910513

1-1-24
Susan

TRANSCRIPT:  MR. HORN, MR. EKKER, MRS. EKKER, EKKER’S ATTORNEY

ATTEMPT TO RECORD A DEPOSITION

00:05
[other speaker] Good afternoon, Ms. Ekker. If you could please state your name for the record. 
[other speaker] Well, let's first have the witness sworn in by the court reporter. 
[other speaker] Oh, has she not been sworn in?  
[other speaker] Please raise your right hand. Do you solemnly swear the testimony you are about to give in this matter will be the truth, nothing but the truth so help you God?
[other speaker] I do.  
[other speaker] Okay, and would you give your name to the court reporter right now? 
[other speaker] Just before we begin, I say.
[other speaker] Wait, wait, wait a minute. 
[other speaker] I'm conducting this deposition. Would you please give your name to the court reporter? 
[other speaker] Before you even begin, I'm going to be posing an objection. I see here two tape recorders. I'd like to know what they're about.
[other speaker] Please give your name to the court, according to this answer. 
[other speaker] I'm going to instruct you not to answer right now. 
[other speaker] Ms. Ekker, are you represented by legal counsel today? [other speaker] Yes. 
[other speaker] And who is that legal counsel? 
[other speaker] Mr. Horn. 
[other speaker] And when did you retain him? I am entitled to inquire. [other speaker] No, we're not going to proceed. 
[other speaker] I'm entitled to inquire. 
[other speaker] Stop. Is this going to be reported or is it not going to be reported? And wait a second. 
[other speaker] When were you retained by Mr. Horn? 
[other speaker] Okay, before you answer any more questions, we're going to resolve the issue now of the tape recordings like we had last time on April 18, 1991 with Mr. Burr. We're going to figure out, I see the court reporter has one, I see Mr. Ekker has one.
[other speaker] So what's your question? 
[other speaker] Who's going to be reporting it and under what section of reason? 
[other speaker] We are entitled to record it by several, for a truth, several sections. Ms. Ekker, before we go on, are you... 
[other speaker] We're not going on. 
[other speaker] Wait a minute. 
[other speaker] We're not going on. 
[other speaker] Wait a minute. We can determine who and what and when she retained you. 
[other speaker] I've been retained by her, I'm her lawyer and I'm representing her. 
[other speaker] When?

[other speaker] I can't make a record of that. 
[other speaker] I know. 
[other speaker] It's irrelevant when, we're going to get the issue of the tape recording resolved right now. If we don't resolve the recording then we're going to leave. 
[other speaker] Well then you'll be faced with yet another motion. 
[other speaker] That's an issue that we'll address at the time the motions are brought. 
[other speaker] Ms. Ekker, when did you retain Mr. Horn? 
[other speaker] Okay, let's go. Are these gonna be recorded or are they not gonna be recorded? Because we're not- 
[other speaker] What do you think? Did you read the deposition notice? [other speaker] We're not gonna go around and around and through this again. There are two trick recordings here. I don't know what Mr. Ekker is doing with his recording. I don't know what the reporter is doing with hers. The reporter is taking it down by stenographic machine. That's fine. If the reporter can't take it all down by stenographic machine, has to record it, then she can put that on the record too. But we're not going to allow Mr. Ecker to record it if he is in fact recording it, and we're going to maintain the same position that we maintained last time. So if Mr. Ecker intends on recording it, let me know now. 
[other speaker] Did you read the deposition notice?  
[other speaker] Does Mr. Ecker intend on recording it?  
[other speaker] Mr. Horne, would you answer my question? Did you read the deposition notice?  
[other speaker] Does Mr. Ecker intend to record this deposition? 
[other speaker] Whose deposition is this? 
[other speaker] Does Mr. Ecker intend to record this deposition?
[other speaker] Did you read the deposition notice, Mr. Horn? 
[other speaker] Does Mr. Ecker intend to record this, yes or no? 
[other speaker] Mr. Horn, if you quit your juvenile antics, maybe we could get on with this deposition. What do you think? 
[other speaker] We're not going to proceed before I get an answer. I'd like to know the reason. 
[other speaker] Did you read the deposition notice? 
[other speaker] I'll answer your question with a question. It's very clearly stated in the deposition notice that this will be recorded. And I'm not even required to do that. 
[other speaker] Well, you are required.
[other speaker] Because it's for his personal use.
[other speaker] Is Mr. Ekker going to record this for his personal use? Yes or no? 
[other speaker] What do you think? Do you see something here? Do you see something here? What do you think? 
[other speaker] When you respond to that question we'll know if we're going to proceed or not. 
[other speaker] Oh I see and so what if I respond in the positive? 
[other speaker] Then we're going to do what we did in Mr. Berg's deposition and we're going to get up and walk out. 
[other speaker] Oh boy, you really are one for that aren't you? Well I can guarantee you Mr. Horn that you are going to be brought into court by a motion to compel and a motion for sanctions not only for the Berg deposition that you missed today the one you missed on April 18th and if you cause this witness to leave you're going to be brought up on a motion for that I guarantee you it assures the sun rises in the east and sets in the west so. 
[other speaker] I'm not going to get involved in that at your account my question is is Mr. Ekker going to record this or isn't he? 
[other speaker] I see you make your own editorial comments you won't get involved in the others. 
[other speaker] Is Mr. Ekker going to record this or isn't he?
[other speaker] Do you see the recorder out to you? 
[other speaker] I see it when I hear it, I don't know if it's activated or not. If it doesn't record it, then I want to remove the tape, and if the court reporter is going to record it, then I want to ascertain the reason the court reporter is going to record it, and if she's recording it for herself or somebody else. 
[other speaker] And so, what is your legal basis for objecting? 
[other speaker] You have the code section open before you, you can look at 2025.
[other speaker] I've looked at 2025. 
[other speaker] Great.
[other speaker] What part of 2025 are you referring to? 
[other speaker] Take a look at L and subdivisions that follow thereafter.  [other speaker] So what about it? 
[other speaker] My question is, is Mr. Ekker going to record this for his personal use? 
[other speaker] No. The question I have for you is upon what basis are you basing your objection? What is your basis for your objection? 
[other speaker] If this is going to go forward, I want to know, is Mr. Ekker going to record this? Yes or no? 
[other speaker] And my answer to you is use your two eyes and look on the table and see what you see. 
[other speaker] Yes or no? That's all I'm asking. 
[other speaker] Ms. Ekker, have you retained Mr. Horn? 
[other speaker] She is not going to answer any of your questions until we can ascertain the purpose of the recordings. 
[other speaker] Mr. Horn, you know, last time we gave you the opportunity to stipulate and you did not take it. And you did so unjustifiably. Then you walked out of the deposition. 
[other speaker] That's your opinion. 
[other speaker] Yes, and I'm going to state my opinion and I'm going to state what we're going to do. Right now you have the opportunity to go forward with the deposition. We're all here. We've come at cost and at expense to our client to be here. And we are going to move for sanctions and I guarantee you that we will do that. And hopefully the court will see our way and grant those sanctions. 
[other speaker] You can stop your self-serving comments. My question is, is Mr. Ekker going to record this deposition? Yes or no? 
[other speaker] Did you read the deposition notice? Yes or no? 
[other speaker] Is Mr. Ekker going to record this? 
[other speaker] What do you think? The deposition notice states that it will be audio recorded. 
[other speaker] We have two recordings here now. We have Mr. Ekker and we have the report. 
[other speaker] So, what's the problem with that? What's your problem with that?
[other speaker] We're going to be leaving unless we get an answer. 
[other speaker] You have gotten an answer. It's in the deposition notice. So you knew about it before you even came down here. 
[other speaker] Is Mr. Ecker going to be recording this? I have no problem if the court reporter is going to record it for her purposes and use the court reporting for her purposes only and the tape will follow the code with what happened. That's fine. If Mr. Ekker intends to record this, we're not going to sit here. Well, we haven't gotten to the part yet where the operator will state his identity and the business address and the like on the recording. And if that's what you're waiting for, are you waiting for that? Is that what you're waiting for?
[other speaker] Is Mr. Ecker going to record this, yes or no? 
[other speaker] You have the answer in the deposition notice. 
[other speaker] I have the answer that the court reporter is going to record it. I don't know if Mr. Ekker is going to record this.
[other speaker] That's your assumption.
[other speaker] It might be and if it's wrong I want to be corrected right now before we leave you show is Mr. Ekker going to record this? [other speaker] I've answered your question.
[other speaker] No you haven't.
[other speaker] Yes I have. It's the same as before nothing has changed. If you want to take that to be an affirmative, then you take that to be an affirmative. But this is going to be audio tape. This is going to go to the script. 
[other speaker] That's fine. There's an audio tape before the court reporter. I want to know if the court reporter is going to record it after I find out if Mr. Ekker is going to record it. If you're not going to disclose that information, then we'll get up and leave. 
[other speaker] It's been disclosed to you. 
[other speaker] No, it hasn't. Stop avoiding the issue. Is Mr. Eckert going to record it or not? 
[other speaker] What do you think? 
[other speaker] Well, we also have a woman here who's present in the room whose identity it has been disclosed who wasn't indicated in the notice to be here. 
[other speaker] Have you even bothered to ask before the deposition? I haven't gotten past the tape recording issue. 
[other speaker] Well, then we don't need to go any further if you're going to stop at that, is that it? 
[other speaker] My question is will Mr. Ekker going to record this? [other speaker] And my response to that is you've read the deposition notice presumably. In it, we indicate that it will be audio taped. And we are prepared to go forward and state the identity of the operators on the tape. And if you have a problem with that, then good luck to you because you'll need it in court. 
[other speaker] Thank you for your editorial comment. I see there's one reporter, a court reporter, and I want to know, is Mr. Ecker going to record this for his personal use? Yes or no?
[other speaker] I have not given you the answer. 
[other speaker] I don't know what your answer is and until I find out the answer this deposition is not going forward. 
[other speaker] We're ready to proceed with the deposition. Well. Are you? 
[other speaker] I am if Mr. Ecker is not going to record and I find that the operator who is going to record is the court reporter to follow the code.
[other speaker] Mr. Ekker is a qualified person, confident to operate an audio tape device. And he is prepared right now to state on his audio tape that he is to do so and will do so. But it doesn't matter because in any event, Section 2025L does not apply. 
[other speaker] Excuse me, don't cut me off. 
[other speaker] Does not apply to people who are just recording for their own personal use. That's our position. 
[other speaker] And is the court reporter also going to record this for her own purposes, as well as take it down on shorthand? 
[other speaker] I don't know. This is the first I've seen of that machine. I can't answer that question.

[other speaker] Ms. court reporter, are you going to record this as well?
[other speaker] Can I go up to the record because I can't write on the record? 
[other speaker] No, you can write on the record, we want it on the record. 
[other speaker] It's kind of tough to record before we talk and write. [other speaker] Are you going to record this? 
[other speaker] Yes. 
[other speaker] For what purpose? 
[other speaker] If another tape is going, I prefer to have one installed for my own purpose. 
[other speaker] Oh, okay. So you don't need to... 
[other speaker] I have to...
[other speaker] You didn't ask Mr. Ekker if Grayden hit a recorder here today, did you? 
[other speaker] No, not at all. 
[other speaker] Thank you. So Mr. Ekker is going to record it? 
[other speaker] And you've read the notice.
[other speaker] My question is, Mr. Ekker is going to record it, is that correct? 
[other speaker] You can head for the door if that's what you're wanting to do. Well, I would suggest that you stay. Let's finish the deposition and go forward with it. 
[other speaker] I'm not going to allow this tape to go into hands that I don't know what's going to happen with it, how it's going to happen with it. And as far as I'm concerned, the court reporter is quite competent to take it down both audibly and cinegraphically. So if Mr. Ekker is going to take this deposition on his personal recorder for his own personal use, we are not staying. 
[other speaker] Well, I disagree with your position. I'm giving you the opportunity to stay because this tape recording is only for Mr. Ekker’s own personal use, the device that he has. It is not for use in court. I'm willing once again to stipulate with you here and now, unconditionally, no holds barred, that that tape will be used for his personal use only. [other speaker] And I question what you're going to do with that tape too. 
[other speaker] I agree with you that the court reporter is competent to take down the testimony, but that's not the issue here. The issue is whether or not a party to the lawsuit has the right to audio tape record for his own personal use, a deposition that's being conducted to which this party is part of. And we submit that he is, and that you are doing nothing more than stalling on all discovery in this case. It's been the situation from day one and we are just going to have to go into court for two reasons. One, to bring the motion let me don't interrupt me to bring the motion and also for a motion for stay of the trial date if necessary. We're more than happy to proceed with the trial when it comes time but if you're going to constantly delay discovery from your client, then we have no choice but to go in and try to stay a trial date until we get such discovery. And that's what we'll do. 
[other speaker] You can go into court and we'll battle it out in court. I don't have a problem with that at all. As far as discovery, Mr. Burg is here, ready, willing, and able to testify. And today we have this witness here, ready, willing, and able to testify. Your client has made the decision to do something with a tape recording and who knows what he's going to do with it. I'm not going to sit here and allow a tape recording to get out into the general public and be used for whatever purpose he decides to use it for. The deposition transcript is the official transcript. If Mr. Ekker wants to plaster that everywhere and anywhere, that's fine. But I'm not going to allow a tape recording and as such, if it's going to be used, as you are steadfastly contending it will be, we are going to leave. So we're giving you one last chance. If Mr. Ekker doesn't record it and we stay, or if Mr. Ekker records it, we leave. 
[other speaker] And, as I told you, we are willing to stipulate right here and now that it will be for Mr. Ekker's and Mrs. Ekker's own private and personal use.
[other speaker] I'm not going to allow that. 
[other speaker] And your basis is entirely on section 2025 L. 
[other speaker] No, it's under the code. You can read the code. Let's go. We're going. And the court report is reflected we are walking out of the deposition. 
[other speaker] I don't care. It's your choice. Closing? Yeah. Okay.
Don't put it back down. No. So... 
[other speaker] Off the record now? Yeah. Sure you want to take your coat? 
14:22
[other speaker] [some undecipherable] I’ve been instructed by Mr. Horn to answer any further questions I'd like to introduce this exhibit to this deposition transcript. The deposition notice and subpoena for his answer and to attach complaint to the deposition transcript.  
[other speaker] I'm sorry I'm sorry for you 
[other speaker] I'm getting used to it It's been 3 years, 4 years I'm in it against you. 
[other speaker] You can have that. That came from the fax machine, but what I'm thinking is the deposition notice for Don Yencer. I thought that, again, they have the face page, so that, otherwise, they would sneak a little card. That was on the day for my PPO. In fact, what happened is he called me, he wrote me a letter and he said, it's not fair, just go off to do something at 1.30am. And I said, and then I realized that there had been a typo by the secretary, and I said, well, it's in the after writing, I'll tell you right now. It's at 1.30pm. And he said, well, we won't accept that. We just won't look for it. So, but I was able to tell him that, convince him that we would, that would not be appropriate. So, anyway, let's see let me find the other the other deposition notice for Donnie Yencer which I don't think I have but I thought I did it's in the one file that I didn't bring but you have a face page at least, right?
[other speakers]  I'm not sure if Steven Berg is on. You have Christine Berg. You should have had it for the Donna Yancey also. I have the subpoena. You have the subpoena on there? Yeah. Okay. You didn't make that exhibit with my certificate.
[other speaker] No, I did not just do it with Christine Berg. Well then, if you could have that as an exhibit and I'll call and get in touch with that. 
[other speaker] Okay, do you want to just stay on there? 
[other speaker] Oh yeah. Also as an exhibit to the deposition transcript, I want to have attached the defendants notice of deposition and for production of documents of Donnie Yencer, which notices her deposition for today's day at 2 p.m. at Frank Nelson and Associates, 14th and Chapala Street, Santa Barbara, California. Such a deposition notice should be attached to an exhibit to this transcript. And like I said please just attempt to do that. And let me call right now, I'll pass these plans back to you. Sure. I was hoping that you'd talk to me about it. Yeah, well, you're right. You can't hear yourself dialing. You know, you're going to lose the channel of the leads. Yeah. Okay. 
[other speaker] I'm going to try hard to remain on negative.
[other speaker] Oh it's me you know the other thing we don't have and I thought I definitely did have this nurse deposition so I need to fax that down to the same number. Do you have that? it's  805-564-7034 and you can fax it right away so we can do it before she rolls out of here. Pardon? Yeah, not the deposition subpoena, the deposition notice. There you have the deposition subpoena. Right, okay. I mean, yes, she showed up 30 more minutes than they lasted. About 10 minutes. No, sorry, about 5 minutes.
Yeah, well, he doesn't like taking 40 minutes. 
[other speaker] The truth might get out. He can't he can't miss them all I'm sorry you know I was in two minds here whether to bring one for myself or not and I thought it might come to me yeah he can't and I knew he was going to go away yeah you know if you were smart to do it I don't know that's what a good reporter would do just in case there was something I knew happened you have them have it but I appreciate maybe one of these days we’ll have a read deposition. I do apologize to you for talking over him sometimes Yeah, I turned it off.
[group good byes}
I'll wait for that. It should come in almost like now. She's just going right to the machine to process it. Great. Thanks. Thanks. 
[other speaker] I'll tell you one thing I would appreciate if you put right up at the top of the list. And that's an amendment for every year. For a quiet title action because that turkey he is going to play dirty all the time. 
[other speaker] Yeah he will he has no real sense of fair play. 
[other speaker] That means that it is rotten to the core if you've got to go that far to protect the slugs that have created the problem.
[other speaker]  Well, you know, it's obvious that if they had gone on, it would have been very destructive anyway. So I wouldn't know if it probably got too much out of her except more grist for the motion mill. So we'll see. 
[other speaker] So your question is going right to the heart of the matter. And I hope your next question would be, and who is paying Mr. Horn?
[other speaker] No. That's true. 
[other speaker] Because there's, you know, when did you retain Mr. Horn a and b who's going to pay Mr. Horn two questions that would disqualify that whole arrangement. 
[other speaker] Well, you'd never get an answer 
[other speaker] Probably not So, it's definitely going to be a motion on all three depositions. Yippee.
[other speaker] If we get all the way to court and we haven't had a deposition, we can require that they testify, can't we? 
[other speaker] Absolutely. I'd like to see him try to pull this in the courtroom. Unless he has a judge in his pocket. 
[other speaker] Not too likely to screw the court. 
[other speaker] No. Not too likely. 
[other speaker] And maybe that's the best way to go. 
[other speaker] No, we need to know more too. 
[other speaker] There's a ton of stuff in that... There's got to be a lot of stuff in that Home Federal thing. Uh huh.
[other speaker] You know, true. 
[other speaker] Do we have to name them to get into there?
[other speaker] Well, we will be naming them. No, you don't have to name them. So... 
[other speaker] Can you just... They're in San Diego. Can you just call down there and say I'm investigating such and such. 
[other speaker] They would never. 
[other speaker] You'd have to go in there with a piece of paper.
[other speaker] Yeah, with a subpoena and it would be bought. But that's okay. That's what this case has been from the beginning. You know better than me. So... 
[other speaker] The citizens of the United States are not going to run out of money. So let's go right ahead. 
[other speaker] Okay, well then we'll just go full bore on the whole thing. 
[other speaker] Claude as much as you can. 
[other speaker] Yeah, Claude's a good influence. 
[other speaker] Yeah, because he really lists things 80 ways, upside and downside and crossways, which is good. And so, yeah, at some point we'll have to take him down to Tehachapi to meet with the guys. So what I'd like to do actually at some point, maybe Tehachapi is a good meeting place, is just get everyone there and do one big strategy session and get it down, You guys can be there, maybe close to the tree house if you don't mind. Or some other place, and just go through it. Keep a clock down there, shoot it up in the line. If I'm going to end up driving or something, I might as well take Oberli and Christian. 
[other speaker] Sure, bring Karen and the bird. Yeah, Karen and the bird. Well, the bird might like being in the aviary. He might like being in the aviary. I don't know how he would take the other birds though, that's the only thing. He needs some place like that. I want to look at yours again and build one very similar because I like the way it was done. Build it out on the property. So, it's funny when he walked out the door I kind of got the feeling he was waiting to be shot in the back. 
[other speaker] I think he's lucked out up until now. 
[other speaker] Well it did change with the hearings and the appellate decision. 
[other speaker] Yeah, I think so. A rat in a corner. But they're dangerous. 
[other speaker] Yeah, they're dangerous well we'll see how the rat reacts to the new lawsuits filed so anyway anything else we need to go over you guys came along 
[other speaker] No, we got to meet her. thank you very much we've laid on her our constitutional ideas and I really think you ought to get Claude to read this. 
[other speaker] I will. 
[other speaker] I mean I wish we bought some more coffee. You both can’t read at the same time.  
[other speaker] oh you know the one you know because they Do you need us to get out of the camera?
[other speaker] No, this is Wes up there and it's the correction that you have. 
[other speaker] Oh yes, thank you very much. And thank you. 
[other speaker] We didn't make as much time as you wanted. 
[other speaker] Okay, I appreciate that. Thank you. 
[other speaker] In fact, we've... There's an accountant that has been in touch with us that would like to, I don't know if he is also a lawyer or if he works with lawyers, I don't remember enough about it. I read the letter but it just gone. Hatonn had said something, well he had quoted Dr. Larson as saying that the OMB numbers on the 1040 forms.
[other speaker] Oh, that was Dr. Scott, Neil Scott. 
[other speaker] Yeah. 
[other speaker] I've read about one third of that so far. 
[other speaker] Well, I'm not sure about the OMB numbers, but Dr. Scott, well, I think maybe he's been talking with George maybe about handling this stuff. Anyway, this accountant had been following the journals now for quite a while and he said so far 
[other speaker to court reporter] Well yes the best for me don't mind the sheer ease oh yeah please do it well that's for today so what it is it's in the fortune and I just didn't have one my father thank you. 
[other speaker] He said that of all the stuff that he's read, that was the only thing, and that one had been accurate, but the IRS got busy.
[other speaker] On the OMB? 
[other speaker] Yeah, the OMB numbers. 
[other speaker] Did they correct it? 
[other speaker] Yeah, they corrected it. So that one's out, but he sure would like to be a part of whatever we're doing. 
[other speaker] Well, it would be interesting. I could see, I just have to put together a projected budget for the Constitutional Law Center and see, because I had a good talk with George about it. I don't know if he discussed any of that with you, but I know he would discuss it with me before I talked to him about it. The main question is that, you know, if I were to do it, I have to think long and hard about its effect on my life. 
[other speaker] Well, yeah, it would just take your life. 
[other speaker] You know, so I don't know yet whether I'm prepared to do that. I've sort of thrived on anonymity. Even my law office phone number is unlisted. I thought you were one of the few unlisted attorneys. But anyway, George seems to think there would be no problem with money so when the people willing to do it to get someone like Claude and you get some others involved  and I have others in mind if slash when more attorneys might want to get involved I just think a lot of people know the reason, but they'll hopefully for philosophical reasons as much as anything. But I guess when it transits, you get to pick of the litter closer to you. So that's a distinct possibility. I just have been so busy, probably on the alligator side, I haven't had time to train the squad for such things. You have to ask Melody if she's going to think about training the squad. So one of these days, Ulrike was telling me about her attorney friend who works in the mornings and then reads detective novels in the afternoons. I was thinking, boy, what a nice life. But he's pretty smart. She was saying, although not directly, but my implication was smarter than me, because he makes sure he gets the...
[other speaker] I didn't, he's much older than you. 
[other speaker] Oh, is he? So he's learned his lessons. 
[other speaker] And he doesn't want to have too much money, so he's cut down. 
[other speaker] Well, then instead of working long hours for little money, he works a few hours for the little money. Exactly. I say, he's very different from me. In fact, one of the things I had to do to make sure I was here on time was Ulrich and I met with someone, a messenger in opposition to a motion to set aside a lien. I had this quantitative workbook for years, promising him, hey, naïve, stupid me. And as soon as he got the settlement check, he took the money and ran. And so I put a lien on the case that he was getting another settlement on, but trying to get it taken off. So, I had to deal with that. So, anyway, that's not one thing. That's why I appreciate you guys all the more, because I've never had a problem before. And so I did first priority to the clients who were that way. And I had one client who was falling behind by two months of previously good really like you to get on this right away I said well you know Mr. X huh be happy to but I have to be a priority to the clients who pay my bills. I think that goes so as soon as I get a check I'll be happy with you so I got a check the next day I was not too far away.

Unfortunately, I was not. It's a shame. Karen's always on me to be tough. She's more the tough one on that. She loves you guys. I bet. So, anyway. But, no, I think there are grounds for doing things. I'm sorry again if we hadn't tape recorded of it in advance. 
[other speaker] I think he was ready to go off or something.

[other speaker] Oh yeah, it doesn't matter, you have the right to be here because you're working in my office. You have the right to be there. But he was already... Oh yeah, but it didn't matter. 
[other speaker] He came in and who are you? 
[other speaker] Did he ask you? 
[other speaker] Oh yeah. 
[other speaker] Did you tell her? 
[other speaker] Yes. 
[other speaker] And what did you say?
[other speaker] I said that I was in your office, a German lawyer, and I was doing an internship with you. 
[other speaker] Good. 
[other speaker] And that my name wasn't Luka. Yeah. That was all I told him. 
[other speaker] So he already knew the name. Huge problem. 
[other speaker] So when he said he didn't know, then he was lying. 
[other speaker] He was lying. Yeah. Exactly. 
[other speaker] For the record. Yeah. Interesting. He didn't write that one. 
[other speaker] Well, I still am old-fashioned enough in my 60 years to feel like right will out. I have to believe that truth and integrity will ultimately rebuild our nation. 
[other speaker] Well, I think so. I'd just like it to be in my lifetime. [other speaker] Well, so would I. And you've got a longer lifetime out there. 
[other speaker] Well, I don't know. I've been working myself into early grave. I've got to do something about that. But, I don't know. We shall see. And see what happens. 
[other speaker] So you're going home tonight? 
[other speaker] No. Well, actually, I don't know yet but no I know I won't be going tonight. Question is will I be going tomorrow night because I don't know yet where that arbitration I should probably call them if it’s going forward or not. [undecipherable] made of very soon So in that case, it may suck to the other side. So I think it's... I'm just, you know, this guy never ceases to amaze me. I'm just so like... What do you think? What's your reading of that? Or let's get the German viewpoint. 
[other speaker] American lawyers are much more aggressive. 
[other speaker] Really? But they have not acted like that? 
[other speaker] Never. It was the play who was in charge here. It was the only question.
[other speaker] Yeah, it's true. 
[other speaker] Who answers whose question. That was part of it. I was going to be damned if I was going to answer his with that answer. 
[other speaker] There's a trap in there somewhere. 
[other speaker] Yes, there was. I think so. But he got the deposition notice, it's part of the record, so he knows the answer, and he would have loved to have been there. So he was preparing all of that.
[other speaker] Well, of course he's not spending his money. 
[other speaker] That's right. That's not coming out of his pocket. 
[other speaker] RTC's got deep pockets. 
[other speaker] Yeah. Yeah, they have our money. 
[other speaker] Yeah, I know. That's what I was going to say. Sort of like when I was going to school in France and paying only $24 a year to go to the university. And people say, oh, that's great. I say, yeah, but I feel sorry for the French peasant toiling in his fields who's paying my way to be in the university, because that's who's paying for this.

It's not some entity called the government who's coming out of someone's pocket somewhere. And $24 certainly doesn't pay the cost of a year. It doesn't pay the cost of that institution, no matter how many students go there. Sort of like that fake commercial where they give the first city change bank that will make change for you and people who want change. It was on Saturday Night Live, which you probably don't watch, but they were asked how they make money, how do they stay in the business making money. All they do is make change for people and said oh it's we do it on volume that's how they make it. Oh yeah we do it on volume. So in Germany they wouldn't have done that. Thank you.
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