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The last page: What’s the word?

The Dude

Q. Okay. Let me go ahead and do something with you I do with a lot of folks who make estimates like that. I’m going to time out 10 seconds on my watch. And you can tell me if you think that’s a good estimate or if it’s a lot more than that or whatever.

A. I might tell you now: I have no idea how long that was. Okay?

Q. Okay. And the reason I ask is this —

A. This thing you’re doing here is —

Q. Well, it’s more important than you think, apparently.

A. It’s not very scientific, dude.


Q. Have you ever run a marathon?

A. Yeah, quite a few.

Q. Have you done Houston?

A. Yeah. My best time was in Houston.

Q. What was that?

A. 2:59, dude.

Alan Turboff, RPR

Houston, Texas


People to know

Q. You say in the email to Mr. Smith, “I have erased this from my hard drive. With the help of Mr. Daniels, I will erase it from my personal hard drive.” Right?

A. That’s what I wrote.

Q. Who is Mr. Daniels?

A. He’s a man from Tennessee who makes Tennessee whiskey.

Q. Other than Jack, do you know any other Mr. Daniels?

A. He is the only Mr. Daniels I know.

Q. In this email, I want to be clear that Mr. Daniels is Jack Daniels; correct?

A. It is.

Q. And that your personal hard drive resides in the space above your neck?

A. It does.

Q. When you say, “I’ve erased this from my hard drive,” do you recall what you were talking about?

A. I don’t recall what I was talking about, and I think that might have to do with Mr. Daniels.

MR. JONES: For the record, I would like to note that this email was sent at 3:37 p.m., Tuesday afternoon.

Camille Macomber, RPR

Walpole, Mass.


Will they ever learn?

Q. Make sure that I finish my question before you start giving your answer so that it makes it easy on our court reporter. Make sure you give an audible answer instead of nodding your head or shaking your head —

A. Okay.

Q. — from side to side, all right?

A. (Nods head affirmatively.)

Marcia Arberman, RPR

Lilburn, Ga.


One way to make a door

Q. Okay. Number four you said was installed in the winter of 2004. Can you describe that door for me?

A. It’s a six-foot wide door. It’s two swinging doors.

Q. Okay. What did they have to do, cut a hole in the building and put it in or what?

A. I hit a patch of ice with the snowplow and made a hole; I drove my tractor through it.

Merissa Racine, RDR

Cheyenne, Wyo.


What can be said

Q. Tell me what was said between you.

A. I just asked him how he was, and he said he was doing okay, and, you know, I was kind of, you know, kind of relieved, you know, that he’s alive and — and that he — you know, just thankful that he was alive. I just — you know, I was praising God the whole time.

Q. And he was able to speak with you, correct?

A. Uh-huh.

Dana Mann-Chipkin

Yuma, Ariz.


Before my time

Q. And I gather, from your testimony, you signed the agreements at the warehouse?

MR. SMITH: Objection. Compound.

MR. JONES: Okay.

MR. SMITH: I objected a little early.

MR. JONES: Premature objection, Your Honor.

MR. SMITH: Exactly.

THE COURT: Well, we don’t want that, do we?

MR. JONES: Not if I can help it.

Dianne Coughlin, RDR, CRR, CMRS

Sacramento, Calif.


No introduction needed

MR. SMITH: We’re here on a notice of deposition, which is dated Feb. 20, 2014, and the deposition is occurring at the offices of Peter E. Quinny, who is counsel to Ms. Lord, and the only other individual present aside from Ms. Lord and Mr. Quinny is myself.

Donna L. Linton, RMR

Ashburn, Va.


Wedded bliss

A. Because I was cleaning. Because we were going to celebrate our wedding anniversary. Some friends were coming to the house, and I was cleaning; that why I don’t forget it.

Q. So you were having friends over to celebrate your wedding anniversary?

A. Yes.

Q. Is that something that you always do?

A. Almost always. It’s been 35 years —

Q. Congratulations.

A. — carrying this cross.

Lisa Selby-Brood, RPR

St. Petersburg, Fla.


Location unknown

Q. This person, Mary, do you remember her last name?

A. I don’t right offhand.

Q. Does she still work there?

A. No, she’s dead now.

Q. That would be absolutely no.

Christine Phipps, RPR

West Palm Beach, Fla.


The small print

Q. The $5 million check, who was that made payable to?

A. It was made payable to the clients and ABC Law Firm.

Q. So they literally typed 22 names plus ABC Law Firm on there?

A. Yes.

Q. Did it look like one of those Wheel of Fortune checks?

A. No. They’re used to it. They didn’t have any problem with it.

Elsa Jorgensen

Birmingham, Mich.


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