Opinion
HHDCV186088970S
11-22-2019
Gloria FARBER, as Executor of the Estate of Hilliard Farber v. FORE GROUP, INC. et al.
UNPUBLISHED OPINION
OPINION
CESAR A. NOBLE, J.
The United States and Connecticut constitutions afford a privilege against self-incrimination (privilege). The plaintiff, Mark Dean, Trustee of the CT RE 2019 Trust under Trust Agreement dated February 19, 2019 (plaintiff), has moved to compel a nonparty, Michelle Troconis (deponent), to answer questions to which she invoked the privilege during a deposition. The following facts are relevant to this decision.
The fifth amendment to the United States constitution provides in pertinent part: "No person shall ... be compelled in any criminal case to be a witness against himself ..." U.S. Const., amend. V. The constitution of Connecticut, article first, § 8, provides in relevant part: "No person shall be compelled to give evidence against himself." Conn. Const. art. I, § 8.
The deponent is a defendant in two pending criminal cases, of which the court takes judicial notice, State v. Troconis, Docket No. FST-CR19-0148553, and State v. Troconis, Docket No. FST-CR19-0167364. The charges in the former action include Tampering with or Fabricating Physical Evidence in violation of General Statutes § 53a-155 and Hindering Prosecution in violation of General Statutes § 53a-165aa. The latter action involves a single charge of Tampering with or Fabricating Physical Evidence in violation of § 53a-155. All charges relate to the alleged conduct of the deponent subsequent to the disappearance on May 24, 2019, of Jennifer Dulos, the wife of the present individual defendant, Fotis Dulos (Dulos). More specifically, the charges in Docket No. FST-CR19-0148553 allege the deponent was present as a passenger in a motor vehicle when Dulos allegedly dumped garbage bags in Hartford that allegedly contain items that bear identifying characteristics of Jennifer Dulos. The charges in Docket No. FST-CR19-0167364 allege that the deponent was with Fotis Dulos when he took his employee’s motor vehicle to a car wash on May 29, 2019, that the same motor vehicle was observed in the Town of New Canaan on the morning of Jennifer Dulos’ disappearance, and that a later examination revealed identifying evidence of Jennifer Dulos in the interior of the motor vehicle. The relationship between the deponent and Dulos is of some relevance to both criminal files.
The court may take judicial notice of files in other proceedings. State v. Gaines, 237 Conn. 695, 705 n.7, 778 A.2d 919 (2001).
The present action seeks to recover money allegedly conveyed as loans by Hilliard Farber (Farber) during his lifetime to the defendants, Dulos and Fore Group, Inc. and to pierce the corporate veil between Fore Group, Inc. and Dulos. Among the defenses raised by the defendants to the present claim is that the funds provided to them were not loans but gifts. On September 25, 2019, the plaintiff deposed the deponent, who invoked the privilege to every question asked of her with the exception of her name and address. The plaintiff has moved to compel answers to his questions. The motion requires the court consider the propriety of the invocation of the privilege by the deponent.
"[The fifth amendment] can be asserted in any proceeding ... and it protects against any disclosure that the witness reasonably believes could be used in a criminal prosecution or could lead to other evidence that might be so used." (Internal quotation marks omitted.) Morant v. State, 68 Conn.App. 137, 162, 802 A.2d 93, overruled in part on other grounds by Shabazz v. State, 259 Conn. 811, 830 n.13, 792 A.2d 797 (2002). "A court’s evaluation of whether to preclude the exercise of the fundamental constitutional right at issue is inherently fact-bound." Johnson v. Commissioner of Correction, 166 Conn.App. 95, 127 n. 12, 140 A.3d 1087 (2016), aff’d, 330 Conn. 520, 198 A.3d 52 (2019).
"For a trial court properly to sustain a witness’ invocation of the privilege against self-incrimination, it need only be evident from the implications of the question, in the setting in which it is asked, that a responsive answer to the question or an explanation of why it cannot be answered might be dangerous because injurious disclosure could result ... Conversely, before refusing to allow the privilege, the trial court must find that the answers to any questions proposed cannot possibly have a tendency to incriminate ... The privilege against self-incrimination depends on the mere possibility of prosecution ... In applying the required test for denying the invocation of the privilege it must be perfectly clear, from a careful consideration of all the circumstances in the case, that the witness is mistaken, and that the answer[s] cannot possibly have such tendency to incriminate." (Citations omitted, emphasis in original, internal quotation marks omitted.) Morant v. State, supra, 68 Conn.App. 162-63. Finally, the court is mindful that the privilege is to be accorded a liberal construction. Spevack v. Klein, 385 U.S. 511, 516, 87 S.Ct. 625, 628, 17 L.Ed.2d 574 (1967).
Guided by these principles and the facts of the present case, the court sustains or overrules the invocation of the privilege as indicated on Exhibit A, which repeats each question posed, followed by an order.
An order overruling the invocation of the privilege to a particular question should not be interpreted to mean that the privilege may not properly be invoked to follow up related questions.
So ordered.
Attachment
Exhibit A
Orders of the Court
Page 5, Line 21 (By Mr. Weinstein) Have you been deposed before?
Privileged use overruled
Page 6, Line 22 (By Mr. Weinstein) Where were you born, ma’am?
Privileged use overruled
Page 7, Line 2 Are you a citizen of the United States:
Privileged use overruled
Line 10 (By Mr. Weinstein) Are you a citizen of Argentina?
Privileged use overruled
Line 14 Do you hold an Argentinian Passport?
Privileged use overruled
Line 17 Do you hold a U.S. passport?
Privileged use overruled
Line 20 When did you first meet Fotis Dulos?
Privileged use sustained
Line 23 Where did you first meet Fotis Dulos?
Privileged use sustained
Page 8, Line 1 What were the circumstances under which you first met Mr. Dulos?
Privileged use sustained
Line 5 When did you first commence an intimate relationship with Mr. Dulos?
Privileged use sustained
Line 9 I understand that prior to moving to Connecticut, you resided in Miami Beach, Florida. Is that correct?
Privileged use overruled
Line 13 What was your address in Miami Beach, Florida?
Privileged use sustained
Line 16 Were you residing in Florida with your daughter, Nicole?
Privileged use overruled
Line 20 Did Mr. Dulos come and visit you in Florida?
Privileged use sustained
Line 23 On how many occasions did Mr. Dulos visit you in Florida?
Privileged use sustained
Page 9, Line 2 When Mr. Dulos visited you in Florida, did he stay at your premises?
Privileged use sustained
Page 9, Line 6 Do you still maintain a residence in Miami?
Privileged use sustained
Line 9 Do you know on how many occasions Mr. Dulos visited you in Miami?
Privileged use sustained
Line 13 Were you aware of the fact that Mr. Dulos used a corporate credit card in the name of Fore Group?
Privileged use sustained
Line 17 Did you ever have possession of a Fore Group credit card?
Privileged use sustained
Line 21 Besides spending time with Mr. Dulos in Miami Beach, Florida, did Mr. Dulos visit you in Vail, Colorado?
Privileged use sustained
Line 25 What was the address that you maintained in Vail, Colorado?
Privileged use sustained
Page 10, Line 4 Was the purpose of you being in Vail, Colorado, to engage in skiing at the resort?
Privileged use sustained
Line 8 On how many occasions did Mr. Dulos visit you in Vail Colorado?
Privileged use sustained
Page 10, Line 12 In Miami Beach, Florida, did you ever observe Mr. Dulos entering into any business transactions?
Privileged use overruled
Line 16 Other than visiting with you and your daughter in Miami, did Mr. Dulos meet with any third person who was either an architect or designer?
Privileged use overruled
Line 21 When Mr. Dulos visited you in Miami, did Mr. Dulos meet with any so-called investors?
Privileged use overruled
Line 25 To your knowledge, did Mr. Dulos ever conduct business in Florida?
Privileged use overruled
Page 11, Line 4 When Mr. Dulos visited you in Vail, Colorado, did he ever meet with any designers or architects?
Privileged use overruled
Line 8 When Mr. Dulos visited you in Vail, Colorado, did he meet with any so-called investors?
Privileged use overruled
Line 12 Did Mr. Dulos ever conduct business in the State of Colorado to your knowledge?
Privileged use overruled
Page 11, Line 16 Besides visiting with you in Miami and in Vail, you and Mr. Dulos spent time in Greece together. Is that correct?
Privileged use sustained
Line 21 Was your daughter, Nicole, with you and Mr. Dulos in Greece?
Privileged use sustained
Line 25 Where did you stay in Greece?
Privileged use sustained
Page 12, Line 3 Did you meet with any individuals who purportedly were investors when you spent time with Mr. Dulos in Greece?
Privileged use sustained
Line 7 How many days did you spend with Mr. Dulos in Greece?
Privileged use sustained
Line 11 Who paid for the expenses of the transportation to Greece?
Privileged use sustained
Line 15 Who paid for the expenses of the hotels or restaurants in Greece?
Privileged use sustained
Line 19 Who paid for the expenses in Miami Beach?
Privileged use sustained
Page 12, Line 22 Who paid the expenses in Vail, Colorado?
Privileged use sustained
Line 25 Did you bring any assets, any money, to Greece on behalf of Mr. Dulos at any time?
Privileged use sustained
Page 13, Line 4 Are you aware of who is paying for Mr. Dulos’ criminal attorney?
Privileged use sustained
Line 8 Are you aware of who is paying for Mr. Dulos’ civil attorneys?
Privileged use sustained
Line 12 Are you aware of any assets Mr. Dulos has in Greece?
Privileged use sustained
Line 16 Were you aware that Mr. Dulos had two automobiles sitting in a parking garage in Athens?
Privileged use sustained
Line 20 Did you discuss with Mr. Dulos the purpose of those vehicles in the garage in Athens, Greece?
Privileged use sustained
Line 24 At any time over the last couple of years, did you travel to Spain with Mr. Dulos?
Privileged use sustained
Page 14, Line 3 How many days did you stay in Spain with Mr. Dulos?
Privileged use sustained
Line 7 Who paid for the expenses to go to Spain?
Privileged use sustained
Line 10 Other than spending time with Mr. Dulos in Miami, in Vail, Greece, and Spain, did you make any other trips with Mr. Dulos over the last couple of years?
Privileged use sustained
Line 15 When you traveled with Mr. Dulos, did your daughter accompany you?
Privileged use sustained
Line 19 When did you first move to Connecticut?
Privileged use sustained
Line 22 Why did you move to Connecticut?
Privileged use sustained
Line 25 Where were you living when you first moved to Connecticut?
Privileged use overruled
Page 15, Line 4 When you moved into 4 Jefferson Crossing, Jennifer Farber Dulos had vacated the house. Is that correct?
Privileged use sustained
Page 15, Line 8 You then lived at 4 Jefferson Crossing with Fotis Dulos for several months, well into 2019, until Jennifer Farber Dulos was missing on or about May 24, 2019. Is that correct?
Privileged use sustained
Line 14 Did you contribute to the living expenses at 4 Jefferson Crossing?
Privileged use sustained
Line 18 Did you daughter reside with you at 4 Jefferson Crossing?
Privileged use sustained
Line 22 Did you contribute in any way to the expenses at 4 Jefferson Crossing?
Privileged use sustained
Page 16, Line 1 Did you ever have any direct contact with Jennifer Farber Dulos?
Privileged use sustained
Line 5 At some point in time, you became involved in the Fore Group. Is that correct?
Privileged use sustained
Line 9 You were aware of the fact that Mr. Dulos was trying to secure portions of real estate commissions for you. Is that correct?
Privileged use sustained
Line 14 Mr. Dulos encouraged you to try to seek a real estate license. Is that correct?
Privileged use sustained
Page 16, Line 18 Mr. Dulos paid for you to secure a real estate license. Is that correct?
Privileged use sustained
Line 22 You did not secure a real estate license. Is that correct?
Privileged use overruled
Page 17, Line 1 What was the date that you first moved into Jefferson Crossing, 4 Jefferson Crossing?
Privileged use sustained
Line 5 What was the last date you spent at 4 Jefferson Crossing?
Privileged use sustained
Line 9 You were aware that the Fore Group maintained an office at 4 Jefferson Crossing. Is that correct?
Privileged use sustained
Line 13 You spent time in the office of the Fore Group in connection with trying to market one or more properties. Correct?
Privileged use sustained
Line 18 Were you ever an employee of the Fore Group?
Privileged use sustained
Line 21 Prior to becoming involved with Mr. Dulos and the Fore Group, did you have any background in real estate?
Privileged use sustained
Page 17, Line 25 Did you have any background in terms of the design of a residential property or marketing a residential property?
Privileged use sustained
Page 18, Line 5 Did you ever receive funds directly from the Fore Group?
Privileged use sustained
Line 9 Were you aware that Mr. Dulos was receiving thousands of dollars by way of reimbursement from the Fore Group?
Privileged use sustained
Line 14 Did you play any role in regard to maintaining books and records of the Fore Group?
Privileged use sustained
Line 18 Did you have occasion to deposit checks into a Fore Group checking account?
Privileged use sustained
Line 22 Did you have occasion to deposit checks into Mr. Dulos’ personal account?
Privileged use sustained
Page 19, Line 1 Is it correct that each employee of the Fore Group had a credit card which was tied to the Fore Group’s account at American Express?
Privileged use sustained
Line 6 What was your role in the day-to-day activities of the Fore Group?
Privileged use sustained
Page 19, Line 10 Did you ever assist Mr. Dulos in regard to the QuickBooks that were maintained for the Fore Group?
Privileged use sustained
Line 14 Were you aware of the loans made by Hilliard Farber to the Fore Group?
Privileged use sustained
Line 18 Did you ever discuss the loans that were made by Hilliard Farber to the Fore Group with Mr. Dulos?
Privileged use sustained
Line 22 Were you aware of the fact that Mr. Dulos was under financial pressure during 2017 and ‘18?
Privileged use sustained
Page 20, Line 1 Were you aware that Mr. Dulos had borrowed approximately $600,000 from a Mr. Masiello?
Privileged use sustained
Line 5 Did Mr. Dulos ever discuss with you why he was securing those funds from Mr. Masiello?
Privileged use sustained
Line 9 Did you ever have discussions with Mr. Dulos about sources of financing for the Fore Group?
Privileged use sustained
Page 20, Line 13 Did Mr. Dulos discuss with you that the divorce pending between Jennifer Farber Dulos and Mr. Dulos was causing difficulty for his business?
Privileged use sustained
Line 18 Did Mr. Dulos discuss with you that he needed to resolve the divorce because of the negative effect on the Fore Group’s business?
Privileged use sustained
Line 23 In any of the instances in which Mr. Dulos reimbursed himself for so-called expenses, did you participate in allocating the invoices for which Mr. Dulos should be reimbursed?
Privileged use sustained
Page 21, Line 4 Did you play any role in regard to reconciling invoices and the amount that should be charged to the Fore Group as opposed to Mr. Dulos individually?
Privileged use sustained
Line 9 Are you aware of any business that Mr. Dulos did on behalf of the Fore Group outside of Connecticut?
Privileged use overruled
Line 13 Were you ever responsible for securing products or services from any third-party vendor for the Fore Group?
Privileged use sustained
Line 17 Were you ever aware of any discussions Mr. Dulos had with banks in regard to securing loans during 2017, ‘18, and ‘19?
Privileged use sustained
Page 21, Line 22 On how many occasions did you and Mr. Dulos socialize at 4 Jefferson Crossing?
Privileged use sustained
Page 22, Line 1 On one or more occasions, was Beth Johnson someone who attended dinners at 4 Jefferson Crossing?
Privileged use sustained
Line 5 On one or more occasions, did an individual named Hutch Haines, H-A-I-N-E-S, attend dinners at 4 Jefferson Crossing with you?
Privileged use sustained
Line 10 Who else attended dinners at 4 Jefferson Crossing while you were living at the residence?
Privileged use sustained
Line 14 Other than the American Express credit card, are you aware of any other credit cards that the Fore Group had in regard to its business?
Privileged use sustained
Line 19 Other than the American Express Fore Group credit cards, are you aware of any credit cards that Mr. Dulos maintained?
Privileged use sustained
Line 24 Did Mr. Dulos purchase any gifts for you?
Privileged use sustained
Page 23, Line 2 Did Mr. Dulos provide any jewelry to you?
Privileged use sustained
Page 23, Line 5 Did you utilize an automobile when you were living at 4 Jefferson Crossing?
Privileged use sustained
Line 9 Who owned the automobile that you were utilizing?
Privileged use sustained
Line 12 Was the vehicle owned by the Fore Group?
Privileged use sustained
Line 15 Did the Fore Group pay for the gas and the maintenance of the vehicles that you drove?
Privileged use sustained
Line 19 Are you aware, at present, of any source of income that Mr. Dulos has
Privileged use sustained
Line 23 What was your source of income when you were living at 4 Jefferson Crossing?
Privileged use sustained
Page 24, Line 2 Is Mr. Dulos contributing in any way to your defense?
Privileged use sustained
Line 6 Do you know who is paying for Mr. Dulos’ attorneys in regard to- whether it’s the civil matter or criminal matter?
Privileged use sustained
Page 24, Line 11 Did you ever have dealings with any member of the Dulos family?
Privileged use sustained
Line 15 When you would go out to dinner here in Connecticut, who paid the bill?
Privileged use sustained
Line 19 Is it correct that Mr. Dulos would pay the bill and charge it to the Fore Group?
Privileged use sustained
Line 23 Was there any occasion when you went out with Mr. Dulos to a restaurant here in Connecticut when it was purportedly for business?
Privileged use sustained
Page 25, Line 3 Did Mr. Dulos discuss with you the cost he was incurring in his defense of the divorce case?
Privileged use sustained
Line 7 Did Mr. Dulos ever discuss with you the second mortgage that was on the property at 4 Jefferson Crossing?
Privileged use sustained
Line 11 In regard to the Jefferson- 4 Jefferson Crossing property, were you aware that the first mortgage was held by Mellon Bank?
Privileged use sustained
Page 25, Line 16 Did Mr. Dulos tell you that he defaulted on the mortgage in the October/November 2018 time frame?
Privileged use sustained
Line 20 Did Mr. Dulos tell you that he expected the estate would be forced to pay for the mortgage and could not foreclose on the property?
Privileged use sustained
Line 25 After Mr. Dulos defaulted on the mortgage in the fall of 2018, you and Mr. Dulos, and your daughter, continued to reside at the premises at least into the May, late May 2019 time frame. Correct?
Privileged use sustained
Page 26, Line 6 Did you ever have discussions with Mr. Dulos as to whether or not an expense was properly attributed to the corporation as opposed to Mr. Dulos individually?
Privileged use sustained
Line 11 At any time did Mr. Dulos place any assets in your name?
Privileged use sustained
Line 15 Can you explain to me the transaction involving 123 Hunter Drive in West Hartford?
Privileged use sustained
Line 19 Can you explain to me whose idea it was to acquire 123 Hunter Drive in West Hartford?
Privileged use sustained
Page 26, Line 23 Can you explain to me the transaction and how you were involved in that transaction?
Privileged use sustained
Page 27, Line 2 Did you receive any money from the 123 Hunter Drive, West Hartford, transaction?
Privileged use sustained
Line 6 At any time did Mr. Dulos request that you place assets in your name, even if you did not do so?
Privileged use sustained
Line 10 Are you aware of any time in which Mr. Dulos transmitted monies overseas?
Privileged use sustained
Line 14 Were you aware that Mr. Dulos was seeking records in regard to the Farber estate?
Privileged use sustained
Line 18 Did Mr. Dulos ever ask you to go to the Probate Court in New York to review the records of the Farber Estate?
Privileged use sustained
Line 23 Did you discuss with Mr. Dulos the approximate amount that was reflected in the Probate Court records as to the Farber Estate?
Privileged use sustained
Page 28, Line 3 Did you have discussions with a Steffen Reich in regard to the business of the Fore Group?
Privileged use sustained
Line 7 Were you involved in discussions in which Fotis Dulos and Mr. Reich discussed valuation for the various properties owned by the Fore Group?
Privileged use sustained
Line 12 Did you have discussions with Mr. Giuffria in regard to 4 Jefferson Crossing?
Privileged use sustained
Line 16 Were you present when Mr. Dulos had discussions with Mr. Giuffria in regard to the valuation of 4 Jefferson Crossing?
Privileged use sustained
Line 21 Did you have any discussion with Mr. Urbanski, the accountant for the Fore Group?
Privileged use sustained
Line 25 Were you present when Mr. Dulos requested Mr. Urbanski to change a loan on the books of the Fore Group from Hilliard Farber to equity?
Privileged use sustained
Page 29, Line 5 Were you aware of the fact that Mr. Dulos changed accountants and hired an individual named Mr. Giustina?
Privileged use sustained
Page 29, Line 9 Were you aware of the fact that Mr. Dulos asked Mr. Giustina to change the loan that was due and owing to Hilliard Farber to equity in regard to the Fore Group?
Privileged use sustained
Line 14 Did you ever go to New York City with Mr. Dulos?
Privileged use sustained
Line 17 To the best of your knowledge, did Mr. Dulos have any business in New York City?
Privileged use sustained
Line 21 You’re aware of Mr. Dulos maintaining a storage unit at Avon Storage?
Privileged use sustained
Are you aware that that storage unit is paid for by the Fore Group?
Privileged use sustained
Are you aware of the contents of that Avon storage unit?
Privileged use sustained
Did you ever go into the storage unit in Avon?
Privileged use sustained
Did Mr. Dulos discuss with you the fact that 4 Jefferson Crossing was owned jointly with his wife, Jennifer Dulos?
Privileged use sustained
Page 30, Line 16 Did Mr. Dulos discuss with you the fact that if Jennifer died that, in fact, he would be the sole owner of the property?
Privileged use sustained
Line 21 Did Mr. Dulos discuss the fact that the estate, Hilliard’s estate, would be obligated to pay the bank loan, and that for whatever reason it would be unable to foreclose on the property?
Privileged use sustained
Page 31, Line 8 (By Mr. Weinstein) Were you aware of the fact that Hilliard Farber’s estate had provided additional security to Mellon Bank of almost $3 million in regard to the mortgage for 4 Jefferson Crossing?
Privileged use sustained
Line 14 Did you ever have discussions with Mr. Dulos as to why he sought reimbursement from the Fore Group as opposed to just utilizing a Fore Group check to pay credit card expenses?
Privileged use sustained
Line 20 Other than Mr. Dulos, were you aware of anybody who provided bookkeeping services in regard to the records of the Fore Group?
Privileged use sustained
Line 25 Did Mr. Dulos ever discuss with you trusts that were maintained for Jennifer Farber Dulos by the Farber family?
Privileged use sustained
Page 32, Line 5 Did Mr. Dulos tell you the amount of money that was held in trust for Jennifer Farber Dulos?
Privileged use sustained
Page 32, Line 9 Did you ever have discussions with Mr. Dulos about rent that he was paying for the office at 4 Jefferson Crossing?
Privileged use sustained
Line 14 Did you have any discussions with Mr. Dulos about how that rent was calculated?
Privileged use sustained
Line 18 Were you ever present when employees of the Fore Group provided reconciliations in regard to expenses to Mr. Dulos?
Privileged use sustained
Line 23 Were any of the checks for reimbursement from the Fore Group to Mr. Dulos cashed, to your knowledge?
Privileged use sustained
Did you ever cash any checks for Mr. Dulos?
Privileged use sustained
Did you ever use a credit card on behalf of the Fore Group?
Privileged use sustained
Do you know a Peter Kotchick, K-O-T-C-H-I-C-K?
Privileged use sustained
Do you know if he was an employee of the Fore Group?
Privileged use sustained
Page 33, Line 16 Do you know where Mr. Kotchick lives?
Privileged use sustained
Line 19 You had dealings directly with a John Engel, E-N-G-E-L. Is that correct?
Privileged use sustained
Line 23 Mr. Dulos was trying to negotiate with Mr. Engel a commission for you on the sale of the New Canaan home. Correct?
Privileged use sustained
Page 34, Line 3 At the time that Mr. Dulos was attempting to secure a real estate commission in connection with the New Canaan home, you were not licensed by the State of Connecticut to sell real estate. Correct?
Privileged use sustained
Line 9 Do you know Yannis, Y-A-N-N-I-S, Toutziardis, T-O-U-T-Z-I-A-R-D-I-S?
Privileged use sustained
Line 13 Have you ever met Yannis? I’ll refer to him at T because I don’t want to mispronounce his last name.
Privileged use sustained
Line 17 Did you ever meet with Yannis T in Greece?
Privileged use sustained
Page 34, Line 20 Do you know what Yannis T does for a living?
Privileged use sustained
Line 23 Did you ever have direct dealings with any suppliers who were doing business with the Fore Group?
Privileged use sustained
Page 35, Line 2 Did you ever review credit card bills in regard to the monthly expenses being incurred by the Fore Group or being reimbursed to Dulos?
Privileged use sustained
Line 7 Did you spend time with Mr. Dulos in Olympia, Greece?
Privileged use sustained
Line 11 Did Mr. Dulos pay for the cost of you and Mr. Dulos being in Olympia, Greece?
Privileged use sustained
Line 15 Did you have any discussions with potential buyers of homes that sought to contract with the Fore Group?
Privileged use sustained
Line 19 Did Mr. Dulos provide financial support for you when you were living here in Connecticut?
Privileged use sustained
Line 23 Did Mr. Dulos ever ask you to conceal assets of his, to put them beyond the reach of any creditors?
Privileged use sustained
Page 36, Line 2 Did Mr. Dulos explain to you why he wanted you to be involved in 123 Hunter Drive in West Hartford?
Privileged use sustained
Line 6 Did you ever meet with the bank officer from whom the loan was secured for 123 Hunter Drive?
Privileged use sustained