Grimma's Deposition: She knows best when it comes to diagnosing mental illness...even from a parked car, across the street, and outside Dad's apartment
Grimma's Deposition: She knows best when it comes to diagnosing mental illness...even from a parked car, across the street, and outside Dad apartment
Grimma spends most of this depostion saying, "Private family matter." Or, "You are harrassing me," when she wants to change the subject. She doesn't remember much. But, about the multi-hour period when Steve was drugged in NY after spending four days awake by Tara's side in the hosptial, it's clear. She confidently states that SHE KNOWS what psychosis looks like, she "has training" as a nurse, and even from inside a parked car outside Mom and Dad's apartment, she was able to make a diagnosis. So good was her training, that she has remained steadfast in that diagnosis ever since, depite five psychatrists who attributed the episode to be drugged and followed by the Walshes.
[Update: The full Maura Walsh deposition video is now available for members after the deposition transcript below.]
Maura Walsh April 23, 2021 NDT Assgn # 50597
Fantastic though, someone with training. They will help Steve, right? Get him to hospital? Stay to watch over him and Tara? Whether drugged or off his meds or worse, he still needed help. They are decent people. A really good family, as they are fond of stating. Not the kind who would ever just kick the father of their grandaughter, exhausted and sick, onto the street. They wouldn't have him followed in hopes of getting him committed to maintain custody and protect the family trust? They just aren't that kind of family. Cringe.
Grimma and Mr. Moore accused Ms. Llaguno of 'harassing' Grimma over 47 times during this deposition. What prompted this parroting of this depositions' keyword?
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.
Video Timeline
REMOTE VIDEO DEPOSITION BY VIDEOCONFERENCE OF MAURA WALSH TAKEN ON FRIDAY, APRIL 23, 2021 5 4:18 P.M.
THE VIDEOGRAPHER: We are on the record. The time is 4:18 p.m. This is the beginning of the deposition of Maura Walsh. The case caption is Russell versus Walsh. Will counsel please introduce yourselves and state who you represent?
MS. LLAGUNO: Good afternoon. My name is Joy Llaguno and I represent plaintiff, Stephen Russell. I'm with the law firm, Hook and Hook.
MR. MOORE: And this is Frank Moore with the Law Offices of Frank S. Moore, representing Maura Walsh for her deposition only.
THE VIDEOGRAPHER: Our court reporter will now swear in the witness.
THE REPORTER: Thank you, Vincent. Sorry for the background noise. But, first, before we do that, I would like all attorneys present to stipulate that the 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 to move forward?
MS. LLAGUNO: Yes, I do.
THE REPORTER: Okay. And, Mr. Moore, do you also agree to move forward?
MR. MOORE: Yes.
THE REPORTER: All right. Thank you very much. Ms. Walsh, will you please raise your right hand? Thank you. Do you solemnly affirm under penalty of perjury that you are Maura Walsh and that the testimony you're about to give will be the truth, the whole truth and nothing but the truth?
THE DEPONENT: Yes.
THE REPORTER: Okay. Thank you very much. Counsel, you may begin.
MS. LLAGUNO: Thank you.
EXAMINATION BY MS. LLAGUNO: Q. Good afternoon, Ms. Walsh. Thank you for being here today. I really appreciate you taking the time out of your day to appear for this deposition. Can you please state your full name for the record?
A. Maura Walsh.
Q. And just to clarify, when I do receive a copy of the transcript for corrections, would you like me to send it to you directly, Ms. Walsh -- Mrs. Walsh, or to your counsel, Mr. Moore?
MR. MOORE: Well --
THE DEPONENT: To my counsel.
MR. MOORE: -- just -- counsel, we're -- we're not -- we're not buying a -- a transcript, so whatever the court reporter's method by which Ms. Walsh can review her deposition and sign off on it is the manner in which we're going to do this because we are -- neither one of us are purchasing a transcript.
MS. LLAGUNO: Right. Regan, what -- could you send it to Mrs. Walsh address or email? What is your preferred method --
THE REPORTER: So what happens -- so what happens is if -- if -- if Mrs. Walsh's counsel doesn't order a copy, then -- and -- but a read and sign is necessary, then we can set up a read and sign at a -- at a separate location, designated location where it's just -- just the deponent. And that's so that people don't make copies of the -- of the --
MS. LLAGUNO: And --
THE REPORTER: -- transcript.
Q. I'm going to show you now what we're going to mark as Exhibit 1.
A. Uh-huh.
Q. Ms. Walsh, do you see this document?
A. I see it in front of me.
Q. I am sharing your deposition subpoena. Do you recognize this document?
A. No. Actually, I've never -- I've never looked at it in detail like this, no.
Q. But you are aware that you've received --
A. Correct.
Q. -- this document? And I'm going to scroll down to Attachment 3. Did you review these requests for documents?
A. I actually didn't, no.
Q. So you are not aware that you were ordered to respond to these requests for production of documents; is that correct?
A. No. I never personally received them, no.
Q. So you did not bring documents with you today; is that correct?
A. Correct.
Q. Okay. Will you be willing to look for responsive documents and produce them?
A. I don't have any documents.
Q. Okay. Are you aware that there is a court order directing you to produce documents responding to this subpoena?
A. I never received any documents.
Q. Okay. Did you do anything to prepare for your deposition today?
A. Other than speaking with my attorney, no.
Q. And you didn't speak with anyone else about this deposition today?
A. No, I did not.
Q. Did you talk to Tara Walsh about this deposition?
A. My -- my daughter is aware that I am doing this deposition, yes. The whole family is aware of that.
Q. But did you speak with them about your deposition?
A. I'm not sure what you mean. They're aware of the deposition. They're -- they live here in the house and they know that I'm doing a deposition.
Q. And you did nothing with them to prepare for the deposition?
A. Did I have conversations with them to prepare for the deposition? No, I did not.
Q. Okay. Did you talk to anyone else about this deposition other than your family?
A. No.
Q. Did you review any other documents in preparation for this deposition?
A. No.
Q. Do you recognize this document, Ms. Walsh?
A. No.
Q. So you've -- so your testimony is you've never seen this document?
A. That's correct.
Q. Thank you. Could you please -- I'm going to scroll down the document to the bottom. This is an order from the Superior Court of the State of New York, County of Westchester. And I'd like you to review at this last page what the Court had ordered. Would you mind reading this out loud beginning with, "Accordingly, it is"?
MR. MOORE: You can read it to yourself. It doesn't need to be read out loud.
MS. LLAGUNO: I'm requesting Ms. Walsh read it out loud so I make sure that she is aware of --
THE DEPONENT: I am read --
MS. LLAGUNO: -- the court order.
THE DEPONENT: I am reading it. I've read it.
BY MS. LLAGUNO: Q. And you -- I'm sorry, you said you've read it?
A. I have just read it. Yes, I have.
Q. And so you were not aware that the Court had ordered you to appear, according to this language?
A. I told you I never received documents.
Brienne Walsh
Q. Okay. And how did you come to know about your deposition today?
A. How did I come to know about it? Because my -- my -- I'm trying to think of the way we -- my -- as a family, we became to know. I believe -- I'm not really sure about that. I'd have to -- I'm not -- I don't -- I don't really recall how I came to know.
Q. Okay. Do you remember when you came to know about the date of today's deposition?
A. When I came to know, when I -- I don't know. Maybe two weeks ago.
Q. You believe you came to know about -- that you had to appear today at deposition about two weeks ago; is that correct?
A. Correct.
Q. Okay. And you -- you have no recollection of who specifically told you that you should appear today at deposition; is that correct?
A. I -- I spoke to my lawyer about this deposition.
Q. Is your communications with your lawyer what you believe is the first time you had notice of this deposition?
A. Yes.
Q. Okay. I am now going to share you what we're going to mark as Exhibit 81. Mrs. Walsh, do you see this document?
A. Mm-hmm.
Q. Do you recognize this document?
A. No.
Q. Did you prepare this document?
A. No.
Q. Did you authorize the filing of this document?
A. No, I did not.
Q. Is this your signature at the bottom of this document?
A. It could be. I don't really recall signing it. It could be, though.
Q. Okay. Thank you. Mrs. Walsh, I'm going to ask a few questions just generally about your background, including your educational and professional history.
A. Mm-hmm.
Q. What is the highest level of education you attained?
A. My bachelor of science.
Q. What was your degree in?
A. I have a degree -- I have a -- a bachelor of science in -- a bachelor of science and I have a -- also, I graduated from a four-year nursing program.
Q. And what do you currently do for a living?
A. I currently take care of my granddaughter.
Q. And prior to that, did you have any other profession that you engaged in?
A. I worked as a registered nurse.
Q. And you -- do you do any volunteer work?
A. Currently, I take care of my granddaughter.
Aunt K
Q. Your husband's name is Steven Walsh; is that correct?
A. Correct.
Q. And you both have six children; is that correct?
A. That's correct.
Q. Could you give me their names?
A. Excuse me?
Q. Would you -- could you give me their names and ages?
A. I just told you it's personal information. It doesn't apply to this situation.
Q. Okay. So does Tara Walsh live with you?
A. Yes, she does.
Q. Does Tara Walsh's daughter, Evie, live with you?
A. Yes, she does.
BY MS. LLAGUNO: Q. Do you and Tara Walsh talk daily?
A. Private information.
Q. Can you tell me if you see Tara daily?
A. We just talked about she lives here. I tell -- I do see her, yes.
Q. So is it fair to say that you know what's going on in Tara's life?
A. I don't have -- I -- that's private information, my relationship with my daughter.
Q. Did you talk about this case with Tara Walsh?
A. I don't recall.
Q. Have you ever talked about other litigation involving Steve Russell with Tara Walsh?
A. I don't recall.
Q. Have you ever given Tara advice with respect to this proceeding?
A. I don't recall.
Q. Have you ever given Tara advice with respect to any other litigation ongoing?
A. I don't recall.
Aunt K
Q. Do you help care for Evie?
A. Yes, I do.
MR. MOORE: Objection. Relevance, invasion of privacy.
BY MS. LLAGUNO: Q. Are you paid for babysitting Evie?
A. Privacy.
Q. Just to clarify, you're refusing to answer this on privacy --
A. It's private information. That -- that's not something I'm going to answer.
Q. Do you know if Tara currently has a job?
A. Private information. I'm not going to answer that.
Q. Your oldest daughter, Brienne, testified that she now lives in Savannah, Georgia. How often do you speak with her?
A. That's private information. I'm not discussing it.
Brienne Walsh
Q. Ms. -- and Brienne Walsh testified at her deposition that she hasn't spoken with you since she moved to Savannah. Is that still true?
MR. MOORE: Objection. Relevance and privacy.
BY MS. LLAGUNO: Q. You can respond, Ms. Walsh.
A. Private information. I'm not discussing that.
Q. Okay. Tara has admitted on a few occasions that she's put certain drugs into Steve Russell's drinks without him knowing it. Did you know that Tara had given Steve Russell drugs without his knowledge or consent?
A. No.
Q. Has Tara ever spoken to you about it?
A. No.
Q. You don't have any knowledge regarding --
A. No.
Q. Again, please let me finish my question. I know you may know what I'm about to ask, but just for the court reporter's sake, just wait for me to finish the question. Do you know what this litigation is about, Mrs. Walsh?
A. I don't understand your question.
Q. Do you know the claims involved in this proceeding?
A. No, I don't recall any details.
Q. So you have no sense of why Tara Walsh gave Stephen Russell drugs without his knowledge or consent?
MR. MOORE: That assumes facts not in evidence. She's already testified she didn't even know about it, so how would she know why?
BY MS. LLAGUNO: Q. Please respond, Ms. Walsh.
A. No.
Q. Do you know if Tara Walsh was afraid of Steve Russell?
A. No.
Aunt K
Q. Do you know if anyone encouraged Ms. Walsh to put drugs in Steve Russell's drinks without his --
A. No.
Q. -- knowledge? And you've never spoken to anyone else within your family regarding drugging Steve -- Tara Walsh's drugging of Steve Russell?
A. No.
Q. And did you -- did you ever have any conversations with Steve Russell about this?
A. Not -- not that I recall, no.
Q. Do these -- do the past two documents refresh your recollection about Tara Walsh --
A. No.
Q. -- drugging --
A. I -- I don't recall, no.
Q. Okay. Thank you. Do you know if Tara Walsh has access to Seroquel?
A. Private information.
Q. Do you know if Tara Walsh takes Seroquel?
A. That's private information.
MR. MOORE: Well, I don't think that's how it works, Counsel. I don't think that's how it works. A deposition is where objections are made and if you think you have the grounds to compel answers to it, be my guest. I am making a record so that if any counsel comes after me knows where the - - the authority is so that they can cite it in any kind of motion. I may not be counsel of record of anything in -- after this, so I'm laying down a record. And if you don't like it, that's your -- that's your problem. But that is what one does as you invoke privileges at depositions. And if you don't like it and you think you have grounds to -- to override the privilege, then you bring a motion. So this is the authority we're relying on. Thank you.
MS. LLAGUNO: Right. And I -- I'd like to make a record that Mr. Moore's improper speaking objection took about over four minutes of this deposition's time, which has -- has been your pervasive pattern throughout all of the depositions. And I don't believe you -- they should have sought a protective order prior and not waste my time going to deposition, having them appear at deposition, only to object to every single question based on privilege.
MR. MOORE: Well, you have a different view of what the law is. And, unfortunately, it's incorrect. So at depositions, it's proper to raise privileges. I don't know what law school you went to, but that's how it's --
MS. LLAGUNO: Mr. --
MR. MOORE: -- taught in California, anyway.
MS. LLAGUNO: Mr. Moore, you can raise privileges, but you cannot make improper speaking objections. If you would like --
MR. MOORE: I just --
MS. LLAGUNO: -- I can --
MR. MOORE: I just made a record, so you know what, you -- you -- you blabbering after the fact doesn't erase what I just did, so move on.
MS. LLAGUNO: Okay. Please stop interrupting me. I just want to kindly remind you on the record, could you please not interrupt me? I'm being respectful of your time. I let you finish your speaking objection. When I am making an objection, please let me finish my statements. That is just basic rules of civility. I am please asking you to stick to those. If you'd like me, I can send you over the California 10 rules of civility, if you'd like.
MR. MOORE: I don't need to listen to you anymore. Just move on.
Q. So I'm going to -- do you have any knowledge regarding Matan Gavish editing documents for Ms. Walsh?
A. No.
Q. Do you have any knowledge of this narrative being submitted to the San Francisco Police Department?
A. No.
Q. As you know, there have been legal proceedings between Tara Walsh and Steve Russell in both San Francisco and New York. You submitted a letter to the judge in one of those legal proceedings; is that --
A. Mm-hmm.
Q. -- correct?
A. I don't recall.
BY MS. LLAGUNO: Q. Mrs. Walsh, do you recognize this document?
A. I don't recall when or where this was sent. I do remember writing this, but I don't recall where it was sent or when it was sent, no.
Q. So you don't -- do you recall the reasons why you wrote this?
A. I don't. Like I've told you, we've been harassed for three years nonstop, constantly, myself, my husband or my children by Mr. Russell. I can't even keep track of all the documents, papers, legal filings that have occurred. I have no clue.
Q. And your testimony here today under oath is that --
A. Yeah.
Q. -- this letter that you recall writing to a judge, you do not --
A. Correct.
Q. -- remember the reason --
A. I don't --
Q. -- for writing it?
A. -- remember where it was sent. No, I don't.
Q. Thank you, Ms. Walsh. Again, can I please remind you to wait until I finish asking you the question just so the court reporter can get a clean transcript of your responses to my questions? Do you recall personally writing this letter?
A. I've already told you that I did write this letter, but I do not recall which judge, what year, when it was. We've had multiple court filings with Mr. Russell with many different judges and I can't keep track of it all. We're inundated with his legal filings. It's complete harassment of our family --
Q. Mrs. Walsh --
A. -- that's been consistent --
Q. -- please don't --
A. -- for three years.
Q. Please respond succinctly to the question I'm asking and --
MR. MOORE: No, she can give -- hey. No. You don't talk over her and you don't argue with her. She gets to take -- tell her testimony. You asked a question. She's answering.
MS. LLAGUNO: I waited to the end --
MR. MOORE: Don't be arguing with -- do not be arguing with -- with her.
MS. LLAGUNO: I waited until the end. I didn't interrupt her. I let her speak, but I am asking please just have responsive answers to my questions.
MR. MOORE: It's responsive. Move on. You don't get to argue with her.
MS. LLAGUNO: Mr. Moore, again, can you please --
MR. MOORE: No, don't --
MS. LLAGUNO: -- stop scream --
MR. MOORE: -- don't be lecturing me. Just move on. Ask your next question.
MS. LLAGUNO: Mr. Moore, please, I'd ask again to stop with your speaking objections. Stop --
MR. MOORE: I'm not --
MS. LLAGUNO: -- continuing to --
MR. MOORE: I'm -- you -- you are not going to hear -- be here and berate a witness and insult her. Do not --
MS. LLAGUNO: I never insulted --
MR. MOORE: -- argue with the witness. I'm -- I'm -- I'm just warning you, man. You have really pushed it today. And if you continue, we're going to end the depo. So you ask and be respectful to this witness and don't argue with her.
BY MS. LLAGUNO: Q. Ms. Walsh, I apologize if you took that as an argument. I just wanted to remind you to try to be as responsive as possible to my questions so we can get through this deposition. Thank you. And, Mr. Moore, can you please stop with your speaking objections and improper coaching of the witness and insults? I've repeated multiple times today that I don't appreciate it and you're taking up time in my depositions.
MR. MOORE: I don't need your lecture. Move on and do your job.
MS. LLAGUNO: Thank you, Mr. Moore. I will do that.
[The letter was sent from Grimma's email to the Westchester Custody Court per Mom's request. Grimma and the Walsh's have not been harassed. Mom named them as witnesses in her case against Dad and he has tried to serve them with subpoenas through legal avenues. Had they accepted service via email, or the first time, the process servers would not have returned to their home. In fact, throwing subpoenas in the trash and evading service is the frowned upon action.]
Brienne WalshMS. LLAGUNO: Mr. Moore, this is an inappropriate venue to lay those objections.
MR. MOORE: I don't think so and I'm going to lay them and I'm going to keep doing it.
MS. LLAGUNO: And because you are not going to be the one responding to a motion to compel; is that correct? You stated you have --
MR. MOORE: I am making --
MS. LLAGUNO: -- a limited --
MR. MOORE: I am making a record. I am making a record of how you are furthering the harassment of these -- this family. That's what I'm making a record of.
MS. LLAGUNO: And I believe you're engaging in sanctionable and disrespectful conduct because you know you're not going to be the one responding to a motion to compel or a motion for sanctions.
MR. MOORE: I don't know that or not. All I'm telling you is that if it comes to be, whoever is representing anyone in a motion to compel, they need to know what you're doing. And I know what you're doing. I got your number. I can see it. Everyone can see it. And so I'm laying a record.
MS. LLAGUNO: Mr. Moore, again, I'd like to remind you to cease your improper speaking objections. You're taking up more time out of the deposition. I would -- I said early on I want to get this deposition finished within the four-hour time frame we have. I don't want -- it's my goal to not have Mrs. Walsh return a second time. But if you're going to continue obstructing my deposition, I can't make that promise. You've laid speaking objections for minutes and minutes obstructing this deposition and I please ask you to stop.
MR. MOORE: Move along, Counsel.
Q. And so, to you, that constitutes physical abuse? Am I understanding --
A. I was saying --
Q. -- that correctly?
MR. MOORE: Argumentative. She gave her observations. Don't put words in her mouth.
BY MS. LLAGUNO: Q. I'm just trying to understand your testimony. Is that what you're basing your understanding --
A. What I'm saying --
Q. -- of the physical --
A. -- to you is that Mr. Russell is mentally unstable. He has a significant mental illness that's untreated and he's capable of any and all of the above. I can't say that he -- he -- what he could or could not do. It -- somebody who is severely mentally ill and not treated can do all kinds of things.
Q. So, Ms. Walsh, do you have a background in psychiatry?
A. I have a training as a registered nurse and I know when someone's psychotic and when they're not.
Brienne Walsh
Q. And can you give me --
A. I can --
Q. -- details --
A. -- guarantee you Mr. -- I witnessed -- what I witnessed was a psychotic episode.
Q. And can you give me details on that training? I know you testified earlier that you're --
A. I am not --
Q. -- a registered --
A. I'm not going to give you -- it's -- it's self-explanatory. I have a -- a degree. It's self explanatory.
Q. Ms. -- Ms. Walsh, can I remind you again to please wait until I finish the question or the statement so we're not talking over each other? If you can imagine, the court reporter taking a transcript, it should ideally look question, response, question, response and not us speaking over each other. So I'd just like to kindly remind you to please wait until I finish my question. I'd really appreciate it.
MR. MOORE: And I will observe that you speak over her.
MS. LLAGUNO: Thanks for that observation, Mr. Moore.
MR. MOORE: You're welcome.
[Grimma was not around Dad after he was drugged by Mom at the hospital. She was in a parked car across the street and they never saw each other.]
Aunt K
Q. Okay. That day where you saw the -- I'm sorry, scratch that. That day that you were bringing Evie home from the hospital and you witnessed Stephen Russell's conduct, is that what you're basing your understanding of physical abuse on, that incident?
A. What I'm saying is that Mr. Russell was in the midst of a psychotic episode and people who are in psychosis are capable of all kinds of things. And it -- untreated mental illness, the -- the symptoms of that are very vast. And Mr. Russell, in my opinion, is capable of all kinds of things.
Q. Were you aware that Mr. Russell's security guards were informing him that there were foreign actors acting against him in a threatening manner?
MR. MOORE: Assumes facts not in evidence.
BY MS. LLAGUNO: Q. You can respond, Mrs. Walsh.
A. I -- I have no knowledge of that.
Q. Were you aware that Mr. Russell was recommend -- recommended -- I'm sorry, scratch that. Were you aware that Mr. Russell's security personnel suggested to Mr. Russell to look for spying devices and other devices in his home to make sure it's safe?
A. I do not believe --
MR. MOORE: Assumes facts not in evidence.
THE DEPONENT: I don't believe that's truthful.
BY MS. LLAGUNO: Q. Were you aware that Mr. Russell's security personnel on that date set door safety traps to ensure that no one was entering Tara's apartment?
MR. MOORE: Assumes --
THE DEPONENT: I don't --
MR. MOORE: -- facts not in evidence.
THE DEPONENT: That's correct.
BY MS. LLAGUNO: Q. Were you -- you can answer, Mrs. Walsh.
A. No, I don't believe that's truthful.
Q. Were you aware that Matan Gavish, unbeknownst to Steve Russell, went to Tara's apartment that day and tripped all of the safety triggers?
MR. MOORE: Assumes facts not in evidence.
BY MS. LLAGUNO: Q. You can respond, Mrs. Walsh.
A. Don't have any comment on that. I have no -- I -- I don't believe that's factual either.
Q. If that were, indeed, factual, would that explain to you why Mr. Russell was engaging in that conduct at Tara's --
MR. MOORE: Lack --
BY MS. LLAGUNO: Q. -- apartment?
MR. MOORE: Lacks foundation, calls for an expert opinion.
BY MS. LLAGUNO: Q. Mrs. Walsh, you can respond.
A. I don't believe that information is factual, is truthful.
Q. My question is, assuming it was --
MR. MOORE: It's an --
MS. LLAGUNO: -- or that --
MR. MOORE: It's an improper hypothetical and she's not here to testify as a -- as an expert witness.
MS. LLAGUNO: Okay. She can still respond.
THE DEPONENT: I already responded.
BY MS. LLAGUNO: Q. So your response was, even assuming that's true, that would not change your view of Mr. Russell's --
A. What I'm saying --
Q. -- conduct that day?
A. -- to you is let's move on. It's a mute [sic] point. I just told you that I think the information you're providing is not truthful. I don't believe that's what happened. I believe Mr. Russell was in the throes of a psychotic episode and that's the truth and that's what I saw. And all of this is not truthful. That's what I'm saying for the record.
Aunt K
Q. Okay. And I'm representing to you that there are text messages confirming those facts.
MR. MOORE: You know what?
BY MS. LLAGUNO: Q. Were you -- you can answer, Mrs. Walsh.
A. No, I don't believe that's truthful.
Q. Were you aware that Matan Gavish, unbeknownst to Steve Russell, went to Tara's apartment that day and tripped all of the safety triggers?
MR. MOORE: Assumes facts not in evidence.
BY MS. LLAGUNO: Q. You can respond, Mrs. Walsh.
A. Don't have any comment on that. I have no -- I -- I don't believe that's factual either.
Q. If that were, indeed, factual, would that explain to you why Mr. Russell was engaging in that conduct at Tara's --
MR. MOORE: You're not the witness, man. You cannot state what the state of the evidence is. You cannot ask a --
MS. LLAGUNO: And --
MR. MOORE: -- question -- you cannot use this kind of way of asking questions in a -- in a -- in a trial or -- or otherwise. You cannot --
MS. LLAGUNO: Mr. --
MR. MOORE: -- make representations about facts and then ask her about it. Just--
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- ask her questions about what she -- her -- her knowledge is.
MS. LLAGUNO: Mr. Moore, that issue is taken up before trial. You can move to --
MR. MOORE: No.
MS. LLAGUNO: -- exclude --
MR. MOORE: No, no, no.
MS. LLAGUNO: -- the --
MR. MOORE: No, no, no. She --
MS. LLAGUNO: -- but --
MR. MOORE: Just move -- just move along. You're -- you're wasting time. You're acting like a complete fool, but go ahead.
MS. LLAGUNO: Again, Mr. Moore, I please request that you stop with the insults during my deposition. I'd like to keep it as civil as possible and I just don't appreciate you with your improper speaking objections and slinging insults at me.
MR. MOORE: Well, you -- you're here as a representative of Stephen Russell and you want to make, as a witness, factual statements for the record. And -- and no one has to listen to you. We don't have to accept your representation of what the evidence is. That's what a --
MS. LLAGUNO: So --
MR. MOORE: -- jury does.
MS. LLAGUNO: -- I --
MR. MOORE: So don't -- don't -- don't feed all your knowledge or your belief of facts into predicates for questions for this witness.
MS. LLAGUNO: I'm able to formulate the questions as I see fit. You can object. You can lay your objection --
MR. MOORE: And that's --
MS. LLAGUNO: -- and --
MR. MOORE: -- exactly what I'm doing.
MS. LLAGUNO: And -- but these are improper speaking objections.
MR. MOORE: No, they're not.
MS. LLAGUNO: You're impeding my deposition and I'm --
MR. MOORE: I'm explaining --
MS. LLAGUNO: -- asking --
MR. MOORE: -- why you're so improper.
MS. LLAGUNO: You don't need to explain. You lay your objection for the record --
MR. MOORE: I am.
MS. LLAGUNO: -- succinctly.
MR. MOORE: I'm -- I'm -- I'm laying the foundation for my objection. Go ahead.
MS. LLAGUNO: And you can then bring it up in court. This deposition, taking up my time, it's not the proper venue to go back and forth and argue the objections.
MR. MOORE: Yes, it is.
MS. LLAGUNO: Mr. Moore --
MR. MOORE: Keep going.
MS. LLAGUNO: Please do not --
MR. MOORE: Keep going. Move on. Ask a question.
MS. LLAGUNO: Mr. Moore, I respectfully waited for you to lay your speaking objections. Please do not talk over me. I find it very disrespectful and demeaning. Can you please stop --
MR. MOORE: I find it disrespectful what you're doing to this family, so just move along and get done with it.
Q. Do you have any psychiatric licenses?
A. I'm not going to go further. It's self explanatory.
Q. Do you have any licenses in psychology?
A. Not going any further.
Q. Do you have any other licenses in the mental health profession that would lend to your ability to make that determination as to Steve Russell's conduct that day?
A. Not going any further. It's self explanatory.
Q. What exactly is self-explanatory, Ms. Walsh?
A. My bachelor of science in nursing. It's a degree that encompasses all facets of medicine, which encompasses psychiatry and it's -- I don't need to say more than that.
Q. So, as a nurse, you're licensed to make psychiatric determinations. Is that your --
A. I'm --
Q. -- belief?
A. I'm telling you what I saw, what I witnessed and, yes, it was a person in a psychotic episode.
Q. Shortly after Tara gave birth to Evie, she went to San Francisco; is that correct?
A. Yes.
Q. How did you feel about her move?
A. I don't --
MR. MOORE: Objection. Relevance.
BY MS. LLAGUNO: Q. You can respond.
A. Again, it's my family relations. It's not relevant.
Q. So just to clarify, you're refusing to respond based on family relations; correct?
A. My -- my personal dialogue with my daughter is private, yes.
Q. Were you upset with Tara Walsh for moving to San Francisco?
A. Yes.
Q. Why were you upset?
A. I think that's self-explanatory, no? Didn't we -- we -- we -- we just discussed earlier Steve Russell's behavior, no? And his mental instability.
Q. So you were upset that Tara was moving to San Francisco because you believed Steve Russell to have mental instability?
A. I -- I don't believe. I factually saw Steve Russell in the midst of a psychotic episode and I didn't think that was a good decision for Tara to be going with an infant into an environment like that.
Q. Did you tell Tara this?
A. Yes.
Q. And how did she respond?
A. I am not going to discuss my dialogue with my daughter.
Q. Did you think Tara moved to San Francisco because she wanted Steve's money?
MR. MOORE: Assumes facts not in evidence, lacks foundation.
BY MS. LLAGUNO: Q. You can still respond, Mrs. Walsh.
A. I'm not going to respond.
Q. Can you explain why you're not going to respond?
A. Because you're harassing me like Mr. Russell has.
Q. I'm not trying to harass you. I'd just like you to respond to --
A. I'm not --
Q. -- my question.
A. -- going to respond. You're harassing me.
Q. Did you ever speak with Tara Walsh about her reasons to --
A. I'm not going to --
Q. -- for her move?
A. -- discuss my conversations with my daughter.
Q. Did Tara Walsh -- did Tara Walsh ever talk to you about trying to get Steve to marry her?
A. I am not discussing that.
Q. Did she -- scratch that. Sorry. Did Tara Walsh ever talk to you about what she could get from Steve financially if she got Steve to marry her?
A. I'm not discussing that. And you're harassing. You're saying things that are harassing in nature.
Aunt K
Q. Mrs. Walsh, I'm not trying to harass you.
MR. MOORE: Don't -- don't --
MS. LLAGUNO: I'm just trying --
MR. MOORE: Don't -- don't -- don't do it. Don't do it. Don't argue with the witness. Just ask your questions.
MS. LLAGUNO: Mr. Moore, can you please speak in a tone that's more respectful? I'd really --
MR. MOORE: No.
MS. LLAGUNO: -- appreciate it.
MR. MOORE: Not when you're disrespectful to the -- the witness. You -- you -- you don't get to do that. Very --
MS. LLAGUNO: I was not --
MR. MOORE: -- unprofessional. Very unprofessional. You shouldn't be doing that.
MS. LLAGUNO: I'm not -- okay. Good.
BY MS. LLAGUNO: Q. Mrs. Walsh, Tara Walsh texted Matan Gavish in February 2018 that if she sued Steve Russell for child support, she would, quote, "get, like, 2k a month, which is not enough to live off of," end quote. And she said, quote, "I'm better pretending I want to be with him and getting the most while I can than leaving him for good," end quote. Did she ever express similar thoughts to you?
A. No.
Q. Did Tara Walsh ever express thoughts that she could get Steve Russell to marry him [sic] and then she --
A. I'm --
Q. -- could just divorce --
A. I'm not --
Q. -- him?
A. I'm not discussing my relationship with my daughter. I -- I really do not want to keep saying this and I don't want you to keep asking me questions. You're harassing me. I want you to stop. I'm not discussing my relationship with my daughter. That's private information.
Q. Okay. I am just -- your counsel advised that I ask the question. I asked earlier in this deposition if you wanted to (audio disruption) objection as to asking questions that involve your family and your counsel stated that I should ask my questions and you state your objection to each and every question. So that's how I'm going to proceed.
MR. MOORE: Well, you know she's not going to -- she's not going to answer any question where you're trying to get into confidential communications with her daughter. So that --
MS. LLAGUNO: Okay. And I can --
MR. MOORE: -- you can take to the bank.
MS. LLAGUNO: Right. And I can still make my record of the questions I'm asking and the objections you make.
THE DEPONENT: But you're harassing me. You're harassing me because you -- I've already stated it clearly and you keep harassing me. And I'm not going to sit here indefinitely and be harassed by you. So you either stop or I'm going to stop the deposition. It's that simple.
BY MS. LLAGUNO: Q. Ms. Walsh, I'm not trying to harass you. Per your --
A. But you are.
Q. -- counsel --
A. You are. I've already stated it many many times, over and over again, so stop asking me.
Q. I'm trying to --
A. I'm not here --
Q. -- create a --
A. -- for you to harass me, okay? I've been harassed for three years by Mr. Russell, who you are representing, and I'm not sitting here for hours being harassed by you. I'm not doing it, period. So if you continue it, I'm finished.
Q. I'm trying to create a record of my questions --
A. You're not.
Q. -- and my --
A. You're harassing me. You're harassing me. You're bullying like he has bullied us for three years and I want you to stop. It's that simple. If you have a relevant question, ask it. We -- I have no knowledge of anything that went on in San Francisco. I was never in there -- in San Francisco. I have no knowledge of anything. I had no part in anything. That's what this is about, the deposition, what -- what supposedly occurred in San Francisco. All these other questions are irrelevant. They're harassment and I want you to stop harassing me.
Q. And I will explain again for the record that I'm just trying to make a record of our questions. You can make a record of your objection and we'll continue.
MR. MOORE: Well, I just think you heard from the witness that she's not going to stand for more harassment. And you have been harassing every witness that has come before you in a deposition, so you can -- you can continue to harass her, but at some point, she's probably going to leave. And it's -- it -- it would be incumbent upon you to ask a relevant question and not spew, you know, evidence that you claim exists as a predicate for a question just to upset her. Why don't you ask her what she knows instead of, like, you know, presenting other people's statements that -- that you think is valuable to your client and ask her, "Did you know that?" I mean, it's really improper It wouldn't be allowed in a courtroom, wouldn't -- it's not even allowed in a deposition. So, you know, you really need to -- to not harass. I mean, just ask some questions that are germane to the -- the -- the -- the -- the -- the -- the gravamen of the complaint, which is about this drugging. That's all this case is about. And all you want to do is -- is go on things that sounds very much like you're trying to relitigate custody. And so, you know, that's over. You -- you -- your client lost. And --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- you know -- and if this stuff ends up in a New York court, I'm making a record that it was improper for you to do that. And I think, you know, you harassing this mother of -- of -- of -- of -- you know, of the -- of mother of her granddaughter after years of this guy harassing her and you're now harassing her is improper. So, you know, she can do --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: She's a -- she's a grownup. She can do what -- what she wants. But if you're going to continue this, she's told you, she's warned you that she's not going to stand for it any longer.
MS. LLAGUNO: Thank you, Mr. Moore. I, again, want to remind you to please stop with your improper speaking --
MR. MOORE: I'm --
MS. LLAGUNO: -- objections.
MR. MOORE: No. I -- I have to protect this --
MS. LLAGUNO: You do not --
MR. MOORE: -- woman because you're harassing.
MS. LLAGUNO: I waited --
MR. MOORE: You're harassing her.
MS. LLAGUNO: Mr. Moore --
MR. MOORE: And I think it's improper. I think you -- you need --
MS. LLAGUNO: I --
MR. MOORE: -- to -- to go back to finishing school.
MS. LLAGUNO: Mr. Moore, I waited until you finished what you were saying. Please do the same for me. I just want to get my statement on the record as well. Stop laying insults against me. It is highly unprofessional and I don't appreciate it.
MR. MOORE: No. You're highly unprofessional for what you're doing. You know, money --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- money is not everything, you know? You don't have to stoop to such levels just to -- to earn a living, you know? You don't have to be this way. You can be a professional --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- yourself.
Q. Did Tara ever tell you that she believed Steve Russell had a gun in the house?
A. I'm not discussing my daughter's dialogue with me. It's private information.
Q. Did Tara tell you that this wasn't true?
A. I'm not discussing any dialogue with my daughter with you.
Q. And in connection with this belief, didn't Tara ask to get an emergency psychiatric evaluation?
A. I'm not discussing -- I have no recollection of anything of that nature.
Aunt K
Q. You don't recall agreeing with Tara that she should have emergency treatment with a psychiatrist in San Francisco?
A. I -- I don't recall that, no.
Q. And you don't recall the results of that evaluation; is that correct?
A. That's correct.
Q. Did Tara tell you that Dr. Gopal had diagnosed her with borderline personality
A. I'm not --
Q. -- disorder?
A. -- discussing any dialogue with my daughter.
Q. If you knew Tara was in a bad mental state, why did you not want to visit her in San Francisco?
A. If I knew Tara was in a bad mental state? You're -- you're assuming that. You're --
Aunt K
MR. MOORE: Yes, assumes facts not in evidence.
BY MS. LLAGUNO: Q. I believe you testified earlier you thought she was in a bad mental state.
A. When did I testify earlier that she was in a bad mental state?
MR. MOORE: I believe that -- I believe the record will reflect it was when she came back from San Francisco.
BY MS. LLAGUNO: Q. Do you believe Tara to be in a bad -- do you believe Tara was in a bad mental state when she was in San Francisco?
A. I'm not discussing my relationship with my daughter.
Q. Have you ever talked to Matan Gavish?
A. Have I ever talked to Matan Gavish? Is that your --
Q. Yes.
A. -- question? How does this --
Q. Yes.
A. -- relate again to this situation in San Francisco? I can't sit here for hours and hours tonight on this. I -- and I will not. You want to ask me relevant case -- questions regarding what the judge asked you to do. And that is to -- this is about this supposed incident in San Francisco. You want to take the rest of the time that we might have, the little time that I have left to - - to talk about that or ask me about that, I will sit here. I'm not going to go off on all these tangents and continue to be harassed. Ask me relevant questions and I'll answer them. I've been harassed for three years. I'm not going to sit and tolerate more of it. I've had enough.
Q. Ms. Walsh, we -- our position is these are relevant to this case --
A. Well, it might be --
MR. MOORE: Don't -- don't argue with the -- do not argue with the deponent. Just move on. If she's not going to answer the question, you can bring a motion if you have to, but don't argue with her.
MS. LLAGUNO: I'm not arguing. I'm making my --
MR. MOORE: Yes, you are.
MS. LLAGUNO: -- statement for the record.
MR. MOORE: No, you're not making a statement for the record. You're arguing with her. Stop it.
MS. LLAGUNO: Mr. Moore, I really don't appreciate the --
MR. MOORE: I don't care --
MS. LLAGUNO: -- threatening --
MR. MOORE: -- what you appreciate. Just go and ask another question. Come on.
MS. LLAGUNO: I'd, again, kindly let you - -
MR. MOORE: Did you talk to a monkey yesterday? I mean, come on.
MS. LLAGUNO: Could you let me finish my statements for the record and stop interrupting me? It's very disrespectful.
THE DEPONENT: I'd like you to ask relevant questions in the remaining time we have. And that's --
MR. MOORE: Yes.
THE DEPONENT: -- it.
MR. MOORE: Let's get --
THE DEPONENT: I'm not going to --
MR. MOORE: -- on with it.
THE DEPONENT: -- sit here for hours going through all these irrelevant -- I'm not going to do it, okay? So you either ask -- you -- you know, you Maura Walsh did it to my son today. I'm not sitting here and my husband's not going to sit either for it, okay? It's enough already. You don't have any right to harass us. We've been harassed for three years and it hasn't -- it hasn't ceased for -- you know, it's been constant. Mr. Russell has harassed us for three years. Now, he's using you to harass us. This is a deposition. You can ask specific questions regarding what, you know, this supposed interest -- incident in San Francisco. You want -- I have no information about it. I don't know anything about it. I wasn't involved with it. I have no knowledge of it, period. If you have a question about it, ask me more. I'm not going to just go off on tangents about all other kinds of things. It's totally irrelevant.
BY MS. LLAGUNO: Q. Okay. May I continue with my deposition now?
A. If it's relevant, yes. If you're going to -- if you're not -- if you're going to stop harassing me, yes.
Q. Do you know if Tara owns a handbag business?
A. What --
MR. MOORE: Objection. Relevance.
THE DEPONENT: -- in God's name does that have to do with an incident in California? Could you just -- could you just -- what -- what does that have to do with anything? I am not --
MR. MOORE: Yeah. What the --
THE DEPONENT: -- sitting --
MR. MOORE: What --
THE DEPONENT: -- here -- I am not sitting here for this. This is ridiculous. This -
MR. MOORE: What does it --
MS. LLAGUNO: Ms. Walsh --
MR. MOORE: -- have to do with the case?
THE DEPONENT: Ridiculous. Okay? It -- and -- and this is, like -- I am not doing this. I -- I can't -- I'm not going to keep saying it. I'm going to just --
MR. MOORE: I -- I -- I agree. I -- I don't think anyone has to put up with this. What does that have to do with the case?
MS. LLAGUNO: Ms. Walsh --
THE DEPONENT: How does a handbag -- I mean, come on. This is ridiculous. This is ridiculous. Ask me -- I'm going to say it one more time. You have a relevant question, ask me. If not, we're ending this, okay? That's it, period.
MS. LLAGUNO: Our position is that Ms. Walsh has made certain statements and we are entitled to look into the truth of those statements.
MR. MOORE: What does a handbag have -- business have to do with the case?
MS. LLAGUNO: We are entitled to look into --
MR. MOORE: You're -- no.
MS. LLAGUNO: -- the truth --
MR. MOORE: No, you're not entitled to look into it.
MS. LLAGUNO: -- Tara's credibility and --
MR. MOORE: Oh, come on.
MS. LLAGUNO: -- her statements.
MR. MOORE: What -- what, because she said she had a handbag or she -- she said she --
MS. LLAGUNO: No.
MR. MOORE: -- didn't have a handbag business? I mean, what does that have to do with anything? That would be --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- impeachment on a collateral issue, potentially. I -- I don't even know what you're talking about. This is --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- babble. Just babbling.
MS. LLAGUNO: Mr. Moore --
MR. MOORE: So why don't you get to something germane?
MS. LLAGUNO: Mr. Moore, our position is that Tara has made --
MR. MOORE: I know --
MS. LLAGUNO: -- certain --
MR. MOORE: -- your position and it's pathetic. It's -- it's irrelevant what your position is because it's not valid. So ask a question that's -- that's relevant.
MS. LLAGUNO: Again, while I'm speaking, I'll kindly ask you to be more respectful and stop - -
MR. MOORE: No.
MS. LLAGUNO: -- cutting me off.
MR. MOORE: I can't --
THE DEPONENT: But you're not being --
MR. MOORE: -- be respectful if it's --
THE DEPONENT: -- respectful --
MR. MOORE: -- someone who's --
THE DEPONENT: -- to me.
MR. MOORE: -- such a disrespectful person.
THE DEPONENT: You're not being respectful to me. You're harassing --
MR. MOORE: Yeah.
THE DEPONENT: -- me. And he's -- he's representing me. You're harassing me.
MR. MOORE: So ask a --
THE DEPONENT: You're not asking --
MR. MOORE: -- a question that's --
THE DEPONENT: -- relevant questions.
MR. MOORE: Yes.
THE DEPONENT: Ask --
MR. MOORE: Ask a relevant question.
THE DEPONENT: -- relevant questions or we're going to end this. It's that simple. You don't -- you're not asking questions that are relevant. There's -- there -- this is about an incident that supposedly occurred in San Francisco. You have questions about that, ask me. I've already stated for the record I have no knowledge of it. I wasn't involved with it. I know nothing about it. You want to ask about that, ask about that. If not, you're just harassing me, as Mr. Russell has for three years.
MS. LLAGUNO: Thank you. Can I continue with my deposition questions now? I'd like to get this done in a timely manner. If we could just refrain --
THE DEPONENT: Well --
MS. LLAGUNO: -- from --
THE DEPONENT: -- it's not -- it's not -- it's not -- it's not -- it's -- it's -- it's -- then you should just stick -- stick with what's relevant here and what -- what we're supposed to be doing, what the -- what the reason for this deposition is and stick with that and stop going off on all these tangents asking all these other questions.
MS. LLAGUNO: And our position is we're entitled to discovery on statements Tara has made.
MR. MOORE: No, you're not. That -- that's just a bad position --
THE DEPONENT: We could --
MR. MOORE: -- to have --
THE DEPONENT: -- be here for a week.
MR. MOORE: -- because it's -- it's a -- it's an --
THE DEPONENT: We could be here --
MR. MOORE: -- improper --
THE DEPONENT: -- for weeks --
MR. MOORE: -- because it --
THE DEPONENT: -- sitting here going around in circles and I'm not doing that, okay? Ask -- I'm here. You're -- we have a short while left. Ask relevant questions or it's over.
MS. LLAGUNO: Ms. Walsh, I'd like to remind you I'm entitled to seven hours of your deposition testimony.
MR. MOORE: No, you're not. Not -- not with -- not with this kind of stuff. You're not going to get it. So you either ask a question that's relevant or we're dead -- we're done.
MS. LLAGUNO: And, again, Mr. Moore, you don't get to decide what is or isn't --
MR. MOORE: I do get to decide.
MS. LLAGUNO: -- relevant.
MR. MOORE: I get to decide if we're going to end this deposition because you're harassing her. So what -- what's it going to be?
MS. LLAGUNO: Mr. Moore, please stop speaking over me. I let you finish when you do your objections. Please let me finish my statements on the record.
THE DEPONENT: Well, then ask me --
MS. LLAGUNO: I didn't --
THE DEPONENT: -- relevant questions and let's be done with it. Ask relevant questions. Asking about my daughter's handbag business is an absolutely ridiculous question.
MS. LLAGUNO: Okay.
THE DEPONENT: And I'm not going to sit here. And I'm going to give you a chance to ask relevant questions. If you don't, it's -- we're -- we're done here.
A. Is my house unsafe for Evie? Absolutely not.
Q. Do you believe -- why would Tara lie about your home --
A. I'm not --
Q. -- being an un --
A. -- discussing my relationship or dialogue with family. I'm not discussing that.
Aunt K
Q. Tara also stated that she was living in your attic without heat; is that true?
MR. MOORE: Objection. Lacks foundation, assumes facts not in evidence, argumentative.
BY MS. LLAGUNO: Q. You can respond, Mrs. Walsh.
A. To -- I'm going to -- I'm responding to Tara living in the -- in the attic with no heat. That's ridiculous. I have no -- no comment on that.
Q. Is that true or false?
A. Absolutely false.
Q. So she's not living in the attic?
A. Absolutely not.
Q. And she's not living without heat?
A. Absolutely not.
Q. So just to clarify, any questions related to your communications or dialogue with Tara Walsh, you refuse to answer --
A. I -- I --
Q. -- based on --
A. I -- that's private -- privacy, yes. That's private information.
Q. So for the sake of efficiency of this deposition, if you also -- are you also refusing to answer related to questions about your relationship with Ms. Walsh based on that same privacy; is that correct?
A. I don't know what you're trying to say.
Q. I'm just trying to understand, so we don't waste any more time, the bounds of what you are objecting to.
MR. MOORE: I -- I think --
MS. LLAGUNO: What questions --
MR. MOORE: -- it's pretty obvious what she's objected to all throughout the day. I -- I've left -- I've -- I made a long statement for the record about the right to familial privacy. I think it encompasses everything you've been asking, not to mention all the other improper reasons that your questions have been posed. But I think it's safe to say that if -- if you are going to ask about the familial relationship, that this witness is not going to answer them.
MS. LLAGUNO: Okay. And just so I understand, could you give me, Mr. Moore -- okay. Our position is --
MR. MOORE: I know what --
MS. LLAGUNO: -- that --
MR. MOORE: -- your position is. I've heard it a million times. The question is -
MS. LLAGUNO: Let me state it --
MR. MOORE: -- is, do -- do you have good cause to compel -- to -- to get into the private matters of this family? That's the question. And so you can make a motion, if you so deem fit, to do so. But I think it's very obvious at this point that this witness is not going to answer your questions as it pertains to her communications with her daughter that -- that impede or -- or invade the familial relationship or the rights to privacy thereto.
MS. LLAGUNO: Okay. And for the sake of efficiency, I just want to clear that up for the record so we don't continue with these questions and blanket objections. I'd like to state for the record that we believe this is squarely within the bounds of discovery for this case, especially related to Tara Walsh's discovery responses and counterclaim that is still active in this incident litigation. And on that note, if Mr. Moore is directing his client not to answer based on --
MR. MOORE: You know --
MS. LLAGUNO: -- familial privacy, I'm going to go ahead and adjourn this deposition, reserve the right to continue it to a second day.
22 MS. LLAGUNO: And, Mr. Moore, that's all - -
MR. MOORE: Those are the -- no, no, no. I'm not done. I'm not done. Those --
[...]
MS. LLAGUNO: That's --
MR. MOORE: -- are the questions that I've instructed her not to answer. And so -- so, for the record, she has chosen to raise her privacy rights on her own, which I agree with, but I am not instructing her not to answer, so you cannot make that representation. So don't make false statements on the record because they're easy to -- to determine how false they are because there's a 1record. All right?
MS. LLAGUNO: Mr. Moore --
MR. MOORE: So if you want to -- if you want to suspend the deposition because you think you have a right to invade the privacy of this family, that's your prerogative. Go to town. Hope you do well in front of a judge because I hope a judge looks at this and sanctions the hell out of you.
MS. LLAGUNO: So, Court Reporter, I'd like to make a record that we are ending this deposition. I reserve the right to continue the deposition at another time and notice it. I also would like to make another record that deponent's counsel, Mr. Moore, has made numerous improper speaking objections, has continuously disrupted this deposition and obstructed my questioning. He's also talked over me multiple times, interrupted me, laid insults and laid multiple improper speaking objections and self-serving statements to coach the witness. And based on that -
MR. MOORE: No.
MS. LLAGUNO: -- conduct --
MR. MOORE: No, there's not been any coaching. No coaching. No, you're -- you're wrong. I have objected and gave a basis for the objections. You're misrepresenting the record. Luckily, there's a record. And anyone who watches it or anyone who reads it will know exactly what happened. And we don't need --
MS. LLAGUNO: Correct.
MR. MOORE: -- your summary of what happened because it's wrong and it's fraudulent, just like you are.
MS. LLAGUNO: Thank you, Mr. Moore. And I'd also like to add that, again, his last line is paradigmatic of his conduct throughout this deposition, completely disrespectful, against the rules of civility.
MR. MOORE: So are you done --
MS. LLAGUNO: And based on --
MR. MOORE: -- or -- or are we done with this deposition? Are we ending it? That's what you just said. Are we going to end it? Is this done?
MS. LLAGUNO: Again, you're interrupting me as I'm trying to make my record.
MR. MOORE: No, I -- I don't need your speeches. I'd like to have the witness be able to leave if you are suspending this deposition.
MS. LLAGUNO: Yes, I am. But I still -- I'm entitled to --
MR. MOORE: Okay.
MS. LLAGUNO: -- set my --
MR. MOORE: You can go, Ms. Walsh --
THE DEPONENT: Oh, okay.
MR. MOORE: -- Mrs. --
THE DEPONENT: Thank you.
MR. MOORE: -- Walsh. Thank you for your time.
MS. LLAGUNO: And based on that conduct, again, I reserve the right to continue this deposition. And --
MR. MOORE: Yeah. You do -- you do whatever you think is fit, but, boy, I'd just -- I have a sneaking suspicion that someone looking at this behavior is going to be quite shocked that you would take on the role of someone to harass a family over three years of litigation, which -- with people who clearly have issues, including --
MS. LLAGUNO: Mr. --
MR. MOORE: -- your client.
MS. LLAGUNO: -- Moore -- Mr. Moore --
MR. MOORE: And -- 8 MS. LLAGUNO: -- we can go off the --
MR. MOORE: And it's just --
MS. LLAGUNO: -- record --
MR. MOORE: It's really --
MS. LLAGUNO: I'm --
MR. MOORE: It's really disturbing that you would -- would take on the -- the mantle of trying to act like you're -- you're so proper and professional when all you're doing is harassing. You -- you --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: And make false --
MS. LLAGUNO: -- I thought you wanted to -
MR. MOORE: -- representations to the Court.
MS. LLAGUNO: Mr. Moore, I thought you wanted to end this deposition.
MR. MOORE: Poor form.
MS. LLAGUNO: Are you done?
MR. MOORE: We -- we should. We should end it. I'm just not going to sit here and let you babble on with falsities. I'm going to comment on them when they come -- when they occur.
MS. LLAGUNO: Again, I want to say for the record you represented at the last deposition that Ms. Walsh's counterclaims have been dismissed and that is not true. There is no court --
MR. MOORE: They --
MS. LLAGUNO: -- order dismissing --
MR. MOORE: There has been -- no. I -- here's what I said. There's been a filing by her, as I understand it, because I've seen it, a -- a voluntary request for dismissal on a judicial counsel form. There's also been a declaration by her in which she's represented to the Court that she either wants your client's requests for the -- for the terminating sanction to be entered or to have her voluntary dismissal filed. That's what the record exists. It doesn't appear to have been filed yet by the clerk of the Court, but that is common in the San Francisco Superior Court. They -- there's things --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- that have gone for -- for weeks without it being -- appearing on the -- on the docket.
MS. LLAGUNO: Mr. Moore --
MR. MOORE: But I have --
MS. LLAGUNO: Mr. Moore --
MR. MOORE: -- seen it. I have seen it and I understand it's been filed. And at -- at any rate, your client has -- has asked for the terminating sanction on the cross-complaint to be entered, so either way --
MS. LLAGUNO: But --
MR. MOORE: -- it's going to be entered. It's going to be dismissed.
MS. LLAGUNO: Until then, there is no court order dismissing the claim.
MR. MOORE: I don't care.
MS. LLAGUNO: Discovery --
MR. MOORE: I know, as an officer of this court -- court, what's going to happen and so should you, but you want to -- you want to play these games. And -- and you're just not very good at it. You're not very good. In fact, you're -- you're quite poor.
MS. LLAGUNO: Thank you again, Mr. Moore. I really appreciate the commentary. I just want to point out that Ms. Walsh filed something two days 1ago that I was served, but I -- it's showing up on the court website and is not a motion for voluntary dismissal, so --
MR. MOORE: Well --
MS. LLAGUNO: -- just wanted --
MR. MOORE: -- I've seen it.
MS. LLAGUNO: -- to point that out. And 1we can go back and forth forever, Mr. Moore. We can end this deposition. There's -- we can take it up in court. I know you have cast -- washed your hands of this and aren't going to be representing them outside of the depositions, as you've stated, so let's leave it at that.
MR. MOORE: Good luck to you. You should try to find --
MS. LLAGUNO: And --
MR. MOORE: -- a better client.
THE REPORTER: With that then, Ms. Llaguno -- I can't even --
MS. LLAGUNO: Llaguno.
THE REPORTER: -- get that -- yes, I'm so sorry.
MS. LLAGUNO: It's been -- been a long --
THE REPORTER: We're going to --
MS. LLAGUNO: It's been a long day.
THE REPORTER: We're going to go ahead -- the deponent is gone. Did you want to order the originals to this, to these past two depositions?
