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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

 Monday, August 23, 2021

 3:13 p.m. - 4:10 p.m.

 DEPOSITION OF EBONY MAYFIELD

 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

 AINSWORTH DUDLEY, ESQ.

 Building One, Suite 200

 4200 Northside Parkway

 Atlanta, Georgia 30327

 BY: AINSWORTH DUDLEY, ESQ.

 On behalf of the Plaintiffs

 GERALD J. TOBIN, P.A.

 4551 Ponce de Leon Boulevard

 Coral Gables, Florida 33146

 BY: HOWARD BRODSKY, ESQ.

 and GERALD J. TOBIN, ESQ.

 _____________________________

 I N D E X

Examinations Page

EBONY MAYFIELD 3

 3

DIRECT EXAMINATION BY MR. BRODSKY 3

Page 3

1 Thereupon--

2

 EBONY MAYFIELD

3 was called as a witness by the Defendant and,

4 having been first duly sworn, testified as follows:

5

 DIRECT EXAMINATION

6 BY MR. BRODSKY:

7

 Q. Please state your name.

8

 A. Ebony Mayfield.

9

 Q. E-b-o-n-y?

10 A. Yes.

11 Q. M-a-y-f-i-e-l-d?

12 A. That's correct.

13 Q. Ms. Mayfield, have you ever had your

14 deposition taken before?

15 A. For this case, no.

16 Q. Any case?

17 A. Yes.

18 Q. What case have you had your deposition

19 taken in?

20 A. A federal case involving another former

21 employer.

22 Q. Who would that employer be?

23 A. Air Peace.

24 Q. Spell it.

25 A. Well, not Air Peace. Springfield Aviation.

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1

 Q. Spring --

2

 A. -- field Aviation.

3

 Q. What kind of company is Springfield

4 Aviation?

5

 A. Aircraft servicing company. Airline

6

servicing company.

7

 Q. Where is it located?

8

 A. Atlanta, Georgia.

9

 Q. What was the complaint in that case about?

10 A. I didn't file a complaint. I worked for

11 the company, so I was called in to do a deposition

12 in reference to the case they have against the

13 company's owner.

14 Q. Understood. So you were not a party to

15 that case?

16 A. No.

17 Q. Have you ever been involved in any law18 suits other than this lawsuit before?

19 A. No.

20 Q. And when was your deposition taken in that

21 case?

22 A. July 2019.

23 Q. And the issue in that case has nothing to

24 do with a wage and hour claim?

25 A. No.

Exhibit 3

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1

 Q. Other than that case where you had your

2 deposition taken, have you ever had your deposition

3

taken before in any other case?

4

 A. No.

5

 Q. So you're pretty familiar with what a

6 deposition is in that you've already been through

7

the process, right?

8

 A. Yes.

9

 Q. So let's just get a couple of, I guess get

10 an understanding --

11 A. Okay.

12 Q. -- of the protocol so this goes smoothly

13 and quickly, okay?

14 A. Okay.

15 Q. Give me an opportunity to ask my question

16 before you answer, and I will give you an

17 opportunity to answer my question, so we're not

18 speaking over each other.

19 A. Okay.

20 Q. Please answer out loud yes, no or what21 ever it is you want to say as opposed to uh-huh or

22 uh-uh or something like that, okay?

23 A. Okay.

24 Q. I'm not asking you to guess or speculate.

25 I'm simply trying to figure out what it is you have

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1

firsthand knowledge about regarding this case.

2

 A. Okay.

3

 Q. What is your date of birth ma'am?

4

 A. June 14, 1982.

5

 MR. BRODSKY: Off the record.

6

 (Discussion held off the record.)

7 BY MR. BRODSKY:

8

 Q. Have you ever been arrested?

9

 A. Yes.

10 Q. When and for what?

11 A. I've been arrested several times. How far

12 back do I go? Earliest I would say was probably

13 1998.

14 Q. Okay. Let's go most recent.

15 A. Most recent, only recent arrest I've had

16 was in June of 2019.

17 Q. And you were arrested for?

18 A. It was in reference to the case

19 aforementioned above --

20 Q. Okay.

21 A. -- with my former employer.

22 Q. And what was the charge?

23 A. It wasn't a charge. It was a federal

24 information is what they call it.

25 Q. Okay.

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1

 A. And your guess is as good as mine. Well,

2

you probably know better than I do, it's a

3

continuing case going on. So I don't have really

4 much explanation of it.

5

 Q. So it's still open?

6

 A. It's still open.

7

 Q. It hasn't been --

8

 A. It hasn't been resolved, no.

9

 Q. All right. And that's out of Atlanta?

10 A. Yes, Northern District Federal Court.

11 Q. And it is a criminal case?

12 A. It is a criminal case.

13 Q. Okay. Prior to that when were you

14 arrested?

15 A. My early 20s. So it would be well over 10

16 years ago.

17 Q. What would that have been for?

18 A. I've gotten a stalking charge. I've gotten

19 battery charge. I got a auto theft charge which was

20 dismissed.

21 Q. Okay. Stalking, battery --

22 A. And criminal trespassing.

23 Q. Auto theft and then criminal trespassing.

24 Anything else?

25 A. That's it.

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1

 Q. Where did these arrests take place?

2

 A. Criminal trespassing took place in Dade

3 County Courthouse. The prior three was in Atlanta,

4 Georgia.

5

 Q. State or federal court?

6

 A. State. All of those were state court.

7

 Q. Do you remember approximately when those

8

took place? Let's start with the stalking.

9

 A. Early 2000. All of those were early 2000s

10 prior to -- because I was (inaudible) in 2006. So

11 those would be prior to 2006. The Dade County

12 charge was in 2008.

13 Q. And these three are prior to 2006, right?

14 A. Yes.

15 Q. What happened with the stalking case, the

16 end result of it?

17 A. That was dismissed.

18 Q. Okay.

19 A. All of those actually were dismissed

20 except that criminal trespassing charge.

21 Q. The one in Dade?

22 A. Yes.

23 Q. So the stalking charge, the battery charge

24 and the auto theft charge --

25 A. Actually the auto theft charge, let me

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correct that, that was in Punta Gorda.

2

 Q. So the stalking and the battery were in

3 Atlanta?

4

 A. Yes.

5

 Q. And the auto theft charge was in Punta

6 Gorda?

7

 A. Yeah.

8

 Q. In Florida?

9

 A. Florida, yes.

10 Q. And that was dismissed as well?

11 A. Yes.

12 Q. And the criminal trespass was here in Dade

13 County in 2008?

14 A. Yes.

15 Q. And I don't remember if you told me what

16 the end result of that was.

17 A. They sent me to anger management.

18 Q. Okay. To your knowledge was that a

19 misdemeanor or a felony?

20 A. That's a misdemeanor. All of those was

21 misdemeanors. I don't have any felonies.

22 Q. Even the auto theft?

23 A. Oh, that was a felony charge, but it was

24 dismissed, yeah.

25 Q. Okay. All righty. So let's see. Are you

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1 currently employed?

2

 A. Yes.

3

 Q. And where are you employed?

4

 A. I work at two clubs in Atlanta, Strokers

5 Club --

6

 Q. S-t-r-o-k-e-r-s?

7

 A. That's correct, and the Blue Flame Lounge.

8

 Q. Blue --

9

 A. Flame.

10 Q. I didn't get the last part.

11 A. Flame, like fire flame.

12 Q. There was a third word.

13 A. Blue Flame Lounge.

14 Q. Lounge, okay. And both of those are adult

15 entertainment clubs?

16 A. Yes.

17 Q. And they're both in Atlanta?

18 A. Blue Flame is in Atlanta. Strokers is in

19 Clarkston, Georgia.

20 Q. Who?

21 A. Clarkston.

22 Q. C-l-a-r-k-s-t-o-n?

23 A. k-s-t-o-n, yes.

24 Q. I'm going to be presumptuous and ask you

25 if these were adult entertainment clubs.

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1

 A. Yes.

2

 Q. And you performed as an adult entertainer

3

in those two clubs?

4

 A. No. I'm an bartender now.

5

 Q. In both?

6

 A. Yes.

7

 Q. And how long have you been working as a

8 bartender at these two clubs?

9

 A. Initially I was an entertainer, and I've

10 worked at both of these clubs off and on for over

11 10 years, off and on. I initially started working

12 at Strokers in 2004. Blue Flame, around the same

13 time, about 2004.

14 Q. And in both of those were you initially an

15 adult entertainer?

16 A. I was initially an adult entertainer, yes.

17 Q. So when did you come to the point where

18 you become a bartender?

19 A. Just kind of transitioning out of the

20 business, wanting to go to the other side.

21 Q. When?

22 A. Initially I began bartending probably -- I

23 got my bar license in 2007.

24 Q. Okay.

25 A. So I used to bartend off and on in

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1 different places, private parties, restaurants. So

2

strip club bartending is a little bit harder to get

3

into. It's easier to be a dancer than it is a bar4

tender. So just kind of as positions open up or as

5

they needed me I would float in and out of it, but

6

it didn't become a full-time thing until like the

7

last two years.

8

 Q. Okay. Prior to bartending at Strokers and

9 Blue Flame what did you do to earn money prior to

10 that?

11 A. I was a dancer.

12 Q. Where?

13 A. I danced at King of Diamonds here. We'll

14 start with Florida because we're in Florida. I

15 danced at King of Diamonds. I danced at Coco's.

16 I've danced at Diamonds which was, which is now G5.

17 I danced at Booby Trap, Doral. I danced at, it was

18 the Alley Cat. It's another club now in South

19 Florida. In Atlanta I danced at Onyx. Prior to Onyx

20 it was Strokers and Blue Flame. Prior to them it

21 was Magic City and Follies, Pinups, Blaze. I danced

22 at Onyx in Houston, danced at Onyx in Charlotte.

23 Oh, Club Nikki's in Charlotte.

24 Q. And when did you -- was all of this prior

25 to or at the same time that you were dancing at the

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1 King of Diamonds?

2

 A. Same time.

3

 Q. All right. So let me ask you this --

4

 A. Okay.

5

 Q. -- for what period of time -- first of

6 all, do you know what case we're here on today?

7

 A. Yes.

8

 Q. And what is your understanding of who your

9 suing and for what?

10 A. Okay. So we're suing Teri Galardi because

11 she is the owner of King of Diamonds, because of

12 work wage violations and violations that they were

13 taking tips-outs from us that they should not have

14 been taking from us.

15 Q. All right. And what is the time frame for

16 which you are claiming damages in this place?

17 A. I started working at King of Diamonds the

18 day it opened, 2009. Going into end of 2008 to 2009

19 I started working at King of Diamonds, and I worked

20 there consistently until the end of 2012. That was

21 what we call our home club. So in the dance world,

22 like you'll go and you'll dance events, you'll

23 dance parties, you'll dance at different places

24 depending upon what's going on in the entertainment

25 world. So you're mobile, but you always have a home

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1

club, and the home club is the club that you're at

2 or the club that you represent when you go to some3 where else.

4

 So Onyx in Atlanta was my home club. King

5 of Diamonds in Miami was my home club and they're

6 both Galardi's clubs. So that's how I ended up

7 dancing at King of Diamonds, because prior to King

8 of Diamonds I was in Atlanta and I worked at Onyx.

9

It's like hey, we're opening a club in Miami, we

10 need girls to come down. How would you all like

11 going to Miami to work, which is how I ended up at

12 King of Diamonds. So started working at King of

13 Diamonds.

14 I was what they consider a VIP girl. VIP

15 girls work a minimum of four days a week. So you

16 had to work four shifts a week. Our tip-outs

17 typically were different from everybody else's. I

18 don't know if you want me to answer that now.

19 Q. We will eventually, but I'm going to go

20 back to my original question, which respectfully

21 you still haven't answered if you even remember

22 what it was.

23 A. Your original question was when did I work

24 at King of Diamonds.

25 Q. No. For what years are you claiming

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1 damages for in this case?

2

 A. Okay. So I started working there 2009,

3 2009 to 2014.

4

 Q. Can you tell when in 2009?

5

 A. I started working there the day they

6 opened their doors and I want to say they opened

7 January 2009.

8

 Q. And in 2014 when did you, what month did

9 you stop?

10 A. I stopped the beginning of 2014. Somewhere

11 like February/March area because I relocated back

12 to Atlanta full-time.

13 Q. Can you tell me how much money in damages

14 you are seeking for the years that you are claiming

15 you're entitled to damages, from January of 2009 to

16 February/March of 2014?

17 A. The total --

18 Q. Yes.

19 A. -- that I came up with my attorney is

20 $363,000.

21 Q. Okay. Can you break that down for me in

22 terms of how much is attributed to this and how

23 much is attributed to that, if you can.

24 A. Okay. Basically how he came to that

25 conclusion is because nightly there's a fee.

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1 There's a flat fee that you're going to pay every

2 night based upon the time that you get to work, and

3

that fee can go anywhere from 150 to $500 a night.

4

I paid as high as $500 a night. So my attorney came

5 up with an average based on me telling him my

6 experience as a dancer. So those fees are just the

7 base fees that let you walk in the door.

8

 Q. Are they called house fees?

9

 A. They're called house fees, yeah. House

10 fees or bar fees. So you pay that just to even

11 enter the building.

12 Q. Understood. What other fees?

13 A. Outside of that they take, they started

14 taking 10% of our money I would say in year 2010.

15 Somewhere in 2010 they started taking 10% of the

16 money, and that's pretty much customers throwing

17 money on you because they throw a lot of dollar

18 bills. So customers throwing dollar bills on you or

19 you're on stage. They have people that they call

20 sweepers that pick up the money. You don't pick up

21 any money at all. They pick up the money. They take

22 the money, put it in a bag, take the bag upstairs.

23 You open the bag with the house mom and out of

24 those bags, they take 10% of the money out of those

25 bags. Those bags, depend upon how many girls in a

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1

crew, if you're dancing alone, it varies. So say if

2

you're dancing, a guy gives you $500 bucks and it's

3

your 500 bucks, they take 10% of that, or you're in

4 a group with five other girls and a guy throws

5 $5,000, they take 10% of that. So that's how the

6 10% works. Then also you tip the DJ.

7

 Q. All right. So the first fee is the house

8

fee and it's 10% of what, the amount of money that

9

is given to you on a particular night?

10 A. In tips. It's the amount of tips given to

11 you by customers. The first fee is the house fee

12 that you pay to walk in the door. That's the flat

13 fee.

14 Q. Tell me what that was.

15 A. The flat fee --

16 Q. I know you gave me a range, but I didn't

17 write it down.

18 A. It starts at about $150 and it goes up,

19 upwards of $500 and that's time based. So every

20 hour it goes up. It goes up in hourly increments.

21 Q. And that's consistent from January 2009 to

22 February/March 2014?

23 A. Yes, that's always.

24 Q. Okay.

25 A. That's the structure of the club. So you

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1

come in the door, it's 8 o'clock. There's a fee

2

sheet at the door. At 8 o'clock you pay whatever

3

that fee is and you go in. You do that as soon as

4

you walk to the door.

5

 Q. No less than a hundred and fifty, as much

6 as 500?

7

 A. I will say they did -- slow times they

8 would drop it down to about $50. That's the

9

cheapest I've ever seen it, but that's rare, that's

10 really, really rare.

11 Q. But on average anywhere between 150 and

12 500?

13 A. Yes.

14 Q. Okay. So we have a house fee, we have a

15 10%, any other fees?

16 A. Yes. You pay the DJ.

17 Q. All right. How much?

18 A. That varies. That depends on how much he

19 likes you and how much money he thinks you make. If

20 you somebody he feel like makes a lot of money on

21 stage he'll ask you for a hundred dollars. If

22 you're somebody that he feels like donate money,

23 he'll ask you for $20, but it's never a small

24 amount of money. If you hand him $20 he's going to

25 look at you like you're crazy.

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1

 Q. Okay. So give me an average of what you

2 paid --

3

 A. I would say an average of $50, that's just

4 meet in the middle.

5

 Q. Any other fees?

6

 A. House mom.

7

 Q. Okay. Tell me about how much that was.

8

 A. That's a minimum of $10 every night.

9

 Q. Okay.

10 A. And then that goes up according to, if you

11 use something or if you needed something more than

12 the regular special provided. Parking, you pay

13 parking.

14 Q. All right.

15 A. And that's like $20 a day.

16 Q. And this is all at the King of Diamonds

17 we're talking about?

18 A. This is all at the King of Diamonds, yeah,

19 you pay for parking.

20 Q. How much was it?

21 A. $20. Parking in the beginning, we didn't

22 pay for parking. They started paying for parking

23 towards the end. Like after Super Bowl they started

24 charging girls to park.

25 Q. What year? What month?

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1

 A. I think that was 2011. It might have been

2 2012, I can't remember. The second Super Bowl

3 because we had two. They started charging girls to

4 park.

5

 Q. Okay. Let's recount so we're on the same

6 page. I have house fees, the 10%, the DJ, the house

7 mom and parking so far.

8

 A. Yes.

9

 Q. Anything else?

10 A. The VIP girls had to tip the manager.

11 Q. How much on average?

12 A. I would say $20 a night.

13 Q. Okay.

14 A. Yeah, on average $20 a night. Sometimes

15 it's more or less, but on average it's like $20 a

16 night.

17 Q. Any other fees?

18 A. No other fees that are coming across right

19 now.

20 Q. Any other part of damages other than these

21 fees that you told me about, to arrive at the

22 $363,000 figure?

23 A. No.

24 Q. Are you seeking as part of this $363,000 a

25 claim for minimum wages?

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1

 A. Yes.

2

 Q. If we can, let's try to agree that anytime

3

I ask you take question about the King of Diamonds

4 we're referring to the time frame of January 2009

5

to February/March of 2014. So I don't have to keep

6

repeating those dates, is that fair?

7

 A. That's fair.

8

 Q. Do you have any idea how much of the

9 $363,000 damage claim is for minimum wages?

10 A. It's about $95,000. That's what was

11 calculated.

12 Q. Total?

13 A. Yes, totals for all years.

14 Q. Got it. So other than the minimum wages

15 and the fees that you've already told me about, is

16 there any other part of the approximate damage

17 amount of $363,000?

18 A. No.

19 Q. What does a VIP girl mean?

20 A. VIP girl, we had our own dressing rooms

21 separate from the main dressing room that we share

22 with the other girls. You were party to things

23 going on in the club that other girls didn't know.

24 So maybe a celebrity had a private party, it would

25 pull the VIP girls into the private party. There

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1 was a section in the club that was specifically for

2 private parties. So it was like a mini club within

3

the club.

4

 Q. Okay.

5

 A. That's how it was designed. So people

6 would rent it out, they would do video shoots and

7

things like that. So for those type of parties they

8 pick the VIP girl.

9

 Q. Understood.

10 A. So the goal in the club was to become a

11 VIP girl so that she can be a part of these private

12 parties.

13 Q. All right.

14 A. And the way that she became a VIP girl was

15 through tip-outs and how often you work. So did you

16 work enough and did you tip out of that. That is

17 what determined a VIP girl.

18 Q. How many days a week on average did you

19 work during the time frame involved in this case?

20 A. Four days.

21 Q. Could you pick those four days or were

22 they picked for you?

23 A. You had to work one slow day.

24 Q. Okay.

25 A. They picked the slow days which were two

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1 Tuesdays and Wednesdays. So you had to work either

2 Tuesday or Wednesday. The other days you can work

3 whenever you wanted to.

4

 Q. What typically days did you work?

5

 A. I worked Friday, Saturday, Sunday, Monday

6 was like the days that I would pick my days out of

7 and then I would work my slow day, Tuesday or

8 Wednesday.

9

 Q. I didn't understand. You said there was

10 four total days --

11 A. Four days, yes. Four total days a week is

12 what I work. Some weeks I work five days.

13 Q. I'm talking about on average.

14 A. On average four days a week.

15 Q. Three of which, excuse me, one of which

16 was a slow day.

17 A. Yes.

18 Q. So the first question is, what three days

19 of the week did you work other than the slow day?

20 A. Other than the slow today I would work

21 Friday, I would definitely work Monday, and then I

22 would rotate between Saturday and Sunday.

23 Q. Okay.

24 A. Mostly Friday, Saturday, Monday, Wednesday

25 really.

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1

 Q. All right. That's fair. And how many hours

2 on average would you work on each of the four days?

3

 A. Me, I would work about 10 hours, and the

4

reason being is because the tip-out is higher. If

5

you come to work later it's a higher tip-out. So I

6 would try to get to work early so I could pay a

7

reasonable tip-out. Our crowd didn't come till 3, 4

8 o'clock in the morning and we closed at 6 in the

9 morning. So if I got to work at 9, usually got to

10 work by latest 10 o'clock. So 9, 10 o'clock range

11 and I would leave at 6, 7 o'clock in the morning.

12 Q. Can we agree that house fees is the same

13 thing as tip-out?

14 A. No, they're not.

15 Q. Then I'm not understanding the difference

16 between a house fee and a tip-out.

17 A. Okay. So house fee is what you pay at the

18 door to get into the building.

19 Q. All right.

20 A. Okay. Tip-out is what you pay to get out

21 of the building.

22 Q. Is that the 10%?

23 A. That's the 10%, that's the tip-out to the

24 DJs, that's the tip-out to the house moms --

25 Q. Okay.

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1

 A. -- those are tip-outs.

2

 Q. So included within the term tip-out is all

3 of these fees that you talk about except for the

4 house fee?

5

 A. House fee, exactly.

6

 Q. Now I understand.

7

 A. Yes.

8

 Q. Okay. On average -- strike that. When you

9 danced at the King of Diamonds you were paid in

10 what form? Was it check, cash, wire, how did you

11 get paid?

12 A. The company never paid us.

13 Q. All right. Who paid you?

14 A. The customers tipped us. We got paid

15 strictly in tips.

16 Q. Okay. And how did you get that tip money,

17 was it in cash, was it by check, how was it?

18 A. Cash.

19 Q. All right. Did you have a bank account at

20 that time?

21 A. Yes.

22 Q. Did you deposit all of the cash that you

23 received in tips in that bank account?

24 A. Not all of it. Not all of it.

25 Q. I looked and I saw that you said that you

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1 did file tax returns --

2

 A. Yes.

3

 Q. -- during 2009 through '14, correct?

4

 A. Yes.

5

 Q. Did you declare all that cash on those tax

6

returns?

7

 A. Yes.

8

 Q. Did you deduct the expenses that we're

9

talking about here as expenses on your tax return?

10 A. Yes.

11 Q. Did you declare yourself as an independent

12 contractor on your tax returns?

13 A. Yes. King of Diamonds gave 1099 tax forms

14 if you asked for them and that's what I used to

15 file my taxes.

16 Q. So you asked for 1099s and they gave it to

17 you?

18 A. When they would give them to us. Some

19 years they didn't give them to us. Actually I've

20 gone so far as to go to their corporate office in

21 Atlanta, because I was based in Atlanta initially,

22 to get my own form because I knew the accountant.

23 But the club -- it wasn't common knowledge, but it

24 was out there. Does that make sense? Like it wasn't

25 published for hey, come get your 1099s, but if you

Page 27

1

took the extra step and went in the office and

2 asked about them they would give them to you.

3

 Q. All right. So you got your 1099s --

4

 A. I got my 1099s.

5

 Q. -- for all the years, and you included

6

that when you filed your taxes?

7

 A. Yes.

8

 Q. All righty. Thank you for that. So --

9

 A. I just thought of something when you

10 went back to fees. I don't know if that's included

11 in there, in those damages, but there were fees for

12 like basically when you had to buy costumes and

13 clothes and things like that. I don't know if that

14 goes into it. You also had to buy certain outfits

15 for certain parties. They might do a all white

16 party, or somebody might do a birthday party and

17 say hey, I need all the girls to wear blue. So

18 those were other external fees, but it wasn't a

19 regular occurrence.

20 Q. How often would that occur percentage-wise

21 in a year?

22 A. Maybe four times a month.

23 Q. Okay. During those four times a month,

24 during the time frame involved here, you're telling

25 me you had to buy what?

Page 28

1

 A. So if you had a all white party you had to

2 buy a all white costume, like everything had to be

3 white.

4

 Q. From where did you buy it?

5

 A. You had vendors that come to the club and

6

sell costumes. If they knew that we were doing a

7 party they would just come to the dressing room and

8

say hey, we got costumes and you're buying them

9

from the vendors there, or if you had time in

10 advance you would order your own or, you know,

11 whoever you bought your stuff from, but there were

12 days you had to have specific things, specific

13 items in order to work.

14 Q. Could you buy it on your own and not buy

15 it from something associated with the -- I'm

16 talking about the outfits. Can you buy the outfits

17 on your own --

18 A. Yes.

19 Q. -- from someone other than through the

20 King of Diamonds?

21 A. Yes.

22 Q. Did you do that?

23 A. Yes.

24 Q. And are you claiming that that's part of

25 your damages for things or for outfits that you

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1 purchased from outside of the King of Diamonds,

2 you're claiming that as part of your damages as

3 well?

4

 A. Yes, because they were ordered by King of

5 Diamonds. So basically what they would say is, if

6

you don't bring a white outfit to work tonight you

7

cannot work. So if you didn't have a white outfit,

8 now you have to go buy a white outfit in order to

9 work. They weren't providing. Does that make sense?

10 Q. Yes.

11 A. Okay.

12 Q. Are there any other fees that you've come

13 with that you didn't talk about?

14 A. That's it.

15 Q. Can you tell me on average what you left

16 with from the King of Diamonds by way of cash,

17 average per night?

18 A. An average, that's a hard one. I would say

19 on average $800.

20 Q. Okay. That would mean after all these

21 other expenses were paid, because I said that you

22 left with.

23 A. Yes, yes, on average. On average, yes.

24 Q. 800 bucks a night?

25 A. 800 bucks a night.

Page 30

1

 Q. Can you tell me what would be the most

2 amount of money you left the King of Diamonds with

3 on a single night?

4

 A. About $5,000.

5

 Q. Okay.

6

 A. The least amount of money, $0. Been nights

7 we left in the negative, because you paid all these

8

fees to work and you didn't make any money.

9

 Q. I asked you earlier, I do believe, that

10 other than this case where you sued Teri Galardi

11 you didn't, you have not sued anybody else,

12 correct?

13 A. No.

14 Q. Including all of these other adult

15 entertainment clubs that you've worked at?

16 A. No.

17 Q. All right. Why did you sue the King of

18 Diamonds and not any of these other clubs?

19 A. The first lawsuit I ever was told about

20 was the initial lawsuit against Onyx, and I was

21 still working at Onyx at the time. There was a lot

22 of rumors going around. There was a lot of chatter

23 about the girls suing the clubs and not being able

24 to work. I have witnessed girls being ostracized. I

25 have witnessed girls being band because they spoke

Page 31

1 out. I'm still in the industry, but I was heavy in

2

the industry then and it just wasn't --

3

 Q. Wasn't a good business decision I'm

4 hearing from you.

5

 A. It wasn't a good business decision to do

6

it at the time because I'm still working everyday.

7

I need to go to work. So I don't want to jump on

8

this lawsuit and sue the club that I'm working at

9 and tomorrow I don't have a job, and then I can't

10 get another job because other clubs have found out

11 about you having issues with this club and they

12 won't hire you.

13 Q. Is that the reason you didn't sue any of

14 these other clubs as well?

15 A. Yes.

16 Q. What gave you the comfort level to sue in

17 this case, because you were no longer dancing

18 there?

19 A. I was no longer dancing. The attorneys

20 that are on this case, they gave me a comfort that

21 no other person had given me before in reference to

22 me being able to be work, because I always felt

23 like, if I did a lawsuit I wasn't going to be able

24 to work.

25 Q. And who were those attorneys that gave you

Page 32

1

that comfort?

2

 A. Michael DeCampo (phonetic) is the first

3 attorney that that I spoke with and then through

4 him.

5

 Q. Anyone else?

6

 A. I met with Ashley Gabbe.

7

 Q. Okay.

8

 A. There's just those two, and today I met

9 with him.

10 Q. Where is Michael DeCampo located?

11 A. He's based out of Fort Lauderdale

12 initially. I think he's moved around since I

13 initially met him, but when I first met with him he

14 was in Fort Lauderdale.

15 Q. Do you know where he is now?

16 A. I'm not sure now.

17 Q. How were you introduced to Michael

18 DeCampo?

19 A. I was introduced to him through one of the

20 girls on the lawsuit, Angela.

21 Q. Angela Milner?

22 A. Yes.

23 Q. Tell me about the introduction and what

24 you and Angela spoke about.

25 A. The introduction was, you worked at King

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1 of Diamonds. I know you have all your taxes and

2

there's a wage lawsuit going on because of back

3 pay. I said wage lawsuit? She says yeah. She says

4

there's several girls getting on this lawsuit to

5

sue King of Diamonds and I think you're good for

6

it. I'm like what do you mean? She says they owe us

7 money, they stole from us. I said yeah, but you

8

know, we've had these issues before and -- at that

9

time the prior lawsuit for Onyx had already

10 settled. So the settlement for those girls was like

11 $22,000 or something like that and I was still

12 working. I said Angela, this is not worth me losing

13 my job over. She says no, you're not going to lose

14 your job, they can't fire you. She said that's

15 illegal, they can't fire you. I said other girls

16 had problems. She said no, that's illegal. They

17 can't fire you now. So that was our conversation

18 and then she introduced me to Michael. So I called

19 him and I asked questions, and we just had a

20 dialogue about it. He said well --

21 Q. I'm asking you to tell me anything between

22 you and any lawyer in this case.

23 A. Okay. So we had dialogue about it and I

24 agreed to it --

25 Q. Understood.

Page 34

1

 A. -- and that's how it started.

2

 Q. And Angela Milner's the one that brought

3 you to Michael DeCampo?

4

 A. Yes.

5

 Q. All right. While you were working at the

6 King of Diamonds during the time frame we've agreed

7

to, would you say that it was productive

8

financially for you?

9

 A. Yes.

10 Q. Did you have any problems while you were

11 there?

12 A. Several. When you say problems, what do

13 you mean by problems?

14 Q. That made you uncomfortable, unhappy or

15 the like.

16 A. Oh, always. The biggest issue I had with

17 them was the expectation of you to make money. It

18 was, oh, if you can't come here and make a thousand

19 dollars we don't want you as a dancer. That was the

20 attitude and the culture of the club. So basically

21 you had to go in and you had to perform and you had

22 to earn, and if you didn't bring in certain amounts

23 in tip-out there was repercussions.

24 Q. Okay.

25 A. Repercussions like you wouldn't be able to

Page 35

1 work, you wouldn't be able to work certain parties,

2

certain events, sometimes higher fees, higher tip3 outs, and then sometimes just harassment.

4

 Q. Define harassment.

5

 A. Harassment in the sense of they would talk

6

crazy or bad about you. I shouldn't use the word

7

crazy. They would talk reckless towards you, in

8

your face.

9

 Q. Like what? Give me an example.

10 A. Maybe you should lose weight and you'll

11 get more money, or you're hair looks crazy, you

12 need to change it, you need more outfits. You don't

13 come to work in a -- just different type of things

14 like that that they will say to you in reference to

15 working. You need to learn to do pole tricks. If

16 you did pole tricks you would make more money.

17 Q. And you didn't like any of that?

18 A. It wasn't the words itself, it was how it

19 came out. Like I said, it was in a harassing,

20 aggressive manner. It wasn't like hey, let's sit

21 down and have a conversation and say what can you

22 do better as an employee type conversation. They

23 didn't come like that. They came in passing. They

24 came, oh, you was in that section, that's all you

25 got. Like they felt like you should have made more

Page 36

1 money off the guy that was in the section. That's

2 how it came off. So it made it sometimes a little

3

stressful to go to work because it was like meeting

4 numbers, you had to meet the numbers.

5

 Q. So why did you continue to dance there for

6

this entire period of time?

7

 A. At the time it was the top club like in

8 Miami for black girls to dance at that was popular.

9

 Q. You make the most money?

10 A. That's where you can make the most money

11 at.

12 Q. More than all these other clubs that you

13 were telling me about?

14 A. Yes. They had all the celebrities, all the

15 superstars. It was a beautiful building, beautiful

16 building. It was clean. We didn't have any violent

17 issues. Like I worked in close where they were

18 shooting. We didn't have those issues at King of

19 Diamonds. So King of Diamonds was the preferred

20 place for people to go and felt safe.

21 Q. Were you able to pick the days you worked?

22 A. Yes.

23 Q. Well, you obviously heard the name Teri

24 Galardi, right, because that's who you sued in this

25 case, correct?

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1

 A. Yes.

2

 Q. Have you ever met Teri Galardi?

3

 A. No, no, I never met her face-to-face. I

4 walked in the office and she's been there, but I've

5 never actually sat down and had a conversation with

6 her.

7

 Q. What office where?

8

 A. In the King of Diamonds there was like a

9 back office.

10 Q. When was that?

11 A. Don't remember exactly. It only happened

12 one time.

13 Q. Did you ever have a conversation with Teri

14 Galardi?

15 A. No.

16 Q. Do you know what, if anything, Teri

17 Galardi did during the years we're talking about as

18 it relates to the King of Diamonds?

19 A. I know that she worked there and she often

20 was in the back office, but we as dancers could not

21 go and specifically talk to her.

22 Q. She worked in the back office at the King

23 of Diamonds?

24 A. Yes.

25 Q. And when did you see her there?

Page 38

1

 A. Usually she's there in the daytime, if you

2 go to the club in the daytime. Sometimes if I get

3

to work early, like maybe 7, 7 o'clock if she's

4

there. She's never there late. She's never there

5 after hours.

6

 Q. Did you ever see her in the club?

7

 A. Inside the building, no.

8

 Q. Did you have any idea what she was doing

9

in the office where you say you saw her?

10 A. No.

11 Q. So you don't know if she was working on

12 business relating to the King of Diamonds or some

13 other business, right?

14 A. Don't know.

15 Q. So you don't really know what, if any16 thing, she had to do during the years we're talking

17 about with the King of Diamonds, right?

18 A. All we were told was she was the owner and

19 you couldn't just walk up to the owner. There were

20 like several people, I guess gatekeepers that she

21 would go to. You would never just talk to her ever.

22 Q. And can you tell me when you saw her in

23 the office in the back of the King of Diamonds in

24 terms of like years or dates or anything?

25 A. I would say it was a time from about 2010

Page 39

1

to maybe about 2012, because that's when I kind of

2

slowed up there.

3

 Q. Are you telling me what you know or are

4 you speculating or --

5

 A. No. I tell you me actually knowing that

6

she's in the back office.

7

 Q. During the time that you just said?

8

 A. Yes, during those years. Like I said, I

9 only personally walked up and seen her myself

10 once. But if you go in the office they're like hey,

11 the owner's in the back. You can't come in here,

12 like you get that often. Like if you're going to go

13 talk to one of the managers or you have an issue

14 they would tell you. Did I physically see her? I've

15 only physically seen her once.

16 Q. Okay. Do you know what owner they

17 were talking about? Could it have been her father

18 Jack Galardi that was in the office that they told

19 you you couldn't go in and see?

20 A. I've never heard them make reference to

21 Jack. I've only heard them make reference, they

22 call her his daughter. They say his daughter.

23 Q. Okay. Did you ever meet Jack Galardi?

24 A. Yes.

25 Q. When did you meet Jack Galardi?

Page 40

1

 A. When King of Diamonds first opened he used

2

to come in the club often.

3

 Q. And for what period of time when it first

4 opened till when did you see Jack Galardi in the

5 club?

6

 A. I don't know when it stopped. I never paid

7 attention to when it stopped, but when it opened it

8 was nothing to see him in there at least once a

9 week. Like he would come in, he would walk around,

10 he will walk the floor and then he would leave out.

11 Q. Do you know if he ever became ill?

12 A. Yes.

13 Q. Do you know when that was?

14 A. I don't know at what point he became ill,

15 but I remember the last time I seen him he was

16 walking with something that looked like an oxygen

17 tank. So I had assumed that he had been ill.

18 Q. And when was that?

19 A. It was 2009.

20 Q. That's the last time you saw him, is that

21 what I heard you say?

22 A. Yeah. I don't remember at what point he

23 stopped coming around, but it was in the beginning.

24 It was definitely when the club first opened. When

25 the club first opened he came in.

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1

 Q. Do you know who owned Fly Low, Inc. doing

2 business as King of Diamonds in 2009?

3

 A. Don't know who owned it. I never really

4 paid attention to the external people because I

5

came from Atlanta. So for me I knew that I worked

6

for the Galardis in my mind. The external people,

7

the Lennys, the Pops (phonetic), the Akinyeles,

8

the -- his name is slipping my mind. Rick. I never

9 paid them any attention honestly, me personally,

10 because -- and that's part of my conflict with

11 them, because I came from Atlanta and I was

12 familiar with the Galardi clubs. I had already

13 worked at Onyx. Before Onyx turned into Onyx it was

14 Masters, but it's the same club. So I had worked

15 for them since the club was Masters. So I was

16 familiar with working for the brand. So when we

17 came to King of Diamonds I just never paid him any

18 attention. They used to say, oh, we own the club

19 and I'm like whatever. You don't look up. But I

20 want to work here, so I did what was asked of me.

21 Q. Okay. I don't know if you did or didn't

22 answer my question, so I'm going to ask it again.

23 Do you know who owned the Fly Low, Inc., doing

24 business as King of Diamonds in 2009?

25 A. No.

Page 42

1

 Q. How about 2010?

2

 A. No.

3

 Q. How about 2011?

4

 A. No.

5

 Q. How about 2012?

6

 A. No.

7

 Q. How about 2013?

8

 A. No.

9

 Q. How about 2014?

10 A. I didn't know who -- no. I didn't know who

11 they were in until this case was filed, because I

12 didn't know that they actually had a business

13 entity --

14 Q. Okay.

15 A. -- involved with King of Diamonds.

16 Q. All right. So during the time frame that

17 you were dancing at the King of Diamonds you didn't

18 know who owned the club?

19 A. I assumed it was the Galardis.

20 Q. But you didn't know who, which one?

21 A. No.

22 Q. And you still don't know?

23 A. No.

24 Q. Okay. Do you know if Teri Galardi ever

25 made any money from the King of Diamonds, where she

Page 43

1

took money and put it in her pocket?

2

 A. No.

3

 MR. DUDLEY: Objection.

4 BY MR. BRODSKY:

5

 Q. Do you know if she actually invested money

6

in the King of Diamonds?

7

 A. No.

8

 MR. BRODSKY: Give us a moment to take a

9

 short break and talk a bit and we'll be back,

10 okay?

11 THE WITNESS: Okay.

12 MR. BRODSKY: And I'm going to use the

13 restroom at the same time.

14 (Thereupon a break was taken.)

15 MR. BRODSKY: We have no further questions.

16 If you have go at it.

17 MR. DUDLEY: Well, let me make sure. Nope,

18 I don't have any.

19 MR. BRODSKY: You want to explain about

20 reading and waiving?

21 THE COURT REPORTER: Yes.

22 (Discussion held off the record.)

23 THE WITNESS: I'll read it.

24 (Thereupon the taking of the deposition

25 was concluded.)

Page 44

1

2

 EBONY MAYFIELD

3

4

5

 Sworn to and subscribed before me this

6

7

 day of 2021.

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

 I, the undersigned authority, certify that

7 EBONY MAYFIELD, personally appeared before me and

8 was duly sworn.

9

10

11 WITNESS my hand and official seal this

12 23rd day of August 2021.

13

14

15

16 JEFFREY M. GOLDSTEIN

17 Notary Public - State of Florida

18 My Commission expires: 02.29.2024

19 Commission No. GG 955442

20

21

22

23

24

25

Page 46

1

 REPORTER'S DEPOSITION CERTIFICATE

2

3 STATE OF FLORIDA

4 COUNTY OF MIAMI-DADE

5

6

 I, JEFFREY M. GOLDSTEIN, Registered

7 Professional Reporter, certify that I was

8 authorized to and did stenographically report the

9 deposition of EBONY MAYFIELD; that a review of the

10 transcript was requested; and that the transcript

11 is a true and complete record of my stenographic

12 notes.

13

14 I further certify that I am not a

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

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

17 of the parties' attorney or counsel connected with

18 the action, nor am I financially interested in the

19 action.

20 DATED this 3rd day of September 2021.

21

22

23

24 JEFFREY M. GOLDSTEIN, R.P.R.

25

Page 47

1

 CORRECTION SHEET

2

3

 Re: Milner, et al., vs. Galardi

 Deponent: Ebony Mayfield

4

 Monday, August 23, 2021

5 PAGE NO. LINE NO. CORRECTION OR CHANGE

6 _______ ________ ____________________________

_______ ________ ____________________________

7 _______ ________ ____________________________

_______ ________ ____________________________

8 _______ ________ ____________________________

_______ ________ ____________________________

9 _______ ________ ____________________________

_______ ________ ____________________________

10 _______ ________ ____________________________

_______ ________ ____________________________

11 _______ ________ ____________________________

_______ ________ ____________________________

12 _______ ________ ____________________________

_______ ________ ____________________________

13 _______ ________ ____________________________

_______ ________ ____________________________

14 _______ ________ ____________________________

_______ ________ ____________________________

15 _______ ________ ____________________________

_______ ________ ____________________________

16 _______ ________ ____________________________

_______ ________ ____________________________

17

 ____________________________

18 EBONY MAYFIELD

Sworn to and subscribed to before me this ______day

19 of ___________, 2021 by _______________________ who

produced________________________ as Identification.

20

 ______________________________

21 Notary Public-State of Florida

 My Commission No.

22 Expires:

23

24

25

Page 48

1

 CHOICE / UNITED REPORTING SERVICE, INC.

 REGISTERED PROFESSIONAL REPORTERS / VIDEOTAPE

2

 DEPOSITIONS COMPUTER TRANSCRIPTION / LITIGATION

 VIDEO TELECONFERENCING

3

4

JEFFREY M. GOLDSTEIN Registered Professional

Reporter

5 Ft. Lauderdale (954) 728-9886 Miami (305) 374-2222

6

7

 Friday, September 3, 2021

8

 RE: Milner, et al., vs. Galardi

9

10

Ebony Mayfield

11 c/o Astrid E. Gabbe, P.A.

P.O. Box 4216

12 Hollywood, Florida 33083

Phone: 954-303-9882

13 Fax: 954-983-1427

14

15 Dear Ms. Mayfield

 With reference to your deposition taken on

16 Monday, August 23, 2021 in connection with the abovecaptioned case, please be advised that the transcript

17 of the deposition has been completed and is awaiting

signature.

18 If this has not been taken care of, however,

within the next 15 days or by the time of trial,

19 whichever comes first, we shall conclude that the

reading and subscribing of the deposition have been

20 waived without further notice.

21 Sincerely,

22 BY: Jeffrey M. Goldstein, RPR

23

24

25

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A

able 30:23 31:22,23

34:25 35:1 36:21

above- 48:16

account 25:19,23

accountant 26:22

action 46:18,19

adult 10:14,25 11:2

11:15,16 30:14

advance 28:10

advised 48:16

aforementioned 6:19

aggressive 35:20

ago 7:16

agree 21:2 24:12

agreed 33:24 34:6

AINSWORTH 2:2,4

Air 3:23,25

Aircraft 4:5

Airline 4:5

Akinyeles 41:7

al 1:8 47:3 48:8

Alley 12:18

amount 17:8,10

18:24 21:17 30:2,6

amounts 34:22

Angela 1:8 32:20,21

32:24 33:12 34:2

anger 9:17

answer 5:16,17,20

14:18 41:22

answered 14:21

any- 38:15

anybody 30:11

anytime 21:2

APPEARANCES 2:1

appeared 45:7

approximate 21:16

approximately 8:7

area 15:11

arrest 6:15

arrested 6:8,11,17

7:14

arrests 8:1

arrive 20:21

Ashley 32:6

asked 26:14,16 27:2

30:9 33:19 41:20

asking 5:24 33:21

associated 28:15

assumed 40:17 42:19

Astrid 48:11

Atlanta 2:4 4:8 7:9

8:3 9:3 10:4,17,18

12:19 14:4,8 15:12

26:21,21 41:5,11

attention 40:7 41:4,9

41:18

attitude 34:20

attorney 15:19 16:4

32:3 46:15,17

attorneys 31:19,25

attributed 15:22,23

August 1:17 45:12

47:4 48:16

authority 45:6

authorized 46:8

auto 7:19,23 8:24,25

9:5,22

average 16:5 18:11

19:1,3 20:11,14,15

22:18 23:13,14 24:2

25:8 29:15,17,18,19

29:23,23

Aviation 3:25 4:2,4

awaiting 48:17

B

back 6:12 14:20

15:11 27:10 33:2

37:9,20,22 38:23

39:6,11 43:9

bad 35:6

bag 16:22,22,23

bags 16:24,25,25

band 30:25

bank 25:19,23

bar 11:23 16:10

bar- 12:3

bartend 11:25

bartender 11:4,8,18

bartending 11:22

12:2,8

base 16:7

based 16:2,5 17:19

26:21 32:11

basically 15:24 27:12

29:5 34:20

battery 7:19,21 8:23

9:2

beautiful 36:15,15

began 11:22

beginning 15:10

19:21 40:23

behalf 2:5

believe 30:9

better 7:2 35:22

biggest 34:16

bills 16:18,18

birth 6:3

birthday 27:16

bit 12:2 43:9

black 36:8

Blaze 12:21

blue 10:7,8,13,18

11:12 12:9,20 27:17

Booby 12:17

bought 28:11

Boulevard 1:16 2:7

Bowl 19:23 20:2

Box 48:11

brand 41:16

break 15:21 43:9,14

bring 29:6 34:22

BRODSKY 2:9,25

3:6 6:5,7 43:4,8,12

43:15,19

brought 34:2

bucks 17:2,3 29:24

29:25

building 2:3 16:11

24:18,21 36:15,16

38:7

business 11:20 31:3,5

38:12,13 41:2,24

42:12

buy 27:12,14,25 28:2

28:4,14,14,16 29:8

buying 28:8

C

C-l-a-r-k-s-t-o-n

10:22

c/o 48:11

calculated 21:11

call 6:24 13:21 16:19

39:22

called 3:3 4:11 16:8,9

33:18

captioned 48:16

care 48:18

case 1:5 3:15,16,18

3:20 4:9,12,15,21

4:23 5:1,3 6:1,18

7:3,11,12 8:15 13:6

15:1 22:19 30:10

31:17,20 33:22

36:25 42:11 48:16

cash 25:10,17,18,22

26:5 29:16

Cat 12:18

cause 1:25

celebrities 36:14

celebrity 21:24

certain 27:14,15

34:22 35:1,2

CERTIFICATE 45:1

46:1

certify 45:6 46:7,14

change 35:12 47:5

charge 6:22,23 7:18

7:19,19 8:12,20,23

8:23,24,25 9:5,23

charging 19:24 20:3

Charlotte 12:22,23

chatter 30:22

cheapest 18:9

check 25:10,17

CHOICE 48:1

City 12:21

claim 4:24 20:25 21:9

claiming 13:16 14:25

15:14 28:24 29:2

Clarkston 10:19,21

clean 36:16

close 36:17

closed 24:8

clothes 27:13

club 10:5 12:2,18,23

13:21 14:1,1,1,2,4,5

14:9 17:25 21:23

22:1,2,3,10 26:23

28:5 31:8,11 34:20

36:7 38:2,6 40:2,5

40:24,25 41:14,15

41:18 42:18

clubs 10:4,15,25 11:3

11:8,10 14:6 30:15

30:18,23 31:10,14

36:12 41:12

Coco's 12:15

come 11:17 14:10

18:1 24:5,7 26:25

28:5,7 29:12 34:18

35:13,23 39:11 40:2

40:9

comes 48:19

comfort 31:16,20

32:1

coming 20:18 40:23

Commission 45:18,19

47:21

common 26:23

company 4:3,5,6,11

25:12

company's 4:13

complaint 4:9,10

complete 46:11

completed 48:17

COMPUTER 48:2

conclude 48:19

concluded 43:25

conclusion 15:25

conflict 41:10

connected 46:17

connection 48:16

consider 14:14

consistent 17:21

consistently 13:20

continue 36:5

continuing 7:3

contractor 26:12

conversation 33:17

35:21,22 37:5,13

Coral 1:16 2:8

corporate 26:20

correct 3:12 9:1 10:7

26:3 30:12 36:25

CORRECTION 47:1

47:5

costume 28:2

costumes 27:12 28:6

28:8

counsel 46:15,17

County 8:3,11 9:13

45:4 46:4

couple 5:9

court 1:1 7:10 8:5,6

43:21

Courthouse 8:3

crazy 18:25 35:6,7,11

crew 17:1

criminal 7:11,12,22

7:23 8:2,20 9:12

crowd 24:7

culture 34:20

currently 10:1

customers 16:16,18

17:11 25:14

Case 1:20-cv-23230-AMC Document 136-3 Entered on FLSD Docket 10/25/2021 Page 13 of

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Page 50

D

D 2:16

Dade 8:2,11,21 9:12

damage 21:9,16

damages 13:16 15:1

15:13,15 20:20

27:11 28:25 29:2

dance 13:21,22,23,23

36:5,8

danced 12:13,15,15

12:16,17,17,19,21

12:22 25:9

dancer 12:3,11 16:6

34:19

dancers 37:20

dancing 12:25 14:7

17:1,2 31:17,19

42:17

date 6:3

DATED 46:20

dates 21:6 38:24

daughter 39:22,22

day 13:18 15:5 19:15

22:23 23:7,16,19

44:7 45:12 46:20

47:18

days 14:15 22:18,20

22:21,25 23:2,4,6,6

23:10,11,11,12,14

23:18 24:2 28:12

36:21 48:18

daytime 38:1,2

de 1:16 2:7

Dear 48:15

DeCampo 32:2,10,18

34:3

decision 31:3,5

declare 26:5,11

deduct 26:8

Defendant 1:12 3:3

Define 35:4

definitely 23:21 40:24

depend 16:25

depending 13:24

depends 18:18

Deponent 47:3

deposit 25:22

deposition 1:20,25

3:14,18 4:11,20 5:2

5:2,6 43:24 46:1,9

48:15,17,19

DEPOSITIONS 48:2

designed 22:5

determined 22:17

dialogue 33:20,23

Diamonds 12:13,15

12:16 13:1,11,17,19

14:5,7,8,12,13,24

19:16,18 21:3 25:9

26:13 28:20 29:1,5

29:16 30:2,18 33:1

33:5 34:6 36:19,19

37:8,18,23 38:12,17

38:23 40:1 41:2,17

41:24 42:15,17,25

43:6

difference 24:15

different 12:1 13:23

14:17 35:13

DIRECT 2:25 3:5

Discussion 6:6 43:22

dismissed 7:20 8:17

8:19 9:10,24

District 1:1,1 7:10

DIVISION 1:2

DJ 17:6 18:16 20:6

DJs 24:24

doing 28:6 38:8 41:1

41:23

dollar 16:17,18

dollars 18:21 34:19

donate 18:22

door 16:7 17:12 18:1

18:2,4 24:18

doors 15:6

Doral 12:17

dressing 21:20,21

28:7

drop 18:8

DUDLEY 2:2,4 43:3

43:17

duly 3:4 45:8

E

E 2:16 48:11

E-b-o-n-y 3:9

earlier 30:9

Earliest 6:12

early 7:15 8:9,9 24:6

38:3

earn 12:9 34:22

easier 12:3

Ebony 1:20 2:23 3:2

3:8 44:2 45:7 46:9

47:3,18 48:10

either 23:1

else's 14:17

employed 10:1,3

employee 35:22

46:15,16

employer 3:21,22

6:21

ended 14:6,11

enter 16:11

entertainer 11:2,9,15

11:16

entertainment 10:15

10:25 13:24 30:15

entire 36:6

entitled 15:15

entity 42:13

ESQ 2:2,4,9,10

et 1:8 47:3 48:8

events 13:22 35:2

eventually 14:19

everybody 14:17

everyday 31:6

exactly 25:5 37:11

EXAMINATION

2:25 3:5

Examinations 2:19

example 35:9

excuse 23:15

expectation 34:17

expenses 26:8,9 29:21

experience 16:6

expires 45:18 47:22

explain 43:19

explanation 7:4

external 27:18 41:4,6

extra 27:1

F

face 35:8

face-to-face 37:3

fair 21:6,7 24:1

familiar 5:5 41:12,16

far 6:11 20:7 26:20

father 39:17

Fax 48:13

February/March

15:11,16 17:22 21:5

federal 3:20 6:23

7:10 8:5

fee 15:25 16:1,3 17:7

17:8,11,11,13,15

18:1,3,14 24:16,17

25:4,5

feel 18:20

feels 18:22

fees 16:6,7,8,9,10,10

16:12 18:15 19:5

20:6,17,18,21 21:15

24:12 25:3 27:10,11

27:18 29:12 30:8

35:2

felonies 9:21

felony 9:19,23

felt 31:22 35:25 36:20

field 4:2

fifty 18:5

figure 5:25 20:22

file 4:10 26:1,15

filed 1:25 27:6 42:11

financially 34:8 46:18

fire 10:11 33:14,15

33:17

first 3:4 13:5 17:7,11

23:18 30:19 32:2,13

40:1,3,24,25 48:19

firsthand 6:1

five 17:4 23:12

flame 10:7,9,11,11,13

10:18 11:12 12:9,20

flat 16:1 17:12,15

float 12:5

floor 40:10

Florida 1:1,16,24 2:8

9:8,9 12:14,14,19

45:3,17 46:3 47:21

48:12

Fly 41:1,23

Follies 12:21

follows 3:4

form 25:10 26:22

former 3:20 6:21

forms 26:13

Fort 32:11,14

found 31:10

four 14:15,16 22:20

22:21 23:10,11,11

23:14 24:2 27:22,23

frame 13:15 21:4

22:19 27:24 34:6

42:16

Friday 23:5,21,24

48:7

Ft 48:5

full-time 12:6 15:12

further 43:15 46:14

48:20

G

G5 12:16

Gabbe 32:6 48:11

Gables 1:16 2:8

Galardi 1:11 13:10

30:10 36:24 37:2,14

37:17 39:18,23,25

40:4 41:12 42:24

47:3 48:8

Galardi's 14:6

Galardis 41:6 42:19

gatekeepers 38:20

Georgia 2:4 4:8 8:4

10:19

GERALD 2:6,10

getting 33:4

GG 45:19

girl 14:14 21:19,20

22:8,11,14,17

girls 14:10,15 16:25

17:4 19:24 20:3,10

21:22,23,25 27:17

30:23,24,25 32:20

33:4,10,15 36:8

give 5:15,16 19:1

26:18,19 27:2 35:9

43:8

given 17:9,10 31:21

gives 17:2

go 6:12,14 11:20

13:22 14:2,19 16:3

18:3 26:20 29:8

31:7 34:21 36:3,20

37:21 38:2,21 39:10

39:12,19 43:16

goal 22:10

goes 5:12 17:18,20,20

19:10 27:14

going 7:3 10:24 13:18

13:24 14:11,19 16:1

18:24 21:23 30:22

31:23 33:2,13 39:12

41:22 43:12

Goldstein 1:22 45:16

46:6,24 48:4,22

good 7:1 31:3,5 33:5

Gorda 9:1,6

gotten 7:18,18

Case 1:20-cv-23230-AMC Document 136-3 Entered on FLSD Docket 10/25/2021 Page 14 of

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group 17:4

guess 5:9,24 7:1

38:20

guy 17:2,4 36:1

H

hair 35:11

hand 18:24 45:11

happened 8:15 37:11

harassing 35:19

harassment 35:3,4,5

hard 29:18

harder 12:2

he'll 18:21,23

heard 36:23 39:20,21

40:21

hearing 31:4

heavy 31:1

held 6:6 43:22

hey 14:9 26:25 27:17

28:8 35:20 39:10

high 16:4

higher 24:4,5 35:2,2

hire 31:12

Hollywood 48:12

home 13:21,25 14:1,4

14:5

honestly 41:9

hour 4:24 17:20

hourly 17:20

hours 24:1,3 38:5

house 16:8,9,9,23

17:7,11 18:14 19:6

20:6,6 24:12,16,17

24:24 25:4,5

Houston 12:22

HOWARD 2:9

hundred 18:5,21

I

idea 21:8 38:8

Identification 47:19

ill 40:11,14,17

illegal 33:15,16

inaudible 8:10

included 25:2 27:5,10

Including 30:14

increments 17:20

independent 26:11

industry 31:1,2

information 6:24

initial 30:20

initially 11:9,11,14,16

11:22 26:21 32:12

32:13

Inside 38:7

interested 46:18

introduced 32:17,19

33:18

introduction 32:23

32:25

invested 43:5

involved 4:17 22:19

27:24 42:15

involving 3:20

issue 4:23 34:16

39:13

issues 31:11 33:8

36:17,18

items 28:13

J

J 2:6,10

Jack 39:18,21,23,25

40:4

January 15:7,15

17:21 21:4

Jeffrey 1:22 45:16

46:6,24 48:4,22

job 31:9,10 33:13,14

July 4:22

jump 31:7

June 6:4,16

K

k-s-t-o-n 10:23

keep 21:5

kind 4:3 11:19 12:4

39:1

King 12:13,15 13:1

13:11,17,19 14:4,7

14:7,12,12,24 19:16

19:18 21:3 25:9

26:13 28:20 29:1,4

29:16 30:2,17 32:25

33:5 34:6 36:18,19

37:8,18,22 38:12,17

38:23 40:1 41:2,17

41:24 42:15,17,25

43:6

knew 26:22 28:6 41:5

know 7:2 13:6 14:18

17:16 21:23 27:10

27:13 28:10 32:15

33:1,8 37:16,19

38:11,14,15 39:3,16

40:6,11,13,14 41:1

41:3,21,23 42:10,10

42:12,18,20,22,24

43:5

knowing 39:5

knowledge 6:1 9:18

26:23

L

Large 1:24

late 38:4

latest 24:10

Lauderdale 32:11,14

48:5

law- 4:17

lawsuit 4:18 30:19,20

31:8,23 32:20 33:2

33:3,4,9

lawyer 33:22

learn 35:15

leave 24:11 40:10

left 29:15,22 30:2,7

Lennys 41:7

Leon 1:16 2:7

let's 5:9 6:14 8:8 9:25

20:5 21:2 35:20

level 31:16

license 11:23

likes 18:19

LINE 47:5

LITIGATION 48:2

little 12:2 36:2

located 4:7 32:10

long 11:7

longer 31:17,19

look 18:25 41:19

looked 25:25 40:16

looks 35:11

lose 33:13 35:10

losing 33:12

lot 16:17 18:20 30:21

30:22

loud 5:20

Lounge 10:7,13,14

Low 41:1,23

M

M 1:22 45:16 46:6,24

48:4,22

M-a-y-f-i-e-l-d 3:11

ma'am 6:3

Magic 12:21

main 21:21

management 9:17

manager 20:10

managers 39:13

manner 35:20

Masters 41:14,15

Mayfield 1:20 2:23

3:2,8,13 44:2 45:7

46:9 47:3,18 48:10

48:15

mean 21:19 29:20

33:6 34:13

meet 19:4 36:4 39:23

39:25

meeting 36:3

met 32:6,8,13,13 37:2

37:3

Miami 1:2 14:5,9,11

36:8 48:5

MIAMI-DADE 45:4

46:4

Michael 32:2,10,17

33:18 34:3

middle 19:4

Milner 1:8 32:21 47:3

48:8

Milner's 34:2

mind 41:6,8

mine 7:1

mini 22:2

minimum 14:15 19:8

20:25 21:9,14

misdemeanor 9:19,20

misdemeanors 9:21

mobile 13:25

mom 16:23 19:6 20:7

moment 43:8

moms 24:24

Monday 1:17 23:5,21

23:24 47:4 48:16

money 12:9 15:13

16:14,16,17,20,21

16:21,22,24 17:8

18:19,20,22,24

25:16 30:2,6,8 33:7

34:17 35:11,16 36:1

36:9,10 42:25 43:1

43:5

month 15:8 19:25

27:22,23

morning 24:8,9,11

moved 32:12

N

N 2:16

name 3:7 36:23 41:8

need 14:10 27:17

31:7 35:12,12,15

needed 12:5 19:11

negative 30:7

never 18:23 25:12

37:3,5 38:4,4,21

39:20 40:6 41:3,8

41:17

night 16:2,3,4 17:9

19:8 20:12,14,16

29:17,24,25 30:3

nightly 15:25

nights 30:6

Nikki's 12:23

Nope 43:17

Northern 7:10

Northside 2:3

Notary 1:23 45:17

47:21

notes 46:12

notice 1:24 48:20

numbers 36:4,4

O

o'clock 18:1,2 24:8

24:10,10,11 38:3

OATH 45:1

Objection 43:3

obviously 36:23

occur 27:20

occurrence 27:19

office 26:20 27:1 37:4

37:7,9,20,22 38:9

38:23 39:6,10,18

official 45:11

oh 9:23 12:23 34:16

34:18 35:24 41:18

okay 5:11,13,14,19

5:22,23 6:2,14,20

6:25 7:13,21 8:18

9:18,25 10:14 11:24

12:8 13:4,10 15:2

15:21,24 17:24

18:14 19:1,7,9 20:5

20:13 22:4,24 23:23

24:17,20,25 25:8,16

27:23 29:11,20 30:5

32:7 33:23 34:24

39:16,23 41:21

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42:14,24 43:10,11

once 39:10,15 40:8

Onyx 12:19,19,22,22

14:4,8 30:20,21

33:9 41:13,13,13

open 7:5,6 12:4 16:23

opened 13:18 15:6,6

40:1,4,7,24,25

opening 14:9

opportunity 5:15,17

opposed 5:21

order 28:10,13 29:8

ordered 29:4

original 14:20,23

ostracized 30:24

outfit 29:6,7,8

outfits 27:14 28:16,16

28:25 35:12

outs 35:3

outside 16:13 29:1

owe 33:6

owned 41:1,3,23

42:18

owner 4:13 13:11

38:18,19 39:16

owner's 39:11

oxygen 40:16

P

P.A 2:6 48:11

p.m 1:17,17

P.O 48:11

page 2:19 20:6 47:5

paid 16:4 19:2 25:9

25:11,12,13,14

29:21 30:7 40:6

41:4,9,17

park 19:24 20:4

parking 19:12,13,19

19:21,22,22 20:7

Parkway 2:3

part 10:10 20:20,24

21:16 22:11 28:24

29:2 41:10

particular 17:9

parties 12:1 13:23

22:2,7,12 27:15

35:1 46:16

parties' 46:17

party 4:14 21:22,24

21:25 27:16,16 28:1

28:7

passing 35:23

pay 16:1,10 17:12

18:2,16 19:12,19,22

24:6,17,20 33:3

paying 19:22

Peace 3:23,25

people 16:19 22:5

36:20 38:20 41:4,6

percentage-wise

27:20

perform 34:21

performed 11:2

period 13:5 36:6 40:3

person 31:21

personally 39:9 41:9

45:7

Phone 48:12

phonetic 32:2 41:7

physically 39:14,15

pick 16:20,20,21 22:8

22:21 23:6 36:21

picked 22:22,25

Pinups 12:21

place 8:1,2,8 13:16

36:20

places 12:1 13:23

Plaintiffs 1:9 2:5

please 3:7 5:20 48:16

pocket 43:1

point 11:17 40:14,22

pole 35:15,16

Ponce 1:16 2:7

Pops 41:7

popular 36:8

positions 12:4

preferred 36:19

presumptuous 10:24

pretty 5:5 16:16

prior 7:13 8:3,10,11

8:13 12:8,9,19,20

12:24 14:7 33:9

private 12:1 21:24,25

22:2,11

probably 6:12 7:2

11:22

problems 33:16

34:10,12,13

process 5:7

produced 47:19

productive 34:7

Professional 1:23

46:7 48:1,4

protocol 5:12

provided 19:12

providing 29:9

Public 1:23 45:17

Public-State 47:21

published 26:25

pull 21:25

Punta 9:1,5

purchased 29:1

pursuant 1:24

put 16:22 43:1

Q

question 5:15,17

14:20,23 21:3 23:18

41:22

questions 33:19

43:15

quickly 5:13

R

R.P.R 46:24

range 17:16 24:10

rare 18:9,10

read 43:23

reading 43:20 48:19

really 7:3 18:10,10

23:25 38:15 41:3

reason 24:4 31:13

reasonable 24:7

received 25:23

reckless 35:7

record 6:5,6 43:22

46:11

recount 20:5

reference 4:12 6:18

31:21 35:14 39:20

39:21 48:15

referring 21:4

regarding 6:1

Registered 1:22 46:6

48:1,4

regular 19:12 27:19

relates 37:18

relating 38:12

relative 46:15,16

relocated 15:11

remember 8:7 9:15

14:21 20:2 37:11

40:15,22

rent 22:6

repeating 21:6

repercussions 34:23

34:25

report 46:8

Reporter 1:23 43:21

46:7 48:4

REPORTER'S 46:1

REPORTERS 48:1

REPORTING 48:1

represent 14:2

requested 46:10

resolved 7:8

respectfully 14:20

restaurants 12:1

restroom 43:13

result 8:16 9:16

return 26:9

returns 26:1,6,12

review 46:9

Rick 41:8

right 5:7 7:9 8:13

13:3,15 17:7 18:17

19:14 20:18 22:13

24:1,19 25:13,19

27:3 30:17 34:5

36:24 38:13,17

42:16

righty 9:25 27:8

room 21:21 28:7

rooms 21:20

rotate 23:22

RPR 48:22

rumors 30:22

S

S-t-r-o-k-e-r-s 10:6

safe 36:20

sat 37:5

Saturday 23:5,22,24

saw 25:25 38:9,22

40:20

says 33:3,3,6,13

seal 45:11

second 20:2

section 22:1 35:24

36:1

see 9:25 37:25 38:6

39:14,19 40:4,8

seeking 15:14 20:24

seen 18:9 39:9,15

40:15

sell 28:6

sense 26:24 29:9 35:5

sent 9:17

separate 21:21

September 46:20

48:7

SERVICE 48:1

servicing 4:5,6

settled 33:10

settlement 33:10

share 21:21

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shoots 22:6

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side 11:20

signature 48:17

simply 5:25

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single 30:3

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specifically 22:1

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speculating 39:4

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started 11:11 13:17

13:19 14:12 15:2,5

16:13,15 19:22,23

20:3 34:1

starts 17:18

state 1:24 3:7 8:5,6,6

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Choice - United 

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45:3,17 46:3

STATES 1:1

stenographic 46:11

stenographically

46:8

step 27:1

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stop 15:9

stopped 15:10 40:6,7

40:23

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taxes 26:15 27:6 33:1

TELECONFEREN...

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throwing 16:16,18

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total 15:17 21:12

23:10,11

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transcript 46:10,10

48:16

TRANSCRIPTION

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trespass 9:12

trespassing 7:22,23

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trial 48:18

tricks 35:15,16

true 46:11

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20:6 24:22,23

1099 26:13

1099s 26:16,25 27:3,4

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2000s 8:9

2004 11:12,13

2006 8:10,11,13

2007 11:23

2008 8:12 9:13 13:18

2009 13:18,18 15:2,3

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21:4 26:3 40:19

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2010 16:14,15 38:25

42:1

2011 20:1 42:3

2012 13:20 20:2 39:1

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2013 42:7

2014 15:3,8,10,16

17:22 21:5 42:9

2019 4:22 6:16

2021 1:17 44:7 45:12

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4 24:7

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954 48:5

954-303-9882 48:12

954-983-1427 48:13

955442 45:19

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