Oracle Corporation et al v. SAP AG et al

Filing 1119

Letter from Steven C. Holtzman re: Further Update. (Attachments: # 1 Exhibit A)(Holtzman, Steven) (Filed on 4/4/2012)

EXHIBIT A

In The Matter Of:
Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.

Reporter's Transcript of Proceedings
March 26, 2012

Behmke Reporting and Video Services, Inc.
160 Spear Street, Suite 300
San Francisco, California 94105
[phone]

Original File 19612Proceeding.txt

Min-U-Script® with Word Index

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
BEHMKE REPORTING AND VIDEO SERVICES, INC.

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IN AND FOR THE COUNTY OF SAN FRANCISCO
- - - - - - - - - - - - - - RINCON EV REALTY LLC,

)

et al.,

)
Plaintiff,

) Case No.

vs.

) CGC 10-496887

CP III RINCON TOWERS, INC.,

)

et al.,

)
Defendants.

)

- - - - - - - - - - - - - - -

REPORTER'S TRANSCRIPT OF PROCEEDINGS
BEFORE THE HONORABLE MARLA J. MILLER
400 McALLISTER STREET, DEPARTMENT 604
SAN FRANCISCO, CALIFORNIA 94102
MONDAY, MARCH 26, 2012

BEHMKE REPORTING AND VIDEO SERVICES, INC.
BY:

MELINDA M. SELLERS, CSR NO. 10686, RPR, CCRR
160 SPEAR STREET, SUITE 300
SAN FRANCISCO, CALIFORNIA 94105
[phone]

BEHMKE REPORTING AND VIDEO SERVICES, INC.

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Page 1 BEHMKE REPORTING AND VIDEO SERVICES, INC.

THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

APPEARANCES OF COUNSEL:
FOR PLAINTIFF:
BOIES, SCHILLER & FLEXNER LLP
BY:

DAVID W. SHAPIRO, ESQ.
MAXWELL V. PRITT, ESQ.

1999 Harrison Street, Suite 900
Oakland, California 94612
Telephone:

[phone]

FOR DEFENDANTS:
MANATT, PHELPS & PHILLIPS, LLP
BY:

BARRY LEE, ESQ.
ANN M. HEIMBERGER, ESQ.
CHRISTIAN E. BAKER, ESQ.
LENARD WEISS, ESQ.

One Embarcadero Center, 20th Floor
San Francisco, California 94111
Telephone:

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MONDAY, MARCH 26, 2012; 9:05 A.M.
THE COURT: Good morning, everybody.
MR. LEE: Good morning, your Honor.
MR. SHAPIRO: Good morning, your Honor.
THE COURT: Calling the matter of Rincon EV Realty
LLC, et al., versus CP III Rincon Towers, Incorporated,
et al.
Appearances, please.
MR. SHAPIRO: Good morning, your Honor. David
Shapiro, Boies, Schiller & Flexner, for the plaintiffs.
MR. PRITT: Maxwell Pritt for the plaintiffs.
THE COURT: Good morning.
MR. LEE: Good morning, your Honor. Barry Lee,
Manatt Phelps, for defendants.
MS. HEIMBERGER: Ann Heimberger, Manatt Phelps, for
defendants.
MR. BAKER: Christian Baker, Manatt Phelps, for
defendants.
MR. WEISS: Lenard Weiss from Manatt. Same.
THE COURT: Good morning, everybody.
We have a number of matters on calendar.
We'll start with the simplest first. This is
defendants' motion to seal confidential investment
committee report. It was originally set for hearing on

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March 16th, but when the parties requested that we move

this hearing until today, this was continued.
So I've read all the papers filed in support
of and in partial opposition, and my tentative view is
to grant the motion for the good cause shown in the
motion to seal.
Does anybody wish to be heard?
MR. SHAPIRO: No, your Honor.
MS. HEIMBERGER: No, thank you, your Honor.
THE COURT: All right. So I'll sign the order.
Okay. The next is the motion to strike
portions of the fourth amended complaint. This was
continued from the last hearing that we had on -- when
was that originally?
MR. LEE: Looks like the 24th.
MS. HEIMBERGER: February 24th.
THE COURT: Is that when it was?
MS. HEIMBERGER: Oh, wait.
THE COURT: Yeah, time flies. February 24th.
And I've read the surreply filed by the
plaintiffs to the motion to strike, as well as the
defendants' surreply in support of the motion to strike
portions of the fourth amended complaint, as well as
considered your previous arguments and briefs.
And this is my thought: My tentative view is

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(1) Pages 1 - 4

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
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to deny the motion, particularly in light of the fact
that this is going to be a court trial. I will better
be able to address the issues raised by the motion to
strike; that is, to what extent, if any, any legal
arguments about Section 726 have merit or remain in
light of Judge Busch's ruling after I've heard all the
evidence.
I've read your briefs. I've read the judge's
order. I'm dubious, the way things stand, that there
is a Section 726 claim, but it seems to me that it's
not something that's best decided on the papers at this
stage as the motion to strike. If there is something
that the plaintiffs come forward with that's different
from what Judge Busch ruled on, I'll certainly hear it
and hear it with an open mind. But it seems to me to
be not a good use of resources at this point to try to
define whether a legal argument can stand when I
haven't heard the evidence that supports the legal
argument.
It also seems to me that this won't really
affect the issues to be proven at trial, in the sense
of what evidence we'll need to put on -- will need to
be put on because it seemed to me that the 726 argument

that the plaintiff was trying to make is a legal
argument that falls out of the evidence that's going to

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complaint that would not otherwise be necessary, in our

view, at this time, and that's substantial evidence
about the actual factual allegations about the flow of
funds through the accounts.
Our original motion and the argument here have
to do with the argument that, even as pled, the facts
don't raise a claim. But the fact is that we deny that
the allegations are true; and in order to prove that,
the evidence that's going to come in is financial
statements for, you know, a year or more and
complicated expert testimony about the flow of funds
through this sort of waterfall of accounts and where it
went from the lockbox account through the cash
management account through all these other reserve
accounts, and what happened to the money on any given

day at any given time.
And that's evidence that otherwise, I don't
think, is going to be necessary to be put in. But if
these claims stay, stay in the case, that will be
additional evidence that will need to be submitted.
THE COURT: All right. Well, you do have Judge
Busch's decision, and you have stipulations or the lack
of dispute on the part of the plaintiffs to a large
number of the facts that were put in evidence by your
motion for summary judgment. So it's not clear to me

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be put on in any event. It's not a separate 726 claim.
So I just think it makes more sense to let the
plaintiffs put on their evidence, see whether they wish
to proceed with the 726 argument that's different from
the one that Judge Busch ruled on, and then hear
motions or argument at trial as to whether or not that
evidence should be precluded or the law should be -let me start over -- or whether, after hearing the
evidence or at trial, whether the judge's prior motion
for summary adjudication precludes the plaintiff from
making the argument in this case. That's my tentative
thought.
And my tentative view also is, as I stated
last time, to deny the motion to strike the other
particular portions of the complaint which were the
subject of defendants' motion for the reasons that I
stated last month.
So Ms. Heimberger?
MS. HEIMBERGER: Yes. Thank you, your Honor.
I think first, just one point that wasn't
raised in the papers -- because I think you know we've
briefed these issues a couple times now, so I don't
want to repeat ourselves, but the point about evidence,
I think there is additional evidence that defendants
will need to put on if these claims stay in the

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that -- it's not immediately clear to me that there
can't be a stipulation or a simpler way to proceed.
But it's your case. I'm not sure.
MR. LEE: Barry Lee for Manatt.
I think one of the problems we have is we
don't really see, based on the allegations or the
argument, what is different about the claim, the 726
claim they're trying to raise now. We don't really see
the difference. Therefore, we've got to prepare our
defense for all kinds of things, which will entail, I
think, in part, this rather fact-intensive description
of the flow of funds for the period in question because
we're not sure what they're claiming other than what
they already claimed.
THE COURT: All right. Thank you.
Mr. Shapiro.
MR. SHAPIRO: I'll respond to what counsel argued
today as best I can because I'm not actually sure that
I follow it.
But I think what they're saying is that they
would want to present evidence about the way money came

in from tenants, went into different reserve accounts,
and then went out to pay for things. I think that's
part of the case, regardless of whether the 726 is in
or not. I'm not really sure what defense counsel is

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(2) Pages 5 - 8

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
BEHMKE REPORTING AND VIDEO SERVICES, INC.

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arguing about that.
One of the claims in the complaint is for an
accounting, which had exactly to do with that, that the
plaintiffs never really knew how much money was in the
account by the time of July or October 2010. And I do
think that if there's evidence that we don't have about
the way funds went in and out, defendants ought to give
it to us.
And maybe we can reach a stipulation about
that. That seems to be pretty simple to me. Whatever
their argument may be, whatever our argument may be
about the money, it is what it is. If there are
account statements, we should have those.
So it's hard for me to really argue, other
than I think that your -- you know, obviously, I'm not
going to argue the tentative on the motion to strike,
but I don't think that questions of evidence really are
relevant at this point.
THE COURT: Okay. Anything further?
MR. LEE: My only comment would be this -- and
maybe this just plays out at trial -- during the period
that the plaintiffs owned the property, it's their
financial statements that demonstrated the flow of
funds. It's not anybody else's. There are bank
statements, obviously, but it's their financial

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MS. HEIMBERGER: Your Honor, we apologize, but we
weren't aware that -- I don't think your Honor
requested case management statements. We weren't
planning on submitting one until we saw theirs.
THE COURT: I thought I would get something that
was an agreed-upon schedule.
So let me read this. I'm going to take a
short recess. I'll be right back.
(Recess taken.)
THE COURT: All right. So I've looked over the
case management conference statements that I received.

To what extent did the parties meet and confer
on the subject of pretrial dates and bifurcation, in
light of the fact that it's a court trial?
MR. SHAPIRO: We got a proposed schedule from the
defendants, I think, on Wednesday or Tuesday last week.

We sent them back our proposed schedule, which
wasn't -- which was different for certain things. Ours
was closer to trial. And then we didn't hear back from
them about that so we filed our proposed schedule.
With respect to the bifurcation, Mr. Lee and I
talked about it, and he said he wanted to think
about -- and I raised the possibility of trying the
foreclosure cause of action, though I did say, and he
recognized, that your ruling on the motion to strike

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statements. So they have the information.
The extra evidence is people coming in and
saying here's how this flowed out, but off of
plaintiffs' financial statements.
But we'll submit at that point.
THE COURT: All right. So the tentative ruling
is -- the ruling of the Court on the motion to strike,
it is denied in its entirety, without prejudice to
making any argument at trial or after trial about the
effect of Judge Busch's order for summary adjudication.
The last thing we have is the case management
conference, and I just received and have not had a
chance to look at the Defendants' Supplement to Case
Management Statement.
So perhaps we could just go off the record for
a minute, and I'll review the different dates that you
have here.
MR. LEE: Okay.
THE COURT: Do you want the case management
conference reported?
MR. SHAPIRO: Sure.
Is it okay?
MR. LEE: Yes, yes.
THE COURT: Why am I getting this now?
MR. SHAPIRO: We got theirs on Friday afternoon.

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might affect that, and he was going to think about it.
So that's what we talked about last time, about
possibly doing that.
But I see from their filing today that I don't
think they agree with it.
THE COURT: All right.
MR. LEE: We sent our schedule on Tuesday last
week. We had a conference call on Wednesday, about an

hour -- just short of an hour, I guess. We did talk
about the proposed bifurcation.
I didn't fully understand exactly what they
were calling the foreclosure action. I understood
better after I saw their statement that they're really
talking about sort of the procedural components of
that.
We did get their proposed schedule dates on
Thursday of last week.
THE COURT: Okay. Well, are you prepared to
discuss this now, or do you think, now that you've -- I
mean, my inclination is to put you in a jury room and
have you discuss this. You know, I just received this
from both of you. My fallback is we'll try the whole
case at once.
I don't think it's worth spending case
management conference after case management conference

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(3) Pages 9 - 12

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
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to try to figure out what to try first if the parties
can't agree.
But if you can agree and there's a way to be
more efficient, I'd like to do that. But receiving
statements on Friday and Monday when we walk into court

indicates to me that you haven't really been talking
about how you really want the case to go forward.
MR. SHAPIRO: I think that the big time-saver will
be things that we can stipulate to, facts in evidence
we can stipulate to.
I think that since it is going to be a judge
trial, the bifurcation and phasing is just less
critical because you can adjust our showing up to court
to fit your schedule and we don't have to worry about
jurors.
So Barry and I -- Mr. Lee and I talked briefly
about trying to stipulate to certain of the facts, and
I think we should be able to do that because there are
things that are just not in dispute. And I -- we just
haven't done -- I don't think we've done enough work on
that.
THE COURT: Well, I would hope so.
But I have to tell you, given the fact that
the parties cannot even agree on whether all of the
documents should be filed under seal or not and that I

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me, something I never appreciated when I was a lawyer, 11
to stop and start and stop and start on your case
12
because I have to -- it's all fresh in your mind, but I
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have to then go back and pick up where I left off when 14
I'm the finder of fact.
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So I do want to try this efficiently. It
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seems to me that trying the foreclosure action first in 17
its entirety, procedural and substantive, makes sense, 18
but you know how the facts go in, and I don't.
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So that would be my thinking. If there's one
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issue that can be tried first, it ought to be that.
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But if you can't agree on that, we'll have to talk
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more.
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So what's the situation now with the trial
24
date? Have you heard anything from Judge Hamilton, or 25

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is that case still going forward?
MR. SHAPIRO: Right now, yes. She hasn't responded
to our -- my advising her that she's had a trial date
that conflicted with this. But we think that if that
goes, when she set it, she's -- it's only going to be a
two-week trial.
So you may recall I originally asked for the
beginning of July, and then we pushed it back to
June 25th at the defendants' request.
So I still think Mr. Boies' schedule could fit
into that July time frame.
THE COURT: Was the Court -- was it brought to the
attention -- start over.
Did plaintiffs' counsel bring to the Court's
attention the fact that we had a trial set on June 25th
when the -MR. SHAPIRO: Yes.
THE COURT: Before that date was set by Judge
Hamilton? -- I'm sorry, it's by Judge Anderson -- it's
Judge Armstrong, right?
MR. SHAPIRO: No. Judge Hamilton. It's the SAP
trial.
That's not my case. I -- we came in on the
24th. I told my partners we were set for June 25th. I
think they were -- had submitted something that day --

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get, you know, two rounds of briefing on that issue,
I'm really concerned about what the contours of the
pretrial stipulations are going to be, if any.
I know it's a court trial, which gives me more
flexibility, but I am stacked back to back to back with
trials. And so there are going to be trial time limits
set on this, even though we don't have jurors. I don't
have, you know, an endless amount of time for this.
And, also, given the fact that it is a court
trial, not a jury trial, it makes it much harder for

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and this is just what I think happened -- and then they
told Judge Hamilton June 25th is the date for the
Rincon trial. I think that's the order of events.
But, in any event, they told her if -- if they
didn't tell her before, they told her immediately after
you set the date.
THE COURT: All right.
MR. LEE: Your Honor, we need to get this trial
started.
THE COURT: I'm going to keep it at June 25th until
such time as we hear from the federal court that
they're not going to change the date, and then we'll
have to go from there. But at this point I'm going to
keep it at that date.
MR. LEE: Our issue, as we just highlighted briefly
in our submission today -- and I apologize for the
lateness. We just didn't get plaintiffs' until Friday.
We didn't know we were submitting anything -- we have
already scheduled our, particularly, third-party
witnesses, most of whom are on the East Coast. You
know, we've got them in a two-week window,
two-and-a-half-week window, as well as our experts.
I have great respect for Mr. Boies, but I've
got trial set -- a very large trial beginning August 7.
I've got a week arbitration beginning August 27th.

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Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
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Starting in July, knowing how these cases work -- and I
actually personally have to prepare for the trial. I
don't just pick the file up and go in -- we are -- very
vigorously oppose anything moving off June 25. This
has been scheduled many times.
THE COURT: At this point I'm not going to change
it.
MR. LEE: Okay.
THE COURT: And I understand that there's been a
request to change a trial date that was set after ours
was. No response has been given to that. So at this
point I'm just going to keep the date on the 25th; and,
pending something further, that's what I'm going to do.
Because I don't know what to do otherwise. Otherwise,
it's just too much of a moving situation.
If we hear something to the contrary, I have
to deal with it. But right now I'm going to keep it at
the 25th.
MR. SHAPIRO: Mr. Lee said something -- and I think
that makes sense, said something that triggered a
thought, and that is he's talked about third-party
witnesses being scheduled.
I don't know whether I should make a motion to
ask for this or we can just get a commitment -- because
we would do the same -- if either side is going to be

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I think we need the additional time. We've
had a lot of discovery disputes, and there are
scheduling issues, and I don't see any reason why we
have to cut it off earlier than what the code provided.
MR. LEE: And our view is, as has been the case in
this case, every deadline that gets set, things get
done right up until the end of it. And this is a big
case, with significant issues, legal and factual, and
there's no reason the parties can't get their fact
discovery done early, earlier than the code. It will
permit a better-prepared case for your Honor to try.
THE COURT: Okay.
MR. LEE: It's as simple as that.
MR. SHAPIRO: If there were no disputes, I would
agree with Mr. Lee. But the problem is that when
there's a dispute, it doesn't get resolved in two days.
There's always briefing, waiting, making sure Judge
Garcia is available. So it's weeks long.
So I think that, in a perfect world, yeah,
everything would be smooth.
THE COURT: How much more fact discovery needs to
be done? Are there more depositions to be -MR. SHAPIRO: There are some more, not a lot more.
THE COURT: Are they all noticed?
MR. SHAPIRO: We're going to serve a few more

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calling live witnesses who have not been deposed, for
whatever reason, I would like the opportunity to depose
anybody who is going to be called as a witness who has
not been deposed. If I'm going to do that, I'll be
happy to tell the defendants, you know, so-and-so
witness is going to come and testify live.
I hope I don't have to make a motion to ask
for that.
THE COURT: Is that acceptable?
MR. LEE: I think it will be, but let me discuss
with -- we have a very involved client.
THE COURT: All right. Okay.
Well, let's go over dates -- well, actually,
let me back up for just a minute.
You're in agreement on a lot of these dates,
except that the plaintiffs are -- the only ones that
you're not in agreement on are where the plaintiffs
have indicated that they want to follow what the Code
of Civil Procedure would require and defendants
proposed earlier dates, for example, fact and expert
discovery cutoffs and motions -- I guess those were the
two things -- relating to those.
What's the issue here? About a month apart, I
guess.
MR. SHAPIRO: Right.

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deposition notices on some Federal Reserve Bank/Maiden

Lane witnesses. There's a motion we have to make to
compel Bank of America -- they're not here -- to
produce documents, but that's not more depositions.
And there are probably a few more document disputes.
THE COURT: Okay. And did you have more
depositions you'll be taking?
MR. LEE: Yes. But I believe -- I don't want to
misspeak. I believe all of the remaining we're
interested in have already been noticed and subpoenaed.

Not blaming anyone on that side, but there's
one of the four law firms that are representing the
plaintiffs now had just recently asked for a number -three depositions that were scheduled to be moved
because of her schedule. I'm happy to do that. So I
don't know when they're going to start.
But I don't believe there are any remaining
witnesses that we have not already subpoenaed with
notices of deposition. The dates are moving a little
bit.
THE COURT: Well, the defendants are proposing
April 30th as the cutoff; the plaintiffs are proposing
May 28 as the cutoff for discovery.
Is it possible to aim to have it all completed
by April 30th, notwithstanding that the deadline is

BEHMKE REPORTING AND VIDEO SERVICES, INC.
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(5) Pages 17 - 20

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
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May 28th? Is that a doable thing, to try to schedule
all remaining discovery so that it happens in April?
MR. SHAPIRO: We'll certainly try.
THE COURT: Does that work for defendants?
MR. LEE: Yes, that was -- yes.
THE COURT: Okay. So the goal will be to get
everything done by April the 30th, that will be the
completion of all depositions by that time.
Then expert discovery, May the 28th versus
June the 11th. Can you aim to have all the expert
discovery done by May the 28th?
MR. SHAPIRO: Well, yes. It looks like the
defendants take the position that the expert exchange
identifications back last year was it. I know we have
one more -- one different expert than we had.
THE COURT: Have you disclosed that person?
MR. SHAPIRO: Not yet. I mean, well, they know
because we're actually trying to get him to go inspect
the property. We have a motion about that because we
have not been able to get him to be able to go inspect
the property.
THE COURT: Has the name been disclosed?
MR. SHAPIRO: I don't know because it's not my
witness, and I haven't been talking to this -THE COURT: No, the name has not been disclosed.

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Page 21 BEHMKE REPORTING AND VIDEO SERVICES, INC.

two sides. So it's -- you know, it's quite a few
people. We can certainly try.
THE COURT: Okay. Well, you've got two months
before it's May 28th. Okay.
And then the hearing on motions, you have made
the 8th versus -- I'm sorry, June the 8th versus June
the 15th, which is the code.
MR. LEE: That's for expert discovery -THE COURT: Right.
MR. LEE: -- hearings.
THE COURT: Okay.
MR. LEE: Expert discovery motions.
THE COURT: So I'm going to stick to the code
dates.
So the plaintiffs' proposed date, to the
extent they differ with the defendants' proposed dates,
will be the governing dates -- and the only reason for
that is that they do comply with the Code of Civil
Procedure -- with the understanding that the parties
are going to try to complete fact and expert discovery
by April 30th and May 28th, respectfully.
MR. LEE: Point of clarification.
THE COURT: Sure.
MR. LEE: On our chart, which is, I think, kind of
easy to look at because it's got our proposal,

Page 22 BEHMKE REPORTING AND VIDEO SERVICES, INC.

MR. LEE: The answer is no.
MR. SHAPIRO: It's Paul Habibi. He's a professor
at UCLA.
THE COURT: Paul Habibi?
MR. SHAPIRO: Paul Habibi. That's a person who
comes to mind.
I assume, from what the defendants say, that
they have no other experts they're planning to
disclose.
MR. LEE: We see what this designation is. And
it's not our contention that the exchange occurred; it
did occur back at the first time.
I understand they're looking to supplement. I
fully expect the Court to grant that request.
THE COURT: Okay.
MR. LEE: And once we see what they're designating,
it may be that we want somebody to rebut that. I don't
know right now.
THE COURT: Okay.
MR. LEE: But all of our experts have been
disclosed.
THE COURT: Well, can you aim to have the expert
discovery completed by May the 28th?
MR. SHAPIRO: We can certainly try. I think there
were a total of about ten experts listed between the

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Page 23

Page 24

plaintiffs' proposal, and the code, if you -- fifth box
from the bottom of the first page, last date to serve
opposition to motions in limine -- well, it's actually
just serve motions in limine, both parties have agreed
to the 1st. So I assume that stands and it won't be
supplanted by the code.
THE COURT: That's right.
MR. LEE: If they agree, then we'll go with the
agreement?
THE COURT: Absolutely.
MR. LEE: Okay.
THE COURT: So I'm basically -- if you just look
down that center column that you have, plaintiffs'
proposed dates, those are the dates that I'm adopting.
In all except four instances, those are also
defendants' proposed dates. To the extent you've
stipulated around the code or local rule requirements,
that's completely fine with me.
MR. LEE: Okay. I just wanted to make sure.
THE COURT: Let me say something about motions
in limine, and I'm probably going to give a written
order about all of this, but I'm not expecting there
will be very many, given that this is a court trial,
and -- all right.
Having said that, you must meet and confer

BEHMKE REPORTING AND VIDEO SERVICES, INC.
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(6) Pages 21 - 24

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
BEHMKE REPORTING AND VIDEO SERVICES, INC.

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before you file motions in limine. So you have to
disclose to each other what the substance is of the
motion and see if there's an agreement. Only if you
cannot agree can you file a motion in limine. Then you
must attach a declaration saying that you did provide
notice, that you did meet and confer, and that you
couldn't reach an agreement under penalty of perjury.
Do not repeat the mistakes made by the lawyers
in the following case: Kelly versus New West, 49
Cal. App. 4th 659 at 670, which is a 1996 case, which
says, and I quote, "Many of the motions filed were not
properly the subject of motions in limine, were not
adequately presented, or sought rulings which would be
declaratory of existing law or would not provide any
meaningful guidance for the parties or witnesses,"
closed quote.
So don't file a motion that says exclude
hearsay or things that don't have foundation. Please
don't file a motion saying there should be a 24-hour
disclosure. That is going to be the rule -- or maybe
more than that. You don't need to file a motion that
excludes witnesses who haven't yet testified.
And if you do make a motion to exclude certain
testimony, you just have to be really, really specific
as to what the testimony is.

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Page 25 BEHMKE REPORTING AND VIDEO SERVICES, INC.

We've advanced our reasoning.
THE COURT: Okay. Mr. Shapiro, you want more time
to talk to counsel about this?
MR. SHAPIRO: We may be able to do that. But I'd
like to talk to Mr. Lee about it. Because sometimes
you can agree to a concept, and then each one of you
has a completely different idea of what that entails.
THE COURT: I know.
MR. SHAPIRO: So I would like -- I will try to be
as specific with him as possible about what I think
that means.
THE COURT: Okay. Let's pick a date by which you
can present in writing to me an agreed-upon proposal
for trying the case in something other than the whole
thing. And if you can agree and it makes sense, I'll
go along with it.
When can you do that?
MR. SHAPIRO: Can we have at least two weeks, maybe
three?
THE COURT: You need three weeks?
MR. SHAPIRO: I don't know. I mean, we can -- you
know, I could always say we couldn't do it. I can try
in two weeks. I think, to think through, since we have
to go first -- or we get to go first, I think I want to
make sure I --

Page 26 BEHMKE REPORTING AND VIDEO SERVICES, INC.

And I also refer you to Amtower,
A-m-t-o-w-e-r, versus Photo Dynamics, 158 Cal. App. 4th

1582 at 1593 to 1596. It's a 2008 case, which also
describes the proper uses of motions in limine.
To the extent you do file any, please number
them sequentially -- so plaintiffs' motion in limine 1,
opposition to motion in limine 1 by the defendant -- so
I can keep track of them. And, please, if you moved
for -- if you make a motion in limine, provide a chart
with all the motions that you've requested for ruling.
Now, I know that last point makes it sounds
like I'm expecting a lot. I'm really not. But I like
to be able to keep them straight. So that's the
motions in limine.
What shall we do here about -- to the
extent -- to what extent we're going to bifurcate this
trial?
MR. LEE: Your Honor, our position, which is laid
out, we do think that if we're going to try -- there
may be some advantage to trying the foreclosure,
procedural and substantive, and the June 2009 default
issues first.
If plaintiffs are not amenable to that, let's
just go to trial, put the witnesses on, and we'll
cross-examine and put our witnesses on.

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Page 27

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MR. LEE: I'll go first.
MR. SHAPIRO: I want to make sure that I have
thought through each thing. But if I could have two
weeks, that would be -THE COURT: All right. You can have two weeks.
MR. SHAPIRO: Okay.
THE COURT: So two weeks from today?
MR. LEE: Is the 9th of April.
THE COURT: 9th of April.
So two weeks from today, give the Court a
detailed written agreement as to how the case will be
bifurcated. If you can agree, great. If you can't,
maybe I'll come up with something. But, more likely,
we'll try the whole thing.
Is there anything further for today?
MR. LEE: No.
MR. SHAPIRO: No, your Honor.
THE COURT: Okay. I'll set a future case
management conference after receiving the April 9th
submission if it seems like it's required.
Okay. Thank you very much. We're off the
record.
(The proceedings concluded at 9:51 a.m.)

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[phone]

(7) Pages 25 - 28

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
BEHMKE REPORTING AND VIDEO SERVICES, INC.

Page 29

1 STATE OF CALIFORNIA
)
2
)
ss
3 COUNTY OF SAN MATEO
)
4
5
I hereby certify that the foregoing in the
6 within-entitled cause was taken at the time and place
7 herein named; that the transcript is a true record of
8 the proceedings as reported by me, a duly certified
9 shorthand reporter and a disinterested person, and
10 was thereafter transcribed into typewriting by
11 computer.
12
I further certify that I am not interested
13 in the outcome of the said action, nor connected
14 with, nor related to any of the parties in said
15 action, nor to their respective counsel.
16
IN WITNESS WHEREOF, I have hereunto set my
17 hand this 26th day of March, 2012.
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MELINDA M. SELLERS, CSR# 10686
23
STATE OF CALIFORNIA
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expert (10)
7:11;18:20;21:9,10,
13,15;22:22;23:8,12,20
experts (4)
16:22;22:8,20,25
extent (7)
5:4;11:12;23:16;
24:16;26:5,16,16
extra (1)
10:2

F
fact (11)
5:1;7:7;11:14;13:23;
14:9,15;15:15;18:20;
19:9,21;23:20
fact-intensive (1)
8:11
facts (5)
7:6,24;13:9,17;14:19
factual (2)
7:3;19:8
fallback (1)
12:22
falls (1)
5:25
February (2)
4:16,19
federal (2)
16:11;20:1
few (3)
19:25;20:5;23:1
fifth (1)
24:1
figure (1)
13:1
file (7)
17:3;25:1,4,17,19,

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

21;26:5
filed (5)
4:3,20;11:20;13:25;
25:11
filing (1)
12:4
financial (4)
7:9;9:23,25;10:4
finder (1)
14:15
fine (1)
24:18
firms (1)
20:12
first (11)
3:23;6:20;13:1;
14:17,21;22:12;24:2;
26:22;27:24,24;28:1
fit (2)
13:14;15:10
flexibility (1)
14:5
Flexner (1)
3:11
flies (1)
4:19
flow (4)
7:3,11;8:12;9:23
flowed (1)
10:3
follow (2)
8:19;18:18
following (1)
25:9
foreclosure (4)
11:24;12:12;14:17;
26:20
forward (3)
5:13;13:7;15:1
foundation (1)
25:18
four (2)
20:12;24:15
fourth (2)
4:12,23
frame (1)
15:11
fresh (1)
14:13
Friday (3)
10:25;13:5;16:17
fully (2)
12:11;22:14
funds (5)
7:4,11;8:12;9:7,24
further (3)
9:19;17:13;28:15
future (1)
28:18

G
Garcia (1)
(2) contours - Garcia

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
19:18
gets (1)
19:6
given (6)
7:15,16;13:23;14:9;
17:11;24:23
gives (1)
14:4
goal (1)
21:6
goes (1)
15:5
Good (9)
3:3,4,5,10,13,14,21;
4:5;5:16
governing (1)
23:17
grant (2)
4:5;22:14
great (2)
16:23;28:12
guess (3)
12:9;18:21,24
guidance (1)
25:15

H
Habibi (3)
22:2,4,5
Hamilton (4)
14:25;15:19,21;16:2
happened (2)
7:15;16:1
happens (1)
21:2
happy (2)
18:5;20:15
hard (1)
9:14
harder (1)
14:10
hear (6)
5:14,15;6:5;11:19;
16:11;17:16
heard (4)
4:7;5:6,18;14:25
hearing (5)
3:25;4:2,13;6:8;23:5
hearings (1)
23:10
hearsay (1)
25:18
Heimberger (8)
3:16,16;4:9,16,18;
6:18,19;11:1
here's (1)
10:3
highlighted (1)
16:15
Honor (13)
3:4,5,10,14;4:8,9;
6:19;11:1,2;16:8;
Min-U-Script®

19:11;26:18;28:17
hope (2)
13:22;18:7
hour (2)
12:9,9

I
idea (1)
27:7
identifications (1)
21:14
III (1)
3:7
immediately (2)
8:1;16:5
inclination (1)
12:20
Incorporated (1)
3:7
indicated (1)
18:18
indicates (1)
13:6
information (1)
10:1
inspect (2)
21:18,20
instances (1)
24:15
interested (1)
20:10
into (3)
8:22;13:5;15:11
investment (1)
3:24
involved (1)
18:11
issue (4)
14:1,21;16:15;18:23
issues (6)
5:3,21;6:22;19:3,8;
26:22

J
Judge (13)
5:6,14;6:5;7:21;
10:10;13:11;14:25;
15:18,19,20,21;16:2;
19:17
judge's (2)
5:8;6:9
judgment (1)
7:25
July (4)
9:5;15:8,11;17:1
June (10)
15:9,15,24;16:2,10;
17:4;21:10;23:6,6;
26:21
jurors (2)
13:15;14:7

jury (2)
12:20;14:10

K
keep (6)
16:10,14;17:12,17;
26:8,13
Kelly (1)
25:9
kind (1)
23:24
kinds (1)
8:10
knew (1)
9:4
knowing (1)
17:1

L
lack (1)
7:22
laid (1)
26:18
Lane (1)
20:2
large (2)
7:23;16:24
last (11)
4:13;6:14,17;10:11;
11:16;12:2,7,17;21:14;
24:2;26:11
lateness (1)
16:17
law (3)
6:7;20:12;25:14
lawyer (1)
14:11
lawyers (1)
25:8
least (1)
27:18
LEE (39)
3:4,14,14;4:15;8:4,4;
9:20;10:18,23;11:21;
12:7;13:16;16:8,15;
17:8,19;18:10;19:5,13,
15;20:8;21:5;22:1,10,
16,20;23:8,10,12,22,
24;24:8,11,19;26:18;
27:5;28:1,8,16
left (1)
14:14
legal (5)
5:4,17,18,24;19:8
Lenard (1)
3:20
less (1)
13:12
light (3)
5:1,6;11:14
likely (1)

28:13
limine (11)
24:3,4,21;25:1,4,12;
26:4,6,7,9,14
limits (1)
14:6
listed (1)
22:25
little (1)
20:19
live (2)
18:1,6
LLC (1)
3:7
local (1)
24:17
lockbox (1)
7:13
long (1)
19:18
look (3)
10:13;23:25;24:12
looked (1)
11:10
looking (1)
22:13
Looks (2)
4:15;21:12
lot (4)
18:15;19:2,23;26:12

M
makes (6)
6:2;14:10,18;17:20;
26:11;27:15
making (3)
6:11;10:9;19:17
management (9)
7:14;10:11,14,19;
11:3,11;12:25,25;
28:19
Manatt (5)
3:15,16,18,20;8:4
many (3)
17:5;24:23;25:11
MARCH (2)
3:1;4:1
matter (1)
3:6
matters (1)
3:22
Maxwell (1)
3:12
may (13)
9:11,11;15:7;20:23;
21:1,9,11;22:17,23;
23:4,21;26:20;27:4
maybe (5)
9:9,21;25:20;27:18;
28:13
mean (3)
12:20;21:17;27:21

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

meaningful (1)
25:15
means (1)
27:11
meet (3)
11:12;24:25;25:6
merit (1)
5:5
might (1)
12:1
mind (3)
5:15;14:13;22:6
minute (2)
10:16;18:14
misspeak (1)
20:9
mistakes (1)
25:8
MONDAY (2)
3:1;13:5
money (4)
7:15;8:21;9:4,12
month (2)
6:17;18:23
months (1)
23:3
more (17)
6:2;7:10;13:4;14:4,
23;19:21,22,23,23,25;
20:4,5,6;21:15;25:21;
27:2;28:13
morning (7)
3:3,4,5,10,13,14,21
most (1)
16:20
motion (30)
3:24;4:5,6,11,21,22;
5:1,3,12;6:9,14,16;7:5,
25;9:16;10:7;11:25;
17:23;18:7;20:2;21:19;
25:3,4,17,19,21,23;
26:6,7,9
motions (13)
6:6;18:21;23:5,12;
24:3,4,20;25:1,11,12;
26:4,10,14
move (1)
4:1
moved (2)
20:14;26:8
moving (3)
17:4,15;20:19
much (5)
9:4;14:10;17:15;
19:21;28:21
must (2)
24:25;25:5

N
name (2)
21:22,25
necessary (2)
(3) gets - necessary

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
7:1,18
need (8)
5:22,22;6:25;7:20;
16:8;19:1;25:21;27:20
needs (1)
19:21
New (1)
25:9
next (1)
4:11
notice (1)
25:6
noticed (2)
19:24;20:10
notices (2)
20:1,19
notwithstanding (1)
20:25
number (4)
3:22;7:24;20:13;
26:5

26:2
pick (3)
14:14;17:3;27:12
plaintiff (2)
5:24;6:10
plaintiffs (13)
3:11,12;4:21;5:13;
6:3;7:23;9:4,22;18:16,
17;20:13,22;26:23
plaintiffs' (7)
10:4;15:14;16:17;
23:15;24:1,13;26:6
planning (2)
11:4;22:8
plays (1)
P
9:21
please (4)
3:9;25:18;26:5,8
page (1)
pled (1)
24:2
7:6
papers (3)
point (10)
4:3;5:11;6:21
5:16;6:20,23;9:18;
part (3)
10:5;16:13;17:6,12;
O
7:23;8:11,24
23:22;26:11
partial (1)
portions (3)
4:4
obviously (2)
4:12,23;6:15
9:15,25
particular (1)
position (2)
occur (1)
6:15
21:13;26:18
22:12
particularly (2)
possibility (1)
5:1;16:19
occurred (1)
11:23
parties (8)
22:11
possible (2)
October (1)
4:1;11:12;13:1,24;
20:24;27:10
9:5
19:9;23:19;24:4;25:15
possibly (1)
partners (1)
off (6)
12:3
15:24
10:3,15;14:14;17:4;
precluded (1)
19:4;28:21
Paul (3)
6:7
once (2)
22:2,4,5
precludes (1)
12:23;22:16
pay (1)
6:10
8:23
one (10)
prejudice (1)
6:5,20;8:5;9:2;11:4;
penalty (1)
10:8
14:20;20:12;21:15,15;
25:7
prepare (2)
27:6
pending (1)
8:9;17:2
17:13
ones (1)
prepared (1)
18:16
people (2)
12:18
only (5)
10:2;23:2
present (2)
9:20;15:5;18:16;
perfect (1)
8:21;27:13
19:19
23:17;25:3
presented (1)
open (1)
perhaps (1)
25:13
5:15
10:15
pretrial (2)
opportunity (1)
period (2)
11:13;14:3
8:12;9:21
18:2
pretty (1)
oppose (1)
perjury (1)
9:10
17:4
25:7
previous (1)
opposition (3)
permit (1)
4:24
19:11
4:4;24:3;26:7
prior (1)
person (2)
order (6)
6:9
4:10;5:9;7:8;10:10;
21:16;22:5
PRITT (2)
16:3;24:22
personally (1)
3:12,12
17:2
original (1)
probably (2)
phasing (1)
7:5
20:5;24:21
originally (3)
13:12
problem (1)
3:25;4:14;15:7
Phelps (3)
19:15
otherwise (4)
3:15,16,18
problems (1)
Photo (1)
7:1,17;17:14,14
Min-U-Script®

ought (2)
9:7;14:21
Ours (2)
11:18;17:10
ourselves (1)
6:23
out (7)
5:25;8:23;9:7,21;
10:3;13:1;26:19
over (4)
6:8;11:10;15:13;
18:13
owned (1)
9:22

8:5
procedural (3)
12:14;14:18;26:21
Procedure (2)
18:19;23:19
proceed (2)
6:4;8:2
proceedings (1)
28:23
produce (1)
20:4
professor (1)
22:2
proper (1)
26:4
properly (1)
25:12
property (3)
9:22;21:19,21
proposal (3)
23:25;24:1;27:13
proposed (10)
11:15,17,20;12:10,
16;18:20;23:15,16;
24:14,16
proposing (2)
20:21,22
prove (1)
7:8
proven (1)
5:21
provide (3)
25:5,14;26:9
provided (1)
19:4
pushed (1)
15:8
put (10)
5:22,23;6:1,3,25;
7:18,24;12:20;26:24,
25

Q
quite (1)
23:1
quote (2)
25:11,16

R
raise (2)
7:7;8:8
raised (3)
5:3;6:21;11:23
rather (1)
8:11
reach (2)
9:9;25:7
read (5)
4:3,20;5:8,8;11:7
really (14)
5:20;8:6,8,25;9:4,14,

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

17;12:13;13:6,7;14:2;
25:24,24;26:12
Realty (1)
3:6
reason (4)
18:2;19:3,9;23:17
reasoning (1)
27:1
reasons (1)
6:16
rebut (1)
22:17
recall (1)
15:7
received (3)
10:12;11:11;12:21
receiving (2)
13:4;28:19
recently (1)
20:13
recess (2)
11:8,9
recognized (1)
11:25
record (2)
10:15;28:22
refer (1)
26:1
regardless (1)
8:24
relating (1)
18:22
relevant (1)
9:18
remain (1)
5:5
remaining (3)
20:9,17;21:2
repeat (2)
6:23;25:8
report (1)
3:25
reported (1)
10:20
representing (1)
20:12
request (3)
15:9;17:10;22:14
requested (3)
4:1;11:3;26:10
require (1)
18:19
required (1)
28:20
requirements (1)
24:17
reserve (3)
7:14;8:22;20:1
resolved (1)
19:16
resources (1)
5:16
respect (2)
(4) need - respect

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
11:21;16:23
respectfully (1)
23:21
respond (1)
8:17
responded (1)
15:2
response (1)
17:11
review (1)
10:16
right (19)
4:10;7:21;8:15;10:6;
11:8,10;12:6;15:2,20;
16:7;17:17;18:12,25;
19:7;22:18;23:9;24:7,
24;28:5
Rincon (3)
3:6,7;16:3
room (1)
12:20
rounds (1)
14:1
rule (2)
24:17;25:20
ruled (2)
5:14;6:5
ruling (5)
5:6;10:6,7;11:25;
26:10
rulings (1)
25:13

5:21;6:2;14:18;
17:20;27:15
sent (2)
11:17;12:7
separate (1)
6:1
sequentially (1)
26:6
serve (3)
19:25;24:2,4
set (11)
3:25;14:7;15:5,15,
18,24;16:6,24;17:10;
19:6;28:18
shall (1)
26:15
SHAPIRO (33)
3:5,10,11;4:8;8:16,
17;10:21,25;11:15;
13:8;15:2,17,21;17:19;
18:25;19:14,23,25;
21:3,12,17,23;22:2,5,
24;27:2,4,9,18,21;28:2,
6,17
short (2)
11:8;12:9
showing (1)
13:13
shown (1)
4:5
side (2)
17:25;20:11
sides (1)
23:1
S
sign (1)
4:10
Same (2)
significant (1)
3:20;17:25
19:8
SAP (1)
simple (2)
15:21
9:10;19:13
saw (2)
simpler (1)
11:4;12:13
8:2
saying (4)
simplest (1)
8:20;10:3;25:5,19
3:23
schedule (10)
situation (2)
11:6,15,17,20;12:7,
14:24;17:15
16;13:14;15:10;20:15;
smooth (1)
21:1
19:20
scheduled (4)
so-and-so (1)
16:19;17:5,22;20:14
18:5
scheduling (1)
somebody (1)
19:3
22:17
Schiller (1)
sometimes (1)
3:11
27:5
seal (3)
sorry (2)
3:24;4:6;13:25
15:19;23:6
Section (2)
sort (2)
5:5,10
7:12;12:14
seemed (1)
sought (1)
5:23
25:13
seems (6)
sounds (1)
5:10,15,20;9:10;
26:11
14:17;28:20
specific (2)
sense (5)
Min-U-Script®

25:24;27:10
spending (1)
12:24
stacked (1)
14:5
stage (1)
5:12
stand (2)
5:9,17
stands (1)
24:5
start (6)
3:23;6:8;14:12,12;
15:13;20:16
started (1)
16:9
Starting (1)
17:1
stated (2)
6:13,17
Statement (2)
10:14;12:13
statements (9)
7:10;9:13,23,25;
10:1,4;11:3,11;13:5
stay (3)
6:25;7:19,19
stick (1)
23:13
still (2)
15:1,10
stipulate (3)
13:9,10,17
stipulated (1)
24:17
stipulation (2)
8:2;9:9
stipulations (2)
7:22;14:3
stop (2)
14:12,12
straight (1)
26:13
strike (9)
4:11,21,22;5:4,12;
6:14;9:16;10:7;11:25
subject (3)
6:16;11:13;25:12
submission (2)
16:16;28:20
submit (1)
10:5
submitted (2)
7:20;15:25
submitting (2)
11:4;16:18
subpoenaed (2)
20:10,18
substance (1)
25:2
substantial (1)
7:2
substantive (2)

14:18;26:21
summary (3)
6:10;7:25;10:10
supplanted (1)
24:6
Supplement (2)
10:13;22:13
support (2)
4:3,22
supports (1)
5:18
sure (10)
8:3,13,18,25;10:21;
19:17;23:23;24:19;
27:25;28:2
surreply (2)
4:20,22

T
talk (4)
12:9;14:22;27:3,5
talked (4)
11:22;12:2;13:16;
17:21
talking (3)
12:14;13:6;21:24
ten (1)
22:25
tenants (1)
8:22
tentative (6)
4:4,25;6:11,13;9:16;
10:6
testified (1)
25:22
testify (1)
18:6
testimony (3)
7:11;25:24,25
theirs (2)
10:25;11:4
Therefore (1)
8:9
thinking (1)
14:20
third-party (2)
16:19;17:21
though (2)
11:24;14:7
thought (5)
4:25;6:12;11:5;
17:21;28:3
three (3)
20:14;27:19,20
Thursday (1)
12:17
times (2)
6:22;17:5
time-saver (1)
13:8
today (7)
4:2;8:18;12:4;16:16;

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

28:7,10,15
told (4)
15:24;16:2,4,5
total (1)
22:25
Towers (1)
3:7
track (1)
26:8
trial (28)
5:2,21;6:6,9;9:21;
10:9,9;11:14,19;13:12;
14:4,6,10,10,24;15:3,6,
15,22;16:3,8,24,24;
17:2,10;24:23;26:17,
24
trials (1)
14:6
tried (1)
14:21
triggered (1)
17:20
true (1)
7:8
try (15)
5:16;12:22;13:1,1;
14:16;19:11;21:1,3;
22:24;23:2,20;26:19;
27:9,22;28:14
trying (8)
5:24;8:8;11:23;
13:17;14:17;21:18;
26:20;27:14
Tuesday (2)
11:16;12:7
two (11)
14:1;18:22;19:16;
23:1,3;27:18,23;28:3,5,
7,10
two-and-a-half-week (1)
16:22
two-week (2)
15:6;16:21

U
UCLA (1)
22:3
under (2)
13:25;25:7
understood (1)
12:12
up (6)
13:13;14:14;17:3;
18:14;19:7;28:13
use (1)
5:16
uses (1)
26:4

V
versus (6)
(5) respectfully - versus

Reporter's Transcript of Proceedings
March 26, 2012

Rincon EV Realty, LLC, et al. v.
CP III Rincon Towers, Inc., et al.
3:7;21:9;23:6,6;
25:9;26:2
view (5)
4:4,25;6:13;7:2;19:5
vigorously (1)
17:4

W
wait (1)
4:18
waiting (1)
19:17
walk (1)
13:5
waterfall (1)
7:12
way (5)
5:9;8:2,21;9:7;13:3
Wednesday (2)
11:16;12:8
week (4)
11:16;12:8,17;16:25
weeks (8)
19:18;27:18,20,23;
28:4,5,7,10
WEISS (2)
3:20,20
weren't (2)
11:2,3
West (1)
25:9
what's (2)
14:24;18:23
whole (3)
12:22;27:14;28:14
window (2)
16:21,22
wish (2)
4:7;6:3
without (1)
10:8
witness (3)
18:3,6;21:24
witnesses (9)
16:20;17:22;18:1;
20:2,18;25:15,22;
26:24,25
work (3)
13:20;17:1;21:4
world (1)
19:19
worry (1)
13:14
worth (1)
12:24
writing (1)
27:13
written (2)
24:21;28:11

year (2)
7:10;21:14

25:9
4th (2)
25:10;26:2

1
6
1 (2)
26:6,7
11th (1)
21:10
158 (1)
26:2
1582 (1)
26:3
1593 (1)
26:3
1596 (1)
26:3
15th (1)
23:7
16th (1)
4:1
1996 (1)
25:10
1st (1)
24:5

659 (1)
25:10
670 (1)
25:10

7
7 (1)
16:24
726 (7)
5:5,10,23;6:1,4;8:7,
24

8
8th (2)
23:6,6

9
2

2008 (1)
26:3
2009 (1)
26:21
2010 (1)
9:5
2012 (1)
3:1
24-hour (1)
25:19
24th (4)
4:15,16,19;15:24
25 (1)
17:4
25th (7)
15:9,15,24;16:2,10;
17:12,18
26 (1)
3:1
27th (1)
16:25
28 (1)
20:23
28th (6)
21:1,9,11;22:23;
23:4,21

9:05 (1)
3:1
9:51 (1)
28:23
9th (3)
28:8,9,19

3
30th (4)
20:22,25;21:7;23:21

4

Y
49 (1)
Min-U-Script®

BEHMKE REPORTING AND VIDEO SERVICES, INC.
[phone]

(6) view - 9th