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 AMERICAN ARBITRATION ASSOCIATION

 EMPLOYEE ARBITRATION TRIBUNAL

 CASE NO.: 01-20-0005-4874

ELLIANDRIA GRIFFIN,

 Claimant,

-vsTERI GALARDI, an individual,

 Respondent.

________________________________________/

 - - -

 ARBITRATION BEFORE JOHN BARKETT

 March 19, 2021

 9:58 a.m. - 4:48 p.m.

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1

 APPEARANCES:

2

On behalf of the Claimants:

3

 RICHARDS LEGAL

 mutepe.akemon@richardslegal.com

4

 BY: MUTEPE AKEMON, ESQUIRE

5 On behalf of the Respondent:

 GERALD J. TOBIN, PA

6

 4551 Ponce de Leon Boulevard

 Coral Gables, Florida 33146

7

 305-858-9020

 howardbrodskyesq@aol.com

8

 geraldtobinpa@aol.com

 BY: HOWARD BRODSKY, ESQUIRE

9

 GERALD J. TOBIN, ESQUIRE

10

11

 - - -

12

13 INDEX

14 MARQUISHA HOLMES

Direct Examination by Mr. Akemon.......................7

15 Cross-Examination by Mr. Tobin........................41

Redirect Examination by Mr. Akemon....................74

16

ELLIADRIA GRIFFEN

17 Direct Examination by Mr. Akemon......................81

Cross-Examination by Mr. Tobin.......................122

18 Redirect Examination by Mr. Akemon...................159

19 TERI GALARDI

Direct Examination by Mr. Brodsky....................170

20 Cross-Examination by Mr. Akemon......................194

21

22

23

24

25

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1

 PROCEEDINGS

2

 *****

3

 THE ARBITRATOR: We're here for the final

4

 hearing in the matter of Elliandria Griffen and

5

 Marquisha Holmes, claimants, versus Teri Galardi,

6

 respondent. I'm Arbitrator John Barkett. Let's

7

 have appearances for the record; counsel for the

8

 claimants?

9

 MR. AKEMON: Attorney Mutepe Akemon. That's

10 M-U-T-E-P-E.

11 THE ARBITRATOR: And counsel for the

12 respondents?

13 MR. BRODSKY: Howard Brodsky and Gerald Tobin

14 on behalf of Teri Galardi, respondent, who is

15 present.

16 THE ARBITRATOR: Very good. And Ms. Galardi

17 is present, as Mr. Brodsky just noted, and Ms.

18 Holmes and Ms. Griffen are also present. And are

19 we going to have any other witnesses today?

20 MR. AKEMON: No, Your Honor.

21 MR. BRODSKY: No, Your Honor.

22 THE ARBITRATOR: Excellent. Very good. And

23 I'll note for the record that to expedite matters,

24 I suggested and the parties agreed that we have Ms.

25 Holmes and Ms. Griffen prepare just declarations

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1

 setting forth their damages claims. And they've

2

 done that, and we'll make them exhibits, and they

3

 can swear -- once they get sworn in, they can swear

4

 to the fact that this is their claim. Who will be

5

 the first witness?

6

 MR. AKEMON: Your Honor, the claimants call

7

 Marquisha Holmes.

8

 THE ARBITRATOR: Okay. So the plan will be to

9

 put Ms. Holmes here in this chair. You can ask

10 questions from over there. And Stephanie, the

11 court reporter, will sit right between you, and she

12 will be able to pick up everything.

13 The only thing I ask is that you speak up,

14 because the lawyers will be -- on the respondent's

15 side will be behind Ms. Holmes. So just speak up

16 when you're talking. If they have any trouble, any

17 difficulty hearing you, I'm sure they will tell you

18 that. But you may proceed.

19 So, Ms. Holmes, if you don't mind coming over

20 here, the court reporter will swear you in or have

21 you indicate that you'll be telling the truth if

22 you're not giving oaths. Is everybody comfortable

23 from the distancing standpoint?

24 I've done my best to set this room up, so I

25 think we're all properly distanced. Anybody

Exhibit 1 

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1

 nervous about the setup? You're okay?

2

 MR. BRODSKY: We're fine.

3

 THE ARBITRATOR: Very good.

4

 MR. BRODSKY: Can we move Mr. Tobin over here?

5

 THE ARBITRATOR: Sure.

6

 MR. TOBIN: He worries about my ability to

7

 hear.

8

 THE ARBITRATOR: Go ahead, if you would, to be

9

 sworn in.

10 (Thereupon, the witness was duly sworn in

11 accordance with the law.)

12 MR. AKEMON: Your Honor, may I give a brief

13 opening statement, if I may?

14 THE ARBITRATOR: You know, I forgot about

15 that. Did you want to make openings? I thought

16 with all we've been through, there was no need to

17 do that. But yes. Mr. Tobin, did you want to make

18 an opening statement?

19 MR. BRODSKY: I don't think it's necessary.

20 THE ARBITRATOR: But you certainly may. You

21 have the right to by all means. And then if you

22 want to respond, gentlemen, you may, but there's no

23 need to. I think I understand the case. Go ahead.

24 MR. AKEMON: Your Honor, we're here on the

25 issue of damages in the matter of Darden, et al v

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1

 Teri Galardi.

2

 As you're aware, this Honorable Court granted

3

 our motion for summary judgment on the issue of

4

 employer liability as to Ms. Galardi. The Court

5

 asked us to address four separate issues for the

6

 final hearing. Those issues are does the statute

7

 allow for the respondent to avoid damages --

8

 THE ARBITRATOR: Mr. Akemon, you don't need to

9

 go through this. I know what I wrote, I know what

10 the issues are. If there's something else you want

11 to say about what I'm going to hear today, I'll be

12 happy to listen to that.

13 MR. AKEMON: No, Your Honor. It's our

14 position that the case law supports that, one --

15 THE ARBITRATOR: Let me shut this door. The

16 only reason -- I think we'll be fine. We'll finish

17 in one day. But -- I'm happy to hear you talk, but

18 you're also going to set forth all that case law in

19 your post-hearing submissions.

20 MR. AKEMON: Yes, I am.

21 THE ARBITRATOR: And I'm not going to decide

22 legal questions today. So I will listen to you if

23 you wish, but it might -- we might expedite matters,

24 since you're starting now 33 minutes later than we

25 were supposed to start, if you go right to

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1

 questioning, unless there's something about the

2

 facts that you want to tell me that you want me

3

 to hear.

4

 If you're just going to make arguments about

5

 what you think the law should be or what the

6

 answers are to the questions I posed, save all that

7

 for your brief.

8

 MR. AKEMON: Yes, Your Honor.

9

 THE ARBITRATOR: Having said that, if there's

10 something else you want to add, by all means, go

11 ahead, sir.

12 MR. AKEMON: No, Your Honor. I'll start with

13 the questions.

14 THE ARBITRATOR: Very good. I understand the

15 case. I just -- I appreciate the formality, and I

16 know it's always good to be reminded of things. But

17 I'm quite familiar with the law here, and I'm

18 looking forward to your briefs because I still

19 have these questions that I would like to see

20 answers to, but I want to hear all the evidence

21 first.

22 MR. AKEMON: Yes, Your Honor.

23 THE ARBITRATOR: So let's get to that.

24 DIRECT EXAMINATION

25 BY MR. AKEMON:

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1

 Q. Please state your name for the record, please.

2

 A. Marquisha Holmes.

3

 Q. And please slow down because the room is

4 pretty large.

5

 A. I know I talk fast. I'm sorry. Marquisha

6 Holmes.

7

 Q. Can you spell that for the --

8

 A. M-A-R-Q-U-I-S-H-A, last name Holmes,

9 H-O-L-M-E-S.

10 THE ARBITRATOR: It's I-S-H-A? So this has

11 been spelled wrong this entire case?

12 THE WITNESS: What is it?

13 THE ARBITRATOR: It's E-S-H-A according to the

14 records. But no problem. I'm glad to know how to

15 spell it now.

16 THE WITNESS: Okay.

17 BY MR. AKEMON:

18 Q. And were you a dancer at the King of Diamonds

19 Gentleman's Club from approximately 2009 to 2014?

20 A. Yes.

21 Q. And when did you stop dancing at the King of

22 Diamonds?

23 A. The night they closed.

24 Q. And do you know what month and year that was?

25 A. 2018.

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 Q. And during that time, can you please describe

2

for the Court how you became a dancer at the King of

3 Diamonds?

4

 A. Well, I was -- I worked -- I started working

5

there when it was Crazy Horse. So when it switched over

6

to King of Diamonds, I was just still there. So I was

7 one of the house girls, what they say.

8

 Q. And can you tell the Court what a "house girl"

9

is?

10 A. A house girl is --

11 Q. And please slow down.

12 A. I'm sorry. The house girls are like, you

13 know, they say the main girls, the girls who work there

14 the longest. It's not -- you know, the house girls.

15 Not you fly in from out of town.

16 If you live here, you're house, you're

17 stationed here. They don't like us to work anywhere

18 else, just work there. So that's the house girls.

19 Q. So from my understanding, a house girl is

20 someone who consistently works at King of Diamonds?

21 A. Yes. So we have a schedule we have to follow

22 with the rules that's there. You have so many hours you

23 have to work, you have so many months you have to work

24 there, you can't work at any other club or, you know,

25 you have to pay the outside rate. You know, that's what

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1

the house girls are.

2

 Q. Okay. And can you describe for me how you

3 were hired, the audition process, for working at King of

4 Diamonds?

5

 A. You come in, show your ID, do auditions, and

6

then they hire you.

7

 Q. And when you began work -- let's go through a

8

typical day at King of Diamonds. When you would arrive

9 at King of Diamonds, what would you do to begin your

10 work shift?

11 A. Well, you have to go in first, and you have to

12 pay. You have to pay before you come in. You can't

13 just go get dressed and say, oh, you'll pay at the end of

14 the night. You have to pay a certain amount of money to

15 work. So you go, you pay and you start working.

16 Q. And do you remember who you would pay that

17 money to?

18 A. Yeah. Tan was the --

19 THE ARBITRATOR: I'm sorry, paid to who?

20 THE WITNESS: Tan.

21 THE ARBITRATOR: Can you spell it for the

22 court reporter?

23 THE WITNESS: You pay the club Tan, I don't

24 know.

25 BY MR. AKEMON:

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1

 Q. He wants you to spell the name of the person

2

that you paid the money to.

3

 A. Oh, Tangala, T-A-N-G-A-L-A, I believe.

4

 THE ARBITRATOR: Oh, that's what you were

5

 saying, Tan?

6

 THE WITNESS: Yeah. I'm sorry.

7

 THE ARBITRATOR: That's all right. I want to

8

 make sure the court reporter gets the names right,

9

 so Tan is not something we normally call somebody.

10 THE WITNESS: Right. Me either, but that's

11 what we call her.

12 THE ARBITRATOR: That's all right. It's a

13 nickname, and I get it, but the court reporter

14 needs to get it all right.

15 THE WITNESS: All right. Well, we'll pay the

16 club when we go to work, and then we go upstairs.

17 And then we're required to pay the house mom.

18 You're required to pay a certain -- like things.

19 If you get on stage, you have to pay certain

20 things. Like to go on stage, you have to pay at least

21 $200 to go on stage. If you don't pay that day,

22 you're not going on stage.

23 BY MR. AKEMON:

24 Q. So let's back up for just a second. When you

25 arrived and you paid Tan, was there a term that they

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1 used to describe this payment?

2

 A. Yeah, a house fee.

3

 Q. It's called a house fee?

4

 A. Yes.

5

 Q. And would you also sign in for the beginning

6 of your shift?

7

 A. Yes, you have to. You have to sign in for the

8 house fee. You're on a list, they put your name there,

9 and they put your phone number next to it and your

10 e-mail, and they have this e-mail they send out to the

11 girls.

12 And if you -- we have to post it on Instagram.

13 You have to post everything on Instagram to get the

14 rates. You have to show them the Instagram post or that

15 someone texted you and sent you the label before you pay

16 the house.

17 If you don't have that or they didn't assign

18 you that, you had to pay a different fee, which is a

19 higher fee. So that's girls that come out of town that

20 don't know about the club just walking in.

21 Q. And was there on occasion times that they

22 would notify you in advance what the house fees were

23 going to be?

24 A. They would notify us what the house fee would

25 be, but it would change. Every week it would be

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1 different.

2

 So say Monday -- say it's spring break.

3 Spring break, it's going to be higher than anything. So

4

you're going to start off paying close to $300, 9:00.

5 The girls from out of town have to pay five. So it will

6 be different. It will fluctuate from different times.

7

 Q. Go ahead. Finish.

8

 A. From different times it would. So the slow

9 nights, say like on Sunday, you come in, we probably

10 pay -- you pay $250 all night. You can come in until

11 12:00. The cutoff time is 12:00 midnight.

12 So the less you'll pay, $200. You're not

13 paying -- $200 on a regular night. That's the lowest

14 you're going to pay. It can go all the way up. Like if

15 Mayweather is there, oh, we're paying $400, $500.

16 Q. And when you say Mayweather, are you referring

17 to a celebrity or --

18 A. Yeah, any celebrity, we're going to start --

19 the house girls are going to start at $500. Like

20 that's -- yeah.

21 Q. And these house fees are mandatory?

22 A. Yeah. You got to go -- you got to pay before

23 you come in. You pay in the front where they check your

24 bags. They are not letting you through unless you pay

25 those fees.

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1

 Q. And what's the highest amount of house fee

2

that you paid to work at King of Diamonds?

3

 A. A lot of money. Maybe -- I don't know. I

4 don't really -- I don't know the exact amount.

5

 Q. And during this time period -- and, Your Honor,

6 we entered the declaration -- well, we stipulated to the

7 declaration that we're going to use, so I don't want to

8 waste the Court's time by going through all those

9 numbers.

10 THE ARBITRATOR: That's fine. You don't have

11 to. If there's anything you want to emphasize,

12 because there is a paragraph here where you

13 indicated that on average, you were required to pay

14 approximately $150 per shift in house fees. That's

15 what appears in this declaration.

16 MR. AKEMON: Yes, Your Honor. That's what I

17 was going to get to, but I didn't want to go

18 through that because I was going through every

19 day. So --

20 THE ARBITRATOR: Well, you asked her the

21 question about what the lowest was that she

22 received. If you want to put this into evidence

23 and go over any of it, that's fine. You're welcome

24 to do that.

25 BY MR. AKEMON:

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1

 Q. Let me start here. Ms. Holmes, what's the

2 average amount of house fee that you paid the King of

3 Diamonds?

4

 A. Average is $150.

5

 Q. Okay. And were you required -- let's go

6

through the rest of your shift. You would work -- after

7 you paid, you would then entertain customers at the King

8 of Diamonds?

9

 A. Yes.

10 Q. How would you get paid?

11 A. From the customers.

12 Q. Okay. Would they hand you the money

13 personally?

14 A. Yes.

15 Q. And would you also engage in, for purposes of

16 this arbitration, we'll call them lap dances, where you

17 danced personally for a customer?

18 A. Yes.

19 Q. And were you paid for those dances?

20 A. Yes.

21 Q. To the best of your knowledge, did the club

22 monitor keep track of the number of dances that you

23 participated in during any given shift?

24 A. No.

25 Q. And to the best of your knowledge, did the

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1 club monitor or keep track of the amount of tips that you

2 earned while you worked at King of Diamonds?

3

 A. The singles, they take ten percent from the

4 singles.

5

 THE ARBITRATOR: I'm sorry, I didn't

6

 understand what you said.

7

 THE WITNESS: I'm sorry. They take ten

8

 percent of the money. So when you get off stage,

9

 you have a bucket, they will take the money. We're

10 not allowed to have the money. They will count the

11 money and take the ten percent out, and then they

12 will put your name usually in envelopes and you'll

13 get it back at the end of the night.

14 BY MR. AKEMON:

15 Q. But to the best of your knowledge, did they

16 write down how much you made every night in tips to the

17 best of your knowledge?

18 A. No.

19 Q. And so let's explore the ten percent for just

20 a second. You were required to pay ten percent at the

21 end of every night?

22 A. Yes.

23 Q. And who would determine what your ten percent

24 would be?

25 A. The managers.

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 Q. The managers make that determination?

2

 A. Yes.

3

 Q. And were you required to tip out anyone else

4 at King of Diamonds?

5

 A. Yes. We had to tip out the DJ, the house mom,

6 mandatory, the on floor host. So say it's 9, 10

7

floor host and they don't help you --

8

 THE ARBITRATOR: I'm sorry, DJ, house mom, and

9

 what was the next one?

10 THE WITNESS: The floor host.

11 THE ARBITRATOR: Oh, floor host?

12 THE WITNESS: Yeah. Like the -- I don't know

13 if it's the running man or --

14 THE ARBITRATOR: Floor house is fine as long

15 as I understand the words.

16 THE WITNESS: Oh, I'm sorry. So it's 9 or

17 10 shift, you have to pay them at least $20, $30,

18 like each girl. Like it's mandatory. They go

19 and they -- you know, they have a list at the end

20 of the night.

21 So if you don't -- you have your name,

22 they will cross out. If you didn't pay this, you

23 didn't pay that, they won't let you leave. They --

24 you have a list.

25 So all the girls running around saying, oh, I

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1

 paid, I paid this, I paid this. Some guys will

2

 lie, oh, you didn't pay me, you didn't pay me, you

3

 have to pay them again or you can't leave.

4 BY MR. AKEMON:

5

 Q. And would the floor host be part of the

6 security staff at King of Diamonds?

7

 A. Yes.

8

 Q. Did you choose the security staff at the King

9 of Diamonds or the floor host?

10 A. No.

11 Q. Were you given the ability to choose which

12 floor host would assist you or would pick up your money?

13 A. No.

14 Q. And tipping these individuals, the house mom,

15 the DJ and the floor host, were these tip-outs

16 mandatory?

17 A. Yes.

18 Q. Were you disciplined at any time for not

19 tipping one of these individuals, say the DJ, the house

20 mom or the floor host?

21 A. Yeah. They would suspend us, or, oh, you don't

22 come back, $250, and then you come back, and you forget

23 about it -- like you forget about it, when they take your

24 singles, they will take the money out of it. Oh -- I'm

25 like, oh, I know this much money, I know how much money I

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1 made, they will say, oh, remember you have your $250 fine

2 or they will say that, and there's nothing you can do

3 because they already took your money out.

4

 Q. Slow down just a little bit.

5

 A. I'm sorry.

6

 Q. The court reporter is typing. And with

7

respect to the DJ, did you pick the DJ or hire the DJ

8

for the club?

9

 A. No.

10 Q. Did you have any involvement in selecting the

11 songs that were played throughout the night at the club?

12 A. No.

13 Q. Were you disciplined for not tipping the DJ?

14 A. Yes. You're not going to work if you don't

15 tip the DJ. The DJ makes -- that's where most of the

16 money comes, the DJs, too. That's one of the most

17 important things, paying the DJ the money. If you don't

18 pay the DJ, you don't get on stage, you're not going to

19 work.

20 Q. And to the best of your knowledge, the DJ was

21 hired by the club?

22 A. Yes.

23 Q. And to the best of your knowledge, the DJ

24 determined what songs were being played during certain

25 sets as well?

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1

 A. Yes.

2

 Q. And can you describe to the Court what a set

3 was?

4

 A. A set is three songs, first song clothes on,

5

second song topless, third song nude.

6

 Q. And would the DJ give you verbal instructions

7 during these sets?

8

 A. Yes.

9

 Q. And at the end of the night, you previously

10 described ten percent. Is that a tip-out or a mandatory

11 payment made to the club?

12 A. Yeah, it's mandatory. Out of $100, they take

13 out $10. So of the pot money, if you get $100 in

14 singles, you'll get $90. And then they give it to us,

15 and they give me the whole $90; when I go upstairs, they

16 will give me back $80.

17 Q. Okay. So let's describe it. So at the end of

18 the night -- let's go to the end of the night. When you

19 would get to the end of your shift, can you describe to

20 the Court what that would consist of?

21 A. At the end of the night, you go into the

22 locker room and you get changed. You can't do anything

23 until you're fully dressed. You go up to the house mom,

24 she gives you a list. You have your name on it, you

25 have all the lists of everybody you have to pay.

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1

 You pay the house mom, she has -- she signs.

2 She says you have me, floor host, you have to go around,

3 oh, did I pay you, did I pay you. The DJ has to be

4 marked off. Everything has to be marked off or you

5

can't leave. The money, ten percent, is the bucket. So

6

say I have a bucket of $200, $300, they take ten percent

7 off and give me the rest.

8

 Q. Okay. And could you leave prior to paying the

9

ten percent?

10 A. No.

11 Q. And what would happen if you attempted to

12 leave before paying ten percent to the club?

13 A. Well, you won't be able to work, and they will

14 fine you, but you won't get your money, because they

15 already have the singles. So if you leave without

16 paying everything, you're not going to -- they are not

17 going to give you your money back, because you have to

18 have everything signed before you can leave.

19 Q. What do you mean, you had everything signed?

20 A. You had to have a ticket, like a slip. So it

21 has house mom, DJ, which was Prince Marky D. You have

22 the floor hosts. Everything needs to be signed. And

23 then they give you your money back, and you're able to

24 leave.

25 Q. And have you ever attempted to leave without

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1

that slip?

2

 A. Yeah. Yes.

3

 Q. And what -- were you stopped?

4

 A. Yes, I was stopped, and they were like, oh,

5

you're not going to leave. They go -- you know, because

6

it's security. It's the floor host. No, you're not

7 going to leave.

8

 Basically, they are guarding the doors, and --

9

it's crazy. Like, they would say, you're not going to

10 leave here, you're not going to come again, this, that,

11 and this, until you pay them. But you pay them because

12 you want to get your money back, you know?

13 Q. And on average, if we were to take the amount

14 of money that you paid in security, the house mom, the

15 DJ and the ten percent, on average, can you describe

16 for the Court what that average would be per night?

17 A. At least $250 a night.

18 Q. And are you -- let me go back. Strike that,

19 Your Honor.

20 When you say $250 a night, are you including

21 house fees and the tip-outs?

22 A. No. The house fee, what we pay to get in the

23 club, has nothing to do with while we're working. That's

24 to get in the door. Basically, it's not -- you can come

25 to work and pay $500 and not make $100. It happens so

Page 23

1 many times. They don't care. You still have to pay

2 everybody accordingly.

3

 Q. Okay. And when you would pay these funds, you

4 would have to consistently pay these funds every shift?

5

 A. Every shift. Every time you work.

6

 Q. And on average, how many days of a week per

7 week would you work at King of Diamonds?

8

 A. I would work at least five, six days a week.

9

 Q. And would that fluctuate? Would you work some

10 days seven days a week or --

11 A. Yeah, some days, I work seven.

12 THE ARBITRATOR: Sorry, you said some days 

13 you work seven?

14 THE WITNESS: Sorry. Some weeks I will work

15 seven. Sorry, Your Honor. Some weeks I will work

16 seven days, you know, seven days a week. And some

17 weeks I will work five or six days. It will, you

18 know --

19 BY MR. AKEMON:

20 Q. Fluctuate a little?

21 A. Yes.

22 Q. And at any point during your employment with

23 King of Diamonds, did you happen to write down or log

24 what you paid in house fees and/or tip-outs to the club?

25 A. Yes. That was a long time ago, though.

Page 24

1

 Q. And at any time during your employment --

2 strike that.

3

 From 2009 to 2014, did you write down the

4

times and dates for which you worked at King of

5 Diamonds?

6

 A. Yes, but you didn't need to write them down,

7

it was an every week thing. It was -- you have to be in

8 by 9:00. You have to go to work 9 until the end of the

9 night.

10 So it's not -- you can't come -- you know,

11 it's like every week, it's the same thing, same thing,

12 same thing. So it's not really something that you have

13 to write down.

14 Q. And from 2009 to 2014, what time would you --

15 on average, how many hours a day would you work?

16 A. At least nine hours. 9:00 to 5:00.

17 Q. And would that time fluctuate as well? Would

18 you come into work earlier and leave later on some days,

19 or would you -- would you work ten hours on some days,

20 or twelve hours on some days?

21 A. Yeah, because sometimes we had -- like they

22 have a Jamaican party, they have the car shows outside,

23 so I think we were -- it was a couple times that we had

24 some -- some girls actually spent the night in the club

25 because the club would open at 10:00 in the morning. So

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1

they had a pool party, so it would be longer times that

2 we would work.

3

 Q. Did the club also have mandatory meetings?

4

 A. Yes.

5

 THE ARBITRATOR: I'm sorry, mandatory what?

6

 MR. AKEMON: Mandatory meetings.

7

 THE ARBITRATOR: Meetings.

8 BY MR. AKEMON:

9

 Q. Did the club also have mandatory meetings?

10 A. Yes.

11 Q. And during what days of the week would those

12 meetings take place?

13 A. Wednesday, I believe. Wednesday.

14 Q. And was the club open or closed on Wednesday?

15 A. Closed.

16 Q. So there were no customers there to tip or

17 engage in?

18 A. No.

19 Q. In addition to that, were you paid for these

20 mandatory meetings?

21 A. No.

22 Q. How long would these mandatory meetings

23 typically take place?

24 A. They would start at 5:00, say either at 5:00,

25 they lock the doors at 5:30, the meeting would start at

Page 26

1 7:00. We would literally walk out of the club when the

2

customers are coming to the club to enjoy; that's how

3

long we were there. At least five hours those meetings

4 were.

5

 THE ARBITRATOR: I'm sorry, I lost track of

6

 your time. I don't understand what you just said.

7

 THE WITNESS: The meetings, they would make us

8

 come to meetings say 5:00 sharp.

9

 THE ARBITRATOR: That would be 5:00 p.m.?

10 THE WITNESS: 5:00 p.m. And we would be -- we

11 would stay at the meetings until the club opened

12 and actual customers are walking in; that's how

13 long we would be there.

14 THE ARBITRATOR: And what time did the club

15 open?

16 THE WITNESS: Sometimes, on the weekend --

17 well, it's a weekday, so 8:00, 9:00.

18 THE ARBITRATOR: Okay. So you would be in the

19 meetings until either 8:00 or 9:00?

20 THE WITNESS: Yes.

21 THE ARBITRATOR: From 5:00?

22 THE WITNESS: Yes.

23 BY MR. AKEMON:

24 Q. Ms. Holmes, do you recognize the young lady

25 sitting at the end of the table?

Page 27

1

 A. Yes.

2

 Q. Do you know her real name?

3

 A. No.

4

 Q. Do you know her dance name?

5

 A. Yes.

6

 Q. Could you tell the Court what her dance

7 name --

8

 A. Persuasion.

9

 Q. Slow down and say it louder.

10 A. I'm sorry, Persuasion. I hate this mask.

11 THE ARBITRATOR: Persuasion?

12 THE WITNESS: Yeah, Persuasion.

13 BY MR. AKEMON:

14 Q. And did you work with Persuasion at the King

15 of Diamonds?

16 A. Yes.

17 Q. And would you often see Persuasion at the King

18 of Diamonds?

19 A. Yes. She worked just as much as I worked,

20 every day. Like we would see each other all the time.

21 Q. What are any other fees or tip-outs that the

22 club had that were mandatory?

23 A. Fees, mandatory fees besides what --

24 Q. I'm just asking was there anything else you

25 had to tip out?

Page 28

1

 A. No, we had to tip out house mom ten percent --

2 oh, we had to give the managers of course. The hype

3 man, Rick, we had to tip the managers. Yeah. Rick, we

4 had to -- yeah. That was mandatory.

5

 Q. And you're asking for damages in this case,

6 monetary damages?

7

 A. Uh-huh.

8

 Q. And you're also asking for damages from 2009

9

to 2014?

10 A. Yes.

11 Q. And did you on occasion have time to attempt

12 to calculate those damages?

13 A. Yeah. I -- I'm a Virgo, so I think a lot.

14 How I did it was I put the months and the years, the

15 months, the dates, the times, minimum wage. So I went

16 to five, six days a week, so I calculated that by the

17 minimum wage. So twelve months in a year. So that's

18 how I calculated it.

19 Q. Okay. And did you on occasion take vacations

20 or time away from King of Diamonds?

21 A. Yes.

22 Q. And approximately how many weeks or days per

23 year?

24 A. I always take like a month, because I have no

25 family here. So I would go back and see my family, just

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1 me and my son.

2

 Q. And it wasn't consistent, was it?

3

 A. No, it was just like once a year, nothing

4

crazy. I --

5

 Q. You stated -- I'm sorry. Go ahead.

6

 A. No, it wasn't months; it was just go, see my

7

family, come back and get back to work.

8

 Q. And would you do that on occasion throughout

9

the year, take a few days off here, a few days off

10 there?

11 A. Yes.

12 THE ARBITRATOR: And you're saying that would

13 add up to about a month a year? That's what you're

14 saying?

15 THE WITNESS: Usually like a month, yeah.

16 Usually a month.

17 THE ARBITRATOR: Okay.

18 THE WITNESS: Because I know my birthday is in

19 August, so, yeah, I would take off a couple days in

20 August. Yeah, about a month.

21 BY MR. AKEMON:

22 Q. And you're also asking the Court to reimburse

23 you tip-outs and house fees that you paid to King of

24 Diamonds, is that right?

25 A. Yes.

Page 30

1

 Q. Did you get a chance to calculate or attempt

2

to calculate what those tip-out amounts would be?

3

 A. Yeah.

4

 Q. Can you describe to the Court how you arrived

5 at that number?

6

 A. Well, the $250 that I would pay that they

7 would charge me over, not including the house fee --

8

like including the house fee, not including that, the

9 $250, and I would do the same thing. I would put $250

10 plus how many days a week I would work, and that's how I

11 calculated that.

12 Q. And it came -- do you have the ability today

13 to describe to the Court how much per year or how much

14 in total that you're asking the Court to award you in

15 damages?

16 A. No, I don't have my notepad, but --

17 Q. If I showed you a document, would it help

18 refresh your memory?

19 A. Yes.

20 MR. AKEMON: Your Honor, may I approach?

21 THE ARBITRATOR: Yes.

22 BY MR. AKEMON:

23 Q. Do you recognize that document, Ms. Holmes?

24 A. Yes. Do I recognize it?

25 Q. Yeah.

Page 31

1

 A. Yes, I seen it.

2

 Q. Okay. Is that a true and accurate reflection

3 of the number that you put together with your attorney?

4

 A. Yes. Wait. Yes.

5

 MR. AKEMON: Your Honor, that's the presuit

6

 notice, Mr. Brodsky and Mr. Tobin.

7

 MR. BRODSKY: What exhibit number is it?

8

 MR. AKEMON: It's -- it would be Exhibit

9

 Number 23 or 24 because they are back to back

10 between Ms. Holmes and Ms. Darden.

11 MR. BRODSKY: And, Your Honor, just so we're

12 clear, I'm referring to the exhibit notebook.

13 MR. AKEMON: Yes, Your Honor. This one right

14 here. Sorry.

15 THE ARBITRATOR: All right. This is where it

16 gets confusing to me because I have an exhibit

17 list that doesn't track the exhibit notebook.

18 MR. AKEMON: May I see the exhibit list that

19 you have, Your Honor?

20 THE ARBITRATOR: Well, that's what you

21 provided, the exhibit list that -- but it's in

22 here, you're saying? We just have to decide how

23 we're numbering these. Are we using the notebook

24 or using the list?

25 MR. AKEMON: We're using the notebook, Your

Page 32

1

 Honor, if I may, because they have a copy of the

2

 exhibit list --

3

 MR. BRODSKY: May I ask a question for

4

 clarification purposes?

5

 THE ARBITRATOR: I see what you're doing. Do

6

 these numbers match up? The declaration, does it

7

 match up to the letters? Are they exactly the

8

 same?

9

 MR. AKEMON: The numbers, yes, Your Honor.

10 THE ARBITRATOR: I see. Okay. I got it now.

11 So you're telling me I didn't even need to have you

12 do the declaration because you already had the

13 letters?

14 MR. AKEMON: Well, we did a presuit notice as

15 required under the law.

16 THE ARBITRATOR: Yes, I understand that, but

17 you're saying that the declaration is identical to

18 the letter?

19 MR. AKEMON: Yes, Your Honor.

20 MR. BRODSKY: Your Honor, may I ask a

21 housekeeping question?

22 THE ARBITRATOR: Yes.

23 MR. BRODSKY: The exhibit list that Your Honor

24 has is dated March 15th?

25 MR. AKEMON: I was going to ask you the same

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 thing. You may not have printed out the March 15th

2

 exhibit list.

3

 THE ARBITRATOR: I don't have an exhibit list

4

 from March 15th. I have it from February the 2nd.

5

 Is there another exhibit list? What did I miss

6

 here? Did I miss an e-mail? Is the exhibit list

7

 in your --

8

 MR. AKEMON: I believe I e-mailed you guys.

9

 Opposing counsel, you have that exhibit list?

10 MR. BRODSKY: I do.

11 THE ARBITRATOR: All right. Well, let's do

12 this. I'm not going to take up the time, but I'll

13 just write them down, so I'll sort it out later.

14 But Exhibit 23, the numbering that I used when I

15 dealt with objections was the proposed list, so

16 that's why I'm a little confused.

17 MR. AKEMON: I'm sorry. Let me fix this for

18 Your Honor. This is actually Ms. Simmons.

19 THE ARBITRATOR: I have letters here. Maybe

20 this is it. Is this April 27th?

21 MR. AKEMON: Yes, Your Honor.

22 THE ARBITRATOR: I have that.

23 MR. AKEMON: That's Ms. Griffen.

24 THE ARBITRATOR: Sorry. Yes. I have it. So

25 this Exhibit 23 marker -- 25, rather, is what we're

Page 34

1

 working with?

2

 MR. AKEMON: Yes, Your Honor. And I'll fix

3

 your --

4

 THE ARBITRATOR: No rush. All right. So I

5

 have this now. So we're looking at Exhibit 25,

6

 which is a letter dated April 27th, 2019, to Ms.

7

 Galardi from Miller Legal, PC, Harlan Esquire, 

8

 and the second page --

9

 MR. BRODSKY: That's Exhibit 25 in the book

10 or on the list?

11 THE ARBITRATOR: That's what I have marked,

12 25. Is it 25 in the book?

13 MR. AKEMON: I'm sorry, Your Honor. Exhibit

14 25, that was part of the motion for summary

15 judgment. Remember, we had 25 exhibits --

16 THE ARBITRATOR: This was what was in the

17 notebook handed to me yesterday. So that's where I

18 got it from. This exhibit number is not right?

19 MR. AKEMON: No, Your Honor.

20 THE ARBITRATOR: What exhibit number is this?

21 MR. AKEMON: This will be Exhibit 24.

22 THE ARBITRATOR: Let's have the court reporter

23 mark this, if you would, as Exhibit 24, Claimant's

24 Exhibit 24.

25 MR. BRODSKY: I have it in this notebook as --

Page 35

1

 MR. AKEMON: The one for Marquisha Holmes.

2

 There's two of them, Holmes and Griffen.

3

 MR. BRODSKY: I'm sorry?

4

 MR. AKEMON: There's Holmes and Griffen. One

5

 is 24, one is 25.

6

 MR. BRODSKY: What I have in the notebook from

7

 yesterday for Number 24 is claimant Lygia Simons'

8

 response to respondent Teri Galardi's request for

9

 production.

10 THE ARBITRATOR: I do, too.

11 MR. AKEMON: And I did tell you yesterday --

12 well, not yesterday -- I e-mailed -- the only thing

13 that was changed was Ms. Simmons was coming out,

14 and Ms. Holmes and Ms. Griffen was coming in.

15 So --

16 MR. BRODSKY: But in what number? That's

17 where I'm confused.

18 MR. AKEMON: It's the same number. So take

19 out Lygia Simons.

20 MR. BRODSKY: Yeah, but Number 24 in this

21 notebook says claimant Lygia Simons' response to

22 respondent Teri Galardi's request for production,

23 and then --

24 MR. AKEMON: Your Honor, if I could clarify

25 something.

Page 36

1

 THE ARBITRATOR: Right. You were in a hurry.

2

 You had Simmons in another case --

3

 MR. AKEMON: No, that's not what happened,

4

 Your Honor.

5

 THE ARBITRATOR: Tell me.

6

 MR. AKEMON: So on Monday, I had sent an

7

 e-mail to opposing counsel informing him because

8

 we're litigating the same issues in this case, the

9

 exhibits will remain the same in the binders, and

10 if he would consent to using the same binders so I

11 didn't have to duplicate another binder.

12 THE ARBITRATOR: That's fine.

13 MR. AKEMON: I also informed him that --

14 THE ARBITRATOR: But where -- he just wants to

15 know what number is the letter that has just been

16 marked as 24? He just needs to know where to put

17 that.

18 MR. AKEMON: That's what I'm getting to. So I

19 told him in an e-mail that Exhibit 24 --

20 THE ARBITRATOR: Forget the e-mail. We're

21 going to work on it for today. You can take out

22 whatever is in the notebook as 24 and put in the

23 letter that we've just marked as Number 24, which

24 is what I'm going to do. And you're telling me

25 that -- what's the Holmes exhibit number going to

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 be?

2

 MR. AKEMON: 24.

3

 THE ARBITRATOR: So they are both going to be

4

 24?

5

 MR. AKEMON: Yes.

6

 THE ARBITRATOR: A and B?

7

 MR. AKEMON: Yes.

8

 THE ARBITRATOR: All right. So we'll mark

9

 this 24A, Stephanie, if you would.

10 MR. BRODSKY: That's Griffen's?

11 MR. AKEMON: That's Griffen's. That will go

12 in Lygia Simmons.

13 THE ARBITRATOR: And when we get to Ms.

14 Holmes' letter, that will be 24B, and that way,

15 you'll maintain the symmetry of your notebook?

16 MR. AKEMON: Yes, Your Honor.

17 MR. BRODSKY: Okay. So this is going to be

18 24A?

19 MR. AKEMON: No, that's Griffen, so that's

20 24B.

21 THE ARBITRATOR: Griffen will be 24B, and

22 Holmes is 24A.

23 MR. BRODSKY: Do you have the Holmes one, too?

24 THE ARBITRATOR: You can insert those into

25 your notebook. I can bring a punchholer if you

Page 38

1

 wish during a break and you can punch a hole in them 

2

 and stick them in the notebook.

3

 MR. BRODSKY: I have a punchhole in this, but

4

 I don't have 24A.

5

 MR. AKEMON: You can use this one.

6

 MR. BRODSKY: Thank you. Got it.

7

 THE ARBITRATOR: You're going to pass me down

8

 24A?

9

 MR. AKEMON: I think I accidentally handed

10 it -- I'm sorry, I handed it to opposing counsel.

11 THE ARBITRATOR: Do you have a copy for him?

12 MR. AKEMON: I e-mailed it to him and I gave

13 it to him. I believe I gave it to him.

14 THE ARBITRATOR: Okay. You can hold onto it

15 for now. I have this --

16 MR. BRODSKY: I know --

17 THE ARBITRATOR: Okay. Very good. Pass it

18 back down to me if you would.

19 MR. BRODSKY: May I approach, Your Honor?

20 THE ARBITRATOR: Yes, of course, of course.

21 Thank you so much.

22 All right. So we've gotten this -- at least I

23 now know how the notebook works, and, apparently,

24 there's another exhibit list that I wasn't aware

25 of.

Page 39

1

 All right. So we have 24A in front of us, and

2

 this was a letter that you're going to ask the

3

 witness about. So go ahead.

4 BY MR. AKEMON:

5

 Q. Yes. And can you tell the Court what you're

6 asking for in total wages? I'm sorry, strike that.

7

 Can you please describe for the Court what

8 you're asking the Court to award you in total wages from

9 your time at King of Diamonds from 2009 to 2014?

10 A. 318,000 -- I have it written down, but --

11 Q. Please speak up.

12 A. $318,000.

13 THE ARBITRATOR: I'm sorry?

14 THE WITNESS: $318,000.

15 THE ARBITRATOR: 318?

16 THE WITNESS: Yes.

17 THE ARBITRATOR: And that's different from the

18 number that's in here, 340, but I understand 318 is

19 what you're seeking.

20 BY MR. AKEMON:

21 Q. And that's an approximate number, is that --

22 A. That's an approximate number. I went from --

23 I have two numbers. So yeah.

24 THE ARBITRATOR: Very good.

25 THE WITNESS: Can I show him this?

Page 40

1

 MR. AKEMON: No.

2

 THE ARBITRATOR: He has it.

3

 MR. AKEMON: I have it.

4

 THE ARBITRATOR: Trust me, he's your lawyer.

5

 He has it.

6 BY MR. AKEMON:

7

 Q. And you're also asking for an equal amount of

8

liquidated damages?

9

 A. Yes.

10 MR. AKEMON: No further questions, Your Honor.

11 THE ARBITRATOR: Okay. So we're not doing

12 anything with this declaration, just the letter?

13 MR. AKEMON: No, because the declaration and

14 the presuit notice are basically the same.

15 THE ARBITRATOR: That's not quite right,

16 because the declaration refers to -- I see. You

17 added 150 plus 100?

18 MR. AKEMON: Yes, Your Honor.

19 THE ARBITRATOR: I see. All right. Very

20 good. Mr. Tobin, your witness. Are you okay,

21 Stephanie? Do you need a break?

22 THE COURT REPORTER: I'm okay, thank you.

23 MR. AKEMON: Does anybody need a break? We're

24 all okay?

25 MR. BRODSKY: My client needs to use the

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1

 rest room if that's okay.

2

 THE ARBITRATOR: Okay. Take a moment.

3

 (Off the record.)

4

 THE ARBITRATOR: We'll go back on the record.

5

 So during our break, counsel conferred, and the

6

 letter dated April 27th, 2019, to Ms. Galardi from

7

 Miller Legal, PC has now been changed from 24A to

8

 23A, and we'll see a similar letter on behalf of

9

 Ms. Griffen. This one is on behalf of Ms. Holmes.

10 That will be 23B. Mr. Tobin, you may proceed with

11 your cross.

12 CROSS-EXAMINATION

13 BY MR. TOBIN:

14 Q. Good morning again, Ms. Holmes. How are you?

15 A. Fine, and you?

16 Q. Nice seeing you again.

17 A. You, too.

18 Q. Ms. Holmes, what year were you a dancer at

19 KOD?

20 A. 2008, 2009 -- you want me to list all of them,

21 or --

22 Q. I'm sorry?

23 A. Do you want me to just tell you -- okay, just

24 from this point to that point?

25 Q. Would you be comfortable taking your mask off?

Page 42

1

 A. Yes, because this is annoying. Okay. I'm

2

ready.

3

 Q. Now tell me the years. I'm sorry.

4

 A. 2008 to the close.

5

 Q. Till it closed?

6

 A. Yes, the day it closed, I was there.

7

 Q. Was it 2018 that it closed?

8

 A. Yes.

9

 Q. Did you dance before KOD?

10 A. No, not -- I was a go-go dancer before KOD.

11 Q. Where were you a go-go dancer?

12 A. In Illinois.

13 Q. I'm sorry?

14 A. In Illinois.

15 Q. In Illinois. And when did you come to South

16 Florida?

17 A. I went back and forth, because I went to

18 school before, so -- when I came to Florida, it was -- I

19 looked at two, three clubs, and then I went to -- it was

20 Crazy Horse. It wasn't King of Diamonds yet.

21 So I worked there, and when everything

22 switched over, it switched to King of Diamonds. It

23 wasn't a black club when I was hired there.

24 Q. It was not?

25 A. No. It was kind of mixed. We had Russians,

Page 43

1 we had Spanish. It was different. Like it was

2 up north, like the go-go dancing. But then it moved 

3

to the urban club when King of Diamonds came.

4

 Q. So in 2008, you went to work for King of

5 Diamonds, correct?

6

 A. Yes. Uh-huh.

7

 Q. Can you describe King of Diamonds for us?

8

 A. Yes.

9

 Q. Was it a giant club?

10 A. Yeah, it was huge.

11 Q. I'm sorry?

12 A. It was huge.

13 Q. Huge?

14 A. Yes.

15 Q. Would you say in square feet probably 60,000

16 square feet?

17 A. I don't know. I'm not a construction --

18 Q. Was there any other club that you had been to

19 that was as large as KOD?

20 A. No. Been to, but never worked.

21 Q. And you were a house girl, correct?

22 A. Yes.

23 Q. And that was because you lived here and they

24 could rely on you to be there, correct?

25 A. Yes.

Page 44

1

 Q. Approximately how many ladies were there per

2 shift?

3

 A. I don't know.

4

 Q. Lots?

5

 A. Yeah. It was a lot of girls. I don't know.

6

 Q. Over 100?

7

 A. I would say over 100 girls there, King of

8 Diamonds, not Crazy Horse.

9

 Q. KOD. KOD.

10 A. Yes. Yes.

11 Q. And you had house rules, didn't you?

12 A. Yes.

13 Q. What were the purposes of those house rules?

14 A. Are you asking my opinion or what they want

15 you to see the house rules are? My opinion on it or --

16 Q. What was your opinion of why they had house

17 rules?

18 A. Because they wanted what they wanted to

19 benefit them. They wanted you to pay and do what they

20 said. If it wasn't to benefit them, then it wasn't --

21 there's no need for the rules. The rules --

22 Q. So none of the rules were assigned to benefit

23 you?

24 A. No.

25 Q. Tell us what some of the rules were.

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1

 A. The rules, you have to pay a certain amount to

2

come into the club or you can't come, you had to tip out

3 generously to everyone. When they see you making money,

4

they want your money. You are going to have to give

5

them what they want out of that money. To make money,

6

you have to give them money to make money.

7

 Q. And that was your interpretation of the rules?

8

 A. Yes.

9

 Q. Was there a large dance floor, stage at KOD?

10 A. Dance floor. Stage is different.

11 Q. Was there a stage?

12 A. Yes, there was a stage.

13 Q. Girls danced on the stage?

14 A. Yes.

15 Q. Girls danced on the floor?

16 A. Yes.

17 Q. It was just giant?

18 A. Yes.

19 Q. I went through some of the notes. You talked

20 about not being allowed to leave.

21 A. Uh-huh.

22 Q. Was there anything else about the club that

23 you didn't like?

24 A. Oh, just -- yeah. I didn't like a lot. I

25 didn't like the fact that you're charging us to come

Page 46

1

into work not knowing what we're going to make. You

2 know? It's --

3

 Q. Why did you stay at King of Diamonds?

4

 A. Because I didn't know -- like coming here, I

5 didn't know any other club, and I was there. It's so

6

long you're working there, you're just like, okay, just

7 stick with it.

8

 Q. But you were there at least eight years. You

9 could have left at any time and gone to another club,

10 right?

11 A. Yeah, but then you have to deal with the

12 different -- they are doing the same thing. You're

13 probably going to have the same problem.

14 Q. So it would have been the same thing at any

15 other club?

16 A. Yeah. You probably would have. I don't know.

17 I never took that chance.

18 Q. But you could have applied, couldn't you?

19 A. Yeah, I could apply.

20 Q. When you were held hostage, did you call the

21 police?

22 MR. AKEMON: Objection, mischaracterizes the

23 testimony.

24 THE ARBITRATOR: The objection is sustained.

25 BY MR. TOBIN:

Page 47

1

 Q. When you were not allowed to leave, did you

2 call the police?

3

 A. No. You --

4

 Q. I'm sorry?

5

 A. No, we didn't call the police. No.

6

 Q. You didn't? Why not?

7

 A. Because you -- at that point when you're

8 saying you're leaving, they are going to have your

9 money. They are not going to let you go. You're going

10 to call the police and lose all your money, and then you

11 won't have a job. So it was more of a fear because you

12 were so used to working there, you know?

13 Q. These fees that you paid to the club, did any

14 of the other clubs have the same fees?

15 A. I don't know. I never worked at the clubs.

16 Q. You worked at G5?

17 A. Yeah. G5?

18 Q. Didn't you work for G5?

19 A. It was Diamonds. It was Diamonds.

20 Q. It was Diamonds?

21 A. Uh-huh.

22 Q. Did they have the same fees?

23 A. No, the fees weren't the same.

24 Q. They weren't as high?

25 A. No. Diamonds -- now it's G5. Diamonds was a

Page 48

1

flat rate. You have day shift -- they have day shift

2

there. So you have a day shift price and a night shift

3 price, so it was different. King of Diamonds was

4

totally different than that.

5

 Q. Isn't it true that you stayed at King of

6 Diamonds because you made more money at King of Diamonds

7

than you would have made anyplace else?

8

 A. Well, I don't know, because I didn't work

9 other places.

10 Q. You just didn't look?

11 A. Yeah. I just wanted to stay there.

12 Q. You paid the house mom?

13 A. Yes.

14 Q. You paid security?

15 A. Yes. We have two different securities. The

16 floor hosts are the money man, and you have the security

17 that's hired by the officers outside, like to wand you

18 and -- so you have to tip both of those, both of the

19 security and the floor man.

20 Q. How did you determine the number that you

21 assigned to wages? How did you determine that?

22 A. Well, I took the minimum wage, and then I took

23 the year, like the calendar, and how many -- on average,

24 how much -- how many hours I worked a week. So then I

25 just added that up.

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1

 Q. Okay. When did you do that?

2

 A. Well, I'm a Virgo, so I'm good with numbers.

3

 Q. You did it Monday?

4

 A. No, I'm good with numbers. I'm a Virgo, so I

5 always think and contemplate on things. It's always on

6 my mind.

7

 Q. I'm also a Virgo, but I'm terrible with

8 numbers.

9

 A. Yeah, but I'm August 28th. You're probably on

10 the cusp.

11 Q. I'm September the 11th.

12 A. Yeah. You're on a cusp. You're like Beyonce.

13 THE ARBITRATOR: And I'm right between you

14 both, August 26th. I'm a Virgo also.

15 MR. AKEMON: Me too.

16 THE WITNESS: See, we have to have

17 everything -- like right now, if you had a spot on

18 your shirt, I would be looking at it the whole day,

19 like wanting to take it off.

20 BY MR. TOBIN:

21 Q. You want to flick it off?

22 A. No, I would want to, like --

23 THE ARBITRATOR: Let's go back to the

24 question. The question was how you computed the --

25 your wages, and you were answering that. So

Page 50

1

 let's --

2

 THE WITNESS: Okay. Well, minimum wage -- so

3

 I determined five to six days a week, right, the

4

 calendar. So I would go back to those years. So

5

 going back twelve months, you know, I had my little

6

 highlighter, highlight it.

7

 So I took off what vacations, what did I say,

8

 a month, so you take off three days here, four days

9

 here, so I determined the month. I would take that

10 off, minus that and add everything up.

11 BY MR. TOBIN:

12 Q. But when did you do it? What year did you do

13 that?

14 A. Well, I do it every -- I do it all the time.

15 This is --

16 Q. You do it day by day? You have calendars at

17 home?

18 A. Anything I do, I have to think about it. I

19 have to know about it. Back then, it was different. It

20 was like every night I had a notepad, this is how much

21 money I made, this is how much money I made, this is

22 how -- you know? But --

23 Q. But back then is when?

24 A. When I first started dancing a long time ago.

25 Q. How long ago?

Page 51

1

 A. Well, before I danced -- I did before this

2 club, when I started as a go-go dancer before I

3 worked -- I was a go-go dancer, and then I worked at

4 Crazy Horse, and then I was at King of Diamonds.

5

 Q. In 2008, did you keep a diary?

6

 A. Of hours? The money that I made? Like the

7 hours, like -- I worked this day, I worked this day, I

8 worked this day, you know, to keep it. Because we had a

9 schedule, we had to abide by that. So as you go by

10 weeks, it was just every day -- it was an every week

11 thing.

12 Q. But where is that diary now from 2008?

13 A. That's a long time ago.

14 Q. What?

15 A. The diary is in my head. I don't keep it.

16 Q. The numbers are in your head from 2008?

17 A. Yes. I keep everything in my head.

18 Q. Tell me on September 11, 2008, how much did you

19 earn.

20 A. I don't know how much money I made.

21 Q. Well, how much money did you spend in 2008?

22 A. If I worked at this club, how much money did

23 they take from me? A lot.

24 Q. How much in 2008?

25 A. 2008? Let me think. Paying my house fee,

Page 52

1 paying all the money that I had to pay in the club, a

2

lot of money. At least $300, me paying.

3

 Q. How much?

4

 A. At least, over maybe -- I don't know.

5

 Q. You don't know, do you?

6

 A. No. That was a long time ago, but it was a

7

lot.

8

 Q. And tell me about 2009. How much did you earn

9

in 2009?

10 A. Earned or paid?

11 Q. How much did you pay?

12 A. The same, the house fees, it was the same

13 thing every day.

14 Q. But how much was it?

15 A. Well, when you walk into the door, you have to

16 pay. When you leave, you have to pay, ten percent

17 taken. So say if I made $200, they would take that.

18 $300, they would take the ten percent.

19 And then plus everything that you paid. So

20 some days, if it was like the big -- they have the big

21 event nights, sometimes, we wouldn't even leave out with

22 money.

23 Q. Were you there on July 7th, 2009?

24 A. I don't know what July 7th was.

25 Q. You didn't work July 7th?

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 A. I don't know when July 7th was.

2

 Q. You don't work in July?

3

 A. I said I don't know when July 7th was.

4

 Q. Oh, you don't know in 2009?

5

 A. No.

6

 Q. You don't know how much you paid that day in

7 house fees?

8

 A. No, but I'm sure it was the same day -- the

9 same price as the same --

10 Q. Was it the same price then?

11 A. If it was an event night, it was more. If it

12 was a regular time, regular days, you paid the regular

13 price.

14 Q. So you don't really know what you paid in

15 2009, do you?

16 A. Paid?

17 Q. Paid.

18 A. I know exactly what I paid for the house fees.

19 I know exactly what I had to pay to leave out. I had to

20 pay tip-outs --

21 Q. How much did you pay in 2009?

22 A. To pay, to come into work? It depends on what

23 time. 9:00 to 5:00, I had to pay $150.

24 Q. I understand that. But how much did you pay

25 that year in fees?

Page 54

1

 A. All the year in fees?

2

 Q. In the year 2009, how much did you pay in

3

fees?

4

 A. I wouldn't know, but if you give me a

5 calculator, I can calculate it.

6

 Q. But you've already calculated it, haven't you?

7

 A. Yes, but I have to --

8

 Q. You don't remember, do you?

9

 A. I'll remember. I have everything written

10 down. I would do minimum wage by five, six -- add this

11 up, minimum wage five, six days a week, calendar year,

12 take off a month. Plus the $250 that they would pay

13 extra every day, so you have to add that in.

14 Q. Did you really work at KOD?

15 A. Yes.

16 Q. How would we know that?

17 A. Well, I was on the disco -- Rick -- the list

18 of dancers under 40, I'm listed there as Vanity.

19 Q. Do you have any photos of yourself at KOD?

20 A. No, because I had a son. My son is 20 now, so

21 I had a thing that anything that stays on the Internet

22 is going to haunt you forever, so that's why I never --

23 I don't even have a social media for myself. I don't

24 have a social media for Instagram.

25 Q. Do you have any advertising of yourself at

Page 55

1 KOD?

2

 A. No, I've never been on file.

3

 Q. Didn't some of the girls advertise?

4

 A. Yes, they did.

5

 Q. You didn't?

6

 A. No. I had a son, so --

7

 Q. I know the best way of proving you were at

8 KOD, your income tax returns. Did you file income tax

9

returns?

10 A. No.

11 Q. You didn't file income tax returns?

12 A. No.

13 Q. For no year?

14 A. No. I didn't think -- at that time, I didn't

15 think that dancing was -- we could claim it. And at

16 that time, I didn't know how I would claim it.

17 Q. When you're talking about claiming fees, what

18 about reporting to the IRS how much you earned? Did you

19 do that?

20 MR. AKEMON: Objection, relevance.

21 THE ARBITRATOR: What's the objection?

22 MR. AKEMON: Relevance.

23 THE ARBITRATOR: I'll allow the question.

24 A. I didn't -- I mean, at that time, I was young,

25 and I didn't know about any of that.

Page 56

1

 Q. In the year 2008, how much did you earn at

2 KOD?

3

 A. 2008? I don't know.

4

 Q. You don't remember?

5

 A. No. It was so long ago.

6

 Q. What about 2009?

7

 A. 2009? No, I don't know.

8

 Q. What about 2010?

9

 A. I don't know.

10 Q. You don't know? What about 2011?

11 A. I don't know the actual numbers.

12 Q. What about 2012?

13 A. I know the total --

14 Q. For the year.

15 A. No.

16 Q. You don't know?

17 A. No.

18 Q. 2013?

19 A. I know that total, it would be -- can I -- can

20 I just -- I was just thinking about something because

21 it popped up in my head.

22 THE ARBITRATOR: I'm sorry?

23 THE WITNESS: I'm sorry, I was just thinking

24 about something from earlier, when I told you the

25 number that he said -- that when he asked me the

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 total number, $340,000. It wasn't 310. I told you

2

 310.

3

 THE ARBITRATOR: 318 is what you said before.

4

 THE WITNESS: Yeah. No. That's wrong. It's

5

 340. You just now --

6 BY MR. TOBIN:

7

 Q. It's not 318, it's 340?

8

 A. $340,000.

9

 Q. For what year?

10 A. For all the years, from 2010 to 2014.

11 Q. That's what you earned total from 2008 to --

12 A. That's what -- that's the -- that's what I'm

13 owed.

14 Q. That's what you're owed?

15 A. Uh-huh.

16 Q. And how did you determine that number?

17 A. I told you.

18 Q. You determined it by adding up the eight or

19 nine years? Is that what you did?

20 A. Yeah. Not eight or nine years. From 2010 to

21 2014.

22 Q. Four years?

23 A. From 2010, '11, '12, '13, '14. Five years.

24 Q. And that's what you're claiming in wages?

25 A. Yes.

Page 58

1

 Q. In 2010, what was the hourly minimum wage?

2

 A. I don't remember hourly minimum wage. I know 

3

that 2010 -- yeah. Next question? I'm sorry.

4

 Q. You don't know the hourly minimum wage for

5 2010?

6

 A. No.

7

 Q. Then how did you determine what is owed to you

8

for 2010?

9

 A. Well, because you're -- this case is 2010 to

10 2014. I worked at KOD from 2008 to 2018. So as you go

11 down the years, the minimum wage changed, right? So

12 everything changed.

13 So you have to still add that now. Every

14 year, you have to do different calculations over again.

15 You're asking me about 2010, 2014. So I'm trying to

16 break it down to the years that you're talking about.

17 Q. Would you tell me how much you're owed for

18 2010 and what the minimum wage was in 2010? Please tell

19 me.

20 A. I'm not sure of that, but I --

21 Q. You're not sure?

22 A. I have it written down.

23 Q. The club provided you with a stage, correct?

24 A. Uh-huh.

25 Q. It provided you with a place to perform,

Page 59

1 correct?

2

 A. Yes.

3

 Q. KOD wasn't a charitable organization, was it?

4

 MR. AKEMON: Objection, relevance.

5

 THE ARBITRATOR: Well, I'll allow the

6

 question. We know the answer to the question, but

7

 I'll allow the question. Mr. Tobin is trying to

8

 make a point on cross. Thank you.

9 BY MR. TOBIN:

10 Q. Was it, ma'am?

11 A. Ask the question again. You said charitable?

12 Q. Was KOD a charitable organization?

13 A. No.

14 Q. As an entertainer, if you didn't have that

15 stage, you couldn't perform, could you?

16 A. Yeah, you could. Some girls didn't get on

17 stage. Some girls weren't allowed to get on stage. You

18 had to look a certain way. If you were the house girls,

19 you could go on stage because you paid more, you know,

20 but if you're out of town, they would pay -- they would

21 think they could get on the stage, but they wouldn't

22 allow them to get on stage.

23 Q. In 2004 -- I'm sorry, in 2010 through 2014,

24 did you know Teri Galardi?

25 A. Not know her. You mean know her? I seen her

Page 60

1 before, but I don't know her.

2

 Q. Did you ever meet Teri Galardi?

3

 A. No.

4

 Q. Did you ever speak to Teri Galardi?

5

 A. No.

6

 Q. Did you ever give Teri Galardi money?

7

 A. No.

8

 Q. You had a bank account, correct?

9

 A. No, I didn't have a bank account then. I used

10 to have these little cards, momento cards, the black

11 momento cards, you know, from the cash place? I don't

12 know. You probably don't know what that is.

13 THE ARBITRATOR: You can explain it by all

14 means.

15 THE WITNESS: They are like little black cards

16 that you take them to the check cashing store to

17 put cash on them. But going back to --

18 BY MR. TOBIN:

19 Q. Wait. Slow down, please.

20 A. I'm sorry. I know I talk so fast. They used

21 to go to the cash store and load them, but I wanted to

22 tell you -- go back to when you said -- about Teri. Her

23 hair was different. It wasn't how it was. I seen her

24 before in the club talking to Akinyele. That's the only

25 time I seen her, when his office was in the back before.

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1

 Q. Did you have a bank account?

2

 A. No.

3

 Q. You never had a bank account?

4

 A. No.

5

 Q. I'm going to refer you to your deposition that

6

I took, Page 20, Line 22, let's do 24.

7

 MR. AKEMON: Your Honor, I'm sorry, I don't

8

 have a copy of whatever he's --

9

 THE ARBITRATOR: This is her deposition.

10 MR. AKEMON: I wasn't provided a copy of --

11 are you going to -- is he going to --

12 THE ARBITRATOR: I assume he's going to

13 impeach her with a question here, so let's see

14 where this goes.

15 BY MR. TOBIN:

16 Q. Did you deposit your cash into that bank

17 account?

18 Answer, I don't remember if I did or don't.

19 Question, do you remember what bank it was?

20 Answer, no.

21 Question, what bank do you have your account

22 in now?

23 Answer, oh, I have -- the bank now that I have

24 is -- I think it's Bank of America and Chase.

25 Do you remember those questions and answers?

Page 62

1

 A. Yes, that's the bank that I have now. I

2 didn't have a bank then. And how I remember that is

3 because remember you asked me about the taxes and you

4 asked me for my Social Security number. It was in the

5 deposition. We were on Zoom --

6

 Q. When I asked you for your Social Security

7 number?

8

 A. Yeah. You were asking me something. So after

9

the deposition, when I was looking it up, I didn't -- I

10 never had a bank account then. I have a bank account

11 now, not back then.

12 Q. By the way, you refused to give me your Social

13 Security number back then?

14 A. No, my lawyer told me not to give it to you.

15 Q. As a matter of fact --

16 MR. AKEMON: Objection, relevance, Your Honor.

17 THE ARBITRATOR: We don't need to get into

18 this, Mr. Tobin. The Social Security number is not

19 going to affect anything that I'm aware of in this

20 case.

21 BY MR. TOBIN:

22 Q. You were instructed not to answer, is that

23 correct?

24 MR. AKEMON: Your Honor, I'll restate --

25 THE ARBITRATOR: That's okay. I've heard the

Page 63

1

 question, and I'm sure that's what you instructed

2

 her to do. Let's move on.

3 BY MR. TOBIN:

4

 Q. Do you know how much KOD's electric bill was

5 per month?

6

 A. No.

7

 Q. If I told you it was $10,000 a month, would

8

that surprise you?

9

 MR. AKEMON: Objection, Your Honor, relevance.

10 THE ARBITRATOR: Well, I'll see where he's

11 going. It's overruled.

12 A. I don't know. I know how much my bill is.

13 Q. What about their mortgage payment? Do you

14 know how much the mortgage payment was on that property?

15 A. No.

16 Q. If I told you it was over $60,000 a month,

17 would that surprise you?

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

19 Q. They have expenses for the building, don't

20 they?

21 A. Everyone does.

22 Q. And is that what the fees you paid went 

23 towards paying?

24 A. I don't know.

25 Q. Did you ever give Teri Galardi one penny?

Page 64

1

 A. No.

2

 Q. Did Teri Galardi ever suspend you?

3

 A. No.

4

 Q. Do you know anybody that she suspended?

5

 A. I don't know who knows her or -- you know. I

6 don't --

7

 Q. Do you know what she did in the building?

8

 A. Yeah. She was owner of the building.

9

 MR. AKEMON: Objection, Your Honor, relevance.

10 I think we established her -- I'm sorry.

11 Relevance.

12 THE ARBITRATOR: No, I'll allow some leeway.

13 I'm not sure where this is going, Mr. Tobin, but

14 I'll allow you some leeway.

15 BY MR. TOBIN:

16 Q. Do you know whether or not she directed the

17 operation of that business?

18 A. No.

19 Q. Do you know if she made the rules, the house

20 rules?

21 A. No.

22 MR. AKEMON: Your Honor, I restate my previous

23 objection.

24 THE ARBITRATOR: Well, there's an issue of

25 willfulness here, Mr. Akemon, and if he's going in

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1

 that direction, I'm not -- I don't pretend to

2

 decide how people make arguments. So this sounds

3

 like the area that he's in, and I'll allow the

4

 questions.

5

 MR. AKEMON: Thank you, Your Honor.

6

 THE ARBITRATOR: I'm sorry, what was the last

7

 question, Mr. Tobin?

8

 MR. TOBIN: Madam Reporter?

9

 (Thereupon, the court reporter played back the

10 question.)

11 BY MR. TOBIN:

12 Q. Do you know Akinyele Adams?

13 A. Yes.

14 Q. Can you just spell Akinyele for the court

15 reporter?

16 A. I can't.

17 THE ARBITRATOR: Mr. Brodsky, can you spell it

18 please?

19 MR. BRODSKY: I don't know how to spell it.

20 THE WITNESS: I can't. I know A-K. That's

21 it.

22 MR. AKEMON: I know how to spell it, Your

23 Honor.

24 THE ARBITRATOR: A-K-I-N-Y-E-L-E?

25 MR. AKEMON: Yes, Your Honor.

Page 66

1

 THE ARBITRATOR: Very good.

2 BY MR. TOBIN:

3

 Q. Do you know him?

4

 A. Yes.

5

 Q. What was his role in KOD?

6

 THE ARBITRATOR: Oh, it's a him?

7

 THE WITNESS: It's a him. It's a guy.

8

 THE ARBITRATOR: I said her. I didn't know.

9

 MR. TOBIN: He's a man.

10 THE ARBITRATOR: Yes. It's my fault. I do

11 remember now this is a male and not a female. Go

12 ahead. What was his role?

13 THE WITNESS: He was the manager.

14 BY MR. AKEMON:

15 Q. Was he the head manager?

16 A. Yeah. He was the head manager.

17 Q. He ran the club, didn't he?

18 A. No, he was the manager. It was him, Rick.

19 Yeah. Him, Rick were the managers. He was head of

20 Rick, and then it was Rick.

21 Q. He was ahead of Rick?

22 A. He was ahead of Rick.

23 Q. And he was the head manager?

24 A. Yeah. It was him and Rick. He was the head

25 manager.

Page 67

1

 Q. Did you know Ms. Galardi's father?

2

 A. Yes. Well, yeah. I worked there before his

3 passing.

4

 Q. Do you know when he died?

5

 A. No. It was one of those years, but yeah.

6

 Q. Do you know how long Mr. Adams operated the

7 club?

8

 A. No.

9

 Q. Do you know what year he took over the club?

10 A. No, not -- it was years. It was more than one

11 year.

12 Q. Do you know if Ms. Galardi had anything at all

13 to do with running the club?

14 A. Yes.

15 Q. What do you know about that?

16 A. Well, Akinyele talked a lot, and when I seen

17 her -- first time I seen her, she was talking to him by

18 the front bar. Because his office was in the back, like

19 by the left side of the bar. You don't know the layout

20 of the club.

21 Q. His office or her office?

22 A. His office, her office, the main office. No

23 one was allowed in the office but them. And I guess

24 what have -- not what I guess, but what Akinyele said

25 was she had a deal with him that he would run the club

Page 68

1

for her, and in exchange that her son, Daryl, whoever,

2 he was out of rehab, and he had to watch him. So he

3 would stay on South Beach with Akinyele.

4

 So he would watch him in the club, make sure

5

that he didn't get off his track, doing his

6

rehabilitation. So that was one of his things for him

7

running the club. Like he run the club, do this.

8

 I don't know what kind of agreement they had,

9 but he was in charge of watching her son and making sure

10 that he wasn't, you know, going back into his old ways

11 of drug use.

12 Q. Did he tell you that Ms. Galardi was the lady

13 that he paid his rent to?

14 A. Yeah. He told him that he had to pay -- he

15 had to pay, you know, a certain amount of money a month

16 to her. Like he would say stuff. I would hear him say

17 stuff on the phone. He's always on the phone. He's

18 always on his headset walking back and forth and

19 talking. I'm a Virgo. I like to know things.

20 Q. So he paid her the rent?

21 A. Yeah. He paid her whatever agreement they

22 had. I don't know. Rent or mortgage or bills. I don't

23 know about that. But yeah. All I know is whatever the

24 deal was, she added in him taking care of her son or

25 watching him so he wouldn't, you know --

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1

 Q. Do you know if Ms. Galardi received any of the

2 money that the managers collected?

3

 A. I don't know about that. That's -- you know,

4

I don't know.

5

 Q. Do you know whether or not the managers kept

6

the money they collected?

7

 A. No, I don't know that either.

8

 Q. Do you know whether or not Ms. Galardi earned

9 one penny out of that?

10 A. No, I don't know.

11 MR. TOBIN: May I have a couple of minutes

12 with Mr. Brodsky?

13 THE ARBITRATOR: Yes, sir.

14 (Off the record.)

15 BY MR. TOBIN:

16 Q. By the way, where are you working now?

17 MR. AKEMON: Objection, relevance.

18 THE ARBITRATOR: I'll allow the question. We

19 won't take it any further than that. You may

20 ask -- you can answer the question.

21 A. Oh, I have my own day spa.

22 Q. I'm sorry?

23 A. I have my own business.

24 THE ARBITRATOR: She has her own business.

25 MR. TOBIN: Okay. Thank you.

Page 70

1 BY MR. TOBIN:

2

 Q. In the year 2012, please tell us what you

3 earned at KOD.

4

 MR. AKEMON: Objection, Your Honor, asked and

5

 answered.

6

 MR. TOBIN: I didn't ask about 2012.

7

 THE ARBITRATOR: Well, he didn't go to 2012.

8

 He stopped there. He stopped at 2011. Ms.

9

 Galardi -- I mean Ms. Holmes was referring back to

10 this compilation that is Exhibit 23A and giving

11 numbers from 2010 to 2014. What he's asking is a

12 specific question. Can you state what you earned

13 in 2012?

14 THE WITNESS: No.

15 BY MR. TOBIN:

16 Q. What about 2013?

17 A. No. I think you asked me all these questions.

18 Q. How much did you earn in 2013?

19 A. I don't know.

20 Q. What about 2014?

21 A. I don't know.

22 Q. You don't know?

23 A. No.

24 Q. Did you keep the writings -- did you write the

25 number down as you had to pay it in your little book?

Page 71

1

 A. What I paid?

2

 Q. What you paid each day, you wrote it down in a

3 book, didn't you?

4

 A. A long time ago.

5

 Q. What?

6

 A. A long time ago. I don't have that book now.

7

 Q. Where is it now?

8

 A. That book is gone. I know what I paid in my

9 head. Like every night, I know what I paid. I don't

10 have --

11 Q. And then you wrote it in the book. You

12 figured it out every night, and you wrote it in the

13 book?

14 A. I don't have that book.

15 Q. As I understand it, you earned in -- I'm

16 sorry, you paid in fees about $250 a day, correct?

17 A. Yes. Not -- that's not including the house

18 fee.

19 Q. That's not including the house fee?

20 A. Right. The house fee is when you come to

21 work, you have to pay to get in the club.

22 Q. On the days that you -- on the days that you

23 paid $250, how much would you have earned?

24 A. I don't know how much every night I would

25 earn.

Page 72

1

 Q. But you know how much you gave up, not how

2 much you earned?

3

 A. Right. Yeah. I remember that.

4

 Q. Did you ever earn as much as $1,000 a day?

5

 A. A night?

6

 Q. I'm sorry?

7

 A. I was taking home $1,000 a night?

8

 Q. A night, yes.

9

 A. Oh, that would rarely happen.

10 Q. That rarely happened?

11 A. Yes.

12 Q. Did you ever earn as much as $2,000 a night?

13 A. No.

14 Q. Were you there when Jeezy was there?

15 A. Yeah. Jeezy was there -- can I tell the

16 story? No?

17 THE ARBITRATOR: We probably don't have time

18 for a story. Maybe when it's all over if you want

19 to tell a story. But who -- how do you spell

20 Jeezy.

21 THE WITNESS: J-E-E-Z-Y.

22 THE ARBITRATOR: Oh, Jeezy.

23 MR. TOBIN: Jeezy.

24 THE ARBITRATOR: Okay. I know he's famous

25 now.

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1

 MR. TOBIN: You do?

2

 THE WITNESS: Yeah. Really famous.

3

 THE ARBITRATOR: I think so. Jay-Z, is that

4

 the person we're talking about?

5

 MR. TOBIN: No, Jeezy, J-E-E-Z-Y.

6 BY MR. TOBIN:

7

 Q. How much did you earn when Jeezy was there?

8

 A. He came, he threw $60,000 on 22, 24 girls, and

9

then he said all the money was stolen. None of the

10 girls got paid.

11 Q. How much money did he throw up in the air?

12 A. At least $60,000, 30 to 60,000. He threw a

13 lot of money up, and they went in the office, had all the

14 plastic bags -- I remember this day. And nobody got paid, 

15 none of us.

16 Q. Did Ms. Galardi get that money?

17 A. I don't know who. They said the money was

18 stolen.

19 Q. Did Akinyele get it?

20 A. I don't know who.

21 Q. You don't know who got it?

22 A. I didn't get it.

23 MR. TOBIN: Nothing else at this time, Your

24 Honor.

25 THE ARBITRATOR: There won't be another time,

Page 74

1

 Mr. Tobin, I don't think, unless you call her on

2

 your case. Anything further on redirect?

3

 MR. AKEMON: A couple redirect, yes.

4

 REDIRECT EXAMINATION

5 BY MR. AKEMON:

6

 Q. Ms. Holmes, you earlier testified that you had

7 a diary or journal of some type. Do you remember that

8

testimony?

9

 A. Yes.

10 Q. Did you destroy that diary?

11 A. No. It was lost.

12 Q. So you didn't purposely get rid of the

13 information?

14 A. No. That was so long ago.

15 Q. And you're not asking the Court -- are you

16 asking the Court to give you the exact number for every

17 night that you worked at King of Diamonds?

18 A. No.

19 Q. Are you asking the Court to give you the

20 average amount that you paid King of Diamonds?

21 A. Yes.

22 Q. You were also asked some questions about the

23 minimum wage. Would it help to refresh your memory with

24 respect to your calculations if I showed you Exhibit

25 23A?

Page 75

1

 A. Yes.

2

 MR. AKEMON: Your Honor, may I approach?

3

 THE ARBITRATOR: Yes.

4

 MR. BRODSKY: Your Honor, the exhibit says

5

 what it says.

6

 THE ARBITRATOR: It's in evidence, and you've

7

 already indicated minimum wage, but if you feel

8

 like you want her to look at it, that's okay.

9

 MR. AKEMON: Thank you, Your Honor.

10 THE ARBITRATOR: Mr. Tobin asked her, and

11 maybe he wants to know.

12 MR. BRODSKY: And we're referring to

13 Exhibit --

14 THE ARBITRATOR: 23A.

15 MR. AKEMON: 23A, second page.

16 BY MR. AKEMON:

17 Q. Would it help to refresh your memory with

18 respect to what the minimum wage was in the years that

19 you're asking for damages?

20 A. Yes.

21 Q. And just for purposes of clarity, can you tell

22 the Court what the minimum wage was in 2010?

23 A. $7.25.

24 Q. And did you use that number to calculate the

25 average number of hours times that number to come up

Page 76

1 with your amount of damages?

2

 A. Yes.

3

 Q. And so when calculating the amount of house

4

fees, you don't -- is it very difficult for you to

5

recall the exact date and house fees from three -- I'm

6 sorry, from approximately eight years ago?

7

 A. Yes. It's -- yes.

8

 Q. But you're asking the Court to reimburse you

9 or award you the average amount in house fees?

10 A. Yes.

11 THE ARBITRATOR: I take it there's no debate

12 among counsels as to what the minimum wage was to each

13 of these years, is that right? That's a published

14 number?

15 MR. BRODSKY: That's correct.

16 THE ARBITRATOR: Okay. Very good.

17 BY MR. AKEMON:

18 Q. And you earlier testified that you saw Ms.

19 Galardi at the King of Diamonds?

20 A. Yes.

21 Q. Where did you see her at?

22 A. Behind the bar. Behind the bar area.

23 Q. And was this during -- was she meeting with

24 anyone?

25 MR. BRODSKY: Your Honor, can we get a time

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1

 frame here? Objection.

2

 THE ARBITRATOR: Well, there wasn't -- Mr.

3

 Tobin asked her the question generally and didn't

4

 specify a time frame, and she's now responding

5

 generally without a time frame, so I'm not sure

6

 whether time frames are really going to matter

7

 because no one has really pinned that down.

8

 But if it's important, you should pin down a

9

 time frame. Because, otherwise, I have no idea

10 whether this was before the relevant time period or

11 after the relevant time period.

12 So Mr. Brodsky makes a good point, but I should

13 note that Mr. Tobin didn't pin down a time period

14 either. But go ahead, Mr. Akemon.

15 BY MR. AKEMON:

16 Q. And when you saw her, was she located inside

17 the club?

18 A. Yes.

19 Q. Where was she located at?

20 A. Inside the club by the bar, like by the

21 office.

22 Q. To the best of your knowledge, was she meeting

23 with anyone?

24 A. Yes.

25 Q. Who was she meeting with?

Page 78

1

 A. Akinyele.

2

 Q. And you saw that that day?

3

 A. Yes.

4

 THE ARBITRATOR: Now you're getting specific,

5

 Mr. Akemon, so you probably ought to try to come up

6

 with a time period.

7

 MR. AKEMON: Yes, Your Honor.

8 BY MR. AKEMON:

9

 Q. Was this during the time frame in which you're

10 asking for damages, between 2010 and 2014?

11 A. Yes.

12 MR. AKEMON: No further questions.

13 MR. BRODSKY: Judge, that's not a time --

14 THE ARBITRATOR: It's enough of an answer, and

15 she's answered the way she's answered that she saw

16 this. I don't know, when was Mr. Adams there? I

17 think that's another way to look at this because I

18 don't think -- didn't he come in a little bit

19 later?

20 MR. AKEMON: Yes, Your Honor. I'll ask one

21 additional question.

22 BY MR. AKEMON:

23 Q. Do you know when Mr. Adams came on board at

24 the King of Diamonds?

25 A. He had to come -- he had to be there 2011.

Page 79

1

I'm not really sure. It's too far back in my head.

2

 Q. Okay. And when you would speak to Akinyele

3 Adams, you said he would volunteer some information to

4 you?

5

 THE ARBITRATOR: That's not the testimony,

6

 though. She said she heard him on the phone. He

7

 talked a lot.

8

 THE WITNESS: No, no. No. He told me

9

 personally what she was there for, because I asked

10 him who she was. That's how I got to know. But

11 when I hear him on the phone talking about other

12 stuff about --

13 THE ARBITRATOR: Sorry. You need to be more

14 specific in your question, Mr. Akemon.

15 MR. AKEMON: Yes, Your Honor.

16 BY MR. AKEMON:

17 Q. Did Akinyele ever discuss with you his

18 relationship with Ms. Galardi?

19 A. Yes.

20 Q. Did Akinyele Adams ever tell you that he

21 reported directly to Ms. Galardi?

22 A. Yes.

23 MR. BRODSKY: Objection, hearsay.

24 THE ARBITRATOR: No, you can answer the

25 question. Go ahead.

Page 80

1

 THE WITNESS: Yes.

2 BY MR. AKEMON:

3

 Q. Did Mr. Adams ever tell you that he was

4

reporting directly to Ms. Galardi?

5

 A. Yes.

6

 Q. And did he also tell you that he spoke with

7 Ms. Galardi?

8

 A. Yes.

9

 Q. And did he also tell you that he had an

10 arrangement with Ms. Galardi?

11 A. Yes.

12 Q. And did he also tell you some of the policies

13 and procedures that were implemented were a result of

14 Ms. Galardi's direction?

15 A. Yes.

16 MR. AKEMON: No further questions, Your Honor.

17 THE ARBITRATOR: Next witness? Thank you very

18 much. You're excused for now.

19 MR. AKEMON: Your Honor --

20 THE ARBITRATOR: Need a break?

21 MR. AKEMON: No. I was going to call my next

22 witness, if you would like.

23 THE ARBITRATOR: Yes. It's 11:30. Let's hear

24 from Ms. Griffen, and then we'll see if we can

25 break for lunch. And then we'll start the cross

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1

 after lunch. You okay, Stephanie?

2

 THE COURT REPORTER: I'm okay. Thank you.

3

 MR. AKEMON: Your Honor, are we stipulating

4

 that 34B has been admitted as well, or just 34A?

5

 THE ARBITRATOR: I'm sorry, I don't know what

6

 you're talking about. 23?

7

 MR. AKEMON: Yes, 23. I'm sorry.

8

 THE ARBITRATOR: Yes, I'll admit both

9

 documents, 23A. I don't have 23 -- I guess I have 

10 it but it's not marked. Do you want to mark this,

11 please?

12 THE COURT REPORTER: Please state your first

13 and last name?

14 THE WITNESS: Elliadria Griffen,

15 E-L-L-I-A-D-R-I-A Griffen, G-R-I-F-F-E-N.

16 (Thereupon, the witness was duly sworn in

17 accordance with the law.)

18 THE ARBITRATOR: You may proceed.

19 DIRECT EXAMINATION

20 BY MR. AKEMON:

21 Q. Good morning, Ms. Griffen.

22 A. Good morning.

23 Q. Were you a dancer at the King of Diamonds

24 Gentlemen's Club?

25 A. Yes.

Page 82

1

 Q. And do you remember when you were hired at

2 King of Diamonds?

3

 A. Yes.

4

 Q. Can you tell the Court when you were hired at

5 King of Diamonds?

6

 A. Around 2010. A few weeks before Memorial

7 Weekend was my first time coming out here.

8

 Q. And do you remember how you were hired at King

9 of Diamonds?

10 A. One of the managers at that time had me

11 audition. I did three songs, one with my clothes on,

12 one with my top off, and my third song, I was fully

13 naked.

14 Q. And that was the audition process?

15 A. Yes.

16 Q. And how long -- after the audition, how long

17 did it take for you to begin working at King of

18 Diamonds?

19 A. They hired me right on the spot. I came back

20 the next night.

21 Q. And when you began working at King of

22 Diamonds, did they give you a set of rules and

23 regulations?

24 A. Yes. I had to be on the floor at a certain

25 time, I had to pay house fees before I could come to

Page 83

1 work, I was -- that was about it. I mean, of course,

2 you know, leaving after your shift, the ten percent,

3

tipping out the DJ, the house mom and security.

4

 Q. And when you -- did they also have rules

5 posted in places throughout the club, including the

6

locker room?

7

 A. If they did, I wasn't paying attention, I

8 already kind of knew the rules because I had been there

9

for so long.

10 Q. And they would give you an entertainer packet

11 when you first began or an application and --

12 A. I didn't sign no application. I didn't fill

13 out no paperwork.

14 Q. If I show you a copy of -- if I show you a

15 document titled rules, would you recognize that

16 document?

17 THE ARBITRATOR: Mr. Akemon, that's not the

18 way to do this. If you want to show her the

19 document, you can ask her.

20 MR. AKEMON: I'm sorry.

21 BY MR. AKEMON:

22 Q. Do you remember any of the other rules and

23 regulations at the King of Diamonds?

24 A. Just the main -- the main important one was

25 the house fee, ten percent and security, and me tipping

Page 84

1 out everybody. Those were the main rules that really

2

concerned me at that time.

3

 Q. And have you on occasion been disciplined for

4 breaking one of those rules?

5

 A. Yes.

6

 Q. And can you tell this Court what that

7 discipline would consist of?

8

 A. I mean, I got fined before for not tipping out

9

security or not paying the DJ.

10 Q. And how much -- can you give the Court an

11 approximation of what that fine was?

12 A. Between $250 and $500. It depends how the

13 manager was feeling that day.

14 Q. Have you been fined more than once?

15 A. I have been fined, like, three times. One of

16 them was for fighting -- no, two of them was for

17 fighting, and one was for not tipping the DJ.

18 Q. For not -- can you say that again?

19 A. For not tipping the DJ.

20 Q. I'm going to show you what has been marked as

21 Claimant's 12.

22 A. Okay.

23 MR. BRODSKY: Can I see --

24 MR. AKEMON: I'm sorry.

25 MR. BRODSKY: And then have an opportunity

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1

 to find it in the notebook, please.

2

 MR. AKEMON: It's Number 12, Mr. Tobin -- I'm

3

 sorry, Mr. Brodsky.

4

 THE ARBITRATOR: All right. My notebook is

5

 blank for 12. Okay. Let's have the court reporter

6

 put a Claimant's Exhibit 12 on here so we don't get

7

 confused. If you want to show that to the witness,

8

 you may.

9

 THE WITNESS: I remember this --

10 MR. AKEMON: Hold on, Ms. Griffen. Mr.

11 Brodsky, do you have it?

12 MR. BRODSKY: Yes.

13 BY MR. AKEMON:

14 Q. Do you recognize that document, Ms. Griffen?

15 A. I remember this when -- around the time

16 Akinyele took over. I didn't attend that meeting, but

17 I -- when I came to work that night, I remember the

18 girls talking about this.

19 Q. Have you seen that document before?

20 A. Yes, but I didn't sign it.

21 MR. AKEMON: Your Honor, I move to admit

22 Claimant's 12.

23 THE ARBITRATOR: I'll allow it.

24 BY MR. AKEMON:

25 Q. And can you tell the Court what the top of

Page 86

1

that document says?

2

 A. Galardi South Enterprises Consulting, Inc. and

3

Its Affiliate Clubs, Rules and Conduct for Contractors

4 and Employees.

5

 THE ARBITRATOR: What's the date of the

6

 document? Is it dated?

7

 THE WITNESS: It's not dated.

8

 MR. BRODSKY: It's not dated, nor is it

9

 signed.

10 BY MR. AKEMON:

11 Q. And can you go to Number 8 of Page 1?

12 A. Our entertainers are responsible to dance each

13 and every song on each of their stage sets. If you want

14 another entertainer to cover your set, you must find the

15 entertainer, pay her a minimum of $10 and notify the DJ

16 immediately. Do not give the DJ the money, find the

17 cover.

18 Q. And can you also read Number 1 on Page 1?

19 A. All entertainers will be expected on

20 performance days that they will be needed to work. If

21 you're not able to perform for legitimate reasons,

22 you're asked to call and speak to -- speak only to your

23 house mom or manager. You will be subject to fines or

24 other appropriate discipline for no call, no shows.

25 Q. Thank you.

Page 87

1

 THE ARBITRATOR: I'll take a look at what she

2

 just read.

3

 MR. AKEMON: In addition, I'm going to show

4

 you what's previously been marked as C6.

5

 THE ARBITRATOR: I'm sorry, what is this now?

6

 THE WITNESS: C6.

7

 MR. AKEMON: C6.

8

 THE ARBITRATOR: C?

9

 MR. AKEMON: As in Claimant's 6, Your Honor.

10 I'm sorry. It will be in the white notebook.

11 THE ARBITRATOR: This is the arbitration

12 policy?

13 MR. AKEMON: Yes, Your Honor. Mr. Brodsky, do

14 you need to see it?

15 MR. BRODSKY: Let me see.

16 THE ARBITRATOR: Would you just hand this to

17 the reporter and have her put the right exhibit

18 number on it for me?

19 THE COURT REPORTER: 6?

20 MR. BRODSKY: I have a blank arbitration

21 policy it looks like. Is that what that is?

22 MR. AKEMON: Yes.

23 MR. BRODSKY: Okay. I have it. And it's not

24 signed, right?

25 MR. AKEMON: Right.

Page 88

1

 THE ARBITRATOR: Okay.

2 BY MR. AKEMON:

3

 Q. Ms. Griffen, do you recognize that document?

4

 A. Yes.

5

 Q. And do you remember when you received that

6 document, approximately when you received that document?

7

 A. I don't remember, but I remember coming into

8 work and they saying that we had to fill out these

9 packages before we could work, and --

10 Q. Was that -- I'm sorry.

11 A. -- I didn't do it.

12 Q. Was that around the time that Akinyele came

13 aboard?

14 A. Yes.

15 Q. And is that a true and accurate copy of what

16 you saw that day?

17 A. Yes.

18 MR. AKEMON: Your Honor, move to admit C6.

19 THE ARBITRATOR: Okay. I'll allow it.

20 BY MR. AKEMON:

21 Q. Ms. Griffen, do you recognize the young lady

22 sitting there?

23 A. Yes.

24 Q. Do you know her real name?

25 A. No.

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1

 Q. Do you know her dancer name?

2

 A. Yes.

3

 Q. Can you tell the Court what her dancer name

4 was?

5

 A. Vanity.

6

 Q. And how do you know this?

7

 A. We worked together for years.

8

 Q. And when you say you worked together for

9 years, can you tell the Court what years you believe you

10 worked together?

11 A. Well, I started working there around 2010.

12 Vanity was already there. So all the way up until I

13 stopped working there in 2014.

14 Q. Okay. And when did you stop working there in

15 2014?

16 A. It was around I want to say June, but I'm not

17 really sure; I just know it was 2014 because I moved

18 back to Texas.

19 THE ARBITRATOR: I'm sorry, moved back to

20 where?

21 THE WITNESS: To Texas that year.

22 THE ARBITRATOR: Texas?

23 THE WITNESS: Yes, sir.

24 BY MR. AKEMON:

25 Q. And did Ms. Holmes -- you heard -- did you

Page 90

1 hear Ms. Holmes' testimony?

2

 A. Yes.

3

 Q. And to the best of your knowledge, did Ms.

4 Holmes work the times that she testified to?

5

 A. Yes. She was at work just as much as me.

6

 Q. Okay. Can you tell the Court how many days

7 per week on average that you worked at King of Diamonds?

8

 A. I worked about five days a week. I gave

9 myself two days off during the week sometimes.

10 Q. And can you also tell the Court -- I'm sorry,

11 strike that.

12 THE ARBITRATOR: Just so it's clear, Ms.

13 Griffen, I'm not a judge, this is not a court.

14 Mr. Akemon is used to saying the word --

15 THE WITNESS: Your Honor, I know. I say sir.

16 I know.

17 THE ARBITRATOR: You can call me whatever you

18 want, because it's easier for me just to not bother

19 to take up the time to say I've never been a judge,

20 I'm not a Your Honor, but it's just easier to do it

21 that way.

22 I just want you to understand this is not a

23 courtroom, this is an arbitration. I'm not going

24 to stop Mr. Akemon because that's his habit. He

25 has been in courtrooms all his life. He's used to

Page 91

1

 saying it.

2

 THE WITNESS: Yes, sir.

3

 THE ARBITRATOR: But I don't want you to be

4

 misled that somehow you're in a courtroom.

5

 THE WITNESS: I totally understand.

6 BY MR. AKEMON:

7

 Q. And would you be -- strike that.

8

 Let's talk about the beginning of a shift.

9

 A. Okay.

10 Q. Typically, on average, what time would you

11 arrive at King of Diamonds?

12 A. About 10:00, because, like Ms. Holmes said, we

13 would get alerts about how much house fees would be, and

14 it would go up every hour before 12:00 or before 11:00,

15 and then after 12:00 or 12:30; it would go up every 30

16 minutes.

17 Q. And when you say alerts, what do you mean

18 alerts?

19 A. Like we get text messages to let us know how

20 much house fees would be. That's the reason they took

21 our numbers at the beginning of our shifts.

22 Q. Okay. And it would explain what the house fee

23 would be?

24 A. Yes.

25 Q. Would it also promote or would they also ask

Page 92

1 you to promote the events for that night as well?

2

 A. Yes, they send it with a flyer.

3

 Q. And on occasion -- I'm sorry, strike that.

4

 From 2010 to 2014, during your employment,

5 would the club hire celebrities to host event nights?

6

 A. I guess that wouldn't come from the club; it

7 would be from the promoters who would be in the club.

8 So --

9

 Q. Is there any -- I'm sorry. Go ahead.

10 A. I guess they would, yes.

11 Q. And during these event nights, would you be

12 expected to pay a higher house fee?

13 A. Yes, of course.

14 Q. And was there an event titled Floyd Mayweather

15 Memorial Day Weekend sometime in 2012 or 2013?

16 A. Yes.

17 Q. Okay. And do you remember that night?

18 A. Yes, verbatim actually.

19 Q. And do you remember what the house fee was

20 that night?

21 A. I paid $450, if I'm not mistaken.

22 Q. Was that typical of any other event nights?

23 A. I mean, if you had been working -- if you're a

24 house girl at King of Diamonds and it's an event night,

25 you automatically know that the tip-out is going to be

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1 crazy -- I mean the house fee.

2

 Let me correct that. When I say tip-out, house

3

fee is going to be crazy. So in your mind, all you're

4 doing is asking yourself, well, how much is it going to

5 start at? Because if it starts at $300 at 10:00, it's

6 going to go up every hour, and by 12:00, it's going to

7 go up every 30 minutes.

8

 Q. And what's the highest amount of house fee

9

that you paid while working at King of Diamonds?

10 A. The most I've paid is $500.

11 Q. And what's the lowest you ever paid?

12 A. An average?

13 Q. Not average, what's the lowest?

14 A. The lowest, when I first started working back

15 in 2010, I paid $100.

16 Q. And can you --

17 A. It was like on a Tuesday.

18 Q. And can you tell the Court what your average

19 house fee during your employment at KOD was?

20 A. $250.

21 Q. And when you say $250, you just mean the house

22 fee, or are you talking about the house fee and the

23 tip-outs for the DJs, house mom, security, et cetera?

24 A. You could put it all together, but it is kind

25 of separate.

Page 94

1

 Q. Okay. And were you required to pay the house

2 mom?

3

 A. Yes.

4

 Q. What about the DJ?

5

 A. Requirement.

6

 Q. And the security?

7

 A. Requirement.

8

 Q. And on average -- strike that.

9

 So when you would arrive at KOD, would you

10 have to sign in with someone by the name of Tan?

11 A. Yes.

12 Q. And was there a sign-in sheet for you as well?

13 A. Yes.

14 Q. And did you also attend some mandatory

15 meetings at King of Diamonds?

16 A. Sometimes I did.

17 Q. Okay. And what would they discuss at these

18 mandatory meetings?

19 A. One meeting I remember they discussed how

20 security was stealing from us. We discussed how tip-out

21 was too high. We discussed how house fee was too high.

22 Once Akinyele got there, the rules just became totally

23 different.

24 Q. Did they become more difficult or stringent?

25 A. Yes.

Page 95

1

 Q. Can you describe how?

2

 A. He just came with his own way of how he wanted

3

the club ran, and how Rick and Mr. Teri was running it

4 before. It just made all the girls who were house girls

5 uncomfortable.

6

 Q. And in addition to that, were you also --

7 strike that.

8

 Were there people located at the club that

9 were called sweepers?

10 A. Yes.

11 THE ARBITRATOR: I'm sorry, called what?

12 MR. AKEMON: Sweepers.

13 THE WITNESS: Sweepers. The money men.

14 THE ARBITRATOR: S-W-E-E-P-E-R-S, sweepers?

15 THE WITNESS: Yes, sir.

16 BY MR. AKEMON:

17 Q. And what was their job?

18 A. To pick up our money off the floor.

19 Q. And --

20 A. To pick up all the money off the stages.

21 Q. And did you hire those money men -- I'm sorry,

22 not money men, those sweepers, or did the club hire

23 sweepers?

24 A. The club.

25 Q. And were you required to tip the sweepers?

Page 96

1

 A. Yes.

2

 Q. And would the sweepers be around during

3 your -- I'll ask you about two separate issues. Were

4

the sweepers around when you would do lap dances or

5

table dances for a customer?

6

 A. It depends. If the customer was throwing your

7 money in the air and it was falling on the floor, then

8

they would be around because they are the ones picking

9 up your money off the floor. Because if we were naked,

10 they didn't want us on our hands and knees picking up

11 money.

12 Q. And they would also be there when it was a

13 stage set?

14 A. Yes.

15 Q. And they would collect the money on the stage

16 as well as the money that fell on the floor?

17 A. Yes.

18 Q. And when they collected the money, where did

19 the money go?

20 A. In the money room.

21 Q. And when they went to the money room, did they

22 take it to the money room or did you take it to the

23 money room?

24 A. They held it in they hands, but if you was

25 smart, you would follow your money to the money room.

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1

 Q. Right. And after they would take it to the

2 money room, would the money remain there all night?

3

 A. It would get counted at some point by

4

somebody.

5

 Q. Would you be allowed to stay in the money room

6 all night with your money?

7

 A. I mean, if that's the only money you want to

8 make for the night, yes.

9

 Q. Were you allowed to take the money from the

10 sweepers and not send it to the money room?

11 A. No.

12 Q. If you attempted to take the money from the

13 sweepers and put it into a -- I'm sorry, strike that.

14 Did you have your own locker?

15 A. I had my own room.

16 Q. Okay. And where you had your own room, did

17 you have a locker inside that room?

18 A. No.

19 Q. If you attempted to take the money that the

20 sweepers collected off the floor and attempted to take

21 it to the -- to your locker -- I mean not your locker,

22 your room, would you be allowed to do so?

23 A. No.

24 Q. Have you attempted to do so before?

25 A. Yes.

Page 98

1

 Q. And what was the result?

2

 A. I got cussed out, yelled at.

3

 Q. Were you ever fined or disciplined or

4 suspended for that?

5

 A. They just took my money and put it in the

6 money room, and they give you these bands with a number

7 on it, and they put the number on your back. So when

8

they count it, they exactly know whose money it is,

9 where it's going and all that. They wrote down

10 everything.

11 Q. And then with the ten percent, did they take

12 ten percent out of those bags?

13 A. Yes. I wanted to clarify what Ms. Holmes had

14 said. Our ten percent came out of every money you made.

15 So my stage money, that's ten percent that they taking

16 out. My money that I'm making in the pow that I'm

17 dancing with, me and four other girls, they taking ten

18 percent out of that.

19 So any loose money as far as dollar bills if

20 you give me in groups, they are taking ten percent out

21 of each of your money; so at the end of the night, I'm

22 paying the club way more than ten percent of all my

23 money. I'm basically giving them ten percent of

24 everything I've made all night.

25 Q. And this was a requirement?

Page 99

1

 A. A requirement.

2

 Q. And when they would take the ten percent out,

3 would they count it first and inform you how much they

4 were taking every time?

5

 A. Well, you wouldn't see it until the end of the

6 night. They will give you an envelope and say, you

7

know, this is what you made, we already took your ten

8 percent out. But if I had five envelopes of money, they

9

taking ten percent out of each of my envelopes.

10 They are not adding it together and taking my

11 ten percent out because I'm not giving them my money all

12 at the same time. I'm giving it to them in lump sums.

13 So they are coming and taking ten percent out of

14 everything I'm making.

15 Q. And you would also have to tip out the DJ?

16 A. Yes.

17 Q. And did you have the opportunity to choose the

18 songs that were played during your set?

19 A. No.

20 Q. And did you hire -- sorry. Let me ask that,

21 again. You did not hire the DJ?

22 A. No.

23 Q. He was hired -- to the best of your knowledge,

24 was he hired by the club?

25 A. Yes.

Page 100

1

 Q. What about the house mom? Did you have to tip

2 her out?

3

 A. Yes.

4

 Q. And when you tipped the house mom out, was

5

that also a requirement?

6

 A. Yes.

7

 Q. Did you hire the house mom?

8

 A. No.

9

 Q. Did you have any input on what the house mom

10 did?

11 A. No.

12 Q. Can you tell the Court, describe to the Court

13 what is a house mom?

14 A. She has all your essentials like wipes, towels.

15 Sometimes -- there was showers there, so sometimes some of 

16 us took a shower at the end of the night, or before the night

17 started, we would take a shower. She has dance outfits

18 that we have to pay for. She has basically snacks,

19 drinks. All this stuff we have to pay for and tip her

20 all in the same time.

21 Q. So in the event you didn't buy any of these

22 products or costumes, were you still required to tip her

23 at night?

24 A. Yes.

25 Q. And with respect to the security, did you hire

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1 or did you have any input with hiring anyone from

2 security?

3

 A. No.

4

 Q. And to the best of your knowledge, what was

5

the purpose of security? What was their purpose at the

6 club?

7

 A. To watch us, but that wasn't their doing. You

8

know what I'm saying? Like you hire security to pick up

9 our money and watch over us, but nine times out of ten,

10 if you're not tipping them, they are not watching over

11 you.

12 Q. And can you tell the Court on average how many

13 hours per week -- not hours per week, hours per day you

14 would work per shift?

15 A. About nine.

16 Q. Nine hours?

17 A. Yes.

18 Q. And are you asking this Court to reimburse you

19 minimum wages from the time that you worked from 2010 to

20 the end of your work in 2014?

21 A. Yes.

22 Q. And did you attempt to calculate the amount of

23 damages that you think you're entitled to in this case?

24 A. Yes.

25 Q. And can you tell the Court how you arrived at

Page 102

1

those numbers? I'm sorry, strike that.

2

 Can you tell the Court how you arrived at what

3 you think you're entitled to in terms of wages?

4

 A. I took the minimum wage at that time, timesed

5

it by how many hours I worked and how many hours per

6

shift I worked that day -- I mean that week, and then I

7 multiplied it all together.

8

 Q. And you came up with a final number?

9

 A. Yes.

10 Q. And can you tell the Court the total

11 wages you're asking for?

12 A. $318,248.

13 Q. Okay. Are you talking wages or total damages?

14 A. Which one?

15 MR. BRODSKY: Let the record reflect that the

16 witness is looking at a document as opposed to

17 just --

18 THE ARBITRATOR: What are we looking at, Mr.

19 Akemon? Is this 23B?

20 MR. AKEMON: 23B, Your Honor.

21 THE ARBITRATOR: My 23B says for that number

22 $340,000. Where do you see $318,000?

23 THE WITNESS: Well, that's hers.

24 THE ARBITRATOR: Is that Marquisha?

25 THE WITNESS: That's Marquisha.

Page 103

1

 THE ARBITRATOR: Sorry. Did I give you the

2

 wrong one, Stephanie? I might have. One second.

3

 One second.

4

 THE WITNESS: The front page is the same.

5

 THE ARBITRATOR: Holmes, Holmes, Holmes. My

6

 first page says Griffen, but the second page says

7

 Holmes. I didn't realize that until just now.

8

 MR. AKEMON: I didn't realize it either.

9

 THE ARBITRATOR: No problem. So I don't have

10 the correct second page. Let me just take a look,

11 see what the difference is.

12 Okay. When we break for lunch, I'll get this

13 fixed. I was wondering how you can start by

14 Memorial Day and have 44 weeks looking at this

15 page. Now I understand. I had the wrong page.

16 You definitely were administratively challenged

17 this week, Mr. Akemon, I want you to know.

18 MR. AKEMON: Your Honor, for the record, I did

19 all this in eight hours because FedEx never

20 delivered my exhibits.

21 THE ARBITRATOR: It's hard. COVID has been

22 hard on everyone.

23 BY MR. AKEMON:

24 Q. Can you tell the Court what you're asking the

25 Court -- can you tell the Court what you're asking for

Page 104

1

in total damages?

2

 A. So that's my total. It's $318,000.

3

 Q. And are you also asking for an equal amount in

4

liquidated damages?

5

 A. Yes.

6

 Q. And can you also tell the Court what time

7 would you typically leave King of Diamonds after your

8 shift? I'm sorry.

9

 A. Well, the club close at 6:00.

10 THE ARBITRATOR: I'm sorry, the club closed at

11 what time?

12 THE WITNESS: 6:00 a.m.

13 THE ARBITRATOR: 6:00 a.m.?

14 THE WITNESS: Yes, sir.

15 BY MR. AKEMON:

16 Q. And was there on occasion times where you

17 would --

18 THE ARBITRATOR: Wait. She didn't answer the

19 question. The club closes at 6:00 a.m., but what

20 was the answer to the question, when would you

21 leave?

22 BY MR. AKEMON:

23 Q. When would you typically leave the club?

24 A. It depends on what type of night I had. If I

25 made a lot of money that night, I wasn't leaving until

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1 around 9:00, 10:00 that morning, because the money was

2

too much. They couldn't count it in the money room in

3

time, so they will wait until the end of the night.

4

 Q. And have you on occasion left work sometimes

5 at 11:00 or 12:00 the next day -- the following day?

6

 A. Yes.

7

 Q. I mean 11:00 or 12:00 a.m. the following day?

8

 A. Yes.

9

 Q. And when you attended these -- when you

10 attended these mandatory meetings, were you paid for

11 those meetings?

12 A. No.

13 Q. And can you also describe for the Court the

14 ten percent that -- I'm sorry, can you describe for the

15 Court how you would leave after you paid ten percent at

16 the end of your shift?

17 A. After you pay the last person, everybody has

18 to sign off on your little slip, and when you go to the

19 front door, they ask you for your slip, they check your

20 bag, make sure you don't have no money because you're

21 not walking out with no ones, and --

22 THE ARBITRATOR: Walking out with no what?

23 THE WITNESS: No ones, no one dollar bills,

24 because they had a --

25 THE ARBITRATOR: No ones. Okay. Sorry.

Page 106

1

 THE WITNESS: We had to recycle all the ones

2

 throughout the night. So they check our bag for that,

3

 give them our slip, and we can leave.

4 BY MR. AKEMON:

5

 Q. And can you describe what the slip would look

6

like?

7

 A. A pink little slip, and everybody will sign

8

it, the DJ, the house mom and the security.

9

 Q. I'm going to show you what has been marked as

10 C24. Your Honor, I handed it to you right before.

11 THE ARBITRATOR: Right, I know. It's just

12 these notebooks are a bit unwieldy. I can't move

13 it around. So this is one, two, three -- a

14 five-page exhibit?

15 MR. AKEMON: Yes, Your Honor.

16 THE ARBITRATOR: Excuse me, a six-page

17 exhibit.

18 MR. AKEMON: Yes, Your Honor.

19 THE ARBITRATOR: Okay. Let's give this to

20 Stephanie. I'll bring a stapler in at the lunch

21 hour and we'll get these stapled as well.

22 MR. BRODSKY: Could you please identify what

23 it is that --

24 MR. AKEMON: C24.

25 MR. BRODSKY: But can you please identify what

Page 107

1

 your document is?

2

 MR. AKEMON: Copies of the slips.

3

 THE ARBITRATOR: I'll have you put that on the

4

 record as soon as it's marked. So we're looking at

5

 a six-page exhibit. The first four pages are the

6

 slips that you're going to explain, and the last

7

 two pages are a series of columns, handwritten

8

 column numbers dated starting March --

9

 MR. AKEMON: I'm sorry, those don't belong in

10 there, Your Honor.

11 THE ARBITRATOR: Ending July 16th.

12 MR. AKEMON: Just these.

13 THE ARBITRATOR: So we're not using these two?

14 MR. AKEMON: No. Just the slips, C24.

15 MR. BRODSKY: So in the book I have, C24 is

16 claimant Lygia Simmons' response to --

17 THE ARBITRATOR: It's apparently attached to

18 that document.

19 MR. AKEMON: It's attached to that. And I

20 explained to you yesterday that everything was

21 Lygia -- not yesterday, but --

22 THE ARBITRATOR: So you can get rid of

23 everything but these four pages, Mr. Brodsky.

24 MR. BRODSKY: But what I'm trying to

25 understand is this is for Ms. Holmes?

Page 108

1

 MR. AKEMON: This is for Ms. Griffen.

2

 MR. BRODSKY: Ms. Griffen. I'm sorry.

3

 MR. AKEMON: Yes.

4

 MR. BRODSKY: This is her response to the

5

 request for production?

6

 MR. AKEMON: No. I'm using it as an exhibit.

7

 It's not her response to the request for

8

 production.

9

 MR. BRODSKY: Are those what were contained

10 within her response?

11 MR. AKEMON: No, but they were part of the

12 exhibit list and exhibit tabs.

13 MR. BRODSKY: Not in my book.

14 MR. AKEMON: It's right there.

15 MR. BRODSKY: Please come and show me.

16 (Off the record.)

17 THE ARBITRATOR: Did you find what you're --

18 did you guys reach an agreement here?

19 MR. BRODSKY: No, not yet. We're trying.

20 THE ARBITRATOR: Are these four pages in his

21 exhibit book?

22 MR. AKEMON: Yes, they are, Your Honor.

23 THE ARBITRATOR: Do you have the four pages?

24 MR. BRODSKY: I do, but they were under

25 another claimant's name.

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1

 THE ARBITRATOR: No, that I understand, but

2

 these are apparently documents that the witness is

3

 going to identify.

4

 MR. AKEMON: Yes, Your Honor.

5

 THE ARBITRATOR: Okay. Let's hear what she

6

 has to say. So Exhibit 24 is four pages of the

7

 slips that each slip has five entries, date, dancer

8

 name, ten percent tip-out, dancer signature,

9

 manager; and you're going to describe these

10 apparently?

11 MR. AKEMON: Yes, Your Honor.

12 THE ARBITRATOR: Let's hear from Ms. Griffen.

13 BY MR. AKEMON:

14 Q. Ms. Griffen, do you recognize those slips?

15 A. Yes.

16 Q. Are those the types of slips that you would --

17 I'm sorry, strike that.

18 Are those the types of slips that you would be

19 required to present to security before leaving?

20 A. Yes.

21 Q. And you have to present these slips every

22 night before leaving? I mean, are these the types of

23 slips that you use to pay the ten percent every night?

24 A. Yes.

25 Q. Okay.

Page 110

1

 MR. AKEMON: Your Honor, this has been admitted,

2

 correct?

3

 THE ARBITRATOR: Yes, I'll admit these. But

4

 let me just ask, I'm just curious, so when it says

5

 10 percent, tip out 20, does that mean it was

6

 $200?

7

 THE WITNESS: Yes. That means that that

8

 dancer, she only turned in $200 in ones. So we

9

 kind of started to get smart on the whole ten

10 percent process, because they were taking so much

11 of our money.

12 So we would tell our customers pay us in big

13 bills because they couldn't calculate our big

14 bills because we were able to keep that money.

15 Anything that was a dollar, they wanted it, and

16 they wanted to count it and take their 10 percent.

17 THE ARBITRATOR: I just want to understand how

18 to read these.

19 MR. BRODSKY: Your Honor, I think what I was

20 trying to say before is correct. The witness -- or

21 the claimant just identified those slips I believe

22 as from another --

23 THE ARBITRATOR: I understand they are not

24 from her. They are just slips that she said this

25 is the type of slip. Mr. Akemon asked if this was

Page 111

1

 the type of slip that got turned in, and I

2

 appreciate that. I just want to understand what

3

 the information on this slip represented. It looks

4

 like the name of a dancer, the amount of the

5

 tip-out, and signed with initials by a manager.

6

 THE WITNESS: Yes.

7

 THE ARBITRATOR: I got it. Okay.

8 BY MR. AKEMON:

9

 Q. And who would you give the slip to at the end

10 of the night?

11 A. Whoever was at the front door, security.

12 Q. Have you ever attempted to leave the club

13 premises without providing this slip to security?

14 A. Yes.

15 Q. And can you tell the Court what would happen

16 on occasion when you tried to leave without presenting

17 this slip?

18 A. Get a fine or they tell you not to come back.

19 Q. And who would sign off on this slip, on these

20 types of slips?

21 A. Either Rick or Akinyele or whoever was the

22 manager at that time.

23 Q. And you also talked about the rules earlier.

24 Were those rules for you and every other dancer at the

25 club?

Page 112

1

 A. Yes.

2

 Q. And on occasion, were you able to -- strike

3

that. When you came to work, there was a sign-in list

4 at the club, correct?

5

 A. Yes.

6

 Q. I'm sorry. I didn't mean to do a leading

7 question. Did that sign-in list determine stage sets?

8

 THE ARBITRATOR: I'm sorry, determine what?

9

 MR. AKEMON: Stage sets.

10 A. It depends. Like Tan, she knew how many girls

11 it took for it to be, like, a real good stage set. So

12 on top of me paying on average $250 in my house fee, I

13 could tip Tan an extra $100 to put me on the list to

14 where I didn't have to go on stage so early.

15 Q. Okay. Let's describe King of Diamonds. You

16 heard testimony earlier that it was a pretty big club?

17 A. Yes, sir.

18 Q. How many stages were at King of Diamonds? How

19 many stages did King of Diamonds have?

20 A. Well, we only used two of them, but there were

21 four or five.

22 Q. Five what? Five stages?

23 A. Five stages. There was the big one in the

24 middle, the two on the side, and it was two stages

25 connected to sections in the back.

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1

 Q. And with respect to those stages, did you get

2

to determine which stages you were going to perform on?

3

 A. No, because we only used two. So they would

4 have basically two lists. They have one list, but they

5 split it up because we have two stages. So they will

6 keep both stages running because we had so many girls.

7

 Q. And then did you keep track of all your tips at

8 King of Diamonds?

9

 A. No.

10 Q. And did you pay taxes during your time at King

11 of Diamonds?

12 A. I did pay taxes, but I didn't use KOD as a job

13 I could write off.

14 Q. And why not?

15 A. I didn't know dancers could file taxes like

16 that.

17 Q. And so did you write off your house fees or

18 tip-outs?

19 A. No.

20 Q. Why not?

21 A. I had no record of none of that.

22 Q. Now, you don't have any documentation about

23 the time that you arrived at King of Diamonds, do you?

24 A. No, but the club should.

25 Q. And do you have any documentation about how

Page 114

1 you paid house fees?

2

 A. No, but the club should.

3

 Q. And can you tell the Court how you would know

4 how many days per week that you worked at King of

5 Diamonds?

6

 A. I mean, I worked there for years, so it's like

7 pretty normal of my schedule throughout the day. I'm

8 cleaning up my house or I'm running errands. By 9:00,

9 10:00, I know I need to be on my way to work. So it was

10 kind of a routine for me, so there was no need for me to

11 document everything because it was a part of my

12 routine.

13 Q. So from 2010 to 2014, this is pretty -- this

14 is like a schedule for you, it's part of your life?

15 A. Yes.

16 Q. And with respect to the house fees, how can

17 you explain -- please explain to this Court how you know

18 that the number that you're giving us is the average

19 number in house fees.

20 A. Can you rephrase it again?

21 Q. I'm sorry. You earlier testified you paid an

22 average amount of house fees. Can you explain to the

23 Court how you arrived at that number? Was it part of

24 your routine as well to pay a certain amount?

25 A. Yes. I mean, of course it fluctuated because

Page 115

1 of the events, but on average, I know for sure I'm

2 paying $250.

3

 Q. Okay. And this was throughout the time that

4 you worked at King of Diamonds?

5

 A. Yes.

6

 Q. And the same with the house mom, DJ and

7 security?

8

 A. Yes.

9

 Q. Was this part of your normal routine with

10 working?

11 A. Yes.

12 Q. So when you would arrive at King of Diamonds,

13 you pretty much knew that either, A, your house fees

14 were going to fluctuate, but you had to pay them?

15 A. Right.

16 Q. And you knew that it was mandatory to pay the

17 house mom, the DJ and security?

18 A. Correct.

19 Q. And did you protest at any time about paying

20 house fees or tipping out security, house mom and DJ?

21 A. No. I mean, I stated my opinion about it and

22 how I felt when we had our meetings and stuff, but like

23 Ms. Holmes said, if -- we could express how we felt, but

24 that didn't mean it was going to change.

25 Q. And during this time when you expressed it,

Page 116

1 were your concerns addressed by management?

2

 A. No, nothing was fixed.

3

 Q. Was it addressed by Akinyele?

4

 A. He didn't fix it because nothing changed.

5

 Q. And so the policy -- let's go back to 2010.

6 You were required to pay house fees in 2010 and 2011,

7 correct?

8

 A. Right. I don't think Akinyele was there at

9

that time, if I'm not mistaken.

10 Q. And then after Akinyele came on board in 2012

11 or 2013 --

12 A. It just got more strict as far as it was

13 mandatory to pay the ten percent. Like you couldn't

14 walk out the door without paying the ten percent.

15 Q. Hold on one second. Let me ask my question.

16 After Akinyele came on board, you still had to pay house

17 fees?

18 A. Right.

19 Q. Were you labeled an independent contractor in

20 2010 or 2011 by the club?

21 A. I mean, they didn't say nothing, but I knew I

22 was an independent contractor.

23 Q. Okay. And then after Akinyele came on board,

24 did they continue a policy of maintaining the house mom,

25 DJ and security tip-outs?

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1

 A. Yes, it was still mandatory.

2

 Q. So nothing changed from 2010 to 2014?

3

 A. Not necessarily, besides the slip and

4 basically locking us in there until we paid.

5

 Q. Okay. And the documents that we previously

6

identified --

7

 A. Right. The slips.

8

 Q. -- the arbitration policy, that came after

9 Akinyele came on board?

10 A. Yes.

11 Q. Okay. No further questions, Your Honor.

12 THE ARBITRATOR: Okay. So it's 12:12. My

13 suggestion is we break now for lunch. Given how

14 long the cross took for Ms. Holmes, I assume it

15 will be roughly similar, Mr. Tobin, is that fair?

16 MR. TOBIN: Yes.

17 THE ARBITRATOR: And then were you going to

18 call Ms. Galardi?

19 MR. AKEMON: No, Your Honor.

20 THE ARBITRATOR: Okay. And you're going to

21 call Ms. Galardi?

22 MR. BRODSKY: Yes.

23 THE ARBITRATOR: And so we'll have -- and how

24 long do you think that direct will go?

25 MR. BRODSKY: Our direct will not be that

Page 118

1

 long.

2

 THE ARBITRATOR: Okay. So I think we'll have

3

 plenty of time to finish before 5:00 today quite

4

 easily. So why don't we come back at 1:15. That

5

 gives everybody an hour and three minutes. Does

6

 that work? Or is 1:30 more --

7

 MR. BRODSKY: 1:15 is good. Also, Your Honor,

8

 just housekeeping, from the comments at the

9

 inception where we're talking about opening, and

10 then we have already previously agreed that we're

11 going to do the post-hearing briefs, we're not

12 going to do closings today, right?

13 THE ARBITRATOR: No need for closings. No

14 need for closings. The hearing will not be closed

15 until the post-hearing briefs are submitted.

16 But I'll get a stapler and staple these, and

17 we have to make sure that we -- I'm a little

18 concerned, Mr. Akemon, that all these exhibit books

19 match up.

20 Your clerical abilities were challenged this

21 week, so I just want to make sure that I'm going to

22 staple the right page onto -- it's the second page

23 I need to fix.

24 MR. BRODSKY: And also by way of housekeeping,

25 all of the exhibits that I've seen so far are being

Page 119

1

 actually introduced separate into evidence?

2

 THE ARBITRATOR: Yes. I'm going to admit all

3

 the exhibits subject to any objections I've not

4

 heard yet as to an exhibit I was not aware of

5

 because I was working with a different list.

6

 But if there are any objections to these

7

 exhibits, you need to raise them at some point.

8

 But, otherwise, it's my general rule of thumb where

9

 I accept whether I -- I could have done much is a

10 different story.

11 MR. BRODSKY: Yeah. You've already made that

12 very clear by e-mail. But my question is a lot

13 simpler than that.

14 THE ARBITRATOR: Okay. I'm going to admit all

15 the exhibits unless somebody else has an objection.

16 MR. BRODSKY: But what I'm seeing so far is

17 they are being admitted individually, correct?

18 THE ARBITRATOR: That's only because of the

19 way of his questioning. I'm going to admit all the

20 exhibits. Part of the reason is they are not

21 premarked.

22 MR. BRODSKY: But is that the way we're going

23 to continue to do this?

24 THE ARBITRATOR: You don't have to, as long

25 as yours are premarked. That's my concern. I have

Page 120

1

 numbers on all these, and if I lose this notebook

2

 somehow and they fall out of order, I don't know

3

 what number they belong to, and they are not -- I'm

4

 just concerned that we make sure we have the right

5

 exhibit labels on the right exhibits, so I'm not

6

 stopping Mr. Akemon from doing what he's doing.

7

 But do not worry, your exhibits will be

8

 admitted, his exhibits are admitted. I just want

9

 to make sure we get them all marked correctly.

10 MR. BRODSKY: But I don't think I'm making my

11 point clear. I'm sorry. I'm doing the best I can.

12 THE ARBITRATOR: No, I'm dense sometimes. Go

13 ahead.

14 MR. BRODSKY: No, no, please. So far during

15 this hearing, individual exhibits have been marked

16 by the court reporter and given to -- and moved in

17 and given to Your Honor. My question is is that

18 the way we're going to continue this process?

19 THE ARBITRATOR: You don't have to do it that

20 way because you can simply say it's already been

21 admitted. That's fine with me, too. But if you

22 wish to do what Mr. Akemon did following protocol,

23 that's okay with me.

24 MR. BRODSKY: In order to show obviously --

25 THE ARBITRATOR: I'm not going to stop you.

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1

 But they have already been -- they are not

2

 premarked is my concern.

3

 That's why I didn't interfere with the way he

4

 was doing it. Because we need to have numbers when

5

 the witness is looking at a document, because some

6

 of these exhibits have different numbers on them.

7

 And I was worried that the witness would say the

8

 number and the court reporter -- and we would all

9

 get confused.

10 MR. BRODSKY: And, I think we've all seen that

11 the numbers on the exhibit list do not correspond

12 to the numbers --

13 THE ARBITRATOR: We're getting all those

14 fixed.

15 MR. AKEMON: Yeah. From the March 15th

16 e-mail, they match.

17 MR. BRODSKY: They do?

18 MR. AKEMON: Yes. The e-mail that you

19 received, they match.

20 THE ARBITRATOR: Why don't we come back --

21 MR. AKEMON: I'll fix all that.

22 THE ARBITRATOR: Let's come back at 1:30.

23 Let's come back at 1:30.

24 (Thereupon, a lunch recess was held.)

25 THE ARBITRATOR: Okay. We're back on the

Page 122

1

 record. Mr. Tobin, you may proceed.

2

 MR. TOBIN: Thank you.

3

 CROSS-EXAMINATION

4 BY MR. TOBIN:

5

 Q. Good afternoon, Ms. Griffen.

6

 A. Good afternoon.

7

 Q. When you were employed at King of Diamonds,

8 were you self-employed?

9

 A. From my knowledge, yes, sir.

10 Q. Do you know anything at all about Teri

11 Galardi?

12 A. I've heard of her name, but I've never met her

13 personally.

14 Q. Have you ever seen her?

15 A. No, sir.

16 Q. During the years in question -- strike that.

17 Are you still attending mortuary school?

18 A. Not right now, not anymore. I just had a

19 daughter. I just had a baby a year ago, so I had to

20 take a break after Christmas.

21 Q. You can take that mask off, by the way.

22 A. Okay. Thank you. I just had a daughter in

23 March of 2020, so I stopped school in December of 2020.

24 Q. Are you doing anything at all right now?

25 A. No, I'm not. I get VA checks.

Page 123

1

 Q. When was the last time you were employed?

2

 A. Before I had my daughter.

3

 Q. How long ago was that?

4

 A. I got pregnant in June.

5

 Q. About?

6

 A. I got pregnant in June 2019.

7

 Q. So you haven't worked since June of 2019?

8

 A. Yes, sir.

9

 Q. How are you supporting yourself?

10 MR. AKEMON: Objection, Your Honor, relevance.

11 THE ARBITRATOR: It's off afield here, Mr.

12 Tobin. What's the relevance of that one? What

13 difference does it make how she's supporting

14 herself today?

15 MR. TOBIN: It's going to relate back to how

16 much money she made at KOD that she's able to --

17 THE ARBITRATOR: Mr. Tobin, we're talking

18 about 2019 versus 2014. I'll sustain the

19 objection.

20 BY MR. TOBIN:

21 Q. When did you work at Allure?

22 A. I worked at Allure 2018 -- no --

23 Q. After you left KOD?

24 A. Yeah, but years after I left KOD.

25 Q. What year did you leave KOD?

Page 124

1

 A. I left KOD in 2014.

2

 Q. Between 2014 and 2018, where did you work?

3

 MR. AKEMON: Again, Your Honor, objection,

4

 relevance.

5

 THE ARBITRATOR: We'll see how she answers

6

 this question first, and then I'll -- I may agree

7

 with you. But let's see where this is going.

8

 A. I had somebody taking care of me.

9

 Q. You had somebody taking care of you?

10 A. Yes.

11 Q. Do you know what Teri Galardi had to do with

12 KOD?

13 A. I never asked, so no.

14 Q. Did you ever ask anybody about her?

15 A. All I know is that when the club got turned

16 over to new management, that the dancers were aware of

17 it. But anything of her requirements of what she's

18 done, I didn't ask.

19 Q. You paid your house fees to Tan?

20 A. Yes, who was employed by the club.

21 Q. How much were the fees that you paid to Tan?

22 A. It fluctuated, so it depends if it was an

23 event night or if it was a normal night.

24 Q. Did the club provide you with a stage to work

25 on?

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 A. Of course.

2

 Q. Did they charge you -- did they provide you

3 with music?

4

 A. Yes, sir.

5

 Q. They provided you with a building to work in?

6

 A. Yes, sir.

7

 Q. Did you pay for any of that?

8

 A. I mean, as in what sense?

9

 Q. Did you contribute to the mortgage on the

10 building?

11 MR. AKEMON: Objection, Your Honor, relevance.

12 THE ARBITRATOR: Well, I allowed these

13 questions for Ms. Holmes. I'll allow these

14 questions for Ms. Griffen. I assume I know the

15 answer to that, but you can answer it.

16 A. I mean, I don't know where my money was going

17 to. All I know is that I was obligated to pay a certain

18 amount of fees when I came into work. When I gave 

19 them the money, what they did with the money I have no

20 idea.

21 Q. Was the money used to give you a place to earn

22 more money, to entertain?

23 A. I can't answer that because I have no idea

24 what the money was used for when it left my hands.

25 Q. Do you have anything that would establish that

Page 126

1 you worked at KOD?

2

 A. I do not personally, no.

3

 Q. You ever appear in photos?

4

 A. I mean, if you look back on the internet, I

5 might.

6

 Q. But you don't know of any? Did you file any

7

federal income tax returns that would show that you

8 worked at KOD?

9

 A. I did file tax returns, but I did not file tax

10 returns as a dancer.

11 Q. You didn't file tax returns as a dancer?

12 A. No, I did not.

13 Q. What did you file tax returns as?

14 A. Excuse me. I filed taxes to make sure that I

15 did not owe the IRS any money.

16 Q. When did you file tax returns?

17 A. I have been filing taxes ever since I came out

18 of the military in 2000 --

19 Q. I'm sorry, ma'am, you're speaking too fast for

20 me.

21 A. I'm sorry. I have been filing taxes; ever

22 since I came out of the military in 2009, I have been

23 filing taxes.

24 Q. You started filing tax returns in 2009?

25 A. Yes, sir.

Page 127

1

 Q. But you never included any of the income from

2 KOD?

3

 A. I didn't know that dancers, which were

4

independent contractors, could. I wasn't informed of

5

that information.

6

 Q. You were an independent contractor? Is that

7 what you're telling me?

8

 A. I mean, that's what I was told.

9

 Q. And that's why you didn't file the information

10 about what you earned at KOD?

11 A. Yes, sir, but KOD wasn't giving out W-2s to

12 the strippers.

13 Q. The meetings that you had monthly, did you

14 attend those meetings?

15 A. Sometimes.

16 Q. Sometimes?

17 A. Yes, sir.

18 Q. It wasn't mandatory, was it?

19 A. They were mandatory, but if I chose not to

20 come, I chose to get fined. So if I choose to pay that

21 money, I just didn't want to come to the meeting because

22 my needs weren't getting met at the meeting, so there

23 was no need for me to come.

24 Q. Wasn't it the purpose of those meetings so

25 that everybody could improve what they were doing and

Page 128

1 earn more money?

2

 A. I mean, but these meetings weren't new, they

3 are old. So, therefore, if I'm going to a meeting that's

4 constantly saying the same thing and there's nothing

5 getting fixed, why do I need to keep going?

6

 The owner of the club, the managers of the

7 club, they are not listening to their workers. So there

8 was no need for me to go to a meeting and state my

9 opinion of how I felt I was being treated because it

10 wasn't getting fixed. This wasn't the first meeting.

11 Q. Who from management attended those meetings?

12 A. Akinyele, Rick, the managers at that time.

13 Q. Akinyele was the boss, wasn't he?

14 A. No, he was not the boss.

15 Q. He was not your boss?

16 A. He was my boss, but he had a boss.

17 Q. He was your boss?

18 A. He was my boss.

19 Q. Did you ever see Teri Galardi at any of those

20 meetings?

21 A. I don't know what she look like.

22 Q. Did you and Ms. Holmes work the same days?

23 A. Sometimes.

24 Q. You're friends?

25 A. I wouldn't say we're friends. We're

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coworkers.

2

 Q. Where do you live now?

3

 A. I live in Atlanta, Georgia.

4

 Q. And Ms. Holmes lives where?

5

 A. I have no idea.

6

 Q. How often do you speak to each other?

7

 A. We don't. This is our first time seeing each

8 other in years.

9

 Q. You were talking about heavy bags, and you

10 stayed extra because you had to count the bags. You

11 want to tell me about that?

12 A. Okay. Well, if I were dancing in a section

13 that had five girls, me and four other girls, they

14 wouldn't -- the club wouldn't count that money until the

15 end of the night because it was so much. So they would

16 wait until the end of the night.

17 Q. Teri Galardi never got the bag with your

18 money, did she?

19 A. I have no idea, sir.

20 Q. Who hired the house mom?

21 A. From my recollection, the club, but I don't

22 know who personally hired the house mom. She was

23 already hired before I got hired.

24 Q. Were there nights that you worked late into

25 the morning because it was too much money to count?

Page 130

1

 A. I mean, what do you mean by that?

2

 Q. You testified that you generally got off at

3 9:00 in the morning, but when there was too much money

4

to count, you stayed until 10:00 or 11:00.

5

 A. Well, when I say that, I mean it's because I'm

6 not the only one who made a lot of money that night. So,

7

therefore, the people who are counting our money, they

8 have to put us in order.

9

 So if I come to you and I'm 50 in line, and I

10 have $10,000, and there's three of us, you're not going

11 to count that by yourself. You're going to wait for the

12 girls who danced in that money to come count their money

13 to straighten it out to make sure that we give the

14 proper ten percent.

15 Q. So there were nights that you counted $10,000?

16 A. There was nights that I counted $30,000,

17 $40,000.

18 Q. There were nights that you counted $40,000?

19 Is that what you said?

20 A. Yes, sir.

21 Q. And how much of that $40,000 was yours?

22 A. It depends on how many girls was in the

23 section. I'm not dancing for $40,000 on my own.

24 Q. Approximately how much of the $40,000 would

25 you get?

Page 131

1

 A. On average, I have no idea, because it

2 depends on how many girls was in that section. I can't

3 pinpoint how much I got because I'm not the only one

4 dancing in that section. I'm not the only one working

5

in that section. The club makes us split our money.

6 We're not obligated to nothing on our own.

7

 Q. Who -- how many times were you fined in the

8 years that you worked there?

9

 A. Four times, three or four times.

10 Q. In how many years?

11 A. From 2010 to 2004 --

12 Q. From -- I'm sorry, ma'am?

13 A. From 2010 to 2004 --

14 THE ARBITRATOR: '14.

15 THE WITNESS: Sorry. I'm off. 2014. I

16 apologize.

17 BY MR. TOBIN:

18 Q. Perhaps once a year, correct?

19 A. I mean, I could have went a year without

20 getting in trouble, so yeah.

21 Q. And how much were you fined average?

22 A. Between $250 and $500. It depends on what I

23 did.

24 Q. How much?

25 A. Between $250 and $500. It depends on what I

Page 132

1 did.

2

 Q. Specifically, could you tell me when Akinyele

3

took over?

4

 A. I don't know the exact year or month or

5 anything like that, but I know it was around -- between

6 2011 to 2012. I'm really not for sure.

7

 Q. In 2012 or 2013, Floyd Maryweather (sic) came

8

in. How much did you pay to work when he was there?

9

 A. I don't know a specific amount.

10 Q. You don't remember?

11 A. I don't remember a specific amount.

12 Q. The Exhibit 24, the slips --

13 A. Yes, sir.

14 Q. -- have you seen them?

15 A. That was before we had our break, correct?

16 Q. Yes.

17 A. Yes, I've seen those.

18 Q. Did Teri Galardi have anything to do with

19 those slips?

20 MR. AKEMON: Objection, calls for speculation.

21 THE ARBITRATOR: I'm sorry, what's the

22 objection?

23 MR. AKEMON: Calls for speculation.

24 THE ARBITRATOR: Speculation? That question

25 is a fair question. Did Ms. Galardi have anything

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 to do with the slips as far as you know?

2

 THE WITNESS: I have no recollection of that.

3

 MR. TOBIN: May I have a moment, Your Honor?

4

 THE ARBITRATOR: Sure.

5

 MR. TOBIN: Mr. Barkett.

6

 THE ARBITRATOR: Whatever you wish to call me.

7

 You're the only Your Honor in the room.

8

 MR. BRODSKY: Do you have a preference?

9

 THE ARBITRATOR: No, I don't care. Whatever

10 you call me.

11 MR. BRODSKY: I just by nature do that.

12 THE ARBITRATOR: I know, it's a habit. That's

13 why I don't say anything. It's just easier for

14 lawyers. Mr. Tobin is the only Your Honor in the

15 room.

16 THE WITNESS: He's a judge?

17 THE ARBITRATOR: Former judge.

18 THE WITNESS: Okay. Former judge.

19 THE ARBITRATOR: But whatever is best for you

20 guys is fine for me. Mr. Arbitrator, Mr. Barkett,

21 Your Honor, whatever you wish.

22 MR. BRODSKY: I'm just going to go with what's

23 comfortable.

24 THE ARBITRATOR: Whatever comes out of your

25 mouth is going to be fine.

Page 134

1

 MR. BRODSKY: Because that's how it's going to

2

 be. We'll be right back, okay?

3

 THE ARBITRATOR: Yes.

4

 (Off the record.)

5

 THE ARBITRATOR: Back on the record. You may

6

 proceed.

7 BY MR. TOBIN:

8

 Q. In the year 2010, could you tell me how much

9 money you earned?

10 A. I cannot be specific with the amount, not at

11 this very moment. If you allow me to look it up, I

12 can.

13 Q. In 2010, did you have one job or two jobs?

14 A. I had one job.

15 Q. King of Diamonds?

16 A. Yes, sir.

17 Q. Earlier, you testified that you had filed

18 income tax returns for your other job.

19 A. I never said it was for my other job. I said I

20 filed so I wouldn't owe the IRS any money, but I never

21 filed because I have another job.

22 Q. So did you file in 2010?

23 A. I filed every year after I got out of the

24 military.

25 Q. You filed a tax return in 2010, but you don't

Page 135

1 know how much you earned, correct?

2

 A. No, I didn't get any money back on my tax

3

returns because I didn't have a job. I was told that

4

I'm supposed to file taxes regardless if I have a job or

5 not because I don't want to owe the IRS any money. So

6

I always filed.

7

 Q. Okay. So we understand that in the year 2010,

8 you did not declare any of the money you earned at KOD,

9 correct?

10 A. Correct.

11 Q. But you don't remember how much you earned at

12 KOD that year?

13 A. No.

14 Q. Do you remember how much you earned at KOD in

15 2010?

16 A. No, sir, I do not remember the number amount.

17 Q. Was it more than $50,000?

18 A. Yes, sir.

19 Q. Was it more than $60,000?

20 A. Probably around there.

21 MR. AKEMON: Objection, Your Honor, relevance

22 to this line of questioning.

23 THE ARBITRATOR: I'll hold onto testimony, and

24 we'll see whether they can connect it up in their

25 post-hearing submissions.

Page 136

1 BY MR. TOBIN:

2

 Q. How much did you earn in 2011 at KOD?

3

 A. I couldn't give you a specific number.

4

 Q. Approximate it for me.

5

 A. I don't want to guess for you. That would --

6

 Q. You don't want to guess?

7

 A. I don't want to guess.

8

 Q. What about 2012?

9

 A. I still don't want to guess.

10 Q. What is it that you have in your hand that

11 you're looking at?

12 A. I can pull up my files that I have.

13 Q. I'm sorry?

14 A. I can pull up my files that I have on my phone

15 if you want me to. Do you want me to?

16 Q. You can pull up what?

17 A. I can pull up my files that I have.

18 THE ARBITRATOR: Her files.

19 THE WITNESS: Files, my documents.

20 BY MR. TOBIN:

21 Q. You have those documents?

22 A. Yes, sir.

23 Q. Okay. Pull them up.

24 A. Okay. Yes, sir. No problem.

25 Q. Would you tell me what document that is?

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 A. If you got Exhibit 24C or 24B.

2

 THE ARBITRATOR: I can just hand it to you if

3

 that's easier.

4

 THE WITNESS: Yes, please. Thank you so much.

5

 MR. TOBIN: May I look at that document to see

6

 what it is?

7

 THE ARBITRATOR: It's the one that she

8

 testified to earlier.

9

 THE WITNESS: There's no WiFi up here, so it's

10 not pulling up.

11 THE ARBITRATOR: That's okay. We have it here

12 as an exhibit. None of us were quite sure what you

13 were talking about, so now we know.

14 MR. TOBIN: Do you have an extra copy of this

15 that I can look at?

16 THE ARBITRATOR: You can show the witness.

17 You need one while you're talking to the witness?

18 Do you have another one?

19 MR. AKEMON: It's in his binder, that

20 document. I believe that's the presuit notice. Is

21 that what you're looking at?

22 THE ARBITRATOR: Yes, that's the presuit

23 notice.

24 MR. AKEMON: Yeah. They have it in their

25 binder.

Page 138

1

 MR. BRODSKY: What exhibit number is it?

2

 MR. AKEMON: 23B.

3

 THE ARBITRATOR: 23B.

4 BY MR. TOBIN:

5

 Q. Do you know who prepared this document for

6 you?

7

 A. Me and my lawyer.

8

 Q. You and your lawyer?

9

 A. Yes, sir.

10 Q. Mr. Akemon?

11 A. Yes, sir.

12 Q. In the year 2010, you worked 30 weeks?

13 A. Yes, sir.

14 Q. Do you have records to establish which during

15 that year the 30 weeks are that you worked?

16 A. No, but I'm sure the club does because they

17 have --

18 Q. I'm sorry?

19 A. I said, no, I do not, but the club does. They

20 document every time we come into work.

21 Q. The clerk does?

22 A. The club.

23 THE ARBITRATOR: The club.

24 BY MR. TOBIN:

25 Q. The club has documents?

Page 139

1

 A. Yes, sir.

2

 Q. Well, do you have anything that would

3 establish the 30 weeks that you worked?

4

 A. I do not personally, no.

5

 Q. Do you have anything that would establish the

6 shifts that you worked per week in the year 2010?

7

 A. No, but as I said, the club should, because we

8 have to sign in before we can even walk into the club.

9

 Q. You're saying the club has records?

10 A. The club should --

11 Q. How do you know that?

12 A. I mean, because Tan was the door girl, and she

13 took our money. She wrote down our names.

14 Q. Did you see Tan write it down?

15 A. Yes, I did.

16 Q. Do you know what Tan did with those papers?

17 A. I have no idea where those documents went to.

18 Q. And that was in 2010 that Tan did that?

19 A. It was 2010 until I stopped working in 2014.

20 Q. And that would show that you worked nine hours

21 per shift?

22 A. Yes, sir.

23 Q. And that was every day?

24 A. It wasn't every day. I worked on an average

25 of five days a week. Sometimes I took off three days.

Page 140

1 Sometimes I took off two days. But on the average, I

2 worked five days a week.

3

 Q. Where is that reflected in the records how 

4 many days you took off per week?

5

 A. I mean, it's not reflected in the records if

6

they didn't document it down.

7

 Q. Actually, it's nothing more than a guess on

8 your part, is it?

9

 A. A guess on what?

10 Q. On your part, is it?

11 A. On what determination?

12 Q. The hours and days and weeks?

13 A. To whose knowledge, me or yours?

14 Q. Do you have any records?

15 A. No, I do not.

16 Q. Forgetting Tan and anybody else, do you have

17 any records?

18 A. No, sir, I do not.

19 Q. So this is a creation of you and your lawyer,

20 correct?

21 A. I mean, it's -- you could call it that, but

22 it's -- it was my routine for four to five years. So

23 there was no way I could deflect from my schedule. It's

24 just like you waking up to be a lawyer every morning. I

25 woke up every morning to be a stripper for King of

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1 Diamonds for four to five years. It was part of my

2

routine. There was no reason for me to document that.

3

 Q. There are 52 weeks in a year.

4

 A. Yes, sir.

5

 Q. In the year 2010, you only worked 30 weeks?

6

 A. Right, because I started in the middle of the

7

year.

8

 Q. And you have no records of your own to

9 support?

10 A. Not my own, no, sir.

11 Q. The year 2011, you worked 18 weeks more than

12 you did in 2010. How do you know that?

13 A. Because I have to deduct my birthday --

14 Q. I'm sorry?

15 A. I have to deduct my birthday, I have to deduct

16 holidays and the times that I went home. I'm not from

17 Florida, so my family is originally from Texas.

18 So I went home to visit family, I went home

19 for birthdays. So I'm not going to count that I worked

20 the whole year every day for seven days a week. That's

21 not logical and that's not believable either.

22 Q. You didn't have a daily calendar to

23 mark off the days that you worked?

24 A. Honestly, sir, I didn't feel like there was

25 a need to do that.

Page 142

1

 Q. Say it again, I'm sorry.

2

 A. I'm sorry. I didn't feel there was a need to

3 document my work schedule.

4

 Q. Why were you thinking that back then? Were

5 you planning on some kind of a lawsuit back then?

6

 A. I'm saying I didn't think it was necessary for

7 me to track my work schedule because I wasn't thinking

8 about anything like this at that time.

9

 Q. It would have been a lot easier to figure out

10 the difference if you had records, wouldn't it be?

11 A. I mean, if I had preplanned suing somebody,

12 then yes. But I didn't preplan this.

13 Q. So what it boils down to is this is your best

14 guess as to what the weeks were, correct?

15 A. It's a guess, but it's also a fact, because I

16 did it every day almost for five years. So of course I

17 know what I've done.

18 Q. The same would apply to 2012, '13 and '14, am

19 I right?

20 A. Yes, sir.

21 Q. You spoke about tip-outs.

22 A. Yes, sir.

23 Q. Is that what you paid when you left?

24 A. Yes, sir.

25 Q. You were saying that if you didn't pay, you

Page 143

1 couldn't leave; is that your testimony?

2

 A. Yes, sir.

3

 Q. Did you call the police?

4

 A. No, sir.

5

 Q. Why did you stay at King of Diamonds?

6

 THE ARBITRATOR: What was your question?

7 BY MR. TOBIN:

8

 Q. Why did she stay at King of Diamonds?

9

 A. I'm not from Florida, so from my knowledge,

10 the best club to work at was King of Diamonds at that

11 time.

12 Q. So you're a Texas girl?

13 A. Yes, sir.

14 Q. Aren't there adult clubs in Texas?

15 A. My family lives there, so there was no reason

16 for me to dance.

17 Q. But that's not an answer to my question.

18 Weren't there clubs in Texas?

19 A. Yes, but it's ran differently. I've danced in

20 Texas before, but it's completely different. Our house

21 fees in Texas is nowhere near how much we pay in

22 Florida.

23 Q. Well, any of the clubs in Texas that you know

24 of where the girls earn 20,000 bucks in a night?

25 MR. AKEMON: Objection, Your Honor, calls for

Page 144

1

 speculation.

2

 THE ARBITRATOR: Well, the question may not

3

 have anything to do with what she's already said,

4

 but you have to -- I'm not sure what it has to do

5

 with anything. It's not so much speculation as to

6

 relevance. What difference does it make what

7

 happened at a Texas club, Mr. Tobin? Tell me how

8

 that's relevant to this case.

9

 MR. TOBIN: What I'm attempting to establish

10 is that King of Diamonds was probably the best club

11 in the United States, and every girl that did adult

12 dancing wanted to work there.

13 THE WITNESS: I wouldn't say that.

14 MR. TOBIN: It was a privilege to work there.

15 THE ARBITRATOR: You can ask her those

16 questions.

17 BY MR. TOBIN:

18 Q. Wasn't it a privilege to work at King of

19 Diamonds?

20 A. When you say privilege, do you mean I was

21 honored to work there or were they honored to have me

22 work there?

23 Q. Both.

24 A. It was an honor for them to have me work

25 there.

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1

 Q. Both.

2

 A. No, it wasn't a privilege for me to be there

3 because I could have took --

4

 Q. So it was an honor for them to have you, but

5

it wasn't an honor for you to work there?

6

 A. I mean, I was paying them --

7

 Q. Is that what you're saying?

8

 A. I mean, I'm paying them to be there.

9

 Q. Why did you stay?

10 A. I mean, in Florida, that was the club you were

11 supposed to work at as a new dancer. And me not knowing

12 anything about South Florida and how it works, I'm going

13 to go where I hear the most chatter at. I'm new, I'm

14 fresh to the city, to the state, everything. So I'm

15 just going to go where I know -- where I hear people are

16 going to be at.

17 Q. But is it fair to say that you could have gone

18 to work at any place and did not have to stay at KOD if

19 you felt abused in any way?

20 MR. AKEMON: Objection, Your Honor,

21 mischaracterizes her previous testimony. I don't

22 think she's ever mentioned --

23 THE ARBITRATOR: I'll allow the question. The

24 question essentially is why did you stay for year

25 two, year three, year four. I'm not so sure about

Page 146

1

 the abuse part. But the question is why did you

2

 stay. You still haven't answered that question.

3

 THE WITNESS: Okay. I will.

4

 THE ARBITRATOR: I understand why you started.

5

 I understand why you started.

6

 THE WITNESS: I was confused.

7

 THE ARBITRATOR: Let me -- I understand why

8

 you started. You answered that. But you still

9

 haven't answered why you stayed.

10 THE WITNESS: Okay. I stayed because it was a

11 part of my normal routine. I didn't know anything

12 about any other club until I completely stopped

13 working at KOD, which was in 2014.

14 I had to completely give it up because it

15 wasn't working in my favor. So I had to figure out

16 a new way, but I stayed that long because that was

17 all I knew. When it's all you know, you're going

18 to stay, even though it's difficult to deal with.

19 BY MR. TOBIN:

20 Q. You worked at Allure, didn't you?

21 A. Allure was after the fact, yes, sir.

22 Q. Did you earn more at Allure than you earned

23 at KOD?

24 MR. AKEMON: Objection, Your Honor, relevance.

25 THE ARBITRATOR: I'll allow the question.

Page 147

1

 A. I worked at Allure at a lesser time than I did

2 at KOD. I worked at KOD for years. I worked at Allure

3

for a year.

4

 Q. And during that year --

5

 A. Within that year --

6

 Q. -- did you earn more than you did at KOD?

7

 A. My first year working at KOD and my first year

8

compared to Allure, yes, I did make more money at Allure

9

than I did KOD.

10 Q. You did?

11 A. Yes, I did.

12 Q. Why didn't you stay?

13 MR. AKEMON: Again, Your Honor, we're talking

14 about a whole other club in --

15 THE ARBITRATOR: But it has potential

16 relevance from an earning standpoint relative to

17 how their comparison works.

18 A. I also don't see how it makes the comparison

19 because it's two different times.

20 MR. AKEMON: Ms. Griffen, just answer the

21 question.

22 THE ARBITRATOR: Why she stayed at Allure is

23 not relevant, Mr. Tobin. The question is -- you

24 asked her whether she earned more at Allure than at

25 KOD the first year, and she said comparing both

Page 148

1

 first years, the answer was yes. That's my

2

 understanding, is that right?

3

 THE WITNESS: Yes, sir.

4 BY MR. TOBIN:

5

 Q. How much did you earn at Allure in your first

6 year, your only year?

7

 A. I can't put in a number. I have no idea.

8

 Q. So how do you know you earned more at Allure?

9

 A. Because Allure house fees and the calculations

10 of how everything worked was nowhere near how KOD was.

11 I mean, my house fees, my tip-out, tipping security,

12 tipping the DJ, it didn't deflect how much money I was

13 taking home. Like it didn't put a dent in my pocket.

14 Walking out of KOD was a difference. I'm paying out

15 more than I was paid to work.

16 Q. Do you know whether or not Teri Galardi had

17 anything to do with the preparation of the rules that

18 everybody lived under at KOD?

19 A. No, I do not.

20 Q. Do you recall when Akinyele Adams started at

21 KOD?

22 A. I don't remember the specific time.

23 THE ARBITRATOR: You asked her that question

24 already, Mr. Tobin.

25 MR. TOBIN: I did. I know I did.

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1

 THE ARBITRATOR: 2012, 2013, somewhere in

2

 there. That's what you said.

3

 THE WITNESS: It was around 2011, 2012.

4

 THE ARBITRATOR: So we're not going to have

5

 her repeat answers she's already given.

6 BY MR. TOBIN:

7

 Q. By the way, at Allure, did you file a tax

8

return and declare that income?

9

 MR. AKEMON: Objection, Your Honor, relevance.

10 THE ARBITRATOR: I'll allow the question.

11 A. Like I said, I filed taxes just to make sure I

12 don't owe the IRS any money. The club at that time,

13 Allure had just opened, so they wasn't giving out W-2s.

14 I don't know what they are doing as of now, but it was a

15 new club the first year I started working.

16 Q. You only worked there one year, I thought.

17 A. Right. Meaning by the time I had to file my

18 taxes, I was pregnant, so I wasn't working.

19 Q. Did you declare on a tax return the income you

20 earned in the one year you worked at Allure, yes or no?

21 A. I never filed taxes -- I never filed taxes as

22 being a stripper, no, I have not. I said that.

23 THE ARBITRATOR: She's answered your question.

24 MR. TOBIN: I have no other questions.

25 MR. BRODSKY: Actually, can we just consult

Page 150

1

 for a second?

2

 THE ARBITRATOR: You may.

3

 MR. BRODSKY: Or I can just get up and ask the

4

 three questions.

5

 THE ARBITRATOR: That's okay. You can

6

 consult. We'll have one questioner. You can

7

 consult with Mr. Tobin.

8

 (Off the record.)

9

 THE ARBITRATOR: You may proceed.

10 BY MR. TOBIN:

11 Q. Specifically, can you tell me when you were

12 fined and by whom?

13 A. I can't say specifically. I can tell you why

14 I was fined.

15 THE ARBITRATOR: And you answered that

16 already. We heard that on direct.

17 Q. But you can't tell me specifically when that

18 was?

19 A. No, I can't.

20 Q. Can you tell me by whom you were fined?

21 A. Akinyele.

22 Q. Only by Akinyele?

23 A. Akinyele or Rick. It had to be those two.

24 But mostly, Akinyele, because I was in trouble.

25 Q. We asked you about the year 2010 and what you

Page 151

1 earned.

2

 A. Uh-huh.

3

 Q. And your testimony was in the range of

4 $60,000, correct?

5

 A. It could have been.

6

 Q. I'm sorry?

7

 A. It could have been, yes.

8

 Q. In the year 2011, how much did you earn?

9

 MR. AKEMON: Objection, asked and answered.

10 THE ARBITRATOR: I don't know that he asked

11 about 2011. Go ahead. You can answer the

12 question.

13 A. I mean --

14 Q. If you know.

15 A. I mean, a specific amount I have on my paper

16 and that I could just guess off the top of my head, I

17 can't just give you a number and guess. But what I've

18 calculated from my -- from my notes is on my paper.

19 MR. BRODSKY: Judge, I think there's some

20 confusion here, if I may?

21 THE ARBITRATOR: No, you may not. We can hear

22 from Mr. Tobin.

23 MR. TOBIN: Thank you.

24 BY MR. TOBIN:

25 Q. You calculated from your notes?

Page 152

1

 A. Yes, from when I went over with my attorney

2 minimum wage at that time, the hours that I worked, the

3 days that I worked, and I just multiplied it.

4

 Q. Where are your notes now?

5

 A. It's your subject 23. Is it 23? Is it 23B?

6 Do you have that?

7

 Q. The calculations that I see are what you

8 should have been paid in minimum wages. That's not what

9

I'm asking you.

10 A. So what are you asking me, sir?

11 Q. What I'm asking you is what did you earn in

12 the year 2011?

13 A. I can't give you a specific number, because I

14 don't want to guess and just give you an answer.

15 Q. In the year 2010, you calculated approximately

16 $60,000?

17 A. It could have been, yes, sir. I still

18 don't --

19 Q. Could it have been the same in 2011?

20 A. It could have been that amount, it could have

21 been less. I can't give you --

22 Q. Could it have been more?

23 A. It could have been more, but I can't give you

24 an exact number. I don't want to guess.

25 Q. It would not have been outrageous if it was

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1 more, would it?

2

 A. I mean, it couldn't have been outrageous. It

3 depends on what type of night it was at the club.

4

 Q. You did pretty well at the King of Diamonds,

5 didn't you?

6

 A. I did well, yes.

7

 Q. That $20,000 that was earned that night, how

8 much of it was yours?

9

 A. I mean, it depends on how many girls was

10 dancing with me that night.

11 Q. I'm sorry?

12 A. It depends on how many girls was in that

13 section.

14 Q. You don't remember how much of that $20,000

15 you took home that night?

16 A. No.

17 Q. But you remember it was $20,000?

18 A. I mean, I remember how much the customers

19 made. I remember a lot about how much money the

20 customers made, but as far as the breakdown of what I

21 got specifically, I couldn't give you that, because it

22 wasn't just me dancing.

23 Q. How much did you earn in the year 2012?

24 A. I don't want to give you a specific number and

25 just be wrong.

Page 154

1

 Q. But it could have been $60,000 or more?

2

 A. Yes, sir.

3

 Q. It could have been $70,000 also, right?

4

 A. It could have, but I don't want to just say

5 yes, that's right.

6

 Q. There were years that you earned $70,000, and

7 years that you earned $80,000, right?

8

 A. I don't want to guess that and give you that

9 specific number, so I don't want to say, yes, that's

10 right, or, no, that's wrong.

11 Q. But it wouldn't have been an outrageous number,

12 would it?

13 A. I mean, no, it wouldn't have been outrageous,

14 but I don't think I made that much.

15 Q. What about the year 2013?

16 A. Do you want me to guess? Again, I don't want

17 to guess for you. I want to be able to give you a

18 specific number, but I don't want to say, yes, I made

19 that amount that year or I didn't.

20 MR. BRODSKY: May I approach my colleague for

21 a second?

22 THE ARBITRATOR: I think we need to bring this

23 to an end, gentlemen. I've already allowed you

24 three sessions.

25 MR. BRODSKY: It will take ten seconds.

Page 155

1

 THE ARBITRATOR: Ten seconds?

2

 MR. BRODSKY: Yes.

3

 THE ARBITRATOR: I'm counting.

4

 MR. BRODSKY: I don't know that I can get

5

 there in ten seconds.

6

 MR. TOBIN: I'm also counting.

7

 MR. BRODSKY: That was less than ten seconds.

8

 THE ARBITRATOR: Not by my watch, Mr. Brodsky,

9

 but that's okay.

10 MR. BRODSKY: That I was up there?

11 BY MR. TOBIN:

12 Q. Did you earn more than $50,000 in the year

13 2013?

14 A. Yes, I could have.

15 Q. I'm sorry?

16 A. I could have.

17 Q. Say it again.

18 A. I could have.

19 Q. What about the year 2014?

20 A. Yes and no. I don't want to guess and just

21 make you feel like I knew exactly the number amount.

22 Q. But you could have earned more than $50,000 in

23 the year 2014, right?

24 A. Well, the year 2014 was a short year because

25 I stopped working there, so it's not a full year.

Page 156

1

 Q. Last question. You testified that the

2 night of the Floyd Mayweather night, you paid $450 in

3 house fees, and you specifically recalled --

4

 THE ARBITRATOR: I didn't hear that, Mr.

5

 Tobin.

6

 THE WITNESS: I said it.

7

 MR. TOBIN: Yes, she did testify to that.

8

 MR. BRODSKY: And she just acknowledged that

9

 she did.

10 THE WITNESS: I did.

11 MR. AKEMON: Stop talking.

12 THE ARBITRATOR: I heard I do not recall the

13 amount is in my notes -- what my notes reflect. I

14 do not recall that --

15 MR. TOBIN: She just testified that she did.

16 THE ARBITRATOR: Well, that's a different

17 story. If she wants to respond now, she can,

18 but --

19 MR. BRODSKY: Your Honor, that was on direct

20 that she testified to that.

21 THE ARBITRATOR: Oh, okay.

22 BY MR. TOBIN:

23 Q. How much did you earn that night?

24 A. I don't remember the specific number --

25 Q. I'm sorry?

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1

 A. I don't remember the number amount that night

2 because it was a lot of confrontation that night. The

3 only reason why I remember the night is because I had to

4

fight for my money. So, honestly, I can't remember the

5 exact amount of money I made.

6

 Q. Who did you fight?

7

 A. The club itself. They took my money.

8

 Q. Who?

9

 A. They stole my money that night.

10 Q. Who stole your money?

11 A. I have no idea. All I know is I gave my money

12 to the money room like I'm supposed to, like I do every

13 night, and my money got missing.

14 Q. You don't know how much you left the club with

15 that night?

16 A. I mean, it was in a trash bag, so no.

17 Q. You didn't get checks, you got cash, right?

18 A. What do you mean?

19 Q. You weren't paid by check, you were paid in

20 cash? At the end of the night, you took home cash,

21 correct?

22 A. No, no, no. This money that I'm talking

23 about got missing from a customer that was given to me

24 before the end of the night. That's the only reason why

25 I remember that night so verbatim because I had money

Page 158

1

stolen from me.

2

 Q. Was it a good night?

3

 A. It would have been a good night if my money

4 wouldn't have gotten stolen.

5

 Q. It would have been a better night, but how

6 much did --

7

 A. No, it would have been a good night if my

8 money wouldn't have got stolen.

9

 THE ARBITRATOR: Let's not argue. Let's not

10 argue.

11 BY MR. TOBIN:

12 Q. When you walked out the front door, how much

13 did you walk out with?

14 A. I don't remember. It could have been more

15 because I got stolen from.

16 Q. What year was that fight?

17 A. The Mayweather?

18 Q. Yes.

19 A. I don't think it was a fight. I think it was

20 Memorial weekend. I don't think it was a fight.

21 Q. What Memorial weekend? What year?

22 A. If I'm not mistaken, Floyd came a lot Memorial

23 weekend, so I can't say specific times, because

24 Memorial weekend when I was there, Floyd -- it was

25 normal for him to come Memorial weekend.

Page 159

1

 MR. TOBIN: I have nothing else.

2

 THE ARBITRATOR: You turned one question, Mr.

3

 Tobin, into about seven, I want you to know.

4

 THE WITNESS: Yeah.

5

 MR. TOBIN: But they were short.

6

 THE ARBITRATOR: You may redirect, but before

7

 you redirect, I did want to ask you, Ms. Griffen,

8

 do you know what a 1099 form is, a form, a 1099?

9

 THE WITNESS: I've heard of that form from the

10 military, but not from the club.

11 THE ARBITRATOR: Did you get any form 1099s

12 from the King of Diamonds?

13 THE WITNESS: Not that I know of, no, sir.

14 THE ARBITRATOR: Okay. Mr. Akemon, you may

15 redirect.

16 MR. AKEMON: Thank you.

17 REDIRECT EXAMINATION

18 BY MR. AKEMON:

19 Q. Ms. Griffen, you stated that on occasion, you

20 have large amounts of money in bags?

21 A. Right.

22 Q. And those bags would go up to the money room?

23 A. Right.

24 Q. And you also testified about an occasion where

25 there was a number of young ladies that danced in the

Page 160

1 pow with approximately, please correct me if I'm wrong,

2 $20,000 or $30,000?

3

 A. Right.

4

 Q. When those young ladies danced in a pow with

5 you, it wasn't just you in that pow, was it?

6

 A. No, it was me plus the other girls that was in

7

there. So at the end of the night, we would split it.

8 But before we could split it, they would take their ten

9 percent out of that money.

10 Q. And on that night, you didn't get an exact

11 accounting of what exactly went inside that money room,

12 did you?

13 A. No, because they just gave us envelopes and

14 say, hey, this is your money from this Mayweather pow.

15 Q. And can you please describe how the money

16 was -- strike that.

17 Please describe where the money appeared

18 during that money pow. Can you describe for everyone

19 how it appeared? Was it thrown in the air, was it

20 handed to you?

21 A. So that night specifically, I was picked

22 first. I remember it because it was -- it was a lot of

23 chaos. Because the rules are in King of Diamonds the

24 first dollar that hits the ground, whatever dancer is

25 there, that's her money. But that's not always how it

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1 worked.

2

 So at that time, Mayweather was throwing money

3 on me, and the first $5,000 that hit the floor, it

4 should have been mine, but it wasn't. They made me

5 split it with the other girls. So I want to say he

6 spent like $30,000 or $40,000 that night, but there was

7

five or six of us.

8

 So they had to take their ten percent out, and

9

then we got our cut. But we didn't specifically sit

10 there and count that money at that time, they did.

11 Q. And you didn't pick that money up, did you?

12 A. No, security picked it up.

13 Q. And when they picked it up, they collected it

14 for you?

15 A. Yes.

16 Q. And then they transported it to the money

17 room?

18 A. Yes.

19 Q. And before they collected it, you didn't get a

20 chance to sort it out?

21 A. No.

22 Q. So you can't verify if it was actually

23 $30,000?

24 A. No, not at all.

25 Q. And, again, your testimony is that they took

Page 162

1

ten percent out before --

2

 A. Before we even got our cut.

3

 Q. Okay. So you didn't actually take $30,000

4 home that night?

5

 A. No, I did not.

6

 Q. Or $40,000?

7

 A. No, I did not.

8

 Q. Were there other occasions where money went to

9

the money room and it became quote, unquote, lost or

10 stolen?

11 A. Yes, plenty of times.

12 Q. Okay. And on those occasions, would the club

13 reimburse you or anybody from the club reimburse you?

14 A. I can't recollect on how Akinyele ran it, but

15 I can speak on how it was ran before he took over the

16 club, only because I got money stolen from me before he

17 got there.

18 Q. Did you have money stolen after he got there?

19 A. Yes, but it wasn't taken care of like how it

20 would have been before.

21 Q. Okay. Can you describe the difference between

22 the two?

23 A. Yes. Mr. Teri, when Meek Mills came into King

24 of Diamonds, it was when his dream was -- his dream

25 and nightmare song came out when he first mentioned King

Page 163

1 of Diamonds in his club -- I mean in his song. I was

2

the first girl there. That money got completely

3 missing.

4

 So Mr. Teri decided to say who was the first

5 girl there dancing. All the girls vouched for me and

6

said I was the first girl there, so I got the first

7 $5,000.

8

 And, then after that, we had to split the rest

9 of the money. When that happened with Floyd and

10 Akinyele was there, the money just went missing, and we

11 just didn't get nothing at all.

12 Q. So you had worked and performed, but you

13 didn't receive --

14 A. Right. We danced, they picked up the money

15 and put it in the trash bag, but there was still more

16 hours in the night, so there was still more customers to

17 dance for.

18 So whatever happened in between them taking

19 our money to the money room and us still working

20 throughout the night, it went missing. So nothing got

21 confirmed.

22 Q. And not just on that night, just on the

23 typical KOD night, the money that you earned, did that

24 come directly from customers?

25 A. Everything came directly from customers.

Page 164

1

 Q. So nothing came directly from KOD?

2

 A. No.

3

 Q. It didn't come from management?

4

 A. No.

5

 Q. It didn't come from security?

6

 A. No.

7

 Q. It didn't come from the house mom?

8

 A. No.

9

 Q. So everything you got, did you perceive it as

10 a tip or did you perceive it as a wage?

11 A. I perceived it as I worked for it.

12 Q. Okay. Was it -- strike that.

13 Did those customers tip you?

14 A. Yes.

15 Q. Okay. In addition to that, when you speak

16 about the collection efforts in the money room, were

17 there any other times that you worked at King of

18 Diamonds and didn't earn anything?

19 A. Yes.

20 Q. So did you pay a house fee on those nights

21 that you didn't earn anything?

22 A. Yes.

23 Q. And did you tip out the house mom, DJ and

24 security on those nights?

25 A. Yes.

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1

 Q. And so did you go home in the negative on

2

those nights?

3

 A. Yes.

4

 Q. And would that occur -- how often would that

5 occur?

6

 A. Tuesdays, Wednesdays, Thursdays. Only reason

7 why I say those specific days is because those were the

8

slow days throughout the week, and Sundays.

9

 Q. And were you required to work slow days?

10 A. Yes, at least two throughout the week.

11 Q. And that was a club policy?

12 A. Yes.

13 Q. And on the slow days, you wouldn't earn

14 anything?

15 A. The club was so big, nobody was coming in

16 there unless it was something going on.

17 Q. And on those days that you worked -- so on

18 those days that you worked but didn't earn anything --

19 strike that, Your Honor. No more questions. I'm sorry.

20 THE ARBITRATOR: You're excused. Thank you

21 very much. I've already -- for the record, I've

22 admitted all the exhibits on the exhibit list of

23 both parties that were submitted to me. The

24 claimant's proposed exhibit list, which has been

25 modified so that instead of 23 being Teri Galardi

Page 166

1

 transcript -- deposition transcript, 23A is the one

2

 letter to Ms. Galardi via Mr. Fuchs.

3

 The other is -- 23B is the other letter to Ms.

4

 Galardi via Fuchs, one for Ms. Holmes, one for Ms.

5

 Griffen. Is this Number 23, Teri Galardi

6

 deposition transcript -- that's now the four slips,

7

 right?

8

 MR. AKEMON: I'm sorry?

9

 THE ARBITRATOR: Number 23, Teri Galardi

10 deposition transcript is now this document here,

11 the four slips?

12 MR. AKEMON: Yes, Your Honor.

13 THE ARBITRATOR: Is there a Teri Galardi

14 transcript in this notebook?

15 MR. AKEMON: It is in that notebook, Your

16 Honor.

17 THE ARBITRATOR: It is?

18 MR. AKEMON: Yes, Your Honor.

19 THE ARBITRATOR: What number?

20 MR. AKEMON: Give me a second. It's -- just

21 for clarification's sake, Your Honor, the large

22 notebook, the large red notebook is the trial

23 transcript, so that will be Exhibit 4.

24 THE ARBITRATOR: Very good. But where is what

25 was originally labeled as 23? Where is that?

Page 167

1

 MR. AKEMON: I'm pulling it now, Your Honor.

2

 I'm sorry.

3

 THE ARBITRATOR: And if we do have that in

4

 here, we have to give it a number.

5

 MR. AKEMON: Well, what was originally marked

6

 as 23 was the presuit notices. That was the

7

 original.

8

 THE ARBITRATOR: I'm sorry, I'm just looking

9

 at what I have here. 23, Teri Galardi transcript.

10 MR. AKEMON: Your Honor, are you looking at --

11 THE ARBITRATOR: I apologize. Where is the

12 right one? I keep picking this thing up and

13 putting it down. Sorry. I apologize. So 23, 24

14 we got, and 25, I have diary in 25, but it's marked

15 26 here.

16 MR. AKEMON: 25 is Teri Galardi personal

17 diary.

18 THE ARBITRATOR: Right. But this says 26.

19 MR. BRODSKY: Wait. I must be looking at a

20 different list, and I'm totally confused.

21 THE ARBITRATOR: Let's try to straighten this

22 out. So now I'm looking at the right one. What

23 does your C26 say, Mr. Akemon? C26, what does that

24 say?

25 MR. AKEMON: Order on motion for summary

Page 168

1

 judgment. I'm sorry. Yes, order on cross-motion

2

 for summary judgment.

3

 THE ARBITRATOR: Mine says C27 for order on

4

 cross-motions.

5

 MR. AKEMON: You're right. I'm sorry. 27

6

 is -- because we switched it.

7

 THE ARBITRATOR: What does your 26 say?

8

 MR. AKEMON: My 26 is -- 27 is order on

9

 cross-motion for summary judgment. 26 is Teri

10 Galardi personal diary.

11 THE ARBITRATOR: Okay. Come look here, Mr.

12 Akemon, because 25 is where the diary exhibit

13 appears. This says 25, and that's the diary. Is

14 that right?

15 MR. AKEMON: Yes, Your Honor.

16 THE ARBITRATOR: So 25 here says claimant's

17 responses to --

18 MR. AKEMON: That's the slip, so --

19 THE ARBITRATOR: The slips are 24.

20 MR. AKEMON: So we should scratch that one

21 out.

22 THE ARBITRATOR: Okay. That's what I want to

23 understand. So we have no Exhibit 25?

24 MR. BRODSKY: So I should cross out Exhibit 25

25 on the exhibit list --

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1

 MR. AKEMON: Yes.

2

 MR. BRODSKY: -- that's dated March 15th of

3

 2021?

4

 THE ARBITRATOR: That's correct.

5

 MR. BRODSKY: Just cross it off?

6

 THE ARBITRATOR: That's correct. 23A and B

7

 are the two presuit notices. 24 is the ten percent

8

 slips. There is no longer a 25. So now with that,

9

 is this complete, Mr. Akemon?

10 MR. AKEMON: Yes, Your Honor. Can you confirm

11 26 and 27, order on cross-motion for summary

12 judgment?

13 MR. BRODSKY: Yes.

14 MR. AKEMON: 27 was the Rule 23 order.

15 THE ARBITRATOR: Okay. So I'm accepting all

16 of the exhibits. Is there anything else you wish

17 to add to your case, Mr. Akemon?

18 MR. AKEMON: No, Your Honor.

19 THE ARBITRATOR: Okay. So you're resting.

20 Mr. Tobin or Mr. Brodsky, you may proceed with your

21 case.

22 MR. BRODSKY: Judge, before we do that, other

23 than the changes that we just made on the exhibit

24 list, are there any other changes on your list?

25 THE ARBITRATOR: No, not on my list.

Page 170

1

 MR. BRODSKY: We're ready to proceed. Can we

2

 have a moment just to talk to our client real

3

 quick?

4

 THE ARBITRATOR: Why do you need to do that?

5

 MR. BRODSKY: I just want to ask her a

6

 question before I put her on the stand. That's

7

 all.

8

 THE ARBITRATOR: Okay. You can do that.

9

 Hurry up. You've had three breaks, you had lunch.

10 But go ahead.

11 (Off the record.)

12 DIRECT EXAMINATION

13 BY MR. BRODSKY:

14 Q. Good afternoon, ma'am. Please state your

15 name.

16 A. Teri Galardi.

17 Q. Where do you live?

18 THE COURT REPORTER: Do you want me to swear

19 her in?

20 MR. BRODSKY: What's that?

21 THE COURT REPORTER: I have to swear her in.

22 THE ARBITRATOR: Swear her in first.

23 THE COURT REPORTER: Please raise your right

24 hand. Please state your first and last name.

25 THE WITNESS: Teri Galardi.

Page 171

1

 (Thereupon, the witness was duly sworn in

2

 accordance with the law.)

3 BY MR. BRODSKY:

4

 Q. Please state your name.

5

 A. Teri Galardi.

6

 Q. Where do you reside, Ms. Galardi?

7

 A. In Flovilla, Georgia.

8

 Q. And tell us something about your educational

9 background, please.

10 A. I completed an associate's degree in

11 merchandising, marketing.

12 Q. And when was that?

13 A. I graduated in 1982.

14 Q. What was your father's name?

15 A. Jack Galardi.

16 Q. And did he pass away at some point?

17 A. He passed away December 1st, 2012.

18 Q. Prior to December 1st, 2012, where did you

19 live?

20 A. In -- well, I lived in Florida from 2009, and

21 before that, Las Vegas, and before that, California.

22 Q. Let's talk about when you resided in Las

23 Vegas. What was that time frame?

24 A. From 1987 to 2009.

25 Q. So you left Las Vegas in 2009?

Page 172

1

 A. Yes.

2

 Q. Where did you go from Las Vegas in 2009 to

3

reside?

4

 A. Southwest Ranches, Florida.

5

 Q. And who did you go there with to reside?

6

 A. My husband and our two daughters.

7

 Q. Is there a reason why you moved to Southwest

8 Ranches, Florida in 2009 from Las Vegas?

9

 A. Yes. My father had pharyngeal cancer in 2005

10 and was treated at Cleveland Clinic. And I came here --

11 Q. Cleveland Clinic where? I'm sorry to

12 interrupt you.

13 A. I'm sorry. In Florida, Weston.

14 Q. Okay.

15 A. And I came for three months in I think it was

16 June, July, August and September while he was doing his

17 radiation and helped him and was there for support.

18 Q. And what year was that?

19 A. It was 2005.

20 Q. Okay. So regarding your father's health from

21 2005, let's say, to 2009, explain to His Honor what

22 happened with his health.

23 A. When you have a radiated head, your nerves

24 have a life span, and so some of the nerves started to

25 deteriorate. It affected his hearing, it affected

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1 his -- he could see.

2

 It didn't affect his eyesight, per se, but he

3 got strabismus in some of the nerves -- so one eye

4

started to cross, so he would wear an eye patch so he

5 didn't see double. His epiglottis stopped working

6 properly, so he would aspirate food into his lungs

7

sometimes.

8

 And at one point, they thought he might have

9

lung cancer, that it might have metastasized, but it

10 didn't. It ended up being -- they went in to do a

11 biopsy and ended up removing his upper left lobe. So

12 there were complications there.

13 Q. So then coming back to 2009, you moved here

14 for what reason?

15 A. Well, there were a few reasons, but the main

16 reason was to be closer in the east to my father,

17 because I was all the way in Vegas, and his doctors were

18 here.

19 So with his, you know, different things

20 happening to him -- but I also wanted to wait for my

21 son, Nicholas, to graduate from high school before we

22 left, and he went off to college, and my grandson was

23 here.

24 Q. Going back to Las Vegas, did you have any

25 business interests in Las Vegas?

Page 174

1

 A. I did. I sold a small bar in 2008.

2

 Q. And was that the extent of your business

3

interest in Las Vegas?

4

 A. I also had a small bar called Beers and

5 Cheers, but I had closed that a few year before then.

6

 Q. Then when you moved here in 2009, did you have

7 any business interests in South Florida?

8

 A. Yes. When I sold my bar there in 2008, it was

9 with the intention of buying another business here and

10 my husband and I buying a home. So we bought a book

11 store in Key West and we bought the Cubby Hole, which is

12 a very small men's gay bar in Fort Lauderdale.

13 Q. So when you moved here in 2009, the business

14 interests that you had were the Cubby Hole in Fort

15 Lauderdale, I believe, is that right?

16 A. Yes.

17 Q. And the book store in Key West?

18 A. Yes.

19 Q. Okay. Now, in 2009 when you moved here, what

20 was your dad's health at that point?

21 A. He was going along pretty good. I mean, he

22 still went back and forth from here to Vegas at times

23 and to Atlanta. He spent most of his time in Atlanta.

24 But he still came back and forth. He came down to

25 doctors.

Page 175

1

 Q. Did there come a time -- a point in time

2 between 2009 or 2012 where his health continued to

3 deteriorate?

4

 A. It started in 2012, May, specifically in May

5 2012. I went up to my cousin's graduation in Chicago,

6 and I got a call that my father took a turn for the

7 worst, so I came down, and he was -- at that point, he

8 was at St. Joseph Hospital, Atlanta, and he came around

9 and came out of that and, you know, went back to

10 business.

11 But it kind of -- I think having his lung

12 removed in 2010 kind of took the wind out of his sails,

13 but he still conducted business.

14 Q. Prior to December 1st, 2012, were you

15 ever involved in any way in any of your father's

16 businesses?

17 A. Never.

18 Q. Were you in any way, shape or form involved

19 in the King of Diamonds prior to December 1st of 2012?

20 A. No.

21 Q. Did there come a time when your father prior

22 to his death stopped conducting business?

23 A. No.

24 Q. So are you saying that he conducted business

25 up until the time he passed away?

Page 176

1

 A. Pretty much. He actually came out to the

2 Thanksgiving table, which I was really surprised, a few

3 weeks before he died. I was kind of shocked about it.

4

 And he closed on the Gold Rush in downtown

5 Miami while he was in his last few months of his life.

6 So he conducted business I would say up until the day he

7 died.

8

 Q. Did you, while your dad's health was

9 deteriorating, assist him in communicating?

10 A. Well, because he had a hard time hearing on

11 the phone and his voice was very, very raspy from the

12 radiated throat. And if you were face to face with him,

13 you could understand him, and then you would -- could

14 yell at him so that he could hear you.

15 But on the phone, it was compromised. So

16 sometimes when I was with him, he would, you know, hand

17 me the phone and say tell me what he's saying or, you

18 know -- so I would word for word tell him what they

19 said, and he would tell me what he wanted me to tell

20 them, and I would repeat that word for word to whoever

21 it was he was talking to.

22 Q. So what you were doing is you were helping him

23 communicate over the phone?

24 A. Yes.

25 Q. Were you involved in those discussions between

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1 your father and whomever else he was speaking to on the

2 other line other than relaying information by way of

3 what was said back and forth?

4

 A. That's it, just what was said word for word.

5

 Q. Did you have any conversations during this

6

time or prior to this time with your father with regard

7

to him and his businesses?

8

 A. No.

9

 Q. Can you describe for His Honor your father's

10 personality?

11 A. My father had a pretty big personality. He

12 kind of took command of a room. Nobody told my dad what

13 to do, whether he was sick or not. He was always in

14 charge. He was well-loved, and he's well-missed. But

15 he was his own man. He was a self-made man --

16 Q. So I gather --

17 A. -- entirely.

18 Q. I'm sorry. Go ahead.

19 A. That's okay.

20 Q. I gather from what you're saying that you

21 weren't giving your father any advice on the running of

22 any of his businesses?

23 A. No.

24 Q. Prior to December 1st of 2012, did you have

25 anything to do specifically with the King of Diamonds?

Page 178

1

 A. No.

2

 Q. When you moved to South Florida in 2009 to

3 Southwest Ranches, you testified that you had two

4 businesses here, which was the Cubby Hole and the book

5 store in Key West, is that right?

6

 A. Correct.

7

 Q. Did there come a point in time prior to your

8

father's passing that you utilized an office space in

9

the building that housed the King of Diamonds?

10 A. Yes. When --

11 Q. Please explain to the arbitrator, His Honor,

12 what that was about.

13 A. I actually bought the businesses before we

14 moved here in preparation. The Cubby Hole was a small

15 bar, about 1,500 square feet. There was really no

16 office space for me and my cousin, my cousin, Kelly

17 Galardi, being my right-hand person, my secretary.

18 You know, she would do bookkeeping and things

19 like that. There was no office for us. We really

20 couldn't afford to rent office space. The King of

21 Diamonds was a huge building, and the King of Diamonds

22 only inhabited maybe half of that building.

23 The rest of it was this huge warehouse. I

24 really don't remember what business was conducted there

25 before he bought this monster building, but there was

Page 179

1 some ancillary warehouse offices that I asked him if we

2 could utilize for Kelly and I. And, you know, he said

3 yes, and he was very generous and even put in some air

4 conditioning for us completely separate.

5

 If we wanted to go see him in his office, we

6 had to go out of ours down the stairs and around the

7

front, and it wasn't a part of his office at all.

8

 Q. Prior to December 1st of 2012, did you ever go

9

into the King of Diamonds club?

10 A. No.

11 Q. Then your father passed, again, on December 1st

12 of 2012. When he passed, did you have a grieving and

13 mourning process for yourself?

14 A. Of course.

15 Q. About how long did that take?

16 A. I don't think that kind of thing ends very

17 soon, but it was about a month before I tried -- started

18 to try to wrap my mind around his businesses and his

19 properties and the LLCs and corporations, so I visited

20 down here in January sometime of '13.

21 Q. And based upon your experience in business and

22 your educational background, in your mind, did you have

23 the ability to operate the King of Diamonds after your

24 father passed?

25 A. Absolutely not. I only ever had small bars.

Page 180

1

 Q. So as a result of everything that had

2

transpired, what did you endeavor to do in the beginning

3 of 2013 with regard to the King of Diamonds?

4

 A. Get it ready for sale. I wanted to sell it.

5

I couldn't even see myself tackling that monster.

6

 Q. If you can, could you tell His Honor

7 approximately how big the building was?

8

 A. I'm not really good at square feet, but it's

9 at least 50,000 square feet. I'm not -- it was a huge

10 warehouse when he bought it.

11 Q. In your endeavor to sell the King of Diamonds

12 in the beginning of 2013, were there any steps that you

13 undertook to do so?

14 A. Yes. My husband and I when we came down here

15 in January, we did a walk-through at the King of

16 Diamonds during the day to -- with all the lights up so

17 that we could see carpet and the booths if they needed

18 reupholstering, if it needed painting, anything we could

19 do to make it presentable for a sale.

20 Q. And as a result of going into the King of

21 Diamonds and doing the inspection that you did, what did

22 you think needed to be done in order for you to be able

23 to sell the King of Diamonds?

24 A. The carpet was horrible, the upholstery had

25 high heel holes from when the girls would put their foot

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1 up on the couches. There was holes in all of that. So

2 we had to redo all of the booths, all the carpeting had

3

to be replaced. It was really gross. I don't even

4

think you could tell what colors were there. And I

5 don't know what else. I think there was some stuff that

6

they did to the stages, but --

7

 Q. Now, as a result of doing these repairs or

8 whatever it is that you would like to characterize them

9 as, approximately how much money did you spend?

10 A. It was about $300,000.

11 Q. And, again, not to belabor the point, the

12 purpose of investing that money into that club, King of

13 Diamonds, was to get it ready for sale, correct?

14 A. Absolutely. That's all I wanted to do was

15 get it ready for sale.

16 Q. Did it -- did you ultimately sell the King of

17 Diamonds?

18 A. I did.

19 Q. And when was that?

20 A. July of 2014.

21 Q. So in the beginning of 2013, knowing that you

22 wanted to sell the club, what did you do -- did you do

23 anything as it relates to -- strike that.

24 Have you heard the name Akinyele Adams?

25 A. Yes. I met Akinyele in maybe March or April

Page 182

1 of 2013. He wanted to buy -- he came -- he was a friend

2 of my -- or my son knew of him. He was a friend of my

3

son's, and he had been an artist with records, CDs, and

4 he was a promoter, and I heard he was a very good report

5 promoter, and he wanted to buy the King of Diamonds.

6

 But he didn't have all the money to buy King

7 of Diamonds, and I didn't want -- I wanted to be bought

8 out of King of Diamonds. I didn't want anything to do

9 with it. So he wanted a chance to, you know, find

10 investors.

11 So I entered into a management agreement with

12 Akinyele that he could have operations of the club, find

13 an investor, and I told -- I had Jennifer make a list of

14 all the expenses such as mortgage, electricity, taxes,

15 insurance, anything that went along with operating that

16 building and the club, because everything was in Fly

17 Low, and that would be the amount he would pay me broke

18 down into weekly payment.

19 And then we didn't -- I didn't do a written

20 lease or anything like that. I just -- because he wanted

21 to find a buyer, which he did.

22 Q. Okay. So when and -- can you tell me

23 approximately when in 2013 you entered into this

24 management agreement with Akinyele Adams?

25 A. It was probably April of 2013.

Page 183

1

 Q. And, so would it be a fair statement that he

2 operated the club from approximately April of 2013 until

3

the time it was sold in July of 2014?

4

 A. Yes.

5

 Q. Now, let's back up to approximately April of

6 2013. Once Akinyele started managing the club based on

7

the agreement that you and he had, did -- strike that.

8

 The amount of money in the agreement between

9 you and Akinyele was enough to cover the expenses, is

10 that what I heard you say?

11 A. Yes.

12 Q. Was there anything contemplated where you

13 would put any of that money into your pocket?

14 A. No.

15 Q. Can you tell His Honor if you have ever

16 received one penny from the King of Diamonds?

17 A. Not from any of the business at all, only the

18 sale of the building.

19 Q. Okay. But I'm talking about from the

20 operations.

21 A. No. Not --

22 Q. Ever?

23 A. Never. Never.

24 Q. But you did receive proceeds when ultimately

25 the business and the building were sold?

Page 184

1

 A. Correct.

2

 Q. During the time from the beginning or -- let's

3 call it the beginning of 2013 through the time it was

4 sold in July of 2014, did you have any involvement in

5

the day-to-day operation of the King of Diamonds?

6

 A. No, I never had any involvement in the

7 operations of King of Diamonds.

8

 Q. You have -- you saw -- I can't remember which

9 of the claimants here today said she saw you in the

10 club by the bar. Do you remember hearing that

11 testimony?

12 A. Yes.

13 Q. Is that true?

14 A. No. I think she was mistaken.

15 Q. Because you were never in there by the bar

16 with Akinyele, correct?

17 A. No. If I saw Akinyele, he came into the main

18 offices, and I don't even know if or where he had an

19 office inside the club.

20 Q. After your dad passed and you came here to do

21 the renovations in 2013, were you living here still or

22 did you go back to Georgia?

23 A. No, I lived in Georgia full-time.

24 Q. Starting when after your dad's passing?

25 A. Well, I actually was living there from May

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1 2012 because I wanted to be near to him because he was

2 having, you know, problems with just the deterioration

3 of nerves. And so I just felt like I needed to be with

4 my father.

5

 Q. Okay. So then at that point in May of 2012,

6 you and your father both were in Georgia?

7

 A. Yes. And then my husband came up also to help

8 with my father.

9

 Q. And he passed in Georgia?

10 A. Yes. He passed in Georgia at home.

11 Q. Prior to December 1st of 2012, did you receive

12 any proceeds from any of your father's other businesses

13 other than the King of Diamonds?

14 A. No, absolutely not.

15 Q. And I think we've already established that

16 you've had absolutely nothing to do with owning or

17 running any of those businesses prior to December 1st of

18 2012, is that correct?

19 A. No, absolutely not. I never got into my dad's

20 business.

21 Q. You saw the various exhibits that were

22 introduced today. May I approach to --

23 THE ARBITRATOR: You may. Which ones would

24 you like to show her?

25 MR. BRODSKY: That one there.

Page 186

1

 THE ARBITRATOR: I'll give you all the ones I

2

 have, and you can pick and choose.

3

 MR. BRODSKY: Thank you.

4

 THE ARBITRATOR: Sure.

5 BY MR. BRODSKY:

6

 Q. I'm going to show you what has been marked as

7 Claimant's Exhibit 24 and ask you to look at it, please.

8

 A. Okay.

9

 Q. Are you familiar with those slips or forms?

10 A. No.

11 Q. Did you have anything to do with preparing

12 them or inventing them?

13 A. No.

14 Q. I'm going to show you what has been marked as

15 Claimant's Exhibit 12 and ask you to look at it.

16 THE ARBITRATOR: These are the rules and

17 regulations?

18 MR. BRODSKY: Yes.

19 A. Okay.

20 Q. Did you have anything to do with the

21 preparation or implementation of those rules?

22 A. No, none.

23 Q. At any time?

24 A. At any time.

25 Q. Same thing with -- I can't see the number.

Page 187

1

 THE ARBITRATOR: It's Number 24.

2 BY MR. BRODSKY:

3

 Q. Same thing with the slips in Number 24,

4 correct?

5

 A. Right. Correct.

6

 MR. BRODSKY: May I just leave these here for

7

 a moment?

8

 THE ARBITRATOR: You may.

9 BY MR. BRODSKY:

10 Q. You're going to hear today I believe that you

11 were listed with the Florida Department or Division of

12 Corporations as the president, secretary and treasurer

13 of I believe Fly Low, Inc. doing business as King of

14 Diamonds. You've heard that before, right?

15 A. Yes.

16 Q. You've seen those documents, correct?

17 A. Yes.

18 Q. And they start at maybe 2008 and go through

19 2000 -- well, for the relevant period anyway in 2014,

20 correct?

21 A. Right.

22 Q. Prior to your father's passing on December 1st

23 of 2012, did you have any idea that you were named as

24 president, secretary and treasurer on those documents?

25 A. Not earlier. I did find out around 2011 or

Page 188

1

'12, but I wasn't told by my father. I didn't know a

2

lot of things until after he passed. But I did know --

3

I didn't know in the beginning. It was surprising to

4 me.

5

 Q. For what years did you not know?

6

 A. I didn't know 2008, 2009, 2010.

7

 Q. Okay. And then in 2011 and '12, you may have

8

learned about that?

9

 A. Around then. Around then. Somebody else told

10 me that I was the president. I was like, what?

11 Q. But you never exercised any --

12 A. No, of course not.

13 Q. -- anything to do with the King -- we've already

14 established that.

15 A. Right.

16 THE ARBITRATOR: Yeah, you've gone over that

17 already. You don't need to ask her again.

18 BY MR. BRODSKY:

19 Q. All right. Did you ever have any meetings

20 with any of the entertainers?

21 A. No.

22 Q. Did you ever have any meetings with the staff

23 members?

24 A. No.

25 MR. BRODSKY: If I may have a moment, Your

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1

 Honor, I'm almost done.

2

 THE ARBITRATOR: You may.

3

 (Off the record.)

4

 MR. BRODSKY: Just a couple more questions,

5

 Your Honor.

6 BY MR. BRODSKY:

7

 Q. Ms. Galardi, I'm now going to show you what

8 has been marked as Claimant's Exhibit 6 titled

9 arbitration policy to the club, and I'm going to ask you

10 some questions about it, but I want you to look at it

11 first.

12 A. Okay.

13 Q. Are you familiar with that document?

14 A. Yes, I know about this document.

15 Q. What is it that you know about the document?

16 A. Well, it's an arbitration agreement that was

17 distributed company-wide to office workers, bartenders,

18 entertainers, everyone that worked.

19 Q. And how did that come to be?

20 A. Dennis Williams in discussions -- I guess in

21 discussions with lawyers came to me one day and

22 presented the idea of an arbitration policy for the

23 company. And in weighing the pros and cons of different

24 lawsuits or -- that could come up, we decided to go with

25 the arbitration policy.

Page 190

1

 Q. And was this after your father's passing?

2

 A. Yes. I don't remember exactly when we did it.

3

 Q. Do you remember the year?

4

 A. Maybe '14.

5

 Q. But you don't remember for sure?

6

 A. It could have been '15. There's a lot of

7

things that happened.

8

 THE ARBITRATOR: I'm sorry, did you say it

9

 could have been '15?

10 THE WITNESS: It could have been '15.

11 THE ARBITRATOR: When did you say you sold the

12 business?

13 THE WITNESS: '14. July of '14. We could

14 have done this in '14.

15 BY MR. BRODSKY:

16 Q. Right. I don't think it makes sense that you

17 did it in '15 after.

18 A. No. It was '14 now that I think about it.

19 Yeah.

20 Q. Okay.

21 A. Because they distributed it at King of

22 Diamonds. So if I had -- if it would have been '15, I

23 would already have sold it.

24 Q. Okay. Did you -- have you ever reviewed that

25 agreement carefully? Strike that.

Page 191

1

 During the process of coming up with that

2 agreement, did you ever read it carefully?

3

 A. No.

4

 Q. Who was handling that?

5

 A. Dennis Williams.

6

 Q. And who is Dennis Williams?

7

 A. Dennis Williams is a CFO for Galardi South

8 Enterprises, which took care of all the clubs that my

9

father owned.

10 Q. Was it a corporation or was it a way of a

11 name?

12 A. No, it's just the office name and the way they

13 answer the phone. It just made it easier than when the

14 girls would answer the phone at the office; instead of

15 saying Pink Pony, Gold Rush, Cheetahs, Masters, they

16 would answer Galardi South.

17 Q. So regarding that arbitration policy, it was

18 brought to your attention by Dennis Williams after he

19 may have consulted with lawyers, right?

20 A. Yes.

21 Q. And you agreed to implement that arbitration

22 policy?

23 A. Yes. I thought it was a good idea.

24 Q. And it was -- after your father's passing,

25 besides the King of Diamonds, how many other businesses

Page 192

1 did he leave to you?

2

 A. There's the Pink Pony here, Doral, Pink Pony

3 Atlanta, Cheetahs Las Vegas, Gold Rush Atlanta, Masters

4 South Carolina.

5

 Q. You're going a little too fast, so slow down a

6

little bit. Pink Pony Doral, Pink Pony Miami --

7

 A. Well, Pink Pony Doral is Miami.

8

 Q. Okay. Pink Pony --

9

 THE ARBITRATOR: Atlanta, she said.

10 THE WITNESS: And Atlanta.

11 THE ARBITRATOR: It was Doral that I didn't

12 hear. What's that?

13 THE WITNESS: Doral. Doral.

14 THE ARBITRATOR: Oh, Pink Pony Doral. That's 

15 Miami.

16 BY MR. BRODSKY: 

17 Q. All rights. Continue with the list, but do it slow.

18 A. Okay. Gold Rush Atlanta, and there was some

19 other properties in Atlanta, but --

20 Q. Okay. Were there any other clubs?

21 A. There was -- Onyx was a club, but we didn't

22 own the property. And --

23 Q. Where was that located?

24 A. In Atlanta. And Masters in South Carolina,

25 Myrtle Beach. And Cheetahs in Las Vegas. As far as

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1 clubs, I think that's it.

2

 Q. And was the arbitration agreement that is

3 sitting in front of you -- it's too far for me to see.

4

It's Claimant's exhibit what?

5

 A. 6.

6

 Q. Was that arbitration agreement implemented in

7 all of these adult clubs that you've just identified?

8

 A. Yes.

9

 Q. And it was across the board with all the

10 people that -- waiters, waitresses, bar backs?

11 A. Office workers, everybody.

12 Q. Including dancers, correct?

13 A. Yes.

14 Q. Did there come a time where you heard about

15 two dancers being terminated because they were already

16 dancing at a particular club, and they didn't want to

17 sign the arbitration agreements, and they were

18 terminated? Do you remember anything of that sort?

19 A. I really don't remember.

20 Q. Were you involved in the hiring or firing of

21 any of the adult entertainers?

22 A. No.

23 Q. The staff, the waiters, the waitresses, the

24 bar backs, any of those folks? Cooks?

25 A. No, not in any of the cities, no.

Page 194

1

 Q. Or in any of the clubs?

2

 A. No.

3

 Q. Before or after --

4

 A. Before or after.

5

 Q. -- your father's passing?

6

 A. Correct.

7

 MR. BRODSKY: I have no further questions.

8

 THE ARBITRATOR: Thank you very much. Mr.

9

 Akemon?

10 MR. AKEMON: Yes, Your Honor.

11 CROSS-EXAMINATION

12 BY MR. AKEMON:

13 Q. Good morning, Ms. Galardi. How are you?

14 A. Good afternoon.

15 Q. I'm sorry. Good afternoon. I'm sorry. My

16 name is Attorney Mutepe Akemon. You may remember me

17 from -- as lead counsel in --

18 A. Yesterday.

19 Q. Not just yesterday, but lead counsel in the

20 Jeter v. Galardi case. Are you familiar with that case?

21 A. Yeah. It's fuzzy, but I remember you sitting

22 next to Harlan Miller.

23 Q. Yeah. And that Jeter case was a wage and hour

24 case, wasn't it?

25 A. Yeah, I think so.

Page 195

1

 THE ARBITRATOR: Just get to the -- let's get

2

 organized, and then you can --

3 BY MR. AKEMON:

4

 Q. And that case involved exotic dancers employed

5 at the King of Diamonds, correct?

6

 A. I think so, yeah.

7

 Q. You just testified about this arbitration

8 agreement. This was a company-wide policy?

9

 A. Yes.

10 Q. And you had the ability to determine that

11 policy, correct?

12 A. I'm not the one who came up with it, but I

13 helped in the decision-making of implementing it, yes.

14 Q. Okay. That wasn't my question. My question

15 was you had ultimate final decision in implementing that

16 policy company-wide, correct?

17 A. When you say it like that, I don't think I --

18 I don't think I ever had a final decision or anything.

19 I always consult with or collaborate with --

20 Q. Okay. I'll rephrase the question. Can anyone

21 else in the Galardi organization -- can anyone else

22 implement a company-wide policy like this without your

23 authority?

24 A. They would probably tell me about it, yeah.

25 Q. That wasn't my question. Again, my question

Page 196

1

is could anybody else in the Galardi South Enterprises

2 universe, I mean anyone in the office in Atlanta, did

3

they have the authority to implement a policy like this

4 company-wide?

5

 A. I don't think so.

6

 Q. And this policy came after your father passed

7 away, correct?

8

 A. Yes.

9

 Q. So you changed this policy at all of the clubs

10 under the Galardi South umbrella?

11 A. I didn't change policy, I just implemented an

12 arbitration agreement.

13 Q. So prior to this, there was no arbitration

14 agreement at any of the clubs?

15 A. Correct.

16 Q. And you also testified about numerous

17 businesses that you've owned and numerous businesses

18 that you inherited. And some of these other businesses

19 that you mentioned, Masters Club, that's an adult

20 entertainment club?

21 A. Yes.

22 Q. And Onyx is an adult entertainment club?

23 A. Yes.

24 Q. King of Diamonds was an adult entertainment

25 club?

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1

 A. Yes.

2

 Q. I'm trying to remember all of them. Onyx,

3 King of Diamonds, Masters --

4

 A. Cheetahs.

5

 Q. Cheetahs. And what was the other?

6

 A. Gold Rush.

7

 Q. Gold Rush. Pink Pony.

8

 A. Pink Pony.

9

 THE ARBITRATOR: You've got all of them now,

10 Mr. Akemon. You've listed them all.

11 MR. AKEMON: Yes, Your Honor.

12 BY MR. AKEMON:

13 Q. And there's also a Pink Pony South?

14 A. Yeah. It was closed. So it never opened

15 again as Pink Pony South.

16 Q. Did it open again as something else?

17 A. It opened up as -- I think we opened it as

18 Crazy Horse after -- it was involved in some litigation

19 with the city, and after the settlement, they allowed

20 two licenses in the city, so we lost one and were

21 granted that one.

22 Q. Okay. And, currently, Pink Pony South, or what

23 it used to be known as, is currently known as King of

24 Diamonds Atlanta, is that true?

25 A. Right now, yeah.

Page 198

1

 Q. Okay. And Akinyele Adams is currently running

2

that club; isn't that also true?

3

 A. He's leased the property from me.

4

 Q. Isn't it also true that Akinyele Adams is

5

involved in King of Diamonds Atlanta?

6

 MR. BRODSKY: Objection, Your Honor. What's

7

 going on in 2000 -- this is 2021, seven years

8

 beyond --

9

 THE ARBITRATOR: What's the relevance of this,

10 Mr. Akemon?

11 MR. AKEMON: I'm going to show the

12 relevance -- sorry. I'm going to show the

13 company-wide policy of how King of Diamonds in

14 Atlanta is the same as the company-wide policy of

15 King of Diamonds --

16 THE WITNESS: No.

17 THE ARBITRATOR: Well, let him finish. He can

18 ask you questions. You're not being asked a

19 question yet.

20 THE WITNESS: Okay.

21 MR. AKEMON: The policy at King of Diamonds

22 Atlanta is similar to the policy at King of

23 Diamonds Florida. Even though they were different

24 time periods, they still have the same management,

25 they still have the same policies.

Page 199

1

 MR. BRODSKY: Same objection. We've done

2

 seven --

3

 THE ARBITRATOR: I'll let you go for a little

4

 bit to see where this is going.

5

 MR. AKEMON: Thank you, Your Honor.

6 BY MR. AKEMON:

7

 Q. And you let him lease the property, or you let

8 him lease the name?

9

 A. No, it's a lease. Oh, I licensed the name. I

10 own the trademark.

11 Q. And so you allowed him to lease the name and

12 the property?

13 A. And I licensed the trademark. It's a lease.

14 It's strictly a lease. I have nothing to do with that

15 business.

16 THE ARBITRATOR: Let me just pause for a

17 second to make sure I understand. This is in

18 Atlanta, Georgia, not in Florida?

19 MR. AKEMON: Yes.

20 THE ARBITRATOR: Okay. But it's the same

21 name?

22 THE WITNESS: It's the same name. I own the

23 trademark.

24 THE ARBITRATOR: But you own the -- okay. Got

25 it now. I think it will technically be a service

Page 200

1

 mark actually, but that's a legal comment.

2

 THE WITNESS: Yeah. It's a trademark. I have

3

 a trademark lawyer. It's a trademark.

4

 THE ARBITRATOR: Right. I understand.

5 BY MR. AKEMON:

6

 Q. And this lease agreement, is it a written

7 agreement?

8

 A. Yes.

9

 Q. And you didn't enter into a written agreement

10 with Akinyele Adams back in 2013?

11 A. No, because he was looking for an investor.

12 So I didn't want to hinder any of that for him.

13 Q. I'm going to show you what has been marked as

14 I believe -- not what I believe, but Claimant's 1, Ms.

15 Galardi. I apologize, Your Honor. This podium is a

16 little small. Let me move around a little bit here.

17 THE ARBITRATOR: No need to apologize. But

18 for COVID, I would have you sitting at the table.

19 This is Number 1?

20 MR. AKEMON: C1, Your Honor. It's the first

21 document in the binder.

22 THE ARBITRATOR: This is the business

23 corporation?

24 MR. AKEMON: Yes, Your Honor.

25 THE ARBITRATOR: Okay. What does your

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1

 document -- does that document have a number on it?

2

 The one that you're going to show her, does it have

3

 a number on it?

4

 MR. AKEMON: Yes. It says Claimant's 1.

5

 THE ARBITRATOR: So why don't we go ahead and

6

 put a Claimant's 1 on there, please.

7

 MR. AKEMON: It has one on here, it just says

8

 Plaintiff's 1.

9

 THE ARBITRATOR: It says Plaintiff's. I'm

10 sorry. I just want to be sure. You're not a

11 plaintiff. We're not in court.

12 MR. AKEMON: Yes, Your Honor.

13 MR. BRODSKY: How many -- just because I

14 haven't seen it, how many different -- is it one

15 document or several?

16 MR. AKEMON: It's several. It goes from 2008

17 to 2016.

18 THE ARBITRATOR: Just describe it for the

19 record, Mr. Akemon.

20 MR. AKEMON: I'm sorry.

21 THE ARBITRATOR: These are the Florida

22 Business Corporation --

23 MR. AKEMON: These are the Florida business

24 corporation annual reports from State of Florida,

25 which are from Fly Low from 2008 to 2018.

Page 202

1

 THE ARBITRATOR: For the company called --

2

 MR. AKEMON: Fly Low, incorporated.

3

 THE WITNESS: Fly Low.

4

 THE ARBITRATOR: Fly Low. Okay. So we have

5

 that.

6 BY MR. AKEMON:

7

 Q. Do you recognize that document, Ms. Galardi?

8

 A. It's a corporation annual report for Fly Low.

9

 Q. And isn't it true that you're listed as the

10 president, the treasurer and secretary of this Fly Low,

11 Incorporated?

12 MR. BRODSKY: Objection, Your Honor, as to

13 which document? There's several documents in

14 there.

15 THE ARBITRATOR: Well, let's go ahead and take

16 a look then. Is that the case for every one of

17 these?

18 THE WITNESS: They are all -- as far as I can

19 see, they are all annual reports.

20 THE ARBITRATOR: And are you listed as the

21 president, secretary and treasurer on all of them?

22 Was that right, president, secretary and

23 treasurer?

24 MR. AKEMON: Yes, Your Honor.

25 THE ARBITRATOR: Are you listed?

Page 203

1

 THE WITNESS: I already told them that my

2

 father put me on before I knew it.

3

 THE ARBITRATOR: We understand that. The

4

 question is whether you're listed on all the

5

 documents as the president, secretary and

6

 treasure, because Mr. Brodsky made an objection.

7

 But if you're listed on all of them --

8

 THE WITNESS: This one actually has John

9

 Ennis, which is Steve.

10 THE ARBITRATOR: And for what position?

11 THE WITNESS: President, secretary, treasurer

12 and director.

13 THE ARBITRATOR: Okay. So you'll have to be

14 more specific, Mr. Akemon.

15 MR. AKEMON: I will, Your Honor.

16 BY MR. AKEMON:

17 Q. Can we go to the first page of that document,

18 Ms. Galardi?

19 A. This?

20 Q. Yes.

21 A. Yes.

22 Q. Could you go to where it says additions,

23 changes to officers and directors?

24 A. Yes, he changed it to me.

25 Q. I'm sorry, let me ask my question first, Ms.

Page 204

1 Galardi. Can you tell the Court -- I'm sorry, tell the

2 arbitrator what is -- who is listed as president,

3

treasurer and secretary in 2008?

4

 A. There's -- it's John Steve Ennis, but then

5

there are additional changes to officers and directors.

6 And then PST, so president, secretary, treasurer, it has

7 an X where it says change, so it's me. And then it

8 makes Steve Ennis vice president, and that's in

9 addition, because he used to be president.

10 Q. And can you go down to 2009 and can you tell

11 the Court --

12 A. It's me and Steve.

13 Q. Let me ask my question first, Ms. Galardi.

14 Can you tell the Court who is listed as president,

15 treasurer and secretary?

16 A. I am.

17 Q. And 2010?

18 A. I am with Steve as vice president.

19 Q. And can you tell us the signature on the

20 bottom of 2010?

21 A. It's just an electronic signature. It's not

22 my signature.

23 Q. And the same with 2011, who is listed as the

24 president, treasurer and secretary?

25 A. I am with Steve.

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1

 Q. And is there a signature there?

2

 A. Yes.

3

 Q. What kind of signature is that?

4

 A. It's an electronic signature, and it's mine.

5

 Q. And what about 2012?

6

 A. 2012 is John Ennis, his signature in 2012, and

7

it's an electronic signature.

8

 Q. And who is listed as the president, secretary

9 and treasurer?

10 A. I am.

11 Q. And what about 2013?

12 A. It's me with the electronic signature.

13 Q. And who is listed as president, treasurer and

14 secretary?

15 A. I am, and Steve is the vice president.

16 Q. And your father passed away in December of

17 2012?

18 A. Yes.

19 Q. And even after his passing, you didn't use a

20 regular signature, you used an electronic signature?

21 A. I'm sure they just filed it like they used to.

22 Q. Okay. Is there anyone else who would have the

23 ability to sign your name on this document without your

24 authority?

25 A. Well, they did it for years without my

Page 206

1 authority.

2

 Q. Well, it's your contention that your

3

father's -- let me finish my question. It's your

4 contention that your father signed your name up prior to

5 his death without your knowledge. Who would you -- who

6

in the organization would have the authority to sign

7 your name after your father's death?

8

 A. I never said my father signed my name. I said

9 he put me on the corporation. My father never signed my

10 name.

11 Q. I'll rephrase it. Who would have the

12 authority after your father's death to put your name on

13 those documents?

14 A. Pat Burnside.

15 Q. You gave her that authority?

16 A. Well, she's the one who did the corporations.

17 Q. I'm saying did you give her that authority,

18 Ms. Galardi?

19 A. After he died?

20 Q. Yes.

21 A. Yeah, I probably did. If she called me and

22 said do you want to renew the corporation, I would say

23 yes.

24 Q. And did you also give the authority in 2014?

25 A. I would think that she would -- yeah, I guess

Page 207

1

I did.

2

 Q. And continuing to 2015, '16, '17 and '18?

3

 A. She did all of our corporations in Florida.

4

 Q. And even in those subsequent years, '16, '17,

5

'18, those are also electronic signatures, Ms. Galardi?

6

 MR. BRODSKY: Objection, Your Honor. It's the

7

 same objection as before. We're talking about '16,

8

 '17 and '18, and this ends --

9

 THE ARBITRATOR: Let's take them one at a

10 time.

11 A. In '14, it was John Ennis. It was his

12 electronic signature.

13 Q. What about '15, Ms. Galardi?

14 A. Do you want me to go on to '15, '16, '17?

15 Q. Yes, I do.

16 A. Then it was signed me, but electronic

17 signature. This was filed by Ms. Pat Burnside, and then

18 the same thing on '16, filed by Ms. Pat Burnside.

19 THE ARBITRATOR: Who signed in '16, Ms.

20 Galardi?

21 THE WITNESS: It was me, electronic.

22 MR. BRODSKY: My objection is to after '14,

23 the relevance of the --

24 THE ARBITRATOR: It's a fair objection, Mr.

25 Akemon. Why are we going through '15, '16, '17?

Page 208

1

 The business has been sold.

2

 MR. AKEMON: Only to establish that -- well,

3

 two things, Your Honor. One, that although she

4

 claims that her father signed her up for -- or put

5

 her on these documents, the same signature, the

6

 same type of signature was used before and after

7

 his death.

8

 MR. BRODSKY: It's just an electronic

9

 signature.

10 THE ARBITRATOR: Okay. Well, the documents in

11 evidence are going to speak for themselves unless

12 there's something you want to draw on.

13 MR. AKEMON: No, Your Honor. I'll move on.

14 THE ARBITRATOR: Very good. I would like to

15 see the document, though. Thank you.

16 THE WITNESS: Of course. Can I look at this

17 to renew my --

18 THE ARBITRATOR: Your parking?

19 THE WITNESS: Yeah. I'm on zero now.

20 THE ARBITRATOR: Yes, sure. By all means. I

21 don't want you to get a parking ticket. They are

22 expensive in Florida.

23 THE WITNESS: I hope I didn't get a ticket

24 already.

25 THE ARBITRATOR: I doubt it.

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1

 MR. BRODSKY: Judge, and a little bit before

2

 4:00 I need to go, because I parked on the street.

3

 THE ARBITRATOR: We'll see how long Mr. Akemon

4

 goes. We may be done by then. But speak up.

5

 THE WITNESS: I'm safe until 5:30.

6

 MR. BRODSKY: You're good until 5:30?

7

 THE WITNESS: Yes. I just put two hours on.

8

 MR. AKEMON: Ms. Galardi -- are you ready, Mr.

9

 Brodsky?

10 MR. BRODSKY: Yes.

11 BY MR. AKEMON:

12 Q. Ms. Galardi, who is Dennis Williams?

13 A. Dennis Williams is the CFO of Galardi South.

14 Q. And Bob Hilton?

15 A. Bob Hilton was an employee of Fly Low, I

16 believe.

17 Q. And what about John Ennis -- Steve Ennis, I'm

18 sorry.

19 A. Steve. Steve was my father's main manager in

20 Florida.

21 Q. And Jennifer Sonders?

22 A. She's a secretary.

23 Q. And Mary Albanez?

24 A. She was a secretary. I'm not sure what her

25 duties were.

Page 210

1

 Q. And isn't it true that all the individuals

2

that I just mentioned were all employees of Fly Low,

3

Incorporated doing business as King of Diamonds?

4

 A. I'm not sure what corporation they were under.

5

I can assume it was Fly Low.

6

 Q. Okay. And isn't it true that those

7

individuals reported directly to you?

8

 A. After my father died, they would have.

9

 Q. And isn't it true that you supervised and gave

10 directions to them after your father died?

11 A. In the office, yes.

12 Q. And isn't it also true that you maintained the

13 office now at Fly Low -- I'm sorry, in the building or

14 building adjacent to King of Diamonds?

15 MR. BRODSKY: Objection, time frame.

16 BY MR. AKEMON:

17 Q. During the relevant time frame in this case,

18 2009 to 2014.

19 A. Before my father died, I had an office in the

20 warehouse with my cousin to conduct business for the

21 Cubby Hole and Truman Book Store.

22 Q. So you did have an office?

23 A. In the warehouse, not in my father's office

24 and not in the club.

25 Q. And from time to time --

Page 211

1

 A. It was space that I could utilize.

2

 Q. And from time to time, you would speak to Mr.

3 Williams about wage and hour compliance like FLSA?

4

 A. In what time are you talking about?

5

 Q. I'm sorry, my questions now would be from 2009

6

to 2014.

7

 A. No, I never spoke with Dennis Williams in 2009,

8 2010, 2011 or 2012. It would have only been 2013 and

9 on.

10 Q. And what -- isn't it true that Mr. Williams

11 was responsible for insuring wage and hour compliance

12 for the Galardi clubs?

13 A. He dealt with a lot of -- a lot of the

14 employees I guess, but --

15 Q. Okay. I need you -- I'm going to ask you the

16 question again. Isn't it true that Mr. Williams was

17 responsible for insuring wage and hour compliance for

18 the Galardi clubs?

19 A. And what time are you talking about?

20 Q. 2009 to 2014?

21 A. I cannot speak for 2009, 2010, 2011 or 2012.

22 In 2013, he may have been one of the people that

23 would --

24 MR. TOBIN: You can finish. Finish your

25 answer.

Page 212

1

 THE WITNESS: -- that would come up with

2

 policy for the clubs in Atlanta.

3 BY MR. AKEMON:

4

 Q. Okay. I'm going to show you -- let's go to

5

the trial notebook, Your Honor, which is the red

6 notebook you have there, the Espinoza trial transcript,

7 day one, Page 47. Could you please read Line 11 please,

8 Ms. Galardi?

9

 MR. BRODSKY: Your Honor, before that, I have

10 an objection, because there's a specific time frame

11 that's at issue here, and none of that is contained

12 on this transcript. So we have no idea what time

13 frame this question surrounds.

14 MR. AKEMON: Your Honor --

15 THE ARBITRATOR: The question at seven reads

16 Ms. Galardi, Mr. Williams has been the chief

17 financial officer at Galardi since 2012 at least,

18 has he not?

19 Answer, yes.

20 And what you were just asked to read, and

21 since this is in evidence, I can read it as well,

22 he's responsible for insuring FLSA compliance

23 through your strip clubs, is that right?

24 Answer, yes.

25 E-mails, the communications with the lawyers

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1

 regarding FLSA compliance, is that right?

2

 Answer, yes.

3

 Question, that would Mr. Fuchs here, correct?

4

 Answer, yes.

5

 So that's what you were bringing out. Now,

6

 does that -- do you want to follow up on that now?

7

 MR. AKEMON: Yes, Your Honor.

8

 THE ARBITRATOR: That's the testimony that you

9

 gave in court, Ms. Galardi, and Mr. Akemon is going

10 to follow up with you.

11 BY MR. AKEMON:

12 Q. Isn't it also true that Mr. Williams was

13 instructed by you to negotiate settlements for various

14 FLSA cases, including --

15 A. From 2013 on.

16 Q. Let me finish my question, Ms. Galardi.

17 -- including cases involving Fly Low, Incorporated 

18 doing business as King of Diamonds?

19 A. I would only have given him that authority

20 from 2013 on because I had no authority to give him

21 before that.

22 Q. My question is did you give him authority to

23 negotiate settlements on behalf of Fly Low?

24 MR. BRODSKY: She's answered the question

25 twice, Your Honor.

Page 214

1

 THE WITNESS: In 2013.

2

 MR. TOBIN: It's argumentative.

3 BY MR. AKEMON:

4

 Q. Let's talk about those various companies.

5 Those companies, Masters, Inc., Onyx, Pink Pony, 

6 Pink Pony South from 2009 to 2014, specifically after 

7 your father died in 2012 and 2014, Isn't it true that 

8

they all had the same business model? And what I 

9 mean by business model, isn't it true that they all

10 labeled exotic dancers at those clubs as

11 a --

12 A. They were all adult clubs.

13 Q. Let me finish my question, Ms. Galardi. That

14 they labeled the dancers there as independent

15 contractors?

16 A. I think so.

17 Q. And isn't it also true that in order to work

18 at those clubs during 2012 and 2014 that those dancers

19 were required to pay house fees for the --

20 A. Yes.

21 Q. Okay. And Fly Low, Incorporated owned and

22 operated KOD?

23 A. Yes.

24 Q. And which clubs are you currently -- I'm

25 sorry, 2012 and 2014, you owned each and every last one

Page 215

1 of those clubs 100 percent?

2

 A. Yes, from December -- well, from day of death.

3 The distributions, they weren't finished with that until

4 well into 2015 and '16, but --

5

 Q. But you did own them 100 percent?

6

 A. Yes.

7

 Q. Each of these clubs featured nude or semi-nude

8 dancers?

9

 A. Yes.

10 Q. And each of these clubs sold beer, wine,

11 liquor and food?

12 A. Yes.

13 Q. And each of these dancers were required to

14 sign independent contractor agreements?

15 A. I think they did.

16 Q. And it was the same at every club, correct?

17 A. It would have been.

18 Q. All right. During this time period,

19 specifically 2012 to 2014, none of the general managers

20 and none of the management at any of those other clubs,

21 including King of Diamonds, their general managers, they

22 weren't free to disregard that business model, were

23 they?

24 A. I think every club operated a little bit

25 differently.

Page 216

1

 Q. But I'm talking specifically about the

2 business model. Was anyone outside of yourself given --

3 did anyone else besides yourself, including Mr. Williams

4 or anyone of that nature --

5

 MR. BRODSKY: Judge -- I'm sorry. Go ahead.

6

 Finish.

7 BY MR. AKEMON:

8

 Q. -- were they free to disregard the business

9 model of labeling dancers independent contractors and/or

10 require house fees for dancers to work?

11 MR. BRODSKY: Judge, my objection is this.

12 I'm just trying to -- because I think we all can

13 agree that the time frames in this case are very

14 important.

15 THE ARBITRATOR: It doesn't matter. He said

16 2012 to 2014. Is that what I heard?

17 MR. AKEMON: That's what I said, Your Honor.

18 THE ARBITRATOR: Okay. So she's able -- she's

19 been quite capable of answering questions and

20 narrowing where appropriate.

21 So the question is in 2012, '13 and '14, did

22 any of the general managers have the authority to

23 disregard the business model of either the exotic

24 dancers signing independent contractor agreements or

25 paying house fees? That's the question that I heard.

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1

 MR. AKEMON: Yes, Your Honor.

2

 THE ARBITRATOR: Okay. So that's the question

3

 that's pending.

4

 A. From December 1st, 2012 and '13 and '14, the

5 business model being that the dancers were hired under

6

independent contracts? Is that what you're asking me?

7

 Q. No. I'm asking were any -- outside of

8 yourself, was anybody -- were any of the general

9 managers given the authority to change the business

10 models at any of those clubs, including King of

11 Diamonds, labeling dancers independent contractors

12 and/or requiring them to pay house fees? Did they have

13 the authority to change that business model?

14 A. No, they would have asked me. They would have

15 gone over it with me.

16 Q. And because you labeled the dancers -- I'm

17 sorry, strike that.

18 Because the dancers were labeled as

19 independent contractors, KOD didn't pay any benefits

20 like health insurance?

21 A. Not on the independent contractors, no.

22 Q. And you didn't pay federal taxes either?

23 A. Not on the -- I paid federal taxes --

24 Q. With respect to the dancers?

25 A. Not on the independent contractors.

Page 218

1

 Q. Or Social Security?

2

 A. No.

3

 Q. What about workman's comp?

4

 A. No.

5

 Q. Unemployment insurance?

6

 A. No.

7

 Q. And, again, all these questions are

8

regarding -- or related to dancers.

9

 A. From December 1st, 2012, 2013.

10 Q. And even after your father died, did you

11 change the business model?

12 A. Yes, after --

13 Q. What part of the business model did you

14 change?

15 A. You know, it's kind of a touchy thing, because

16 you change the business model, and we tried to implement

17 W-2s and nobody would work there. They would leave. So,

18 you know, we would have to come up with a system where

19 they were employees and made sure they got minimum wage.

20 Q. So you tried to change the business model at

21 King of Diamonds?

22 A. Well, King of Diamonds was already gone.

23 Q. In 2012 to 2014, did you change the business

24 model at King of Diamonds?

25 A. Akinyele Adams -- I was under a business

Page 219

1 management agreement with him. I would not have

2

interfered in his business.

3

 Q. Again, Ms. Galardi, this is my question.

4

 A. No, I did not.

5

 Q. My question is did you change the business

6 model after your father died in King of Diamonds?

7

 A. No.

8

 Q. Okay. Thank you. There was a lawsuit filed

9 against a Galardi controlled club in Atlanta styled Clincy

10 versus Galardi South Enterprises. Are you familiar with

11 that case?

12 A. Only through these hearings and depositions.

13 It was my father's at the time.

14 Q. And this occurred sometime back in 2011,

15 correct?

16 A. I really don't know when it occurred.

17 Q. And isn't it true that in that case, the judge

18 held that Galardi South Enterprises had misclassified

19 dancers as independent contractors instead of employees?

20 THE ARBITRATOR: Hold on one second. What's

21 your objection?

22 MR. BRODSKY: Objection, relevance.

23 THE ARBITRATOR: No, I'll allow the question.

24 A. I really don't know the specifics of that

25 case. I was not involved at all.

Page 220

1

 Q. Okay. That wasn't my question. Isn't it true

2

that the judge in that case held that Galardi control --

3

that that particular club that was a Galardi controlled

4 club misclassified dancers as independent contractors

5

instead of employees?

6

 A. I don't know.

7

 Q. Isn't it also true that decision came out 

8 sometime around 2011?

9

 A. I don't know what time it came out.

10 Q. And prior -- I'm sorry. Sometime in 2013,

11 April 2013, isn't it true that another FLSA lawsuit was

12 filed against the King of Diamonds staff, Ochoa v. Fly

13 Low, Incorporated?

14 A. I don't know. It sounds familiar.

15 Q. And isn't it true that that lawsuit was

16 settled?

17 A. It could have been.

18 Q. And isn't it true --

19 A. Dennis probably negotiated a settlement. I'm

20 not sure.

21 Q. And isn't it also true that you signed the

22 settlement agreement?

23 A. If there was a settlement, I would have signed

24 it.

25 Q. And isn't it also true that that lawsuit,

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1 Ochoa v. Fly Low, was a wage and hour suit with one of

2

the employees there?

3

 A. Probably.

4

 Q. And they alleged that King of Diamonds did not

5 pay them minimum wage?

6

 A. Probably.

7

 Q. And there was another lawsuit styled Henderson

8 v. Fly Low, and that was another wage and hour lawsuit.

9 Are you familiar with that one?

10 A. It's familiar.

11 Q. And in that case, they also allege they

12 weren't paid minimum wage?

13 A. Probably.

14 Q. And you settled that case as well?

15 A. If I signed a settlement agreement.

16 Q. And you also testified earlier about the

17 remodel. You selected the vendors to complete that

18 remodel?

19 A. No, I didn't select the vendors.

20 Q. How are the vendors selected?

21 A. Steve knew a carpet guy, so --

22 Q. And you paid the invoices?

23 A. Yeah, the club would -- Fly Low would pay the

24 invoices, not me.

25 Q. You didn't personally pay for the remodel?

Page 222

1

 A. Yeah, I did.

2

 Q. Okay. So you paid -- you personally paid for

3

the remodel?

4

 A. Yeah, I probably would have put the money into

5 Fly Low.

6

 Q. So you took some of your personal funds and

7 put them into Fly Low?

8

 A. It was my father's funds. I don't have

9 personal funds.

10 Q. And so after your father died -- strike that.

11 Your earlier testimony is that Akinyele 

12 Adams came on sometime around March or April of 2013,

13 correct?

14 A. Right.

15 Q. And he -- you interviewed Mr. Adams for this

16 position; is that also true?

17 A. No, I did not. I did not interview Mr. Adams.

18 Q. How did he come about this position?

19 A. He wanted to buy the club, and he didn't have

20 all the money to buy me out of the club. He was a

21 promoter. So I went into a management agreement with

22 him.

23 Q. And even after you went into this management

24 agreement, you testified that it wasn't on -- it wasn't

25 a signed contract, correct?

Page 223

1

 A. That's right. It was a handshake deal.

2

 Q. Okay. And even after that signed contract,

3 Bob -- I'm sorry, Robert Hilton was still an employee of

4 Fly Low, correct?

5

 MR. BRODSKY: Objection, the testimony was an

6

 unsigned contract. He just said signed.

7 BY MR. AKEMON:

8

 Q. I'm sorry. I'll strike that. Even after the

9 alleged agreement between yourself and Mr. Adams, Bob

10 Hilton was still an employee of Fly Low, Incorporated?

11 A. Even after I went into a management agreement

12 with Akinyele Adams, Bob Hilton I believe was still an

13 employee of Fly Low.

14 THE ARBITRATOR: Pause for just one second.

15 We just have to make sure you finish your question

16 before you respond and you finish your answer

17 before you say anything.

18 So just pause, if you would, because you're --

19 every now and then, you're talking over each other.

20 I'm trying not to interrupt, but let's just try to

21 be more disciplined.

22 Let him finish the question, and you answer,

23 let her finish the answer. You're revved up, and

24 she's revved up. Just calm down. Calm down.

25 BY MR. AKEMON:

Page 224

1

 Q. And Steve Ennis, he was still an employee of

2 Fly Low after Akinyele Adams came on as general manager?

3

 A. Yes.

4

 Q. And Jennifer Sonders was still an employee of

5 Fly Low after he came on as general manager?

6

 A. Yes.

7

 Q. What about Mary Albanez? Was she still an

8 employee of Fly Low?

9

 A. For a time.

10 Q. And they still worked in or around the

11 premises at King of Diamonds, is that correct?

12 A. They worked in the office specifically.

13 Q. And they reported directly to you, is that

14 also true, after Akinyele came on as general manager?

15 A. Yes, because they weren't employed by

16 Akinyele.

17 Q. And isn't it also true that Akinyele would

18 give the daily sales reports to Bob Hilton, who would

19 then relay that information to you?

20 A. No. After Akinyele took over, I never looked

21 at sales reports.

22 Q. So then sometime later, Liz Cedeno was still

23 employed at King of Diamonds, isn't that also true,

24 after Akinyele came on in 2013?

25 A. I believe so.

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1

 Q. And isn't it true that even though Akinyele

2 Adams was the general manager and you entered into this

3 agreement with him, that you ordered her firing as the

4 manager of the King of Diamonds?

5

 A. They say I did. I really don't remember doing

6

that, but I guess I did.

7

 Q. If I show you your --

8

 A. I understand.

9

 Q. So you acknowledge that you did order her

10 firing?

11 A. I do acknowledge that; I just don't recall it.

12 Q. Isn't it also true that you ordered the firing

13 of other managers during that time frame after Akinyele

14 Adams was the general manager?

15 A. No.

16 Q. If I showed you a document, would it help

17 refresh your memory?

18 THE ARBITRATOR: Well, she's answered the

19 question no, Mr. Akemon, so are you going to show

20 her the document?

21 MR. AKEMON: Yes, Your Honor.

22 BY MR. AKEMON:

23 Q. I'm going to show you what has been marked as

24 Claimant's 18.

25 THE ARBITRATOR: Another one I do not have,

Page 226

1

 Mr. Akemon. I don't have anything after --

2

 MR. AKEMON: You can have mine, Your Honor.

3

 THE ARBITRATOR: Mr. Brodsky, it's getting

4

 close to 4:00. Are you nervous?

5

 MR. BRODSKY: I wouldn't say nervous, but --

6

 THE ARBITRATOR: I don't want you to get a

7

 ticket either.

8

 MR. BRODSKY: I would like to go pay my

9

 parking.

10 MR. AKEMON: It's the request for admissions.

11 THE ARBITRATOR: No problem. Have the court

12 reporter mark this so I know what it is since I

13 have nothing here.

14 MR. AKEMON: This is 18, Claimant's 18.

15 THE ARBITRATOR: We'll finish this document,

16 and then we'll let Mr. Brodsky go feed the meter

17 and then you can continue after that, Mr. Akemon.

18 THE WITNESS: Can I use the rest room while --

19 THE ARBITRATOR: Absolutely. Do you want a

20 break now?

21 THE WITNESS: Sure.

22 (Off the record.)

23 THE ARBITRATOR: Back on the record.

24 MR. AKEMON: I believe we left off with the

25 introduction of Claimant's 18.

Page 227

1

 THE ARBITRATOR: Request for admissions.

2

 MR. AKEMON: Yes, Your Honor.

3 BY MR. AKEMON:

4

 Q. Ms. Galardi, isn't it true that you made the

5 decision to wholesale change KOD club management after

6 Mr. Adams was hired as GM?

7

 A. No.

8

 Q. I'll refer you --

9

 A. I don't know what wholesale change means. I

10 think I told you that yesterday or the day before.

11 Q. Well, I want to show you what has been marked

12 as C18. Mr. Brodsky, it's the request for admissions.

13 MR. BRODSKY: Understood, thank you.

14 BY MR. AKEMON:

15 Q. And for the record, could you please read

16 number 13?

17 A. You made the decision to wholesale change KOD

18 club management, and my response was admitted.

19 Q. And isn't it also true that you ordered the

20 firing of Liz Cedeno after Akinyele Adams was installed

21 as the general manager?

22 MR. BRODSKY: Your Honor, I have one

23 objection, and that is in the request for

24 production, I --

25 THE ARBITRATOR: Request for admissions.

Page 228

1

 MR. BRODSKY: Yes, sir. It refers to a

2

 Galardi deposition Page 39, which is not part of

3

 this.

4

 THE ARBITRATOR: I don't have it in front of

5

 me, so let me see what you're talking about.

6

 MR. AKEMON: He's talking about this, Your

7

 Honor.

8

 THE ARBITRATOR: What's the issue there? Can

9

 we clear this up?

10 MR. AKEMON: After -- it says you made the

11 decision to wholesale change KOD club management,

12 but in parentheses, it says Galardi deposition.

13 THE ARBITRATOR: Okay. It's just a reference,

14 but the point is that the request itself is

15 admitted?

16 MR. BRODSKY: I agree with that, but what I'm

17 saying is there's no context in the sense of the

18 way it's presented.

19 THE ARBITRATOR: Okay. I can ignore the

20 parenthetical. It doesn't seem like it's

21 particularly relevant.

22 MR. AKEMON: Say that again, Your Honor. I'm

23 sorry.

24 THE ARBITRATOR: I said I can ignore the

25 parenthetical. I'm assuming that's a question and

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1

 an answer in a deposition, but if it's not

2

 otherwise in the record, I'll ignore the

3

 parenthetical.

4 BY MR. AKEMON:

5

 Q. And you also ordered the firing of manager Liz

6 Cedeno?

7

 A. They say I did. I don't remember, so I

8 admitted it. Yes.

9

 Q. Okay. And you also may have caused the firing

10 of other KOD employees at the same time you ordered the

11 firing of Ms. Cedeno?

12 A. No. I say admitted here, but I really don't

13 remember firing anyone else.

14 Q. For the purposes of the record, can you read

15 number two please?

16 A. The record says I admitted it.

17 Q. And you also selected Akinyele Adams to

18 replace Ms. Cedeno and manage KOB on behalf of Fly Low.

19 Isn't that also true?

20 A. It says admitted, but I didn't do it to

21 replace her. But I do have the responses.

22 Q. And these are your responses to the requests

23 for admissions?

24 A. Yes. Yes.

25 Q. I have no further questions from this exhibit,

Page 230

1 Ms. Galardi.

2

 A. You're not going to ask me that one?

3

 Q. No, I'm not. Thank you.

4

 THE ARBITRATOR: That's all of it?

5

 MR. AKEMON: Yes, Your Honor.

6

 THE ARBITRATOR: What requests were these,

7

 which numbers?

8

 MR. AKEMON: This was C --

9

 THE ARBITRATOR: No, what were the requests?

10 I don't know if you actually referred to the

11 request number.

12 MR. AKEMON: Numbers 13 --

13 THE ARBITRATOR: So it's 13, 14 --

14 MR. AKEMON: -- 14, 15 and 16.

15 THE ARBITRATOR: Got it.

16 BY MR. AKEMON:

17 Q. And even after this, after your -- after you

18 installed -- I'm sorry, strike that.

19 Even after you hired Akinyele Adams as the

20 general manager of the King of Diamonds, isn't it also

21 true that you implemented this arbitration policy while

22 he's the general manager?

23 A. I didn't hire him. He wasn't my employee.

24 But the arbitration agreement probably came after him,

25 yeah.

Page 231

1

 Q. Okay. And when the arbitration came in, it

2 was your testimony earlier that you had nothing to do

3 with King of Diamonds, correct?

4

 A. Correct.

5

 Q. How is it that you were able to install a

6 company-wide policy related to King of Diamonds if you

7 had nothing to do with King of Diamonds?

8

 A. Because it was still operating under Fly Low,

9 which I still owned. Actually, I still own Fly Low,

10 which owns the trademark. So because of that, it just

11 went company-wide. I had a management agreement with

12 him, but it was still in my name, so --

13 Q. And so you believed you had the authority to

14 implement this policy at the King of Diamonds?

15 A. I believed I had the authority to do it

16 company-wide, and that was part of -- still part of the

17 company because it was in my name. But I did have a

18 management agreement with him.

19 Q. So the answer is you believe you had the

20 authority to implement this policy at King of Diamonds?

21 A. Yes.

22 Q. Even after Akinyele Adams was hired?

23 A. Yes. I didn't hire him.

24 Q. Even after Akinyele Adams became general

25 manager?

Page 232

1

 A. Well, I really wouldn't consider him general

2 manager either. He didn't have a position. He wasn't

3 an employee of Fly Low.

4

 THE ARBITRATOR: I understand the distinction

5

 here between your position and what you're asking,

6

 so when you use the word hire, let's just accept it

7

 as being under this management agreement that

8

 you've referred to so we don't get into this back

9

 and forth on the word hire.

10 I appreciate the distinction that you're

11 making, Ms. Galardi. Don't worry that I will

12 interpret hire to mean that you're changing your

13 testimony.

14 THE WITNESS: Thank you.

15 BY MR. AKEMON:

16 Q. And even after this policy was -- strike that.

17 I mentioned a number of lawsuits that were

18 filed against King of Diamonds, specifically Anderson v.

19 King of Diamonds -- well, I'm sorry, Fly Low,

20 Incorporated, Ochoa v. Fly Low, Incorporated. Those

21 were wage and hour lawsuits. Do you remember those

22 questions I asked you earlier?

23 A. Anderson?

24 Q. I believe so, Anderson. I know Ochoa v. Fly

25 Low, Incorporated. Do you remember that question?

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1

 A. Yes.

2

 Q. And do you remember that case?

3

 A. I don't remember the details of the case, no.

4

 Q. But it was a wage and hour case?

5

 MR. BRODSKY: Objection, asked and answered.

6

 THE ARBITRATOR: We've covered that already,

7

 Mr. Akemon.

8

 MR. AKEMON: I'm setting a foundation for the

9

 next question, Your Honor. I apologize.

10 THE ARBITRATOR: Okay. What's the next

11 question?

12 BY MR. AKEMON:

13 Q. And they allege that even after these wage and

14 hour lawsuits --

15 THE ARBITRATOR: Who is the they?

16 BY MR. AKEMON:

17 Q. I'm sorry. Even after the wage and hour

18 lawsuits, Fly Low did not change the policy of not

19 paying dancers minimum wages. Isn't that also true?

20 A. Technically, yes. I wouldn't have changed

21 policy at King of Diamonds because I felt that I had a

22 management agreement with Akinyele, so I would not have

23 gotten into his business.

24 Q. And even after Akinyele came on board between

25 December and let's say March or April of 2013, isn't it

Page 234

1 also true that you didn't attempt to change the policy

2 at King of Diamonds?

3

 A. I didn't have my mind on any policy or

4 arbitration agreements. I was dealing with my father's

5 death and his estate, so I really wasn't thinking about

6

that. So no.

7

 Q. And you had signatory authority on the bank

8 accounts listed with Fly Low, Incorporated, isn't that

9

true?

10 A. I probably had a -- I'm not sure if I had a

11 signature card or not. I think Steve did all the

12 signing of the checks --

13 Q. But you had the -- I'm sorry. Go ahead.

14 A. -- at the office. Steve signed all the

15 checks.

16 Q. But did you have the authority and ability to

17 sign the checks as the president, secretary and

18 treasurer of Fly Low, Incorporated?

19 A. Probably.

20 Q. And these house fees, let's talk about those

21 for a minute. Did you include the house fees or did Fly

22 Low, Incorporated include the house fees in its

23 corporate taxes?

24 A. I don't know if -- when I took over, if any

25 house fees were ever received by Fly Low. I can't

Page 235

1 answer that. I don't think we received house fees.

2

 Q. My question was were they reported on Fly

3 Low's taxes?

4

 A. If I didn't receive them, if Fly Low didn't

5

receive them, I would have to look at my taxes. I don't

6

think that house fees ever came into Fly Low.

7

 Q. Did you keep track or did Fly Low keep track

8 of the amount of house fees that came in?

9

 A. No. It wasn't my business.

10 Q. Did Fly Low keep track of the amount of tips

11 that the dancers made?

12 A. No, not my business.

13 Q. Did Fly Low ever inform the dancers that they

14 were entitled to a tip credit?

15 A. If they were wage and hourly, if -- they would

16 have to be a W-2 for a tip credit.

17 Q. Did Fly Low inform the dancers that they were

18 entitled to a tip credit?

19 A. Not to my knowledge.

20 Q. And did Fly Low keep track of the amount of

21 lap dances or lap dance fees that were paid to the

22 dancers?

23 MR. BRODSKY: Again, Your Honor, I would just

24 want to make sure that we're dealing with a time

25 frame.

Page 236

1

 MR. AKEMON: 2012 to 2014. I'm sorry.

2

 MR. BRODSKY: When we say 2012, are we talking

3

 about December 1st, 2012 on?

4

 MR. AKEMON: December 1st, 2012 to 2014.

5

 THE ARBITRATOR: Very good.

6

 A. No.

7

 Q. And then did Fly Low incorporate those lap

8 dance fees into their taxes?

9

 A. I just said we didn't keep track of those

10 things, so no. Not my business.

11 Q. And you earlier testified that you had nothing

12 to do with the hiring or firing of dancers at King of

13 Diamonds?

14 A. Correct.

15 Q. Isn't it true that the arbitration policy was

16 a requirement for all of the dancers currently working

17 at King of Diamonds?

18 A. It was a requirement for everyone that worked

19 for any of the companies.

20 Q. I'm not asking about any of the other

21 companies. Was it a requirement at King of Diamonds?

22 A. Yes, that would have been a requirement for

23 them as well.

24 Q. Okay. And if anyone, specifically the dancers

25 during the time this arbitration policy was implemented,

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1

isn't it true that if they did not sign it, they were

2 not allowed to work at King of Diamonds?

3

 A. Not to my knowledge.

4

 Q. Isn't it true that a couple of the -- a few

5 young ladies refused to sign the arbitration policy and

6

they were terminated?

7

 A. Well, I've heard that now through all that,

8 but I don't know why they were terminated.

9

 Q. And isn't it also true that after they were

10 terminated, you instructed your attorney at the time,

11 Dane Fuchs, to ensure that they were rehired at King of

12 Diamonds?

13 A. Yeah. I don't remember that.

14 Q. I'm going to show you what has been marked as

15 C10 and 11.

16 THE ARBITRATOR: Okay. Let me take these out.

17 MR. AKEMON: I'll have these marked for Your

18 Honor.

19 THE ARBITRATOR: Okay. I'm going to give

20 these to you so you can have them back, and I have

21 the one marked Exhibit 48.

22 MR. AKEMON: So this is 10, and this is 11.

23 THE ARBITRATOR: I'll trade with you.

24 MR. AKEMON: Yes, Your Honor.

25 THE ARBITRATOR: And this is going to be

Page 238

1

 Claimant's 11? Or, I'm sorry, this is Claimant's --

2

 MR. AKEMON: The one that says VP is going to

3

 be 11.

4

 THE ARBITRATOR: That's claimant's. Yeah.

5

 You can use these, but that way, I can look at them

6

 while you're asking questions.

7 BY MR. AKEMON:

8

 Q. Isn't it true that around the time that the

9 arbitration agreements were circulated, your attorney

10 responded to a letter from attorney Harlan Miller

11 reinstating those young ladies who were terminated for

12 refusing to sign the arbitration agreement?

13 MR. BRODSKY: Your Honor, I have an objection

14 to these. These are hearsay, number one. Number

15 two, Mr. Miller is no longer with us. Number

16 three, I don't want to get into the attorney/client

17 privilege between -- I mean, I don't know, but

18 possibly between my client and her lawyer, Mr.

19 Fuchs.

20 THE ARBITRATOR: Your hearsay objection is

21 overruled. I'm not sure what you mean about Mr.

22 Fuchs no longer -- Mr. Miller not being with us.

23 What does that --

24 MR. BRODSKY: He's deceased.

25 THE ARBITRATOR: Mr. Miller is deceased?

Page 239

1

 MR. BRODSKY: Yes.

2

 MR. AKEMON: He passed away about a month ago,

3

 Your Honor.

4

 THE ARBITRATOR: Poor guy. He wasn't that

5

 old, was he?

6

 MR. AKEMON: No.

7

 MR. TOBIN: He had a bran aneurysm.

8

 THE ARBITRATOR: Sad. So sad. Sorry.

9

 MR. BRODSKY: And you're talking about

10 dialogue between two lawyers that -- and not --

11 THE ARBITRATOR: The objection is overruled.

12 I've allowed these exhibits in. You may ask the

13 questions.

14 MR. AKEMON: Madam Reporter, can you please

15 read the question back?

16 THE ARBITRATOR: Ms. Galardi said she didn't

17 remember this event. You've now shown her these

18 documents. Does this refresh your recollection at

19 all, Ms. Galardi?

20 THE WITNESS: No. I don't -- I wasn't in

21 this. This looks like it was between Dean and

22 Harlan. I really don't -- I don't remember this.

23 BY MR. AKEMON:

24 Q. So you don't recall instructing those dancers

25 to be reinstated after they were terminated?

Page 240

1

 A. It doesn't say that I instructed that; it's

2

just Dean saying that.

3

 Q. My question is do you recall asking those --

4

that those young ladies be reinstated?

5

 A. No, but that would have been nice if I did.

6

 Q. And then there was another lawsuit filed in

7 2014 styled Espinoza v. Galardi. Isn't it also true

8

that the reason for the arbitration policy was a result

9 of all of the lawsuits that occurred against yourself

10 and the Galardi controlled clubs?

11 A. You asked me about Espinoza and all of the

12 lawsuits. It was not a result of Espinoza. But with --

13 in regards to other lawsuits, I felt like the

14 arbitration, like as we're doing here, I could answer

15 individually to complaints, and, really, I hoped that

16 people would come to me instead of running to a lawyer,

17 but nobody did.

18 Q. Okay. And isn't it also true that Espinoza

19 was filed sometime in 2014, it was certified as a Rule

20 23 class action?

21 A. Yeah. I'm not sure when it was filed.

22 Q. Okay. Isn't it true that it was a --

23 A. I know it was 2014, but I don't know what

24 month or anything.

25 Q. Isn't it true it was a Rule 23 class action?

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1

 A. I guess it was.

2

 MR. AKEMON: I'll move to admit it, Your

3

 Honor, even though she's already answered.

4

 THE WITNESS: I don't know what Rule 23 means.

5

 MR. AKEMON: I move to admit it because

6

 she --

7

 THE ARBITRATOR: Admit what?

8

 MR. AKEMON: The next exhibit, Your Honor.

9

 THE ARBITRATOR: I admitted all your exhibits.

10 You don't have to move to admit anything. They are

11 all admitted.

12 MR. AKEMON: Okay. All right.

13 THE ARBITRATOR: What weight I give them is

14 something that you can argue, but I will receive

15 the exhibits.

16 BY MR. AKEMON:

17 Q. And isn't it also true that you described your

18 involvement in King of Diamonds as quote, unquote

19 steering the wheel? That you were steering the wheel?

20 A. I think that was when I was going through my

21 father's estates and dealt with everything. I don't

22 think I was steering the wheel at King of Diamonds

23 specifically.

24 Q. I'm going to show you -- you have the

25 binder in front of you, Ms. Galardi. I want you to

Page 242

1

read -- I'm sorry. I'll get to that, because the binder

2

is pretty voluminous. Your Honor, I'm looking at day

3

two.

4

 THE ARBITRATOR: Okay. What page?

5

 MR. AKEMON: Day two, Page 30. And day two

6

 would be the second color there. At the top, it

7

 will be 354.

8

 THE ARBITRATOR: Well, the pages at the very

9

 top right-hand corner, what is that page number?

10 MR. AKEMON: That's the page number -- yeah,

11 that's the page number.

12 THE ARBITRATOR: I know, but what page should

13 I look for?

14 MR. AKEMON: Page 30.

15 THE ARBITRATOR: Page 30 of 302?

16 MR. AKEMON: Yes, Your Honor.

17 THE ARBITRATOR: I have page 30 of 302.

18 BY MR. AKEMON:

19 Q. Line 11. And during that time period, Mr.

20 Harlan Miller was asking you about a deposition

21 testimony that you had previously given, and he asked

22 you whether or not -- he asked you about your

23 involvement in King of Diamonds. And can you read Line

24 11 of Page 30, please? Line 11 through 14.

25 MR. BRODSKY: Judge, I object to this. It's

Page 243

1

 improper impeachment. She's being asked about a

2

 transcript that refers to a deposition that we

3

 don't know what it says, that's not here or

4

 attached hereto for her to look at in answering the

5

 question.

6

 THE ARBITRATOR: Let me read this. So at Line

7

 6, the Court actually raised something similar.

8

 I'll need to see the transcript in order to rule on

9

 that. Do you have an extra copy for me? This is

10 Line 22 on Page 29 of 302.

11 Mr. Miller, said yes, Your Honor, this is the

12 copy that I'm working on. This is the excerpt.

13 And we're talking about Line 22.

14 Mr. Miller, the highlighted portions are what

15 I've already talked about -- talked with her about.

16 The Court, objection overruled.

17 So Mr. Miller then says so, Ms. Galardi, let's

18 kind of do it again so it's clear for the jury.

19 The question at Line 15 was referring to the

20 transcript, okay, and now since December 1st, you

21 tell me your involvement, your answer at Line 17

22 was what?

23 And, apparently, Ms. Galardi, your answer was

24 I'm completely involved now.

25 Question, and then you were asked a question,

Page 244

1

 what does that mean.

2

 And your answer at Line 18 was what -- and

3

 apparently you said in the transcript, I'm

4

 completely involved, I'm like at a steering wheel

5

 now, so -- and so --

6

 THE WITNESS: My father had --

7

 THE ARBITRATOR: The actual transcript

8

 references are in here, Mr. Brodsky, so your

9

 objection is overruled.

10 MR. BRODSKY: So is this December of 2012

11 we're talking about?

12 THE ARBITRATOR: That's what this says.

13 MR. BRODSKY: It doesn't have a year I don't

14 think.

15 THE ARBITRATOR: And it says okay, and now since

16 December 1st, you tell me your involvement.

17 MR. BRODSKY: So we're --

18 THE ARBITRATOR: That's exactly what that

19 says.

20 MR. BRODSKY: What we're saying is that means

21 2012, the year.

22 THE ARBITRATOR: Well, that's presumed,

23 because that's when he died. I don't know why he

24 would pick that date otherwise.

25 MR. BRODSKY: And that's the purpose of why

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1

 I'm saying we don't have the transcript here which

2

 may have involved that type of issue. It's like --

3

 THE ARBITRATOR: I think the context is quite

4

 clear, Mr. Brodsky, that it's 2012.

5

 MR. BRODSKY: Okay.

6

 THE ARBITRATOR: Now, what's your question?

7 BY MR. AKEMON:

8

 Q. My question was do you remember making that

9 statement that you were steering the wheel of your -- at

10 King of Diamonds?

11 A. I did not say at King of Diamonds. It does

12 not say that here. It says my father had an extensive

13 estate and I needed to get a flow chart to keep it all

14 together, which is why I was totally involved, because

15 he had names like Bella Mia for Pink Pony here and Mia

16 Luna for something else, and I just -- it was a lot for

17 me and my cousin and even Mike and Dennis to just put

18 everything together.

19 And we had to have extensive valuations of

20 this estate to do a 706 for the IRS. So, yes, it was -- I

21 was in a whirlwind of things, not for King of Diamonds.

22 This does not say I was a steering wheel for King of

23 Diamonds. So that's my answer.

24 Q. Okay. Ms. Galardi, as president of Fly Low,

25 couldn't you change the business model between December

Page 246

1 1st, 2012 and 2014?

2

 MR. BRODSKY: Objection, asked and answered.

3

 MR. AKEMON: I don't believe I asked her if

4

 she could change it.

5

 THE ARBITRATOR: I'll allow this question.

6

 A. You did ask me, but I said that wouldn't have

7 been something I would have done, but because Akinyele

8 was -- I had a business arrangement with him, so I

9 wouldn't have interfered.

10 Q. And in your experience in running these

11 various exotic dancer clubs, the funds -- the way the

12 young ladies would make money is tips directly from the

13 customers?

14 A. I really don't run the clubs even now, so I

15 don't have experience in operating the clubs.

16 Q. I'll rephrase. To the best of your knowledge,

17 the money that these young ladies -- the exotic dancers

18 who work at these clubs, to the best of your knowledge,

19 is the money that they make given to them directly from

20 the customers?

21 A. I would think so.

22 Q. They don't get any money or did not receive

23 any money directly from Fly Low, Incorporated or --

24 doing business as King of Diamonds?

25 A. That's right.

Page 247

1

 Q. And a couple other questions and I'll be

2 done, Your Honor. There was also a case styled Beck v.

3 Galardi. Are you familiar with that case?

4

 A. I'm not really familiar, no. I've heard of

5

it, but I'm not familiar with it.

6

 Q. And that was an arbitration involving other

7 dancers who alleged that King of Diamonds did not pay

8

them minimum wage. Does that refresh your memory?

9

 A. I don't remember an arbitration with Beck.

10 Q. Isn't it true that --

11 A. Was I present?

12 Q. I was about to get to that. Isn't it true

13 that you did not attend the final hearing at that Beck

14 arbitration?

15 A. That's probably why I don't remember it. I

16 don't know.

17 Q. Isn't it also true that you did not present

18 any defenses at that arbitration?

19 A. I don't know.

20 Q. What, if any, research did you do regarding wage

21 and hour compliance at the King of Diamonds or for any

22 of your clubs during December 1st, 2012 and July of

23 2014?

24 A. None.

25 Q. Did you do any research -- did you contact the

Page 248

1 Department of Labor?

2

 A. No.

3

 Q. Did you consult with an attorney about wage

4 an hour?

5

 A. No.

6

 Q. So you didn't do anything --

7

 A. Not during that time, no.

8

 Q. So you didn't do anything to figure out

9 whether or not you were in compliance with the law?

10 A. No. Honestly, it wasn't what I was working on

11 at that time.

12 Q. So you just decided to keep the business model

13 that the ladies were independent contractors and they

14 must pay house fees?

15 A. My dad was in business for decades.

16 Q. And you chose to keep his business model?

17 A. I left things as they were until, you know, it

18 became an epidemic of lawsuits, so -- and, you know, we

19 explored changes.

20 Q. So after, as you described it --

21 A. I don't know what year.

22 Q. What?

23 A. I don't know what year. I don't know what

24 year we started changing things.

25 Q. But it was after 2014?

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 A. Yes.

2

 Q. It wasn't from 2012 to 2014?

3

 A. No.

4

 MR. AKEMON: Okay. No further questions, Your

5

 Honor.

6

 THE ARBITRATOR: Okay. Mr. Brodsky?

7

 MR. BRODSKY: Let me have a minute with my

8

 colleague here. I think we're done, but I just

9

 want to check.

10 (Off the record.)

11 MR. BRODSKY: Your Honor, we have no further

12 questions.

13 THE ARBITRATOR: Very good. You're excused,

14 Ms. Galardi.

15 THE WITNESS: Thank you.

16 THE ARBITRATOR: So let's talk about

17 housekeeping going forward. I would like to get --

18 Mr. Akemon, if you could stay and just put exhibit

19 numbers on these documents, claimant's exhibits,

20 the ones that we haven't marked so that in case

21 anything happens to this notebook, which is already

22 falling apart, we know what's what.

23 And I'm going to bring in some alligator clips

24 as well to clip these things so we keep them

25 together. Your agreement on -- well, how long will

Page 250

1

 it take you to get a transcript prepared?

2

 THE COURT REPORTER: Seven to ten days,

3

 business days.

4

 THE ARBITRATOR: Seven to ten days you'll have

5

 a transcript.

6

 MR. BRODSKY: Did you say business days?

7

 THE COURT REPORTER: Business days.

8

 THE ARBITRATOR: Business days, right. And

9

 then you asked for -- was it 30 days?

10 MR. BRODSKY: Yes.

11 THE ARBITRATOR: So let's just pick out --

12 pull out a calendar here. So from the time you get

13 the transcript, when would you like to make your

14 submission?

15 MR. BRODSKY: 30 days.

16 MR. AKEMON: 30 days after we receive the

17 transcripts.

18 THE ARBITRATOR: So if you get the transcript

19 by April 1st, then we're talking about essentially

20 April 30th?

21 MR. AKEMON: Yes, Your Honor.

22 THE ARBITRATOR: Will that work for you guys?

23 MR. BRODSKY: Yes.

24 THE ARBITRATOR: Okay. Post-hearing

25 submissions, you'll address the questions that were

Page 251

1

 raised in my e-mail factually and legally, and we

2

 will not have replies.

3

 You -- is the form -- I forget whether we

4

 talked about this. Do you plan to submit proposed

5

 findings of fact and conclusions of law or simply

6

 take the questions and make your arguments as to

7

 each question?

8

 MR. BRODSKY: That's what we agreed to.

9

 MR. AKEMON: Yeah. We agreed that we would

10 let Your Honor do that.

11 THE ARBITRATOR: Okay. So I'll just receive

12 your legal argument. And so what I'm expecting is

13 you'll tell me under Article 10 what you think the

14 outcome should be and why, under Section 448 what

15 you think the outcome should be and why.

16 On the willfulness question, the liquidated

17 damages question, whether you think the claimant

18 prevails or whether the respondent prevails, and

19 you'll go through the testimony and explain to me

20 why.

21 And then you'll explain whether this last

22 question that you just asked about tips from

23 customers, whether that's to be taken into account

24 or not taken into account in any calculations. Now,

25 have I left anything out?

Page 252

1

 MR. AKEMON: Yes, Your Honor. One other -- I

2

 believe the time that you asked us to --

3

 THE ARBITRATOR: Oh, yes. Whether it relates

4

 back to prior to December 1st, 2012. And that's

5

 the other issue. So those are the issues that I

6

 expect to see addressed. Everyone is clear on

7

 that?

8

 MR. BRODSKY: Yes, it's in your order.

9

 THE ARBITRATOR: Yeah. No, I just want to be

10 sure. If you have anything to raise, you can raise it

11 now.

12 So, number one, thank you ladies, all ladies.

13 All of our witnesses were ladies. It's women's

14 history month, so thank you very much for your

15 time.

16 Counsel, thank you very much for being so

17 professional and being so prompt and efficient. I

18 appreciate that. We got a late start, but we got

19 an early finish, which is always good. The hearing

20 will remain open until I receive your post-hearing

21 submissions, and that will start the clock for me

22 to get out my order under the AAA rules. I think I

23 have either 30 or 60 days. I forgot the time

24 frame.

25 But we'll start that clock from when I get

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 your submissions. Now, does anybody have anything

2

 else, going to claimant's side?

3

 MR. AKEMON: A couple quick questions, Your

4

 Honor.

5

 THE ARBITRATOR: Yes.

6

 MR. AKEMON: Should we address attorney's fees

7

 as well in this post --

8

 THE ARBITRATOR: Yes, we need to talk about

9

 that. My -- what I would prefer is that you

10 make -- you -- well, you prepare your claim, I

11 would provide it to the other side and find out

12 where there's objections or not objections, and

13 then you need to confer over that.

14 And then include in your submissions whatever

15 your differences are on any claim for attorney's

16 fees. I know that the respondents have asked for 

17 a hearing on that. It's very unlikely that I'll 

18 have a hearing on attorney's fees, but I'll reserve

19 judgment on that. I just don't think I have 

20 the time, honestly, to deal with a hearing for

21 attorney's fees. And it's just going to

22 add to your costs, which I don't think it

23 will make that much difference, honestly, in my

24 experience.

25 Attorney's fees in arbitrations, I have yet to

Page 254

1

 hold a hearing, and I really think it would run up

2

 both of your expenses. So my inclination is not to

3

 hold a hearing. How long will it take you to

4

 prepare whatever it is that you believe you would

5

 be entitled to, Mr. Akemon?

6

 MR. AKEMON: Well, if I could get a little

7

 clarification, would you like me to include it in

8

 the post-hearing brief or --

9

 THE ARBITRATOR: Yes, I'm afraid you have

10 to do that as well.

11 MR. AKEMON: Okay. I'll include it in the

12 post-hearing brief then.

13 THE ARBITRATOR: Yeah. You can put in a

14 placeholder there, but it's not going to be -- at

15 the end of the day, that's not going to be that

16 material compared to all the times for the hearing

17 and prehearing.

18 So I would put something together that

19 explains to counsel on the other side what it is

20 that you've done, what rate that you think you're

21 entitled to. I would compile your costs and submit

22 it.

23 Obviously, there will be issues over how much

24 you prevail on or don't prevail on. I'll take that

25 into account, obviously, when I issue my award. But

Page 255

1

 I would like to do this once, frankly.

2

 So I don't -- while you're waiting for the

3

 transcript to come, maybe that would be a good

4

 exercise for you to put together your attorney's

5

 fees claim and get it over to Mr. Tobin and Mr.

6

 Brodsky. And if they have questions, they can

7

 inquire, obviously, and I would encourage you to

8

 talk those things out, because the more that you

9

 communicate with each other, the less you'll have

10 to argue about it, or at least the more focused

11 your argument will be.

12 And then you can cover in your post-hearing

13 submissions what those claims are. If you have any

14 difficulty with this --

15 MR. AKEMON: No, Your Honor. May I include an

16 affidavit from an attorney regarding fees?

17 THE ARBITRATOR: You may, but if you have any

18 issues -- you want to get that to them in case they

19 want to have a counter-affidavit. But if there are

20 any issues on the process, send me an e-mail and

21 we'll get on the phone if you're having any

22 difficulty.

23 Because I don't want this to be something that

24 you argue over. You have your conversations, your

25 communications. If you have differences, state

Page 256

1

 your differences. It seems like you guys get along

2

 pretty well.

3

 But if the process requires you to talk to me,

4

 shoot me an e-mail and we'll get on the phone. I'm

5

 just trying to truncate this so that we build all

6

 this into your post-hearing submission and not have

7

 to do another submission after that. That's my

8

 goal.

9

 And I believe from just being with you guys

10 today that you seem to get along well enough that

11 you can have those communications, as long as you

12 can get the information to them.

13 MR. AKEMON: Yes, Your Honor.

14 THE ARBITRATOR: And let them reflect on it,

15 ask you questions, and if you have an affiant, by

16 all means, share that with them. If they have a

17 counter-affiant, they can have one prepared, and

18 I'll receive your affidavits, I'll receive your

19 submissions as part of your post-hearing

20 submissions.

21 In terms of numbers of pages, I don't really

22 believe in page limits for something like this, so

23 whatever it takes you guys to write is fine with

24 me. I just ask you to be as succinct as you

25 possibly can; that's my only request is just be

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1

 succinct.

2

 You know, if you need the pages, take the

3

 pages, but try to be succinct. I'm not going to be

4

 critical if you end up writing 40 pages. I'll be

5

 really happy if you write 20, but if it takes you

6

 40, it takes you 40. I'm not going to be difficult

7

 over the length. You've worked very hard. The

8

 case is important to both sides, I recognize that.

9

 So I'll give you every opportunity to make all

10 of your arguments, and I'll study them quite

11 carefully. So, ladies, however I rule, I want you

12 to know that I enjoyed being with you-all today.

13 But I'll deal with the evidence, and I'll deal with

14 it as fairly as I possibly can. And that's my

15 commitment. Anything else? Did you have another

16 issue, Mr. Akemon?

17 MR. AKEMON: No, Your Honor.

18 MR. BRODSKY: I have two questions.

19 THE ARBITRATOR: Sure.

20 MR. BRODSKY: And one relates to the

21 attorney's fees issue. So Mr. Akemon is going to

22 give me -- or give us, within when I don't know, a

23 request for attorney's fees, basically, from you,

24 for your award to him, and then we're to respond to

25 that in the final submission?

Page 258

1

 THE ARBITRATOR: Yeah. To the extent there's

2

 disagreement, address whatever you disagree about.

3

 MR. BRODSKY: Okay.

4

 MR. AKEMON: So to piggyback on that question,

5

 so would you prefer after I send it to him that

6

 we discuss whatever disagreements first --

7

 THE ARBITRATOR: Yes, please discuss your

8

 disagreements, and then whatever your differences

9

 are, that will allow you to focus in your

10 post-hearing submissions. For example, you pick a

11 rate, an hourly rate.

12 You think it's too high, you guys talk. And if

13 you can't agree, then I know that the rate is going

14 to be an issue that you'll address and you'll

15 address in your post-hearing submission. There may

16 be a debate over hours, the number of hours spent.

17 Mr. Brodsky may feel it was excessive, you may feel

18 it was quite appropriate.

19 I will take into account in evaluating your

20 claim, Mr. Akemon, where you succeeded and where

21 you have not succeeded, so you may need to take

22 that into account as you present your request. But

23 these are things that you guys can talk about. You

24 may agree, which would be great if you could 

25 agree. But if you can't, that's what I'm for. 

Page 259

1

 But I just want you to be focused in your

2

 submission on whatever it is that you can't agree

3

 on. You may disagree on everything, which is okay

4

 also.

5

 And just make your arguments. That's okay,

6

 too. I'm not asking you to give in on anything. I

7

 just want you to get the information to them, let

8

 them look at it, communicate, confer. If there's

9

 agreement, great. If there's disagreement, so be

10 it.

11 Then you at least know what you're going to be

12 writing about. And if you need me to help you 

13 with that process, let me know, and I'll get on the

14 phone with you. I don't want you to spend time

15 arguing; I want you to spend time talking and

16 seeing if you can agree.

17 MR. BRODSKY: The only other issue I have 

18 is when I walk out of here today, I just want 

19 to know what exhibits are in evidence, 

20 and --

21 THE ARBITRATOR: All the ones in your

22 notebook, assuming they are the same ones in my

23 notebook.

24 MR. BRODSKY: I don't mean it that -- I'm

25 talking about the ones specifically -- that

Page 260

1

 specifically were marked.

2

 THE ARBITRATOR: They are all going to be

3

 marked after the hearing. I'm going to mark them

4

 all carefully.

5

 The ones that are labeled with these tabs are

6

 going to be marked with the same number, and they

7

 are going to match the claimant's exhibit list C

8

 whatever through C27 with the understanding that

9

 there is no 25. And your exhibits will be marked

10 as -- well, are these the same letters? I guess

11 they are.

12 So your Respondent's Exhibit 1, 1A, 2A, 3 and

13 3A, have all been admitted.

14 MR. BRODSKY: So, in other words, I can take

15 the claimant's proposed exhibit list under

16 certificate of service March 15th with the

17 understanding that C23 is there's an A and a B,

18 which are the presuit notices, and there's no 25?

19 THE ARBITRATOR: That's correct.

20 MR. BRODSKY: I can refer if I need to to

21 those exhibits the way they are otherwise in that

22 exhibit book?

23 THE ARBITRATOR: They are the same as your

24 Respondent's Exhibits 1 and 1A. So you can pick

25 which ones you want to refer to. They are the same

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1

 exhibits.

2

 MR. BRODSKY: I'm talking about, for instance,

3

 if I want to refer to C18, I can just refer to C18

4

 as it is in the exhibit list?

5

 THE ARBITRATOR: That's right.

6

 MR. BRODSKY: Okay. That's what I wanted to

7

 know. Thank you.

8

 THE ARBITRATOR: Okay. We're adjourned for

9

 now until I receive the post-hearing submissions.

10 MR. BRODSKY: Thank you.

11 THE ARBITRATOR: And I'll formally close the

12 hearing, assuming nobody has anything further.

13 MR. TOBIN: Thank you for your time.

14 MR. AKEMON: Thank you for your time, Your

15 Honor.

16 (Thereupon, the proceeding was concluded.)

17

18

19

20

21

22

23

24

25

Page 262

1

 CERTIFICATE OF REPORTER

2

 - - -

3

4

 I, Stephanie Anez-Arriechi, Court

5 Reporter, certify that I was authorized to and did

6

report the foregoing proceedings and that the

7

transcript, Pages 1 through 262, is a true and complete

8

record of my notes.

9

 I further certify that I am not a

10 relative, employee, attorney or counsel of any of the

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

12 parties' attorneys or counsel connected with the action,

13 nor am I financially interested in the action.

14

15

16 Dated this 20th day of April, 2021.

17

18

19

20

21

22

 ___________________________

 Stephanie Anez-Arriechi

23 Court Reporter

24

25

Case 1:20-cv-23230-AMC Document 136-1 Entered on FLSD Docket 10/25/2021 Page 66 of

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Page 263

A

A-K 65:20

A-K-I-N-Y-E-L-E

65:24

a.m 1:16 104:12,13

104:19 105:7

AAA 252:22

abide 51:9

abilities 118:20

ability 5:6 18:11

30:12 179:23

195:10 205:23

234:16

able 4:12 21:13,23

86:21 110:14 112:2

123:16 154:17

180:22 216:18

231:5

aboard 88:13

absolutely 179:25

181:14 185:14,16

185:19 226:19

abuse 146:1

abused 145:19

accept 119:9 232:6

accepting 169:15

accidentally 38:9

account 60:8,9 61:1,3

61:17,21 62:10,10

251:23,24 254:25

258:19,22

accounting 160:11

accounts 234:8

accurate 31:2 88:15

acknowledge 225:9

225:11

acknowledged 156:8

action 240:20,25

262:12,13

actual 26:12 56:11

244:7

Adams 65:12 67:6

78:16,23 79:3,20

80:3 148:20 181:24

182:24 198:1,4

200:10 218:25

222:12,15,17 223:9

223:12 224:2 225:2

225:14 227:6,20

229:17 230:19

231:22,24

add 7:10 29:13 50:10

54:10,13 58:13

169:17 253:22

added 40:17 48:25

68:24

adding 57:18 99:10

addition 25:19 87:3

95:6 164:15 204:9

additional 78:21

204:5

additions 203:22

address 6:5 250:25

253:6 258:2,14,15

addressed 116:1,3

252:6

adjacent 210:14

adjourned 261:8

administratively

103:16

admissions 226:10

227:1,12,25 229:23

admit 81:8 85:21

88:18 110:3 119:2

119:14,19 241:2,5,7

241:10

admitted 81:4 110:1

119:17 120:8,8,21

165:22 227:18

228:15 229:8,12,16

229:20 241:9,11

260:13

adult 143:14 144:11

193:7,21 196:19,22

196:24 214:12

advance 12:22

advertise 55:3

advertising 54:25

advice 177:21

affect 62:19 173:2

affiant 256:15

affidavit 255:16

affidavits 256:18

Affiliate 86:3

afford 178:20

afield 123:11

afraid 254:9

afternoon 122:5,6

170:14 194:14,15

ago 23:25 50:24,25

51:13 52:6 56:5

71:4,6 74:14 76:6

122:19 123:3 239:2

agree 124:6 216:13

228:16 258:13,24

258:25 259:2,16

agreed 3:24 118:10

191:21 251:8,9

agreement 68:8,21

108:18 182:11,24

183:7,8 189:16

190:25 191:2 193:2

193:6 195:8 196:12

196:14 200:6,7,9

219:1 220:22

221:15 222:21,24

223:9,11 225:3

230:24 231:11,18

232:7 233:22

238:12 249:25

259:9

agreements 193:17

215:14 216:24

234:4 238:9

ahead 5:8,23 7:11

13:7 29:5 39:3

66:12,21,22 77:14

79:25 92:9 120:13

151:11 170:10

177:18 201:5

202:15 216:5

234:13

air 73:11 96:7 160:19

179:3

Akemon 2:4,14,15,17

2:18,20 3:9,9,20 4:6

5:12,24 6:8,13,20

7:8,12,22,25 8:17

10:25 11:23 14:16

14:25 16:14 18:4

23:19 25:6,8 26:23

27:13 29:21 30:20

30:22 31:5,8,13,18

31:25 32:9,14,19,25

33:8,17,21,23 34:2

34:13,19,21 35:1,4

35:11,18,24 36:3,6

36:13,18 37:2,5,7

37:11,16,19 38:5,9

38:12 39:4,20 40:1

40:3,6,10,13,18,23

46:22 49:15 55:20

55:22 59:4 61:7,10

62:16,24 63:9 64:9

64:22,25 65:5,22,25

66:14 69:17 70:4

74:3,5 75:2,9,15,16

76:17 77:14,15 78:5

78:7,8,12,20,22

79:14,15,16 80:2,16

80:19,21 81:3,7,20

83:17,20,21 84:24

85:2,10,13,21,24

86:10 87:3,7,9,13

87:22,25 88:2,18,20

89:24 90:14,24 91:6

95:12,16 102:19,20

103:8,17,18,23

104:15,22 106:4,15

106:18,24 107:2,9

107:12,14,19 108:1

108:3,6,11,14,22

109:4,11,13 110:1

110:25 111:8 112:9

117:19 118:18

120:6,22 121:15,18

121:21 123:10

124:3 125:11

132:20,23 135:21

137:19,24 138:2,10

143:25 145:20

146:24 147:13,20

149:9 151:9 156:11

159:14,16,18 166:8

166:12,15,18,20

167:1,5,10,16,23,25

168:5,8,12,15,18,20

169:1,9,10,14,17,18

194:9,10,12,16

195:3 197:10,11,12

198:10,11,21 199:5

199:6,19 200:5,20

200:24 201:4,7,12

201:16,19,20,23

202:2,6,24 203:14

203:15,16 207:25

208:2,13 209:3,8,11

210:16 212:3,14

213:7,9,11 214:3

216:7,17 217:1

223:7,25 225:19,21

225:22 226:1,2,10

226:14,17,24 227:2

227:3,14 228:6,10

228:22 229:4 230:5

230:8,12,14,16

232:15 233:7,8,12

233:16 236:1,4

237:17,22,24 238:2

238:7 239:2,6,14,23

241:2,5,8,12,16

242:5,10,14,16,18

245:7 246:3 249:4

249:18 250:16,21

251:9 252:1 253:3,6

254:5,6,11 255:15

256:13 257:16,17

257:21 258:4,20

261:14

Akinyele 60:24 65:12

65:14 67:16,24 68:3

73:19 78:1 79:2,17

79:20 85:16 88:12

94:22 111:21 116:3

116:8,10,16,23

117:9 128:12,13

132:2 148:20

150:21,22,23,24

162:14 163:10

181:24,25 182:12

182:24 183:6,9

184:16,17 198:1,4

200:10 218:25

222:11 223:12

224:2,14,16,17,20

224:24 225:1,13

227:20 229:17

230:19 231:22,24

233:22,24 246:7

al 5:25

Albanez 209:23 224:7

alerts 91:13,17,18

allege 221:11 233:13

alleged 221:4 223:9

247:7

alligator 249:23

allow 6:7 55:23 59:5

59:7,22 64:12,14

65:3 69:18 85:23

88:19 125:13

134:11 145:23

146:25 149:10

219:23 246:5 258:9

allowed 16:10 45:20

47:1 59:17 67:23

97:5,9,22 125:12

154:23 197:19

199:11 237:2

239:12

Allure 123:21,22

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146:20,21,22 147:1

147:2,8,8,22,24

148:5,8,9 149:7,13

149:20

America 61:24

AMERICAN 1:1

amount 10:14 14:1,4

15:2 16:1 22:13

40:7 45:1 68:15

74:20 76:1,3,9 93:8

101:22 104:3 111:4

114:22,24 125:18

132:9,11 134:10

135:16 151:15

152:20 154:19

155:21 156:13

157:1,5 182:17

183:8 235:8,10,20

amounts 30:2 159:20

ancillary 179:1

and/or 23:24 216:9

217:12

Anderson 232:18,23

232:24

aneurysm 239:7

Anez-Arriechi 262:4

262:22

annoying 42:1

annual 201:24 202:8

202:19

answer 59:6 61:18,20

61:23 62:22 69:20

78:14 79:24 104:18

104:20 125:15,15

125:23 143:17

147:20 148:1

151:11 152:14

191:13,14,16

211:25 212:19,24

213:2,4 223:16,22

223:23 229:1

231:19 235:1

240:14 243:21,23

244:2 245:23

answered 70:5 78:15

78:15 146:2,8,9

149:23 150:15

151:9 213:24

225:18 233:5 241:3

246:2

answering 49:25

216:19 243:4

answers 7:6,20 61:25

124:5 149:5

anybody 4:25 40:23

64:4 124:14 140:16

162:13 196:1 217:8

253:1

anymore 122:18

anyplace 48:7

anyway 187:19

apart 249:22

apologize 131:16

167:11,13 200:15

200:17 233:9

apparently 38:23

107:17 109:2,10

243:23 244:3

appear 126:3

appearances 2:1 3:7

appeared 160:17,19

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appreciate 7:15

111:2 232:10

252:18

approach 30:20

38:19 75:2 154:20

185:22

appropriate 86:24

216:20 258:18

approximate 39:21

39:22 136:4

approximately 8:19

14:14 28:22 44:1

76:6 88:6 130:24

152:15 160:1 180:7

181:9 182:23 183:2

183:5

approximation 84:11

April 33:20 34:6 41:6

181:25 182:25

183:2,5 220:11

222:12 233:25

250:19,20 262:16

arbitration 1:1,2,13

15:16 87:11,20

90:23 117:8 189:9

189:16,22,25

191:17,21 193:2,6

193:17 195:7

196:12,13 230:21

230:24 231:1 234:4

236:15,25 237:5

238:9,12 240:8,14

247:6,9,14,18

arbitrations 253:25

arbitrator 3:3,6,11

3:16,22 4:8 5:3,5,8

5:14,20 6:8,15,21

7:9,14,23 8:10,13

10:19,21 11:4,7,12

14:10,20 16:5 17:8

17:11,14 23:12 25:5

25:7 26:5,9,14,18

26:21 27:11 29:12

29:17 30:21 31:15

31:20 32:5,10,16,22

33:3,11,19,22,24

34:4,11,16,20,22

35:10 36:1,5,12,14

36:20 37:3,6,8,13

37:21,24 38:7,11,14

38:17,20 39:13,15

39:17,24 40:2,4,11

40:15,19 41:2,4

46:24 49:13,23

55:21,23 56:22 57:3

59:5 60:13 61:9,12

62:17,25 63:10

64:12,24 65:6,17,24

66:1,6,8,10 69:13

69:18,24 70:7 72:17

72:22,24 73:3,25

75:3,6,10,14 76:11

76:16 77:2 78:4,14

79:5,13,24 80:17,20

80:23 81:5,8,18

83:17 85:4,23 86:5

87:1,5,8,11,16 88:1

88:19 89:19,22

90:12,17 91:3 95:11

95:14 102:18,21,24

103:1,5,9,21 104:10

104:13,18 105:22

105:25 106:11,16

106:19 107:3,11,13

107:17,22 108:17

108:20,23 109:1,5

109:12 110:3,17,23

111:7 112:8 117:12

117:17,20,23 118:2

118:13 119:2,14,18

119:24 120:12,19

120:25 121:13,20

121:22,25 123:11

123:17 124:5

125:12 131:14

132:21,24 133:4,6,9

133:12,17,19,20,24

134:3,5 135:23

136:18 137:2,7,11

137:16,22 138:3,23

143:6 144:2,15

145:23 146:4,7,25

147:15,22 148:23

149:1,4,10,23 150:2

150:5,9,15 151:10

151:21 154:22

155:1,3,8 156:4,12

156:16,21 158:9

159:2,6,11,14

165:20 166:9,13,17

166:19,24 167:3,8

167:11,18,21 168:3

168:7,11,16,19,22

169:4,6,15,19,25

170:4,8,22 178:11

185:23 186:1,4,16

187:1,8 188:16

189:2 190:8,11

192:9,11,14 194:8

195:1 197:9 198:9

198:17 199:3,16,20

199:24 200:4,17,22

200:25 201:5,9,18

201:21 202:1,4,15

202:20,25 203:3,10

203:13 204:2 207:9

207:19,24 208:10

208:14,18,20,25

209:3 212:15 213:8

216:15,18 217:2

219:20,23 223:14

225:18,25 226:3,6

226:11,15,19,23

227:1,25 228:4,8,13

228:19,24 230:4,6,9

230:13,15 232:4

233:6,10,15 236:5

237:16,19,23,25

238:4,20,25 239:4,8

239:11,16 241:7,9

241:13 242:4,8,12

242:15,17 243:6

244:7,12,15,18,22

245:3,6 246:5 249:6

249:13,16 250:4,8

250:11,18,22,24

251:11 252:3,9

253:5,8 254:9,13

255:17 256:14

257:19 258:1,7

259:21 260:2,19,23

261:5,8,11

area 65:3 76:22

argue 158:9,10

241:14 255:10,24

arguing 259:15

argument 251:12

255:11

argumentative 214:2

arguments 7:4 65:2

251:6 257:10 259:5

arrangement 80:10

246:8

arrive 10:8 91:11

94:9 115:12

arrived 11:25 30:4

101:25 102:2

113:23 114:23

Article 251:13

artist 182:3

asked 6:5 14:20

56:25 62:3,4,6 70:4

70:17 74:22 75:10

77:3 79:9 86:22

110:25 124:13

147:24 148:23

150:25 151:9,10

179:1 198:18

212:20 217:14

232:22 233:5

240:11 242:21,22

243:1,25 246:2,3

250:9 251:22 252:2

253:16

asking 27:24 28:5,8

29:22 30:14 39:6,8

40:7 44:14 58:15

62:8 70:11 74:15,16

74:19 75:19 76:8

78:10 93:4 101:18

102:11 103:24,25

104:3 152:9,10,11

217:6,7 232:5

236:20 238:6 240:3

242:20 259:6

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aspirate 173:6

assign 12:17

assigned 44:22 48:21

assist 18:12 176:9

associate's 171:10

ASSOCIATION 1:1

assume 61:12 117:14

125:14 210:5

assuming 228:25

259:22 261:12

Atlanta 129:3 174:23

174:23 175:8 192:3

192:3,9,10,18,19,24

196:2 197:24 198:5

198:14,22 199:18

212:2 219:9

attached 107:17,19

243:4

attempt 28:11 30:1

101:22 234:1

attempted 21:11,25

97:12,19,20,24

111:12

attempting 144:9

attend 85:16 94:14

127:14 247:13

attended 105:9,10

128:11

attending 122:17

attention 83:7 191:18

attorney 3:9 31:3

152:1 194:16

237:10 238:9,10

248:3 255:16

262:10

attorney's 253:6,15

253:18,21,25 255:4

257:21,23

attorney/client

238:16

attorneys 262:12

audition 10:3 82:11

82:14,16

auditions 10:5

August 29:19,20 49:9

49:14 172:16

authority 195:23

196:3 205:24 206:1

206:6,12,15,17,24

213:19,20,22

216:22 217:9,13

231:13,15,20 234:7

234:16

authorized 262:5

automatically 92:25

average 14:13 15:2,4

22:13,15,16 23:6

24:15 48:23 74:20

75:25 76:9 90:7

91:10 93:12,13,18

94:8 101:12 112:12

114:18,22 115:1

131:1,21 139:24

140:1

avoid 6:7

award 30:14 39:8

76:9 254:25 257:24

aware 6:2 38:24

62:19 119:4 124:16

B

B 37:6 169:6 260:17

baby 122:19

back 11:24 16:13

18:22,22 20:16

21:17,23 22:12,18

28:25 29:7,7 31:9,9

38:18 41:4 42:17

49:23 50:4,5,19,23

60:17,22,25 62:11

62:13 65:9 67:18

68:10,18 70:9 79:1

82:19 89:18,19

93:14 98:7 111:18

112:25 116:5 118:4

121:20,22,23,25

123:15 126:4 134:2

134:5 135:2 142:4,5

173:13,24 174:22

174:24 175:9 177:3

183:5 184:22

200:10 219:14

226:23 232:8

237:20 239:15

252:4

background 171:9

179:22

backs 193:10,24

bag 105:20 106:2

129:17 157:16

163:15

bags 13:24 73:14

98:12 129:9,10

159:20,22

bands 98:6

bank 60:8,9 61:1,3,16

61:19,21,23,24 62:1

62:2,10,10 234:7

bar 67:18,19 76:22

76:22 77:20 174:1,4

174:8,12 178:15

184:10,15 193:10

193:24

Barkett 1:13 3:6

133:5,20

bars 179:25

bartenders 189:17

based 179:21 183:6

basically 22:8,24

40:14 98:23 100:18

113:4 117:4 257:23

Beach 68:3 192:25

Beck 247:2,9,13

beer 215:10

Beers 174:4

began 10:7 82:21

83:11

beginning 12:5 91:8

91:21 180:2,12

181:21 184:2,3

188:3

behalf 2:2,5 3:14 41:8

41:9 213:23 229:18

belabor 181:11

believable 141:21

believe 11:3 25:13

33:8 38:13 89:9

110:21 137:20

174:15 187:10,13

200:14,14 209:16

223:12 224:25

226:24 231:19

232:24 246:3 252:2

254:4 256:9,22

believed 231:13,15

Bella 245:15

belong 107:9 120:3

benefit 44:19,20,22

benefits 217:19

best 4:24 15:21,25

16:15,17 19:20,23

55:7 77:22 90:3

99:23 101:4 120:11

133:19 142:13

143:10 144:10

246:16,18

better 158:5

Beyonce 49:12

beyond 198:8

big 52:20,20 110:12

110:13 112:16,23

165:15 177:11

180:7

bill 63:4,12

bills 68:22 98:19

105:23 110:13,14

binder 36:11 137:19

137:25 200:21

241:25 242:1

binders 36:9,10

biopsy 173:11

birthday 29:18

141:13,15

birthdays 141:19

bit 19:4 78:18 106:12

192:6 199:4 200:16

209:1 215:24

black 42:23 60:10,15

blank 85:5 87:20

board 78:23 116:10

116:16,23 117:9

193:9 233:24

Bob 209:14,15 223:3

223:9,12 224:18

boils 142:13

book 34:9,12 70:25

71:3,6,8,11,13,14

107:15 108:13,21

174:10,17 178:4

210:21 260:22

bookkeeping 178:18

books 118:18

booths 180:17 181:2

boss 128:13,14,15,16

128:16,17,18

bother 90:18

bottom 204:20

bought 174:10,11

178:13,25 180:10

182:7

Boulevard 2:6

bran 239:7

break 13:2,3 38:1

40:21,23 41:5 58:16

80:20,25 103:12

117:13 122:20

132:15 226:20

breakdown 153:20

breaking 84:4

breaks 170:9

brief 5:12 7:7 254:8

254:12

briefs 7:18 118:11,15

bring 37:25 106:20

154:22 249:23

bringing 213:5

Brodsky 2:8,19 3:13

3:13,17,21 5:2,4,19

31:6,7,11 32:3,20

32:23 33:10 34:9,25

35:3,6,16,20 37:10

37:17,23 38:3,6,16

38:19 40:25 65:17

65:19 69:12 75:4,12

76:15,25 77:12

78:13 79:23 84:23

84:25 85:3,11,12

86:8 87:13,15,20,23

102:15 106:22,25

107:15,23,24 108:2

108:4,9,13,15,19,24

110:19 117:22,25

118:7,24 119:11,16

119:22 120:10,14

120:24 121:10,17

133:8,11,22 134:1

138:1 149:25 150:3

151:19 154:20,25

155:2,4,7,8,10

156:8,19 167:19

168:24 169:2,5,13

169:20,22 170:1,5

170:13,20 171:3

185:25 186:3,5,18

187:2,6,9 188:18,25

189:4,6 190:15

192:16 194:7 198:6

199:1 201:13

202:12 203:6 207:6

207:22 208:8 209:1

209:6,9,10 210:15

212:9 213:24 216:5

216:11 219:22

223:5 226:3,5,8,16

227:12,13,22 228:1

228:16 233:5

235:23 236:2

238:13,24 239:1,9

242:25 244:8,10,13

244:17,20,25 245:4

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245:5 246:2 249:6,7

249:11 250:6,10,15

250:23 251:8 252:8

255:6 257:18,20

258:3,17 259:17,24

260:14,20 261:2,6

261:10

broke 182:17

brought 191:18

bucket 16:9 21:5,6

bucks 143:24

build 256:5

building 63:19 64:7,8

125:5,10 178:9,21

178:22,25 180:7

182:16 183:18,25

210:13,14

Burnside 206:14

207:17,18

business 64:17 69:23

69:24 173:25 174:2

174:7,9,13 175:10

175:13,22,24 176:6

178:24 179:21

183:17,25 185:20

187:13 190:12

199:15 200:22

201:22,23 208:1

210:3,20 213:18

214:8,9 215:22

216:2,8,23 217:5,9

217:13 218:11,13

218:16,20,23,25

219:2,5 233:23

235:9,12 236:10

245:25 246:8,24

248:12,15,16 250:3

250:6,7,8

businesses 175:16

177:7,22 178:4,13

179:18 185:12,17

191:25 196:17,17

196:18

buy 100:21 182:1,5,6

222:19,20

buyer 182:21

buying 174:9,10

C

C 87:8 230:8 260:7

C1 200:20

C10 237:15

C18 227:12 261:3,3

C23 260:17

C24 106:10,24

107:14,15

C26 167:23,23

C27 168:3 260:8

C6 87:4,6,7 88:18

calculate 28:12 30:1

30:2 54:5 75:24

101:22 110:13

calculated 28:16,18

30:11 54:6 151:18

151:25 152:15

calculating 76:3

calculations 58:14

74:24 148:9 152:7

251:24

calculator 54:5

calendar 48:23 50:4

54:11 141:22

250:12

calendars 50:16

California 171:21

call 4:6 11:9,11 15:16

46:20 47:2,5,10

74:1 80:21 86:22,24

90:17 117:18,21

133:6,10 140:21

143:3 175:6 184:3

called 12:3 95:9,11

174:4 202:1 206:21

calls 132:20,23

143:25

calm 223:24,24

cancer 172:9 173:9

capable 216:19

car 24:22

card 234:11

cards 60:10,10,11,15

care 23:1 68:24 124:8

124:9 133:9 162:19

191:8

carefully 190:25

191:2 257:11 260:4

Carolina 192:4,24

carpet 180:17,24

221:21

carpeting 181:2

case 1:3 5:23 6:14,18

7:15 8:11 28:5 36:2

36:8 58:9 62:20

74:2 101:23 144:8

169:17,21 194:20

194:20,23,24 195:4

202:16 210:17

216:13 219:11,17

219:25 220:2

221:11,14 233:2,3,4

247:2,3 249:20

255:18 257:8

cases 213:14,17

cash 60:11,17,21

61:16 157:17,20,20

cashing 60:16

caused 229:9

CDs 182:3

Cedeno 224:22

227:20 229:6,11,18

celebrities 92:5

celebrity 13:17,18

certain 10:14 11:18

11:19 19:24 45:1

59:18 68:15 82:24

114:24 125:17

certainly 5:20

certificate 260:16

262:1

certified 240:19

certify 262:5,9

cetera 93:23

CFO 191:7 209:13

chair 4:9

challenged 103:16

118:20

chance 30:1 46:17

161:20 182:9

change 12:25 115:24

196:11 204:7 217:9

217:13 218:11,14

218:16,20,23 219:5

227:5,9,17 228:11

233:18 234:1

245:25 246:4

changed 20:22 35:13

41:7 58:11,12 116:4

117:2 196:9 203:24

233:20

changes 169:23,24

203:23 204:5

248:19

changing 232:12

248:24

chaos 160:23

characterize 181:8

charge 30:7 68:9

125:2 177:14

charging 45:25

charitable 59:3,11,12

chart 245:13

Chase 61:24

chatter 145:13

check 13:23 60:16

105:19 106:2

157:19 249:9

checks 122:25 157:17

234:12,15,17

Cheers 174:5

Cheetahs 191:15

192:3,25 197:4,5

Chicago 175:5

chief 212:16

choose 18:8,11 99:17

127:20 186:2

chose 127:19,20

248:16

Christmas 122:20

circulated 238:9

cities 193:25

city 145:14 197:19,20

claim 4:4 55:15,16

253:10,15 255:5

258:20

claimant 1:5 35:7,21

107:16 110:21

251:17

claimant's 34:23

84:21 85:6,22 87:9

108:25 165:24

168:16 186:7,15

189:8 193:4 200:14

201:4,6 225:24

226:14,25 238:1,1,4

249:19 253:2 260:7

260:15

claimants 2:2 3:5,8

4:6 184:9

claiming 55:17 57:24

claims 4:1 208:4

255:13

clarification 32:4

254:7

clarification's 166:21

clarify 35:24 98:13

clarity 75:21

class 240:20,25

cleaning 114:8

clear 31:12 90:12

119:12 120:11

228:9 243:18 245:4

252:6

clerical 118:20

clerk 138:21

Cleveland 172:10,11

client 40:25 170:2

238:18

Clincy 219:9

Clinic 172:10,11

clip 249:24

clips 249:23

clock 252:21,25

close 13:4 42:4 104:9

226:4 261:11

closed 8:23 25:14,15

42:5,6,7 104:10

118:14 174:5 176:4

197:14

closer 173:16

closes 104:19

closings 118:12,13,14

clothes 20:4 82:11

club 8:19 9:24 10:23

11:16 12:20 15:21

16:1 19:8,11,21

20:11 21:12 22:23

23:24 24:24,25 25:3

25:9,14 26:1,2,11

26:14 27:22 42:23

43:3,9,18 45:2,22

46:5,9,15 47:13

51:2,22 52:1 58:23

60:24 66:17 67:7,9

67:13,20,25 68:4,7

68:7 71:21 77:17,20

81:24 83:5 92:5,6,7

95:3,8,22,24 98:22

99:24 101:6 104:9

104:10,19,23

111:12,25 112:4,16

113:24 114:2

116:20 124:15,20

124:24 128:6,7

129:14,21 131:5

138:16,19,22,23,25

139:7,8,9,10 143:10

144:7,10 145:10

146:12 147:14

149:12,15 153:3

157:7,14 159:10

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162:12,13,16 163:1

165:11,15 179:9

181:12,22 182:12

182:16 183:2,6

184:10,19 189:9

192:21 193:16

196:19,20,22,25

198:2 210:24

215:16,24 219:9

220:3,4 221:23

222:19,20 227:5,18

228:11

clubs 42:19 47:14,15

86:3 143:14,18,23

191:8 192:20 193:1

193:7 194:1 196:9

196:14 211:12,18

212:2,23 214:10,12

214:18,24 215:1,7

215:10,20 217:10

240:10 246:11,14

246:15,18 247:22

collaborate 195:19

colleague 154:20

249:8

collect 96:15

collected 69:2,6 96:18

97:20 161:13,19

collection 164:16

college 173:22

color 242:6

colors 181:4

column 107:8

columns 107:7

come 10:5,12 12:19

13:9,10,23 18:22,22

22:10,24 24:10,18

26:8 29:7 42:15

45:2,2,25 53:22

71:20 75:25 78:5,18

78:25 82:25 92:6

108:15 111:18

118:4 121:20,22,23

127:20,21,23 130:9

130:12 138:20

158:25 163:24

164:3,5,7 168:11

175:1,21 178:7

189:19,24 193:14

212:1 218:18

222:18 240:16

255:3

comes 19:16 133:24

comfortable 4:22

41:25 133:23

coming 4:19 26:2

35:13,14 46:4 82:7

88:7 99:13 165:15

173:13 191:1

command 177:12

comment 200:1

comments 118:8

commitment 257:15

communicate 176:23

255:9 259:8

communicating 176:9

communications

212:25 255:25

256:11

comp 218:3

companies 214:4,5

236:19,21

company 189:23

202:1 231:17

company-wide

189:17 195:8,16,22

196:4 198:13,14

231:6,11,16

compared 147:8

254:16

comparing 147:25

comparison 147:17

147:18

compilation 70:10

compile 254:21

complaints 240:15

complete 169:9

221:17 262:7

completed 171:10

completely 143:20

146:12,14 163:2

179:4 243:24 244:4

compliance 211:3,11

211:17 212:22

213:1 247:21 248:9

complications 173:12

compromised 176:15

computed 49:24

concern 119:25 121:2

concerned 84:2

118:18 120:4

concerns 116:1

concluded 261:16

conclusions 251:5

conditioning 179:4

conduct 86:3 210:20

conducted 175:13,24

176:6 178:24

conducting 175:22

confer 253:13 259:8

conferred 41:5

confirm 169:10

confirmed 163:21

confrontation 157:2

confused 33:16 35:17

85:7 121:9 146:6

167:20

confusing 31:16

confusion 151:20

connect 135:24

connected 112:25

262:12

cons 189:23

consent 36:10

consider 232:1

consist 20:20 84:7

consistent 29:2

consistently 9:20 23:4

constantly 128:4

construction 43:17

consult 149:25 150:6

150:7 195:19 248:3

consulted 191:19

Consulting 86:2

contact 247:25

contained 108:9

212:11

contemplate 49:5

contemplated 183:12

contention 206:2,4

context 228:17 245:3

continue 116:24

119:23 120:18

192:17 226:17

continued 175:2

continuing 207:2

contract 222:25

223:2,6

contractor 116:19,22

127:6 215:14

216:24

contractors 86:3

127:4 214:15 216:9

217:11,19,21,25

219:19 220:4

248:13

contracts 217:6

contribute 125:9

control 220:2

controlled 219:9

220:3 240:10

conversations 177:5

255:24

Cooks 193:24

Copies 107:2

copy 32:1 38:11 61:8

61:10 83:14 88:15

137:14 243:9,12

Coral 2:6

corner 242:9

corporate 234:23

corporation 191:10

200:23 201:22,24

202:8 206:9,22

210:4

corporations 179:19

187:12 206:16

207:3

correct 43:5,21,24

58:23 59:1 60:8

62:23 71:16 76:15

93:2 103:10 110:2

110:20 112:4

115:18 116:7

119:17 131:18

132:15 135:1,9,10

140:20 142:14

151:4 157:21 160:1

169:4,6 178:6

181:13 184:1,16

185:18 187:4,5,16

187:20 193:12

194:6 195:5,11,16

196:7,15 213:3

215:16 219:15

222:13,25 223:4

224:11 231:3,4

236:14 260:19

correctly 120:9

correspond 121:11

costs 253:22 254:21

costumes 100:22

couches 181:1

counsel 3:7,11 33:9

36:7 38:10 41:5

194:17,19 252:16

254:19 262:10,12

counsels 76:12

count 16:10 98:8 99:3

105:2 110:16

129:10,14,25 130:4

130:11,12 141:19

161:10

counted 97:3 130:15

130:16,18

counter-affiant

256:17

counter-affidavit

255:19

counting 130:7 155:3

155:6

couple 24:23 29:19

69:11 74:3 189:4

237:4 247:1 253:3

course 28:2 38:20,20

83:1 92:13 114:25

125:1 142:16

179:14 188:12

208:16

court 4:11,20 6:2,4

9:2,8 10:22 11:8,13

19:6 20:2,20 22:16

27:6 29:22 30:4,13

30:14 34:22 39:5,7

39:8 40:22 65:9,14

74:15,16,19 75:22

76:8 81:2,12 82:4

84:6,10 85:5,25

87:19 89:3,9 90:6

90:10,13 93:18

100:12,12 101:12

101:18,25 102:2,10

103:24,25,25 104:6

105:13,15 111:15

114:3,17,23 120:16

121:8 170:18,21,23

201:11 204:1,11,14

213:9 226:11 243:7

243:16 250:2,7

262:4,23

Court's 14:8

courtroom 90:23

91:4

courtrooms 90:25

cousin 178:16,16

210:20 245:17

cousin's 175:5

cover 86:14,17 183:9

255:12

covered 233:6

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COVID 103:21

200:18

coworkers 129:1

crazy 9:5 22:9 29:4

42:20 44:8 51:4

93:1,3 197:18

creation 140:19

credit 235:14,16,18

critical 257:4

cross 17:22 41:11

59:8 80:25 117:14

168:24 169:5 173:4

Cross-Examination

2:15,17,20 41:12

122:3 194:11

cross-motion 168:1,9

169:11

cross-motions 168:4

Cubby 174:11,14

178:4,14 210:21

curious 110:4

currently 197:22,23

198:1 214:24

236:16

cusp 49:10,12

cussed 98:2

customer 15:17 96:5

96:6 157:23

customers 15:7,11

25:16 26:2,12

110:12 153:18,20

163:16,24,25

164:13 246:13,20

251:23

cut 161:9 162:2

cutoff 13:11

D

D 21:21

dad 177:12 184:20

248:15

dad's 174:20 176:8

184:24 185:19

daily 141:22 224:18

damages 4:1 5:25 6:7

28:5,6,8,12 30:15

40:8 75:19 76:1

78:10 101:23

102:13 104:1,4

251:17

dance 27:4,6 42:9

45:9,10 86:12

100:17 143:16

163:17 235:21

236:8

danced 15:17 45:13

45:15 51:1 130:12

143:19 159:25

160:4 163:14

dancer 8:18 9:2 41:18

42:10,11 51:2,3

81:23 89:1,3 109:7

109:8 110:8 111:4

111:24 126:10,11

145:11 160:24

246:11

dancers 54:18 113:15

124:16 127:3

193:12,15 195:4

214:10,14,18 215:8

215:13 216:9,10,24

217:5,11,16,18,24

218:8 219:19 220:4

233:19 235:11,13

235:17,22 236:12

236:16,24 239:24

246:17 247:7

dances 15:16,19,22

96:4,5 235:21

dancing 8:21 43:2

50:24 55:15 98:17

129:12 130:23

131:4 144:12

153:10,22 163:5

193:16

Dane 237:11

Darden 5:25 31:10

Daryl 68:1

date 76:5 86:5 109:7

244:24

dated 32:24 34:6 41:6

86:6,7,8 107:8

169:2 262:16

dates 24:4 28:15

daughter 122:19,22

123:2

daughters 172:6

day 6:17 10:8 11:21

14:19 24:15 27:20

42:6 48:1,1,2 49:18

50:16,16 51:7,7,8

51:10 52:13 53:6,8

54:13 69:21 71:2,16

72:4 73:14 78:2

84:13 88:16 92:15

101:13 102:6

103:14 105:5,5,7

114:7 139:23,24

141:20 142:16

176:6 180:16

189:21 212:7 215:2

227:10 242:2,5,5

254:15 262:16

day-to-day 184:5

days 23:6,8,10,10,11

23:12,16,16,17

24:18,19,20 25:11

28:16,22 29:9,9,19

30:10 50:3,8,8

52:20 53:12 54:11

71:22,22 86:20 90:6

90:8,9 114:4 128:22

139:25,25 140:1,2,4

140:12 141:20,23

152:3 165:7,8,9,13

165:17,18 250:2,3,4

250:6,7,8,9,15,16

252:23

de 2:6

deal 46:11 67:25

68:24 146:18 223:1

253:20 257:13,13

dealing 234:4 235:24

dealt 33:15 211:13

241:21

Dean 239:21 240:2

death 175:22 206:5,7

206:12 208:7 215:2

234:5

debate 76:11 258:16

decades 248:15

deceased 238:24,25

December 122:23

171:17,18 175:14

175:19 177:24

179:8,11 185:11,17

187:22 205:16

215:2 217:4 218:9

233:25 236:3,4

243:20 244:10,16

245:25 247:22

252:4

decide 6:21 31:22

65:2

decided 163:4 189:24

248:12

decision 195:15,18

220:7 227:5,17

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195:13

declaration 14:6,7,15

32:6,12,17 40:12,13

40:16

declarations 3:25

declare 135:8 149:8

149:19

deduct 141:13,15,15

defenses 247:18

definitely 103:16

deflect 140:23 148:12

degree 171:10

delivered 103:20

Dennis 189:20 191:5

191:6,7,18 209:12

209:13 211:7

220:19 245:17

dense 120:12

dent 148:13

Department 187:11

248:1

depends 53:22 84:12

96:6 104:24 112:10

124:22 130:22

131:2,22,25 153:3,9

153:12

deposit 61:16

deposition 61:5,9

62:5,9 166:1,6,10

228:2,12 229:1

242:20 243:2

depositions 219:12

describe 9:1 10:2

12:1 20:2,17,19

22:15 30:4,13 39:7

43:7 95:1 100:12

105:13,14 106:5

109:9 112:15

160:15,17,18

162:21 177:9

201:18

described 20:10

241:17 248:20

destroy 74:10

details 233:3

deteriorate 172:25

175:3

deteriorating 176:9

deterioration 185:2

determination 17:1

140:11

determine 16:23

48:20,21 57:16 58:7

112:7,8 113:2

195:10

determined 19:24

50:3,9 57:18

dialogue 239:10

Diamonds 8:18,22

9:3,6,20 10:4,8,9

14:2 15:3,8 16:2

17:4 18:6,9 23:7,23

24:5 27:15,18 28:20

29:24 39:9 42:20,22

43:3,5,7 44:8 46:3

47:19,19,20,25,25

48:3,6,6 51:4 74:17

74:20 76:19 78:24

81:23 82:2,5,9,18

82:22 83:23 90:7

91:11 92:24 93:9

94:15 104:7 112:15

112:18,19 113:8,11

113:23 114:5 115:4

115:12 122:7

134:15 141:1 143:5

143:8,10 144:10,19

153:4 159:12

160:23 162:24

163:1 164:18

175:19 177:25

178:9,21,21 179:9

179:23 180:3,11,16

180:21,23 181:13

181:17 182:5,7,8

183:16 184:5,7

185:13 187:14

190:22 191:25

195:5 196:24 197:3

197:24 198:5,13,15

198:21,23 210:3,14

213:18 215:21

217:11 218:21,22

218:24 219:6

220:12 221:4

224:11,23 225:4

230:20 231:3,6,7,14

231:20 232:18,19

233:21 234:2

236:13,17,21 237:2

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242:23 245:10,11

245:21,23 246:24

247:7,21

diary 51:5,12,15 74:7

74:10 167:14,17

168:10,12,13

died 67:4 176:3,7

206:19 210:8,10,19

214:7 218:10 219:6

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difference 103:11

123:13 142:10

144:6 148:14

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differences 253:15

255:25 256:1 258:8

different 12:18 13:1,6

13:6,8 39:17 43:1

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48:15 50:19 58:14

60:23 94:23 119:5

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direct 2:14,17,19

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246:12,19,23

director 203:12

directors 203:23

204:5

disagree 258:2 259:3

disagreement 258:2

259:9

disagreements 258:6

258:8

discipline 84:7 86:24

disciplined 18:18

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223:21

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discuss 79:17 94:17

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discussed 94:19,20

94:21

discussions 176:25

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disregard 215:22

216:8,23

distanced 4:25

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distinction 232:4,10

distributed 189:17

190:21

distributions 215:3

Division 187:11

DJ 17:5,8 18:15,19

19:7,7,7,13,15,15

19:17,18,20,23 20:6

21:3,21 22:15 83:3

84:9,17,19 86:15,16

94:4 99:15,21 106:8

115:6,17,20 116:25

148:12 164:23

DJs 19:16 93:23

doctors 173:17

174:25

document 30:17,23

83:15,16,19 85:14

85:19 86:1,6 88:3,6

88:6 102:16 107:1

107:18 114:11

121:5 136:25 137:5

137:20 138:5,20

140:6 141:2 142:3

166:10 189:13,14

189:15 200:21

201:1,1,15 202:7,13

203:17 205:23

208:15 225:16,20

226:15

documentation

113:22,25

documents 81:9

109:2 117:5 136:19

136:21 138:25

139:17 187:16,24

202:13 203:5

206:13 208:5,10

239:18 249:19

doing 32:5 40:11

46:12 68:5 93:4

101:7 120:6,6,11

121:4 122:24

127:25 149:14

172:16 176:22

180:21 181:7

187:13 210:3

213:18 225:5

240:14 246:24

dollar 98:19 105:23

110:15 160:24

door 6:15 22:24

52:15 105:19

111:11 116:14

139:12 158:12

doors 22:8 25:25

Doral 192:2,6,7,11,13

192:13,14

double 173:5

doubt 208:25

downtown 176:4

draw 208:12

dream 162:24,24

dressed 10:13 20:23

drinks 100:19

drug 68:11

duly 5:10 81:16 171:1

duplicate 36:11

duties 209:25

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E-L-L-I-A-D-R-I-A

81:15

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e-mailed 33:8 35:12

38:12

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E-S-H-A 8:13

earlier 24:18 56:24

74:6 76:18 111:23

112:16 114:21

134:17 137:8

187:25 221:16

222:11 231:2

232:22 236:11

early 112:14 252:19

earn 51:19 52:8 56:1

70:18 71:25 72:4,12

73:7 125:21 128:1

136:2 143:24

146:22 147:6 148:5

151:8 152:11

153:23 155:12

156:23 164:18,21

165:13,18

earned 16:2 52:10

55:18 57:11 69:8

70:3,12 71:15,23

72:2 127:10 134:9

135:1,8,11,14

146:22 147:24

148:8 149:20 151:1

153:7 154:6,7

155:22 163:23

earning 147:16

easier 90:18,20

133:13 137:3 142:9

191:13

easily 118:4

east 173:16

educational 171:8

179:22

efficient 252:17

efforts 164:16

eight 46:8 57:18,20

76:6 103:19

either 11:10 25:24

26:19 69:7 77:14

103:8 111:21

115:13 141:21

216:23 217:22

226:7 232:2 252:23

electric 63:4

electricity 182:14

electronic 204:21

205:4,7,12,20 207:5

207:12,16,21 208:8

Elliadria 2:16 81:14

Elliandria 1:4 3:4

emphasize 14:11

employed 122:7

123:1 124:20 195:4

224:15,23

employee 1:2 209:15

223:3,10,13 224:1,4

224:8 230:23 232:3

262:10,11

employees 86:4 210:2

211:14 218:19

219:19 220:5 221:2

229:10

employer 6:4

employment 23:22

24:1 92:4 93:19

encourage 255:7

endeavor 180:2,11

ended 173:10,11

ends 179:16 207:8

engage 15:15 25:17

enjoy 26:2

enjoyed 257:12

Ennis 203:9 204:4,8

205:6 207:11

209:17,17 224:1

ensure 237:11

enter 200:9

entered 14:6 182:11

182:23 225:2

Enterprises 86:2

191:8 196:1 219:10

219:18

entertain 15:7 125:22

entertainer 59:14

83:10 86:14,15

entertainers 86:12,19

188:20 189:18

193:21

entertainment 196:20

196:22,24

entire 8:11

entirely 177:17

entitled 101:23 102:3

235:14,18 254:5,21

entries 109:7

envelope 99:6

envelopes 16:12 99:8

99:9 160:13

epidemic 248:18

epiglottis 173:5

equal 40:7 104:3

errands 114:8

Espinoza 212:6 240:7

240:11,12,18

Esquire 2:4,8,9 34:7

essentially 145:24

250:19

essentials 100:14

establish 125:25

138:14 139:3,5

144:9 208:2

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185:15 188:14

estate 234:5 245:13

245:20

estates 241:21

et 5:25 93:23

evaluating 258:19

event 52:21 53:11

92:5,11,14,22,24

100:21 124:23

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events 92:1 115:1

everybody 4:22

20:25 23:2 84:1

105:17 106:7 118:5

127:25 148:18

193:11

evidence 7:20 14:22

75:6 119:1 208:11

212:21 257:13

259:19

exact 14:4 74:16 76:5

132:4 152:24 157:5

160:10

exactly 32:7 53:18,19

98:8 155:21 160:11

190:2 244:18

Examination 2:14,15

2:17,18,19 7:24

74:4 81:19 159:17

170:12

example 258:10

Excellent 3:22

excerpt 243:12

excessive 258:17

exchange 68:1

Excuse 106:16

126:14

excused 80:18 165:20

249:13

exercise 255:4

exercised 188:11

exhibit 31:7,8,12,16

31:17,18,21 32:2,23

33:2,3,5,6,9,14,25

34:5,9,13,18,20,21

34:23,24 36:19,25

38:24 70:10 74:24

75:4,13 85:6 87:17

106:14,17 107:5

108:6,12,12,21

109:6 118:18 119:4

120:5 121:11

132:12 137:1,12

138:1 165:22,24

166:23 168:12,23

168:24,25 169:23

186:7,15 189:8

193:4 229:25

237:21 241:8

249:18 260:7,12,15

260:22 261:4

exhibits 4:2 34:15

36:9 103:20 118:25

119:3,7,15,20 120:5

120:7,8,15 121:6

165:22 169:16

185:21 239:12

241:9,15 249:19

259:19 260:9,21,24

261:1

exotic 195:4 214:10

216:23 246:11,17

expect 252:6

expected 86:19 92:12

expecting 251:12

expedite 3:23 6:23

expenses 63:19

182:14 183:9 254:2

expensive 208:22

experience 179:21

246:10,15 253:24

explain 60:13 91:22

107:6 114:17,17,22

172:21 178:11

251:19,21

explained 107:20

explains 254:19

explore 16:19

explored 248:19

express 115:23

expressed 115:25

extensive 245:12,19

extent 174:2 258:1

extra 54:13 112:13

129:10 137:14

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eyesight 173:2

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face 176:12,12

fact 4:4 45:25 62:15

142:15 146:21

251:5

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fair 117:15 132:25

145:17 183:1

207:24

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fall 120:2

falling 96:7 249:22

familiar 7:17 186:9

189:13 194:20

219:10 220:14

221:9,10 247:3,4,5

family 28:25,25 29:7

141:17,18 143:15

famous 72:24 73:2

far 79:1 98:19 116:12

118:25 119:16

120:14 133:1

153:20 192:25

193:3 202:18

fast 8:5 60:20 126:19

192:5

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173:16 175:6,21

177:1,6,11,21

179:11,24 185:4,6,8

188:1 191:9 196:6

203:2 205:16 206:4

206:8,9 208:4 210:8

210:10,19 214:7

218:10 219:6

222:10 244:6

245:12

father's 171:14

172:20 175:15

177:9 178:8 185:12

187:22 190:1

191:24 194:5 206:3

206:7,12 209:19

210:23 219:13

222:8 234:4 241:21

fault 66:10

favor 146:15

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featured 215:7

February 33:4

federal 126:7 217:22

217:23

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fee 12:2,3,8,18,19,24

14:1 15:2 22:22

30:7,8 51:25 71:18

71:19,20 83:25

91:22 92:12,19 93:1

93:3,8,19,22,22

94:21 112:12

164:20

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258:17,17

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fees 12:22 13:21,25

14:14 22:21 23:24

27:21,23,23 29:23

47:13,14,22,23

52:12 53:7,18,25

54:1,3 55:17 63:22

71:16 76:4,5,9

82:25 91:13,20

113:17 114:1,16,19

114:22 115:13,20

116:6,17 124:19,21

125:18 143:21

148:9,11 156:3

214:19 216:10,25

217:12 234:20,21

234:22,25 235:1,6,8

235:21 236:8

248:14 253:6,16,18

253:21,25 255:5,16

257:21,23

feet 43:15,16 178:15

180:8,9

fell 96:16

felt 115:22,23 128:9

145:19 185:3

233:21 240:13

female 66:11

fight 157:4,6 158:16

158:19,20

fighting 84:16,17

figure 142:9 146:15

248:8

figured 71:12

file 55:2,8,11 113:15

126:6,9,9,11,13,16

127:9 134:22 135:4

149:7,17

filed 126:14 134:17

134:20,21,23,25

135:6 149:11,21,21

205:21 207:17,18

219:8 220:12

232:18 240:6,19,21

files 136:12,14,17,18

136:19

filing 126:17,21,23,24

fill 83:12 88:8

final 3:3 6:6 102:8

195:15,18 247:13

257:25

financial 212:17

financially 262:13

find 85:1 86:14,16

108:17 182:9,12,21

187:25 253:11

findings 251:5

fine 5:2 6:16 14:10,23

17:14 19:1 21:14

36:12 41:15 84:11

111:18 120:21

133:20,25 256:23

fined 84:8,14,15 98:3

127:20 131:7,21

150:12,14,20

fines 86:23

finish 6:16 13:7 118:3

198:17 206:3

211:24,24 213:16

214:13 216:6

223:15,16,22,23

226:15 252:19

finished 215:3

firing 193:20 225:3

225:10,12 227:20

229:5,9,11,13

236:12

first 4:5 7:21 10:11

20:4 50:24 67:17

81:12 82:7 83:11

93:14 99:3 103:6

107:5 124:6 128:10

129:7 147:7,7,25

148:1,5 149:15

160:22,24 161:3

162:25 163:2,4,6,6

170:22,24 189:11

200:20 203:17,25

204:13 258:6

five 13:5 23:8,17 26:3

28:16 50:3 54:10,11

57:23 90:8 99:8

109:7 112:21,22,22

112:23 129:13

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118:23 121:21

fixed 103:13 116:2

121:14 128:5,10

flat 48:1

flick 49:21

floor 17:6,7,10,11,14

18:5,9,12,15,20

21:2,22 22:6 45:9

45:10,15 48:16,19

82:24 95:18 96:7,9

96:16 97:20 161:3

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141:17 143:9,22

145:10,12 171:20

172:4,8,13 174:7

178:2 187:11

198:23 199:18

201:21,23,24 207:3

208:22 209:20

Flovilla 171:7

flow 245:13

Floyd 92:14 132:7

156:2 158:22,24

163:9

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213:1,14 220:11

fluctuate 13:6 23:9,20

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fluctuated 114:25

124:22

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187:13 201:25

202:2,3,4,8,10

209:15 210:2,5,13

213:17,23 214:21

220:12 221:1,8,23

222:5,7 223:4,10,13

224:2,5,8 229:18

231:8,9 232:3,19,20

232:24 233:18

234:8,18,21,25

235:2,4,6,7,10,13

235:17,20 236:7

245:24 246:23

flyer 92:2

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follow 9:21 96:25

213:6,10

following 105:5,7

120:22

food 173:6 215:11

foot 180:25

foregoing 262:6

forever 54:22

forget 18:22,23 36:20

251:3

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forgot 5:14 252:23

form 159:8,8,9,11

175:18 251:3

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formally 261:11

Former 133:17,18

forms 186:9

Fort 174:12,14

forth 4:1 6:18 42:17

68:18 174:22,24

177:3 232:9

forward 7:18 249:17

foundation 233:8

four 6:5 50:8 57:22

98:17 107:5,23

108:20,23 109:6

112:21 129:13

131:9,9 140:22

141:1 145:25 166:6

166:11

frame 77:1,4,5,9 78:9

171:23 210:15,17

212:10,13 225:13

235:25 252:24

frames 77:6 216:13

frankly 255:1

free 215:22 216:8

fresh 145:14

friend 182:1,2

friends 128:24,25

front 13:23 39:1

67:18 103:4 105:19

111:11 158:12

179:7 193:3 228:4

241:25

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237:11 238:19,22

full 155:25

full-time 184:23

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funds 23:3,4 222:6,8

222:9 246:11

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74:2 78:12 80:16

117:11 194:7

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261:12 262:9

fuzzy 194:21

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G-R-I-F-F-E-N 81:15

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Gables 2:6

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3:14,16 6:1,4 34:7

41:6 59:24 60:2,4,6

63:25 64:2 67:12

68:12 69:1,8 70:9

73:16 76:19 79:18

79:21 80:4,7,10

86:2 117:18,21

122:11 124:11

128:19 129:17

132:18,25 148:16

165:25 166:2,4,5,9

166:13 167:9,16

168:10 170:16,25

171:5,6,15 178:17

189:7 191:7,16

194:13,20 195:21

196:1,10 200:15

202:7 203:18 204:1

204:13 206:18

207:5,13,20 209:8

209:12,13 211:12

211:18 212:8,16,17

213:9,16 214:13

219:3,9,10,18 220:2

220:3 227:4 228:2

228:12 230:1

232:11 239:16,19

240:7,10 241:25

243:17,23 245:24

247:3 249:14

Galardi's 35:8,22

67:1 80:14

gather 177:16,20

gay 174:12

general 119:8 215:19

215:21 216:22

217:8 224:2,5,14

225:2,14 227:21

230:20,22 231:24

232:1

generally 77:3,5

130:2

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generously 45:3

Gentleman's 8:19

gentlemen 5:22

154:23

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184:22,23 185:6,9

185:10 199:18

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getting 36:18 78:4

121:13 127:22

128:5,10 131:20

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43:21 92:24 139:12

143:12 144:11

163:2,5,6

girls 9:7,12,13,13,14

9:18 10:1 12:11,19

13:5,19 17:25 24:24

44:5,7 45:13,15

55:3 59:16,17,18

73:8,10 85:18 95:4

95:4 98:17 112:10

113:6 129:13,13

130:12,22 131:2

143:24 153:9,12

160:6 161:5 163:5

180:25 191:14

give 5:12 20:6,14,15

20:16 21:7,17,23

28:2 45:4,6 54:4

60:6 62:12,14 63:25

74:16,19 82:22

83:10 84:10 86:16

98:6,20 99:6 103:1

106:3,19 111:9

125:21 130:13

136:3 146:14

151:17 152:13,14

152:21,23 153:21

153:24 154:8,17

166:20 167:4 186:1

206:17,24 213:20

213:22 224:18

237:19 241:13

257:9,22,22 259:6

given 15:23 18:11

117:13 120:16,17

149:5 157:23

213:19 216:2 217:9

242:21 246:19

gives 20:24 118:5

giving 4:22 70:10

98:23 99:11,12

114:18 127:11

149:13 177:21

glad 8:14

GM 227:6

go 5:8,23 6:9,25 7:10

10:7,11,13,15 11:16

11:16,20,21 13:7,14

13:22 14:17,23 15:5

17:18 20:15,18,21

20:23 21:2 22:5,18

24:8 28:25 29:5,6

37:11 39:3 41:4

47:9 49:23 50:4

51:9 58:10 59:19

60:21,22 66:11 70:7

77:14 79:25 86:11

91:14,15 92:9 93:6

93:7 96:19 105:18

112:14 116:5

117:24 120:12

128:8 133:22

145:13,15 151:11

159:22 165:1

170:10 172:2,5

177:18 179:5,6,8

184:22 187:18

189:24 199:3 201:5

202:15 203:17,22

204:10 207:14

209:2 212:4 216:5

226:8,16 234:13

251:19

go-go 42:10,11 43:2

51:2,3

goal 256:8

goes 61:14 201:16

209:4

going 3:19 6:11,18,21

7:4 11:22 12:23

13:3,4,14,18,19

14:7,8,17,18 19:14

19:18 21:16,17 22:5

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22:7,9,10 32:25

33:12 36:21,24,25

37:3,17 38:7 39:2

45:4 46:1,13 47:8,9

47:9 50:5 54:22

60:17 61:5,11,11,12

62:19 63:11 64:13

64:25 68:10 77:6

80:21 84:20 87:3

90:23 92:25 93:3,4

93:6,6 98:9 106:9

107:6 109:3,9 113:2

115:14,24 117:17

117:20 118:11,12

118:21 119:2,14,19

119:22 120:18,25

123:15 124:7

125:16 128:3,5

130:10,11 133:22

133:25 134:1

141:19 145:12,15

145:16 146:17

149:4 165:16

173:24 174:21

180:20 186:6,14

187:10 189:7,9

192:5 198:7,11,12

199:4 200:13 201:2

207:25 208:11

211:15 212:4 213:9

225:19,23 230:2

237:14,19,25 238:2

241:20,24 249:17

249:23 253:2,21

254:14,15 257:3,6

257:21 258:13

259:11 260:2,3,6,7

Gold 176:4 191:15

192:3,18 197:6,7

good 3:16,22 5:3 7:14

7:16 38:17 39:24

40:20 41:14 49:2,4

66:1 76:16 77:12

81:21,22 112:11

118:7 122:5,6 158:2

158:3,7 166:24

170:14 174:21

180:8 182:4 191:23

194:13,14,15

208:14 209:6 236:5

249:13 252:19

255:3

gotten 38:22 158:4

233:23

graduate 173:21

graduated 171:13

graduation 175:5

grandson 173:22

granted 6:2 197:21

great 258:24 259:9

grieving 179:12

Griffen 2:16 3:4,18

3:25 33:23 35:2,4

35:14 37:19,21 41:9

80:24 81:14,15,21

85:10,14 88:3,21

90:13 103:6 108:1,2

109:12,14 122:5

125:14 147:20

159:7,19 166:5

Griffen's 37:10,11

GRIFFIN 1:4

gross 181:3

ground 160:24

groups 98:20

guarding 22:8

guess 67:23,24 81:9

92:6,10 136:5,6,7,9

140:7,9 142:14,15

151:16,17 152:14

152:24 154:8,16,17

155:20 189:20

206:25 211:14

225:6 241:1 260:10

guy 66:7 221:21

239:4

guys 18:1 33:8

108:18 133:20

250:22 256:1,9,23

258:12,23

H

H-O-L-M-E-S 8:9

habit 90:24 133:12

hair 60:23

half 178:22

hand 15:12 87:16

136:10 137:2

170:24 176:16

handed 34:17 38:9,10

106:10 160:20

handling 191:4

hands 96:10,24

125:24

handshake 223:1

handwritten 107:7

happen 21:11 23:23

72:9 111:15

happened 36:3 72:10

144:7 163:9,18

172:22 190:7

happening 173:20

happens 22:25

249:21

happy 6:12,17 257:5

hard 103:21,22

176:10 257:7

Harlan 34:7 194:22

238:10 239:22

242:20

hate 27:10

haunt 54:22

head 51:15,16,17

56:21 66:15,16,19

66:23,24 71:9 79:1

151:16 172:23

headset 68:18

health 172:20,22

174:20 175:2 176:8

217:20

hear 5:7 6:11,17 7:3

7:20 68:16 79:11

80:23 90:1 109:5,12

145:13,15 151:21

156:4 176:14

187:10 192:12

heard 62:25 79:6

89:25 112:16 119:4

122:12 150:16

156:12 159:9

181:24 182:4

183:10 187:14

193:14 216:16,25

237:7 247:4

hearing 3:4 4:17 6:6

118:14 120:15

172:25 176:10

184:10 247:13

252:19 253:17,18

253:20 254:1,3,16

260:3 261:12

hearings 219:12

hearsay 79:23 238:14

238:20

heavy 129:9

heel 180:25

held 46:20 96:24

121:24 219:18

220:2

help 17:7 30:17 74:23

75:17 185:7 225:16

259:12

helped 172:17 195:13

helping 176:22

Henderson 221:7

hereto 243:4

hey 160:14

high 47:24 94:21,21

173:21 180:25

258:12

higher 12:19 13:3

92:12

highest 14:1 93:8

highlight 50:6

highlighted 243:14

highlighter 50:6

Hilton 209:14,15

223:3,10,12 224:18

hinder 200:12

hire 10:6 19:7 92:5

95:21,22 99:20,21

100:7,25 101:8

230:23 231:23

232:6,9,12

hired 10:3 19:21

42:23 48:17 82:1,4

82:8,19 99:23,24

129:20,22,23,23

217:5 227:6 230:19

231:22

hiring 101:1 193:20

236:12

history 252:14

hit 161:3

hits 160:24

hold 38:14 85:10

116:15 135:23

219:20 254:1,3

hole 38:1 174:11,14

178:4,14 210:21

holes 180:25 181:1

holidays 141:16

Holmes 2:14 3:5,18

3:25 4:7,9,15,19 8:2

8:6,8 15:1 26:24

30:23 31:10 35:1,2

35:4,14 36:25 37:22

37:23 41:9,14,18

70:9 74:6 89:25

90:4 91:12 98:13

103:5,5,5,7 107:25

115:23 117:14

125:13 128:22

129:4 166:4

Holmes' 37:14 90:1

home 50:17 72:7

141:16,18,18

148:13 153:15

157:20 162:4 165:1

174:10 185:10

honestly 141:24

157:4 248:10

253:20,23

honor 3:20,21 4:6

5:12,24 6:13 7:8,12

7:22 14:5,16 22:19

23:15 30:20 31:5,11

31:13,19 32:1,9,19

32:20,23 33:18,21

34:2,13,19 35:24

36:4 37:16 38:19

40:10,18 61:7 62:16

62:24 63:9 64:9,22

65:5,23,25 70:4

73:24 75:2,4,9

76:25 78:7,20 79:15

80:16,19 81:3 85:21

87:9,13 88:18 90:15

90:20 102:20

103:18 106:10,15

106:18 107:10

108:22 109:4,11

110:1,19 117:11,19

118:7 120:17

123:10 124:3

125:11 133:3,7,14

133:21 135:21

143:25 144:24

145:4,5,20 146:24

147:13 149:9

156:19 165:19

166:12,16,18,21

167:1,10 168:15

169:10,18 172:21

177:9 178:11 180:6

183:15 189:1,5

194:10 197:11

198:6 199:5 200:15

200:20,24 201:12

202:12,24 203:15

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207:6 208:3,13

212:5,9,14 213:7,25

216:17 217:1

225:21 226:2 227:2

227:22 228:7,22

230:5 233:9 235:23

237:18,24 238:13

239:3 241:3,8 242:2

242:16 243:11

247:2 249:5,11

250:21 251:10

252:1 253:4 255:15

256:13 257:17

261:15

Honorable 6:2

honored 144:21,21

hope 208:23

hoped 240:15

horrible 180:24

Horse 9:5 42:20 44:8

51:4 197:18

Hospital 175:8

host 17:6,7,10,11

18:5,9,12,15,20

21:2 22:6 92:5

hostage 46:20

hosts 21:22 48:16

hour 91:14 93:6

106:21 118:5

194:23 211:3,11,17

221:1,8 232:21

233:4,14,17 247:21

248:4

hourly 58:1,2,4

235:15 258:11

hours 9:22 24:15,16

24:19,20 26:3 48:24

51:6,7 75:25 101:13

101:13,13,16 102:5

102:5 103:19

139:20 140:12

152:2 163:16 209:7

258:16,16

house 9:7,8,10,12,14

9:16,18,19 10:1

11:17 12:2,3,8,16

12:22,24 13:19,21

14:1,14 15:2 17:5,8

17:14 18:14,19

20:23 21:1,21 22:14

22:21,22 23:24 28:1

29:23 30:7,8 43:21

44:11,13,15,16

48:12 51:25 52:12

53:7,18 59:18 64:19

71:17,19,20 76:3,5

76:9 82:25 83:3,25

86:23 91:13,20,22

92:12,19,24 93:1,2

93:8,19,21,22,23

94:1,21 95:4 100:1

100:4,7,9,13 106:8

112:12 113:17

114:1,8,16,19,22

115:6,13,17,20,20

116:6,16,24 124:19

129:20,22 143:20

148:9,11 156:3

164:7,20,23 214:19

216:10,25 217:12

234:20,21,22,25

235:1,6,8 248:14

housed 178:9

housekeeping 32:21

118:8,24 249:17

Howard 2:8 3:13

howardbrodskyesq...

2:7

huge 43:10,12,13

178:21,23 180:9

hurry 36:1 170:9

husband 172:6

174:10 180:14

185:7

hype 28:2

I

I-S-H-A 8:10

ID 10:5

idea 77:9 125:20,23

129:5,19 131:1

139:17 148:7

157:11 187:23

189:22 191:23

212:12

identical 32:17

identified 110:21

117:6 193:7

identify 106:22,25

109:3

ignore 228:19,24

229:2

Illinois 42:12,14,15

immediately 86:16

impeach 61:13

impeachment 243:1

implement 191:21

195:22 196:3

218:16 231:14,20

implementation

186:21

implemented 80:13

193:6 196:11

230:21 236:25

implementing 195:13

195:15

important 19:17 77:8

83:24 216:14 257:8

improper 243:1

improve 127:25

inception 118:9

inclination 254:2

include 234:21,22

253:14 254:7,11

255:15

included 127:1

including 22:20 30:7

30:8,8 71:17,19

83:5 193:12 213:14

213:17 215:21

216:3 217:10

income 55:8,8,11

126:7 127:1 134:18

149:8,19

incorporate 236:7

incorporated 202:2

202:11 210:3

213:17 214:21

220:13 223:10

232:20,20,25 234:8

234:18,22 246:23

independent 116:19

116:22 127:4,6

214:14 215:14

216:9,24 217:6,11

217:19,21,25

219:19 220:4

248:13

INDEX 2:13

indicate 4:21

indicated 14:13 75:7

individual 1:8 120:15

individually 119:17

240:15

individuals 18:14,19

210:1,7

inform 99:3 235:13

235:17

information 74:13

79:3 111:3 127:5,9

177:2 224:19

256:12 259:7

informed 36:13 127:4

informing 36:7

inhabited 178:22

inherited 196:18

initials 111:5

input 100:9 101:1

inquire 255:7

insert 37:24

inside 77:16,20 97:17

160:11 184:19

inspection 180:21

Instagram 12:12,13

12:14 54:24

install 231:5

installed 227:20

230:18

instance 261:2

instructed 62:22 63:1

213:13 237:10

240:1

instructing 239:24

instructions 20:6

insurance 182:15

217:20 218:5

insuring 211:11,17

212:22

intention 174:9

interest 174:3

interested 262:13

interests 173:25

174:7,14

interfere 121:3

interfered 219:2

246:9

internet 54:21 126:4

interpret 232:12

interpretation 45:7

interrupt 172:12

223:20

interview 222:17

interviewed 222:15

introduced 119:1

185:22

introduction 226:25

inventing 186:12

investing 181:12

investor 182:13

200:11

investors 182:10

invoices 221:22,24

involved 175:15,18

176:25 193:20

195:4 197:18 198:5

219:25 243:24

244:4 245:2,14

involvement 19:10

184:4,6 241:18

242:23 243:21

244:16

involving 213:17

247:6

IRS 55:18 126:15

134:20 135:5

149:12 245:20

issue 5:25 6:3 64:24

212:11 228:8 245:2

252:5 254:25

257:16,21 258:14

259:17

issues 6:5,6,10 36:8

96:3 252:5 254:23

255:18,20

J

J 2:5,9

J-E-E-Z-Y 72:21

73:5

Jack 171:15

Jamaican 24:22

January 179:20

180:15

Jay-Z 73:3

Jeezy 72:14,15,20,22

72:23 73:5,7

Jennifer 182:13

209:21 224:4

Jeter 194:20,23

job 47:11 95:17

113:12 134:13,14

134:18,19,21 135:3

135:4

jobs 134:13

John 1:13 3:6 203:8

204:4 205:6 207:11

209:17

Joseph 175:8

journal 74:7

judge 78:13 90:13,19

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133:16,17,18

151:19 169:22

209:1 216:5,11

219:17 220:2

242:25

judgment 6:3 34:15

168:1,2,9 169:12

253:19

July 52:23,24,25 53:1

53:2,3 107:11

172:16 181:20

183:3 184:4 190:13

247:22

June 89:16 123:4,6,7

172:16

jury 243:18

K

keep 15:22 16:1 51:5

51:8,15,17 70:24

110:14 113:6,7

128:5 167:12 235:7

235:7,10,20 236:9

245:13 248:12,16

249:24

Kelly 178:16 179:2

kept 69:5

Key 174:11,17 178:5

kind 42:25 68:8 83:8

93:24 110:9 114:10

142:5 175:11,12

176:3 177:12

179:16 205:3

218:15 243:18

King 8:18,21 9:2,6,20

10:3,8,9 14:2 15:2,7

16:2 17:4 18:6,8

23:7,23 24:4 27:14

27:17 28:20 29:23

39:9 42:20,22 43:3

43:4,7 44:7 46:3

48:3,5,6 51:4 74:17

74:20 76:19 78:24

81:23 82:2,5,8,17

82:21 83:23 90:7

91:11 92:24 93:9

94:15 104:7 112:15

112:18,19 113:8,10

113:23 114:4 115:4

115:12 122:7

134:15 140:25

143:5,8,10 144:10

144:18 153:4

159:12 160:23

162:23,25 164:17

175:19 177:25

178:9,20,21 179:9

179:23 180:3,11,15

180:20,23 181:12

181:16 182:5,6,8

183:16 184:5,7

185:13 187:13

188:13 190:21

191:25 195:5

196:24 197:3,23

198:5,13,15,21,22

210:3,14 213:18

215:21 217:10

218:21,22,24 219:6

220:12 221:4

224:11,23 225:4

230:20 231:3,6,7,14

231:20 232:18,19

233:21 234:2

236:12,17,21 237:2

237:11 241:18,22

242:23 245:10,11

245:21,22 246:24

247:7,21

knees 96:10

knew 83:8 112:10

115:13,16 116:21

146:17 155:21

182:2 203:2 221:21

know 5:14 6:9,9 7:16

8:5,14,24 9:13,14

9:24,25 10:24 12:20

14:3,4 17:12,19

18:25,25 22:5,12

23:16,18 24:10 27:2

27:4 29:18 36:15,16

38:16,23 43:17 44:3

44:5 46:2,4,5,16

47:12,15 48:8 50:5

50:19,22 51:8,20

52:4,5,24 53:1,3,4,6

53:14,18,19 54:4,16

55:7,16,25 56:3,7,9

56:10,11,13,16,19

58:2,4 59:6,19,24

59:25,25 60:1,11,12

60:12,20 63:4,12,12

63:14,18,24 64:4,5

64:5,7,16,19 65:12

65:19,20,22 66:3,8

67:1,4,6,9,12,15,19

68:8,10,15,19,22,23

68:23,25 69:1,3,3,4

69:5,7,8,10 70:19

70:21,22 71:8,9,24

72:1,24 73:17,20,21

75:11 78:16,23

79:10 81:5 83:2

88:24 89:1,6,17

90:15,16 91:19

92:25 98:8 99:7

101:8 103:17

106:11 113:15

114:3,9,17 115:1

120:2 122:10

124:11,15 125:14

125:16,17 126:6

127:3 128:21

129:22 132:4,5,9

133:1,12 135:1

137:13 138:5

139:11,16 141:12

142:17 143:23

145:15 146:11,17

148:8,16,25 149:14

151:10,14 155:4

157:11,14 159:3,8

159:13 173:19

175:9 176:16,18

178:18 179:2 181:5

182:9 184:18 185:2

188:1,2,3,5,6

189:14,15 218:15

218:18 219:16,24

220:6,9,14 226:12

227:9 230:10

232:24 234:24

237:8 238:17

240:23,23 241:4

242:12 243:3

244:23 247:16,19

248:17,18,21,23,23

249:22 253:16

257:2,12,22 258:13

259:11,13,19 261:7

knowing 46:1 145:11

181:21

knowledge 15:21,25

16:15,17 19:20,23

77:22 90:3 99:23

101:4 122:9 140:13

143:9 206:5 235:19

237:3 246:16,18

known 197:23,23

knows 64:5

KOB 229:18

KOD 41:19 42:9,10

43:19 44:9,9 45:9

54:14,19 55:1,8

56:2 58:10 59:3,12

66:5 70:3 93:19

94:9 113:12 123:16

123:23,24,25 124:1

124:12 126:1,8

127:2,10,11 135:8

135:12,14 136:2

145:18 146:13,23

147:2,2,6,7,9,25

148:10,14,18,21

163:23 164:1

214:22 217:19

227:5,17 228:11

229:10

KOD's 63:4

L

label 12:15

labeled 116:19

166:25 214:10,14

217:16,18 260:5

labeling 216:9 217:11

labels 120:5

Labor 248:1

ladies 44:1 159:25

160:4 237:5 238:11

240:4 246:12,17

248:13 252:12,12

252:13 257:11

lady 26:24 68:12

88:21

lap 15:16 96:4 235:21

235:21 236:7

large 8:4 43:19 45:9

159:20 166:21,22

Las 171:21,22,25

172:2,8 173:24,25

174:3 192:3,25

late 129:24 252:18

Lauderdale 174:12

174:15

law 5:11 6:14,18 7:5

7:17 32:15 81:17

171:2 248:9 251:5

lawsuit 142:5 219:8

220:11,15,25 221:7

221:8 240:6

lawsuits 189:24

232:17,21 233:14

233:18 240:9,12,13

248:18

lawyer 40:4 62:14

138:7,8 140:19,24

200:3 238:18

240:16

lawyers 4:14 133:14

189:21 191:19

212:25 239:10

layout 67:19

lead 194:17,19

leading 112:6

learned 188:8

lease 182:20 199:7,8

199:9,11,13,14

200:6

leased 198:3

leave 17:23 18:3 21:5

21:8,12,15,18,24,25

22:5,7,10 24:18

45:20 47:1 52:16,21

53:19 104:7,21,23

105:15 106:3

111:12,16 123:25

143:1 187:6 192:1

218:17

leaving 47:8 83:2

104:25 109:19,22

leeway 64:12,14

left 46:9 67:19 105:4

123:23,24 124:1

125:24 142:23

157:14 171:25

173:11,22 226:24

248:17 251:25

legal 2:3 6:22 34:7

41:7 200:1 251:12

legally 251:1

legitimate 86:21

length 257:7

Leon 2:6

lesser 147:1

let's 3:6 7:23 10:7

11:24 15:5 16:19

20:17,18 33:11

34:22 49:23 50:1

61:6,13 63:2 80:23

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109:5,12 112:15

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212:4 214:4 223:20

232:6 233:25

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249:16 250:11

letter 32:18 34:6

36:15,23 37:14 39:2

40:12 41:6,8 166:2

166:3 238:10

letters 32:7,13 33:19

260:10

letting 13:24

liability 6:4

licensed 199:9,13

licenses 197:20

lie 18:2

life 90:25 114:14

172:24 176:5

lights 180:16

limits 256:22

line 61:6 130:9

135:22 177:2 212:7

242:19,23,24 243:6

243:10,13,19,21

244:2

liquidated 40:8 104:4

251:16

liquor 215:11

list 12:8 17:19,24

20:24 31:17,18,21

31:24 32:2,23 33:2

33:3,5,6,9,15 34:10

38:24 41:20 54:17

108:12 112:3,7,13

113:4 119:5 121:11

165:22,24 167:20

168:25 169:24,24

169:25 182:13

192:17 260:7,15

261:4

listed 54:18 187:11

197:10 202:9,20,25

203:4,7 204:2,14,23

205:8,13 234:8

listen 6:12,22

listening 128:7

lists 20:25 113:4

literally 26:1

litigating 36:8

litigation 197:18

little 19:4 23:20 33:16

50:5 60:10,15 70:25

78:18 105:18 106:7

118:17 192:5,6

199:3 200:16,16

209:1 215:24 254:6

live 9:16 129:2,3

170:17 171:19

lived 43:23 148:18

171:20 184:23

lives 129:4 143:15

living 184:21,25

Liz 224:22 227:20

229:5

LLCs 179:19

load 60:21

lobe 173:11

located 77:16,19 95:8

192:23

lock 25:25

locker 20:22 83:6

97:14,17,21,21

locking 117:4

log 23:23

logical 141:21

long 17:14 23:25

25:22 26:3,13 46:6

50:24,25 51:13 52:6

56:5 67:6 71:4,6

74:14 82:16,16 83:9

117:14,24 118:1

119:24 123:3

146:16 179:15

209:3 249:25 254:3

256:11

longer 25:1 169:8

238:15,22

longest 9:14

look 48:10 59:18 75:8

78:17 87:1 103:10

106:5 126:4 128:21

134:11 137:5,15

168:11 186:7,15

189:10 202:16

208:16 235:5 238:5

242:13 243:4 259:8

looked 42:19 224:20

looking 7:18 34:5

49:18 62:9 102:16

102:18 103:14

107:4 121:5 136:11

137:21 167:8,10,19

167:22 200:11

242:2

looks 87:21 111:3

239:21

loose 98:19

lose 47:10 120:1

lost 26:5 74:11 162:9

197:20

lot 14:3 28:13 44:5

45:24 51:23 52:2,7

67:16 73:13 79:7

104:25 119:12

130:6 142:9 153:19

157:2 158:22

160:22 188:2 190:6

211:13,13 245:16

Lots 44:4

louder 27:9

Low 182:17 187:13

201:25 202:2,3,4,8

202:10 209:15

210:2,5,13 213:17

213:23 214:21

220:13 221:1,8,23

222:5,7 223:4,10,13

224:2,5,8 229:18

231:8,9 232:3,19,20

232:25 233:18

234:8,18,22,25

235:4,6,7,10,13,17

235:20 236:7

245:24 246:23

Low's 235:3

lowest 13:13 14:21

93:11,13,14

lump 99:12

Luna 245:16

lunch 80:25 81:1

103:12 106:20

117:13 121:24

170:9

lung 173:9 175:11

lungs 173:6

Lygia 35:7,19,21

37:12 107:16,21

M

M-A-R-Q-U-I-S-H-A

8:8

M-U-T-E-P-E 3:10

ma'am 59:10 126:19

131:12 170:14

Madam 65:8 239:14

main 9:13 67:22

83:24,24 84:1

173:15 184:17

209:19

maintain 37:15

maintained 210:12

maintaining 116:24

making 45:3 68:9

98:16 99:14 120:10

232:11 245:8

male 66:11

man 17:13 28:3 48:16

48:19 66:9 177:15

177:15

manage 229:18

management 116:1

124:16 128:11

164:3 182:11,24

198:24 215:20

219:1 222:21,23

223:11 227:5,18

228:11 231:11,18

232:7 233:22

manager 66:13,15,16

66:18,23,25 84:13

86:23 109:9 111:5

111:22 209:19

224:2,5,14 225:2,4

225:14 227:21

229:5 230:20,22

231:25 232:2

managers 16:25 17:1

28:2,3 66:19 69:2,5

82:10 128:6,12

215:19,21 216:22

217:9 225:13

managing 183:6

mandatory 13:21

17:6,18 18:16 20:10

20:12 25:3,5,6,9,20

25:22 27:22,23 28:4

94:14,18 105:10

115:16 116:13

117:1 127:18,19

March 1:15 32:24

33:1,4 107:8 121:15

122:23 169:2

181:25 222:12

233:25 260:16

mark 34:23 37:8

81:10 141:23 200:1

226:12 260:3

marked 21:4,4 34:11

36:16,23 81:10

84:20 87:4 106:9

107:4 120:9,15

167:5,14 186:6,14

189:8 200:13

225:23 227:11

237:14,17,21

249:20 260:1,3,6,9

marker 33:25

marketing 171:11

Marky 21:21

Marquisha 2:14 3:5

4:7 8:2,5 35:1

102:24,25

Mary 209:23 224:7

Maryweather 132:7

mask 27:10 41:25

122:21

Masters 191:15

192:3,24 196:19

197:3 214:5

match 32:6,7 118:19

121:16,19 260:7

material 254:16

matter 3:4 5:25 62:15

77:6 216:15

matters 3:23 6:23

Mayweather 13:15

13:16 92:14 156:2

158:17 160:14

161:2

mean 21:19 55:24

59:25 70:9 83:1

84:8 91:17 92:23

93:1,21 97:7,21

102:6 105:7 109:22

110:5 112:6 114:6

114:25 115:21,24

116:21 125:8,16

126:4 127:8 128:2

130:1,1,5 131:19

139:12 140:5,21

142:11 144:20

145:6,8,10 148:11

151:13,15 153:2,9

153:18 154:13

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Meaning 149:17

means 5:21 7:10

60:14 110:7 208:20

227:9 241:4 244:20

256:16

media 54:23,24

Meek 162:23

meet 60:2

meeting 25:25 76:23

77:22,25 85:16

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128:3,8,10

meetings 25:3,6,7,9

25:12,20,22 26:3,7

26:8,11,19 94:15,18

105:10,11 115:22

127:13,14,24 128:2

128:11,20 188:19

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members 188:23

Memorial 82:6 92:15

103:14 158:20,21

158:22,24,25

memory 30:18 74:23

75:17 225:17 247:8

men 95:13,21,22

men's 174:12

mentioned 145:22

162:25 196:19

210:2 232:17

merchandising

171:11

messages 91:19

met 122:12 127:22

181:25

metastasized 173:9

meter 226:16

Mia 245:15,15

Miami 176:5 192:6,7

192:15

middle 112:24 141:6

midnight 13:11

Mike 245:17

military 126:18,22

134:24 159:10

Miller 34:7 41:7

194:22 238:10,15

238:22,25 242:20

243:11,14,17

Mills 162:23

mind 4:19 49:6 93:3

179:18,22 234:3

mine 161:4 168:3

205:4 226:2

minimum 28:15,17

48:22 50:2 54:10,11

58:1,2,4,11,18

74:23 75:7,18,22

76:12 86:15 101:19

102:4 152:2,8

218:19 221:5,12

233:19 247:8

minus 50:10

minute 234:21 249:7

minutes 6:24 69:11

91:16 93:7 118:5

mischaracterizes

46:22 145:21

misclassified 219:18

220:4

misled 91:4

missing 157:13,23

163:3,10,20

mistaken 92:21 116:9

158:22 184:14

mixed 42:25

model 214:8,9 215:22

216:2,9,23 217:5,13

218:11,13,16,20,24

219:6 245:25

248:12,16

models 217:10

modified 165:25

mom 11:17 17:5,8

18:14,20 20:23 21:1

21:21 22:14 28:1

48:12 83:3 86:23

93:23 94:2 100:1,4

100:7,9,13 106:8

115:6,17,20 116:24

129:20,22 164:7,23

moment 41:2 133:3

134:11 170:2 187:7

188:25

momento 60:10,11

Monday 13:2 36:6

49:3

monetary 28:6

money 10:14,17 11:2

14:3 15:12 16:8,9

16:10,11 18:12,24

18:25,25 19:3,16,17

20:13 21:5,14,17,23

22:12,14 45:3,4,5,5

45:6,6 47:9,10 48:6

48:16 50:21,21 51:6

51:20,21,22 52:1,2

52:22 60:6 68:15

69:2,6 73:9,11,13

73:16,17 86:16

95:13,18,20,21,22

96:7,9,11,15,16,18

96:19,20,21,22,23

96:25,25 97:2,2,5,6

97:7,9,10,12,19

98:5,6,8,14,15,16

98:19,21,23 99:8,11

101:9 104:25 105:1

105:2,20 110:11,14

123:16 125:16,19

125:19,21,22,24

126:15 127:21

128:1 129:14,18,25

130:3,6,7,12,12

131:5 134:9,20

135:2,5,8 139:13

147:8 148:12

149:12 153:19

157:4,5,7,9,10,11

157:12,13,22,25

158:3,8 159:20,22

160:9,11,14,15,17

160:18,25 161:2,10

161:11,16 162:8,9

162:16,18 163:2,9

163:10,14,19,19,23

164:16 181:9,12

182:6 183:8,13

222:4,20 246:12,17

246:19,22,23

monitor 15:22 16:1

monster 178:25

180:5

month 8:24 28:24

29:13,15,16,20 50:8

50:9 54:12 63:5,7

63:16 68:15 132:4

179:17 239:2

240:24 252:14

monthly 127:13

months 9:23 28:14,15

28:17 29:6 50:5

172:15 176:5

morning 24:25 41:14

81:21,22 105:1

129:25 130:3

140:24,25 194:13

mortgage 63:13,14

68:22 125:9 182:14

mortuary 122:17

motion 6:3 34:14

167:25

mourning 179:13

mouth 133:25

move 5:4 63:2 85:21

88:18 106:12

200:16 208:13

241:2,5,10

moved 43:2 89:17,19

120:16 172:7

173:13 174:6,13,19

178:2,14

multiplied 102:7

152:3

music 125:3

Mutepe 2:4 3:9

194:16

mutepe.akemon@r...

2:3

Myrtle 192:25

N

naked 82:13 96:9

name 8:1,8 11:1 12:8

16:12 17:21 20:24

27:2,4,7 81:13

88:24 89:1,3 94:10

108:25 109:8 111:4

122:12 170:15,24

171:4,14 181:24

191:11,12 194:16

199:8,9,11,21,22

205:23 206:4,7,8,10

206:12 231:12,17

named 187:23

names 11:8 139:13

245:15

narrowing 216:20

nature 133:11 216:4

near 143:21 148:10

185:1

necessarily 117:3

necessary 5:19 142:6

need 5:16,23 6:8 24:6

32:11 40:21,23

44:21 62:17 79:13

80:20 87:14 114:9

114:10 118:13,14

118:23 119:7 121:4

127:23 128:5,8

137:17 141:25

142:2 154:22 170:4

188:17 200:17

209:2 211:15 243:8

253:8,13 257:2

258:21 259:12

260:20

needed 86:20 180:17

180:18,22 185:3

245:13

needs 11:14 21:22

36:16 40:25 127:22

negative 165:1

negotiate 213:13,23

negotiated 220:19

nerves 172:23,24

173:3 185:3

nervous 5:1 226:4,5

never 43:20 46:17

47:15 54:22 55:2

61:3 62:10 90:19

103:19 122:12

124:13 127:1

129:17 134:19,20

149:21,21 175:17

183:23,23 184:6,15

185:19 188:11

197:14 206:8,9

211:7 224:20

new 124:16 128:2

145:11,13 146:16

149:15

nice 41:16 240:5

Nicholas 173:21

nickname 11:13

night 8:23 10:14

13:10,13 16:13,16

16:21 17:20 19:11

20:9,18,18,21 22:16

22:17,20 24:9,24

48:2 50:20 53:11

71:9,12,24 72:5,7,8

72:12 74:17 82:20

85:17 92:1,17,20,24

97:2,6,8 98:21,24

99:6 100:16,16,23

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nightmare 162:25

nights 13:9 52:21

92:5,11,22 129:24

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nine 24:16 57:19,20

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normal 114:7 115:9

124:23 146:11

158:25

normally 11:9

north 43:2

note 3:23 77:13

notebook 31:12,17,23

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notebooks 106:12

noted 3:17

notepad 30:16 50:20

notes 45:19 151:18

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notice 31:6 32:14

40:14 137:20,23

notices 167:6 169:7

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notify 12:22,24 86:15

nude 20:5 215:7

number 12:9 15:22

30:5 31:3,7,9 34:18

34:20 35:7,16,18,20

36:15,23,25 39:18

39:21,22 48:20

56:25 57:1,16 62:4

62:7,13,18 70:25

74:16 75:24,25,25

76:14 85:2 86:11,18

87:18 98:6,7 102:8

102:21 114:18,19

114:23 120:3 121:8

135:16 136:3 138:1

148:7 151:17

152:13,24 153:24

154:9,11,18 155:21

156:24 157:1

159:25 166:5,9,19

167:4 186:25 187:1

187:3 200:19 201:1

201:3 227:16

229:15 230:11

232:17 238:14,14

238:15 242:9,10,11

252:12 258:16

260:6

numbering 31:23

33:14

numbers 14:9 32:6,9

39:23 49:2,4,8

51:16 56:11 70:11

91:21 102:1 107:8

120:1 121:4,6,11,12

230:7,12 249:19

256:21

numerous 196:16,17

O

oaths 4:22

object 242:25

objection 46:22,24

55:20,21 59:4 62:16

63:9 64:9,23 69:17

70:4 77:1 79:23

119:15 123:10,19

124:3 125:11

132:20,22 135:21

143:25 145:20

146:24 149:9 151:9

198:6 199:1 202:12

203:6 207:6,7,22,24

210:15 212:10

216:11 219:21,22

223:5 227:23 233:5

238:13,20 239:11

243:16 244:9 246:2

objections 33:15

119:3,6 253:12,12

obligated 125:17

131:6

obviously 120:24

254:23,25 255:7

occasion 12:21 28:11

28:19 29:8 84:3

92:3 104:16 105:4

111:16 112:2

159:19,24

occasions 162:8,12

occur 165:4,5

occurred 219:14,16

240:9

Ochoa 220:12 221:1

232:20,24

office 60:25 67:18,21

67:21,22,22,22,23

73:13 77:21 178:8

178:16,19,20 179:5

179:7 184:19

189:17 191:12,14

193:11 196:2

210:11,13,19,22,23

224:12 234:14

officer 212:17

officers 48:17 203:23

204:5

offices 179:1 184:18

oh 10:13 11:3,4 13:15

17:11,16,25 18:2,21

18:24,25 19:1 21:3

22:4 28:2 45:24

53:4 61:23 66:6

69:21 72:9,22

156:21 192:14

199:9 252:3

okay 4:8 5:1 8:16

10:2 15:5,12 20:17

21:8 23:3 26:18

28:19 29:17 31:2

32:10 37:17 38:14

38:17 40:11,20,22

40:24 41:1,2,23

42:1 46:6 49:1 50:2

62:25 69:25 72:24

75:8 76:16 79:2

81:1,2 84:22 85:5

87:23 88:1,19 89:14

90:6 91:9,22 92:17

94:1,17 97:16

102:13 103:12

105:25 106:19

109:5,25 111:7

112:15 115:3

116:23 117:5,11,12

117:20 118:2

119:14 120:23

121:25 122:22

129:12 133:18

134:2 135:7 136:23

136:24 137:11

146:3,10 150:5

155:9 156:21

159:14 162:3,12,21

164:12,15 168:11

168:22 169:15,19

170:8 172:14,20

174:19 177:19

182:22 183:19

185:5 186:8,19

188:7 189:12

190:20,24 192:8,18

192:20 195:14,20

197:22 198:1,20

199:20,24 200:25

202:4 203:13

205:22 208:10

210:6 211:15 212:4

214:21 216:18

217:2 219:8 220:1

222:2 223:2 228:13

228:19 229:9 231:1

233:10 236:24

237:16,19 240:18

240:22 241:12

242:4 243:20

244:15 245:5,24

249:4,6 250:24

251:11 254:11

258:3 259:3,5 261:6

261:8

old 68:10 128:3 239:5

once 4:3 29:3 84:14

94:22 131:18 183:6

255:1

ones 96:8 105:21,23

105:25 106:1 110:8

185:23 186:1

249:20 259:21,22

259:25 260:5,25

Onyx 192:21 196:22

197:2 214:5

open 24:25 25:14

26:15 197:16

252:20

opened 26:11 149:13

197:14,17,17

opening 5:13,18

118:9

openings 5:15

operate 179:23

operated 67:6 183:2

214:22 215:24

operating 182:15

231:8 246:15

operation 64:17

184:5

operations 182:12

183:20 184:7

opinion 44:14,15,16

115:21 128:9

opportunity 84:25

99:17 257:9

opposed 102:16

opposing 33:9 36:7

38:10

order 120:2,24 130:8

167:25 168:1,3,8

169:11,14 180:22

214:17 225:9 243:8

252:8,22

ordered 225:3,12

227:19 229:5,10

organization 59:3,12

195:21 206:6

organized 195:2

original 167:7

originally 141:17

166:25 167:5

ought 78:5

outcome 251:14,15

outfits 100:17

outrageous 152:25

153:2 154:11,13

outside 9:25 24:22

48:17 216:2 217:7

overruled 63:11

238:21 239:11

243:16 244:9

owe 126:15 134:20

135:5 149:12

owed 57:13,14 58:7

58:17

owned 191:9 196:17

214:21,25 231:9

owner 64:8 128:6

owning 185:16

owns 231:10

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p.m 1:16 26:9,10

PA 2:5

packages 88:9

packet 83:10

page 34:8 61:6 75:15

86:11,18 103:4,6,6

103:10,15,15

118:22,22 203:17

212:7 228:2 242:4,5

242:9,10,11,12,14

242:15,17,24

243:10 256:22

pages 107:5,7,23

108:20,23 109:6

242:8 256:21 257:2

257:3,4 262:7

paid 10:19 11:2,25

14:2 15:2,7,10,19

18:1,1,1 22:14

23:24 25:19 29:23

47:13 48:12,14

52:10,19 53:6,12,14

53:16,17,18 59:19

63:22 68:13,20,21

71:1,2,8,9,16,23

73:10,14 74:20

92:21 93:9,10,11,15

105:10,15 114:1,21

117:4 124:19,21

142:23 148:15

152:8 156:2 157:19

157:19 217:23

221:12,22 222:2,2

235:21

painting 180:18

paper 151:15,18

papers 139:16

paperwork 83:13

paragraph 14:12

parentheses 228:12

parenthetical 228:20

228:25 229:3

parked 209:2

parking 208:18,21

226:9

part 18:5 34:14

108:11 114:11,14

114:23 115:9

119:20 140:8,10

141:1 146:1,11

179:7 218:13 228:2

231:16,16 256:19

participated 15:23

particular 193:16

220:3

particularly 228:21

parties 3:24 165:23

262:11

parties' 262:12

party 24:22 25:1

pass 38:7,17 171:16

passed 171:17 175:25

179:11,12,24

184:20 185:9,10

188:2 196:6 205:16

239:2

passing 67:3 178:8

184:24 187:22

190:1 191:24 194:5

205:19

Pat 206:14 207:17,18

patch 173:4

pause 199:16 223:14

223:18

pay 9:25 10:12,12,13

10:14,15,16,23

11:15,17,18,19,20

11:21 12:15,18 13:5

13:10,10,12,14,22

13:23,24 14:13

16:20 17:17,22,23

18:2,2,3 19:18

20:25 21:1,3,3

22:11,11,22,25 23:1

23:3,4 30:6 44:19

45:1 52:1,11,16,16

53:19,20,21,22,23

53:24 54:2,12 59:20

68:14,15 70:25

71:21 82:25 86:15

92:12 94:1 100:18

100:19 105:17

109:23 110:12

113:10,12 114:24

115:14,16 116:6,13

116:16 125:7,17

127:20 132:8

142:25 143:21

164:20 182:17

214:19 217:12,19

217:22 221:5,23,25

226:8 247:7 248:14

paying 13:4,13,15

19:17 21:8,12,16

51:25 52:1,2 63:23

83:7 84:9 98:22

112:12 115:2,19

116:14 145:6,8

148:14 216:25

233:19

payment 12:1 20:11

63:13,14 182:18

PC 34:7 41:7

pending 217:3

penny 63:25 69:9

183:16

people 65:2 95:8

130:7 145:15

193:10 211:22

240:16

perceive 164:9,10

perceived 164:11

percent 16:3,8,11,19

16:20,23 20:10 21:5

21:6,9,12 22:15

28:1 52:16,18 83:2

83:25 98:11,12,14

98:15,18,20,22,23

99:2,8,9,11,13

105:14,15 109:8,23

110:5,10,16 116:13

116:14 130:14

160:9 161:8 162:1

169:7 215:1,5

perform 58:25 59:15

86:21 113:2

performance 86:20

performed 163:12

period 14:5 77:10,11

77:13 78:6 187:19

215:18 242:19

periods 198:24

person 11:1 73:4

105:17 178:17

personal 167:16

168:10 222:6,9

personality 177:10

177:11

personally 15:13,17

79:9 122:13 126:2

129:22 139:4

221:25 222:2

Persuasion 27:8,10

27:11,12,14,17

pharyngeal 172:9

phone 12:9 68:17,17

79:6,11 136:14

176:11,15,17,23

191:13,14 255:21

256:4 259:14

photos 54:19 126:3

pick 4:12 18:12 19:7

95:18,20 101:8

161:11 186:2

244:24 250:11

258:10 260:24

picked 160:21 161:12

161:13 163:14

picking 96:8,10

167:12

piggyback 258:4

pin 77:8,13

pink 106:7 191:15

192:2,2,6,6,7,8,14

197:7,8,13,15,22

214:5,6 245:15

pinned 77:7

pinpoint 131:3

place 25:12,23 58:25

60:11 125:21

145:18

placeholder 254:14

places 48:9 83:5

plaintiff 201:11

Plaintiff's 201:8,9

plan 4:8 251:4

planning 142:5

plastic 73:14

played 19:11,24 65:9

99:18

please 8:1,1,3 9:1,11

39:7,11 58:18 60:19

65:18 70:2 81:11,12

85:1 106:22,25

108:15 114:17

120:14 137:4 160:1

160:15,17 170:14

170:23,24 171:4,9

178:11 186:7 201:6

212:7,7 227:15

229:15 239:14

242:24 258:7

plenty 118:3 162:11

plus 30:10 40:17

52:19 54:12 160:6

pocket 148:13 183:13

podium 200:15

point 23:22 41:24,24

47:7 59:8 77:12

97:3 119:7 120:11

171:16 173:8

174:20 175:1,7

178:7 181:11 185:5

228:14

police 46:21 47:2,5

47:10 143:3

policies 80:12 198:25

policy 87:12,21 116:5

116:24 117:8

165:11 189:9,22,25

191:17,22 195:8,11

195:16,22 196:3,6,9

196:11 198:13,14

198:21,22 212:2

230:21 231:6,14,20

232:16 233:18,21

234:1,3 236:15,25

237:5 240:8

Ponce 2:6

Pony 191:15 192:2,2

192:6,6,7,8,14

197:7,8,13,15,22

214:5,6 245:15

pool 25:1

Poor 239:4

popped 56:21

portions 243:14

posed 7:6

position 6:14 203:10

222:16,18 232:2,5

possibly 238:18

256:25 257:14

post 12:12,13,14

253:7

post-hearing 6:19

118:11,15 135:25

250:24 252:20

254:8,12 255:12

256:6,19 258:10,15

261:9

posted 83:5

pot 20:13

potential 147:15

pow 98:16 160:1,4,5

160:14,18

prefer 253:9 258:5

preference 133:8

pregnant 123:4,6

149:18

Case 1:20-cv-23230-AMC Document 136-1 Entered on FLSD Docket 10/25/2021 Page 82 of

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Page 279

prehearing 254:17

premarked 119:21,25

121:2

premises 111:13

224:11

preparation 148:17

178:14 186:21

prepare 3:25 253:10

254:4

prepared 138:5 250:1

256:17

preparing 186:11

preplan 142:12

preplanned 142:11

present 3:15,17,18

109:19,21 247:11

247:17 258:22

presentable 180:19

presented 189:22

228:18

presenting 111:16

president 187:12,24

188:10 202:10,21

202:22 203:5,11

204:2,6,8,9,14,18

204:24 205:8,13,15

234:17 245:24

presuit 31:5 32:14

40:14 137:20,22

167:6 169:7 260:18

presumed 244:22

pretend 65:1

pretty 8:4 112:16

114:7,13 115:13

153:4 174:21 176:1

177:11 242:2 256:2

prevail 254:24,24

prevails 251:18,18

previous 64:22

145:21

previously 20:9 87:4

117:5 118:10

242:21

price 48:2,3 53:9,10

53:13

Prince 21:21

printed 33:1

prior 21:8 171:18

175:14,19,21 177:6

177:24 178:7 179:8

185:11,17 187:22

196:13 206:4

220:10 252:4

privilege 144:14,18

144:20 145:2

238:17

probably 13:9 43:15

46:13,16 49:9 60:12

72:17 78:5 135:20

144:10 182:25

195:24 206:21

220:19 221:3,6,13

222:4 230:24

234:10,19 247:15

problem 8:14 46:13

103:9 136:24

226:11

problems 185:2

procedures 80:13

proceed 4:18 41:10

81:18 122:1 134:6

150:9 169:20 170:1

proceeding 261:16

proceedings 3:1

262:6

proceeds 183:24

185:12

process 10:3 82:14

110:10 120:18

179:13 191:1

255:20 256:3

259:13

production 35:9,22

108:5,8 227:24

products 100:22

professional 252:17

promote 91:25 92:1

promoter 182:4,5

222:21

promoters 92:7

prompt 252:17

proper 130:14

properly 4:25 173:6

properties 179:19

192:19

property 63:14

192:22 198:3 199:7

199:12

proposed 33:15

165:24 251:4

260:15

pros 189:23

protest 115:19

protocol 120:22

provide 124:24 125:2

253:11

provided 31:21 58:23

58:25 61:10 125:5

providing 111:13

proving 55:7

PST 204:6

published 76:13

pull 136:12,14,16,17

136:23 250:12

pulling 137:10 167:1

punch 38:1

punchhole 38:3

punchholer 37:25

purpose 101:5,5

127:24 181:12

244:25

purposely 74:12

purposes 15:15 32:4

44:13 75:21 229:14

put 4:9 12:8,9 14:22

16:12 28:14 30:9

31:3 36:16,22 60:17

85:6 87:17 93:24

97:13 98:5,7 107:3

112:13 130:8 148:7

148:13 163:15

170:6 179:3 180:25

183:13 201:6 203:2

206:9,12 208:4

209:7 222:4,7

245:17 249:18

254:13,18 255:4

putting 167:13

Q

question 14:21 32:3

32:21 49:24,24

55:23 58:3 59:6,6,7

59:11 61:13,19,21

63:1 65:7,10 69:18

69:20 70:12 77:3

78:21 79:14,25

104:19,20 112:7

116:15 119:12

120:17 122:16

124:6 132:24,25

143:6,17 144:2

145:23,24 146:1,2

146:25 147:21,23

148:23 149:10,23

151:12 156:1 159:2

170:6 195:14,14,20

195:25,25 198:19

203:4,25 204:13

206:3 211:16

212:13,15 213:3,16

213:22,24 214:13

216:21,25 217:2

219:3,5,23 220:1

223:15,22 225:19

228:25 232:25

233:9,11 235:2

239:15 240:3 243:5

243:19,25,25 245:6

245:8 246:5 251:7

251:16,17,22 258:4

questioner 150:6

questioning 7:1

119:19 135:22

questions 4:10 6:22

7:6,13,19 40:10

61:25 65:4 70:17

74:22 78:12 80:16

117:11 125:13,14

144:16 149:24

150:4 165:19 189:4

189:10 194:7

198:18 211:5

216:19 218:7

229:25 232:22

238:6 239:13 247:1

249:4,12 250:25

251:6 253:3 255:6

256:15 257:18

quick 170:3 253:3

quite 7:17 40:15

118:3 137:12

216:19 245:3

257:10 258:18

quote 162:9 241:18

R

radiated 172:23

176:12

radiation 172:17

raise 119:7 170:23

252:10,10

raised 243:7 251:1

ran 66:17 95:3

143:19 162:14,15

Ranches 172:4,8

178:3

range 151:3

rarely 72:9,10

raspy 176:11

rate 9:25 48:1 254:20

258:11,11,13

rates 12:14

reach 108:18

read 86:18 87:2

110:18 191:2 212:7

212:20,21 227:15

229:14 239:15

242:1,23 243:6

reads 212:15

ready 42:2 170:1

180:4 181:13,15

209:8

real 27:2 88:24

112:11 170:2

realize 103:7,8

really 14:4 24:12

53:14 54:14 73:2

77:6,7 79:1 84:1

89:17 132:6 176:2

178:15,19,24 180:8

181:3 193:19

219:16,24 225:5

229:12 232:1 234:5

239:22 240:15

246:14 247:4 254:1

256:21 257:5

reason 6:16 91:20

119:20 141:2

143:15 157:3,24

165:6 172:7 173:14

173:16 240:8

reasons 86:21 173:15

recall 76:5 148:20

156:12,14 225:11

239:24 240:3

recalled 156:3

receive 163:13

183:24 185:11

235:4,5 241:14

246:22 250:16

251:11 252:20

256:18,18 261:9

received 14:22 69:1

88:5,6 121:19

183:16 234:25

235:1

recess 121:24

recognize 26:24

30:23,24 83:15

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85:14 88:3,21

109:14 202:7 257:8

recollect 162:14

recollection 129:21

133:2 239:18

record 3:7,23 8:1

41:3,4 69:14 102:15

103:18 107:4

108:16 113:21

122:1 134:4,5 150:8

165:21 170:11

189:3 201:19

226:22,23 227:15

229:2,14,16 249:10

262:8

records 8:14 138:14

139:9 140:3,5,14,17

141:8 142:10 182:3

recycle 106:1

red 166:22 212:5

redirect 2:15,18 74:2

74:3,4 159:6,7,15

159:17

redo 181:2

refer 61:5 227:8

260:20,25 261:3,3

reference 228:13

references 244:8

referred 230:10

232:8

referring 13:16 31:12

70:9 75:12 243:19

refers 40:16 228:1

243:2

reflect 102:15 156:13

256:14

reflected 140:3,5

reflection 31:2

refresh 30:18 74:23

75:17 225:17

239:18 247:8

refused 62:12 237:5

refusing 238:12

regard 177:6 180:3

regarding 172:20

191:17 213:1 218:8

247:20 255:16

regardless 135:4

regards 240:13

regular 13:13 53:12

53:12,12 205:20

regulations 82:23

83:23 186:17

rehab 68:2

rehabilitation 68:6

rehired 237:11

reimburse 29:22 76:8

101:18 162:13,13

reinstated 239:25

240:4

reinstating 238:11

relate 123:15

related 218:8 231:6

relates 181:23 252:3

257:20

relationship 79:18

relative 147:16

262:10,11

relay 224:19

relaying 177:2

relevance 55:20,22

59:4 62:16 63:9

64:9,11 69:17

123:10,12 124:4

125:11 135:21

144:6 146:24

147:16 149:9 198:9

198:12 207:23

219:22

relevant 77:10,11

144:8 147:23

187:19 210:17

228:21

rely 43:24

remain 36:9 97:2

252:20

remember 10:16 19:1

34:15 54:8,9 56:4

58:2 61:18,19,25

62:2,3 66:11 72:3

73:14 74:7 82:1,8

83:22 85:9,15,17

88:5,7,7 92:17,19

94:19 132:10,11

135:11,14,16

148:22 153:14,17

153:18,19 156:24

157:1,3,4,25 158:14

160:22 178:24

184:8,10 190:2,3,5

193:18,19 194:16

194:21 197:2 225:5

229:7,13 232:21,25

233:2,3 237:13

239:17,22 245:8

247:9,15

reminded 7:16

remodel 221:17,18,25

222:3

removed 175:12

removing 173:11

renew 206:22 208:17

renovations 184:21

rent 68:13,20,22

178:20

repairs 181:7

repeat 149:5 176:20

rephrase 114:20

195:20 206:11

246:16

replace 229:18,21

replaced 181:3

replies 251:2

report 182:4 202:8

262:6

reported 79:21 210:7

224:13 235:2

reporter 4:11,20

10:22 11:8,13 19:6

34:22 40:22 65:8,9

65:15 81:2,12 85:5

87:17,19 120:16

121:8 170:18,21,23

226:12 239:14

250:2,7 262:1,5,23

reporting 55:18 80:4

reports 201:24

202:19 224:18,21

represented 111:3

request 35:8,22 108:5

108:7 226:10 227:1

227:12,23,25

228:14 230:11

256:25 257:23

258:22

requests 229:22

230:6,9

require 216:10

required 11:17,18

14:13 15:5 16:20

17:3 32:15 94:1

95:25 100:22

109:19 116:6 165:9

214:19 215:13

requirement 94:5,7

98:25 99:1 100:5

236:16,18,21,22

requirements 124:17

requires 256:3

requiring 217:12

research 247:20,25

reserve 253:18

reside 171:6 172:3,5

resided 171:22

respect 19:7 74:24

75:18 100:25 113:1

114:16 217:24

respond 5:22 156:17

223:16 257:24

responded 238:10

respondent 1:9 2:5

3:6,14 6:7 35:8,22

251:18

respondent's 4:14

260:12,24

respondents 3:12

253:16

responding 77:4

response 35:8,21

107:16 108:4,7,10

227:18

responses 168:17

229:21,22

responsible 86:12

211:11,17 212:22

rest 15:6 21:7 41:1

163:8 178:23

226:18

restate 62:24 64:22

resting 169:19

result 80:13 98:1

180:1,20 181:7

240:8,12

return 134:25 149:8

149:19

returns 55:8,9,11

126:7,9,10,11,13,16

126:24 134:18

135:3

reupholstering

180:18

reviewed 190:24

revved 223:23,24

RICHARDS 2:3

Rick 28:3,3 54:17

66:18,19,20,20,21

66:22,24 95:3

111:21 128:12

150:23

rid 74:12 107:22

right 4:11 5:21 6:25

11:7,8,10,12,14,15

29:24 31:13,15

33:11 34:4,18 36:1

37:8 38:22 39:1

40:15,19 46:10

49:13,17 50:3 58:11

71:20 72:3 76:13

82:19 85:4 87:17,24

87:25 97:1 106:10

106:11 108:14

115:15 116:8,18

117:7 118:12,22

120:4,5 122:18,24

134:2 141:6 142:19

148:2 149:17 154:3

154:5,7,10 155:23

157:17 159:21,23

160:3 163:14 166:7

167:12,18,22 168:5

168:14 170:23

174:15 178:5 187:5

187:14,21 188:15

188:19 190:16

191:19 197:25

200:4 202:22

212:23 213:1

215:18 222:14

223:1 241:12

246:25 250:8 261:5

right-hand 178:17

242:9

rights 192:17

Robert 223:3

role 66:5,12

room 4:24 8:3 20:22

41:1 83:6 96:20,21

96:22,23,25 97:2,5

97:10,15,16,17,22

98:6 105:2 133:7,15

157:12 159:22

160:11 161:17

162:9 163:19

164:16 177:12

226:18

roughly 117:15

routine 114:10,12,24

115:9 140:22 141:2

146:11

rule 119:8 169:14

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240:19,25 241:4

243:8 257:11

rules 9:22 44:11,13

44:15,17,21,21,22

44:25 45:1,7 64:19

64:20 82:22 83:4,8

83:15,22 84:1,4

86:3 94:22 111:23

111:24 148:17

160:23 186:16,21

252:22

run 67:25 68:7

246:14 254:1

running 17:13,25

67:13 68:7 95:3

113:6 114:8 177:21

185:17 198:1

240:16 246:10

rush 34:4 176:4

191:15 192:3,18

197:6,7

Russians 42:25

S

S-W-E-E-P-E-R-S

95:14

sad 239:8,8

safe 209:5

sails 175:12

sake 166:21

sale 180:4,19 181:13

181:15 183:18

sales 224:18,21

save 7:6

saw 76:18 77:16 78:2

78:15 88:16 184:8,9

184:17 185:21

saying 11:5 17:25

29:12,14 31:22

32:17 47:8 88:8

90:14 91:1 101:8

128:4 139:9 142:6

142:25 145:7

175:24 176:17

177:20 191:15

206:17 228:17

240:2 244:20 245:1

says 21:2 35:21 75:4

75:5 86:1 102:21

103:6,6 110:4

167:18 168:3,13,16

201:4,7,9 203:22

204:7 228:10,12

229:16,20 238:2

243:3,17 244:12,15

244:19 245:12

schedule 9:21 51:9

114:7,14 140:23

142:3,7

school 42:18 122:17

122:23 173:21

scratch 168:20

se 173:2

second 11:24 16:20

20:5 34:8 75:15

103:2,3,6,10 116:15

118:22 150:1

154:21 166:20

199:17 219:20

223:14 242:6

seconds 154:25 155:1

155:5,7

secretary 178:17

187:12,24 202:10

202:21,22 203:5,11

204:3,6,15,24 205:8

205:14 209:22,24

234:17

section 129:12 130:23

131:2,4,5 153:13

251:14

sections 112:25

securities 48:15

security 18:6,8 22:6

22:14 48:14,16,19

62:4,6,13,18 83:3

83:25 84:9 93:23

94:6,20 100:25

101:2,5,8 106:8

109:19 111:11,13

115:7,17,20 116:25

148:11 161:12

164:5,24 218:1

see 7:19 27:17,20

28:25 29:6 31:18

32:5,10 40:16,19

41:8 44:15 45:3

49:16 61:13 63:10

76:21 80:24 84:23

87:14,15 99:5

102:22 103:11

124:5,7 128:19

135:24 137:5

139:14 147:18

152:7 173:1,5 179:5

180:5,17 186:25

193:3 199:4 202:19

208:15 209:3 228:5

243:8 252:6

seeing 41:16 119:16

129:7 259:16

seeking 39:19

seen 31:1 59:25 60:23

60:25 67:16,17

85:19 118:25

121:10 122:14

132:14,17 187:16

201:14

select 221:19

selected 221:17,20

229:17

selecting 19:10

self-employed 122:8

self-made 177:15

sell 180:4,11,23

181:16,22

semi-nude 215:7

send 12:10 92:2

97:10 255:20 258:5

sense 125:8 190:16

228:17

sent 12:15 36:6

separate 6:5 93:25

96:3 119:1 179:4

September 49:11

51:18 172:16

series 107:7

service 199:25

260:16

sessions 154:24

set 4:24 6:18 20:2,4

82:22 86:14 96:13

99:18 112:11

sets 19:25 20:7 86:13

112:7,9

setting 4:1 233:8

settled 220:16 221:14

settlement 197:19

220:19,22,23

221:15

settlements 213:13,23

setup 5:1

seven 23:10,11,13,15

23:16,16 141:20

159:3 198:7 199:2

212:15 250:2,4

shape 175:18

share 256:16

sharp 26:8

sheet 94:12

shift 10:10 12:6 14:14

15:6,23 17:17 20:19

23:4,5 44:2 48:1,1,2

48:2 83:2 91:8

101:14 102:6 104:8

105:16 139:21

shifts 91:21 139:6

shirt 49:18

shocked 176:3

shoot 256:4

short 155:24 159:5

show 10:5 12:14

39:25 83:14,14,18

84:20 85:7 87:3

106:9 108:15

120:24 126:7

137:16 139:20

185:24 186:6,14

189:7 198:11,12

200:13 201:2 212:4

225:7,19,23 227:11

237:14 241:24

showed 30:17 74:24

225:16

shower 100:16,17

showers 100:15

shown 239:17

shows 24:22 86:24

shut 6:15

sic 132:7

sick 177:13

side 4:15 67:19

112:24 253:2,11

254:19

sides 257:8

sign 12:5,7 83:12

85:20 94:10 105:18

106:7 111:19 139:8

193:17 205:23

206:6 215:14

234:17 237:1,5

238:12

sign-in 94:12 112:3,7

signatory 234:7

signature 109:8

204:19,21,22 205:1

205:3,4,6,7,12,20

205:20 207:12,17

208:5,6,9 234:11

signatures 207:5

signed 21:18,19,22

86:9 87:24 111:5

206:4,8,9 207:16,19

208:4 220:21,23

221:15 222:25

223:2,6 234:14

signing 216:24

234:12

signs 21:1

similar 41:8 117:15

198:22 243:7

Simmons 33:18 35:13

36:2 37:12

Simmons' 107:16

Simons 35:19

Simons' 35:7,21

simpler 119:13

simply 120:20 251:5

singles 16:3,4 18:24

20:14 21:15

sir 7:11 69:13 89:23

90:15 91:2 95:15

104:14 112:17

122:9,15 123:8

125:4,6 126:25

127:11,17 129:19

130:20 132:13

134:16 135:16,18

136:22,24 138:9,11

138:13 139:1,22

140:18 141:4,10,24

142:20,22,24 143:2

143:4,13 146:21

148:3 152:10,17

154:2 159:13 228:1

sit 4:11 161:9

sitting 26:25 88:22

193:3 194:21

200:18

six 23:8,17 28:16 50:3

54:10,11 161:7

six-page 106:16

107:5

slip 21:20 22:1

105:18,19 106:3,5,7

109:7 110:25 111:1

111:3,9,13,17,19

117:3 168:18

slips 107:2,6,14 109:7

109:14,16,18,21,23

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117:7 132:12,19

133:1 166:6,11

168:19 169:8 186:9

187:3

slow 8:3 9:11 13:8

19:4 27:9 60:19

165:8,9,13 192:5,17

small 174:1,4,12

178:14 179:25

200:16

smart 96:25 110:9

snacks 100:18

social 54:23,24 62:4,6

62:12,18 218:1

sold 174:1,8 183:3,25

184:4 190:11,23

208:1 215:10

somebody 11:9 97:4

119:15 124:8,9

142:11 188:9

son 29:1 54:20,20

55:6 68:1,9,24

173:21 182:2

son's 182:3

Sonders 209:21 224:4

song 20:4,5,5 82:12

86:13 162:25 163:1

songs 19:11,24 20:4

82:11 99:18

soon 107:4 179:17

sorry 8:5 9:12 10:19

11:6 16:5,7 17:8,16

19:5 23:12,14,15

25:5 26:5 27:10

29:5 31:14 33:17,24

34:13 35:3 38:10

39:6,13 41:22 42:3

42:13 43:11 47:4

56:22,23 58:3 59:23

60:20 61:7 64:10

65:6 69:22 71:16

72:6 76:6 79:13

81:5,7 83:20 84:24

85:3 87:5,10 88:10

89:19 90:10 92:3,9

95:11,21 97:13

99:20 102:1 103:1

104:8,10 105:14,25

107:9 108:2 109:17

112:6,8 114:21

120:11 126:19,21

131:12,15 132:21

136:13 138:18

141:14 142:1,2

151:6 153:11

155:15 156:25

165:19 166:8 167:2

167:8,13 168:1,5

172:11,13 177:18

190:8 194:15,15

198:12 201:10,20

203:25 204:1

209:18 210:13

211:5 214:25 216:5

217:17 220:10

223:3,8 228:23

230:18 232:19

233:17 234:13

236:1 238:1 239:8

242:1

sort 33:13 161:20

193:18

sounds 65:2 220:14

South 42:15 68:3

86:2 145:12 174:7

178:2 191:7,16

192:4,24 196:1,10

197:13,15,22

209:13 214:6

219:10,18

Southwest 172:4,7

178:3

spa 69:21

space 178:8,16,20

211:1

span 172:24

Spanish 43:1

speak 4:13,15 39:11

60:4 79:2 86:22,22

129:6 162:15

164:15 208:11

209:4 211:2,21

speaking 126:19

177:1

specific 70:12 78:4

79:14 132:9,11

134:10 136:3

148:22 151:15

152:13 153:24

154:9,18 156:24

158:23 165:7

203:14 212:10

specifically 132:2

150:11,13,17

153:21 156:3

160:21 161:9 175:4

177:25 214:6

215:19 216:1

224:12 232:18

236:24 241:23

259:25 260:1

specifics 219:24

specify 77:4

speculation 132:20

132:23,24 144:1,5

spell 8:7,15 10:21

11:1 65:14,17,19,22

72:19

spelled 8:11

spend 51:21 181:9

259:14,15

spent 24:24 161:6

174:23 258:16

split 113:5 131:5

160:7,8 161:5 163:8

spoke 80:6 142:21

211:7

spot 49:17 82:19

spring 13:2,3

square 43:15,16

178:15 180:8,9

St 175:8

staff 18:6,8 188:22

193:23 220:12

stage 11:19,20,21,22

16:8 19:18 45:9,10

45:11,12,13 58:23

59:15,17,17,19,21

59:22 86:13 96:13

96:15 98:15 112:7,9

112:11,14 124:24

stages 95:20 112:18

112:19,22,23,24

113:1,2,5,6 181:6

stairs 179:6

stand 170:6

standpoint 4:23

147:16

staple 118:16,22

stapled 106:21

stapler 106:20

118:16

start 6:25 7:12 10:15

13:4,18,19 15:1

25:24,25 80:25 93:5

103:13 187:18

252:18,21,25

started 9:4 50:24

51:2 89:11 93:14

100:17 110:9

126:24 141:6 146:4

146:5,8 148:20

149:15 172:24

173:4 175:4 179:17

183:6 248:24

starting 6:24 107:8

184:24

starts 93:5

state 8:1 70:12 81:12

128:8 145:14

170:14,24 171:4

201:24 255:25

stated 29:5 115:21

159:19

statement 5:13,18

183:1 245:9

States 144:11

stationed 9:17

statute 6:6

stay 26:11 46:3 48:11

68:3 97:5 143:5,8

145:9,18,24 146:2

146:18 147:12

249:18

stayed 48:5 129:10

130:4 146:9,10,16

147:22

stays 54:21

stealing 94:20

steering 241:19,19,22

244:4 245:9,22

Stephanie 4:10 37:9

40:21 81:1 103:2

106:20 262:4,22

steps 180:12

Steve 203:9 204:4,8

204:12,18,25

205:15 209:17,19

209:19 221:21

224:1 234:11,14

stick 38:2 46:7

stipulated 14:6

stipulating 81:3

stole 157:9,10

stolen 73:9,18 158:1

158:4,8,15 162:10

162:16,18

stop 8:21 89:14 90:24

120:25 156:11

stopped 22:3,4 70:8,8

89:13 122:23

139:19 146:12

155:25 173:5

175:22

stopping 120:6

store 60:16,21 174:11

174:17 178:5

210:21

story 72:16,18,19

119:10 156:17

strabismus 173:3

straighten 130:13

167:21

street 209:2

strict 116:12

strictly 199:14

strike 22:18 24:2 39:6

90:11 91:7 92:3

94:8 95:7 97:13

102:1 109:17 112:2

122:16 160:16

164:12 165:19

181:23 183:7

190:25 217:17

222:10 223:8

230:18 232:16

stringent 94:24

strip 212:23

stripper 140:25

149:22

strippers 127:12

study 257:10

stuff 68:16,17 79:12

100:19 115:22

181:5

styled 219:9 221:7

240:7 247:2

subject 86:23 119:3

152:5

submission 250:14

256:6,7 257:25

258:15 259:2

submissions 6:19

135:25 250:25

252:21 253:1,14

255:13 256:19,20

258:10 261:9

submit 251:4 254:21

submitted 118:15

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subsequent 207:4

succeeded 258:20,21

succinct 256:24 257:1

257:3

suggested 3:24

suggestion 117:13

suing 142:11

suit 221:1

summary 6:3 34:14

167:25 168:2,9

169:11

sums 99:12

Sunday 13:9

Sundays 165:8

supervised 210:9

support 141:9 172:17

supporting 123:9,13

supports 6:14

supposed 6:25 135:4

145:11 157:12

sure 4:17 5:5 11:8

53:8 58:20,21 63:1

64:13 68:4,9 77:5

79:1 89:17 105:20

115:1 118:17,21

120:4,9 126:14

130:13 132:6 133:4

137:12 138:16

144:4 145:25

149:11 186:4 190:5

199:17 201:10

205:21 208:20

209:24 210:4

218:19 220:20

223:15 226:21

234:10 235:24

238:21 240:21

252:10 257:19

surprise 63:8,17

surprised 176:2

surprising 188:3

surrounds 212:13

suspend 18:21 64:2

suspended 64:4 98:4

sustain 123:18

sustained 46:24

swear 4:3,3,20

170:18,21,22

sweepers 95:9,12,13

95:14,22,23,25 96:2

96:4 97:10,13,20

switched 9:5 42:22,22

168:6

sworn 4:3 5:9,10

81:16 171:1

symmetry 37:15

system 218:18

T

T-A-N-G-A-L-A 11:3

table 26:25 96:5

176:2 200:18

tabs 108:12 260:5

tackling 180:5

take 16:3,7,9,11

18:23,24 20:12 21:6

22:13 25:12,23

28:19,24 29:9,19

33:12 35:18 36:21

41:2 49:19 50:8,9

51:23 52:17,18

54:12 60:16 69:19

76:11 82:17 87:1

90:19 96:22,22 97:1

97:9,12,19,20 98:11

99:2 100:17 103:10

110:16 122:20,21

154:25 160:8 161:8

162:3 179:15

202:15 207:9

237:16 250:1 251:6

254:3,24 257:2

258:19,21 260:14

taken 52:17 162:19

251:23,24

takes 256:23 257:5,6

talk 6:17 8:5 60:20

91:8 170:2 171:22

214:4 234:20

249:16 253:8 255:8

256:3 258:12,23

talked 45:19 67:16

79:7 111:23 243:15

243:15 251:4

talking 4:16 55:17

58:16 60:24 67:17

68:19 73:4 79:11

81:6 85:18 93:22

102:13 118:9

123:17 129:9

137:13,17 147:13

156:11 157:22

176:21 183:19

207:7 211:4,19

216:1 223:19 228:5

228:6 236:2 239:9

243:13 244:11

250:19 259:15,25

261:2

Tan 10:18,20,23 11:5

11:9,25 94:10

112:10,13 124:19

124:21 139:12,14

139:16,18 140:16

Tangala 11:3

tax 55:8,8,11 126:7,9

126:9,11,13,16,24

134:18,25 135:2

149:7,19

taxes 62:3 113:10,12

113:15 126:14,17

126:21,23 135:4

149:11,18,21,21

182:14 217:22,23

234:23 235:3,5

236:8

technically 199:25

233:20

tell 4:17 7:2 9:8 27:6

35:11 36:5 39:5

41:23 42:3 44:25

51:18 52:8 58:17,18

60:22 68:12 70:2

72:15,19 75:21

79:20 80:3,6,9,12

82:4 84:6 85:25

89:3,9 90:6,10

93:18 100:12

101:12,25 102:2,10

103:24,25 104:6

110:12 111:15,18

114:3 129:11 132:2

134:8 136:25 144:7

150:11,13,17,20

171:8 176:17,18,19

176:19 180:6 181:4

182:22 183:15

195:24 204:1,1,10

204:14,19 243:21

244:16 251:13

telling 4:21 32:11

36:24 127:7

ten 16:3,7,11,19,20

16:23 20:10 21:5,6

21:9,12 22:15 24:19

28:1 52:16,18 83:2

83:25 98:11,12,14

98:15,17,20,22,23

99:2,7,9,11,13

101:9 105:14,15

109:8,23 110:9

116:13,14 130:14

154:25 155:1,5,7

160:8 161:8 162:1

169:7 250:2,4

Teri 1:8 2:19 3:5,14

6:1 35:8,22 59:24

60:2,4,6,22 63:25

64:2 95:3 122:10

124:11 128:19

129:17 132:18

148:16 162:23

163:4 165:25 166:5

166:9,13 167:9,16

168:9 170:16,25

171:5

term 11:25

terminated 193:15,18

237:6,8,10 238:11

239:25

terms 102:3 256:21

terrible 49:7

testified 74:6 76:18

90:4 114:21 130:2

134:17 137:8 156:1

156:15,20 159:24

178:3 195:7 196:16

221:16 222:24

236:11

testify 156:7

testimony 46:23 74:8

79:5 90:1 112:16

135:23 143:1

145:21 151:3

161:25 184:11

213:8 222:11 223:5

231:2 232:13

242:21 251:19

Texas 89:18,21,22

141:17 143:12,14

143:18,20,21,23

144:7

text 91:19

texted 12:15

thank 38:6,21 40:22

59:8 65:5 69:25

75:9 80:17 81:2

86:25 122:2,22

137:4 151:23

159:16 165:20

186:3 194:8 199:5

208:15 219:8

227:13 230:3

232:14 249:15

252:12,14,16 261:7

261:10,13,14

Thanksgiving 176:2

thing 4:13 24:7,11,11

24:12 30:9 33:1

35:12 46:12,14

51:11 52:13 54:21

128:4 167:12

179:16 186:25

187:3 207:18

218:15

things 7:16 11:18,20

19:17 49:5 68:6,19

173:19 178:18

188:2 190:7 208:3

236:10 245:21

248:17,24 249:24

255:8 258:23

think 4:25 5:19,23

6:16 7:5 24:23

28:13 38:9 49:5

50:18 51:25 55:14

55:15 59:21 61:24

64:10 70:17 73:3

74:1 78:17,18

101:23 102:3

110:19 116:8

117:24 118:2

120:10 121:10

142:6 145:22

151:19 154:14,22

158:19,19,20

172:15 175:11

179:16 180:22

181:4,5 184:14

185:15 190:16,18

193:1 194:25 195:6

195:17,18 196:5

197:17 199:25

206:25 214:16

215:15,24 216:12

227:10 234:11

235:1,6 241:20,22

244:14 245:3

246:21 249:8

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252:22 253:19,22

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thinking 56:20,23

142:4,7 234:5

third 20:5 82:12

thought 5:15 149:16

173:8 191:23

three 20:4 42:19 50:8

76:5 82:11 84:15

106:13 118:5

130:10 131:9

139:25 145:25

150:4 154:24 170:9

172:15 238:16

threw 73:8,12

throat 176:12

throw 73:11

throwing 96:6 161:2

thrown 160:19

thumb 119:8

Thursdays 165:6

ticket 21:20 208:21

208:23 226:7

Till 42:5

time 9:1 13:11 14:5,8

18:18 23:5,25 24:1

24:14,17 26:6,14

27:20 28:11,20

33:12 39:9 46:9

50:14,24 51:13 52:6

53:12,23 55:14,16

55:24 60:25 67:17

71:4,6 72:17 73:23

73:25 76:25 77:4,5

77:6,9,10,11,13

78:6,9,13 82:7,10

82:25 84:2 85:15

88:12 90:19 91:10

99:4,12 100:20

101:19 102:4 104:6

104:11 105:3

111:22 113:10,23

115:3,19,25 116:9

118:3 123:1 128:12

129:7 138:20 142:8

143:11 147:1

148:22 149:12,17

152:2 161:2,10

171:23 174:23

175:1,1,21,25

176:10 177:6,6

178:7 183:3 184:2,3

186:23,24 193:14

198:24 207:10

210:15,17,25,25

211:2,2,4,19 212:10

212:12 215:18

216:13 219:13

220:9 224:9 225:13

229:10 235:24

236:25 237:10

238:8 242:19 248:7

248:11 250:12

252:2,15,23 253:20

259:14,15 261:13

261:14

times 12:21 13:6,8

23:1 24:4,23 25:1

28:15 75:25 84:15

90:4 101:9 104:16

131:7,9,9 141:16

147:19 158:23

162:11 164:17

174:22 254:16

timesed 102:4

tip 17:3,5 19:15 25:16

27:25 28:1,3 45:2

48:18 95:25 99:15

100:1,19,22 110:5

112:13 164:10,13

164:23 235:14,16

235:18

tip-out 20:10 30:2

92:25 93:2 94:20

109:8 111:5 148:11

tip-outs 18:15 22:21

23:24 27:21 29:23

53:20 93:23 113:18

116:25 142:21

tipped 100:4

tipping 18:14,19

19:13 83:3,25 84:8

84:17,19 101:10

115:20 148:11,12

tips 16:1,16 113:7

235:10 246:12

251:22

titled 83:15 92:14

189:8

Tobin 2:5,9,15,17

3:13 5:4,6,17 31:6

40:20 41:10,13

46:25 49:20 50:11

57:6 59:7,9 60:18

61:15 62:18,21 63:3

64:13,15 65:7,8,11

66:2,9 69:11,15,25

70:1,6,15 72:23

73:1,5,6,23 74:1

75:10 77:3,13 85:2

117:15,16 122:1,2,4

123:12,15,17,20

131:17 133:3,5,14

134:7 136:1,20

137:5,14 138:4,24

143:7 144:7,9,14,17

146:19 147:23

148:4,24,25 149:6

149:24 150:7,10

151:22,23,24 155:6

155:11 156:5,7,15

156:22 158:11

159:1,3,5 169:20

211:24 214:2 239:7

255:5 261:13

today 3:19 6:11,22

30:12 36:21 118:3

118:12 123:14

184:9 185:22

187:10 256:10

257:12 259:18

told 36:19 56:24 57:1

57:17 62:14 63:7,16

68:14 79:8 127:8

135:3 177:12

182:13 188:1,9

203:1 227:10

top 82:12 85:25

112:12 151:16

242:6,9

topless 20:5

total 30:14 39:6,8

56:13,19 57:1,11

102:10,13 104:1,2

totally 48:4 91:5

94:22 167:20

245:14

touchy 218:15

towels 100:14

town 9:15 12:19 13:5

59:20

track 15:22 16:1 26:5

31:17 68:5 113:7

142:7 235:7,7,10,20

236:9

trade 237:23

trademark 199:10,13

199:23 200:2,3,3

231:10

transcript 166:1,1,6

166:10,14,23 167:9

212:6,12 243:2,8,20

244:3,7 245:1 250:1

250:5,13,18 255:3

262:7

transcripts 250:17

transpired 180:2

transported 161:16

trash 157:16 163:15

treasure 203:6

treasurer 187:12,24

202:10,21,23

203:11 204:3,6,15

204:24 205:9,13

234:18

treated 128:9 172:10

trial 166:22 212:5,6

TRIBUNAL 1:2

tried 111:16 179:17

218:16,20

trouble 4:16 131:20

150:24

true 31:2 48:5 88:15

184:13 197:24

198:2,4 202:9 210:1

210:6,9,12 211:10

211:16 213:12

214:7,9,17 219:17

220:1,7,11,15,18,21

220:25 222:16

224:14,17,23 225:1

225:12 227:4,19

229:19 230:21

233:19 234:1,9

236:15 237:1,4,9

238:8 240:7,18,22

240:25 241:17

247:10,12,17 262:7

Truman 210:21

truncate 256:5

Trust 40:4

truth 4:21

try 78:5 167:21

179:18 223:20

257:3

trying 58:15 59:7

107:24 108:19

110:20 197:2

216:12 223:20

256:5

Tuesday 93:17

Tuesdays 165:6

turn 175:6

turned 110:8 111:1

124:15 159:2

twelve 24:20 28:17

50:5

twice 213:25

two 35:2 39:23 42:19

48:15 84:16 90:9

96:3 106:13 107:7

107:13 112:20,24

112:24 113:3,4,5

134:13 140:1

145:25 147:19

150:23 162:22

165:10 169:7 172:6

178:3 193:15

197:20 208:3 209:7

229:15 238:15

239:10 242:3,5,5

257:18

type 74:7 104:24

110:25 111:1 153:3

208:6 245:2

types 109:16,18,22

111:20

typical 10:8 92:22

163:23

typically 25:23 91:10

104:7,23

typing 19:6

U

Uh-huh 28:7 43:6

45:21 47:21 57:15

58:24 151:2

ultimate 195:15

ultimately 181:16

183:24

umbrella 196:10

uncomfortable 95:5

understand 5:23 7:14

16:6 17:15 26:6

32:16 39:18 53:24

71:15 90:22 91:5

103:15 107:25

109:1 110:17,23

111:2 135:7 146:4,5

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146:7 168:23

176:13 199:17

200:4 203:3 225:8

232:4

understanding 9:19

148:2 260:8,17

Understood 227:13

undertook 180:13

Unemployment 218:5

United 144:11

universe 196:2

unquote 162:9 241:18

unsigned 223:6

unwieldy 106:12

upholstery 180:24

upper 173:11

upstairs 11:16 20:15

urban 43:3

use 14:7 38:5 40:25

68:11 75:24 109:23

113:12 205:19

226:18 232:6 238:5

usually 16:12 29:15

29:16

utilize 179:2 211:1

utilized 178:8

V

v 5:25 194:20 220:12

221:1,8 232:18,20

232:24 240:7 247:2

VA 122:25

vacations 28:19 50:7

valuations 245:19

Vanity 54:18 89:5,12

various 185:21

213:13 214:4

246:11

Vegas 171:21,23,25

172:2,8 173:17,24

173:25 174:3,22

192:3,25

vendors 221:17,19,20

verbal 20:6

verbatim 92:18

157:25

verify 161:22

versus 3:5 123:18

219:10

vice 204:8,18 205:15

Virgo 28:13 49:2,4,7

49:14 68:19

visit 141:18

visited 179:19

voice 176:11

voluminous 242:2

volunteer 79:3

vouched 163:5

VP 238:2

vs- 1:6

W

W-2 235:16

W-2s 127:11 149:13

218:17

wage 28:15,17 48:22

50:2 54:10,11 58:1

58:2,4,11,18 74:23

75:7,18,22 76:12

102:4 152:2 164:10

194:23 211:3,11,17

218:19 221:1,5,8,12

232:21 233:4,13,17

235:15 247:8,20

248:3

wages 39:6,8 48:21

49:25 57:24 101:19

102:3,11,13 152:8

233:19

wait 31:4 60:19

104:18 105:3

129:16 130:11

167:19 173:20

waiters 193:10,23

waiting 255:2

waitresses 193:10,23

waking 140:24

walk 26:1 52:15

116:14 139:8

158:13 259:18

walk-through 180:15

walked 158:12

walking 12:20 26:12

68:18 105:21,22

148:14

wand 48:17

want 5:15,17,22 6:10

7:2,2,10,20 11:7

14:7,11,17,22 22:12

41:20,23 44:14 45:4

45:5 49:21,22 72:18

75:8 81:10 83:18

85:7 86:13 89:16

90:18,22 91:3 96:10

97:7 103:17 110:17

111:2 118:21 120:8

127:21 129:11

135:5 136:5,6,7,9

136:15,15 152:14

152:24 153:24

154:4,8,9,16,16,17

154:18 155:20

159:3,7 161:5

168:22 170:5,18

182:7,8 189:10

193:16 200:12

201:10 206:22

207:14 208:12,21

213:6 226:6,19

227:11 235:24

238:16 241:25

249:9 252:9 255:18

255:19,23 257:11

259:1,7,14,15,18

260:25 261:3

wanted 44:18,18,19

48:11 60:21 95:2

98:13 110:15,16

144:12 173:20

176:19 179:5 180:4

181:14,22 182:1,5,7

182:9,20 185:1

222:19 261:6

wanting 49:19

wants 11:1 36:14

75:11 156:17

warehouse 178:23

179:1 180:10

210:20,23

wasn't 29:2,6 38:24

42:20,23 44:20,20

57:1 59:3 60:23

61:10 68:10 77:2

83:7 101:7 104:25

127:4,11,18,24

128:10,10,13

139:24 142:7

144:18 145:2,5

146:15 149:13,18

153:22 160:5 161:4

162:19 179:7 188:1

194:24 195:14,25

220:1 222:24,24

230:23 232:2 234:5

235:9 239:4,20

248:10 249:2

waste 14:8

watch 68:2,4 101:7,9

155:8

watching 68:9,25

101:10

way 13:14 37:14 55:7

59:18 62:12 69:16

78:15,17 83:18

89:12 90:21 95:2

98:22 114:9 118:24

119:19,22 120:18

120:20 121:3

122:21 140:23

145:19 146:16

149:7 173:17

175:15,18 177:2

191:10,12 228:18

238:5 246:11

260:21

ways 68:10

we'll 4:2 6:16,16

11:15 15:16 37:8

41:4,8 80:24,25

106:21 117:23

118:2 124:5 134:2

135:24 150:6 209:3

226:15,16 252:25

255:21 256:4

we're 3:3 4:25 5:2,24

11:17 13:15,18 14:7

16:9 22:23 31:11,23

31:25 33:25 34:5

36:8,20 40:11,23

46:1 73:4 75:12

107:4,13 108:19

118:9,10,11 119:22

120:18 121:13,25

123:17 128:25,25

131:6 147:13 149:4

170:1 201:11 207:7

235:24 240:14

243:13 244:11,17

244:20 249:8

250:19 257:24

261:8

we've 5:16 36:23

38:22 121:10

185:15 188:13

199:1 233:6

wear 173:4

Wednesday 25:13,13

25:14

Wednesdays 165:6

week 12:25 23:6,7,8

23:10,16 24:7,11

25:11 28:16 30:10

48:24 50:3 51:10

54:11 90:7,8,9

101:13,13 102:6

103:17 114:4

118:21 139:6,25

140:2,4 141:20

165:8,10

weekday 26:17

weekend 26:16 82:7

92:15 158:20,21,23

158:24,25

weekly 182:18

weeks 23:14,15,17

28:22 51:10 82:6

103:14 138:12,15

139:3 140:12 141:3

141:5,11 142:14

176:3

weighing 189:23

weight 241:13

welcome 14:23

well-loved 177:14

well-missed 177:14

went 28:15 39:22

42:17,17,19 43:4

45:19 63:22 73:13

96:21 131:19

139:17 141:16,18

141:18 152:1

160:11 162:8

163:10,20 173:10

173:22 174:22

175:5,9 182:15

222:21,23 223:11

231:11

weren't 47:23,24

59:17 127:22 128:2

143:18 157:19

177:21 215:3,22

221:12 224:15

West 174:11,17 178:5

Weston 172:13

wheel 241:19,19,22

244:4 245:9,22

whirlwind 245:21

white 87:10

wholesale 227:5,9,17

228:11

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WiFi 137:9

willfulness 64:25

251:16

Williams 189:20

191:5,6,7,18 209:12

209:13 211:3,7,10

211:16 212:16

213:12 216:3

wind 175:12

wine 215:10

wipes 100:14

wish 6:23 38:1

120:22 133:6,21

169:16

witness 4:5 5:10 8:12

8:16 10:20,23 11:6

11:10,15 16:7 17:10

17:12,16 23:14 26:7

26:10,16,20,22

27:12 29:15,18 39:3

39:14,16,25 40:20

49:16 50:2 56:23

57:4 60:15 65:20

66:7,13 70:14 72:21

73:2 79:8 80:1,17

80:22 81:14,16 85:7

85:9 86:7 87:6

89:21,23 90:15 91:2

91:5 95:13,15

102:16,23,25 103:4

104:12,14 105:23

106:1 109:2 110:7

110:20 111:6 121:5

121:7 131:15 133:2

133:16,18 136:19

137:4,9,16,17

144:13 146:3,6,10

148:3 149:3 156:6

156:10 159:4,9,13

170:25 171:1

190:10,13 192:10

192:13 198:16,20

199:22 200:2 202:3

202:18 203:1,8,11

207:21 208:16,19

208:23 209:5,7

212:1 214:1 226:18

226:21 232:14

239:20 241:4 244:6

249:15

witnesses 3:19 252:13

woke 140:25

women's 252:13

wondering 103:13

word 90:14 176:18

176:18,20,20 177:4

177:4 232:6,9

words 17:15 260:14

work 9:13,17,18,23

9:23,24 10:7,10,15

11:16 14:2 15:6

19:14,19 21:13

22:25 23:5,7,8,9,11

23:13,14,15,17 24:8

24:15,18,19 25:2

27:14 29:7 30:10

36:21 43:4 46:1

47:18 48:8 52:25

53:2,22 54:14 71:21

83:1 85:17 86:20

88:8,9 90:4,5

101:14,20 105:4

112:3 114:9 118:6

123:21 124:2,24

125:5,18 128:22

132:8 138:20 142:3

142:7 143:10

144:12,14,18,21,22

144:24 145:5,11,18

148:15 165:9

214:17 216:10

218:17 237:2

246:18 250:22

worked 9:4 16:2 24:4

27:19,19 42:21

43:20 47:15,16

48:24 51:3,3,7,7,8

51:22 58:10 67:2

74:17 89:7,8,10

90:7,8 101:19 102:5

102:6 114:4,6 115:4

123:7,22 126:1,8

129:24 131:8

138:12,15 139:3,6

139:20,24 140:2

141:5,11,19,23

146:20 147:1,2,2

148:10 149:16,20

152:2,3 161:1

163:12 164:11,17

165:17,18 189:18

224:10,12 236:18

257:7

workers 128:7

189:17 193:11

working 9:4 10:3,15

22:23 34:1 46:6

47:12 69:16 82:17

82:21 89:11,13,14

92:23 93:9,14

115:10 119:5 131:4

139:19 146:13,15

147:7 149:15,18

155:25 163:19

173:5 236:16

243:12 248:10

workman's 218:3

works 9:20 38:23

145:12 147:17

worried 121:7

worries 5:6

worry 120:7 232:11

worst 175:7

wouldn't 52:21 54:4

59:21 68:25 92:6

99:5 128:25 129:14

129:14 134:20

142:10 144:13

154:11,13 158:4,8

165:13 226:5 232:1

233:20 246:6,9

wrap 179:18

write 16:16 23:23

24:3,6,13 33:13

70:24 113:13,17

139:14 256:23

257:5

writing 257:4 259:12

writings 70:24

written 39:10 54:9

58:22 182:19 200:6

200:9

wrong 8:11 57:4

103:2,15 153:25

154:10 160:1

wrote 6:9 71:2,11,12

98:9 139:13

X

X 204:7

Y

yeah 10:18 11:6 12:2

13:18,20,22 17:12

18:21 20:12 22:2

23:11 24:21 27:12

28:3,4,13 29:15,19

29:20 30:3,25 35:20

39:23 43:10 44:5

45:24 46:11,16,19

47:17 48:11 49:9,12

57:4,20 58:3 59:16

62:8 64:8 66:16,19

66:24 67:2,5 68:14

68:21,23 72:3,15

73:2 119:11 121:15

123:24 131:20

137:24 159:4

188:16 190:19

194:21,23,25 195:6

195:24 197:14,25

200:2 206:21,25

208:19 221:23

222:1,4 230:25

237:13 238:4

240:21 242:10

251:9 252:9 254:13

258:1

year 8:24 28:17,23

29:3,9,13 30:13

41:18 48:23 50:12

53:25 54:1,2,11

55:13 56:1,14 57:9

58:14 67:9,11 70:2

89:21 122:19

123:25 131:18,19

132:4 134:8,23

135:7,12 138:12,15

139:6 141:3,5,7,11

141:20 145:24,25

145:25 147:3,4,5,7

147:7,25 148:6,6

149:15,16,20

150:25 151:8

152:12,15 153:23

154:15,19 155:12

155:19,23,24,24,25

158:16,21 172:18

174:5 190:3 244:13

244:21 248:21,23

248:24

years 28:14 42:3 46:8

50:4 57:10,19,20,22

57:23 58:11,16 67:5

67:10 75:18 76:6,13

89:7,9,9 114:6

122:16 123:24

129:8 131:8,10

140:22 141:1

142:16 147:2 148:1

154:6,7 188:5 198:7

205:25 207:4

yell 176:14

yelled 98:2

yesterday 34:17 35:7

35:11,12 107:20,21

194:18,19 227:10

you-all 257:12

young 26:24 55:24

88:21 159:25 160:4

237:5 238:11 240:4

246:12,17

Z

zero 208:19

Zoom 62:5

0

01-20-0005-4874 1:3

1

1 86:11,18,18 200:14

200:19 201:4,6,8

260:12,24 262:7

1,000 72:4,7

1,500 178:15

1:15 118:4,7

1:30 118:6 121:22,23

10 17:6,17 20:13

86:15 110:5,16

237:22 251:13

10,000 63:7 130:10

130:15

10:00 24:25 91:12

93:5 105:1 114:9

130:4

100 20:12,13 22:25

40:17 44:6,7 93:15

112:13 215:1,5

1099 159:8,8

1099s 159:11

11 51:18 57:23 212:7

237:15,22 238:1,3

242:19,24,24

11:00 91:14 105:5,7

130:4

11:30 80:23

11th 49:11

12 57:23 84:21 85:2,5

85:6,22 186:15

188:1,7

12:00 13:11,11 91:14

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12:12 117:12

12:30 91:15

122 2:17

13 57:23 142:18

179:20 216:21

217:4 227:16

230:12,13

14 57:23 131:14

142:18 190:4,13,13

190:14,18 207:11

207:22 216:21

217:4 230:13,14

242:24

15 190:6,9,10,17,22

207:13,14,25

230:14 243:19

150 14:14 15:4 40:17

53:23

159 2:18

15th 32:24 33:1,4

121:15 169:2

260:16

16 207:2,4,7,14,18,19

207:25 215:4

230:14

16th 107:11

17 207:2,4,8,14,25

243:21

170 2:19

18 141:11 207:2,5,8

225:24 226:14,14

226:25 244:2

19 1:15

194 2:20

1982 171:13

1987 171:24

1A 260:12,24

1st 171:17,18 175:14

175:19 177:24

179:8,11 185:11,17

187:22 217:4 218:9

236:3,4 243:20

244:16 246:1

247:22 250:19

252:4

2

2,000 72:12

20 17:17 54:20 61:6

110:5 257:5

20,000 143:24 153:7

153:14,17 160:2

200 11:21 13:12,13

21:6 52:17 110:6,8

2000 126:18 187:19

198:7

2004 59:23 131:11,13

2005 172:9,19,21

2008 41:20 42:4 43:4

51:5,12,16,18,21,24

51:25 56:1,3 57:11

58:10 174:1,8

187:18 188:6

201:16,25 204:3

2009 8:19 24:3,14

28:8 39:9 41:20

52:8,9,23 53:4,15

53:21 54:2 56:6,7

126:22,24 171:20

171:24,25 172:2,8

172:21 173:13

174:6,13,19 175:2

178:2 188:6 204:10

210:18 211:5,7,20

211:21 214:6

2010 56:8 57:10,20

57:23 58:1,3,5,8,9

58:15,18,18 59:23

70:11 75:22 78:10

82:6 89:11 92:4

93:15 101:19

114:13 116:5,6,20

117:2 131:11,13

134:8,13,22,25

135:7,15 138:12

139:6,18,19 141:5

141:12 150:25

152:15 175:12

188:6 204:17,20

211:8,21

2011 56:10 70:8

78:25 116:6,20

132:6 136:2 141:11

149:3 151:8,11

152:12,19 187:25

188:7 204:23 211:8

211:21 219:14

220:8

2012 56:12 70:2,6,7

70:13 92:15 116:10

132:6,7 136:8

142:18 149:1,3

153:23 171:17,18

175:2,4,5,14,19

177:24 179:8,12

185:1,5,11,18

187:23 205:5,6,6,17

211:8,21 212:17

214:7,18,25 215:19

216:16,21 217:4

218:9,23 236:1,2,3

236:4 244:10,21

245:4 246:1 247:22

249:2 252:4

2013 56:18 70:16,18

92:15 116:11 132:7

149:1 154:15

155:13 180:3,12

181:21 182:1,23,25

183:2,6 184:3,21

200:10 205:11

211:8,22 213:15,20

214:1 218:9 220:10

220:11 222:12

224:24 233:25

2014 8:19 24:3,14

28:9 39:9 57:10,21

58:10,15 59:23

70:11,20 78:10

89:13,15,17 92:4

101:20 114:13

117:2 123:18 124:1

124:2 131:15

139:19 146:13

155:19,23,24

181:20 183:3 184:4

187:19 206:24

210:18 211:6,20

214:6,7,18,25

215:19 216:16

218:23 236:1,4

240:7,19,23 246:1

247:23 248:25

249:2

2015 207:2 215:4

2016 201:17

2018 8:25 42:7 58:10

123:22 124:2

201:25

2019 34:6 41:6 123:6

123:7,18

2020 122:23,23

2021 1:15 169:3

198:7 262:16

20th 262:16

22 61:6 73:8 243:10

243:13

23 31:9 33:14,25 81:6

81:7,9 152:5,5

165:25 166:5,9,25

167:6,9,13 169:14

240:20,25 241:4

23A 41:8 70:10 74:25

75:14,15 81:9 166:1

169:6

23B 41:10 102:19,20

102:21 138:2,3

152:5 166:3

24 31:9 34:21,23,24

35:5,7,20 36:16,19

36:22,23 37:2,4

61:6 73:8 109:6

132:12 167:13

168:19 169:7 186:7

187:1,3

24A 37:9,18,22 38:4

38:8 39:1 41:7

24B 37:14,20,21

137:1

24C 137:1

25 33:25 34:5,9,12,12

34:14,15 35:5

167:14,14,16

168:12,13,16,23,24

169:8 260:9,18

250 13:10 18:22 19:1

22:17,20 30:6,9,9

54:12 71:16,23

84:12 93:20,21

112:12 115:2

131:22,25

26 167:15,18 168:7,8

168:9 169:11

262 262:7

26th 49:14

27 168:5,8 169:11,14

27th 33:20 34:6 41:6

28th 49:9

29 243:10

2A 260:12

2nd 33:4

3

3 260:12

30 17:17 73:12 91:15

93:7 138:12,15

139:3 141:5 242:5

242:14,15,17,24

250:9,15,16 252:23

30,000 130:16 160:2

161:6,23 162:3

300 13:4 21:6 52:2,18

93:5

300,000 181:10

302 242:15,17 243:10

305-858-9020 2:7

30th 250:20

310 57:1,2

318 39:15,18 57:3,7

318,000 39:10,12,14

102:22 104:2

318,248 102:12

33 6:24

33146 2:6

340 39:18 57:5,7

340,000 57:1,8

102:22

34A 81:4

34B 81:4

354 242:7

39 228:2

3A 260:13

4

4 166:23

4:00 209:2 226:4

4:48 1:16

40 54:18 257:4,6,6

40,000 130:17,18,21

130:23,24 161:6

162:6

400 13:15

41 2:15

44 103:14

448 251:14

450 92:21 156:2

4551 2:6

47 212:7

48 237:21

5

5,000 161:3 163:7

5:00 24:16 25:24,24

26:8,9,10,21 53:23

118:3

5:30 25:25 209:5,6

50 130:9

50,000 135:17 155:12

155:22 180:9

500 13:15,19 22:25

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131:25

52 141:3

6

6 87:9,19 189:8 193:5

243:7

6:00 104:9,12,13,19

60 252:23

60,000 43:15 63:16

73:8,12,12 135:19

151:4 152:16 154:1

7

7 2:14

7.25 75:23

7:00 26:1

70,000 154:3,6

706 245:20

74 2:15

7th 52:23,24,25 53:1

53:3

8

8 86:11

8:00 26:17,19

80 20:16

80,000 154:7

81 2:17

9

9 17:6,16 24:8

9:00 13:4 24:8,16

26:17,19 53:23

105:1 114:8 130:3

9:58 1:16

90 20:14,15

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