EXHIBIT 5

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 1 of 21 PageID #:480
UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

COVER LETTER

Exhibit 5 is the deposition transcript of Special Administrator of the Estate of Gus Tousis, 

Aleia Tousis, taken on October 8, 2021. 

ALEIA TOUSIS, as Special Administrator of 

the Estate of GUS TOUSIS,

Plaintiff,

v.

SPECIAL AGENT KEITH BILLIOT,

Defendant.

)

)

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)

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)

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)

)

No. 20 C 3012

Judge Coleman

Magistrate Judge Cox

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 2 of 21 PageID #:481
1

 IN THE UNITED STATES DISTRICT COURT

 NORTHERN DISTRICT OF ILLINOIS

 EASTERN DIVISION

ALEIA TOUSIS, as Special )

Administrator of the Estate of )

GUS TOUSIS, )

 Plaintiff, )

 -vs- ) No. 20 C 4945

SPECIAL AGENT KEITH BILLIOT, )

 Defendant. )

 The videoconference deposition of

ALEIA TOUSIS, called for examination pursuant to

the Rules of Civil Procedure for the United States

District Courts pertaining to the taking of

depositions, taken before Raelene Stamm, a

Certified Shorthand Reporter licensed by the State

of Illinois, on the 28th day of October, 2021, at

the hour of 2:30 p.m.

Reported by: RAELENE STAMM, CSR

License No.: 084-004445

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L.A. Court Reporters, L.L.C.

2 (Pages 2 to 5)

2

1 APPEARANCES:

2

3 GREGORY E. KULIS AND ASSOCIATES, LTD.

4 BY: MR. VINCENZO CAPORALE

5 (via video)

6 30 North LaSalle Street

7 Suite 2140

8 Chicago, Illinois 60602

9 (312) 580-1830

10 vcaporale@kulislawltd.com

11 On behalf of the Plaintiff;

12

13 ASSISTANT UNITED STATES ATTORNEY

14 BY: MR. ALEX HARTZLER

15 (via video)

16 219 South Dearborn Street

17 Chicago, Illinois 60604

18 (312) 886-1390

19 alex.hartzler@usdoj.gov

20 On behalf of the Defendant.

21

22

23

24

3

1 I N D E X

2 WITNESS EXAMINATION

3 ALEIA TOUSIS

4 By Mr. Hartzler 5

5 By Mr. 39

6

7

8

9

10

11 E X H I B I T S

12 NUMBER IDENTIFICATION

13

14 (No exhibits marked.)

15

16

17

18

19

20

21

22

23

24

4

1 COURT REPORTER: We are on the record.

2 This deposition is being taken by means of

3 Zoom video conference.

4 The attorneys participating in this

5 deposition acknowledge that I am not physically

6 present in the deposition, and the oath will be

7 administered remotely.

8 The parties and their counsel consent to

9 this arrangement and waive any objections to this

10 manner of reporting.

11 Will all counsel present please state your

12 name, who you represent and indicate your agreement

13 on the record?

14 MR. CAPORALE: Mr. Vince Caporale and I do

15 consent to the recording, yes. Correct.

16 MR. HARTZLER: Alex Hartzler for the defendant,

17 agreed.

18 (WHEREUPON, the witness was

19 duly sworn.)

20

21

22

23

24

5

1 ALEIA TOUSIS,

2 called as a witness herein, having been first duly

3 sworn, was examined and testified as follows:

4 EXAMINATION

5 BY MR. HARTZLER:

6 Q. Miss Tousis, could you state your name and

7 spell your name for the record?

8 A. Aleia Tousis, A-l-e-i-a, T-o-u-s-i-s.

9 Q. My name is Alex, and I'll be the lawyer

10 taking your deposition this afternoon. Have you

11 ever had your deposition taken before?

12 A. No.

13 Q. Okay. So testifying in a deposition is

14 like testifying in a courtroom insofar as you've

15 taken an oath to tell the truth under penalty of

16 perjury, and the main difference is there's no

17 judge here listening to us like there would be in a

18 courtroom. Do you understand that?

19 A. Uh-huh.

20 Q. You kind of said uh-huh there which I

21 think meant yes. We should be careful because that

22 happens a lot in depositions, and it's important to

23 say yes or no if the answer is yes or no because

24 the court reporter who's writing all this down can

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6

1 have trouble if it's like uh-huh or uh-uh.

2 Does that make sense?

3 A. Yes.

4 Q. Great. The purpose of this deposition is

5 because if there's ever a trial, it's very hard for

6 lawyers to prepare for the trial if we don't know

7 what the various possible witnesses are gonna say;

8 and so that's why we do these depositions, to find

9 out. I expect if we had a trial in this case your

10 lawyer would probably put you on the stand, and you

11 would testify. So my goal here today is just to

12 find out what you would say in that case. That's

13 really the main purpose. Does that make sense?

14 A. Yes.

15 Q. This is not gonna be a marathon session,

16 and the fact that we're starting at 2:30 in the

17 afternoon hopefully is some indication of that.

18 But if you ever want to talk a break at any point,

19 please just let me know, and we can do that. But

20 one thing I would ask is that if I've asked you a

21 question, if you could answer the question before

22 the break. Does that sound fair?

23 A. Yes.

24 Q. We talked about the importance of

7

1 answering yes or no if the answer is yes or no as

2 opposed to nodding the head or saying uh-huh or

3 uh-uh. On Zoom sometimes there's like an audio

4 delay, and we end up talking over each other. It's

5 important to try not to do that cause that again

6 makes it hard for the court reporter to write down

7 what we're saying. So I will make an effort to try

8 to be sure that you're finished with your answer

9 before I ask another question. And, likewise,

10 could you try to make sure I'm finished asking the

11 full question before you give an answer?

12 A. Yes.

13 Q. Okay. Where are you currently right now?

14 A. At my home.

15 Q. And is that in Bartlett?

16 A. No. I just moved to Streamwood.

17 Q. Can you spell that?

18 A. S --

19 Q. Oh, Streamwood?

20 A. Yes.

21 Q. Okay. I thought you said Charmont.

22 So is anyone else at home right now?

23 A. No.

24 Q. Can you let us know if anyone comes home

8

1 while you're doing this deposition?

2 A. Yes.

3 Q. Okay. And because we're doing this by

4 video which we've been doing over the last year and

5 a half at this point, the Zoom video depositions

6 have gone very well from my perspective; but it's a

7 little harder to tell what the witness is doing

8 cause you can't see the whole witness, and so I

9 just want to let you know that you shouldn't be

10 communicating with anyone outside of the Zoom

11 platform during this deposition. So that would

12 include no emailing or texting anyone.

13 Does that sound fair?

14 A. Yes.

15 Q. Okay. Are you currently under the

16 influence of alcohol or any drug that might make it

17 difficult to understand my questions and answer

18 them truthfully today?

19 A. No.

20 Q. Besides this case have you ever been

21 involved in any other lawsuits in any way?

22 A. No.

23 Q. What year were you born?

24 A. 1999.

9

1 Q. And what's your current age?

2 A. 22.

3 Q. What year did you graduate from high

4 school?

5 A. 2017.

6 Q. What high school was that?

7 A. Bartlett High School.

8 Q. And I saw you pursued a certificate in

9 cosmetology after high school; is that right?

10 A. Yes.

11 Q. What year did you receive that, and what

12 was the name of the institution?

13 A. 20 -- oh, my gosh, 2020 and Pivot Point

14 Academy.

15 Q. Where is that?

16 A. Bloomingdale, Illinois.

17 Q. And have you had any other educational

18 pursuits other than the cosmetology certificate

19 since high school graduation?

20 A. No.

21 Q. Could you talk me through your work

22 history since 2016?

23 A. Since 2016, let's see, I was working at

24 Jasper's cafe in Glenview, and then that was right

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10

1 when my father passed. I don't remember before.

2 After I was working at Jimmy's Charhouse in Elgin

3 while I was at school. And then I was nannying for

4 a bit, and now I'm at Studio Styl Company in

5 Palatine.

6 Q. Is Studio Styl a salon?

7 A. Yes.

8 Q. Do you -- how many hours do you work

9 there?

10 A. It varies because I just had surgery, so

11 right now it's between like 20, 30 hours. It just

12 really depends.

13 Q. Has it ever been 40 hours a week or does

14 it usually fall in the 20 to 30 range?

15 A. It usually falls between 20 and 30. I

16 work four days a week.

17 Q. And when did you start working at

18 Studio Styl?

19 A. I started working in May of 2021.

20 Q. And you said you were working at Jimmy's

21 Charhouse while you were at school. That's

22 referring to Pivot Point?

23 A. Yes.

24 Q. Okay. So it sounds like you were taking

11

1 some classes in person or doing some in-person

2 training with Pivot Point; is that right?

3 A. Yes.

4 Q. What period of time were you at Pivot

5 Point?

6 A. Monday through -- Tuesday through

7 Saturday, 8:35 to 4:45.

8 Q. I meant to ask when -- so you graduated

9 2020. When did you start at Pivot Point?

10 A. 2019.

11 Q. Was it a one-year program?

12 A. Yes, 11 months.

13 Q. Okay. When you were working -- did you

14 work at Mapleberry Pancake House before Jasper's?

15 A. I did.

16 Q. Was that -- were you in high school at the

17 time?

18 A. Yes.

19 Q. Did you also work at the place called

20 Swerve Salon?

21 A. I did, yes.

22 Q. Where was that?

23 A. At their shop in Chicago.

24 Q. And what period of time did you work there

12

1 just approximately?

2 A. Actually I worked there June of, I'm sorry

3 about the years, 2019 to 2020, I believe. I'm

4 sorry. I really don't remember.

5 Q. Were you working at Swerve before you

6 started at the Pivot Point Academy?

7 A. I was at Pivot Point Academy while I was

8 at Swerve, and then I ended up leaving in, sorry,

9 September of last year.

10 Q. Are you still nannying or has that stopped

11 since you started working at Styl?

12 A. That stopped.

13 Q. Okay. Are you married?

14 A. No.

15 Q. Do you have a domestic partner?

16 A. Yes.

17 Q. Is that a -- you don't need to tell me

18 that person's name, but do they live with you?

19 A. Yes.

20 Q. How long have you been in a relationship

21 with that person?

22 A. Almost a year.

23 Q. Did you move in together in the new house?

24 A. Yes.

13

1 Q. Do you have any children?

2 A. No.

3 Q. You're the daughter of Gus Tousis?

4 A. Yes.

5 Q. And do you know what year he was born?

6 A. 1974.

7 Q. Okay. Do you know how far he went in

8 school?

9 A. I believe high school. I'm not sure.

10 Q. Do you know what high school he went to?

11 A. Elgin High School.

12 Q. Do you know what year he graduated?

13 A. No.

14 Q. Okay. Do you know if he had any medical

15 conditions in the later years of his life?

16 A. Diabetes.

17 Q. I'm not a medical expert. I have a sense

18 there's a couple different types of diabetes.

19 Do you know what type it was?

20 A. No.

21 Q. Do you know when he was diagnosed with

22 diabetes?

23 A. He had it for a long time. He didn't

24 know. I believe in 2016, I'm not sure the exact

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14

1 date, but he was in an induced coma because of it.

2 Q. I saw something that your lawyer provided

3 that gave 2017 as the year where he went into a

4 coma. Does that sound right?

5 A. Okay. Yes, yes. 2017, I apologize.

6 Q. Was it at that time that he learned that

7 he had diabetes?

8 A. I believe so, yes.

9 Q. Okay. But he had had it for a long time

10 is your understanding?

11 A. Yes.

12 Q. And he was in the hospital for a month

13 with the coma; is that right?

14 A. Yes.

15 Q. Do you remember when it was in 2017? Like

16 what time of year?

17 A. No, I don't know.

18 Q. Do you know what he did for work over the

19 years?

20 A. No.

21 Q. I saw something from your lawyer that he

22 after high school worked in a mechanic shop. Does

23 that sound familiar to you?

24 A. I don't recall.

15

1 Q. Okay. And then what -- do you know if he

2 was working as a painter doing rehabs in homes at

3 any point prior to 2017?

4 A. He did work for Certapro, I believe, on

5 the side of that, but I don't know how long.

6 Q. Can you spell Certapro?

7 A. C-e-r-t-a-p-r-o.

8 Q. When you say on the side, that suggests on

9 the side of something else. What was the other

10 thing?

11 A. Just rehabbing and painting on the side.

12 Q. Oh, okay. What is Certapro?

13 A. I believe it's a painting business.

14 Q. So he was doing -- to your understanding,

15 he was doing painting, rehabbing, and some of that

16 was for Certapro?

17 A. Yes.

18 Q. And I saw that after the 2017 illness he

19 stopped doing that work as far as you know?

20 A. Yes.

21 Q. Okay. Do you know -- do you have any

22 siblings?

23 A. No.

24 Q. Do you know how much money he earned from

16

1 the painting work or the rehab work?

2 A. No.

3 Q. Did he become a stay-at-home father in the

4 wake of the illness?

5 A. Yes.

6 Q. And was that -- would that be a

7 stay-at-home father to you or to someone else?

8 A. To me.

9 Q. Do you know whether he expected to return

10 to work at any point?

11 A. No, I don't know.

12 Q. Did you have any opinion whether he was

13 gonna be able to return to work in the wake of the

14 2017 illness?

15 A. No.

16 Q. Again, I was provided by your lawyer some

17 information about various places you've lived over

18 the years and who you were living with, and I

19 really just want to ask you what periods of time

20 those places were. And it doesn't -- you don't

21 need to be exact, but just to the best of your

22 memory let me know. If you could tell me the year,

23 great. If you can tell me that you know it was,

24 you know, sixth grade, that's fine.

17

1 It looked like at some point you were

2 living in Carol Stream with your father and his

3 girlfriend Jessica?

4 A. Yes.

5 Q. Approximately what period of time was

6 that?

7 A. Fourth grade through, I believe, sixth

8 grade.

9 Q. Okay. And at some point you were living

10 in Bartlett with your mother and grandmother?

11 A. Yes.

12 Q. And what period of time was that?

13 A. That has kind of been on and off. It was

14 before fourth grade and then after seventh grade.

15 Q. And is your mother's name Tina Amelio,

16 A-m-e-l-i-o?

17 A. Yes.

18 Q. And is your grandmother's name Roxanne --

19 I don't know how to pronounce it. Last name

20 spelled M-l-e-k-u-s-h?

21 A. Yes.

22 Q. Do you know how to pronounce it?

23 A. Mlekush.

24 Q. Great. At some point were you living in

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1 Schaumburg with your father and Jessica?

2 A. Yes.

3 Q. And approximately when was that?

4 A. I believe that was sixth grade.

5 Q. Okay. And at some point did you move to

6 Bartlett with your father and Jessica?

7 A. Yes, I did.

8 Q. What period of time was that?

9 A. High school.

10 Q. Okay. And what about living in Streamwood

11 with your mother at some point?

12 A. Yes. That was in between with my father

13 at Bartlett and her, so within high school as well.

14 Q. Okay. So in high school were you

15 splitting time between Bartlett and Streamwood?

16 A. Yes. I was with my father more though.

17 Q. What would be the breakdown in high school

18 in terms of five days a week, two days a week,

19 three days a week, four days a week, one week on,

20 one week off? How did it work?

21 A. I would like to say like five days a week

22 with my father and then two with my mom.

23 Q. That was in the high school years?

24 A. Yes.

19

1 Q. What about in the junior high year or

2 middle school years? What was the situation in

3 terms of where you were living?

4 A. That depended as well. I think I was with

5 my mom more and then my dad less at that time.

6 Q. So mom more than dad in middle school, dad

7 more than mom in high school?

8 A. Yes.

9 Q. And what about before middle school?

10 A. Before middle school, I don't recall how

11 often I was with each.

12 Q. I guess I'm assuming your parents split up

13 at some point in your life; is that right?

14 A. Yes.

15 Q. Do you know how old you were when they

16 split up?

17 A. I was in third grade.

18 Q. Third grade.

19 So it's really just part of third grade

20 and fourth and fifth where we're not totally sure

21 what the time breakdown was between living with mom

22 and dad?

23 A. Yes.

24 Q. At some point I saw you were living in

20

1 Elgin with a roommate; is that right?

2 A. Yes.

3 Q. Is that after high school?

4 A. Yes. That was in 2018 right after my

5 father passed.

6 Q. And where were you living between

7 graduating from high school and moving in with the

8 roommate? Was that still splitting time between

9 Streamwood and Hanover Park?

10 A. I was in Hanover Park at that time with my

11 father.

12 Q. Was your roommate a friend of yours or

13 someone you found for the purpose of living with a

14 roommate?

15 A. A friend.

16 Q. And at some point did you move out of the

17 Elgin place and move back in with your mother?

18 A. Yes.

19 Q. And what approximately when was that?

20 A. Last year in April.

21 Q. April 2020?

22 A. Yes.

23 Q. And I think you said you just moved out of

24 your mom's place to your new place, but was that

21

1 just October 2021 or --

2 A. August.

3 Q. August 2021.

4 I really apologize for asking. Do you

5 know whether your father had a criminal record of

6 any kind?

7 A. I do know that he had a criminal record,

8 yes.

9 Q. What do you know about that?

10 A. I knew it was just some drug offenses.

11 Q. Do you have any memory of even

12 approximately when the offenses were?

13 A. No, I do not.

14 Q. Like '90s, 2000s, more recently? Do you

15 have any idea?

16 A. No.

17 Q. Was it your understanding as of, let's

18 say, early 2018 that he had had some drug offenses

19 in the past, but you didn't really know the

20 details?

21 A. Yes.

22 Q. Okay. Why did you decide to file this

23 will lawsuit?

24 A. I wanted justice for my father.

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1 Q. Can you say more about in which you expect

2 the lawsuit to achieve justice for your father?

3 A. When would I like it to achieve justice

4 for my father?

5 Q. It sounds like you said the purpose is to

6 achieve justice, so I'm just asking in what way do

7 you expect it to or hope it will.

8 A. Just to prove that he was unjustifiably

9 shot and killed.

10 Q. Is it your belief that he was

11 unjustifiably shot?

12 A. Yes.

13 Q. What is the basis for that belief?

14 A. I don't believe that he was trying to hurt

15 a DEA officer.

16 Q. And why do you say you don't believe he

17 was trying to hurt a DEA officer?

18 A. Because my father has never shown any

19 signs of violence towards me or any other person,

20 so I don't believe that he would do that to another

21 person.

22 Q. So it sounds like -- I think I'm hearing

23 you to say that the reason you think the shooting

24 was unjustified was because your father never

23

1 showed signs of violence toward others, and so

2 therefore he wouldn't have done so in the instance

3 on June 2, 2018?

4 A. Yes.

5 Q. Is there anything besides that that forms

6 the basis for your belief that the shooting was

7 unjustified?

8 A. No.

9 Q. So I guess I should ask an obvious

10 question.

11 You were not present during the incident

12 on June 2, 2018; is that right?

13 A. No. Or yes, yes, that's right. I was

14 not.

15 Q. I assume you have some knowledge of what

16 happened on that date as we all do, and I want to

17 ask what the source of the knowledge is. And I

18 want to make sure I don't -- I don't want you to

19 tell me things that you've learned from your

20 lawyer. I guess more accurately, I don't want you

21 to tell me about any conversations that you've had

22 with your lawyers. Let's just make sure that's

23 clear.

24 So with that stipulation, I guess, let's

24

1 start. Without telling me the source of any

2 information, can you tell me what your

3 understanding is of what happened on that day?

4 A. Yes. So I believe that he was in a

5 high-speed car chase with the DEA. He got off on

6 Central Road in Chicago and I guess made a U-turn

7 and said that he hit a DEA officer, and then they

8 shot him.

9 Q. And where -- and then now I will ask, what

10 is the source of those -- the sequence of events

11 that you described, what is the source of your

12 understanding about what happened?

13 A. Basically just online, the newsletters and

14 stuff.

15 Q. There was some coverage in like the

16 Chicago Tribune maybe --

17 A. Yes.

18 Q. -- that --

19 A. Yes.

20 Q. When you say newsletters, is that what

21 you're talking about?

22 A. Yes.

23 Q. It might have been -- I don't remember

24 actually if there was any TV coverage.

25

1 Do you remember?

2 A. No, I don't remember.

3 Q. Was it -- so is it really anything besides

4 the newspaper story?

5 A. No.

6 Q. I'm sorry. I didn't hear you.

7 A. No.

8 Q. Okay. Did you learn anything about the

9 incident from anything you read online other than

10 the newspaper story if you read that online?

11 A. No.

12 Q. Did you speak -- sorry, go ahead. I

13 thought Rae had something to day. My mistake.

14 Miss Tousis, did you speak with your

15 father on June 2, 2018?

16 A. Yes.

17 Q. When did you speak with him?

18 A. Before he left that day.

19 Q. Do you know what time he left?

20 A. I believe around 6:30 maybe.

21 Q. And forgive me. Was this in Hanover Park

22 then?

23 A. Yes.

24 Q. What did you talk about before he left?

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26

1 A. All he said was have a good day at work.

2 Q. Have you spoke -- do you have an uncle

3 named George?

4 A. Yes.

5 Q. Are you in touch with him?

6 A. Yes.

7 Q. Have you spoken to him about his

8 understanding of what happened on June 2, 2018?

9 A. Not really, no.

10 Q. I guess this question might be too

11 obvious, but, I mean, obviously you haven't spoke

12 with any of the law enforcement officers that were

13 involved?

14 A. No.

15 Q. You have not?

16 A. I have not.

17 Q. Have you looked at any of the police

18 reports or anything from the incident?

19 A. I have, yes.

20 Q. Does some of your understanding of what

21 happened come from those reports?

22 A. Not really because a lot was blacked out.

23 Q. Do you know a person named Vernon Turner?

24 A. No.

27

1 Q. Do you know of anyone who has knowledge

2 about what happened during the incident that led to

3 this lawsuit other than someone who was on the

4 scene at the time?

5 A. No.

6 Q. Did you yourself handle the funeral or

7 burial arrangements for your father?

8 A. Yes. I helped pick out, you know, his

9 casket and where it was going to be.

10 Q. Do you remember what the cost was for any

11 of the services or anything?

12 A. I do not.

13 Q. Did you handle any of that stuff or did

14 somebody else in the family take care of it?

15 A. Somebody else did.

16 Q. Who was that person?

17 A. That was my father's stepfather.

18 Q. What's his name?

19 A. Pete Hronopolous.

20 Q. Can you spell the last name?

21 A. H-r-o-n-o-p-o-l-o-u-s.

22 Q. Do you know if Pete paid for the funeral

23 arrangements or the burial?

24 A. He did, yes.

28

1 Q. This is a big question. You can answer

2 however you like, but how has your father's death

3 affected you in your life?

4 A. It's affected me tremendously.

5 Everything -- every day I don't have him. I was

6 very young. You know, I was 18 when he passed.

7 It's a big milestone for me. I won't have him at

8 my wedding. I won't have him when I have children.

9 I don't have him to talk to every day.

10 Q. Did you and your father have a close

11 relationship?

12 A. Yes, we did.

13 Q. You were living together at the time of

14 his passing. How frequently did you talk?

15 A. Every single day.

16 Q. How much time per day would you guess that

17 you spent together?

18 A. I would say a couple hours a day every

19 day.

20 Q. What kind of activities did you do

21 together?

22 A. We would -- we would go to eat. He would

23 just talk to me in the living room. We would do a

24 lot of things. I would go on drives with him. He

29

1 helped me out with my car, cleaning it and

2 everything. He's very big on that.

3 Q. What kind of places would you go to eat?

4 A. Restaurants.

5 Q. For example?

6 A. Dinner restaurants, breakfast restaurants.

7 Q. Do you remember any specific restaurants

8 you'd go to?

9 A. No.

10 Q. Did you guys watch TV together in the

11 living room?

12 A. We did, yes.

13 Q. What kind of shows did you watch together?

14 A. He really liked the Sopranos. He really

15 liked King of Thrones. He really liked sports. So

16 I would watch that with him. He would watch, you

17 know, certain reality TV shows with me, and he

18 would tolerate it.

19 Q. What was your favorite reality show to

20 watch with him?

21 A. I would say Jersey Shore.

22 Q. I never got into that one, but I know some

23 of the references.

24 Was your father still with Jessica when he

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1 died?

2 A. Yes.

3 Q. Do you know how his death affected her?

4 A. No.

5 Q. Are you still in touch with her?

6 A. No.

7 Q. Do you know how his passing affected your

8 mother, if it did?

9 A. It affected her tremendously as well. Now

10 she's a single patient. She has to take care of me

11 all alone.

12 Q. Are you still in touch with anyone on your

13 father's side of the family?

14 A. I am.

15 Q. And who are those people?

16 A. I am in touch with my grandmother, his

17 mother. I am in touch with his aunt and his uncle,

18 cousins.

19 Q. How has his death affected your

20 grandmother, his mother?

21 A. It has affected her a lot as well.

22 Q. How have you seen that?

23 A. I talk to her almost every week, and she

24 cries all the time.

31

1 Q. In the wake of your father's passing, I

2 think we established that you moved out of the

3 Bartlett home into the Elgin place with your

4 roommate. Do I have that right?

5 A. I moved out of the Hanover Park home into

6 the place with my roommate in Elgin, yes.

7 Q. Forgive me. How quickly did that happen?

8 A. My father passed in June of 2018. I moved

9 in September of 2018.

10 Q. Did you remain living with Jessica for the

11 summer?

12 A. Yes.

13 Q. Have you sought or received any mental

14 health treatment or therapy or anything like that

15 in the wake of your passing?

16 A. I have, therapy, yes.

17 Q. When did you start going to therapy?

18 A. I believe I started in September of 2018.

19 Q. Have you been seeing a particular

20 therapist since then?

21 A. No.

22 Q. I guess I should ask, starting in

23 September 2018, how long did you go to therapy?

24 A. I'm not sure the exact time, but I think a

32

1 couple of months.

2 Q. Are you still doing any therapy or was it

3 just a couple months after September 2018?

4 A. It was just a couple of months after.

5 Q. Do you remember the name of the therapist?

6 A. No, I do not.

7 Q. Do you remember where the office was?

8 A. I believe it was in West Dundee.

9 Q. Was there any reason that you stopped?

10 A. No.

11 Q. Before your -- excuse me.

12 Before your father passed, was he

13 providing you with financial support?

14 A. Yes.

15 Q. And what type of financial support was he

16 providing you?

17 A. A house over my head, food, clothes,

18 everything.

19 Q. Was he renting a place at the time, do you

20 know?

21 A. Yes, yep.

22 Q. I'm gonna guess that you didn't study the

23 apartment lease or the grocery bill very closely,

24 but did he provide you like cash to go shopping or

33

1 anything like that?

2 A. Yes.

3 Q. How much would he give you?

4 A. I'm not sure, probably maybe like a couple

5 hundred a week.

6 Q. So you had something in the order of a

7 couple hundred dollars a week from him to use as

8 you saw fit?

9 A. Yes.

10 Q. Okay. Did you -- did your father leave a

11 will, to your knowledge?

12 A. No.

13 Q. Did you inherit anything from him?

14 A. No.

15 Q. When he was not working after the 2017

16 illness, do you know what the source of the money

17 he would give you each week was?

18 A. Yes.

19 Q. And what was it?

20 A. Drugs.

21 Q. Oh, okay. Do you know -- was he selling

22 drugs?

23 A. What kind of drugs he was selling?

24 Q. I meant to ask, do you know if he was

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1 selling drugs.

2 A. Yes.

3 Q. Do you know what kind?

4 A. Cocaine.

5 Q. Do you know how much he earned?

6 A. No.

7 Q. Enough to give you spending money, but

8 beyond that you don't know more about?

9 A. Yes, beyond that I don't know.

10 Q. Do you know when he started doing that?

11 A. No.

12 Q. Who would you say your father was closest

13 to in the final year of his life?

14 A. Me.

15 Q. Assuming you're at the top, anyone else on

16 the next tier down?

17 A. Probably Jessica and my mom.

18 Q. Did he and your mom have a cordial

19 relationship?

20 A. Yes.

21 Q. I apologize for probing this, but since

22 you mentioned it, I feel like I should ask.

23 As far as your father selling drugs goes,

24 do you know the names of anyone that he was doing

35

1 that with?

2 A. No, I do not recall.

3 Q. Do you know whether he used drugs himself?

4 A. I do not, no.

5 Q. Do you know anything about his

6 relationship with alcohol?

7 A. He never drank.

8 Q. I mentioned earlier that I don't want to

9 hear anything about the substance of any

10 communications that you had with your lawyer, in

11 this case I guess really any lawyer; but at some

12 point in the wake of your father's death, did you

13 reach out to a lawyer?

14 A. Yes.

15 Q. And why did you do that?

16 A. After my father's death?

17 Q. Yes.

18 A. To get justice for my father.

19 Q. Did you speak with any lawyers besides

20 Mr. Kulis or anyone at his firm?

21 A. No.

22 Q. To your understanding, who are you suing

23 in this case?

24 A. The DEA, I believe.

36

1 Q. Did you say the DEA?

2 A. Yes.

3 Q. So the defendant in the case is actually a

4 DEA officer as opposed to the DEA.

5 A. Okay.

6 Q. Did you know that before just now?

7 A. No.

8 Q. Did you ever make a decision to sue the

9 individual officer as opposed to the government?

10 A. Yes. I just don't know who the officer

11 is.

12 Q. Okay. I thought you just said you didn't

13 know that the defendant was the officer.

14 A. Oh, I just thought that it was going to

15 the DEA because I didn't know who the officer was,

16 and I still don't know who the officer is.

17 Q. I understand. I understand.

18 Understanding that you don't know who the

19 officer is, do you understand that the person

20 you're suing in the case is the officer and not the

21 government?

22 A. Yes, now I do.

23 Q. And did you make a decision at some point

24 that you were gonna be suing the officer as opposed

37

1 to the government?

2 A. Yes.

3 Q. As you sit here today are you aware that

4 an individual officer might be protected from suit

5 by some defenses that wouldn't apply to the

6 government?

7 A. Can you rephrase that, please?

8 Q. Yeah.

9 As you sit here today are you aware that

10 an individual officer when he gets sued might be

11 protected by certain defenses that wouldn't be

12 available to the government when it gets sued?

13 A. I'm not sure.

14 Q. Do you know if you've ever been aware of

15 that?

16 A. No.

17 MR. HARTZLER: Let's go off the record for one

18 second.

19 MR. CAPORALE: You want to take a break? We'll

20 take five.

21 MR. HARTZLER: Five is fine.

22 MR. CAPORALE: Let's come back at 3:15. We'll

23 go off the record.

24

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1 (WHEREUPON, a short recess was

2 taken.)

3 MR. HARTZLER: Back on the record.

4 BY MR. HARTZLER:

5 Q. Miss Tousis, we just took a six-minute

6 break. Is there anything you said during this

7 deposition that you want to revisit having had

8 second thoughts about it?

9 A. No.

10 Q. The one more thing I want to talk about

11 with you is the testimony you gave earlier about

12 your father not showing signs of violence toward

13 anyone. I wonder if you could just expand on that

14 in terms of what you observed in his life that

15 leads you to say that.

16 A. I just have never seen him yell, hit

17 anybody.

18 Q. Have you seen him have a disagreement with

19 someone?

20 A. Yes.

21 Q. And how was it handled?

22 A. Just talking.

23 Q. Do you know whether he owned a firearm?

24 A. No.

39

1 Q. Do you know whether he ever had a firearm

2 in his possession in 2018?

3 A. I don't know.

4 MR. HARTZLER: I don't have any further

5 questions.

6 MR. CAPORALE: Okay. Thank you, Alex. Thank

7 you, Alli. I do have just a few basic questions,

8 and then we should be good to go out of here.

9 EXAMINATION

10 BY MR. CAPORALE:

11 Q. Alli, can you just describe your

12 relationship with your father? Go ahead. Did

13 you -- what was your opinion of your father? Can

14 you describe your relationship with your father?

15 A. Yeah. My relationship, we were very, very

16 close. We would go out together, go out to

17 restaurants. We would talk all the time. We laugh

18 together, cry together. He was my hero, my

19 everything, and -- yeah.

20 Q. Did you look up to him?

21 A. I did, yes.

22 Q. You saw him as a role model of sorts?

23 A. I did.

24 Q. Can you describe some good qualities he

40

1 had?

2 A. Yes. He was kind. He was funny. He was

3 truthful.

4 Q. Thank you.

5 What was your father's reputation amongst

6 your family, both his family, your mother's family,

7 you know, the overarching, the connecting family?

8 A. Yeah. Everybody has always loved my

9 father. They've always looked up to him. They

10 have always gone to him for advice. He was truly

11 an amazing man, and it hurts that we lost him.

12 Q. And could the same be said about his

13 reputation amongst friends?

14 A. Yes.

15 Q. Did he have a big friend group?

16 A. He did, yes.

17 MR. CAPORALE: Those are all the questions I

18 have. Alex, if you have any redirect.

19 MR. HARTZLER: No. Thank you for your time

20 today, Miss Tousis.

21 THE WITNESS: Thank you.

22 MR. CAPORALE: Thank you.

23 Alli, I'm going to explain one thing to

24 you. Because we did record this deposition and we

41

1 have our court reporter here as well, she recorded,

2 you know, typewriting essentially everything that

3 was written down, everything that was said in a

4 transcript form.

5 Now, you have the option to either reserve

6 signature which means that you can go back and look

7 at the transcript and the record. You cannot

8 change any of your answers, but you can change the

9 spelling or grammatical mistake or anything. If

10 you choose to waive signature rather than reserve

11 signature, that means that you trust that the court

12 reporter got everything down correctly.

13 I would suggest that you waive signature

14 because I do think that this court reporter did a

15 great job here today, and I don't think there's,

16 you know, any grammatical issues. Like I said, you

17 can't go back and change any of your answers. But

18 the decision is with you whether you want to

19 reserve signature, which means that you can review

20 the transcript prior to approval, or you can waive

21 signature, which means, you know, you trust the

22 court reporter here to have gotten down everything.

23 It's your choice.

24 THE WITNESS: We can waive signature.

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42

1 MR. CAPORALE: Okay. Then we're gonna waive

2 signature, Miss Court Reporter.

3 FURTHER DEPONENT SAITH NAUGHT.

4 (WHEREUPON, the deposition

5 concluded at 3:30 p.m.)

6

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43

1 STATE OF ILLINOIS )

2 ) SS:

3 COUNTY OF C O O K )

4 I, RAELENE STAMM, Certified Shorthand

5 Reporter, licensed by the State of Illinois, do

6 hereby certify that heretofore, to-wit, on the

7 28th day of October, 2021, appeared before me via

8 Zoom Video Conference, ALEIA TOUSIS, a witness in a

9 certain cause now pending and undetermined in the

10 United States District Court, Northern District of

11 Illinois, Eastern Division, wherein ALEIA TOUSIS,

12 as Special Administrator of the Estate of GUS

13 TOUSIS, is the Plaintiff and SPECIAL AGENT KEITH

14 BILLIOT is the Defendant.

15 I further certify that the said

16 ALEIA TOUSIS was by me first duly sworn to testify

17 the truth, the whole truth, and nothing but the

18 truth in the cause aforesaid; that the testimony

19 then given by said witness was reported

20 stenographically by me in the presence of said

21 witness and afterwards reduced to typewriting by

22 Computer-Aided Transcription, and the foregoing is

23 a true and correct transcript of the testimony so

24 given by said witness as aforesaid.

44

1 I further certify that the signature to

2 the foregoing deposition was waived by counsel for

3 the respective parties.

4 I further certify that the taking of this

5 deposition was pursuant to Notice and that there

6 were present at the deposition the attorneys

7 hereinbefore mentioned.

8 I further certify that I am not counsel

9 for nor in any way related to the parties to this

10 suit, nor am I in any way interested in the outcome

11 thereof.

12 IN TESTIMONY WHEREOF: I have hereunto set

13 my hand this 26th day of November, 2021.

14

15

16

17 ________________________________________

18 CERTIFIED SHORTHAND REPORTER

19

20

21

22

23

24

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accurately 23:20

achieve 22:2,3,6

acknowledge 4:5

activities 28:20

administered 4:7

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advice 40:10

aforesaid 43:18

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afternoon 5:10

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age 9:1

AGENT 1:10

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agreed 4:17

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ahead 25:12 39:12

alcohol 8:16 35:6

Aleia 1:5,14 3:3

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alex.hartzler@u...

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amazing 40:11

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answer 5:23 6:21

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apartment 32:23

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case 6:9,12 8:20

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casket 27:9

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children 13:1 28:8

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classes 11:1

cleaning 29:1

clear 23:23

close 28:10 39:16

closely 32:23

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clothes 32:17

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coma 14:1,4,13

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happens 5:22

hard 6:5 7:6

harder 8:7

Hartzler 2:14 3:4

4:16,16 5:5

37:17,21 38:3,4

39:4 40:19

head 7:2 32:17

health 31:14

hear 25:6 35:9

hearing 22:22

helped 27:8 29:1

hereinbefore 44:7

heretofore 43:6

hereunto 44:12

hero 39:18

high 9:3,6,7,9,19

11:16 13:9,10,11

14:22 18:9,13,14

18:17,23 19:1,7

20:3,7

high-speed 24:5

history 9:22

hit 24:7 38:16

home 7:14,22,24

31:3,5

homes 15:2

hope 22:7

hopefully 6:17

hospital 14:12

hour 1:20

hours 10:8,11,13

28:18

house 11:14 12:23

32:17

Hronopolous

27:19

hundred 33:5,7

hurt 22:14,17

hurts 40:11

I

idea 21:15

IDENTIFICAT...

3:12

Illinois 1:2,19 2:8

2:17 9:16 43:1,5

43:11

illness 15:18 16:4

16:14 33:16

importance 6:24

important 5:22

7:5

in-person 11:1

incident 23:11

25:9 26:18 27:2

include 8:12

indicate 4:12

indication 6:17

individual 36:9

37:4,10

induced 14:1

influence 8:16

information 16:17

24:2

inherit 33:13

insofar 5:14

instance 23:2

institution 9:12

interested 44:10

involved 8:21

26:13

issues 41:16

J

Jasper's 9:24

11:14

Jersey 29:21

Jessica 17:3 18:1

18:6 29:24

31:10 34:17

Jimmy's 10:2,20

job 41:15

judge 5:17

June 12:2 23:3,12

25:15 26:8 31:8

junior 19:1

justice 21:24 22:2

22:3,6 35:18

K

K 43:3

KEITH 1:10

43:13

killed 22:9

kind 5:20 17:13

21:6 28:20 29:3

29:13 33:23

34:3 40:2

King 29:15

knew 21:10

know 6:6,19 7:24

8:9 13:5,7,10,12

13:14,19,21,24

14:17,18 15:1,5

15:19,21,24 16:9

16:11,22,23,24

17:19,22 19:15

21:5,7,9,19

25:19 26:23

27:1,8,22 28:6

29:17,22 30:3,7

32:20 33:16,21

33:24 34:3,5,8,9

34:10,24 35:3,5

36:6,10,13,15,16

36:18 37:14

38:23 39:1,3

40:7 41:2,16,21

knowledge 23:15

23:17 27:1

33:11

Kulis 2:3 35:20

L

LaSalle 2:6

laugh 39:17

law 26:12

lawsuit 21:23 22:2

27:3

lawsuits 8:21

lawyer 5:9 6:10

14:2,21 16:16

23:20 35:10,11

35:13

lawyers 6:6 23:22

35:19

leads 38:15

learn 25:8

learned 14:6

23:19

lease 32:23

leave 33:10

leaving 12:8

led 27:2

left 25:18,19,24

let's 9:23 21:17

23:22,24 37:17

37:22

License 1:24

licensed 1:18 43:5

life 13:15 19:13

28:3 34:13

38:14

liked 29:14,15,15

likewise 7:9

listening 5:17

little 8:7

live 12:18

lived 16:17

living 16:18 17:2

17:9,24 18:10

19:3,21,24 20:6

20:13 28:13,23

29:11 31:10

long 12:20 13:23

14:9 15:5 31:23

look 39:20 41:6

looked 17:1 26:17

40:9

lost 40:11

lot 5:22 26:22

28:24 30:21

loved 40:8

M

M-l-e-k-u-s-h

17:20

main 5:16 6:13

man 40:11

manner 4:10

Mapleberry 11:14

marathon 6:15

marked 3:14

married 12:13

mean 26:11

means 4:2 41:6,11

41:19,21

meant 5:21 11:8

33:24

mechanic 14:22

medical 13:14,17

memory 16:22

21:11

mental 31:13

mentioned 34:22

35:8 44:7

middle 19:2,6,9

19:10

milestone 28:7

mistake 25:13

41:9

Mlekush 17:23

model 39:22

mom 18:22 19:5,6

19:7,21 34:17,18

mom's 20:24

Monday 11:6

money 15:24

33:16 34:7

month 14:12

months 11:12

32:1,3,4

mother 17:10

18:11 20:17

30:8,17,20

mother's 17:15

40:6

move 12:23 18:5

20:16,17

moved 7:16 20:23

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 17 of 21 PageID #:496
Tousis Aleia

October 28, 2021

312-419-9292

L.A. Court Reporters, L.L.C.

Page 48

31:2,5,8

moving 20:7

N

N 3:1

name 4:12 5:6,7,9

9:12 12:18

17:15,18,19

27:18,20 32:5

named 26:3,23

names 34:24

nannying 10:3

12:10

NAUGHT 42:3

need 12:17 16:21

never 22:18,24

29:22 35:7

38:16

new 12:23 20:24

newsletters 24:13

24:20

newspaper 25:4

25:10

nodding 7:2

North 2:6

Northern 1:2

43:10

Notice 44:5

November 44:13

NUMBER 3:12

O

O 43:3,3

oath 4:6 5:15

objections 4:9

observed 38:14

obvious 23:9

26:11

obviously 26:11

October 1:19 21:1

43:7

offenses 21:10,12

21:18

office 32:7

officer 22:15,17

24:7 36:4,9,10

36:13,15,16,19

36:20,24 37:4,10

officers 26:12

oh 7:19 9:13

15:12 33:21

36:14

okay 5:13 7:13,21

8:3,15 10:24

11:13 12:13

13:7,14 14:5,9

15:1,12,21 17:9

18:5,10,14 21:22

25:8 33:10,21

36:5,12 39:6

42:1

old 19:15

one-year 11:11

online 24:13 25:9

25:10

opinion 16:12

39:13

opposed 7:2 36:4

36:9,24

option 41:5

order 33:6

outcome 44:10

outside 8:10

overarching 40:7

owned 38:23

P

p.m 1:20 42:5

paid 27:22

painter 15:2

painting 15:11,13

15:15 16:1

Palatine 10:5

Pancake 11:14

parents 19:12

Park 20:9,10

25:21 31:5

part 19:19

participating 4:4

particular 31:19

parties 4:8 44:3,9

partner 12:15

passed 10:1 20:5

28:6 31:8 32:12

passing 28:14

30:7 31:1,15

patient 30:10

penalty 5:15

pending 43:9

people 30:15

period 11:4,24

17:5,12 18:8

periods 16:19

perjury 5:16

person 11:1 12:21

22:19,21 26:23

27:16 36:19

person's 12:18

perspective 8:6

pertaining 1:16

Pete 27:19,22

physically 4:5

pick 27:8

Pivot 9:13 10:22

11:2,4,9 12:6,7

place 11:19 20:17

20:24,24 31:3,6

32:19

places 16:17,20

29:3

Plaintiff 1:8 2:11

43:13

platform 8:11

please 4:11 6:19

37:7

point 6:18 8:5

9:13 10:22 11:2

11:5,9 12:6,7

15:3 16:10 17:1

17:9,24 18:5,11

19:13,24 20:16

35:12 36:23

police 26:17

possession 39:2

possible 6:7

prepare 6:6

presence 43:20

present 4:6,11

23:11 44:6

prior 15:3 41:20

probably 6:10

33:4 34:17

probing 34:21

Procedure 1:15

program 11:11

pronounce 17:19

17:22

protected 37:4,11

prove 22:8

provide 32:24

provided 14:2

16:16

providing 32:13

32:16

purpose 6:4,13

20:13 22:5

pursuant 1:14

44:5

pursued 9:8

pursuits 9:18

put 6:10

Q

qualities 39:24

question 6:21,21

7:9,11 23:10

26:10 28:1

questions 8:17

39:5,7 40:17

quickly 31:7

R

Rae 25:13

Raelene 1:17,23

43:4

range 10:14

reach 35:13

read 25:9,10

reality 29:17,19

really 6:13 10:12

12:4 16:19

19:19 21:4,19

25:3 26:9,22

29:14,14,15

35:11

reason 22:23 32:9

recall 14:24 19:10

35:2

receive 9:11

received 31:13

recess 38:1

record 4:1,13 5:7

21:5,7 37:17,23

38:3 40:24 41:7

recorded 41:1

recording 4:15

redirect 40:18

reduced 43:21

references 29:23

referring 10:22

rehab 16:1

rehabbing 15:11

15:15

rehabs 15:2

related 44:9

relationship 12:20

28:11 34:19

35:6 39:12,14,15

remain 31:10

remember 10:1

12:4 14:15

24:23 25:1,2

27:10 29:7 32:5

32:7

remotely 4:7

renting 32:19

rephrase 37:7

reported 1:23

43:19

reporter 1:18 4:1

5:24 7:6 41:1,12

41:14,22 42:2

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 18 of 21 PageID #:497
Tousis Aleia

October 28, 2021

312-419-9292

L.A. Court Reporters, L.L.C.

Page 49

43:5 44:18

reporting 4:10

reports 26:18,21

represent 4:12

reputation 40:5

40:13

reserve 41:5,10,19

respective 44:3

restaurants 29:4,6

29:6,7 39:17

return 16:9,13

review 41:19

revisit 38:7

right 7:13,22 9:9

9:24 10:11 11:2

14:4,13 19:13

20:1,4 23:12,13

31:4

Road 24:6

role 39:22

room 28:23 29:11

roommate 20:1,8

20:12,14 31:4,6

Roxanne 17:18

Rules 1:15

S

S 3:11 7:18

SAITH 42:3

salon 10:6 11:20

Saturday 11:7

saw 9:8 14:2,21

15:18 19:24

33:8 39:22

saying 7:2,7

scene 27:4

Schaumburg 18:1

school 9:4,6,7,9

9:19 10:3,21

11:16 13:8,9,10

13:11 14:22

18:9,13,14,17,23

19:2,6,7,9,10

20:3,7

second 37:18 38:8

see 8:8 9:23

seeing 31:19

seen 30:22 38:16

38:18

selling 33:21,23

34:1,23

sense 6:2,13 13:17

September 12:9

31:9,18,23 32:3

sequence 24:10

services 27:11

session 6:15

set 44:12

seventh 17:14

shooting 22:23

23:6

shop 11:23 14:22

shopping 32:24

Shore 29:21

short 38:1

Shorthand 1:18

43:4 44:18

shot 22:9,11 24:8

show 29:19

showed 23:1

showing 38:12

shown 22:18

shows 29:13,17

siblings 15:22

side 15:5,8,9,11

30:13

signature 41:6,10

41:11,13,19,21

41:24 42:2 44:1

signs 22:19 23:1

38:12

single 28:15 30:10

sit 37:3,9

situation 19:2

six-minute 38:5

sixth 16:24 17:7

18:4

somebody 27:14

27:15

Sopranos 29:14

sorry 12:2,4,8

25:6,12

sorts 39:22

sought 31:13

sound 6:22 8:13

14:4,23

sounds 10:24 22:5

22:22

source 23:17 24:1

24:10,11 33:16

South 2:16

speak 25:12,14,17

35:19

Special 1:5,10

43:12,13

specific 29:7

spell 5:7 7:17 15:6

27:20

spelled 17:20

spelling 41:9

spending 34:7

spent 28:17

split 19:12,16

splitting 18:15

20:8

spoke 26:2,11

spoken 26:7

sports 29:15

SS 43:2

Stamm 1:17,23

43:4

stand 6:10

start 10:17 11:9

24:1 31:17

started 10:19 12:6

12:11 31:18

34:10

starting 6:16

31:22

state 1:18 4:11 5:6

43:1,5

States 1:1,15 2:13

43:10

stay-at-home 16:3

16:7

stenographically

43:20

stepfather 27:17

stipulation 23:24

stopped 12:10,12

15:19 32:9

story 25:4,10

Stream 17:2

Streamwood 7:16

7:19 18:10,15

20:9

Street 2:6,16

Studio 10:4,6,18

study 32:22

stuff 24:14 27:13

Styl 10:4,6,18

12:11

substance 35:9

sue 36:8

sued 37:10,12

suggest 41:13

suggests 15:8

suing 35:22 36:20

36:24

suit 37:4 44:10

Suite 2:7

summer 31:11

support 32:13,15

sure 7:8,10 13:9

13:24 19:20

23:18,22 31:24

33:4 37:13

surgery 10:10

Swerve 11:20 12:5

12:8

sworn 4:19 5:3

43:16

T

T 3:11

T-o-u-s-i-s 5:8

take 27:14 30:10

37:19,20

taken 1:17 4:2

5:11,15 38:2

talk 6:18 9:21

25:24 28:9,14,23

30:23 38:10

39:17

talked 6:24

talking 7:4 24:21

38:22

tell 5:15 8:7 12:17

16:22,23 23:19

23:21 24:2

telling 24:1

terms 18:18 19:3

38:14

testified 5:3

testify 6:11 43:16

testifying 5:13,14

testimony 38:11

43:18,23 44:12

texting 8:12

Thank 39:6,6 40:4

40:19,21,22

therapist 31:20

32:5

therapy 31:14,16

31:17,23 32:2

thereof 44:11

thing 6:20 15:10

38:10 40:23

things 23:19

28:24

think 5:21 19:4

20:23 22:22,23

31:2,24 41:14,15

third 19:17,18,19

thought 7:21

25:13 36:12,14

thoughts 38:8

three 18:19

Thrones 29:15

tier 34:16

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 19 of 21 PageID #:498
Tousis Aleia

October 28, 2021

312-419-9292

L.A. Court Reporters, L.L.C.

Page 50

time 11:4,17,24

13:23 14:6,9,16

16:19 17:5,12

18:8,15 19:5,21

20:8,10 25:19

27:4 28:13,16

30:24 31:24

32:19 39:17

40:19

Tina 17:15

to-wit 43:6

today 6:11 8:18

37:3,9 40:20

41:15

tolerate 29:18

top 34:15

totally 19:20

touch 26:5 30:5

30:12,16,17

Tousis 1:5,7,14

3:3 5:1,6,8 13:3

25:14 38:5

40:20 43:8,11,13

43:16

training 11:2

transcript 41:4,7

41:20 43:23

Transcription

43:22

treatment 31:14

tremendously

28:4 30:9

trial 6:5,6,9

Tribune 24:16

trouble 6:1

true 43:23

truly 40:10

trust 41:11,21

truth 5:15 43:17

43:17,18

truthful 40:3

truthfully 8:18

try 7:5,7,10

trying 22:14,17

Tuesday 11:6

Turner 26:23

TV 24:24 29:10

29:17

two 18:18,22

type 13:19 32:15

types 13:18

typewriting 41:2

43:21

U

U-turn 24:6

uh-huh 5:19,20

6:1 7:2

uh-uh 6:1 7:3

uncle 26:2 30:17

understand 5:18

8:17 36:17,17,19

understanding

14:10 15:14

21:17 24:3,12

26:8,20 35:22

36:18

undetermined

43:9

United 1:1,15

2:13 43:10

unjustifiably 22:8

22:11

unjustified 22:24

23:7

use 33:7

usually 10:14,15

V

varies 10:10

various 6:7 16:17

vcaporale@kuli...

2:10

Vernon 26:23

video 2:5,15 4:3

8:4,5 43:8

videoconference

1:13

Vince 4:14

VINCENZO 2:4

violence 22:19

23:1 38:12

vs- 1:9

W

waive 4:9 41:10

41:13,20,24 42:1

waived 44:2

wake 16:4,13 31:1

31:15 35:12

want 6:18 8:9

16:19 23:16,18

23:18,20 35:8

37:19 38:7,10

41:18

wanted 21:24

watch 29:10,13,16

29:16,20

way 8:21 22:6

44:9,10

We'll 37:19,22

we're 6:16 7:7 8:3

19:20 42:1

we've 8:4

wedding 28:8

week 10:13,16

18:18,18,19,19

18:19,20,21

30:23 33:5,7,17

went 13:7,10 14:3

West 32:8

WHEREOF

44:12

witness 3:2 4:18

5:2 8:7,8 40:21

41:24 43:8,19,21

43:24

witnesses 6:7

wonder 38:13

work 9:21 10:8,16

11:14,19,24

14:18 15:4,19

16:1,1,10,13

18:20 26:1

worked 12:2

14:22

working 9:23 10:2

10:17,19,20

11:13 12:5,11

15:2 33:15

wouldn't 23:2

37:5,11

write 7:6

writing 5:24

written 41:3

X

X 3:1,11

Y

yeah 37:8 39:15

39:19 40:8

year 8:4,23 9:3,11

12:9,22 13:5,12

14:3,16 16:22

19:1 20:20

34:13

years 12:3 13:15

14:19 16:18

18:23 19:2

yell 38:16

yep 32:21

young 28:6

Z

Zoom 4:3 7:3 8:5

8:10 43:8

0

084-004445 1:24

1

11 11:12

18 28:6

1974 13:6

1999 8:24

2

2 23:3,12 25:15

26:8

2:30 1:20 6:16

20 1:9 9:13 10:11

10:14,15

2000s 21:14

2016 9:22,23

13:24

2017 9:5 14:3,5,15

15:3,18 16:14

33:15

2018 20:4 21:18

23:3,12 25:15

26:8 31:8,9,18

31:23 32:3 39:2

2019 11:10 12:3

2020 9:13 11:9

12:3 20:21

2021 1:19 10:19

21:1,3 43:7

44:13

2140 2:7

219 2:16

22 9:2

26th 44:13

28th 1:19 43:7

3

3:15 37:22

3:30 42:5

30 2:6 10:11,14,15

312 2:9,18

39 3:5

4

4:45 11:7

40 10:13

4945 1:9

5

5 3:4

580-1830 2:9

6

6:30 25:20

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 20 of 21 PageID #:499
Tousis Aleia

October 28, 2021

312-419-9292

L.A. Court Reporters, L.L.C.

Page 51

60602 2:8

60604 2:17

7

8

8:35 11:7

886-1390 2:18

9

90s 21:14

Case: 1:20-cv-03012 Document #: 62-7 Filed: 02/22/22 Page 21 of 21 PageID #:500