Compile the Facts into a summary using ALWD.

1) How do you cite to Paxton's understanding that he had to tell the truth at his deposition? a) Ex. A Paxton Deposition 2:21 to 2:23 b) Ex. A, Paxton Dep. 2:21-23. c) EX. A, Paxton Dep. 2:21-23 d) Ex. A, Paxton Dep 21-23:2 2) You want to cite to the Answer, paragraph 9. What is the correct citation? a) Answer 1 9. b) Answer, paragraph 9. c) Answer, 112 d) Answer 119. 3) You want to cite to the Complaint, paragraphs 3 and 8. What would be the correct citation? a) Compl. 11 3-8. b) Compl. 11 3, 8. c) Complaint 1 3-8 d) Compl. 1 3, 8. 4) You are citing Johnston's deposition, from page 13 line 32 through page 14 line 5. What is the correct cite? a) Ex. A, Johnston Dep. 13:32-14:5. b) Ex. 1, Johnston Dep. 13:32, 14:5. c) Ex. 1, Johnston Dep. 13:32-14:5. d) Ex. 1, Johnston Deposition 13:32-14:5.6) You are citing Paxton's deposition at page 4, line 13 and page 7, line 5. What is the correct cite? a) Ex. A, Paxton Dep. 4:13-7:5. b) Ex. A. Paxton Dep, 4:13, 7:5. C) EX. A, Paxton Dep. 4:13, 7:5. d) Ex. A, Paxton Dep. 13:4, 5:7. 7) You are citing Paxton's deposition at page 5, lines 24-27. What is the correct cite? a) Ex. A, Paxton Dep. 5:24-27. b] Ex. A Paxton Dep. 5:24-27. c) Exhibit A, Paxton Dep. 5:24, 5:27 d) Ex. A, Paxton Deposition 5:24-5:27AWN- Cleo and Alex Johnston, Plaintiffs V. Civil Action No.: 23-CV-8635 9 Honor Paxton, 10 11 Defendant 12 13 14 15 Transcript of oral testimony of Honor Paxton, as taken on February 6, 2024 by and before Kathryn 16 Cato, a certified Shorthand Reporter and Notary Public of the State of Rhode Island at the office of 17 Sheryl Gutierrez, Gutierrez & Gruffalo LLC, 31 Ash Street, Wyoming, RI 99101. 18 19 REPORTING SERVICES ARRANGED THROUGH: 20 THYGROVE AND CATO, C.S.R. 21 350 CEDAR STREET 22 Maple, RI 99101 23 617.515.1559 24 25 APPEARANCES: 26 Charles Yang Sheryl Gutierrez 27 State Bar No. 506070 State Bar No. 509801 28 Law Office of Charles Yang, P.C. Guittierez & Gruffalo LLC 29 520 Front Street 31 Ash Street 30 Maple, RI 99101 Wyoming, RI 99101 31 (401) 515-1561 (401) 515-2121 32 Attorney for Plaintiffs Attorney for Defendant 33HONOR PAXTON P.O. BOX 24601 W N WYOMING, RI Having been duly sworn according to law, testifies as follows: DIRECT EXAMINATION BY MR. YANG: MR. YANG: Good afternoon, Mr. Paxton. My name is Charles Yang and I am a lawyer for the Plaintiffs. MR. PAXTON.: Good afternoon. 9 Q Thank you, Mr. Paxton. Before we begin, there are a few things to go over. First, would you 10 please spell your name for the court reporter, and also tell us your address? 11 A Honor Paxton. That's H-O-N-O-R space P-A-X-T-O-N. My mom was kind of a hippie, see, 12 naming me that. But I think it fits, don't you? 13 Yes, it's, um, a lovely name. So. Your address? 14 A Well, I live at 421 River's Edge in Wyoming, but I also have a P.O. Box. 15 Q Thank you. Mr. Paxton, have you had your deposition taken before? 16 A Yes, I have, it was a while ago, a buddy of mine got into some trouble and I guess I was a 17 witness to some of those shenanigans. Now, he ended up having to pay out the nose for- 18 Q Excuse me, Mr. Paxton, thank you. Sorry to interrupt. So you're familiar with the process, so 19 some of this may be repetitive. 20 A Yes Sir. 21 Q You understand that you have been sworn to tell the truth, and you understand that means the 22 whole truth, and nothing but the truth, yes? 23 A Yes. 24 Q And do you have any medical or other condition, or are you under the influence of any 25 medication, alcohol, or any substance that might affect your ability to accurately perceive, 26 remember, and testify completely truthfully? 27 A No. 28 Q Thank you. Okay. And I want you to be sure that you understand any question before you 29 answer it. If you are not certain as to any question, please don't hesitate to ask me to restate it 30 or have the reporter read it back - or somehow let me know you don't completely know what I 31 am asking. Like everyone, sometimes I ask questions in a mixed-up sort of way, and I don't 32 want that to affect your answer. Okay? 33 A Okay. Yes. 34 Q Also, if you don't hear the question completely, let me know. 35 A (Witness nods) 2Q Oh, and another instruction, the reporter can't record head nods or shakes ornon-verbal signals like that. It's subject to personal interpretation. Also "uhh-uhh" and "uh-huh" don't come W N across clear on the record. So, say "yes" or "no." Give me as clear a verbal response as you can muster. Understood? A Yes. I do understand. Q Okay, and if you don't hear an entire question, you'll let me know? 7 Yes, yes I will. Q Thank you. If you don't tell me that you didn't hear or didn't understand, then I will assume 9 you heard and understood fully. 10 A Yes. 11 Q Also, please wait for me to finish my questions before you answer. The reporter can't 12 transcribe us talking over each other, and you may not understand the question until I 13 complete it. Okay? 14 Sure. 15 Thank you. Okay, and last, if someone objects during questioning, please allow Ms. Gutierrez 16 and me to discuss the objection and resolve the issue. Then Ms. Gutierrez will advise you how 17 to proceed. Do you understand? 18 A Yes. 19 Q So you mentioned you'd been deposed before. Do you remember what kind of case? 20 A Really, not so well. A buddy of mine, like I said - well, we'd both been drinking, but he was 21 the one who ended up doing some damage to a car so it was an insurance thing. Anyway, I 22 don't touch the stuff anymore, so I guess something good came out of it. 23 Q By "stuff" you are referring to alcohol? 24 A Well, yeah, but anything now, really. 25 Q Excellent. So. What is your current occupation? 26 A I'm retired. Worked in the capitol building. Providence. Handled facilities, people's offices, 27 stuff like that. 28 Q Did you attend college? 29 A Oh yeah, I have a bachelor's in history. History of all things. Now I'm history. Ha. I did well 30 at it though. Went to Providence College. 31 Q In Rhode Island? 32 A Yes Sir. Go Friars. 33 Q Excuse me? 34 A The mascot. The Friars. 3Q. Oh. Of course. Thank you. I want to talk to you about your-well, the parcel of land at 421 River's Edge W N A Yes. As I understand it, that's what I'm here for. Q When did you first step foot on the land at 421 River's Edge? 5 A The actual date, I don't know. And I don't know the boundaries or what have you, like at what point I was inside that parcel. But you know, I'd been wandering. They say that. Wandering, all who wander are not lost. Anyway, I don't have much, I have my truck. I have my integrity. I have my memories. Most of them. I have my tent. So I ended up there. Pitched it. 9 Q Pitched the tent? 10 A Yes, the tent. 11 Q And how big is your tent? 12 A A two person, but big enough for just me. As you can see, I'm a big guy. Good tent. My sister 13 bought it for me for Christmas in, well, it must have been 2007. 14 Q And you pitched it on the Johnston's property soon after you received it as a gift? 15 MS. GUITTIEREZ: Objection. 16 Q I'll rephrase. You pitched it at 421 River's Edge soon afterwards? 17 A Yeah. Well, I did part of the Appalachian trial. Then I wanted to be home - home among the 18 trees I know. The land I know. So I kind of took off early 2008 with the tent, hiked through 19 the spring, and ended up at 421 River's Edge that next summer. So that would be summer of 20 2008. 21 Q Okay. And for how long did you stay in the tent? 22 A Every night for about three years. Maybe four. Like I said. I had everything I needed. My 23 truck. My integrity. Most of my- 24 Q Thank you. Yes. Memories. So we're going to speak about some of your memories now. Do 25 you remember meeting Mr. and Mrs. Johnston for the first time? 26 A Well, I didn't know his name when I met him, but now I do, yeah. I met the guy. Not the wife. 27 Q And when was that? 28 A It was spring, I suppose, Spring 2009. I'd been camping by the river there for the better part of 29 a year. I was taking a piss - excuse me. I was relieving myself behind my tent and I hear this 30 guy yelling at me. He was wearing - I will never forget this - a knit tie. 31 Q Okay, and what was he yelling? 32 Well, excuse me in advance if a mild cuss word offends anyone here, but he was yelling "Who 33 the hell are you?" 34 Q And were those his exact words? 35 A I mean, it was in 2008, years ago, so I can't say for sure, but he did make an impression. 4Q Did you say anything back to him? A Oh, yeah. You want me to, like, tell how it was? W N Q Yes, please. A Okay. So I was taking a-behind my tent. As I said. He starts yelling, "Who the hell are you?" and I turn. He's in a suit, which is weird, he's got his suit and his thready pastel knit tie and his face was red. He seemed like he was getting mad. He says what he says, inquiring about who I am, and I say, "My name's Honor, I've been camping here." I'm looking at him and I am thinking I should, you know, diffuse the situation a bit. So I say, "real gorgeous bit of land." And I guess that worked because the red goes out of his face pretty quickly, he kind of 10 calms down and says, "sure is." 11 And you understood that he owned the land? 12 A Sure. I mean, he didn't say as much, but he was walking around like he did. I'd been there a 13 while, though, and I'd never seen him. His wife, either. And you say, "he owned it." 14 Sometimes I am not so sure. I think man cannot own land, but only belong to it. 15 Q Okay. What happened next? 16 A With Mr. Johnston? It was weird. Not much of anything. He looked at me funny and kind of 17 huffed off. We might have exchanged a few more words about birds. Which ones I'd seen. I 18 don't remember if he said anything else. 19 Q So he didn't come back and tell you to go? 20 A No. 21 Q He just let you stay? 22 A I guess. I mean, he didn't bother me any more. 23 Q Did he tell you that you had to leave? 24 A No. 25 Q Did he tell you that you were trespassing? 26 A No, look. He didn't say those words, as I recall, but it's not like he rolled out a red carpet. He 27 walked away but I knew he was angry. So when he left, I just stayed. I thought he might come 28 back, but he never did. At all. So I stayed. 29 Q And did you stay in your tent? 30 A You know I didn't. 31 Q Can you elaborate on what your situation is now? 32 A I got a house. I mean, you probably wouldn't call it a house, but I do. And an outhouse. 33 Q And what is that? 34 A You're asking me what an outhouse is? 35 Q I'll be more specific. Is it connected with plumbing? 5A No. It's both high tech and also kind of basic. It composts. But let me tell you, it smells better N than most port-o-potties I've been in. Q When did you add the outhouse? A Gosh, I don't know. The outhouse, maybe 12 years ago, when I still had the tent. And then it was just six months after I put in the outhouse that I built the house to replace the tent. Feels like forever. Q So the house and the outhouse were both completed by 2012? A Yes sir, I'd say so. 9 Q And do you have running water? 10 A No. I don't need it with the river so close. 11 Q What about power? 12 A Yes. I got power. It's through a solar generator. It's not even too expensive, it's just- 13 Q Sorry, Mr. Johnston, I'm just going to stop you right there and move on with my questions. 14 Are you connected to a power grid? 15 A No. Sorry. No. I get mail, though, so the post office knows where I am. I have that P.O. Box 16 but I also have a box on the property. Actually. Now that you mention it, I could connect to a 17 grid and sell back some of my electricity. 18 Q Sorry, you mentioned you get mail? 19 A Yup. Got a box on the main road with my name on it. 20 Q And how do you get to the main road? 21 A Well, I made a clearing, so I can drive my truck. 22 Q Is it a paved road? 23 A No. I mean, I just whacked down some branches. Drove my truck over it, again and again and 24 again, and then I had a road. I use it mostly to get my mail. 25 Q How long have you gotten mail? 26 A I don't keep a file cabinet with records. But let me see. The mailbox I think I put up - well, 27 that would have been in 2013 because that was, if you can believe it, twenty years after my 28 daughter died, and I remember that because the Unitarian church we buried her in sent me a 29 beautiful letter, and I got it in my mailbox. They sent it to my sister and she forwarded it to 30 me there. And I was so happy I'd installed the mailbox because I don't check the P.O. Box too 31 often. Twenty years to the day. And it really meant a lot to me that someone remembered. I 32 mean, besides my sister, god bless her. 33 Q That's I'm so sorry. 34 A Thank you. Life. Life and its pain, you know. We make the most of it. Grief is proof of love. 35 Q Yes, that's beautiful - I really am sorry. 6A Q Thank you. Um, can we pleasecan we go off the record for a moment? COURT REPORTER: Yes. I'll do that now. [questioning resumes in 10 minutes. | MR. YANG: I am sorry about that. Okay, Mr. Paxton, when was the next time you encountered A Q 2 o Q Mr. Johnston? You doing okay? Yes, please answer the question. Well, it was 2023. November. Which I think you know. He and his wife come up my driveway and knock on the door. And I see him and I remember him. I think oh, here he is again. What did they say? Something like, \"what do you think you're doing?\" And I said, I'm having an O'Doul's and listening to the game. Really? That's what vou said? That's what I was doing. So I invited them in. And they said no. And he says \"we own this property.\" And she says, \"how long have you been here?\" Did vou answer? Oh veah. I told her something like \"Longer than you! Sixteen years and counting, by last count.\" I could see the manAlex. His face looked kinda weird at that point. Like he was putting it all together. And he told me, \"You have to go.\" And I said \"No sit, I don't think [ do.\" I mean, I live here. Been living here since 2008. Sure, I started out in a tent, but I put in that road, the house, the toilet, the panels. I even got a welcome mat. So. I''m not leaving. You live in a place, you can't just Mr. Paxton, please. Just answer the question. I did. Okay. Sorry. It's just that. You see what it's like for someone to knock on your door and tell you just to pack up and leave. I take what comes. In my life I've always done that. I have had to do that. But I've been searching for peace for a long while. I found some on the banks of that river. You know? Thank vou Mr. Paxton. [ think that will be all. Actually. One moment. So I just want to clarify something. When you first met Mr. Johnston, in 2011, he didn't say you had to leave, right? MS. GUITTIEREZ: Objection. MR. YANG: On what grounds? MS. GUITTIEREZ: Confusing. Unclear. Also, asked and answered. MR. YANG: I'll rephrase. Did Mr. Johnston ever tell you that you had to go? In so many words? A No. But I will say MR. YANG: Thank you. That will be all. MS. GUITTIEREZ: You have to let him finish. MR. YANG: He answered the question. W N MS. GUITTIEREZ: Mr. Paxton, please continue. Mr. Yang, you must let him finish. MR. PAXTON: I do not like being in between two lawyers fighting, but I'll listen to mine. Um. Okay. So, he saw I was there and he didn't tell me to go. But he also didn't say "Honor, lovely to meet you, you can stay." For sure those words didn't come out. MR. YANG: If he had told you to leave, would you have? MS. GUITTIEREZ: Objection. Calls for speculation. MR. YANG: He can still answer. 10 MS. GUITTIEREZ [to Mr. Paxton]: You can answer. 11 MR. PAXTON: I don't know, okay? I see the guy in 2009, and then he's trying to make me 12 homeless. So I don't know. 13 MR. YANG: Nothing further. 14 MS. GUITTIEREZ: I have a few questions for follow-up. 15 A: Sure thing 16 Q: Mr. Paxton, did you tell Mr. Johnston you were on his property temporarily? 17 A: No, Ma'am. 18 Q: Did you ask if you could stay? 19 A: No. 20 Q: Did you tell him you'd be leaving? 21 A: No. 22 Q: If you had asked if you could stay for fourteen years, what do you think he would have said? 23 A: Hell no. 24 Q: Did you leave the property in the fourteen years you've been there? 25 A: Well I've been there since 2008. So now that's sixteen. And no. Not even for a night. Look. I 26 got a good thing going. Like I said. Some peace there. And I didn't intend to let it go. I just 27 want to stay in my house. With my memories. 28 Q: When was the next time you saw Mr. Johnston? 29 A: When he and his wife came to my house a couple of months ago. 30 MS. GUITTIEREZ: Thank you. 31 WHEREUPON THE DEPOSITION CONCLUDED AT 11:00 a.m. 32 33 34 35 8AWN- Cleo and Alex Johnston, Plaintiffs V. Civil Action No.: 23-CV-8635 9 Honor Paxton, 10 11 Defendant 12 13 14 15 Transcript of oral testimony of Alex Johnston, as taken on February 6, 2024 by and before Kathryn 16 Cato, a certified Shorthand Reporter and Notary Public of the State of Rhode Island at the office of 17 Sheryl Gutierrez, Gutierrez & Gruffalo LLC, 31 Ash Street, Wyoming, RI 99101. 18 19 REPORTING SERVICES ARRANGED THROUGH: 20 THYGROVE AND CATO, C.S.R. 21 350 CEDAR STREET 22 Maple, RI 99101 23 401.515.1559 24 25 APPEARANCES: 26 Charles Yang Sheryl Gutierrez 27 State Bar No. 506070 State Bar No. 509801 28 Law Office of Charles Yang, P.C. Gutierrez & Gruffalo LLC 29 520 Front Street 31 Ash Street 30 Maple, RI 99101 Wyoming, RI 99101 31 (401)515-1561 (401) 515-2121 32 Attorney for Plaintiffs Attorney for Defendant 9ALEX JOHNSTON WN - 42 ELEMENT LANE MAPLE, RI 99101 Having been duly sworn according to law, testifies as follows: DIRECT EXAMINATION BY MS. GUTIERREZ: MS. GUITTIEREZ: Good afternoon, Mr. Johnston. I'm Sheryl Guittierez and I represent Mr. Honor Paxton in this matter. MR. JOHNSTON: Good afternoon, Sheryl. Q Oh, Um, Mr. Johnston I- 10 MR. YANG: Can we go off record for a very quick second? 11 COURT REPORTER: Sure. [record resumes 3 minutes later] 12 MS. GUITTIEREZ: Is everything okay now, Mr. Johnston? 13 Mr. JOHSNON: Yes, Ms. Gutierrez. It is fine, Ms. Guittierez. 14 Q Thank you. To start, would you please state your full given name, spelling your last 15 name for the record? 16 Alex Johnston, J-O-H-N-S-T-O-N. 17 Q Thank you. And what is your address please? 18 42 Element Lane, in Maple, Rhode Island, 99101. But I also, along with my wife, own 19 the property at 421 River's Edge in Wyoming. 20 Q Thank you. We'll get to all of that. You understand that you've been sworn to tell the 21 truth? 22 Yes, I do. 23 Q Are you currently taking any medication, or suffering from a medical or other 24 condition, or under the influence of alcohol or any substance that may affect your 25 abilities to remember and testify completely, truthfully, and honestly? 26 A No. 27 Have you ever had your deposition taken before? 28 A No, I haven't. 29 Q I'm going to give you some instructions about the deposition procedure. We give these 30 instructions to all those who have their deposition taken, so that everyone understands 31 the procedure. First, make sure you understand a question before you answer it. If you 32 have any difficulty at all understanding a question, please let me know. 33 A Yes. 10Q It is very important that you understand a question fully before you answer it. If you don't completely understand it, I'll try to rephrase it so that you do understand it. I can w also ask the reporter to read the question back to you. I understand. Another instruction is that you have to answer out loud, with words. If you mean "yes," you must actually say the word "yes," and if you mean "no," you must say "no." Unless you tell us you don't understand or didn't hear the entire question, I will assume that you did hear it and that you fully understood it. I understand. Q Please make sure you wait until I complete my question before you give us an answer. I will also try to wait until you are done with your answer before asking another question. I understand. To begin, can you please state your occupation? A Yes, I am a mechanical engineer. Q And who is your employer? Nichols, Inc. in Providence. I've been there 21 years. So has my wife. Q Okay, thank you. And you and your wife own multiple properties? 18 A Yes. 19 Beautiful vacation homes. 20 MR. YANG: Objection. Relevance. 21 MS. GUITTIEREZ. I'll withdraw it. When did you purchase 421 River's Edge? 22 1999. Our plan was that we'd retire there in 25 years, and that's what we're doing. 23 How many times have you visited the property? 24 What do you mean? 25 I'm not sure how to ask the question more simply. I want to know how many times you 26 have set foot on the property you own at 421 River's Edge in Wyoming 27 A Well, there is some ambiguity there because I certainly stepped foot on it before I 28 owned it. 29 Q Okay, and after that? After 1999 when you purchased it? 30 A I can't say. 31 Q Can you estimate? 32 A No. 33 Q Was it more than ten or less than ten? 34 D I don't know. 35 Was it more than five? 11MR. YANG : Objection. Asked and answered. N - MS. GUITTIEREZ: It's certainly been asked but not answered. I would simply like to know how many times Mr. Johnston has visited the property. I'll wait for an answer or we can suspend this deposition and go before the judge. MR. YANG: You may answer. MR. JOHNSTON: No. MS. GUITTIEREZ: Okay. Thank you. So fewer than five times. And one of those times was in 2009, correct? 9 Yes. 10 Oh, and just to be clear, did your wife ever go visit without you? 11 Not that I'm aware of. 12 Okay, so in 2009 you arrive on the property. Can you describe the property? 13 Yes. It is ten acres of wooded land on the river. Pine, cyprus, all kinds of trees, I mean, 14 I'm not an arborist but there's quite a variety. And it's remote. You can't see any 15 houses from the middle of the property. From the river's edge, you can see docks and 16 some rooftops, so you know there are houses out there, but otherwise it is easy to feel 17 like you are the only one out there. That's what we wanted after retirement, to leave the 18 hustle and bustle behind. 19 What happened after you arrived in 2009? 20 A Well, I walked around looking at the property, imagining the time when I could retire 21 there, away from all the whining in the office, all the people who need things, need 22 answers, sending you all the ping ping pings on your laptop, you know. And I saw a 23 tent by the river, right smack in the middle of my parcel. And I walked over and I saw 24 a guy, a big hulk of a man, it looked like - excuse me, it appeared he was relieving 25 himself on one of my trees. And I said, "Who are you?" 26 Did he answer? 27 Yes. As I recall, he did. 28 And what did he say, please? 29 He told me his name. Honor. And said he was camping. And then he said it was 30 beautiful. Which it really is. 31 Did you tell him he had permission to stay? 32 A Well, I didn't get a bulldozer right then, I didn't call the cops, so yeah, I walked away, 33 assuming he was just spending a night there. I mean, he had a tent. I didn't think he'd 34 move in. I figured it's fine if he's there for a few nights. I mean, I'm not a monster. 35 Q Did you say that to him? 12What? Did you express to him that you would allow him to stay temporarily? WN - Like I said, I didn't call the cops. Which I could have. And this is how I get repaid. Let's fast forward. Did you have any more contact with Mr. Paxton after that initial meeting? A No. Until 2023? D Yes, until I saw he put in a road, a shower, some kind of electric hookup. A house thing that looks like a shed. An eyesore. Like some kind of cross between a doomsday 10 prophet and a hillbilly. Horrific. 11 What about flowers? 12 A Excuse me? 13 Q Mr. Paxton planted some flowers, didn't he? 14 Yeah, I guess I saw those. And tomatoes. And some other things. 15 How big is the structure? 16 The shed? ODOROF 17 Where Mr. Paxton lives. 18 I don't know. 19 Did he invite you in? 20 A Yes, he did. 21 Q So you were close enough to see how big it was. 22 A Yes. He invited me and my wife in. I suppose - I saw through the door. He had an old 23 pew, a bed, a makeshift kitchen table and a fridge. I don't know if I'd trust the roof not 24 to come down on my head, though, if I'd gone inside. 25 Q Did you ever send Mr. Paxton any notices? 26 Like what? 27 Q Well, specifically I'm referring to what's called a "notice of intent to dispute 28 interrupting adverse possession." 29 MR. YANG: Objection, calls for privileged information. 30 MS. GUITTIEREZ: No, it doesn't, I'm asking him if he ever ...... I am certainly not asking 31 about privileged conversations or advice. 32 MR. YANG: Mr. Johnston, to the extent you can answer without divulging any privileged 33 information, you may do so. 34 MR. JOHNSTON: I never sent him anything. Like I said, I thought he was there for a few 35 nights camping. How was I supposed to know he'd move in? 13~l O o B W N MS. GUITTIEREZ: So at no time did you or any of your representatives file a \"notice of intent to dispute interrupting adverse possession,\" which is section 34-dash-7-dash-6 of the Rhode Island statutes? MR. JOHNSTON: No. I don't even know what you're talking about. There was nothing to interrupt. I didn't think he'd be there fourteen years later. MS. GUITTIEREZ: Thank you. Nothing further. WHEREUPON THE DEPOSITION WAS CONCLUDED AT 3:30 p.m. 14