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HOWARD WEINBERG, ESQ.

- VOLUME I
September 17, 2014

COUNTY LINE HOLDINGS, LLC v.


JAIME DeJESUS GONZALEZ
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A. Yes.
Q. County Line Holdings was formed to acquire
title to the property that's in question in this case;
correct?
A. Correct.
Q. And as I understand it, it was formed a few
days before the actual execution sale; is that correct?
A. I'm not certain.
Q. Okay. The execution sale that we'll be talking
about occurred on April 18th, 2013.
Is that how you recall the date?
A. That's my recollection -- I'm sorry. Do you
mean the sheriff's sale?
Q. Yes.
A. Yes.
Q. I'll be referring to that event, that sheriff's
sale, execution sale, many different ways but mainly as
the execution sale. So that's how I'll be referring to
that. County Line Holdings, LLC, I'm just going to call
County Line. I may refer to the trustee. The trustee
that I'm talking about is Jaime Gonzalez, trustee of the
Mansdorf Family Trust. And the property that we're all
here to figure out where it's going to go is the
approximately 1291 contiguous acres of coastal real
property in Ventura County.

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A. I am the manager.
Q. Managing member?
MR. ANTONI: Objection. Misstates his
testimony.
THE WITNESS: I'm sorry. Is that a question?
MR. ANTONI: Objection. Misstates his
testimony.
He said manager.
BY MR. DEARING:
Q. Okay. Manager.
And is there a president of County Line?
A. No.
Q. Is manager, in effect, the chief manager of the
enterprise?
A. Yes. Let me digress for just a second.
Q. Sure.
A. Limited liability companies can be
member-managed or manager-managed.
Q. Yes.
A. In this case County Line is manager-managed,
and I am the designated manager, so I can act on behalf
of the LLC as the manager.
Q. Okay. You know John Torjeson; correct?
A. Yes.
Q. And you know his lawyer, Christopher Barnes;

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Understand what I'm -- those definitions?


A. I do.
Q. Okay. Now, does that help you recall whether
the County Line was formed a few days before the
execution sale?
A. I don't recall the date County Line was formed.
Q. Okay. Were you a founder of County Line?
A. Yes.
Q. And you represented County Line at the
execution sale; correct?
MR. ANTONI: Objection. Vague as to
"represented."
BY MR. DEARING:
Q. You understand what I mean by "represented"?
A. No, I don't.
Q. I mean, you were the person from County Line
who made bids and accepted the deed; is that correct?
A. Yes.
Q. And are you -- are you a member of County Line
now?
A. Yes.
Q. And were you a member of County Line at the
time of the execution sale?
A. Yes.
Q. And what is your title now?

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correct?
A. Not really, no.
Q. Is John Torjeson a member of County Line?
A. No.
THE WITNESS: Excuse me for a second. Can we
go off the record for a second? I need to ask my
counsel a question.
MR. DEARING: Sure.
(Discussion held off the record.)
BY MR. DEARING:
Q. So who are the other members?
MR. ANTONI: Let's just put this on the record.
We just had a discussion off the record. We recognize
that counsel is going to inquire regarding the
membership interests in the LLC. We've indicated that
the underlying operating agreement imposes
confidentiality obligations on the witness not to
generally disclose the ownership interest to the public.
And what we've asked for -- and counsel has
agreed -- is the ability to designate those portions of
the transcript discussing the identity of any other
members as confidential and that they're not going to be
put in the public record without some effort to preserve
that confidentiality.
MR. DEARING: And I'm going to also be asking

Barkley Court Reporters

(3) Pages 10 - 13

HOWARD WEINBERG, ESQ. - VOLUME I


September 17, 2014

COUNTY LINE HOLDINGS, LLC v.


JAIME DeJESUS GONZALEZ
Page 14

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about contributions of those members, so that same


confidentiality can be applicable to those disclosures
as well.
MR. ANTONI: Very good. Thank you.
BY MR. DEARING:
Q. Okay. So who are the other members?
A. There is one other member. It's an individual
named Dr. Bambang Rachmadi. It's B-a-m-b-a-n-g. And
last name is Rachmadi, R-a-c-h-m-a-d-i.
Q. And where does he live?
A. In Los Angeles.
Q. And is he a physician?
A. No, he's not.
Q. What does he do for a living?
A. I'm not certain.
Q. An investor?
How did you come to meet him?
A. He's a client of mine.
Q. Did John Torjeson ever have any financial
interest in County Line?
A. No.
Q. Do you know if your client, the gentleman who
is the member -- does he have any affiliation with John
Torjeson?
MR. ANTONI: Objection. Vague as to

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BY MR. DEARING:
Q. It's quite all right to ask questions of your
counsel, but it kind of puts the questioner off if
you're right in the middle of a question.
A. I apologize. I'm afraid that I'm stepping into
attorney-client privilege territory.
Q. Okay. So we'll do it this time.
MR. ANTONI: If you're simply describing facts,
fine. If you're describing contents that would only be
known through confidential communications with the
client, then obviously that can't be disclosed.
THE WITNESS: Could you read me back what I was
saying before I asked -MR. DEARING: It's okay to read it back.
(The record is read by the reporter as
follows:
"A. Dr. Rachmadi purchased a piece of property
in Los Angeles to renovate and sell. When he
acquired" --)
THE WITNESS: -- title to the property, there
were irregularities with the title. Dr. Rachmadi
contacted me to represent him to try to clear the
difficulties that were on title. And my work with
Dr. Rachmadi did not involve litigation. But after the
title discrepancies were resolved, he retained John

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"affiliation."
BY MR. DEARING:
Q. Does he have any shared business interest? Did
you ever represent him? Did he have any kind of
business relationship with John Torjeson?
A. Dr. Rachmadi retained John Torjeson to
represent him in a litigation that Dr. Rachmadi is the
plaintiff in.
Q. Any other relationship with Torjeson that you
know?
A. Not to my knowledge.
Q. Do you know -- is that lawsuit ongoing?
A. To my knowledge, yes.
Q. And do you know the nature of the lawsuit?
A. Yes, I do.
Q. What is it?
A. Dr. Rachmadi purchased a piece of property in
Los Angeles to renovate and sell. When he acquired -I'm going to ask my counsel -- I assume I can discuss
the facts of the question.
Q. Don't do it while a question is pending.
MR. ANTONI: Well, he's trying to address the
attorney-client privilege issues.
MR. DEARING: Okay.
///

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Torjeson to then sue the -- the tortfeasors in that


case, which included, as I recall, the escrow company
and the broker.
BY MR. DEARING:
Q. Did you recommend that Dr. Rachmadi hire
Torjeson?
A. No.
Q. How did Rachmadi hire Torjeson? Do you -A. I have no idea. I did not know John Torjeson.
Q. Do you know when they first met each other?
A. I don't know for certain, but it was likely
in -- sometime in the summer of 2012.
Q. Have you ever represented Torjeson yourself?
A. I don't understand your question.
Q. You're a lawyer. Torjeson is a lawyer;
correct?
A. Yes.
Q. Have you ever represented Torjeson?
A. No, I have not.
Q. Have you ever helped him on any other matter
except this -- the matter that we're discussing about
the property?
A. No, I have not.
Q. And has he ever represented you?
MR. ANTONI: I'm going to object when you

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