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 UNITED STATES DISTRICT COURT

 SOUTHERN DISTRICT OF FLORIDA

 MIAMI DIVISION

 CASE NO. 20-23230-CIV-CANNON/Otazo-Reyes

ANGELA MILNER, et al.,

 Plaintiffs,

vs.

TERI GALARDI,

 Defendant.

- - - - - - - - - - - - - - - x

 4551 Ponce de Leon Boulevard

 Coral Gables, Florida 33146

 August 20, 2021

 10:55 a.m. - 11:55 a.m.

 DEPOSITION OF MARLEKA WILLIAMS

 Taken Before Jeffrey M. Goldstein, Registered

Professional Reporter and Notary Public for the

State of Florida at Large, pursuant to Notice of

Taking Deposition filed in the above cause.

Page 2

 APPEARANCES

 THE LAW OFFICE OF ASTRID E. GABBE, P.A.

 P.O. Box 4216

 Hollywood, Florida 33083

 BY: ASTRID E. GABBE, ESQ.

 On behalf of the Plaintiffs

 GERALD J. TOBIN, ESQ.

 4551 Ponce de Leon Boulevard

 Coral Gables, Florida 33146

 BY: HOWARD BRODSKY, ESQ.

 and GERALD J. TOBIN, ESQ.

 On behalf of the Defendant

 _____________________________

 I N D E X

Examinations Page

MARLEKA WILLIAMS 3

 3

DIRECT EXAMINATION BY MR. BRODSKY 3

Page 3

1 Thereupon--

2

 MARLEKA WILLIAMS

3 was called as a witness by the Defendant and,

4 having been first duly sworn, testified as follows:

5

 MR. BRODSKY: Okay. Let the record reflect

6

 that this deposition was duly noticed by

7

 agreement of the parties to commence today at

8

 9:30 a.m., and counsel for the claimant who is

9

 present and the claimant arrived at

10 approximately 10:30 a.m. We are now getting

11 ready to start the deposition.

12 The witness is sworn?

13 THE COURT REPORTER: Yes.

14 DIRECT EXAMINATION

15 BY MR. BRODSKY:

16 Q. Please state your name.

17 A. Before I do, I apologize for my tardiness,

18 but I didn't get your guys' address until 9:30 and

19 I'm all the way in Dania Beach. So I apologize.

20 Q. I apologize that is not our responsibility

21 to give you.

22 A. I understand. I just wanted to apologize,

23 that's all.

24 Q. So you're saying you didn't get the

25 address from your lawyer until this morning?

Page 4

1

 A. Correct.

2

 Q. At 9:30?

3

 A. Correct.

4

 Q. Okay.

5

 MR. GABBE: From my paralegal. I was in

6

 traffic.

7 BY MR. BRODSKY:

8

 Q. Please state your name.

9

 A. Marleka Williams.

10 Q. Have you ever had your deposition taken

11 before?

12 A. No sir.

13 Q. So let me go over what it is and try to

14 put together certain guidelines so it goes as

15 smooth as possible, okay?

16 A. Okay.

17 Q. You're a claimant in this case. You know

18 that, right?

19 A. Umm-hmm.

20 Q. And one of the things you have to do is

21 you have answer out loud, say yes, no or whatever

22 it is you're going to say. Uh-huh, uh-uh doesn't

23 work.

24 A. Okay.

25 Q. Because he's taking down everything we're

Exhibit 4

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1 saying, okay?

2

 A. Okay.

3

 Q. So we're here today in a case styled

4 Angela Milner, et al., versus Teri Galardi, and you

5 are one of the named plaintiffs, correct?

6

 A. Correct.

7

 Q. I see that you have a piece of paper

8 sitting in front of you. What is it that you have

9 sitting in front of you?

10 A. It was my information. I was making sure

11 that everything that Daya (phonetic) gave him was

12 correct. This is my first time getting this

13 document. So yeah.

14 Q. Okay. So keep that there. We'll deal with

15 it, all right?

16 Now, let me ask the question --

17 A. Okay.

18 Q. -- then I'll let you answer the question

19 so we're not talking over each other, okay?

20 A. Okay. Because that way it makes it

21 difficult for the court reporter to take it down.

22 MR. GABBE: And may I make one

23 interjection? Just in case I want to object,

24 just give it one or two seconds. So if I

25 want -- probably I will not, but if so, then

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1

 allow me to go forward with my objection

2

 before you answer, okay?

3

 THE WITNESS: Okay.

4 BY MR. BRODSKY:

5

 Q. Okay. Also I'm asking you to tell me about

6 what you know today, not what you think. I'm not

7 asking you to speculate. I'm asking you to tell me

8 what it is that you know, okay?

9

 A. Okay.

10 Q. If you don't understand something, tell me

11 you don't understand and I'll do my best to make it

12 clear so we're both on the same page.

13 A. Okay.

14 Q. Do you have any questions of me before we

15 start in terms of how the procedure is going to be?

16 A. You're going to ask the question and I'm

17 going to answer it, correct?

18 Q. That's right.

19 A. All right. Got it.

20 Q. You've been sworn under oath.

21 A. Okay.

22 Q. And now let's begin the deposition.

23 A. All right.

24 Q. Your name is Marleka Williams, right?

25 A. Correct.

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1

 Q. What is your date of birth?

2

 A. 04/26/1989.

3

 MR. BRODSKY: And off the record.

4

 (Discussion held off the record)

5 BY MR. BRODSKY:

6

 Q. Have you ever been arrested?

7

 A. Teenage years, so not really.

8

 Q. Tell me about it. About how long ago and

9 what was it?

10 A. Under 18.

11 Q. Well, let's see. '89, '99, 2009.

12 A. I'm 32.

13 Q. So 32. What were you arrested for as a

14 teenager?

15 A. Excuse my language, but smoking marijuana.

16 Q. Okay. Anything else?

17 A. No sir.

18 Q. So you've been arrested one time?

19 A. Yes sir, to my knowledge.

20 Q. And it was for possessing marijuana?

21 A. Umm-hmm.

22 THE COURT REPORTER: You have to say yes or

23 no. You can't --

24 THE WITNESS: I'm sorry, I'm sorry. Yes

25 sir.

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1 BY MR. BRODSKY:

2

 Q. All right. Now, tell me about what your

3 claim is in this case, explain it to me. What are

4 you claiming that Teri Galardi did wrong?

5

 A. I was an employee there, and I paid to

6 work there but I never received a salary, I never

7

received a paycheck from her at all. I paid to be

8

there, and then they took 10% of my money every

9 night that I worked.

10 Q. Okay. What is the time frame for which you

11 are claiming damages in this case?

12 A. From March 2012 until December 2014.

13 Q. March 2012 till December did you say?

14 A. December 2014.

15 Q. Okay. So you were working, you were

16 dancing at the King of Diamonds, is that correct?

17 A. Correct.

18 Q. And you started March of 2012?

19 A. Well, I originally got hired in September

20 of 2011, but it was just for an event and I didn't

21 really start working until March. So on the record,

22 March 2012 is when I officially started really

23 working.

24 Q. And again your claim for damages is from

25 March of 2012 according to you and through December

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1 of 2014 --

2

 A. Correct.

3

 Q. -- is that right?

4

 A. Yes sir.

5

 Q. Okay. So tell me in March of 2012 till

6 December of 2014, what were you doing at the King

7 of Diamonds?

8

 A. I was an entertainer.

9

 Q. Okay. A nude dancer?

10 A. You can see that.

11 Q. And you said that you were not paid

12 minimum wages, is that what I heard you say?

13 A. I was not.

14 Q. Okay. And you said you had to pay.

15 A. Yes sir I did.

16 Q. Explain that to me.

17 A. Can I just speak freely?

18 Q. Yes.

19 A. Okay. I'm not one of the girls that have

20 fake accessories, so I had to get there a little

21 bit earlier. So I would get there normally when I

22 open like I'll say 8:30ish when security got there,

23 and it started like a hundred dollars and it'd go

24 up each hour that you would come. So minimum I

25 will pay like a hundred dollars to walk in the

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1 building.

2

 Q. And that's on each day that you danced

3 you're saying --

4

 A. Yes sir.

5

 Q. -- between the same time frame?

6

 A. Yes sir. I always got there early. Because

7

I have stretch marks, so I had to get spray tan

8 done, I had to get makeup done, I had to get hair

9 done. They would not let you walk out the dressing

10 room unless you were done up. They were sitting

11 right back in there. So yes sir, I would get there

12 early to make sure everything was ready so I can

13 get on the floor.

14 Q. So that would be --

15 MS. GABBE: I'm sorry.

16 BY MR. BRODSKY:

17 Q. -- 8 --

18 A. 8:30.

19 Q. 8:30.

20 A. I stayed from 8:30 when they opened till

21 the time they closed.

22 Q. 8:30 a.m. or p.m.?

23 A. P.m.

24 Q. Did I hear you also -- can I continue or

25 are you -- are you ready? Can I go, continue or

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1 what with the deposition?

2

 MS. GABBE: Well, they're turned off. I'm

3

 not using the phones. I just wanted to make

4

 sure they're --

5

 MR. BRODSKY: So the answer is yes, I can

6

 continue?

7

 MR. GABBE: You may continue --

8

 MR. BRODSKY: Thank you.

9

 MS. GABBE: -- and -- sorry, I did not

10 think of the phones. It's been a morning.

11 BY MR. BRODSKY:

12 Q. Okay. So --

13 MS. GABBE: It's my fault.

14 BY MR. BRODSKY:

15 Q. Did I hear you say that in addition to the

16 payment of the hundred dollars, that you had to pay

17 something else --

18 A. Yes.

19 Q. -- when you danced?

20 A. Yes sir.

21 Q. What was that?

22 A. I had to pay the hairdressers. I had to

23 pay the makeup artists. They had special rooms

24 where they had hairdressers and special rooms for

25 the makeup artists. Then I also had to get spray

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1

tan and the house mom had to spray tan.

2

 Q. So you had to pay all these people money?

3

 A. Yes sir.

4

 Q. How much did you pay each individual?

5

 A. It's different. Ballpark, light face would

6

start at like $25.

7

 Q. Who?

8

 A. A light face meaning light makeup. That

9

started at $25, but it can go up to at least 80.

10 Like if you wearing jewels and eyelashes and all

11 that stuff it can go up to $80.

12 Q. All right.

13 A. So between 25 and $80 on the makeup.

14 Q. All right.

15 A. On the hair, the hair always started at

16 $50.

17 Q. All right.

18 A. It depends on what you had done, but it

19 always started at 50.

20 Q. Okay.

21 A. And the spray tan it was $10 each time I

22 used it.

23 Q. Did you have to pay anything else?

24 A. At the end of the night. We talking about

25 walking in right now. That's just walking in the

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1 door.

2

 Q. Spray was $10?

3

 A. Yes sir.

4

 Q. Anything else that you had to pay walking

5

in the door?

6

 A. Nope, that's it.

7

 Q. And these payments that you just

8

identified were each day that you worked?

9

 A. Yes sir.

10 Q. And were they mandatory payments?

11 A. Yes sir.

12 Q. Let me explain to you what I mean by that.

13 Could you have done your own makeup if you chose

14 to?

15 A. Yes, but I would not have been able to

16 work. If it wasn't to their standard you're not

17 getting on their floor.

18 Q. Did you ever try to do your own --

19 A. I did.

20 Q. Remember we're not going to talk over each

21 other.

22 A. I'm sorry, I apologize. He told me this

23 morning, I'm sorry.

24 Q. Did you ever do your own makeup and then

25 try to dance and it was unacceptable, is that what

Page 14

1 you said?

2

 A. Yes sir.

3

 Q. You're telling me that it was the policy

4 of the King of Diamonds that you had to have your

5 makeup done at the King of Diamonds?

6

 A. You didn't have to have it done there, but

7

you had to have their standard of what they wanted

8

you to look like basically. One of the ladies who

9 was their main makeup artist, she would let some

10 girls come to her house. They were going to be all

11 in the makeup room too long. So some girls were

12 going to her house and then some girls would get

13 their makeup done at the club. It was a standard,

14 you had to have a certain I would say model look.

15 You had to have that makeup done correctly.

16 Q. Could you have done it yourself if you

17 chose to?

18 A. I tried, it was unacceptable.

19 Q. So your testimony is that it was mandatory

20 that your makeup be done by a makeup --

21 A. By a professional. Sorry, sorry, I

22 apologize. By a professional.

23 Q. A makeup artist through the King of

24 Diamonds --

25 A. Yes sir.

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1

 Q. -- to be acceptable, is that what you're

2

telling me?

3

 A. Pretty much, yes sir.

4

 Q. What does pretty much mean?

5

 A. She would do it at the club or she would

6 do it at her house. So it's still the same lady,

7

she works for the club. So that's what I mean by

8 pretty much. So yeah, I had to have my makeup done

9 by professionals.

10 Q. That was involved with the King of

11 Diamonds?

12 A. Yes sir.

13 Q. And that was mandatory?

14 A. Yes sir.

15 Q. What about the hair?

16 A. Hair was as long as you look good, but if

17 you didn't look good you had to get your hair done.

18 Q. Did you ever have your hair done before

19 walking in there by someone unrelated to the King

20 of Diamonds?

21 A. Yes sir I have.

22 Q. And was there an issue with that?

23 A. Yes sir. They wanted me to get curls

24 instead of having straight the way I had it. So I

25 had to go and pay $25 for the curls.

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1

 Q. I thought you just told me before --

2

 A. No, it starts at 50.

3

 Q. Right.

4

 A. All I got was the curl. The curl -- it's

5

like -- it's hard to explain if you're not a woman,

6 but certain little small things, they'll do little

7

small things, but if you want your head done it

8

starts at 50. So if you want like a flat iron,

9

that's like 15, $10. If you want curls it was $25.

10 You need some gel or something, you know, they'll

11 charge you a little tip. It's little small minor

12 things, but getting your actual head done started

13 at 50.

14 Q. So are you saying that it was

15 predominantly the curls that you got done there

16 with regard to your hair?

17 A. No, no, no, no, no. Going back to the

18 original question, you actually said did I ever get

19 my hair done outside of King of Diamonds and I

20 still had to get it fixed. That was the question

21 you asked me. I said yes, they asked me to get

22 curls instead of leaving it straight.

23 Q. Okay. So if you had your hair done or you

24 did your own hair before you walked into the King

25 of Diamonds you had to pay $25 each time to get

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1 your head curled?

2

 A. No sir. If it looked good and you're fine

3

they didn't bother you, but if it wasn't up to

4

standard they're going to send you to send you in

5

their with the hairdresser. You have to go and get

6

your hair fixed before you can get on the dance

7

floor.

8

 Q. Okay. So tell me the percentage of time

9

that you danced at the King of Diamonds that you

10 had to pay $50 for your hair.

11 A. I would say maybe a good, maybe a good six

12 times, because I'm not really from here and I

13 didn't know too many hairdressers in Miami, so I

14 had to go to them. So maybe a good six times, yes

15 sir.

16 Q. So during March of 2012 to December of

17 2014?

18 A. All the way to the 14th, yes sir.

19 Q. Six times you paid $50?

20 A. Or more, yes sir.

21 Q. Okay. How many times did you have to pay

22 to get your hair curled during that time frame?

23 A. It's been so long. I'm just going to say

24 that one because that's the only incident that I

25 actually remember. Because I thought my hair looked

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1 gorgeous straight, but they want it curled. So I

2

remember that. So I'm just going to say one.

3

 Q. One time?

4

 A. Yes sir.

5

 Q. And then spray, $10?

6

 A. Every single time.

7

 Q. Every time?

8

 A. Every single time, period. Because I have

9

stretch marks. I had twins. So if they're not that

10 visible -- but they said if I spray tan then I can

11 work. So every single time, and I worked six days a

12 week.

13 Q. Okay.

14 A. I'm sorry. This hair keeps touching back,

15 it's itchy.

16 Q. Are there any other fees that you had to

17 pay other than those that you just identified when

18 you walked in?

19 A. Walking in, that was the only fees.

20 Q. Are there any other fees that you had to

21 pay at all --

22 A. Walking out.

23 Q. -- while dancing? Let me finish the

24 question please.

25 A. I'm sorry. I apologize.

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1

 Q. Are there any other fees that you had to

2 pay while dancing at the King of Diamonds?

3

 A. I had to pay fees walking out of the King

4 of Diamonds.

5

 Q. Tell me about how you had to pay those

6

fees.

7

 A. You had pay the DJ. You had to pay the

8 house mom. You had to pay security, and then the

9

club took 10% of your earnings.

10 Q. DJ --

11 A. House mom, security and a 10%.

12 Q. 10% was what?

13 A. 10% of whatever you made.

14 Q. Okay. How much did you have to pay the DJ?

15 A. I believe it was $25. I believe it was 25.

16 Q. How about the house mom?

17 A. House mom, she always asked for tips on

18 the side. I'm trying to remember. I'll say 25 also.

19 The security fee was what was high because you had

20 to pay each and every security.

21 Q. How much was that?

22 A. I would say 50 total.

23 Q. On average?

24 A. On average every night.

25 Q. Tell me about the 10%.

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1

 A. 10% is whatever you made. Whatever you

2 made they're taking 10% of it.

3

 Q. How did you make money while dancing at

4

the King of Diamonds?

5

 A. On the stage, table dances and lap dances.

6 Sometimes on the floor, because they did this thing

7 on Mondays called Monday Night Boxing, and they

8 would do what was called Rain Money. The people,

9

I'm sorry, the customers, they would just throw

10 money everywhere, and you could just be standing on

11 the floor sometimes and end up with a pile of

12 money. So stage, table dances, lap dances and Rain

13 Money on the floor.

14 Q. Okay. How much did you earn from the money

15 that you just described that you received on

16 average during March of 2012 till December 2014?

17 A. Are you asking nightly or the whole

18 amount?

19 Q. That's a very good question, and I'll

20 leave it to you to answer however you would like.

21 A. Okay. Rephrase the question one more time.

22 Q. What did you earn -- let's do it this way,

23 let's start from March of 2012 which is when you

24 said you started --

25 A. Umm-hmm.

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1

 Q. -- to December --

2

 A. I'm sorry. Yes sir.

3

 Q. -- till December 31st of 2012. Can you

4 give me a realistic approximation of the amount of

5 money that you received while dancing at the King

6 of Diamonds during that time?

7

 A. I apologize, but I literally cannot. It

8 was some nights we were making bank, then some

9 nights you didn't make any money.

10 Q. What's the most that you recall ever

11 making in one night?

12 A. I made 5,000 in one night, yes.

13 Q. Can you tell me on average what you made a

14 night?

15 A. At least a thousand. At least a thousand.

16 Q. Okay.

17 A. Yeah.

18 Q. So you did pretty well over there --

19 A. Yes sir.

20 Q. -- during the time that you worked there,

21 right?

22 A. Yes sir.

23 Q. What happened in December of 2014 that

24 caused you to no longer dance at the King of

25 Diamonds?

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1

 A. I became pregnant with my five year old

2 son now and became a real mother. It changed my

3 whole life around. I'm in college, I got a job,

4 stop doing all of that. So that's what changed my

5

life.

6

 Q. So since December of 2014 through the

7 present you have not danced anywhere else?

8

 A. No sir.

9

 Q. Prior to dancing at the King of Diamonds

10 beginning in March of 2012 did you dance anywhere?

11 A. Yes sir. I was a traveling entertainer,

12 but the King of Diamonds was my main club that I

13 worked at.

14 Q. Were you allowed to work at other clubs

15 while dancing at the King of Diamonds?

16 A. They never said anything to me, so yes

17 sir.

18 Q. Okay. Did you set your own schedule?

19 A. Yes and no.

20 Q. Explain please.

21 A. Yes, because you work when you want to

22 work because you have to pay to work, period, you

23 have to pay to work.

24 Q. Okay.

25 A. No, because you have to work at least two

Page 23

1

slow days. Basically if you wanted to be considered

2 a house girl you had to work two slow days. Say

3

like the main, they had to work the Monday Night

4 Boxing on Mondays, you will have to pay extra. You

5 have to pay like 350 or something to work if you

6 didn't work those two slow days. So not really

7 making your own schedule because you have to work

8

two slow days, but you are making your own schedule

9 because you get to pick the two slow days you want.

10 Make sense?

11 Q. And I'm surmising by what you're telling

12 me that if you decided you didn't want to work slow

13 days you could work the better days, but you would

14 just have to pay more to walk in the club?

15 A. Yes sir, correct.

16 Q. So how much money are you seeking by way

17 of damages in this case?

18 A. From wages it's about a good 57,000. Total

19 about 280. No, no. I'm sorry. About 240. About

20 240,000 rounded off, yeah, because I worked there

21 for a while and I never received a paycheck, never

22 received a paycheck.

23 Q. So are you including in the number that

24 you just gave me, in addition to minimum wages

25 these other fees that you paid?

Page 24

1

 A. No, because those were the rules of the

2 club. I'm only seeking what's owed to me and that's

3

the wages.

4

 Q. So the only thing that you're seeking by

5 way of this case is minimum wages?

6

 A. Correct.

7

 Q. Okay. Tell me if you have ever met Teri

8 Galardi.

9

 A. Not to my knowledge. If I have she

10 probably was at, what they used to call them, I

11 haven't danced in so long, it was like a meeting we

12 will have. They would have like a meeting with all

13 the girls. I'm not sure if she's ever there, but I

14 don't believe so.

15 Q. Let's go back to some of the ground rules.

16 I'm asking what you know.

17 A. Okay.

18 Q. To your knowledge --

19 A. No.

20 Q. -- have you ever met Teri Galardi?

21 A. Personally, face-to-face, no.

22 Q. Have you ever spoken to her?

23 A. No.

24 Q. Have you ever seen her? Strike that. Let

25 me do it another way. Have you ever seen her during

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1

the course of March 2012 to December 2014?

2

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

3

 Q. Okay.

4

 A. -- because I'm -- honestly I don't even

5

remember.

6

 Q. You saw her yesterday during the

7 mediation.

8

 A. Yes, correct.

9

 Q. Is it fair to say that's the first time

10 you really saw her?

11 A. No.

12 Q. When would you have seen her prior to

13 that?

14 A. The other mediation we had prior to that.

15 MR. GABBE: She's correct.

16 BY MR. BRODSKY:

17 Q. Were you the one yesterday talking about

18 another mediation?

19 A. No, that wasn't me.

20 Q. Okay. I'm trying to understand what

21 mediations that you just talked about.

22 A. I can't remember the date for a fact, but

23 all of us were on a Zoom, and we talked about going

24 to settlement then and trying to, you know, get the

25 case settled and she didn't want to settle.

Page 26

1

 Q. Was that in this case?

2

 A. Yes, this same case.

3

 MS. GABBE: In May. If I can interrupt --

4

 MR. BRODSKY: No, I'm not asking you to

5

 answer the question.

6

 THE WITNESS: But yes sir, this case.

7 BY MR. BRODSKY:

8

 Q. Okay.

9

 A. And it happened this year. It actually

10 happened twice. The first time it was messing up.

11 The second time it actually worked, because I was

12 sitting there for about an hour drinking coffee. I

13 don't even like coffee, but I was drinking coffee

14 to stay awoke. So yes sir.

15 Q. Okay. So prior to that mediation was that

16 the, in other words, was that the first time you

17 actually saw her?

18 A. To my memory?

19 Q. Yes.

20 A. Yes sir.

21 Q. Okay. Is there anything that would refresh

22 your recollection otherwise?

23 A. Pictures from the past.

24 Q. Like what?

25 A. We took a lot of pictures at the King of

Page 27

1 Diamonds. We took a lot of pictures. So if she's in

2 one of those pictures, I was like yeah, I remember

3

that night.

4

 Q. So, in other words, if you saw a picture

5 where you were dancing at the King of Diamonds and

6 you saw her in the picture, that would be the way

7 you would know?

8

 A. Yes sir.

9

 Q. But short of that the answer is no, is

10 that right?

11 A. I'm one of those people, I'm bad with

12 names but great with faces. So yeah, I have a

13 photogenic memory. If you can show me a photo14 graph, I'm like, Yeah, I remember that night, but

15 off the top of my brain, no.

16 Q. And if you didn't see a picture like

17 you've just described your answer would be no?

18 A. My answer would be the mediations, that's

19 the only time.

20 Q. Okay, we're on the same page. Do you know

21 if Teri Galardi owned the King of Diamonds during

22 March 12th, March 2012 to December of 2014? Strike

23 that. During March of 2012 through December of 2014

24 did you know if Teri Galardi did or didn't own the

25 King of Diamonds?

Page 28

1

 A. All I remember from that time is the last

2 name, because we had a meeting and they were

3

telling us that something was happening with the

4

family, and they gave out these papers and were

5

saying, you know, it's on you if you want to sign

6

it, it's on you if you don't. I can only put it

7

like that because that's the only way that I

8

remember, but I remember the last name. The first

9 name I don't.

10 Q. Okay. So it could have been Jack Galardi?

11 A. It could have been any Galardi. I just

12 remember the last name.

13 Q. All right. Do you know what, if anything,

14 Teri Galardi had to do with the King of Diamonds

15 during March of 2012 through December of 2014?

16 A. From the rumors, and I hate to say the

17 rumors --

18 Q. No, no. From your own knowledge I'm

19 asking.

20 A. Okay. Well, from my own knowledge from

21 being an employee inside the club she was taking

22 responsibility because we were told that the owners

23 were sick. They talked a lot in the club about what

24 was going on. The girls, the security, the people

25 that worked there, the staff, like the waitresses

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1 and stuff, some of the people that worked there

2 actually knew everybody personally. I didn't

3 because I'm not from here, but they told us that

4

the owner was sick or whatever and his daughter was

5

stepping in. I never knew the name, I just knew the

6

last name.

7

 Q. Do you know when that was?

8

 A. I don't remember, I'm sorry.

9

 Q. Okay.

10 A. A lot of gossip happens in strip clubs.

11 Q. Putting aside gossip, of your own

12 knowledge.

13 A. Sorry for saying gossip. Like talking

14 happened. That is from my knowledge because I was

15 told that when I was working at the club.

16 Q. You were told that by who?

17 A. From the employees that worked at the club

18 with me --

19 Q. Can you name --

20 A. -- that the owner was sick and that their

21 daughter was taking over. One of the main -- I

22 can't talk today I'm so hungry. One of the main

23 people that told me that was the black lady that

24 worked at the front door. I don't know her govern25 ment name, but we call her Tan or Tangie Tan somePage 30

1

times.

2

 Q. All right. Do you know when the owner

3 became sick? You don't know that, right?

4

 A. Like I said, we had a meeting about it and

5

then everybody talked about it, but the exact

6 dates --

7

 Q. But you don't know when?

8

 A. I don't.

9

 Q. Do you know if it was in 2012?

10 A. I don't remember.

11 Q. Do you know if it was in 2013?

12 A. I don't remember.

13 Q. Do you know if it was in 2014?

14 A. I literally don't remember.

15 Q. Putting aside what you heard do you have

16 any firsthand knowledge of what Teri Galardi's

17 involvement in the King of Diamonds was on a daily

18 basis?

19 A. To my knowledge she was the overseer of

20 the club. Whatever her father consigned to do she

21 did it to my knowledge.

22 Q. Okay. And where do you get that knowledge

23 from?

24 A. From working inside the club.

25 Q. From hearsay, from other people talking?

Page 31

1

 A. Like I said, everybody knew what was going

2 on.

3

 Q. Okay. And you don't know when that was?

4

 A. I can't remember the dates. I'm 32. I was

5

in my 20s. I drunk a lot of Tequila back then. I

6 don't remember, I'm sorry. I'm just being honest.

7

 Q. When you say took over can you define what

8

that means?

9

 A. What you mean?

10 Q. You said at some point you heard that Teri

11 Galardi took over because the owner was sick.

12 A. Meaning she -- what is the word. I don't

13 want to say overseer, but what is the word. It's

14 like when your wife or your husband is sick and

15 they give you power of attorney, there we go. It's

16 like she had the power of attorney over it. Like

17 she had the okay, she had the say so.

18 Q. Okay. Do you know what specifically if

19 anything she did?

20 A. The wages part because all that had

21 changed. They started giving us papers and stuff to

22 sign and stuff. When I originally got hired they

23 took a photo, I'm sorry, they took a copy of my

24 driver's license and they had me to sign an

25 independent contractor license agreement.

Page 32

1

 Q. Okay.

2

 A. And then after the -- I'm so hungry,

3 excuse me. After being told about the owner being

4

sick, that's when they started passing out papers

5

saying that we can be paid and we can get tips and

6 all that and explaining that to us, but that didn't

7 happen until she stepped in.

8

 Q. Explain to me, when you say you could get

9 paid and you can tips --

10 A. Meaning that we can get a paycheck while

11 working as an entertainer.

12 Q. Okay. And did you choose to get a pay13 check?

14 A. I did, but I never got it.

15 Q. So you actually told somebody you wanted

16 to --

17 A. They gave us documents. It was papers for

18 us to sign and I signed it. What happened to that

19 paperwork I have no idea.

20 Q. So you signed paperwork where the King of

21 Diamonds gave you the option --

22 A. Yes sir.

23 Q. -- of receiving a paycheck for wages --

24 A. Correct.

25 Q. -- and to keep your tips as well, is that

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1 what you said?

2

 A. Correct. I can't remember off the top of

3 my head, but -- because it was a lot of words in

4

the document, but it was basically like doing the

5 10% at the end of the night. You know how

6 waitresses that work at a restaurant, it was the

7 balancing of the wages is how they were explaining

8

it to us. You know how waitresses, they get a pay9

check. It might not be much, but they get a pay10 check and they still get to keep their tips. That's

11 how it was explained to us.

12 Q. Like to pool the tips together and then

13 split them, is that what you're kind of saying?

14 A. No. When you're a waitress at a restaurant

15 you keep every tip you get, but at the end of the

16 week you still get a paycheck. It might be like $5,

17 but you still get a paycheck.

18 Q. In other words, you were given the option,

19 at least paper-wise --

20 A. Correct.

21 Q. -- to be paid a minimum wage as a tipped

22 employee?

23 A. Correct.

24 Q. And that was under Teri Galardi's, that

25 you believe Teri Galardi's watch?

Page 34

1

 A. Correct.

2

 Q. All right. And you say you filled out that

3 paperwork, but you never received a paycheck?

4

 A. Never received a paycheck, but I did fill

5 out the paperwork, because like I said it was at a

6

club meeting we had.

7

 Q. Okay.

8

 A. I believe Disco Rick was the one that was

9 over that meeting that day. He was the man that was

10 on a microphone all the time.

11 Q. And you don't know when that meeting was

12 then?

13 A. It was in -- I have the screenshot.

14 Because I was taking pictures, I was bored. October

15 4, 2012. It says me and my friend (indiscernible)

16 at KOD meeting October 4, 2012, and that's from my

17 Instagram.

18 Q. Okay. Would you be kind enough to give a

19 copy of that picture or whatever that is that

20 you're looking at, to your lawyer who can then give

21 it to us?

22 MS. GABBE: Yeah. I mean I'm not under23 standing in 2012 --

24 THE WITNESS: Hmm?

25 MS. GABBE: I'm not understanding --

Page 35

1

 THE WITNESS: No. We used to have meetings

2

 all the time.

3

 MS. GABBE: Right. Her name is Xena Fox,

4

 that was her stage name. We got hired at the

5

 same time. We were at the meeting together.

6

 MR. GABBE: My vision is --

7

 THE WITNESS: It's okay.

8

 MR. GABBE: Which one was you?

9

 THE WITNESS: That's me with the hat and

10 that's Xena Fox.

11 MR. GABBE: Okay. And that was at a

12 meeting.

13 THE WITNESS: That was at a meeting on, it

14 says October 4th.

15 MR. GABBE: And was there any particular --

16 MR. BRODSKY: Excuse me -- no, no, no, no,

17 no. This is not your deposition. All I'm

18 asking her is if she would be kind enough to

19 give you a copy of what she's looking at so

20 that you can give it to us.

21 MS. GABBE: Yeah.

22 MR. BRODSKY: That's all I'm asking.

23 MR. GABBE: I mean you can have the

24 pictures, that's fine.

25 MR. BRODSKY: That's all I'm asking.

Page 36

1 BY MR. BRODSKY:

2

 Q. Are there any other pictures that you

3 possess that you think are relevant to your claim?

4

 A. When I changed my life I kind of deleted a

5

lot of them, because I was like that's the past,

6 but I have the meeting one and then I have the one

7

that I had a KOD pole burn. They had a 50 inch pole

8 and my leg got caught and I had a burn on it, and

9

that's on September 29th of 2012. 2012 was my year.

10 I was there a lot.

11 Q. Okay. And that would be the extent of the

12 pictures that you have?

13 A. Yeah, that's all I have. Because I deleted

14 the rest, and I have no problem with giving them to

15 her.

16 Q. When do you think you can give them to

17 her?

18 A. She can get it as soon as we get done with

19 this.

20 MR. BRODSKY: Beautiful. And then would you

21 kindly just forward them to us when you get

22 done?

23 MR. GABBE: Well, I mean -- okay. Allow me

24 to explain.

25 MR. BRODSKY: I'm sorry?

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1

 MS. GABBE: I don't know what I'm going to

2

 do with the pictures. I'm not even sure how

3

 I'm going to receive them. My knowledge of

4

 technology is less than -- it's not good. So I

5

 mean if we can print it here and you could

6

 have a paper copy --

7

 MR. BRODSKY: If I give you an e-mail

8

 address right now, can you e-mail it to that

9

 e-mail address?

10 MR. GABBE: And copy me on my --

11 THE WITNESS: I did it again. Yes sir.

12 MS. GABBE: And copy me and that would be

13 acceptable, because I'm not techy.

14 MR. BRODSKY: All right. So here. So do it

15 right now please.

16 THE WITNESS: So if you can write it down I

17 can get it done quicker.

18 MR. BRODSKY: This is all one word, okay?

19 I'm writing it separately.

20 THE WITNESS: Okay.

21 MR. BRODSKY: And what is your e-mail

22 address? You got about six of them.

23 MR. GABBE: astridgabbe@aol.com.

24 MR. BRODSKY: So why don't you take a

25 moment to do that and that way we can verify

Page 38

1

 that it comes through --

2

 THE WITNESS: Okay.

3

 MR. BRODSKY: -- on both of those. While

4

 you're doing that we're going to take a quick

5

 break.

6

 THE WITNESS: Okay.

7

 (Thereupon a break was taken)

8 BY MR. BRODSKY:

9

 Q. All right. I didn't ask you this, what is

10 your current address?

11 A. Mailing address or where I live?

12 MR. TOBIN: Where you live.

13 THE WITNESS: 1345 Turkey Run Lane.

14 BY MR. BRODSKY:

15 Q. Is that separate words?

16 A. Yes sir.

17 Q. Turkey --

18 A. Run Lane.

19 Q. R-u-n?

20 A. (No verbal response).

21 Q. R-u-n, run, like run?

22 A. Yes.

23 Q. Okay.

24 A. Memphis, Tennessee 38116.

25 Q. And I'd also ask you for your phone

Page 39

1 number. We will not contact you by phone regarding

2

this case, but maybe at some point in the future,

3

if we need to contact you on an unrelated matter,

4 we'd like to be able to do so.

5

 A. Okay. 901-364-5262.

6

 MR. BRODSKY: Sorry. Excuse me, I forgot

7

 your water.

8

 THE WITNESS: Thank you so much.

9

 (Thereupon a break was taken)

10 BY MR. BRODSKY:

11 Q. Back on the record.

12 A. Okay.

13 Q. You talked about your allegation that you

14 danced from March 2012 to December 2014. Other than

15 your testimony do you have any other documentation

16 which would substantiate that?

17 A. I filed taxes as self-employed.

18 Q. For what years?

19 A. Every year that I danced.

20 Q. Okay.

21 A. I've always filed taxes.

22 Q. And on those taxes did you I'm sure deduct

23 those expenses that you had to pay?

24 A. Yes sir.

25 Q. And just so we're clear, we're talking

Page 40

1 about the makeup, the hairspray, the DJ, the house

2 mom, security, and the 10% you deducted from your

3

taxes as being self-employed, right?

4

 A. Including the travel expenses also.

5

 Q. Okay. And let me ask you this, did you

6 declare all of the income or tips that you

7

received, excuse me, not income, tips that you

8

received while dancing at the King of Diamonds on

9 your tax returns?

10 A. To my knowledge, yes.

11 Q. Okay. How were you paid?

12 A. Cash.

13 Q. And you declared all that cash on those

14 tax returns?

15 A. I used to have like -- what is that thing

16 called? I can't remember nothing. I think it's the

17 baby. I'm just having memory loss. It was like a

18 log. My uncle does taxes, and he showed me how to

19 log in my cash and keep up with it, because he's

20 the one that did my taxes for me. He did every year

21 my taxes. So I don't remember what the log is

22 called. I'm pretty sure he might still have it. I'm

23 not for sure.

24 Q. Would you kindly -- do you have copies?

25 The only tax returns I'm interested in are 2012,

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1 2013 and 2014.

2

 A. The IRS has them, but I can request them.

3

 Q. No. You don't have them?

4

 A. Probably at home.

5

 Q. Would you double-check --

6

 A. When I get home.

7

 Q. -- and if you have them, send them to your

8

lawyer who will then send them to us.

9

 A. Okay.

10 Q. And then you can contact your uncle who

11 does taxes. He may have them?

12 A. It's a family thing, but I will look

13 through my records. If I don't have it in my

14 records I can get it from the IRS.

15 Q. And you will do that?

16 A. Yes sir.

17 MR. GABBE: May I interject? I thought you

18 had all the tax information from us.

19 MR. BRODSKY: Not on her.

20 MR. GABBE: No?

21 MR. BRODSKY: (No verbal response).

22 THE WITNESS: May I say something?

23 MR. BRODSKY: Certainly.

24 THE WITNESS: You should have it, because I

25 told they can pull my tax information like

Page 42

1

 last year. So you should have it. If not I

2

 will give them a call at the office. Because I

3

 gave that okay for them to contact the IRS and

4

 pull my tax --

5 BY MR. BRODSKY:

6

 Q. But you seem to think you may have them.

7

 A. I might have them because I try to keep up

8 with stuff like that. My mom told me that's some9

thing you should always keep up with.

10 Q. Good for you. And she's right, she gave

11 you good advice.

12 A. So I might have them myself, but all I'm

13 saying is, on my attorney's behalf I gave them the

14 okay to pull it from the IRS. So they should have

15 that also.

16 MR. BRODSKY: All right. Let's take --

17 we're just about done.

18 THE WITNESS: Okay.

19 MR. BRODSKY: Let's take a minute, all

20 right?

21 (Thereupon a break was taken)

22 BY MR. BRODSKY:

23 Q. Are you aware that the club, King of

24 Diamonds, was sold in July of 2014?

25 A. I'm aware that the club was sold, but I

Page 43

1 don't remember the actual date, because now the

2

club is franchised.

3

 Q. You may think that, but regardless I'm

4 not, that's not what I'm talking about. I'm talking

5 about, I'm representing to you -- strike that. You

6 know the club was sold, right?

7

 A. I know it was sold and I know it was

8

franchised, because I have a partner that owns one

9

in Dallas, but go ahead.

10 Q. All right. Forget about the franchise for

11 now.

12 A. Okay.

13 Q. I'm talking about when it was sold.

14 A. Correct.

15 Q. You know it was sold, right?

16 A. Correct.

17 Q. And you continued dancing after the club

18 was sold initially?

19 A. Correct, because they were still open.

20 Q. And there was new ownership that came in

21 when it was sold?

22 A. Not to my knowledge, because the staff was

23 still the same. You still had the same people at

24 the front door, you had the same security, you had

25 the same guy on the microphone, you had the same

Page 44

1 DJ. So I didn't really notice a difference being an

2 employee because the staff was still the same.

3

 Q. Okay. If it turns out that Teri Galardi

4 sold the King of Diamonds in July of 2014, would

5 you agree with me that your claim against her, Teri

6 Galardi, would have ended when she sold the club in

7 December, excuse me, in July of 2014?

8

 A. Legally that makes sense. If she's no

9

longer the owner then she's not responsible for it.

10 Q. Okay.

11 MR. GABBE: Objection on one day. There is

12 no question --

13 MR. BRODSKY: Just object to form.

14 MS. GABBE: There's no question as far as

15 that's when our claim ends.

16 MR. BRODSKY: Well, your client testified

17 that she's seeking damages through December of

18 2014, that was her testimony. That's why I

19 asked the question.

20 THE WITNESS: Right.

21 MR. GABBE: Oh, sorry.

22 MR. BRODSKY: All right.

23 THE WITNESS: Correct.

24 MS. GABBE: Hold on.

25 MR. BRODSKY: Give me one second.

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1

 MS. GABBE: Let me look at this.

2

 MR. BRODSKY: Let's go outside.

3

 (Thereupon a break was taken)

4 BY MR. BRODSKY:

5

 Q. All right. Just a couple more questions

6 and we're done.

7

 A. Can we go back to your last question?

8

 MS. GABBE: We clarified what was going on,

9

 because the December -- we filed for 26 hours,

10 but she continued to work on your other

11 people, so we didn't ask for it.

12 MR. BRODSKY: I'm fine for that.

13 MS. GABBE: So we're okay.

14 BY MR. BRODSKY:

15 Q. All right. So couple more questions and

16 we're done.

17 A. Okay.

18 Q. Can you tell me sitting here today the

19 approximate amount of income you declared on your

20 2012, '13 and '14 tax returns?

21 A. No I cannot sir.

22 Q. Okay. And earlier I asked you whether you

23 could dance at other clubs if you chose to and you

24 said you could, but you didn't.

25 A. No, I did. I was a traveling entertainer.

Page 46

1

 Q. I'm talking about while working at King of

2 Diamonds.

3

 A. Yes sir I did.

4

 Q. Oh, so you did work at the other clubs?

5

 A. Yes sir.

6

 Q. Tell me about the other clubs you worked

7 at.

8

 A. The main club that I worked at and that's

9

the reason why I did file self-employment was in

10 Birmingham, Alabama, and in Alabama you have to

11 have a (indiscernible) license. I had to go to the

12 courthouse and get what's called -- it wasn't a

13 vendor's license. What was it called. I can't

14 remember what the license was called, but you had

15 to renew it yearly and I was a licensed

16 entertainer. So that's how I filed my taxes. So it

17 was the club in Birmingham and it was King of

18 Diamonds. Those were the two clubs I worked at in

19 between each other.

20 Q. Okay. And you could have worked at other

21 clubs if you chose to, right?

22 A. Correct.

23 Q. Why did you limit it, your dancing, during

24 the time we're talking about, to dancing at the

25 King of Diamonds and the club you're talking about

Page 47

1

in Birmingham?

2

 A. Those were the two clubs to be in back in

3

those times.

4

 Q. Meaning you made the most money?

5

 A. That's where I made my money at, simple

6 and plain. That was the place to be, yes sir.

7

 Q. What was the name of the club in

8 Birmingham?

9

 A. The Palace Gentlemen's Club.

10 MS. GABBE: The what?

11 THE WITNESS: The Palace Gentlemen's Club.

12 There's a couple of girls that work, they came

13 to Diamonds. They came from the Palace with

14 me. There were a couple of girls. There were a

15 couple of girls that came from Birmingham that

16 worked at King of Diamonds with me.

17 MR. BRODSKY: We have no further questions

18 unless your lawyer does.

19 MR. GABBE: Actually I do not. It was

20 pretty straight forward. I'm fine.

21 MR. BRODSKY: You want to explain to her

22 about reading or waiving?

23 MR. GABBE: We're going to waive.

24

25

Page 48

1

 (Reading and subscribing waived.)

2

 (Thereupon the taking of the deposition was

3

 concluded.)

4

5

 - - -

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

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1

 CERTIFICATE OF OATH

2

3 STATE OF FLORIDA

4 COUNTY OF MIAMI-DADE

5

6

7

 I, the undersigned authority, certify that

8 MARLEKA WILLIAMS personally appeared before me and

9 was duly sworn.

10

11

12 WITNESS my hand and official seal this 20th

13 day of August 2021.

14

15

16

17

18

19 JEFFREY M. GOLDSTEIN

20 Notary Public - State of Florida

21 My Commission Expires: 02/29/24

22 Commission No. GG 955442

23

24

25

Page 50

1

 REPORTER'S DEPOSITION CERTIFICATE

2

3

4 STATE OF FLORIDA

5 COUNTY OF MIAMI-DADE

6

7

8

 I, JEFFREY M. GOLDSTEIN, Registered

9 Professional Reporter, certify that I was

10 authorized to and did stenographically report the

11 deposition of MARLEKA WILLIAMS; that a review of

12 the transcript was not requested; and that the

13 transcript is a true and complete record of my

14 stenographic notes.

15 I further certify that I am not a

16 relative, employee, attorney, or counsel of any of

17 the parties, nor am I a relative or employee of any

18 of the parties' attorney or counsel connected with

19 the action, nor am I financially interested in the

20 action.

21

22 DATED this 31st day of August 2021.

23

24

25 JEFFREY M. GOLDSTEIN, R.P.R.

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A

a.m 1:18,18 3:8,10

10:22

able 13:15 39:4

acceptable 15:1

37:13

accessories 9:20

action 50:19,20

actual 16:12 43:1

addition 11:15 23:24

address 3:18,25 37:8

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advice 42:11

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agreement 3:7 31:25

ahead 43:9

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allegation 39:13

allow 6:1 36:23

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amount 20:18 21:4

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26:5 27:9,17,18

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3:22 13:22 14:22

18:25 21:7

APPEARANCES 2:1

appeared 49:8

approximate 45:19

approximately 3:10

approximation 21:4

arrested 7:6,13,18

arrived 3:9

artist 14:9,23

artists 11:23,25

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asked 16:21,21 19:17

44:19 45:22

asking 6:5,7,7 20:17

24:16 26:4 28:19

35:18,22,25

ASTRID 2:2,4

astridgabbe@aol.c...

37:23

attorney 31:15,16

50:16,18

attorney's 42:13

August 1:18 49:13

50:22

authority 49:7

authorized 50:10

average 19:23,24

20:16 21:13

aware 42:23,25

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B

baby 40:17

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balancing 33:7

Ballpark 12:5

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basically 14:8 23:1

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Beach 3:19

Beautiful 36:20

beginning 22:10

behalf 2:4,10 42:13

believe 19:15,15

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better 23:13

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46:17 47:1,8,15

birth 7:1

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black 29:23

bored 34:14

bother 17:3

Boulevard 1:17 2:6

Box 2:3

Boxing 20:7 23:4

brain 27:15

break 38:5,7 39:9

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3:5,15 4:7 6:4 7:3,5

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call 24:10 29:25 42:2

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25:25 26:1,2,6 39:2

cash 40:12,13,19

caught 36:8

cause 1:25

caused 21:24

certain 4:14 14:14

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Certainly 41:23

CERTIFICATE 49:1

50:1

certify 49:7 50:9,15

changed 22:2,4 31:21

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charge 16:11

check 32:13 33:9,10

choose 32:12

chose 13:13 14:17

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claim 8:3,24 36:3

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claimant 3:8,9 4:17

claiming 8:4,11

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clear 6:12 39:25

client 44:16

closed 10:21

club 14:13 15:5,7

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coffee 26:12,13,13

college 22:3

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comes 38:1

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Commission 49:21,22

complete 50:13

concluded 48:3

connected 50:18

considered 23:1

consigned 30:20

contact 39:1,3 41:10

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continue 10:24,25

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continued 43:17

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contractor 31:25

copies 40:24

copy 31:23 34:19

35:19 37:6,10,12

Coral 1:17 2:7

correct 4:1,3 5:5,6,12

6:17,25 8:16,17 9:2

23:15 24:6 25:8,15

32:24 33:2,20,23

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44:23 46:22

correctly 14:15

counsel 3:8 50:16,18

COUNTY 49:4 50:5

couple 45:5,15 47:12

47:14,15

course 25:1

court 1:1 3:13 5:21

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courthouse 46:12

curl 16:4,4

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curls 15:23,25 16:9

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current 38:10

customers 20:9

D

D 2:16

daily 30:17

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damages 8:11,24

23:17 44:17

dance 13:25 17:6

21:24 22:10 45:23

danced 10:2 11:19

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39:14,19

dancer 9:9

dances 20:5,5,12,12

dancing 8:16 18:23

19:2 20:3 21:5 22:9

22:15 27:5 40:8

43:17 46:23,24

Dania 3:19

date 7:1 25:22 43:1

DATED 50:22

dates 30:6 31:4

daughter 29:4,21

day 10:2 13:8 34:9

44:11 49:13 50:22

Daya 5:11

days 18:11 23:1,2,6,8

23:9,13,13

de 1:17 2:6

deal 5:14

December 8:12,13,14

8:25 9:6 17:16

20:16 21:1,3,23

22:6 25:1 27:22,23

28:15 39:14 44:7,17

45:9

decided 23:12

declare 40:6

declared 40:13 45:19

deduct 39:22

deducted 40:2

Defendant 1:12 2:10

3:3

define 31:7

deleted 36:4,13

depends 12:18

deposition 1:20,25

3:6,11 4:10 6:22

11:1 35:17 48:2

50:1,11

described 20:15

27:17

Diamonds 8:16 9:7

14:4,5,24 15:11,20

16:19,25 17:9 19:2

19:4 20:4 21:6,25

22:9,12,15 27:1,5

27:21,25 28:14

30:17 32:21 40:8

42:24 44:4 46:2,18

46:25 47:13,16

difference 44:1

different 12:5

difficult 5:21

DIRECT 2:25 3:14

Disco 34:8

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Discussion 7:4

DISTRICT 1:1,1

DIVISION 1:2

DJ 19:7,10,14 40:1

44:1

document 5:13 33:4

documentation 39:15

documents 32:17

doing 9:6 22:4 33:4

38:4

dollars 9:23,25 11:16

door 13:1,5 29:24

43:24

double-check 41:5

dressing 10:9

drinking 26:12,13

driver's 31:24

drunk 31:5

duly 3:4,6 49:9

E

E 2:2,4,16

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earlier 9:21 45:22

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earnings 19:9

employee 8:5 28:21

33:22 44:2 50:16,17

employees 29:17

ended 44:6

ends 44:15

entertainer 9:8 22:11

32:11 45:25 46:16

ESQ 2:4,5,8,9

et 1:8 5:4

event 8:20

everybody 29:2 30:5

31:1

exact 30:5

EXAMINATION

2:25 3:14

Examinations 2:19

excuse 7:15 32:3

35:16 39:6 40:7

44:7

expenses 39:23 40:4

Expires 49:21

explain 8:3 9:16

13:12 16:5 22:20

32:8 36:24 47:21

explained 33:11

explaining 32:6 33:7

extent 36:11

extra 23:4

eyelashes 12:10

F

face 12:5,8

face-to-face 24:21

faces 27:12

fact 25:22

fair 25:9

fake 9:20

family 28:4 41:12

far 44:14

father 30:20

fault 11:13

fee 19:19

fees 18:16,19,20 19:1

19:3,6 23:25

file 46:9

filed 1:25 39:17,21

45:9 46:16

fill 34:4

filled 34:2

financially 50:19

fine 17:2 35:24 45:12

47:20

finish 18:23

first 3:4 5:12 25:9

26:10,16 28:8

firsthand 30:16

five 22:1

fixed 16:20 17:6

flat 16:8

floor 10:13 13:17

17:7 20:6,11,13

Florida 1:1,17,24 2:3

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follows 3:4

Forget 43:10

forgot 39:6

form 44:13

forward 6:1 36:21

47:20

Fox 35:3,10

frame 8:10 10:5

17:22

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franchised 43:2,8

freely 9:17

friend 34:15

front 5:8,9 29:24

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future 39:2

G

GABBE 2:2,4 4:5

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11:13 25:15 26:3

34:22,25 35:3,6,8

35:11,15,21,23

36:23 37:1,10,12,23

41:17,20 44:11,14

44:21,24 45:1,8,13

47:10,19,23

Gables 1:17 2:7

Galardi 1:11 5:4 8:4

24:8,20 27:21,24

28:10,11,14 31:11

44:3,6

Galardi's 30:16

33:24,25

gel 16:10

Gentlemen's 47:9,11

GERALD 2:5,9

getting 3:10 5:12

13:17 16:12

GG 49:22

girl 23:2

girls 9:19 14:10,11,12

24:13 28:24 47:12

47:14,15

give 3:21 5:24 21:4

31:15 34:18,20

35:19,20 36:16 37:7

42:2 44:25

given 33:18

giving 31:21 36:14

go 4:13 6:1 9:23

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going 4:22 6:15,16,17

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good 15:16,17 17:2

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gorgeous 18:1

gossip 29:10,11,13

govern- 29:24

graph 27:14

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ground 24:15

guidelines 4:14

guy 43:25

guys' 3:18

H

hair 10:8 12:15,15

15:15,16,17,18

16:16,19,23,24 17:6

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hairdresser 17:5

hairdressers 11:22

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hairspray 40:1

hand 49:12

happen 32:7

happened 21:23 26:9

26:10 29:14 32:18

happening 28:3

happens 29:10

hard 16:5

hat 35:9

hate 28:16

head 16:7,12 17:1

33:3

hear 10:24 11:15

heard 9:12 30:15

31:10

hearsay 30:25

held 7:4

high 19:19

hired 8:19 31:22 35:4

Hmm 34:24

Hold 44:24

Hollywood 2:3

home 41:4,6

honest 31:6

honestly 25:4

hour 9:24 26:12

hours 45:9

house 12:1 14:10,12

15:6 19:8,11,16,17

23:2 40:1

HOWARD 2:8

hundred 9:23,25

11:16

hungry 29:22 32:2

husband 31:14

I

idea 32:19

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inch 36:7

incident 17:24

including 23:23 40:4

income 40:6,7 45:19

independent 31:25

indiscernible 34:15

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individual 12:4

information 5:10

41:18,25

initially 43:18

inside 28:21 30:24

Instagram 34:17

interested 40:25

50:19

interject 41:17

interjection 5:23

interrupt 26:3

involved 15:10

involvement 30:17

iron 16:8

IRS 41:2,14 42:3,14

issue 15:22

it'd 9:23

itchy 18:15

J

J 2:5,9

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50:8,25

jewels 12:10

job 22:3

July 42:24 44:4,7

K

keep 5:14 32:25

33:10,15 40:19 42:7

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kind 33:13 34:18

35:18 36:4

kindly 36:21 40:24

King 8:16 9:6 14:4,5

14:23 15:10,19

16:19,24 17:9 19:2

19:3 20:4 21:5,24

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22:9,12,15 26:25

27:5,21,25 28:14

30:17 32:20 40:8

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knew 29:2,5,5 31:1

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16:10 17:13 24:16

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28:5,13 29:7,24

30:2,3,7,9,11,13

31:3,18 33:5,8

34:11 37:1 43:6,7,7

43:15

knowledge 7:19 24:9

24:18 28:18,20

29:12,14 30:16,19

30:21,22 37:3 40:10

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KOD 34:16 36:7

L

ladies 14:8

lady 15:6 29:23

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language 7:15

lap 20:5,12

Large 1:24

LAW 2:2

lawyer 3:25 34:20

41:8 47:18

leave 20:20

leaving 16:22

leg 36:8

Legally 44:8

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let's 6:22 7:11 20:22

20:23 24:15 42:16

42:19 45:2

license 31:24,25

46:11,13,14

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life 22:3,5 36:4

light 12:5,8,8

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literally 21:7 30:14

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16:11

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log 40:18,19,21

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loss 40:17

lot 26:25 27:1 28:23

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makeup 10:8 11:23

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13:24 14:5,9,11,13

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March 8:12,13,18,21

8:22,25 9:5 17:16

20:16,23 22:10 25:1

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39:14

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marks 10:7 18:9

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3:2 4:9 6:24 49:8

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matter 39:3

mean 13:12 15:4,7

31:9 34:22 35:23

36:23 37:5

meaning 12:8 31:12

32:10 47:4

means 31:8

mediation 25:7,14,18

26:15

mediations 25:21

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meeting 24:11,12

28:2 30:4 34:6,9,11

34:16 35:5,12,13

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meetings 35:1

memory 26:18 27:13

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ment 29:25

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met 24:7,20

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MIAMI-DADE 49:4

50:5

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43:25

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minimum 9:12,24

23:24 24:5 33:21

minor 16:11

minute 42:19

model 14:14

mom 12:1 19:8,11,16

19:17 40:2 42:8

moment 37:25

Monday 20:7 23:3

Mondays 20:7 23:4

money 8:8 12:2 20:3

20:8,10,12,13,14

21:5,9 23:16 47:4,5

morning 3:25 11:10

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mother 22:2

N

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28:2,8,9,12 29:5,6

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new 43:20

night 8:9 12:24 19:24

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nightly 20:17

nights 21:8,9

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notes 50:14

notice 1:24 44:1

noticed 3:6

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number 23:23 39:1

O

oath 6:20 49:1

object 5:23 44:13

objection 6:1 44:11

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okay 3:5 4:4,15,16,24

5:1,2,14,17,19,20

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7:16 8:10,15 9:5,9

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16:23 17:8,21 18:13

19:14 20:14,21

21:16 22:18,24 24:7

24:17 25:3,20 26:8

26:15,21 27:20

28:10,20 29:9 30:22

31:3,17,18 32:1,12

34:7,18 35:7,11

36:11,23 37:18,20

38:2,6,23 39:5,12

39:20 40:5,11 41:9

42:3,14,18 43:12

44:3,10 45:13,17,22

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old 22:1

open 9:22 43:19

opened 10:20

option 32:21 33:18

original 16:18

originally 8:19 31:22

outside 16:19 45:2

overseer 30:19 31:13

owed 24:2

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owner 29:4,20 30:2

31:11 32:3 44:9

owners 28:22

ownership 43:20

owns 43:8

P

P.A 2:2

p.m 10:22,23

P.O 2:3

page 2:19 6:12 27:20

paid 8:5,7 9:11 17:19

23:25 32:5,9 33:21

40:11

Palace 47:9,11,13

paper 5:7 37:6

paper-wise 33:19

papers 28:4 31:21

32:4,17

paperwork 32:19,20

34:3,5

paralegal 4:5

part 31:20

particular 35:15

parties 3:7 50:17

parties' 50:18

partner 43:8

passing 32:4

pay 9:14,25 11:16,22

11:23 12:2,4,23

13:4 15:25 16:25

17:10,21 18:17,21

19:2,3,5,7,7,8,14,20

22:22,23 23:4,5,14

39:23

pay- 32:12 33:8,9

paycheck 8:7 23:21

23:22 32:10,23

33:16,17 34:3,4

payment 11:16

payments 13:7,10

people 12:2 20:8

27:11 28:24 29:1,23

30:25 43:23 45:11

percentage 17:8

period 18:8 22:22

personally 24:21 29:2

49:8

phone 38:25 39:1

phones 11:3,10

phonetic 5:11

photo 31:23

photo- 27:13

photogenic 27:13

pick 23:9

picture 27:4,6,16

34:19

pictures 26:23,25

27:1,2 34:14 35:24

36:2,12 37:2

piece 5:7

pile 20:11

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plain 47:6

plaintiffs 1:9 2:4 5:5

please 3:16 4:8 18:24

22:20 37:15

point 31:10 39:2

pole 36:7,7

policy 14:3

Ponce 1:17 2:6

pool 33:12

possess 36:3

possessing 7:20

possible 4:15

power 31:15,16

predominantly 16:15

pregnant 22:1

present 3:9 22:7

pretty 15:3,4,8 21:18

40:22 47:20

print 37:5

prior 22:9 25:12,14

26:15

probably 5:25 24:10

41:4

problem 36:14

procedure 6:15

professional 1:23

14:21,22 50:9

professionals 15:9

Public 1:23 49:20

pull 41:25 42:4,14

pursuant 1:24

put 4:14 28:6

Putting 29:11 30:15

Q

question 5:16,18 6:16

16:18,20 18:24

20:19,21 26:5 44:12

44:14,19 45:7

questions 6:14 45:5

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quick 38:4

quicker 37:17

R

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R.P.R 50:25

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ready 3:11 10:12,25

real 22:2

realistic 21:4

really 7:7 8:21,22

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recall 21:10

receive 37:3

received 8:6,7 20:15

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receiving 32:23

recollection 26:22

record 3:5 7:3,4 8:21

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records 41:13,14

reflect 3:5

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regard 16:16

regarding 39:1

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Registered 1:22 50:8

relative 50:16,17

relevant 36:3

remember 13:20

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28:1,8,8,12 29:8

30:10,12,14 31:4,6

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report 50:10

reporter 1:23 3:13

5:21 7:22 50:9

REPORTER'S 50:1

representing 43:5

request 41:2

requested 50:12

response 38:20 41:21

responsibility 3:20

28:22

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rest 36:14

restaurant 33:6,14

returns 40:9,14,25

45:20

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Rick 34:8

right 4:18 5:15 6:18

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10:11 12:12,14,17

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34:2 35:3 37:8,14

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42:10,16,20 43:6,10

43:15 44:20,22 45:5

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room 10:10 14:11

rooms 11:23,24

rounded 23:20

rules 24:1,15

rumors 28:16,17

run 38:13,18,21,21

S

salary 8:6

saw 25:6,10 26:17

27:4,6

saying 3:24 5:1 10:3

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says 34:15 35:14

schedule 22:18 23:7,8

screenshot 34:13

seal 49:12

second 26:11 44:25

seconds 5:24

security 9:22 19:8,11

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43:24

see 5:7 7:11 9:10

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seeking 23:16 24:2,4

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40:3

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separate 38:15

separately 37:19

September 8:19 36:9

set 22:18

settle 25:25

settled 25:25

settlement 25:24

short 27:9

show 27:13

showed 40:18

sick 28:23 29:4,20

30:3 31:11,14 32:4

side 19:18

sign 28:5 31:22,24

32:18

signed 32:18,20

simple 47:5

single 18:6,8,11

sir 4:12 7:17,19,25

9:4,15 10:4,6,11

11:20 12:3 13:3,9

13:11 14:2,25 15:3

15:12,14,21,23 17:2

17:15,18,20 18:4

21:2,19,22 22:8,11

22:17 23:15 26:6,14

26:20 27:8 32:22

37:11 38:16 39:24

41:16 45:21 46:3,5

47:6

sitting 5:8,9 10:10

26:12 45:18

six 17:11,14,19 18:11

37:22

slow 23:1,2,6,8,9,12

small 16:6,7,11

smoking 7:15

smooth 4:15

sold 42:24,25 43:6,7

43:13,15,18,21 44:4

44:6

some- 29:25 42:8

somebody 32:15

son 22:2

soon 36:18

sorry 7:24,24 10:15

11:9 13:22,23 14:21

14:21 18:14,25 20:9

21:2 23:19 29:8,13

31:6,23 36:25 39:6

44:21

SOUTHERN 1:1

speak 9:17

special 11:23,24

specifically 31:18

speculate 6:7

split 33:13

spoken 24:22

spray 10:7 11:25 12:1

12:21 13:2 18:5,10

staff 28:25 43:22 44:2

stage 20:5,12 35:4

standard 13:16 14:7

14:13 17:4

standing 20:10 34:23

start 3:11 6:15 8:21

12:6 20:23

started 8:18,22 9:23

12:9,15,19 16:12

20:24 31:21 32:4

starts 16:2,8

state 1:24 3:16 4:8

49:3,20 50:4

STATES 1:1

stay 26:14

stayed 10:20

stenographic 50:14

stenographically

50:10

stepped 32:7

stepping 29:5

stop 22:4

straight 15:24 16:22

18:1 47:20

stretch 10:7 18:9

strike 24:24 27:22

43:5

strip 29:10

stuff 12:11 29:1 31:21

31:22 42:8

styled 5:3

subscribing 48:1

substantiate 39:16

sure 5:10 10:12 11:4

24:13 37:2 39:22

40:22,23

surmising 23:11

sworn 3:4,12 6:20

49:9

T

table 20:5,12

take 5:21 37:24 38:4

42:16,19

taken 1:22 4:10 38:7

39:9 42:21 45:3

talk 13:20 29:22

talked 25:21,23 28:23

30:5 39:13

talking 5:19 12:24

25:17 29:13 30:25

39:25 43:4,4,13

46:1,24,25

tan 10:7 12:1,1,21

18:10 29:25,25

Tangie 29:25

tardiness 3:17

Case 1:20-cv-23230-AMC Document 136-4 Entered on FLSD Docket 10/25/2021 Page 17 of

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Page 55

tax 40:9,14,25 41:18

41:25 42:4 45:20

taxes 39:17,21,22

40:3,18,20,21 41:11

46:16

technology 37:4

techy 37:13

Teenage 7:7

teenager 7:14

tell 6:5,7,10 7:8 8:2

9:5 17:8 19:5,25

21:13 24:7 45:18

46:6

telling 14:3 15:2

23:11 28:3

Tennessee 38:24

Tequila 31:5

Teri 1:11 5:4 8:4 24:7

24:20 27:21,24

28:14 30:16 31:10

33:24,25 44:3,5

terms 6:15

testified 3:4 44:16

testimony 14:19

39:15 44:18

Thank 11:8 39:8

Thereupon-- 3:1

thing 20:6 24:4 40:15

41:12 42:9

things 4:20 16:6,7,12

think 6:6 11:10 36:3

36:16 40:16 42:6

43:3

thought 16:1 17:25

41:17

thousand 21:15,15

throw 20:9

till 8:13 9:5 10:20

20:16 21:3

time 5:12 7:18 8:10

10:5,21 12:21 16:25

17:8,22 18:3,6,7,8

18:11 20:21 21:6,20

25:9 26:10,11,16

27:19 28:1 34:10

35:2,5 46:24

times 17:12,14,19,21

30:1 47:3

tip 16:11 33:15

tipped 33:21

tips 19:17 32:5,9,25

33:10,12 40:6,7

TOBIN 2:5,9 38:12

today 3:7 5:3 6:6

29:22 45:18

told 13:22 16:1 28:22

29:3,15,16,23 32:3

32:15 41:25 42:8

top 27:15 33:2

total 19:22 23:18

touching 18:14

traffic 4:6

transcript 50:12,13

travel 40:4

traveling 22:11 45:25

tried 14:18

true 50:13

try 4:13 13:18,25

42:7

trying 19:18 25:20,24

Turkey 38:13,17

turned 11:2

turns 44:3

twice 26:10

twins 18:9

two 5:24 22:25 23:2,6

23:8,9 46:18 47:2

U

Uh-huh 4:22

uh-uh 4:22

Umm-hmm 4:19 7:21

20:25

unacceptable 13:25

14:18

uncle 40:18 41:10

under- 34:22

undersigned 49:7

understand 3:22 6:10

6:11 25:20

understanding 34:25

UNITED 1:1

unrelated 15:19 39:3

V

vendor's 46:13

verbal 38:20 41:21

verify 37:25

versus 5:4

visible 18:10

vision 35:6

vs 1:10

W

wage 33:21

wages 9:12 23:18,24

24:3,5 31:20 32:23

33:7

waitress 33:14

waitresses 28:25 33:6

33:8

waive 47:23

waived 48:1

waiving 47:22

walk 9:25 10:9 23:14

walked 16:24 18:18

walking 12:25,25

13:4 15:19 18:19,22

19:3

want 5:23,25 16:7,8,9

18:1 22:21 23:9,12

25:25 28:5 31:13

47:21

wanted 3:22 11:3

14:7 15:23 23:1

32:15

wasn't 13:16 17:3

25:19 46:12

watch 33:25

water 39:7

way 3:19 5:20 15:24

17:18 20:22 23:16

24:5,25 27:6 28:7

37:25

We'll 5:14

we're 4:25 5:3,19

6:12 13:20 27:20

38:4 39:25,25 42:17

45:6,13,16 46:24

47:23

wearing 12:10

week 18:12 33:16

wife 31:14

Williams 1:20 2:23

3:2 4:9 6:24 49:8

50:11

witness 3:3,12 6:3

7:24 26:6 34:24

35:1,7,9,13 37:11

37:16,20 38:2,6,13

39:8 41:22,24 42:18

44:20,23 47:11

49:12

woman 16:5

word 31:12,13 37:18

words 26:16 27:4

33:3,18 38:15

work 4:23 8:6 13:16

18:11 22:14,21,22

22:22,23,25 23:2,3

23:5,6,7,12,13 33:6

45:10 46:4 47:12

worked 8:9 13:8

18:11 21:20 22:13

23:20 26:11 28:25

29:1,17,24 46:6,8

46:18,20 47:16

working 8:15,21,23

29:15 30:24 32:11

46:1

works 15:7

write 37:16

writing 37:19

wrong 8:4

X

x 1:13 2:16

Xena 35:3,10

Y

yeah 5:13 15:8 21:17

23:20 27:2,12,14

34:22 35:21 36:13

year 22:1 26:9 36:9

39:19 40:20 42:1

yearly 46:15

years 7:7 39:18

yesterday 25:6,17

Z

Zoom 25:23

0

02/29/24 49:21

04/26/1989 7:2

1

10 12:21 13:2 16:9

18:5

10% 8:8 19:9,11,12

19:13,25 20:1,2

33:5 40:2

10:30 3:10

10:55 1:18

11:55 1:18

12th 27:22

13 45:20

1345 38:13

14 45:20

14th 17:18

15 16:9

18 7:10

2

20 1:18

20-23230-CIV-CA...

1:5

2009 7:11

2011 8:20

2012 8:12,13,18,22

8:25 9:5 17:16

20:16,23 21:3 22:10

25:1 27:22,23 28:15

30:9 34:15,16,23

36:9,9 39:14 40:25

45:20

2013 30:11 41:1

2014 8:12,14 9:1,6

17:17 20:16 21:23

22:6 25:1 27:22,23

28:15 30:13 39:14

41:1 42:24 44:4,7

44:18

2021 1:18 49:13

50:22

20s 31:5

20th 49:12

240 23:19

240,000 23:20

25 12:6,9,13 15:25

16:9,25 19:15,15,18

26 45:9

280 23:19

29th 36:9

3

3 2:23,24,25

31st 21:3 50:22

32 7:12,13 31:4

33083 2:3

33146 1:17 2:7

350 23:5

38116 38:24

4

4 34:15,16

4216 2:3

4551 1:17 2:6

4th 35:14

5

5 33:16

5,000 21:12

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Choice - United 

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50 12:16,19 16:2,8,13

17:10,19 19:22 36:7

57,000 23:18

6

7

8

8 10:17

8:30 10:18,19,20,22

8:30ish 9:22

80 12:9,11,13

89 7:11

9

9:30 3:8,18 4:2

901-364-5262 39:5

955442 49:22

99 7:11

Case 1:20-cv-23230-AMC Document 136-4 Entered on FLSD Docket 10/25/2021 Page 19 of

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