident with Evie."

A. I -- I didn't --

Q. Has --

A. -- I --

MR. MOORE: That's not -- there's – there's not --


A. -- didn't --

MR. MOORE: -- a question pending -- not a question pending. Don't -- no -- no answer is required.

THE REPORTER: Stop. Please -- please do speak one at a time. I would like to stipulate for the record that, if you do not speak one at a time, the record will reflect as such, will not be clear. So before we move forward, do you agree that the record --

MR. MOORE: You know --

THE REPORTER: -- will not be clear if you do not speak one at a time --

MR. MOORE: We -- we know this. Court Reporter, we know this. We heard this many times from you, and you -- you're really starting to get on my nerves, okay?

THE REPORTER: All right. We can go --

MR. MOORE: So you know --

THE REPORTER: -- we can go off the record at this time --

MR. MOORE: No. You -- you can do your job and stop interrupting us.

THE REPORTER: It is impossible to keep a clear record if you keep interrupting. So before we move forward, I would like to stipulate that the record will not be clear if you keep doing that --


THE REPORTER: -- this deposition. So --

MR. MOORE: We --

THE REPORTER: -- before we move forward - -

MR. MOORE: -- we -- we might --

THE REPORTER: -- I'd like to stipulate --

MR. MOORE: -- get a better court reporter because, you know, I --

MS. LLAGUNO: Mr. Moore, please --

MR. MOORE: -- this stuff happens all the time in --

MS. LLAGUNO: -- please don't insult --

MR. MOORE: -- depositions.

MS. LLAGUNO: -- the court reporter. The last court reporter made the same comment saying she cannot get a clear record because of your interruptions. So please stop interrupting when someone is speaking.

MR. MOORE: You -- you --

MS. LLAGUNO: Mr. Walsh --

MR. MOORE: -- need to ask --

MS. LLAGUNO: -- was speaking --

MR. MOORE: -- ask a question --

MS. LLAGUNO: -- Mr. Walsh --

MR. MOORE: -- that's reasonable.

MS. LLAGUNO: I'm speaking. Please wait until I'm finished speaking, and then you can speak. That is how a deposition works. One person speaks at a time. Thank you, Mr. Moore. Mr. Walsh was speaking, and you interrupted what he was testifying. So I'd appreciate if you don't do that again. You have to let your client speak. You cannot coach him to not speak.

MR. MOORE: I'm not coaching. I am stating things for the record. This Zoom process is not very conducive because there's not enough delay between your question, his answer, my ability to get an objection in before he answers. So if the court reporter can't keep up with it, then everyone's going to have to slow down and give some pause between so I can get my objections in. The court reporter doesn't seem to have the capacity as what -- what I've seen in California to be able to do this type of work. But nevertheless, I think we need to get back on track what the case is about. And if you would ask -- ask him questions about that, then we can get done.

MS. LLAGUNO: Mr. Moore, please refrain from insulting the court reporter, or anyone else on this deposition for that matter.Thank you.

Q. Since Tara turned 18, did you ever have power of attorney over her?

MR. MOORE: Objection; privacy.

A. Not going to answer that.


Q. And I just wanted to clarify for the record you do -- you're refusing to respond to the question of if you've ever had power of attorney over Tara; is that correct?

A. Yes.

Q. Do you know when Tara and Steve began dating?

A. I have no idea.

Q. Do you know how Tara met Steve Russell?

A. No idea.

Q. Prior to Tara being in San Francisco, did you ever speak with Tara regarding Steve Russell?

A. He came to our house one time for Thanksgiving. I don't -- I don't know when it was. If it was before that, after that, I really don't know.

Q. On --

A. First time I met him, I didn't know anything about him.

Q. What was your impression when you met him at Thanksgiving?

A. I really tried to like him. He -- he seemed to be friendly. But we didn't have enough of an engagement to -- for me to really draw any kind of opinion.

‌Q. And did you say the first time you met Steve Russell was at Thanksgiving at your house?

A. To the best of my recollection, yes.

Q. And to the best of your recollection, how many times have you met Steve Russell in person?

A. Outside of that, I met him at the hospital and then in Brooklyn at the apartment. So it's – it's less than, you know, maybe three or four, at most.

Q. Did Tara ever tell you that Steve had hurt her or abused her prior to giving birth to Evie?

A. I really don't recall. I -- I -- I didn't -- I -- I didn't have much knowledge of the guy one way or the other until Evie -- until she became pregnant with Evie.

Q. So after became -- she became pregnant with Evie, did Tara ever tell you that Steve had hurt her or physically abused her?

A. I -- I don't remember specifics, but I --I seem to think that she did mention it one time when she was in San Francisco.

Q. What did she say?

A. I -- I don't -- I'm -- I'm -- I'm going to say I -- I -- I -- I really don't know. I really don't know.

Q. Did you do anything about it when she did tell you that?

A. If I had felt that she was physically abused, I probably would have done something, but I don't -- I would have told Tara to get out of the situation as fast as should could. So -- but – but, no, I have no -- no recollection.

Q. Did -- did you ever witness any concerning behavior from Mr. Russell prior to Evie's birth?

A. I didn't -- I didn't meet the guy prior to Evie's birth other than that one time.

Q. So other than those two times you stated that Mr. Russell was acting bizarrely, was there any other concerning behavior from Mr. --

A. Yes.

Q. -- Russell?


Q. And so this was according to what Tara told you, correct?

A. Yes. It's according to what Tara told me.

Q. You never personally witnessed that.

A. I didn't, no, because I didn't see the guy. And quite frankly, I had no interest in going to Brooklyn to see the guy.

‌Q. And so Tara never told you that Mr. Russell physically hurt or assaulted her at any time; is that accurate?

A. I -- I don't know. I don't know if she ever mentioned it. I've never witnessed it, no.

Q. Do you have an understanding of why Tara Walsh would drug Stephen Russell?

A. No.

MR. MOORE: Assumes facts not in evidence.

BY MS. LLAGUNO: Q. You can respond, Mr. Walsh.

A. I do not, no.

Q. Has Tara Walsh ever told you that she drugged Stephen Russell because she wanted him to go to sleep?

A. No.

Q: Do you have any knowledge of Tara Walsh explaining that she drugged Stephen Russell because of self-defense?

A. No. Who -- what -- where -- where are you reading from? You're not reading for -- are you reading from a screen, or are you being fed these questions as we speak

Q. I'm sorry. What was that?

A. You appear to be looking at something when you -- when you ask the questions. Are you being fed these questions from another source like Stephen Russell, or are these questions you have prepared? Because it looks to me as if you're reading the questions before you ask me the questions.

Q. I do have an outline of categories that I prepared of questioning for you. No one is feeding me questions live, if that's your question.

A. Yeah. That is my question.

Q. So you do not have an idea from -- or –  or -- sorry. Let me rephrase.You do not have an idea of where Tara got the idea to give Steve Russell prescription drugs -

A. I have --

Q. -- without his knowledge.

A. -- no idea whatsoever. I -- I have no knowledge of Tara Walsh ever drugging Steve Russell in any manner, shape, or form.

Q. I am going to now continue with my questions --

MR. MOORE: Here, here.

BY MS. LLAGUNO: Q. -- appreciate it if we stop getting on these tangents, we don't take time at the depositio --

MR. MOORE: You're -- you're on the tangent, counsel.


A. You've been on one continuous tangent. You just -- it's the same nonsense you keep spinning over and over again, okay? If you want to stick to the facts of the case, Steve Russell is a man with serious mental instability. And you are one of the few lawyers in the world that would take payment from this guy to basically allow him to run rampant and -- and -- and ruin people's lives, okay? So that's the basis of the case. There is no other basis.

Q. So back to my question, has Tara ever lashed out at --

A. No.

Q. -- other --

A. No. Never. She's been a perfect saint her entire life. She's a model citizen. I've never met a more genuine, wonderful, beautiful woman in my life.

Q. And yet you take what she says with a grain of salt; is that correct?

A. No. I believe everything she says. She's a very, very straight-forward person.

A. You already asked me that. He's a friend of hers. Did Steve forget to -- did he -- that he already asked that?

MR. MOORE: Yeah. You know, I mean, we – we now are treading over --

MS. LLAGUNO: Mr. Moore –

MR. MOORE: -- asked and answered questions. It seems like you've run out of questions. Can you ask a question that is not a repetitive question? This is --

MS. LLAGUNO: Can you stop?

MR. MOORE: -- really off track here.

MS. LLAGUNO: Mr. Moore, it is for the judge to decide what isn't and what is off track. You can object --

MR. MOORE: I'm telling you what's off track because I can -- I can determine whether or not you're just harassing a witness. And that's what this appears to be. So if you're going to continue down this road --

MS. LLAGUNO: State your objection --

MR. MOORE: That's my objection. You're harassing and you're -- because you're asking questions you already got answers to. If you've run out of questions -- it's becoming very obvious you have -- we should end this. If you have something additional that's relevant, ask it.

MS. LLAGUNO: And this is all relevant. And I'm continuing with my --

THE DEPONENT: It's not all relevant. Let's -- let's wrap it up because this is -- it's just more of the same nonsense. We're going around in circles. And -- and I -- I don't believe for a second that Steve Russell is not involved here. (p.165)

Q. While Steve was at the hospital, how was he acting?

A. Bizarre.

Q. How, specifically?

A. The security guards were there. He had security guards with him at the birth, ok?

Q. Did Tara tell you that Steve believed the apartment had broken -- been broken into?

A. Yes.

Q. Did Tara tell you --

A. No --

Q. -- that --

A. And -- and Steve -- Steve told me that himself.

Q. Did Tara tell you that Steve and his security personnel had set safety triggers to let him know if somebody had entered the apartment without their consent?

A. Tara didn't tell me that, no.

Q. Did Tara tell you that, in fact, Matan Gavish had been in -- in the apartment without Steve's knowledge and triggered the safety triggers?

A. No. I had no knowledge of that whatsoever.

Q. So if Steve believing that -- seeing that somebody had triggered the safety triggers, that wouldn't change your opinion of -- on why Steve thought he had -- the apartment had been broken into?

MR. MOORE: Assumes facts not in evidence; incomplete hypothetical. You can answer if you have an opinion.‌‌‌‌

A. No. No.

Q. And did you ever see any actual evidence of that happening, or you just base – solely relying on what Tara told you?

A. Joy, I'm going to - - ask you this against because it's clear that you're - - you're communicating with Russell right now. And - - and I wish you'd be honest about that because you turn your eyes and you read the questions. And you - - it – – it – it's – you – you're you're being fed the questions. There's no doubt in my mind.

Q. Okay. Well, I'll represent to you that that's not true. I've prepared my own topics -

A. Okay. Well – well, your - your - your reputation is on the line. And if we discover otherwise, it's – it's going to be – I – I– I think it's going to be an issue. So...

‌ Q. Do you know if anybody in your family went to San Francisco to help Tara?

A. No. Nobody in our family went to San Francisco.

Q. Why not?

A. Why not? San Francisco is a six-hour flight, right, from New York. It's not something you just go and do.

Q. Brienne also produced text messages in which she called Tara a liar. Would you agree that Tara is a liar?

A. No.

Q. Has Tara ever lied to you?

A. No.

Q. Has Tara ever lied about you?

A. No.

Q. Can you recall any times Tara has lied to someone?

A. No.

Q. Do you have the impression that Tara has no qualms about lying?

A. No.

Q. Is lying something Tara does to get what she wants?

A. No.

Q. Tara has stated that being in your home is an unsafe environment for Evie. Do you think that's true?

A. Evie is in a very, very loving environment. She prospers in the environment she's in.

Q. So would you say Tara Walsh stating that your home is unsafe, would you consider that a lie?

A. I would say that it was not a lie. I would say it was -- it was a bad interpretation.

Q. Brienne testified at length about your family and how she and Tara were raised.

MS. LLAGUNO: Where did Mr. Walsh go?

A. Personal question; not going to answer; has nothing to do with the case or anything else.

Q. For example, Brienne testified that she described the environment in which she was raised as emotionally abusive. Do you agree with Brienne's characterization?

A. Absolutely not.

We were abused. Grumpa told us to throw Court Orders in the trash. And other revelations from Aunt Brie’s deposition
It took two years, but the first of the Walsh houshold finally sat for a deposition. Aunt Brie and her husband both spent several hours with attorneys and swore to tell the truth. The couple and faced significant retaliation from Grumpa and Grimma, and as a result. Her father demanded

Q. Do you believe Brienne was lying?

MR. MOORE: You can't -- that's impermissible vouching.

THE DEPONENT: Just it's --

MR. MOORE: This is a -- this is a vouching question. It's not --

A. Yeah. It's --

MR. MOORE: -- appropriate.

A. -- an obnoxious question. It's unprofessional. It's -- it's pathetic, quite frankly. And it's -- you know what? I'd blame you, Joy, if I -- more so if I didn't think you were just reading off a script. So -- but I wish you -- I wish you great success in your career once you dislodge yourself from this guy because you're – you're taking yourself down a bad path here being his -- being his -- you know, his disciple.

Q. Brienne also called her childhood -- or – traumatic --

A. Go ahead. Great. Great. Fantastic.

Q. You disagree with that characterization as well?

A. Yeah. Brienne went to Brown University, and her entire tuition and living expenses were paid for by her abusive parents. Her European vacations were paid for by her abusive parents. She went to one of the best high schools in the country as a result of her abusive parents. So you tell me, okay? You make the – (p.171)

‌Q. Brienne also testified that when she and Tara were teenagers, Tara or her attorney called Child Protective Services on you and Maura Walsh multiple times; is that true?

A. It's ridiculous.

Q. Why was Child Protective Services called?

MR. MOORE: Assumes facts not in evidence.

A. Yeah. It has nothing to do with anything; not answering; personal question; personal information.

Q. Are you refusing to answer if it was true or not?

A. I am, yes.

Excerpted from 8/27/18 Aunt Brie's blog post titled “Someone Wants To Sue Me Over This Blog" from "A Brie Grows in Brooklyn"

Q. Brienne also described a legal proceeding over custody or emancipation of Tara involving Tara and Brienne's aunts. Do you recall this proceeding?

A. Not going to answer that; personal question --

Q. Will you answer --

A. No.

Q. -- will you answer --

A. I will not --

Q. -- who brought --

A. -- answer. I will not answer.

Q. Just to clarify, you're not going to answer anything in regards to -- on emancipation or custody proceeding.

A. That's correct.

Q. Did you remain Tara's --

A. You're --

Q. -- legal guardian?

A. You're going to -- you're going to follow it up with an emancipation question, right? Did I remain? Yes. We were Tara's guardians, yes, through her --

Q. No one else --

A. -- pre-adult life, yes.

Q. So no one else became Tara's legal guardian.

A. Not to my knowledge, no.

CPS called on Grimma and Grumpa over 35 times; An act that’s never been forgiven
The abuse was so extreme that Mom even sued her parents for emancipation as a teenager.

Q. Is Tara currently living at your home willingly?

A. Other than the 12 hours she's kept in shackles in the basement, she can walk around.

Don’t move out! Grimma and Grumpa threaten to sue for custody if Mom and Evie leave
“I told my family and now they have all joined up to say they will take legal action against Steve and I for custody of Evie if we leave.”

Q. Tara told the court that she was living in a cold attic with no heat at your house; is that true?

A. Did -- she didn't mention the bats? Or the wild animals?

Q. Mr. Walsh, please respond to the question. Is that true?

A. Of course not.

Q. So Tara is not living in a cold attic with no heat in your house.

A. Absolutely not.

MS. LLAGUNO: Again, please refrain from your speaking objections, Mr. Moore, and let me continue with my --

MR. MOORE: I'm going to make my record. You can't tell me what to do. So sorry.

‌Q. Do you know if she has ever had any employees?

A. No. I'm not -- I'm not going to answer these questions.

Q. Can you explain the basis for your refusal to answer?

A. Because they have nothing to do with anything that involves this case or -- or with me personally.

Q. We are able to conduct discovery onto Tara's background.

A. I --

MR. MOORE: No, you're not. You're far afield of what this case is about. You're harassing the witness now. So you -- you better get to something that's relevant and germane to your case.

MS. LLAGUNO: So are you directing him not to respond?

MR. MOORE: I'm directing you to stop harassing the witness. That's what I'm directing you to do.

MS. LLAGUNO: Noted. Are you directing him not to respond?

MR. MOORE: I am directing you to stop harassing the witness.

MS. LLAGUNO: And you can state your objection for the record. I'm asking --

MR. MOORE: That's what I just did three times now. So shut up and move on.

BY MS. LLAGUNO: Q. Tara also started a company called Vital Branding; is that right?

A. You know, Joy, it -- the -- we're -- it's the same line of questioning and, you know, about her character and things like that. You're trying to get me to say that she's an awful person who's capable of drugging your -- you know, your -- your esteemed client. And you know, it's -- well, you – you haven't gotten there yet, and you're not going to get there. We're never going to get there. So let's -- unless you have any real questions, let's wrap this up, okay? I'm done answering question after question about absolute nonsense, so questions that have been dictated to you by your client, who has gone out of his way to harass us for years and which you're not part and parcel --

Q. And so just to confirm, you -- you prefer not --

A. -- aiding and abetting. So ...

Q. I'm sorry if I interrupted you. I -- it cut out a bit. I was -- okay. I just -- to clarify for my understanding, you are refusing to answer questions regarding Tara's background.

A. Yeah. I -- at this point, no, I -- I --I'm not refusing. I'm refusing from this point on because I've been asked so many of them. But I -- I -- I did not refuse to answer. I've answered quite a few questions, hundreds of questions from you. So to put it in the -- you know, to -- to -- for -- for purposes of stating that I refuse to answer, the -- the -- that's just not fair, and it's ludicrous. What I'm saying is I'm just tired of answering the same questions over and over and over again that -- that are -- are, I think, designed to get me to say something terrible about Tara, which will then validate all of Steve Russell's, basically, fears, paranoid responses to, and all the other stuff. And it's just -- it's just silly, and -- and -- and we should wrap this up.

MR. MOORE: Yeah. I mean, we've been going on now for, it looks like, almost four hours. And you've really gotten off the deep end and are now into just character assassination, harassing conduct, irrelevant questions, some of them which are repetitive of questions already asked and answered. I have other things to do. I'm going to have to move on and get out of this. So I'd like you to wrap this up and be done with it.

MS. LLAGUNO: Mr. Moore, respectfully, you can't dictate when the deposition --

THE DEPONENT: Yeah. I -- I'm -- I'm going to --

MR. MOORE: I -- I can --

THE DEPONENT: -- I'll -- I'll make that decision, and I'll let the chips fall as they may. And if a judge figures I'm in violation of, you know, refusing to be held hostage for nonsense for hours, I'll leave that up to the judge. So I'm willing -- I'm willing to take my chances. If you have some real questions you want to ask me, ask me. If you want to just maybe get Steve Russell to summarize his most pertinent concerns and have him run them by me right now, we can finish this up.

BY MS. LLAGUNO: Q. Currently, I was just asking about your understanding of what Tara does for a living and her company called Vital Branding. You --

A. I'm not going to answer. I'm not going to answer anything to do with her career. Zero.

‌ MS. LLAGUNO: So I think, Court Reporter, we've been going on for more than an hour now. Can we take a quick, five-minute break?

THE DEPONENT: No. I'm done. I'm done --

MR. MOORE: No. I -- yeah. You -- you – if you're -- if you're -- if you're going to continue, we're -- we're -- we're going to finish now, or we'll give you a few more minutes if you've got some additional questions. But you -- you've running -- kind of run the ship aground at this point.

THE DEPONENT: Yeah. If -- if -- if you have questions, a couple of them, we can wrap it up. But if you go to break, I'm gone.

THE REPORTER: Would you like -- would you like to go off the record at this time?




MR. MOORE: Not -- not unless we're finishing. If we're finishing, let's --


MR. MOORE: -- let's finish. If -- if not, then -- if we're not finishing, she's -- you know, whatever your last questions are, let's wrap it up.

MS. LLAGUNO: I would like to take a five-minute break.

THE VIDEOGRAPHER: Okay. The time is 3:44 p.m., and we are off the record.‌‌2 (WHEREUPON, a recess was taken.)

MS. LLAGUNO: Thank you, Mr. Walsh. I will be ending the deposition for today, but I will be adjourning it based on that there were no documents produced today and reserving my right to continue if we need to do so to get those documents compelled.

MR. MOORE: Yeah. So just so you understand, Mr. Walsh, the -- that only means that you -- you -- you -- you only have to come back if there's a court order from a San Francisco Superior Court.


MR. MOORE: You've met your obligation of the New York order. And so in order to compel you further, she would have to get an order from the San Francisco Superior Court.

THE DEPONENT: Thank you, Frank.

MS. LLAGUNO: And we --

MR. MOORE: You're welcome.

MS. LLAGUNO: -- we disagree --

MR. MOORE: Thank you.

MS. LLAGUNO: -- we'd agree -- disagree with that representation. But the counsel can direct you how he wishes. Frank, did you have any follow-up questions or anything else to add?

MR. MOORE: I have nothing.

THE VIDEOGRAPHER: Okay. This is the end of the deposition of Stephen Walsh. The court reporter will now take the orders for the transcript.

THE REPORTER: All right.

MR. MOORE: Nice meeting you, Stephen --

THE REPORTER: Ms. Llaguno, would you like to order the original of this transcript at this time?

MS. LLAGUNO: Yes. And --


MS. LLAGUNO: -- get a rough draft expedited as well?

THE REPORTER: Yes. I'll just note for the record Mr. Moore has discontinued the call. But he did note off the record that he does not wish to order a copy at this time.

MS. LLAGUNO: Right. Correct. And --


MS. LLAGUNO: -- and -- I'm sorry. Go ahead.

THE REPORTER: Yeah. Oh, no. Sorry. My apologies. For the rough, when -- when do you need that by? (p.186)

Bromide: Video Depositions give you some interesting side-by-side views, as well.

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