Exhibit "A" 

Exhibit "A" Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 1 of 74
Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 2 of 74 Exhibit "B"









BATES STAMP 19 OF 137








 UNITED STATES BANKRUPTCY COURT

 SOUTHERN DISTRICT OF FLORIDA

 MIAMI DIVISION

 CASE NO. 20-15954-RAM and 20-01350-RAM

IN RE:

PHUONG MIMI NGUYEN,

 Debtor

_________________________/

MELANIE ADAMS, individually and on behalf

Of her minor daughter, TAYLOR ADAMS,

 Plaintiff,

vs.

PHUONG MIMI NGUYEN,

 Defendant.

_________________________/

 DEPOSITION OF MELANIE ADAMS

 TAKEN ON BEHALF OF THE DEFENDANT

 FEBRUARY 16, 2021

 1:30 P.M. TO 3:18 P.M.

 ALL PARTIES APPEARED REMOTELY

 PURSUANT TO

 FLORIDA SUPREME COURT ORDER AOSC20-23

REPORTED BY:

MEGHAN WILLIS, COURT REPORTER

NOTARY PUBLIC, STATE OF FLORIDA

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 21 of 74 Exhibit "I" 
Adams, Melanie 02-16-2021

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1 APPEARANCES OF COUNSEL

2 ON BEHALF OF THE PLAINTIFF:

3 ZACHARY FRIEDMAN, ESQUIRE

 2 GROVE ISLE DRIVE, APT 1210

4 COCONUT GROVE, FLORIDA 33133

 305.446.6485

5 usczach@gmail.com

 (REMOTELY VIA ZOOM)

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ON BEHALF OF THE DEFENDANT:

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 RICARDO A. RODRIGUEZ, ESQUIRE

8 RODRIGUEZ LAW, P.L.

 900 W 49TH STREET, SUITE 505

9 HIALEAH, FLORIDA 33012

 305.262.8226

10 ricardo@rdgzlaw.com

 (REMOTELY VIA ZOOM)

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1 INDEX OF EXHIBITS

2 EXHIBIT DESCRIPTION PAGE

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1 INDEX OF EXAMINATION

2 WITNESS: Melanie Adams

 PAGE

3 DIRECT EXAMINATION

 By Ricardo Rodriguez, Esquire 6

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1 VIDEOTAPED DEPOSITION OF MELANIE ADAMS

2 FEBRUARY 16, 2021

3 THE COURT REPORTER: Today's date is February

4 16th, 2021.

5 This is the videotaped deposition of Melanie

6 Adams taken in the matter of, in reply to Phuong

7 Mimi Nguyen, Debtor.

8 Case Number 20-15954-RAM in the matter of

9 Melanie Adams individually and on behalf of her

10 minor daughter Taylor Adams v. Phuong Mimi Nguyen.

11 Case Number 20-01350-RAM.

12 We are located remotely, the Court Reporter is

13 Meghan Willis with the Universal Court Reporting.

14 Would counsels please introduce themselves?

15 MR. RODRIGUEZ: Ricardo, go ahead, I'm sorry.

16 MR. FRIEDMAN: No, I'm sorry. Zach Friedman

17 on behalf of the Plaintiffs and Creditors, Taylor

18 and Melanie Adams.

19 MR. RODRIGUEZ: Ricardo Rodriguez on behalf of

20 the Debtor. Give me one second.

21 Thereupon:

22 MELANIE ADAMS,

23 was called as a witness, and after having been first

24 duly sworn, testified as follows:

25 THE WITNESS: I do.

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1 DIRECT EXAMINATION

2 BY MR. RODRIGUEZ:

3 Q Hello, Ms. Adams. If you could please

4 pronounce your full name?

5 A Melanie Adams.

6 Q And I'd like to ask you a few questions about

7 your, you know, background, basically. What do you do

8 for a living?

9 A I work for the Fire Department, I'm a Fire

10 Chief.

11 Q Okay. And how long have you been working

12 there?

13 A Since 1994.

14 Q And what do you do as a fire chief?

15 A I'm in -- I am the chief over the fire

16 prevention division.

17 Q I'm sorry?

18 A I'm the chief over the fire prevention

19 division.

20 Q Okay. What does that mean?

21 A That means -- I don't understand your

22 question.

23 Q I don't understand what you do. I'm trying to

24 figure out what you do as a chief?

25 A I pretty much manage the fire prevention

8

1 construction site.

2 Q Okay. So, why have you been to a construction

3 site as part of your job?

4 A I went there many years ago as a lieutenant

5 inspector.

6 Q Okay. Prior to being chief, you've been chief

7 since 1994?

8 A No, less than a year.

9 Q Less than a year? Okay.

10 A Yeah.

11 Q So, before you became chief, what were you

12 doing?

13 A I was the captain in charge of the emergencies

14 at Miami International Airport for aircraft emergencies.

15 Q And how long did you do that for?

16 A Approximately two years maybe.

17 Q Were you doing that when the incident in this

18 case occurred?

19 A I don't recall.

20 Q Can you explain again, what the captain --

21 what you did as a captain?

22 A I as a -- prior to the division chief's

23 position, I was a -- I don't know if you're familiar

24 with the big crash trucks that respond to aircraft

25 emergencies.

7

1 division for Miami-Dade Fire Department.

2 Q What is a fire -- fire prevention division?

3 A It's a division of the fire department that

4 works to prevent fires.

5 Q Okay. And how many people do you oversee?

6 A Approximately 150.

7 Q Okay. And how long have you been doing that,

8 overseeing, you know, being the chief for that division?

9 A Less than a year.

10 Q Okay. What does that entail, in terms of your

11 responsibilities in your day-to-day activities?

12 A Everything that managing a division of the

13 fire department would entail. I'm not sure what part of

14 the question I'm supposed to answer. There's a lot of

15 responsibility.

16 Q Well, just give me some form of overview of

17 what it is you do on a day-to-day basis?

18 A Budgeting, supervision, goals.

19 Q Did you ever supervise any construction sites

20 or anything of that nature?

21 A No.

22 Q You've never gone to a site to determine if

23 the Fire Department or if a building is in compliance

24 with --

25 A I have never supervised a site, I've been to a

9

1 Q No.

2 A I -- if there was an aircraft emergency, the

3 pilot would radio in and me and my staff would show up

4 to mitigate the emergency.

5 Q Okay. Do you have any children? Are you

6 married?

7 A I have one daughter and I'm single.

8 Q And what's your daughter's name?

9 A Taylor Adams.

10 Q How old is she?

11 A She is 14.

12 Q And where do you live?

13 A 14024 Southwest 132 Avenue, Miami, 33186.

14 Q Do you have any degrees formal education?

15 A Only in the fire service.

16 Q Okay. Did you complete high school?

17 A Yes.

18 Q Do they give you any training in the fire

19 service?

20 A Yes.

21 Q What kind of training?

22 A Fire college medical, I mean, there's been a

23 lot of training along the way.

24 Q So, for instance, fire college, what does that

25 entail?

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1 A Learning how to put out fires, learning how to

2 treat medical patients.

3 Q But is that like a -- it's not a degree is it

4 or it's just a college requirement?

5 A It is a certification.

6 Q Certification. And as far as medical, what

7 are you doing medical as well, kind of --

8 A An emergency medical technician.

9 Q Okay. So, at this point, I want to direct

10 your attention to your relationship with Mimi, I'll call

11 her Mimi, her full name is, it's hard for me to

12 pronounce this Phuong Mimi Nguyen. Do you know her?

13 A Yes.

14 Q Okay. And what kind of relationship did you

15 have with her? And when did it start or when did your

16 relationship with her start?

17 A Approx -- sometime approximately 2016.

18 Q Beginning of 2016, middle or end?

19 A I don't recall.

20 Q Okay. So, what kind of relationship did you

21 have with her? How would you describe your relationship

22 with her?

23 A She introduced herself as a general contractor

24 the day I met her. I met her to discuss a house that

25 was for sale next door. And so, we started with her as

12

1 out of the house for renovations?

2 A There were several people.

3 Q Why did you think it was her that was doing

4 these renovations?

5 A I just happen to catch her as the first person

6 I introduced myself to.

7 Q Can you tell me exactly how you introduced

8 yourself to her and what your conversation consisted of?

9 A I introduced myself. She said she was the

10 general contractor and I said that was impressive,

11 because I had never met -- excuse me, my AirPods. I'm

12 sorry.

13 I introduced myself and I told her that I was

14 interested in some work on my house. And she said that

15 she was the general contractor and that she was

16 renovating the house.

17 Q So, what happened after that?

18 A Can you be more specific?

19 Q I just want to know what happened. How did

20 this relationship evolve into her doing work for you?

21 I'm trying to understand how it went from you meeting

22 her to the end result of this lawsuit.

23 So, I, you know, the only one that would know

24 that it would be you, not me.

25 A Okay. Do you have a specific question?

11

1 my general contractor.

2 Q Okay. So, this was so your -- so, you met her

3 in 2016, this house next door. What house is that are

4 you referring to?

5 A There is a house right next door directly to

6 the north of me.

7 Q Okay. So, how did you meet her?

8 A I met her in the front yard, I introduced

9 myself.

10 Q You met her in the front yard of the house

11 next door to you?

12 A Correct.

13 Q Okay. Do you know the address of the house

14 next door to you?

15 A I would be guessing if I told you.

16 Q And why would you -- what was it that made you

17 introduce yourself to her?

18 A I had some interest in doing some work on my

19 house.

20 Q How did you know that she was doing work next

21 door?

22 A Because there was ongoing renovation going on

23 next door.

24 Q And she was the only one that was going in and

25 out of the house or were there other people going in and

13

1 Q Yeah. I'd like to know what happened next.

2 A She told me she was renovating the house next

3 door for a bank in California that hired her to do

4 renovations as their general contractor. And that's how

5 it started.

6 Q Okay. And then what happened next?

7 A Next that day, next, I'm not sure what you're

8 looking for.

9 Q You -- I'm just trying to understand. You

10 tell me, what happened next? You hired her and she said

11 she met you, she was a contractor.

12 So, I'd like to know how you got from point A

13 to point B to point C.

14 A Are you asking what did she work on my house

15 first?

16 Q No. I'm asking what happened next, you know,

17 she introduced -- you introduced yourself, she told you

18 she was --

19 A In that conversation?

20 Q Yeah.

21 A Okay.

22 Q What happened next, I mean, I don't know, how

23 did she end up going to your house? I have no idea. Did

24 you follow-up with her, did you call her, did you tell

25 her show me something. I have no -- I'm trying to

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1 figure out what happened?

2 A I don't recall what exactly was next.

3 Q Okay. So the -- at this point, you only

4 recall introducing yourself. Did you get her number?

5 A We did exchange numbers.

6 Q Okay. And you gave her your number, she gave

7 you -- did you ask her for her number?

8 A I don't recall.

9 Q So, after that day, when you met her, when did

10 -- how did you guys get in contact again?

11 A I don't recall the specifics. It's been

12 years.

13 Q Well, you filed a lawsuit against her?

14 A I don't --

15 MR. FRIEDMAN: There's no question, Melanie.

16 A Okay.

17 Q (By Mr. Rodriguez) Why did you file a lawsuit

18 against her if you don't recall the events?

19 MR. FRIEDMAN: Object to the form.

20 A That's not the question you asked. You asked

21 me what happened next and I said, I'm not sure of the

22 sequencing of what happened next. That I am not -- your

23 question is not specific enough for me to answer.

24 Q (By Mr. Rodriguez) I don't really need to ask

25 you specific questions, I can ask you open-ended

16

1 house.

2 So, I had no reason to doubt that she was

3 representing herself as a general contractor the day we

4 met.

5 Q Did the other company -- did the company that

6 she was affiliated with or working with tell you that

7 she was a general contractor?

8 A They did not deny that she was a general

9 contractor and they said they had hired her. I asked

10 her, I said that I had met the general contractor that

11 was working at the house next door.

12 And they said that she was indeed their GC and

13 I said I'm interested in that house. Could you send me

14 some information? And so, that's how I felt I confirmed

15 that she was who she said she was.

16 Q Why did you feel that you needed to call them

17 rather than just talk to her if she was a general

18 contractor?

19 A I wasn't calling them specifically for that

20 reason I was interested in the house next door.

21 Q Okay. Did you enter the house next door?

22 A I did.

23 Q Okay. So, when I asked you what happened

24 next, I would like to know what you did after you spoke

25 to her.

15

1 questions. And that's the purpose of this deposition.

2 A And that's --

3 MR. FRIEDMAN: Melanie, stop. There's no

4 question.

5 Q (By Mr. Rodriguez) What happened after you

6 first met her? What was the next, I mean, you guys

7 meet, what'd would you do, you know? You don't recall

8 any relationship with her after that or --

9 A I do. But I -- you're asking me for a

10 specific what happened next and I do not recall.

11 Q No. I'm not asking for specific. I'm just

12 asking you tell me what was the next thing that occurred

13 between you and her?

14 A We discussed work on my house.

15 Q Okay.

16 A I would imagine was part of that conversation

17 that first day. She said that, I could call the company

18 in California. I was interested in purchasing the house

19 next door.

20 And so, I asked her some questions about that

21 house. She said she worked for the company in

22 California. And so, I called the company in California.

23 I told them that I spoke to their general

24 contractor and they confirmed that she was working for

25 them. I'm sorry, the bank. And we discussed that

17

1 So, was that something you did after you spoke

2 to her or while you were speaking to her?

3 A I don't recall.

4 Q Okay. So, that day, you did see the house

5 next door?

6 A No.

7 Q Okay. When did you see the house next door?

8 A At a later date.

9 Q Okay.

10 A And I had been in the house previous with the

11 previous owners.

12 Q So, earlier in my questioning to you, you said

13 that you -- the work was impressive. How did you see --

14 how did you know the work was impressive if you didn't

15 been to the house?

16 A I didn't say that.

17 Q Or what you like -- you saw something that

18 caught your attention. Correct?

19 A I don't recall.

20 Q What did you see in the house next door that

21 made you approach Ms. Nguyen?

22 A I had been in the house when the previous

23 owners were there and it was a larger house than I have.

24 Q Right. What did you see that resulted in you

25 approaching Ms. Nguyen?

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1 A Just out of convenience, there was contractors

2 working next door. That was the reason that I

3 approached them and I'm a friendly person.

4 Q How did you know they were contractors?

5 A Because they were doing heavy construction

6 over there.

7 Q So, can you describe the construction that's

8 heavy?

9 A Bringing in wood and appliances and cabinetry.

10 I could hear the banging. It was an obvious

11 construction site.

12 Q Right. So, you were just curious, you had not

13 seen any of the work at that point?

14 A Correct.

15 Q Did you see any vans or anything that may have

16 indicated that they were contractors?

17 A I do not recall.

18 Q Okay. When did you and her have contact

19 again?

20 A I don't recall.

21 Q Is it your testimony today that you only had a

22 professional relationship with Ms. Nguyen?

23 A No. We -- she was hired by me as a general

24 contractor, but we became friends over time. We got

25 along very well. And I would have said that our

20

1 her to do anything. If you want to look at me to

2 make sure I'm not talking to her. That's fine.

3 MR. RODRIGUEZ: No, but I don't know who is in

4 the house. I mean, --

5 MR. FRIEDMAN: I think she's at her office.

6 MR. RODRIGUEZ: Oh, in her office? I have no

7 idea. I mean, but, you know, typically in a

8 deposition, somebody just doesn't, you know,

9 disappear while we're in the deposition.

10 MR. FRIEDMAN: All right. Melanie, you're

11 frozen. Can you hear us? Melanie, can you hear

12 us?

13 You froze. You have to log off and log back

14 on. Okay, fine.

15 THE WITNESS: Can you hear me, Zach?

16 MR. FRIEDMAN: Yeah.

17 MR. RODRIGUEZ: Yeah.

18 THE WITNESS: Okay. I'm back.

19 MR. FRIEDMAN: Just don't turn off your video,

20 if you leave.

21 THE WITNESS: Okay. I know I didn't, it

22 disconnected. I apologize.

23 MR. RODRIGUEZ: Are you ready to go, do you

24 need some more time?

25 THE WITNESS: Yes.

19

1 relationship did develop.

2 Q Okay. So, please describe your relationship

3 with her.

4 A In what context?

5 Q In the relationship as a friend? Was she your

6 friend or was she not your friend?

7 A Are you asking me if I thought she was friend,

8 my friend at the time?

9 Q No. I'm asking you in the whole -- in your

10 whole relationship with her. Was she your friend at

11 some point or not?

12 A Yes.

13 Q Okay. So, can you please describe your

14 friendship with her?

15 A You hold on one second and let me change over

16 my audio because my AirPods are dying?

17 Q Sure.

18 A Okay.

19 MR. RODRIGUEZ: You know, I'm objecting to

20 this blockage of the video. This is -- it should

21 not be happening.

22 MR. FRIEDMAN: Sorry?

23 MR. RODRIGUEZ: Zack, the video is being

24 blocked. I mean, --

25 MR. FRIEDMAN: I don't know. I didn't tell

21

1 Q (By Mr. Rodriguez) Okay. I wanted you to

2 describe your friendship with Ms. Nguyen.

3 A I -- at the time, I thought that we developed

4 a friendship. I don't know how else to describe it.

5 Q Okay. Did you share personal information with

6 her?

7 A Yes.

8 Q Okay. Did you share any, you know, what were

9 your conversations like with her as far as being

10 friends?

11 A Just like any other friendship.

12 Q Okay.

13 A I don't -- I mean, we did share personal

14 information. We talked about many things, but are you

15 looking for something besides that?

16 Q I'm trying to figure out your friendship with

17 her, but you know. So, I'm trying to figure out did you

18 go out with her?

19 A Yeah. A couple of times, we did. I mean, we

20 had lunch. Usually when we went, you know, in the times

21 that I can remember if we had lunch, we spoke about the

22 house and working on the house or her business.

23 I was -- I thought that it was neat that she

24 was a woman general contractor.

25 Q Did you ever try to research whether she was a

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1 general contractor?

2 A I'm sorry?

3 Q Did you try to research whether she was a

4 general contractor or not?

5 A No. I believed what she told me.

6 Q Okay.

7 A I --

8 Q So, you met her in 2016. Correct?

9 A I believe it was 2016.

10 Q Okay. And when did the incident occur?

11 A It may have been 2000 -- it was between 2015

12 and '16. I don't recall.

13 Q Okay.

14 A The incident occurred January 30th, 2018.

15 Q So, from January -- from 2016 through January

16 30th, 2018. You and her shared some form of

17 relationship. Correct?

18 A I don't recall when I met her.

19 Q Well, you said that you met her in 2016 or

20 2015?

21 A I'm not sure if it was the end of 2016. I

22 don't remember.

23 Q Okay. So, let's assume it's 2016, the end of

24 2016.

25 A Okay.

24

1 Q Okay. What did you do at the rodeo?

2 A I don't recall.

3 Q What's a rodeo? I have no idea. What do you

4 do at rodeo? I have no idea what you do at a rodeo?

5 A You watch cowboys.

6 Q Okay. What are they doing?

7 A They ride bulls.

8 Q Okay. So, you and her --

9 A Horses.

10 Q Were there any other people with you in that -

11 - that day?

12 A I don't recall.

13 Q Do you often go to rodeos?

14 A I go to the rodeo every year, if I can.

15 Q Okay. Do you invite random people to go to

16 the rodeo with you?

17 A Not typically, but yes I have invited people

18 that I didn't know well, I enjoy it.

19 Q Okay. So, you went to a rodeo with her?

20 A Yes.

21 Q Okay. Did you at any point buy her special

22 needs son a gift?

23 A I'm sorry?

24 Q Did you at any point buy her special needs

25 son, a gift?

23

1 Q I'll give you that benefit of the doubt. So,

2 from 2016, the end of 2016 through January 30th, 2018,

3 you and her had a friendship, correct?

4 A No. When I met her, I met her as a general

5 contractor.

6 Q All right. Okay. And then at some point, you

7 became friends, right?

8 A Yes. I would say at some point, we took on a

9 friendship. Yes.

10 Q So, -- So, from the end of 2016 through

11 January 30th, 2018, you and her only discussed business?

12 Is that what you're saying or your cabinets or what was

13 your discussions with her?

14 MR. FRIEDMAN: Object to the form.

15 Q (By Mr. Rodriguez) Just professional?

16 A I'm sorry?

17 Q What was your discussions with her from 2016,

18 from the end of 2016 through January 30th, 2018?

19 A I don't recall.

20 Q Okay. Did you and her ever go to a rodeo

21 together?

22 A Yes. We went to a rodeo.

23 Q And what did you discuss cabinets at the

24 rodeo?

25 A I don't recall.

25

1 A I don't recall.

2 MR. FRIEDMAN: Objection, relevance.

3 Q (By Mr. Rodriguez) Do you recall her having a

4 special needs son?

5 A I do recall that she had -- no, I thought it

6 was her brother.

7 Q Okay. I'm sorry, her brother, her brother.

8 Thank you for clarifying.

9 A I do -- I don't recall buying him a gift. No.

10 Q Okay. Did you ever confide in Ms. Nguyen

11 about a problem you were having with a boyfriend?

12 A Yes.

13 Q And why did you do that?

14 A The --

15 Q Why did you confide in her with your problem

16 with your boyfriend?

17 A I don't recall.

18 Q You don't know why you confided in her?

19 A I don't recall why. No.

20 Q Were you having problems with your boyfriend?

21 A Yes.

22 Q Did you need emotional support from her?

23 A I don't recall.

24 Q What kind of problems --

25 A You mean how --

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1 Q -- what kind of problems were you having with

2 your boyfriend?

3 MR. FRIEDMAN: Objection, relevance. You can

4 answer.

5 A It was a domestic issue. I had to call the

6 police and I was worried that he was stalking me. And I

7 was very worried about him.

8 Q (By Mr. Rodriguez) Did you e-mail Ms. Nguyen

9 about this problem you were having with him?

10 A I don't recall.

11 Q So, I'm going to show you briefly on the

12 screen, if you can see. Do you recall sending this e13 mail to her?

14 It's dated February 11th, 2021. I'm sorry,

15 that's this date -- strike that -- The date that you

16 sent the e-mail was December 27th, 2016.

17 It says from Melanie Adams to designmimiyoko.

18 Do you recall sending that e-mail to Ms. Nguyen?

19 A It's obviously from me, but I don't really

20 recall sending it.

21 Q Okay. Can you read what it says in the e22 mail?

23 A The entire e-mail?

24 Q No, just where it says, "I spoke with the main

25 office."

28

1 personal things.

2 Q Okay. So, now you confide, you're testifying

3 that you did discuss personal things?

4 A I already said that too.

5 Q I like to mark this as I guess, Exhibit A.

6 (Thereupon, Exhibit A was marked into record.)

7 MR. RODRIGUEZ: Court Reporter?

8 THE COURT REPORTER: Yes.

9 MR. RODRIGUEZ: I'd like to mark this as

10 Exhibit A. I'm not sure if you heard?

11 THE COURT REPORTER: Yes, I heard you.

12 MR. RODRIGUEZ: Okay. Great. Thank you.

13 Q (By Mr. Rodriguez) Would you say that at the

14 point that you confided with her about your boyfriend,

15 that your relationship with her hit a turning point that

16 you and her bonded?

17 A I don't recall.

18 Q Do you recall going to her friend's wedding in

19 December of 2016, late December 2016?

20 A I don't recall. I don't remember.

21 Q Do you remember sharing with her information

22 about your profile on Match.com?

23 A I don't remember.

24 Q Did you have a profile in Match.com?

25 A At that time? I don't remember.

27

1 A "I spoke with the main office at my

2 association, they're sending this to their security

3 personnel. My remotes and cards have been deactivated

4 and he has been taken off the residency list.

5 They are going to put his picture up in the

6 main office to keep an eye out. My gut tells me that he

7 is not seeing someone in the neighborhood, I think that

8 he is just looking for an opportunity to reconnect and

9 he is lying.

10 So, that he wouldn't be busted for keeping the

11 access card that he said he lost to get in the main

12 entrance. See below, so sad. We had so many good

13 times."

14 Q Why would you send an e-mail like this to her?

15 A I think as I already said we developed a

16 friendship.

17 Q Well, I'm trying to understand the kind of

18 friendship you and her had. Would you consider her just

19 an acquaintance?

20 A No. We developed a friendship.

21 Q Were you good friends, were you -- you told

22 me, describe the relation?

23 A I think I already did.

24 Q I don't recall you describing the relation.

25 A We developed a friendship. We talked about

29

1 Q Did you ever have to visit an Amazon

2 construction site in relation to your job?

3 A Yes.

4 Q And why did you have to do that?

5 A I had to -- there was an Amazon Construction

6 Site that I visited many times, it would depend on the

7 time.

8 Q Okay. So, tell me what it is that you did in

9 those Amazon construction sites?

10 A I've only been to one Amazon construction

11 site.

12 Q For some reason I thought you had mentioned

13 that you've been to an Amazon construction site many

14 times? Do you know --

15 A I have been to one Amazon construction site

16 many times, not to many Amazon construction sites.

17 Q All right.

18 A Sorry you --

19 Q No, that's okay. So, I just want to

20 understand what did you do the many times you visited

21 the Amazon construction site?

22 A I -- you would have to be more specific

23 because --

24 Q What was your purpose being there?

25 A There's different times that I was there. So,

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1 I'm not understanding the question.

2 Q Just tell me what you did on any time. I want

3 to understand why you were visiting an Amazon

4 construction site?

5 A I -- to take a tour, to talk about fire

6 protection there. There were many reasons that I've

7 been to an Amazon construction site.

8 Q Okay. Is it an Amazon construction site or

9 one Amazon construction site?

10 A I have been to one Amazon construction site.

11 Q Have you been to other construction sites as

12 part of your job?

13 A As part of my current job?

14 Q Any job, ma'am.

15 A Yes.

16 Q Okay.

17 A If you're specific with me, I'll be with you.

18 Q I don't want you -- no, I understand but --

19 okay. I don't really need to be specific. I'm just

20 asking you a general question. I don't know.

21 With the Amazon construction site, can you

22 describe what your function was there? You said you

23 went there multiple times.

24 A Correct. I was the bureau officer in charge

25 of the Aviation Life Safety bureau, which does the same.

32

1 of fire that that the hazards in that building may

2 present.

3 Q So, do you go there to determine whether

4 they're up to code?

5 A No. I oversee the inspectors that go there to

6 determine if they are up to code.

7 Q So, it's basically the same thing, just --

8 you're just saying it in a different way. Correct?

9 A I don't go there to enforce the code. I go

10 there as the supervisor.

11 Q Right. But let's assume for the sake of

12 argument that these inspectors are not fulfilling their

13 job or that the -- whatever they've installed is not up

14 to code. What would you do at that point?

15 A I would help them resolve the issue.

16 Q And how would you do that?

17 A It depends on the issue.

18 Q So, if there's a code violation, you would

19 help fix that code, right?

20 A I would help them read the code and interpret

21 the code. Yes.

22 Q So, you are familiar with reading codes?

23 A Fire codes, yes.

24 Q Right. And they have to do with construction?

25 A I'm sorry?

31

1 It's a similar to the position that I have now to a

2 lesser degree. It's --

3 Q Again, I just don't understand why as a fire

4 fighter in chief, you're required to go to an Amazon

5 construction site.

6 And I'm not, from your testimony, I'm not

7 understanding. Can you please help me understand why

8 you visited in Amazon construction site?

9 A So, the project was new and it was on an

10 airport property. So, our bureau had work to do there.

11 So, depending on the time that I went there, you know,

12 would have different agenda for that day.

13 Q What were the different agendas, give me five?

14 A They're for tours, they are for fire

15 protection. There --

16 Q What -- let's talk about the fire protection.

17 A Okay.

18 Q What was your purpose there for fire

19 protection?

20 A To discuss how to protect that particular

21 building.

22 Q Okay. And what does that require? So, I can

23 be -- what does it require for a building to be

24 protected?

25 A Okay. It has to be able to suppress the type

33

1 Q And they have to do with construction

2 obviously?

3 A Not always.

4 Q But in this particular case.

5 A In this case, yes.

6 Q Okay. Did you have to -- are there permits

7 that are pulled when these type of things happen or

8 being installed or --

9 A Absolutely.

10 Q Okay. Are you involved in the pulling of

11 permits?

12 A No.

13 Q Do you work with construction -- contractors?

14 I'm sorry.

15 A Not typically,

16 Q Are you -- and when I say do you work I'm

17 using the word directly or indirectly. In other words,

18 I understand that you supervise and you're not the

19 contractor obviously.

20 But do you have -- do you supervise

21 contractors?

22 A I typically -- no, I don't supervise

23 contractors.

24 Q Do the people that work with you supervise

25 contractors?

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1 A No.

2 Q The inspectors?

3 A No, they don't supervise contractors.

4 Q Okay. Do they oversee the work they've done?

5 A When it comes to fire codes to make sure that

6 they have built it correctly. They would, yes.

7 Q Okay. As part of your job, do you ever

8 research whether these contractors are licensed?

9 A No.

10 Q Okay.

11 A I don't.

12 Q Okay. Does someone in your department do it?

13 A I would imagine probably somebody in the new

14 construction bureau might do that if they had a reason

15 to believe. You know what, no licensed and insured, was

16 that the question?

17 Q I'm sorry?

18 A Can you repeat the question?

19 Q I'm just trying to figure out your connection

20 with the -- I guess --

21 A My --

22 Q -- Amazon construction site.

23 A My work does not research if people -- if

24 contractors are licensed or insured.

25 Q How many times did you go to this Amazon

36

1 the fire codes. And they may have had questions.

2 Q And you're familiar with those fire codes?

3 A I am familiar with some of them.

4 Q Well, I'm trying to understand why you would

5 meet with the architects and engineers. Can you explain

6 this?

7 A I already said I was the bureau officer in

8 charge of the Aviation Life Safety Bureau.

9 Q Ms. Adams, you're giving me conclusions. I'd

10 like you to describe what --

11 A Can you be more specific? I'm not sure what

12 question you're asking?

13 Q I'm asking you why you needed to meet with

14 architects and engineers in the Amazon construction

15 site.

16 A Because they were having problems with their

17 design.

18 Q And what is it that you do to help them? I

19 don't know, you -- I don't know what?

20 A I would help them interpret the code.

21 Q And that's all you do?

22 A That's a lot.

23 Q Well, I'm asking you, when it comes to the --

24 okay. So, that's a lot, right. So, explain to me what

25 that a lot is.

35

1 construction site?

2 A I don't recall.

3 Q Would you say at least five times?

4 A Yes.

5 Q About ten?

6 A Yeah. Probably closer to ten.

7 Q And how long did this project take?

8 A A couple of years.

9 Q Okay. So, in the couple of years, let's say,

10 two years, you went there ten times?

11 A Approximately.

12 Q Can you tell me -- can we go over the agendas

13 that you had when you visited the site?

14 A I know I gave a tour to the units one time to

15 the operations units, you know, I was in on a tour that

16 Amazon gave.

17 I remember meeting there with the architects

18 and engineers to discuss some of the problems they were

19 having.

20 Q Okay. Any more agendas?

21 A Not that I recall.

22 Q You said you met with architects and

23 engineers. Why would you meet with architects and

24 engineers?

25 A Assuming they're trying to design according to

37

1 A I would -- I mean, there's a lot of fire codes

2 to interpret. So, I would help them to understand what

3 the intent of the code is.

4 Q Okay. Have you been to any other construction

5 sites as part of your job?

6 A Yes.

7 Q How many?

8 A I don't recall.

9 Q Was it one?

10 A I could not give you a number, I have no idea.

11 Q Would that information be in your office, if I

12 subpoenaed?

13 A No.

14 Q Okay. So, there's no information on your

15 schedule in your office?

16 A I didn't say there was no information on my

17 schedule in my office.

18 Q So, how can we find out how many times you

19 would visit construction sites?

20 A There -- you'll have documentation on some of

21 it, but you won't have documentation on others.

22 Q Okay.

23 A For instance, as a bureau officer in charge,

24 those are not documented visits, you know, that would be

25 on my normal calendar. It's not documented or those

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1 numbers are not captured.

2 Q When did you start visiting construction

3 sites? A year from now, two years from now? Beginning

4 of your career --

5 A I don't recall.

6 Q Was it at the beginning of your career?

7 A No.

8 Q Was it after you became chief?

9 A No.

10 Q Was it before you became chief?

11 A Yes.

12 Q Okay. How many years before, so just give me

13 an approximate, I mean, I'm not asking you to be

14 specific, one year, two years, three years, four years.

15 A I would be guessing.

16 Q Okay. So, you have no idea when you started

17 visiting construction sites? Is that what you -- your

18 testimony is today?

19 A I'm telling you, I don't recall when I started

20 visiting construction sites.

21 Q Okay. But you don't either -- you don't want

22 to give me an approximate date either. So, I'm asking

23 you, is it your testimony today that you don't recall

24 when you started visiting construction sites?

25 A Yes.

40

1 sites was a regular part of your job?

2 A At one point, yes.

3 Q What point is that?

4 A Many years ago.

5 Q So, many years ago --

6 A It's been decades, since I have visited

7 construction sites in that capacity.

8 Q So, when did you visit Amazon, the Amazon

9 construction site?

10 A I would be guessing, I don't remember the

11 year.

12 Q What was the address?

13 A I don't know the address.

14 Q Approximately.

15 A Opa-Locka Airport.

16 Q How often did you communicate with Ms. Nguyen

17 by phone, text, e-mail, call?

18 A I don't recall.

19 Q Once a week, maybe?

20 A I would be guessing. I'm sure there were

21 times we spoke more than others.

22 Q Okay. At any point did you get quotes for the

23 service you received?

24 A Sorry.

25 Q Well -- strike that -- Did you at any point

39

1 Q Okay. Do you recall what you did at these

2 construction sites?

3 A It depends on what position I was filling,

4 sir.

5 Q In any position that you were involved --

6 A Okay.

7 Q -- what you did at these construction sites?

8 A When I was a bureau officer in charge, it

9 would be for helping to resolve issues for the

10 architects and engineers. And help to determine a plan

11 of action so, that they could achieve compliance.

12 Q Would you wear those, you know, shell helmets

13 when you walk into these construction sites?

14 A Sometimes.

15 Q Do you attend these construction sites on your

16 own?

17 A Do I -- I don't attend any construction sites

18 at this point.

19 Q The construction sites that you attended

20 Amazon construction site and the other ones that you

21 don't recall when you started attending. Did you do

22 them on your own or did you go with someone?

23 A On my own or with someone depending on the

24 situation.

25 Q So, would you say that attending construction

41

1 you give Ms. Nguyen, the keys to your garage so that

2 your ex-boyfriend could pick up his belongings there?

3 A I don't recall.

4 Q Do you have video in your house?

5 A I do.

6 Q Did you have video the date the cabinets fell?

7 A I don't recall.

8 Q Did you have video in your kitchen?

9 A I'm sorry.

10 Q Did you have video in your kitchen?

11 A I don't remember.

12 Q Did you ever have video in your kitchen,

13 cabinets?

14 A I had video in my kitchen at one point. But I

15 don't recall if we have video at that time.

16 Q Okay. Let's talk about the installation of

17 cabinets. Can you tell me what happened the day that

18 you know these cabinets were installed?

19 A The day they were installed or the day that --

20 the day they were installed?

21 Q Yes.

22 A Specifically, okay. I don't remember.

23 Q Who installed them?

24 A A man named Alex Feranos (phonetic). And he

25 had some men with him that were doing the work.

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1 Q Okay. Was Ms. Nguyen there with them?

2 A She was there for the initial consultation.

3 But she was on another job, if I remember correctly that

4 day.

5 Q So, you asked me to be specific. And I'm

6 trying to be specific. On the day of the installation,

7 was Ms. Nguyen there with the men?

8 A So, there were several days of installation.

9 And yes, she had been on site when they were there.

10 Q Every single time they were there. She was on

11 site?

12 A Not every single time that I can remember. But

13 she was there at the same time they were. I don't

14 recall if it was every single time.

15 Q How long did the installations of the cabinets

16 take?

17 A I don't recall. I would have to guess.

18 Q Can you give me an approximate time?

19 A A week.

20 Q Okay. When was it that they were installed?

21 A I don't recall. I would have to look at my

22 paperwork. I don't recall.

23 Q Okay. What paperwork?

24 A Just my -- when I wrote the checks and try to

25 get a guesstimate.

44

1 A I did not reach out to any company. She

2 always got the quotes from the subcontractors or what

3 she called her guys.

4 Q All right. So, she would give you the quotes

5 and then what would happen? You would say yes or no?

6 A Correct.

7 Q And it's your testimony that she would get the

8 quotes for the cabinets or was there other work that was

9 going on?

10 A There was other work.

11 Q Okay. So, these quotes, how many quotes did

12 you get?

13 A I don't recall.

14 Q Do you recall how much you spent?

15 A I would have to look it up.

16 Q Okay. But if you look that up, would you be

17 able to get the exact amount that you spent?

18 A Yes.

19 Q So, what did you have installed other than the

20 cabinets or what other work did you have done?

21 A What other worked that Mimi do for me?

22 Q Any work, you had done when you were repairing

23 your house.

24 A When I was buying my house?

25 Q Repairing, renovating or --

43

1 Q Who did you write the checks to?

2 A I wrote them to Mimi Nguyen and New Concepts

3 if I remember correctly. I know I wrote them to Mimi,

4 but I don't remember if I wrote them directly to Alex

5 Feranos name or New Concept.

6 Q Okay. Before getting these cabinets

7 installed, did you get any quotes?

8 A I believe I got another quote before that.

9 Q Okay.

10 A I am sorry. I should say Mimi got another

11 quote before that.

12 Q Why was she helping you with the quotes?

13 A Because I told her that I needed to redo my

14 kitchen. And she offered to facilitate that.

15 Q Can you explain why as a general contractor,

16 she would have to get quotes from other parties instead

17 of just giving her -- giving you her own estimate?

18 A I can't explain.

19 MR. FRIEDMAN: Object to the form.

20 A I don't know how that works.

21 Q (By Mr. Rodriguez) Okay. So, my understanding

22 is, and correct me if I'm wrong. You got quotes from

23 other parties, but she was a general contractor.

24 A No.

25 Q So, explain -- can you explain that or no?

45

1 A Okay. So, all of the work that I did on the

2 renovation went through Mimi. It was Mimi's plumber,

3 electrician, demolition, cabinet guy, painter, floor. I

4 think that's it.

5 Q So, for the plumber, did you get an estimate?

6 A She gave me an estimate.

7 Q Okay. So, you did get an estimate?

8 A She gave me an estimate.

9 Q Okay. Did you pay the plumber directly or did

10 you pay Mimi directly for the plumber?

11 A I don't recall.

12 Q For the floor, did you pay Mimi directly or

13 did you pay the floor installer directly?

14 A I don't recall.

15 Q For the demo, did you pay Mimi directly or her

16 company? And when I say Mimi, I'm referring to her or

17 her company?

18 A Right.

19 Q Did you pay her or her company for the demo?

20 A I don't recall.

21 Q Okay.

22 A And she had me pay her directly. And if the

23 subcontractor was on site needed to be paid right away,

24 she would tell me to pay him directly. So, I can't

25 recall what was what.

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46

1 Q And it's your testimony today that she was the

2 contractor for the plumbing, cabinet, floor, demo and

3 electricity?

4 A Yes. She -- these were all her workers or her

5 subcontractors.

6 Q For the electricity. Did you pay that

7 directly to Ms. Nguyen or a company or did you pay the

8 electrician directly?

9 A I don't recall.

10 Q Can you find out?

11 A I can, if I go back to my records, but it

12 would take a little while.

13 Q Can you provide your attorney information on

14 who you paid with regard to, you know, all these

15 subcontractors?

16 A Absolutely.

17 Q Did you ask any of these subcontractors, if

18 they were licensed or insured?

19 A I did.

20 Q Okay. What was the answer?

21 A I asked Mimi and all of her subs, if they were

22 licensed and insured. And they all said yes.

23 Q Did you ask for a verification, like the

24 license number and the insurance?

25 A No. I felt that that -- in my, no. The

48

1 people to offer.

2 Q Okay. And when you first met Ms. Nguyen, she

3 randomly just said to you, "I'm a contractor," is that

4 what --

5 MR. FRIEDMAN: Object to the form.

6 A She introduced herself that way.

7 Q (By Mr. Rodriguez) She introduced herself, can

8 you please let me know exactly how she introduced

9 herself?

10 A I don't recall the exact wording other than I

11 asked who the GC was on the project next door and she

12 said it was her.

13 Q Okay. After the cabinets were installed,

14 right. Was everything okay after, you know, immediately

15 after they were installed? Were you happy with the end

16 result?

17 A No.

18 Q What was wrong?

19 A They weren't functioning correctly and -- they

20 weren't functioning correctly.

21 Q What do you mean by that?

22 A Some of the doors weren't shutting correctly.

23 So, I had to call Mimi and let her know.

24 Q Okay. And then what happened after you let

25 her know?

47

1 answer's no.

2 Q Did you receive a discount for doing work

3 through Mimi?

4 A I don't know.

5 Q So, you trusted Ms. Nguyen enough that you got

6 very little quotes from anyone else. Correct?

7 MR. FRIEDMAN: Object to the form.

8 A Yes, I --

9 Q (By Mr. Rodriguez) Did you trust Ms. Nguyen

10 enough to only get quotes from her?

11 A I did, I did.

12 Q So, you didn't bother at any point to try to

13 get a quote from, let's say, the cabinet's from another

14 company that wasn't involved with her?

15 MR. FRIEDMAN: Object to the form. You can

16 answer.

17 A Can you repeat the question?

18 Q (By Mr. Rodriguez) Did you -- did you at any

19 point attempt to get an estimate or a quote from a

20 subcontractor or handyman, anyone to do the work other

21 than through Mimi?

22 A No.

23 Q Why?

24 A I -- like I said, the biggest reason was the

25 convenience of meeting Mimi and that she had these

49

1 A She would call her cabinet guy and he would

2 schedule somebody to come out and fix it.

3 Q Okay. What did -- did it eventually get

4 fixed?

5 A Not all of it, no. She told me that he was no

6 longer responding to her that she fired him.

7 Q Okay. Did you use the cabinets?

8 A Yes.

9 Q Okay. What did you, you know store in the

10 cabinets?

11 A Normal dishes, Tupperware.

12 Q So, let's talk then about the date of the

13 incident, the day that this accident occurred.

14 A Okay.

15 Q Please describe that day.

16 A My daughter and I were in the kitchen and the

17 cabinets fell on us.

18 Q Okay. Can you describe which cabinets, how

19 they fall on you? I mean I'm not getting -- I want to

20 get the full picture.

21 A The cabinets were on the south wall, large

22 bank of them and then they fell off the wall and hit my

23 daughter and I in the head.

24 Q Okay. Were you standing immediately below the

25 cabinets that fall?

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1 A Yes.

2 Q Okay. So, just so I get an understanding, was

3 there a countertop above the cabinets?

4 A No. Above the counter -- I'm sorry, above the

5 cabinet?

6 Q I'm sorry. Below the cabinets, I'm sorry.

7 A Yes.

8 Q Okay. Does that countertop extend further out

9 than the cabinets?

10 A I would be guessing if I said how far they

11 extend out.

12 Q I'm not asking you how far, I'm just asking

13 you if they do extend that?

14 A I believe the counter extends out a little bit

15 further than the cabinets up top.

16 Q So, when they felt that they rip off from the

17 top or the bottom. What came off first?

18 A You mean the --

19 Q The cabinets, yeah.

20 A -- did they fall from the top of the cabinet

21 or did the bottom of the cabinet give away first?

22 Q Yeah. I'm trying to see how --

23 A I don't --

24 Q You don't know?

25 A I don't know.

52

1 A No.

2 Q Okay. And what was your daughter doing when

3 they fell?

4 A The same, she was standing at the counter.

5 Q And what kind of injury did you sustain on

6 your head after the cabinets fell?

7 A I sustained head, neck and back injury.

8 Q Okay. And those cabinets that fell, what was

9 stored?

10 A Some Tupperware, some dishes, some spices.

11 Q So, just so that we are on the same page, from

12 the date that they were installed. Do you remember that

13 date, when they were installed more or less?

14 A No.

15 Q Do you remember what year they were installed?

16 A I don't recall.

17 Q So, you don't recall when, the year that they

18 were installed?

19 A I would have to go back and look at my

20 records.

21 Q So, would you agree with me that they were

22 installed somewhere around the time that you paid the

23 installers or Ms. Nguyen?

24 MR. FRIEDMAN: Object to the form.

25 Q (By Mr. Rodriguez) You can answer.

51

1 Q You were both in the kitchen at the time that

2 the cabinets fall?

3 A Yes.

4 Q Where did they fall on your head? Can you

5 point on your head where they fall? So, they fell right

6 on top?

7 A Um-hum.

8 Q Were you facing away from the cabinets?

9 A No.

10 Q Or it was -- so, your eyes were looking

11 straight at the cabinets?

12 A No, I was looking down.

13 Q Okay. So you're looking down. Were you --

14 can you explain how, you know, what position you were

15 when these cabinets fall?

16 A Standing.

17 Q Okay. And can you be a little but more

18 detailed?

19 A I was standing at the counter and looking down

20 when they fell.

21 Q Okay. And they just randomly fell?

22 A Yes.

23 Q Had the -- had you had any indication in the

24 past that they were loose or, you know, not properly

25 installed?

53

1 A Yes, I would think that would be around the

2 installation date. Yeah.

3 Q So, this from the date of installation, until

4 the day they fell you used those cabinets?

5 A Yes.

6 Q And they were properly functioning in terms of

7 holding the weight?

8 A They had not fallen off the wall.

9 Q Right. So, they were -- they held the weight,

10 whatever you put in those cabinets from the time they

11 were installed to the time they fell, they held the

12 weight?

13 A Yes.

14 Q Okay. Why do you think that it's the Mimi's

15 fault that they fell?

16 A I don't understand the question.

17 Q I'm going to show you the complaint that you

18 filed. And then maybe you can let me know. Okay. Do

19 you see the complaint?

20 A Yes.

21 Q This first amended complaint titled --

22 challenging discharge of debts. Is that correct?

23 A I'm sorry?

24 Q The title of the complaint says "Creditors,

25 Plaintiff's first amended complaint to challenge this

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54

1 chargeability of service." Correct?

2 A I see that. Yes.

3 Q Have you read this complaint?

4 A I have.

5 Q So, you are aware of what it said?

6 A I don't recall the details exactly.

7 Q This complaint, unfortunately, I have some

8 notes on it. But it's not the A or the B or my notes

9 that you can ignore that. I'm sorry, the A or the B is

10 something I wrote on that you can ignore.

11 A Okay.

12 Q So, I'm going to ask you. My question is,

13 before we get into the complaint is, why do you think

14 that it was Ms. Nguyen's fault that the cabinets fell?

15 A I think that a general contractor has the

16 responsibility to make sure that her subcontractors or

17 his whoever it is that they are licensed and insured.

18 And that we depend on them for those reasons,

19 so that we remain safe and this doesn't happen.

20 Q Right. But that's not what I'm asking. What

21 I'm asking is, why do you think the cause of the

22 cabinets falling is her fault after, you know, after

23 they had been working for an extended period of time?

24 MR. FRIEDMAN: Objection. Asked and answered.

25 If you can answer it again.

56

1 Q And how do you know they were egregiously and

2 negligently installed, based on what you just said?

3 A Because there was a inspector that came over

4 afterwards and put that in his report.

5 Q What inspector?

6 A I believe his name was John McNally.

7 Q And is he someone that works for the county or

8 is it someone that, you know, he came on your behalf?

9 A I don't recall exactly where he came from, but

10 I believe he's an independent inspector.

11 Q Okay. So let's read paragraph nine of the

12 amended complaint. Would you mind reading that for me?

13 A "Specifically debtor knowingly and verbally

14 made false statements and relied in or misrepresented to

15 plaintiffs about having insurance being a licensed

16 general contractor and employing or working with

17 licensed subcontractors with purpose and intention of

18 deceiving plaintiffs to win the construction bid and

19 obtain the construction work job from plaintiffs."

20 Q Well, let's first talk about construction bid,

21 to win -- plaintiffs to win the construction bid. You

22 testified earlier that there was no other bids. So, how

23 did she work?

24 MR. FRIEDMAN: Object to the form, misstates

25 her testimony.

55

1 THE WITNESS: I'm sorry, Zach, say that again.

2 MR. FRIEDMAN: Don't worry about what I say

3 unless I say don't answer. Go ahead and answer.

4 A Okay. Okay. Can you repeat the question?

5 MR. RODRIGUEZ: Can you read -- Madam Court

6 Reporter, can you read back the question?

7 THE COURT REPORTER: What I'm asking is why do

8 you think the cause of the cabinets falling after

9 they had been working an extended period of time?

10 A Why do I think that, one more time, Meghan?

11 Why do I think that they felt after an extended period

12 of time? Was that the question?

13 Q (By Mr. Rodriguez) You know, I'll just

14 rephrase.

15 A Thank you.

16 Q Well, what I'd like to know was, why do you --

17 okay, you filed a lawsuit against Ms. Nguyen. Correct?

18 A Okay.

19 Q And my question to you is, why do you think

20 that it's her fault that the cabinets fell?

21 A It's her responsibility to make sure that her

22 subcontractors are licensed. If they're licensed, then

23 they have had to go to school to learn the safe way and

24 the correct way to install these cabinets. These were

25 egregiously negligently installed.

57

1 Q (By Mr. Rodriguez) Then I'll strike that. What

2 bids did -- what other bids did you obtain?

3 A I didn't feel I needed to get any other bits

4 because I was happy with the price that she had given

5 me.

6 Q And what price was that?

7 A It depends on which job. She did several

8 different jobs.

9 Q For the cabinets?

10 A The first quote that she represented was too

11 high. So, we went with the second one.

12 Q Okay. And what was the second one?

13 A I don't recall exactly, I'd have to look it

14 up.

15 Q So, I'm asking you why did you reference in

16 the complaint that she was the winning bid when there

17 was no other bits. Can you please explain that?

18 A I -- like I said, I don't think I needed to go

19 any further because I was happy with the price that she

20 gave me.

21 Q Again, I'm asking you this complaint, you're

22 not answering my question. The complaint, it says that

23 the plaintiffs -- deceiving plaintiffs to win a

24 construction bid. Can you explain that?

25 A I don't know how to explain that any different

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1 than that.

2 Q But there was nothing to win, correct?

3 A Well, if her price hadn't been good then I

4 would have gone onto someone else.

5 Q But you didn't -- there was no bids, that was

6 only her. Correct?

7 A At that point, it depends on what you're

8 talking about. Are you talking about a particular job,

9 because she did several different jobs for me?

10 Q Let's focus on the cabinets.

11 A Okay.

12 Q These are the things that fell on your head,

13 correct?

14 A Okay. There were multiple bids on the

15 cabinets.

16 Q Okay. What multiple bids were there on the

17 cabinet? So, I've asked you this before you said there

18 wasn't, but go ahead.

19 A The -- all right.

20 MR. FRIEDMAN: Move to strike. Objection. Go

21 ahead, Melanie.

22 A She brought two different quotes to me.

23 Q (By Mr. Rodriguez) Excuse me, she or did you

24 get bids from someone else?

25 A I did not get bids from someone else.

60

1 if you're dealing directly with Ms. Nguyen and she is

2 responsible for fixing for repairing, you know, or

3 installing your cabinets, right.

4 According to your testimony, she's the one

5 who's responsible or partly responsible for installing

6 your cabinets. Is that your testimony? Am I correct

7 or --

8 A Is there a question there?

9 Q Yeah, I'm asking am I correct in what I'm

10 saying or is it -- am I misleading?

11 A Can you repeat the question?

12 Q Who is responsible for installing your

13 cabinets?

14 A Are you asking my belief or --

15 Q No, I'm asking you --

16 A Because if you're asking me what the code or

17 the law says, I don't know.

18 Q I didn't say nothing about code. Ma'am.

19 A Um-hum.

20 Q I'm asking you, who is responsible for

21 installing your cabinets?

22 A I'm asking you are you talking about who is

23 responsible as per the law or code or who do I think is

24 responsible?

25 Q Based on your complaint whatever you --

59

1 Q So, she's the contractor. She doesn't need --

2 she's not giving you bids from anyone else who did the

3 work right? So when did --

4 A I didn't understand the question.

5 Q I'm trying to understand your testimony.

6 You're saying she bought you bids. If she's a

7 contractor, why would she bring you bids? I'm trying to

8 understand that part.

9 A Because she was hiring cabinet companies. I'm

10 trying to understand your question.

11 Q Have you ever had any construction done in

12 your house?

13 A No.

14 Q Have you ever had any handy -- handyman work

15 done in your house?

16 A Very little.

17 Q Has it been more than one person working with

18 another firm? Has it been a person working with someone

19 else, has it been just one person doing the work?

20 A I don't recall.

21 Q As part of your job, do you get involved with

22 the payments of contractors or any of the laborers

23 there?

24 A Not at all.

25 Q Okay. So, what I'm trying to figure out is,

61

1 whatever testimony you want to give.

2 A I believe the general contractor bears a

3 responsibility.

4 Q Okay. Who is responsible, in this case for

5 installing your cabinets?

6 A I really don't -- if you -- you need to be

7 specific. Are we talking about the code --

8 Q Mimi didn't install your cabinets. Correct?

9 A No.

10 Q She wasn't involved in installing the

11 cabinets. Correct?

12 A That is not what I said.

13 Q Okay. So, you tell me what it is that you're

14 saying.

15 A She was involved for hiring the company for

16 overseeing the work, for supervising for making sure

17 that corrections were made to not just the cabinet work,

18 but everybody that she had work in my house.

19 Q So, she is the person you retained to do the

20 work. Correct?

21 A Are you talking about her hands on the work?

22 Q No. For the work, whatever it is that she

23 hired. You're saying, you hired her to get the work

24 done for you?

25 A Yes.

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1 Q Okay. That's what I want to hear. So, you

2 hired her to get -- to have the cabinets installed.

3 Correct?

4 A I hired her, yes. I hired her since the

5 beginning. I hired her to paint my fence, --

6 Q Okay. Great.

7 A -- my walls. I hired her to do the --

8 Q So you -

9 A -- work in my kitchen. I hired her to do all

10 of it.

11 Q Perfect. That's it. That's your testimony.

12 A Yeah.

13 Q Then you would pay her for her work, correct?

14 You've got to pay the contractor for their work. Right?

15 A I wrote her checks. Yes.

16 Q But you paid her for her work. Am I correct?

17 A I wrote her checks. Yes.

18 Q Did you pay her for her work?

19 A I can -- I am not understanding the question.

20 Q What do you do, when you go buy groceries you

21 pay for the groceries?

22 A I paid her -- when you say her work, are you

23 trying to differentiate whether or not she physically

24 put the cabinets out?

25 Q No. I'm not making any distinction. You're

64

1 Q But you hired --

2 A I don't know.

3 Q But you hired her.

4 A I don't know.

5 Q But you hired her. So, with her, I'm not

6 talking about anyone else, just with her. Is the normal

7 way of doing business is for her to give you quotes.

8 And but you're hiring her.

9 That's -- that was the normal way of doing

10 business?

11 A The quotes that she gave me, she said she was

12 not happy with the first quote that she got, it was too

13 high. And that she was going to go to another cabinet

14 company.

15 Q All right. So, in number nine, paragraph

16 nine, you said she made false statements. What were the

17 false statement?

18 A She said she was a general contractor.

19 Q Okay. Or lied and misrepresented the

20 Plaintiff. How often does she tell you that she was a

21 general contractor?

22 A I don't recall.

23 Q Did she tell you once?

24 A Multiple times.

25 Q Is that more than three or more than four?

63

1 the one who's saying that she had a responsibility with

2 the cabinets. So, I am asking did you pay her for her

3 work.

4 A Yes, I believe I did.

5 Q Okay. So, my question to you, after all the

6 things you just said, she's responsible and you've paid

7 her.

8 Why would she give you quotes so that you can

9 pick which one is lower when she just could have told

10 you I'm charging you X?

11 A I don't know. That's her way of doing

12 business.

13 Q So, --

14 A I don't know.

15 Q It's her way of doing business to undermine

16 how much she can make, is that what you're saying?

17 MR. FRIEDMAN: Object to the form.

18 A I don't know.

19 Q (By Mr. Rodriguez) You don't know. So, you --

20 so in your opinion, it's normal for a contractor to --

21 for you to hire a contractor and for them to give you

22 quotes on the different jobs.

23 That's the normal way of doing business?

24 A I've already said I have not hired a

25 contractor before this.

65

1 A I don't recall. I do remember that on one of

2 her quotes she put GC on the paperwork.

3 Q Great. Where is the paperwork?

4 A I would have to give that to you if my

5 attorney doesn't already have that for you.

6 Q Yes, give me that. I don't have it. So, can

7 you provide the quote provided by Ms. Nguyen that's says

8 she's a GC?

9 A I don't recall if it was quote. But it was

10 documentation to another company.

11 Q Can you explain that please?

12 A I don't remember if it was exactly a quote on

13 the document. I just remember it was documentation to

14 another company.

15 Q That part, can you explain documentation to

16 another company. I don't understand that.

17 A She may have -- it may have been a

18 documentation about the design of my kitchen. She was

19 working with the subcontractor on a design of my

20 kitchen.

21 Q Do you think you have any responsibility in

22 investigating whether the people that are doing work for

23 your house are licensed and insured?

24 A I thought I had by asking.

25 Q No. My question, you know, I'll ask it again.

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1 Do you believe that you have any responsibility in

2 investigating whether the person installing your

3 cabinets or subcontractors are licensed and insured?

4 MR. FRIEDMAN: Objection. Asked and answer.

5 You can answer it.

6 A I don't have an opinion on that question.

7 Q (By Mr. Rodriguez) I'm not asking you for an

8 opinion. I'm asking you, if you have a responsibility

9 to investigate the credentials of those that enter your

10 house to install cabinets or those that quote you on

11 installation of cabinets.

12 MR. FRIEDMAN: Object to the form.

13 A At this point I would say no. I would say I

14 did my due diligence by asking.

15 Q (By Mr. Rodriguez) Had she told you "Ms. Adams

16 I am not a licensed or insured," you would not have her

17 do the job. Is that a --

18 A 100 percent, no I would not have done the job

19 with her.

20 Q Can you describe some of your injuries and

21 your daughter's injuries?

22 A My injuries were a head injury, neck injury,

23 back injury. My daughter was head and neck,

24 neurological.

25 Q How is your daughter feeling now?

68

1 A Yeah. Commercial construction environment,

2 I'm not -- I don't deal with residential at all.

3 Q Do you do any research as part of your job

4 when it comes to construction sites?

5 A In what regard?

6 Q Any research that you do in any regard when it

7 comes to these construction sites?

8 A I research the codes.

9 Q You don't do anything with permits?

10 A In what regard?

11 Q With regards to your job?

12 A I don't research any permits at this point.

13 No.

14 Q Did you do that in the last four years?

15 A No.

16 Q Do you have any experience with permits?

17 A I do.

18 Q You do. What kind of experience do you have

19 with permits?

20 A In regards to the commercial construction,

21 part of it.

22 Q Okay. So, what kind of experience do you

23 have? Elaborate on the experience you have with the

24 permits?

25 A I know what they are and I know what trades

67

1 A She's doing better.

2 Q Did she attend school?

3 A I'm sorry. Does she now?

4 Q Yes.

5 A Yes. Oh, no. She's doing online learning.

6 Q Did she attend school after the incident?

7 A It took her two months to get back to school.

8 Q And just to clarify, did you pay with check or

9 cash?

10 A Pay what?

11 Q For the installation on the cabinets.

12 A Check, several checks.

13 Q Okay. Did you pay with check or cash for the

14 installation of the floors or the floor, I'm sorry?

15 A I believe it was checks.

16 Q Okay. And you paid also for -- so, everything

17 you paid for was generally with check?

18 A Generally yes, I believe so.

19 Q So, as someone who's been on construction

20 sites for, let's say several years as part of your job.

21 You have no understanding of, you know, the general

22 contractor relationship with the subcontractors or you

23 do or you don't?

24 A I do.

25 Q You do?

69

1 are supposed to inspect a commercial construction site.

2 Q So, how long have you dealt with permits or

3 how many years have you had experience with permits?

4 A I don't recall.

5 Q One year, two years?

6 A I'm sorry?

7 Q One year, two years?

8 A I don't recall. There was a point in time

9 where I was, I mean I would see what trades were

10 supposed to sign off on a construction site.

11 But it's been a long time since I've been

12 involved in --

13 Q So, you don't --

14 A -- in a commercial construction site. Like, I

15 said I have no experience with residential construction.

16 Q So, but you know what a permit is?

17 A Yes.

18 Q You know what it is.

19 A Yes.

20 Q You know that it is required when the work is

21 done, construction work is done. Correct?

22 A Yes. And for commercial construction, I am

23 familiar. I don't always know the answers. But I'm

24 familiar with it.

25 Q So, when you had your cabinets installed. You

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1 didn't ask for them to see if the permits were being

2 pulled?

3 A I 100% asked Alex and Mimi and they said they

4 were not required.

5 Q Okay. And you took it at face value although

6 you have a background in commercial construction that

7 they were not required?

8 MR. FRIEDMAN: Objection form, you can answer.

9 A I had no experience, you could tell me that

10 otherwise.

11 Q (By Mr. Rodriguez) But you have experienced

12 commercially, which is more elaborate than residential?

13 MR. FRIEDMAN: Object to the form.

14 Q (By Mr. Rodriguez) Do you have experience in

15 commercial construction when it was in regard to

16 permits?

17 A Yes.

18 Q Okay. So, at no point did you question

19 whether it may have been needed?

20 A I already told you I asked them both if it was

21 needed and they both told me, no.

22 Q After they told you no, did that raise a red

23 flag that maybe, you know, something was wrong?

24 A No.

25 Q You didn't think you needed, you had a

72

1 in the past?

2 A When I, yes. The answer is yes.

3 Q So, what work did you see?

4 A I saw the work that she did next door. She

5 took me to her house to see the kitchen cabinets that

6 were installed at her house.

7 And I saw her doing work with a construction

8 team at a -- another house. I don't know the location.

9 Q When you went to her house and saw her

10 cabinets, did you like them?

11 A I don't recall.

12 Q Did you see any of the work that was done by

13 any of the other, the person who installed the cabinets

14 in your home?

15 A I don't recall.

16 Q Is it your tendency not to investigate before

17 having worked done?

18 MR. FRIEDMAN: Object to the form.

19 A Can you repeat the question?

20 Q (By Mr. Rodriguez) Is it your tendency not to

21 investigate before having work done?

22 MR. FRIEDMAN: Same objection.

23 Q (By Mr. Rodriguez) You can answer.

24 A It depends on what you're referring to.

25 Q I'm referring to the cabinets --

71

1 electrical done. Correct?

2 A There -- I had somebody hang a light fixture.

3 Q So, you had electrical work done. You had

4 someone hang a light fixture?

5 A Yes.

6 Q You had plumbing, correct?

7 A I had a sink changed out.

8 Q Okay. And so, you have floor installed,

9 right?

10 A I had, no. I don't know if you can call it

11 installed, they put veneer over the tile type of thing.

12 Q So, you don't feel like you had any elaborate

13 work?

14 A No. I do think that they did elaborate work

15 and if you call elaborate work putting in a new kitchen.

16 Q Just give me one second. Did you ever go to

17 Ms. Nguyen's house?

18 A I did. Yes.

19 Q More than once?

20 A I don't recall.

21 Q Did she ever come -- go to your house?

22 A Yes.

23 Q More than once?

24 A Yes.

25 Q Okay. And did you ever see work she has done

73

1 A I -

2 Q I'm asking you, if you saw previous work from

3 the person who installed the cabinets and you said you

4 didn't recall.

5 So, I'm trying to understand that it's normal

6 for you not to look at, you know, previous work.

7 A I saw the cabinets installed at her house.

8 Q I asked if you liked them, you said you don't

9 recall?

10 A I don't recall --

11 Q And now you are saying --

12 A I do not recall my personal feeling on whether

13 I liked the cabinets or not.

14 Q Okay. So, what is the correlation between her

15 cabinets and the person installing them in your house?

16 A I don't recall.

17 Q So, why did you just mention that you saw her

18 cabinets after I asked you a question. That was not

19 related to her cabinets?

20 A Okay. So, can you rephrase the question

21 because I'm confused by the question?

22 Q Okay. You said that you don't recall if the

23 person who installed the cabinets showed you work

24 they've done in the past. Correct?

25 A The person that installed the cabinets did not

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1 show me work they did in the past.

2 Q Is that how you usually conduct business when

3 it comes to installation of, you know, cabinets or

4 things like that in your house or when you make a

5 purchase, let's say you don't look at prior work.

6 You just, I mean how would you have known to

7 hire them? Like, you know, what, I'll -- strike that --

8 How would you have known to that you wanted to hire this

9 person to do your work?

10 A I trusted Mimi.

11 Q So, you weren't concerned about the aesthetics

12 of the cabinets?

13 MR. FRIEDMAN: Object to the form.

14 Q (By Mr. Rodriguez) Were you concerned about

15 the aesthetics of the cabinets?

16 A No.

17 Q So, if they were purple, if they weren't

18 finished that was not a concern for you?

19 A We discussed what color they would be. They

20 weren't going to be purple.

21 Q No, I'm asking you --

22 A Mimi and I discussed all the details of the

23 cabinets prior to the installation.

24 Q Okay. Right. But you didn't see anything.

25 That's what your testimony is that, you didn't see any

76

1 your neighbor's house?

2 A I don't recall.

3 Q Did you have any written agreement with Ms.

4 Nguyen with regard to the installation of the cabinets?

5 A I don't recall.

6 Q Do you remember signing any documents with

7 regard to the installation of the cabinets?

8 A I don't recall.

9 Q Do you recall signing an agreement with the

10 cabinet installer?

11 A I don't -- I can't remember. I can't remember

12 what documentation I signed at that time. I would have

13 to go back in my records.

14 Q Did you ever buy the house next door?

15 A No.

16 Q And I'm sorry. What did you say about the

17 camera? You don't -- you didn't have a camera when the

18 cabinets fell?

19 A I don't remember having a camera when the

20 cabinets fell.

21 Q You said you had a cabinet at some point in

22 your kitchen, correct?

23 A I have cabinets in my kitchen.

24 Q No, I said, you testified that you had a

25 camera in your kitchen at some point.

75

1 prior work that, you said okay, I like that. I want

2 something similar to that installed in my house?

3 A I do not recall.

4 Q Okay. And then what I want to know is that

5 how you usually conduct yourself when it comes to, you

6 know, something like installing cabinets or maybe, I

7 don't know, installing the floor.

8 Did you just say, I want to install floors and

9 then go ahead and install, you know, some --

10 A I -

11 MR. FRIEDMAN: Object to the form. Go ahead,

12 you can answer.

13 A I feel that Mimi and I discussed all the

14 details prior to me writing the first check for deposit

15 on the cabinets.

16 Q (By Mr. Rodriguez) Can you -- so, then I'm

17 going to ask you that this question. Can you please

18 elaborate on all the details that you discussed with

19 Mimi?

20 A Where the cabinets would go, where -- what

21 finish day would be, you know, whatever it was that the

22 install -- that our installer would need to know, we

23 discussed prior to hiring them.

24 Q So, when you saw your neighbor's house and you

25 went inside, did you like the way the cabinets looked in

77

1 A I had a camera in my kitchen at some point.

2 But I do not believe I had a camera at this time of the

3 accident.

4 Q Okay. Why do you believe you didn't have a

5 camera?

6 A I would have video of the accident.

7 Q Were the cameras in your house working at the

8 time you had the accident?

9 A I don't know.

10 Q Did you have cameras in your house when you

11 had the accident?

12 A I don't recall.

13 Q What companies do you use for camera service

14 in your house?

15 A ADT.

16 Q ADT.

17 A Sometimes they work, sometimes they don't.

18 Q So, did ADT install cameras in your kitchen?

19 A No one has installed cameras in my house. You

20 just plug them in.

21 Q All right. So, did you plug in cameras in

22 your kitchen?

23 A At one point I did.

24 Q Okay. And do you know what point that was?

25 A No, I don't.

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1 Q Was it before the incident, after the

2 incident?

3 A I do not recall.

4 Q Wouldn't it be convenient to have a camera in

5 the kitchen at the day of the incident, this way we can

6 see exactly what happened.

7 A I think you would be terrified.

8 Q I'm asking you, would it be convenient to have

9 a camera? Would it have been convenient to have a

10 camera on the day of the accident?

11 A Yes.

12 Q But according to your testimony that camera

13 was not installed in the kitchen?

14 A I don't recall.

15 Q Is there any way to investigate whether there

16 was a camera or not?

17 A We could call ADT and see if they have that

18 footage from them.

19 Q All right. I'm almost done. Did you ever

20 asked Ms. Nguyen for a card?

21 A I don't recall.

22 Q Did you ever look on a website, if she had a

23 website?

24 A I don't remember.

25 Q Do you remember anything significant?

80

1 A No.

2 Q Okay. What's your boyfriend's name?

3 A Greg Mitchell. At the time his name was Greg

4 Mitchell.

5 Q What's his phone number?

6 A The number that I have for him is 305-748-

7 7975.

8 Q Do you have his address?

9 A I do not.

10 Q So, Greg Mitchell was present when the

11 cabinets fell?

12 A He was in the house.

13 Q Did he see the cabinets fall?

14 A I don't know.

15 Q What was your reaction to him right after they

16 fell?

17 A I'm sorry?

18 Q What was your reaction after they fell, the

19 cabinets?

20 A I honestly thought a plane hit the house. And

21 I was under all these cabinets and looking at my

22 unconscious daughter, my reaction was -- I was

23 horrified. I was terrified.

24 Q Did you scream?

25 A I don't remember if I screamed or not.

79

1 MR. FRIEDMAN: Objection.

2 Q (By Mr. Rodriquez) There's a lot that you

3 didn't recall. What --

4 MR. FRIEDMAN: Are you withdrawing that

5 question or moving on?

6 MR. RODRIGUEZ: I was asking.

7 MR. FRIEDMAN: Okay. Object to the form.

8 Q (By Mr. Rodriquez) What are the things that

9 you recall?

10 A I recall looking over at my own unconscious

11 daughter buried under cabinets and feeling horrified.

12 Q And I'm very sorry. But other than that, do

13 you recall anything else that you might want to tell me?

14 A Can you be more specific?

15 Q You -- is there anything you might want to

16 tell me regarding the incident, the installation that I

17 haven't asked you?

18 A It was egregious from what the inspector said

19 and it should have never happened.

20 Q Okay. Was anyone present in your house when

21 you -- when this happened, when the incident occurred?

22 A Yes.

23 Q Who was present in your home?

24 A My boyfriend at the time.

25 Q The gentleman that you had the issue with?

81

1 Q All right. Did you, maybe call out to him for

2 help?

3 A I don't remember.

4 Q Did you call 911?

5 A Yes.

6 Q Did they take your daughter to the hospital?

7 A They took us both to the trauma room, yes.

8 Q And after, were you admitted?

9 A I'm not sure what admitted means?

10 Q Did you say overnight?

11 A No.

12 Q Did your daughter stay overnight?

13 A I can't remember if we were there overnight. I

14 honestly don't know how long I was there.

15 Q Did you have any lacerations on your head?

16 A No.

17 Q Did your daughter have any laceration on her

18 head?

19 A She had scratches.

20 Q Did there -- was there any bruising, bumps?

21 A A lot of bruising, a lot of bumps, a lot of

22 swelling.

23 Q What were the -- what was the bruising and the

24 bumps on you or both?

25 A On me, I don't recall exactly where the

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1 bruising was. The bumps were on the top of my head. Do

2 you want me to go onto her?

3 Q Yes.

4 A She had bruising all over one side of her face

5 and swelling. She was hit more towards the face than I

6 was.

7 Q Did you take pictures?

8 A I don't recall.

9 Q How soon after you have this accident, did you

10 contact an attorney?

11 A I don't remember.

12 MR. FRIEDMAN: Objection.

13 Q (By Mr. Rodriguez) How soon after the accident

14 did you go to another clinic or hospital?

15 A I had ongoing treatment. I'm still undergoing

16 treatment. So, I'm not sure, you know, I'm not sure

17 what your question is.

18 Q My question is after you left the hospital,

19 how soon after that did you start getting additional

20 treatment?

21 A I -- it was, as soon as I could get to a

22 doctor for a follow-up. But I don't remember how long.

23 Q Was it five months?

24 A No, it was immediately, I was in incredible

25 pain and so was my daughter.

84

1 know, your entire body?

2 A I don't recall.

3 Q So, you don't recall if the cabinets were on

4 your stomach? You don't recall if they were on top of

5 your legs, you just recall that they were on top?

6 A Yes.

7 Q And what about your daughter?

8 A I don't recall exactly what body parts it was

9 on. They were very large cabinets.

10 Q Okay. The way you testified, made it seem

11 like it's a cabinet on top of you. And someone had to

12 come and help you out, you know, get them off.

13 So, that's why I'm asking you where they were?

14 Did you get the cabinet off yourself or did someone have

15 to -- did Mr. Mitchell have to come and take the

16 cabinets off?

17 A The way that I remember it was that he came

18 and helped me get them off of me.

19 Q Okay. And --

20 A He would be a better person to ask since he

21 wasn't directly involved in the incident.

22 Q And was that the same way with your daughter?

23 A What's the question?

24 Q Was it the same situation where your daughter

25 that he came and removed the cabinets from, off your

83

1 Q Right so --

2 A We both wound up seeing neurologists.

3 Q That's what I'm asking. So, how soon after

4 they, do they --

5 A I don't remember. It was a very traumatic

6 event and I do not recall.

7 Q What was Greg Mitchell's reaction when the

8 cabinet's fall?

9 A You would have to ask him.

10 Q Did he come to help you? Did he help you at

11 all?

12 A Yes. Yes. He came to help me get the

13 cabinets off me and then together we got them off my

14 daughter.

15 Q But when you say the cabinets off you, you

16 were laying flat on the floor with the cabinets on top

17 of you?

18 A I don't remember how I was laying. But yes,

19 there were cabinets on top of me.

20 Q Where were they?

21 A On top of me. I don't know --

22 Q I know, well, --

23 A I --

24 Q -- can you explain where, was it on your

25 torso, was it on your leg, was it all over your, you

85

1 daughter?

2 A He lifted them up and I pulled her out as I

3 remember.

4 Q I mean, they were that heavy that he had to

5 lift them up and then --

6 A Yes.

7 MR. RODRIGUEZ: All right. I have no further

8 questions.

9 MR. FRIEDMAN: No questions for me.

10 (Deposition concluded at 03:18 p.m.)

11 (Reading and signing of the deposition by the

12 witness has been reserved.)

13

14

15

16

17

18

19

20

21

22

23

24

25

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 42 of 74
Adams, Melanie 02-16-2021

86

1 CERTIFICATE OF REPORTER

2 STATE OF FLORIDA

3 COUNTY OF HILLSBOROUGH

4

5 I, Meghan Willis, Court Reporter and Notary Public

6 for the State of Florida, do hereby certify that I was

7 authorized to and did digitally report and transcribe

8 the foregoing proceedings, and that the transcript is a

9 true and complete record of my notes.

10

 I further certify that I am not a relative,

11

employee, attorney or counsel of any of the parties,

12

nor am I a relative or employee of any of the parties'

13

attorneys or counsel connected with the action, nor am

14

I financially interested in the action.

15

16 Witness my hand this 18th day of March, 2021.

17

18

19

20

____________________________________

21 MEGHAN WILLIS, COURT REPORTER

NOTARY PUBLIC, STATE OF FLORIDA

22

23

24

25

88

1 DATE: March 17, 2021

TO: Melanie Adams

2 C/O Zachary Friedman, Esquire

 2 Grove Isle Drive, Apt 1210

3 Coconut Grove, Florida 33133

4 IN RE: Phuong Mimi Nguyen, Debtor and Melanie Adams,

individually and on behalf of her minor daughter,

5 Taylor Adams vs. Phuong Mimi Nguyen

6 CASE NO: 20-15954-RAM and 20-01350-RAM

7 Dear Ms. Adams,

8 Please take notice that on February 16, 2021, you gave

your deposition in the above-referenced matter. At

9 that time, you did not waive signature. It is now

necessary that you sign your deposition. You may do so

10 by contacting your own attorney or the attorney who

took your deposition and make an appointment to do so

11 at their office. You may also contact our office at

the below number, Monday - Friday, 9:00 AM - 5:00 PM,

12 for further information and assistance.

13 If you do not read and sign your deposition within

thirty (30) days, the original, which has already been

14 forwarded to the ordering attorney, may be filed with

the Clerk of the Court.

15

If you wish to waive your signature, sign your name in

16 the blank at the bottom of this letter and promptly

return it to us.

17

18 Very truly yours,

19 Meghan Willis, Court Reporter

Universal Court Reporting

20 (954)712-2600

21 I do hereby waive my signature.

22

_______________________

23 Melanie Adams

Cc: via transcript: Ricardo Rodriguez, Esquire

24

25

87

1 CERTIFICATE OF OATH

2 STATE OF FLORIDA

3 COUNTY OF HILLSBOROUGH

4

5 I, Meghan Willis, the undersigned authority,

6 certify that Melanie Adams, appeared before me remotely

7 pursuant to Florida Supreme Court Order AOSC20-23 and

8 was duly sworn on the 16th day of February, 2021.

9

Witness my hand this 18th day of March, 2021.

10

11

12

13

14

____________________________________

15 MEGHAN WILLIS, COURT REPORTER

NOTARY PUBLIC, STATE OF FLORIDA

16 Commission No.: GG 188381

Commission Exp: 02/25/2022

17

18

19

20

21

22

23

24

25

89

1 ERRATA SHEET

2 I wish to make the following changes, for the following

 reasons:

3

 PAGE NO. LINE NO.

4

 _______ _______ CHANGE______________________________

5

 REASON______________________________

6

 _______ _______ CHANGE______________________________

7

 REASON______________________________

8

 _______ _______ CHANGE______________________________

9

 REASON______________________________

10

 _______ _______ CHANGE______________________________

11

 REASON______________________________

12

 _______ _______ CHANGE______________________________

13

 REASON______________________________

14

 _______ _______ CHANGE______________________________

15

 REASON______________________________

16

 _______ _______ CHANGE______________________________

17

 REASON______________________________

18

 _______ _______ CHANGE______________________________

19

 REASON______________________________

20

 _______ _______ CHANGE______________________________

21

 REASON______________________________

22

 _______ _______ CHANGE______________________________

23

 REASON______________________________

24

 ______________________ _______________

25 SIGNATURE DATE

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 43 of 74
Adams, Melanie 02-16-2021 Page 1 of 31

0

02/25/2022

87:16

03:18 85:10

1

1:30 1:18

100 66:18

100% 70:3

11th 26:14

1210 2:3 88:2

132 9:13

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17 88:1

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18th 86:16

87:9

1994 6:13 8:7

2

2 2:3 88:2

2000 22:11

20-01350-RAM

1:3 5:11 88:6

2015 22:11,20

20-15954-RAM

1:3 5:8 88:6

2016 10:17,18

11:3

22:8,9,15,19,

21,23,24

23:2,10,17,18

26:16 28:19

2018 22:14,16

23:2,11,18

2021 1:18

5:2,4 26:14

86:16 87:8,9

88:1,8

27th 26:16

28 4:3

3

3:18 1:18

30 88:13

305.262.8226

2:9

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33133 2:4 88:3

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4

49TH 2:8

5

5:00 88:11

505 2:8

6

6 3:3

7

7975 80:7

9

9:00 88:11

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911 81:4

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88:20

A

able 31:25

44:17

about 6:6

15:20

21:14,21

25:11 26:7,9

27:25

28:14,22 30:5

31:16 35:5

41:16 49:12

55:2 56:15,20

58:8 60:18,22

61:7,21 64:6

65:18

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above 50:3,4

abovereferenced

88:8

Absolutely

33:9 46:16

access 27:11

accident 49:13

77:3,6,8,11

78:10 82:9,13

according

35:25 60:4

78:12

achieve 39:11

acquaintance

27:19

action 39:11

86:13,14

activities

7:11

Adams 1:8,9,16

3:2

5:1,6,9,10,18

,22 6:3,5 9:9

26:17 36:9

66:15 87:6

88:1,4,5,7,23

additional

82:19

address 11:13

40:12,13 80:8

admitted

81:8,9

ADT

77:15,16,18

78:17

aesthetics

74:11,15

affiliated

16:6

after 5:23

12:17 14:9

15:5,8 16:24

17:1 38:8

48:13,14,15,2

4 52:6 54:22

55:8,11 63:5

67:6 70:22

73:18 78:1

80:15,18 81:8

82:9,13,18,19

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 44 of 74
Adams, Melanie 02-16-2021 Page 2 of 31

83:3

afterwards

56:4

again 8:20

14:10 18:19

31:3 54:25

55:1 57:21

65:25

against

14:13,18

55:17

agenda 31:12

agendas 31:13

35:12,20

ago 8:4 40:4,5

agree 52:21

agreement

76:3,9

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55:3 58:18,21

75:9,11

aircraft

8:14,24 9:2

AirPods 12:11

19:16

airport 8:14

31:10 40:15

Alex 41:24

43:4 70:3

all 1:19 20:10

23:6 29:17

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45:1

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63:5 64:15

68:2 74:22

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almost 78:19

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already

27:15,23 28:4

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am 6:15 14:22

36:3 43:10

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66:16 69:22

86:10,12,13

88:11

Amazon

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3,15,16,21

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59:18 64:13

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answer 7:14

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46:20 47:16

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75:12

answered 54:24

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answer's 47:1

any 7:19

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15:8 18:13,15

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30:2,14 35:20

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44:1,22 46:17

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51:23

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59:11,14,22

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71:12

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79:20

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18:15 20:1

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79:13,15

AOSC20-23 1:20

87:7

apologize

20:22

APPEARANCES

2:1

appeared 1:19

87:6

appliances

18:9

appointment

88:10

approach 17:21

approached

18:3

approaching

17:25

Approx 10:17

approximate

38:13,22

42:18

approximately

7:6 8:16

10:17 35:11

40:14

Apt 2:3 88:2

architects

35:17,22,23

36:5,14 39:10

argument 32:12

around 52:22

53:1

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 45 of 74
Adams, Melanie 02-16-2021 Page 3 of 31

ask 6:6

14:7,24,25

46:17,23

54:12 65:25

70:1 75:17

83:9 84:20

asked 14:20

15:20 16:9,23

42:5 46:21

48:11 54:24

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70:3,20

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79:17

asking

13:14,16

15:9,11,12

19:7,9 30:20

36:12,13,23

38:13,22

50:12

54:20,21 55:7

57:15,21

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,20,22 63:2

65:24

66:7,8,14

73:2 74:21

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83:3 84:13

assistance

88:12

association

27:2

assume 22:23

32:11

Assuming 35:25

attempt 47:19

attend

39:15,17

67:2,6

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attending

39:21,25

attention

10:10 17:18

attorney 46:13

65:5 82:10

86:11

88:10,14

attorneys

86:13

audio 19:16

authority 87:5

authorized

86:7

Avenue 9:13

Aviation 30:25

36:8

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50:21 51:8

B

back 20:13,18

46:11 52:7,19

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70:6

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bank 13:3

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BANKRUPTCY 1:1

based 56:2

60:25

basically 6:7

32:7

basis 7:17

bears 61:2

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38:8,10

because 11:22

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before 8:11

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beginning

10:18 38:3,6

62:5

behalf 1:8,17

2:2,6

5:9,17,19

56:8 88:4

belief 60:14

believe 22:9

34:15 43:8

50:14 56:6,10

61:2 63:4

66:1 67:15,18

77:2,4

believed 22:5

belongings

41:2

below 27:12

49:24 50:6

88:11

benefit 23:1

besides 21:15

better 67:1

84:20

between 15:13

22:11 73:14

bid

56:18,20,21

57:16,24

bids 56:22

57:2

58:5,14,16,24

,25 59:2,6,7

big 8:24

biggest 47:24

bit 50:14

bits 57:3,17

blank 88:16

blockage 19:20

blocked 19:24

body 84:1,8

bonded 28:16

both 51:1

70:20,21

81:7,24 83:2

bother 47:12

bottom

50:17,21

88:16

bought 59:6

boyfriend

25:11,16,20

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 46 of 74
Adams, Melanie 02-16-2021 Page 4 of 31

26:2 28:14

79:24

boyfriend's

80:2

briefly 26:11

bring 59:7

Bringing 18:9

brother 25:6,7

brought 58:22

bruising

81:20,21,23

82:1,4

Budgeting 7:18

building 7:23

31:21,23 32:1

built 34:6

bulls 24:7

bumps

81:20,21,24

82:1

bureau

30:24,25

31:10 34:14

36:7,8 37:23

39:8

buried 79:11

business 21:22

23:11

63:12,15,23

64:7,10 74:2

busted 27:10

buy 24:21,24

62:20 76:14

buying 25:9

44:24

C

C/O 88:2

cabinet 45:3

46:2 49:1

50:5,20,21

58:17 59:9

61:17 64:13

76:10,21

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23:12,23

41:6,13,17,18

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49:7,10,17,18

,21,25

50:3,6,9,15,1

9

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1

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13:3 15:18,22

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13:24 15:17

16:16 26:5

40:17 48:23

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78:17 81:1,4

called 5:23

15:22 44:3

calling 16:19

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76:17,19,25

77:1,2,5,13

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16

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,21

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34:18 35:12

36:5,11 37:18

41:17

42:12,18

43:15,25

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49:18

51:4,14,17

52:25 53:18

54:9,10,25

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57:17,24

60:11 62:19

63:8,16

65:6,11,15

66:5,20 70:8

71:10

72:19,23

73:20

75:12,16,17

78:5 79:14

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can't 43:18

45:24 76:11

81:13

capacity 40:7

captain

8:13,20,21

captured 38:1

card 27:11

78:20

cards 27:3

career 38:4,6

case 1:3

5:8,11 8:18

33:4,5 61:4

88:6

cash 67:9,13

catch 12:5

caught 17:18

cause 54:21

55:8

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 47 of 74
Adams, Melanie 02-16-2021 Page 5 of 31

Cc 88:23

CERTIFICATE

86:1 87:1

certification

10:5,6

certify

86:6,10 87:6

challenge

53:25

challenging

53:22

change 19:15

89:4,6,8,10,1

2,14,16,18,20

,22

changed 71:7

changes 89:2

charge 8:13

30:24 36:8

37:23 39:8

chargeability

54:1

charging 63:10

check

67:8,12,13,17

75:14

checks 42:24

43:1 62:15,17

67:12,15

chief

6:10,14,15,18

,24 7:8

8:6,11 31:4

38:8,10

chief's 8:22

children 9:5

clarify 67:8

clarifying

25:8

Clerk 88:14

clinic 82:14

closer 35:6

Coconut 2:4

88:3

code

32:4,6,9,14,1

8,19,20,21

36:20 37:3

60:16,18,23

61:7

codes 32:22,23

34:5 36:1,2

37:1 68:8

college

9:22,24 10:4

color 74:19

come 49:2

71:21 83:10

84:12,15

comes 34:5

36:23 68:4,7

74:3 75:5

commercial

68:1,20

69:1,14,22

70:6,15

commercially

70:12

Commission

87:16

communicate

40:16

companies 59:9

77:13

company

15:17,21,22

16:5 44:1

45:16,17,19

46:7 47:14

61:15 64:14

65:10,14,16

complaint

53:17,19,21,2

4,25

54:3,7,13

56:12

57:16,21,22

60:25

complete 9:16

86:9

compliance

7:23 39:11

Concept 43:5

Concepts 43:2

concern 74:18

concerned

74:11,14

concluded

85:10

conclusions

36:9

conduct 74:2

75:5

confide

25:10,15 28:2

confided 25:18

28:14

confirmed

15:24 16:14

confused 73:21

connected

86:13

connection

34:19

consider 27:18

consisted 12:8

construction

7:19 8:1,2

18:5,7,11

29:2,5,9,10,1

3,15,16,21

30:4,7,8,9,10

,11,21 31:5,8

32:24 33:1,13

34:14,22 35:1

36:14 37:4,19

38:2,17,20,24

39:2,7,13,15,

17,19,20,25

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56:18,19,20,2

1 57:24 59:11

67:19

68:1,4,7,20

69:1,10,14,15

,21,22

70:6,15 72:7

consultation

42:2

contact 14:10

18:18 82:10

88:11

contacting

88:10

context 19:4

contractor

10:23 11:1

12:10,15

13:4,11 15:24

16:3,7,9,10,1

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 48 of 74
Adams, Melanie 02-16-2021 Page 6 of 31

8 18:24 21:24

22:1,4 23:5

33:19

43:15,23 46:2

48:3 54:15

56:16 59:1,7

61:2 62:14

63:20,21,25

64:18,21

67:22

contractors

18:1,4,16

33:13,21,23,2

5 34:3,8,24

59:22

convenience

18:1 47:25

convenient

78:4,8,9

conversation

12:8 13:19

15:16

conversations

21:9

correct 11:12

17:18 18:14

22:8,17 23:3

30:24 32:8

43:22 44:6

47:6 53:22

54:1 55:17,24

58:2,6,13

60:6,9

61:8,11,20

62:3,13,16

69:21 71:1,6

73:24 76:22

corrections

61:17

correctly 34:6

42:3 43:3

48:19,20,22

correlation

73:14

could 6:3

15:17 16:13

18:10 37:10

39:11 41:2

63:9 70:9

78:17 82:21

counsel 2:1

86:11,13

counsels 5:14

counter

50:4,14 51:19

52:4

countertop

50:3,8

county 56:7

86:3 87:3

couple 21:19

35:8,9

Court

1:1,20,24

5:3,12,13

28:7,8,11

55:5,7

86:5,21

87:7,15

88:14,19

cowboys 24:5

crash 8:24

credentials

66:9

Creditors 5:17

53:24

curious 18:12

current 30:13

D

date 5:3 17:8

26:15 38:22

41:6 49:12

52:12,13

53:2,3 88:1

89:25

dated 26:14

daughter 1:9

5:10 9:7

49:16,23 52:2

66:23,25

79:11 80:22

81:6,12,17

82:25 83:14

84:7,22,24

85:1 88:4

daughter's 9:8

66:21

day 10:24 13:7

14:9 15:17

16:3 17:4

24:11 31:12

41:17,19,20

42:4,6

49:13,15 53:4

75:21 78:5,10

86:16 87:8,9

days 42:8

88:13

day-to-day

7:11,17

deactivated

27:3

deal 68:2

dealing 60:1

dealt 69:2

Dear 88:7

debtor 1:7

5:7,20 56:13

88:4

debts 53:22

decades 40:6

deceiving

56:18 57:23

December 26:16

28:19

Defendant

1:13,17 2:6

degree 10:3

31:2

degrees 9:14

demo 45:15,19

46:2

demolition

45:3

deny 16:8

department 6:9

7:1,3,13,23

34:12

depend 29:6

54:18

depending

31:11 39:23

depends 32:17

39:3 57:7

58:7 72:24

deposit 75:14

deposition

1:16 5:1,5

15:1 20:8,9

85:10,11

88:8,9,10,13

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 49 of 74
Adams, Melanie 02-16-2021 Page 7 of 31

describe 10:21

18:7 19:2,13

21:2,4 27:22

30:22 36:10

49:15,18

66:20

describing

27:24

DESCRIPTION

4:2

design 35:25

36:17

65:18,19

designmimiyoko

26:17

detailed 51:18

details 54:6

74:22

75:14,18

determine 7:22

32:3,6 39:10

develop 19:1

developed 21:3

27:15,20,25

didn't

17:14,16

19:25 20:21

24:18 37:16

47:12 57:3

58:5 59:4

60:18 61:8

70:1,25 73:4

74:24,25

76:17 77:4

79:3

different

29:25

31:12,13 32:8

57:8,25

58:9,22 63:22

differentiate

62:23

digitally 86:7

diligence

66:14

direct 3:3 6:1

10:9

directly 11:5

33:17 43:4

45:9,10,12,13

,15,22,24

46:7,8 60:1

84:21

disappear 20:9

discharge

53:22

disconnected

20:22

discount 47:2

discuss 10:24

23:23 28:3

31:20 35:18

discussed

15:14,25

23:11

74:19,22

75:13,18,23

discussions

23:13,17

dishes 49:11

52:10

distinction

62:25

DISTRICT 1:1

division 1:2

6:16,19

7:1,2,3,8,12

8:22

doctor 82:22

document 65:13

documentation

37:20,21

65:10,13,15,1

8 76:12

documented

37:24,25

documents 76:6

doesn't 20:8

54:19 59:1

65:5

domestic 26:5

done 34:4

44:20,22

59:11,15

61:24 66:18

69:21

71:1,3,25

72:12,17,21

73:24 78:19

don't 6:21,23

8:19,23 10:19

13:22

14:2,8,11,14,

18,24 15:7

17:3,19 18:20

19:25 20:3,19

21:4,13

22:12,18,22

23:19,25

24:2,12

25:1,9,17,18,

19,23

26:10,19

27:24

28:17,20,23,2

5 30:18,19,20

31:3 32:9

33:22 34:3,11

35:2 36:19

37:8

38:5,19,21,23

39:17,21

40:10,13,18

41:3,7,11,15,

22

42:13,17,21,2

2 43:4,20

44:13

45:11,14,20

46:9 47:4

48:10

50:23,24,25

52:16,17

53:16 54:6

55:2,3 56:9

57:13,18,25

59:20 60:17

61:6

63:11,14,18,1

9 64:2,4,22

65:1,6,9,12,1

6 66:6 67:23

68:2,9,12

69:4,8,13,23

71:10,12,20

72:8,11,15

73:8,10,16,22

74:5 75:7

76:2,5,8,11,1

7,19

77:9,12,17,25

78:14,21,24

80:14,25

81:3,14,25

82:8,11,22

83:5,18,21

84:2,3,4,8

door 10:25

11:3,5,11,14,

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 50 of 74
Adams, Melanie 02-16-2021 Page 8 of 31

21,23 13:3

15:19

16:11,20,21

17:5,7,20

18:2 48:11

72:4 76:14

doors 48:22

doubt 16:2

23:1

down

51:12,13,19

Drive 2:3 88:2

due 66:14

duly 5:24 87:8

dying 19:16

E

earlier 17:12

56:22

education 9:14

egregious

79:18

egregiously

55:25 56:1

either

38:21,22

elaborate

68:23 70:12

71:12,14,15

75:18

electrical

71:1,3

electrician

45:3 46:8

electricity

46:3,6

else 21:4 47:6

58:4,24,25

59:2,19 64:6

79:13

e-mail 4:3

26:8,16,18,23

27:14 40:17

emergencies

8:13,14,25

emergency

9:2,4 10:8

emotional

25:22

employee

86:11,12

employing

56:16

end 10:18

12:22 13:23

22:21,23

23:2,10,18

48:15

enforce 32:9

engineers

35:18,23,24

36:5,14 39:10

enjoy 24:18

enough 14:23

47:5,10

entail 7:10,13

9:25

enter 16:21

66:9

entire 26:23

84:1

entrance 27:12

environment

68:1

ERRATA 89:1

Esquire 2:3,7

3:3 88:2,23

estimate 43:17

45:5,6,7,8

47:19

event 83:6

events 14:18

eventually

49:3

every 24:14

42:10,12,14

everybody

61:18

everything

7:12 48:14

67:16

evolve 12:20

exact 44:17

48:10

exactly 12:7

14:2 48:8

54:6 56:9

57:13 65:12

78:6 81:25

84:8

EXAMINATION

3:1,3 6:1

ex-boyfriend

41:2

exchange 14:5

excuse 12:11

58:23

Exhibit 4:2

28:5,6,10

EXHIBITS 4:1

Exp 87:16

experience

68:16,18,22,2

3 69:3,15

70:9,14

experienced

70:11

explain 8:20

36:5,24

43:15,18,25

51:14

57:17,24,25

65:11,15

83:24

extend

50:8,11,13

extended 54:23

55:9,11

extends 50:14

eye 27:6

eyes 51:10

F

face 70:5

82:4,5

facilitate

43:14

facing 51:8

fall 49:19,25

50:20

51:2,4,5,15

80:13 83:8

fallen 53:8

falling 54:22

55:8

false 56:14

64:16,17

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 51 of 74
Adams, Melanie 02-16-2021 Page 9 of 31

familiar 8:23

32:22 36:2,3

69:23,24

far 10:6 21:9

50:10,12

fault 53:15

54:14,22

55:20

February 1:18

5:2,3 26:14

87:8 88:8

feel 16:16

57:3 71:12

75:13

feeling 66:25

73:12 79:11

fell 41:6

49:17,22

51:5,20,21

52:3,6,8

53:4,11,15

54:14 55:20

58:12

76:18,20

80:11,16,18

felt 16:14

46:25 50:16

55:11

fence 62:5

Feranos 41:24

43:5

few 6:6

fighter 31:4

figure 6:24

14:1 21:16,17

34:19 59:25

file 14:17

filed 14:13

53:18 55:17

88:14

filling 39:3

financially

86:14

find 37:18

46:10

fine 20:2,14

finish 75:21

finished 74:18

fire

6:9,14,15,18,

25

7:1,2,3,13,23

9:15,18,22,24

30:5

31:3,14,16,18

32:1,23 34:5

36:1,2 37:1

fired 49:6

fires 7:4 10:1

firm 59:18

first 5:23

12:5 13:15

15:6,17 48:2

50:17,21

53:21,25

56:20 57:10

64:12 75:14

five 31:13

35:3 82:23

fix 32:19 49:2

fixed 49:4

fixing 60:2

fixture 71:2,4

flag 70:23

flat 83:16

floor

45:3,12,13

46:2 67:14

71:8 75:7

83:16

floors 67:14

75:8

Florida

1:1,20,25

2:4,9

86:2,6,21

87:2,7,15

88:3

focus 58:10

following 89:2

follows 5:24

follow-up

13:24 82:22

footage 78:18

foregoing 86:8

form 7:16

14:19 22:16

23:14 43:19

47:7,15 48:5

52:24 56:24

63:17 66:12

70:8,13 72:18

74:13 75:11

79:7

formal 9:14

forwarded

88:14

four 38:14

64:25 68:14

Friday 88:11

Friedman 2:3

5:16 14:15,19

15:3 19:22,25

20:5,10,16,19

23:14 25:2

26:3 43:19

47:7,15 48:5

52:24 54:24

55:2 56:24

58:20 63:17

66:4,12

70:8,13

72:18,22

74:13 75:11

79:1,4,7

82:12 85:9

88:2

friend

19:5,6,7,8,10

friendly 18:3

friends 18:24

21:10 23:7

27:21

friend's 28:18

friendship

19:14

21:2,4,11,16

23:3,9

27:16,18,20,2

5

from 12:21

13:12 22:15

23:2,10,17,18

25:22

26:17,19 31:6

38:3 43:16,22

44:2

47:6,10,13,19

50:16,20 51:8

52:11 53:3,10

56:9,19

58:24,25 59:2

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 52 of 74
Adams, Melanie 02-16-2021 Page 10 of 31

73:2 78:18

79:18 84:25

front 11:8,10

froze 20:13

frozen 20:11

fulfilling

32:12

full 6:4 10:11

49:20

function 30:22

functioning

48:19,20 53:6

further

50:8,15 57:19

85:7 86:10

88:12

G

garage 41:1

gave 14:6

35:14,16

45:6,8 57:20

64:11 88:8

GC 16:12 48:11

65:2,8

general 10:23

11:1 12:10,15

13:4 15:23

16:3,7,8,10,1

7 18:23 21:24

22:1,4 23:4

30:20

43:15,23

54:15 56:16

61:2 64:18,21

67:21

generally

67:17,18

gentleman

79:25

get 14:4,10

27:11 40:22

42:25 43:7,16

44:7,12,17

45:5,7

47:10,13,19

49:3,20 50:2

54:13 57:3

58:24,25

59:21 61:23

62:2 67:7

82:21 83:12

84:12,14,18

getting 43:6

49:19 82:19

GG 87:16

gift 24:22,25

25:9

give 5:20 7:16

9:18 23:1

31:13 37:10

38:12,22 41:1

42:18 44:4

50:21 61:1

63:8,21 64:7

65:4,6 71:16

given 57:4

giving 36:9

43:17 59:2

go 5:15 20:23

21:18 23:20

24:13,14,15

31:4 32:3,5,9

34:25 35:12

39:22 46:11

52:19 55:3,23

57:18

58:18,20

62:20 64:13

71:16,21

75:9,11,20

76:13 82:2,14

goals 7:18

going

11:22,24,25

13:23 26:11

27:5 28:18

44:9 53:17

54:12 64:13

74:20 75:17

gone 7:22 58:4

good 27:12,21

58:3

Great 28:12

62:6 65:3

Greg 80:3,10

83:7

groceries

62:20,21

Grove 2:3,4

88:2,3

guess 28:5

34:20 42:17

guessing 11:15

38:15

40:10,20

50:10

guesstimate

42:25

gut 27:6

guy 45:3 49:1

guys 14:10

15:6 44:3

H

had 11:18

12:11

16:2,9,10

17:10,22

18:12,21

21:20,21 23:3

25:5 26:5

27:12,18

29:5,12 31:10

34:14 35:13

36:1 41:14,25

42:9 44:22

45:22 47:25

48:23 51:23

53:8 54:23

55:9,23 57:4

59:11,14

61:18 63:1

65:24 66:15

69:3,25

70:9,25

71:2,3,6,7,10

,12 76:21,24

77:1,2,8,11

78:22 79:25

81:19 82:4,15

84:11 85:4

hadn't 58:3

hand 86:16

87:9

hands 61:21

handy 59:14

handyman 47:20

59:14

hang 71:2,4

happen 12:5

33:7 44:5

54:19

happened

12:17,19

13:1,6,10,16,

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 53 of 74
Adams, Melanie 02-16-2021 Page 11 of 31

22 14:1,21,22

15:5,10 16:23

41:17 48:24

78:6 79:19,21

happening

19:21

happy 48:15

57:4,19 64:12

hard 10:11

has 27:4 31:25

54:15

59:17,18,19

71:25 77:19

85:12 88:13

have 6:11

7:7,25 8:2

9:5,7,14

10:15,21

12:25

13:23,25

17:23

18:15,18,25

20:6,13 22:11

24:3,4,17

27:3 28:24

29:1,4,15,22

30:10,11

31:1,12 32:24

33:1,6,20

34:6 36:1

37:4,10,20,21

38:16 40:6

41:4,6,8,10,1

2,15 42:17,21

43:16

44:15,19,20

52:19

54:3,4,7

55:23 57:13

58:4 59:11,14

62:2 63:9,24

65:4,5,6,17,2

1

66:1,6,8,16,1

8 67:21

68:16,18,23

69:2,3,15

70:6,11,14,19

71:8 74:6,8

76:3,12,17,23

77:4,6,10

78:4,8,9,17

79:19 80:6,8

81:15,17 82:9

83:9 84:14,15

85:7

haven't 79:17

having 5:23

25:3,11,20

26:1,9 35:19

36:16 56:15

72:17,21

76:19

hazards 32:1

he 26:6

27:4,6,8,9,10

,11 41:24

49:1,5

56:7,8,9

80:12,13

83:10,12

84:17,20,25

85:2,4

head 49:23

51:4,5 52:6,7

58:12

66:22,23

81:15,18 82:1

hear 18:10

20:11,15 62:1

heard 28:10,11

heavy 18:5,8

85:4

held 53:9,11

Hello 6:3

helmets 39:12

help 31:7

32:15,19,20

36:18,20 37:2

39:10 81:2

83:10,12

84:12

helped 84:18

helping 39:9

43:12

her 1:9 5:9

10:11,12,15,1

6,21,22,24,25

11:2,7,8,10,1

7

12:3,5,8,13,2

0,22

13:3,10,24,25

14:4,6,7,9,13

,18

15:6,8,13,20

16:9,10,17,25

17:2 18:18

19:3,10,14

20:1,2,5,6

21:6,9,17,18,

22

22:8,16,18,19

23:3,4,11,13,

17,20

24:8,19,21,24

25:3,6,7,15,1

8,22 26:13

27:14,18

28:14,15,16,1

8,21 43:13,17

44:3

45:15,16,17,1

9,22 46:4,21

47:10,14

48:12,23,25

49:1,6

54:16,22

55:20,21

56:25 58:3,6

61:21,23

62:2,4,5,7,9,

13,15,16,17,1

8,22

63:2,7,11,15

64:3,5,6,7,8

65:2 66:16,19

67:7

72:5,6,7,9

73:7,14,17,19

81:17 82:2,4

85:2 88:4

hereby 86:6

88:21

herself 10:23

16:3 48:6,7,9

he's 56:10

HIALEAH 2:9

high 9:16

57:11 64:13

HILLSBOROUGH

86:3 87:3

him 25:9

26:7,9 41:25

45:24 49:6

80:6,15 81:1

83:9

hire 63:21

74:7,8

hired 13:3,10

16:9 18:23

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 54 of 74
Adams, Melanie 02-16-2021 Page 12 of 31

61:23

62:2,4,5,7,9

63:24

64:1,3,5

hiring 59:9

61:15 64:8

75:23

his 27:5 41:2

54:17 56:4,6

80:3,5,8

hit 28:15

49:22 80:20

82:5

hold 19:15

holding 53:7

home 72:14

79:23

honestly 80:20

81:14

horrified

79:11 80:23

Horses 24:9

hospital 81:6

82:14,18

house 10:24

11:3,5,10,13,

19,25

12:1,14,16

13:2,14,23

15:14,18,21

16:1,11,13,20

,21

17:4,7,10,15,

20,22,23 20:4

21:22 41:4

44:23,24

59:12,15

61:18 65:23

66:10

71:17,21

72:5,6,8,9

73:7,15 74:4

75:2,24

76:1,14

77:7,10,14,19

79:20

80:12,20

I

I'd 6:6

13:1,12 28:9

36:9 55:16

57:13

idea 13:23

20:7 24:3,4

37:10 38:16

ignore 54:9,10

I'll 10:10

23:1 30:17

55:13 57:1

65:25 74:7

I'm 5:15,16

6:9,15,17,18,

23 7:13,14

9:7 12:11,21

13:7,9,16,25

14:21

15:11,25

16:13 18:3

19:9,19

20:2,18

21:16,17

22:2,21 23:16

24:23 25:7

26:11,14

27:17 28:10

30:1,19 31:6

32:25

33:14,16

34:17,19

36:4,11,13,23

38:13,19,22

40:20 41:9

42:5 43:22

45:16 48:3

49:19

50:4,6,12,22

53:17,23

54:9,12,20,21

55:1,7

57:15,21

59:5,7,9,25

60:9,15,20,22

62:25 63:10

64:5 66:7,8

67:3,14 68:2

69:6,23 72:25

73:2,5,21

74:21 75:16

76:16 78:8,19

79:12 80:17

81:9 82:15,16

83:3 84:13

imagine 15:16

34:13

immediately

48:14 49:24

82:24

impressive

12:10

17:13,14

incident 8:17

22:10,14

49:13 67:6

78:1,2,5

79:16,21

84:21

incredible

82:24

indeed 16:12

independent

56:10

INDEX 3:1 4:1

indicated

18:16

indication

51:23

indirectly

33:17

individually

1:8 5:9 88:4

information

16:14 21:5,14

28:21

37:11,14,16

46:13 88:12

initial 42:2

injuries

66:20,21,22

injury 52:5,7

66:22,23

inside 75:25

inspect 69:1

inspector 8:5

56:3,5,10

79:18

inspectors

32:5,12 34:2

install 55:24

61:8 66:10

75:8,9,22

77:18

installation

41:16 42:6,8

53:2,3 66:11

67:11,14

74:3,23

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 55 of 74
Adams, Melanie 02-16-2021 Page 13 of 31

76:4,7 79:16

installations

42:15

installed

32:13 33:8

41:18,19,20,2

3 42:20 43:7

44:19

48:13,15

51:25

52:12,13,15,1

8,22 53:11

55:25 56:2

62:2 69:25

71:8,11

72:6,13

73:3,7,23,25

75:2 77:19

78:13

installer

45:13 75:22

76:10

installers

52:23

installing

60:3,5,12,21

61:5,10 66:2

73:15 75:6,7

instance 9:24

37:23

instead 43:16

insurance

46:24 56:15

insured

34:15,24

46:18,22

54:17 65:23

66:3,16

intent 37:3

intention

56:17

interest 11:18

interested

12:14 15:18

16:13,20

86:14

International

8:14

interpret

32:20 36:20

37:2

into 12:20

28:6 39:13

54:13

introduce 5:14

11:17

introduced

10:23 11:8

12:6,7,9,13

13:17

48:6,7,8

introducing

14:4

investigate

66:9 72:16,21

78:15

investigating

65:22 66:2

invite 24:15

invited 24:17

involved 33:10

39:5 47:14

59:21

61:10,15

69:12 84:21

Isle 2:3 88:2

issue 26:5

32:15,17

79:25

issues 39:9

it's 7:3

10:3,4,11

14:11 22:23

26:14,19

31:1,2 32:7

37:25 40:6

44:7 46:1

53:14 54:8

55:20,21

63:15,20

69:11 73:5

84:11

I've 7:25

29:10 30:6

58:17 63:24

69:11

J

January

22:14,15

23:2,11,18

job 8:3 29:2

30:12,13,14

32:13 34:7

37:5 40:1

42:3 56:19

57:7 58:8

59:21

66:17,18

67:20 68:3,11

jobs 57:8 58:9

63:22

John 56:6

just 7:16 10:4

12:5,19 13:9

15:11 16:17

18:1,12

20:8,19 21:11

23:15 26:24

27:8,18 29:19

30:2,19 31:3

32:7,8 34:19

38:12 42:24

43:17 48:3

50:2,12 51:21

52:11 55:13

56:2 59:19

61:17 63:6,9

64:6 65:13

67:8 71:16

73:17 74:6

75:8 77:20

84:5

K

keep 27:6

keeping 27:10

keys 41:1

kind 9:21

10:7,14,20

25:24 26:1

27:17 52:5

68:18,22

kitchen

41:8,10,12,14

43:14 49:16

51:1 62:9

65:18,20

71:15 72:5

76:22,23,25

77:1,18,22

78:5,13

know 6:7 7:8

8:23 10:12

11:13,20

12:19,23

13:1,12,16,22

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 56 of 74
Adams, Melanie 02-16-2021 Page 14 of 31

15:7 16:24

17:14 18:4

19:19,25

20:3,7,8,21

21:4,8,17,20

24:18 25:18

29:14 30:20

31:11 34:15

35:14,15

36:19 37:24

39:12 40:13

41:18 43:3,20

46:14 47:4

48:8,14,23,25

49:9 50:24,25

51:14,24

53:18 54:22

55:13,16

56:1,8 57:25

60:2,17

63:11,14,18,1

9 64:2,4

65:25 67:21

68:25

69:16,18,20,2

3 70:23 71:10

72:8 73:6

74:3,7

75:4,6,7,9,21

,22 77:9,24

80:14 81:14

82:16

83:21,22

84:1,12

knowingly

56:13

known 74:6,8

L

laborers 59:22

laceration

81:17

lacerations

81:15

large 49:21

84:9

larger 17:23

last 68:14

late 28:19

later 17:8

law 2:8

60:17,23

lawsuit 12:22

14:13,17

55:17

laying

83:16,18

learn 55:23

learning 10:1

67:5

least 35:3

leave 20:20

left 82:18

leg 83:25

legs 84:5

less 7:9 8:8,9

52:13

lesser 31:2

let's 22:23

31:16 32:11

35:9 41:16

47:13 49:12

56:11,20

58:10 67:20

74:5

letter 88:16

license 46:24

licensed

34:8,15,24

46:18,22

54:17 55:22

56:15,17

65:23 66:3,16

lied 64:19

lieutenant 8:4

Life 30:25

36:8

lift 85:5

lifted 85:2

light 71:2,4

LINE 89:3

list 27:4

little 46:12

47:6 50:14

51:17 59:16

live 9:12

living 6:8

located 5:12

location 72:8

log 20:13

long 6:11 7:7

8:15 35:7

42:15 69:2,11

81:14 82:22

longer 49:6

look 20:1

42:21

44:15,16

52:19 57:13

73:6 74:5

78:22

looked 75:25

looking 13:8

21:15 27:8

51:10,12,13,1

9 79:10 80:21

loose 51:24

lost 27:11

lot 7:14 9:23

36:22,24,25

37:1 79:2

81:21

lower 63:9

lunch 21:20,21

lying 27:9

M

ma'am 30:14

60:18

Madam 55:5

made 11:16

17:21 56:14

61:17 64:16

84:10

mail 26:13,22

main 26:24

27:1,6,11

make 20:2 34:5

54:16 55:21

63:16 74:4

88:10 89:2

making 61:16

62:25

man 41:24

manage 6:25

managing 7:12

many 7:5 8:4

21:14 27:12

29:6,13,16,20

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 57 of 74
Adams, Melanie 02-16-2021 Page 15 of 31

30:6 34:25

37:7,18 38:12

40:4,5 44:11

69:3

March 86:16

87:9 88:1

mark 28:5,9

marked 28:6

married 9:6

Match.com

28:22,24

matter 5:6,8

88:8

may 18:15

22:11 32:1

36:1 65:17

70:19

88:9,11,14

maybe 8:16

40:19 53:18

70:23 75:6

81:1

McNally 56:6

me 5:20 7:16

9:3 10:11

11:6

12:7,11,24

13:2,10,25

14:21,23

15:9,12 16:13

18:23 19:7,15

20:1,15 22:5

26:6,19

27:6,22 29:8

30:2,17

31:7,13 35:12

36:9,24

38:12,22

41:17 42:5,18

43:22 44:21

45:6,8,22,24

48:8 49:5

52:21 53:18

56:12 57:5,20

58:9,22,23

60:16 61:13

64:11 65:6

70:9,21 71:16

72:5 74:1

75:14

79:13,16

81:25 82:2

83:12,13,19,2

1 84:18 85:9

87:6

mean 6:20 9:22

13:22 15:6

19:24 20:4,7

21:13,19

25:25 37:1

38:13 48:21

49:19 50:18

69:9 74:6

85:4

means 6:21

81:9

medical 9:22

10:2,6,7,8

meet 11:7 15:7

35:23 36:5,13

meeting 12:21

35:17 47:25

Meghan 1:24

5:13 55:10

86:5,21

87:5,15 88:19

Melanie 1:8,16

3:2

5:1,5,9,18,22

6:5 14:15

15:3 20:10,11

26:17 58:21

87:6

88:1,4,23

men 41:25 42:7

mention 73:17

mentioned

29:12

met 10:24

11:2,8,10

12:11 13:11

14:9 15:6

16:4,10

22:8,18,19

23:4 35:22

48:2

Miami 1:2 8:14

9:13

Miami-Dade 7:1

middle 10:18

might 34:14

79:13,15

Mimi 1:6,12

5:7,10

10:10,11,12

43:2,3,10

44:21

45:2,10,12,15

,16 46:21

47:3,21,25

48:23 61:8

70:3 74:10,22

75:13,19

88:4,5

Mimi's 45:2

53:14

mind 56:12

minor 1:9 5:10

88:4

misleading

60:10

misrepresented

56:14 64:19

misstates

56:24

Mitchell

80:3,4,10

84:15

Mitchell's

83:7

mitigate 9:4

Monday 88:11

months 67:7

82:23

more 12:18

20:24 29:22

35:20 36:11

40:21 51:17

52:13 55:10

59:17 64:25

70:12

71:19,23

79:14 82:5

Move 58:20

moving 79:5

much 6:25

44:14 63:16

multiple 30:23

58:14,16

64:24

my 9:3 11:1,18

12:11,14

13:14 15:14

17:12 19:8,16

27:1,3,6

30:13

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 58 of 74
Adams, Melanie 02-16-2021 Page 16 of 31

34:21,23

37:16,17,25

39:23 41:14

42:21,24

43:13,21

44:24

46:11,25

49:16,22

52:19 54:8,12

55:19 57:22

60:14 61:18

62:5,7,9 63:5

65:4,18,19,25

66:14,22,23

73:12 75:2

76:13,23

77:1,19

79:10,24

80:21,22

82:1,18,25

83:13 86:9,16

87:9 88:21

myself 11:9

12:6,9,13

N

name 6:4 9:8

10:11 43:5

56:6 80:2,3

88:15

named 41:24

nature 7:20

neat 21:23

necessary 88:9

neck 52:7

66:22,23

need 14:24

20:24 25:22

30:19 59:1

61:6 75:22

needed 16:16

36:13 43:13

45:23 57:3,18

70:19,21,25

needs 24:22,24

25:4

negligently

55:25 56:2

neighborhood

27:7

neighbor's

75:24 76:1

neurological

66:24

neurologists

83:2

never 7:22,25

12:11 79:19

new 31:9 34:13

43:2,5 71:15

next 10:25

11:3,5,11,14,

20,23

13:1,2,6,7,10

,16,22

14:2,21,22

15:6,10,12,19

16:11,20,21,2

4 17:5,7,20

18:2 48:11

72:4 76:14

Nguyen 1:6,12

5:7,10 10:12

17:21,25

18:22 21:2

25:10 26:8,18

40:16 41:1

42:1,7 43:2

46:7 47:5,9

48:2 52:23

55:17 60:1

65:7 76:4

78:20 88:4,5

Nguyen's 54:14

71:17

nine 56:11

64:15,16

no 1:3 5:16

7:21 8:8 9:1

13:16,23,25

14:15 15:3,11

16:2 17:6

18:23 19:9

20:3,6 22:5

23:4 24:3,4

25:5,9,19

26:24 27:20

29:19 30:18

32:5 33:12,22

34:1,3,9,15

37:10,13,14,1

6 38:7,9,16

43:24,25 44:5

46:25 47:1,22

48:17 49:5

50:4 51:9,12

52:1,14 56:22

57:17 58:5

59:13 60:15

61:9,22 62:25

65:25

66:13,18

67:5,21

68:13,15

69:15

70:9,18,21,22

,24 71:10,14

74:16,21

76:15,24

77:19,25 80:1

81:11,16

82:24 85:7,9

87:16 88:6

89:3

nor 86:12,13

normal 37:25

49:11

63:20,23

64:6,9 73:5

north 11:6

not 7:13 10:3

12:24 13:7

14:20,21,22,2

3 15:10,11

16:8 18:12,17

19:6,11,21

20:2 22:4,21

24:17 27:7

28:10 29:16

30:1 31:6

32:12,13

33:3,15,18

34:23 35:21

36:11

37:10,24,25

38:1,13 42:12

44:1 49:5,19

50:12 51:24

53:8 54:8,20

57:22 58:25

59:2,24

61:12,17

62:19,23,25

63:24 64:5,12

66:7,16,18

68:2 70:4,7

72:16,20

73:6,12,13,18

,25 74:18

75:3 77:2

78:3,13,16

80:9,25 81:9

82:16 83:6

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 59 of 74
Adams, Melanie 02-16-2021 Page 17 of 31

86:10 88:9,13

Notary 1:25

86:5,21 87:15

notes 54:8

86:9

nothing 58:2

60:18

notice 88:8

now 28:2 31:1

38:3 66:25

67:3 73:11

88:9

number 5:8,11

14:4,6,7

37:10 46:24

64:15 80:5,6

88:11

numbers 14:5

38:1

O

OATH 87:1

Object 14:19

23:14 43:19

47:7,15 48:5

52:24 56:24

63:17 66:12

70:13 72:18

74:13 75:11

79:7

objecting

19:19

objection 25:2

26:3 54:24

58:20 66:4

70:8 72:22

79:1 82:12

obtain 56:19

57:2

obvious 18:10

obviously

26:19 33:2,19

occur 22:10

occurred 8:18

15:12 22:14

49:13 79:21

off 20:13,19

27:4 49:22

50:16,17 53:8

69:10

83:13,15

84:12,14,16,1

8,25

offer 48:1

offered 43:14

office 20:5,6

26:25 27:1,6

37:11,15,17

88:11

officer 30:24

36:7 37:23

39:8

often 24:13

40:16 64:20

Oh 20:6 67:5

okay 6:11,20

7:5,7,10

8:2,6,9

9:5,16

10:9,14,20

11:2,7,13

12:25 13:6,21

14:3,6,16

15:15

16:21,23

17:4,7,9

18:18

19:2,13,18

20:14,18,21

21:1,5,8,12

22:6,10,13,23

,25 23:6,20

24:1,6,8,15,1

9,21 25:7,10

26:21 28:2,12

29:8,19

30:8,16,19

31:17,22,25

33:6,10

34:4,7,10,12

35:9,20 36:24

37:4,14,22

38:12,16,21

39:1,6 40:22

41:16,22

42:1,20,23

43:6,9,21

44:11,16

45:1,7,9,21

46:20

48:2,13,14,24

49:3,7,9,14,1

8,24 50:2,8

51:13,17,21

52:2,8

53:14,18

54:11

55:4,17,18

56:11 57:12

58:11,14,16

59:25 61:4,13

62:1,6 63:5

64:19

67:13,16

68:22 70:5,18

71:8,25

73:14,20,22

74:24 75:1,4

77:4,24

79:7,20 80:2

84:10,19

old 9:10

on 1:8,17

2:2,6

5:9,17,19

7:17 11:18,22

12:14 13:14

15:14 19:15

20:14 21:22

23:8 26:11

28:22 29:6

30:2 31:9,11

32:17 35:15

37:14,16,20,2

1,25

39:3,15,22,23

42:3,6,9,10

44:9 45:1,23

46:13 48:11

49:17,19,21

51:4,5,6

52:5,11

54:8,10,18

56:2,8 57:7

58:7,10,12,14

,16 60:25

61:21 63:22

65:1,2,12,19

66:6,10

67:11,19

68:23 69:10

72:24 73:12

75:15,18

78:10,22 79:5

81:15,17,24,2

5 82:1

83:16,19,21,2

4,25

84:3,4,5,9,11

87:8 88:4,8

once 40:19

64:23

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 60 of 74
Adams, Melanie 02-16-2021 Page 18 of 31

71:19,23

one 5:20 9:7

11:24 12:23

19:15

29:10,15

30:9,10 35:14

37:9 38:14

40:2 41:14

55:10

57:11,12

59:17,19 60:4

63:1,9 65:1

69:5,7 71:16

77:19,23 82:4

ones 39:20

ongoing 11:22

82:15

online 67:5

only 9:15

11:24 12:23

14:3 18:21

23:11 29:10

47:10 58:6

onto 58:4 82:2

Opa-Locka

40:15

open-ended

14:25

operations

35:15

opinion 63:20

66:6,8

opportunity

27:8

Order 1:20

87:7

ordering 88:14

original 88:13

other 11:25

16:5 21:11

24:10 30:11

33:17 37:4

39:20

43:16,23

44:8,10,19,20

,21 47:20

48:10 56:22

57:2,3,17

72:13 79:12

others 37:21

40:21

otherwise

70:10

our 18:25

31:10 75:22

88:11

out 6:24 10:1

11:25 12:1

14:1 18:1

21:16,17,18

27:6 34:19

37:18 44:1

46:10 49:2

50:8,11,14

59:25 62:24

71:7 81:1

84:12 85:2

over 6:15,18

18:6,24 19:15

35:12 56:3

71:11 79:10

82:4 83:25

overnight

81:10,12,13

oversee 7:5

32:5 34:4

overseeing 7:8

61:16

overview 7:16

own

39:16,22,23

43:17 79:10

88:10

owners

17:11,23

P

P.L 2:8

p.m 1:18 85:10

page 3:2 4:2

52:11 89:3

paid 45:23

46:14 52:22

62:16,22 63:6

67:16,17

pain 82:25

paint 62:5

painter 45:3

paperwork

42:22,23

65:2,3

paragraph

56:11 64:15

part 7:13 8:3

15:16

30:12,13 34:7

37:5 40:1

59:8,21 65:15

67:20 68:3,21

particular

31:20 33:4

58:8

parties 1:19

43:16,23

86:11,12

partly 60:5

parts 84:8

past 51:24

72:1 73:24

74:1

patients 10:2

pay

45:9,10,12,13

,15,19,22,24

46:6,7

62:13,14,18,2

1 63:2

67:8,10,13

payments 59:22

people 7:5

11:25 12:2

24:10,15,17

33:24 34:23

48:1 65:22

per 60:23

percent 66:18

Perfect 62:11

period 54:23

55:9,11

permit 69:16

permits

33:6,11

68:9,12,16,19

,24 69:2,3

70:1,16

person 12:5

18:3

59:17,18,19

61:19 66:2

72:13

73:3,15,23,25

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 61 of 74
Adams, Melanie 02-16-2021 Page 19 of 31

74:9 84:20

personal

21:5,13

28:1,3 73:12

personnel 27:3

phone 40:17

80:5

phonetic 41:24

Phuong 1:6,12

5:6,10 10:12

88:4,5

physically

62:23

pick 41:2 63:9

picture 27:5

49:20

pictures 82:7

pilot 9:3

Plaintiff 1:10

2:2 64:20

plaintiffs

5:17

56:15,18,19,2

1 57:23

Plaintiff's

53:25

plan 39:10

plane 80:20

please 5:14

6:3 19:2,13

31:7 48:8

49:15 57:17

65:11 75:17

88:8

plug 77:20,21

plumber

45:2,5,9,10

plumbing 46:2

71:6

PM 88:11

point 10:9

13:12,13 14:3

18:13 19:11

23:6,8

24:21,24

28:14,15

32:14 39:18

40:2,3,22,25

41:14

47:12,19 51:5

58:7 66:13

68:12 69:8

70:18

76:21,25

77:1,23,24

police 26:6

position 8:23

31:1 39:3,5

51:14

present 32:2

79:20,23

80:10

pretty 6:25

prevent 7:4

prevention

6:16,18,25

7:2

previous

17:10,11,22

73:2,6

price

57:4,6,19

58:3

prior 8:6,22

74:5,23

75:1,14,23

probably 34:13

35:6

problem

25:11,15 26:9

problems

25:20,24 26:1

35:18 36:16

proceedings

86:8

professional

18:22 23:15

profile

28:22,24

project 31:9

35:7 48:11

promptly 88:16

pronounce 6:4

10:12

properly 51:24

53:6

property 31:10

protect 31:20

protected

31:24

protection

30:6

31:15,16,19

provide 46:13

65:7

provided 65:7

Public 1:25

86:5,21 87:15

pulled 33:7

70:2 85:2

pulling 33:10

purchase 74:5

purchasing

15:18

purple

74:17,20

purpose 15:1

29:24 31:18

56:17

pursuant 1:20

87:7

put 10:1 27:5

53:10 56:4

62:24 65:2

71:11

putting 71:15

Q

question 6:22

7:14 12:25

14:15,20,23

15:4 30:1,20

34:16,18

36:12 47:17

53:16 54:12

55:4,6,12,19

57:22 59:4,10

60:8,11 62:19

63:5 65:25

66:6 70:18

72:19

73:18,20,21

75:17 79:5

82:17,18

84:23

questioning

17:12

questions 6:6

14:25 15:1,20

36:1 85:8,9

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 62 of 74
Adams, Melanie 02-16-2021 Page 20 of 31

quote 43:8,11

47:13,19

57:10 64:12

65:7,9,12

66:10

quotes 40:22

43:7,12,16,22

44:2,4,8,11

47:6,10 58:22

63:8,22

64:7,11 65:2

R

radio 9:3

raise 70:22

random 24:15

randomly 48:3

51:21

rather 16:17

RE 1:5 88:4

reach 44:1

reaction

80:15,18,22

83:7

read 26:21

32:20 54:3

55:5,6 56:11

88:13

reading 32:22

56:12 85:11

ready 20:23

really 14:24

26:19 30:19

61:6

reason 16:2,20

18:2 29:12

34:14 47:24

89:5,7,9,11,1

3,15,17,19,21

,23

reasons 30:6

54:18 89:2

recall 8:19

10:19

14:2,4,8,11,1

8 15:7,10

17:3,19

18:17,20

22:12,18

23:19,25

24:2,12

25:1,3,5,9,17

,19,23

26:10,12,18,2

0 27:24

28:17,18,20

35:2,21 37:8

38:5,19,23

39:1,21 40:18

41:3,7,15

42:14,17,21,2

2 44:13,14

45:11,14,20,2

5 46:9 48:10

52:16,17 54:6

56:9 57:13

59:20 64:22

65:1,9 69:4,8

71:20

72:11,15

73:4,9,10,12,

16,22 75:3

76:2,5,8,9

77:12

78:3,14,21

79:3,9,10,13

81:25 82:8

83:6

84:2,3,4,5,8

receive 47:2

received 40:23

reconnect 27:8

record 28:6

86:9

records 46:11

52:20 76:13

red 70:22

redo 43:13

reference

57:15

referring 11:4

45:16

72:24,25

regard 46:14

68:5,6,10

70:15 76:4,7

regarding

79:16

regards

68:11,20

regular 40:1

related 73:19

relation

27:22,24 29:2

relationship

10:10,14,16,2

0,21 12:20

15:8 18:22

19:1,2,5,10

22:17 28:15

67:22

relative

86:10,12

relevance 25:2

26:3

relied 56:14

remain 54:19

remember 21:21

22:22

28:20,21,23,2

5 35:17 40:10

41:11,22

42:3,12

43:3,4

52:12,15

65:1,12,13

76:6,11,19

78:24,25

80:25 81:3,13

82:11,22

83:5,18 84:17

85:3

remotely 1:19

2:5,10 5:12

87:6

remotes 27:3

removed 84:25

renovating

12:16 13:2

44:25

renovation

11:22 45:2

renovations

12:1,4 13:4

repairing

44:22,25 60:2

repeat 34:18

47:17 55:4

60:11 72:19

rephrase 55:14

73:20

reply 5:6

report 56:4

86:7

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 63 of 74
Adams, Melanie 02-16-2021 Page 21 of 31

REPORTED 1:24

Reporter 1:24

5:3,12

28:7,8,11

55:6,7

86:1,5,21

87:15 88:19

Reporting 5:13

88:19

represented

57:10

representing

16:3

require

31:22,23

required 31:4

69:20 70:4,7

requirement

10:4

research 21:25

22:3 34:8,23

68:3,6,8,12

reserved 85:12

residency 27:4

residential

68:2 69:15

70:12

resolve 32:15

39:9

respond 8:24

responding

49:6

responsibiliti

es 7:11

responsibility

7:15 54:16

55:21 61:3

63:1 65:21

66:1,8

responsible

60:2,5,12,20,

23,24 61:4

63:6

result 12:22

48:16

resulted 17:24

retained 61:19

return 88:16

Ricardo 2:7

3:3 5:15,19

88:23

ricardo@rdgzla

w.com 2:10

ride 24:7

right 11:5

17:24 18:12

20:10 23:6,7

29:17

32:11,19,24

36:24 44:4

45:18,23

48:14 51:5

53:9 54:20

58:19 59:3

60:3 62:14

64:15 71:9

74:24 77:21

78:19 80:15

81:1 83:1

85:7

rip 50:16

rodeo

23:20,22,24

24:1,3,4,14,1

6,19

rodeos 24:13

Rodriguez

2:7,8 3:3

5:15,19 6:2

14:17,24 15:5

19:19,23

20:3,6,17,23

21:1 23:15

25:3 26:8

28:7,9,12,13

43:21 47:9,18

48:7 52:25

55:5,13 57:1

58:23 63:19

66:7,15

70:11,14

72:20,23

74:14 75:16

79:6 82:13

85:7 88:23

Rodriquez

79:2,8

room 81:7

S

sad 27:12

safe 54:19

55:23

Safety 30:25

36:8

said

12:9,10,14

13:10 14:21

15:17,21

16:9,10,12,13

,15 17:12

18:25 22:19

27:11,15 28:4

30:22 35:22

36:7 46:22

47:24 48:3,12

50:10 54:5

56:2 57:18

58:17 61:12

63:6,24

64:11,16,18

69:15 70:3

73:3,8,22

75:1 76:21,24

79:18

sake 32:11

sale 10:25

same 30:25

32:7 42:13

52:4,11 72:22

84:22,24

saw 17:17

72:4,7,9

73:2,7,17

75:24

say 17:16 23:8

28:13 33:16

35:3,9 37:16

39:25 43:10

44:5 45:16

47:13

55:1,2,3

60:18 62:22

66:13 67:20

74:5 75:8

76:16 81:10

83:15

saying 23:12

32:8 59:6

60:10

61:14,23

63:1,16 73:11

says

26:17,21,24

53:24 57:22

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 64 of 74
Adams, Melanie 02-16-2021 Page 22 of 31

60:17 65:7

schedule

37:15,17 49:2

school 9:16

55:23

67:2,6,7

scratches

81:19

scream 80:24

screamed 80:25

screen 26:12

second 5:20

19:15

57:11,12

71:16

security 27:2

see

17:4,7,13,20,

24 18:15

26:12 27:12

50:22 53:19

54:2 69:9

70:1 71:25

72:3,5,12

74:24,25

78:6,17 80:13

seeing 27:7

83:2

seem 84:10

seen 18:13

send 16:13

27:14

sending

26:12,18,20

27:2

sent 26:16

sequencing

14:22

service

9:15,19 40:23

54:1 77:13

several 12:2

42:8 57:7

58:9 67:12,20

share

21:5,8,13

shared 22:16

sharing 28:21

she 9:10,11

10:23

11:20,24

12:9,14,15

13:2,10,11,14

,17,18,23

14:6

15:17,21,24

16:2,6,7,8,12

,15,17 18:23

19:5,6,7,10

21:23,25

22:3,5 25:5

42:2,3,9,10,1

3

43:12,14,16,2

3 44:1,3,4,7

45:6,8,22,24

46:1,4 47:25

48:2,6,7,8,11

49:1,5,6 52:4

56:23

57:4,7,10,16,

19 58:9,22,23

59:1,6,7,9

60:1

61:10,15,18,1

9,22 62:23

63:1,8,9,16

64:11,12,13,1

6,18,20,23

65:2,17,18

66:15

67:2,3,6

71:21,25 72:4

78:22 81:19

82:4,5

SHEET 89:1

shell 39:12

she's 20:5

59:1,2,6 60:4

63:6 65:8

67:1,5

should 19:20

43:10 79:19

show 9:3 13:25

26:11 53:17

74:1

showed 73:23

shutting 48:22

side 82:4

sign 69:10

88:9,13,15

signature

88:9,15,21

89:25

signed 76:12

significant

78:25

signing 76:6,9

85:11

similar 31:1

75:2

since 6:13 8:7

40:6 62:4

69:11 84:20

single 9:7

42:10,12,14

sink 71:7

sir 39:4

site 7:22,25

8:1,3 18:11

29:2,6,11,13,

15,21

30:4,7,8,9,10

,21 31:5,8

34:22 35:1,13

36:15 39:20

40:9 42:9,11

45:23

69:1,10,14

sites 7:19

29:9,16 30:11

37:5,19

38:3,17,20,24

39:2,7,13,15,

17,19 40:1,7

67:20 68:4,7

situation

39:24 84:24

some 7:16

11:18 12:14

15:20 16:14

19:11 20:24

22:16 23:6,8

29:12 35:18

36:3 37:20

41:25 48:22

52:10 54:7

66:20 75:9

76:21,25 77:1

somebody 20:8

34:13 49:2

71:2

someone 27:7

34:12

39:22,23

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 65 of 74
Adams, Melanie 02-16-2021 Page 23 of 31

56:7,8

58:4,24,25

59:18 67:19

71:4 84:11,14

something

13:25 17:1,17

21:15 54:10

70:23 75:2,6

sometime 10:17

sometimes

39:14 77:17

somewhere

52:22

son 24:22,25

25:4

soon

82:9,13,19,21

83:3

sorry 5:15,16

6:17 12:12

15:25 19:22

22:2 23:16

24:23 25:7

26:14 29:18

32:25 33:14

34:17 40:24

41:9 43:10

50:4,6 53:23

54:9 55:1

67:3,14 69:6

76:16 79:12

80:17

south 49:21

SOUTHERN 1:1

Southwest 9:13

speaking 17:2

special

24:21,24 25:4

specific

12:18,25

14:23,25

15:10,11

29:22

30:17,19

36:11 38:14

42:5,6 61:7

79:14

specifically

16:19 41:22

56:13

specifics

14:11

spent 44:14,17

spices 52:10

spoke 15:23

16:24 17:1

21:21 26:24

27:1 40:21

staff 9:3

stalking 26:6

standing 49:24

51:16,19 52:4

start 10:15,16

38:2 82:19

started 10:25

13:5

38:16,19,24

39:21

State 1:25

86:2,6,21

87:2,15

statement

64:17

statements

56:14 64:16

STATES 1:1

stay 81:12

still 82:15

stomach 84:4

stop 15:3

store 49:9

stored 52:9

straight 51:11

STREET 2:8

strike 26:15

40:25 57:1

58:20 74:7

subcontractor

45:23 47:20

65:19

subcontractors

44:2

46:5,15,17

54:16 55:22

56:17 66:3

67:22

subpoenaed

37:12

subs 46:21

SUITE 2:8

supervise 7:19

33:18,20,22,2

4 34:3

supervised

7:25

supervising

61:16

supervision

7:18

supervisor

32:10

support 25:22

supposed 7:14

69:1,10

suppress 31:25

Supreme 1:20

87:7

sure 7:13 13:7

14:21 19:17

20:2 22:21

28:10 34:5

36:11 40:20

54:16 55:21

61:16 81:9

82:16

sustain 52:5

sustained 52:7

swelling 81:22

82:5

sworn 5:24

87:8

T

take 30:5 35:7

42:16 46:12

81:6 82:7

84:15 88:8

taken 1:17 5:6

27:4

talk 16:17

30:5 31:16

41:16 49:12

56:20

talked 21:14

27:25

talking 20:2

58:8 60:22

61:7,21 64:6

Taylor 1:9

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 66 of 74
Adams, Melanie 02-16-2021 Page 24 of 31

5:10,17 9:9

88:5

team 72:8

technician

10:8

tell 12:7

13:10,24

15:12 16:6

19:25 29:8

30:2 35:12

41:17 45:24

61:13

64:20,23 70:9

79:13,16

telling 38:19

tells 27:6

ten 35:5,6,10

tendency

72:16,20

terms 7:10

53:6

terrified 78:7

80:23

testified 5:24

56:22 76:24

84:10

testifying

28:2

testimony

18:21 31:6

38:18,23 44:7

46:1 56:25

59:5 60:4,6

61:1 62:11

74:25 78:12

text 40:17

than 7:9 8:8,9

16:17 17:23

40:21 44:19

47:21 48:10

50:9,15 58:1

59:17 64:25

70:12

71:19,23

79:12 82:5

Thank 25:8

28:12 55:15

that 6:20,21

7:3,7,8,10,12

,20

8:15,17,24

9:24 10:3,24

11:3,16,20,24

12:3,10,13,14

,15,17,23,24

13:3,7,19

14:9,22

15:8,12,16,17

,20,23,24,25

16:2,5,6,8,10

,12,13,15,16,

19

17:1,4,13,16,

17,20,24

18:2,13,15,16

,21,25

21:3,15,21,23

22:19 23:1,12

24:10,11,18

25:5,13

26:6,15,18

27:6,7,10,11

28:3,4,13,14,

15,25

29:4,6,8,13,2

5 30:6

31:1,11,12,20

,22

32:1,5,12,13,

14,16,19

33:7,18,24

34:5,14,16

35:13,15,21

36:18,25

37:11,24

38:17,23

39:5,11,19,20

,25 40:3,7,25

41:1,15,17,19

,25

42:3,12,20

43:8,11,13,14

,20,25

44:7,8,16,17,

21 45:1

46:1,6,25

47:5,14,25

48:3,6,21

49:5,6,13,15,

25 50:8,13,16

51:1,24

52:8,11,12,17

,21,22

53:1,14,15,17

,22

54:2,9,10,14,

15,16,17,18,1

9

55:1,10,11,12

,20,21

56:3,4,7,8,12

,22

57:1,4,6,10,1

6,17,19,22,24

,25

58:1,5,7,12

59:8 60:6

61:12,13,17,1

8,22

63:1,8,16

64:9,11,12,13

,20,25

65:1,4,5,6,11

,15,16,22

66:1,6,9,10,1

7 68:6,14

69:20

70:6,9,22,23

71:14

72:4,5,12

73:5,17,18,22

,25

74:2,4,7,8,18

,25

75:1,2,4,13,1

7,18,21,22

76:12,24

77:24

78:12,17

79:2,4,8,12,1

3,16,25 80:6

82:19

84:5,17,22,25

85:4

86:6,8,10

87:6 88:8,9

that's 13:4

14:20 15:1,2

16:14 18:7

20:2 26:15

29:19

36:21,22,24

45:4 54:20

62:1,11

63:11,23 64:9

65:7 74:25

83:3 84:13

their 13:4

15:23 16:12

27:2 32:12

36:16 62:14

88:11

them 15:23,25

16:16,19 18:3

32:15,20

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 67 of 74
Adams, Melanie 02-16-2021 Page 25 of 31

36:3,18,20

37:2 39:22

41:23 42:1

43:2,3,4

49:22 54:18

63:21 70:1,20

72:10 73:8,15

74:7 75:23

77:20 78:18

83:13

84:12,18

85:2,5

themselves

5:14

then 13:6 23:6

44:5 48:24

49:12,22

53:18 55:22

57:1 58:3

62:13

75:4,9,16

83:13 85:5

there 6:12 8:4

9:2

11:5,22,25

12:2 17:23

18:1,6 24:10

29:5,24,25

30:6,22,23

31:10,11,15,1

8 32:3,5,9,10

33:6 35:10,17

37:16,20

40:20 41:2

42:1,2,7,8,9,

10,13 44:8,10

50:3 56:3,22

57:16

58:2,5,14,16,

17 59:23 60:8

69:8 71:2

78:15 79:15

81:13,14,20

83:19

there's 7:14

9:22 14:15

15:3 29:25

32:18 37:1,14

79:2

Thereupon 5:21

28:6

these 12:4

32:12 33:7

34:8

39:1,7,13,15

41:18 43:6

44:11

46:4,14,17

47:25 51:15

55:24 58:12

68:7 80:21

they 9:18

15:24

16:8,9,12

18:4,5,16

24:6,7 27:5

31:14 32:6,24

33:1

34:3,4,6,14

35:18 36:1,16

39:11

41:19,20

42:9,10,13,20

46:18,21,22

48:15,19

49:19,22

50:10,13,16,2

0

51:4,5,20,21,

24

52:3,12,13,15

,17,21

53:4,6,8,9,10

,11,15

54:17,23

55:9,11,23

56:1 68:25

70:3,7,21,22

71:11,14

74:1,17,19

77:17 78:17

80:15,18

81:6,7

83:4,20

84:4,5,9,13

85:4

they're 27:2

31:14 32:4

35:25 55:22

they've 32:13

34:4 73:24

thing 15:12

32:7 71:11

things 21:14

28:1,3 33:7

58:12 63:6

74:4 79:8

think 12:3

20:5

27:7,15,23

45:4 53:1,14

54:13,15,21

55:8,10,11,19

57:18 60:23

65:21 70:25

71:14 78:7

thirty 88:13

this 5:5 8:17

10:9,12

11:2,3

12:20,22 14:3

15:1 19:20

26:9,12,15

27:2,14

28:5,9 33:4,5

34:25 35:7

36:6 39:18

49:13

53:3,21,25

54:3,7,19

57:21 58:17

61:4 63:25

66:13 68:12

74:8 75:17

77:2 78:5

79:21 82:9

86:16 87:9

88:16

those 29:9

36:2 37:24,25

39:12 52:8

53:4,10 54:18

66:9,10

thought 19:7

21:3,23 25:5

29:12 65:24

80:20

three 38:14

64:25

through 22:15

23:2,10,18

45:2 47:3,21

tile 71:11

time 18:24

19:8 20:24

21:3 28:25

29:7 30:2

31:11 35:14

41:15

42:10,12,13,1

4,18 51:1

52:22

53:10,11

54:23

55:9,10,12

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 68 of 74
Adams, Melanie 02-16-2021 Page 26 of 31

69:8,11 76:12

77:2,8 79:24

80:3 88:9

times 21:19,20

27:13

29:6,14,16,20

,25 30:23

34:25 35:3,10

37:18 40:21

64:24

title 53:24

titled 53:21

today 18:21

38:18,23 46:1

Today's 5:3

together 23:21

83:13

told 11:15

12:13 13:2,17

15:23 22:5

27:21 43:13

49:5 63:9

66:15

70:20,21,22

took 23:8 67:7

70:5 72:5

81:7 88:10

top

50:15,17,20

51:6 82:1

83:16,19,21

84:4,5,11

torso 83:25

tour 30:5

35:14,15

tours 31:14

towards 82:5

trades 68:25

69:9

training

9:18,21,23

transcribe

86:7

transcript

86:8 88:23

trauma 81:7

traumatic 83:5

treat 10:2

treatment

82:15,16,20

trucks 8:24

true 86:9

truly 88:18

trust 47:9

trusted 47:5

74:10

try 21:25 22:3

42:24 47:12

trying 6:23

12:21 13:9,25

21:16,17

27:17 34:19

35:25 36:4

42:6 50:22

59:5,7,10,25

62:23 73:5

Tupperware

49:11 52:10

turn 20:19

turning 28:15

two 8:16 35:10

38:3,14 58:22

67:7 69:5,7

type 31:25

33:7 71:11

typically 20:7

24:17

33:15,22

U

Um-hum 51:7

60:19

unconscious

79:10 80:22

under 79:11

80:21

undergoing

82:15

undermine

63:15

undersigned

87:5

understand

6:21,23 12:21

13:9 27:17

29:20 30:3,18

31:3,7 33:18

36:4 37:2

53:16

59:4,5,8,10

65:16 73:5

understanding

30:1 31:7

43:21 50:2

62:19 67:21

unfortunately

54:7

UNITED 1:1

units 35:14,15

Universal 5:13

88:19

unless 55:3

until 53:3

up 9:3 13:23

27:5

32:4,6,13

41:2 44:15,16

50:15 57:14

83:2 85:2,5

us 20:11,12

49:17 81:7

88:16

usczach@gmail.

com 2:5

use 49:7 77:13

used 53:4

using 33:17

usually 21:20

74:2 75:5

V

value 70:5

vans 18:15

veneer 71:11

verbally 56:13

verification

46:23

via 2:5,10

88:23

video 19:20,23

20:19

41:4,6,8,10,1

2,14,15 77:6

videotaped

5:1,5

violation

32:18

visit 29:1

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 69 of 74
Adams, Melanie 02-16-2021 Page 27 of 31

37:19 40:8

visited

29:6,20 31:8

35:13 40:6

visiting 30:3

38:2,17,20,24

visits 37:24

vs 1:11 88:5

W

waive

88:9,15,21

walk 39:13

wall 49:21,22

53:8

walls 62:7

want 10:9

12:19 20:1

29:19 30:2,18

38:21 49:19

61:1 62:1

75:1,4,8

79:13,15 82:2

wanted 21:1

74:8

wasn't 16:19

47:14 58:18

61:10 84:21

watch 24:5

way 9:23 32:8

48:6 55:23,24

63:11,15,23

64:7,9 75:25

78:5,15

84:10,17,22

we 5:12 10:25

14:5 15:14,25

16:3 18:23,24

21:3,13,14,19

,20,21

23:8,22

27:12,15,20,2

5 35:12 37:18

40:21 41:15

52:11

54:13,18,19

57:11 61:7

74:19 75:22

78:5,17 81:13

83:2,13

wear 39:12

website

78:22,23

wedding 28:18

week 40:19

42:19

weight

53:7,9,12

went 8:4 12:21

21:20 23:22

24:19 30:23

31:11 35:10

45:2 57:11

72:9 75:25

were 8:11

11:25 12:2

17:2,23

18:4,5,12,16

21:8 25:11

26:1,9 27:21

30:3,6 31:13

35:18 36:16

39:5 40:20

41:18,19,20,2

5

42:8,9,10,13,

20 44:22

46:4,18,21

48:13,15

49:16,21

51:1,10,14,24

52:12,13,15,1

8,21

53:6,9,11

55:24 56:1

58:14,16

61:17 64:16

66:22 69:9

70:1,4,7 72:6

74:17

81:8,13,23

82:1

83:16,19,20

84:3,4,5,9,13

85:4

we're 20:9

Were 8:17

24:10 25:20

27:21 48:15

49:24 51:8,13

74:14 77:7

weren't

48:19,20,22

74:11,17,20

what

6:7,14,20,23,

24

7:2,10,13,17

8:11,20,21

9:21,24

10:6,14,20

11:3,16

12:8,17,19

13:1,6,7,10,1

4,16,22

14:1,2,21,22

15:5,6,10,12

16:23,24

17:17,20,24

19:4 21:8

22:5

23:12,17,23

24:1,3,4,6

25:24 26:1,21

29:8,20,24

30:2,22

31:13,16,18,2

2,23 32:14

34:15

36:10,11,18,1

9,24 37:2

38:17

39:1,3,7

40:3,12 41:17

42:23

44:2,5,19,20,

21 45:25

46:20

48:4,18,21,24

49:3,9 50:17

51:14

52:2,5,8,15

54:5,20

55:2,7,16

56:2,5

57:1,2,6,12

58:7,16 59:25

60:9,16

61:12,13

62:1,20 63:16

64:16 67:10

68:5,10,18,22

,25

69:9,16,18

72:3,24 73:14

74:7,19,25

75:4,20

76:12,16

77:13,24 78:6

79:3,8,18

80:15,18

81:9,23 82:17

83:3,7 84:7,8

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 70 of 74
Adams, Melanie 02-16-2021 Page 28 of 31

what'd 15:7

whatever 32:13

53:10 60:25

61:1,22 75:21

what's 9:8

24:3 80:2,5

84:23

when 8:17

10:15 14:9

16:23 17:7,22

18:18 21:20

22:10,18 23:4

33:7,16 34:5

35:13 36:23

38:2,16,19,24

39:8,13,21

40:8

42:9,20,24

44:22,24

45:16 48:2

50:16

51:15,20

52:2,13,17

57:16 59:3

62:20,22 63:9

68:4,6

69:20,25

70:15 72:2,9

74:2,4

75:5,24

76:17,19

77:10

79:20,21

80:10 83:7,15

where 9:12

26:24 51:4,5

56:9 65:3

69:9 75:20

81:25

83:20,24

84:13,24

whether 21:25

22:3 32:3

34:8 62:23

65:22 66:2

70:19 73:12

78:15

which 30:25

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3 61:4 72:13

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9 27:14 29:4

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43:12,15

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54:13,21

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,19 57:15

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84:13

Willis 1:24

5:13 86:5,21

87:5,15 88:19

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wish 88:15

89:2

with 5:13 7:24

8:24

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8 23:13,17

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0 26:1,9,24

27:1

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6 39:22,23

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within 88:13

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0,21,22,23

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,18,22 63:3

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69:20,21

71:3,13,14,15

,25

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 71 of 74
Adams, Melanie 02-16-2021 Page 29 of 31

72:3,4,7,12,2

1 73:2,6,23

74:1,5,9 75:1

77:17

worked 15:21

44:21 72:17

workers 46:4

working 6:11

15:24 16:6,11

18:2 21:22

54:23 55:9

56:16

59:17,18

65:19 77:7

works 7:4

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worried 26:6,7

worry 55:2

would 5:14

7:13 9:3

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27:14,18

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31:12

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8,20 34:6,13

35:3,23

36:4,20

37:1,2,11,19,

24 38:15

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40:10,20

42:17,21

43:16

44:4,5,7,15,1

6 45:24 46:12

49:1 50:10

52:19,21 53:1

56:12 58:4

59:7 62:13

63:8 65:4

66:13,16,18

69:9

74:6,8,19

75:20,21,22

76:12 77:6

78:7,8,9 83:9

84:20

wouldn't 27:10

78:4

wound 83:2

write 43:1

writing 75:14

written 76:3

wrong 43:22

48:18 70:23

wrote 42:24

43:2,3,4

54:10

62:15,17

Y

yard 11:8,10

yeah 8:10

13:1,20

20:16,17

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50:19,22 53:2

60:9 62:12

68:1

year 7:9 8:8,9

24:14 38:3,14

40:11

52:15,17

69:5,7

years 8:4,16

14:12

35:8,9,10

38:3,12,14

40:4,5 67:20

68:14

69:3,5,7

yes 9:17,20

10:13 19:12

20:25 21:7

23:8,9,22

24:17,20

25:12,21

28:8,11 29:3

30:15

32:21,23 33:5

34:6 35:4

37:6 38:11,25

40:2 41:21

42:9 44:5,18

46:4,22 47:8

49:8 50:1,7

51:3,22

53:1,5,13,20

54:2 61:25

62:4,15,17

63:4 65:6

67:4,5,18

69:17,19,22

70:17

71:5,18,22,24

72:2 78:11

79:22 81:5,7

82:3 83:12,18

84:6 85:6

you

6:3,6,7,11,14

,23,24

7:5,7,8,17,19

8:2,11,15,17,

20,21

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18

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,21

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1,13,14,15,16

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21,23,24,25

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,14,16,17,24

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0,25

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3

16:6,13,16,21

,23,24

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,13,14,17,20,

21,24

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18,21

19:7,9,13,15,

19

20:1,7,8,11,1

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26:1,3,8,9,11

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27:14,18,21,2

4

28:2,3,10,11,

12,13,14,16,1

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 72 of 74
Adams, Melanie 02-16-2021 Page 30 of 31

8,21,24

29:1,4,8,12,1

4,18,20,22

30:2,3,11,17,

18,20,21,22

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32:3,14,16,18

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13,18,19,21,2

3

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41:1,4,6,8,10

,12,17,18

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17,22,25

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16,17,19,20,2

2

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14,17,23

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24

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51:1,4,8,13,1

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2,13,21,22,25

55:4,5,6,8,13

,15,16,17,19

56:1,2,8,12,2

1

57:2,15,17,21

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4,21

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21,23,24

62:1,8,13,16,

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69:2,3,13,16,

18,20,25

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19,23

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23

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19,21,24

78:7,8,19,22,

25

79:2,4,9,13,1

4,15,17,21,25

80:8,24

81:1,4,8,10,1

5,24

82:2,7,9,14,1

6,18,19

83:9,10,15,17

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1,12,13,14

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15

you'll 37:20

your 6:4,7,21

7:10,11 8:3

9:8

10:10,15,21

11:2 12:8

13:23 14:6,22

17:18 18:21

19:2,5,6,9,10

,13 20:19

21:2,9,16

23:12,13,17

25:15,16,20

26:2

28:14,15,22

29:2,24

30:12,22

31:6,18

34:7,12,19

37:5,11,14,15

38:4,6,17,23

39:15,22 40:1

41:1,2,4,8,10

,12 44:7,23

46:1,13

51:4,5,10

52:2,6 56:8

58:12

59:5,10,12,15

,21

60:3,4,6,12,2

1,25 61:5,8

62:11 63:20

65:23

66:2,9,20,21,

25 67:20

68:3,11 69:25

71:21

72:14,16,20

73:15

74:4,9,25

75:24

76:1,22,25

77:7,10,14,18

,22 78:12

79:20,23

80:2,15,18

81:6,12,15,17

82:17

83:24,25

84:1,4,5,7,22

,24,25

88:8,9,10,13,

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 73 of 74
Adams, Melanie 02-16-2021 Page 31 of 31

15

you're 8:23

13:7 15:9

20:10 23:12

28:2 30:17

31:4 32:8

33:18

36:2,9,12

51:13 57:21

58:7 59:6

60:1,16

61:13,23

62:25 63:16

64:8 72:24

yours 88:18

yourself 11:17

12:8 13:17

14:4 75:5

84:14

you've 7:22

8:6 29:13

62:14 63:6

Z

Zach 5:16

20:15 55:1

Zachary 2:3

88:2

Zack 19:23

ZOOM 2:5,10

Case 20-01350-RAM Doc 29-1 Filed 04/15/21 Page 74 of 74