Phaedra Parks Deposition Took Place in July of 2014

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PHAEDRA C. PARKS vs.
ANGELA STANTON
IN THE STATE COURT OF GWINNETT COUNTY
STATE OF GEORGIA
PJIAEORA C. PARKS,
Plaintiff,
CIVIL ACTION
vs.
Page 1
FILE NO. 12-C-06313-53
ANGELA STANTON,
Defendant.
DEPOSITION OF
PHAEDRA C. PARKS
Thursday, June 19, 2014
1:21 p.m.
104 Marietta Stroot
Atlanta, Georgia
Linda C. Ruggori, CCR-A-261
DEFENDANT'S
EXHIBIT
Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
PHAEDRA C. PARKS
June 19, 2014
TABLE OF CONTENTS
DESCRIPTION
Linkodin Profile for
Phaedra c. Parks
Page 3 i
t'AGE i
20
2013 Corporation Annual 50
Registration for Nida Fitnoss, Inc.
Aztj;cles of Incoz:poration 63 j
National Recovery Group Inc. '
Photo9raph
Photograph
Article entitled "Apollo Nida
Responds to Angela Stanton's
Accusations"
May 17, 2014
Lotter - June 19, 2014
Radford to Parks
81
83
117
147
(Original Exhibits l through 7 havo been attachod i
to tho original transcript.) I
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1
-------i------ -----
.i
APPEARANCES OF COUNSEL
On behalf of tho Plaintiff:
PAUL E. ANDREW, Esq.
LEANNA a. RUOTANEN, Esq.
Andrew, Morritt, Reilly & Smith
Seven Lumpkin Stroot
Lawrenceville, Georgia 30046
770-513120.0
CHRISTOPHER T. PORTIS, Esq.
Law Offices of Christopher T. Portis
3384 Peachtree Stroot
Suite 250
Atlanta, Georgia 30326
On behalf of the Defendant:
JAMES E. RADFORD, JR., Esq.
James E. Radford, Jr., LLC
545 North McDonough Street
Suite 212
Docatur, Goorgia 30030
678-369-3609
Also Present:
Ms. Angela Stanton
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(Reporter disclosure made pursuant to
Article 10.B of the Rules and Regulations of the
Board of Court Reporting of the Judicial Council
of Georgia.)
MR. ANDREW: Put on the record just
briefly you and 1 have an agreement about no use
of the deposition outside the context of the
litigation and blogging about it. blah, blah,
blah.
MR. RADFORD: Sure. I think we've got a
document to that effect so --
MR. ANDREW: We do.
MR. RADFORD: -- I think that will speak
for itself.
This will be the deposition of Phaedra
Parks, taken in the matter of Parks versus
Stanton, currently pending in the State Court of
Gwinnett County, Georgia, taken pursuant to
notice and agreement of the parties. for all
purposes allowable under the Georgia Rules of
Evidence and the Georgia Rules of Civil
Procedure. And I'll ask my opposing counsel if
we agree to the standard reservation of
objections, except as to the form of the question
and the responsiveness of the answer.
.JPA Reporting, LLC- (404) 853-1811 (I) Pages I - 4
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ANGELA ST ANTON
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MR. ANDREW: That is fine. And I guess to
amplify, too, that the only way this thing is
being recorded today is through our court
reporter.
MR. RADFORD: As far as I know. If you
guys aren't recording it any other way, we aren't
either.
MR. ANDREW: Okay. Super.
MR. RADFORD: All right.
PHAEDRA C. PARKS,
having been first duly sworn, was examined and
testified as follows:
CROSS-EXAMINATION
BY MR. RADFORD:
Q. Ms. Parks. thank you for being he.re .today.
My name is James Radford. I'm an attorney. I
represent Angela Stanton, who is a defendant in a
lawsuit that you have filed. And as part of the
discovery process for that lawsuit, I'd like to ask
you a series of questions today.
For the record, coutd you state your tuft
name.
A. Phaedra C. Parks.
.Q. AH right. Ms. Parks, where {lo you
reside?
Page6
r11 A. My mailing address is 3384 Peachtree Road,
21 Northeast. No. 250, Atlanta, Georgia 30327.
[3]
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(6J
Q, Okay. Is that your residential address?
A. That is not.
Q. Where do you reside physically?
A. I reside in Fulton County.
c11 Q. That mailing address that you gave me,
rsJ where does that address go to?
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A. That is my office.
Q. All right. Have you ever lived in
Gwinnett County?
A. No, I have not.
Q. Okay. Do you have any family in Gwinnett
County?
A. Not that I know of.
Q. So no immediate family, at least?
A. No immediate family.
a. All right. Are you a member of any
churches in Gwinnett County?
A. No, sir.
Q. Okay. A member of any charitable
organizations that operate out of Gwinnett County?
A. No, sir, not that I know of. I'm a member
of several charitable organizations but none that l
know that operates specifically out of Gwinnett.
PHAEDRA C. PARKS
.June 19, 2014
Page 7 1
c11 Q. Okay. Do you do substantial business with !
c21 anyone in Gwinnett County?
[3] A. No, sir.
c 4 l Q. All right. Ms. Parks, you are an
[SJ attorney, is that right?
61 A. I am.
[71 Q. All right. So I imagine you're basically
[81 familiar with the deposition process, is that true?
C9l A. Yes, sir.
c10J Q. Okay. So I won't give you the standard
c111 instructions I give to witnesses. I will assume that
c121 you understand the basic ground rules.
Cl3J Is your legal name Phaedra Parks?
[141 A. Yes, sir. It's Phaedra Parks Nida.
US} Q.. Old you !1ave a JegaJly .cilaAged upon your
[HJ marriage to Mr. Nida?
Cl7J A. Yes.
181 Q. And when did you marry Mr. Nida?
[191 A. November the 1st, 2009.
r201 Q. Your lawsuit sounds in defamation. is that
1211 correct?
c221 A. I believe so.
C23J Q. Okay. And you have alleged that my :
[241 client, Ms. Stanton, has published things about you I
[251 that are untrue and that have damaged your reputation, I
'
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Page 8
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r11 is that correct?
c21 A. That is correct.
[31 Q. All right. And part of your reputational
f4l damage relates to your reputation as an attorney, is i
[SJ that correct? :
c 61 A. That is correct. .
[7J Q. So I want to ask you some questions about !
{8] your legal practice and your history as an attorney. r
c 9J When did you first become licensed to practice law?
c101 A. In 1999. !
[lll Q. All right. And have you maintained a law l
r121 practice from that point forward, from 99 forward?
Cl3l A. Could you be more specific as to what you
[141 mean, a law practice?
c1s1 Q. Have you actively practiced law from '99
Cl6J forward?
c111 A. Yes, sir.
[18] Q. And do you actively practice law today?
[191 A. Yes, sir.
c201 Q. You have never been formally disciplined,
c211 correct?
r221 A. No, sir.
f23J Q. In addition to your law practice - well,
[24] let me ask you this: How would you describe your
c2s1 occupation?
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JPA Rc1>orting, LLC - (404) 853-1811 (2) Pages S - 8
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ANGELA STANTON
c11 A. I am a lawyer.
Page9
c21 a. Okay. You're also a cast member on a
C3J television show, is that right?
41 A. That is correct.
[Sl Q, And how long have you been a cast member
c 61 of that show? When did that begin?
C7l A. In 2010.
C8l Q, And is that something that you're paid
C9l for?
c101 A. Yes, sir.
Clll Q. And that show is called Real Housewives of
c121 Atlanta, is that correct?
(131 A. Yes, sir_
[141 Q. And if this has changed from year to year,
c1s1 you can let me know; but from the time you began
[161 your -- I don't know if "occupation" is the right
c i 11 word, but from the time you began your work on the
(181 television show to the present day, how much of your
[191 work time has been dedicated to the television show
c201 versus how much has been dedicated to your law
(211 practice, in your best estimation?
c221 A. I'm a full-time lawyer. I work Monday
(231 through Friday as a lawyer full-time.
(241 Q. Forty hours a week?
c2s1 A. Yes, sir, if not more.
Page 10
c11 Q. And the television show, are you involved
r21 in activities with the show during the workweek as
[31 well?
C4J A. Sometimes.
[SJ Q. Okay. Does the show have a standard
{6J shootJng schedule? I imagine they don't shoot all
c11 year?
C8l A. That is correct.
C9l Q. Okay_ Whafs the standard shooting
c101 schedule for the show?
c111 A. It depends on which year you're referring
u21 to. ttchanges periodicatty. You know, it changes
[13] depending on when the production company decides to
(141 record.
c1s1 a. Okay. Let's say the most recent season of
161 the television show_
c111 A. Yes, sir.
(181 Q. Do you recan about when estimated
[19] beginning and end dates the production for that show
c201 took place?
c211 A. When you say "production," could you be
c221 very specific as to -
I [231 Q. Anything you were involved in. Like there
PHAEDRA C. PARKS
June 19, 2014
. --- -- . 11 .,
Cll far as activities for the television show that you
C2l were involved in for the previous season, the most i
[31 recent season, approximately when were you involved in I
c 4 J that date-wise? !
cs1 A. For the season that just past, season six.I
c 61 I would have been involved from early summer to fall.
c11 Q. Like June to September?
1
81 A. June to, we'll say, October.
C9l Q. And have previous seasons been different
1101 than that in terms of when you were involved?
1111 A. Yes, sir.
c121 a. Okay. So the season directly prior to
[13] that, how was that different?
141 A. It might be a different start and end
c1s1 time.
Cl6J Q. Okay. Well, so specifically? So if last
[l 7) season was June through October, the previous season
[l8J was May to September or something totally different?
Cl9l A. I don't recall. I can get that
c201 information to you if you need it. but I don't
c211 specifically recall. But it's normally during the
c221 summer.
[231 Q. Okay. Is it typically summer to fall but
[241 just different specific start and end times?
c2s1 A. Yes, usually.
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Page 12 l
Q. Okay. During shooting, how often do you
C2l shoot during the week, if you could estimate, how many
hours?
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A. It depends. Maybe three days a week,
maybe four.
Q. Okay.
A. It just depends. It varies.
Q. And are those full work days?
A. Not always. It depends on the schedule.
Q. And, again, this may have changed over
time and you can tell me if that's true. Roughly what
percentage of your income do you derive from the
tefevision show versus your taw practice?
A. I would really have to calculate that, so :
I don't want to give you the wrong answer. So I could l
obviously amend the answer later if that works for I
you. !
a. l mean, just for now r your best estimate. i
We'll stipulate that, you know, it's not precise, but :
just your best estimate. Is that a 50/50 kind of deal !
or a 20/80 kind of deal or what? I
A. We'll say 50/50_
a. Okay. And do you have other sources of
income beyond the law practice and the television
show?
I
(24 l may have been preproduction or editing later and you
t25J weren't involved in that. I understand that. But as
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.JPA LLC- (404) 853-1811 (3) Pages 9-12
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ANGELA STANTON
Page 13
[1] A. Yes, sir.
[2) Q. What are those other sources of income?
[3] A. Public speaking.
[4] Q. Okay. Anything else?
[5] A. I have other businesses as well.
[6] Q. Okay. What sort of other businesses?
[7] A. I have a production company and I also
[8] have a -- you know, I have my own book; so I'm an
[9) author as well.
[10) Q. Okay. So you make money selling your
[11) book, right?
[121 A. I do.
[13) Q. And you say a production company. What is
[14] the name of the production company?
[15] A. Sweet Pea Productions.
[16] Q. Sweet Pea?
[17] A. Uh-huh.
[18] Q. And what sort of things do you produce?
[19] A. It varies. It just depends on what
[20) projects are presented to me.
{21) Q. So an example would be?
[22) A. I've produced TV shows.
[23] Q. Okay. Any shows that I would be familiar
[24) with? Or I guess that's a bad way to ask the
[25) question. What's an example of a TV show that you've
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PHAEDRA C. PARKS
June 19, 2014
---- 1s!
was pregnant and I was in school and I had a baby. l
Q. Okay. So 2011?
A. I would have to check on that, but I have :
done some things. But I just don't want to obviously I
misspeak. I
Q. Right And I'm not going to hold you to i
it. Just sort of your best estimate is - I
A. We'll say 5 percent. :
a. Okay. So the majority of your revenue
comes for the past four years or so from your law
practice and the TV show, is that fair to say?
A. Correct; yes, sir. ,
a. How much do you get paid for the TV show? I
A. I will not be answering that.
1
Q. What's your basis for not answering that?
A. I won't be answering it.
Q. You're just going to refuse?
A. Yes, sir.
a. Okay. In 2013 how much did you derive
from your law practice? .
A. I'm not my own accountant, so I would have i
to obviously amend those answers.
a. What would be your best estimate?
A. I won't be estimating it.
Q. So you can't or you won't?
i
. . .
Page 16 :
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Cll recently produced? [ll A. I can't. I'm not an accountant. I
c21 A. Tiny and Toya. That wasn't recent. c21 Q. You have no rough figure of how much money i
CJJ That's been about four years ago. Usually I'm C3l you made in 2013 from your law practice?
[41 consulting more so than --you know, I'm actually 41 A. Yes, sir.
CSJ advising people on other shows or helping people fuel [5J Q. Do you and you just don't want to say or .
C6J their shows. [6J do you truly not have any idea? What's the answer to !
c11 Q. So these side businesses, does a [7J that question? !
C8l significant portion of your income derive from those? [SJ A. What was the question again? i
[9J I think you originally said, you know, 50 percent from C9J MR. RADFORD: Would you mind reading the i
c101 your law practice, 50 percent from the TV show. Those c101 question back. I'
[111 additional businesses, what percentage of your income [llJ (The record was read by the reporter.)
c121 is derived from those? c121 THE WITNESS: I don't have any idea.
[131 A. It really varies because it depends on [131 Q. (By Mr. Radford) Does someone else handle I
141 what projects I have time to do and what projects I'm [141 your finances for you? i
c1s1 interested in. So, you know, it depends on what year [lSJ A. Yes, sir. I
Cl6J and what I'm actually doing. [161 a. Who is that? 1
1
c111 Q. Okay. Well, let's say 2013. What would c111 A. My accountant. i
[18] be your best estimate? [18] a. Who is that? i
[l9J A. Well, it would be nothing in 2013 because [191 A. Preston Business Management.
c201 I just had a baby. c201 Q, Is that an individual or is that a firm? 1
c211 Q. Okay. How about 2012? c211 A. It's an accounting firm. !
c221 A. I was pregnant. c221 Q. Okay. Where are they located? j
C23l Q. So none of those side businesses going on C23l A. In California and Georgia. ,
for'12and'13? Q. Dotheyhaveaphysicafaddressherein j
[SJ A. Well, pretty much. I mean, no, because I C25J Georgia? j
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JPA Reporting, LLC- (404) 853-1811 (4) Pages 13 - 16
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ANGELA ST ANTON
Page 17
PHAEDRA C. PARKS
June 19, 2014
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c11 A. I'm pretty sure so.
c21 Q. Okay. What is it?
[l]
I
my income derives from. So I'm asking you in that I
(21 context, do you have any particular clients that are a
[31 A. I don't know it. [3J
[4] c 4 l Q. How do you communicate with them?
[51 A. Telephone. (5)
61 Q. Tell me a little bit about your law [6]
C7l practice. Do you have any specialties, any focus
[81 areas for your practice?
[7]
[8]
[9] C9l A. Entertainment law, intellectual property.
c101 Q. Okay. So do you do litigation or- [10]
CllJ A. I do. [11]
c121 Q. Okay. What are, I guess, some examples of [12]
(13]
[14]
[131 the type of legal work that you've done in the past
(141 couple of years, the most prominent sort of work that
(151 you've done? What's been your focus, I guess? [15]
(161 C16J A. Contract negotiation, litigation regarding
cl 7 J contracts. [17]
Cl8J Q. Okay. So entertainment law from the (18]
[19) 191 contract perspective is the focus of your practice, is
c201 that a fair statement? [20)
c211 A. Yes, sir. [21)
r221 1221 Q, Do most qt yc:>Ur clients pay you by the
C23J hour or do you work on contingencies? [23)
241 A. By the hour or a percentage of their deal. [24]
[251 Q. Is part of your practice artist [25]
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Page 18
management? c11
A. Not at this time. c21
Q; Okay. When you say a percentage of the 31
deal, does that mean if you like secure someone a r 4 J
record contract, for example, and there's an advance, [5J
you get some percentage of that? 61
A. Yes, sir. [71
Q. And then you're entitled to some [81
percentage of the royalties? 91
A. Excuse me? c101
Q. And then you're entitled to some c111
percentage of any royalties they earn? c121
A. Not always. It just depends on the deal. tl3J
Q. Is this an attorney-client relationship C14J
with this particular type of client or is this a c1s1
manager relationship? [16J
A. Attorney relationship. c 17 J
Q. Okay. Do you currently have any clients c1s1
that are - T guess where a majority of your income [19J
comes from, certain big clients that are the primary c201
source of your income? c211
A. I don't understand that question. c221
Q. Well, you know, like I'm a lawyer and so I 231
may have 30 cases; but two or three of those cases are [24 J
the ones that, you know, is my focus and where most of [251
focus of your practice that form the basis of a !
significant portion of your income? !
A. I wouldn't say so. i
Q. Okay. About how many clients do you have I
presently? I
A. Probably on or about 30.
1
.
Q. And these are all artists who you
represent from a contract perspective?
A. No.
Q. Okay. Are these all entertainment law
clients?
A. No.
Q. What other sort of work do you do other
than entertainment law?
A. Personal injury.
Q. So among those 30 clients, how many of
those roughly are personal injury versus artists?
A. I would have to look at the log at the
office. I can't say definitely.
Q. Okay. Whafs your best estimate? ts that
a 50/50 deal or is that 80/20 type situation?
A. I wouldn't want to say without obviously
looking at the cases.
Page 20 I
MR. RADFORD: Could we mark that, please, !
I
as Defendant's 1. :
(Defendant's Exhibit 1 was marked for i
identification.)
Q. {By Mr. Radford) I show you a document
that we're marking as Defendanfs Exhibit 1. tf you j
could take a look at that and I'll state for the '
record this is a profile I found on the website
linkedin.com. It appears to be your Linkedln profile.
Do you recognize this?
A. I do.
Q. And this is a profile that you created on
Linked In?
A. I didn't create it.
Q. Did someone create it with your
authorization or to your knowledge?
A. I'm assuming someone created it on my
behalf, but I didn't create it.
Q. So this isni like a fake something that I
someone made as far as you know?
A. I don't think so. I mean -- I
Q. Okay. So, for example, on the second page
it lists a number of organizations you belong to. Is !
that an accurate list of some organizations you belong I
to? I
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JPA Reporting, LLC- (404) 853-JSJ I (5) Pages 17 - 20
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C. PARKS vs.
ANGELA STANTON
PHAEDRA C. PARKS
June 19,2014
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Page 23 j Page21
[l] A. Not presently, it's not accurate.
[2] Q. Okay.
[3] A. I have belonged to some of these
(4) organizations.
[5) Q,
Okay. Is there anything about this
[6] document that has some information about you that is
[7) inaccurate or false in some way that you can see?
[8] A. Not on just generally looking over it on a
[9] brief glance, no.
(10] Q. If you'll take a look at the front page,
[ll] there's a header. It says "Experience," and then
(12] there's three, I guess, employers or jobs listed below
[13] that. And the third down says you worked for GEICO
[14] from 1990 to 2000, is that correct?
[15] A. That is correct.
[16] a. And when you were working at GEICO, was
[17] that before you got your law degree or were you
[18] working at GEICO as a lawyer?
[19] A. I think I've got two questions. Could you
[20] break that up into two separate questions?
[21] a. Sure. Did you work at GEICO as a lawyer?
[22] A. Yes, sir.
{23] The next one up says "Attorney" with - l
[24) think that's the law firm of Bridges. Ormand & Faenza,
[25) is that right?
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Q. Well, 1990 to 1997.
A. Oh, okay. Numerous different positions.
Q. Do you work in an office or do you work
from home?
A. In an office.
a. Where did you physically work?
A. What year are you referring to?
a. 1990.
A. In Macon in GEICO.
a. How long did you work at the Macon office? !
A. To2000. '
a. Okay. So you were in Macon from 1990 to
2000?
A. On and off. I mean, that's the
headquarters. That's the regional office.
a. And you worked at the regional office?
A. You know, on and off, because I was in
school.
Q, Okay.
A. So I would work summers. It just depends
on, you know, what time you're referring to.
Q, Well, you said you held various positions
at GBCO. What were the positions that you held at 1
GEICO? i
;
A. I was a management intern. I worked in j
-+--------------- .......... --- ------ ----- ..... I
Page 22 Page 24 i
lll A. Yes,. sir.
c21 Q. From 1998 through 2000, is that accurate?
[31 A. No, that's not accurate.
41 a. Okay. When did you work for that law
I51 firm?
[6] A. I worked for them from '98 or maybe '97 to
[7) 2000.
ca1 Q. Okay. Did they do work for GEICO?
[9]
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A. Yes, sir.
Q. All right. Was there sometime when you
were working for GEICO but you weren't working for the
law firm?
A. Repeat that again.
Q. Well, so GEICO on this document states you
worked there from 1990 to 2000, right? But then you
said you worked with the law firm from 1997 to 2000.
So if this is correct, there would be a three-year
period that you worked on GEICO's behalf but you were
employed by that law firm, correct?
A. That law firm is owned by GEICO.
Q. It's a captured firm of GEICO?
A. Yes, sir.
Q. Understood, okay. So what were you doing
for GEICO prior to 1997, so from 1990 to 1997?
A. You say 1992?
(1] human resources. l worked in underwriting. l worked I
in endorsements. I worked in claims. I worked for I
c 3 J house counsel. I worked at the corporate headquarters !
in Washington, D.C.
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a. What did you do at the corporate
headquarters in D.C.?
A. Worked in-house counsel.
a. In-house counsel?
A. Compliance. '
a. Focusing on the time when you worked for I
GEtCO but before you became an attomey. were you ever I
a full-time employee of GEICO?
A. Yes, sir.
a. Were you working for GEICO while you were
in law school?
A. Yes, sir.
Q. Were you full-time while you were in Jaw
school?
A.
a.
No, sir. I
Okay. So you went part-time when you went l
I
to law school? I
A. Yes, sir.
a. But then the remainder of that period of !
time you were full-time?
A. It depends on what time you're referring
- ------- ----
JPA Reporting, LLC - (404) 853-1811 (6) Pages 21 - 24
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PHAEDRA C. PARKS vs. PHAEDRA C. PARKS
June 19, 2014 ANGELA STANTON
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Page25
[l] to because it's ten years.
{2) Q. Right.
[3] A. So that's -
[4] Q,
How many of those ten years were you
[SJ full-time?
[6] A. The majority of them.
(7] Q. Okay.
[8) A. But I was a full-time student during most
[9] of that time. So ten years, obviously, I was in
(10] school for my undergrad degree and my law degree.
[ll] Q. Okay. Tell me about what were your
{12) primary duties at GEICO.
[13] A. What year?
[14] Q. Well, so I asked you different jobs you
(15] had; and you stated management intern, human
[16] resources, underwriting, endorsements, in-house
[17] counsel. Were there any other jobs you held at GEICO?
{18] A. Could you say those again just so I -
[19] Q. Management intern, human resources,
[20] underwriting, endorsements, in-house counsel. Were
[21] there other jobs that you held?
[22] A. Sales and service. I did sales and
[23] service, too, and claims adjusting.
[24] Q. Your time at GEICO, was it equally
[25] dedicated to each of those areas or were there one or
Page26
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Q. Yes, at the law firm.
A. -- period are you referring to?
Q. The law firm.
I
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I
A. Alvin Bridges. !
Q, And where did you physically work? Where
1
was the office that you reported to as an attorney? I
A. In Buckhead. j
Q, Okay. What was the address? :
A. I don't recall now because that's been
well over ten years ago, but I can get it to you.
Q, What was the street, do you know?
A. Peachtree.
Q. And you left GEICO in 2000, is that right?
A. That is correct.
Q. Did you continue to work in the same ,
office space or did you change office space when you !
went out on your own? I
A. I changed office spaces.
Q. Was it the same building or a totally ,
different building? I
A. Totally different building. I
Q. Prior to going to the law firm, when you I
worked in the rotation, who was your primary I
supervisor at that time? I
A. Can you be very specific, please? I
--- ------ -... - ----- -- . .. ... !
Page 28 !
r l l two of those areas where you spent most of your time? r11 Q. Well, during that rotation period, I'll
[2] A. I was in a rotation program, which was a r21 call it, was there a person who you primarily reported
[31 management program. So I rotated throughout the whole
c 41 system. So ii just depends on, you know, what year
you're talking about again. {5]
[3]
(4]
[5]
[6]
to from a chain-of-command perspective?
A. When I was in the management program?
Q. Yes.
c 61 Q, After you became an attorney and you A. David Pushman.
c 11 worked through the law firm, you weren't continuing to
rotate then, were you? [8]
[7]
[8]
[9]
Q. And you were working out of the Macon
office for that time, correct?
[9)
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fl.Bl
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A. No, sir. A. Yes, sir.
I
Q. Okay. You were in-house counsel at that [10] Q. Do you remember the address for that Macon !
point? c111 office? i
A. That is correct, sir. c121 A. East Ocmulgee, but I don't recall the
Q. Were you still doing claims adjusting? {131 numbers.
A. No. sir. [141 Q. Ocmulgee, do you know how to spell that'?
Q. Were you doing endorsements? c1s1 A. 0-c -
A. No, sir. [16] MR. ANDREW: Ocmulgee, u-1-g-e-e.
Q. Were you doing underwriting? [17] Q. (By Mr. Radford) So during that rotation
A.. No, sir. ua1 period, l imagine you were not writing briefs and
Q. So tell me, when you were an attorney. (19] doing legal research, correct?
what were your duties for GEICO? c201 A. I wasn't an attorney.
A. Writing briefs and research. c211 Q. Right. So, no, you were not, correct?
Q. Who was your primary supervisor during r221 A. Correct.
your time as an attorney at GEICO? [231 Q. Okay. Among the duties that you earlier I
A. Alvin Bridges. Well, yoo're referring at f 2-t 1 identified to me, during that rotation period, did you i
tbe Jaw flfm or what -- 12s J spend an-equat amount of time on eaeh of those duties !
- - __! ___________ ----- . -. .. . .... - . j
JPA Rcr>orting, LLC- (404) 853-1811 (7) Pages 25 28
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ANGELA STANTON
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or did you spend most of your time on, for example, c11
claims adjusting or most of your time on undeiwriting? c21
A. I really don't recall. That's been a long CJJ
time ago. You know, just to be honest with you, I [41
really don't recall. It was a rotation and you learn [5J
the job. Once you became proficient, they moved you c 61
to another area. c11
Q. Okay. This wasn't an unpaid internship, [81
was it? C9J
A. No. This was a management program. c101
Q. So you were being paid for this, correct? c111
A. Yes, sir. c121
Q. Okay. What sort of insurance claims did [13J
you work on at GEICO before you were an attorney? [141
A. Injuries. [151
Q, Auto accidents? [161
A. Auto accidents and homeowners, [171
specifically trailers. [181
Q. Like trailers people live in? (191
A. Yes, sir. c201
Q. Did you do work on claims for damaged c211
automobiles? c221
A. What do you mean when you say did you do C23l
work on? C24l
Q. I don't know how else to put it. I mean, [251
Page 30
did you do work on claims with respect to damaged c11
automobi1es, insurance c1aims? r21
A. Sometimes, but that wasn't my focus. C31
Q. When did you finish your undergrad? C4l
A. I finished early in '93. CSJ
Q. Okay. And where did you go to undergrad? C6J
A. Wesleyan. C7l
Q. And you were working for GEICO while you CSJ
were at Wesleyan? C9l
A. Yes, sir. c101
Q. Remind me, where is Wesleyan? r111
A. Macon, Georgia. c121
Q. Okay, gotcha. Between, I guess, your [131
graduation from college and the present day, have you [141
had any other employers beyond the three that are [151
listed on this Exhibit 1 here? Cl6J
A. Give me those dates again. [17]
Q. College forward, college graduation until [181
the present day. Cl9J
A. I'm sure I have. c201
Q. Okay. What other employers have you had? c211
A. I worked at Target in college. r221
Q. Okay. Any others? I231
A. That's all I can, you know, recall is C24J
Target. [251
PHAEDRA C.
.June 19, 2014
Page 31 i
Q. Any other law firms you've worked for?
A. No, sir.
Q. Any other insurance companies?
A. No, sir.
Q. Do you have a law partner presently?
A. No, sir.
Q. Have you ever had a law partner?
A. No, sir.
Q. Okay. At some point you shared office
space with Ronald Freeman, is that correct?
A. Yes, sir.
a. And did you and he have any sort of
business relationship?
A. No, sir. Besides a rental relationship,
'.:.
no.
a. And did you rent space from him? Did he .1
rent space from you?
A. I rented space in his building. !
Q. Okay. Do you remember the address of that I
building?
A. 1069 Spring Street.
Q. Were there any other attorneys in that
office?
A. Yes, sir.
a. Who else was in there?
... -- - ______ .. _ .. __________ .. I
Page 32
1
A. Clarence Johnson, Dorian Murry. I
Q. Dorian? I
A. Dorian, D-o-r-i-a-n, Murry. i
!
A. Nathania Stewart. A couple other I
attorneys that I can't recall their names right now. 1
Q. Okay. ii
A. But about probably three. minimally three .
or four other attorneys. I just can't recall their
names at this moment.
Q. Okay.
A. Oh, Maureen McLeod.
Q. Maureen?
A. Maureen McLeod. And Horace Johnson as
well.
Q. Horace Johnson?
A. Uh-huh.
Q. Do you claim to have suffered any economic :
damages as a result of the statements that Ms. Stanton .
has made that you claim are defamatory?
A. Yes, sir.
Q. Okay. What are those damages?
A. You want a specific -- what are you
specifically asking me?
Q. What economic damages have you suffered?
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ANGELA STANTON
PHAEDRA C. PARKS
June 19, 2014
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[lJ What economic losses have you suffered as a result of Cll
c21 the allegedly defamatory statements of my client? c21
C3J A. I think that is in the pleadings. C3J
C4l Q. Well, I'm asking you. This is a [4J
C5l deposition. C5l
C6J A. I understand. C6J
C7l Q. So, again, what economic damages have you C7l
C8J suffered as a result of the statements that you claim C8l
C9l to be defamatory by Ms. Stanton? [9]
c101 A. I'll need to amend that because I want to c101
c111 be very specific and I don't want to actually c111
c121 misspeak. c121
[131 Q. Now is the time to tell it. Now is the [131
[14 J time when you're under testimony, you're under oath, [14 J
C15J and we're creating a record of any damages you've [151
{161 suffered. I need you to state for the record if Cl6J
(17 J there -- let me ask you this: Have you suffered any c 1 7 J
[18J economic losses as a result of the statements that you (181
[19] claim to be defamatory? [191
c201 A. Yes. sir. c201
c211 Q. Okay. And describe those to me. What are c211
c221 they? c221
[231 A. I think it has damaged my credibility and [231
[24] damaged my reputation. [241
(251 Q. Okay. Has that caused you any economic [251
Page 34
Ill harm? [1]
Page 35 :
A. I am not sure.
Q. Okay. Well, where would I go to find the
information as to what damages you've suffered,
economic damages?
A. The pleadings possibly.
Q. The pleadings. There's nothing in the
pleadings identifying any specific damages, I'll tell
you that
A. Okay.
a. If there was any, this is the time to tell
it. So have you fully answered the question as best
you can for today?
A. Yes, sir.
a. Okay. And other than the pleadings, can ,
you identify any other place where I could go to look I
to find the evidence of any economic harm you have :
suffered? i
A. I'm not sure. i
a. You're not sure, okay. You say there's !
been damage to your reputation. What sort of damage !
has been done to your reputation? I
A. As far as? .
Q. As far as damage to your reputation. What j
damage has been done to your reputation? :
A. Well, I obviously have been defamed by
statements that were not true.
.. - . - . Pa.ge 36 I
I
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I
[2] A. Yes, sir. I am an attorney.
[3] a. What economic harm has it caused you?
c 4 J What money have you lost? Let me ask you this: Do
(51 you have any evidence that you've lost any money as a
c 61 result of the actions that you allege to be
[7J defamatory?
a. Well, to say you've been defamed is to say
an element of liability, right, that there's been a
statement made about you that's not true. And I'm
(5] asking you about the separate issue of damages. What
[6] damage has been done to your reputation as a result of
the alleged defamation?
[2]
[3]
[4]
{7]
[8] [8J A. I would have to review that prior to
C9J answering it because I don't handle my money. So I
would actually have to ask someone else who would
obviously --
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a. Well, sitting here today, do you know of
any evidence that you have mt money as a r-esutt of
these actions?
A. I am not sure.
a. Okay. Well, do you or don't you? I mean,
do you have any evidence today?
A. I am not sure.
Q. So you don't know if you have any
evidence? I mean, can you describe to me -- just say
we're just sitting here talking. If I asked you the
question what money have you lost as a result of these
statements, can you identify anything, any economic
harm you've suffered with any degree of specificity?
Can you or not?
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A. It has damaged my ability to work. I
a. Okay. Tell me how. Can you give me an I
example of damage it's done to your ability to work? j
A. It has damaged my ability to obviously i
reach some clients.
Q. Okay. Do you have anyevkfenceof this?
A. Yes, sir.
a. Okay. Is there a specific client you've
lost who said I will not retain you due to the things
Angela Stanton has said?
A. Possibly.
Q. Wett, yes or no? I dont want possibly.
I need to know if there's any evidence in this case to :
support your damages claim. So have you lost a j
particular client due to Ms. Stanton's statements?
1
A. I would have to look over my roster to
determine that.
Q. Wen, r woufd imagine - okay. So now is
JPA Reporting, LLC-(404) 853-1811 (9) Pages 33 - 36
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ANGELA STANTON
PHAEDRA C. PARKS
June 19, 2014
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Page37
the time. I mean, if there's been a client you've
lost or some business opportunity you've lost as a
result of Ms. Stanton's statements, I'd like you to
identify those for me, please. while you're under oath
today and while we're taking your deposition. So can
you identify with specificity any business opportunity
you've lost or client or anything to that effect as a
result of the alleged defamation?
A. At this moment, I can't.
Q. Okay. Are you aware of any evidence that
would, any nondocument or, you know, other than your
testimony, is there any document or other form of
evidence I could look to to see the damage you have
suffered in terms of losing a client or anything to
that effect as a result of the alleged defamation?
A. I'm not sure.
Q. Okay. Are you aware of any evidence that
you have suffered any damages to your reputation or
economically as a result of the defamation?
A. I'm not sure.
Q. Okay. Well, now is the time to say it
because I've got to be able to identify it and locate
it and review it for trial if there's some evidence of
damages you're going to present. So I need to know
where that evidence is or what it is. And is your
Page 38
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c11 testimony that you cannot identify any evidence to Ill
c21 support your damages claim sitting here today? c21
31 MR. ANDREW: I think her testimony is she C3J
[4] cannot identify any particular client or business C4J
51 opportunity she has lost. cs1
61 MR. RADFORD: Okay. 61
71 MR. ANDREW: I think obviously there's a [71
ca1 general damage presumed if I say somebody is a [81
91 thief. 91
[10] MR. RADFORD: Well, that's a legal [10]
c111 argument you can make in your brief, and I c111
c121 understand that. c121
[13] MR. ANDREW: Yeah. [13]
141 Q. (By Mr. Radford) Are you aware of any [141
[151 evidence of any specific damage you've suffered as a [15]
[16J result of the alleged defamation that you can point me [161
c111 to that I could review? c111
c1s1 A. Not at this time. c1a1
[191 Q. All right. Would you dispute the notion [191
c201 that you are a public figure? c201
c211 A. I would. c211
c221 Q. You would dispute that? Are you aware c221
[231 that in pleadings that have been filed on your behalf [231
[241 the statement has been made that you are a public [241
[251 figure? [251
Page 39
A. Possibly. I'm not looking at the
pleadings presently.
Q. Okay. So sitting here today, you're not
aware of that? I mean, anything Is possible. You can :
say possibly to every question I ask you, okay. So i
I'm asking you yes or no, do you recall that there
have been pleadings that have been filed on your
behalf which describe you as a public figure?
A. I am not my own attorney.
a. That doesn't answer my question. Are you
1
aware of this? Are you aware that pleadings have been !
filed on your behalf which describe you as a public j
figure? !
A. I can't answer that without looking at all '
the pleadings.
a. So, no, you're not aware, is that correct?
No? Do you dispute that, that you're not aware?
A. I'm not disputing anything because I'm not
reviewing the pleadings currently. I
a. Okay. Do you have any sense of how many !
people -1 guess the ratings for the Real Housewives
show that you appear on, how many people view it on !
any given night?
A. We're currently not on air.
Q. Well, that's not what I asked you. When
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Page 40
. I
the show arrs, do you have any knowledge as to the j
ratings that it gets in terms of how many people view !
the show? i
A. No, not generally. You know, I hear l
numbers; but I'm obviously not in that department and I
that is- i
Q. Over a million, right? I
A. I'm sure. i
Q. Several million, right? !
A. You know, I can't say yes to that.
a. Okay. Over a million, though, correct?
A. Yeah, I'm sure.
a. And you are prominently featured on that
television show, is that correct?
A. I'm a cast member.
Q. Okay. And you appear on camera quite
often as a part of that TV show. correct?
A. I'm a cast member.
Q. All right. Well, I didn't ask you that.
I asked you do you appear quite often on camera?
A. It depends on what episode you're
referring to.
Q. The aggregate of the entire show that you
have appeared on while you were a cast member. you i
often appear on the television screen, correct?
.JPA Reporting, LLC- (404) 853-1811 (10) Pages 37 - 40
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ANGELA STANTON
(ll A. Possibly.
Page41
c21 a. Possibly is not an answer. Anything is
C3l possible. It's a yes or no question.
[41 MR. ANDREW: I think, you know, when you
[SJ say "often," we would stipulate that .she appears
cs1 on the television show.
[71 MR. RADFORD: I understand it's an
C8l imprecise term.
c 91 Q. (By Mr. Radford} Just in layman's terms,
c101 not a legal term, would you dispute that you appear
111 often on the television screen as a part of this
c 12 J television show?
[131 A. I have answered the question.
(141 Q. No, you haven't. You said possibly.
c1s1 A. Because I'm not sure what your definition
[16] of "often" is.
c 1 7 J Q. Okay. No one forced you to be on that iV
[181 show, is that a fair statement?
191 A. I'm under contract.
c201 Q. Well, but you voluntarily agreed to that
c211 contract, is that true? You entered into the contract
1221 with the television network to appear on the show of
[23J your own volition?
241 A. Yes, sir.
(251 Q. Okay. And you're compensated financially
Page42
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PHAEDRA C. PARKS
June 19, 2014
---- ----- .. -------- -----P.43-t
A. l'm not presently disputing that. I
Q. Okay. So you don't dispute that you're a
public figure, because I asked you earlier if you I
dispute that and I believe you said no? I think the I
[SJ record will reflect but -- I
(6] A. Okay.
[7]
[8]
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Q, So to clarify, do you dispute that you are
a public figure?
MR. ANDREW: Same objection?
MR. RADFORD: Duly noted.
Q, (By Mr. Radford) And your answer is?
A. What do you define "public figure" as?
Q, Well, I'll stipulate that there is law out
there that says what a public figure is. And so I
don't want to - even though you are an attorney in
the entertainment law field who I would imagine you !
have some notion of what a public figure means from a [
regal perspective, but putting that aside, let's say i
as a layperson, your lay definition of "public i
figure," do you have any basis for disputing that you j
would fall under that standard definition? Yes or no? j
A. no. !
Q, Possibly no? I
A. Wait. Say the question again because I've
gotten confused with -
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A. That is correct. r21 language, correct? l
a. And you appear on a television show before [31 A. Most definitely. j
millions of people whenever the show airs, is that a 4 J Q. All right. And you understand in common :
true statement? cs1 parlance the word "public" and the word "figure," is I
A. Could you repeat that? c 61 that correct? j'
Q, You appear on millions of people's [7J A. That is correct.
television screens as part of your participation in cs1 Q, Okay. Now, based on your understanding of j
that show, is that correct? [9J that term in common parlance, do you dispute that you, .
1
A. I don't know if I can agree to that. c101 as a person, would meet the definition of a public
Q. Well, what would be your basis for c111 figure? !
disagreeing with that? c121 A. I don't dispute that.
A. Because I'm not sure how many people, when [131 a. Okay. Do you understand the meaning of
you say "millions," what you're -- [141 that term in a legal sense?
Q, More than a million. (151 A. Yes, sir.
A. Sure. [161 Q, Okay. Do you dispute that you meet the
Q. Okay. If you say you dispute the notion [171 definition in a legal sense?
that you're a public figure, upon what basis do you c101 MR. ANDREW: Same objection.
dispute that? [19] Q. (By Mr. Radford) Are you thinking or are
MR. ANDREW: Objection to the extent it r201 you just ignoring me? Let the record reflect that
calls for a legal conclusion. c211 several seconds have past now. You're doodling.
Q, {By Mr. Radford} You can answer the c221 You're not answering my questions.
.question. What is your basis for disputing that? it 23} A. WeU, just give it to me once more, and i
I state you are a public figure and you say no, I'm [241 will try to duly answer it.
not, tell . - _ _ __ -- . ask the court
JPA H.eporting, LLC- (404) 853-181 I (11) Pages 41 - 44
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PHAEDRA C. P l ~ K S vs.
ANGELA STANTON
Page45
Cll reporter, if you can, to read it back, please.
c21 (The record was read by the reporter.)
31 Q. (By Mr. Radford) Of public figure.
C4J A. I'm not disputing that.
SJ Q. Okay. lt took about ten minutes to get .a
[6J simple answer to a simple question. This will move
[71 much faster, I promise, if we can sort of not talk
C8J around the issues.
[9) Your husband recently pied guilty to a
uo1 number of federal financial crimes, is that correct?
r111 A. I will not be discussing my husband.
c121 Q. Well, you don't have to discuss him. But
[13] is that true, that your husband recently pied guilty
[141 to a number of federal financial crimes?
c1s1 A. I will not be answering any questions
[161 regarding my husband.
[171 Q. Okay. So you're going to refuse to answer
[181 that question?
[191 A. That is correct.
c201 Q. All right. Do you believe that your
c211 husband's criminal activity had an effect on your
c221 reputation?
[231 And I'll note again that you're doodling.
[241 You appear to be ignoring me. Are you refusing to
[251 answer that question as well?
. . --- ------- .... -- - --- - ---- - .. -..
Page46
[1] A. As I have answered earlier. I will not be
(2] having any answers or having any discussion regarding
[3] my husband.
[4] Q. Okay. I'm going to continue to ask you
[5] questions; and if you refuse to answer, I'm going to
[6] ask that you state that you're refusing to answer
[7] because, if you just ignore me, I don't know whether
{8) you are thinkklg about the answer or refusing to
[9] answer and we're going to be here all day, okay.
[10] Who is your husband? What is his name?
[11] How about that? Will you answer that question?
(12] A. Apollo Nida.
ll3] Q. And when did you first meet Mr. Nida?
[14J A. 1n the '90s.
(15] a. Okay. That's a ten-year period. When in
[16] the '90s?
{17] A. '95, '96 -wen, '96, '97, maybe.
(18] Q. And did you know at that time that he was
[19] invotved in criminal activities?
I20J A. r did not
[21] a. He was incarcerated sometime after you met
[22] him, is that right?
[23] A. I will not be answering questions about my
[24] husband.
{25} Q. Okay. So you'ra refusing to answer that
PHAl-:ORA C. PARKS
.lune 19, 2014
Page 47 1
c11 question, correct? Is that right? Is that right?
c21 A. That is correct.
1
.
[3J Q. Okay. And you knew when you married him
C4J that he had been involved in a number of criminal j
c 5 J activities, is that correct?
C6J Again, if you're refusing to answer, just .
C7l say it because, if you ignore me, I'm going to wait
[SJ all day for you to answer.
[9J A. I will not be answering that question.
c101 MR. RADFORD: All right. Can you remind
c n 1 me what my last question was.
c121 (The record was read by the reporter.)
C13J Q. (By Mr. Radford) And you knew that the
[141 criminal activities he had been convicted of and
c1s1 incarcerated for related to financial fraud, is that
[161 correct?
[17 J A. I will not be answering that question.
c1e1 Q. Okay. And you married him in spite of
[19] your knowledge of his involvement in financial fraud, I
c201 correct? '
c211 A. I will not be answering that question.
c221 a. Mr. Nida is also a cast member of Real
C23J Housewives of Atlanta, is that correct?
[241 A. That is incorrect.
[251 a. Well, he appears on that television show
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Page48
alongside you, is that correct?
A. I will not be answering that question.
Q. Okay. And you've been part of a number of
business ventures with Mr. Nida, is that correct?
a. Okay. For example, if I went on your
I
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Twitter page, I would see a large image of you and .
your husband s1anWng together as part of something !
called Nida Fitness. is that correct? J
A. That is incorrect. j
a. Okay. At some point was that displayed on
your Twitter page? !
I
A. I am not sure. !
Q. Okay. Do you thtnk that your a$$Gefatioo
with Mr. Nida has any effect on your reputation?
a. Why not?
A. Because I will not be answering any
questions related to my husband.
Q. And do you not think your retationship
with your husband is relevant to the instant
litigation?
A. No, it is not.
Q. You don't think it's relevant to your
claim of .reputati.onat damage?
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PHAEDRA C. PARKS
June 19, 2014
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[l] A. No, it is not.
c21 Q. Okay. You don't think that your husband's
C3l involvement in numerous financial crimes is relevant
c 4 l to the question of whether a reasonable person could
r11 A. I mean, I obviously have a workout !
(2) company; and, you know, he is on the workout videos /
[3] with me. j
believe that you are also involved in those crimes?
[4]
CS]
Q, Okay. But does he have a formal j
[5]
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A. No, it is not.
Q. So in your opinion, it has no relevance,
is that right?
relationship to the business? In other words, do you l
[6] pay him to appear in the videos or does he have some
interest in the business? [7]
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A. Correct.
Q. Okay. Have you had awareness that your
husband was involved in criminal activities while
those activities were going on?
A. Again, I will not be answering that
question.
Q. Are you pleading the Fifth Amendment?
A. I will not be answering any questions as
it relates to my husband.
Q. All right. What is Nida Fitness,
Incorporated? What is that? What is Nida Fitness,
Incorporated?
A. It sounds as if it's a company.
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MR. ANDREW: That is two separate
questions.
Q. (By Mr. Radford) Does he have an interest
in the business?
A. Yes, sir.
Q. Okay. And you and him jointly own this
business, is that correct?
A. Yes; yes, sir.
Q, What is this business? What is the
business that this entity is engaged in?
A. Exercise workout videos.
Q. And anything else? I guess the production
and sale of videos, is that a fair description of what
this company does?
A. Yes, sir.
[23]
[24]
[25]
Q, Is that a company that you are involved in
in any way?
A. No, sir.
Q. Have you ever been involved in it?
[23)
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[25)
Q. Does this company do anything else beyond
that; seminars, personal training, anything like that? I
A. Not that I'm aware of.
j__ __
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Page 50 Page 52 ;
c11 A. Not that I know of. c11 Q. Okay. And you derive some income from
!
c21 (Defendant's Exhibit 2 was marked for c21 this business?
[31 identification.) [3] A. Yes, sir.
41 Q. (By Mr. Radford) I'm going to show you C4l Q. Okay. About how much income in 2013 do
cs1 what I'm marking as Defendant's Exhibit 2. This is cs1 you derive from this business?
[61 something I got from the Georgia Secretary of State's [6] A. I would have to look. I wouldn't know
71 website. It's a record of 2013 corporation annual 71 offhand.
81 registration of Nida Fitness, Incorporated. And the 81 Q, Just estimate.
[91 CEO and CFO are listed as Apollo and Phaedra Nida. C9l A. I would not know, just to be honest with
c101 And then there's a section that says "authorized r101 you.
c11J signature." Beside that, it says "Phaedra Nida." Are [111 Q. More than a thousand dollars?
c121 you, in fact, a CEO or CFO for this organization? c121 A. I would not know. Just to be very honest
[131 A. Oh, you're talking about my exercise C13J with you, I wouldn't know.
[141 company. Okay. I'm sorry. I'm sorry. I was [14J Q, Do you think it's possible it might not be
r1s1 mistaken when you were saying something else. I do c1s1 more than a thousand dollars?
I 1-&J apologize. {.16.J A. 1 wouldn't want to make an estimate
1
[171 Q, What did you think I was saying? [17] 'without actually speaking to an accountant who handles I
c1s1 A. I didn't know because your line of [181 this. i
191 question has been so suspect. shall! say_ So. yeah. {l.9J Q.. Okay. Who could I speak to to find that !
c201 this is my exercise company. c201 information? '
c211 Q. Okay. And you and Mr. Apollo Nida are c211 A. I would have to see who handles the
(221 jointly the CEO of thisa>mpany? {22J finances for this company.
[231 A. On paper, yes. (231 Q. Who do you think it is?
[241 Q. Well, tell me, is there some difference [241 A. Probably Preston Business Management.
{251 between what's oo paper and -reaUty? {251 Q. Okay. ls there a particuiar person ov.er
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ANGELA STANTON
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Page 53
there who handles your business?
A. Charles.
Q. Charles Preston?
A. Huh-uh. Charles -- gosh. I can't think
of his name. I can't remember his last name, bu! it's
not Preston. It's Chartes -
Q. And this is the person that handles all
your accounting?
A. Yes, sir.
Q. And you don't know his last name?
A. rm just drawing a bfank at this moment.
I mean, I can look it up and give it to you, though.
Q. And this is a person that handles all of
your finances?
A. Yes, sir.
Q. And his last name eludes you?
A. At this moment, yes.
Q. So Charles at Preston Business Management,
that's who I would go to find out about the income of
this company, is that right?
A. Yes, sir.
Q. All right. How long have you known
Charles?
A. Charles Peters.
Q. Charles Peters?
A. Uh-huh.
Page 54
Q. How long has Mr. Peters been handling your
finances?
A. I'm thinking. Probably over five years.
Q. Okay. With respect to Nida Fitness. I
c 6J would imagine you had some capital that you used to
start this business, is that correct? [7)
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A. Yes, sir.
Q. Okay. And did you and Mr. Apollo Nida
both contribute to that capital?
A.. I don't believe that that's relevant
Q. That's not what I asked you. Did you and
Mr. Apollo Nida -
A. I don't know.
Q. - both contribute to the capital?
A. I don't know.
Q. Who would I go to to find ool that
information? Would Mr. Peters have that information?
A. Hopefully.
Q. Okay. Because that's who manages your
finances with respect to this entity, right?
A. I believe so.
Q. Coufditb:e someone else?
A. It could be, but I'm thinking it's
Charles.
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PHAEDRA C. PARKS
June 19, 2014
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fia-9e 55 l
Q. Who else could it be?
A. Maybe someone else at Preston Business
Management.
Q. Okay. But it would definitely be someone
at P.reston Business Management, correct?
A. Yes, sir.
Q. Okay. There's not some other entity out
there that may handle the finances for this
organization, correct?
A. I wouldn't believe so. but maybe.
Q. Okay.
A. To be honest, I'm thinking -- well, in the
fitness world, you always have someone that's
processing everything. And so I don't handle any
1
processing. So there's another company that processes i
everything. ;
Q. What do you mean by processing things,
like credit card transactions?
A. Everything, uh-huh.
Q. Like what?
A. They would process -- the company that I
obviously handles the manufacturing of the actual item
would do everything with the financial stuff, you j
know: and they would obviously remit me a payment once
things were processed and sold. i
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Q. So you mean the company that like
physically manufacturers the CDs or whatever it is,
the DVDs?
A. Uh-huh; yeah.
Q. Okay. I don't understand that. Is there
anyone else that you know of other than you and
Mr. Nida who would have contributed to the capital to
begin this company?
A. No.
Q. Okay.
MR. ANDREW: Can we take a five-minute
rest room break?
MR. RADFORD: Yes. Let me finish just
about this document here.
Q. {By Mr. Radford) And you and he both
contributed some money to the capital to begin this
business, corfeci?
A. l don't know.
Q. To your knowledge, did you contribute
100 percent of the capital?
A. I'm not sure.
Q. Okay. But there wouldn't be some third
party out there who may have contributed capitaJ?
A. No, sir.
Q. It would be you and Mr. Nida, correct? I
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ANGELA STANTON
PHAEDRA C. PARKS
June 19, 2014
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think that's already been answered.
Who is Stephen Wang?
A. They have him down as the secretary.
Q. Right. Who is that?
A. A guy that used to work with us.
Q. Okay. How do you know Mr. Wang?
A. He used to work with us.
Q. Okay. Who is he? What does he do? Is he
an accountant? Is he a dude off the street? Who is
Mr. Wang? Is he an accountant?
Q. How do you know Mr. Wang? How did you
come into his acquaintance?
A. He used to work with us.
Q. With who?
A. With this company.
Q. Okay. Is he a workout instructor? Is he
a -- this isn't a difficult question. You know, did
you just find Stephen Wang out on the street or is
this someone who is some professional that has some
proficiency that helps you in your business?
A. He's a guy that used to work in the office
with us. Yes, he used to work with us.
Q. In what capacity? What was his job?
A. Marketing.
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Q. Is that the address for your law firm?
A. Yeah. That's just my law firm address.
Q. Okay. So does Nida Fitness, Inc. have
c 4 l some other place where they do business from?
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A. It's not anything that does business. It
doesn't do any business.
Q, You're not selling the videos anymore, is
that what you're saying?
A. I don't sell them anyway. They're sold by
another third party that processes it. I don't
physically go and sell them myself.
Q. What is the purpose of this entity?
A. Just so we'd be incorporated so that you
could produce a video.
Q. Who makes the video? You said there's a
processing company. Who is that?
A. A company out of California made the
video.
Q.
A.
Q.
A.
Q.
A.
Q.
Okay. What's that company called?
Win Productions.
Wind?
I think W-i-n.
Win Productions?
Uh-huh.
Okay. And they're in California? i
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Q. Okay. Does he work for a marketing firm?
A. I don't know.
Q. How did you meet Mr. Wang?
A. He sent over a resume.
Q. Was there some job posting for the job?
A. No.
Q. How did he know to send you a resume?
A. People send me resumes every day.
Q. So how did you get this resume from
Mr. Wang?
A. I didn't get it. Someone in the office
got it.
Q. Who? Who would that be?
A. Someone on my staff.
Q. Who might that be?
A. Latoya possibly.
Q. How old is this person?
A. Twenty-one, twenty-two.
Q. Okay. Do you have a copy of his resume
somewhere still?
A. Possibly. I mean. I don't know. You
know, maybe, maybe not.
a. Is this entity still functioning at
3384 Peachtree Street, Northeast, Suite 250?
A. No, sfr.
[l] A. Yes, sir, Los Angeles.
[2] Q. Who is your contact person out there for
[31 Win Productions?
[41 A. I would have to look that up.
[51 Q. Okay. But you pay them to make the video
C6l for you, correct?
A. Yes, sir. [7]
[8] Q. Okay. And then you get the money from the
[91 video, correct?
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A. Not all of it.
Q. Well, not all of it. I guess. You have
costs, for example.
A. Exactly.
Q. And then you and Mr. Nida split the money
from the video?
A. I mean, I'm not in the accounting portion
of it; so 1 don't really know the specifics of it.
Q. Okay. So I would need to go to Mr. Peters
to find that out, right?
A. Yes, sir.
Q. Who is Eric Croone?
c221 A. My attorney; one of my attorneys.
I
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C23J Q. Okay. Is this business still functioning? .
I [241 MR. N D R E W ~ When you say "his business," I
1 r2s1 do you mean if he's stitl her lawyer? l
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Page61
[1] MR. RADFORD: I said "this," "this
[2] business," Nida Fitness, Inc.
[3] MR. ANDREW: I thought you said "his."
[4] I'm sorry.
[S] Q. (By Mr. Radford) Is this business still
(6] functioning?
[7] A. When you say "functioning," what do you
(8] mean?
[9] MR. ANDREW: I think it's sort of like
(10] Angela selling a book. I mean, they produce the
[11] video; and it's out somewhere on a website.
[12] MR. RADFORD: I appreciate that. I don't
(13] want to solicit testimony from her attorney.
[14] MR. PORTIS: I need to stay in the room.
(15] Can we take a break for five minutes?
[16] MR. RADFORD: Yes, last question.
[l 7] Q. (By Mr. Radford) Do you still take orders
(18] for this video?
{19] A. I never took orders for it.
(20] Q. Or does Nida Fitness, Inc. still take
[21] orders for this video?
[22] A. I mean, I don't know. I don't think Nida
[23] Fitness ever took orders for it. I think a third
[24] party takes orders for it.
[25] MR. RADFORD: Okay. We can take a break.
Page62
[l} MR. ANDREW: Thank you.
[2) (Recess from 2:38 p.m. to 2:51 p.m.)
[3] MR. RADFORD: We are back from a break,
[4] back on the record.
[Sl Q. (By Mr. Radford) Ms. P9rks, what is
[6) National Recovery Group Inc.?
{7] A. I don't know.
[8] Q. Okay. Are you aware of being listed as an
(9] incorporator on something called National Recovery
[10) Group Inc.?
{11) A. No, sir.
(12] Q. Do you know what's at 239 Harriett Street,
(13) Atlanta, Georgia 30315?
{14] A. No, sir.
[15] Q. Is that address not familiar to you?
[16] A. No, sir.
[17] Q. Okay. Do you know a Michael Derrick?
[18] A. Uh-huh. Yes. sir.
[19] Q. Who is Michael Derrick?
[20) A. My brother-in-law.
[21] Q. Okay. Do you know who Tanya Bussey is?
[22) A. No, sir.
(23) Q. Do you have any businesses with
(24] Mr. Derrick?
[25] A. No. sir.
[1]
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PHAEDRA C. PARKS
June 19, 2014
Page 63 '.
(Defendant's Exhibit 3 was marked for
1
identification.) !
Q. (By Mr. Radford) I show you what I've I
marked as Defendant's 3. This is articles of '
incorporation that I got from the Georgia Secretary of I
State's website for something called National Recovery
Group Inc.; and it states the incorporators are listed i
as Michael Derrick, Apollo Nida, and Phaedra Nida. j
A. I have no idea what this document is.
1
Q. So you have no idea what National Recovery !
Group Inc. is? I
A. No, sir.
Q. Do you know who Anthony Derrick is?
A. No, sir.
Q. Before today has it ever come to your
attention that there is something called National
Recovery Group Inc. on which you are listed as an
incorporator?
A. No.
Q. So you have never heard about this until
today?
Q. Okay.
A. No.
Q. You know, let's say, for example, someone
---------
.... - ---- --- -- -. -- I
Page64 j
[1] used your name on this without your knowledge.
[2] A. Uh-huh.
[3] Q. Are you telling me that today is the first
[4] time you've ever --
[Sl .A. Today is the first time someone has
[6] brought this to my attention that I recall.
{7] Q, Okay. Your brother-in-law, Michael
[8] Derrick, is he your husband's brother?
[ 9] A. Yes, sir.
[10] Q. Okay. Is that someone you speak with
{11} regularly?
[12] A. No.
[13] Q. Do you and your husband maintain a joint
[14) bank account?
(15] A. No, sir.
[16] Q. Have you ever maintained a joint bank
(17) account?
tc1s1
A. Yeah, some years ago.
I [19] Q. After you were married, though, right?
I [20]
A. Uh-huh.
[21) Q. Where did y'all bank?
[22) A. I think it was maybe - maybe First
(23] Citizens Bank.
[24] Q. First Citizens?
(25) A. Uh-huh.
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.JPA Reporting, LLC - (404) 853-1811 (16) Pages 61 - 64
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ANG ELA ST ANTON
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[l) Q. That's where y'all would have maintained a
[2) joint bank account?
[3] A. Uh-huh.
[4] Q. Is that a yes?
[SJ A. Yes, sir.
(6) a. Was there a particular branch that you
[7] used most regularly?
[8) A. I don't actually go to banks, so no.
[9] Q. Like you don't ever go to a bank?
[10) A. No, I don't.
[ll) Q. Is there any reason why you don't ever go
(12) to bank?
[13) A. I just don't. I don't.
[14) a. You just don't like the way they smell?
[15] A. No. I just usually don't go to banks.
(16] Q. Okay. Was your husband handling the joint
(17) account? I mean. I imagine someone had to go to the
(18] bank at some point in time to do business, right?
[19] A. I'm sure he did.
[20) Q. Was it one that was close to your house?
(21) A. I don't know.
[22] Q. Okay. Do you have any idea what branch
[23) y'all may have used or which branch he may have used
[24) to manage your joint account?
[25] A. No.
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PHAEDRA C. PARKS
June 19, 2014
- -- -- --Page 67 !
provided any financial records for that purpose,
correct?
A. No.
Q. During your marriage to Mr. Nida, do you
have any knowledge of what his sources of income were? I
A. He is not a party to this lawsuit, so I
don't believe that that is relevant
Q. I guess to the extent that's an objection,
your objection is noted for the record. I'll ask you
the question again.
During the time of your marriage to
Mr. Nida, did you have any awareness as to what his
sources of income were?
A. Asked and answered.
Q. Okay. So are you refusing to answer that
question?
A. Answered and answered.
Q. My question to you is: Are you refusing
to answer that question?
Q. I'll object as nonresponsive. It hasn't
been answered.
My question to you now is: Are you
refusing to answer the question?
A. I stated earlier that I would not be
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Page68 i Page66
c11 Q. To your knowledge did your husband c11
c21 recently attend a deposition conducted by the U.S. c21
[3] Attorney's Office that was part of his criminal C3J
c 4 J sentencing? c 4 J
51 A. I don't know. C5l
[6J Q. You don't know, okay. Did you provide any [6J
Pl -documents to him or to his attorneys, financial 111
C8J records, for use in that deposition? C8J
C9l A. I don't know. C9J
c101 Q, How would you not know that? c101
c111 A. Obviously, he's my husband; so he would c111
[12] probably be privy to the documents if he needed some. [12J
t13J Q. Did you provide any documents? [131
cu1 A. I did not. C14J
[151 Q. Okay. Are you aware that he was asked by c1s1
[161 the U.S. Attorney's Office to bring documents related [161
c111 toyourfinances? c111
[l8J A. I don't know. I wasn't there. I don't c1a1
Cl9J know -- I don't even know if this occurred. But if it [191
c201 did, I don't know. c201
r211 Q. Okay. So no one has ever told you that c211
c221 you had any obligation to produce any financial c221
[231 records? [231
[241 A. No. [241
[251 Q. And to your knowledge, you have not [25J
discussing my husband.
Q. So, yes, you are refusing to answer my
question?
A. That would be correct if it is regarding
him.
Q, Fine. And it is.
A. Okay.
Q. And, again, the reason you're refusing is
why?
MR. ANDREW: It's not relevant.
Q. (By Mr. Radford) Your attorney says
because it's not relevant. From your perspective
whafs the reason why youre not answering?
A. Because it's not relevant.
Q. Would you agree with me that if you did j
know about your husband's criminal activities and his
income came from criminal activities, that would cut I
against your claim that Ms. Stanton's book is l
defamatory? Would you agree with that?
A. I would not agree with that.
Q. Okay. So you think your marriage to
someone and your knowledge that his source of income
is derived from criminal dealings during your
marriage, you think that has no relevance to the
question of whether someone might reasonably believe
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.JPA Reporting, LLC - (404} 853-1811 (17) Pages 65 - 68
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PHAF.l>RA C. PARKS vs.
ANGELA STANTON
PHAEDRA C. PARKS
June 19, 2014
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you were involved in criminal activities? That's your
position?
A. As I stated earlier.
Q. Is that your position?
A. This case has nothing to do with my
husband.
Q. Okay. It does. But is that your
position?
A. It doesn't.
Q. Is that your position as I just stated it?
Q. Is that your position -
A. My position is -
a. -- as I stated it?
A. -- this case is about defamation.
Q. Yeah, gotcha. Trust me, I understand
that. I'm asking you questions as to whether you can
prove that claim or not. And part of your claim is as
to whether a reasonable person could believe that you
were involved in the sort of criminal activity that
Ms. Stanton described. And my question to you is: Do
you not believe that your marriage to someone --
A. I do not believe that.
Q. Let me finish my question. You do not
believe that your marriage to someone who was actively
[1] case?
!
[2] A. Yes.
[3] a. Okay. And do you think that as part of
1
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the facts that would underlie your case? Do you :
disagree with that? l
A. I'm not disagreeing with that. i
Q. Okay. And do you disagree that you should
1
provide truthful information that would assist in the I
truth-telling mission of the Court?
A. I have provided such.
Q. You have provided such, is that what
you're saying?
A. Truthful information to you, yes, sir.
Q. Okay. But, yet, you're refusing to answer
my questions as to wh.ether or not you had kno.wledge of
your husband's deriving his income primarily from
criminal activities during the time when you were
married because you don't think that's relevant?
A. That is your assumption.
Q. What's my assumption?
A. Your assumption is that that's how he
derived his income, and no one has said that.
Q. I didn't make the assumption. I asked you
the question. Did you?
_.,__ --------
Page 70 Page 72
involved in financial fraud and the question of [1] A. Did I what?
!
whether you had knowledge of that during your marriage [2] Q. Did you know during the time of your
i
to him, you do not think that is relevant to the [3] marriage that his income was derived from criminal I
defamation claim? Is that a no? [4] activities?
A. First of all, you're making assumptions [5] A. No, I did not know that.
!
that I have - about things that I have not said. [6] Q. Okay.
i
a. You haven't said that and that's the [7] A. Okay.
problem. I'm having to make assumptions because {8] Q. You could have answered that question a
you're refusing to answer my questions. [9J long time ago and avoided all this back and forth.
Do you understand that you can't prove Cl.OJ Okay. So your testimony is you had no
your case if you refuse to provide evidence or {11] knowledge of that?
testimony that would be relevant to your case? (12] A. That would be correct
A. Uh-huh. [13] Q. All right. To your knowledge, what was
Q. You do understand that? (l.4] the source of your husband's income during your
A. That is not what I'm saying. [15] marriage?
Q. You said uh-huh and nodded your head. Was [16] A. As I stated, I will not be discussing my
that a yes? [17] husband. He's not a party to this case. i
I
A. That was not a yes. That was not a yes (18] Q. So tell me this: Are you going to answer I
and that was not a nod to what you were saying. [19] any further questions 1 ask you about the extent of I
a. Okay. So, I mean, do you think you have [20J your knowledge of your husband's criminal activity?
some obligation to prove your claim? You're the [21] A. I will not be answering that. i
plaintiff in this case, right? (22] a. Okay.
I
A. Most ptaintiffs do. [23J MR. ANDREW: I think she just said she
I
Q. That's not my question to you. Do you [24] didn't have any knowledge of his criminal I
believe that you have some obtigation to prove your [25] activity.
I
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JPA Reporting, LLC - (404) 853-181 I (18) Pages 69 - 72
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PHAEDRA C. PARKS
ANGELA STANTON
June 19, 2014
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Page73
Page 75 !
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[1] MR. RADFORD: But now I want to ask - you [1] Q. Okay. You don't dispute that you saw her
!
[2] know, it's cross-examination. I want to ask [2] on a number of occasions after your initial meeting
[3] questions in detail to test the truth of that [3] with her? You don't dispute that, do you?
[4] assertion. If she's not going to answer any [4] A. I did see her, yes.
[5] questions about that, then that's what I want to [5] Q. In what context would you see her?
[6] know. [6] A. Sometimes with the client. Pretty much
[7] Q. (By Mr. Radford) Are you going to answer [7] with him. Sometimes she would stop by my office.
[8] any more questions in detail as to this issue, which [8] Q. Just her?
[9] is: Did you have knowledge of his criminal [9] A. Well, you know, that's been well over 1 O.
!
[10] activities? [10] almost 15 years ago - well, maybe not 15. But that's I
[11] A. I have answered it already, and I won't be [11] been over 10 years ago. But sometimes with him. You I
(12] speaking on itfurther. Thank you. [12] know, t mean, randomly. I
[13] Q. Have you ever discussed your claims [13] Q, So sometimes she would come by herself:
[14] against Ms. Stanton with Mr. Nida? [14] sometimes she would come with him? That's your
[15] A. I will not be answering that. [15] testimony?
(16] Q,
Okay. You don't deny, do you, that you [16] A. Uh-huh.
knew Angela Stanton prior to her writing this book, do Q.
I
(17) (17] When she would come by herself, what would :
{t.8) you? {181 be the purpose of that visit?
l
(19] A. I don't deny that. [19} A. A lot of times she would need a ride
Q,
And you originally met her while you had
'
[20] [20] somewhere. l
(21) some sort of business relationship with a rap artist (21) a. And you would give her a ride somewhere? I
(22) called Drama, is that right? [22] A. Uh-huh.
[23} A. Correct. [23} Q. Is that a yes for the court reporter?
{24] Q,
Oo you know Orama, what his reat name was t24J A. Yes, sir. Sorry about that, ma'am.
[25] or is? [25] Q. Where was your office located at that
.. -- ---- ------------ - ------ .. - - ---- ---!------
76 I
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Page 74
[1] A. Terence Cook.
{2)
Q,
Have you spoken with Mr. Cook recently?
[3] A. No, sir.
[4] a. I may refer to him as Orama; and I know
[5] that's not his real name. but just for ease of use.
[6} Tell me about how you came into
[7} Ms. Stanton's acquaintance.
[8] A. What would you like to know?
[9] Q. Just what I asked you. When is the first
[10} time you met her?
[11] A. As far as the date or what are you --
[12] Q. Describe it to me. I know you probably
[13] don't know the date of it. But describe to me the
[14] context, the occasion, the first time you met her.
[15] A. She was dating my client. and he
[16] introduced me to her.
[l 7] Q. Do you remember where you were when he
[18] introduced you?
[19] A. I don't recall where we were specifically.
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time? I
A. 1069 Spring Street. I
Q. Who is the individual - I asked you
1
earlier - that you shared space with? Ronald
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Freeman, were you sharing space with Mr. Freeman at i
that time? I
A. Yes, sir. ,
Q, All right. Do you recall about how often j
you would give her a ride, as you stated? j
A. No. But during that time I was traveling I
about 75 percent of the week because I was on tour j
during that time. So it couldn't be that often
1
.
because t was usualty out of town Tuesday through .
Sunday.
Q. Okay. Do you recall other reasons she
would come by your office other than needing a ride?
A. No. i
Q. Do you remember where she needed a ride .,.
to?
[20] Q. All right. Do you dispute that after [20} A. I mean, that was well over ten years ago. !
(21]
{22]
[23)
[24]
[25)
meeting her, whether as friends or social [21)
acquaintances or however you want to put it, that you (22]
had ongoing contact with her in a social setting? [23]
A. I would dispute ongoing contact. I had [24}
contact with her. [25]
.. --------- ---- . ' --L-----
Home usually, you know, to her house. I
Q. Okay. So you can't recall any other
1
reason why she would have come by your office other 1
than to ask you for a ride? 1
A. Well, I mean, no.
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.JPA LLC- (404) 853-ISJ J (19) Pages 7J - 76
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ANGELA STANTON
Pagen
Cll Q. All right.
c21 A. I mean, to talk about him, the boy.
C3l Q. Who?
(41 A. Drama.
cs1 Q. So you would discuss with Ms. Stanton your
61 representation of Drama?
c11 A. No. But what I'm saying -- no. What I'm
[9] saying is she would come sometimes and obviously they
C9J would link up or, I mean, just-- it would just be,
c101 you know, random visits.
c111 Q. I don't know.
1121 A. Random visits.
Cl3l Q. Just to hang out?
[141 A. What I'm saying is, it wasn't like it was
c1s1 something that was an appointment. She might just
[161 drop in, drop by. It wasn't like it was scheduled.
[17) It might be a random pop-up. Oh, do you know where he
[18J ls? Has he been by here today? Have you seen him?
[191 They were dating.
[20J Q. Okay. And that happened fairly regularly
c211 during --
r221 A. No, because I was traveling most of the
(231 time. So I wasn't really in the office.
(24 l Q. But not just one time or two times, a
[251 number of times?
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A. Possibly.
Q. Do you dispute that you had Ms. Stanton in
your home?
A. She's been by one of my homes, uh-huh.
Q. Okay. Which one was that?
A. The one on Oregon Trail.
Q. Okay. fs it your testimony that she only
came to the home on Oregon Trail once?
A. I can't say because I haven't had that
home in 14 years, 13 years. So that's been a long
time ago.
Q. So it's possible she may have been there
more than once? You just don't remember?
A. Yeah, it's possible.
Q. You don't dispute that she was there more
than once?
A. I can't say. You know, that's been a long
time ago.
Q. But you don't dispute it? That's what I'm
asking you. You don't have some knowledge to say, no,
I know she wasn't there more than once?
A. No. I don't.
Q. Okay. On the times that you can recall
her being there, what was the reason for her being
there?
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PHAEDRA C. PARKS
.June 19, 2014
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Page 79 :
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A. Again, that was 13 years ago. So I don't
recall, you know. I don't know if it was a social
visit. I don't know if it was him, with him. I mean,
that's 13 years ago.
Q. Okay. I imagine you have given some
thought to this, given you filed a lawsuit and that
sort of thing. You have probably given some thought
with your relationship with Ms. Stanton and the times
you may have seen her.
I
I
I
A. Uh-huh.
Q. Is that a true statement?
A. Yeah. Yes, that would be true. .
Q. Okay. Do you dispute that you sometimes I
attended events at Ms. Stanton's grandmother's home?
A. I would dispute that. i
Q. You would dispute that?
A. Yes, sir.
Q. Do you dispute whether you would have met :
other members of Ms. Stanton's family?
A. No. I have met members of her family.
Q. When?
A. I've been - I've obviously dropped her by
her grandmother's house; and I did meet her
grandmother, obviously, by dropping her off there.
I'd met her mother. And, you know, there could have I
-- .... ---------- --------- I
Page 80 i
been other family members that I met. But, you know. '
I definitely met her mother on a couple of occasions. :
I'm sure.
Q. Okay. What were those occasions?
A. When l dropped her off to her grandmamma's !
house. !
Q. Okay. So on more than one occasion you 1
took Ms. Stanton fn your car to -
A. Yes.
Q. - her grandmother's home?
A. Uh-huh.
Q. And you went inside and met with the
members of her family?
A. I mean, yeah.
Q. Okay. Do you recall about how often that
happened?
A. I can't recall how often. I mean, but if I
someone invites me into their home and I'm giving them
1
!
a ride, I mean, I will oblige them.
Q. Okay. Why would you go inside if you were I
just dropping her off? ;
A. If someone invites you inside and says, j'
hey, meet my relatives --1 mean, I'm from the South.
That's very southern to do. !
Q. Okay. Do you recall ever having her
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ANGELA ST ANTON
PHAEDRA C. PARKS
June 19, 2014
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children in your office?
A. Never.
Q.
Are you sure about that?
A. I'm pretty sure about that.
MR. RADFORD: Okay. I want to put an
exhibit on the record, but let me do this for the
record. I'm going to mark this as Defendant's 4.
I'm going to show you the exhibit for the record,
but I have a color photo on my iPad here that
l'JJ show you.
identification.)
Q. (By Mr. Radford) Does this appear to be
the interior of an office that you maintained at any
point?
A. No.
Q. No. Do you recognize the person in the
doon.vayinthatphoto?
A. That looks like me, but that doesn't look
like an office I maintained.
Q. What about that little statue there on the
table in the foreground, does that look familiar to
you?
A. 1t doesn't, to be very honest to you or
with you.
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Page 82
Q. This isn't your office space at - I think
irs at 1069 Peachtree?
A. I had an upstairs office that definitely
was very small with just two chairs.
Q. I see one chair here.
A. It didn't have a couch.
Q. Okay. This looks like a lobby area. Was
there a lobby area in that office?
A. I mean, the office was pretty big. So
this could be somewhere in that office, but I don't
recall this. Just being very honest with you, I
don't.
Q. It looks like you're holding a child and
then there's a child in the foreground asleep on the
couch. Do you recognize those children?
A. I don't.
Q. You recognize those to be Ms. Stanton's
children, don't you?
A. l don't recognize those to be her
children.
Q. This is a photo of you and Ms. Stanton's
children in your office, isn't it?
A. I don't recognize them to be her children.
Q. Do you dispute that what I've just
stated?
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identification.)
Q. (By Mr. Radford) I show you what I've
marked as Defendant's Exhibit 5. I'll show you a
color copy on my iPad so you can see a better view. ,
Do you recognize that to be part of some office space j
where you once maintained some space?
A. It could be; but, I mean, I don't - I
don't recognize it, just to- be- honest with you, but ft
could be. I don't recognize it, though.
Q. Do you dispute that that's an image taken
somewhere where you maintained office space?
A. I have to dispute it because I don't
recognize it as being a part of that office.
Q. Okay. And do you know who that little boy
is in the chair there?
A. I-do not.
Q. Okay. In fact, this is a photo of one of
Ms. Stanton's children in your office, isn't it?
A. I don't know it to be so. I don't know
that this is my office, and I don't know this to be
her child.
Q. Okay. You say 1069 -- was it Peachtree or
Spring?
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A. Spring.
Q. Spring Street. Was there a suite number?
A. No. It was an upstairs double-story
building.
Q. Do you know who's in that space now?
A. I don't.
Q. All right. I'll take that back from you.
In the first image I showed you that we
marked as Defendanfs 4, you don't dispute that that's '.
you in that image, do you?
A. It looks like it's me. :
Q. As you look at these images, does that in l
any way change your testimony as to whether you deny t
everhaving Ms. Stanton's children in your office? i
A. It doesn't because I don't recognize this I
to be my office and I don't recognize those children I
to be hers. I
Q. Okay. Have you ever seen any of her
children before?
A. She was always pregnant when I knew her.
either pregnant or just had a baby or pregnant.
Q, Okay.
A. You know, sol don't recall. You know, I
know she had numerous kids; but l don't ever -- 1
never knew her to have custody of them.
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C. vs.
ANGELA STANTON
Page85
[l] Q.
Okay. So your recollection is you didn't
[2}
think she had custody of any of her kids?
[3) A.
I don't recall her ever having custody of
[4]
any of them. I knew she had them. She had several
[5}
children, but I never recall her having custody of any
(6} of them.
[7] Q.
Well, how did you have any knowledge or
[8]
another of what her custody situation was?
[9) A. Because she never had them.
[10) Q,
So your recollection is you never saw her
[11] with her kids?
[12] A. No. I mean, she was usually pregnant.
[13] Q.
What does that have to do with whether you
[14) saw her kids --
[15) A. I mean, I'm just telling you --
[161 Q. -- being pregnant?
[171 A. -- when I saw her, she was normally
[18) pregnant or had just had a baby or pregnant again.
[19) mean, I didn't see her like every day. But the times
[20) I did see her, she was pregnant or just had a baby.
[21) Q. I asked you if you saw her with her kids
[22) and you said -
(23) A. No.
[24) Q,
- she was pregnant. She can be pregnant
[25) and have kids.
Page86
[lJ A. That means you're with child. When you're
c21 pregnant, you're with child, right? Correct?
C3J Q. So you're saying you saw her kids because
c 4 J you saw that she was pregnant?
[51 A. I'm not saying I saw them. I said she was
c 6] with child. If you're pregnant, you're with child.
171 Q. Okay. Who is Everett Tripodis?
ra1 A. As far as?
C9J Q. Is that someone who you know?
c101 A. Yes, I know him.
c111 Q. Who is that? How do you know him?
c121 A. He's one of my husband's friends.
(131 Q, Okay. Did you know Mr. Tripodis priorto
c 14 J your marriage to your husband?
[151 A. I had seen him one time prior to being
[16] married to my husband.
[17l Q. And Mr. Tripodis has appeared on the Real
[181 Housewives television show with you, hasn't he?
[191 A. I can't say that for sure to be honest.
1201 He might have; he might not have.
c211 Q. Did Mr. Tripodis drive you to the hospital
c221 at some point when you were delivering one of your
231 children?
[24l A. He might have.
r2s1 Q. That seems Uke something you would
PHAEDRA C. PARKS
June 19, 2014
Page 87 !
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remember, J guess. right?
A. Well, when you're in labor. you don't
recall a lot.
Q. Okay. Do you dispute that Mr. Tripodis
drove you to the hospital? That was featured on
television.
A. Oh, no. You know what. He didn't drive
me to the hospital.
Q. Okay.
A. He did not.
Q. Do you dispute that he was on television
alongside you?
A. I mean, I don't know how they showed it on
television; but I know he didn't drive me to the
hospital. After thinking about it, he did not
[16) a. Okay. Do you think the show may have l
[17)
[18)
concocted a scenario to make it look like he drove you ;
to the hospital?
[19) A. I can't say because. obviously, that's ;
[20]
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been four years ago. So I don't want to say because I ,
don't remember every episode. It's been over 100 '
episodes. So I can't say that I recall that episode.
But I know he didn't actually drive me to the
hospital.
[25] Q. Okay. You don't dispute that Mr. Tripodis
--------- -------------- . I
Page 88
111 has been someone shown on this television show and jl
r21 depicted as someone associated with you. correct? ,
I
[31 A. I'd sort of have to say I can't agree with !
r 41 that.
cs1 Q. Okay. Tell me why you disagree with that.
c 61 A. Because I haven't seen him showed
c11 prominently on the TV show that I recall.
(81 Q. Okay. Do you dispute that he was on the
[91 show and depicted as having some relationship to you?
c101 A. I don't recall because that's been over
r111 four years ago, but I don't recall him being
c121 prominently displayed on the show.
131 Q. Well, let's take the word "prominently"
[141 out of it, okay. Do you recall that he was depicted
c1s1 on the show? i
Cl6l A. I don't recall that. to be very honest. j'
1111 You know, he's probably been on the show; but I don't .
[181 recall that he was, you know, depicted as being
Cl91 someone so very close to me. I don't recall that.
c201 Q. I didn't ask that. I didn't say he was so
c211 close to you. I said he was depicted as someone on
c221 the show by merit of his relationship to you, a cast
C23J member on the show.
C24J A. Wait. Repeat that again.
251 Q. It wasn't like they did a pan down the
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ANGELA STANTON
PHAEDRA C. PARKS
June 19, 2014
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street and there were just random people on the street
with no relation to anyone and he happened to be among
the people. I'm saying, in contrast, he was depicted
on the show and by merit of the fact that he knew you
or had some relationship with you. Do you recall
that?
A.
I mean, he possibly could have been on the
show.
Q.
I know he possibly could have been.
Anything is possible.
A. That is correct.
Q.
Okay. I'm asking if you dispute that or
not.
A. I can't answer it yes.or no because I
don't recall.
Q,
You don't recall what?
A. I don't recall if he was depicted on the
show as someone close to me.
Q. I didn't ask you if he was close to you.
A. Okay. So what are you asking?
Q. Do you dispute that he was on the show?
A. I don't recall. So he possibly could have
been, but I can't say that he actually was.
Q,
So you do dispute that?
A. I don't recall.
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obviously had some issues, but I don't know I
specifically what his issues have been. I
Q. Okay. Do you know that he is a convicted
felon?
A. Yes. I do know that.
Q. Okay. And do you know that his crimes
were financial crimes of some sort?
I
A. I don't know that to be true.
Q. Okay. Let me just ask - and this is a ,
tegal questton, but you understand that your testimony l
today is under penalty of perjury, correct? l
A. I do understand that.
Q. And you understand that if I ask you a r
question and you say that you don't recall and you do j
in fact recall, that is perjury? You understand that, :
correct? !
A. I do understand that.
Q. Okay.
A. But that doesn't mean that I recall it
just because you want to tell me the rules of perjury.
Q. I understand. I just want to make sure
you understand.
A. I do understand.
Q. And do you understand that if I ask you a
question and you say I don't know, that is also
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Page90 Page 92 !
Q. Fine. UJ perjury if you do in fact know?
A. Meaning I don't remember. r21 A. I do understand that.
Q. You don't remember whether he was ever on [31 Q. Okay. Do you recall Mr. Tripodis being
c 4 J the show? r 4 J arrested at some time when you knew him?
[5] A. I don't remember. He could have been, but [51 A. I do. I
C6l I don't remember. That's been well over four years [61 Q. Okay. Do you recall around when that was? I
71 ago. So I don't remember specifics. [71 A. I don't recall when it was. Yeah, but I
[81 Q. All right. Mr. Tripodis is someone who [81 do recall it; but I don't recall when it was.
[91 has been convicted of a number of financial crimes. C9l Q. Tell me what you recall about that.
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Would you disagree with that? c101 A. As far as what do you want me to recall ,
A. I would have to because I'm not his Clll about it? I
attorney, so I don't know what he's been convicted of. (12) Q. What happened, to your knowledge? Why was ;
Q. You don't have to be somebody's attorney (131 he arrested? :
to know if they were convicted of something. You said [14] A. I don't know why he was arrested. But I i
he was a friend of your husband. [151 know he was on the lam and something happened. And I
A. Well, I never attended a trial for [161 obviously he had called my husband, and they thought 1
Everett; and I don't know Everett's legal issues. [l 7J my husband was him. And it was something crazy. And I
Q. Okay. He's a friend of your husband, is c1s1 then they later found him. !
that right? Cl9J Q. Okay. How did you team about thrs?
A. That is correct. c201 A. From a blogger.
c211 Q. And if I ask you the question do you have c211 Q. From a blogger?
c221 any knowledge of whether or not Mr. Tripodis has ever c221 A. Uh-huh. Someone calling my office and
[231 been convicted of a crime, you're telling me -- [23] asking me did I know anything about it.
I
[241 A. I can say he's been convicted of a crime. [241 Q. Okay. When did this happen, like within
[_c_2_s_1 .. What But r_ t:_ the last two years or _ --------
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Page 93
ClJ A. No, no, no. It's been at least over three
c21 years ago.
C3l Q. Okay. Do you recall him being arrested
c 4 l sometime in the time frame of 2004?
CSJ A. No. I mean, I didn't really know him in
[6) 2004.
[7J Q. Okay. Well, that's an important point.
[8] So your testimony is you did not know Everett Tripodis
C91 in 2004?
c10 l A. J met him one time in the '90s after I met
Clll my husband, and I didn't see him anymore until after I
r121 married my husband.
[131 Q. I know your husband recently is about to
c 14 J go to jail. What was the period of time of his last
c1s1 prison sentence?
[161 A. t don't know. I know he went in 2000, but
[17] I can't give you a specific date. I would not know.
us1 Q. What year did he get out of prison?
[191 A. He got out in 2009.
[20] Q. 2009.
c211 A. So he probably went around 2005 because he
c221 was there for five years. So 2005.
C23J Q. Okay. And your testimony is you had no
[241 d'eafings with Mr. Tripodis during any time when
[251 Mr. Nida was incarcerated?
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Page94
A. No; huh-uh. I did not.
Q. Oo you know who Sharee Strickfand is?
A. No, no. I don't know who that is.
Q. Do you recognize that name at all?
A. It sounds familiar, but I can't say that I
know who it is. I mean, do you have a picture?
Q. No. Do you recall or isn't it true that
you had a limousine go pick Mr. Tripodis up at a
federal halfway house to come to your wedding?
A. No, I didn't.
Q; That's not true?
A. That is not true.
Q. Did he attend your wedding?
A. Hedid.
Q. Okay. Do you have any knowledge as to how
he got there?
A. I don't I don't l<now how he got there.
but he attended.
Q. All right.
A. He was in the wedding.
Q. Was he the best man?
A. He was a groomsman. I don't know if he
was the best man, but he was definitely a groomsman.
Q. Do you know where Mr. Tripodis is now?
A. l don't
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PHAEDRA C. PARKS
June 19, 2014
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Page 95 '.
Q. If I told you he was in prison, would that
surprise you?
A. Possibly not. i
Q. Possibly not. What does that mean? Would /
it surprise you? !
A. Nothing really surprises me.
Q. Okay. Did you know he was in prison prior
to me just telling you that?
A. Yeah. I had heard that he had been
convicted of something and was back in prison.
Q. Okay. How did you hear that?
A. A girl that knows him knows me was telling
me about it.
Q. Okay. Your husband didn't tell you about
it?
A. We don't discuss Everett.
Q. Why not?
A. Beeausewejust-don't.
Q. Is that a sensitive subject for some
reason?
A. No.
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Q. Are you aware that Ms. Stanton and 1
Mr. Tripodis were coindictees that were indicted on I
the same federar I
A. Uh-huh; yes, sir. !
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Page96 !
r11 Q. You're aware of that?
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A. Yes.
Q. And for mutual involvement in a scheme to
steal automobiles, are you aware of that?
A. I don't know a lot of details about it,
but I'm aware that they - I think she testified
against him.
Q. I don't think thars true, but --
A. That's what I was told.
Q. Okay. Who told you that?
A. f believe Everett told me that.
Q, When did you have that conversation with
him?
A. Oh, that's been years ago.
Q. How did that come out? What were you
talking about that that came out?
A. I don't reca!f. But. I mean, he would be
the only person that obviously would know that she !
testified against him. I
Q. Were you representing -- l
A. No, I have never represented Everett. I
Q. Okay. So why were you talking about his
criminal case with Ms. Stanton?
A. I didn't say I was talking about his 1
criminal case with Ms. Stanton. I said he advised me I
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ANGELA STANTON
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Page97
that she testified against him.
Q. Okay. Well, why were you talking about
that?
A. I don't think I was talking about that.
think he was telling me about it.
Q. Okay. How did it come up?
A. I don't recall. That's been eons ago.
Q. You appeared as an attorney on behalf of
Ms. Stanton sometime in 2004 in a criminal matter. Do
you recall that?
A. Uh-huh, a probation revocation.
Q. ts that a yes for the court reporter?
A. Yes, a probation revocation.
Q. Are you sure? Do you think it may have
been a sentence modification?
A. Maybe a sentence modification. Excuse me.
I was wrong.
a. Okay. How did that representation come
into being?
A. She was pregnant and I think she had
gotten a new charge and she asked for some help and I
went. And she said I'm pregnant, I obviously need to
.get a modification so I can have my baby and not be in
prison again. And so I said, you know, what do you
need? And she said I need, you know, to ask if I can
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Page 98
have the sentence modified.
Q. Do you remember what court that was in?
A. Clayton County, but I can't remember,
maybe Clayton Superior.
a. Do you recall how you came into contact
with Ms. Stanton? Did she call you?
A. I'm sure she would have called or come by.
Q. Okay. Did she pay you for that?
A. I doubt it.
Q. You did it for free?
A. Yeah. I mean, I don't recall. But I'm
sure I mean, she's never really had money to pay.
Q. Why would you do that for free? I mean,
do you typically - why would you do that for free for
her?
A. If someone is pregnant and they obviously
are very pregnant at that time -- I think she was near
birth -- and she - a lot of the times -- she was in
and out of jail most of the time I've actually known
her. And, you know, to be very honest, I wanted to
help her because she was always into something or. you
know, battling with something, whether it be
pregnancy, some kind of trouble that she was having in
her personal life. And so it's not unlike me not to
be very helpful. And so if someone calls me, I will
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PHAEDRA C. PARKS
.June 19, 2014
Page99 !
help them. I mean, and I would --you know, I didn't j
have kids at that time. But I didn't want her to be
pregnant and in prison again.
Q. So you're saying from the time you first
met her through your client Drama through this 2004
time frame when you represented her in court, you knew j
throughout that time that she was always in some ktnd I
of trouble, is that right? .
A. Pretty much so.
Q. How did you know that?
A. Well, Drama would know. But she would I
I
always talk about she always had problems. I mean. I
she was a stripper, you know. So it was just -- she
obviously had issues. I
Q. Okay. And you spoke with her throughout j
that time about her issues? I
A. Well, not throughout. I can't say :
throughout that time. But, I mean, she would surface. i
go to jail somewhere, resurface. So she would pop up l
and in and out a lot of times. I mean, and her and
Drama were continuously on and off in their
relationship. They would be together. They wouldn't
be together. She would be pregnant. He wouldn't know !
if it was his child. She wouldn't know if it was his i
child. So it was always something contentious with !
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Page 100 I
them.
Q.
A.
know.
Okay. And you were privy to all this?
Some of it. I mean, pretty much so, you
j
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a. I mean, you seem to have a pretty close
knowledge of everything that was going on between !
them.
A. Yeah. Oh, well. he was obviously my
client and -- yeah.
Q, Okay. And she spoke to you about these
issues? You and her spoke about these issues?
A. Sometimes. I mean, I don't know how much
she told me; but, I mean, sometimes we did.
Q. You represented Drama with respect to his
musical career, is that right?
A. Yes.
Q. You didn't do any crimina! representation
of him, did you?
A. ldid.
Q. You did, okay. What criminal matters did
you represent him on?
A. I don't know if I can reveal that.
Q. I'm not asking you to tell me any
privilege. I mean, you know, if you represent someone
at a trial, for example, you file notice of
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PHAEl>RA C. PARKS vs.
ANGELA STANTON
Page 101
[ll appearance. You say I'm representing. So that's not
c21 a privileged piece of information. So I'm asking you
c 3 l what sort of criminal matters did you represent him on
c 4 J as his attorney.
[SJ A. He had some felonies.
c 6J Q. Okay. He went to prison in 2001, do you
Pl remember that?
[SJ A. I think it was maybe -- yeah, maybe 2001.
C9J Q. Okay. Did you continue to represent him
c101 after that time?
c111 A. Yes, sir.
[121 Q. How long did you represent him after that
13J time?
Cl4J A. I don't know if I can actually divulge
[lS) that
tl6J Q. I think you can. How long did you --
171 A. May I speak to my attorney off the record
c1s1 for a second?
Cl9J MR. RADFORD: Sure.
r201 (Off the record.)
c211 Q. (By Mr. Radford) So the question was:
[22] How long did your representation of Orama continue
[23J after he went to prison in 2001?
C24J A. Several years after.
c2s1 Q. Okay. And did you continue to represent
--- -------- .... ---
Page 102
[1] him with respect to music issues during that time or
[2] was it primarily with respect to criminal issues?
[3] A. Both.
(4) Q. And your recollection is with the sentence
[5] modification hearing that you represented Ms. Stanton
c 6] on in 2004 you just did that for free?
[7] A. It is 2004, so that's been over ten years
[8] ago now. I don't recall -- I mean, it was a very
[9] short hearing. It was a day, you know, 30, 40 minutes
[10] at most. So it wasn't an extensive representation or
[11] an extensive amount of work.
[12] Q. So you did it for free?
(13] A. More than likely, yes.
[14] Q. And that's because you - she wasn't just
(15] someone who was referred to you. She was someone who
[16] you had some kind of personal relationship with?
{17] A. She was dating my client.
(18] Q,
And your testimony is that was the extent
(19] of the relationship, the fact that she was dating your
(20] client?
(21] A. Pretty much so.
[22] Q. Okay. You also represented Ms. Stanton's
[23] mother in a cfaim related to an auto accident, is that
[24] right?
!25] A. I don't recall that.
PHAEDRA C. PARKS
June 19, 201.t
Page 103 ;
Cll Q. Are you disputing that happened or you are
c21 just saying you don't recall?
C3J A. I don't remember it. I mean, I'm not
C4l saying -- it might have happened, but I just don't-
C5J I don't remember it offhand, just to be honest.
{6J Q, Do you know Justin Cody?
C7J A. Yes, sir.
CSl Q, Who is that?
C9J A. A young artist, rapper.
c101 Q. Is he someone who you represented as an
Clll attorney?
c 12 J A. No, sir.
[13] Q. How do you know him?
(141 A. I think he's one of her baby's father's.
c1s1 Q. Well, how that does mean that you know
C16J him?
c111 A. Because he's a musician. I know the
[lBJ people he was signed to. But she dated him while she !
[191 dated my client as well.
1
c201 Q. And so you knew Justin Cody through
c211 Ms. Stanton?
c221 A. I would -- yeah, I would assume you could
C23J say that.
[241 Q. I know from your lawsuit you deny, you
[251 know, that you ever had any involvement in any
--
[1]
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Page 104 ~
criminal dealings. Did you ever use Angela to do any !
type of work for you?
A. Never.
Q. Okay. So if someone testified that they
were present when Ms. Stanton delivered some items to ,
you in a car in a parking lot, you would dispute that? II
A. lwould.
Q. Did you represent Mr. Cody in an auto
accident case? i
A. I don't recall. I mean, I know Justin; i
but I don't recall ever representing him. I mean, I j
possibly could have because I hadn't dealt with him ,
in -- you know, even dealt with her, you know, had any I
remote knowledge of them in over ten years. So if I
it's something ten years ago, I mean, I've had, you
know, gobs of cases since then.
Q. So you don't dispute that you represented
him?
I c211
[22]
A. I'm saying I don't recall. I mean, I
haven't seen Justin in well over - well over 10
years, if not 11 years.
Q. Okay.
!C23J
1
[24]
(25]
'
A. So, I mean, I don't recall every case I've
ever had. I mean, on a Pl case. it's not like I would
be so intimately involved with it that I would just
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ANGELA ST ANTON
c11 remember every case that I have.
Page 105
c21 Q. Okay. You did have some contact with
C3J Mr. Cody fairly recently electronically, is that
[4] right?
!51 A, What do you mean by "electronically"?
t 6l What are you referring to?
C7l Q. Like over the Internet.
C8J A. What do you mean, "over the Internet"?
(9] Q. Did you exchange some electronic messages
c101 with Mr. Cody over the website Twitter?
c111 A. Oh, I think he tweeted me and I tweeted
c121 him back. But thafs been two or three years ago, if
[131 I'm not mistaken. That wasn't like recent.
Cl4l Q. Didn't you speak with him on the phone
[151 after that interaction?
(161 A. He called my office, if I'm not mistaken,
ll 7J or maybe even my cell phone. But I might have spoke
(181 to him one time.
Cl9J Q. What did y'all talk about?
c201 A. He was just saying that he knew that
c211 Angela was, you know, obviously harassing me.
c221 Q, That she was harassing you?
[231 A. Uh-huh.
C24J Q. And what did he tell you?
[251 A. That he knew she was harassing me. That's
Page 106
c1 J the gist of the conversation.
c21 Q. Like he was calling to comfort you about
[31 this or he was providing you some information?
C4l A. I don't remember him providing me any
[5J information. He was just saying he felt bad that she
c 6 l was harassing me because he knew that I had never done
[71 anything to her, you know, and had always tried to
cs1 help her anytime 1 could and he was like that was just
c 9 l horrible.
c101 Q. He was just calling you to tell you he
c111 felt bad?
c121 A. Yeah, pretty much so.
[13J Q. Okay. You also did some legal services or
141 something for Ms. Stanton while she was in jail to
c1s1 help her attend her mother's funeral, is that right?
c16J A. I did, yes.
c111 Q. How did you get involved in that
.
1
U8J situation?
(191 A. I received a call. I don't know if it was
[20) from her sister-in-law or someone said her mom had
c211 died, and they wanted to try to see if I could help
c221 them get her to her mother's funeral. I mean, and I
[23] said, you know, anything I can do to help you because
[24 J I knew that that was horrib1e. So i made some calls
C25l to the sheriff - I think it was in Gwinnett County --
L_ .... ------------- .. --. -- --
PHAEDRA C. P l ~ K S
.June 19, 201-1
Page 107 j
j
c11 and, you know, helped them get her out so she could I
(21 attend her mom's funeral. j
[3]
Q. Okay. Did you charge any money for that? !
(4J A. No, no way. I
rs1 Q. And you actually attended her mother's I
C6l funeral, didn't you?
[7]
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A. I did.
Q. And why did you attend her funeral?
A. Strange enough, I am a mortician, a
licensed mortician. currently. But I am somewhat ;
intrigued by funerats. You know, so it's not strange !
for me to attend people's funerals because I find I
funerals somewhat intriguing. 1
a. Just anybody's funeral?
A. Yeah. l
Q. You just go to funerals without having a I
personal connection?
A. No. What I'm saying is is obviously I was
working to help her get there. So since I was a part :
of trying to help her get there, I would not attend
after I did all this work to help her get to her
mother's funeral.
Q. What? You would not -- say that again.
A. I wouldn't not attend - I wouldn't not j
attend a funeral that I helped someone obviously get \
I
------- > ------- ---- > - - .,
Page 108 !
to.
Q. You mean you would attend?
31 A. I would not not attend.
C4J Q. Okay. And this was just a matter of
(51 professional intrigue because you're interested in the
business of funerals? I .[6]
(7] A. No. But it's because I helped her get out ii
cs1 to go to the funeral. So I wanted to make sure that
[91 obviously she made it to the funeral because I had .
made all these calls so that she could be released to I
come to the funeral. So I wanted to make sure that ;
she mad.e it to the funeral. So I wanted to attend to I
make sure that they actually brought her after they I
confirmed with me that they were going to bring her to I
the funeral. !'
a. Why? What stake did you have in whether :
[10]
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she showed up or not? I
A. lt's because I had called m the favor and I
made all the calls so that she could attend the l
funeral. I
Q. Okay. But what's this whole thing about
you being a mortician? Did you do this because you l
were interested from a professional standpoint or !
because you wantmi to foffow up on yout legat work? !
A. No, it wasn't any legal work. It wasn't
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ANGELA STANTON
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Page 109
Cll legal work for me to help her assist her to get there.
121 But it was a matter of just respect. Obviously, I had
C31 made the calls to help her get out. And so out of
c 4 J respect, I would not obviously make the calls and not
C5l follow up to make sure that they actually brought her
C6J to the funeral.
[71 Q. Okay. Well, you first answered by saying
cs1 you're a mortician.
C9J A. I am.
1101 Q. Okay. So is that the reason why or this
u11 thing you just explained because you wanted to -
121 A. I'm intrigu_ed by funerals. Yes, I do like
C13J them.
C14J Q. All right. And do you recall holding any
c1s1 of her children at the funeral?
C16J A. I don't recall that.
[1'7] Q. No, okay. Do you remember where the
c1s1 funeral was?
Cl9J A. I don't recall.
1201 Q. Did people there recognize you? Did you
1211 talk to anyone? That's two questions. Did you talk
c221 to anyone at the funeral?
[231 A. I mean, I don't recall. That's been years
C24J ago.
[25] Q. So it's possible you may have just stood
------- - - -
PHAEDRA C. PARKS
June 19, 2014
[1]
[2)
-Page 111 l
I
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Q. Okay. And you just happened to see her
occasionally as a result of that?
C3l A. She was a young lady that obviously had 1
[4] lots of issues. Anytime she would call me for help or l
[51 whatever. I would attempt to help her. She was in and
[6]
out of jail quite frequently. If she asked me a i
C7J question and I knew someone that could help her. I I
[8] would tell her. I would do that to anyone. You know, I
c 9 J now I'm a mother and I understand even more about how I
(10]
(11]
[12]
[13]
[14]
(15]
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to be helpful to people. But at the end of the day, i
I'm a very helpful and gracious person. Whether I'm :
in a courtroom on a case that I haven't been paid for.
1
if there's a defendant in there, they need some
advice, and they say, hey, are you a lawyer, will you
help me, I will help them. That's just the type of
person I am.
Q. Okay. So you do a lot of pro bono regal
[181 work?
[191 A. I do, a lot.
c201 Q. Do you recall Ms. Stanton contacting you
1211 sometime after she got out of prison in 2005?
[22] A. I recall her contacting me saying she had
(231 a rap song.
C24J Q. Okay.
[251 A. And she wanted to send it to me. I recall
-- ----- ---------------- ---- ---- --------- _______ _,__ _________ - -- ----- - -- --- ---- --- - I
Page 11 O Page 112
[l] there at this family's funeral who you're not in the c11
c21 family and didn't talk to anybody? c21
(31 A. Have you ever attended a funeral? C3l
[4]
[SJ
[6]
[7}
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[161
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Q. Yes. C4l
A. Okay. Well, when you attend a funeral, C5l
it's usually in a church. You usually speak to C6l
people. That's what people do. So it wouldn't be [7]
uncommon if you're at anyone's funeral to speak to C8l
people and be cordial. C9J
Q. Okay. So that's what you recall, just c101
chit-chat, sort of? c 11 J
A. I mean, that's been a long time ago, too; Ll2J
so it's not like I have some ingrained memory of it. C13J
Q. Were you at the funeral and the wake? [141
A. I don't remember being at a wake. [151
Q. Okay. Do you see how it could strike [161
someone as strange that you would do all these favors I cl 7 J
fof a persoo who youorny knew by merit ef them being j c 18]
the troubled girlfriend of one of your clients? I Cl...91
A. I don't see how it could. c201
Q. Okay. According to you, the extent of I c211
your having any acquaintance with Ms. Stanton was just 1221
due to the fact that she was dating one of your I [231
cffentS? f t24}
A. Yes. I 251
I
I
her contacting me saying she wanted to do a book: and I
I gave her an agent's name, several agents' names. So I
she would call and ask me things all the time. I !
don't know if it was 2005. I don't know the year. i
But she would randomly call, hey, do you know someone I
that could help me with this. I've got a rap song. j
You know, I want to be a rapper now. You know, so i
that wasn't strange, you know. So I would say send it j
to me if you've got something that's good. Oh, I'm ,
working with this, you know. Do you know somebody I
that can help me with this? '
Q. Okay. Do you recall her contacting you,
stating that someone, a music producer, had raped her.
somebody named Johnnie Cabbell?
A. I do recall her contacting me.
Q. Did you talk to her about that?
A. Yes .
Q. Do you feeaH, accOfdffig to fler, why was
she contacting you? Did she state why she was
contacting you?
A. My recollection is that she wanted to try .
to get some money out of Johnnie, and I told her she 1
should obviously call the police and report the rape. .
Q. Okay. Did you speak more than onee? 1
A. 1 don't recall. I mean, because, again,
!
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JPA Reporting, LLC - {404) 853-181 I (28) Pages 109 - 112
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ANGELA STANTON
PHAEl>ltA C. PARKS
June 19, 2014
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Page 113
it was one of those calls where out of nowhere you c 1 J
would just -- the phone would ring, it would be her, c21
and she was saying I've got this issue, someone raped [31
me. I said you need to call the police. Well, I [41
think I would rather get a settlement from him. And C5l
I'm like, well, that's not really how it works. You C6l
need to have a case, you know, do a criminal case. I [7J
mean, you just can't hustle, you know, money out of caJ
everybody. C9l
Q. So that's your recollection of that c101
conversation? c111
A. Uh-huh. r121
Q. Do you know Goldie Taylor? 131
A. Uh-huh. I do. C14J
Q. Do you recall having any discussions or r1s1
conversations with Ms. Taylor about Ms. Stanton? [161
A. I actually gave -Angela called me [17J
because I think she was doing a - trying to do a book c101
deal with Goldie. C19l
Q. Who called you? Angela called you and c201
said she was trying to do a book deal with Goldie? c211
A. Uh-huh. c221
Q. Okay. C23J
A. And asked me did I know Goldie; and 1 said (241
yes, I know Goldie. c2s1
Page 114
. - -.-Page 115 !
it was just - it had just become - you know, she was
saying all this crazy stuff to me on Twitter and to
the point that I felt that she had become dangerous.
And so I went and reported it to the police.
Q. Did she make any kind of threat?
A. She made some threats obviously that I
felt were serious enough that I -- you know, I just
went and reported it.
Q. Did you maintain a copy of any of those
1
Twitter messages or tweets, I guess they're called? j
A. Uh-huh. I do have some. '
Q. Okay. I guess how did you become aware or I
did you become aware prior to her book actually being i
announced or released that she was authoring a book? I
A. I think just on Twitter, to be honest. !
Thars what I -- I mean, I think it was just on social l
network. I mean, from my recollection it was through I
social network. I
Q. Okay. Did you attempt to contact her or I
anyone-
A. No.
Q. -- to prevent this book from being
published?
A. Huh-'uh.
Q. Is that a no?
Page 116 !
Q. Okay. Cll A. That would be a no. No, sir.
A. And at that time I didn't realize Goldie c21 Q. Okay. Why not?
was-- I didn't realize she was in the book business C3J A. I mean, I didn't know how to contact her.
at that point. c 4 J I had no Interest in contacting her. She had
1
Q. Okay. After that point did you ever talk [SJ obviously made threats against my life and my baby's j
with Ms. Taylor. Ms. Goldie Taylor, about Ms. Stanton? C6l life and so I felt very threatened. i
A. Maybe. I mean, I know Goldie. We see [71 Q. What sort of threat did she make against I
each other on and off. But it's not like, you know, [8J your life? j
we talk to each other quite a bit. She lives in c 91 A. It was around Christmastime, something she
1
New York. So I don't really see her so much. So I c101 was going to stab me in the back and do all this stuff I
don't recall that we specifically had some c 11 J to me. And so I had went and took those threats down 1
conversation about Angela. c121 to the police department and filed a complaint. i
Q. Prior to Ms. Stanton actually releasing [131 Q. And you're referring to messages that were !
the book Lies of a Real Housewife, did you come to any [141 on Twitter?
knowledge that she was writing a book in which you [15] A. Uh-huh.
were discussed or that she was planning to release a (161 Q. Okay. And you say you have copies of
book of that nature? c111 those that you could provide us?
A. She had began to harass me on Twitter, and c101 A. I believe so. But I know you can
J actually had filed a warrant against her because she Cl.9J obviously - it's .public record. It's in Smyrna
was hara!"sing me on Twitter. And I think that's how I (20] Police Department. It's a file.
found out about the book. I c211 a. Smyrna, City of Smyrna?
Q. When you say she was harassing you on c221 A. City of Smyrna.
Twitter, what was she doing? [23] Q. Okay.
A. Threatening me. At that time I think I [24] A. And it's from, I think, 2010.
just .. __ j_{_2s_1 __ 0_. Okay .
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Page ;11 r--
PHAEDRA C. PARKS
June 19, 2014
- Page 119 i
c11 A. In December. Ul
c21 MR. RADFORD: Let's take a quick break. c21
C3l (Recess from 4:01 p.m. to 4:05 p.m.) C3J
41 Q. (By Mr. Radford) Did you and your husband [4]
51 ever discuss reaching out to Ms. Stanton after you 51
c 61 learned that she was intending on writing a book to c 61
PJ discuss trying to resolve any disputes with her? c11
C8J A. I don't know. I mean - [BJ
c 91 Q. Is that the extent of your answer. I don't c 91
c101 know? r101
c111 A. I mean. you know, we discuss a lot of 1111
c121 things. I mean -- c121
interactions Ms. Stanton would have had with your
husband by merit of you representing the boyfriend of
someone Ms. Stanton was dating, is that correct?
A. Huh?
Q. I know. That's very confusing, I know.
A. Yeah. I'm very confused by that.
Q. Well, you have testified the extent of
your relationship with her was through this Drama
fellow, correct?
A. Uh-huh.
Q. Okay.
A. That's how we met.
[131 Q. Okay. Does that complete your answer? [131
[141 A. It does. Cl4l
Cl5J Q, Okay. I guess you're aware that your [15J
[l6J husband gave an interview with a magazine called [161
[17] Sister 2 Sister in which he discussed Ms. Stanton and c111
Q. And you're not aware of any reason why
Mr. Nida would have been privy to that relationship, I
is that fair to say?
A. That doesn't really make -- say that again
because f'm --
[181 her case? [18J Q. Well, let me ask you this: Are you aware ,
[191 A. Yeah. I'm aware he gave an interview. I [191 or did you ever witness any event in which Mr. Nida, l
your husband, met or interacted with Ms. Stanton? i c201 haven't read the interview, but I'm aware that he did [20J
c211 give one. c211 A. Not that I recall.
1
c221 (Defendant's Exhibit 6 was marked for c221 Q. Okay. So if he were to say, if Mr. Nida j
(231 identification.) C23J were to say, I know Angela Stanton, you would have no I
way to know how he would know her, is that correct? .
1
C24J Q. (By Mr. Radford) Well, let me show you [241
[251 what I'll represent to you to be a copy of portions of [251 A. I mean, it's Atlanta. I mean, this is not .
!
----------------.. - ------ . -----
Page 118
c11 this interview he gave. And I understand you can't,
r2 J you know, authenticate this document if you say you
have never read it. But if you take a look at the
second page, according to this transcript, the third
(51 question down, someone named Jamie, who I guess thars
[3)
[4]
C6J the interviewer, states: "How do you know Angela?"
c11 And he answers: "I know her from the past. This is
C8J exactly how it happened. I've had dispositions on
C9J this throughout Phaedra's lawsuit. I've spoken to
[10)
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numerous attorneys because I hold the key."
You don't dispute, I guess, that your
husband knew Ms. Stanton in addition to you knowing
her, correct?
A. He obviously says here he does know her.
a. Okay. Because you said you knew her
because she was the girlfriend or she was dating one
of your clients?
A. Uh-huh.
Q. Obviously, why would Mr. Nida -- your
husband, how would he know her? Do you know?
A. Well, you would need to ask him.
Q. So you don't have any idea how your
husband would know Ms. Stanton, is that right?
A. Yeah. You would need to ask him.
Q, Okay. And you're not aware of any
-----------------Page.120 I
c11 the biggest town.
c21 Q. Okay. So as far as you know, they know
C3J each other as just coincidence?
[41 A. You know, possibly. I mean, she's a
[5J stripper. She was a stripper.
C6J a. Okay.
[71 A. And, you know, my husband obviously has
[81 been one to frequent strip clubs.
[9J Q. Okay.
c101 A. So, I mean, it's numerous ways he could
Clll have obviously known her. '
r121 Q. So your testimony is, to your knowledge, !
[131 Mr. Nida didn't have any connection to Ms. Stanton I
c 141 through you? !
[151 A. I mean, I don't think their connection was j
[161 through me, no, I do not. 1
c111 Q. It would have just been coincidence, is
1
181 that rjght?
[191 A. I mean, coincidence that she knew him?
c201 Q. Right.
c211 A. Yeah.
c221 a. Okay. Did you ever discuss your
[231 relationship with Mr. Nida with Ms. Stanton?
[241 A. Say that again.
t251 Q. Did you ever discuss your retationsftfp
.IPA Reporting, LLC- (404) 853-1811 (30) Pages 117 - 120
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ANGELA STANTON
,-- --- ---- - --- --.
F>a9e 121 - - -- --------- - -
PHAEDRA C. PARKS
.June 19, 2014
-Page 123 I
[l] with Mr. Nida with Ms. Stanton? [1]
[2] A. Did I ever discuss my relationship with. [2]
[3] Q. Mr. Nida.
[3]
[4] A. With my husband with Angela? [4]
[5] a. Correct.
[5]
[6] A. What do you mean, did I ever discuss my [6]
[7] relationship?
[7]
[8] a. Did you ever have any conversations with [8]
[9] Ms. Stanton about Mr. Nida? [9]
(10] A. I mean, I don't - I don't -- I don't [10]
[11) recall. Like, are you talking about something [111
[ ~ l speci.fic? [12]
[13) a. Well, I'm going to ask you a question; and [13]
[14] I'm not saying this to embarrass anybody because of [14]
[15] really specific detail. Did you ever tell Ms. Stanton [15]
[16] that Mr. Nida only had one testicle? [16]
[17] A. I don't believe so. [17)
[18) Q. Is that a fact, that he only has one [18)
[19] testicle? [19]
[20) A. That is not a fact. [20]
[21] Q. All right. Again, I'm not trying to -- [21]
[22] A. No, no, no, that's obviously not a fact. [22]
{23] The last time I saw it, he had two. {23]
[24] Q. Understood. When he says "I've had [24]
[25] dispositions on this throughout Phaedra's lawsuit," it [25)
Page 122
c11 sounds like he's trying to say he's had depositions on Ul
c21 this. Do you know if he has ever given any kind of -- c21
C3J A. No. He's never given a deposition, so I C3l
41 don't -yeah. 41
C5l Q. Okay. cs1
C6J A. I don't know what he's talking about C6J
71 there. 71
C8l Q. Do you know if he's ever given any kind of ceJ
91 statement about Ms. Stanton and your claims against [91
c101 her? c101
c111 A. Not while I have been present. I mean, c111
c121 you know, so, obviously there was a much larger c121
[131 lawsuit that invotved the publisher of the book. And 131
[141 so I know that he was reached out to by my legal team, [141
[151 and so I -- but I wasn't privy to it. I wasn't there. [15]
(161 a. Okay. Do you know if he gave any kind of [161
[171 written or recorded statement as part of that? 171
c1e1 A. I don't believe so. c1e1
191 Q. Okay. Who would know that? [19]
c201 A. Lin Wood, B.J. Bernstein. c201
c211 Q. Okay. c211
c221 A. Stacey Godfrey. c221
[23] Q. If you look at the third page of this [231
C24J exhibit at the very top, a statement that's attributed C24J
251 to him, third line down. in this context he's talking C25J
about, I guess, a conversation between you and him !
after Ms. Stanton, I guess, allegedly contacted one of !
you all or one of you all contacted her. And he says, i
"I said to her," talking about you, "back then when I
this was happening, I want to say 201 O - 'Let's sit j
down and talk to her."' And then it sounds like he :
says that you said no. "That's how she is and that's
1
probably part of where we are to this point."
Do you recall having a conversation with j
him about Ms. Stanton around the time frame that he is l
talking about here or similar to what he's talking
!
about here?
A. I'm sure if he recalls a conversation, we
probably had one, but I don't -- I would never allow
someone to extort money out of me.
a. Okay.
A. So I would never, you know, entertain
someone who is trying to extort me.
Q. Well, I haven't seen any evidence that she
tried to extort you.
A. Okay.
I
I
Q. Do you have some evidence that she tried l
to extort you, that she said I won't write the book if
1
you pay me some money, anything like that? Do you
have any evidence of that?
i
? ~ 9 ~ 124 I
A. No, because I have never talked to her.
Q. Okay.
A. But I know obviously, you know, her
purpose in doing this is obviously to try to make
money off of my success and not her own hard work.
Q. But she didn't ever try to extort - she
didn't ever tell you that she wouldn't write the book
if you paid her some money or anything like that?
A. Because I never had a conversation with
her.
Q. So the answer to that question is no,
correct?
A. t never had the conversation with her.
Q. Okay. So, neither herself or through an
intermediary or through any form did she ever say that
she would withhold publishing a book if you paid her
money?
A. I can't say that because I don't know that
to be true; but, personally, I never spoke to her.
I
!
I
I
Q. Okay. Well, I mean, I think you're kind I
of talking around a question that has a simple answer I
to it. Are you aware of her either personally or I
through an intermediary or through any form whatsoever !
threatening you to pay her money in order to prevent j
her from publishing the book? :
J
JPA Reporting, LLC- (404} 853-181 l (31) Pages 121 - 124
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ANGELA STANTON
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Page 125
A. I believe there was some talk about that. [1]
I mean, you know, I don't want to specifically say [2]
where I heard it from. I would have to obviously ask. (3]
But, I mean, yeah, I believe that she obviously wanted [4]
to extort money from me. [5]
Q. Well, you say there was talk of that. I [6]
mean, that's not a very good extortion attempt if I [7]
can't even get the message to the person who I'm [8]
trying to extort. Who told you this? [9]
A. I'll just leave it alone because I [10]
can't - I can't recall now what the exact [11]
conversation was. But I know obviously -- I don't [12]
know if maybe it was something my husband said. [13]
don't know. But I remember someone said, well, you [14]
know. 1 mean. it's always about money with her. {151
Q. So you heard someone speculate that she [16]
wanted some money? [17]
A. Yes, sir. [18)
Q. Okay. But you don't have any evidence or [19]
personal knowledge that she actually attempted to [20]
extort you for any money, correct? [21)
A. No, I don't believe so. [22]
Q. Okay. [23J
A. But if I locate some, I will obviously [24]
send it to you. [25]
Page 126
Q. I would imagine that's something that [ll
would have been front and center in this lawsuit. [21
You also sued VIBE magazine and Augustus [3J
Publishing as part of your defamation case. is that c 4 J
right? [SJ
A. That is correct. [6]
Q. Okay. And eventuafly you reached some 17 J
agreement with each of those parties to settle your c 81
claims against them, correct? C9J
A. That is correct. [lOJ
Q. Okay. And as part of that settlement, c111
each of them agreed to discontinue promotion of the c121
book, is that correct? [131
A. I don't believe that I can discuss that. [l4l
Q. Well, I'm going to ask you the question c1s1
again; and you can tell me you're refusing to answer. [16]
Ifs fine. But is it true that part of your agreement [l 7J
with them was that they would stop promoting the book? c 18 l
A. t .am refusing to answer that. [191
Q. Okay. c201
MR. ANDREW: Subject to a confidentiality c211
provision. r221
MR. ANDREW: Subject to a confidentiality [24 J
provision of the agreement. [25 J
PHAEDRA C. PARKS
.lune 19, 2014
Page 127 :
THE WITNESS: Subject to the
confidentiality of the agreement.
Q. (By Mr. Radford) When did you reach your
agreement with them?
A. I was pregnant; so I guess it would have
been in 2013, 2012. I'll have to -- I mean --
Q. Was it June of 2013?
A. It was in the wintertime. I can't -- I
know -- I think it was cold outside, so I don't think
it was June.
Q. How do you remember that it was cold
outside?
A. Because I remember I had on stockings.
Q. Like at some sort of mediation you were
wearing stockings?
A. Uh-huh. Yes. sir.
Q. Okay. Do you know Ron Triplett?
A. Yes, sir.
Q. Who is that?
A. He was security for Drama, and he traveled
on the road with us.
Q. Okay. Have you discussed your claims
against Ms. Stanton with Mr. Tripfett?
A. No.
Q. No, not at all?
i
----- -------- ...... -- ..... I
Page 128 !
I
i
A. I mean, t'm sure - I don't see Ron. I t
have seen Ron a few times. But, I mean, I'm sure he's
1
aware of the lawsuit, obviously; but ifs not like we I
discuss it. l
Q. Did you talk with him on the phone !
recently about your claim with Ms. Stanton, about the :
litigation with Ms. Stanton?
A. I talked to Ron - I don't think it's - I
know it hasn't been super recently.
Q. Let's say within the last year.
A. Yeah. I know I spoke to him in the last
year. yeah.
Q. About the litigation with Ms. Stanton?
A. I don't think -- we've never had a
conversation specifically about the litigation. I'm i
sure he's obviously mentioned it because he knows I
about it, but it's not as though we just specifically !
talked about the litigation.
Q. You didn't contact him by phone sometime
within the last three or four months to discuss the
case against Ms. Stanton?
A. I might have contacted him because we both I
have children the same age and he's obviously very i
familiar with my relationship with Angela and how we I
mef and sometimes he has remembered things better than I
r:: ---
MR. RADFORD: What? 1[231
._,,, ______ .. ____ ,,__ -- --.. --- I
JPA Reporting, LLC- (404) 853-1811 (32) Pages I 25 - I 28
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ANGELA STANTON
PHAEDRA C. PARKS
June 19, 2014
.. - ...... --1------..
Page 129 -----Page 131 I
[1]
[2}
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{61
[7]
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[lOJ
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(12]
[13)
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UJ
(21
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Pl
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I have. But, you know, I have asked him like when did
I actually meet this girl, and so yeah. But beyond
that, ifs not to discuss the litigation. Sometimes
it's been to refresh my memory on when did I meet her.
And he's like, oh, yeah, we met her, because he was
there the 1'.iay t met her.
Q. Okay. Do you know Jessica Lacy Voker?
A. Yes.
Q.
Who is that? How do you know that?
A. She is a client's wife, an ex-client's
wife, who's been in prison for some years, for some
years. yeah.
Q. Did you ever have any business dealings
with Ms. Voker?
A. No.
Q. Do you know someone that goes by DJ Nabs?
A.. Uh-lluh> yeah.
Q. How do you know Mr. --1 don't know if
it's Mr. Nabs or not, but how do you know -
A. We've worked together. We're friends.
Q. Okay.
A. I've known himfor years. You know, I've
obviousfy done business wfth him on numerous
occasions.
Q. Have y'all ever had a dating relationship?
Page 130
A. I woufdn't eoosidef us having a dating
refationship.
Q. Okay. Did you and Angela together travel
to Mr. Nabs' house al some point lo confront him over
a relational dispute?
A. Huh?
Q. Dfdyou?
A. Not that 1 recall.
Q, Okay.
A. But what kind of -- what do you mean. a
relational dispute?
Q, I don't know. You know, the sort of
disputes people have, rover's quarrel, so to speak,
did you ever have any kind of confrontation with him
like that?
A. No, definitely not
Q. Do you know a Shaheed Rahman. who also
goes by Leonard Holland?
A. Uh-huh. I think that's one of her
children's fathers.
Q, How do you know him?
A. Basically through this, you know, through
her and this case.
a. But did you know about him prior to your
lawsuit being brought?
[1]
[2]
[3]
(4]
(5)
(6)
[7]
[8]
[9]
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[12)
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{24]
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Ht
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A. Say that again. Excuse me.
Q. Did you know him prior to your lawsuit
being brought? You know, did you know him outside of
the context of this litigation?
A. I knew him through her.
Q. Right. Okay. So how did you become
introduced to him?
I
A. Well, she thought he was going to kill her ;
or something one time. And I think she came, popped I
up by the office, and told me that I think he was a I
murderer or something and she was afraid he might kill
1
!
her or something. you know, and said. you know, if he r
killed her - if something happened to her, he killed I
her, basically. :
Q. Okay. Did you ever meet him personally?
A. I maybe have, maybe didn't. I just
r.emembet that specWcalJy because 1 remember her :
I
showing up being very, very concerned about this guy l
because they were dating and I think she was pregnant. j
You know, I don't know if she was pregnant then or
later got pregnant; and she was afraid he might kill
her because - I can't remember what the ssue was,
but it was somettitng that she was fll<e +'ve-got k> ,
tett you about this guy. You know, he might kitt me. i
If something happens to me, this is the guy. And, you i
I
i
.. P ~ g ~ 1 3 2 !
know, aftd wash, oo my GOO, yoo know. So, yean,.
So that's what t 1et11ember mostly. That's what st1cks
out in my mind.
a. Okay. And was this after she was no
longer dating your client, Mr. Drama?
A. I can't remember if they were dating then
I
or not, to be honest. They atways had an off-arn:t-on
reTati'onsnip. You know, so r don1know1flhey were '
dating. I just don't know because it was always some i
connection between the two of them. !
Q. Okay.
A. But I do recall her showing up saying my
life might be in danger, this guy might km me_
Q. Okay. Have you read Ms. Stanton's book,
Lies of a Real Housewife?
A. I have.
a. Okay. I'm going to ask you about a couple .
of details in it and determine where there's a dispute I
and where there's not. In one part of the book she
describes you coming lo her grandmother's house and I
bringing scratch-off lottery tickets and a bottle of 1
Smirnoff.
A. No.
Q. Do you dispute that?
A. I dispute that.
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JPA Reporting, LLC- (-'04) 853-181 J (33) Pages 129- 132
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ANGELA STANTON
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PHAEDRA C. PARKS
June 19, 2014
--- Page 135 '
[1]
[2]
[3]
Q. Any kind of interaction flke that ever
happened?
Page 133
A. I dispute that. I have never bought a
c 4 J scratch-off.
51 Q. Okay.
[6]
[7]
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[17]
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A. And never bought cheap vodka or any vodka.
Q. Never bought any vodka?
A. Huh-uh. I don't drink. I might have a
glass of champagne once in a blue moon. but I'm not a
drinker.
Q. So you never bought vodka for anybody else
either?
A. Huh-uh.
Q. All right
A. No. Now, I buy champagne; but vodka, no.
Q. All right. Did you ever eat at a
Pappadeaux restaurant with Ms. Stanton?
A. I don't recall that. I mean, I'm not
saying it didn't happen. But I hate Pappadeaux.
Q. Oh, you hate it, okay.
A. That is the one restaurant that I actually
hate. And anyone who really knows me knows that's the
one restaurant you can never take me to. I do hate
it.
a. Of all the restaurants, that's the one you
Page 134
c11 hate?
c21 A. No, it's a couple of them; but Pappadeaux
C3J is on that list.
C4l Q. Okay.
cs1 A. So, I mean, for me to go there would be --
61 I mean, would probably be against my best judgment.
171 a. Okay.
C8J A. But that's not saying that I didn't go,
C9J but-
c101 Q. Okay.
c111 A. -1 mean, that is a restaurant I can say
c121 that I hate because the food always gives me, when I
[131 have had it, a terrible stomachache because it's so
Cl4J much grease in it. It's horrible.
c1s1 Q. Okay. So in Ms. Stanton's book, she
Cl6J states it was one of your favorite places to eat.
[l 7J A. Well, so that would be very wrong.
(181 Q. And you're saying not only -- in fact, you
C19l hate it?
c201 A. Yeah. You can ask anyone who knows me.
c211 That's the one restaurant you cannot drag me to.
c221 Q. Okay. Did you ever make the statement on
[23] the Real Housewives show something to the effect that
C24l "Your freak number was B or 9"?
r2s1 A. I mean. I don't recall. But. I mean --
{1]
[2]
[31
[4]
[5]
[ 6]
Q. What does that mean?
A. I don't know. You tell me.
Q. Is that something that you said?
A. I don't recall saying it.
Q. Okay.
A. I mean, it doesn't mean I didn't say it;
[7J but I don't recall saying it.
C8J Q. Okay. Do you recall saying it in the
C9l context of a discussion as to --
[10] A. I don't.
Q. - people's sexual proclivities?
l
(11]
[12]
[13]
[14]
A. I don't. i
Q. You don't dispute that Ms. Stanton was in j
your home one or more times, correct. the home on
1
Oregon Trail? [15)
[16] A. I know she's been there. I can't say how
t
. I
many 1mes. I
Q. Okay. I
[17]
[18]
(19] A. I mean, but yeah.
[20] Q. She was there with your consent. right?
[21] A. Uh-huh. I'm sure.
[22]
(23]
Q. Okay. And this was during the time that
you knew her back in the early 2000s, correct?
[24] A. Well, yeah. Okay.
[25] Q. When did you live at Oregon Trail?
Page 136
c11 A. I built that house in '94. I sold it in
[2] 2001.
C3J a. Okay.
I 4 J A. So and I didn't live in it from -- I
C5J actually didn't live in it until '97-ish, '96, '97.
C6J had it, but I used to let others live in it. I didn't
r 7 l actually live in it myself.
C8J Q. Okay. Ms. Stanton describes meetings that j
[ 9] she would have with you at your office on 1069 Spring l
1101 Street She states that you would provide her with 1
Clll computer printouts with items that she wanted you to I
c121 purchase, fake identification cards, and fraudulent .
[13J checks and instruct her to go and purchase these items I
[ 14 J with these fraudulent instruments. Do you dispute ;
c1s1 that that happened?
[l6J A. I dispute that that happened. Yeah, I
c111 dispute that that happened. I wasn't even in the
c1a1 office. Yeah.
[191 a. What do you mean you weren't even in the
c201 office?
c211 A. I was on tour.
r221 Q. You were in the office sometime?
[231 A. Every blue moon.
C24J Q. Okay.
c2 s J A. And anyone that was at that office would
JPA Reporting, LLC - (404) 853-1811 (34) Pages 133 - 13<1
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ANGELA STANTON
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Page 137
PHAEDRA C. PARKS
.June 19,2014
c11 tell you that.
c11 That would be a question for him.
Page 139 j
C2l Q. So the whole time that you did business at [2)
Q. Okay. But I'm just saying you couldn't
C3l 1069 Spring Street?
C4l A. I was there maybe three times a week, if
C3l say definitively it's not true if she were to say that
[5J that.
C4l she had criminal dealings with Mr. Nida? i
A. I can't say definitively who she had !
[6J Q. Okay, three times a week.
[7] A. If that You know, some weeks maybe not
ce1 at all.
[9] Q. All right.
r101 A. Butyeah.
Clll Q. Who were you on tour with?
r121 A. Artists, different artists, different
[131 actors.
[14] Q. You were there three times a week?
151 A. Possibly.
[161 Q. On average?
c111 A. Sometimes not.
[18] Q. On average you would say?
[19] A. I can't say because I'm not- but I know
[20] I traveled from usually Wednesday through Sunday. And
c211 so when I was back home, I was usually packing,
c223 getting myself together to go back on the road. So it
23] wasn't like I was in the office like a regular 9:00 to
[24) 5:00.
C25J Q. Okay. So you're saying you couldn't have
[5]
[6]
[7)
[8]
[9]
[10]
[11]
[12]
[13]
[14]
(15]
(16]
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(18)
[19]
[20]
[2l]
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[23)
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dealings with. But I know she has obviously not told j
the truth about her dealings with me. I
Q. Well, you say she's not telling the truth. j
A. Yeah. She's not telling the truth.
1
Q. According to you?
A. Okay.
Q. Okay. Ms. Stanton states in the book that
you Introduced her to Everett Tripodis.
A. That's a lie. That's not true.
Q. Okay. You dispute that.
Has Ronald Freeman ever disclosed to you :
any conversations that he had with Ms. Stanton?
A. Not that I recall.
Q. Okay. And, finally, Ms. Stanton alleges
the scheme for which she did prison time related to :
stealing cars with fraudulent titles and she alleges :
that you had a part in helping to organize the scheme
1
by which to do that. !
A. And that's definitely not true. I
I
Q. And so you dispute that?
- . - --. ... - - ---- -- ------------
Page 138
c11 done that because you were hardly in the office,
21 correct?
[1]
[2]
[3] [3]
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A. I'm saying that it's not true.
Q. Okay.
A. None of it is true. That's what I'm
[4]
[5)
[6) saying, none of it is true. [61
[7J Q. Okay. She states that in March 2001 you c11
[8) introduced her to Apollo Nida. Do you dispute that? C8l
[9]
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A. I dispute that as well. C9J
Q. Okay. Let me ask you this: If c101
Ms. Stanton were to say that she had criminal dealings [11]
with Mr. Nida, would you dispute that or would you say c 12 J
you don't know whether that's true or not? C13J
A. I wouldn't know if that was true or not. C14J
Q. Okay. So you don't have any basis to [15J
dispute her description of her criminal dealings at [161
least as they pertain to Mr. Nida? c111
A. What I'm saying is is, first of all, r1s1
you're deposing Phaedra Parks, not Apollo Nida. [19J
Q. Sure. c20 l
A. So if you want to talk about him, you c211
should depose him because I can't speak as to wh]t c221
their relationship was - [231
Q. Understood. I24J
A. - or if they even knew each other at all. [.251
-. - . --- .. ---- --- - ---- ... -- ~ - ~
Page 140 :
A. That's a lie.
MR. RADFORD: Let me take a quick break.
I'm close to the end.
MR. ANDREW: Good.
(Recess from 4:35 p.m. to 4:39 p.m.)
Q. (By Mr. Radford) Back on the record.
Ms. Parks, you stated, I think. that you filed a
police report with the Smyrna Police?
1
A. Yes, sir. l
Q. Do you know what the outcome of that was? j
A. They couldn't find her address. They !
looked for her but couldn't find a good address to I
actually serve her the warrant.
Q. How do you know that?
A. Because I followed up on it numerous
times.
Q.
A.
Yes.
a.
A.
Q.
a--
So you were trying to have her arrested?
She was stalking me and threatening me.
Okay. This wasn't like a --
This was a criminal warrant.
I understand. But you didn't file like
MS. RUOTANEN: TRO,
Q. (By Mr. Radford) -- TRO, temporary
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ANGELA STANTON
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Page 141
restraining order?
A. It could have been a TRO mixed in it, but
they couldn't locate a good address for her.
Q. But did you ever go to like a civil judge
and do an ex parte TRO?
A. No, I didn't do that. I went down to the
City of Smyrna and filed it.
Q. Okay.
A. And they attempted to try to figure out
her address.
Q. Do you still have copies of any of the
documentation related to that police report?
A. I don't personally, I don't believe. l
mean, obviously, you know, it's public record and you
can obviously get it from Smyrna.
Q. Sure. Does your attorney, for example,
have any of that?
A. Not that I know of, no.
Q. Okay.
A. I mean, it wasn't done through an
attorney. It was me getting up and going to the
police station.
Q. Okay. You've had some contact with
Ms. Stanton's daughter, is that correct?
A. Not really. She tweeted me.
... - .. - - ----
Page 142
Q. When did that happen?
A. I don't have an exact date. But she
tweeted me, and I tweeted her back, you know, because
she's -you know, she said Angela threatened to kill
her or something.
Q. Okay.
A. And so, you know, I told her, obviously, I
don't think, you know, she would obviously
4
-
hopefully you wouldn't hurt your own child.
Q. Okay. Was all your correspondence with
her through Twitter or did you ever speak with her on
the phone?
A. I think it was through Twitter. I don't
think I ever talked to her on the phone.
Q. Did you ever send her any e
4
mails?
A. l don't recall an e-mail .from her. I
mean, I only, you know, spoke to her maybe, I guess,
that once or twice. It wasn't like I have a
relationship with her or anything like that.
a. In Ms. Stanton's deposition you all
produced what appeared to be text messages between
Ms. Stanton and her daughter. How did you come into
possession of those?
A. I don't know if -- I don't know if she
sent them to me on a direct message or -- I don't
PHAEDRA C. PARKS
,June 19, 2014
. - ----. .... .. --- .
Page 143 ;
11 believe that she has a cell number for me or sent them !
c21 to me on e-mail. I don't recall, but I could
C3l obviously try to figure it out.
c 4 l Q. Would it be fair to say those messages
[51 would be in your Twitter account?
I6J A. Possibly. I don't know if that's --1
71 can't recall. I know that I forwarded them to my
ca J attorney.
C9J Q. What is the Twitter account that you use
c101 that you have those messages under?
[111 A. I'm not saying that it's in a Twitter
c12 J account. However, my Twitter account is Phaedra
[131 Parks.
Il4J Q. Just at Phaedra Parks?
C15J A. Just simple.
Cl6J Q. Is it your recollection that that's the
[17] account that she used to interact with you?
c1a1 A. I mean, that's the only Twitter account I
Cl9J have.
c201 Q. Okay.
c211 A. And I do recall her mentioning to me she
c221 wanted to go to law school at Howard, and I told her ;
[23 J that she needed a letter of recommendation and I told l
[24 J her I would write her one. ,
c2s1 Q. Okay. And I would imagine you preserved ,
!
Page 144 !
'
all those communications?
I
[1]
[2] A. Yeah, I probably did. I mean, but it's
[3] not like there's been an extensive amount of
[4] communication with this young lady. I
l
[5] Q. Okay. But there was some evidence 1
[ 6] exchanged that you used as part of this case in that ]
[7] communication, correct? i
[8] A. Yeah. Anything that has been pertinent to
I
[9] this case I have obviously given it to him.
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(10] a. I would imagine -
4
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I [11] A. To my attorney.
(12) a. Did you preserve all that communication
I
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[13] between you and she?
I
[14] A. Yes. Anything that has been obviously
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(15] something that's relative, you know, to this case, I
I
I
[16] have given it to my attorney. I
I
[17] a. Did you delete any of the communication '
!
[18] you had with her?
I
[19] A. I don't think that I would have.
!
[20] Q. Okay. Did you have any personal '
[21] relationship with this young lady prior to these
[22] Twitter messages being exchanged?
[23] A. No.
[24] a. No?
[25) A. No.
JPA Rc1>orting, LLC - (-404) 853-1811 (36) Pages 141
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ANGELA STANTON
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Q.
Did you have any knowledge as to her --
whether she's good academically or --
A. I have no --
Q. -- a person of good character?
A. I don't. I don't know.
Q.
On what basis would you write her a letter
of recommendation to law school?
A. I mean, she wants to go to law school.
I'm a lawyer. Obviously, I would try to help her out.
Q,
You would recommend her?
A. Yeah, if she asked.
Q. On what basis? If you have no knowledge
of her-
A. On the basis that she's asking for
assistance.
Q. And so the letter would just say I'm a
lawyer, I hereby recommend this person? I mean. would
you make up something that you knew about her?
A. I would not make up anything.
a. Okay. Why would you offer to write her a
letter of recommendation?
A. Why wouldn't I?
a. Well, you don't know her.
A. Well, she wants to go to a law school that
I'm very familiar with and so --
Page 146
Q. Okay. And so just anyone off the street
you would recommend to a law school?
A. If you came to me and you asked me and you
were sincere in your attempt, saying, hey, I want to
be a lawyer, you know -- and she did tell me that she
graduated from some school or, you know, with high
[71 accolades -- and you need a letter of recommendation,
C8l obviously, it's no skin off my back to help somebody.
[9J Q. Well, you wouldn't want to recommend
[10]
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someone of bad character to practice law, would you?
A. Well, I don't think she's of bad
character.
Q. But you don't know, do you?
A. Well, she said she graduated with honors.
But is this deposition about her or about your client?
a. Well, it's about evidence in this case and
c 17 J how you attained that evidence and whether you offered
{l.81 someone a benefit in exchange for --
1 [191 A. Why would I offer her a benefit? Okay.
c201 Well, that conversation had nothing to do with this.
c211 That conversation was secondary to this.
c221 Q. Okay.
[231 A. I don't need her to be -
{241 Q. WiU you produce copies of those messages
c2s1 for us, please?
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PHAEDRA C. PARKS
.June 19, 2014
--------- - ---Page 141 !
A. Yeah.
MR. RADFORD: Okay. I think I'm about
finished with my questions. One thing I want to 1
give you on the record is a notice under Georgia ;
Code 51-7-84_ And we're asking that you dismiss i
your lawsuit against Ms. Stanton based on the
standards of that statute.
And I'll show you -- actually, I want to
mark this. I'm going to mark a copy of this as
Defendant's Exhibit 7 for the record.
identification.)
I
MR. RADFORD: And if you could take a look !
at Defendant's Exhibit 7 and tell me if it is an !
accurate copy of the notice that I've just handed I
to you.
I
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MR. ANDREW: It looks like the copy is the
i
same as the exhibit.
:
MR. RADFORD: Okay. That's all. I'm not
asking if you agree with it, obviously. I'm just
asking if what we will admit into the record is
I
an authentic copy of the actual notice I provided 1
to you.
a. (By Mr. Radford) Do we agree that the
I
exhibit is an authentic copy of the notice I provided? ;
i
------ -- --- --- - - - - t
Page 148
1
.
A. It appears to be the same. ,
MR. RADFORD: Okay. T don't have anything I
u ~ ~ I
(Deposition concluded at 4:48 p.m.} I
cs1 (Pursuant to Rule 30(e) of the Federal :
[61 Rules of Civil Procedure and/or O.C.G.A. 9-11-30(e),
signature of the witness has been reserved.) [7]
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ANGELA STANTON
[l]
[2]
CERTIFICATE OF COURT REPORTER
[3] STATE OF GEORGIA:
(4] COUN'l'Y OF FULTON:
[5)
Page 149
(6] I hereby certify that the forogoing
(7] transcript was reportod as stated in the caption and
[8] tho questions and answers thereto were reduced to
[9) writing by me; that the foreqoing 148 pages represent
{10] a ti:ue, CCi::'toct, and co111plet.e transcript of the
[11] evidence given on Thursday, June 19, 2014, by t.he
(12] witness, Phaedra C. Parks, who was first duly sworn by
(13] me.
[14] l certify that I am not disqualified
[15] for a relationship of interest under
[16] O.C.G.A. 9-ll-28(c): I am a Georgia Certified Court
[17] Reporter here as an independent contractor of
[18] JPA Reporting, LLC who was cont.acted by
[19] James E. Radford, Jr., Esq. to provide court reporting
[20] services for the procoodings: I will not be taking
[21] these proceedings under any contract that is
[22] prohibited by O.C.G.A. l5-14-37(a) and (bl or
[23] Article 7.C. of the Rules and Regulations of the
[24] Board: and by the attached disclosure form I confirm
[25] that neither I nor JPA Reporting, LLC are a party to a
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Page 150
contract prohibitod by o.c.G.A. 15-14-37(a) and (bl or
.l!.rUc.le 7. c. QI! t.be 2u.les anii 2ogl,l,lations of the
Board.
This 18th day of July, 2014.
LINUX C. RVGGHI
CEK'l'n'tED COOR'l"
GEORGIA CERTIFICATE NO. CCR-A-261
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... .J __ .
PHAEDRA C. PARKS
June 19, 2014
Page 151
DISCLOSURE OF NO CONTRACT
I, Lynn Pyles, do hereby disclose pursuant
to Article 10.B of the Rules and Regulations of the
Board of Court Reporting of the Judicial Council of
Georgia that JPA Reporting, LLC was contacted by tho
party taking the proceedings to provide court
reporting services for these proceedings and thero is
no contract that is prohibited by O.C.G.A. 15-14-31(al
and (bl or Azticle 7.C. of the Rules and Requlations
of the Board for the taking of these proceedings.
There is no contract to provicla reporting
services between JPA Reporting, LLC or any person with
whom JPA Reporting, LLC has a principal and agency
relationship nor any attorney at law in this action,
party to this action, party having a financial interoat
in this action, or agent for an attorney at law in
this action, party to this action, or party having a
financial interest in this action. Any and all
financial arrangements beyond our usual and customary
rates have been diaclosod and offered to all parties.
This 18th day of July, 2014.
LYNN PXLES, FIRM REPIU:sENTATIVE
JPA REPORTING, LLC
Page 152
DEPOSJ:TION OF: PHAEDRA C. PARKS /LCR
I di:> hoJ:ol:>y ee;tify tha.t l have rQa!:i ,aJ.l
questions propounded to me and all answers given by aa
on June 19, 2014, taken before Linda C. Ruggeri, and
that:
1) There are no changes noted.
2) The following changes are noted:
Pursuant to Rule 30(e} of the Federal Rules of
Civil Procedure and/or tho Official Code of Georgia
Annotated 9-11-30(e), both of which read in part: Any
changes in form or substance which you desire to make
sha11 be entered upon the deposition .. with a
statement of tho reasons given, .. for making them.
Ac:cocdingly, to assist you in effecting corrections,
please use the for111 below:
Page No. Line No. should road:
Page No. Line No. should read:
Page No. Lino No. should read:
Pago No. Lino No. should read:
Page No. Lino No. should read:
Page No. Line No, should read:
Pago No. Line No. should read:
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ANGELA STANTON
[l)
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DEPOSITION OF: PHAEDRA C. PARKS /LCR
Paga No. Lino No. should road:
Paga No. Line NO. should road:
Page No. Lina No. should read:
Page No, Line No. should read:
Pago No. Line No. should road:
If supplemental or additional are
please furnish same in typewriting annexed to this
deposition.
PHAEDRA C. PARKS
Sworn to and subscribed before me,
This the day of , 20
Notai:y Public
My cominission expires:
Please forward corrections to:
Jl?A Reporting, LI.C
1776 Peachtree Street, N.W., Suite 230-S
Atlanta, Georgia 30309
404-853-1811
I
I
_j _______ _
.JPA Reporting, LLC - (404) 853-1811
PHAEDRA C. PARKS
.June 19, 2014
(39) Page 153
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PHAEDRA C. PAl{KS vs.
ANGELA STANTON
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accountant (6) 15:21;16:1.17; 17,25; 127:2.4
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acquaintances (1) 74:22 atlow(1) 123:14
actions (2) 34:6, 14 allowable (1) 4:20
actively (3) 8: I 5, I 8;69:25 almost (1) 75: 10
activities (13) 10:2;1 l:I; I alone (1) 125:10
46: 19;47:5, 14;49: 11, 12; I alongside (2) 48: I ;87: 12
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activity (4) 45:21 ;69:20;72:20, I 55: I 3;84:20;98:2I;99:7,12,
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actors (1) 137:13 1 134:12
actual (2) 55:22;147:22 amend (3) 12:16;15:22;33:10
actually (24) 14:4, I 6;33: 11; Amendment {1) 49: 15
34:10;52:17;65:8;87:23; among (3) 19:18;28:23;89:2
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19:115:13;125:20:129:2; amplify (1) 5:2
133:21:136:5,7;140:13;147:81 and/or (1) 148:6
addition (2) 8:23; 118: 12 ANDREW (24) 4:5, I 2;5: 1,8;
additional (1) 14:11 , 28:16:38:3.7.13:41:4:42:20;
address (15) 6: 1,3,7,8; 16:24; 43:9;44: 18;51:8;56:11;
27:8;'.!8: 10;3I:19;59: 1,2; 60:24;61:3.9;62: I :68: to;
62: 15; 140: I I, 12;141:3,10 72:23:126:21,24; 140:4:
adjusting (3) 25:23;26:13; 147:17
29:2 Angela (15) 5: 17;36: 17;
admit (1) 147:21 61: 10;73: 17; I 04: I: 105:21;
advance (1) 18:5 113:17,20;114:12;118:6;
advice (1) 111: 14 119:23; 121:4;128:24;130:3;
advised (1) 96:25 142:4
advising (1) 14:5 Angeles (1) 60: I
afraid (2) 131:11,21 announced (1) 115:14
again {25) 12: 10;16:8;22: 13: I annual (1) 50:7
25:18:26:5;30:17;33:7; . answered (13) 35:11 ;41 :13;
43:24;45:23;47:6;49: 13; i 46: I ;57:1:67: l4.l 7.17,20,22;
67: t0;68:.8:79: I :85: 1.8: I 69: 11;72:8;73:11: I 09:7
88:24;97:24;99:3: 107:23; ; Anthony {1) 63: 13
112:25; 119: 16; 120:24; I anymore (2) 59:7:93: 11
121:21;126: 16; 131: I Apollo (8) 46: 12;50:9,21;
against(14) 68:18;73:14; j 54:9,13;63:8;138:8,19
96:7,19;97:1;114:19;116:5,7; apologize (1) 50:16
122:9;126:9;127:23; 128:21; appear (11) 39:22;40:16,20,
134:6;147:.6 25;4l:10,22;42:3.7;45:24;
age (1) 128:23 51:6;81:13
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appearance 11) iO I: I
appeared (4) 40:24;86:17;
97:8; 142:21
appears (4) 20:9;41 :5;47:25;
148:1
appointment (1) 77: 15
appreciate (1) 61:12
approximately (1) 11 :3
area {3) 29:7;82:7,8
areas (3) I 7:8;25:25;26: I
argument (1) 38: 11
PHAEDRA C. PAIU(S
June 19, 2014
104:8
1 ...... --
1
automobiles (3) 29:22;30:2;
' 96:4
laverage(2) 137:16,18
I
avoided (1) 72:9
aware (26) 37: IO, I 7;38: 14,
l 22;39:4.11,11,16,17;51:25;
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I - - - .....
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I 16:9;123:10;124:21
arrested (5) 92:4,13,14;93:3;
14{}:17 !
Article(1)4:2 (baby(G) 14:20;15:1;84:21:
articles (1) 63:4 ' 85: 18,20;97:23
artist(3) 17:25;73:21;103:9 I baby's (2) 103:14;116:5
artists (4) 19:9,19;137:12,12 . back (16) 16:10;45:1;62:3,4;
aside (1) 43:18 i 72:9;84:7;95: 10;105: 12;
asleep (1) 82:14 j 116:10;123:4;135:23;137:21.
assertion (1) 73:4 I 22; J 40:6; f42:3; t 46:8
assist(2) 71:9;109:1 bad (5) 13:24:106:5,11;
assistance (1) 145:15 I 146:10,11
associated (1) 88:2 bank (8) 64: 14.16,21,23;65:2,
association (1) 48:14 i 9,12,18
assume (2) 7:11;103:22 : banks (2) 65:8,15
assuming (1) 20:17 : based (2) 44:8;147:6
assumption {4) 71:20,21,22, ; basic (1) 7:12
24 : basically (3) 7: 7: 130:22;
assumptions (2) 70:5,8 : 13 I : 14
Atlanta (5)6:2;9:12;47:23; I basis (10) 15:15;19:3;42:1 I,
62:13;119:25 18,23;43:20;138:15;145:6.
attained (1} 146:17 1' 12,14
attempt{4) 111:5;115:19; battling (1) 98:22
125:7;146:4 I became (3) 24: 11 ;26:6;29:6
I
attempted (2) 125:20;141 :9 I become (6) 8:9;115: 1,3.12,
attend(14)66:2;94:13; I 13;131:6
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I 08:2,3, 12, l 9; 110:5 ! begin (3) 9:6;56:8, I 6
attended (5) 79:14;90:16; i beginning (1) 10: 19
94: i behalf (6) 20:18;22: 18;38:23;
attent1on(2)6.J:l6;64:6 j 39:8,12;97:8
attorney (30) 5: I 6;7:5;8:4,8; j belong (2) 20:23,24
18: I 7;21 :23;24: I I ;26:6, 19, belonged (1) 21 :3
23;27:6;28:20;29: 14;34:2; below (1) 21: 12
39:9;43:15;60:22;61:13; benefit(2) 146:18,19
68:11;90:12,13;97:8;101:4, Bernstein (1) 122:20
17;103:11;141:16,21;143:8; Beside (1) 50:11
144: 11, 16 , Besides (1) 3 I : 14
attorney-client (1) 18: 14 I best(11) 9:21; 12: 18,20;
attorneys (6) 31:22;32:6,9; 14:18;15:7,23;19:22;35:1 I:
60:22;66:7; 118: JO '. 94:21,23; 134:6
Attorney's (2) 66:3,16 ! better (2)
attributed (1) 122:24 'beyond (4) 12:24:30:15:
Augustus (1) 126:3 51:23;129:2
authentic (2) 147:22,25 big (2) 18:20;82:9
authenticate (1) I 18:2 i biggest (1) 120: I
author (1} I 3:9 j birth (1) 98: 18
authoring (1) 115:1'4 bit(2) 17:6;114:9
authorization (1) 20:16 i BJ (1) 122:20
authorized (1) 50:10 ; blah (3) 4:3,.8,9
Auto (4) 29:16,17;102:23; i blank (1) 53:11
- .1 ... ---------------- ...
JPA LLC - (404} 853-1811 (I) ability - blank
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PHAEDRA C. vs.
ANGELA STANTON
..... - - -! - .. -----
blogger (2) 92:20,21 i can (45) 9: 15; 11: 19; 12: l 1;
blogging (1) 4:8 I 21:7;27:I0,25;30:24:34:20,
blue (2) 133:9;136:23 23,25;35:12,14;36:9;37:5;
Board (1) 4:3 38:11,16;39:4;42:10,22;45:1,
bono (1) 111:17 7;47:!0;53:12;56:11;61:15,
book (28) 13:8, 11;6I:10; 25;69: 17;78:23;83:6;85:24;
68:18;73:17;112:1;113:18, 90:24;97:23,25;100:22;
21; I 14:3,14, 15,17,21; 11S:13, 10I:14, 16; 106:23; 112: 11;
14,22; 117:6;122: 13: 123:23; 116: 18; 126: 14,16;133:23;
124:7,16.25:126: 13. 1 s; I 134: 11.20;141: 1 s
132:14.19;134:15;139:12 , capacity (1)57:24
both (5) 54: 10.15;56: 15; I capital (7) 54:6, 10, 15;56:7,16,
102:3: 128:22 \ 20.23
bottle (1) I 32:21 j captured (1) 22:21
bought {4} 133:3,6,7,1 l 1 car (2) 80:8;104:6
boy (2) 77:2;8l: 16 I card (1) 55: 18
boyfriend (1) 119:2 cards (1) 136:12
branch (3) 65:6,22,23 career (1) I 00: I 5
break (7) 21:20;56:I2;61: 15, cars (1) 139:21
25;62:3; 117:2; 140:2 case (26} 36:20;69:5, 15;
Bridges{3} 21:24;26:24;27:4 70:l 1, 12,22;7J:t ,5;72:17;
brief l l 96:23,25; I 04:9,23,24; l05: l;
briefly (1)4:6 111:12;113:7,7;117:18;
briefs (2) 26:21;28:18 126:4; 128:21: 130:23:144:6,
bring (2) 66: 16; 108: 14 i 9, 15; 146: 16
bringing (1) 132:21 ! cases (4) 18:24,24:19:25:
brother (1) 64:8 I 104: 16
brother-in-iaw(2) 62:20;64:7 l cast {7) 9:2,5;40: 15.
brought(5)"64;6;l08:13; 41:22;88:22
109:5:130:25;131:3 caused (2) 33:25;34:3
Buckhead (1) 27:7 CDs (1) 56:2
building (6) 27: 19,20,21; cell (2) I 05: 17; 143: I
31 : 18 ,20;84 :4 center (1) 126 :2
built(1) 136:1 CEO (3) 50:9,12,22
business (37) 7;1;16;19; certain m 18:20
31: T3;37:2,6;38:4;48:4;5 I :5, CFO (2) S0:9, 12
7, 11, 14,I 6, I 7;52:2,5,24;53: 1, chain-of-command (1) 28:3
18:54:7;55:2,5;56: I 7;57:21; chair (2) 82:5;83: 17
59:4,5,6;60:23,24;6 I :2,5: I chairs (1) 82:4
65: I 8;73:21; I 08:6; 114:3; I champagne (2) 133:9, I 5
129:13,23;137:2 i change (2) 27: 16;84: 13
businesses{&} 13:5,6;14:7, I changed(4)
11,23;62:23 27: 18
Bussey (1) 62:21 changes (2) 10:12,12
buy (1) 133: I 5 character (3) 145:4; 146: 10, 12
- --- - -------- --- - - - -- charge (2) 97:21;107:3
C charitable (2) 6:21,24
--- --- -- ----- -- --- Charles (9) 53:2,3,4,6, 18,23,
Cabbell (1) t 12: 14 24.25;54;25
calculate (1) 12: 14 cheap (1) 133:6
California (3) 16:23;59: 17,25 check (1) 15:3
call (8) 28:2;98:6; I 06: 19; checks (1) 136: 13
111:4:112:3,5,23:113:4 child (10) 82: I 3, 14;83:23;
called (16) 9: 11;48:9;59:19; 86: l ,2,6,6;99:24,25;142:9
62:9;63:6.16;73:22:92:16; I children (14) 81:1;82:15,18,
98:7;105:16;l08:18:t 13:17, 20,22,23;83:20;84: 14,16,t9;
20,20;115: 10; 117: 16 J 85:5;86:23; 109: 15; 128:23
calling (3) 92:22; I 06:2.10 children's (1) 130:20
calls (8) 42:21;98:25;I06:24; chit-chat (1) 11O:11
I 08: I 0, 19; I 09:3,4; 113: I I Christmastime (1) 116:9
came (7) 68; l 7;74:6;78:8; ' church (1) 110:6
96:16;98:5;131:9;146:3 churches (1) 6:19
camera (2) 40: 16,20 Citizens (2) 64:23,24
PMAEDRA C. PARKS
June 19, 2014
City (3) 116:21,22;141:7 ; 120:13.15;132:10
Civil (3) 4:21 ;141 :4;148:6 ; consent (1) 135:20
claim (14) 32: 18,20;33:8, 19; i consider (1) 130: I
36:21;38:2;48:25;68:18; I consulting (1) 14:4
69:18,18;70:4,21;102:23; contact (10) 60:2;74:23,24,
128:6 I 25;98:5;105:2;115:19;116:3;
claims (12) 24:2;25:23;26: 13; 128: 19;141 :23
29:2,13,21;30:1,2;7:3:13; I contacted (3) 123:2,3;128:22
1'.12:9;126:9;127:22 i contacting (8) 111:20,22;
Clarence{1)32:1 I 112:1,12,15,19,20;116:4
clarify (1) 43:7 j contentious (1) 99:25
Clayton (2) 98:3,4 I context (7) 4:7: 19:2;74: 14:
client (18)7:24; 18:15;33:2: I 75:5; 122:25: 131:4:135:9
36:15,22;37:1,7,14;38.:4; I contingencies (1} 17:23
74:15;75:6;99:S;100:9; : continue (5) 27: 15;46:4;
102:17,20;1(}3:19;132:5: ; 101:9,22.25
146: IS ! continuing (1) 26:7
clients (11) 17:22; 18: 18,20;
1
1
continuously (1) 99:21
19:2,6,13,18;36:12; 110: 19, Contract (7) 17: 16, 19;18:5:
24;118:17 19:10:41:19,21,21
client's {1) 129: lft l contracts (1) 17: 17
close(7)65:20;88:19,21; I contrast (1) 89:3
89:18,19;100:5;140:3 1 contribute (3) 54:10,15;56:19
clubs (1) 120:8 ! contributed (3) 56:7,16.23
Code (1) 147:5 conversation (13) 96: 12;
Cody (5) 103:6,20;104:8; : 106:1:113:11:114:12:123:1.
105:3,10 9, 13: 124:9, I 3: 125:12:
coincidence (3} 120:3,17,19 12&15:146:20.21
coindictees {1} 95:23 : conversations (3) 113:16;
cold (2) 127:9,11 I 121:8;139:17
college (4) 30: 14, l 8, 18,22 : convicted (8) 47: 14;90:9, 12.
color(2) 81:9;83:6 14,23,24;91:3;95:10
comfort (1) 106:2 Cook (2)74: 1,2
coming (1) 132:20 copies 116: 141: II;
common (2) 44:4,9 l 146:24
communicate (1) 17:4 l copy (9) 58:19;83:6;115:9;
communication (4) 144:4,7, I I 17:25;147:9,15,17,22.25
12,17 I cordial (1) 110:9
communications (1) 144: I i corporate (2) 24:3,5
companies (1) 31:3 I corporation (1) 50:7
company (22) 10:13;13:7,13. 1 correspondence (1) 142:10
t4;49:21,22;50:t4,20,2!; ! cost$ {1) 60: 12
51 :2,21,23;52:22;53:20; I couch (2) 82:6, I 5
55:15,21 ;56: l,8;57:16;59: 16, Council (1) 4:3
17,19 counsel (7) 4:22;24:3,7,8;
compensated (1)41:25 25:17,20;26:10
complalnt(1) 116:12 County (9)4:18;6:6,11,14,19.
complete (1) t 17:13 22;7:2;98:3;106:25
Compliance (1) 24:9 couple (5) 17: 14:32:5;80:2;
computer(1) 136:11 '1 132:17;134:2
concerned (1) 131:18 Court(9)4:3,17;5:3;44:25:
concluded (1) 148:4 ; 71:10:75:23;97:12;98:2;99:6
conclusion (1) 42:21 ! courtroom (1) 111:12
concocted (1) 87: 17 I crazy {2} 92: 17: 115:2
conducted (1) 66:2 ! create (3) 20:14,15.18
confidentiality (3) 126:21,24 t created (2) 20: 12, 17
127:2 icreating(1)33:15
confirmed (1) I 08: 14 J credibility {1) 33:23
confront (1) 130:4 ; credit {1) 55: 18
confrontation (1) 130: 14 I crime {3) 90:23,24,25
confused (2) 43:25;119:6 l crimes (7) 45:!0.14;49:3,5;
confusing (1) ll 9:5
1
I :6, 7
connection (4) I 07: 17; ! criminal (29) 45:21:46:19;
--- ----- - .l ... - --
.j
JPA Reporting, LLC - (404) 853-181 I (2) bloggcr - criminal
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PHAEDRA C. PARKS vs. PHAEDRA C. PARKS
ANGELA STANTON June 19, 2014
139:24 - . ! ... ---- --- ----
23;69:1,20;11:18;72:3,20,24; definition (5) 41:15;43:19,21; 72:16 I E
9 96 ., .. '>5 97 9 100 17 4410 17 discussion (2) 46:2,135:9
1
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...... _____ -- .>: ; ; _ _,,_ ; : ; : , '
20; IOI :3; 102:2;104: I; 113:7; definitively (2) 139:3,5 discussions (1) 113:15 j earlier (6) 28:23;43:3;46: I:
138: ll,16;139:4;140:21 degree (4) 21: 17;25: 10,IO; dismiss (1) 147:5 , 67:25;69:3;76:4
Croone (1) 60:21 34:24 displayed (2) 48: I 1;88:12 ! early (3) I J :6;30:5: J 35:23
CROSS-EXAMINATION (3) l delete (1) 144:17 dispositions (2) I 18:8;121:25 I earn (1) 18:12
s:f3;7f:4;73:2 I delivered {1l 1045 aispute (53)38:t9.22;39:17;. ease(1P4:5
currently (5) 4: 17; 18: 18; I delivering (1) 86:22 .. 41: I 0;42: l 7, I 9;43:2,4, 7; East (1) 28: 12
39:19,24:107:10 deny (4) 73:16,19;84:1.>; 44:9,12,16;74:20,24;75:1,3: eat(2) 133:16;134:16
custody (5) 84:25;85:2,3,5,8 103:24 78:2,15,19;79: 13, 15,16, 18; I economic (10) 32: 18,25;33: I,
cut(1}68:17 department(3)40:5;116:12, 82:24;83:12,14;84:9;87:4,l I. 7,18,25;34:3,23;35:4,16
---- -- 20 25;88:8;89:12,21,24;104:6, economically(1)37:19
D depending (1) 10:13 17;118:11;130:5,11;132:18, j editing {1} 10:24
depends (12) 10:11;12:4,7,9; 24,25;133:3;135:13;136:J4.: 'effect (6) 4:11;37:7,15;45:21;
damage (11) 8:4;35:20,20,23, 13:19; 14: 13, 15; 18: I 3;23:20; 16, 17;138:8,9, 12,16; 139: b, 48:15; 134:23
24;36:6, 10;37: I 3;38:8, 15; 24:25;26:4;40:2 l 25 either (4) 5:7;84:21; 124:22;
48:25 depicted (7) 88:2,9,14,18,21; disputes (2) 117:7;130:13 133:12
damaged (7) 7:25;29:21; 89:3,17 disputing (6) 39:18;42:23; electronic (1) 105:9
30:1;33:23,24;36:8,l I depose (1) 138:22 43:1,20;45:4;103:1 j electronically (2) 105:3,5
damages (13) 32:19,22,25; deposing (1) 138:19 divulge {1} 101:14 element(1)36:3
33:7,15;35:3,4,7;36:5,21: ! deposition (11) 4:7, f 5;7:8; DJ (1) 129: 16 (13) 13:4: 16: I 3;29:25:
37: 18,24;38:2 j 33:5;37:5;66:2,8; 122:3; document (8) 4: 11 ;20:5;2 I :6; ii 31:25;34:10;50: J 5:51: 19,23:
danger(1) 132:13 142:20;146:15;148:4 22:14;37:12;56:14;63:9: 54:23;55:1,2;56:6:133:11
dangerous(1) 115:3
1
depositions(1) 122:1 118:2 'ieludes{1)53:16
date (4) 74: 11, 13;93: 17; derive (5) 12: 12; 14:8;15: 19; documentation (1) 141: 12 e-mail (2) 142: 16;143:2
142:2 52:1,5 documen.ts (4)66:7,12,13,16 je-mails(1) 142:15
l03-:i&,l9 derived(4} 14:12;6&:23; doUars(2}52:B,15 embarrass(1} l2t:t.:f
dates{2) IO:l9;30:17 71:23;72:3 done{11} 15:4;17:13,15; I employed (1) 22:19
date-wise (1) 11 :4 derives (1) 19: I 35:21,24;36:6, 10;106:6; j employee (1) 24: 12
dating (13) 74: 15;77: 19; deriving (1) 71: 17 129:23;138:1;14 l :20 I employers (3) 21:12;30:15.21
102: 17, J 9; 110:23; 118: 16; I Derrick (6) 62: 17, 19,24;63:8, doodling (2) 44:21 ;45:23
1
end (5) IO: 19; 11: 14,24;
119:3;129:25;130:1:131:19; 13;64:8 doorway(1)81:18 ! 111:10;140:3
132:5,6,9 ,. describe (7) 8:24;33:2l; Dorian (3) 32: 1,2,3 I endorsements (4) 24:2;25: 16,
daughter(?) t4t:24;t42:22 34:20;39=8, t2;74:'t2, t3 (1) 32:3 I 20;26: t S
David (1} described (1) 69:21 double-story {"t) 84:3 I engaged (1) SI: 17
day (10) 9: 18;30: 14, I 9;46:9; describes (2) 132:20; 136:8 doubt (1) 98:9 I English (1) 44: I
47:8;58:8;85: 19; I 02:9; description (2) 51:20;138: 16 down (8) 21: 13;57:3;88:25; 'enough (2) I 07:9: 115:7
111:10;129:6 detail (3)73:3,8;121: 15 116:11;118:5;122:25;123:6; entered (1) 41:21
days (2) 12:4,8 details (2) 96:5; 132: 18 141 :6 entertain (1) 123: I 7
DC (2) 24:4,6 detennine (2) 36:24; 132: 18 drag (1) 134:21 17:9,18:
deal {8) 12'>0.,21; 17:24; 18:4. died {1) 106:21 Drama (13} 73:22,24;74:4;
13;19:23: 113: 19,21 difference (1) 50:24 77:4,6;99:5, 11,21;100:14; entire (1) 40:23
dealings (9) 68:23;93:24; different (11) 11:9,13,14, 18, 101 :22;119:8;127:20;132:5 entitled (2) 18:8, 11
104: I ;129: 13; 138: 11,16; 24;23:2;25: 14;27:20,21; drawing (1) 53: I I I entity (5) 51: 17;54:21
139:4,6,7 , 137: 12, 12 drink (1) 133:8 58:23;59: 12
dealt(2) 104:12,13
1
1difficult(1)57:18 drinker(1) 133:10 !eons{1)97:7
December (1) 117: l direct (1} 142:25 drive {4) j episode {3) l,22
decides(1) IO:t3 directly (1) 11 :12 drop (2) 77716,.16 I episodes (1) 87:22
dedicated (3) 9: 19,20;25:25 disagree (4) 71 :6,8;88:5; dropped (2) 79:22;80:5 j equal (1) 28:25
defamation (9) 7:20;36:7; 90:10 dropping (2) 79:24;80:21
1
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37:8, 15, I 9;38: 16;69: 15:70:4: disagreeing (2) 42: 12;7 l :7 drove (2) 87:5, I 7 I Eric (1) 60:21
126:4 disciplined (1) 8:20 dude (1) 57:9 estimate (9) 12:2, 18,20;
defamatory (6) 32:20;33:2,9, disclosed {1) 139: 16 due (3) 36:16,22; 110:23
1
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19;34:7;6s: 19 disclosure <1)4:1 ctu1y <3> I estimated t1> w: rs
defamed (2)35:25;36:'2 discontinue {1) 126:12 during (22) 10:2; I I :21 ;12: I,
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estimating (1) 15:24
defendant (2) 5: 17; 111: 13 I discovery (1) 5: 19 2;25:8;26:22;28:1,17,24;
1
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Defendant's (16) 20:2,3,6; discuss (14) 45: 12:77:5; 67:4, I I ;68:23;70:2;71: 18: even (9) 43: 15;66: 19;104: 13;
50:2,5;63: I ,4;81 :7,11 ;83:2,5; I 95: 16;117:5,7,l l:l20:22,25; 72:2,14;76:10, 12;77:21; I; I 05: 17; 111 :9: l25:8; 136: 17.
84:9;117:22; 147: 10, I I, 14 i 121:2,6;126: 14;128:4,20; 93:24; 102: I; 135:22 19; 138:25
define (1) 43:12 i 129:3 duties (4) 25:12;26;20;28:23,
1
event (1) t f9: 19
-definitely (8) 19:21 ;44:3;55:4; j discussed (4)73:13; 114:16; 25 I events (1) 79: 14
130: 16; , l 17: 17; 127:22 DVDs (1) 56:3 eventually (1) 126:7
----- -- _t. ---- ___ ,...._ --- -- -------- .i. ______________ _
.;,:: .
.JPA Reporting, LLC (404) 853-181 I (3) Croonc - eventually
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ANGELA STANTON
PHAEDRA C. PARKS
.June 19, 2014
. . .. . . -- ... ---- -
i i
Everett (7) 86:7;90: I 7;93:8; I federal (5) 45: 10, 14:94:9; frame (3) 93:4;99:6;123: to I gosh (1) 53:4
95: 16;96: 11,21; 139: 13 I 95:24; 148:5 fraud (3) 47: IS,19;70: I j gotcha (2) 30: 13;69: 16
Everett's (1) 90: 17 fellow (1) 119:9 fraudulent (3) 136:12, 14;
1
gracious (1) 111: 11
everybody (1) 113:9 felon (1) 91:4 139:21 I graduated (2) 146:6,14
Evidence (23) 4:21 ;34:5,13, felonies (1) I 01 :5 freak (1) 134:24 j graduation (2) 30: 14,18
17,20;35: 16;36: 13,20:37: 10, felt (5) 106:5, 11; 115:3,7; free (5) 98:10, 13,14;102:6, 12
1
grandmamma's (1) 80:5
13, 17,23,25;38: I, 15;70: 11; 116:6 Freeman (4) 31 :10;76:5,5; grandmother (1) 79:24
123:19,22,25;125:19;144:5; I few {1) 128:2 139:16 grandmother's
146: 16, I 7 field (1} 43: I 6 frequent (1) 120:8 I 80: I 0; 132:20
ex(1} 141:5 !Fifth(1)49:15 frequently(1) 111:6 !grease(1) 134:14
exact (2) 125: 11; 142:2 j figure (18} 16:2;38:20,25; Friday (1} 9:23 I groomsman (2) 94:22,23
Exactly (2) 60: 13; 118:8 J 39:8, 13;42: I 8,24;43:3,8,12, friend (2) 90: IS,18 j ground (1) 7: 12
examined (1) 5:11 I 14,17,20;44:5,11;45:3;141:9; friends (3) 74:21;86:12; Group (5) 62;6,10;63;7,11,17
example (11) 13:21,25:18:5; I 143:3 129:20 ! guess (21) 5:1;13:24;17:12.
20:22;29: 1;36:10;48:6: j me (3) t.00:25;116:20;140:22 front (2) 21 :10;126:2 i l 5;18:19;21 :12;30:13;39:21;
fifed(9)5:f8;38:2J;39:7,f2; fuef(1) 14:5 i St:t9;60:f1:67:g;S7;1;
examples (1) 17: 12 79:6; 114: 19; 116: 12; 140:7; full (2) 5:21 ;12:8 j 115: 10.12; 117: 15; 118:5.11:
except(1)4:24 141:7 full-time (7) 9:22,23;24:12,17. : 123:1,2;127:5:142:17
exchange (2) 105:9;146: 18 finally (1) 139: 19 24;25:5,8 t guilty (2) 45:9,13
.exchanged{2} l44:6,22 fmances{7) 16:14;52:22; fufly (1) 35:H i guy {6>
ex-client's (1) 129:10 53:14;54:3,21;55:8;66:17 Fulton (1) 6:6 ' 132:13
Excuse (3) 18:10;<J7:t6;13f:t financial (12} 45:IO,f4;47:15, functioning (4) 58:23;60:23; guys (1) 5:6
exercise (3) 50: 13,20;5I:18 I 9;49:3;55:23;66:7,22;67: I; 61 :6,7 Gwinnett (8) 4: 18;6: 11, 13, I 9,
Exhibit (18} 20:3,6:30: 16; 70: I ;90:9;9 I :7 funeral (23) 106: 15,22; 107:2, 22,25;7:2; I 06:25
50:2,5;63: I ;81 :6,8, I I ;83:2.5; financially (1) 41 :25 6,8, 14,22,25; 108:8,9,11, 12, 1-------- - --- -
117:22; 122:24; 147: 10, 11,14. find (10) 35:2,16;52: 19; 15,20; 109:6,15, 18,22;JIO: I, i H
(1) 21: 11 I
107:11,12,13,16; !" .
explained. {1) I09;U fi:ne '4) 10&;6;109;12 l handed (1) 147;15
extensive (3) I 02: I 0, 11; 144:3 finish (3) 30:4;56: I 3;69:24 further (3) 72: 19;73: 12; 148:3 I handle (4) 16: I 3;34:9:55:8.
extent (7) 42:20;67:8;72:19; finished (2) 30:5;147:3 - -----------
1
14
102:18;110:21;117:9;119:7 firm (17) 16:20,21;21:24;22:5, G J handles (6) 52:17,21;53:1,7.
extort(S) 123:15,18,20,23; 12,16,19,20,21;26:7,25;27:1, ---....,.....------ i 13;55:22
124:6;125:5,9,21 3,22;58: t ;59: t ,2 gave (7J 6:7;112:2; l 13: 17; handltng {2) 54:2;65: T 6
extortion (1) 125:7 firms (1) 31:1 117:16,19;118:1;122:16 hang (1) 77:13
------------- - - - ftrst {15> S:H ;8:9;46: 13;64:3, GEICO (24t 2l:13,16, 18,2 happen {at t9;
F I 5,22,24;70:5;74:9, 14;84:8; 22:8, l I, 14,20,21,24;23:9,23, 142: I
-------------- --- -- - - 99:4;109:7;114:25;138:18 24;24:11,12,14;25:12,17,24; happened (14) 77:20;80:16;
fact (11) 50: 12;83: I 9;89:4; I Fitness (10) 48:9;49: 18,19; 26:20,23;27: 13;29:14;30:8 89:2;92: 12,15;103:1,4; 111: I;
91: 15;92: I :102: 19; 110:23: ! 50:8:54:5:55: 13;59:3:61:2, GEICO's (1) 22:18 118:8; 131: 13;133:2: 136: 15.
121:18,20,22;134:18 i 20,23 general(1}38:8
1
16,17
facts (1) 71 :5 'five (3) 54:4;61: 15:93:22 generally (2) .21:8;40:4 I happening (1} 123:5
f'aenza f1) 2 t :24 five-mfnute (1} 56: t 1 Georgia {12} 4:4, 18,20,21; , happens (1} 13 t :25
talr(6) 15:11;17:20;41:18; focus (6) 17:7,15,19;18:25; 6:2;16:23,25;30:12;50:6; ! harass (1) 114:18
51:20;119:15;143:4 19:3;30:3 62:13;63:5;147:4 1 harassing (6) 105:21.22,25:
fairly (2) 77:20;105:3 Focusing (1) 24: 10 gets {1).40:2 i 106:6; 114:20,22
fake(2)20:19;136:12 follow(2) 108:24;109:5 girl(2)95:12;129:2 hard(1) 124:5
fall (3) 11 :6,23;43:21 followed (1) 140: 15 girlfriend (2) 1IO:19; 118: 16 hardly (1) 138: I
fa1sef1}2l:7 foltows{1} 5:12 gist{1} 106:1 harm {4} 34:t,3,24;35:16
familiar (7) 7:8; 13:23;62: 15; I food (1) 134: 12 given (9) 39:23;79:5,6,7; ! Harriett (1) 62: 12
81:22:94:5;128:24;145:25 forced (1)41:17 122:2,3,8;144:9,16 I hate (7) 133:19,20,22,23;
family (8) 6: 13.16.17:79: 19, I foreground (2) 81 :22;82:14 gives (1) 134:12 l 134:1, 12,19
. form (5) 4:24;19:3:37:12; giving (1) 80:18 head (1) 70:16
family's(1)110:1 : 124:15,23 glance(1)21:9 header(1)21:11
far (9) 5:5; 11: I :20:20:35:22. l formal (1} 51 :4 glass (1} 133:9 headquarters (3)23:15:24:3.6
1fonnattytt)8:20 gobs (1) 104;16 hear (2)40-:4;95:1 l
faster (1) 45:7 I forth (1) 72:9 God (1) 132: I heard (4) 63:20;95:9: 125:3.
fathers (1) 130:20 J Forty (1) 9:24 Godfrey (1) 122:22 16
father's (1) 103:14
1
forward (4) 8:12,12,16;30:18 goes (2) 129:16;130:18 hearing (2) 102:5,9
favor (1) 108:18 l forwarded (1) 143:7 Goldie (8) 113:13,19,21,24, I held (4) 23:22,23;25: 17,21
favorite (1) 134: 16 found (3) 20:8;92: 18;114:21 25;114:2,6,7 1 help (21) 97:21 ;98:21 ;99: I;
favors {1) 110: l 7 . four (8) good (7) 1 l2:9;l2S:7;140:4, I
(2) ... l 12;141:3;145:2,4 __ 1,3,I ._4 . ...
JPA Reporting, LLC- (404) 853-1811 (4) Evcrctl - hclJ>
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ANGELA STANTON
112:6.11;145:9;146:8 136:12;147:12
helped (3) 107:1,25;108:7 identified (1) 28:24
helpful (3) 98:25;1 I l:IO,l I identify (7) 34:23;35:15;37:4,
helping (2) 14:5; 139:22 6,22;38: 1,4
helps (1) 57:21 identifying (1) 35:7
her'" {1) 123:6 I ignore (2) 46:1;47:7
hereby (1) 145: 17 ignoring (2) 44:20;45:24
herself (3) 75: 13, 17; 124: 14 image (4) 48:7;83: 12;84:8, 10
hey (4) 80:23;1II:14; 112:5; imagos (1) 84: 12
146:4 imagine (11) 7:7; 10:6;28: 18;
high (1) 146:6 36:25;43: 16;54:6;65: 17;
history (1} 8:8 79:5;126:1;143:25;144:10
hold (2) 15:6; 118: 1 O Immediate (2) 6: 16, 17
holding (2) 82: 13; 109: 14 important (1) 93:7
.HollaBd {1J 130.:l&
home (11) 23:4;76:21 ;78:3,8, inaccurate (1) 2 I :7
10;79:14;80:10,18;135: 14, Inc (8) 59:3;61 :2,20;62:6, IO;
14;137:21 63:7,11,17
homeowners (1) 29:17 Incarcerated (3)46:2l;47:15;
homes (1) 78:4
1
93:25
honest (13) 29:4;52:9, 12; I income {20) t 2: I 2,24;B:2;
t f4:8, t ,4;
86:19;88: 16;98:20; 103:5; i 52: I ,4;53: 19;67:5.13;68: 17,
11s:15;132:1 I 22:11:11.23;72:3,14
honors (1) 146: 14 i Incorporated (4) 49: 19.20;
Hopefufly (2) 54: 19; 142:9 I 50:8;59: 13
Horace (2) 32: 14,16 incorporation (1) 63:5
horrible (3) 106:9,24; 134: 14 incorporator (2) 62:9;63: IS
l'lospitat fSl 86:2 I ;87:5,8, f 5. incorporators (1) 63:7
18,24 incorrect (2) 47:24;48: 10
hour (2) 17:23,24 indicted (1) 95:23
hours {2) 9:24;12:3 indictment (1) 95:24
house (9) 24:3;65:20;76:21; individual (2) 16:20;76:3
79:23;8.0:6;94:9; 130:4; j information (11) I J :20:21 :6;
132:20;136:1 .
Housewife (2) 114: 14; l 32: 15
1
lOl .-, 106.3,5
Housewives (5) 9: 11 :39:21; ingrained (1) 11O:I3
47:23;86: 18; 134:23 in-house (5) 24:7,8;25: 16,20;
Howard (1) 143:22 i 26:10
Huh (2) 119:4; 130:6 i initial (1) 75:2
Huh-uh (5} 53:4;94:1:115:24: Injuries {1) 29:15
133:8,13 injury (2) 19:17,19
human (3) 24:1;25:15,19 inside (3) 80:12,20,22
hurt (1) 142:9 instant (1) 48:21
husband (39) 45:9, 11, 13, 16; instruct (1) I 36: 13
46:3,10,24;48:8,19,21 ;49: I I, instructions (1) 7:11
PHAEDRA C. PARKS
June 19. 2014
118:1 ! knowing (1) 118:12
Interviewer (1) 118:6 ! knowledge (28) 20: 16;40: I:
intimately (1) 104:25 47:19;56:19;64:1;66:1.25;
into (10) 21:20;41:21;57:13; 67:5;68:22;70:2;71: 16;72:11.
74:6;80: 18;97: 19;98:5,21; 13,20,24;73:9;78:20;85:7;
142:22; 147:2 l 90:22;92: 12;94: I 5; 100:6;
intrigue (1) 108:5 : !04:14;114:15;120:12;
intrigued (2) 107:11;109:12 i 125:20;145:1,12
intriguing (1) 107:13 I known (4) 53:22;98: 19;
Introduced (5) 74:16,18; l J?OJ JP9.,.,
131:1;138:8;139:13 I csi 9s:.i2.12;12s:16:
invites {2} 80: 18,22 ! 133:22,22;134:20
involved (19) 10:1,23,25;11:2, 1-------------
3,6,10;46:19;47:4;49:5,I 1,22, L
2S;o9:1,20;1a:1;104.:2>.; r----- --- ------- -
106: 17; 122:13 ] labor (1) 87:2
involvement(4)47:19;49:3; j Lacy (1) 129:7
96:3;103:25 1 lady (3) 1I1:3;144:4,21
iPad (2} 81 :9;83:6 I lam (1} 92:15
issue (4) 36:5;73:8; 113:3; i language (1) 44:2
f 3 f :22 [ large (1) 48:7
issues (11J4Y.t;90:t1;9J;f, f larger(1J t22:t2
2;99:14, 16;100:11,11; 102: I, i last (12) 11: 16;47: 11 ;53:5, IO.
2;111:4 I 16;61:16;92:25;93:14;
item (1) 55:22 : 121:23:128:10.11.20
items (3) 104:5;136: I l, lJ. ! tater {4, J0:24;12: 16;92: 18:
- . -1 131:21
,J !Latoya(1)58:16
jail (5) 93:14;98:19;99:19;
106: 14; 111 :6
James (1) 5: 16
Jamie (1) 118:5
Jessica (1) I 29:7
job (4) 29:6;57:24;58:5,5
Jobs (4) 21:12;25:14,17,21
Johnnie (2) 112: 14,22
Johnson (3) 32: I, 14, I 6
joint (5) 64:13,16;65:2,16,24
jointly (2) 50:22;5I:13
Judge (1} 14 l :4
judgment(1) 134:6
Judicial (1) 4:3
June (5) 11:7,8,17;127:7,IO
Justin (4) I 03:6,20; 104: 10,20
K
l faw (47} 8:9, f I, I 4, fS, t8;23;
I 9:20:12:13,24;14:10;15:10.
I 20;16:3;17:6,9,18;t9:12.16;
I
21: 17,24;22:4,12,16,19,20:
24:15,17,21;25:!0;26:7,25;
I 27:J,3,22;3U,5,7;43:13,16;
59:1,2;143:22;145:7,8,24:
I J46:2,l0
i lawsuit (14) 5: I 8, 19:7:20:
; 67:6;79:6; I 03:24; 118:9:
! 121:25;122:13:126:2:128:3;
i 130:25;131:2;147:6
tawyer(11} 9:t ,22,23;18:23:
21:18,21;60:25:1JI:14:
145:9, 17;146:5
lay (1) 43: 19
layman's (1) 41 :9
layperson (1) 43: 19
team (2) 29:5;92: 19
. 1 I I: ! instructor (1) 57:
i Instruments (1) l..>6.l4 - --- -- learned {1) 117:6
18:92: 16, I 7;93: 11,12,13: i Insurance (3) 29: 13;30:2;3 I :3 key (1) 118: 10
95:14;117:4,16;118:12,20, ! intellectual (1) 17:9 kids (8) 84:24;85:2,11,14,21,
23:119:2,20;120:7;121:4;
1
. intending (1) 117:6 25;86:3;99:2
125:13 interact (1) 143:17 kill (6) 131:8,11,21,24;
husband's (8) 45:21 ;49:2; interacted (1) 119:20 132: 13;142:4
64:8;68:16;71:17;72:14,20: ! Interaction (2) 105:15;133:1 killed (2) 131:13,13
86:12 interactions (1} 119:1 kind (13) 12:20,21;98:23;
hustle (1) 113:8 interest (3) 51:7,10;116:4 99:7;102: 16;115:5;122:2,8,
-------- - -- ------ interested (3) 14: I 5; I 08:5,23 16; 124:20; 130: 10, 14; I 33: I
I interior(1)81:14 knew(23)47:3,13;73:17;
------------ --- - -- - 1 intermediary (2) 124:15,23 84:20,25;85:4;89:4;92:4;
idea (6) 16:6, I 2;63:9, l 0; , intern (3) 23:25;25: 15, 19 99:6; 103:20; I 05:20,25;
65:22; 118:22 i Internet (2) I 05:7,8 I 06:6,24; 110: 18; 111 :7;
identification (8} 20:4;50:3; I internship (1) 29:8 I J8:12,J5;lW:l9;l31:5;
63:2;8I:12;83:3;117:23: 1 interview (4) 117: 16.19,20; 135:23;138:25;145: 18
1 - - --- ------
- : 1 -
.JPA Reporting, LLC- (404) 853-181 l
; least (3) 6: 16;93: I: 138: 17
i leave (1) 125: 10
I left (1) 27: 13
j 1egal (18) 7:13;8:8;17:13;
! 28: 19;38: 10;4 l: I 0;42:21;
i 43: 18;44: 14, I 7;90: 17;9 l: IO:
I
. I 06: l 3; 108:24,25: I 09: l;
111:17;122:14
I
legally (1) 7: 15
Leonard (1) 130: 18
j letter(5) 143:23;145:6,16.21:
! 146:7
i liability (1} 36:3
i licensed (2)8:9;107:H>
'lie (2) 139:14;140:1
(5) helped - lie
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Phaedra Parks Deposition Took Place in July of 2014

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