1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ZHU ZHAI HOLDINGS LIMITED and )

PETER PUI TAK LEE, )

)

Plaintiffs/Judgment Creditors, )

)

v. ) Case No. 20-cv-4985

)

STEVEN IVANKOVICH, ) Honorable Susan E. Cox 

) 

Defendant/Judgment Debtor. )

PLAINTIFFS’ MOTION TO COMPEL AND EXTEND THE HOLD ON THE WALKER 

& DUNLOP FUNDS 

Plaintiffs/Judgment Creditors, ZHU ZHAI HOLDING LIMITED and PETER PUI TAK 

LEE, by their attorneys, KONICEK & DILLON, P.C., pursuant to Federal Rules of Civil 

Procedure 26 and 37 and Local Rule 37.2, hereby move this Court to compel Defendant/Judgment 

Debtor, STEVEN IVANKOVICH, to produce all documentation evidencing any and all transfers 

made by Judgment Debtor to or from entities he owned, operated, managed, maintained, 

controlled, had an interest in or was a signatory to from 2018 to present and to extend the hold on 

the Walker & Dunlop funds. In support thereof, Judgment Creditors state as follows:

FACTS

A. Judgment Creditors Obtain a Judgment Against Judgment Debtor and Judgment 

Debtor Produces Personal Financial Statement Evidencing Amount of Net Worth

On August 17, 2021, Judgment Creditors obtained a judgment in the amount of 

$4,503,842.00 (the “Judgement”) against Judgment Debtor. (Dkt. 92). Later, the Judgment Debtor 

provided Judgment Creditors with an August 26, 2020, sworn personal financial statement in 

response to a citation issued to Judgment Debtor. (Ex. 1, Judgment Debtor’s Personal Financial 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 1 of 182 PageID #:3186
2

Statement).1 The sworn personal financial statement established that Judgment Debtor had a total 

net worth in excess of $55,000,000 at the time Judgment Debtor executed the personal financial 

statement. Id. 

B. Judgment Debtor Testifies That He Uses Personal Finances to Fulfill “Obligations” 

Owed by Entities He Owns, Operates, Manages, Maintains, Controls, Has an Interest 

In or Is a Signatory To

On August 31, 2022, the Judgment Debtor was deposed. (Ex. 2, Deposition of Judgment 

Debtor). The Judgment Debtor testified that he used millions of dollars in “personal funds” to pay 

“obligations” owed by companies Judgment Debtor owned, operated, managed, maintained, 

controlled, had an interest in or was a signatory to. That is, he repeatedly used personal funds to 

pay obligations owed by his network of companies: 

Q: So you used personal funds to pay obligations of the companies?

A: Yes.

Q: Okay. And that was through 2020 and 2021, correct?

A: It started in 2019 as well. 

Q: Okay. And then – and then what – who was the one that authorized payment of 

your personal funds to pay obligations of the companies, it had to be you, right?

A: Yes. 

Q: And how did you transfer funds to these companies – well, which funds did you 

pay expenses for or obligations for, which corporations?

A: All of them. 

Q: And how were those funds transferred?

A: It would have been any way transferring funds. It would have been just bank 

transfers, wire transfers, check, you know, any means people use to pay bills. 

Id. at 50:12 – 51:3. 

1

 This exhibit is submitted in camera as it has been designated as confidential. 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 2 of 182 PageID #:3187
3

Indeed, Judgment Debtor moved over $11 million of his own liquid assets to pay bills 

owed by entities he controlled or had an interest in: 

Q: And then if you go down to Schedule B, it talks about “Marketable Securities, 

Stocks, Bonds, U.S. Government” and the total market value you have is $11 

million, do you see that?

A: Yes. 

Q: This is again on your personal financial statement?

A: Yes. 

Q: And today, Mr. Ivankovich, do you still have that $11 million in marketable 

securities, stocks, bonds, and U.S. government?

A: No. 

Q: Okay. And are you telling me that between again 2020 and today August 2022, 

all of that money was transferred out?

A: It was used to pay bills. 

Q: Okay. And what bills was it used to pay?

A: Payroll for the companies, mortgage payments, reserve payments, just the 

expenses of the companies when everything shut down during COVID. 

Id. at 51:17 – 52:9. 

Judgment Debtor Ivankovich also asserted that his net worth went from $55,000,000 to 

effectively zero in a short period of time because of COVID-19: 

Q: So in the year from August 2020 until the end of 2021, your net worth went from 

approximately 55,367,404 to pretty much zero; is that right?

A: Correct. 

Q: And your explanation for that is because you made transfers in order to meet the 

obligations of companies in which you had an interest?

A: My explanation of that is COVID. 

Id. at 58:23 – 59:5. 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 3 of 182 PageID #:3188
4

However, Debtor Ivankovich admitted he has been involved in the movement of his 

personal funds among company accounts as recently as April of last year: 

Q: Since April 6th of 2022, has any money been transferred out of the P2 Portfolio 

Managing Member LLC or Ivankovich Family LLC accounts? 

A: I’m sure there was. 

...

Q: Well, you were involved with them, right?

A: Yeah. 

Q: And –

A: I was involved in the organization. 

Q: And how much was transferred out?

A: I don’t know.

...

Q: Why was any money moved?

A: Because these are companies that conduct business so to pay bills, to make 

investments. 

Id. 71:25 – 72:13; 73:16-17. 

C. Judgment Creditors Issue Rule 37 Letter to Judgment Debtor Seeking Production of 

Any and All Documents Evidencing Transfers Judgment Debtor Testified To During 

His August 31, 2022, Deposition 

On February 3, 2023, counsel for Judgment Creditors wrote counsel for Judgment Debtor 

a Rule 37 letter requesting the production of all documentation evidencing any and all transfers 

made by Judgment Debtor to entities he owned, operated, managed, maintained, controlled, had 

an interest in or was a signatory to from 2018 to present. (Ex. 3, February 3, 2023, Letter). The 

letter included the above testimony in support. Id.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 4 of 182 PageID #:3189
5

Roughly two weeks later, Gary Goldstein – a lawyer who has no formal appearance on file 

in this matter – called counsel for Judgment Creditor. (Ex. 4, March 1, 2023, Correspondence). 

Mr. Goldstein advised that the Judgment Creditor would be producing documents responsive to 

the Judgment Creditor’s February 3, 2023, Rule 37 letter. Id. On March 1, 2023, counsel for 

Judgment Creditor followed up with Mr. Goldstein. Id. The latter advised the former that the 

production responses would be made available to Judgement Creditor by March 8, 2023. Id. 

Thereafter, Judgment Debtor produced documents, but they were not responsive to Judgment 

Creditors’ requests. 

D. Judgment Debtor Produces Inadequate Production Responses 

The documents Judgment Debtor produced were not responsive because they were mere 

supplements of what Judgment Debtor had already produced in this action; namely, documents 

evidencing transactions for some, but not nearly all, of the entities Judgment Debtor has an interest 

in. Critically, the documents produced in early March did not show proof of the transactions 

Judgment Debtor testified to during his deposition wherein he said he used personal finances to 

fulfill “obligations” of entities he owned, operated, managed, maintained, controlled, had an 

interest in or was a signatory to. 

On March 22, 2023, counsel for Judgment Creditor followed up with Mr. Goldstein as none 

of the production responses propounded upon the Judgment Creditor at that time evidenced the 

transactions that Judgment Debtor testified to during his deposition. (Ex. 5, March 22, 2023, and 

April 4, 2023, Correspondence). A week later, Mr. Goldstein finally responded. Id. In his 

response, Mr. Goldstein indicated that Judgment Debtor would have a further formal production 

response by April 4, 2023. Id. That date has come and gone and Judgment Debtor has still not 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 5 of 182 PageID #:3190
6

provided Judgment Creditor with financial documents responsive to Judgment Creditor’s February 

3, 2023, Rule 37 letter. 

E. Judgment Debtor’s Separated Wife Testifies That He Recently Bought a $3.5 Million 

Yacht, Has Control Over Countless Entities and Comingles Personal and Business 

Finances 

Importantly, on March 23, 2023, Judgment Debtor’s separated wife, Ms. Jeanette 

Ivankovich, was deposed. (Ex. 6, Deposition of Jeanette Ivankovich). Ms. Ivankovich 

contradicted many of the Judgment Debtor’s sworn statements. She testified that, contrary to 

Judgment Debtor’s assertions, COVID did not affect their extravagant lifestyle whatsoever. 

Instead, if anything, Ms. Ivankovich testified there was an uptick in their lifestyle. Id. at 10:14-

16; 11:3. For example, Judgment Debtor purchased a $3.5 million yacht on September 30, 2021 

(approximately one month after judgment was entered in this action): 

Q: Okay. So you say here, While I am unclear of Steven’s income from all sources, 

on or about September 30, 2021, Steven purchased a five-bedroom, 150-foot yacht 

for $3.5 million. Do you see that?

A: Yes. 

Q: And as far as you know, that did occur by Mr. Ivankovich?

A: Yes. 

Q: And you, in fact – at that time were you guys still together, or was that –

A: Yes. 

Id. at 24:11-22. 

According to Ms. Ivankovich, “Steven had – he has involvement in everything Atlas.” Id. 

at 42:11-12. Ms. Ivankovich made clear that Judgment Debtor is involved in a plethora of Atlas 

entities: 

Q: Okay. And what are the names of those LLCs that are under the umbrella of Atlas 

Alliance?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 6 of 182 PageID #:3191
7

...

A: Atlas Homes, Atlas Management, Atlas, LLC, Atlas P2, P3, P4, Atlas Caribbean, 

Atlas – I mean, they’re all, right?

Id. at 59:9-16. 

Ms. Ivankovich further testified that Judgment Debtor controlled the transfer of funds from 

a number, if not all, of the entities he has an interest in. Id. at 66:5-9; 84:3-7. Judgment Debtor’s 

own testimony during a trial of an action pending in New York State against one of his entities 

confirmed that he can move monies to and from the entities he owns, operates, manages, maintains, 

controls, has an interest in or is a signatory to: 

Q: How is it that your counsel could represent to this Court yesterday that that entity 

has no assets?

A: The specific entity doesn’t, but the chain of ownership, as I said, has plenty of 

assets. We could populate that entity with the signing of a pen and a phone 

call in a matter of minutes. 

Q: Is it your testimony, sir, in this Court under oath that you have the authority to move 

money as you see fit to that entity or away from that entity?

A: I don’t have the authority, but I have the ability. 

Ex. 7, Excerpt of January 13, 2020, Trial Transcript at 304:8-17. (Emphasis added). 

Additionally, the Judgment Debtor has an interest in the Ivankovich Family LLC. Ex. 6 at 

42:13-24. Remarkably, Judgment Debtor and Ms. Ivankovich never had a personal bank account 

during their marriage. Instead, the couple’s personal finances were always comingled with the 

businesses Judgment Debtor owned, operated, managed, maintained, controlled, had an interest in 

or was a signatory to: 

Q: On that, I guess, as far as when you were married, before the divorce was filed, did 

the – did you guys have a personal bank account?

A: No. 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 7 of 182 PageID #:3192
8

Q: Okay. Were all your accounts through –

A: Business.

Q: Businesses?

A: Yes. 

 

Id. at 31:22 – 32:5. 

Further, according to Ms. Ivankovich, Judgment Debtor’s business expenses are comingled 

with his personal expenses: 

Q: I think you said earlier that as far as you understood there was always somewhat of 

a blur between Mr. Ivankovich’s personal finances and what he would take from 

the businesses.

A: Correct. 

...

Q: But as far as you understood that the – a lot of Mr. Ivankovich’s – Steven 

Ivankovich’s business expenses were intermingled with some of the personal 

expenses?

A: Yes. 

Id. at 33:9-13; 34:14-18. 

That Judgment Debtor comingles his personal finances and business expenses is further 

confirmed by the fact that Judgment Debtor uses his entities to execute long-term apartment leases. 

For example, on May 16, 2019, Judgment Debtor executed a 24-month lease with monthly rent 

costing almost $9,000 a month wherein the tenant was Atlas Holdings Investment LLC. (Ex. 8, 

May 2019 Atlas Lease). The lease identifies Judgment Debtor as the Manager of Atlas Holdings 

Investment LLC. Id. Later, on December 21, 2021, Judgment Debtor renewed a lease with a 

landlord wherein the tenant he acted on behalf of was Atlas Apartment Acquisition, LLC. (Ex. 9, 

December 2021 Atlas Lease). The monthly rent for said lease was $9,000 per month. Id. 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 8 of 182 PageID #:3193
9

To date, none of the documents produced by Judgment Debtor show proof of transfers 

testified to by Judgment Debtor or Ms. Ivankovich. Moreover, the documents produced to date do 

not suggest that monies were transferred to offshore bank accounts from entities Judgment Debtor 

owns, operates, manages, maintains, controls, has an interest in or is a signatory to. However, it 

is uncontroverted that Judgment Debtor has such offshore bank accounts. Ms. Ivankovich testified 

that Judgment Debtor has multiple offshore bank accounts: 

Q: Are there any other entities that we haven’t talked about so far, Ms. Ivankovich, 

that your husband mentioned he had some ownership interest in or control over?

A: I did see approximately seven overseas accounts that Steven had bank numbers to 

on his desk. They were under the heading Overseas Accounts. They had the bank 

account numbers. But at this point – I took a picture of them because we were not 

doing well, and he had already filed for divorce a few times. And I sent it 

somewhere. I don’t recall where I sent it just yet. But there are overseas accounts 

that he must have access to or otherwise he would not have had those numbers. 

Ex. 6 at 43:23 – 44:13. 

ARGUMENT 

I. The Judgment Creditor Should Be Required to Produce Documentation of the 

Testified to Transactions 

“Parties may obtain discovery regarding any nonprivileged matter that is relevant to any 

party’s claim ... and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). “The scope 

of post-judgment discovery is broad and permits the judgment creditor to obtain information about 

the debtor's current and past financial assets which could reasonably lead to the discovery of 

concealed or fraudulently transferred assets.” Cent. States, Se. & Sw. Areas Health & Welfare 

Fund v. Neurobehavioral Assocs., 1997 WL 757879, at *2 (N.D. Ill. Dec. 2, 1997) (citations 

omitted). The Federal Rules of Civil Procedure governing post-judgment discovery are “quire 

permissive,” generally allowing a judgment creditor to obtain discovery from any person, 

including the judgment debtor, as provided in the federal rules or by the procedure of the state in 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 9 of 182 PageID #:3194
10

which the court is located. Leibovitch v. Islamic Republic of Iran, 297 F. Supp. 3d 816, 825 (N.D. 

Ill. February 27, 2018) (citing Fed. R. Civ. P. 69(a)(2)). 

§ 2-1402 of the Illinois Code of Civil Procedure provides a court with broad powers, 

including the power to “compel any person cited ... to deliver up any assets so discovered, to be 

applied in satisfaction of the judgment, in whole or in part, when those assets are held under such 

circumstances that in an action by the judgement debtor the debtor could recover them.” 735 ILCS 

5/2-1402(c)(3). What must be alleged to pierce the corporate veil does not fall within the scope of 

what may be heard in a supplementary proceeding. Star Ins. Co. v. Risk Mktg. Group, Inc., 561 F 

.3d 656, 660 (7th Cir. 2009). The only relevant inquiries in supplementary proceedings are (1) 

whether the judgement debtor is in possession of assets that should be applied to satisfy the 

judgment or (2) whether a third party is holding assets of the judgement debtor that should be 

applied to satisfy the judgement. Id. at 660-61. 

Here, the Judgment Debtor’s testimony highlighted above establishes that he used his many 

millions of dollars of personal liquid assets to pay “obligations” of companies he owned, operated, 

managed, maintained, controlled, had an interest in or was a signatory to. However, the fact 

remains that Judgment Debtor was unable (or unwilling) to recall with specificity which entities’ 

obligations were paid with his personal assets and when. Additionally, it is irrefutable that 

Judgment Debtor comingles his personal and business finances to fund his extravagant lifestyle 

and to pay for high-end rental units. Given this, there must be financial documents evincing proof 

of as much. However, to date, Judgment Debtor’s counsel has failed to produce documents 

responsive to the Judgment Creditors’ February 3, 2023, letter requesting the production of said 

transactions. 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 10 of 182 PageID #:3195
11

The documentation of said transactions is highly relevant to the Judgment Creditors’ claim 

against the Judgment Debtor. The transactional documents will allow the Judgment Creditors to 

establish that Judgment Creditor was both in control of the companies that he used his personal 

assets to pay obligations for and or that Judgement Creditor simply used said companies to hold 

his own personal assets in an effort to avoid paying the instant judgment. Therefore, this Court 

should compel Judgment Debtor to produce said transactions as they are relevant pursuant to Rule 

26 and this proceeding more generally. 

Finally, Plaintiffs ask that this Court extend the hold on the frozen Walker & Dunlop funds 

due to Plaintiffs’ difficulty in obtaining the aforementioned transactional documents. In short, 

Plaintiff has shown there is good cause for this Court to require Walker & Dunlop to hold the funds 

for an extended period of time. See Ill. S. Ct. R. 277(f) (permitting the Court to “grant extensions 

... as justice may require.”). 

WHEREFORE, Plaintiffs/Judgment Creditors, ZHU ZHAI HOLDING LIMITED and 

PETER PUI TAK LEE, respectfully request this Court enter an order extending the hold on the 

Walker & Dunlop funds and requiring Judgment Debtor to produce the following: 

1. Documentation evidencing any and all transactions made by Judgment Debtor to 

or from entities he owned, operated, managed, maintained, controlled, had an interest in or was a 

signatory of from 2018 to the present; 

2. Documentation evidencing any and all transactions made by Judgment Debtor to 

or from the following entities from 2018 to the present:2

 Overlook Managing Member LLC

 PILGRIM Windtree LLC

2

 Attached hereto is Plaintiffs’ Exhibit 10. Of import, said exhibit is from the website https://opencorporates.com. A 

search of “Steven Ivankovich” on the website indicates that Judgment Debtor is or was an officer of at least 115 

different entities. It is immaterial that many of the entities are inactive as the inactive entities might still conduct 

transactions or maintain bank accounts. 

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 11 of 182 PageID #:3196
12

 PILGRIM Coulter LLC

 PILGRIM Warrick LLC

 PILGRIM Caribbean Isle LLC

 PILGRIM Forest Park LLC

 Alliance HTTX GP, LLC

 Alliance HTFL GP, LLC

 Alliance HTTX Limited Partnership

 Alliance HTFL Limited Partnership

 Atlas Apartment Acquisitions LLC

 Atlas Apartment Homes LLC

 2519 Halsted Properties LLC

 Tyler Atlas, LLC

 Alliance SH 2GP, Inc.

 IMG Marine LLC

 J&S Family LLC

 Atlas Residential Solutions Management UK Limited

 Atlas Residential LLC

 Alliance Residential Management LLC

 April 2022 Sale of PILGRIM Caribbean Isle LLC, PILGRIM Forest Park LLC 

and Cypress Lakes 

 Glencoe Family LLC

 A&O Family LLC

 Consilient Holdings Investments LLC

 Atlas P2 Managing Member LLC

 Atlas Holdings Investments LLC

3. Documentation evidencing any and all transactions made by Judgment Debtor to 

or from JP Morgan Chase & Co. from 2018 to the present. 

Dated: April 24, 2023 Respectfully submitted,

/s/ Amir Tahmassebi

Amir Tahmassebi, Bar #6287787

Konicek & Dillon, P.C.

70 W. Madison, Suite 2060

Chicago, IL 60602

(312) 328-9166 (Direct)

(630) 262-9659 (Fax)

amir@konicekdillonlaw.com

Steven Lammers, Bar #6294413

Mandel Rauch & Lammers, P.C.

704 Adams Street, Suite F

Carmel, IN 46032

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 12 of 182 PageID #:3197
13

(317) 581-7440 (Direct)

(317) 848-6197 (Fax)

slammers@mhmrlaw.com

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 13 of 182 PageID #:3198
14

CERTIFICATE OF SERVICE

I, the undersigned, hereby certify that a true and correct copy of the foregoing was filed 

with the Court on April 24, 2023, causing all counsel of record to be served via the Court’s 

CM/ECF filing system. 

/s/ Amir R. Tahmassebi

Amir R. Tahmassebi

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 14 of 182 PageID #:3199
A

A

A

A

A A

A

A A A

A A A

W

Y A A A

A A

A

Y A

A WA A

A Y A A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 15 of 182 PageID #:3200
A A A

A

Y A W A

A A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 16 of 182 PageID #:3201
A

A A Y A

A Y

A

WA

W

Y

A

A Y

w

A A w

A A

A A

w

A A W w w

A w w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 17 of 182 PageID #:3202
w

w

A A

w Y A

W w w w

A A

A A

w

w w A

A A Y

w

A

A A

w

A Y

A A Y

Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 18 of 182 PageID #:3203
A

w w

w

W

w w

w

w w

w

A

A A

A A w w

Y A A

A

A w

A

A w

A

A

A w

A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 19 of 182 PageID #:3204
A

w

W

A A

Y A A

A

W w

A w

A w

A w

A w w w

A

A w

w

w w

w

A A w w

A

A A Y w w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 20 of 182 PageID #:3205
Y A A

Y

w

A Y

w

A

w

w

w w

Y A A

w w

w

A

A

A Y

A w w

A Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 21 of 182 PageID #:3206
A

A A

A

A A w

A A A

A

w A

A w

Y A A

A w

A

A

w

A w

w w

w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 22 of 182 PageID #:3207
A

w w

A Y

W w

A

w Y

w w

W

w w

A

Y A A

A Y

A A

A

A A

w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 23 of 182 PageID #:3208
w

W

A

w

A A

Y A A

A w

A w

w W

w

A

A w A

A Y

A w

A Y

A

A Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 24 of 182 PageID #:3209
A A

A A

w

A A

A

Y A A

A

A

A

A w w

A

w

A

A w

A

A

A

A

Y w

w w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 25 of 182 PageID #:3210
w

A

Y

A Y

A

A

w

w

A

A A

Y

w w

A w

A A w

w

A w w

w

A A

w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 26 of 182 PageID #:3211
A A

Y

Y A A

A

w

A

A

Y A A

w

Y A A

A

A

A

A

w

A A Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 27 of 182 PageID #:3212
w w

w

w

A A

Y A A

A

A

w

A

A

w

A

A

w

A

W

w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 28 of 182 PageID #:3213
w w

w w

A Y

w

A

w A w w

A w w

w

w

A

A

A

A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 29 of 182 PageID #:3214
A Y w

A

A

A w

w A w

A

W

A W

w w

w

A w

A

W

A A w

w

w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 30 of 182 PageID #:3215
A

Y w

w w w

W

w

A A

Y A A

A w w

w

A

A

A w

A

A

A W

Y

A

W

W

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 31 of 182 PageID #:3216
W

w

W

Y A A

A

w

w

A A A

w A

w A

A Y

A w w w

A

A

w

w

A

W w w

w w w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 32 of 182 PageID #:3217
A

w

W w

A

w

A Y

w

A w W

A

A

W

A w

A w W W w

A w

A

A A

A

A w A

A

A

A A w A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 33 of 182 PageID #:3218
A

A

A

W

A w

w w w

W W w

w

A Y

A w A

w w

A w

w Y

Y

A

Y W w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 34 of 182 PageID #:3219
A Y

A

Y

A

A w w

A w w

A W

w A w

w w

A

Y w

A

A w

A Y

A

w

w

A Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 35 of 182 PageID #:3220
w

A w

Y

A

A

W w w

A w w

A

A

w

A

w

A Y

w

w W

w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 36 of 182 PageID #:3221
A Y

w

w W

A A w

w

W

W w w

w

A

A w

w w

w

A Y

A W

w

w

A A

w

w w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 37 of 182 PageID #:3222
W w

A

A W

A w

w w

W

A

A W

w w w

w w

w

A A

A w

A

A w

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 38 of 182 PageID #:3223
w w w w

w

w Y

w

w Y

WA Y w

Y

w w

w

w

w w

W

WA

Y

WA

w w

WA

w w

w

w w

Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 39 of 182 PageID #:3224
WA w w w w

w w

W

WA

w

w

w

w

w

WA

w w w

w w

w

w

w w

w A

w

WA

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 40 of 182 PageID #:3225
WA Y

A A

w w

W w

Y

A A w

w

A A

A A

A

Y Y A

WA

A Y A W

A w

w w

A A

A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 41 of 182 PageID #:3226
AY

A w

w w A

A A

Y A A

w w

w A w

w w

A

w w w

A w w

A

A w

A

A

A W

A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 42 of 182 PageID #:3227
w

A

A Y

A Y

A A

w

Y

A

A

A

w W

w w

A Y

A

A w

W

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 43 of 182 PageID #:3228
A w

W w

A

A

w w

A

w

A

WA w

w

A A

W

A

Y A A

A

A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 44 of 182 PageID #:3229
A w w

w

A

Y

A

w

A Y

A w w

w

A

w

w

w

A

w A

w

w w

w A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 45 of 182 PageID #:3230
w A

w w w

w

W w

A

w w

w w

w w

A w w

A

A A Y Y

W w

w

w w A w

w

w w w

W w

A A Y

w A

w w

A A

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 46 of 182 PageID #:3231
A

A A W w

A Y

A Y

w

A

A

Y w

w

W

w

A

w

Y

A Y

Y w Y w

w Y

w

w A

A Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 47 of 182 PageID #:3232
W

w

w Y

A

Y Y

A Y

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 48 of 182 PageID #:3233
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 35

(WHEREUPON, an exchange of reporters took place; after

which the following proceedings were held in the jury room:)

BY MR. TAHMASSEBI:

Q Okay. If we can go back to Exhibit No. 6,

Mr. Ivankovich, the Atlas P5 Portfolio asset summary --

COURT REPORTER: I'm sorry, you have to speak

louder.

MR. TAHMASSEBI: Oh, I'm sorry.

BY MR. TAHMASSEBI:

Q Yeah, the asset summary, Atlas P5 Portfolio. These --

they list five different -- at the first page, it lists five

different properties, five assets, 1,208-unit Multifamily

Portfolio. Was this -- were these units built,

reconstructed, whatever the case?

A Were they built or reconstructed?

Q Yes.

A I don't understand the question.

Q Sure. Did the -- when we talk about the 448 units, 188

units, 152, 276, 144, were those -- are those units that

exist today?

A I believe they do exist today, yes.

Q Okay. And did you or any of the entities you have an

affiliation with have an interest in that portfolio?

A Yes.

Q Okay. And which entities -- I'm assuming because you

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 49 of 182 PageID #:3234
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 36

don't do anything individually that you individually had no

interest in that P5 Portfolio; is that accurate?

A Correct.

Q Okay. And then what entities that you are affiliated

with, in fact, did have an interest in the P5 -- Atlas P5

Portfolio?

A I don't know sitting here right now. I'd have to go

back and look at the organizational charts.

Q All right. Does the entity Pilgrim LLC ring a bell?

A Not --

COURT REPORTER: I'm sorry, you have to speak

clearer.

THE WITNESS: I'm sorry. Not Pilgrim LLC.

BY MR. TAHMASSEBI:

Q Pilgrim Wind Tree LLC.

A Yes.

Q Okay. That has an interest in the P5 Portfolio?

A I don't think so. Not directly.

Q Okay. Has the P5 Portfolio -- strike that. Have any of

the Pilgrim entities -- I'm going to list them for you --

Pilgrim Wind Tree, LLC, Pilgrim Coulter LLC, Pilgrim Warwick

LLC, Pilgrim Caribbean L -- Isle, LLC, and Pilgrim Forest

Park LLC, those are all entities that you have an interest in

through a company called Overlook Managing Member LLC,

correct?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 50 of 182 PageID #:3235
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 37

A Correct.

Q Okay. And then the ownership of Overlook Managing

Member LLC is 95 percent you approximately, 90 -- I think

it's 97 percent now and the remaining percentage to a

gentleman named Romaniello, R-o-m-a-n-i-e-l-l-o, correct?

A I don't think Gary Romaniello owns any part of Overlook

directly.

Q Okay. Is your interest still in the 90, 95 percentile

range? Is it --

A Yeah. It's in the 90s. It's not 100 percent.

Q Okay. Who is the other member then of Outlook?

A There's a corporation whose name escapes me, I believe.

Q Now the assets listed on Exhibit No. 6, the five

properties, have any of those been sold since the year 2019?

A Yes. Caribbean Isle; Forest Park.

Q And when were they sold?

A In -- oh, I can't tell you the exact date.

Q Give me a ballpark.

A End of 2021, beginning of 2022.

Q And did any entities that you have an interest or

affiliation with receive proceeds from the sale of either the

Caribbean Isle or Forest Park properties?

A Yes.

Q Okay. And which entities were those?

A The document -- the entities you mentioned on the

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 51 of 182 PageID #:3236
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 38

organizational chart.

Q Okay. So the five entities that I mentioned each

received proceeds?

A I don't know if it would have been all five but

certainly some of those entities would have.

Q And where were those proceeds paid from, was it from

Walker Dunlop that ultimately paid -- in other words, who

sent the money, who sent the check, Walker Dunlop or some

other entity?

A Probably -- well, maybe. I don't know actually sitting

here where those proceeds came from.

Q Okay. Who at Pilgrim Wind Tree LLC would know how they

received the proceeds?

A Probably one of the attorneys that handled the closing.

Q Okay. Who was that?

A It would have been Cadwalader, Wickersham & Taft.

Q I'm sorry. Did you say Cad --

A Cadwalader, Wickersham & Taft were the attorneys --

COURT REPORTER: Can you spell that for me?

THE WITNESS: C-a-d-w-a-l-a-d-e-r, comma,

Wickersham, W-i-c-k-e-r-s-h-a-m, ampersand, Taft, T-a-f-t.

BY MR. TAHMASSEBI:

Q And who was the individual at that firm that handled

that?

A Okay. I don't think there was one individual. I think

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 52 of 182 PageID #:3237
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 39

there was numerous. I can't -- I don't even know the names

of the people that --

Q And they represented the Pilgrim LLCs at the closings?

A Yeah.

Q And give me one individual if you can, Mr. Ivankovich.

A I actually -- I had no contact with the lawyers

directly.

Q Who did have the contact with the lawyers?

A A gentleman named Mark Brown.

Q And who is Mark Brown?

A Mark Brown is another manager of this organizational

chart.

Q Okay. What -- and so the organizational chart, just so

we're on the same page and the record is clear, if you look

at Exhibit 9. And I see you saw what I was looking at --

A Oh, yes.

COURT REPORTER: I'm sorry, I didn't understand

you.

MR. TAHMASSEBI: Oh, sure.

BY MR. TAHMASSEBI:

Q Exhibit 9, that's the organizational chart you and I

have been referring to, fair?

A Uh-huh.

Q Yes?

A Yes.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 53 of 182 PageID #:3238
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 40

Q And this is an accurate representation as far as you can

say today of the organizations with the exception of

Mr. Romaniello still being a member of Overlook?

A Yeah. I don't think that part is correct. I --

Q Okay. Let's do this so we're not getting too much in

the weeds. As far as the Pilgrim entities, the five Pilgrim

entities, Overlook and you having a 95 percent interest in

Overlook, Overlook having 100 percent interest in the P --

five P entities, that part is accurate?

A Approximately, yes.

Q How much did the Pilgrim entities receive as a result of

the sale of part of the P5 -- Atlas P5 Portfolio?

A I don't know.

Q Who would know the answer to that how much money P5

received?

A Maybe Mr. Brown. I don't know specifically.

Q All right. Who else had involvement in the closing of

those properties besides Mr. Brown and the lawyers, if

anybody?

A I don't think anybody else. I mean, I would imagine

Walker Dunlop as well since they were repaid their loan.

Q Do you know what those properties sold for?

A I don't.

Q Since Pilgrim received funds from the sale of the

Caribbean Isle, Forest Park properties, had they transferred

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 54 of 182 PageID #:3239
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 41

any money out of any accounts that they hold?

A I don't know.

Q Who would know the answer as to whether or not money has

been transferred from the P5 accounts?

A Probably Mr. Brown as well.

Q Where is Mr. Brown located?

A Colorado.

Q Where in Colorado?

A I believe Colorado.

Q Okay. Where in Colorado?

A An area called -- what's the name of the town? Give me

a moment to try and recall the town.

Q Sure.

(Brief pause.)

THE WITNESS: It's a small town near Breckenridge,

Colorado. I don't know the specific name of the town.

BY MR. TAHMASSEBI:

Q Do you know what company he's affiliated with?

A Yeah, of the -- of Atlas -- Atlas Apartment Homes LLC.

Q Who was the managing member of the P5 entities?

A I don't know. I don't believe there was a managing

member. I believe it was the corp -- I think the corporate

managing member. I'd have to look at the documents, but I

think there was a corporate managing member. I don't think

there was an individual. I don't know specifically.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 55 of 182 PageID #:3240
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 42

Q Who handles the accounting for the Pilgrim, the P5 LLCs?

A Currently or in 2017?

Q Both, if you could.

A In 2017 it would have been a company called RealPage.

Q Where are they out of?

A I don't know.

Q Who was the individual at RealPage that handled the

accounting?

A I don't know.

Q Okay. How about today?

A It's in-house with Alliance -- not Alliance. With Atlas

Apartment Homes LLC --

Q Atlas --

A -- but I'm not entirely sure.

Q Atlas Apartment Homes LLC, is it still operating?

A I believe so.

Q Is that bank accounts?

A I don't know. I would imagine so. I don't know.

Q Well, who would know if Atlas Apartment Homes LLC has

any --

A Mr. Brown would.

COURT REPORTER: I'm sorry, I couldn't understand

you.

MR. TAHMASSEBI: Sorry. I keep putting my mouth --

COURT REPORTER: I know it's a little informal.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 56 of 182 PageID #:3241
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 43

You probably feel like it's informal in here but I have to

take a record.

MR. TAHMASSEBI: No, I don't feel like it's

informal. Less formal than out there, I suppose.

COURT REPORTER: Exactly; so just reminding you.

BY MR. TAHMASSEBI:

Q So Mr. Brown would be the individual that knows about

the finances of Atlas Apartment Homes LLC, correct?

A Yes.

Q Do you know who the accountants are for Atlas Apartment

Homes LLC, the same ones that we already mentioned or is

there somebody new?

A It changed from RealPage to another provider but I don't

know specifically which provider it changed to.

Q In 2020, did you have interest in any other real

estate -- strike that. In 2020, did you or any entity you

have an interest in have any other real estate holdings?

A Yes.

Q Okay. Tell me about those.

A Similar apartment complexes to the ones on this page.

Q Well, where are they, how many are there, things like

that?

A Oh, Texas, Florida, Illinois that I recall.

Q And then how were those -- how was that real estate

held, in a company, in a corporation?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 57 of 182 PageID #:3242
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 44

A Yeah, that's -- I suspect that would have been the case.

Q In which entity that you have an interest in has an

interest in those real estate holdings?

A Oh, I couldn't tell you sitting here. I'd have to go

back and look. There's quite a few.

Q Well, when you say "quite a few" --

A It's similar to the org chart that we're looking at

right now that says "Pilgrim V Portfolio Organizational

Chart."

Q Okay. So Exhibit 9 is an organizational chart that

covers kind of the P5 Portfolio; is that right?

A Correct.

Q Okay. And then for your holdings in Texas, Florida, and

Illinois, you have another kind of myriad of LLCs that have

different ownership interests?

A Yes.

Q And then ultimately in that myriad of LLCs that have

those ownership interests, are those also 100 percent owned

by Outlook or are they 100 percent owned by a different

entity?

A No, no. This would have -- it would have been a

different entity.

Q Okay. And then the -- that entity that's at the top,

like Outlook is here, who would be the majority owner of that

entity you, you, correct?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 58 of 182 PageID #:3243
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 45

A I don't think Outlook. I think Overlook Managing Member

LLC which -- I'd have to see the documents -- seems to be the

manager of the Pilgrims to your previous question.

Q I'm sorry. I misspoke. Overlook is the --

A Yeah.

Q -- 100 percent owner of the other myriad of LLCs?

A Yes.

Q In your other holdings in Texas, Florida, and Illinois,

do you ultimately have a parent company that owns 100 percent

the other LLCs below it?

A I think every structure is different based on the

ownership structure.

Q Well, that's what I'm trying to find out so -- and you

said you have three or four other properties but you might --

A I did at the time. I don't anymore.

Q Do you have any real estate holdings currently?

A Individually, no, except for my home on Menomonee Street

in Chicago. There's a residential residence; not my home.

Q No. I'm not talking individually. Let me make a clear

question. Do any of the entities that you have an interest

in currently have real estate holdings today?

A Yes.

Q Okay. And what are the names of those entities?

A I believe just Overlook Managing Member.

Q Okay. Is Overlook Managing Member 100 percent owner of

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 59 of 182 PageID #:3244
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 46

other entities aside from the P5 LLCs that are depicted on

Exhibit 9?

A I don't believe so, no.

Q Okay. And there's -- is there another parent company --

what I'm trying to find out is what LLC owns the property in

Texas, what LLC owns the property in Florida, what LLC owns

the property in Illinois?

A Well, that owned. That was previously. So Overlook

Managing Member owns Pilgrim Wind Tree, Pilgrim Coulter,

Pilgrim Warwick, which owned three properties in Texas and

that's it.

Q And that's all that is currently -- you currently have?

A Correct.

Q What's the value of those properties in Texas?

A Oh, I have no idea. I'm not sure the last time it was

valued.

Q Where are they located?

A That's a good question. I believe Abilene and Amarillo,

Texas.

Q Who manages those properties?

A Atlas -- Atlas Apartment Homes LLC.

Q Is Atlas Homes LLC also the entity that would collect

the rents for those properties?

A No.

Q Okay. What's the name of the entity that would collect

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 60 of 182 PageID #:3245
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 47

the rents for those properties?

A I believe the rents go into the Pilgrim Wind Tree LLC,

Pilgrim Coulter LLC, and Pilgrim Warwick LLC companies.

Those would collect the rents.

Q And those three Pilgrim entities are still collecting

rents today?

A I hope so. I don't know.

Q Okay. All right. You would expect so, right?

A After COVID, I don't expect anything anymore.

Q Okay. And then those three entities or all five

entities I think we said are 100 owned by Overlook Managing

Member LLC?

A That's correct.

Q All right. Do you currently own any other properties

today? Let me ask it again. Did any entities that you have

an interest in currently own any other properties today?

A No.

Q What is your membership interest in Atlas Apartment

Homes LLC?

A I don't know specifically. I don't remember.

Q Who handles the accounting for Atlas Apartment Homes

LLC? I think I asked you that but --

A Again, it would have been one of the vendors or

RealPage, or whoever is doing it now.

Q And Mr. Brown would know the answer to that if you can't

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 61 of 182 PageID #:3246
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 48

answer it?

A Yes.

Q Let's go back to Exhibit 3 and I want to talk about

the -- by the way, just so we're clear, if you look at

Exhibit 3, Mr. Ivankovich, there's a Bates stamp at the

bottom, at the very bottom right that says "Ivankovich 248,"

do you see that?

A I do.

Q Do you understand this was a document produced by your

attorneys in this litigation before the judgment was entered

against you?

A I don't.

Q Did you know that your lawyers represented that this was

a true and accurate copy of your financials -- personal

financials in August -- on August 26th of 2020?

A I do not.

Q Did you know there was a court order requiring you to

produce this accurate financial statement in the year August

26th of 2020?

A It's possible I knew then. I don't recall.

Q It's possible you knew back at the time this personal

financial statement was produced that it, in fact, had to be

signed and attested to and produced, fair?

A I -- I actually don't recall that.

Q Let's look at the fourth page. In the second -- well,

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 62 of 182 PageID #:3247
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 49

let's look at Schedule A and I know it's a little difficult

to read.

A I got it. I got my readers on.

Q Okay. All right. Good. There -- it talks about "Cash,

Checking and Saving Accounts, Certificates or Deposits, Money

Market Funds" and then the total that's listed there on this

personal financial statement is $1,103,196. Do you see that?

A Yes.

Q And that was accurate in 2020 for the amount of cash,

checking and savings that you had?

A Sounds accurate.

Q And today is that money still in a cash, checking or

savings account today?

A No.

Q Do you have a bank account today?

A No.

Q Do you have any personal assets today?

A My interest in my home. Well, in the home on -- in the

real estate owned jointly with my wife on Menomonee.

Q So you were served with this complaint in September of

2020, the complaint that was filed by my clients?

A Yes.

Q Okay. And at what point in time did you transfer money

from these cash, checking and savings accounts listed on

Exhibit 3, Page 3? Page 4, excuse me.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 63 of 182 PageID #:3248
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 50

A When you say "transfer," would you be more specific?

Q Sure. As of 2020, you had $1,103,196 according to your

personal financial statements, right?

A Yes.

Q And today you're telling me you have zero, right?

A Correct.

Q And when was this money transferred out?

A Well, it was spent over the course of 2020, 2021 to

pay bills --

Q Okay.

A -- to pay obligations of the companies.

Q So you used your personal funds to pay obligations of

the companies?

A Yes.

Q Okay. And that was through 2020 and 2021, correct?

A It started in 2019 as well.

Q Okay. And then -- and then what -- who was the one that

authorized payment of your personal funds to pay obligations

of the companies, it had to be you, right?

A Yes.

Q And how did you transfer funds to these companies --

well, which funds did you pay expenses for or obligations

for, which corporations?

A All of them.

Q And how were the funds transferred?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 64 of 182 PageID #:3249
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 51

A It would have been any way transferring funds. It would

have been just bank transfers, wire transfers, check, you

know, any means people use to pay bills.

Q The cash on hand, the 500,000, where was that held in

2020?

A Good question. It could have been --

COURT REPORTER: I'm sorry, can you take your hand

away?

THE WITNESS: Oh, I'm sorry. Good question. It

could have been either -- probably Glenview State Bank.

BY MR. TAHMASSEBI:

Q Anywhere else?

A No. That's probably where I kept my -- most of the cash

accounts.

Q Here in Glenview, Illinois?

A Yes.

Q And then if you go down to Schedule B, it talks about

"Marketable Securities, Stocks, Bonds, U.S. Government" and

the total market value you have is $11 million, do you see

that?

A Yes.

Q This is again on your personal financial statement?

A Yes.

Q And today, Mr. Ivankovich, do you still have that $11

million in marketable securities, stocks, bonds, and U.S.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 65 of 182 PageID #:3250
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 52

government?

A No.

Q Okay. And are you telling me then between again 2020

and today August 2022, all of that money was transferred out?

A It was used to pay bills.

Q Okay. And what bills was it used to pay?

A Payroll for the companies, mortgage payments, reserve

payments, just the expenses of the companies when everything

shut down during COVID.

Q You knew in 2021 -- excuse me, in 2020, August -- 2020

September that there was a lawsuit filed against you, right?

A Which lawsuit specifically?

Q This lawsuit, I'm sorry, the one we're sitting here for.

You were served in September of 2020 with this lawsuit, okay?

A Yeah. I know -- I remember the court call with Coleman

where you guys alleged to serve me but I don't think I was

ever personally served with the summons for this.

Q Well, if you remember the court call, you were aware of

the lawsuit?

A I was aware of the lawsuit and the court call, yeah,

whatever that date was.

Q Okay. Well, it was sometime in September of 2020?

A Yes.

Q In any event, after that date you continued to transfer

money from certain accounts, right?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 66 of 182 PageID #:3251
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 53

A I continued to pay obligations, yes. I continued to pay

bills.

Q And then where would I find the transfers that you made

of the $11 million between -- and those transfers that were

made were made between August 2020 and all the way up through

present?

A No. I would have said probably to the end of COVID,

whenever that is, that sort of 20 --

Q Well, any that date. 2021?

A Through the end of 2021.

Q Okay. So through the end of 2021, you continued to make

transfers in your eyes to pay bills of the companies you had

an interest in?

A No, not in my eyes. That was what the payments were

for.

Q And then what companies of the $11 million did you

transfer money to specifically or LLCs specifically?

A Did I transfer to?

Q Yeah.

A I don't know sitting here.

(Counsel conferring.)

BY MR. TAHMASSEBI:

Q Oh, yeah. What entities were you paying bills for in

2021, 2022?

A The Atlas entities, the entities that owned apartment

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 67 of 182 PageID #:3252
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 54

complexes where there was debt and payroll obligations.

Q And those -- and those -- that and payroll obligations

you were making payments from your personal finances through

approximately December 2021, January 2022, fair?

A No, no, before that but toward the end of the third

quarter 2021, maybe beginning of the fourth quarter. I was

getting notices by the Department of Labor.

Q Okay. You were paying, let's just say after -- it went

into October, November 2021 when you were paying bills

through your personal finances?

A Something like that. Maybe sooner than that.

(Counsel conferring.)

BY MR. TAHMASSEBI:

Q Oh, yeah. So there's two, under Schedule B, the stocks,

it says they were held in -- is it Stifel and Oppenheimer?

A Yes.

Q And that was an account -- that was in your account at

Stifel and Oppenheimer?

A It wouldn't have been in my name personally. It would

have been probably a trust account.

Q But you had the ability personally to make the decision

to use those funds for other obligations of entities you had

an interest in?

A No.

Q Okay. All right. I'm going to leave it at that. The

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 68 of 182 PageID #:3253
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 55

last schedule, Schedule G, do you see that three quarters of

the way down?

A Yes.

Q The third one is Atlas P5 Portfolio. That's the

portfolio we had just been discussing, right?

A Yes.

Q All right. And that's valued at approximately

$29,140,000 in your personal financial statement, do you see

that?

A Are you saying that is the value of the portfolio?

Q I'm sorry. That's what it is listed as your -- the

value of what your ownership was. Maybe I wasn't being

precise.

A Correct.

Q Okay. So the value of what your ownership was in the

Atlas P5 Portfolio, so we're clear, was listed in August of

2020 as 29,140,000?

A Yes.

Q All right. And then if we go down the rest of the

properties -- and I'm going to list them -- Alliance Holding

HT LLC, Atlas P --

A I'm having a tough time reading this but I think what I

see, it says Atlas P5 Portfolio, that would have been -- my

interest would have been held in the Deerfield irrevocable

trust.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 69 of 182 PageID #:3254
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 56

Q Okay. I'm beyond that at this point.

A Okay. Well, that's just to clarify the question. I'm

having a tough time reading this but I'm -- yes.

Q Okay. All right. So if we go through the -- there's

another one. I'm just going to read the entities so we have

a clear record.

A Uh-huh.

Q Alliance Holdings HT LLC is the entity listed. Atlas P2

Managing Member LLC is an entity listed.

A Yes.

Q Atlas Birchwood LLC is an entity listed, right?

A Yes.

Q Atlas Multifamily 3 LLC is an entity listed?

A Yes.

Q Hazardous Sports LLC is an entity listed?

A Yes.

Q HC -- S Venture Incorporated is an entity listed?

A Yes.

Q Modline (sic) International S.A.M. is an entity listed.

Am I saying that right?

A Yeah. I'm not seeing --

MR. WANDNER: Modulac (sic).

MR. TAHMASSEBI: Modulac (sic), yeah.

THE WITNESS: I can't tell what that is, that word

is.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 70 of 182 PageID #:3255
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 57

BY MR. TAHMASSEBI:

Q Okay. All right. That's a small "l."

MR. TAHMASSEBI: What's the next one, Steven?

BY MR. TAHMASSEBI:

Q Gesterchel (phonetic) LLC is an entity listed.

A I'm not -- yeah, I can't make out that word.

Q Okay. Atlas GP SCI is an entity listed, right?

A Yes.

Q Gruppo C'E Incorporated is an entity listed?

A Yes.

Q And ZIP LLC is an entity listed, right?

A Right. Yes.

Q And under all those entities that I listed, your

personal financial statement under Ownership states your

name, correct?

A Not entirely, no.

Q Mr. Ivankovich, if you look at the document, there's a

column called Ownership.

A Yes.

Q In the ones that I listed, the last one, two -- so you

start from the fourth one down, Atlas Alliance Holdings HT

says the owner is Steven Ivankovich. Do you see that?

A Yes. From the fourth one down, that's correct.

Q Okay. So from the fourth down, all those entities that

I just listed under Ownership in your personal financial

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 71 of 182 PageID #:3256
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 58

statement it states your name, right?

A Correct.

Q Okay. Do you still have an ownership in all of those

entities that are listed under Schedule G?

A In so much as the entities exist, I probably do.

Q The last page, TRG International, what does that do real

quick?

A Nothing anymore. It used to be a real estate

development company here in Chicago.

Q ZIP LLC, same question.

A It used to run a sports car team.

Q Is it around anymore? It doesn't look like it.

A It doesn't exist, no.

Q Do any of these entities listed on schedule -- on

Schedule of Officer Positions exist at the present time?

A They're not active. I don't know if they still exist on

the register of companies but they're not active companies.

Q When was the last time one of these companies was

active?

A I don't know.

Q Just give me a ballpark, two years ago, five years ago?

A Based on this document, probably 2013.

Q So in the year from August 2020 until the end of 2021,

your net worth went from approximately 55,367,404 to pretty

much zero; is that right?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 72 of 182 PageID #:3257
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 59

A Correct.

Q And your explanation for that is because you made

transfers in order to meet the obligations of the companies

in which you had an interest?

A My explanation of that is COVID.

Q My question is a little bit different. The money had to

go somewhere, right?

A Yes.

Q And your explanation as to where the money went was the

money was transferred in 2019, 2020, 2021 -- strike that.

Your explanation of what happened to the -- your $55 million

net worth that you indicate on your signed financial

statement in 2020 is that that money was transferred to pay

obligations and expenses of LLCs in which you had an

interest, correct?

A Well, no. 55 million wouldn't have been transferred.

You're -- I think you're -- it's not correct. It's not a

correct statement.

Q Well, let's -- let's find out why because again, your

net worth is 55,367,404 as of August of 2020. Today you're

telling me your net worth is almost zero, right?

A Yes, but that's not because I transferred 54 million

dollars of cash. That $54 million doesn't represent my net

worth as being cash.

Q Well, I understand that. Then do you still hold

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 73 of 182 PageID #:3258
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 60

securities, stocks, other real estate that gives you a net

worth of anything?

A I'd like to think that maybe the three companies in

Texas have some -- have a value but I don't know what it is.

Q When you say "the three companies in Texas," what are

you referring to?

A The three companies that are left at the bottom of the

organizational chart of the P5 Portfolio.

Q Who would have an idea of what those three companies are

worth?

A I don't know. An appraiser.

Q You're in real estate but you have no idea about what

these entities that you're invested in might be worth?

A I have an idea but I haven't looked at the financials.

I mean right now based on the financial condition as I know

it, they are probably worth zero.

Q Okay. Exhibit 6 -- again, you can go to it if you want

but I'm just going to read it -- Page 12, Walker Dunlop says

that you -- and this is about five paragraphs down.

A What page is this?

Q Sure. Page 12 of Exhibit 6.

A Yep.

Q It says you have been involved in -- this is under

Comments -- over 7 billion of property transactions to date

and have overseen annual construction and renovation budgets

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 74 of 182 PageID #:3259
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 61

in the tens of millions of dollars; is that true?

A It is true.

Q But as you sit here today, you believe your net worth is

limited to the three properties in Texas that we talked about

of the P5 that are left and whatever equity you have in your

current home?

A Correct.

Q And so today, your net worth is nowhere near the 55

million 367 it was in August of 2020, is that your sworn

testimony?

A Unfortunately, that's not the net worth. That is my

sworn testimony; yes.

Q These entities -- you mentioned COVID, Mr. Ivankovich.

COVID, are you saying -- these are residential properties,

right?

A Correct.

Q And you're saying COVID caused the downfall of these

residential properties somehow?

A Correct.

Q Okay. And so the residential properties are all in --

sounds like most of them are in Texas or Florida, right?

A And Illinois, yes.

Q Well, how many are in Illinois?

A Not anymore.

Q Okay. The majority of your portfolio back in 2020 and

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 75 of 182 PageID #:3260
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 62

2021 was in Texas and Florida, right?

A Correct.

Q And you're telling me that because of COVID, those

properties in Texas and Florida no longer were able to be

profitable?

A Not only profitable but they were negative, yes.

Q Who has the financial statements for those properties to

show that they were negative and received your funds in 2021?

A You could get those from Mr. Brown, Mark Brown.

Q And then that should also reflect you'll receive from

Mr. Brown money that you paid in to those companies in 2020,

2021, right?

A It should, yes.

Q And the market in Texas and Florida, I'm assuming it's

your sworn testimony based on your education and experience,

when COVID hit, the residential market went down, not up?

A Well, this is a -- these buildings are an aspect of the

residential market called multi-family so they're

commercialized residential. They're not single-family homes.

Q What was the occupancy rate in the Texas and Florida

properties in 2020, 2021, do you have any idea?

A I don't know but I recall that the occupancy and more

importantly the economic occupancy dropped almost to zero.

Q In your -- as you were transferring this 58 million in

2020 and 2021 or approximately that amount of your personal

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 76 of 182 PageID #:3261
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 63

assets, who was making the requests on behalf of these

entities?

A I never transferred $58 million.

Q How much did you transfer? How much from your total --

your total net worth as shown is 58 million. Today you're

telling me it's almost zero. How much money did you

transfer, Mr. Ivankovich, in 2020 and 2021 to go from 58

million to nearly zero?

A To clarify your statement, the financial statement you

showed me and as it read was approximately $11 million of

liquidity and the rest was interest in unmarketable

securities, mostly these real estate assets. So the cash

portion of that was used to pay the deficits of the apartment

companies and --

Q Which ones?

A All of them in the Atlas world, if you will. Anywhere

there was an employee employed by Atlas or a building owned

by an Atlas entity, I had to make payments to subsidize those

buildings and to pay debt service, so.

Q You individually were paying those employees?

A Yes. Well, no. That's not true. The proper

channels --

Q Now it's not true?

MR. WANDNER: Counsel, let him answer the question.

THE WITNESS: There would have been a capital call

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 77 of 182 PageID #:3262
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 64

made from those entities. I would have funded those entities

who would have then in turn pay the obligations of those

entities.

BY MR. TAHMASSEBI:

Q Who made the capital call?

A The company.

Q When were they made? When were these capital calls

made?

COURT REPORTER: I'm sorry, I didn't hear you.

MR. TAHMASSEBI: Oh, sorry.

BY MR. TAHMASSEBI:

Q Yeah, when were these capital calls made?

A Beginning -- it was a routine part of business.

(Interruption in proceedings.)

THE WITNESS: These companies had capital calls

starting going back to 2016 as a normal part of business and

escalated during COVID.

BY MR. TAHMASSEBI:

Q Who made the decision as part of these entities to make

the capital call, was that you?

A No, not solely.

Q Okay. Who else?

A The members of the company.

Q And how was the capital call done, was it something done

in writing, did you have a meeting? Let me ask you this: Do

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 78 of 182 PageID #:3263
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 65

you have any evidence that any capital calls were made by any

of the entities that you have an interest in in 2020 and 21,

any documentation?

A I don't sitting here but there are -- there are capital

call documents; correct.

Q Okay. And who -- where are those documents?

A You could ask Mr. Brown about those documents. In

addition to that, there was demand letters from the

Department of Labor that were sent to me as the manager of

those companies. I didn't know this but payrolls flows

personally through managers at the company so I had lots of

letters and interactions from the Department of Labor to make

sure the companies were funded to fund people's payrolls.

Q Let me ask you this: Of the 58 million that are

listed -- that's listed as your net worth in 2020, how much

of that do you have access to today?

A None.

Q You do have a ninety-some percent interest in Overlook,

right?

A Yes.

Q And Overlook still owns the P5 entities 100 percent and

the P5 entities have an interest in the three properties we

listed as part of the portfolio, correct?

A That's correct.

Q And if you were, based on your education and experience,

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 79 of 182 PageID #:3264
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 66

in over a billion dollars in real estate transactions to give

me an estimate of what those properties are worth today, what

would you say?

MR. WANDNER: Objection. Asked and answered.

BY MR. TAHMASSEBI:

Q You can answer.

A I would have to see the financials but last time I

checked, their values were negative.

Q There was a big, I guess, huge change from your

financial wherewithal and status in August of 2020 until

today that appears?

A Correct.

Q Okay. And in the interim between August of 2020 when

you had a net worth of 58 million and today, you also had a

judgment in this case entered against you. You're aware of

that?

A Yes.

Q And you've taken zero steps to attempt to pay that

judgment, correct?

A No. I haven't taken any steps --

COURT REPORTER: I can't hear you.

THE WITNESS: No, I haven't taken any steps to pay

the judgment.

BY MR. TAHMASSEBI:

Q Do you believe you have an obligation to pay that

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 80 of 182 PageID #:3265
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 67

judgment?

A I do.

Q Have you gone, Mr. Ivankovich, to any of the entities

that you have an interest in and attempt to either sell that

interest or somehow withdraw funds so that you had the

ability to pay this judgment?

A There are no funds to withdraw from those entities

and --

Q Have you looked into assigning your interest in the

Pilgrim entities to the plaintiffs in this case who have a

judgment in order to satisfy your obligations to the

plaintiffs?

A I don't have an interest in the Pilgrim entities.

Q You have a 97 percent interest in Overlook Managing

Member LLC, right?

A That's correct.

Q Which would give you the majority of voting rights,

correct?

A In Overlook, yes.

Q You have -- Overlook then has 100 percent interest in

the five Pilgrim entities which have the interest in the

properties we talked about as part of the portfolio, correct?

A Correct.

Q Take a look at Exhibit 14. By the way, you've sued

Stifel down in Florida?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 81 of 182 PageID #:3266
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 68

A Yes.

Q You used to have a friend that was an advisor at Stifel,

right?

A Please be specific.

Q Yeah. Did you -- there was a gentleman at Stifel that's

no longer there that you have a -- had a professional

relationship with and you now have a personal relationship

with, correct?

A Are you asking me to guess on the gentleman? Please

tell me.

Q You don't know his name?

A I don't know his name. I don't know who you're

referring to.

Q You don't know -- you've never been seen with this

gentleman on different boats, on different yachts? You don't

know who I'm talking about?

MR. WANDNER: Counsel, counsel, if you have a name

that you're asking, please ask him. You're asking him

to speculate.

BY MR. TAHMASSEBI:

Q Mr. Ivankovich --

MR. WANDNER: Objection as to speculation.

BY MR. TAHMASSEBI:

Q -- is there a gentleman from Stifel that you have been

seen going on yacht trips with, going out to dinners with,

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 82 of 182 PageID #:3267
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 69

having wine with that rings a bell anywhere?

A No.

Q Okay. You want to stick with that as your answer,

you've never -- never been seen with a gentleman who used to

be at Stifel on a boat down in southern Florida?

A Or a gentlewoman, no.

Q Okay. All right. Back to -- is it 14 I marked it as --

the answer to the amended citation, have you seen this

document before?

A No.

Q Third page, there's a chart and I want to talk about

just the last two. Okay, sir? There's a number 13 is under

"P2 Portfolio Managing Member LLC" and then the amount in the

account, account balance is 10 million 991 dollars --

Excuse me. I have to get the right one.

(Brief pause.)

BY MR. TAHMASSEBI:

Q -- the amount in the account is $10,991,073.82.

A Which page of the document are you looking at?

Q Sure. Page 3 --

A Yep.

Q -- in the chart at the -- there's numbers on the

left-hand side, the very bottom in the middle of the page.

A Okay.

Q There's two accounts there, P2 Portfolio Managing Member

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 83 of 182 PageID #:3268
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 70

LLC, what's your interest in that entity?

A Maybe I'm a -- I think I'm 5 percent --

COURT REPORTER: Can you speak up for me?

THE WITNESS: I believe I'm 5 percent owner of that

entity.

BY MR. TAHMASSEBI:

Q Did you have the ability to transfer funds out of the

Stifel account for P2 Portfolio Managing Member LLC?

A Not on my own, no.

Q Well, who else would have to assist you?

A Anthony Ivankovich.

Q Your father?

A Yes.

Q How old is your father?

A 82, I believe.

Q Where does he reside?

A In Florida.

Q Where in Florida? What's the address?

A Key Biscayne, Florida.

Q What's the address?

A 791 Crandon Boulevard, Key Biscayne, Florida.

Q Does he reside there alone, with his wife, your mother?

A With his wife and with me.

Q Is he retired?

A He's retired from being a physician; yes.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 84 of 182 PageID #:3269
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 71

Q And then the Ivankovich family -- by the way, who

handles the finances for P2 Portfolio Managing Member LLC?

A Again, it would have been the successor to RealPage.

Q Who, the successor to RealPage?

A To RealPage.

Q Well, when you say "the successor," is that a different

firm or did they merge or --

A I don't know if they merged but it's not RealPage

anymore.

Q Ivankovich Family LLC, what's your interest in that

company?

A Again, in the 5 percent range.

Q And it looks like the account there is $19,042,437, do

you see that?

A Yes.

Q And the individuals that would have to authorize

transfer any of those funds would be yourself and your

father?

A Myself, my father, and my mother.

Q Okay. And has either -- has any money been transferred

out of P2 Portfolio Managing Member LLC or the Ivankovich

Family LLC that are listed here in the Stifel accounts?

A I'm sure money was transferred in the normal course of

business.

Q Since April 6th of 2022, has any money been transferred

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 85 of 182 PageID #:3270
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 72

out of the P2 Portfolio Managing Member LLC or Ivankovich

Family LLC accounts?

A I'm sure there was.

Q Well, did you authorize those transfers?

A No, not entirely.

Q Well, you were involved with them, right?

A Yeah.

Q And --

A I was involved in the organization.

Q And how much was transferred out?

A I don't know.

Q Where was it transferred to?

A I don't know.

Q Well, when you authorized the transfer, you didn't ask

what are -- where is the money going?

A Well, you're using the term transfers but in the normal

course of business, there are transfers all the time anywhere

from a dollar to any amount so you have to be specific what

you're asking me.

Q Well, I'm asking you, if you -- you said money was moved

from the P2 and Ivankovich accounts to somewhere else.

A I didn't say money was moved. I said -- you asked me if

money was transferred, so.

Q Okay. Let me do it this way, Mr. Ivankovich. When you

and your mother and your father sat down since April of 2022

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 86 of 182 PageID #:3271
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 73

and said we're going to take money from one place and either

spend it or put it in another place, what term would you like

me to use for that?

A I like to use the term specific to what you're asking

me.

Q Was any money moved out of the P2 Portfolio Member LLC

account and the Ivankovich Family LLC investment account

since April of 2022?

A Can you please repeat the question?

Q Sure. Was any money moved out of the P2 Portfolio or

Ivankovich Family LLC Stifel accounts since April of 2022?

A Well, I imagine there was. Yes.

Q Okay. And then how much was moved? And if you need to

do it by P2 and Ivankovich, you can do that.

A I can't tell you sitting here.

Q Why was any money moved?

A Because these are companies that conduct business so to

pay bills, to make investments.

Q Okay. What bills were needed to be paid by P2 Portfolio

Managing?

A I don't know.

Q Who would know?

A My father would know.

Q Okay. Ivankovich Family LLC, again, money was moved.

I'd have to ask your father why it was moved?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 87 of 182 PageID #:3272
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 74

A Ask my father, my mother; yes.

Q Okay. You want me to ask your 82-year-old father or

your mother why money would have been moved since April of

'22 out of these two LLCs, correct?

A I don't want you to.

Q Well, you just said they were the ones that would know,

not you, so, I mean, that to me is telling me that's who I

have to ask --

A Correct.

Q -- so we'll ask them. Now --

(Counsel conferring.)

BY MR. TAHMASSEBI:

Q Did you ever have an individual account with Stifel?

A No.

Q The -- going back to Exhibit 14, the accounts

themselves, account ending 1602, did you have any interest in

that account, you individually?

A I don't understand the question when you say "interest

in the account."

Q Yeah. Was it -- did you have a -- did you take money

from that account?

A No, not on my own volition.

Q Same with the 4799, did you have any interest in that

account itself?

A Again, when you say "interest," I don't know what you

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 88 of 182 PageID #:3273
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 75

mean.

Q Did you move money from that account?

A Not on my own, no.

Q Okay. And then so you were in New York for a trial, do

you remember that?

A Yeah, many years ago.

Q Relating to Atlas?

A Correct.

Q And when you were asked about the Ivankovich Family LLC

and the P2, you told the court that you could use those funds

to populate an entity with the signing of a pen and a phone

call in a matter of minutes, do you remember that testimony?

A I don't. Can I -- I do not.

Q Was that true that if you wanted to move money, in this

case you were saying you could have gotten it out of these

Stifel accounts and sent it to an Atlas account with the

signing of a pen and a phone call in a matter of minutes,

were you telling the truth when you told that to the New York

court?

A I don't believe that's the testimony.

Q We could populate that answer -- Page 2 -- Exhibit --

well, let's see. Page 303 (sic) of the transcript from

January 13th, 2020, in answer to a question "the specific

entity doesn't, but the chain of ownership, as I said, has

plenty of assets. We could populate that entity with the

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 89 of 182 PageID #:3274
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 76

signing of a pen and a phone call in a matter of minutes," is

that your testimony?

A You'd have to show me the document so I can look at it.

Q I can mark your testimony, sure. Let's call this

Exhibit --

(Counsel conferring.)

BY MR. TAHMASSEBI:

Q Exhibit 13 is the transcript from January 13th, 2020.

(Brief pause.)

BY MR. TAHMASSEBI:

Q I highlighted it for you. I just need you to confirm

that's what you testified to and that you were telling the

truth when you made those statements. That's the only

question I'm asking you.

A What is the question you were asking?

Q Yeah. Is that your testimony that I just showed you on

Page 304?

A I'm looking at a copy of my testimony but what is the

question you're asking?

Q Were you telling the truth when you said that to the

judge in New York?

A When I said what's -- in this testimony?

Q Yes.

A Is this testimony my truth?

Q Yes.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 90 of 182 PageID #:3275
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 77

A The truth?

Q Yes.

A Yes.

Q Okay. You can set that aside. She's going to take it.

COURT REPORTER: Can I ask a quick question?

MR. TAHMASSEBI: Sure.

(Discussion off the record.)

BY MR. TAHMASSEBI:

Q Do you have any income today, sir?

A No.

Q How did you get up here?

A Airplane from Miami.

Q Who paid for it?

A My father.

Q Who pays for your daily living expenses?

A My parents.

Q How old are you again?

A 52.

Q And who pays to assist in running the entities you still

have an interest in so far like Overlook Management (sic)

Member LLC or the P5 entities?

A Whatever income I would imagine comes off the properties

pays for the staff there.

Q Anything else?

A No.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 91 of 182 PageID #:3276
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 78

Q Do you have any involvement in paying the staff there?

A No.

Q Who does?

A When you say "who does," meaning --

Q Yeah. I mean, who is the one that's taking the income

from the properties and paying staff?

A I don't believe staff is paid directly. I believe it --

there's a management contract.

Q And who is that with?

A With Atlas Apartment Homes LLC but I actually don't know

how the staff is paid at this point.

Q How do you pay -- do you have a car?

A No.

Q How do you get around?

A Uber, walk.

Q Okay. Who pays for your Uber?

A My father.

Q Do you have a credit card?

A No. I use his.

Q Who pays your lawyers?

MR. WANDNER: Objection. Move to strike.

BY MR. TAHMASSEBI:

Q You can answer.

MR. WANDNER: No. I'm instructing him not to

answer unless the Court orders him to.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 92 of 182 PageID #:3277
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 79

BY MR. TAHMASSEBI:

Q Did you retain Mr. Wandner to represent you in this

matter?

MR. WANDNER: I object. I instruct you not to

answer --

MR. TAHMASSEBI: Whether or not he retained you is

not --

COURT REPORTER: I'm sorry, I have to -- one at a

time.

MR. WANDNER: I'm objecting and I'm instructing him

not to answer unless the Court orders him to answer that.

It's not an appropriate question.

MR. TAHMASSEBI: I just asked him whether he

retained you to be able to represent him.

MR. WANDNER: It's still -- it violates the

attorney-client privilege, counsel.

BY MR. TAHMASSEBI:

Q Okay. Who is paying Mr. Wandner's bill, do you know?

MR. WANDNER: Objection. Same objection.

BY MR. TAHMASSEBI:

Q Who hired the -- is it "Chukek" or Chuhak -- guys that

are sitting here, your lawyers that are sitting here to

represent the LLCs?

MR. PORRAS: Objection --

MR. DEBRE: Objection.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 93 of 182 PageID #:3278
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 80

MR. WANDNER: Objection.

MR. PORRAS: -- as to foundation.

BY MR. TAHMASSEBI:

Q Did you hire the Chuhak lawyers to represent the LLCs?

A I can't answer the question on advice of attorney.

Q No one has told you not to answer.

MR. WANDNER: I'm objecting to these questions.

They impact the attorney-client privilege, counsel.

BY MR. TAHMASSEBI:

Q Are you following his advice?

A I am.

Q Okay. Who is paying the Chuhak lawyers for the P2 --

MR. WANDNER: Same objection. Asked and answered.

MR. TAHMASSEBI: Guys, you gotta -- Hey, gentlemen,

let's just -- there's a method to my madness, okay? I'm

not -- let's be professional. Let me finish the question --

MR. WANDNER: I am being professional.

MR. TAHMASSEBI: -- and I respect that you have to

make an objection and if you instruct him not to answer,

that's fine, but I need a record so that if I decide to go to

the Judge, we're not talking over each other and also for the

benefit of the reporter so please let me finish and then you

can make your objection.

BY MR. TAHMASSEBI:

Q Mr. Ivankovich, do you know who hired the Chuhak &

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 94 of 182 PageID #:3279
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 81

Tecson lawyers to represent the LLCs, specifically the

Ivankovich Family LLC, the P2 LLC and the Pilgrim LLCs, the

P5?

MR. PORRAS: At this point I'd like to make a

standing objection for any further questions relating to

communications with Chuhak & Tecson on behalf of the LLCs.

We're asking that Mr. Ivankovich not answer the questions.

BY MR. TAHMASSEBI:

Q Okay. And you're following that advice?

A I am.

MR. TAHMASSEBI: See, guys, not that hard.

BY MR. TAHMASSEBI:

Q While we're on this Exhibit No. 1, this is an Alias

Citation to Discover Assets to Steven Ivankovich and if you

go to Page 5 -- excuse me, Page 7 --

A Go ahead.

Q On 7, there's a statement, I certify everything that --

in the answer to the citation proceedings is true and

accurate. I understand that making a false statement on this

form is perjury and has penalties provided by law. Do you

see that?

A I do.

Q And that's your signature, correct?

A It is.

Q And your name above there?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 95 of 182 PageID #:3280
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 82

A Yes.

Q And do you remember actually signing this document?

A I don't.

Q Did you sign this document?

A Yes. That's my signature.

Q Turn back, if you could for me, to Page 5.

A Sure.

Q It says you own property 235 West Menonee,

M-e-n-o-n-e-e, Street and 234 Willow Street --

MR. WANDNER: That's Page 6, counsel.

MR. TAHMASSEBI: I'm sorry. Page 6.

THE WITNESS: Yes, although there's a typo on West

Menomonee. It should be Menomonee, M-e-n-o-m-e-e (sic).

BY MR. TAHMASSEBI:

Q And on the Menomonee property, what type of property is

that?

A It's a single-family home.

Q In the North Chicago area?

A Yeah.

Q And is there a mortgage on that property?

A Yes.

Q With what bank?

A Originally it was with a bank called Cole Taylor but

there's been five different mergers and acquisitions since

then so I'm not sure who the current bank is.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 96 of 182 PageID #:3281
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 83

Q Well, who do you pay your mortgage to?

A I don't pay the mortgage.

Q Who does pay the mortgage?

A Nobody. The home is in foreclosure.

Q When is the last time you paid the mortgage on the 235

West Menomonee property?

A 2019.

Q The same time you were putting a lot of your own

personal assets into the entities that you had an interest

in, right?

A Correct.

Q Is this --

A By the way, I may not have even owned it anymore. I

think there was a share scale -- sale scheduled in August so

I don't know if that happened or not yet.

Q Did you own it yourself or with your wife, the Menomonee

property?

A It's owned jointly with my wife.

Q The 234 West Willow property, is that owned by you

individually or with your wife?

A It's the same residence. It's a contiguous lot --

Q Got it.

A -- or I think they call them a tandem lot.

Q When is the last time you paid the mortgage on that

property?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 97 of 182 PageID #:3282
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 84

A The same. It's the same -- it's one mortgage, I think,

covering both.

Q All right. Just so I'm clear, back in 2020 you had a

net worth of approximately 58 million and today you depend

upon your father to provide you with a living space, right?

A And my mother.

Q And your mother; I'm sorry. And your mother to provide

you with a living space, right?

A Yes.

Q To pay any bills that you have, if you have any?

A I don't have any more anymore, thankfully.

Q To make sure you get transportation to anywhere you need

to go, right?

A Yes.

Q And, for example, the flight that you got up here today,

you didn't pay for that, did you?

A No.

Q And what -- on a daily basis, Mr. Ivankovich, then what

do you spend your time doing unless you have a job that I

didn't see but I thought you said you were unemployed.

A No. Play tennis, do a lot of reading.

Q So how you spend your day --

A Go to the gym.

Q Okay. So you spend your days --

A Do some fishing, look at women on the beach when I'm

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 98 of 182 PageID #:3283
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 85

there, which is why I'm getting a divorce.

Q All right. Exhibit No. 2, if you could, please. So

most of your days are spent, I guess, tennis, gym, looking at

women on the beach, time on the beach --

MR. WANDNER: Sorry. Objection, asked and

answered.

BY MR. TAHMASSEBI:

Q -- right, fair enough?

A (Nodding).

Q You got to say "yes" for her.

A Yes.

Q Okay. Exhibit 2 is a financial statement dated April of

2017. Do you see that?

A Yes.

Q And is that your signature?

A Yes.

Q Okay. Do you have any reason to believe you did not

sign this on or around April of 2017?

A No.

Q Second page. Your salary at that time was 250,000?

A Correct.

Q And if we go to the balance sheet from 2017, at this

time you had liquid marketable assets of around $6,103,196,

does that sound about right?

A Yes. That's what the document says, correct.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 99 of 182 PageID #:3284
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 86

Q And then the net worth is 28 million 603 thousand

approximately?

A Yes, correct.

Q So from 2017 up until 2020, you actually did fairly well

and your assets and net worth improved up until that year,

right?

A Yes.

MR. TAHMASSEBI: What time is your call? Off the

record. Sorry.

(Recess taken.)

MR. WANDNER: You say you have about 20 minutes

left?

MR. TAHMASSEBI: Yes.

MR. WANDNER: Okay.

BY MR. TAHMASSEBI:

Q Mr. Ivankovich, when is the last time you filed a tax

return?

A Maybe 2017.

Q 2017 was the last time you filed an individual tax

return?

A Yep.

Q And who filed that for you?

A I think a company called Professional Financial

Consultants. That sounds about right.

Q Are you planning to file tax returns anytime soon?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 100 of 182 PageID #:3285
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 87

A Yeah.

Q Did you get extensions for your tax returns?

A I did get extensions but I think the extension is only

for a year.

Q Have you paid taxes since 2017?

A No. I also think there's a -- I've got like a $2

million federal tax lien that I have on there.

Q Do you know that the judgment in this case was entered

against -- did you know on or around August 17th of 2021 that

there was a judgment in this case entered against you?

A I probably did, yes. I don't recall the specific day.

Q Did you have a bank account in August -- on August -- on

or around August of 2021?

MR. WANDNER: I object. Asked and answered. You

asked him if he had bank accounts earlier.

THE WITNESS: A personal bank account?

BY MR. TAHMASSEBI:

Q You got to listen to the question.

A Yeah. No.

Q When was the last time you had a personal bank account?

A 2016, '17.

Q The companies that you said you had to use your personal

finances for, the 58 million, did any of those companies

apply for any governmental assistance during COVID?

A I didn't say I used $58 million. Let's get that clear.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 101 of 182 PageID #:3286
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 88

I didn't use $58 million in those companies.

Q Well, how much did you transfer to those companies?

A In the $12 million range.

Q Okay. So then of your $56 million net worth, you still

have a significant amount of that?

A No.

Q So what happened to the rest of the --

A As the assets' value went to zero or foreclosed upon,

those interests disappeared.

Q Did any of your companies during COVID that you had an

interest in apply for any governmental assistance relating to

COVID?

A I don't know.

Q Well, as an interested -- as an owner of these

companies, didn't you have an interest -- somebody who was

forking over $11 million from the year two thousand -- from

you said the time of COVID about until the end of 2021, did

you ever think it might be a good idea to see if there's

other avenues besides giving over your personal assets?

A I did. My recollection was that was -- those programs

were based on companies with employees and none of these

companies have employees. There's only one company that had

any employees, that was Atlas Apartment Homes, and it's

possible that may have applied for something.

Q Well, hold on. You said earlier you used money from the

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 102 of 182 PageID #:3287
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 89

11 million for payroll?

A Yes.

Q But now you're saying the payroll consisted of just one

person?

A No, no. Of one company.

Q Okay. One company?

A Yes.

Q Okay. What -- which company was that?

A Atlas Apartment Homes.

Q Okay. And did Atlas Apartment Homes apply for a PPP

loan or any of the other programs that the government had

during COVID?

A I don't know.

Q Did you ever ask that somebody from Atlas Homes apply

for that program so that you don't have to yourself put in

your personal assets to the tune of $11 million according to

what you said today?

A I don't think I asked; no.

Q Why not?

A I'm just not used to taking money from the government.

Q Did you ever consult with anybody in 2020, 2021 as to

whether or not these entities that you put this $11 million

into could have received funds from the government, loans

that were ultimately forgiven as a result of the COVID

crisis?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 103 of 182 PageID #:3288
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 90

MR. WANDNER: Object to the form of the question.

MR. TAHMASSEBI: Did you say "no"?

THE WITNESS: I didn't consult with anybody but I

recall reading about the programs.

BY MR. TAHMASSEBI:

Q But you never consulted with anybody as to whether or

not those programs, the COVID programs that the government

put forth specifically for companies like yours made sense,

fair?

A I didn't consult with anybody; no.

Q Do you own any jewelry, any -- anything else of value,

antiques, anything like that, just so --

A No.

Q No?

A No.

Q Do you plan to move out of your parents' home anytime

soon?

A No.

Q Okay. If you do, will you please have your lawyer

contact me?

A Sure.

Q How old are your children now?

A 15 and 11.

Q Do they live with you?

A No.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 104 of 182 PageID #:3289
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 91

Q Where does your wife reside?

A I believe in Chicago.

Q What's the address?

A I don't know.

Q You don't know your wife's address?

A No. We haven't spoken since she filed for divorce in

October.

Q Does your wife work?

A I don't know.

Q Well, okay. Let me go back then. In October, the last

time you spoke to her, did she have employment?

A No.

Q When is the last time she worked at all that you're

aware of?

A In -- it would be when we met in 2005, 2006.

Q Okay. So once you guys met and married, she -- she

stopped working?

A No. She didn't stop working but --

Q I didn't mean it like that. I mean she didn't have

employment.

A She was a professional mother and housewife.

Q Okay. The hardest job. All right. The -- and that

wasn't sarcastic just anyone that's reading this knows. The

15-year-old and 11-year-old, where do they go to school?

MR. WANDNER: I'd like to interpose an objection.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 105 of 182 PageID #:3290
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 92

Is this really necessary --

MR. TAHMASSEBI: Yeah.

MR. WANDNER: -- to get into his children's lives?

MR. TAHMASSEBI: I'm not asking him any more

questions about them. It is necessary.

MR. WANDNER: Well, you're asking a question about

them, about his children's lives. Why is that relevant?

MR. TAHMASSEBI: It's relevant because if they go

to a certain school --

MR. WANDNER: Okay. So why don't you ask him if

the kids go to a private school?

MR. TAHMASSEBI: No. Let me just ask him how I'm

doing it.

MR. WANDNER: Well, I'm going to object to you

asking those questions.

BY MR. TAHMASSEBI:

Q Where -- where do your kids go to school?

MR. WANDNER: I'm going to object --

MR. TAHMASSEBI: Okay. You can object.

MR. WANDNER: -- and instruct him not to answer

unless the Court orders him to answer the question.

MR. LAMMERS: There's no privilege for asking about

relevant information.

MR. WANDNER: It's not relevant where his children

go to school.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 106 of 182 PageID #:3291
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 93

MR. LAMMERS: You can't instruct someone --

MR. WANDNER: If you want to ask him --

BY MR. TAHMASSEBI:

Q Do your children --

MR. WANDNER: -- if he personally --

COURT REPORTER: I'm sorry, I have to make a

record.

MR. WANDNER: -- if he personally pays for a

private school for his kids, then I won't object to that as

relevance, but asking them where they go to school on a

public document I believe is not proper.

BY MR. TAHMASSEBI:

Q Do your children go to private school or public school?

A They go to private school.

Q And who pays for that private school?

A At this point, I don't know.

Q When was the last time you paid for your children's

private education?

A 2019.

Q 2019?

A Yep.

Q What's the cost of their private schooling?

A I don't know.

Q What was it in 2019?

A In the range of $10,000 per year.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 107 of 182 PageID #:3292
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 94

Q For each, right?

A Yes.

Q What is A & O Family LLC?

A A limited liability company.

Q Well, I get that but what does it do?

A I don't know.

Q Who are the members?

A I don't know exhaustively but members of my family.

Q Okay. Give me the ones that you do know.

A Anthony Ivankovich, Olga Ivankovich, Daniel Ivankovich,

Sophie Ivankovich, Anthony Ivankovich the second, Lucas

Ivankovich, Katarina Ivankovich. That's all I know.

Q And you are not a member?

A And me, yes.

Q Okay. And what does that LLC do?

A I believe it's an investment company.

Q Where does A & O Family LLC bank?

A I believe it does have -- it does have accounts at

Stifel.

Q How much are in those accounts, do you know?

A I don't know.

Q 10,000, 10 million like the other ones?

A I don't know. I'm not privy to those statements.

Q All right.

(Counsel conferring.)

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 108 of 182 PageID #:3293
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 95

BY MR. TAHMASSEBI:

Q As far as the P5 Portfolio, the Warwick property, the

Wind Tree property and the Coulter Landing property I think

we said those still are -- those have not been sold, right?

A Correct.

Q And those are owned as far as who has title to those

by -- is it Atlas Apartments Management LLC?

A No.

Q Okay. Who is it?

A Do you know what page the org chart was on?

Q Sure. 9.

A The Alliance HTTX Limited Partnership.

Q Okay. So the Alliance HTTX GP Limited Partnership, got

it, owns the three properties. All right. Did you ever give

personal money to -- I'm sorry, just so -- let me just ask a

better question so we can be done. The personal funds that

you disbursed into the LLCs in 2020, '21, would have gone to

a variety of LLCs of which are listed in the organizational

chart marked as Exhibit 9?

A Yes.

Q Oh, yeah. The residential properties that you owned,

were those always owned by you and your wife or at some point

were they owned by just you, the two Chicago properties?

A Yeah. I owned it prior to us getting married.

Q And then it was transferred over at the time you were

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 109 of 182 PageID #:3294
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 96

married?

A Yes.

Q And that was what date?

A 2006.

Q Have you ever owned any property, you individually, in

Florida?

A No.

Q How about your wife?

A I don't know.

Q Not since you've known her?

A Not since I've known her. It's possible she does. I

don't know about --

Q And then --

(Brief pause.)

BY MR. TAHMASSEBI:

Q Did you provide -- and if you want something to

reference, I'm going back to Page 12 of Exhibit 6.

A Go ahead.

Q The last paragraph that starts with "Mr. Ivankovich

reports --"

COURTROOM DEPUTY: Hi. Judge says she's going to

give you guys another ten, 15 minutes.

MR. TAHMASSEBI: We're about -- we're done in like

two.

COURTROOM DEPUTY: Okay. Perfect.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 110 of 182 PageID #:3295
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Direct by Mr. Tahmassebi 97

MR. TAHMASSEBI: Yeah.

MR. WANDNER: I have a couple questions, too.

Please.

MR. TAHMASSEBI: Oh, all right. Okay. Maybe we

will need ten minutes. Sorry.

COURTROOM DEPUTY: Okay. So ten minutes then.

MR. TAHMASSEBI: Got it. Thanks.

COURTROOM DEPUTY: All right.

THE WITNESS: Go ahead. I'm on Page 12.

BY MR. TAHMASSEBI:

Q Yeah. The information on that last paragraph, did you

provide documentation to support your net worth and liquidity

of 42.7 million and 12.7 million to Walker Dunlop?

A Yes.

Q Okay. And who did that documentation come from, you

directly or one of your professionals?

A Me directly.

Q Was it via email, was it mailed, how would you have done

that?

A Hard to say. Probably either -- some private way. It's

sensitive information so either by courier --

Q All right.

MR. TAHMASSEBI: So I'll make a formal --

Mr. Wander?

MR. WANDNER: Yes, sir?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 111 of 182 PageID #:3296
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Cross by Mr. Wandner 98

MR. TAHMASSEBI: I'm going to make a formal request

for additional documents.

MR. WANDNER: File what you need to file.

MR. TAHMASSEBI: Those are what I need. And then

the last thing is, I want to put on the record I'm handing --

I'm handing Mr. Ivankovich a Citation to Discover Assets in

the Atlas LLC case in the collection portion, 2019 L 454, so

I'm just serving you with that document to respond to. And

also appear --

MR. WANDNER: Can I have a copy of it?

MR. TAHMASSEBI: Yeah, absolutely. And also appear

for another citation exam. That's all I have.

MR. WANDNER: Can I ask you why you didn't

coordinate the dates on this with his counsel?

MR. TAHMASSEBI: Because I didn't -- I didn't know

what the Judge had in mind. We can go off the record.

(Discussion off the record.)

MR. WANDNER: I just have a few questions.

CROSS EXAMINATION

BY MR. WANDNER:

Q Mr. Ivankovich, early on in the first part of the depo,

you had said something about a cut-and-paste of your

financial statements. Did you want to expand on your answer

at all?

A Yeah. I have to study the document closer but this

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 112 of 182 PageID #:3297
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Cross by Mr. Wandner 99

doesn't look like something I would have produced. There's

just too many inconsistencies on the pages that I can see. I

mean, for example, in 2020, I would have been 50 years old

and my kids would have been older. This -- this statement

below I don't ever recall having that in my financial

statements. It just doesn't seem right.

Q Did you see where Exhibit 2 and Exhibit 3 on the

signature page, one seems to be in blue ink and one seems to

be more of a copy?

A Yes. Yeah, yeah. That's --

Q Is that also something that raises questions?

A Yeah, that looks fishy.

Q Okay. Now you brought up in your answers that there

seems to be some differences internally within Exhibit 3

referenced to the date of August 26th, 2020, and March of

2020, which is interspersed within the document. Did you

reference that?

A Yeah. It's not just that. I mean, there's all sorts of

dates in here.

Q Can you tell for the record purposes what happened in

and around March of 2020 to the world?

A Oh, I think we got locked down with COVID.

Q Okay. And did that have a negative effect upon your

assets?

A Oh, yeah. Everyone stopped paying rent.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 113 of 182 PageID #:3298
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Cross by Mr. Wandner 100

Q Okay. And when -- when renters stopped paying rent, did

that stop the obligations of the landlords, whomever they

were, to pay their bills?

A No.

Q And was there negative consequences to the entities and

to the renters if the landlord stopped paying their bills?

A Oh, yeah. The water shut down, the mortgage foreclosure

power would have got shut down, no insurance. I mean --

Q And you said --

A -- all of that happened.

Q And you said you got some notices from the Department of

Labor that there's personal obligations to, you know, take

care of certain things --

A Yeah.

Q -- on behalf of corporate entities?

A Yeah.

Q Okay.

A Yeah, I didn't -- I didn't realize that the payroll goes

personally to the manager of the company.

Q Did the entities -- and I'm not going to get into the --

using counsel's term getting into weeds on which ones, but

the entities that were referenced here today, did they have

tax burdens and tax obligations that were documented during

that period of time?

A We had to pay. We had to continue to pay real estate

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 114 of 182 PageID #:3299
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Cross by Mr. Wandner 101

taxes; yes.

Q Okay. And do you know whether those entities or some of

those entities indicated losses during the time period

reflected between August of 2020 and today?

A They all had losses.

Q Millions of dollars in losses?

A Yes.

Q You said some of -- some of the assets were in Florida,

right?

A Yes.

Q Okay. Do you know whether the State of Florida

specifically had passed some rules in response to COVID where

people who failed to pay rent could not be evicted?

A Yeah. There was an eviction moratorium everywhere,

Texas, Florida, Illinois, everywhere.

Q And did that negatively affect your assets during the

period of time from when the documents reflected in what

Mr. --

MR. WANDNER: I'm sorry.

MR. TAHMASSEBI: Mr. Tahmassebi.

THE WITNESS: Tahmassebi.

MR. TAHMASSEBI: It doesn't bother me.

BY MR. WANDNER:

Q -- Tahmassebi referenced and as we sit here today?

A Yeah, people stopped paying rent essentially.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 115 of 182 PageID #:3300
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Cross by Mr. Wandner 102

Q But again, that didn't stop bills coming in, right?

A No, no. And we -- we asked. We tried to get the water

company to give us a pass but they shut down the water unless

we paid the bills.

Q Do you have any other judgments against you personally

out there?

A Yeah. There's --

Q You mentioned a tax lien.

A Yeah.

Q What else?

A In reading this document, it's referenced on -- in one

of these exhibits. There's a judgment now for a million

eight on my home mortgage and I think the company is called

Edgefield. There's a $26 million judgment from 2019 --

Q Okay.

A -- I believe.

Q And in your testimony that counsel asked a couple of

random questions about, did you ever indicate that you had

the authority to use moneys from these LLCs to pay your own

debts?

A No.

Q In fact, didn't you indicate specifically that you were

not authorized to use the money to pay your own debts without

gaining authority?

A Yes.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 116 of 182 PageID #:3301
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Ivankovich - Cross by Mr. Wandner 103

Q And, in fact, in -- even in the cite to the transcript

that counsel mentioned, he said "a stroke of the pen and a

phone call," the phone call was to the person who you needed

to gain authority from which to make a move; isn't that

correct?

A I'd have to go back and re-read it but I didn't have

authority on my own to move money. That's correct.

Q Okay. So the bottom line is, like a banker who has the

key to the vault at a bank, he has the ability to move money,

that doesn't mean he has the authority to move money; is that

right?

A I believe that's right. Yes.

Q Okay. Like a banker who is a manager of Wells Fargo has

the key to the vault, he can't go in there, take half a

million and go pay his water bill with it, right?

A I couldn't -- I couldn't -- I can't move money without

my permission.

Q Okay.

MR. WANDNER: One second.

(Brief pause.)

MR. WANDNER: That's all I have. Thank you, guys.

MR. TAHMASSEBI: We're done.

(Proceedings concluded at 12:07 p.m.)

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 117 of 182 PageID #:3302
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

C E R T I F I C A T E

I hereby certify that the foregoing is a complete, true

and accurate transcript of the proceedings had in the

above-entitled matter before the Honorable Sharon Johnson

Coleman at Chicago, Illinois, on August 31, 2022.

/s/Laura LaCien September 7, 2022

Official Court Reporter DATE

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 118 of 182 PageID #:3303
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 119 of 182 PageID #:3304
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 120 of 182 PageID #:3305
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 121 of 182 PageID #:3306
Re: Ivankovich

Gary Goldstein <gary@gagpa.com>

Wed 3/1/2023 10:18 AM

To: Amir Tahmassebi <amir@konicekdillonlaw.com>

Cc: jason@wandnerlaw.com <jason@wandnerlaw.com>;Connor Whitting

<connor@konicekdillonlaw.com>;Sheila Jacobsen <sheila@konicekdillonlaw.com>;Tihana Karlovic

<tihana@konicekdillonlaw.com>;Michael Debre <MDebre@chuhak.com>;Cecilio I. Porras

<cporras@chuhak.com>

Amir:

Do you have a confidentiality agreement that you prefer to use? I thought there was one entered

already in the case approved by Judge Coleman.

You could check with Will Sears. If so we could just agree that the additional documents produced

would be covered by that order.

That would include the LLCs whose records most likely will be included in the production.

We have been diligent in attempting to discover and review documents that we believe may be

relevant to your informal document request.

We interpret the request to seek information on Steve Ivankovich’s contributions to the various LLCs

for the period 2018-2020, possibly 2017 if that year has relevant information on this issue.

Most likely we will create a cloud link.

We intend to start putting documents in and sharing them

By next Wednesday. We will not wait for execution of confidentiality order and will rely upon your

discretion in granting access to said documents. They should not be included in any public filing

absent a court order.

Any questions call Jason or me to work through issues in good faith.

I am copying Mike Debre and Cy with this email because the production will include LLC documents.

Gary 

On Mar 1, 2023, at 10:54 AM, Amir Tahmassebi <amir@konicekdillonlaw.com> wrote:

Gary and Jason,

We received your answers to the interrogatories. However, we still have not received the

documents requested in our Rule 37 letter. I spoke with Mr. Goldstein approximately two (2) weeks

ago and was told they would be forthcoming. Please provide the documents within the next seven

(7) days. I’m happy to discuss any issues relating to the production.

Regards,

Amir R. Tahmassebi

Konicek & Dillon, P.C.

70 W. Madison, Suite 2060

Chicago, IL 60602

(312) 328-9166 (Direct)

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 122 of 182 PageID #:3307
RE: Ivankovich

Gary Goldstein <gary@gagpa.com>

Wed 3/29/2023 10:17 AM

To: Connor Whitting <connor@konicekdillonlaw.com>

Connor:

 I will respond to the production demand separately. I expect that you will have a formal response from

Jason and myself by April 4, 2023. We are proceeding in good faith notwithstanding there being no request for

production that complies with FRCP 34 directed to Steven Ivankovich. We have already created and given your

firm access to a substantial amount of financial documents including LLC tax returns. If you believe it appropriate

at this time to file a Rule 37 motion do so.

 I have spoken with Mark Brown about “the telephone call”. He received a call from an unknown number

and indicated it was a woman’s voice who of course he did not recognize and hung up what he believed was a

spam call. I provided you with his personal cell number so obviously we in good faith were providing you with

information to allow you to contact Mark. I suggest that you text mark identify yourself and provide him with a

call back number, he can then return your call and arrange for service of a deposition notice.

 Please coordinate the time place and means of deposition zoom preferably with Jason and Cy. I suggest

zoom because Mark is not subject to attending a deposition in Chicago. To avoid that dispute try zoom or in

person were convenient for the parties and Marks counsel.

 Mark’s number for you to text: 908-208-5421

Gary

From: Connor Whitting

Sent: Wednesday, March 22, 2023 6:08 PM

To: Gary Goldstein <gary@gagpa.com>; jason@wandnerlaw.com

Cc: Amir Tahmassebi <amir@konicekdillonlaw.com>; Sheila Jacobsen <sheila@konicekdillonlaw.com>

Subject: Re: Ivankovich

Counsel:

It has been almost seven weeks since we sent a Rule 37 letter seeking the production of any and all

transfers that were made by Steven Ivankovich to entities that he controlled or had an interest in from

2018 to the present. To date, and despite Mr. Goldstein's prior assurances, we have yet to receive

compliance. Many of the documents produced are non-responsive and do not evidence the transfers

Ivankovich claims were made in his deposition. If we do not receive said production responses by next

Tuesday, we will file a motion to compel. Of note, there have already been a number of Rule 37

conferences. I am available tomorrow or Friday for a Rule 37 conference. 

Additionally, I called Mark Brown this morning and he proceeded to hang up on me after I told him who

I was. We would ask that you please obtain the suite number to his address at 100 Park Avenue as it

should not take you more than a brief phone call to obtain the specific address. He is, after all, the

manager of all the relevant entities.

Thank you.

Best,

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 123 of 182 PageID #:3308
Connor

Connor J. Whitting

Konicek & Dillon, P.C.

70 W. Madison, Suite 2060

Chicago, IL 60602

(630) 262-9655 (Direct)

(630) 262-9659 (Fax)

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 124 of 182 PageID #:3309
·1· · · · · IN THE UNITED STATES DISTRICT COURT

· · · · · ·FOR THE NORTHERN DISTRICT OF ILLINOIS

·2· · · · · · · · · · EASTERN DIVISION

·3· ·ZHU ZHAI HOLDINGS LIMITED· ·)

· · ·and PETER PUI TAK LEE,· · · )

·4· · · · · · · · · · · · · · · ·)

· · · · · · · · · ·Plaintiffs,· ·)

·5· · · · · · · · · · · · · · · ·)

· · · · · · · vs.· · · · · · · · )· ·No. 20-cv-4985

·6· · · · · · · · · · · · · · · ·)

· · ·STEVEN IVANKOVICH,· · · · · )

·7· · · · · · · · · · · · · · · ·)

· · · · · · · · · ·Defendant.· · )

·8

·9· · · · · · The deposition of JEANETTE IVANKOVICH,

10· taken pursuant to the Federal Rules of Civil

11· Procedure, before Nick D. Bowen, Certified

12· Shorthand Reporter No. 084-001661, at 70 West

13· Madison Street, Suite 2060, Chicago, Illinois, on

14· Thursday, March 23, 2023, commencing at 1:41 p.m.

15· pursuant to subpoena and notice.

16· · · ·APPEARANCES:

17· · · · · · KONICEK & DILLON, PC, by

· · · · · · · MR. AMIR TAHMASSEBI

18· · · · · · (70 West Madison Street, Suite 2060

· · · · · · · ·Chicago, Illinois· 60602

19· · · · · · ·630.262.9655

· · · · · · · ·amir@konicekdillonlaw.com)

20· · · · · · · ·appeared on behalf of the plaintiffs;

21

22

23

24

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 125 of 182 PageID #:3310
Page 2

·1· · · · APPEARANCES:· (Cont'd)

·2· · · · · · CHUHAK & TECSON, PC, by

· · · · · · · MR. CECILIO PORRAS

·3· · · · · · (120 South Riverside Plaza, Suite 1700

· · · · · · · ·Chicago, Illinois· 60606

·4· · · · · · ·312.855.4603

· · · · · · · ·cporras@chuhak.com)

·5· · · · · · · ·appeared via Zoom on behalf of the

· · · · · · · · ·defendant;

·6

· · · · · · · SCHILLER DuCANTO & FLECK, by

·7· · · · · · MS. TANYA STANISH

· · · · · · · (321 North Clark Street, Suite 1200

·8· · · · · · ·Chicago, Illinois· 60654

· · · · · · · ·312.235.6611

·9· · · · · · ·tstanish@sdflaw.com)

· · · · · · · · ·appeared on behalf of the deponent;

10

· · · · · · · LAW OFFICE OF GARY S. GOLDSTEIN, by

11· · · · · · MR. GARY S. GOLDSTEIN

· · · · · · · (11 High Street

12· · · · · · ·Chester, New York 10918

· · · · · · · ·845.469.8630)

13· · · · · · · ·appeared via Zoom on behalf of Steven

· · · · · · · · ·Ivankovich.

14

15

· · · · · · · · · · ·*· *· *· *· *· * *

16

17

18

19

20

21

22

23

24

Page 3

·1· · · · · · · · · · · ·I N D E X

·2

· · Witness:· · · · · · · · · · · · · · · · · ·Page

·3

· · · · ·JEANETTE IVANKOVICH

·4

· · · · · · · Examination by:

·5

· · · · · · · Mr. Tahmassebi...............· · · 4

·6· · · · · · Mr. Porras...................· · ·53

·7

·8

·9

10· · · · · · · · · · E X H I B I T S

11· ·No.· ·Description· · · · · · · · Marked/Referenced

12· · ·1· Personal Financial Statement - Steven

· · · · · Ivankovich August 2020.................· 11

13· · ·2· Pilgrim V Portfolio Organization

· · · · · Chart..................................· 19

14· · ·3· Affidavit in Support of Emergency

· · · · · Petition for Temporary and Permanent

15· · · · Maintenance, Child Support and for

· · · · · Other Relief...........................· 23

16· · ·4· Affidavit in Support of Emergency

· · · · · Petition for Exclusive Possession......· 29

17· · ·5· Asset Summary, Atlas P5 Portfolio......· 35

· · · ·6· Answer to Amended Citation

18· · · · Proceedings by Stifel Financial Corp...· 41

19

· · · · · · · ·(Exhibits attached/scanned.)

20

21· · · · · · · · · · · · · - - -

22

23

24

Page 4

·1· · · · · · · · · · · · · ·(Witness sworn.)

·2· · · · · · · · · JEANETTE IVANKOVICH

·3· called as a witness herein, having been first duly

·4· sworn, was examined and testified as follows:

·5· · · · · · · · · · · EXAMINATION

·6· BY MR. TAHMASSEBI:

·7· · · · Q.· · Can you please state your name?

·8· · · · A.· · Jeanette Ivankovich.

·9· · · · Q.· · Okay.· You still go by Ms. Ivankovich;

10· is that okay?

11· · · · A.· · Yes.

12· · · · Q.· · Okay.· Have you given a deposition

13· before?

14· · · · A.· · Yes.

15· · · · Q.· · Okay.· And just give me the context if

16· you could of the deposition.

17· · · · A.· · I was deposed by Steven's divorce

18· counsel.

19· · · · Q.· · Okay.· And I'm assuming that related to

20· something with one of the service motions where the

21· jurisdiction will be or something to that effect.

22· · · · A.· · Yes.

23· · · · MR. TAHMASSEBI:· Okay.· Counsel, you wanted

24· to make an announcement.

Page 5

·1· · · · MS. STANISH:· Yeah.

·2· · · · MR. TAHMASSEBI:· Do you want to do that now

·3· so we don't forget?

·4· · · · MS. STANISH:· Sure.· Tanya Stanish, Schiller

·5· DuCanto & Fleck on behalf of Jeanette Ivankovich.

·6· · · · · · · · ·I just wanted to let counsel know

·7· that in the divorce matter, which is 2021 D 9220,

·8· there is a protective order which is about to be

·9· entered.· It was tendered to the court yesterday.

10· Hasn't been officially stamped yet.· But I did --

11· I am providing a copy to you, Counsel, of the

12· protective order that was sent to the judge.· It

13· protects documents and information relating to

14· Atlas, LLC.

15· · · · · · · · ·So to the extent that you ask

16· Ms. Ivankovich any questions related specifically

17· to Atlas, LLC, we may need to pause to see -- and

18· for me to review and confer with my client to see

19· if she can answer the question or not.

20· · · · MR. TAHMASSEBI:· Okay.· Understood.· And I

21· haven't had a chance to look at this, but I'll do

22· so.· And if we come to an issue, we'll take a

23· break.

24· · · · MS. STANISH:· And I don't know.· Mr. Porras,

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 126 of 182 PageID #:3311
Page 6

·1· do you want to put your appearance on the record?

·2· · · · MR. PORRAS:· Yeah.· Yeah, I do.· Thanks,

·3· Tanya.· So Cy Porras, P-o-r-r-a-s, on behalf of the

·4· intervenor LLCs.

·5· · · · · · · · ·And just for my knowledge, since I'm

·6· on Zoom, is Jason Wandner there or Gary Goldstein?

·7· I didn't hear any introduction of any sort at the

·8· beginning.

·9· · · · MR. TAHMASSEBI:· So Mr. Goldstein, who does

10· not have an appearance in this matter for one, but

11· has indicated he represents Mr. Ivankovich as you

12· know in various correspondence in the -- in our

13· cases, asked for the Zoom information, asked if he

14· could sit in.· I said he's welcome to.· Despite

15· that he doesn't have an appearance, we sent him the

16· information.

17· · · · · · · · ·Mr. Wandner received notice of the

18· deposition just as you did, Counsel.· I haven't

19· heard from them.

20· · · · · · · · ·About ten minutes ago -- we were

21· supposed to start at 1:30.· Everybody was here on

22· time, including yourself.· I did them the courtesy

23· of a note saying we'd wait about 10 to 15 minutes

24· for them.· We're since past that time.· So I don't

Page 7

·1· see any reason to wait any longer.

·2· · · · MR. PORRAS:· I see.· Amir, do you mind if I

·3· just give them a call, specifically Jason, to see

·4· if I can reach him, I mean one or two minutes, and

·5· then obviously if he doesn't answer, doesn't give

·6· me any indication as to what's going on, we can

·7· proceed?

·8· · · · MR. TAHMASSEBI:· Is that okay, Counsel?

·9· · · · MS. STANISH:· That's fine.

10· · · · THE WITNESS:· I mean, I'm on a time limit. I

11· have kids, so ...

12· · · · MR. TAHMASSEBI:· Yeah, we'll give him a

13· minute or two if you want to try.

14· · · · MS. STANISH:· Yeah.

15· · · · MR. TAHMASSEBI:· But no longer.

16· · · · MR. PORRAS:· Okay.· Appreciate it.· Just give

17· me one minute.

18· · · · MR. TAHMASSEBI:· We'll go off the record.

19· · · · · · · · · · · · · ·(Brief pause.)

20· · · · MR. TAHMASSEBI:· Let's go back on the record

21· then.

22· BY MR. TAHMASSEBI:

23· · · · Q.· · Ms. Ivankovich, where do you currently

24· reside?

Page 8

·1· · · · A.· · 920 West George, Chicago.

·2· · · · Q.· · And how long have you been at that

·3· address?

·4· · · · A.· · Since September 1st, 2021.

·5· · · · Q.· · And is that a rental, I think I saw on

·6· some of the papers?

·7· · · · A.· · Correct.

·8· · · · Q.· · And does Mr. Ivankovich pay for those

·9· rental expenses?

10· · · · A.· · Yes.

11· · · · Q.· · And approximately what's the rent a

12· month?

13· · · · A.· · The rent started out at 9,000 on

14· September 1st, 2021.· Went to -- I negotiated it

15· down when Mr. Ivankovich stopped providing support

16· for me and the children in July 2021 to 8,000.· And

17· then November 2021 I negotiated it down to --

18· · · · MS. STANISH:· I think you misspoke.· July of

19· what year?

20· · · · THE WITNESS:· Oh, 2022.· I'm sorry.· I'm

21· sorry.· 2022.

22· · · · · · · · ·And then in November 2022, I

23· negotiated it down to 5,000 due to my financial

24· circumstances.

Page 9

·1· BY MR. TAHMASSEBI:

·2· · · · Q.· · Okay.· And when approximately did

·3· Mr. Ivankovich stop providing assistance to you and

·4· the children?· You have two children, right?

·5· · · · A.· · I do have two children.

·6· · · · Q.· · And I don't want to talk about the

·7· children.· But I just want to know if they're

·8· still --

·9· · · · A.· · Yeah, just for the family.

10· · · · · · · · ·In October --

11· · · · Q.· · Approximately.

12· · · · A.· · October 2021, he stopped providing

13· assistance and made me contact his mother for

14· support.

15· · · · · · · · ·In February 2022, he started

16· supporting us again.

17· · · · · · · · ·And then in July 2022, he cut off

18· all support until December 2022 when the judge said

19· probably not a good idea.

20· · · · Q.· · Okay.· And so prior to Mr. Ivankovich

21· cutting off the support, did he tell you at any

22· time in the year or two prior to that that his

23· businesses were failing, that his personal assets

24· had all been transferred away, and that he could no

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 127 of 182 PageID #:3312
Page 10

·1· longer provide you support from a financial basis

·2· and that was the reason for stopping helping you

·3· and the kids with your finances?· Do you understand

·4· what I'm --

·5· · · · A.· · I don't understand.· Could you please

·6· clarify that?

·7· · · · Q.· · Yeah.· So when the support was cut off,

·8· was there a discussion between you and him where he

·9· came to you and said, Look, since COVID has come

10· about, I have had to basically liquidate all of my

11· resources?· At one point, and I'll show you the

12· financial statement, he was worth approximately

13· 55 million.· And since COVID now I am worth zero?

14· · · · A.· · He didn't say anything to me.· But our

15· lifestyle definitely did not reflect what you are

16· saying.

17· · · · · · · · ·When I filed for divorce, we were on

18· a 150-foot yacht that requires a seven-person crew.

19· He had a fishing boat that he purchased for a

20· captain at 42 foot.· And he had a recreational boat

21· that we used that was 34 foot.

22· · · · · · · · ·So I think Steve's always been fluid

23· with what he considers personal and business

24· expenses.· But our lifestyle did not reflect any

Page 11

·1· downturn during COVID.

·2· · · · Q.· · Okay.· Great.

·3· · · · A.· · In fact, it was kind of an uptick.

·4· · · · Q.· · And so that's exactly -- so Mr. -- just

·5· so you know, Mr. Ivankovich testified that once

·6· COVID hit, he had to transfer any personal assets,

·7· any interest -- a lot of interest that he had in

·8· his businesses to keep them afloat, and he went

·9· from close to, and I'll show it to you, a net worth

10· of 56 million to a net worth of almost zero.

11· · · · · · · · ·And all I'm getting at is based on

12· what you saw and the lifestyle you guys lived, that

13· testimony is not true?

14· · · · A.· · Correct.

15· · · · Q.· · And so I'll show you what I've marked

16· as Exhibit No. 1.

17· · · · A.· · Can I get my glasses?

18· · · · Q.· · Yeah, please do.

19· · · · · · · · ·So Exhibit No. 1 is -- you'll see

20· the P is missing.· But, Jeanette, it's a personal

21· financial statement of Steven Ivankovich dated

22· August 2020.

23· · · · A.· · Okay.

24· · · · Q.· · And then does that -- do you recognize

Page 12

·1· that signature?· Does that look like --

·2· · · · A.· · That's Steven's, yes.

·3· · · · MR. TAHMASSEBI:· Okay.· And then if you go

·4· to the third page of Exhibit 21 -- and this is a

·5· document, just so you know, Counsel, that was

·6· produced in the other litigation.· In our

·7· litigation.· Excuse me.

·8· · · · MS. STANISH:· Okay.

·9· · · · MR. TAHMASSEBI:· And it is also subject to

10· a protective order.· So I would ask that it not be

11· disseminated at this point in time without leave of

12· court in the other action.

13· · · · MS. STANISH:· Okay.

14· · · · MR. TAHMASSEBI:· But we're here for our

15· action, so there's no preclusion about me asking

16· Ms. Ivankovich about it.

17· · · · MS. STANISH:· Okay.

18· BY MR. TAHMASSEBI:

19· · · · Q.· · So if you look at -- in the third page

20· on the right column, and then you look down, it's a

21· little hard to read, but you see where it says Net

22· Worth (Total Assets minus Liabilities)?

23· · · · A.· · Net Worth (Total Assets, minus -- yes.

24· · · · Q.· · Okay.· And there it says -- and this is

Page 13

·1· his personal financial statement -- that as of

·2· September -- excuse me, August 26, 2020,

·3· $55,367,404.· Do you see that?

·4· · · · A.· · I do.

·5· · · · Q.· · Okay.· And since -- and if I hear your

·6· testimony correctly, since August 26 of 2020,

·7· Mr. Ivankovich never came to you and said,

·8· Jeanette, that 55 million, or whatever I've had in

·9· the bank, it's gone, I can no longer support you

10· and the children?

11· · · · A.· · No.

12· · · · Q.· · Okay.· And, in fact, I think you said

13· your lifestyle exemplified almost -- not the

14· opposite, but that you had those kinds of funds?

15· · · · A.· · Yes.

16· · · · Q.· · Okay.· Would you have expected if --

17· and I don't want to get into the whole husband and

18· wife dynamic.· But I'm just thinking from my own

19· experience if there was a financial hardship of

20· that amount, 55 million, would you have expected

21· you to somehow know or have some idea that that was

22· the case?

23· · · · A.· · If the 55 million took a turn, I would

24· expect it to be reflected in our lifestyle. I

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 128 of 182 PageID #:3313
Page 14

·1· don't know if Steven would come to me personally

·2· and say that, but I would expect our lifestyle to

·3· change, which it didn't.

·4· · · · Q.· · Okay.· Let's look at Exhibit No. 2.

·5· · · · · · · · ·Make sure I'm done with 1.

·6· · · · · · · · ·Oh, let me -- these are tough to

·7· read.· But can we go back to Exhibit 1 just for a

·8· second?

·9· · · · A.· · Is that page 3?

10· · · · Q.· · We're going to look at page 4.· I'm

11· really going to test everybody's eyes a little bit.

12· · · · · · · · ·And there's a Schedule G about two13· thirds of the way down.

14· · · · A.· · Yes.

15· · · · Q.· · Okay.· And in the column, there's a --

16· it's Schedule G, just so the record's clear,

17· Unlisted Securities Owned.· And then the one I want

18· to talk about is Atlas P5 Portfolio.· It's the

19· third one down.· Do you see that?· I know it's

20· tough to see.

21· · · · A.· · I do.

22· · · · Q.· · Okay.· And then at the very right, it

23· says an amount of 29,140,000.· Do you see that?

24· · · · A.· · I do.

Page 15

·1· · · · Q.· · Okay.· I think you said earlier -- do

·2· you know what Atlas P5 Portfolio is?· Have you

·3· heard of those -- that entity before or no?

·4· · · · A.· · I know Atlas and Alliance have

·5· covered --

·6· · · · · · · · · · · · · ·(Brief interruption.)

·7· · · · MR. TAHMASSEBI:· Mr. Goldstein, if you're

·8· going to appear, we'd ask that you turn on your

·9· video.

10· · · · MR. GOLDSTEIN:· Turn it on?

11· · · · MR. TAHMASSEBI:· Yes.

12· · · · MR. GOLDSTEIN:· No.

13· · · · MR. TAHMASSEBI:· You're refusing to turn on

14· your video?

15· · · · MR. GOLDSTEIN:· I don't see why you have to.

16· I can't see you.

17· · · · MR. TAHMASSEBI:· Well, then you know what?

18· You don't have to see me.· The deponent is here.

19· I'm here live.

20· · · · · · · · ·Did you ever file an appearance in

21· the matter?

22· · · · MR. GOLDSTEIN:· Okay.· Wait a minute.· Who --

23· okay.· Just let's get -- let me -- I'm not -- I

24· just joined.· Who's talking?

Page 16

·1· · · · MR. TAHMASSEBI:· Sure.

·2· · · · MR. GOLDSTEIN:· Can you just identify

·3· yourself?· Because I came in late.· And then I

·4· can comment.

·5· · · · MR. TAHMASSEBI:· Yeah, you did come in late.

·6· My name is Amir Tahmassebi.· I represent the

·7· holdings entities.

·8· · · · MR. GOLDSTEIN:· Okay.

·9· · · · MR. TAHMASSEBI:· And I don't -- I did not see

10· your appearance on file, but I did tell you that

11· I'd, as a courtesy, allow you to appear.· But I'm

12· going to ask that if you're going to appear you

13· appear with your video.

14· · · · MR. GOLDSTEIN:· Okay.· And you did tell me

15· that I could appear, did you not?

16· · · · MR. TAHMASSEBI:· I said as a courtesy you

17· could appear.· But if you're going to appear,

18· you're going to have to follow the rules that we're

19· doing here in Illinois.· And if it's a dep via

20· Zoom, I'd want to see your video on.

21· · · · MR. GOLDSTEIN:· Okay.· And -- yeah.· Let's

22· try this.· Well, you -- wait a minute.· Okay.· But

23· you can't see me, so let's get this going in the

24· right direction.· Here you go.· Can you see me?

Page 17

·1· · · · MR. TAHMASSEBI:· Yes.

·2· · · · MR. GOLDSTEIN:· You see me now?

·3· · · · MR. TAHMASSEBI:· Yep.

·4· · · · MR. GOLDSTEIN:· Okay.· Now you can go on with

·5· your deposition.· Wait a minute.· I'll even make it

·6· better for you because you don't want to see that

·7· picture in the background.· I go through this all

·8· the time.· Okay.· Go ahead, and I'll fix it up,

·9· unless you want to wait until I get it absolutely

10· perfect for you.

11· · · · MR. TAHMASSEBI:· No, I don't want to wait any

12· longer than I've already waited for you.

13· · · · MR. GOLDSTEIN:· You didn't wait for me.

14· · · · MR. TAHMASSEBI:· Okay.· The -- I'm going to

15· continue.

16· · · · MS. STANISH:· I think Cy wanted to say

17· something.

18· · · · MR. GOLDSTEIN:· Just so we're clear, you did

19· consent to me appearing, did you not?

20· · · · MR. TAHMASSEBI:· I said yes.

21· · · · MR. GOLDSTEIN:· Okay.· Good.· Let's go.

22· BY MR. TAHMASSEBI:

23· · · · Q.· · Ms. Ivankovich, we were talking about

24· the Atlas P5 Portfolio and the Alliance.· And I

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 129 of 182 PageID #:3314
Page 18

·1· think you were going to discuss what your knowledge

·2· of those entities is or was.

·3· · · · A.· · I know there's multiple Alliance Atlas

·4· LLCs; whether it's portfolio, Birchwood, Multi-

·5· family, Atlas Homes, Atlas -- the specifics, but

·6· there's probably more than 15 or 20 --

·7· · · · Q.· · Okay.

·8· · · · A.· · -- that are associated with that, yes.

·9· · · · Q.· · And is it your understanding that

10· Mr. Ivankovich individually has some interest in

11· those entities?

12· · · · A.· · Yes.

13· · · · Q.· · Okay.· And where does that understanding

14· come from?· Mr. Ivankovich himself?

15· · · · A.· · Yes, directly from Steven.

16· · · · Q.· · And what has Steven told you?· And I'm

17· not asking for -- you don't have to go into the

18· specifics, but just that he's an owner of these

19· entities, has control over them?

20· · · · A.· · Yes.· From my understanding, he has

21· control of the funds going in and out, and he's a

22· partner.

23· · · · Q.· · And just so -- we list some of them.

24· The Alliance entities, there's a couple.· The Atlas

Page 19

·1· P5 Portfolio, that's one.· The Atlas P2 Portfolio.

·2· · · · · · · · ·What about the Ivankovich -- those

·3· are some that you've been told he has an interest

·4· in and controls the funds that are transferred in

·5· and out?

·6· · · · A.· · Yes.

·7· · · · Q.· · And then as far as the couple others I

·8· want to talk about -- you know what?· I'll show you

·9· a document so it'll make it easier.· We'll mark

10· this actually as Exhibit 2.

11· · · · · · · · ·I don't think I showed her the

12· affidavit.

13· · · · · · · · ·Exhibit 3 is a document that

14· actually Mr. Ivankovich was shown at his deposition

15· and authenticated the structure.

16· · · · · · · · ·But take a look at Exhibit Number --

17· Exhibit 2, just for the record, is a chart of a

18· number of different LLCS and kind of where they

19· stand as far as the subsidiaries and then the

20· ultimate ownership.· So I just want to talk a

21· little bit, Ms. Ivankovich, about some of these and

22· if you've been told at some point in time that, in

23· fact, Steven Ivankovich has an interest and/or

24· control over some of these LLCs.· And we can

Page 20

·1· either --

·2· · · · MR. PORRAS:· Amir, real --

·3· BY MR. TAHMASSEBI:

·4· · · · Q.· · We can either -- we can either do it

·5· you can go through it yourself, Ms. Ivankovich, and

·6· tell me the ones that you recognize or a variation

·7· thereof, or I can go through it one by one,

·8· whichever you prefer.

·9· · · · MR. PORRAS:· Amir, real quickly.· Real

10· quickly.· This is Cy Porras again.· Do you mind if

11· she just shows the camera what the exhibit shows so

12· I know what we're looking at?

13· · · · MR. TAHMASSEBI:· I don't mind, no.

14· · · · MR. PORRAS:· Okay.· I appreciate that.· Okay.

15· All right.· And that's Exhibit 3, I think.· Did

16· you --

17· · · · MR. TAHMASSEBI:· Exhibit 2.

18· · · · MR. PORRAS:· Okay.· It's marked as Exhibit 3.

19· · · · MS. STANISH:· That was one of my questions.

20· · · · · · · · ·My second question is this a

21· protected document under your protective order?

22· · · · MR. TAHMASSEBI:· This is not.

23· · · · MS. STANISH:· Okay.

24

Page 21

·1· BY MR. TAHMASSEBI:

·2· · · · Q.· · So do you recognize -- let's just start

·3· with the entity Overlook, Ms. Ivankovich.· Does

·4· that name ring a bell to you?· You'll see Steven V.

·5· Ivankovich listed as the managing member.

·6· · · · A.· · Managing member.

·7· · · · Q.· · Yeah.

·8· · · · A.· · Some of these are not familiar with

·9· me nor would they be because we wouldn't have

10· discussed them.· I do recall seeing in publications

11· that Steven was the facilitator of a sale for

12· Caribbean Isle for 49.5 million with a purchase

13· price four years previous of like 22 million and

14· that he was the CFO and the facilitator of that

15· sale.

16· · · · Q.· · You're talking about Pilgrim Caribbean

17· Isle, LLC?

18· · · · A.· · Yes.

19· · · · Q.· · Okay.· And then we talked about the

20· Alliance entities already, right?

21· · · · A.· · Yes.· And then the Alliance entities,

22· there's multiple that I've always assumed Steven

23· was part of based off conversations with him.

24· · · · Q.· · Okay.· And Mr. Ivankovich never told

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 130 of 182 PageID #:3315
Page 22

·1· you since COVID hit in 2020 up until you guys had a

·2· falling out that he had to transfer money out of

·3· these entities or he had to transfer his personal

·4· funds to the point where he could no longer afford

·5· to live the lifestyle you guys were living, correct?

·6· · · · A.· · He would not have shared that

·7· information with me.· That wasn't how our marriage

·8· operated.

·9· · · · · · · · ·But I will say that our lifestyle

10· did not reflect Steven transferring funds out.

11· · · · Q.· · Did Mr. Ivankovich ever tell you that

12· he was taking on a bunch of loans or personal

13· liability in order for you guys to maintain your

14· lifestyle?

15· · · · A.· · He told me that after I filed for

16· divorce.· But that was not part of our conversation

17· pre-divorce, no.

18· · · · Q.· · So it wasn't until you filed for

19· divorce that you heard from Mr. Ivankovich that he

20· was, quote, unquote, broke?

21· · · · A.· · That he was destitute, yes.

22· · · · Q.· · Okay.

23· · · · A.· · And looking for a job as a tennis

24· instructor or dive instructor.· Year and a half

Page 23

·1· still job hunting.

·2· · · · Q.· · He testified in our case that he was --

·3· spent his days sitting on the beach, playing

·4· tennis, and looking at girls.· Is that similar to

·5· what you're referring to?

·6· · · · A.· · No, no.· Because my experience with

·7· Steven is actually he worked around the clock and

·8· he traveled for work.· And he told me he was

·9· working hard.· And COVID definitely kind of pulled

10· back on a lot of his, quote, unquote, business

11· travel.

12· · · · · · · · ·But I was not told that he was

13· sitting on the beach looking at girls especially as

14· he was married.· I can't say what he's doing now.

15· But he's had a pretty active travel schedule for

16· somebody who doesn't have a job.· And he has

17· partners who accompany him on these trips, so ...

18· Living the life.

19· · · · Q.· · Exhibit No. 3.· And you touched on --

20· so Exhibit 3, for the record, is an affidavit filed

21· October 25th, 2021 in the divorce action here in

22· Cook County.· And just so I can confirm, there's --

23· on the last page, that's your it looks like kind of

24· stamped signature, right?

Page 24

·1· · · · A.· · Yes.

·2· · · · Q.· · Okay.· And this is an affidavit that

·3· you would have reviewed for its accuracy before you

·4· signed it?

·5· · · · A.· · Yes.

·6· · · · Q.· · Okay.· And this is what you touched on

·7· already.· I want to look at paragraph 16 on what is

·8· page 10 of the document, but that's because it's

·9· part of the --

10· · · · A.· · Yes.

11· · · · Q.· · Okay.· So you say here, While I am

12· unclear of Steven's income from all sources, on or

13· about September 30th, 2021, Steven purchased a

14· five-bedroom, 150-foot yacht for $3.5 million.· Do

15· you see that?

16· · · · A.· · Yes.

17· · · · Q.· · And as far as you know, that did occur

18· by Mr. Ivankovich?

19· · · · A.· · Yes.

20· · · · Q.· · And you, in fact -- at that time were

21· you guys still together, or was that --

22· · · · A.· · Yes.

23· · · · Q.· · All right.· And I'm assuming you knew

24· he purchased it because he told you, I bought this

Page 25

·1· yacht.

·2· · · · A.· · Yes.· I was in the process of helping

·3· him rehab it.

·4· · · · Q.· · Okay.· And, in fact -- and then he also

·5· told you, I'm assuming, around that same time that

·6· it cost about 20,000 -- well, let me back up.· Did

·7· he ever tell you that the yacht, the $3.5 million

·8· yacht, he couldn't afford it?

·9· · · · A.· · No.

10· · · · Q.· · Okay.· Do you know how or if he

11· financed the yacht at all?

12· · · · A.· · I don't know.· I wasn't privy to that.

13· · · · Q.· · Did he ever tell you at the time of

14· the purchase that it was someone else that

15· purchased it, not him?

16· · · · A.· · I mean, from my --

17· · · · Q.· · Just -- I'm sorry.· Did he ever tell

18· you?

19· · · · A.· · No.

20· · · · Q.· · Okay.· And then he also told you, it

21· sounds like, that it cost about 20,000 to dock it?

22· · · · A.· · Correct.

23· · · · Q.· · And did he ever tell you that someone

24· else -- did Mr. Ivankovich say someone else besides

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 131 of 182 PageID #:3316
Page 26

·1· him was covering that $20,000 at the time or on or

·2· around the time he purchased it?

·3· · · · A.· · That was not the implication.· The

·4· implication was it belonged to Steven.· He implied.

·5· · · · Q.· · And then it says 150,000 a year for the

·6· yacht's captain salary, which sounds about right.

·7· · · · A.· · That's what we discussed, because he

·8· wanted to replace the captain and how much it would

·9· cost to replace the captain of the boat.

10· · · · Q.· · And so I'm assuming when this purchase

11· was made, it was -- it's a big deal for you guys,

12· right?· Number one, it's fun and interesting.

13· · · · A.· · Yes.

14· · · · Q.· · Number two, it's expensive.

15· · · · A.· · Yes.

16· · · · Q.· · And number three, it was going to be a

17· lot of work for sounds like you and Mr. Ivankovich.

18· · · · A.· · Yes.

19· · · · Q.· · Okay.· Was there anybody else -- when

20· you -- I think you said you were going to assist

21· with the rehab of it.

22· · · · A.· · Yes.

23· · · · Q.· · I'm assuming remodeling, design, things

24· like that.

Page 27

·1· · · · A.· · Yes.

·2· · · · Q.· · Was there anybody else that you worked

·3· with in order to -- let me -- how can I put it?

·4· Aside from you and Mr. Ivankovich, were there other

·5· people that you were aware of that were directly

·6· involved with the rehab or with the operation of

·7· the yacht or with --

·8· · · · A.· · Many.· When you talk about a 150-foot

·9· boat, that's not something that can be carried out

10· by one or two people.

11· · · · Q.· · No.· But as far as who was in charge --

12· · · · A.· · Yes.

13· · · · Q.· · -- that would have been you guys, you

14· and Mr. Ivankovich?

15· · · · A.· · And Steve was employing other people to

16· help facilitate --

17· · · · Q.· · Got it.

18· · · · A.· · -- the rehab.

19· · · · Q.· · Okay.· Now I think we're on the same

20· page.· So in other words, obviously it takes a lot

21· of people to do what was being done.

22· · · · A.· · Correct.

23· · · · Q.· · So Steve would employ people to assist.

24· I'm assuming you would direct -- Steve and yourself

Page 28

·1· employed people to assist you on what needed to be

·2· helped with.

·3· · · · A.· · I had people helping me, and Steven was

·4· employing people.

·5· · · · Q.· · I guess what I'm getting at is as far

·6· as who the bosses were --

·7· · · · A.· · Steven.

·8· · · · Q.· · Okay.

·9· · · · A.· · Steven was the boss for sure.

10· · · · Q.· · Okay.

11· · · · A.· · There's text messages from people he

12· employed referring to him as boss man with this

13· project.

14· · · · Q.· · Okay.· And as far as you -- good

15· enough.· I don't want to get into it.· I read

16· about -- how many times did you actually go down

17· and -- let me back up.

18· · · · · · · · ·Approximately when did you go down

19· to first see the boat, the yacht, whatever we're

20· calling it?

21· · · · A.· · I think I spent two periods on the boat

22· before Steven had me falsely arrested.· And then I

23· filed for divorce.

24· · · · Q.· · And I don't want to go into that

Page 29

·1· because I'm sure it's not fun to talk about.· But

·2· the kids -- were the kids there on that trip?

·3· · · · A.· · The kids were on that trip, yes.

·4· · · · Q.· · And I'm assuming you were released and

·5· there were no charges filed.

·6· · · · A.· · I was released.· Steven pushed charges.

·7· The charges were dismissed.· And then Steven tried

·8· to get the charges reinstated.

·9· · · · Q.· · Okay.

10· · · · A.· · Unsuccessfully.· But continued to

11· threaten me with getting them reinstated for the

12· next year.· I then continued to show the children

13· the video of my arrest.

14· · · · Q.· · The purchase, it says, was on or around

15· September 30th, 2021.· Is that just -- is that date

16· based on what Steven told you?

17· · · · A.· · Yeah.· Probably a little earlier than

18· that.· But that is when I started to become

19· involved.

20· · · · Q.· · Okay.· Did you ever see any paperwork

21· relative to that purchase?

22· · · · A.· · No.

23· · · · Q.· · Okay.· Exhibit No. 4.· This is Exhibit

24· No. 4.· This is another affidavit.· And just if you

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 132 of 182 PageID #:3317
Page 30

·1· can just confirm for me on the last page, 13, that

·2· looks like the same signature stamp.

·3· · · · A.· · Yes.

·4· · · · Q.· · Okay.

·5· · · · MS. STANISH:· Can I have a copy?

·6· · · · MR. TAHMASSEBI:· Oh, I'm sorry.

·7· · · · THE WITNESS:· I think it's the same one.

·8· BY MR. TAHMASSEBI:

·9· · · · Q.· · Did I give you the same one?· I think

10· it's a little bit -- it's a little bit different.

11· · · · · · · · ·A lot of it, Exhibit 4, overlaps,

12· but I want to focus on one part that doesn't.· And

13· that's at the very -- it's on the very last page

14· too.

15· · · · A.· · Page 13?

16· · · · Q.· · Yes.· Thank you.· Page 13.

17· · · · · · · · ·So on paragraph 26 of page 13, the

18· affidavit says, Steven has sufficient housing

19· available to him in that his parents reside in a

20· luxury home in North Shore, Steven has friends that

21· live in the City of Chicago, and Steven has ample

22· moneys to pay for a hotel while not living on his

23· yacht in Florida, our rental apartment -- is that

24· Islamorada?

Page 31

·1· · · · A.· · Islamorada, correct.

·2· · · · Q.· · -- (continuing) or his parents' home in

·3· Key Biscayne.· Or "Biscon."· I don't know how --

·4· · · · A.· · Key Biscayne, yes.· Correct.

·5· · · · Q.· · And so when you say -- in this

·6· affidavit that's signed on October 25th, 2021, just

·7· give me an idea when you say that Steven has ample

·8· money to pay for a hotel kind of, you know, what's

·9· that based on.

10· · · · A.· · Well, it could be based on in December

11· 2022 we subpoenaed his passport, and Steven has

12· been in Dubai, Spain, France, the Cayman Islands,

13· the Dominican Republic, and other countries that I

14· can't name offhand --

15· · · · Q.· · Sure.

16· · · · A.· · -- where I'm sure he's paying for a

17· hotel living there.· So I think yes.· And Steven

18· has traveled extensively.· My impression was for

19· work.· That's what he always implied and told me.

20· But he has told the court that he hasn't had a job

21· for ten years, so ...

22· · · · Q.· · On that, I guess, as far as when you

23· were married, before the divorce was filed, did

24· the -- did you guys have a personal bank account?

Page 32

·1· · · · A.· · No.

·2· · · · Q.· · Okay.· Were all your accounts through --

·3· · · · A.· · Business.

·4· · · · Q.· · Businesses?

·5· · · · A.· · Yes.

·6· · · · Q.· · Okay.· And were you listed on those

·7· accounts as a signator?· Or at least somebody that

·8· could withdraw funds maybe would be a better way to

·9· put it.

10· · · · A.· · No.

11· · · · Q.· · Okay.· So then when you needed -- for

12· example, let's just go back in, say, the year 2020,

13· if you needed to get out cash, a thousand dollars.

14· · · · A.· · Steven would transfer money to a TRG

15· account, and then I would have access to it.· TRG

16· International.· That was what my debit card was.

17· Or he would Venmo me money.

18· · · · Q.· · Did -- and at that time, let's just say

19· 2020, 2021, before you and Mr. Ivankovich split up

20· or you filed for divorce, was there ever a time

21· where you said, Steven, I need five grand to go for

22· whatever, and he said, No, we can't afford that,

23· or, No, I'm not going to authorize that?

24· · · · A.· · I never really asked for five grand.

Page 33

·1· I would always get it in like couple grand

·2· increments.· But, no, I mean ...

·3· · · · Q.· · Any time you needed money at least --

·4· · · · A.· · Any time -- there were a couple points

·5· where I -- he wasn't able to provide money for

·6· whatever reason, and I would call his mother, and

·7· she would provide; for like tuition or children's

·8· expenses, if tuition was late.

·9· · · · Q.· · I think you said earlier that as far as

10· you understood there was always somewhat of a blur

11· between Mr. Ivankovich's personal finances and what

12· he would take from the businesses.

13· · · · A.· · Correct.

14· · · · Q.· · Can you expand on that a little?

15· · · · A.· · Yeah.· As Steven presented, we had a

16· Chase credit card that has business expenses and

17· personal expenses on it.

18· · · · Q.· · Okay.· And so the Chase credit card,

19· was that through -- do you know which business that

20· was through?· Was that one of the Atlas entities?

21· · · · A.· · I think his father was the primary card

22· holder, Anthony Ivankovich.

23· · · · Q.· · When you say it had business, as far as

24· personal, in other words, you would be able to use

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 133 of 182 PageID #:3318
Page 34

·1· the card?

·2· · · · A.· · Yes.

·3· · · · Q.· · And then also as far as you understood

·4· it, it was used for business expenses?

·5· · · · A.· · Yes.

·6· · · · Q.· · And which businesses in your mind?

·7· They kind of all --

·8· · · · A.· · I mean, Atlas is an umbrella company

·9· for multiple LLCs.· So Atlas Homes, Atlas -- I

10· don't know.· I didn't delve that far.

11· · · · Q.· · Atlas Homes, LLC, and then you knew --

12· · · · A.· · Management, you know.· I don't know

13· what else.

14· · · · Q.· · But as far as you understood that the --

15· a lot of Mr. Ivankovich's -- Steven Ivankovich's

16· business expenses were intermingled with some of

17· the personal expenses?

18· · · · A.· · Yes.

19· · · · Q.· · And I'm just going to -- try to let me

20· finish the question first so that Nick can take it

21· down.· You know where I'm going, and I know where

22· I'm going.· But I don't want him to -- and I think

23· just so that one's clear, the business expenses

24· that Mr. Ivankovich had for Atlas were intermingled

Page 35

·1· a lot of the times with your personal expenses,

·2· correct?

·3· · · · A.· · Correct.

·4· · · · Q.· · Okay.· An entity called A & O Family,

·5· LLC, are you familiar with that entity?

·6· · · · A.· · Yes.

·7· · · · Q.· · All right.· Let me show you what I'm

·8· going to mark as Exhibit 5.

·9· · · · A.· · Is this finished?

10· · · · Q.· · Yes.

11· · · · · · · · ·So Exhibit 5 is a document called

12· Asset Summary Atlas P5 Portfolio.· You said you

13· were familiar with the A & O Family, LLC?

14· · · · A.· · Yes.

15· · · · Q.· · Tell me what your understanding of what

16· that entity is.

17· · · · A.· · That it is the -- one of the multiple

18· family trusts that the Ivankovich family owns.

19· · · · Q.· · And do you understand that Mr. Ivankovich

20· is a beneficiary or has some type of interest?

21· · · · A.· · Yes.

22· · · · Q.· · And has he ever told you approximately

23· what that is?

24· · · · A.· · No.

Page 36

·1· · · · Q.· · Okay.· If you take a look at page --

·2· it's a double-sided one first.· But if you look at

·3· page 12 of Exhibit No. 5.

·4· · · · MS. STANISH:· Is this a protected document?

·5· · · · MR. TAHMASSEBI:· It is not.

·6· · · · MS. STANISH:· Okay.

·7· BY MR. TAHMASSEBI:

·8· · · · Q.· · And I want to look specifically at the

·9· third paragraph under the heading Comments about

10· two-thirds of the way down.

11· · · · A.· · Yes.

12· · · · Q.· · And just so you know, Ms. Ivankovich,

13· this is, you know, basically -- this was not

14· prepared by Mr. Ivankovich, but he testified he

15· provided information for Walker Dunlop to put this

16· together.

17· · · · A.· · Okay.

18· · · · Q.· · Third paragraph down under Comments,

19· Mr. Ivankovich reports his tangible net worth and

20· liquidity to be 42.7 million and 12.1 million

21· respectively as of January 2019.· And it goes on,

22· Of his 12.1 million in liquidity, 11 million is in

23· marketable securities and 1.1 million in cash.· Do

24· you see that?

Page 37

·1· · · · A.· · Yes.

·2· · · · Q.· · Is that consistent with what your

·3· understanding of Mr. Ivankovich's worth was at

·4· least on or around --

·5· · · · A.· · I had no direct under- --

·6· · · · MS. STANISH:· Hold on.· Let him finish.

·7· · · · THE WITNESS:· Oh, I'm sorry.

·8· BY MR. TAHMASSEBI:

·9· · · · Q.· · -- (continuing) on or around April of

10· 2019 at least based on how you guys lived your

11· life?

12· · · · A.· · Well, I had no information on the exact

13· amount.· I had information on our lifestyle.

14· · · · Q.· · And I think you said in some of the

15· papers that were filed in the divorce proceedings

16· that you guys were fortunate to live a very

17· extravagant lifestyle.

18· · · · A.· · Yes.

19· · · · Q.· · And then it goes on, The director of

20· investments at Stifel provided a letter stating

21· that the A & O Family, LLC, of which Steven

22· Ivankovich is 15.07 owner as well as one of the two

23· managing members, holds cash and marketable

24· securities in excess of 88 million (13.26 million

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 134 of 182 PageID #:3319
Page 38

·1· allocation) as of May 2019.· Do you see that?

·2· · · · A.· · Yes.

·3· · · · Q.· · And I know you don't know the exact

·4· percentage, but the statement here that he was an

·5· owner and one of the managing members, that's

·6· consistent with your understanding?

·7· · · · A.· · Yes.

·8· · · · Q.· · And you also -- maybe you -- I don't

·9· want to put words in your mouth.· But did you also

10· have an understanding that the A & O Family, LLC

11· had significant assets here it says?

12· · · · A.· · Yes.

13· · · · Q.· · And did Mr. -- and I would expect at

14· some point during the marriage Mr. Ivankovich told

15· you that he had access to funds that were held in

16· the A & O LLC and some of these other LLCs like the

17· Atlas LLCs.

18· · · · A.· · That would have never been a

19· discussion.· It just would have been implied from

20· our lifestyle.· We did not live a lifestyle of a

21· jobless man.

22· · · · Q.· · Okay.· So in other words, you had no

23· personal bank accounts, you said, right?

24· · · · A.· · No.

Page 39

·1· · · · Q.· · But somehow you were able to spend

·2· money on a lot of different things?

·3· · · · A.· · Yes.

·4· · · · Q.· · How much was your house before it went

·5· into that dilapidation because he didn't upkeep it

·6· approximately?

·7· · · · A.· · Well, it wasn't that it was

·8· dilapidated.· The house needed to be rehabbed.

·9· That was always our intention, to rehab it.· From

10· my understanding, it's -- it's a double lot back to

11· front in Old Town where there are no alleys.· So

12· it's tandem.· And Steven or an entity through

13· Steven has recently purchased the property next

14· door to, so now it's a three-lot property that his

15· intention, which has always been his intention --

16· he reached out to the owner multiple times before

17· the owner died and he purchased it -- to purchase

18· the property and let him live there for free.· But

19· now it's a three-lot property that I think he plans

20· to connect.

21· · · · Q.· · Does he still have an ownership

22· interest in it, or do you know?

23· · · · A.· · I mean, he has an ownership interest in

24· it through whatever he's covering himself.

Page 40

·1· · · · MS. STANISH:· Just so we're clear, which --

·2· are you referring to their original house, or are

·3· you --

·4· · · · THE WITNESS:· 235 West Menomonee.

·5· BY MR. TAHMASSEBI:

·6· · · · Q.· · Yeah, I want to go back to the

·7· original, so thank you for that clarification. I

·8· understand the one -- yeah, I'm familiar with the

·9· Old Town one.

10· · · · A.· · Yes.

11· · · · Q.· · He told me that that's in foreclosure,

12· but I don't know if that's true or not.

13· · · · A.· · I will just say it's been in foreclosure

14· for years, but the property taxes are always up to

15· date.

16· · · · Q.· · Okay.· Your prior home then, do you

17· know who owned that?· Was that you -- let's get the

18· address on the record.

19· · · · A.· · The rental?

20· · · · Q.· · No.· The one before -- the home that

21· you lived in once you -- you know, the time around

22· when you were first married and thereafter.

23· · · · A.· · That was 235 West Menomonee.

24· · · · Q.· · Oh, that was.· Okay.

Page 41

·1· · · · A.· · Yes.

·2· · · · Q.· · And that was a rental?

·3· · · · A.· · No.· We owned it.

·4· · · · Q.· · Do you know -- when you say "we owned

·5· it," was that you and him, or was that in some

·6· entity?

·7· · · · A.· · Steven had purchased it -- sorry.

·8· · · · Q.· · That's okay.

·9· · · · A.· · Steven had purchased it before we were

10· married, and my name was put on it in 2007 or 2008.

11· · · · Q.· · Let's take a look at Exhibit 6.

12· · · · · · · · ·Exhibit 6 is also not a protected

13· document, Counsel.

14· · · · A.· · Are we finished with this one?

15· · · · Q.· · Yes.· Thank you.

16· · · · · · · · ·Exhibit 6 is a document called

17· Answer to Amended Citation by Stifel Financial

18· Corp.· And I know, Ms. Ivankovich, it looks a

19· little bit -- very -- it's a court document.· But

20· what I want to focus on is the page No. 3.· And

21· what this is is a document that I requested

22· information as I would guess your counsel probably

23· did from Stifel.

24· · · · · · · · ·And towards the bottom there on

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 135 of 182 PageID #:3320
Page 42

·1· No. 13 and 14 on page 3, there is a P2 Portfolio

·2· Managing Member, LLC, and the account amount in

·3· that is $10,991.73.· Do you see that?

·4· · · · A.· · Yes.

·5· · · · Q.· · And is that one of the entities we

·6· talked about earlier that you had an understanding

·7· Mr. Ivankovich either owned a part of or controlled

·8· the finances?

·9· · · · A.· · Well, the other document said Atlas P2

10· Portfolio.· It doesn't say Atlas P.· But my

11· impression was Steven had -- he had involvement in

12· everything Atlas.

13· · · · Q.· · Okay.· And then the Ivankovich Family

14· LLC --

15· · · · A.· · Yes.

16· · · · Q.· · -- you've heard of that before?

17· · · · A.· · Yes.

18· · · · Q.· · Okay.· And is it your understanding

19· Mr. Ivankovich had some interest -- Steven

20· Ivankovich just to be clear -- in that --

21· · · · A.· · Yes.

22· · · · Q.· · And that comes from a discussion you

23· had with him?

24· · · · A.· · Yes.

Page 43

·1· · · · Q.· · All right.· And as far as you

·2· understood -- you kind of said it was implied he

·3· had access to these funds.· That was because of,

·4· again, the fact that any time you needed money or

·5· funds, it was there?

·6· · · · A.· · Yes.

·7· · · · Q.· · And as there were no personal bank

·8· accounts, you would expect that these funds were

·9· coming out of one of these entities that we've

10· mentioned if not numerous of them?

11· · · · A.· · They were coming from somewhere.

12· · · · Q.· · But as far as you understood, it was --

13· · · · A.· · Yes.

14· · · · Q.· · Let me just finish that question.

15· · · · · · · · ·So as you understood, it would be

16· one of the LLCs we've discussed, the Atlas, the

17· Ivankovich, the A & O?

18· · · · A.· · A trust -- Steven has a trust as well.

19· So it would have been an LLC or a trust.

20· · · · Q.· · What's his trust -- name of his trust,

21· do you know?

22· · · · A.· · I don't know.

23· · · · Q.· · Are there any other entities that we

24· haven't talked about so far, Ms. Ivankovich, that

Page 44

·1· your husband mentioned he had some ownership

·2· interest in or control over?

·3· · · · A.· · I did see approximately seven overseas

·4· accounts that Steven had bank numbers to on his

·5· desk.· They were under the heading Overseas

·6· Accounts.· They had the bank account numbers.· But

·7· at this point -- I took a picture of them because

·8· we were not doing well, and he had already filed

·9· for divorce a few times.· And I sent it somewhere.

10· I don't recall where I sent it just yet.

11· · · · · · · · ·But there are overseas accounts that

12· he must have access to or otherwise he would not

13· have had those numbers.

14· · · · Q.· · How long ago was that, do you know?

15· · · · A.· · We were at 2142 North Cleveland.· So

16· approximately two years ago.· It would have been

17· right before I filed for divorce.

18· · · · Q.· · And I think you were getting to the

19· picture.· Have you been able to locate that or not?

20· · · · A.· · I sent it somewhere to protect it.· And

21· I'm still trying to recall.

22· · · · Q.· · Okay.· Based on your interactions with

23· Mr. Ivankovich, would you expect that he, in fact,

24· does have overseas accounts?

Page 45

·1· · · · · · · · ·Oh, I'll let you --

·2· · · · MS. STANISH:· Okay.

·3· BY MR. TAHMASSEBI:

·4· · · · Q.· · Would you expect that he does have

·5· overseas accounts?

·6· · · · A.· · Yes.· And accounts here.· I mean, I

·7· know -- like I said, he purchased the property next

·8· door to 235 West Menomonee to make a three-lot

·9· through an LLC.

10· · · · · · · · ·He toured and represented himself as

11· a purchaser and resident to a multimillion dollar

12· apartment in Trump Tower.

13· · · · · · · · ·He told the kids he purchased -- a

14· year and a half ago that he purchased a farm in

15· Florida for them to live.

16· · · · · · · · ·So he's been on a spending spree.

17· I don't know whose money he's using.

18· · · · Q.· · And this has been over the past --

19· · · · A.· · Year and a half.

20· · · · Q.· · Year and a half.· Okay.

21· · · · A.· · Yes.

22· · · · Q.· · Your husband has said and made

23· representations in the court, the federal courts

24· here and I think --

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 136 of 182 PageID #:3321
Page 46

·1· · · · A.· · Steven.

·2· · · · Q.· · I'm sorry.

·3· · · · A.· · Thank you.

·4· · · · Q.· · Thank you.· I apologize.

·5· · · · · · · · ·Mr. Ivankovich has made

·6· representations in the federal courts here in

·7· Illinois and I believe also in the divorce courts

·8· that he's, in fact, destitute and has no funds --

·9· · · · A.· · Yes.

10· · · · Q.· · -- right?

11· · · · A.· · Yes.· Though it hasn't affected his

12· lifestyle.

13· · · · Q.· · Okay.· And so that goes to my next

14· question.· I'm kind of direct.· Do you believe that

15· that's true?

16· · · · A.· · No.

17· · · · Q.· · Okay.· And I think you've already

18· explained this, but just so we can kind of come

19· full circle.· Tell me, Jeanette, why you believe

20· he's making these -- why you believe the statements

21· he's making are false.

22· · · · A.· · He -- you have to understand he has

23· filed for divorce with me three separate times, and

24· each time told me he would leave me destitute, he

Page 47

·1· would get me committed for mental incompetency, he

·2· would take my children, he would leave me with

·3· nothing, that everything that he owned was hidden

·4· and I'd never have access to it.· So that's one

·5· thing that would make me think that.

·6· · · · · · · · ·Two, his lifestyle hasn't changed.

·7· He's deep sea fishing.· He's diving.· He's

·8· traveling.· He has a girlfriend.· He's living his

·9· best life and not supporting his kids.

10· · · · · · · · ·And so I -- he's got to have access

11· to money somehow, right?· I mean, it's not cheap to

12· go to the Maldives, to go to the Cayman Islands,

13· the Isle of Wight, Spain, Dubai, buy an apartment

14· in Trump Tower with HOA fees close to $3,000 a

15· month.

16· · · · · · · · ·He sent the kids home with -- he

17· takes them only -- he had -- he didn't see them for

18· a year, and then he started seeing them on holiday.

19· They'd come home with $1200 cash each in their

20· pocket, thousands of dollars worth of clothes, new

21· watches, iPhone 14s, brand new Macs, daily -- daily

22· private training sessions, thousand-dollar-a-day

23· Skip Barber driving school, private ski instruction,

24· you know, with a seven-bedroom ski-out home.· This

Page 48

·1· is not a man that's living a destitute life.

·2· · · · Q.· · Yeah.· Well, we agree on that.

·3· · · · · · · · ·His family I want to talk a little

·4· bit about.

·5· · · · A.· · Yes.

·6· · · · Q.· · Okay.· He has a -- his parents are, I

·7· think we talked about, down in Key Biscayne?

·8· · · · A.· · They spent at least six months and one

·9· day in Florida to validate them as Florida residents.

10· And then they have a waterfront home in Wilmette on

11· Michigan Avenue a couple -- beautiful.· It's

12· gorgeous.· It's a couple houses down from Gillson

13· Beach.

14· · · · Q.· · In Wilmette, Illinois?

15· · · · A.· · Yes.

16· · · · Q.· · Okay.· And so are they -- do you know

17· where they're -- you would expect they're in

18· Florida during the winter months here.· But, you

19· know, based on your experience, do you know when

20· they're usually there and when they're usually up --

21· · · · A.· · Now I pretty much cut off contact

22· except to ask his mom to make this nonsense stop.

23· · · · Q.· · Yeah.

24· · · · A.· · They would spend the winter months in

Page 49

·1· Florida and then the summer months in Wilmette.

·2· · · · Q.· · And then what's -- do you know the

·3· address by chance of the house?

·4· · · · A.· · Yes.· 1150 North Michigan Avenue -- or

·5· 1150 Michigan Avenue, 60697 -- 60- -- I can't

·6· remember.· It was their credit card.

·7· · · · Q.· · It was a credit card address?

·8· · · · A.· · It was a credit card address, but it's

·9· changed now to Key Biscayne because Steven is now a

10· Florida resident, I guess.

11· · · · Q.· · And then how old are his parents, do

12· you have an idea?

13· · · · A.· · 83.

14· · · · Q.· · Mr. Ivankovich testified -- Steven

15· Ivankovich testified that his father still had

16· significant roles in the businesses and was the one

17· still in charge.· And you may not have knowledge of

18· this.

19· · · · A.· · No.· I have enough knowledge to know

20· that the last times that I've seen Steven's father,

21· he's not doing well and he's not in charge.

22· · · · Q.· · So if Steven Ivankovich were to have

23· told me under oath when I asked him the question

24· about who controls the money, the transfers of a

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 137 of 182 PageID #:3322
Page 50

·1· lot of these LLCs, and he would say, Oh, you'd have

·2· to ask my elderly -- my father, and I said, Your

·3· 80-year-old father? and he said, Yes ...

·4· · · · A.· · His father -- his father is sick, and

·5· his father can't speak very well or so or make

·6· decisions like that.· I would say the decision-

·7· making is Steven and Steven's mother.

·8· · · · Q.· · And how long -- and without getting too

·9· much into his health, but based on your observations,

10· how long has that been the case?· Two or three

11· years?· Five years?

12· · · · A.· · Yeah, over two years.

13· · · · Q.· · Over two years.

14· · · · · · · · ·And then his mother, is she a little

15· bit younger or around the same age?

16· · · · A.· · No.· She's the same sage.

17· · · · Q.· · And as far as you -- and the last time

18· when -- you still talk to her, I think you said,

19· to say help stop what's going on or help your

20· grandchildren or whatever.

21· · · · A.· · I stopped talking to them when I

22· realized the path of destruction the whole family

23· was on against me.· But I do reach out in times

24· of desperation to his mother because -- this is a

Page 51

·1· pattern.· They did the same thing with Steven's

·2· brother's divorce and the way they treated his wife

·3· and his brother's children and ...

·4· · · · Q.· · So -- and that goes into my next

·5· question.· His brother -- he has the one brother

·6· that's supposedly the -- whatever, the jazz or

·7· something --

·8· · · · A.· · He's a musician, and he's a doctor,

·9· correct.· He's an orthopedic surgeon.

10· · · · Q.· · And you said he went through a divorce

11· where the Ivankovich family did a similar thing to

12· his ex-wife?

13· · · · A.· · Yes.

14· · · · Q.· · I would expect you haven't had any

15· communications with him in the last couple years,

16· or have you?

17· · · · A.· · I've had -- he's checked in on me

18· knowing what I've gone through.· But I haven't had

19· any conversation with him probably in over six

20· months, six, seven months.

21· · · · Q.· · Do you know where he lives?

22· · · · A.· · He lives in Gary, Indiana.

23· · · · Q.· · Any idea like --

24· · · · A.· · On the beach.· They purchased -- him

Page 52

·1· and his wife, current wife, purchased a beachfront

·2· home.

·3· · · · Q.· · And they've had that for a couple years

·4· now as far as you know?

·5· · · · A.· · Yeah, couple years.· I don't know

·6· exactly how long.

·7· · · · MR. TAHMASSEBI:· Okay.· Give me two-minute

·8· break, and then I think I'm close to done.

·9· · · · THE WITNESS:· Okay.

10· · · · MR. TAHMASSEBI:· Guys, we're going to take a

11· two-minute break.· All right?

12· · · · MR. PORRAS:· Okay.

13· · · · · · · · · · · · · ·(Recess taken.)

14· · · · MR. TAHMASSEBI:· We're back on the record.

15· BY MR. TAHMASSEBI:

16· · · · Q.· · You mentioned the purchase in the Trump

17· Tower.

18· · · · A.· · Yes.

19· · · · Q.· · And that -- I think you said it was --

20· at least Mr. Ivankovich facilitated it, signed for

21· whatever LLC as far as you understand?

22· · · · A.· · Yes.

23· · · · MR. TAHMASSEBI:· Okay.· I don't have anything

24· further.

Page 53

·1· · · · MR. PORRAS:· Okay.· I do have a few follow-up

·2· questions related to the remaining LLCs.

·3· · · · THE WITNESS:· Does he get to ask me questions?

·4· · · · MS. STANISH:· Yes.

·5· · · · THE WITNESS:· Okay.

·6· · · · MR. TAHMASSEBI:· Just a few.

·7· · · · MR. PORRAS:· And just for the record again,

·8· Cy Porras for the intervenor LLCs.· I know the

·9· court reporter had asked, I think that's just for

10· the sake of the record, which LLCs I represent.

11· There's about 17.· So I'll provide it afterwards.

12· · · · · · · · · · EXAMINATION

13· BY MR. PORRAS:

14· · · · Q.· · But in any event, Ms. Ivankovich, I'm

15· going to ask you a few questions based off the

16· information you talked to Mr. Tahmassebi about.

17· · · · A.· · Ivankovich.

18· · · · Q.· · So just to be clear, Mr. Tahmassebi is

19· the attorney in front of you.· He asked you a few

20· questions.· Those are the questions and information

21· I want to ask you about.· Okay?

22· · · · A.· · Okay.

23· · · · Q.· · So you testified about Steven's

24· ownership, control of multiple Alliance LLCs.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 138 of 182 PageID #:3323
Page 54

·1· · · · · · · · ·Do you know the names of those LLCs?

·2· · · · A.· · No.· I think I stated that earlier,

·3· that there were multiple and just through inference

·4· that Steven was part of all of them per Steven.

·5· · · · Q.· · I see.· Okay.· So you don't know the

·6· names of them, but it's your suspicion that he

·7· controlled or was involved --

·8· · · · MR. TAHMASSEBI:· Hold on.· Let me just show

·9· an objection because she did go through the names,

10· number one.· And she didn't say it was her

11· suspicion.· She said it was based on discussions

12· with Mr. Ivankovich.· So let's not be putting words

13· in her mouth to make it sound like she doesn't have

14· knowledge of something she already testified she

15· had personal knowledge of.

16· · · · THE WITNESS:· We were married for 17 years,

17· Cy, and together for over 18.· So we had many

18· discussions over that.

19· BY MR. PORRAS:

20· · · · Q.· · And you just said that you inferred

21· that information; is that right?

22· · · · MR. TAHMASSEBI:· Again, I think that was

23· based on you leading her, which you're allowed to

24· do.

Page 55

·1· · · · · · · · ·But you can answer however you want.

·2· · · · THE WITNESS:· Did we go through every single

·3· LLC associated with Atlas?· No.· But we had

·4· discussions on Atlas entities without naming them

·5· specifically.

·6· BY MR. PORRAS:

·7· · · · Q.· · Okay.· And what were some of the names

·8· if you remember today of the Atlas entities that

·9· you recall?

10· · · · A.· · Atlas Alliance.· That's all that really

11· needed to be said.· And whatever follows was kind

12· of umbrellaed under Atlas and Alliance.

13· · · · Q.· · Okay.· So did you have any independent

14· knowledge other than your conversations with Steven

15· that led you to believe that Steven had control or

16· ownership of Atlas Alliance or any other LLCs?

17· · · · A.· · Unless Steven's a liar.

18· · · · Q.· · I'm sorry.· So --

19· · · · A.· · If Steven's a liar, then he doesn't.

20· But that's what he told me.· We've been together

21· for over 18 years, Cy.

22· · · · Q.· · Okay.

23· · · · A.· · We've had multiple conversations

24· regarding that, yes.

Page 56

·1· · · · Q.· · All right.· I'm just going to ask the

·2· question again to make sure you understand.· So

·3· aside from those conversation, did you have any

·4· independent knowledge as to whether Mr. Ivankovich,

·5· Steven, had control or ownership of any Atlas

·6· Alliance LLC or any other LLCs?

·7· · · · A.· · Define "independent."

·8· · · · Q.· · So I believe my question was outside

·9· of those conversations, did you have any other

10· information that led you to believe that?

11· · · · A.· · Conversations with his parents.

12· Conversations with his family.· Conversations with

13· people who worked at Alliance Atlas, yes.

14· · · · Q.· · Okay.· And what were the names of those

15· people that you spoke with at --

16· · · · A.· · Olga, Antonia Ivankovich, Mark Brown,

17· Leslie Andren, Ravi Malli, David Latham, Jason

18· Wandner.· Who else?· I mean, you'd have to give me

19· a moment to go back.· Keep in mind, again, we've

20· been together for 18 years, so ...

21· · · · Q.· · Okay.· So based on that 18-year

22· relationship, can you name the Atlas Alliance LLCs

23· aside from just the name Atlas Alliance?

24· · · · A.· · No.· There would be no need for me to

Page 57

·1· name them.· Atlas and Alliance are umbrella

·2· companies for multiple LLCs.

·3· · · · Q.· · Okay.· What are the names of those

·4· multiple LLCs?

·5· · · · A.· · There's no need for me to name them.

·6· They're umbrellas.

·7· · · · Q.· · So, ma'am, it's your deposition.· I'm

·8· asking a question.· If you do know the answer, I

·9· ask that you respond.· If you don't know, you can

10· tell me you don't know.· But to your knowledge,

11· what are the names of those Atlas LLCs?

12· · · · MS. STANISH:· She's answered multiple times.

13· · · · MR. TAHMASSEBI:· Yeah.· I don't think she

14· needs to answer it again.

15· · · · MR. PORRAS:· I'm sorry.· What was the

16· objection?

17· · · · MS. STANISH:· Asked and answered multiple

18· times.

19· · · · MR. PORRAS:· What was her answer?

20· · · · MS. STANISH:· Do you want the court reporter

21· to read it back all the times she answered?

22· · · · MR. PORRAS:· We can -- Mr. Court Reporter,

23· would you mind reading back the last answer from

24· the witness.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 139 of 182 PageID #:3324
Page 58

·1· · · · · · · · · · · (The record was read as follows:

·2· · · · · · · · · · · ·Q. There's no need for me to

·3· · · · · · · · · · · ·name them.· They're umbrellas.)

·4· · · · MR. PORRAS:· Okay.· So to me she's not

·5· answered the question.· If she's refusing to answer

·6· the question, then I could reserve the question for

·7· the judge.· But to the extent that she's here today

·8· and has knowledge, I think she should answer.

·9· · · · MR. TAHMASSEBI:· You're going to reserve a

10· silly question like that for the judge?

11· · · · MR. PORRAS:· Is she refusing to answer?

12· · · · MR. TAHMASSEBI:· I think she's answered to

13· the best of her knowledge.

14· · · · · · · · ·Do you have anything to add?

15· · · · MR. PORRAS:· No.· I think she's evading the

16· question.· So to the extent that she can answer --

17· · · · THE WITNESS:· Are you kidding?· There's a lot

18· of evading going on.· But, no, not by me.

19· BY MR. PORRAS:

20· · · · Q.· · By you, ma'am?

21· · · · A.· · No, not by me.

22· · · · Q.· · I understand.· So are you refusing to

23· answer the question?

24· · · · A.· · No.· I think I answered it, Cy.

Page 59

·1· · · · MS. STANISH:· Answer it again, Jeanette, just

·2· so Cy is clear as to what your answer is.· Why

·3· don't you go ahead and answer it for him for the

·4· fourth time.

·5· · · · THE WITNESS:· So any conversations that were

·6· had, Atlas and Alliance would have been umbrella

·7· companies for all the LLCs.

·8· BY MR. PORRAS:

·9· · · · Q.· · Okay.· And what are the names of those

10· LLCs that are under the umbrella of Atlas Alliance?

11· · · · MS. STANISH:· If you can remember any names

12· as you sit here today, name them.· If you can't,

13· tell him you can't remember the names.

14· · · · THE WITNESS:· Atlas Homes, Atlas Management,

15· Atlas, LLC, Atlas P2, P3, P4, Atlas Caribbean,

16· Atlas -- I mean, they're all, right?

17· BY MR. PORRAS:

18· · · · Q.· · Sure.· And to your memory, was the name

19· Atlas in all the LLCs' names?

20· · · · A.· · There would have been Alliance in some.

21· But, no, there are -- there's so many, Cy.

22· · · · Q.· · Sure.· Okay.· I understand.· And today

23· is not meant to be a memory quiz.· It's not meant

24· to be --

Page 60

·1· · · · A.· · That's what you're turning it into.

·2· · · · Q.· · So it's not meant to be anything other

·3· than what you remember today.· If you don't

·4· remember, you can just let me know that.· That's

·5· fine.

·6· · · · · · · · ·So I think you also said that

·7· there's about 15 to 20 businesses that you believe

·8· Steven Ivankovich controls.· Is that number

·9· accurate to your memory?

10· · · · A.· · I think you said there's 17.

11· · · · Q.· · So --

12· · · · A.· · I think that's what was said.· I think

13· there's multiple -- was it 10 to 20?· There's a

14· lot, yes.

15· · · · Q.· · Okay.· So does 15 to 20 sound accurate?

16· · · · A.· · I'm not going to go on record with

17· that.· That's guessing.

18· · · · Q.· · Why not?

19· · · · A.· · Because it's guessing.· And then

20· guessing turns back into "I don't know" and I'm

21· lying.· It turns into something leading.· So I'm

22· not going to guess, Cy.

23· · · · Q.· · Okay.· And then for the names of LLCs,

24· were you also guessing there?

Page 61

·1· · · · A.· · Can I say asked and answered?

·2· · · · MS. STANISH:· No.· Just answer his question.

·3· · · · THE WITNESS:· Am I guessing?· No.· I'm not

·4· guessing.· Those were ones that I knew for sure.

·5· BY MR. PORRAS:

·6· · · · Q.· · Okay.· And did you ever see the

·7· businesses' operating agreements?

·8· · · · A.· · No.

·9· · · · Q.· · Okay.· And, I'm sorry, did you know

10· what an operating agreement is?

11· · · · A.· · I mean, for the most part, yes.

12· · · · Q.· · Okay.· And did you see any bank

13· statements for any of these businesses?

14· · · · A.· · No.· I would be relying on Steven's

15· word.

16· · · · Q.· · Okay.· So your testimony as to any and

17· all of Steven's businesses, as you put it, is based

18· off your conversations with either him or his

19· family members or individuals that you believe

20· worked for those businesses; is that right?

21· · · · A.· · I don't believe they worked for those

22· businesses.· They did work for those businesses

23· according to them and according to their website.

24· And that I trusted what came out of my husband's

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 140 of 182 PageID #:3325
Page 62

·1· mouth as the truth, yes.

·2· · · · Q.· · Okay.· So just to be clear, yes, it's

·3· based off conversations you had various individuals

·4· including your ex-husband, Mr. Ivankovich?

·5· · · · A.· · He's not ex yet.· We're working towards

·6· that.

·7· · · · Q.· · Okay.· But that's a yes to the

·8· question, correct?

·9· · · · A.· · Yes.

10· · · · Q.· · Okay.· And did you ever work for any of

11· those businesses?· And to put it a different way,

12· were you ever employed by any of the businesses

13· directly?

14· · · · A.· · No.· Despite my husband claiming that I

15· had sex with men for money and drugs, I have never

16· worked outside of the home during our marriage,

17· including at Atlas.

18· · · · Q.· · Okay.· I understand.· So you've not

19· been employed by any business including Atlas

20· obviously?

21· · · · MR. TAHMASSEBI:· She just answered -- asked

22· and answered.

23· · · · MS. STANISH:· Answer again so he's clear of

24· his answers.

Page 63

·1· · · · THE WITNESS:· I have never worked for Atlas

·2· Homes, Management, LLC, P2, P3, P4, Atlas

·3· Caribbean, Atlas Forest, Atlas Alliance.· No.

·4· BY MR. PORRAS:

·5· · · · Q.· · Okay.· During your marriage to

·6· Mr. Ivankovich, were you ever employed by anyone

·7· even if it wasn't related to Mr. Ivankovich's

·8· business as you put it?

·9· · · · MR. TAHMASSEBI:· Asked and answered again.

10· · · · MS. STANISH:· Answer it.

11· BY MR. PORRAS:

12· · · · Q.· · You can go ahead and answer.

13· · · · A.· · No.

14· · · · Q.· · Thank you.

15· · · · · · · · ·Did you know the -- who the

16· members -- or do you know who the members of

17· the LLCs that you believe are controlled by

18· Mr. Ivankovich are?· Do you know who the members

19· of those LLCs are?

20· · · · MR. TAHMASSEBI:· Aside from what's she's

21· already testified to, that Mr. Ivankovich -- Steven

22· Ivankovich was a member?

23· · · · MR. PORRAS:· Yes.· Go ahead.

24· · · · THE WITNESS:· I know Steven was a member. I

Page 64

·1· know his mother, his father.· I was told my

·2· children are.· Steven told me he was trying to

·3· remove his brother's children from the LLCs because

·4· they don't deserve anything.· My assumption would

·5· be Dan, his brother, would be part of the LLCs

·6· based off of our conversations.· But that's it.

·7· BY MR. PORRAS:

·8· · · · Q.· · Okay.· And is it your understanding

·9· that all the LLCs have all the same members?

10· · · · A.· · No, that would not be my understanding

11· at all.

12· · · · Q.· · And so do you have an understanding of

13· which LLCs have which members?

14· · · · A.· · No.

15· · · · Q.· · Okay.· And it's, I believe, your

16· testimony that Steven Ivankovich makes all the

17· decisions on behalf of these various LLCs that

18· we're referring to; is that right?

19· · · · A.· · I would say up until the last two or

20· three years before his father got sick to the point

21· where he couldn't -- couldn't participate in

22· decisions anymore that they were jointly based. I

23· think Steven and his mother make those decisions

24· based off of conversations that I've had with both

Page 65

·1· Steven and his mother for those.· But I would say

·2· at this point the majority of the decisions are

·3· made by Steven.

·4· · · · Q.· · Okay.· So I understand, at some point

·5· prior to Steven's father getting sick, the father

·6· was involved in some of the decisions on behalf of

·7· these LLCs; is that right?

·8· · · · A.· · Yes.

·9· · · · Q.· · Okay.· And in conjunction -- or rather,

10· is it your testimony that in conjunction with

11· Mr. Ivankovich's father that Steven and his mother

12· also were part of the decisionmaking process for

13· those LLCs at the same time the father was?

14· · · · A.· · No.· I don't think Steven's mother was

15· as heavily involved until Steven's father got sick.

16· That would be my -- that would be my impression as

17· a member of the immediate family.

18· · · · Q.· · Okay.· So that was based off, again,

19· your impressions from being around the family and

20· talking to Steven and other family members; is that

21· right?

22· · · · A.· · Correct.

23· · · · Q.· · Okay.· And then after Mr. Ivankovich's

24· father became ill, his mother, Steven's mother,

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 141 of 182 PageID #:3326
Page 66

·1· came on and also was making decisions about the

·2· LLCs or aiding in making decisions; is that right?

·3· · · · A.· · That would have been my impression

·4· based off of conversations.

·5· · · · Q.· · And I believe you testified that Steven

·6· Ivankovich controlled the funds of the LLCs.· Do

·7· you recall testifying to that?

·8· · · · A.· · I recall saying that would be my

·9· impression based off of conversations.

10· · · · Q.· · Okay.· So just so I understand that,

11· your understanding that Steven Ivankovich controls

12· the funds of the LLCs is based solely off your

13· conversations with Mr. Ivankovich, is that right,

14· with Steven Ivankovich?

15· · · · A.· · Me being under the impression that my

16· husband was not lying to me, yes, my impression was

17· that he did have control over decisionmaking of

18· those LLCs.

19· · · · Q.· · Okay.· But what about, say, specific

20· control of the LLCs' funds; so did he ever say to

21· you, I can go and take out money from this LLC bank

22· account?

23· · · · MR. TAHMASSEBI:· Asked and answered again.

24· She's already testified to that.

Page 67

·1· · · · · · · · ·But you can answer again.

·2· · · · THE WITNESS:· No, that wouldn't be a

·3· conversation that we had.· The conversation would

·4· have been we needed money and then money appeared.

·5· So whether it was magically through the sky or from

·6· an LLC, it came from somewhere.

·7· BY MR. PORRAS:

·8· · · · Q.· · Okay.· But you don't know where that

·9· money would have come from that Steven was using

10· for his own personal life; is that fair to say?

11· · · · MR. TAHMASSEBI:· Again, she already testified

12· from the LLCs.· You're trying to go back on her

13· prior testimony.· I think it's improper especially

14· in what would be an evidence deposition.· So I'm

15· going to object that you're misstating her --

16· you're trying to make her go back on what she's

17· already said.

18· · · · MR. PORRAS:· I'm only reiterating what she

19· just said right now to make sure I understand and

20· to clarify any further points so --

21· · · · MR. TAHMASSEBI:· Well, that's not what she

22· said.· But go ahead.

23· BY MR. PORRAS:

24· · · · Q.· · Ms. Ivankovich, did you answer the

Page 68

·1· question?· I'm sorry.· Did you understand the

·2· question?

·3· · · · A.· · Can you ask it again?

·4· · · · MR. PORRAS:· Sure.· So -- and actually,

·5· Mr. Court Reporter, do you mind reading back the

·6· question.

·7· · · · · · · · · · · (The record was read as follows:

·8· · · · · · · · · · · ·Q. But you don't know where

· · · · · · · · · · · · ·that money would have come from

·9· · · · · · · · · · · ·that Steven was using for his

· · · · · · · · · · · · ·own personal life; is that fair

10· · · · · · · · · · · ·to say?)

11· · · · THE WITNESS:· I guess that money would be

12· traceable if you follow through with the subpoena

13· on our credit cards and how everything was funded

14· through our lifestyle.· Then there would be no

15· questions.

16· BY MR. PORRAS:

17· · · · Q.· · Okay.· Sorry, ma'am.· So just so I

18· understand, to your knowledge, you don't have any

19· understanding of where those funds came from?

20· · · · A.· · To my knowledge, my husband had a job

21· for our entire marriage that he was able to pull

22· funds from.· Yes, that was my impression.· That was

23· the impression that Steven gave me.· That was the

24· impression that I had.· The LLCs are attached to

Page 69

·1· the business, so I would assume as money came in,

·2· like he said, that he would be able to pull from

·3· it.

·4· · · · · · · · ·Do I have specifics for you?· No,

·5· I do not.· But we could get specifics through

·6· subpoenas and forensic accounting.· So if you're

·7· that concerned, we could move forward with that.

·8· · · · Q.· · Okay.· And when was, to your knowledge,

·9· Steven Ivankovich last employed?

10· · · · A.· · To my knowledge, he's still employed.

11· · · · Q.· · Okay.· And who employs Steven

12· Ivankovich?

13· · · · A.· · To my knowledge, he's still working for

14· the family business.· And that's based off of what

15· he has said himself under deposition six months

16· ago, seven months ago.

17· · · · Q.· · And when you say "working for the

18· family business," does that family business have a

19· name?· Is there a specific entity?

20· · · · A.· · I think it has approximately 17 names

21· according to you.

22· · · · Q.· · Okay.· So when you refer to the family

23· business, are you referring to the LLCs that we've

24· been talking about?

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 142 of 182 PageID #:3327
Page 70

·1· · · · A.· · Yes.· And more.· And more.· Now,

·2· there's been new outside of Atlas that has -- that

·3· have been added.

·4· · · · Q.· · Okay.· And, sorry, which ones are

·5· those?

·6· · · · A.· · Just get a forensic accountant to come

·7· up with them.

·8· · · · Q.· · Do you have an independent knowledge as

·9· to what those --

10· · · · A.· · I have an independent knowledge that

11· there are boats and houses and apartments and

12· travel that has all been used and taken by

13· Mr. Ivankovich.· I know specifically he's used two

14· different LLCs to represent himself in the Trump

15· Tower.· I know he's used an LLC to represent

16· himself in the 235 West -- 233 West Menomonee. I

17· know he has presented himself as the owner of the

18· Octopussy based on text messages that I have had

19· with vendors coming to me, employees coming to me.

20· · · · · · · · ·So, yeah, there's more, Cy.· I think

21· a forensic accountant could clear all this up for

22· everyone.

23· · · · Q.· · Okay.· I'm sorry.· I don't know what

24· the Octopussy is.· What is the Octopussy?

Page 71

·1· · · · A.· · Oh, he hasn't invited you on his boat

·2· yet?· It is a 150-foot motor yacht undergoing an

·3· extensive rehab.

·4· · · · Q.· · Okay.· So that's the boat that you were

·5· talking with Mr. Tahmassebi about earlier; is that

·6· right?

·7· · · · A.· · That would be the boat that Steven had

·8· me falsely arrested on.· I'm sure you're aware of

·9· that.

10· · · · Q.· · And you said that Steven owns it

11· through an LLC.· How do you know that?

12· · · · MR. TAHMASSEBI:· Well, hold on.· I don't

13· think she said that.· So I think it misstates --

14· objection; misstates.

15· · · · THE WITNESS:· I mean, Steven implied to me as

16· his wife through texts and through conversations

17· and through emails that that boat was going to be

18· used for personal and work events.· And so if he

19· didn't buy it himself, he bought it through an LLC,

20· which seems to be a pattern.

21· BY MR. PORRAS:

22· · · · Q.· · Do you know who owns that boat?

23· · · · MR. TAHMASSEBI:· Objection.· She already

24· testified that she believes --

Page 72

·1· · · · THE WITNESS:· An LLC owns it.

·2· · · · MR. TAHMASSEBI:· -- either Steven

·3· individually or an LLC.· She said that twice now.

·4· BY MR. PORRAS:

·5· · · · Q.· · Okay.· So do you know who owns that

·6· boat?

·7· · · · A.· · Steven or the LLC.

·8· · · · Q.· · Okay.· When you say "the LLC," does

·9· that LLC have a name?

10· · · · A.· · Why don't you ask Steven, Cy?

11· · · · Q.· · Do you know the name of the LLC that

12· you think may own that boat?

13· · · · MS. STANISH:· Answer if you know or don't

14· know.

15· · · · THE WITNESS:· There is like Contessa Marine

16· Research.· It's something like that.· I know that's

17· purchased.· I know the St. Anthony was used to --

18· an LLC to purchase.· I mean, Steven creates LLCs

19· like passing out candy on Halloween.· Everything's

20· an LLC, you know.· You know how rich people do

21· things.

22· BY MR. PORRAS:

23· · · · Q.· · I see.· And for the properties you

24· mentioned that Steven purchased, and I believe --

Page 73

·1· correct me if I'm wrong, but I think you said he

·2· purchased through an LLC; is that right?

·3· · · · A.· · Yes.

·4· · · · Q.· · Okay.· Do you know the names of those

·5· LLCs?

·6· · · · A.· · Delaware something.· I don't -- I don't

·7· recall off -- if I saw it --

·8· · · · MS. STANISH:· If you want them, they are

·9· admitted into evidence in the divorce proceedings.

10· We can get them for you.

11· · · · THE WITNESS:· Yeah, they're admitted into

12· evidence in the divorce proceedings.

13· BY MR. PORRAS:

14· · · · Q.· · Okay.· And sitting here today, to your

15· recollection, Delaware something or another, I know

16· you don't recall the other ones, just sitting here

17· today; is that right?

18· · · · A.· · My answer is they're submitted into

19· evidence through the divorce proceedings.· Please

20· feel free to reference.

21· · · · Q.· · Okay, ma'am.· So we're here for your

22· deposition today obviously in a different proceeding.

23· · · · MS. STANISH:· If you remember their names as

24· you sit here today, say yes or no, I remember them

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 143 of 182 PageID #:3328
Page 74

·1· or don't remember them.

·2· · · · THE WITNESS:· I don't remember them, no.

·3· · · · MR. TAHMASSEBI:· Let's not waste time on

·4· that.

·5· · · · MS. STANISH:· We'll be happy to get you the

·6· names.· I'll send them to you.

·7· · · · MR. TAHMASSEBI:· They said they're going to

·8· give you the names.· I mean, come on.

·9· · · · MS. STANISH:· And they're incor- -- one of

10· them at least is incorporated in Delaware, which

11· is, I think, what she's remembering.

12· · · · MR. TAHMASSEBI:· If you're truly concerned

13· about the information, they said they'd provide it.

14· So you don't need to sit here and harass the

15· witness about, Well, you're here for your deposition.

16· · · · MR. PORRAS:· Amir, I don't think I'm

17· harassing her at all.· I think I'm asking her

18· questions, and I think she's evading them.· And I

19· think you're raising objections on her behalf --

20· · · · THE WITNESS:· Evading?· No.· I think I've

21· answered every question you've asked.

22· · · · MR. PORRAS:· I just want to put that on the

23· record, and I'm going to continue asking questions --

24· · · · THE WITNESS:· Several times.

Page 75

·1· · · · MR. PORRAS:· -- Ms. Ivankovich.

·2· · · · THE WITNESS:· I'm not evading anything, Cy.

·3· I'm here.· I showed up for my deposition.· I'm

·4· answering you honestly.· That's more than your

·5· representation can ...

·6· BY MR. PORRAS:

·7· · · · Q.· · Okay.· So when you said that Steven

·8· bought or purchased properties through LLCs, you

·9· don't recall the names sitting here today; is that

10· right?

11· · · · A.· · Correct.

12· · · · Q.· · Okay.· To your memory, did any of those

13· names include the name Atlas, for instance?

14· · · · A.· · No.

15· · · · Q.· · Okay.· Were those LLCs related to what

16· you think as the family business, Atlas businesses?

17· · · · MS. STANISH:· Hold on.· That's -- I'm going

18· to object to that.· That's a compound question,

19· Atlas businesses versus family businesses.· So can

20· you restate the question for her?

21· BY MR. PORRAS:

22· · · · Q.· · Yes.· That's no problem.

23· · · · · · · · ·So to your understanding, are the

24· LLCs that Steven used to purchase these properties

Page 76

·1· that you mentioned the family businesses, the

·2· family business LLCs?

·3· · · · A.· · In my mind, they would be one and the

·4· same.· It all goes back to the same pond, right?

·5· The money -- it's the same money source.· So you

·6· can call it whatever you want.· But it goes back to

·7· the same money source.

·8· · · · Q.· · And what do you base that understanding

·9· that it's the same money source on?

10· · · · A.· · Being married to Steven and being a

11· part of the immediate Ivankovich family for the

12· last 18 years.

13· · · · Q.· · Okay.· And I think you had also

14· mentioned that there was a Chase credit card that

15· was used to pay your and Steven's personal

16· expenses; is that right?

17· · · · A.· · I think you're pretty familiar with it.

18· You have gone up in front of the judge trying to

19· stop the subpoena.· So, yes, there is a Chase

20· credit card that I had a name -- that I had in my

21· name for the last 12-plus years, correct.

22· · · · Q.· · So that was a credit card under your

23· name, and it was your understanding that that

24· credit card was tied to an account owned by

Page 77

·1· Steven's father; is that right?

·2· · · · A.· · Correct.

·3· · · · Q.· · Okay.· So that wasn't an account owned

·4· by the family business LLC; is that right?

·5· · · · A.· · I think Steven used it for business

·6· expenses as well as personal.· They were

·7· intermingled.

·8· · · · Q.· · Okay.· And what do you base your

·9· understanding that they were used for intermingled

10· business and personal expenses?

11· · · · A.· · Based off of my knowledge Steven paying

12· business expenses and personal expenses with the

13· credit card.

14· · · · Q.· · Okay.· And this is using his father's

15· credit card to pay those expenses, right?

16· · · · A.· · I mean, it was Steven's credit card.

17· Just because his father was the primary account

18· holder didn't mean it wasn't Steven's credit card.

19· · · · Q.· · I see.

20· · · · A.· · His father -- and his father never used

21· that card.· His mother never used that card.

22· · · · Q.· · And what kind business expenses were

23· used -- were paid by that card?

24· · · · A.· · Utility bills for apartment complexes.

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 144 of 182 PageID #:3329
Page 78

·1· Payments for multifamily homes owned by Atlas.

·2· · · · Q.· · Okay.

·3· · · · A.· · Landscaping.· Utilities.

·4· · · · Q.· · And aside from the use of that credit

·5· card that we're just talking about, do you have any

·6· other basis to believe that Steven Ivankovich

·7· intermingled his business expenses with his

·8· personal expenses?

·9· · · · A.· · No.· I think that's enough.

10· · · · Q.· · And during the use of that credit card,

11· was it your understanding that Steven's father was

12· ultimately the person paying for those charges?

13· · · · A.· · No, not at all.

14· · · · Q.· · Okay.

15· · · · A.· · It was -- my impression from Steven was

16· he was going to pay the card, that the card was

17· paid -- being paid by him.· He's going to make a

18· payment in a couple --

19· · · · Q.· · By "him," who do you mean by "him"?

20· · · · A.· · Steven.

21· · · · Q.· · Okay.· So Steven was going to be the

22· ultimate payer of those charges?

23· · · · A.· · Yeah.· And there's text messages that

24· would support -- between Steven and I that would

Page 79

·1· support that.

·2· · · · Q.· · Okay.· So Mr. Tahmassebi, again, who's

·3· the attorney that just asked you questions, he

·4· asked you --

·5· · · · A.· · I'm sorry?

·6· · · · Q.· · I'm sorry.· I'm speaking very quickly,

·7· I know.

·8· · · · MS. STANISH:· First name is Amir.

·9· · · · THE WITNESS:· Oh, I'm sorry.

10· · · · MS. STANISH:· Go ahead.

11· BY MR. PORRAS:

12· · · · Q.· · Okay.· So the attorney that just asked

13· you questions, I believe asked you a few questions

14· about whether Steven Ivankovich transferred funds

15· to the family businesses.· Do you remember that

16· line of questioning?

17· · · · A.· · No.

18· · · · Q.· · Okay.· And I believe you testified that

19· you didn't know whether Steven Ivankovich did or

20· did not transfer his own personal funds to

21· businesses; is that right?

22· · · · A.· · I don't -- I'm sorry.· I don't recall

23· that.· I recall Steven taking money from the

24· businesses for personal use.· I don't recall the

Page 80

·1· questioning being Steven taking his own money and

·2· putting it into Atlas.

·3· · · · MS. STANISH:· He's referring to the beginning

·4· of the deposition where counsel was asking you

·5· about Steven saying he went from $56 million value

·6· to zero because he had to give all his money, his

·7· personal money to the defunct businesses, something

·8· along those lines.

·9· · · · THE WITNESS:· No, I was never informed of

10· that.

11· · · · MR. PORRAS:· Okay.

12· · · · THE WITNESS:· And our lifestyle did not

13· reflect that transaction.

14· BY MR. PORRAS:

15· · · · Q.· · That he was sending money to the

16· businesses -- or, rather, to the family businesses

17· we'll say.

18· · · · A.· · No.· Well, while traveling on a

19· 150-foot yacht and going deep sea fishing with

20· friends and -- no.· Doesn't sound like a man in

21· destitute.

22· · · · Q.· · And you said that Steve Ivankovich

23· would send you money occasionally through Venmo.

24· Do you know where that money came from?

Page 81

·1· · · · MR. TAHMASSEBI:· I think she's asked and

·2· answered.

·3· · · · THE WITNESS:· Steven?

·4· · · · MR. PORRAS:· Yes.

·5· · · · THE WITNESS:· Well, when the money would come

·6· up on my Venmo, it would say Steven Ivankovich.· So

·7· what we could do is we could subpoena Venmo to find

·8· the source of that money or hire a forensic

·9· accountant, and then there would be no questions as

10· to the source.

11· · · · MS. STANISH:· After we get through a motion

12· to quash.· But go ahead.

13· · · · THE WITNESS:· It's easy.· I'm not the one

14· making it difficult.

15· BY MR. PORRAS:

16· · · · Q.· · Okay.· But you don't know where those

17· funds came from in short?

18· · · · A.· · So when the money in my Venmo showed

19· up, it showed up as Steven Ivankovich.· So for me,

20· the source was Steven Ivankovich.· Where he

21· received that money from, it's a different question.

22· · · · Q.· · Okay.· And then you don't know the

23· answer to that question?

24· · · · A.· · No.· You could ask Steven, or we could

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 145 of 182 PageID #:3330
Page 82

·1· get a forensic accountant, or we could subpoena.

·2· · · · Q.· · Okay.· But, again, you don't know the

·3· answer to that question; you don't know where those

·4· funds came from?

·5· · · · A.· · Steven.· They came from Steven.

·6· · · · Q.· · Okay.· And I believe you also mentioned

·7· that he would send you money to a TRG account.· Did

·8· I remember that correctly?

·9· · · · A.· · You did.

10· · · · Q.· · Okay.· And is that a bank account, or

11· what kind of account is that?

12· · · · A.· · Correct.· That was a business account

13· that was attached to a debit card that Steven

14· canceled two days after I filed for divorce.

15· · · · Q.· · Okay.· And do you know what business

16· that was tied to, the TRG account?

17· · · · A.· · I think TRG was the name of the

18· business.· Steven loved putting things in the name

19· of the business.· So once again, we could subpoena

20· that account and see the source of the funds.

21· · · · Q.· · I see.· Okay.· So what bank was the TRG

22· account with?

23· · · · A.· · It was Glenview State Bank.· It is

24· where his family banked.· And then it -- it turned

Page 83

·1· over.· It was purchased by a larger bank.· And I

·2· can't remember the name.· But it was -- it was

·3· fairly recently.

·4· · · · · · · · ·And then after I filed for divorce,

·5· Steven cut off my access to those accounts.

·6· · · · Q.· · Okay.· And I do apologize if --

·7· · · · A.· · No, you don't.· No, you don't.· But go

·8· ahead.

·9· · · · Q.· · -- this question was asked specifically.

10· But did any -- to your knowledge, did any of the

11· family businesses, whether they're LLCs or trusts

12· or anything else from your understanding, directly

13· send you money?

14· · · · A.· · No.· It would always be funneled

15· through Steven.

16· · · · MR. PORRAS:· Okay.· That's I think all I

17· have, Ms. Ivankovich.· I appreciate your time.· I'm

18· not sure if Mr. Tahmassebi has any additional

19· follow-up or further questions.· But I'm wrapped up.

20· · · · MS. STANISH:· Amir.

21· · · · MR. TAHMASSEBI:· No.

22· · · · · · · · ·The LLCs that we've mentioned, it's

23· your understanding, based on 18 years of marriage,

24· being around the family for --

Page 84

·1· · · · THE WITNESS:· It's 17 years of marriage, but

·2· we've been together for 18.

·3· · · · MR. TAHMASSEBI:· Okay.· It's your

·4· understanding, based on 17 years of marriage, that

·5· Steven Ivankovich controlled the transfer of funds

·6· from a number if not all those LLCs?

·7· · · · THE WITNESS:· Yes.

·8· · · · MR. TAHMASSEBI:· That's all I have.

·9· · · · · · · · ·All right.· I think -- what do you

10· want to do about signature, Counsel?

11· · · · MS. STANISH:· Do you want the opportunity to

12· review the transcript before it's official?· You

13· can't make any substantive changes, but if the

14· court reporter has made any errors that are non15· substantive that you have the opportunity to

16· correct them.· Do you want that opportunity, or do

17· you want to waive that?

18· · · · THE WITNESS:· I would like that opportunity,

19· please.

20· · · · MS. STANISH:· Okay.· So reserve.

21· · · · MR. TAHMASSEBI:· All right.· Great.· We will

22· attach the exhibits.· I'm going to order the

23· transcript, Nick.· Same order as usual.

24· · · · · · · · ·Do you guys want a copy?

Page 85

·1· · · · MR. GOLDSTEIN:· We should get it.

·2· · · · MR. PORRAS:· Yes.

·3· · · · MR. GOLDSTEIN:· Cy, why don't you order a

·4· copy.

·5· · · · MR. PORRAS:· Okay.· You got it.

·6· · · · · · · · · · · (The deposition concluded at

·7· · · · · · · · · · · ·3:23 p.m.)

·8

·9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 146 of 182 PageID #:3331
Page 86

·1· · · · · IN THE UNITED STATES DISTRICT COURT

· · · · · ·FOR THE NORTHERN DISTRICT OF ILLINOIS

·2· · · · · · · · · ·EASTERN DIVISION

·3· ·ZHU ZHAI HOLDINGS LIMITED· ·)

· · ·and PETER PUI TAK LEE,· · · )

·4· · · · · · · · · · · · · · · ·)

· · · · · · · · · ·Plaintiffs,· ·)

·5· · · · · · · · · · · · · · · ·)

· · · · · · · vs.· · · · · · · · )· ·No. 20-cv-4985

·6· · · · · · · · · · · · · · · ·)

· · ·STEVEN IVANKOVICH,· · · · · )

·7· · · · · · · · · · · · · · · ·)

· · · · · · · · · ·Defendant.· · )

·8

·9· · · · · · This is to certify that I have read my

· · deposition taken on Thursday, March 23, 2023,

10· in the foregoing cause and that the foregoing

· · transcript accurately states the questions asked

11· and the answers given by me, with the changes or

· · corrections, if any, made on the Errata Sheet

12· attached hereto.

13

14

15· · · · · · · · · ______________________________

· · · · · · · · · · · · ·JEANETTE IVANKOVICH

16

17· No errata sheets submitted (Please initial)

· · Number of errata sheets submitted _______ pages

18

· · Subscribed and sworn to

19· before me this _______ day

· · of _________________ 2023.

20

21· __________________________

· · · · ·Notary Public

22

23

24

Page 87

·1· · · · · · · · REPORTER'S CERTIFICATE

·2· · · · I, Nick D. Bowen, do hereby certify that

· · JEANETTE IVANKOVICH was duly sworn by me to testify

·3· the whole truth, that the foregoing deposition was

· · recorded stenographically by me and was reduced to

·4· computerized transcript under my direction, and

· · that said deposition constitutes a true record of

·5· the testimony given by said witness.

·6· · · · I further certify that the reading and

· · signing of the deposition was not waived, and the

·7· deposition was submitted to Ms. Tanya Stanish,

· · deponent's counsel, for signature.· Pursuant to

·8· Rule 30(e) of the Federal Rules of Civil Procedure,

· · if deponent does not appear or read and sign the

·9· deposition within 30 days, the deposition may be

· · used as fully as though signed, and this

10· certificate will then evidence such failure to

· · appear as the reason for signature not being

11· obtained.

12· · · · I further certify that I am not a relative

· · or employee or attorney or counsel of any of the

13· parties, or a relative or employee of such attorney

· · or counsel, or financially interested directly or

14· indirectly in this action.

15· · · · IN WITNESS WHEREOF, I have hereunto set my

· · hand and affixed my seal of office at Chicago,

16· Illinois, this 31st day of March 2023.

17

18

· · · · · · · · · ·______________________________

19· · · · · · · · ·Illinois CSR No. 084-001661

20

21

22

23

24

Page 88

·1· ·Errata Sheet

·2

·3· ·NAME OF CASE: ZHU ZHAI HOLDINGS LIMITED and PETER PUI TAK LEE vs STEVEN IVANKOVICH

·4· ·DATE OF DEPOSITION: 03/23/2023

·5· ·NAME OF WITNESS: Jeanette Ivankovich

·6· ·Reason Codes:

·7· · · · 1. To clarify the record.

·8· · · · 2. To conform to the facts.

·9· · · · 3. To correct transcription errors.

10· ·Page _____ Line ______ Reason ______

11· ·From ____________________ to ____________________

12· ·Page _____ Line ______ Reason ______

13· ·From ____________________ to ____________________

14· ·Page _____ Line ______ Reason ______

15· ·From ____________________ to ____________________

16· ·Page _____ Line ______ Reason ______

17· ·From ____________________ to ____________________

18· ·Page _____ Line ______ Reason ______

19· ·From ____________________ to ____________________

20· ·Page _____ Line ______ Reason ______

21· ·From ____________________ to ____________________

22· ·Page _____ Line ______ Reason ______

23· ·From ____________________ to ____________________

24

25· · · · · · · · · · · · · · ·_______________________

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 147 of 182 PageID #:3332
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 148 of 182 PageID #:3333
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 149 of 182 PageID #:3334
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 150 of 182 PageID #:3335
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 151 of 182 PageID #:3336
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 152 of 182 PageID #:3337
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 153 of 182 PageID #:3338
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 154 of 182 PageID #:3339
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 155 of 182 PageID #:3340
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 156 of 182 PageID #:3341
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 157 of 182 PageID #:3342
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 158 of 182 PageID #:3343
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 159 of 182 PageID #:3344
Atlas v.

Macquarie et al (FINAL) January 13, 2020

Ivankovich - Plaintiff - Cross (Mr. Rossman) Page 301

 1 get on.

 2 MR. ROSSMAN: I would object to that. There's

 3 overlapping factual knowledge between these two witnesses

 4 and I would not want to have this witness still open, have

 5 Mr. Morris testify, and then have this witness be recalled.

 6 THE COURT: I thought that might be your response

 7 there. All right. Let's see how we do. Let's see if we

 8 can try to get -- I'm sure Mr. Ivankovich would be

 9 heartbroken to be done soon, but let's see if we can get it

10 done.

11 MR. ROSSMAN: To the limites of the Court Reporter

12 being mad with me, I will go as quickly as I can, your

13 Honor.

14 CROSS EXAMINATION CONTINUED

15 BY MR. ROSSMAN: 

16 Q Mr. Ivankovich, I want to understand something. The

17 Atlas entity, Atlas -- Atlas MF Mezzaine Borrower, LLC is the

18 plaintiff entity in this case, correct?

19 A Correct.

20 Q Okay. I want to make sure that we're on the same page

21 about what the actual financial condition of that entity is.

22 You were in the courtroom yesterday when Mr. Meister

23 represented that we don't have any money. He said that on Page

24 31 of the transcript referring to Atlas.

25 A I don't recall that statement.

Ivankovich - Plaintiff - Cross (Mr. Rossman) Page 302

 1 Q Do you recall your counsel said, prior hearing January

 2 7th, 2020 hearing in this case, I'm referring to transcript Page

 3 14, Atlas, the entity that is the party here, is obviously at

 4 the moment bereft of assets because the assets that it had was

 5 the equity collateral that was sold at the auction, is that a

 6 true statement?

 7 A Yeah. I would categorize that as true.

 8 Q Would you like, sir, in your binder, there's a copy of

 9 the Verified First Amended Complaint that was filed in this

10 action.

11 A This is your binder.

12 Q Yes. The cross-examination examination binder that I

13 gave you. It's toward the back of that binder. You see

14 something that's First Amended Complaint. It's a Verified

15 Complaint, which means you actually had to sign verification to

16 the truthfulness of it's contents, are you aware of that?

17 A Correct.

18 Q Okay. This is a complaint that was filed in this Court

19 on October 30th, 2017. Let me know when you're there.

20 A Yep. I'm here.

21 Q Okay. If you turn to paragraph 43 you'll see the

22 statement, Atlas still today is in a strong financial position

23 and is able to obtain financing to pay off the Mezzanine Loan?

24 A Paragraph 43?

25 Q 43. It's in the back of that --

Ivankovich - Plaintiff - Cross (Mr. Rossman) Page 303

 1 A My paragraph 43 says, however, despite the harm caused

 2 by Macquarie's wrongful notice of a default on the Mezzanine

 3 Loan, Atlas still today is in a strong financial position and is

 4 able to obtain financing to pay off the Mezzanine Loan.

 5 Q So focusing on the second half of that sentence, where

 6 it's true, the verified complaint says that Atlas still today is

 7 in a strong financial position, correct?

 8 A Correct.

 9 Q Was that a true statement?

10 A Yes.

11 Q At the time you signed the verification?

12 A Yes.

13 Q Okay. Now, can you explain to me, sir, how it is that

14 on October 30th, 2017 and this is about five months after --

15 more than five months after the closing of my client's purchase

16 of the equity interest in the properties, how you could

17 represent to the Court that that entity was in a strong

18 financial condition?

19 A I take that to mean that the overall Atlas entity,

20 which includes the Atlas principals. We could capitalize that

21 entity in five minutes.

22 Q Now, if you turn to the first page of the Complaint,

23 the Verified Complaint.

24 A Yes.

25 Q Atlas is defined as the plaintiff, Atlas MF Mezzaine

Ivankovich - Plaintiff - Cross (Mr. Rossman) Page 304

 1 Borrower, LLC. Do you see that term Atlas?

 2 A I see that.

 3 Q So you're now telling me that that statement in the

 4 Verified Complaint, in paragraph 43 that that particular entity

 5 was in a strong financial condition, is that an untrue statement

 6 or a true statement?

 7 A Absolutely. That's a true statement.

 8 Q How is it that your counsel could represent to this

 9 Court yesterday that that entity has no assets?

10 A The specific entity doesn't, but the chain of

11 ownership, as I said, has plenty of assets. We could populate

12 that entity with the signing of a pen and a phone call in a

13 matter of minutes.

14 Q Is it your testimony, sir, in this Court under oath

15 that you have the authority to move money as you see fit to that

16 entity or away from that entity?

17 A I don't have the authority, but I have the ability.

18 Q Okay. Now, the -- I want to turn your attention to the

19 subject of obtaining a bank check for the auction that took

20 place on February 27th, 2017.

21 Do you recall testifying about that in response to

22 Mr. Gonzalez's questions?

23 A Yes.

24 Q You talked about not being able to get a check from JP

25 Morgan Chase that day, correct?

Min-U-Script® NY Supreme Court Civil Division (76) Pages 301 - 304

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 160 of 182 PageID #:3345
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 161 of 182 PageID #:3346
	
	

		
	
									
 
	!"#
	$




	

					
			
		%			&
		'		(	)

	*							
$

	



							  	)		*")*"	 
		+,-		#.//01

22&		*					3	
	$




 	
"*		4+	 )
5	$

 	5	"	(		*		)*	$	5	"					
"		(			6

 )
	$





	*			")	 *470*
	-"6 	("		*	3	
		*
	 	
	8

		
	1$

		


	
9	
9	:


		
;	



<		=
$



>
&0/+807

 
+,-		#.//012&



		
9	:


 
	!"#

 
00'		&/#.//&8


VWHYHQLYDQNRYLFK=		"$



!
0078




	-"
9	:


	(	.(<(


(<(=
	$



>
&&087/

"







	) 	
ZKRPD\RFFXS\	3	
		:6WHYHQ,YDQNRYLFK?			@<	+RQRULD,YDQNRYLFK,VLGRUH,YDQNRYLFK$

	
#



	


	(		 		
		 *			 			
	 *$	

(	*
		 "	*
(	"	
	*		

				*	"	
	(	$

	
"
#

		 	*	*"		(	:#	A#

"	(	#	9		#)	(	'	

	(	-		(	-	(	.		 ")	(	3	#		,	5	
($"	

" 	)			B 			"			!"	)*		"	$

	

.*	5	)					(	)		*	0)*		5	"			
" )	*		

*40		
	C		$


$



.*)	<	<"
				* )
	*)			"		"	*"**	*"	 )

40$*			$*"	(			
)"	"		
		 	)	

		6	<
	)	$.*			
		<<*"		
*			

	"	*"**	*"(			
*""			"		 )		6	<


	)	$

	
$



"	<	
	(	"*	3	
		D
)			)	
	 	
$.	40$

*		
<"C					
	*	(	$;)" 				 (			 
	$





.*	 			")	 "		6 	* 	*
	*		(	)		
	(	"	

			(		"	"			")	 	 	**

)	*"		 )
	*				")$.*	
 	

"			70)*		(		3	
		*"		")	 $		")	 	

	C		)."				"<(	*"$.				")

	 	 			)	#)#
 	*	")	 	
	B

)	 			

	))		*
*		"$		")	 		)	 )
	*5	$

3	*0

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 162 of 182 PageID #:3347








 		<				 			3	
		

		
	*					B	*

	3	
			!" 
	) 		*"		 	<	$

 								(	
	 
			*	3	
	$

 					"	3	
		*				
			*			$










	

#
	


	 			3	
	

	*	  	)	*"	"				


*				 		$	<				(				 		 
		

"	<))	*
	"							B	 		B 	)
	

	(			 		
(*) *	3	
	*	  	)$	*"	<		

				 	*)*			(	*
	#)*#"		(	
 				*		

( 	*	*
)") (			
*")	(	$



	






			 	*	!"	
		*	" #	*#		
	

E	5	 )F		*)
	
)"	"*	G*"	)	))

	!"	
		*	" #	*#	)")	 )	!"	*		

	 	
	 		%	%"*	$



	


	
	3	
		 			*	
			*	)"

		"$		
*		" "		*	3	
	*B"	 	 	  	)*

		
		)					%		
			B	 	$
)	 "	

 *		")	 
*)	 9	 	)
	6  	)"				))	)	6

			$





	(	 	*	3	
					%		$.*"		(	 		

"				
*"*		**		B	 	5			 " 		(		"	

			
* 	*	3	
	" 					
			$





	3	
		" 		B"(	)*		 " 	)			 	 	*)		 )

	
)			")*	"				
$

2			) 	
)" )	3	
	"			 $H			) 	

	" )*	3	
	 	*
 	
) 	""	
			 "*	"	

D""			

				* "		  	)$
	"				

	 			

	3	
	"	 	
	)	  	"9I	*	#)*#$

	@"2%H%9
*	5'H;;,'"			$
				8	


"		
*	%H%		
			$"		
					*		"	*	
$

	

	"				"	 		*	"	)	$
)

	!"				*
	"				
	$)"		*						*
	6

		"	"	*" 	* 	*
	**		(	)		
	(			"	$		

	*)
	)8
	)		*		"	)	6"	$



			"	 		*



	


	
<	"		
	)		3	
	"	 		*

"	"
	)<	")	(		3	
		  	)"
 6	$

%




		


	 	
			)*G(				"	

	" 		()G	)
		 				
			* (		$

(	

				3	
		*	
		)			 
							""	B 		)

	!"	"	$(			*"	))*	"	)$

%





%
&




#

%

(			3	
	  	(		 "	)*6	(		

	"	9	$	 	
			" 		()G	)


		 				
			* (	

	$,"	(				3	
	<	  9(	*	3	
	*
<	

 " 	$			*)
	"	**"	 		"	 ($		*		

6	**		
<			3	
				*)
	"	)	* ($

#
%

	
"	(		3	
		()3#			'	
(	;"
	$

%
	

#

			*"		5			(			 	*) *	3	
	*		(	;"
	

			'	$
)	 " 					

	)			

	"		
		
*		$)*		 	*) *	3	
	*	

			'	 )	"		5		  )
		
	

	)

)	 )		)				"		
		
*		$

3	*0

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 163 of 182 PageID #:3348


	

			*)
			 	
		"*	6	G(		"		"I			

	3	
					*"	*
*	 		) 	(	
		3	
	$




	3	
				
						*	#5		9	;	(			
	

(					3	
	 	*	6 		
	 		)$




)			

)		(	)		) 			)			 	*	3	
	J

)	*	
				"		 	!"		J) " 	3	
	*"I	 	"		

		 	*	3	
	$C"		B	 	"			!"				) "
		

			"	
)		(		)		

"
	8
)	8
				

		
	$""
					*	)*		"
		" 					

 $			*


		)*)	
		$






.*	3	
	) *	  	)	)	
		B	
<		3	
	"			
)	

	
		 	"		$."	(		"	<	)(		 		

	3	
		$

'

	



'B	  (	) 			 	*	*)*	6 	  	)	3	
	

) *	  	)$	"	"**	(	 	

	$

		
'
	

	

"))	"
	6		  	)*	3	
	*
 $.		(	

				"	)	"
				"	

*(	)*		
)$)	"
			)	"	
		*		$			

*
	"	)"	*		"		"*)	* (	

	B	 	
	)"		$

		
(

			*	*		"	)	"*6	**	*	) (*		

		B	 	
	)""	"		$

	


&

.		(				B	*	)"		"	"C	')

			 	*	3	
		*	) (*

			 	"	B			#	<*#"#" 	 *	"$








	"		 	*	3	
		"	<	)6	

		)" 	B *

		" 	
"		6	$"		* 				
	(	"	*		"	<	)

 		B *		$






	)
	

		"	
	" 	  	)*	3	
	*
 		 		
	*			B	"


)	 	" 	  	))
	"		
*		$		B	"	)	 				!"	))


			 "	*	  	)	(		**
*	6		"$





.* *	3	
		  	)*	3	
	*
 	
		B  				"	))

(	
	")
	" 	(	*"" )				
					)


 	$

%



*	 
	(			
					" "				**		

	B	"
"	*	$






%

'B	 			*8 )
	*	
)	 	*								*"	

" )*	3	
		(		B"6	
			(	)"
)	*	 	

	
	*		$



%


	*				*	 )
	*		 	*
	*		(	)(		
		
	*		

			
 	
	$

#	

.		(	) (  "	(						
	("	*			
 *

		"((		"				)$

		
'


	
					"				
		 	"
"(			B		*	
			*

(		B" 	"			B		*)		
	)"	


	 	*) 	)""	"		$			!"	
 )) ((	

		
			"	(		
 	*
6*"		B		)*	
		$

3	&*0

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 164 of 182 PageID #:3349



	


#

	 	*
) 		(			))	*
*		)*
) *	  	)	

	3	
	$	*"	)	(				
	)"	 	*B"	$




					 	"		3	
	"						" )$

*


#	
		

 		B	"			D)	(	)	*	 	*
	*		(	)		
	(	

		"	$

+$


	
$





#

	(				8<	)	<
	3	
	 
 ) (				*

$	

		) (	 )*	<	)		<$.		(		*(			

<	)" 	!"	"*"				
	)	*	H8#
 	"			
*		$

	
#



.*	
" 
("		
	"	 	
	"	*			 	
	*	

*

*	)#
	
	"		*.(		(				(				 	
	$




&
%	

		*				
*				(	)				 )			

"
)"	

$	
					*				
)				*	

		
"(			 )	+) 			*		)*				
)				*$


#
	&

		
		(		"		 		)""		*		*.

	

"					!"		B	"*			-""			 	*
	*

	"				$-"		(									*			")	G

 	*
	"						*	 (	$

-"		)(	*:

$ ,-.-""	)")	()"			*"**" 
  	*
	*


 		)		
*			""
	:
	 )
	*)5	 )	)

	"				
	 	*
		(	*	(		
		
	*			

	 	*
		(	)	$-"			)	
	"	)*	 	*	*	

*	"				$

$ /- 
.*		*"	 )
	*)5	 )	)	"					 	*
	*)*	

(		
		
					-"

		):
 )"5	)

			*J
**") 	*
*"**"(		
		
	J
 )	


		B 		
)		!"		*)	*")	"			"	)"	)

)"	*"9)		*	
	*-")$-") 
)"	""")

* )
	* 	*
	*
			$-"G)		"		
)		*	"

		!"		)		
	)	")$	()*-")	*-"		"	

		
	**		
 	)	*			*"		)	*)*	

	
				(	 ""	 (*			$

&$ + -")	
*"*		**	"						))


 	):
)
	
	
**" 	
		B			
 "" 	(	

		*			
		
			)
	*			**-"		)	

J
)	B		8	B		*) 		
	) (		"		 	*			-"))

(		 ()	 	)*	(		
		
					

)"		*			B	*
	* 	*
		(			*

	
	*)	

*
	J
	(")(")!""*			*")*		*		


*				(	 	( (	)<" )
	*			**	

	I	
	
 	D"
	*	
 		**		)*	G	J


)
	)*	"						<" )*)	
	)*		*	
	

		*	"*
	 	*) 		*""	 (*	H%<" )	"	*
		

*)"J
	)	B	*				)	B		)	

	

	


$ 2	 	
					
	
	 	
		  	)	3	
	"6 

					
				(	)		)$

$ ')) 	 "

	
)	"	))
)	"	*			

	 ))
	
		)" (					*	"$

&$ 	 	
)	"*	*
		*	"$

7$ H(		)			3	
	")

	*	  	)"			 	*			

*
	$

0$ .				 		"		 		
 					) <	

	 	$H	B (		(	) 		
		 			""		$

/$ H(		
		 	"" )	*	3	
	"" 		*

	"				(	

		)" 		*$

1$ H	
* 	  	)	 	"" )

	*	"$

$ H		" 	
	"		" *
!"		D)
	*	 
	

	*	

  	)$

+$ H<<
() 	
	"		<		$@	(	))*
	"	 	*

		)	$

3	7*0

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 165 of 182 PageID #:3350
Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 166 of 182 PageID #:3351
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 1 :: OpenCorporates

https://opencorporates.com/officers?page=1&q=Steven+Ivankovich&utf8=✓ 1/4

The Open Database Of The Corporate World

Officer’s name Search

 Companies Officers

My Account

Logout

Found 115 officers

Steven Ivankovich Go

 exclude inactive Advanced Options

inactive IVANKOVICH, STEVEN manager, inactive 2519 HALSTED PROPERTIES, LLC

(Illinois (US), 7 Sep 2018- ) 2519 N. HALSTED, CHICAGO, IL, 60614

inactive IVANKOVICH, STEVEN manager, inactive HONORIA, LLC (Illinois (US), 7 Jul 2009-

) 135 REVERE DRIVE, NORTHBROOK, IL, 60062

inactive IVANKOVICH, STEVEN manager, inactive ATLAS LONGFELLOW ARMS, LLC

(Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS VISTAS OF PINNACLE PARK,

LLC (Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS MARIPOSA VILLAS, LLC (Illinois

(US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN member, inactive 2519 HALSTED, LLC (Illinois (US), 23 Mar

2016- ) 2519 N HALSTED ST, CHICAGO, IL, 60614

inactive IVANKOVICH, STEVEN manager, inactive ALLIANCE HOLDINGS, L.L.C. (Illinois

(US), 1 Mar 1996- ) 222 N LASALLE ST STE 800, CHICAGO, IL, 60601

inactive IVANKOVICH, STEVEN manager, inactive ATLAS APARTMENTS ACQUISITION

LLC (Illinois (US), 19 Feb 2014- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS SAVOY OF GARLAND, LLC

(Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS BRIDGES ON KINSEY, LLC

(Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS RESIDENTIAL MANAGEMENT,

LLC (Illinois (US), 17 Feb 2016- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

IVANKOVICH, STEVEN manager, TYLER ATLAS, LLC (Illinois (US), 12 Aug 2020- ) 791

CRANDON BLVD, KEY BISCAYNE, FL, 33149

inactive IVANKOVICH, STEVEN manager, inactive ATLAS PARAMOUNT TERRACE, LLC

(Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ZIP, L.L.C. (Illinois (US), 8 Nov 2000-31

Dec 2050) 221 N LASALLE ST STE 3700, CHICAGO, IL, 60601

inactive IVANKOVICH, STEVEN manager, inactive ATLAS APARTMENTS DEVELOPMENT,

LLC (Illinois (US), 16 Jun 2017- ) 55 E. MONROE ST., STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive 610 DREXEL, LLC (Illinois (US), 15 Jul

2016- ) 55 E. MONROE ST., STE. 3610, CHICAGO, IL, 60603

IVANKOVICH, STEVEN manager, GLENCOE FAMILY DWELLING LLC (Illinois (US), 16 Aug

2016- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 167 of 182 PageID #:3352
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 1 :: OpenCorporates

https://opencorporates.com/officers?page=1&q=Steven+Ivankovich&utf8=✓ 2/4

inactive IVANKOVICH, STEVEN manager, inactive ATLAS APARTMENT HOLDINGS LLC

(Illinois (US), 25 Oct 2011- ) 791 CRANDON BLVD, MIAMI, FL, 33149

inactive IVANKOVICH, STEVEN manager, inactive GRUPPO C'E, LLC (Illinois (US), 28 May

2009- ) 135 REVERE DR, NORTHBROOK, IL, 60062

inactive IVANKOVICH, STEVEN member, inactive REVEREND DR. DAN, LLC (Illinois (US),

5 Apr 2016- ) 2519 N HALSTED ST, CHICAGO, IL, 60614

inactive IVANKOVICH, STEVEN manager, inactive ATLAS HUNTINGTON RIDGE, LLC

(Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS APARTMENT HOMES LLC

(Illinois (US), 25 Oct 2011- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive CARIBBEAN WELLNESS

INVESTMENTS LLC (Illinois (US), 14 Apr 2011- ) 135 REVERE DRIVE, NORTHBROOK, IL,

60062

inactive IVANKOVICH, STEVEN manager, inactive ATLAS DORADO RANCH, LLC (Illinois

(US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS LEGENDS OF EL PASO, LLC

(Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS STONEBRIDGE AT CITY PARK,

LLC (Illinois (US), 14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

inactive IVANKOVICH, STEVEN manager, inactive ATLAS RIVER OAKS, LLC (Illinois (US),

14 May 2018- ) 55 E MONROE ST STE 3610, CHICAGO, IL, 60603

Ivankovich, Steven assistant secretary, branch Alliance SH 2 GP, Inc. (North Carolina (US),

31 Aug 2000- ) 221 North Lasalle Street, Chicago, IL, 60661

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE CP GP, INC. (Georgia

(US), 15 May 2003- ) 221 N. LASALLE ST., SUITE 3700, CHICAGO, IL, 60601

inactive STEVEN IVANKOVICH inactive branch ALLIANCE GD OG GP, INC. (Florida (US),

10 Mar 2000- ) 221 N. LASALLE STREET, SUITE 3700, CHICAGO, IL 60601

← Previous

1

2

3

4

Next →

Results per page Enterprise users only

Filter by jurisdiction

1 California (US)

55 Florida (US)

1 Georgia (US)

29 Illinois (US)

1 Indiana (US)

1 North Carolina (US)

20 Texas (US)

7 United Kingdom

Filter by position

4 agent

2 assistant sec.

1 assistant secretary

1 chairman 30

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 168 of 182 PageID #:3353
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 1 :: OpenCorporates

https://opencorporates.com/officers?page=1&q=Steven+Ivankovich&utf8=✓ 3/4

1 chief executive officer

14 director

2 executive vice president

1 llp designated member

26 manager

6 managing member

2 member

2 owner

7 president

11 secretary

13 vice president

22 [blank]

Filter by nationality

7 AMERICAN

108 [blank]

Filter by occupation

1 COMPANY DIRECTOR

3 REAL ESTATE CEO

2 REAL ESTATE PROFESSIONAL

109 [blank]

About us

About

Blog

Team

Governance

Jobs

Using our data

Our data

Our purpose

Legal/Licence

User/Cookie privacy policy

Public records privacy policy

Help

API Reference

Glossary

Status

Contact

Twitter

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 169 of 182 PageID #:3354
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 1 :: OpenCorporates

https://opencorporates.com/officers?page=1&q=Steven+Ivankovich&utf8=✓ 4/4

Medium

Newsletter

Problems with our data?

Temporary redaction

Impact

Impact

Grants

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 170 of 182 PageID #:3355
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 2 :: OpenCorporates

https://opencorporates.com/officers?page=2&q=Steven+Ivankovich&utf8=✓ 1/4

The Open Database Of The Corporate World

Officer’s name Search

 Companies Officers

My Account

Logout

Found 115 officers

Steven Ivankovich Go

 exclude inactive Advanced Options

inactive STEVEN IVANKOVICH inactive branch ALLIANCE GT 2 GP, INC. (Florida (US), 28

Aug 2000- ) 221 NORTH LASALLE STREET STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE GD CC GP, INC.

(Florida (US), 10 Mar 2000- ) 221 NORTH LASALLE STREET SUITE 3700, CHICAGO, IL

60601

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE HC GP II, L.L.C.

(Florida (US), 11 Jul 2005- ) 135 REVERE DRIVE, NORTHBROOK, IL 60062

STEVEN IVANKOVICH chairman, branch ATLAS APARTMENT HOMES LLC (Florida (US),

17 Mar 2014- ) 791 Crandon Blvd, Key Biscayne, FL 60614

inactive STEVEN IVANKOVICH assistant sec., inactive branch ALLIANCE GT 2 GP, INC.

(Texas (US), 24 Aug 2000- 8 Jul 2005) 221 N LASALLE ST STE 3700, Chicago, IL, 60601, USA

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE GT 2 GP, INC.

(Florida (US), 28 Aug 2000- ) 221 NORTH LASALLE STREET STE 3700, CHICAGO, IL 60601

STEVEN IVANKOVICH IMG MARINE, LLC (Florida (US), 21 Sep 2022- ) 382 NE 191

STREET, MIAMI, FL 33179

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE GD OG GP, INC.

(Florida (US), 10 Mar 2000- ) 221 N. LASALLE STREET, SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE GT 2 GP, INC. (Florida

(US), 28 Aug 2000- ) 221 NORTH LASALLE STREET STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH inactive branch ALLIANCE SH PORTFOLIO I, INC. (Florida

(US), 17 Apr 1998- ) 221 N. LASALLE ST., STE.3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE HC GP I, INC.

(Florida (US), 31 Oct 2003- ) 221 NORTH LASALLE ST, STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE GD OG GP, INC.

(Florida (US), 10 Mar 2000- ) 221 N. LASALLE STREET, SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE TD GP, INC. (Florida

(US), 16 Jul 2002- ) 221 NORTH LASALLE STREET, SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE DK GP, INC.

(Florida (US), 7 Aug 2001- ) 221 NORTH LASALLE STE STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH assistant sec., inactive branch ALLIANCE GD HD 2 GP, INC.

(Texas (US), 9 Mar 2000- 8 Jul 2005) 221 N LA SALLE ST FL 37, Chicago, IL, 60601-1206, USA

inactive STEVEN IVANKOVICH executive vice president, inactive branch ALLIANCE GD HD

2 GP, INC. (Texas (US), 9 Mar 2000- 8 Jul 2005) 221 N LA SALLE ST FL 37, Chicago, IL,

60601-1206, USA

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 171 of 182 PageID #:3356
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 2 :: OpenCorporates

https://opencorporates.com/officers?page=2&q=Steven+Ivankovich&utf8=✓ 2/4

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE SH PORTFOLIO I,

INC. (Florida (US), 17 Apr 1998- ) 221 N. LASALLE ST., STE.3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH inactive branch PILGRIM FOREST PARK LLC (Florida (US),

14 May 2019- ) 55 E MONROE, STE 3610, CHICAGO, IL 60603

inactive STEVEN IVANKOVICH inactive branch OVERLOOK MANAGING MEMBER, LLC

(Florida (US), 8 Nov 2018- ) 55 E. MONROE, SUITE 3610, CHICAGO, IL 60603

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE HC GP I, INC. (Florida

(US), 31 Oct 2003- ) 221 NORTH LASALLE ST, STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE TD GP, INC. (Florida

(US), 16 Jul 2002- ) 221 NORTH LASALLE STREET, SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH inactive ALLIANCE HTFL LLC (Florida (US), 1 Nov 2021- ) 1

EAST ERIE STREET SUITE 525 253, CHICAGO, IL 60611

inactive STEVEN IVANKOVICH inactive branch ALLIANCE DK GP, INC. (Florida (US), 7 Aug

2001- ) 221 NORTH LASALLE STE STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH inactive branch ALLIANCE GD HD 1 GP, INC. (Florida (US),

10 Mar 2000- ) 221 NORTH LASALLE STREET SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH inactive branch ALLIANCE TD GP, INC. (Florida (US), 16 Jul

2002- ) 221 NORTH LASALLE STREET, SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE HC GP I, INC. (Florida

(US), 31 Oct 2003- ) 221 NORTH LASALLE ST, STE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH inactive branch ALLIANCE GD CC GP, INC. (Florida (US), 10

Mar 2000- ) 221 NORTH LASALLE STREET SUITE 3700, CHICAGO, IL 60601

inactive STEVEN IVANKOVICH agent, inactive ALLIANCE HTTX LLC (Florida (US), 1 Nov

2021- ) 791 CRAMDON BLVD., KEY BISCAYNE, FL 33149

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE GD HD 1 GP, INC.

(Florida (US), 10 Mar 2000- ) 221 NORTH LASALLE STREET SUITE 3700, CHICAGO, IL

60601

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE GJ GP, INC.

(Florida (US), 27 Feb 2001- ) 221 NORTH LASALLE STREET, STE 3700, CHICAGO, IL 60601

← Previous

2

3

4

Next →

Results per page Enterprise users only

Filter by jurisdiction

1 California (US)

55 Florida (US)

1 Georgia (US)

29 Illinois (US)

1 Indiana (US)

1 North Carolina (US)

20 Texas (US)

7 United Kingdom

Filter by position

4 agent

2 assistant sec.

1 assistant secretary 30

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 172 of 182 PageID #:3357
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 2 :: OpenCorporates

https://opencorporates.com/officers?page=2&q=Steven+Ivankovich&utf8=✓ 3/4

1 chairman

1 chief executive officer

14 director

2 executive vice president

1 llp designated member

26 manager

6 managing member

2 member

2 owner

7 president

11 secretary

13 vice president

22 [blank]

Filter by nationality

7 AMERICAN

108 [blank]

Filter by occupation

1 COMPANY DIRECTOR

3 REAL ESTATE CEO

2 REAL ESTATE PROFESSIONAL

109 [blank]

About us

About

Blog

Team

Governance

Jobs

Using our data

Our data

Our purpose

Legal/Licence

User/Cookie privacy policy

Public records privacy policy

Help

API Reference

Glossary

Status

Contact

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 173 of 182 PageID #:3358
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 2 :: OpenCorporates

https://opencorporates.com/officers?page=2&q=Steven+Ivankovich&utf8=✓ 4/4

Twitter

Medium

Newsletter

Problems with our data?

Temporary redaction

Impact

Impact

Grants

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 174 of 182 PageID #:3359
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 3 :: OpenCorporates

https://opencorporates.com/officers?page=3&q=Steven+Ivankovich&utf8=✓ 1/4

The Open Database Of The Corporate World

Officer’s name Search

 Companies Officers

Log in/Sign up

Found 115 officers

Steven Ivankovich Go

 exclude inactive Advanced Options

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE GD CC GP, INC.

(Florida (US), 10 Mar 2000- )

inactive STEVEN IVANKOVICH inactive branch ALLIANCE HC GP I, INC. (Florida (US), 31

Oct 2003- )

inactive STEVEN IVANKOVICH inactive ALLIANCE HTTX LLC (Florida (US), 1 Nov 2021- )

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE GD HD 1 GP, INC.

(Florida (US), 10 Mar 2000- )

inactive STEVEN IVANKOVICH inactive branch PILGRIM CARIBBEAN ISLE LLC (Florida

(US), 8 Nov 2018- )

STEVEN IVANKOVICH J & S FAMILY LLC (Florida (US), 2 Jun 2021- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE SH PORTFOLIO I,

INC. (Florida (US), 17 Apr 1998- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE GD OG GP, INC.

(Florida (US), 10 Mar 2000- )

inactive STEVEN IVANKOVICH inactive branch ALLIANCE HTTX GP, L.L.C. (Florida (US),

13 Jun 2019- )

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE GT 5 GP, INC. (Florida

(US), 28 Aug 2000- )

STEVEN IVANKOVICH manager, A & O FAMILY LLC (Illinois (US), 3 Jun 2021- )

inactive STEVEN IVANKOVICH inactive branch ALLIANCE GJ GP, INC. (Florida (US), 27

Feb 2001- )

inactive STEVEN IVANKOVICH inactive branch ALLIANCE OG PORTFOLIO I, INC. (Florida

(US), 23 Oct 1996- )

inactive STEVEN IVANKOVICH agent, inactive ALLIANCE HTFL LLC (Florida (US), 1 Nov

2021- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE GT 5 GP, INC.

(Florida (US), 28 Aug 2000- )

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE DK GP, INC. (Florida

(US), 7 Aug 2001- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE OG PORTFOLIO

I, INC. (Florida (US), 23 Oct 1996- )

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE GJ GP, INC. (Florida

(US), 27 Feb 2001- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE GD CC GP, INC.

(Florida (US), 10 Mar 2000- )

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 175 of 182 PageID #:3360
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 3 :: OpenCorporates

https://opencorporates.com/officers?page=3&q=Steven+Ivankovich&utf8=✓ 2/4

inactive STEVEN IVANKOVICH inactive branch ALLIANCE GT 5 GP, INC. (Florida (US), 28

Aug 2000- )

STEVEN IVANKOVICH branch ATLAS APARTMENT HOMES LLC (Florida (US), 17 Mar

2014- )

STEVEN IVANKOVICH TATTERED FLAG INTREPID LLC (Florida (US), 26 Jan 2021- )

inactive STEVEN IVANKOVICH president, inactive branch ALLIANCE DK GP, INC. (Florida

(US), 7 Aug 2001- )

inactive STEVEN IVANKOVICH executive vice president, inactive branch ALLIANCE GT 2

GP, INC. (Texas (US), 24 Aug 2000- 8 Jul 2005)

STEVEN IVANKOVICH agent, A & O FAMILY LLC (Illinois (US), 3 Jun 2021- )

inactive STEVEN IVANKOVICH secretary, inactive branch ALLIANCE GJ GP, INC. (Florida

(US), 27 Feb 2001- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE HD PORTFOLIO I,

INC. (Florida (US), 21 Jul 1997- )

inactive STEVEN IVANKOVICH vice president, inactive branch ALLIANCE TD GP, INC.

(Florida (US), 16 Jul 2002- )

inactive STEVEN V IVANKOVICH vice president, inactive branch ALLIANCE FHW GP, INC.

(Indiana (US), 13 Aug 2003-17 Mar 2009)

inactive STEVEN V. IVANKOVICH chief executive officer, inactive branch HAZARDOUS

SPORTS, INC. (California (US), 24 Feb 2003- 2 May 2011)

← Previous

3

4

Next →

Results per page Enterprise users only

Filter by jurisdiction

1 California (US)

55 Florida (US)

1 Georgia (US)

29 Illinois (US)

1 Indiana (US)

1 North Carolina (US)

20 Texas (US)

7 United Kingdom

Filter by position

4 agent

2 assistant sec.

1 assistant secretary

1 chairman

1 chief executive officer

14 director

2 executive vice president

1 llp designated member

26 manager

6 managing member

2 member

2 owner

7 president 30

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 176 of 182 PageID #:3361
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 3 :: OpenCorporates

https://opencorporates.com/officers?page=3&q=Steven+Ivankovich&utf8=✓ 3/4

11 secretary

13 vice president

22 [blank]

Filter by nationality

7 AMERICAN

108 [blank]

Filter by occupation

1 COMPANY DIRECTOR

3 REAL ESTATE CEO

2 REAL ESTATE PROFESSIONAL

109 [blank]

About us

About

Blog

Team

Governance

Jobs

Using our data

Our data

Our purpose

Legal/Licence

User/Cookie privacy policy

Public records privacy policy

Help

API Reference

Glossary

Status

Contact

Twitter

Medium

Newsletter

Problems with our data?

Temporary redaction

Impact

Impact

Grants

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 177 of 182 PageID #:3362
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 3 :: OpenCorporates

https://opencorporates.com/officers?page=3&q=Steven+Ivankovich&utf8=✓ 4/4

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 178 of 182 PageID #:3363
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 4 :: OpenCorporates

https://opencorporates.com/officers?page=4&q=Steven+Ivankovich&utf8=✓ 1/4

The Open Database Of The Corporate World

Officer’s name Search

 Companies Officers

My Account

Logout

Found 115 officers

Steven Ivankovich Go

 exclude inactive Advanced Options

STEVEN VALENTINO IVANKOVICH director, ATLAS RESIDENTIAL SOLUTIONS

MANAGEMENT UK LIMITED (United Kingdom, 3 Mar 2016- ) BROAD HOUSE THE

BROADWAY, OLD HATFIELD, HERTS, AL9 5BG, ENGLAND

inactive STEVEN VALENTINO IVANKOVICH llp designated member, inactive ATLAS

RESIDENTIAL MANAGEMENT LLP (United Kingdom, 14 Mar 2013-14 Jun 2016) 111

BUCKINGHAM PALACE ROAD, LONDON, SW1W 0SR, UNITED KINGDOM

inactive STEVEN VALENTINO IVANKOVICH director, inactive GRUPPO CE UK LIMITED

(United Kingdom, 12 May 2015-18 Jan 2022) BROAD HOUSE THE BROADWAY, OLD

HATFIELD, HERTS, AL9 5BG, UNITED KINGDOM

inactive STEVEN VALENTINO IVANKOVICH director, ATLAS RESIDENTIAL MANAGEMENT

LIMITED (United Kingdom, 11 Oct 2019- ) BROAD HOUSE THE BROADWAY, OLD HATFIELD,

HERTFORDSHIRE, AL9 5BG, UNITED KINGDOM

inactive STEVEN VALENTINO IVANKOVICH director, inactive ATLAS GP MEZZ UK LIMITED

(United Kingdom, 3 Apr 2013- 4 Mar 2014) 27 OLD GLOUCESTER STREET, LONDON, WC1N

3AX, UNITED KINGDOM

inactive STEVEN VALENTINO IVANKOVICH director, inactive GP SENIOR HOLDCO UK

LIMITED (United Kingdom, 3 Apr 2013- 4 Mar 2014) 27 OLD GLOUCESTER STREET,

LONDON, WC1N 3AX, UNITED KINGDOM

inactive STEVEN VALENTINO IVANKOVICH director, inactive GP MEZZ HOLDCO UK

LIMITED (United Kingdom, 3 Apr 2013- 4 Mar 2014) 27 OLD GLOUCESTER STREET,

LONDON, WC1N 3AX, UNITED KINGDOM

inactive Steven Ivankovich director, inactive branch Atlas Apartment Homes LLC (Texas (US),

1 May 2018-25 Jan 2019) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich managing member, inactive branch PILGRIM Warwick Owner LLC

(Texas (US), 6 Jun 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich managing member, inactive branch PILGRIM Coulter LLC (Texas

(US), 9 May 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich managing member, inactive branch PILGRIM Warwick LLC (Texas

(US), 9 May 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich managing member, inactive branch PILGRIM Windtree Owner

LLC (Texas (US), 6 Jun 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611,

USA

inactive Steven Ivankovich managing member, inactive branch PILGRIM Coulter Owner LLC

(Texas (US), 6 Jun 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 179 of 182 PageID #:3364
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 4 :: OpenCorporates

https://opencorporates.com/officers?page=4&q=Steven+Ivankovich&utf8=✓ 2/4

Steven Ivankovich agent, branch ATLAS APARTMENT HOMES LLC (Florida (US), 17 Mar

2014- ) 791 Crandon, Key Biscayne, FL 33149

inactive Steven Ivankovich director, inactive branch PILGRIM Coulter LLC (Texas (US), 9 May

2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich owner, inactive branch Atlas Apartment Homes LLC (Texas (US),

1 May 2018-25 Jan 2019) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich director, inactive branch Atlas Apartment Homes LLC (Texas (US),

1 May 2018-25 Jan 2019) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich director, inactive branch PILGRIM Windtree LLC (Texas (US), 9

May 2019-20 Aug 2021) 1 E Erie St, Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich director, inactive branch PILGRIM Coulter Owner LLC (Texas

(US), 6 Jun 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich owner, inactive branch Atlas Apartment Homes LLC (Texas (US),

1 May 2018-25 Jan 2019) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich director, inactive branch PILGRIM Warwick Owner LLC (Texas

(US), 6 Jun 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich managing member, inactive branch PILGRIM Windtree LLC

(Texas (US), 9 May 2019-20 Aug 2021) 1 E Erie St, Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich director, inactive branch PILGRIM Warwick LLC (Texas (US), 9

May 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven Ivankovich director, inactive branch PILGRIM Windtree Owner LLC (Texas

(US), 6 Jun 2019-20 Aug 2021) 1 East Erie Street Ste 525 253, Chicago, IL, 60611, USA

inactive Steven V Ivankovich inactive branch ALLIANCE HTFL GP, L.L.C. (Florida (US), 18

Jun 2007- ) 55 E Monroe, Chicago, IL 60603

← Previous

4

Next →

Results per page Enterprise users only

Filter by jurisdiction

1 California (US)

55 Florida (US)

1 Georgia (US)

29 Illinois (US)

1 Indiana (US)

1 North Carolina (US)

20 Texas (US)

7 United Kingdom

Filter by position

4 agent

2 assistant sec.

1 assistant secretary

1 chairman

1 chief executive officer

14 director

2 executive vice president

1 llp designated member

26 manager

6 managing member 30

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 180 of 182 PageID #:3365
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 4 :: OpenCorporates

https://opencorporates.com/officers?page=4&q=Steven+Ivankovich&utf8=✓ 3/4

2 member

2 owner

7 president

11 secretary

13 vice president

22 [blank]

Filter by nationality

7 AMERICAN

108 [blank]

Filter by occupation

1 COMPANY DIRECTOR

3 REAL ESTATE CEO

2 REAL ESTATE PROFESSIONAL

109 [blank]

About us

About

Blog

Team

Governance

Jobs

Using our data

Our data

Our purpose

Legal/Licence

User/Cookie privacy policy

Public records privacy policy

Help

API Reference

Glossary

Status

Contact

Twitter

Medium

Newsletter

Problems with our data?

Temporary redaction

Impact

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 181 of 182 PageID #:3366
4/24/23, 11:58 AM Company officers with names matching 'Steven Ivankovich' :: Page 4 :: OpenCorporates

https://opencorporates.com/officers?page=4&q=Steven+Ivankovich&utf8=✓ 4/4

Impact

Grants

Case: 1:20-cv-04985 Document #: 263 Filed: 04/24/23 Page 182 of 182 PageID #:3367