Vip: IN THE EIGHTEENTH JUDICIAL IN AND FOR BREVARD COUNTY, FLORIDA IN THE CIRCUIT COURT CIRCUIT CASE NUMBER: 05-2005-DR-022015-Xxxx IN RE: The Ma age Of NANCY ST. GEORGE, CERTIFIED —_ COPY JAMES ST. GEORGE, an Respondent. gz 5 8 aan = 8 = BS pas BS= 8 a 83s UE Sas c mae ~ F fof = ram 3 a DEPOSITION OF JAMES S' GEOR‘ The transcript of the testimony taken before LISA B. JOHNSTON, RPR, CRR, CCP, Court Reporter and Notary Public, at e law office Jacoby, Brimo, Figueroa & Chase, 2111 Dairy Road, Melbourne, Florida, on the 10th of August, 2006, commencing at 1:37 p.m. Case # 05-2005. DR-022015:2000 XX Document Hint #2 {AT i RYAN REPORTING REGISTERED PROFESSIONAL REPORTERS 1670 SOUTH ROCKLEDGE, KE BOULEVARD 100 RIALTO PLACE, FLORIDA 32955 SUITE 700 MELBOURNE, FLORIDA 32901 (321) 636-4450 FAX: (321) 633-0972 1) a eei APPEARANCES 2 FOR THE PETITIONER 3 DIANA J. FIGUEROA, ESQUIRE 4 Of Jacoby, Johnson, Brimo, Figueroa & Chase 2111 Dairy Road 5 Melbourne, Florida 32904 6 7 FOR THE RESPONDENT 8 DOUGLAS D. MARKS, ESQUIRE Of Boyd & Marks, P.A. 8 709 South Harbor City Boulevard Suite 230 Melbourne, Florida 32901 12 ALSO PRESENT: 13 NANCY ST. GEORGE, Petitioner 7 18 19 20 22 23 24 Ryan Reporting (321) 636-445012 13 14 16 17 18 19 20 21 22 23 24 INDE Testimony of James St. George: Direct Examination by Ms. Figueroa 3 Word Index: 134 Be xXeHeripe rete) PETITIONER'S DEPOSITION EXHIBITS FOR IDENTIFICATION: #1 Document entitled "Men Can and Do Win Custody" #2 Document entitled “Jamie's Medication" Ryan Reporting (321) 636-445010 a1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THEREUPON, JAMES ST. GEORGE, having been first duly sworn, was examined and testified as follows: RECT EXAMINATION BY MS. FIGUEROA: Q. Will you state your name, please. A, James Kevin St. George. Q. And your current address. A. 4093 Deerwood Trail, Melbourne. Q. Okay. Who lives at this address? Myself, my fiancée, Sonya Casey, and her son, Douglas Casey full-time, and of course my son and my daughter visit. Q. Okay. And does Douglas Casey have his own room? He does. Q. Okay. Is Sonya receiving child support for Douglas? Yes. Q. How much does she receive? I'm not sure. I think it's a hundred dollars a week. Q. Okay. And other than that, do you support any other needs that's not met by the hundred dollars a Ryan Reporting (321) 636-445010 11 12 13 14 15 17 18 19 20 week? He lives in the same house and uses the same electricity and such. o. Okay. Do you buy anything else for him? Meals outside? Clothing? A. Q. No. Sonya has a full-time job. Okay. Okay. Are you still renting? No. Okay. So this is a purchase? Yes. Okay. When did this purchase occur? 12/05. And have you provided your attorney all the documents regarding to the sale and the purchase? time of the separation up un’ They were turned over to Mr. Feinberg. They were turned over to Mr. Feinberg? Okay. And what was the purchase price of the home? One million fifty. Okay. How many bedrooms? Four. And what's the square footage? Don't know. A little over four. Can I assume that you rented then from the 12/05? Yes. Ryan Reporting (321) 636-445010 11 12 14 15 16 17 18 1g 20 21 22 23 be Q. Okay. And is the home in Sonya's name as wel AL Yes. Q. How much money did she put into the home? A. I don't know. Q. Well, how much for the down payment? A, Her home is being sold now, so she contributed I think a few thousand. I don't have an exact number Q. Okay. So the majority of the down payment came from you, correct? eee Yes. Q. You agree the date of marriage is June 27, 19992 A, I guess. I don't recall. And the place of your marriage Jupiter Florida? Yes. Q. Okay. A. Actually Tequest Q. Pardon me? A. Actually Tequesta was the place of marriage. Now, I just want to go over just a brief history here. You lived in Jupiter for approximately one month and moved to New York July 1999? No. Ryan Reporting (321) 636-445010 ql 12 13 14 15 16 7 18 19 20 21 22 23 24 25 Q. | Hmm? No Q. All right. What happened? I lived in Jupiter £ x two years. You lived in Jupiter for two years. Okay And when you moved, you moved for the purpose of your job in Syracuse. A Yes. . MARKS: Let me just state for the record, you were quite insistent with me on not going into what was inquired of in the prior deposition, and his work history and moves were dealt with extensively. MS. FIGUEROA: Except the purpose of the moves were not. MR. MARKS: Well, I don't agree with that but I think he was asked quite a few questions about that. BY MS. FIGUEROA: Q. What was your rate of pay at the time of marriage? At the time of marriage, less than 200,000. Q. Okay. And then when you moved to Syracuse for that new job, what was your rate of pay? 225,000. Ryan Reporting (321) 636-445010 a1 12 13 14 15 16 17 18 19 20 22 23 24 25 he Q. And what was Nancy's rate of pay in Syracuse? A In Syracuse? Nancy stopped working the day we got married. Q. Okay. From the beginning, you would agree would you not, that you were going to be the primary financial provider? A. How do you mean by “primary"? Only or primarily? Q Primary. A. I make more money. Q. Well, was it an agreement between the two of you that you would be the financial -- the primary financial provider? A. There was no agreement. I worked; she refused to work. Q. Okay. So you're saying you asked her to work? A. On a number of occasions. Q. From the very beginning. A, Well, she became pregnant a week after we got married and she chose not to seek work Q. Okay. And you asked her to work during her pregnancy. AY Yes. Q. Okay. And you recall this conversation. ae ea Ryan Reporting (321) 636-445014 15 16 17 18 19 20 21 22 23 24 25 q. Q. Okay. A. Most people who are pregnant work. Q. Okay. And what was the point of her working right after she got pregnant? Were you not -- MR. MARKS: I object to the form. TI don't understand the question. Vagueness is the objection. MS. FIGUEROA: I'll restate it BY MS. FIGUEROA: Q. You would agree, would you not, that you had sufficie: income to support the two of you during her pregnancy, is that correct? A There were de’ - I would say no. We're two people, we're a spouse and she could work as well as I could work. Additional income would have been useful to the marriage. Q. Okay. $0 you're ~~ A, In fact, I took out a second mortgage on that property to pay debts. Q Okay. Now, these debts, were these your debts from premarital debts? Yes. Q. How much debt did you come into the marriage with? I don't have an exact number. Ryan Reporting (321) 636-445010 a. 12 13 14 15 16 a7 18 19 20 21 22 23 24 25 \0 Q. Give me an approximation. A. I have no idea. The second mortgage was for $40,000. Q. Okay. Some of that money was to pay debts, some of that was buffer savings for the marriage. I placed 100 percent of my premarital savings on the down payment of the house in Syracuse. Q. And the house in Syracuse is in joint names? Yes. Q. Okay. A. Unfortunately. MR. MARKS: Just answer the que BY MS. FIGUEROA: Q. On the second mortgage for the 40,000, do you have any documentation to show what went to pay your premarital debts and what went into the present marriage? A Repeat. Q. Do you have any documentation to show where that $40,000, how that was spent? A. Specifically no. All the documents were taken by Nancy at the time I was removed from the home. 1 would suspect that some of those -- that money was spent for taxes and expenses for the new home. Ryan Reporting (321) 636-445010 cL 12 13 14 22 23 24 25 Do you have any documentation that would indicate what your premarital debts were A. I don't recall. Okay. So then you would have expected her to be working in order to pay some of your debts? Pay my debts? 2. Mmm-hmm. A. I expected her to work to help support the household. Q. Okay. And where was she working when you first met her? A. New Look Hair, something of that nature Okay. And was she working full-time? Yes. Q Okay. And it's your testimony today that upon your marriage to you, she immediately stopped working and refused to work even after your insistence -~ AL Yes. -- that your testimony? A. Yes. Q. Okay. Now, er two years, you moved with Nancy from Syracuse to Philadelphia. A. After two years. After two years I moved -- I took a job Philadelphia; Nancy stayed in Syracuse in the home. Ryan Reporting (321) 636-445010 1 12 13 14 22 23 24 25 Q. Okay. And, again, that would due -- this whole move had to do with your employment. A. Correct. Q. Okay. And amie was born, though, in Syracuse, correct? AL Yes. Q. Okay. So while you were separated, Jamie -- well, strike that. Nancy was a full-time, stay-at-home mother, correct, with Jamie while you were in Philadelphia. AL Yes. Q. Okay. So she provided solely for Jamie on a full-time basis, is that correct? How do you mean "provided sol Q. Well, since you were in Philadelphia, she was the sole person, giving him a bath, doing laundry; caring for your son. A For one year - Q. Okay. A, -~ while the house Syracuse was on the market. It took a year to sell. And then you had Nancy again move to New Jersey, right outside of Philadelphia. That was when the house sold. Q. Okay. And then approximately after two years Ryan Reporting (321) 636-445012 13 14 15 16 a7 18 19 20 21 22 23 24 25 Be again you changed your job again, is that correct? We've been through this, haven't we? MR. MARKS: Yeah. BY MS. FIGUEROA: Q.- . Well, 1 t me just, so I can summarize it. All the moves in this marriage have been due to your job changes, is that correct? A, Correct well, Nancy wanted to move to Florida; she did not like Philadelphia. Q. Okay. But you had a job change, is that correct? I had a job change -- Q. Okay. A, -- when we moved to Florida, yes. Q. And during all these moves, Nancy was the primary care provider for Jamie, is that correct? I worked and Nancy did not work. Q. My question is - Re If you -- Q. ~~ she was the primary care provider taking care of your son, correct? During the day while I worked Q. And during this time that you worked up until the time you came back Florida -- Excuse me, actually I'd like to modify Ryan Reporting (321) 636-445010 11 12 13 14 15 16 1 18 19 20 21 22 23 24 \e something. That is incorrect. While we were in Philadelphia, my son was in full-time day care. Q. And for how long was he in full-time day care? A. Almost a year. Q. One year. AB From September to July. Q. Of what year? A. I'll have to do the math. September of '02 to July of ‘03. Q. How old was he? A. Again, I'll have to do the math. So he was probably -- he was born in 2000, so he was two Q. Two years old. A. He was two, two and a half. Q. Okay. And do you have any documentation from this day care? A. Yes. Q. Okay. And what's the name of the day care? A. Excel Learning Center Q. And has that been turned over to Feinberg? Why would I turn that over to Feinberg? MR. MARKS: Just answer the question. BY MS. FIGUEROA: Q. Have you turned it over to your attorney? A. No. Ryan Reporting (321) 636-445010 aa 12 13 14 15 16 aw 18 19 20, 21 22 23 24 25 All right. So where are these documents being held? A They're reflected in bank statements and canceled checks. Q. Okay. A. There's no documents. Q. Now, was he in full-time day care due to the agreement between the two of you? A. Yes Q. Okay. And, I'ms in what state was this in? A. New Jersey. Q. Okay. And what was Nancy doing while he was ime day care? A. Don't know. Shopping. Q. Okay. If you don't know, you don't need to speculate. If you know, tell me. If you don't, tell me you don't know. A. Shopping Q. Okay. So you know for a fact she was shopping A, I assume she was taking care of the -- you know, doing laundry and household chores and running errands. Q Okay. And when you say full-time, can you Ryan Reporting (321) 636-445012 13 14 15 16 wy 18 19 20 21 22 \o 16 what hours were full-time day care? A. 8:00 in the morning till afternoon sometime Q. What time in the afternoon? I don't recall. Was it a preschool? He was two and a ha Q. So you don't know what kind of school -- did you visit the day care? t's preschool. Q. Okay. So -- you day care. A, I'm sorry, what's the distinction? ©. I don't answer questions. Do you know the distinction? It was preschool in the sense that they did some educational, you know, helping him with learning his basic ABCs and such, so it wasn't ro ne day care in the sense that it was a cl d being, you know, just watched and not, you know.... Q. And at what time during the day did it become a day care? A, I don't understand your question. Q. Well, obviously if part of it's preschool there are certain hours that it's preschool and the other part is day care. Are you aware that there's a distinction? {______ryan Reporting (321) 636-445010 11 12 16 17 18 1g 20 au 22 23 24 25 1» I think that distinction's rather gray. I mean, I think many at that age group, these entities are functioning as both accommodation day care and as to -- you know, some of them offer a little more services than day care, but in essence it's day care in that someone is taking care of your child while you're not there. you want to call it preschool or you want to call it day care, that's your choice. What is your understanding when preschool -- what time preschool ended? There were parents that picked up their children at 5:00 or 6:00. Q. Okay. A. There was after care for people -- for older children in the community schools. Q. How often were you at this facility? A. Quite a bit. Q. Okay. What's "quite a bit"? A, I don't recall. Q. Do you ever take Jamie there? A. Yes, and I picked him up. Q. And you picked him up. A. Yes. Q. Okay. And was Jamie learning at that facility? Ryan Reporting (321) 636-445012 13 14 15 16 1 18 19 20 22 23 24 25 Ve A, Was he progressing? Is that what you're asking me? Q. 9 Mmm-hmm. A. He's had a learning disability from early on so one of the reasons for putting him there was to help him with his learning problems. Q. Okay. Now, can you state under oath here today for certain that he was in full-time, meaning he stayed there every day until 5:00 o'clock? A, I don't recall what time she picked him up. I think she may have -- it depended on what her -- what she chose to do. Some days she picked him up at noon other days he was there till 5:00. I think early on when he first started there he started there part-time and then he later progressed to full-time. What do you mean "progressed"? A. The decision was made to keep him there full-time by us. Nancy refused to allow him to be in full-time before that. Q. Okay. And why? I can't speculate. She didn't want him in me care. Q. Okay. When was he first diagnosed with having any kind of issues? A We suspected that when we moved to New Jersey Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 21 22 23 \q2 His speech was delayed. Q. Okay. Was he diagnosed at that point in time? A. No. Q Okay. A Well, at that point in time we initiated early intervention program through the State of New Jersey and he was assessed Q. What was the assessment? A. That there was speech delay. And that's all that you all knew at that point in time. A. Well, he underwent extensive -- he underwent evaluation by -- he had a hearing test, he had evaluation by occupational therapy and evaluation by a behavioral therapist, he had evaluation by a speech therapist. All these documents were turned over -- or I believe turned over -- or Nancy turned them over to Mr. Feinberg. Now, what were your hours of work up until the time that you were in New Jersey? Up until the time I was in New Jersey? I went in at 7:30 or 8:00 and depending on the day and/or was on call, home by 5:00, Ore ett) Uivasiom cali o could be there later, depending on what additional Ryan Reporting (321) 636-445010 ql 12 13 14 15 16 a7 18 19 20 21 22 24 25 cases needed to be done at the hospital. Q. How many days a wee A. How many days a week? Q. Mmm-hmm. I don't recall my schedule in Syracuse. on average I was probably on call every fourth weekend Q. And your normal weekdays were what? A f I wasn’t on call, 8:00 to 5:00. Q. | Monday through Friday? Sunday through Thursday? What days of the week? Monday through Friday. If I was on call, would be required to be available by pager during the weekend. Q. Okay. And when you got home from work, tell me what activities you did en I got home from work, Nancy would be generally quite irritated taking care of Jamie and I essentially took care of my son until bedtime and helped her with whatever needed to be done around the house. Q. What exactly did you do? A. I played with my son, I interacted with my son, played games, watched TV with him. I was a parent to him when I got home from work Q. And what time did he go to bed? {_____________yan Reporting (321) 636-445010 1 12 14 15 16 17 18 19 20 21 22 24 25 Wa It varied, but generally depending on his age of course, and I was there when he was born so he would be an infant, and so he was essentially in Syracuse from the day he was born till we moved, so, you know depending on his age he would go to bed at different times, but, you know, obviously infants have different schedules than two year olds. Q. So you didn't have a routine bedtime for h Unfortunately not. It varied. Sometimes he would go to bed later, 8:00 o'clock. Sometimes even later. Q. Who primarily put him to bed, you or Nancy? A. We both did. Q. Equally? A, I would say so. Q. Okay. Now, hen you got home from work, who did the cooking and cleaning and laundry and so forth? Nancy did laundry. Cooking was variable, she didn't really cook. You know, it was a typical division of labor in the household. I did the male -- typical male jobs, she did the stereotypical female jobs. I'm not familiar with your definition of “typical jobs." A. She did the laundry and cleaned; I, you know Ryan Reporting (321) 636-445010 1 12 13 14 15 16 a7 18 19 20 22 23 24 25 he fixed the car and did repairs. Q. Okay. Now, you purchased the marital home in July of 2003, correct? A. Correct. Q. And from what funds did you use to purchase the home? You said some was from your premarital savings? No, that was the Syracuse home. Q. Oh, the Syracuse. Okay. So the - A. Joint funds. Q. Joint funds? Okay Since the marriage to Nancy, have you maintained all joint accounts? A. Have I -- MR. MARKS: Up until today you mean? MS. FIGUEROA: Mmm-hmm -- no, up until the separation; I'm sorry. THE WITNESS: What do you mean by "maintained"? FIGUEROA: Q. Have all your accounts been joint with Nancy? A. Any money I put in was joint. Nancy kept joint marital funds in an account that she refused to put my name on. And what account was that? Ryan Reporting (321) 636-445010 aL 12 13 14 15 21 22 23 Q joint funds in that account? A Q of why she put joint funds into her separate account? A always threatening divorce, so she wanted to keep that money in from me. threatening divorce from beginning? A Syracuse. Q having? unhappy with Syracuse. She got pregnant, her emotional and psychological issues became aggravated. She was -~ I came home from work, I would expect not to find her there. So basically from within a week from moving Syracuse, a. + Plaud? The New Jersey P and C account, And why, to your knowledge -- why did she put Say ag, To your knowledge, wha is your understanding She wanted it in case -- well, Nancy was an account for her use should she be divorced Okay. So you mentioned that she was - I'm assuming from the very Literally from almost a week from moving to And what type of problems were the two of you We weren't getting along. She was very she was threatening to leave. Okay. Now, did you secure the services for a Ryan Reporting (321) 636-445010 1 12 13 18 19 20 21 22 Xe ever consult with your + No. Q. Okay. So his information from you? I did. Q. Okay. And do you have a copy of the Cv for Dr. Plaud? A. Was that turned over to Feinberg? MR. MARKS: I honestly don't remember. THE WITNESS: To answer your question, yes. BY MS. FIGUEROA: Q. Okay. A. He also has a website. The CV's on the website. Q. Did he provide you a report? A. He did Q. Okay. Has that been turned over to your attorney? AL Yes. Q. Okay. Do you have a copy of it? Do I personally have a copy? Q. | Mmm-hmm. That was sent directly to my attorney. Q. Okay. And to your knowledge, did Mr. Plaud Ryan Reporting (321) 636-4450 wife? report is solely based on10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 2s A, It's based on psychological testing. Q. And information provided by you solely. Yes. Q. Okay. Do you recall what kind of psychological testing was performed? A. Don't know. MR. MARKS: I'll object at this point; it's work product. He's not going to testify he's a non-testifying expert, so it's work product. MS. FIGUEROA: He's not listed on your pretrial statement? MR. MARKS: I don't believe so. THE WITNESS: No, he's n MS. FIGUEROA: Off the record. (Thereupon, discussion was held off the record.) MS. FIGUEROA: Okay. We can go back on BY MS. FIGUEROA: Q. When did Jamie -- besides the preschool we talked about in Syracuse, did he go to any other schools? When we moved here to Florida, he continued his early intervention program and he was in -~ was supposed to be in full-time early intervention at Sea Ryan Reporting (321) 636-445010 11 12 13 14 15 16 7 18 19 20 2. 22 23 24 Nore Park Elementary in 2:30 until school ended. wouldn't let pick him up at noon. And do you know why? based on? Indication to me that Okay. Were you there A, He wouldn't stay past him stay past 2:30 Q. Did you ever pick him Yes. Q. Okay. How often -- A. I don't recall. Q. == were you at Satellite Beach and initiated shortly after I moved here, in that program until he Q. Okay. And what time o Sea Park? A He was supposed to be Nancy that was and he continued became regular kindergarten f the day did he attend there from 8:00 until routinely -- Nancy him stay there the full time and would A. She said that he was unhappy there if he stayed there longer. Q. Was he? A. I don't believe so. Q. You don't believe so? Or what is your belief he was not. at 2 0 to pick him up? 2:30, Nancy wouldn't let up there? the school? Ryan Reporting (321) 636-4450ee e 1 fee donut recall: 2 Q. On a weekly basis, how long would you either 3] take him to Sea Park or pick him up? 4 A. Occasionally. I worked. 5 Q. What was the name of his teacher there? 6 A. Mrs. Mullen. 7 Q. And how often did you meet with Mrs. Mullen in 8] person? 9 A. Oh, once or twice. ybe -- no, I'd say about two or three times. 1 Q. Okay. Did Nancy express to you Jamie's 12] behavior when she went to pick up Jamie? e 13 A She did. 14 Q. Okay. And are you telling me you didn't 15] believe her? 16 A. I did at the time, but I've come to realize 17] that her assessment of Jamie's behavior and mine are 18] extremely different. 19 2 So you saying at the time that this 20| occurred, you did believe her. 21 A, I did at the time. 22 Q. Okay. Now, would you agree that Nancy was the 23| one that primarily took him to Sea Park and picked him 24) up? e = Ryan Reporting (321) 636-445010 a 13 14 16 7 18 19 20 21 22 23 24 AY 2 Q. Would you also agree that Nancy was the one primarily that took him to and from doctors’ appointments? AL Yes. Q. Okay. Have you filed your taxes for 2002 three, four, and five? AL No. Q. 9 why not? A. The taxes have been paid through W-2 withholdings. However, when we moved -- my account was in Syracuse. We moved down here, never got an accountant down here; really just lack of -- lack of attention to it is why they haven't been filed I started to put the taxes together shortly you know, a number of months before the separation and then she had all documents, I wasn't able to proceed. Q. Can you tell me what forms of discipline have you used on Jamie? A. Time out, with a very rare spanking of a hand or a buttocks. Q. How old was he when you started spanking him? A. Over two. And I would say that Jamie's been spanked with maybe a single light spank no more than two or three times in his entire 1 Q. Tell me how you use time out Ryan Reporting (321) 636-445010 11 12 14 15 16 17 20 21 22 23 24 25 2» I would place him in time out for a period of time. Usually the guidelines are his time out is his age plus or minus a minute. Q. Well, tell me what you did, not what the guidelines are. A. That's what I did. Q. Okay. And where was the time out? A. Time out was in New Jersey in the kitchen near a phone, or in the bathroom/the powder room around the corner from the kitchen. Q. Okay. Was he placed in the chair or on the floor? A. On the floor. Q. Okay. Does Sonya discipline Jamie? A. No. Q. Has she ever? A, I think she may have placed him in time out once or twice. Q. Has she ever struck Jamie? A. No, absolutely not. Q. Has your fiancée been married before? AL Yes. Q. When was she divorced? A. October of 2004, Q. What was her married name? Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ®, 0 A. Q. was she divorced? A. Here. Q. At any time during the marriage did you possess pornography with underaged teenagers? MR. MARKS: I object. This was gone into extensively in the ot er depos direct you to the page. MS. FIGUEROA: Then go ahead THE WITNESS: Actually talk to my wife to see if you want to go there. MS. FIGUEROA: Look at page 119 to 120. Let's go off the record. (Thereupon, discussion was held off the record.) MS. FIGUEROA: Okay. Let's go back on the record. BY MS. FIGUEROA: Q. Did you possess pornography with underaged teenagers? Absolutely not. Q. Okay. And did you possess pornography in the home? Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 a 31 AL Yes. Q. Okay. Where did you keep it? A. My personal -- MR. MARKS: Again, I believe this was gone MS. FIGUEROA: That was in there? MR. MARKS: Yeah. In the desk, by the computer. was gone into. MS. FIGUEROA: Okay. I'll take your word for it, because I don't want to look at it again. MR. MARKS: Well, let me -- you know, I'll go through the word index. I truly believe there was questions about whether it was in the desk, in the computer, that kids had access to the computer. There was a full discussion on that subject. MS. FIGUEROA: Okay. THE WITNESS: There was also testimony in court. MS. FIGUEROA: Okay. 1 will move on then BY MS. FIGUEROA: Q@ All rig I'm going to refer your attention to your son. You agree, do you not, that he is a special-needs child? Ryan Reporting (321) 636-445010 11 a7 18 19 20 21 22 23 24 wy, - T absolu ly do not believe that. ©. Okay. So do you deny that he's a specia needs child? A. Yes. Q. Okay. What is that based on? MR. MARKS: I'm going to object. You know, just to make sure we're on the same page no predicate as to the term “special-needs child." MS. FIGUEROA: Well, he answered it. BY MS. FIGUEROA: Q. If you're den: g that he's a special-needs child, tell me what the basis of your denial is. MR. MARKS: All I'm trying to figure out Diana, is whether you have some particular meaning in mind when you say "special needs." MS. FIGUEROA: Okay. So you have an objection to the terminology, just so we're on the same page, as to the definition? MR. MARKS: ect. BY MS. FIGUEROA: Q. Okay. What do you understand "special needs" to mean? A. I understand special-needs children to require special care outside the needs of a normal, healthy. Ryan Reporting (321) 636-445010 oy 12 13 14 15 16 17 18 19 20 2 22 23 24 25 ® stereotypical child. Q. Okay. BR. Special med cal needs, special personal needs care above and beyond, sometimes an additional provider. Generally those type of -- I consider those type of children impaired and disabled Okay. I know you consider them impaired -- I didn't ask you if your child was impaired and disabled but a special needs. ith that definition, including extra needs for educational purposes, do you agree that Jamie is a special needs with that definition? No. Q. Okay. And what is your denial based on? A, Jamie has a learning disability, period Q. Okay. A. Hundreds and hundreds of children have learning disabilities. That does not label them special needs. @. Okay. Now, describe to me your understanding of what his disabi ity is. Oh, I think we're in the process of discerning that, but Jamie is immature and behind in his ability to master ABCs and counting and the fundamental core curriculum of kindergarten. Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 x, Q. And do you know why he's behind? There's been a lot testing. We believe there may be some phonetical central processing in terms of his ability to process concepts. Q. Before you go on, when you say "we believe," who is "we"? A. This testing is ongoing; this testing that Jamie is currently being seen by Brevard Learning Center, he is being evaluated and tested by Dr. liamson, and when I say "we" at this point in time, that's those two individuals who have done extensive testing on Jamie. Okay. My question is really what you understand his needs are, not what the doctors believe Your understanding. My understanding is conveyed through those doctors and that's what -- I just expres: what my understanding was as explained to me by the professionals. Okay. Now, let me just be clear. So you think it's st a phonetic type of problem? Can you explain what your understanding is one more time? aA s an ability to process and learning Jamie needs to learn outside of perhaps traditional methods of teaching. He requires integration of all Ryan Reporting (321) 636-445022 23 24 his senses to process and retain the material. Q. Okay. Now, with that in mind, you would agree, would you not, that it's in Jamie's best interest to be under the care of his mother or a parent than in a day care facility, after school day care facility that does not understand his needs? A. Absolutely not. Q. Okay. A Well, there are no needs. His issues are educational. School ends at 2:30, education ends at 2:30. Q Okay. So you're saying outside of his educational issues, you believe Jamie's a normal child that can thrive in a regular public school/day care facility. A. Absolutely Q. Okay. Have you caused Jamie to be evaluated by any of the schools? A Evaluated by any of the schools. Yes. ted? Q. Okay. What have you ini A, Let's see. Well, Nancy and I both initiated the early intervention program. Q. Not Nancy and you. What have you -- A. Okay. Q. =~ on your own. Ryan Reporting (321) 636-445010 12 12 13 14 15 16 7 18 19 20 22 23 24 Be Well, I was involved in that. I initiated the early intervention program. MR. MARKS: Hold on a second. Is your question what he initiated without any involvement of Mrs. St. George? MS. FIGUEROA: Other things that Nancy didn't do. BY MS. FIGUEROA: Q. It's my understanding that Nancy's done most of all the initiation of the testi: I want to know if you've done anything over and above A. That's incorrect. Q. If I'm incorrect, please -- MR. MARKS: Okay. I'm just trying to understand what you're asking. He's saying there's things that they did together. Do you want to exclude that? BY MS. FIGUEROA: Q. Okay. No, go ahead and tell me. What did you do? A. I was integral and the driving force behind Jamie's involvement in early intervention. I initiated and evaluation by [MMMM Nancy removed Jamie from NM. I filed a motion to have Jamie complete evaluation and treatment by Jy. = Ryan Reporting (321) 636-445018 1g 20 OK, initiated and required a motion and court hearing to I filed motions to have Jamie evaluated by have Jamie evaluated by MMMM. 1 facilitated Jamie's hearing test at the children's hospital -- one of the children's hospital in Philadelphia. Let me think, what else has he had done? We jointly initiated evaluation and therapy of s speech problems. He had i in nucd NE in New Jersey and has been ongoing in J here in Brevard. Q. Who has taken Jamie to all of these Jamie! Syracuse. appointments? A. Nancy took Jamie to the speech therapy appointments. Q. Mmm-hmm. Dr. Mosher. A. With SY Nency took -- well, an injunction was in place with the evaluation of actions. I was unable to take Jamie due to her And I took Jamie to [NNN as much as she does. 0. Okay. Under EE zequest. AL Yes. Q. Okay. And what about 2 A. Again, she prohibit g contact Ryan Reporting (321) 636-445015 16 17 18 19 20 Se with Jamie through the injunction and she took Jamie to What is your understanding why Nancy removed A, My understanding that -- MM had a conversation with me, explained to me where Jamie was and what her evaluation of Jamie was, and within days Nancy removed him from further evaluation following a meeting with me And do you know why? A. I have -- I mean, do I know why? Her explanation and my understanding of why that happened are totally different. Q. Okay. What was her explanation? She claimed that MY did not know Jamie -- forgot Jamie's name; that ME didn't A tell Nancy that she met with me. They were excuses. The real reason she took Jamie from me -- took Janie fron is because ME net with me. Q. Okay. And why would that concern Nancy? A You'll have to ask your client that. Q. Okay. Now, during this entire time of all this early -- from the early intervention all this time, you would agree, would you not, that Nancy was Ryan Reporting (321) 636-445010 11 12 3) 14 15 16 aq 18 19 20 21 22 23 24 25 5 providing him the primary care? A During the day while I worked. I provided care in the evenings. Q. Now, there is no question that you're financially able pay your child support, as well as any extra monies that Jamie may need for his issues A. I earn a good income. Q My que on is, do you see any problem with your financial ability to continue paying the guideline child support plus any other expenses with regard to his special issues? A. We have taxes to file, assuming that -- I do not know what my liabilities there will be. I would have to see what those numbers would be; I cannot say right now. Do you know what other costs are associated with Jamie's special issues? A. Currently? Q. Mmm-hmm. A. Well, there's the cost of his There's the co-pays with ay Q. Okay. Do you know what they average per month? A. Well, Nancy only -- has only brought Jamie to Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ®, $35. I believe the [MMM payment is out of pocket and I believe that's $45. Q. Okay. So they're rather nominal costs. A. Correct. Q. Okay. Do you have any ~~ would you agree would you not, that you're also financially able to ute to the financial support of your wife? Absolutely not Q. You're not able to? AL No. Q. 9 Why not? I have expenses. I've got another child support to pay from my previous marriage, I've got household expenses, I've got personal expenses. Q. What -- AL Nancy is ~ Q. I'm sorry. A. Nancy is able bodied and able to work. Q. What other child support do you pay? 1,841 a month for my child in Boston. Q. Can you tell me what retirement plans you have? I have a TIF Cref (phonetic spelling) that was initiated premaritally when I was staff at Brigham and Women's Hospital in Boston. Ryan Reporting (321) 636-445014 15 16 17 18 19 20 21 22 23 24 25 Q. Okay. That's the TIAA? A. Yes. Q. Okay. You're saying that's premarital? A. Yes. Q. Have you contributed -- let's take that one first. The TIAA, have you contributed since your marriage? I believe most of that is Brigham and Women's Hospital in Boston. I personally haven't contributed I would have to go back and look at the records Q. Upon your marriage to Nancy, were there any employer contributions? A. Not that I recall. Q. So you're saying that there's been no contributions since -- A. I would have to check what HAN was. I'm not sure what the retirement plan at HAN was. I only had some contribution from HAN maybe the last six months of my employment there, and I'm not sure what that was. Q. All right. During the litigation in this case, have you produced documentation from the date of the marriage on TIAA? . Nancy had all those document. I received them recently; I haven't looked at them. Q. Okay. All right. and -- Ryan Reporting (321) 636-4450Vv Qe 10 11 12 13 14 15 19 20 21 22 24 25 I received them to months ago, three months ago. Okay. And go ahead and tell me about your other retirement plans. I have -- let me think, I have a SEP with maybe $4,000 in it, which is premarital. Q. A SEP. Is that the one that's in NBT Bank? No, that is ~ well, yes, there is one at NBT Bank. It was originally in Fleet Bank in Boston and I had t that was premarital when I was living in Boston. When I joined Syracuse University, Syracuse University while I was married established a retirement at NBT Bank. I transferred the funds from Fleet Bank to NBT Bank to just being in one institution. Q. Okay. So then the one that's listed on your financial affidavit for NBT Bank in the amount of 4,077.23, that's the one you transferred from Fleet. Correct. Q. Okay. And that's still the value currently? A, It's 4,000 and change. I'm not sure what the exact number is. Now, have you -- I have not contributed to i Q. Okay. And you're alleging this is also premarital. Ryan Reporting (321) 636-44501. 12 13 14 16 17 18 19 20 21 22 23 24 25 Ww 43 Correct. Q. That was the value at the time of the marriage and it's still the same value -- Yes. Q. = plus or minus -- Dividend and interest. Q. And then I have another one here for 67,000. in that one? A. That was during the marriage; that was earned during the period of my marriage and during my appointment at Syracuse. Q. Okay. Now, for purposes of the trial, do you have a current statement of what the value is? Probably. Q. Okay. And you haven't produced that to your attorney? A. What was produced early on in the proceedings. MR . MARKS: I don't know that I have a recent one, but we'll get one. MS. FIGUEROA: Okay. The only reason I'm asking, Mr. Marks, is just because of the discovery cutoff so we have current values. So for the record, Marks is agreeing to produce, that would be the NBT Bank Marital Retirement Plan in the amount of 67,000. Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 44 MR. MARKS: Let's go off the record. (Thereupon, cussion was held off record.) BY MS. FIGUEROA: Q. Have you taken any loans from that? AL No. Q. Okay. During the marriage, did you have any assets that were titled in your name only? MR. MARKS: I'm sorry, other than these retirement plans? MS. FIGUEROA: Correct. THE WITNESS: A 1992 Acura NSX, which was premarital. BY MS. FIGUEROA: Q. Okay. And what happened to that vehicle? A. It's in total disrepair in my garage. Q. Other than that? Well, personal belongings, furniture, things of that nature. Q. Okay. Furniture that's still in the marital home? You're saying some of that's premarital? Our home was sold. Q. Okay. Whatever furniture she has now, that Nancy has. BR. She has some things that are still premarital. Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 19 20 21 Okay. Have you made a list of what items you believe are premarital? A. T have. Q. Okay. And have you produced them to your attorney? I believe I » but... MS. FIGUEROA: Again, I'll ask for the record that -- MR. MARKS: Didn't we come to an agreement? THE WI NESS: Yeah. MS. FIGUEROA: Let's go off the record (Thereupon, discussion was held off the record.) MS. FIGUEROA: Okay. Let's go back on the record BY MS. FIGUEROA: ©. What items of personal property are you requesting? A. Well, I don't have a list with me, but off of recollection, that recollection's not complete Certain things are expected to be turned over. There was some incidentals; there was a red carpet, there was some minor personal items like, you know, tennis racket and things like that. She was supposed to divide the Ryan Reporting (321) 636-4450we 46 14 15 16 17 19 20 21 22 23 24 kitchen property 50 percent; that didn't happen. She was supposed to divide some other things 50 percent; that didn't happen. Accessories; the numerable things that are in the home that were supposed to be divided equally, that didn't happen MR. MARKS: He's referring to that agreement. There was an agreement that they were going to divide -- I don't have it in front of me, but they were going to divide half the kitchen utensils and so he's saying that that didn't happen. BY MS. FIGUEROA: Q. So the agreement hasn't been complied with A Correct. ° Is there anything over and above the agreement that you're still requesting? A. No. Q. Okay. A. Well, other than I think the agreement itself didn't address all the accessories and belongings and various things that were in the home that cumulatively add up but individually are not high value And the other thing the agreement did outline is she was supposed to -- she took possession of all my Ryan Reporting (321) 636-445010 11 12 13 14 15 16 W 18 19 20 «| 47 child's videotapes, all my child's photographs -- Q. You say "your" child's. You're talking about your daughter? A. My son. Our son Q. All right. So -- She took possession of all of Jamie's pictures, all of Jamie's video. In addition, she has possession of my daughter's -- my prior marriage's daughter's videos, which are irreplaceable. Q. Okay. A. She has possession of personal mementoes that are irreplaceable, specifically my Eagle Scout award She's got a -- Are those all premarital personal mementoes? A. Yes. Q. Well, instead of spending the time today which may take hours to go through, I would ask you to make a list of what those items are, supply them to your attorney -- A. Okay. Q. -- so we can get these resolved prior to A. Mmm-hmm. Okay? Now, the 2003 Acura NSX, tell me the status of {______yan Reporting (321) 636-445010 1. 12 13 14 15 16 a7 18 19 20 21 22 23 24 25 A. It's in Nancy's possession. Q. Okay. Do you have any objection to her having ownership? The loan's in my name, I've been making all payments on that car. There's a financial responsibility due on that car. Q. Okay. And how much is owed on that car? A. 'd have to get an updated purchase price -- an updated balance on the loan, but the purchase price on the car was $44,000 and such. Nancy has all the documents for the purchase of that car and she did not turn them over. Q. You have the car listed at a value of $38,000 A. That statement was done -- Q. In 2005, A, Yeah, so that needs to be updated Q. Okay. So you don't have -- you haven't updated your financial affidavit since then? A. I need to do that. Q. Okay. wi would you say the value is? A. I have no idea. Q. Okay. And you're not rea certain how much is owed on it at this time? A. I have no idea. Ryan Reporting (321) 636-445010 an 12 13 14 15 16 a7 18 19 20 21 22 49 MS. FIGUEROA: Let's go off the record. (Thereupon, discussion was held off the record. MS. FIGUEROA: All right. Let's go back on the record. BY MS. FIGUEROA: Q. Are the vehicles in joint names that are listed on the financial affidavit, which is the Acura NsX, the BMW, and the -- well, that was your premarital. Yes, the vehicles are in joint names. Q. Okay. A. Well, no, hold on. You know, I think they're only in my name because I hold the loan and for whatever reason I think I registered them, so they were in my name. Q. Okay. But those two vehicles were purchased during the marriage, the BMW and the Acura? AL Yes. Q. Again, can you -- if I give you your financial affidavit that ve from 2005, can you tell me what debts were acquired during the marriage? I'm concerned, since you said there's debts, premarital debts, what debts -~ A. There's no premarital debts now. Ryan Reporting (321) 636-445010 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 QD 50 Q. Okay. So the MBNA, your Key Bank MasterCard and I guess this would be your student lo ee iesr Q. Okay. Those were all acquired during the marriage? A, Student loan was premarital; that is no longer -- that is paid off Q. Okay. A. The MBNA and Key Bank are premarital; they were my daily-use credit cards. Q. Which one is? A, The credit cards were Q. They were premarital? A. No, they were -- I mean, they were used during the marriage. Q. Are they paid off? A. I guess there was a revolving balancing at various times during the marriage. There was a balance. Q. So we don't know what the debts are. A, I would have to go back historically and look at it at the time of separation Q. Have you produced those statements during the course of litigation as -- a Yes. Ryan Reporting (321) 636-445010 qi 12 13 14 15 51 Q. -- of the time of separation? A. Yes. Q. So they're all -- A. Should be. Okay. Now, her name wasn't on these cards? Pee Noe So there's no issue of her charging after the separation. A Not with the Mastercards. Q. Okay. And there are no other debt Besides the vehicles, I understand we have vehicles and we have the credit cards. Is that the only debts that we're talking about in this divorce? A, Taxes. ©. Okay. And there's nothing listed on your financial affidavit with regard to taxes, not even an approximation. I don't know. I received a lot of those documents just a number of months ago and with the divorce I haven't had any time to address it. Q. Okay. Now, do you have any accounts in your girlfriend's name? No Q. Have you transferred any assets or monies to your girlfriend or anyone else? Ryan Reporting (321) 636-445010 ay 12 13 14 15 16 a7) 18 19 20 21 22 23 24 25 Gv A. No. Q. What was the result of your criminal charges for agg. assault and domestic violence? A. No Informa on. Q. And what is the status of the injunction currently, as you understand it A. Dismissed. Q. After your release from jail on or about February 12th -- was that 2005 or 2006? A. Five. Q. Five -- did you try or did you cancel your wife's cell phone service? . I -- she took my cell phone, my wife took possession of my cell phone prior to her actions and I did not have a cell phone. I canceled my cell phone account; as part of that, her cell phone was canceled That cost me $175 per phone, three phones, her phone my phone, and her daughter's phone, that I had to get a new cell phone. Did you notify her that you were going to do that in advance? How would I do that? There was an injunction and no contact. Q. Through your attorney A. Why would I do that? Ryan Reporting (321) 636-445013 14 15 16 a7 18 19 20 21 22 23 24 25 My question is if you did -- if you made any attempt to notify her. No. Q. Okay. Now, how much money, since this litigation started, have you been paying per mo for the support of Nancy and Jamie? A. $2,000. Q. Total? A. No, $2,000 child support and then she obtained a temporary alimony of 850 per month, plus I'm paying -- I paid for her car payment, I paid for her health insurance, I made a number of payments for utilities early in the period, the first number of months of the separation; I paid all costs associated with the mortgage, primary mortgage, secondary mortgage, all escrow, all payments for the home association dues and some other odds and ends there. I don't recall off the top of my head, but I have a list. Q. Okay. And you were able to pay those and be current? A. Nancy emptied out 100 percent -- You need to -- A, The answer is no. I had to take out a $30,000 cash advance from my credit card. Ryan Reporting (321) 636-445010 11 12 13 14 16 17 18 19 20 21 22 23 24 25 Q. Which credit card? A. The MBNA MasterCard. Q. Okay. Did you provide that documentation in this litigation? A. I don't recall. Q. Okay. Have you -- did you remove any marital assets from the home before it was sold? AL Well -- MR. MARKS: When you say "before it was sold," you mean before the closing? MS. GUEROA: Yes. MR. MARK: I mean, they had an agreement as to some things that were going to be t of the mediation. TI removed. That was p: don't know if you meant that. In other words -- go off the record for a second (Thereupon, discussion was held off the record.) MS. FIGUEROA: Okay. Let's go back on the record BY MS. FI UEROA: Q. Okay. It's my understanding then the personal property, whatever was left over after she moved out you took. A. Correct. Ryan Reporting (321) 636-445010 11 12 13 14 15 16 18 19 20 21 22 24 25 55 Q. Okay. And for the record -- A. Or threw away. MS. FIGUEROA: And for the record, if there's any items that my client's still requesting, I will produce that in a list and provide it to you prior to trial. MR. MARKS Okay. MS. FIGUEROA: Okay. Let's go off the record. (Thereupon, discussion was held off the record.) MS. FIGUEROA: All right. Let's go on the record. The attorneys are agreeing we're going to provide a list of marital property that's in our clients’ possessions and have them indicate the fair market value of each and every item. We will exchange these lists prior to trial. BY MS. FIGUEROA: Q. Okay. Now, in your counter-petition, you allege at s e filed criminal -- a criminal complaint for the sole purpose to improve her chances of obtaining sole parental responsibility. AL Yes. Q. Okay. And that was done through your previous lawyer. Ryan Reporting (321) 636-445012 13 14 15 16 17 18 19 20 56 Yes. Q. Okay. Can you explain what you meant by that? A. Well, first she stated at the time that morning, I. believe her exact words were "I can't live like" -- first she asked me to move out; I refused She said "I can't live like this." She called her lawyer, falsely told the lawyer as defined in testimony in court that I was holding her hostage with a knife. Based on that, the lawyer called the police, and the police took me away and arrested me She then obtained sole possession and control of the marital home, all its contents, all documents, all finances, all monies. At the same time, she de facto obtained custody of my son Immediately following that, that afternoon she went down to the courthouse, filed a civil injunction despite her being told and understanding that there was a no-contact order as part of the arrest, no contact. The same protection provided her by a civil injunction as you know, she -- despite that she went down to the courthouse and filed a petition for a civil injunction and in that check box in that civil injunction checked "no visitation." Q. Okay. Can you tell me in the last 24 months what doctor visits you have attended? Ryan Reporting (321) 636-445010 11 12 13 14 15 16 17 18 23 24 25 a1 57 Well, for the first -- Q. With Jamie. A. For the first nine months, a civil injunction was in place and I was prohibited. Q. My question is the last 24 months. Let's see. Well, I'm answering your question. Q. Then do the last 12 months. A, Let's see. The last 12 months, 7 with Jamie. I had met with his doctors without Jamie. With Janie, MMMM not the pediatrician, and that's it, Q. Now, you understand, do you not, that you've been welcome to attend the sessions with NE or MMM, correct? A. Well, initially I could not, because of the injunction. And then subsequently after that she -~ the divorce is obviously quite acrimonious and she did not inform me at any point at any ime ever when those eee cee eles 0. tsn't it true thet i.) have indicated to you you can call at any time and find out when the appointments are? A. ‘They have and I did. Q. Okay. And why haven't you attended any of those? Ryan Reporting (321) 636-445011 12 13 14 15 16 7 18 20 21 22 23 24 25 A. Because they're only once a month and her -- they inform me that the appointments were made sporadically and so, number one, it wasn't -- the appo tment was with Jamie and the psychologist and the therapist and Nancy would bring the child because she had him in her possession, so really, due to the nature of this proceeding, I did not want to be enclosed with Nancy. Q. Okay. Can you tell me what size clothes Jamie wears? A, He's growing. Let's see, I think a shoe he's a -- he's got a big foot. Let's see, I think he was an eight but now he's almost a two, I believe, in a boys You know, shirts are just -- put a small shirt on him. And his waistline, I'm not sure of his waist. Q. Do you know who Jamie's best friend is? A. He's got Abby, Rachel, and Nick. They live next door. Q. To? A. To Nancy. Q. Okay. Do you know what his current teacher's name is? A, Well, the previous teacher was Ms. Dora at Sea Park, and Nancy just registered Jamie and I haven't been to the school ye he hasn't started school yet. Ryan Reporting (321) 636-445010 11 12 13 14 16 17 18 19 20, 21 22 Q. Okay. Now, you have alleged parental alienation, correct? A, That's part of this. Q. Okay. And what is your understanding of parental alienation? A. A parent who, through actions, deeds, psych logically, emotionally, verbally creates an environment for the child that results in various: forms of a. nation of that child from the other parent. + And if that results in alienation, what is your understanding how the child's relationship is with that other parent? A. Poor. Q. Okay. A. If not at all. Q. Okay. And would you classify your relationship with Jamie as non-existent and/or poor? At times. Q. And what do you mean "at times"? A. He has on many occasions refused to talk to me on the phone. when he does talk to me, he essentially doesn't want to have conversation. I've many times on the phone heard him say "I don't want to talk to him.” Q. Okay. And Jamie's six years old now? A. Mmm-hmm, Ryan Reporting (321) 636-44501a 12 13 14 15 16 7 18 20 21 22 23 24 25 Cg 60 Okay. And is it your understanding that six year olds commonly like to t on the telephone? A. Hmm -- I see the way he talks -- he talks very differently to his mother on the phone during the same contact. Q. Okay. So is that your basis of why you feel your relationship's non-existent or poor? A. I think the basis of my relationship with Jamie varies. It depends on what the situation is at home with his mother. There are times when he -- when he's with me, it takes him a day or more to warm up to me and become more of a normal child in my presence. Q. How do you differentiate that behavior as being attributed to parental aliena ion versus just a transition from going to parent to parent like in any other divorce case? A. The things that Jamie has said to me and the way Jamie has behaved with me during these proceedings are not typical of a six year old. Q. What things has Jamie said to you? A, Let's see -- he has on many occasions sworn at me. He has said “Wait till -- you can't talk to me like that. Mom's the boss. Mom makes the rules. TI don't have to listen to you." He's said the same things - " 1 don't - he's called me a "cheap asshole Ryan Reporting (321) 636-445010 1 12 13 14 15 23 24 25 know where he got that from, He has -- Q. Well, with these statements so far you're assuming that these somehow came from the mother, or do you have any direct proof that they came from the mother? I don't have any direct proof Q. Okay. A. Parental alienation is a summation of multiple factors; it's simply something he says to me at any one point in time. Q. Okay. And you've also indicated that there was parental alienation in past relationships. what evidence do you have of that? What evidence do I have? Q. Mmm-hmm. A, Nancy refused to have her children have any contact whatsoever in any manner whatsoever for over eight years. The former husband would try to call Nancy would change the phone number. Nancy filed motions with the court to prohibit his discovering her residential address during a recent modification. Nancy -- he would send pictures; she would throw them away without telling the children. He would send cards and letters; she would throw them away without telling the children, Ryan Reporting (321) 636-445013 14 15 16 17 18 19 20 21 22 23 24 25 62 Q. In the beginning, did you -- MR. MARKS: I'm not sure if he was finished. BY MS. FIGUEROA: Q. Okay. Is there anything else? A, She routinely, almost whenever the father's name was brought up in the household, would become hysterical, crying, screaming, acting fearful, acting like her life was in danger, that she was in terrible fear of this man, that the children should also be in terrible fear of this man. She, through her own testimony described how she would take the children and sleep -- this was after h a knife to the divorce, would sleep in the bedroom w protect themselves from perceived threats from this man. The list goes on and on Q. Now, in the beginning did you have concerns about her exposing her children to that man? A. My only experience with this man was through what she told me and manipulated me into believing. I have since come to discover that she's following the same playbook with me. You didn't answer my question. I know those are your assumptions and your perception of this. My question to you is at that time didn't you even express Ryan Reporting (321) 636-445010 ae 12 13 14 15 16 17 19 20 21 22 23 24 25 63 concerns about her exposing her children to their former -- to their dad? A Based on her accusations, when she conveyed to me, yes. Q. Okay. Do you currently use corporal punishment to discipline Jamie? A. You've asked me that already; I've said no Q. Okay. Have you attended any parenting classes focused on the special issues of Jamie? A. Parenting classes? I'm not aware of any parenting classes like that. I've purchased numerous books and have read about Jamie's issues. Q. Okay. Have you attended or visited the Life Skills facility? A, No. Q. Okay. Would you agree that it is difficult or impossible for you to confer with Nancy regarding issues of Jamie? I have tried. Nancy usually -- I would agree it's difficult. I have tried. She usually -- i usually does not work. Q. Okay. And it doesn't work because of Nancy. A. I believe so. Q. What is your current work schedule? A. Depends on the day, but usually I'm in at @:00 Ryan Reporting (321) 636-445010 ant 12 13 14 15 16 17 18 20 21 22 23 25 ut 64 and, you know, home by 5:00 to 6:00. Q@. Okay. And weekends? . If I'm on call, I'm in there for a few hours. If I'm not on call, I'm off Q. Okay. And how often are you on call? Every third weekend. Q. And you said Sonya works full-time? A. She's per diem. So I take -- Q. What does she do? - I correct that. She's not full-time in the traditional sense, she's per diem, so if we have obligations, she works; if she doesn't... Q. Okay. And who does she work for? A. HealthFirst. Q. What does she do? A, She's a vascular ultrasound technologist. Q. And you're saying her hours are flexible? A. Her hours are flexible depending on the child care needs. Q. How old is her son? A. ‘Thirteen. Q. Where does he go to school? A. Just started at Central Middle School. Q. Did you accuse Nancy of allowing her children to be abused physically and sexually by her former Ryan Reporting (321) 636-44507) 18 1g 20 Ob 65 husband? A. Did I -- say again - Did you accuse Nancy -- did you suggest that Nancy allowed her children to be abused physically and sexually by her former husband? A. I don't know if I accused. She made allegations that her husband did these things and asked her why she didn't intervene to do something about it if she really believed that was the case Q. Now, would you agree that Nancy sincerely believed that the children were abused physically and sexually by her former husband? MR. MARKS: Object to the form; speculation. Go ahead. THE WITNESS: I believe Nancy has mental health issues. I believe she believes it and that it's a delusion and that she convinces perhaps on some level that they're true. I think it's delusional I also believe that she has made those allegations for her own malicious intent. BY MS. FIGUEROA: Q. Have you spoken to the children? A. I never brought that up with the children Ryan Reporting (321) 636-4450We 1] that would be inappropriate. @ | . 3] whether or not those abuse allegations are true or not. Okay. So to this day you are not certain of 4 A. My basis -- my experience now after the fact 5| is I believe that they're not true. 6 Q. I understand that you believe that. But you 7| have no absolute proof whether they're true or not at @| this point; you haven't spoken to the children, you 9| just disbelieve Nancy. 10 A. I have in that I -- no, I have no 11] legal proof. 12 Q. Okay. And would you agree, would you not, e 13] that her taking care of Jamie primarily helped you 14] continue in your career during the marriage? 1s AL Certainly. 16 Q. Okay. Have you maintained any visitation 17| journals for this case? 18 A. No. ig Q. Okay. What monies do you contend Nancy 20| wrongfully removed from any of the joint bank accounts? 21 A. It was discussed in the prior deposition, but 22] I don't know the exact number, but she essentially 23) emptied 100 percent of all funds from the savings and 24| the checking account days preceding her having me e 25| removed from the home in excess of $38,000. _____________—-hyan Reporting (321) 636-445067 1 Okay. And you have proof of this? 2 A. Yes. 3 Q. Okay. And what proof is there? 4 A. Bank statements, deposit slips -- or 5| withdrawal slips. 6 MR. MARKS: Can we go off the record? 7 (Thereupon, discussion was held off the 8| record.) 9] BY MS. FIGUEROA: 10 Q. Have you acquired any new assets besides the home since the separation? Boats? Motorcycles? 12] Stocks? Investments? Buildings? 13 No. 14 Q. Okay. When did Nancy start complaining about is] her back problems? 16 A. As long as I've known her. 17 Q. Okay. Have you reviewed Dr. Robinson's 18] medical ev. tion? 19 A. I have not seen it. 20 Q. Are you aware that he has provided her a 12 21| percent permanent impairment rating? 22 A, I probably have a 12 percent permanent 23| impairment rating. That's relatively low. 24 Q. Okay. Do you have any reason you would agree 25| or disagree with that? Ryan Reporting (321) 636-445068 14 15 16 1 18 1g 20 23 24 25 A. I haven't seen the report. Okay. Has Nancy ever attended college full-time during the marriage? ne Nor Q. Okay. Why not? A. Same reason she didn't work. I'm not sure You're not sure? What is her highest level of education? A couple course work in community college; so A high school. Q. Okay. Are you against Jamie being put in Life Skills? Yes. Q. Why? A. It's unnecessary; he does not need it. Jamie is fully capable of being in a regular kindergarten with supportive tutoring through Brevard Learning Clinic. Let me ask you this: What investigation into a A. I reviewed the website and the information she provided me. Q. Okay. ee it mainly specializes in Ryan Reporting (321) 636-4450a 10 a1 12 14 15 16 af 18 22 23 24 25 Wi 69 dysfunction. There are similar centers locally. Q. Do you know that Life Skills also provides services here in Brevard? A. I was not aware of that. Q. Okay. Assuming tha correct, do you have any objection to him being part of that program? A. I would not -- well, let me clarify. I don't have that information that you provided. Are you saying there's a program here in Brevard? I'm not aware of that program. The information that Nancy gave to me, the program is in Orlando. @. So is your objection the location of the program or the location itself? A. Both. I really don't feel, number one, he eve that Jamie has needs it, because I really don't b HE) scunceion. 1 disagree with that diagnosis. Q. Didn't you describe earlier on in your deposition -- A. I did not. Q. -- that you had issues integrating -- you mentioned sensory integration prior My understanding 07 (ryan Reporting (321) 636-445018 1g 20 21 22 23 ay dysfunction is the child has issue with hypersensitivity to his environment, sounds, noises, the feeling of the cloth on the skin causes extreme frustration and behavioral issues. Jamie does not have that. Q. Do you know how much the program costs? A. I have no idea what it costs. Q. Did the cost have a factor in you objecting to the program? A. I have no idea what it cost, so how could it? Okay. Did you speak with the jz, es A. I did not. Q. Okay. why not? A. Because I don't agree with her pursuit of this diagnosis. Nancy has pursued this agenda without the input or recommendation of any of the professionals taking care of him. She chose to do this within the last two or so months on her own and it is -- she's the only one interested in doing this. Q. I see. Okay. A. No professional taking care o integration dysfunction, nor have they ever suggested Jamie, evaluati oned sensory Ryan Reporting (321) 636-445016 17 18 19 20 m1 Life Skills. Q. Okay. that assuming that they're even familiar with that concept? So are you suggesting -- I would not presume that Nancy has more knowledge of this diagnosis and this behavioral issue than child psychologists and psychiatrists taking care of my son. Q. Are you aware how your son was diagnosed with ADHD by Dr. Mosher? A. I believe_M does not believe he has Q. Really. Yes Q. Assuming he does -- He has been treated with medication -- Q. For? AL Initially presumed to be found to be I -- Q. My question is -- let's go back. When WMS © ciagnosed your son vithiM do you know how long it took him to make that diagnosis and what testing or what observations were made to come to that diagnosis? . Am I aware? Q. Mmm-hmm A. Yes. Ryan Reporting (321) 636-445015 16 7 19 20 21 22 23 24 25 Okay. How long did it take him to make that diagnosis? A. Well, he probably had a one-hour appointment with Jamie. Mmm-hmm. A. His assessment is also based upon evaluation and testing by a previous psychologist, as well as the interview and perceptions and distorted perceptions of his mother Q. And are you aware that he had no medical records at the time that he made that diagnosis? No medical records He didn't review any medical records at the time of the diagnosis. I would have no knowledge of that. Again, I could not attend the evaluation due to the civil injunction; I was not able to attend. I have spoken extensively to MJ about my son and his diagnosis and his assessment of Jamie is that he is a healthy, happy child who probably does not have i. probably does have a learning disability, and he has put him on a relatively benign medication, not a stimulant not a high medication for MMM, and he's treated my son with medication probably more to help him with his issues in terms of dealing with the stress {____ryan Reporting (321) 636-445012 13 14 16 17 18 19 22 23 24 of the situation. Q. Okay. We'll go back to that in a minute. With regard to the closing from the house, did you keep $15,000 from the proceeds? Did I keep? No. Q. Okay. MR. MARKS: The money's in escrow. THE WITNESS: It's in escrow. BY MS. FIGUEROA: Q. Whose escrow? A. The title company, Alliance Title. Q. And what's your understanding what's to be done with that? A, It's my contention those funds belong to me they're post-separation funds Q. Post-separation funds? A. Correct. Q. Okay. And so that's an item in dispute for trial? A. Correct. Those funds were escrow funds, money in the escrow account of the mortgage company who had the mortgage. I paid all mortgage payments to the company after the separation while Nancy lived in the house. ‘Those -- that money represents post-separation dollars. Ryan Reporting (321) 636-4450a 12 13 14 16 17 18 19 20 21 22 23 24 25 74 Q. Okay. Did you participate, conspire, or cause Nancy's tires to be damaged or any lug nuts to be removed? A. Absolutely not. Q. Who is Donna Chase-Solomon? A. I don't know, I saw it on the witness list Q. Did you have any -- do you recall -- you're saying you don't even know her? A. I don't recall the name. Can you refresh my memory? Q. Do you recall any inappropriate incidents with her? A. Who is Donna Chase-Solomon? I don't know who she is. Q. Okay. A, If you refresh my memory, perhaps I can answer your question. Q. Okay. We'll come back to that Where does Nancy obtain her prescriptions? A. HealthFirst requires prescriptions I believe through cvs. Q. Okay. A. It was previously Walgreens. Q. Did you obtain a list of her prescriptions? AL No. Ryan Reporting (321) 636-445010 a 12 13 14 15 20 21 22 23 24 25 75 Q. You didn't go on-line and obtain a list of her prescriptions? No. Q. Did you obtain any of her medical records? A, Medical records? Q. Mmm-hmm, A. No. MR. MARKS: Well, I've obtained some of the medical records; I don't know if you mean that. MS. FIGUEROA: O££ the record (Thereupon, discussion was held off the record.) BY MS. FIGUEROA: Q. Okay. Do you have access to her health history on-line? - No. Q. Did you attempt to cancel or did you cancel Nancy's health insurance? A. No. Q. Did you give Jamie -- or actually did you give Jamie a BB gun to blow up his baby bottle? A. To blow up his baby bottle. I bought Jamie a BB gun as motivation to give up his baby bottle. Q. Okay Ryan Reporting (321) 636-4450ae 76 e 1 - I felt it was inappropriate for a six year old 2] boy to still be using a baby bottle. TI previously had 3] numerous discussions both through written contact and 4] verbally with Nancy asking her to stop using a baby 5] bottle with Jamie. She refused. Jamie would come to 6] my home wi my contact and ask for a baby bottle. And 7) i€ he did not get i he became very upset. It was a 8] source of support for him and other issues, I assume. 9 I negotiated with Jamie and we discussed with 10] Jamie that " fey, if you give up the baby bottle, we can 11) buy a BB gun and I'll teach you how to shoot." That's 12] a bonding thing between a father and son; my father did e a3 |e 14] together. with me, it's something I did with him. We did it t was a -- he had a great time. He did it 15] very well. It was done in a controlled environment and 16] we shot targets and bo es and 17 Q. Okay. Now, you understand J anc 18] BB ave dealing wi 19] impulsivity and aggression. Are you aware of that? sorts of things. th your son's issues of 20 Yes, that's one -- that's, in the past, been 21] some of his issues. 22 Q. Actually for the last year. Are you aware of 23) that? 24 A. Again ~~ e 25 MR. MARKS: Object to the form; predicate. {_____nyan Reporting (321) 636-4450v1 77 1] BY MS. FIGUEROA: 2 Q. Are you aware that that's been their concern 3] for the past year? Yes or no. 4 No. 5 MR. MARKS: Same objection. 6] BY MS. FIGUEROA: 7 Q. Okay. Being that in the past there has been 8| issues of aggression and impulsivity, do you believe 8} your giving him a BB gun was an appropriate parental 10] decision? a - I think you're mis -- you have misperception of what "giving him a BB gun" is. The BB gun is done 13] only in my supervision, only in my presence -~ 14 Q. Assuming that that's all true and you took the 15] most careful precautions -- 16 He does not have access to the BB gun. 17 Q. =~ do you believe it was appropriate to have 18] him blow up his baby bottles? 19 A, Blow up his baby bottles? 20 Q. Or shoot them. 21 A. He shot. 22 Q. Do you believe that's an appropriate parental 23| decision? 24 A. Yes. 25 Q. Did MBM) have a discussion with you Ryan Reporting (321) 636-445010 cs 12 13 14 15 16 17) 18 19 20 22 23 24 25 Ab 718 because he felt it was inappropriate. A, No, he did not. Q. So if QM testified to that, he would be lying. MR. MARKS: Object to the form. First of all, I don't believe he testified he had a conversation with him about it. THE WITNESS: No ~~ MR. MARKS: You asked him whether he thought it was appropriate. THE WITNESS: [9M and 1 discussed the baby bottle. We did not have extensive discussion about the BB gun, nor did we ever -- he may have an opinion on that, but he never conveyed that opinion to me. BY MS. FIGUEROA: Q. Did you have Jamie on an ATV? A. He took a ride with me. Q. Okay. when? A. Five, six months ago. We went up and down the driveway. He was wearing a helmet. Q. And this ATV, was this purchased after the marriage, after the separation? t's Sonya's son's ATV. Q. It's Sonya's son? Okay. Ryan Reporting (321) 636-445010 qa 12 13 14 15 16 17 18 19 20 21 22 23 24 25 q A. And it was a -- in his possession when I met them. Q. Is there any reason why you haven't e-mail even though you couldn't have been there, let's say for work reasons you couldn't be present to participate and keep current on Jal 's therapy? I met with them numerous times. Q. Okay. When you say numerous times, are you talking about alone? AL Yes. Q. Okay. Isn't it true that the only time you met with Dr. Mosher is to discuss your agenda and telling him that everything Nancy had told him was distorted and wrong, and you brought in a notebook? A. I brought in a notebook with information in it to -- again, Nancy had conveyed to BBM ana to other professionals taking care of my son, who I also have to interact with as a parent and have relations with those professionals. Nancy has conveyed to them that I was viewing underaged pornography, that I was -- she made allegations about my abilities as a physician she made allegations about my ability to take care of my son, and essentially painted a picture of me as a horrible human being, that I had to clarify those {___ yan Reporting (321) 636-445010 nl 12 13 14 18 16 17 18 19 20 21 22 23 24 80 perceptions. Q. Other than your agenda of clarifying those perceptions -- A. I met -- Q. -- why haven't you been in contact with these professionals even by e-mail? A, Thave. I met with at least two or three t mes after that to discuss my son and only my son, and I met with t least twice. Okay. Now, did you tell Nancy that rescinded his diagnosis and took him off his medicine? A, I never said that. Q. Are you certain? A, I'm absolutely certain. I did have objection to Nancy i. itiating the medication without consulting or speaking to me. We had numerous conversations prior to the initiation of that medication. Part of that court order was I was allowed to record conversations with Nancy during when we had them to avoid these kind of issues. Q. 9 Mmm-hmm, A. I specifically left messages with her asking her to discuss the medication with me before starting it. So I had -- so she both had my consent and I had Ryan Reporting (321) 636-445012 13 14 15 16 17 18 19 20 22 23 24 * some understanding of what was being done. She didn't do that. So I disagreed with initiating my son on a particular medication that he was starting on before talking to MMM) «anc once he started it, at no point did I ever p it or not give it to him; that would be dangerous to my son. Q. Tell me what Jamie's medications are and when he's supposed to take them. A, He's currently on [MY and he was taking a half a tablet a day. Through a phone conversation the insistence upon Nancy to Nancy indicated to MMMM that Jamie's behavior was becoming worse -- Q. You just need to answer my question. A. Okay. Q. I need to know what his current medication is and his schedule. A. She is currently giving him one-half of a tablet in the morning and a quarter tablet in the evening. Q. Okay. And are you doing this when he is in your care? A. Absolutely. Q. Okay. Do you ever give him more if you're not {_____ryan Reporting (321) 636-445010 qn 12 13 14 15 16 17 19 20 21 22 23 24 25 oY 82 going to be around in the evening? Do you give him one pill as opposed to a half a pill? A, No. Q. Are you certain? A. Am I certain? I give him one whole pill? Q. Mmm-hmm. A, No. Imean, no, I don't give him a whole pill. Have you ever given him a whole pill because you weren't going to be there later to give him the other quarter in the evening? A. No. I sometimes -- I don't agree with a quarter tablet pill. There are times I haven't given him the quarter tablet, because I don't witness the behavior that Nancy's claims that she has a problem in the evening. The purpose of the quarter tablet was, according to Nancy, his behavior became worse in the evening. That has never occurred in my care. Okay. So then you decided on your own not to give him the quarter tablet A, At times. Q. Okay. Do you know what the effects are when you on the weekends take away that quarter tablet and then he's put back on it days later? Ryan Reporting (321) 636-445012 13) 14 15 19 20 21 22 23 24 25 4b 83 A. The h her dose can make him a little sleepy and a little drowsy, but there's no adverse effects. In fact, the medication is a rather benign medication and that's why BBM bes indicated to me he's kept Jamie on it. WM, ncicated to me he doesn't necessarily believe Jamie needs the medication. He also conveyed to me that he had intended to actually discontinue the medication this summer. There was through the insistence of Nancy and through the insistence that the medication continue because of her claims of behavioral issues while at home; it was through the insistence of Nancy that Jamie had behavioral issues in the evening that the medication was increased to one quarter. I don't witness that behavior. Q. Are you aware that MN showed her documents he submits for insurance to reinforce the fact that he has never changed his diagnosis and that you were playing head games with her? Are you aware that he made that statement? MR. MARKS: I'm sorry? Can you repeat the question? BY MS. FIGUEROA: Q. Are you aware that BBM) showed Nancy Ryan Reporting (321) 636-445010 11 13 14 18 16 a7 18 19 20 21 22 23 24 25 a4 documents he submits to insurance -- A. Okay. Q. -- to reinforce the fact that he's continuing this prescription -- A. Okay. Q. =~ of MMMM and told Nancy that you were playing head games with her? A. Am I aware that he made that statement? No. Q. Would that surprise you? A. It would be sort of unprofessional. Yeah, it would surprise me. Q. What other medication besides the IEP A. Um Q. What medication does he take for his digestion system? A. (Witness laugh Nancy, again, through her own agenda and her own initiation of diagnoses, has seen a ‘yy understanding is he saw this gentleman July 31st. And in deposition last week, we asked her what medications my son was taking and she could not answer the question. Q. Okay. A. So how would I know what medications he's taking? ‘Ryan Reporting (321) 636-4450MS. ST. GEORGE: I haven't given him this MS. FIGUEROA: Okay. THE WITNESS: Now, I did contact a -- BY MS. FIGUEROA: Q. That's my next question. A, -- and he informed me of some medications my son is taking. Q. Mmm-hmm. A. I'm not -- I have not seen 7 tions, but evidently he is taking « Ce ee because of aM difficulty, and he's also taking o MMMNNNN)s«i's board certified in family practice and sports med qual d like to know why an individual with those qualifications is treating my son with MM, 2 very serious medication. This man is neither a pediatrician nor is he a pediatric endocrinologist Q. Okay. Have you expressed your concerns A. I did a little bit, but in a phone conversation I was not going to insult him what he was Ryan Reporting (321) 636-4450ho 86 e@ 1] doing. 2 Don't you believe as a parent you had every 3] reason to question medications that you believe to be 4] serious? 5 A. I did. I did question 6 Q. And -- 7 A. And he gave me his reasons why he believed my 8] son should be on I asked him some medical 9} questions regarding the indications for that. 10 I am not an endocrinologist, I do not 1] understand the medicine behind this. He gave me answers, that's fine, he gave me answers, but he is not r ) 13] a pediatric endocrinologist, he is a family 14] practitioner, which is -- on the medical food chain is 15] not considered necessarily a high-level practitioner. 16 Q. Okay. So do you have any objections to the 17| medications he put -~ I'm not understanding where the 18] answer is sufficient or you still have -- you just 19] don't have an understanding of it. 20 I think the person who put my son on 21| medication is not qualified to do so based on my 22| understanding of who he is. I have not seen any CV or 23| documentation that he is qualified to do this. 24 Q. Okay. e 25 A. And Nancy neither discussed this with me nor Ryan Reporting (321) 636-445010 a 12 13 14 16 17 18 19 20 22 23 24 25 9 87 informed me that my son was taking these medications. MR. MARKS: Is this for me? MS. FIGUEROA: I'll make you a copy. MR. MARKS: Okay. Thank you. MS. FIGUEROA: I'll give you the pretty one. MR. MARKS: All right. BY MS. FIGUEROA: Q. During your visitations with Jamie, how much time do you spend with Jamie? The entire time he's with me. Okay. And the other time he's left with Sonya when you're not there? A. If I'm on call, she takes care of him while I'm at the hospital. Q. How often has she done that? A. I don't know the on-call schedule. I don't recall the exact frequency Q. On average. rd week. A. Every th Qo. We I understand that, but when you're on call, how long would you be away? A. If I'm on call, I'm away anywheres from three to six hours, depending on the day. Q. Three to six hours? Ryan Reporting (321) 636-445010 11 12 14 15 16 17 18 1g 20 21 22 23 24 25 {___ yan Reporting (321) 636-4450 88 A. Mmm-hmm. a. Did you come from work today to the depos? AL Yes. Q. Okay. Do you often wear scrubs driving to avoid getting tickets? A. No. I wear scrubs because I wear scrubs to go to work. Q. Okay. MR. MARKS: Does that work? I'll try it. (Laughter.) MS. FIGUEROA: You're going to go get some today? BY MS. FIGUEROA: Q. On your financial affidavit, I know this is old, so this is the only one I have to go by. Well, I won't go by it, I'll just ask you some questions in general then. Your household expenses now A. Didn't we go through this with Feinberg? MR. MARKS: Well, there's new information now. THE WITNESS: All right. BY MS. FIGUEROA: @. Your household expenses, how long has Sonya16 17 18 19 20 21 22 23 24 25 4 been living with you? Since we bought the new home Q. Okay. A. December of '05. Q. Okay. Since December '05. So whatever amounts are current now for your mortgage and whatever, other fees, they are -- that's including -- at includes the mortgage for her, too, because you're providing the home for her as well, correct? A Correct. Okay. Do you happen to know what your mortgage payment is? A. Ballpark, it's approaching $7,000, 6,700 and change. Q. So not too far off from what you were paying before? No, it's more. Q. Well, this one shows 7,598. A. Maybe they're combined -- Q. Okay. A, -+ you know, primary and secondary mortgages. I would have to review Q. Okay. Would it be fair to say all these expenses, whatever your new financial affidavit would state would include expenses for Sonya? Ryan Reporting (321) 636-445010 ql 12 13 14 15 16 7 18 19 20 21 22 23 24 25 0 90 A. There's some joint expenses there. I mean, we share the same household. Q. So the household expenses would also benefit her and her son, correct Correct. She contributes financially. Not as well as I can, but she contributes financially. Q. How much per month does she contribute? A. She makes probably -- well, depending on how many hours she works and depending on the per diem hours she gets and depending on how much time she needs to help her child care and such, if she were working full-time she would be making 50 to $60,000 a year Q. But she's not, so -~ She's no I don't know what her current income is. Q. What does she contribute to the household? I would say it's anywheres from two to $4,000 a month. Q. Okay. And is she the one primarily responsible for the home, again, the cleaning, the laundry, making the dinners and lunches, breakfast? She's able to contribute more, but we both do it. Okay. Have you -- does she have her own vehicle? Ryan Reporting (321) 636-445010 Gy 12 13 15 16 17 18 19 20 21 22 23 24 25 91 A. She does. Q. Okay. Are there any other joint assets besides the house with you and Sonya? ou Not Q. And have you directly paid for any expenses for her son? A. No. a. od, dinner, lunch, you always pay separate monies? A. Oh, you know, if we go out to eat, I pick up the check, you know, occasionally, but, you know that's little stuff Q. Okay. A, But I'm not paying his support care. Q. Who takes care of her child after school? A, Well, he was -- he's in after-school programs or he's in middle school, he's got band and things like that. Q. So he's not picked up until later? A. Correct. Q. Okay A. Middle school starts at 9:00; he doesn't get out And what is his r tionship w. Ryan Reporting (321) 636-4450