Kerrie Kennedy, Will Kinnear

Kerrin Kennedy Kerrin Kennedy v.
Kevin Mudd
1 STATE OF ILLINOIS)
) SS.
2 COUNTY OF C O O K)
3 IN THE CIRCUIT COURT OF COOK COUNTY
COUNTY DEPARTMENT - DOMESTIC RELATIONS DIVISION
4
IN RE THE MARRIAGE OF: )
5 )
KERRIN KENNEDY, )
6 )
Petitioner, ) No. 15 D 11137
7 )
and )
8 )
KEVIN MUDD, )
9 )
Respondent. )
10
11
12
13 The deposition of KERRIN KENNEDY, called by

14 the Respondent for examination, pursuant to notice
15 and pursuant to the provisions of the Illinois Code
16 of Civil Procedure and the Rules of the Supreme
17 Court of the State of Illinois, for the purpose of
18 discovery, taken before Suzanne Thalji, CSR and
19 Notary Public in and for the County of Cook and
20 State of Illinois, at 30 North LaSalle Street,
21 Suite 3100, Chicago, Illinois, on February 6, 2018,
22 at 2:23 p.m.
23
24
Bridges Court Reporting Page: 1

Kerrin Kennedy Kerrin Kennedy v. Kevin Mudd
1 APPEARANCES:
2 GRUND & LEAVITT PC
BY MR. ROBERT S. KIPNIS
3 MS. LAURA M. PRESTO
812 North Dearborn Street
4 Chicago, Illinois 60610
312.650.0500
5 rkipnis@grundlaw.com
lpresto@grundlaw.com
6
on behalf of the Petitioner;
7
BRADFORD & GORDON LLC
8 BY MR. MITCHELL B. GORDON
MS. JESSICA A. SMITH
9 MS. BURCU OZADALI
30 North LaSalle Street, Suite 3100
10 Chicago, Illinois 60602
312.346.6911
11 mitch@bradfordandgordon.com
jessica@bradfordandgordon.com
12 burcu@bradfordandgordon.com
13 on behalf of the Respondent.
14 ALSO PRESENT:
15 MR. KEVIN MUDD
16
17
18
19
20
21
22
23
24

1 I N D E X
2 WITNESS
3 KERRIN KENNEDY
4 EXAMINED BY PAGE
5 MR. GORDON 4
6
7 E X H I B I T S
8 KENNEDY DEPOSITION EXHIBITS PAGE
9 Exhibit A 42
10 Exhibit B 64
11 Exhibit C 102
12 Exhibit D 108
13
14
15 Note: Exhibits not tendered for inclusion

16 into deposition transcript.
17
18
19
20
21
22
23
24

1 (Witness sworn.)
2 MR. GORDON: This is the discovery
3 deposition of Kerrie Kennedy in the case of Kerrie
4 Kennedy versus Kevin Mudd, taken pursuant to notice.
5 I will let everybody go around the room and
6 introduce themselves.
7 MR. KIPNIS: Robert Kipnis and Laura Presto
8 on behalf of Kerrie.
9 MR. MUDD: Kevin Mudd.
10 MS. OZADALI: Burcu Ozadali on behalf of
11 Kevin Mudd.
12 MS. SMITH: Jessica Smith on behalf of
13 Kevin Mudd.
14 MR. GORDON: And I'm Mitch Gordon on behalf
15 of Kevin Mudd.
16 KERRIN KENNEDY,
17 having been first duly sworn, was examined and
18 testified as follows:
19 EXAMINATION
20 BY MR. GORDON:
21 Q So a couple of quick ground rules,
22 Ms. Kennedy.
23 A Um-hum.
24 Q Have you ever had your deposition taken
1 before?
2 A No.
3 Q Okay. So I am going to ask you a series of
4 questions.
5 A Yes. I have seen depositions, though, so I
6 know --
7 Q Great. So you have a general idea how it's
8 going to work?
9 A I do.
10 Q Okay, good. So you need to answer audibly.
11 You need to say yes or no.
12 A Um-hum.
13 Q You can't say um-hum or uh-uh, because the
14 court reporter is transcribing, yes, no, maybe,
15 whatever the answer is.
16 A Got it.
17 Q Something audible and something that's a
18 word. Fair enough?
19 A Yes.
20 Q Okay. If you don't understand a question
21 of mine, tell me. I will rephrase it. Okay?
22 A Okay.
23 Q If you answer a question, I will presume
24 you understood its meaning.
1 A Okay.
2 Q You have a right to take a break. If you
3 would like to talk to your counsel, whatever you
4 want, go for it.
5 A Okay.
6 Q Okay. State your name, please.
7 A Kerrin Kennedy.
8 Q And how old are you?
9 A Fifty-six.
10 Q When is your birthday?
11 A February 23.
12 Q Okay. What is your cell phone number?
13 A 847-257-5811.
14 Q Any other cell phones?
15 A No.
16 Q No other numbers you use?
17 A No.
18 Q Okay. What is your email address?
19 A Kerriekennedy@yahoo.com. And that's
20 k-e-r-r-i-e-k-e-n-n-e-d-y @yahoo.
21 Q Do you use any other email addresses?
22 A No.
23 Q Where do you live?
24 A 200 Golf Terrace in Wilmette.
1 Q And how long have you lived there?

2 A I think about ten years.
3 Q Who do you reside there with?
4 A My daughter when she is not in college.
5 Q And that property is currently under -- are
6 foreclosure proceedings started on that property?
7 A Yes.
8 Q And when did those proceedings start?
9 A I would have to ask my foreclosure lawyer,
10 but I think -- I think in September.
11 Q Of '17?
12 A Yeah, I think so.
13 Q Okay.
14 A I don't know the official date.
15 Q And when is the last time the mortgage was
16 paid on that property?
17 A That's a question for Kevin.
18 MR. KIPNIS: Does that mean you don't know?
19 THE WITNESS: I don't know.
20 BY MR. GORDON:
21 Q How long do you plan on living there?
22 A Until the bank takes it away.
23 Q Do you know when that may be?
24 A I do not.
1 Q Do you have any idea?

2 A I do not.
3 Q Okay. What is your plan after the bank
4 takes it away?
5 A I don't have a plan.
6 Q Okay. What do you do for a living?
7 A I am a freelance writer. I have turned my
8 house into a bed and breakfast. So I rent my house
9 out. And my third job is I am a full-time advocate
10 and support system for my son, and I have been
11 managing the guardianship process, hired the
12 lawyers, filled out all the paperwork, got
13 statements from his caretakers. Every facility that
14 he's been in I have found. I have done all the
15 paperwork. I am constantly in communication with
16 his psychiatrist and his therapist, and I am
17 currently trying to manage and find the next steps
18 for him for his care.
19 I have been filling out applications. I am
20 setting up tours, and I am flying out there to take
21 him on a couple tours and then managing -- trying to
22 manage the payment process through insurance and/or
23 the school district.
24 Q We'll get to that part. So let's stay on
1 that. You manage the care for your son Connor,

2 right?
3 A Yes.
4 Q Where is Connor?
5 A He is in Utah.
6 Q In what facility is he?
7 A It's called Youth Care.
8 Q And why is he there?
9 A Since he's been 13, he struggled with
10 depression and anxiety, and then it turned into
11 substance abuse, sort of self-treatment. So he's
12 had a lot of issues, and he's had years of school
13 refusal and just emotionally struggled.
14 Q Has he ever had a neurocognitive analysis?
15 A He's had many, yes, testing done, a lot.
16 Q So how long has he been at the facility in
17 Utah?
18 A That particular facility, he's been there
19 since June 20, I believe. Prior to that he was at
20 another facility in Utah.
21 Q Okay.
22 A And he went basically directly from the
23 hospitalization -- his almost monthlong
24 hospitalization for toxic shock syndrome and then he
1 went directly to Utah, and I set everything up

2 myself.
3 Q When did he first go to Utah?
4 A It was sometime in March.
5 MR. KIPNIS: What year are we in?
6 THE WITNESS: Of 2017, yes.
7 BY MR. GORDON:
8 Q March of '17?
9 A Yes. My dad died in February of 2017.
10 Connor went to the funeral. He got sick the day
11 after and then was hospitalized for three weeks, and
12 then right after that he went to Utah.
13 Q So he has resided in Utah since then?
14 A Correct.
15 Q Okay. And you said you are managing his
16 care?
17 A Yes.
18 Q So he's in an in treatment facility,
19 correct?
20 A That is correct.
21 Q Okay. So when you say you are managing his
22 care, how many days a week are you managing his
23 care?
24 A Right now every day because I'm working to
1 find -- the place where he's at, he cannot stay

2 there. Technically he's supposed to leave when he's
3 18, but I have arranged -- I got him to sign -- the
4 last time I was there, I got him to sign a waiver
5 allowing him -- that the -- he would have -- in
6 order to stay longer, he would have to sign the
7 waiver.
8 I don't know. I am really distracted by
9 all of this. So do you guys want to take a break
10 or -- because I can't focus on the question if you
11 guys are all talking and writing notes to each
12 other.
13 Q Well, they are going to be writing notes to
14 each other. So you are going to have to learn to
15 address the --
16 MR. KIPNIS: No, she is not. If she is
17 distracted, then she doesn't have to answer the
18 question. Please have your client just simmer
19 down --
20 THE WITNESS: Right.
21 MR. KIPNIS: -- and maybe put it in writing
22 instead of walking around and talking to people.
23 MR. GORDON: Well, he is sitting in his
24 chair. He hasn't gotten up.
1 THE WITNESS: It's hard for me to -- like I

2 have forgot even what I was saying.
3 BY MR. GORDON:
4 Q Ma'am, let me be real clear.
5 MR. KIPNIS: I just saw him standing here.
6 BY MR. GORDON:
7 Q Let me be real clear.
8 MR. KIPNIS: Was I in the wrong room?
9 BY MR. GORDON:
10 Q Let me be real clear. Let me be real
11 clear. This is easy.
12 A Go ahead.
13 Q They are going to take notes. It's going
14 to happen.
15 A Okay.
16 Q If you need to take a break because of
17 their note taking, say the word.
18 A Okay. Thank you. Appreciate that.
19 MR. KIPNIS: The note taking isn't the
20 issue. I guess it's the walking around and talking.
21 THE WITNESS: It's the walking and talking
22 that makes it --
23 BY MR. GORDON:
24 Q Anyway, I would like to get back on this
1 thread. So you were talking about a waiver?

2 A Yeah. So in order for Connor to stay at
3 the facility past the age of 18, due to their
4 insurance, he would actually have to sign a waiver
5 stating that he is willing to stay, and even if we
6 get the guardianship without the waiver, he can't
7 stay.
8 Q Is he going to sign the waiver?
9 A Well, he had said he wouldn't sign it,
10 wouldn't sign it, wouldn't sign it. He told
11 everybody at the facility no way.
12 I have been working with my own therapist
13 on ways to talk to Connor and work with him. So I
14 spent a lot of time when I was out there for family
15 week with Connor, and I got him to sign the waiver,
16 and everyone couldn't believe that he did it.
17 Q Great.
18 A So it was a huge step. It's just part of
19 the --
20 Q So how long is he going to stay?
21 A And it's just part of the -- part of all
22 the work that's still ahead that I am working on.
23 Q Great. So how long is he going to stay
24 there?
1 A That is a question I can't answer, and I

2 don't know that they know. I would say anywhere
3 from three to six months. It's dependent upon the
4 New Trier district and Youth Care and his -- I also
5 worked out a plan with the school -- with both
6 schools, and we had an IEP meeting for Connor to be
7 able to test out of some subjects. And if he's able
8 to do that, he will have completed almost
9 three-quarters -- he's almost three-quarters of the
10 way towards graduation, which is a huge thing for
11 him.
12 We had thought that he was probably just
13 going to take the GED, but, you know, I've helped
14 figure out this new path by working with the
15 education coordinator at New Trier. So it depends
16 on how long the testing takes him in terms of how
17 long he would stay there.
18 Q So how many hours a day are you spending on
19 this?
20 A Well, on all of it? At least --
21 Q No, no. On this Connor portion.
22 A Yeah. On Connor and his future and the
23 plans and --
24 Q Yes.
1 A Three hours a day at least.

2 Q Every day?
3 A Yes, because I have mountains of papers of
4 applications and things to be done.
5 Q So let's talk --
6 A And I am also dealing with the insurance
7 companies and trying to --
8 Q Let's take yesterday.
9 A Yes.
10 Q Monday, the 5th.
11 A Okay.
12 Q How many hours did you spend on Monday, the
13 5th?
14 A I would say I spent about four hours
15 because I spent --
16 Q Doing what?
17 A -- two hours working on insurance, going
18 through the bills, calling -- we've got all these
19 bills that haven't been paid. So calling the
20 insurance claim relief guy that I'm working with,
21 calling the hospital, calling my insurance
22 companies, trying to straighten all that out.
23 Then I called two different facilities. I
24 also filled out applications for two different
1 programs.
2 Q Which ones?
3 A Serenity Mesa, which is in Albuquerque, and
4 New Roads Behavioral Health, which is --
5 Q And you filled those out yesterday?
6 A Yes, I did.
7 Q Okay. Completed them?
8 A No, because I still have a lot more
9 information that I have to gather, tests that I have
10 to send --
11 Q How about today, how many hours have you
12 spent today?
13 A I haven't spent any time on it today
14 because I'm doing this deposition.
15 Q How about tomorrow, what is your plan for
16 tomorrow?
17 A Tomorrow I have to be in court in the
18 morning, as you know, and then I will get right back
19 into it.
20 Q But what are you going to do tomorrow?
21 A It's my top priority.
22 Q Right back into it, doing what? What is on
23 the agenda?
24 A What's on the agenda? I have to reach out
1 to his home psychiatrist, Dr. Raden, who I have been

2 working with, who treats Connor for Lyme disease.
3 He has ordered a number of tests for Connor. Connor
4 did complete one of the tests when I was there. So
5 I have to talk to him about the results of that
6 test.
7 Q Okay.
8 A Probably make an appointment to go in,
9 finish the paperwork, follow up -- I have to go drop
10 off mountains of bills with the Claim Relief person
11 who I have been paying and your client hasn't paid a
12 penny. So, yeah, I have my work cut out for me.
13 Q So how about Friday, February 2, what did
14 you do on February 2? How many hours did you put in
15 on this?
16 A Friday, February 2, I don't recall. I
17 mean, every day is different --
18 Q How about Thursday, the 1st, February 1,
19 how many hours did you put in on this?
20 A I think I already answered your question,
21 Counsel.
22 Q How many hours did you put in?
23 A I told you that I put in an average of
24 three to four hours a day on this.
1 Q How did you calculate that average?

2 A And I stand by -- it's just the work that
3 I've been doing, and I stand by my answer. So I
4 will continue to give you that same answer.
5 Q Explain to me how you calculated the
6 average of three to four hours a day.
7 A Well, I look at the different areas of work
8 that I have to do for it, which is locating
9 programs, filling out applications, dealing with all
10 of the medical bill mess, which is a nightmare,
11 dealing with the school district, dealing with his
12 home psychiatrist. Oh, and his psychiatrist there I
13 talk to at least every week because we're
14 fine-tuning his medications.
15 Q And how long are those calls?
16 A It varies. Sometimes we will text back and
17 forth, and sometimes he will call me.
18 Q So sometimes it's a text exchange?
19 A Yeah.
20 Q And not a call, okay.
21 A And sometimes he calls me. So it just
22 depends.
23 Q So how long?
24 A How long what?
1 Q How long are the calls?

2 MR. KIPNIS: When? On the 1st, the 2nd, or
3 generally?
4 MR. GORDON: Generally.
5 A That's impossible for me to answer that
6 question.
7 Q Okay. So how did you calculate the average
8 of three to four hours a day? Has that been over
9 the past six months, over the past year, over the
10 past week?
11 A It has been since my son started having
12 problems at age 13. So a long, long time that I
13 have been dealing with hospitalizations, finding
14 doctors, finding programs for him, dealing with what
15 do I do when he suddenly gets kicked out. And that
16 has happened many times, and I'm the one that has to
17 figure it all out, just me.
18 Q Not in 11 months it hasn't happened,
19 though?
20 A Getting kicked out?
21 Q Yes.
22 A Yeah. He just got kicked out of the first
23 program in Utah.
24 Q How long was he there for?
1 A A couple of months. So March -- yeah, two

2 to three months, and he threatened to commit suicide
3 if I sent him back there. He had a leave -- I was
4 there on Mother's Day, and he got to leave with my
5 daughter and I for a short while. And he said he
6 was going to kill himself if I sent him back, that
7 it was abusive.
8 I took him to the emergency room, and he
9 was eventually hospitalized at UNI in Salt Lake
10 City.
11 Q Did you ever hire an educational
12 consultant?
13 A Yes, I did.
14 Q Okay. And did you use the educational
15 consultant?
16 A Yes. She found that terrible place.
17 Q Who did you hire?
18 A Jamie Goodman.
19 Q Okay. And is that the only time you have
20 ever worked with an educational consultant?
21 A No. I found another one that I think is
22 really good, but Kevin didn't want to pay for it.
23 Q Who?
24 A It's called Great Lakes Consulting in
1 Winnetka.
2 Q And when did you find Great Lakes
3 Consulting?
4 A I don't know. Probably about three months
5 ago.
6 Q How much do they cost?
7 A I want to say -- I don't know for sure. I
8 think it's around 3000.
9 MR. KIPNIS: Don't guess. Remember, don't
10 guess.
11 THE WITNESS: Yeah. I don't know.
12 BY MR. GORDON:
13 Q How come you didn't pay for it?
14 A Well, Kevin hadn't been paying me support.
15 So I didn't have the money.
16 Q What about borrowing it from your mom?
17 A He's in contempt of court.
18 Q He is?
19 A Yeah.
20 Q How about borrowing it from your mother?
21 A Your --
22 MR. KIPNIS: Just answer his questions.
23 A How about borrowing it from my mother? You
24 know, I had -- good question, Mitch. I actually had
1 to borrow the money from my mother to pay for --

2 BY MR. GORDON:
3 Q For the educational consult?
4 MR. KIPNIS: Let her finish.
5 A No. To pay for the attorney to represent
6 my son in the guardianship. He's entitled to -- he
7 has to have his own attorney.
8 I contacted your client many times asking
9 him to at least pay half. He would not respond. So
10 I borrowed the money from my mother. So I can only
11 really ask her for so much money. She is a widow on
12 a fixed income. So money is not -- she is not like
13 rich like Kevin's mother.
14 MR. KIPNIS: Every time you over-answer,
15 you give him more to question you about.
16 THE WITNESS: All right.
17 MR. GORDON: He's right.
18 MR. KIPNIS: You want to watch where he
19 goes.
20 THE WITNESS: Okay.
21 BY MR. GORDON:
22 Q Did you ask your mother?
23 A No, I did not.
24 Q Okay. And when you hired Mr. Kipnis, did
1 you ask your mother for money to pay that retainer?

2 A I did.
3 Q How much was that retainer?
4 A $10,000.
5 Q How much was the money -- did you borrow
6 from your mother -- receive from your mother to pay
7 for the guardianship lawyer?
8 A $1500.
9 Q Okay. And have you asked anybody other
10 than Kevin for money to pay for the educational
11 consultant?
12 A No.
13 Q Have you asked to take money out of the
14 escrow account your lawyer is holding?
15 A No.
16 Q Okay. Did you ever think about putting the
17 cost for the educational consultant on a credit
18 card?
19 A Okay. I spoke with my therapist about
20 this --
21 MR. KIPNIS: Excuse me. I want you to
22 answer his question.
24 MR. KIPNIS: I don't want you disclosing
1 anything you speak to your therapist about.

2 THE WITNESS: Okay. All right. Well, it's
3 just -- all I want to say is I think -- I'm not sure
4 I need an educational consultant at this point.
5 BY MR. GORDON:
6 Q Why?
7 A Because I am working with the school
8 district and I would like to get them to pay. So I
9 would like to get a place that is state funded, and
10 I'm hoping that the school district could help me
11 through this process.
12 Q So how does an educational consultant not
13 do that for you?
14 A My understanding is that they find programs
15 that are not necessarily state funded but private
16 pay.
17 Q Did you ask the educational consultant if
18 they can help with that?
19 A Yes. I had several conversations with her.
20 Q Okay.
21 A And I'm not saying I am not going to hire
22 her, but I'm right now relying upon the New Trier
23 School District as well as Connor's therapist at
24 Youth Care to help navigate the next steps for him.
1 Q You rent out your house as a bed and

2 breakfast?
3 A Yes, I do.
4 Q When did you start doing that?
5 A In June.
6 Q Okay. The house you currently reside in,
7 Golf View?
8 A Golf Terrace.
9 Q Or Golf Terrace?
10 A Yes.
11 Q Okay. And how do you rent this out as a
12 bed and breakfast? Explain the process. Explain
13 this process to me. Like a --
14 A So it's an Airbnb.
15 Q Okay.
16 A I use Airbnb, and people, you know, will
17 request a stay. And then I'd make arrangements for
18 a hotel for myself or, if my daughter is with me,
19 for both of us. And I have been doing it out of
20 desperation because your client is a bit of a
21 deadbeat and he hasn't been paying me.
22 Q And that's since June?
23 A He hasn't been paying me for the majority
24 of the two years of this divorce.
1 Q I am talking about the bed and breakfast.

2 A In June I started doing it because I
3 finally had my son out of the house and I had some
4 breathing room, and I was able to think outside the
5 box and try to be resourceful and figure out a way
6 to create some income for my children and I.
7 Q Because Kevin wasn't paying?
8 A That is correct.
9 Q And you have no money?
10 A Correct. At that time I had no money.
11 Q In the past 18 months, how many cosmetic
12 surgery procedures have you had?
13 A None.
14 Q None, okay. We'll get into it.
15 A Yeah, please do.
16 Q So let's --
19 BY MR. GORDON:
20 Q Let's go back to the bed and breakfast. Is
21 somebody there, like providing breakfast, for these
22 people that are renting the place?
23 A I have to leave all the food, wine, food
24 and, you know, supplies, towels, toilet paper --
1 Q So you started a business?

2 A I guess you could call it that.
3 Q Have you incorporated?
4 A You don't have to if you're doing Airbnb.
5 Q Have you incorporated?
6 A I have not.
7 Q Okay. Are you keeping any records?
8 A It's all on my Glenview State Bank account.
9 Q Is that a yes?
10 A I'm not sure how to answer that question.
11 I just -- my answer is everything is on my bank
12 account. You can refer to that.
13 Q So the costs you incur are on your bank
14 account?
15 A Yes. I have one bank account, and I have
16 one credit card.
17 Q But you are not keeping a separate ledger
18 or book or QuickBooks, any file that's a -- no, you
19 have not --
20 MR. KIPNIS: Excuse me.
21 BY MR. GORDON:
22 Q -- that's a recording of money coming in
23 for the Airbnb and money going out on what your
24 costs are?
1 A It's all on my Glenview State Bank account,

2 Mitch.
3 Q So nothing other than the Glenview State
4 Bank account?
5 A Correct.
6 Q Okay. So is this profitable to you?
7 A Well, I don't know how to answer that
8 question because sometimes I lose money because I
9 come home and things are damaged and broken or
10 stolen. Sometimes I break even once I figure all my
11 travel costs and hotel rooms, et cetera, but
12 sometimes I make a little money.
13 Q Okay. Let's go through it. Let's go
14 through the damaged, broken, or stolen. How
15 often -- let me ask you a different question.
16 Since you have been doing this in June of
17 '17, how many times have you rented out the house on
18 Airbnb?
19 A I would refer you to my Glenview State Bank
20 account, and you can see right there. I don't know
21 how many times.
22 Q Okay. So out of the unknown amount of
23 times, how many times has something been stolen from
24 the property?
1 A More times than I can count.

2 Q What has been stolen?
3 A Everything from dishes to blankets to
4 bedding, towels. People take everything.
5 Q How much money have you spent replacing the
6 stolen items?
7 A I don't know.
8 Q Okay. And you also said sometimes things
9 are broken?
10 A Correct.
11 Q What's been broken?
12 A My son's desk was --
13 Q Okay.
14 A I came home, and it was in pieces on the
15 floor.
16 Q Okay.
17 A A chair was destroyed. The dishwasher,
18 they screwed it up somehow. I had to get that
19 fixed. The countertop in the kitchen they stained.
20 Q So they're ruining the property; is that
21 right?
22 A Some people do.
23 Q Okay. How much money have you spent
24 repairing the Airbnb rentals?
1 A Quite a bit because I have to --

2 Q How much is that?
3 A -- have it in working order.
4 Q How much is "quite a bit"?
5 A Well, I don't know the exact amount, but,
6 you know, I had to fix the dishwasher. I had to --
7 Q How much is that?
8 A -- replace the broken furniture.
9 The dishwasher? I can't recall, but the
10 check for it is on my Glenview State Bank account.
11 Q Where are you getting the money to do these
12 repairs?
13 A Airbnb money, you know.
14 Q And you said other things are damaged. Is
15 that the same as broken?
16 A You know, like stained rugs and had a
17 carpet cleaner come out, things like that.
18 Q So in the last six -- since you have been
19 doing this Airbnb rental, have you made more money
20 than you have lost?
21 A Not really. I mean, I've made a little
22 money.
23 Q How much have you made?
24 A Close to nothing, I would say. I don't
1 know. I couldn't even tell you. I don't know how

2 to -- I would have to look at my records.
3 Robert, you might know.
4 Q So why do you keep doing it?
5 MR. KIPNIS: I do know, but I can't -- I'm
6 not under oath.
7 THE WITNESS: Oh, okay.
8 Why do I keep doing it?
9 BY MR. GORDON:
10 Q Yes.
11 A Because I've made a little bit of money and
12 I really don't have many other options, you know.
13 Q But how much have you made?
14 A A lot of my other work is dried up.
15 Q Are you earning any money as a freelance
16 writer?
17 A Hardly.
18 Q What does "hardly" mean?
19 A Hardly anything because --
20 Q Are you working on anything right now?
21 A Yeah. So my -- I had a job with a magazine
22 in New Orleans, and that went away. They couldn't
23 pay me anymore. So I work in a dying industry,
24 publishing.
1 Q What are you working on right now?

2 A I write for Modern Luxury magazines, and
3 the problem with that is I write something and I
4 don't get paid for three or four months.
5 MR. KIPNIS: He asked if you're working on
6 anything right now.
7 THE WITNESS: Yeah.
8 MR. KIPNIS: Tell him what you're working
9 on right now, if you can.
10 THE WITNESS: Okay. I am writing an
11 interior design story for CS Interiors.
12 BY MR. GORDON:
13 Q Okay. How much are you getting paid for
14 that?
15 A $400.
16 Q Okay. What else?
17 A I'm working on a real estate story for
18 Hinsdale Magazine.
19 Q How much are you getting paid for that?
20 A 200.
21 Q Okay. What else are you working on?
22 A That's it so far.
23 Q Are you looking for full-time employment?
24 A I have been reaching out to a lot of my
1 colleagues and trying to, you know, work people that

2 I know, and I feel like that's the best way to get a
3 job is through friends and people --
4 Q So what does this mean, you're reaching out
5 to people, to colleagues? What kind of job are you
6 looking for?
7 A I am looking for a full-time writer or
8 editor position.
9 Q Didn't you say it was a dying industry?
10 A Well, that's the problem, yeah. I am
11 trying to get into television writing.
12 MR. KIPNIS: You should go to Northwestern
13 and become a brain surgeon.
14 THE WITNESS: Yes.
15 BY MR. GORDON:
16 Q You can go downstairs and work at the
17 Starbucks.
18 A Well, so can your client. That would be
19 great.
20 MR. KIPNIS: But that wasn't the question,
21 so don't answer him.
22 THE WITNESS: Okay. What is the question,
23 Counsel?
24 BY MR. GORDON:
1 Q I want to know what you are doing to look

2 for full-time work.
3 MR. KIPNIS: She just answered.
4 A I just answered.
5 MR. KIPNIS: She has reached out to
6 colleagues.
8 BY MR. GORDON:
9 Q Okay. Which colleagues have you reached
10 out to in the last six months?
11 A My friend, Vince Lane, who works for Apple
12 in San Francisco. He's a former colleague.
13 Q Are you going to move to San Francisco?
14 A I would if I got a job.
15 Q Okay. And what does Vince do?
16 A He is a senior designer at Apple.
17 Q And you reached out to him and said what?
18 A I actually went to San Francisco and met
19 with him.
20 Q For what purpose?
21 A Well, I saw my nephew who lives in
22 Palo Alto, and then I met and had lunch with him to
23 talk about any, you know, possibilities he might
24 think of for me.
1 Q When was this?

2 A It was in September.
3 Q Did that result in anything?
4 A No. I mean, we're staying in touch.
5 Q Okay. Anything else?
6 A Yeah. My friend, Liz Elert, who lives in
7 Los Angeles and is senior director at the Honest
8 Company, I --
9 Q And you spoke with her?
10 A -- met with her.
11 Q When did you meet with her?
12 A I was in LA like three weeks ago.
13 Q Was it the purpose of your trip to meet
14 with her --
15 A Um-hum.
16 Q -- for a job?
17 MR. KIPNIS: Is that yes?
18 A Yes.
19 BY MR. GORDON:
20 Q And what was the result of your meeting
21 with her?
22 A She is keeping her eyes open for me.
23 Q But she didn't have a job for you?
24 A Well, that's kind of how it works. Maybe
1 something comes up and they think of you so --

2 Q Have you applied for any positions --
3 A I have --
4 Q -- in the last six months?
5 A Maybe not the last six months, but prior to
6 that I applied for a lot of jobs. I even had
7 interviews and --
8 Q Where?
9 A I had an interview with some start-up
10 company in Chicago. I forget the name of it.
11 Q When?
12 A And I ultimately -- I feel I am
13 discriminated against because of my age.
14 Q When?
15 A When was it?
16 Q Yes.
17 A I don't know. I would have to look on my
18 emails or something.
19 Q Okay. Anything else?
20 A No.
21 Q Okay.
22 A Well, I am working on a -- I wrote a
23 television pilot. I have been taking classes in
24 television writing. I wrote --
1 Q Has it been optioned?

2 A Well, I went to Sundance and met a lot of
3 people.
4 Q Has it been optioned?
5 A No, it hasn't been optioned. It's a whole
6 long process.
7 Q Do you have an agent?
8 A I am trying to get an agent.
9 Q So you don't have one?
10 A No.
11 Q Okay. And do you have any plans on
12 applying for a full-time position anywhere?
13 MR. KIPNIS: You mean other than what she
14 just testified to?
15 THE WITNESS: Yeah. I just kind of
16 answered your question.
17 MR. GORDON: That was in the past.
18 MR. KIPNIS: You are asking her future?
19 MR. GORDON: In the future, any future
20 plans.
21 MR. KIPNIS: How much support is she
22 getting? How much of the estate is she walking
23 with? Why don't you give us those answers. Then
24 maybe she can tell us what she is doing.
1 THE WITNESS: Yes. It's kind of hard for

2 me --
3 BY MR. GORDON:
4 Q Is that right, that your waiting to work is
5 dependent on the outcome of a divorce?
6 MR. KIPNIS: She testified she is working.
7 A I told you I have -- I actually have four
8 jobs, okay? I write for magazines.
9 BY MR. GORDON:
10 Q So looking for a full --
11 A I wrote a television pilot. I turned my
12 house into a bed and breakfast, and that is hard
13 work to have to leave your house and come back and
14 find it destroyed by people, you know, and the
15 fourth job is the hardest job that I have, and that
16 is taking care of my son.
17 Q How much of those make you money?
18 A So how many jobs should I have, Counsel?
19 Q How much of those jobs make you money?
20 A Two of them do. The other one is an
21 investment, and it could make me money.
22 Q Which one is that?
23 A The television pilot.
24 Q Okay.
1 A And the taking care of my son obviously

2 doesn't make me money but it is --
3 Q Do you have any plans to seek full-time
4 employment in the next 12 months?
5 A In the next 12 months? Certainly.
6 Q What is your plan?
7 A My plan is to try to get my television
8 pilot sold.
9 Q Do you have any plans to seek part-time
10 employment in the next 12 months?
11 A Yes. I do that every day as a freelancer.
12 Q Okay. Other than the freelancing?
13 A Do you have something against the
14 freelancing?
15 Q No.
16 MR. KIPNIS: Just answer his question.
17 THE WITNESS: Okay. All right.
18 BY MR. GORDON:
19 Q You said it was a dying industry. So I
20 want to know if you have any plans to expand beyond
21 what you classified as a dying industry.
22 A Well, I do. Obviously I told you with the
23 television pilot, that is my plan is to move into --
24 to utilize my many years of skills as a writer and
1 to move into a direction that's more lucrative.

2 Q Do you have any plans to receive a regular,
3 stable income?
4 A I am not sure how to answer that question,
5 Counsel. What do you mean?
6 Q Are you going to apply for a job that would
7 give you a steady paycheck anytime in the next six
8 months? Do you have any plans to do that?
9 A Yes.
10 Q Okay. What is your plan?
11 A To try to sell my television pilot and
12 become a showrunner and get a steady paycheck.
13 Q Anything other than that?
14 A No.
15 Q Got it. Okay. I am going to do these on
16 tablets. Okay. I am going to show you on this
17 tablet here --
18 MR. KIPNIS: So we have updated the
19 financial affidavit. Do you want that now?
20 MR. GORDON: Sure. That would be helpful.
21 MR. KIPNIS: She hasn't signed it. So do
22 you want to give us five minutes?
23 MR. GORDON: Yes. We'll take a five-minute
24 break.
1 (Recess taken.)
2 BY MR. GORDON:
3 Q Ma'am, you have updated your financial
4 affidavit, I see, dated today?
5 A Um-hum.
6 Q Yes?
7 MR. KIPNIS: Is that a yes?
8 A Yes.
9 BY MR. GORDON:
10 Q And you have signed this affidavit today?
11 A Yes.
12 MR. GORDON: So we can mark this as Exhibit
13 A.
14 MR. KIPNIS: A?
15 MR. GORDON: A.
16 MR. KIPNIS: Not one?
17 MR. GORDON: I go letters.
18 MR. KIPNIS: You do?
19 MR. GORDON: Yes.
20 MR. KIPNIS: Okay.
21 MR. GORDON: You can go numbers and then we
22 will --
23 MR. KIPNIS: No, that's okay.
24 MR. GORDON: But I like it that way because
1 then it keeps it straight.

2 (Deposition Exhibit A was
3 marked for identification.)
4 BY MR. GORDON:
5 Q So I assume given that you just signed this
6 two minutes ago, this is completely accurate?
7 A Yes.
8 Q There's nothing you want to change on this?
9 A No.
10 Q Okay. You made $35,000 last year?
11 A Yes.
12 Q And that's in 2017?
13 A Yes.
14 Q How did you make $35,000?
15 A Airbnb.
16 MR. KIPNIS: Is that it?
17 THE WITNESS: What? Oh, and freelance
18 writing.
19 BY MR. GORDON:
20 Q How much of it was Airbnb, and how much of
21 it was freelance writing?
22 A I don't know.
23 Q Okay. And how many hours a week on average
24 in 2017 did you spend freelance writing?
1 A How many hours a week?

2 Q Yes, in 2017, did you spend freelance
3 writing.
4 MR. KIPNIS: Don't guess, okay? So if you
5 have an answer, a factual answer for him, give it to
6 him.
7 A I don't know. It depends on my story load.
8 It really depends.
9 BY MR. GORDON:
10 Q Do you think you spent more or less than a
11 thousand hours in 2017 writing?
12 A I think I spent about six hours a day
13 writing between my pilot and my freelance
14 assignments.
15 Q And you made it looks here -- I see there
16 is a note on your affidavit that you made $9,450 in
17 freelance work.
18 A Yeah. I haven't been paid out yet on a lot
19 of my stories.
20 Q Okay. But for six hours a day writing over
21 '17 -- and how many days a week is that?
22 A Five days a week.
23 Q Okay. So 30 hours a week you made $9,450?
24 A Yeah, but some of the -- as I mentioned, I
1 haven't been paid for some of the work that I did

2 yet.
3 Q How much are you owed?
4 A I would have to look. I can't answer that
5 accurately at --
7 A Probably like -- I don't know.
8 Q More or less than $5000?
9 A Less, I think.
10 Q Okay. More or less than $3000?
11 A Don't know.
12 Q Okay. So maybe 12,000 or 13,000 for 30
13 hours a week, 52 weeks out of the year?
14 A I don't know.
15 Q Okay. And the Airbnb -- it also says
16 here -- it says which is no longer available. What
17 does that mean, it's no longer available?
18 A I don't know what that means.
19 Q You signed it.
20 A Oh, well, because some of the work went
21 away. Like one of the publications that I wrote
22 for -- they ran out of money, and the other one
23 reduced my assignment load. I used to write like
24 three stories for them. Now I'm down to one.
1 Q Okay. So that time is -- they don't need

2 anymore?
3 A Yeah.
4 Q Got it.
5 A They're running out of money, these
6 magazines.
7 Q So that freelance work is not available to
8 you?
9 A Correct.
10 Q Got it. Okay. On page 3 you say you
11 have -- do you pay your own health insurance
12 premiums? $501.09 a month, who pays that?
13 A I have been, and I think Kevin is paying
14 the kids' now, but I have been paying it all myself.
15 Q You pay $501.09?
16 A Yes.
17 Q And it says here $187.07, expenditures for
18 repayment of debts that represent reasonable and
19 necessary expenses for the production of income.
20 What does that mean?
21 A I believe that's student loan payment.
22 Q Do you know?
23 A I would have to -- I would have to think
24 about this. I'm not positive.
1 Q You signed the affidavit ten minutes ago.

2 MR. KIPNIS: Objection. That's the third
3 time he's asked you if you signed it. So don't
4 answer that question anymore.
6 MR. KIPNIS: It's argumentative and
7 bordering on harassing.
8 MR. GORDON: I am not asking --
9 MR. KIPNIS: She signed the affidavit.
10 It's true and correct, just like the certification
11 says.
12 BY MR. GORDON:
13 Q So what is the 187 for?
14 MR. KIPNIS: She said she thinks student
15 loans. She doesn't recall. She will have to get
16 back to you.
17 BY MR. GORDON:
18 Q Let's go to page 4. Mortgage or rent,
19 $7,285.68, do you pay that?
20 A No.
21 Q Under Section 13 which of these items do
22 you actually pay for?
23 A I pay the electric bill.
24 Q Okay.
1 A I've paid some of the gas bills. I believe

2 Kevin has paid a few of them.
3 Q Okay. So sometimes gas and sometimes not
4 gas?
5 A Correct.
6 Q Okay.
7 A I pay the phone. I pay the cable bill. I
8 pay the Internet. Water and sewer, I paid some. I
9 don't know if Kevin has paid some of them. Laundry
10 and dry cleaning, I pay that. Housecleaning, I have
11 been paying 100 percent of that.
12 Q You have a cleaning lady?
13 A Cleaning man.
14 Q Cleaning man?
15 A Yeah.
16 Q Okay. And how often do they come?
17 A Every two weeks. Repairs and maintenance I
18 pay. In fact, I just paid a thousand dollars to
19 repair the roof that was leaking into the house.
20 Q Do you submit that bill to insurance?
21 A Insurance?
22 Q Insurance.
23 A You think they would pay that? I didn't.
24 I didn't know. I don't think Kevin is paying the
1 insurance.
2 Q So that's a no, you didn't submit it to
3 insurance?
4 A Right, because I don't believe Kevin is
5 paying for the insurance on the house. Perhaps I'm
6 wrong.
7 MR. KIPNIS: Do you know the deductible?
8 Isn't it a thousand?
10 MR. KIPNIS: So you're going to submit the
11 thousand dollar bill to the deductible?
12 THE WITNESS: Right, right.
13 MR. GORDON: Stop giving her the answers.
14 MR. KIPNIS: I am trying to help you.
15 MR. GORDON: No, you're not.
16 THE WITNESS: Yeah, it is. I wouldn't get
17 anything back.
18 MR. KIPNIS: Don't listen to me. Just
19 answer the question.
20 MR. GORDON: Yes, don't listen to him.
21 A So necessary repairs and then groceries,
22 household supplies, and toiletry, yes.
23 Q That's 1200 a month you spend on groceries?
24 A No, household supplies and toiletries. I
1 have to supply a lot of things for the Airbnb

2 people.
3 Q So this includes your Airbnb occupants?
4 A Yes.
5 Q So this is not just for you. This is for
6 other people?
7 A Well, it's to earn a living.
8 Q So these expenses that are listed include
9 people that aren't you; is that correct?
10 A I'm not sure. I have to think about that
11 one.
12 Q Do they include strangers from the Internet
13 that are from Airbnb?
14 MR. KIPNIS: Which particular expense are
15 you talking about?
16 MR. GORDON: Groceries, household supplies,
17 and toiletries.
18 MR. KIPNIS: He is asking you about this
19 line item (indicating).
20 THE WITNESS: Yeah, I know. I have a
21 question for you guys about that. Can we --
22 MR. KIPNIS: If you can't answer it, you
23 can't answer it.
24 THE WITNESS: Yeah. I can't answer that
1 right now. Sorry.

2 BY MR. GORDON:
3 Q Okay. Are any of the other expenses under
4 13 for --
5 A No.
6 Q -- people other than you?
7 A No, they're not.
8 Q What about repairs?
9 A No. They're for me so I can -- necessary
10 repairs so I can live in the house, you know, so
11 there's not water leaking into the house.
12 Q Got it. Okay. You spend $300 a month on
13 clothes --
14 A Yeah.
15 Q -- while Kevin is a deadbeat and gives you
16 no money?
17 A Well, you know --
18 MR. KIPNIS: Excuse me. You don't have to
19 answer that question.
20 MR. GORDON: These are her words.
21 MR. KIPNIS: Is that an admission on your
22 part that he is not supporting her?
23 MR. GORDON: These are her words. She said
24 he is a deadbeat and he gives her no money.
1 A What is your question, Counsel?

2 Q During the time period -- you have said a
3 few times throughout today that Kevin gives you no
4 money. You said he's in contempt of court. He is
5 supposed to pay bills. He doesn't. He is a
6 deadbeat.
7 During this time period --
8 A I will be happy to answer your question. I
9 lost --
10 MR. KIPNIS: He hasn't asked it. He hasn't
11 asked it.
12 THE WITNESS: Okay. All right.
13 MR. GORDON: Thank you.
14 Q During that time period that he's all those
15 pejoratives, you spent $300 a month on clothes?
16 A I have lost a lot of weight because of the
17 stress that your client has put me through, and I
18 need clothing to wear.
19 Q So is that a yes?
20 A That is a yes.
21 Q Okay. And under that same time period, you
22 spent $300 a month on grooming?
23 A Yes.
24 Q Okay. And $300 a month on entertainment,
1 dining out, and hobbies?

2 A Yes.
3 Q Okay. And are any of those hobbies, or is
4 that just entertainment and dining out?
5 A I don't know. I don't know. What do you
6 consider hobbies?
7 Q I don't know. What do you consider a
8 hobby?
9 A Movies. I don't know.
10 Q Okay. And you have here under D on page 5,
11 you spend $3,333.33 a month on tuition.
12 A Yes.
13 Q Explain that to me.
14 A Well, that's my daughter's tuition.
15 Q And you pay it?
16 MR. KIPNIS: We have a 513 petition
17 pending --
18 BY MR. GORDON:
19 Q And you pay it?
20 MR. KIPNIS: -- that's going to be taken
21 with the trial.
22 BY MR. GORDON:
23 Q Do you pay it, ma'am?
24 A I have in a sense because Kevin stole money
1 out of the escrow account to pay it without my

2 permission.
3 Q Okay. So have you paid a tuition bill?
4 A I did pay some of my son's tuition at
5 Fusion when he was there.
6 Q Okay. I am talking about your daughter.
7 MR. KIPNIS: You mean has she written the
8 check or does it come from marital assets or what?
9 THE WITNESS: Right. It's come from
10 marital assets, Counsel.
11 BY MR. GORDON:
12 Q Okay. So this 3300 came out of the marital
13 estate?
14 A Correct.
15 Q Came out of the escrow?
16 A I believe so.
17 Q All of it?
18 A I don't know.
19 Q Okay. But are you writing any checks or
20 paying anything --
21 A I think I already answered that question.
22 Q You actually did not.
23 A I am not writing the checks myself.
24 Q Okay. I got you. Have you ever?
1 MR. KIPNIS: Written a check for tuition?

2 MR. GORDON: Yes. She said sometimes she
3 pays it. I want to know what she is talking about.
4 A I paid for books recently.
5 Q Tuition, the line item is tuition.
6 A Yeah, and I did pay some tuition.
7 Q How much?
8 A Something for Ivy Tech. It's some online
9 classes that she is taking.
10 Q How much did you pay?
11 A I would have to look. I don't know.
12 Q When did you pay it?
13 A It's all on my Glenview State Bank account.
14 Q When did you pay it?
15 A Over the summer.
16 Q Of '17?
17 A Yeah, but I would have to look. I'm not
18 sure. The answer to that question is I don't know.
19 Q Okay. And going up actually -- and during
20 this time period that you said Kevin doesn't pay,
21 $300 a month on vacations?
22 A Yes. I have to visit my son in Utah very
23 often.
24 Q Okay. On D, $300 a month, money sent to
1 Alex at school.
2 A Correct.
3 Q You send her 300 a month?
4 A Yeah. She also uses my credit card for --
5 Q Which credit card?
6 A Glenview State Bank, for --
7 Q Your Discover?
8 A Both. Glenview State Bank is like a debit
9 card. She has a copy of it. So she will use it
10 for, you know -- to order groceries or things that
11 she needs.
12 Q So you don't send her 300 a month?
13 A Sometimes I give her cash. I will send her
14 cash. I FedEx a lot to her.
15 Q In cash?
16 A I have, yes.
17 Q When is the last time?
18 A I'm at FedEx at least once or twice a week.
19 Q So you FedEx her cash once or twice a week?
20 MR. KIPNIS: He asked you the last time you
21 FedEx'd her cash.
22 A No, not once or twice. I'm there once or
23 twice a week sending her things that she needs. I
24 was just there yesterday.
1 BY MR. GORDON:
2 Q When is the last time you sent her cash?
3 A I actually gave her cash the last time she
4 was home for break.
5 Q When was that?
6 A December.
7 Q How much did you give her?
8 A 300.
9 Q When is the last time you FedEx'd her cash?
10 A Last time I FedEx'd her cash, I don't know.
11 A couple months ago.
12 Q Okay. And does she use your Discover card?
13 A Yeah.
14 Q How often does she use your Discover card?
15 A She has it.
16 Q You don't even have it?
17 A No -- well, I got another one for me but,
18 yeah.
19 Q She just uses it?
20 A Yes.
21 Q So let's go to the next page. Creditor
22 name, one, Discover, 21,858.54.
23 A Yes.
24 Q That's the card your daughter uses?
1 A Correct.
2 Q Okay. And how much of those charges are
3 her charges?
4 A Everything.
5 Q Everything is her. Okay. And Von Maur,
6 clothing, family expenses, is that a credit card?
7 A Yeah.
8 Q American Airlines line of credit, family
9 expenses, 2800, what is that?
10 A It's a loan that I had that I'm -- that I'm
11 paying off. I don't use it.
12 Q When did you take out a loan?
13 A I don't know.
14 Q In the last three years?
15 A No.
16 Q Okay. Evanston Hospital, $5000, is this
17 the medical bills you are talking about?
18 A Yeah. There's more than that, though, and
19 I --
20 Q That aren't listed on here?
21 A Yeah.
22 Q Okay. How much?
23 A I don't know because I have just hired
24 somebody to try to help get my insurance company to
1 pay for Connor's hospitalization at University of

2 Utah.
3 Q Who did you hire?
4 A It's called Claim Relief.
5 Q When did you hire them?
6 A Yesterday.
7 Q How much did you pay them?
8 A I don't know. I haven't gotten the bill
9 yet but --
10 Q Got it.
11 A So that bill is, I think, something like
12 8000 and then --
13 MR. KIPNIS: I'm sorry. What bill?
14 THE WITNESS: The University of Utah. I
15 gave you those bills.
16 MR. KIPNIS: Okay, okay. All right.
17 BY MR. GORDON:
18 Q So that's different than what is on here?
19 A I will be happy to give you copies of those
20 bills. There's a -- the kids' insurance got
21 exhausted in September. I had a plan that was a
22 grandfathered in plan from American, and all three
23 of us were suddenly without insurance, which is a
24 nightmare, and I alone as usual -- I did all the
1 work, and I found insurance plans for both of my

2 children and myself, and I have been paying for it,
3 so FYI.
4 MR. KIPNIS: I thought he was paying.
5 THE WITNESS: Well, now he is, I think.
6 MR. KIPNIS: Probably something we should
7 figure out before trial.
9 MR. GORDON: My thoughts exactly.
10 Q Lucy Kennedy, who is that?
11 A That's my mother.
12 Q And you owe her $22,400?
13 A That's correct.
14 Q Okay. Do you have any notes?
15 A I have two promissory notes and --
16 MR. GORDON: Do we have those?
17 MR. KIPNIS: Yes. We tendered them.
18 MS. SMITH: We should have them.
19 MR. KIPNIS: Yes.
20 A And for the 10,000 that I borrowed to pay
21 Robert and then the 1500 that I borrowed to pay
22 Connor's attorney.
23 BY MR. GORDON:
24 Q Okay.
1 A And then the other -- I have copies of

2 checks. So the rest of it represents when Kevin
3 wasn't paying support, my mother, when she could,
4 would send me a check for 300 or 500, just to buy
5 groceries.
6 Q But there are no promissory notes for that?
7 A No, there isn't.
8 Q Okay. And your mother expects you to pay
9 her back?
10 A Yes.
11 Q Are you going to pay her back?
12 A I am.
13 Q What's the interest rate on those notes?
14 A She is not charging me interest.
15 Q Okay. When are they due?
16 A I probably will start paying her back as
17 soon as I settle the divorce and have money
18 hopefully, unless you guys take all of it.
19 Q Grund & Leavitt, how much do you owe them?
20 A I don't know.
22 A Honestly, I haven't been able to look at
23 the bills.
24 Q Why not?
1 A It's too upsetting.

2 Q So you are choosing not to?
3 A I guess you could call it a choice.
4 Q Okay. How much money do you think Kevin
5 makes in a given year? Right now how much do you
6 think he earns?
7 A I know that throughout the course of our
8 marriage, he earned enough to pay a mortgage of more
9 than $7000 a month, and we had a nice lifestyle. He
10 was an attorney, a real estate developer and --
11 yeah. I do know that he's reduced his income
12 willfully.
13 Q How do you know that?
14 A He told me.
15 Q When did he tell you that?
16 A He told me right before I filed for
17 divorce. He said, I want a divorce, and I'm worth a
18 million dollars. I'll give you 500. And I said,
19 Oh, well, first of all, I would have to find out if
20 that's really true that you're worth a million.
21 Second of all, you're going to have to pay me
22 alimony and child support.
23 And you know what he said to me? He said,
24 I will never pay you alimony or child support. And
1 I said, Well, you can't do that. He goes, I'll just

2 stop working. Have you ever thought of that?
3 Those were his words to me.
4 Q Any other proof that he's willfully reduced
5 his income?
6 A Yeah. Look at his income. It's gone way
7 down.
8 Q Okay. But any proof that he's doing it on
9 purpose?
10 A And he's taking trips to Thailand and
11 Vietnam and all over Asia --
12 Q So how is that evidence that he --
13 A -- some sex trips with underage girls.
14 MR. KIPNIS: Can you answer his question?
16 MR. KIPNIS: He is asking you how that is
17 evidence. So you are going to say what, that if
18 he's out on a vacation, he can't be here working?
19 THE WITNESS: That's right.
20 MR. GORDON: Thanks, Bob.
21 MR. MUDD: Good answer, Bob.
22 BY MR. GORDON:
23 Q So you say sex trips for underage people?
24 MR. KIPNIS: You see what happens when you
1 say that? Do you see?

2 BY MR. GORDON:
3 Q How in the world do you know that?
4 A I've seen -- would you like to see a
5 picture?
6 Q Yeah.
7 A Okay.
8 MR. KIPNIS: Can you show me what you're
9 going to show him before you show him, please.
10 THE WITNESS: The picture of him in the
11 Philippines with his girlfriend, the one that he's
12 been sending money to.
13 MR. KIPNIS: That's an exhibit on the --
15 BY MR. GORDON:
16 Q Let me see it.
17 MR. KIPNIS: Show him.
18 A The one that he admitted to sending money
19 to her and her son for at least two years.
20 MR. KIPNIS: You are just showing him a
21 picture, though. There is no question pending. Let
22 me see.
23 THE WITNESS: Here we go.
24 MR. KIPNIS: Wait, wait, wait, wait, wait.
1 Is that the same person? Take a break. Do you want

2 these?
3 MR. GORDON: We can mark these as Group
4 Exhibit B.
5 (Group Deposition Exhibit B was
7 BY MR. GORDON:
8 Q Explain to me how this is -- you say this
9 is an underage sex trip.
10 A The Thailand was. This is Vietnam -- I'm
11 sorry. This was the Philippines.
12 MR. KIPNIS: I am going to write B on the
13 back of both of these, okay?
14 MR. GORDON: Sure. Thanks, Bob.
15 Q How do you say that's an underage sex trip?
16 MR. KIPNIS: That's him?
17 THE WITNESS: That's Kevin right there
18 (indicating).
19 MR. KIPNIS: Oh, my God. I'm so bad. I
20 can't --
21 BY MR. GORDON:
22 Q Why are either of those two photos evidence
23 of an underage sex trip? Is there any sexual
24 relation evidenced in either of those two photos?
1 They look like they're at a zoo with silly hats on.

2 A Okay. I don't think you're going to fly to
3 Vietnam to see -- or to the Philippines to see a
4 woman and her son who you have been spending --
5 sending money to for two years if sex is not
6 involved.
7 Q So you are assuming it's sex?
8 A Yeah, but I also came across a bag of his
9 sex toys that he left in his room.
10 Q And why do you say -- let's stay actually
11 on the underage part. If this person has a child,
12 are they also underage? Why do you say underage?
13 What does that mean?
14 A I saw him in Evanston one day with two
15 Asian girls that looked like they were about 16.
16 Q Do you know how old they were?
17 A I don't know for sure.
18 Q Are they the women from the photos that you
19 just showed me, the zoo photos?
20 A No, no.
21 Q Okay.
22 A This was in Evanston.
23 Q So you are making -- you are guessing?
24 When you say underage sex, you are guessing?
1 A Correct.
2 MR. KIPNIS: Wait, wait, wait. No, no, no.
3 I need those.
4 MR. GORDON: Those have to stay out.
5 MR. KIPNIS: Now they stay.
6 A I am making an assumption, an educated
7 assumption.
8 BY MR. GORDON:
9 Q Do you think Kevin's law practice has any
10 value?
11 A I don't know how to answer that question,
12 Counsel.
13 Q Do you have any other evidence or proof
14 that Kevin is willfully reducing his income other
15 than what you have testified to?
16 A He's told me, and his trips, when he's not
17 working, is evidence.
18 Q We have gone through those. So what else,
19 anything concrete for me?
20 MR. KIPNIS: I am going to object to the
21 form of the question.
22 A How about his income?
23 MR. KIPNIS: If you can answer his
24 question, answer it. But she just did. His income.
1 BY MR. GORDON:
2 Q I said anything other than those two
3 things. Anything other than those?
4 MR. KIPNIS: She just added a third, his
5 income.
6 BY MR. GORDON:
7 Q His income. Anything else?
8 MR. KIPNIS: Or at least what he's
9 reporting to be his income.
10 THE WITNESS: Yeah, yeah.
11 BY MR. GORDON:
12 Q So do you have any idea what he makes?
13 A I did find --
14 Q I'm sorry. I didn't finish letting you
15 answer that question. Anything else?
16 A Well, yeah, there is something. I did
17 find -- in the attic where he used to work, there
18 was a crawlspace with a white cooler in it that was
19 filled with money and guns, and it was about
20 $300,000. And I believe probably he has that money
21 hidden in his house somewhere.
22 Q When did you find a cooler full of cash and
23 guns? I'm sorry. Was it cash?
24 A Yeah.
1 Q How do you know it was $300,000?

2 A I counted it.
3 Q So you put your hands on the money?
4 A I did. I put gloves on.
5 Q Where is the money now?
6 A Gone. It disappeared so --
7 Q When did this happen?
8 MR. KIPNIS: You are asking her when she
9 found it, right?
10 MR. GORDON: Yes.
11 MR. KIPNIS: Okay. When was it?
12 BY MR. GORDON:
13 Q When did you find it?
14 A It was right around the time that I filed
15 for divorce. So that was December of 2015. Right
16 around that time --
17 Q How much of it did you take?
18 A Nothing.
19 Q What about the guns?
20 MR. KIPNIS: You should have retained me
21 from the beginning.
23 MR. GORDON: Stipulated.
24 A The guns, I'm afraid of guns. I was afraid
1 to even touch them and afraid for my son's

2 well-being because he was living in the house at the
3 time and he was depressed, and I didn't want him to
4 get a hold of the guns.
5 Q So did you take the guns?
6 A I did not.
7 Q Okay. So even though you were afraid that
8 your son could be injured, you left them -- you just
9 left them be?
10 A Well, they were hidden away, but then I --
11 when Kevin --
12 Q Not well enough for you not to find them,
13 right?
14 A I did, though, confront Kevin about the
15 guns and made him -- because then another time I
16 went up there and he had the guns out, and they were
17 numerous guns, like a pistol and rifle.
18 Q How many?
19 A At least two, maybe three and I --
20 Q But you are not sure how many?
21 MR. KIPNIS: She just said two or three.
22 A Yeah, I'm not sure.
23 MR. GORDON: She said two, maybe three.
24 MR. KIPNIS: All right.
1 A So I stand by my answer.
2 BY MR. GORDON:
3 Q Those are two different numbers.
4 A Two, maybe three.
5 Q So you are not sure, okay.
6 A I confronted Kevin and was very upset
7 because I was worried about my son's safety, and I
8 asked him to take the guns out of the house. I --
9 Q So you --
10 MR. KIPNIS: I don't think she is done.
11 BY MR. GORDON:
12 Q I'm sorry. Go ahead.
13 A My understanding is that he had his
14 assistant, Jeff Koppel, take the guns to his
15 apartment. He lives for free in one of Kevin's
16 apartments on Medill.
17 Q So --
18 A I also called Connor's psychiatrist about
19 this at the time, and he said I don't care if
20 there's a lock on the guns. Get them out. You
21 know, there should not be guns in your house with
22 your son --
23 Q And so did you? Did you get them out?
24 A Well, Kevin -- I made Kevin get them out.
1 Q Okay.
2 A Yeah.
3 Q And you did what with the cash then?
4 A The cash was gone by then.
5 Q Did you take photos of the cash?
6 A Yeah, I did, and the problem is that I --
7 my old phone broke and the -- it cracked and the
8 screen -- you can't -- I can't get anything off of
9 it. I've tried.
10 Q How many photos did you take?
11 A Probably six.
12 Q Okay. Who was with you, if anybody, when
13 you were counting the cash?
14 A Who was with me? I mean, I was by myself.
15 Q And you went back -- let me get this
16 straight. So you found a cooler full of cash and
17 guns --
18 A Yes.
19 Q -- and then you went back to the cooler,
20 and the guns were out again?
21 A No. Then a few days later, I went up to
22 Kevin's office, and he was there with his assistant
23 working. And the guns were out in the open, because
24 I was afraid actually -- when I found the cash and
1 the guns, I thought what is happening here? It just

2 seemed dangerous and I was --
3 Q You didn't remove them from the home
4 then --
5 A Right. I was --
6 Q -- even though you were afraid?
7 A I was afraid to say anything, and then I
8 called people that I knew to try to get advice. I
9 called Connor's psychiatrist, and then he said get
10 the guns out immediately.
11 And I just happened to walk up to the third
12 floor, and Kevin was working with his assistant, and
13 the guns were out in the open.
14 Q How is it that you think Kevin acquired
15 $300,000 worth of cash in a cooler?
16 MR. KIPNIS: And the cooler?
17 MR. GORDON: In a cooler.
18 A I don't know how to answer that.
19 MR. GORDON: I don't care how it got in the
20 cooler.
21 A I don't know how to answer that question.
22 Q I guess, if you want to know, how did he
23 get a cooler?
24 A I think that would be a question for Kevin.
1 MR. KIPNIS: Kevin?

2 BY MR. GORDON:
3 Q So you filed for -- divorce pending, you
4 found 300,000 in cash. There are photos that are
5 now no longer accessible. How long did it take you
6 to count all this cash?
7 A A long time and I was afraid.
8 Q What does "a long time" mean?
9 A I don't know. I spent the whole morning up
10 there, but he was out of town so --
11 Q So you were afraid. Why were you afraid?
12 A I mean, I didn't know where the money came
13 from, if he was involved in some kind of criminal
14 activity, and so of course I was afraid.
15 Q Were you represented by Maol Sloan at the
16 time?
17 A No. I think I hired Maol right after that.
18 So I didn't have counsel.
19 Q So this cash is just now coming up, but you
20 called Connor's mental health treaters?
21 A Yes.
22 Q Anyone else you called about the cash?
23 A My gay friend and asked him what to do.
24 Q And does he have a name?
1 A Mark Olley.
2 Q Spell it, please.
3 A O-l-l-e-y.
4 Q And what did Mark have to say about the
5 cash in the cooler?
6 A He said take it.
7 Q And did you call anyone else?
8 A No.
9 Q Okay. Did you call the police?
10 A No.
11 Q Did you call the fire department?
12 A No.
13 Q Did you call the FBI?
14 A No.
15 Q Okay. You said you were worried about some
16 sort of criminal activity so --
17 A Well, I was, but I didn't -- you know, I
18 didn't know what to do.
19 Q Okay. You think Connor is capable of
20 living on his own?
21 A No.
22 Q What is the plan for Connor?
23 A I don't know. I'm trying to find a
24 transitional facility for him, for young adults, and
1 it's hard to find and then --

2 Q Are you having a joint guardianship with
3 Kevin?
4 A Yeah.
5 Q When do you expect that process to be
6 completed?
7 A The court date is March 7, I believe,
8 March 6. I would have to look, and we need to
9 take --
10 MR. MUDD: The 7th.
11 A -- note of that in case we go to trial and
12 the trial is -- we have to be there for that date.
13 BY MR. GORDON:
14 Q I see. How many checking accounts do you
15 have?
16 A One.
17 Q Is that at Glenview State Bank?
18 A Correct.
19 Q And that is account -- it looks like that's
20 account ending 9770. It used to be account ending
21 1425?
22 A That doesn't sound right. It's ending in
23 2823.
24 MR. KIPNIS: That's the checking?

2 MR. KIPNIS: When did that happen? 8308 --
3 THE WITNESS: Somebody hacked into my bank
4 account. So I had to close my other one and open a
5 new one.
6 BY MR. GORDON:
7 Q So I don't have any statements of your
8 checking or savings from November for -- anything
9 past November of '17.
10 MS. PRESTO: Okay. So we'll update from
11 November.
12 MR. GORDON: Thank you.
13 MR. KIPNIS: I thought I saw November and
14 December. Maybe I have it on me.
15 MS. PRESTO: I think you may have it.
16 MR. GORDON: On here?
17 MR. KIPNIS: No, no, no. I might have it
18 in my -- I brought -- what did I give you, bills?
19 MS. PRESTO: You gave me bills and -- oh,
20 and the updated statements.
21 MR. KIPNIS: Yeah. I think all I did was
22 highlighted them.
23 THE WITNESS: I have them.
24 MR. KIPNIS: With you?
1 THE WITNESS: No.

2 MS. PRESTO: These have our markings on
3 them. So I will get you guys copies. These are the
4 updates she brought. Somebody marked them up.
5 BY MR. GORDON:
6 Q Ma'am, I am going to show you here -- if
7 you need the documents for your reference -- so you
8 have a Glenview checking account --
9 MR. KIPNIS: Are you showing her this?
10 MR. GORDON: If she wants it for her
11 reference.
13 MR. GORDON: I am building to something.
14 MS. PRESTO: So dramatic.
15 MR. GORDON: Yes.
16 MR. KIPNIS: It's very dramatic in here.
17 MR. GORDON: Hold on, everybody.
18 Q And you have a Glenview Bank savings
19 account?
20 A Correct.
21 Q Okay. And do you have any other checking
22 or savings accounts?
23 A In my name, no.
24 Q Okay. Anything that you have access to or
1 ownership interest in?

2 A No.
3 Q Okay. And you said your daughter has
4 access to your Glenview checking?
5 A Yeah.
6 Q Does she ever make deposits into it?
7 A No.
8 Q Okay. She just uses the debit card?
9 A Yeah, and not that often but when she needs
10 something.
11 Q Okay. Does she ask you for permission
12 first?
13 A Always, yeah.
14 Q Okay. Does anybody else have access to
15 your Glenview checking or savings?
16 A No, no.
17 Q So based on my calculations --
18 MR. KIPNIS: Are you talking about
19 currently or ever?
20 MR. GORDON: Currently.
22 BY MR. GORDON:
23 Q How about -- let's call it from December of
24 '16 until now?
1 MR. KIPNIS: December of --

2 A December of --
3 BY MR. GORDON:
4 Q Has anyone had access?
5 A Well, my son.
6 Q Was he making any deposits?
7 A No.
8 Q Okay. So I have based on my calculations
9 between December 16th of 2016 and November 14th of
10 2017, you deposited $110,969.81 --
11 MS. PRESTO: Can you say that again, Mitch?
12 MR. KIPNIS: 110,969.81.
13 MR. GORDON: Thank you, Bob.
14 Q -- into those accounts. So help me
15 reconcile how someone who makes $35,000 a year from
16 writing and Airbnbs deposited $110,000 in an
17 11-month period.
18 A Well, you can pull that all up. So those
19 were refunds from insurance that I used to support
20 my family, and that was all --
21 Q All of it?
22 A Yeah. You can look at my --
23 Q You had $110,000 worth of insurance
24 refunds?
1 MR. KIPNIS: Objection. That's not what

2 she said.
3 MR. GORDON: That is what she said.
4 MR. KIPNIS: You presupposed it with
5 35,000, right?
6 MR. GORDON: That's correct.
7 Q So the difference is all insurance refunds?
8 A Yeah.
9 Q Okay.
10 A Oh, well, I mean -- and then my mother gave
11 me money too.
12 Q How much of that is your mother?
13 A 23,000 or something like that. I have to
14 look.
15 MR. KIPNIS: It's on the --
16 A 22,400.
17 BY MR. GORDON:
18 Q Okay. So approximately 50,000 is insurance
19 refunds?
20 A Correct. That sounds right.
21 Q Okay.
22 MR. KIPNIS: That is right.
23 BY MR. GORDON:
24 Q And did you spend all that money?
1 A I did.
2 Q Okay. And one insurance refund was for, I
3 believe, $57,525.53?
4 A Um-hum.
5 Q Is that a yes?
6 A Yes.
7 Q And you spent all of that?
8 A Correct, and we already went through this
9 with Judge Boyd. I did my accounting and showed him
10 that I was using the money to support my family, my
11 children, and he agreed with me, and it was settled.
12 That was already settled, Counsel.
13 Q When did that happen?
14 A Oh, you were there. So it's funny that you
15 should ask me that question. Maol Sloan and you
16 were in the back room with Judge Boyd. Judge Boyd
17 said -- he look at my accounting, and he said it all
18 makes sense. And I was able to show that every bit
19 of it was used to support my children. I was not
20 receiving any support from Kevin. He was already in
21 contempt of court at that time.
22 Q And this was in chambers or behind closed
23 doors?
24 A That is correct, Counsel.
1 Q So did you hear Judge Boyd say this?

2 A I was not there, but I was told by my
3 attorney at the time --
4 MR. KIPNIS: Well, you are not going to
5 waive your privilege so --
6 BY MR. GORDON:
7 Q Without waiving privilege, the story you
8 just told me, and I will reiterate it as a story --
9 A You were there, Counsel, so are you going
10 to lie about that?
12 BY MR. GORDON:
13 Q So the story you just told me, and I
14 understand you're not waiving privilege --
15 A I stand by -- I'm not going to say it
16 again. I stand by what I told you. That is the
17 truth and nothing but the truth.
18 Q According to Maol Sloan.
19 A No.
20 Q According to you?
21 A According to Judge Boyd. Why don't we ask
22 him.
23 MR. KIPNIS: We will.
24 MR. GORDON: You bet.
1 MR. KIPNIS: I mean, I don't see a sanction

2 order in here against her, so I don't know what
3 happened.
4 BY MR. GORDON:
5 Q So that $57,000 was the --
6 A That was the reason Judge Boyd --
7 Q Let me ask you, what court date was that?
8 A That I don't know.
9 Q And it was the reason Judge Boyd what? I
10 cut you off. What were you about to say?
11 A Nothing. Forget it.
12 Q But that was -- you made that deposit in
13 January of '17.
14 A Okay.
15 MR. KIPNIS: Which deposit?
16 MR. GORDON: The 57,000.
17 Q How quickly did you spend that money?
18 A Well, let me explain something to you.
19 Q Please.
20 A We had a certain lifestyle, and I was
21 trying to -- I was paying for everything. I was
22 even paying for our club membership dues. I was
23 paying for -- I had both children living with me. I
24 paid some of my son's tuition. I was paying the
1 doctor bills. I was paying the utility bills,

2 groceries, food, clothing, everything, my daughter's
3 college expenses, her, you know -- moving her twice,
4 to her dorm and to her apartment, bought her
5 furniture, you know, bought her clothes, took
6 care -- it all adds up, Counsel, and when --
8 A When you are getting nothing from your
9 husband, of course I'm going to live off of whatever
10 I can.
12 A It's all on my Glenview State Bank
13 accounts. Let me refer you to that.
14 Q They're right in front of you.
15 A Okay.
17 MR. KIPNIS: Does that mean you want her to
18 go through her statements?
19 MR. GORDON: Sure, yes.
20 MR. KIPNIS: Okay. Pull up, if you can,
21 from the $57,000 deposit and tell him when it was
22 all used up.
23 THE WITNESS: Where is it?
24 MR. KIPNIS: It's somewhere in here. I
1 don't know. I don't know about those computer

2 things.
3 THE WITNESS: And what was the date of the
4 check?
5 MR. KIPNIS: I think he directed you to
6 January of 2017.
7 MR. GORDON: January 24th of 2017.
8 MR. KIPNIS: 1/24/17, and you want to know
9 how long it took her to spend that 57?
10 MR. GORDON: Correct.
11 THE WITNESS: This isn't really pulling up.
12 Does anyone have --
13 MS. SMITH: It is a little -- here, let me
14 pull it up for you.
16 MR. KIPNIS: I am --
17 THE WITNESS: One of the things that I was
18 spending money on was --
19 MR. KIPNIS: I think he asked you for
20 length of time.
21 THE WITNESS: Oh, okay. So how do I go to
22 the next one?
23 MS. SMITH: Just scroll. Like use it as if
24 you are using your phone kind of now. You can
1 scroll up.
2 THE WITNESS: But I think this is the end
3 of this.
4 MS. SMITH: Oh, okay.
5 MR. GORDON: Then you go back like this
6 (indicating).
7 Want to take a break now, have her look
8 through it?
9 MR. KIPNIS: Sure.
10 (Recess taken.)
11 BY MR. GORDON:
12 Q So, ma'am, now that you've had a chance to
13 look through your bank statements, how long did it
14 take you to spend that $57,000?
15 A Counsel, that's impossible for me to
16 decipher because I had money coming in and out of
17 those accounts, so I have no idea. I can't possibly
18 answer that question.
19 Q Okay. Who is Roger Hague?
20 A Roger Hague? He is a doctor.
21 Q Okay. Is he a cosmetic surgeon?
22 A He is.
23 Q Okay. And did you spend $3600 with Roger
24 Hague on January 18th of 2017?
1 A Not for cosmetic surgery.

2 Q Did you spend $3600 with Roger Hague on
3 January 18th of 2017?
4 A My hair was falling out from stress --
5 MR. KIPNIS: Hang on. What date,
6 January 18 --
7 MR. GORDON: 2017, yes.
8 A My hair was falling out from all the stress
9 of the divorce. So I had a treatment. It wasn't
10 plastic surgery.
11 Q And it was 3600 bucks?
12 A That's correct.
13 Q Okay. Have you been on a Princess cruise
14 in 2016?
15 A I took my children on a cruise for
16 Christmas, both children.
17 Q What is Taylor Reese Salon?
18 A That's my hair salon.
19 Q How often do you go?
20 A Once a week. I have been doing it my
21 entire marriage. Kevin is well aware of that.
22 MR. KIPNIS: He is not asking you about
23 that, though.
1 BY MR. GORDON:
2 Q Are you on Tinder?
3 A Yes.
4 Q How come you pay for Tinder?
5 A Because I wanted to protect my privacy for
6 the sake of my children.
7 Q What does that mean?
8 A That means for $20 a month, no one can see
9 me unless I like them first. So I don't want
10 everyone to know I'm on Tinder.
11 Q Do you have photos of your children on
12 Tinder?
13 A I do not. My daughter is very upset about
14 the divorce, and I'm trying to protect her.
15 Q So the Airbnb money, is that always
16 deposited in your Glenview State Bank?
17 A Yes, it is.
18 Q Let's talk about Golf Terrace again.
19 A Okay.
20 Q There was an offer to rent Golf Terrace in
21 May of '17, correct?
22 A Not exactly.
23 Q Okay.
24 A I never saw an official offer.
1 Q Okay. But you are aware that you rejected

2 the opportunity to rent?
3 A What I am aware of, Counsel, is that I had
4 a court order stating expressly that Golf Terrace
5 was to be sold, not leased.
6 Q And so you rejected the opportunity to
7 rent?
8 A It was something that both Kevin and I came
9 to a decision about, and at that time Kevin was in
10 contempt of court. He hadn't been paying me court-
11 ordered maintenance. So I was getting no money at
12 that time, and my rental townhouse had expired. So
13 I had nowhere to go. And, third, I had to stay in
14 the district because of my son's care.
15 Q So is that a yes, you rejected the
16 opportunity to rent --
17 A Both of us did.
18 Q Including you?
19 MR. KIPNIS: That's both.
20 THE WITNESS: Yeah, that's both.
21 MR. KIPNIS: But the court order on
22 April 10 says it's listed for sale only. So you
23 want her to violate a court order?
24 THE WITNESS: For sale only. Do you want
1 me to violate a court order?

2 MR. GORDON: I didn't ask her to violate a
3 court order, Mr. Kipnis and Ms. Kennedy.
4 THE WITNESS: What are you suggesting,
5 Counsel?
6 MR. KIPNIS: Don't ask him --
8 BY MR. GORDON:
9 Q First of all, I am going to ask you to put
10 your phone away, because since our break, you have
11 been texting. Are you recording this?
12 A No. I haven't texted anyone.
13 Q Okay. You have been looking at your phone
14 since the --
15 MR. KIPNIS: She is expecting a phone call,
16 so that's why.
17 THE WITNESS: I am expecting a call from my
18 son, just FYI.
19 MR. GORDON: Great.
20 MR. KIPNIS: And if it comes, we got to
21 take a break.
22 BY MR. GORDON:
23 Q Okay. So let's talk about that townhouse.
24 You said the townhouse was expired. What are you
1 talking about?
2 A I had a year lease.
3 Q On what?
4 A What do you mean?
5 Q A year lease on what property?
6 A On Central Street, townhouse.
7 Q Okay. And was that rent paid in advance?
8 A Yes, it was.
9 Q How much?
10 A Your client willingly gave me the money --
11 Q How much?
12 A -- because we both thought the house would
13 sell quickly.
14 Q How much?
15 A I believe it was 27-5 or something like
16 that.
17 Q 27,500?
18 A I believe so.
19 Q Okay. Did you ever move into that
20 property?
21 A I moved a few pieces of furniture in, but I
22 was told by my real estate agent at the time that I
23 should not leave my house, the marital house for
24 sale empty, and I didn't have two sets of furniture.
1 Q Did you ever move into the property, into

2 the townhouse?
3 A No.
4 Q Okay. Did you ever rent it out as a bed
5 and breakfast or an Airbnb or any other similar
6 service?
7 A I didn't have the right to do that.
8 Q So it sat vacant for 12 months?
9 A My daughter and son occasionally would stay
10 there before an early showing so that I didn't have
11 to get them out of bed.
12 Q They would stay there by themselves?
13 A Well, my daughter is an adult.
14 Q They would stay there by themselves?
15 A A night or two, yeah.
16 Q Okay. And do you trust Connor to be there
17 by himself?
18 A If he's with his sister, yes.
19 Q So you never moved into that townhouse?
20 MR. KIPNIS: Objection. She has answered
21 that.
23 BY MR. GORDON:
24 Q You never moved in?
1 A I already answered that.

2 Q That's a no, you didn't?
3 MR. KIPNIS: She said no.
4 MR. GORDON: I want her to say it.
5 THE WITNESS: No, I'm not going to say it
6 again.
7 MR. KIPNIS: She said it.
8 THE WITNESS: I already said it once. This
9 is feeling abusive. I don't really care for this.
10 MR. KIPNIS: Just hang in there. He's got
11 a little time left. If he continues to ask --
12 BY MR. GORDON:
13 Q Golf Terrace --
14 MR. KIPNIS: -- repetitive questions, we'll
15 leave.
16 BY MR. GORDON:
17 Q Did you ever take that house -- since you
18 are talking about a court order, did you ever pull
19 that house off the market?
20 A I did once, yes.
21 Q Okay. And when did you do that?
22 A I believe it might have been in April. I'm
23 not quite certain.
24 Q Why?
1 A Because Kevin -- I got shutoff notices from

2 the Village that the water was being shut off. I
3 got a shutoff notice from ComEd. I tried to get
4 Kevin to pay these bills. He wouldn't respond. I
5 spoke to my real estate agent, and she said you
6 can't list -- I can't list the house if the
7 utilities are not functioning.
8 Q Did you seek permission from the Court to
9 remove it from the real estate market?
10 A No. I didn't actually remove it. I think
11 that's incorrect. I just didn't -- I just said we
12 can't do a showing.
13 Q So you stopped -- so you were refusing
14 showings?
15 A One showing because we were about to not
16 have utilities.
17 MR. GORDON: Excuse me. You two are being
18 very distracting.
19 MR. KIPNIS: Where is the court order
20 requiring the house to be listed? Do you have a
21 point of reference --
22 MR. GORDON: I will get --
23 MR. KIPNIS: -- that she was violating a
24 court order?
1 MR. GORDON: She is the one that brought it

2 up.
3 MR. KIPNIS: Yes, but you are the one that
4 knows. Where is the order requiring --
5 MR. GORDON: I will get you a copy, but she
6 brought it up. She brought up a court order saying
7 it has to be listed for sale, so I am asking her
8 about it.
9 MS. PRESTO: I think you are conflating the
10 orders.
11 MR. GORDON: Not really, but I understand
12 your point.
13 Q Okay. So you were refusing showings?
14 A Just one until Kevin could get the house in
15 working condition so it could be showed.
16 Q How come everything is Kevin's fault?
17 MR. KIPNIS: Don't answer that question.
18 A And it actually wasn't me. It was my real
19 estate agent who had tried unsuccessfully to reach
20 Kevin to get him to pay these bills, and she is the
21 one that said I can't show your house if there's no
22 utilities.
23 BY MR. GORDON:
24 Q 843-845 West Lakeside, is that Kevin's
1 nonmarital property?
2 MR. KIPNIS: Objection, calls for a legal
3 conclusion. How can she possibly answer that?
4 A I stand by what my counsel said.
5 BY MR. GORDON:
6 Q You don't know?
7 MR. KIPNIS: You can answer if you know or
8 not. I mean, are you a lawyer?
9 A It was purchased during the marriage. I
10 consider it marital property, Counsel.
11 BY MR. GORDON:
12 Q And now you have made overtures before that
13 there's some sort of marital contribution to that
14 property. How much?
15 MR. KIPNIS: To which one? I'm sorry.
16 MR. GORDON: 843-845 West Lakeside.
18 BY MR. GORDON:
19 Q How much are you claiming is marital
20 contribution?
22 Q Do you know?
23 A I would have to look at my record -- I
24 would have to like think about it and think about
1 all the improvements that were done over the years,

2 look at tax returns.
3 Q So do you have any idea?
4 A Not at this moment.
5 Q Okay. 2313 --
6 A Substantial, though, a substantial amount
7 of money.
8 Q What does substantial mean?
9 A It means there were a lot of expensive
10 things that were done to the building.
11 Q How much?
12 A I just answered that question.
13 Q 2313 West Medill --
14 A Yes.
15 Q -- do you believe there is a marital
16 contribution to that --
17 A Absolutely.
18 Q Okay. And how much?
19 A Well, I lived there. I personally put
20 central air in the two upstairs units. I paid for
21 it myself.
22 Q How did you pay for it?
23 A We added -- my job, you know. I wrote a
24 check.
1 Q How much?
2 A It was a long time ago but --
3 Q When?
4 A In the '90s.
5 Q And you were living there at the time?
6 A Correct.
7 Q Okay.
8 A We put in a new kitchen, Kevin and I.
9 MR. KIPNIS: Do you know how much the
10 central air was? Don't guess but tell him if you
11 know.
12 THE WITNESS: I don't know. Probably a
13 couple thousand.
14 BY MR. GORDON:
15 Q Are you guessing?
16 A Yes.
17 Q Okay.
18 MR. KIPNIS: Okay. Don't guess.
19 A We put in a new kitchen.
20 BY MR. GORDON:
21 Q Were you living there?
22 A We refinished the floors.
23 We were living there. We added --
24 Q Was this all in the '90s?
1 A Yes. We added closets upstairs.

2 Q Yes. All the '90s?
3 A Yes, yes.
4 Q Okay, closets. How much did you spend on
5 the kitchen?
6 A I am going to say 30,000.
8 A Yeah, but I kind of remember the amounts.
9 Q Do you have any documents evidencing
10 anything you spent?
11 A No.
12 Q Okay. And you said there were closets.
13 How much did you spend on the closets?
14 A Probably a couple thousand.
16 A Yes.
17 Q Okay. Do you have any evidence showing how
18 much you spent on the closets?
19 A We put in a garage too.
20 Q Do you have any evidence showing how much
21 you spent on the closets?
22 A No.
23 Q Okay. The garage, how much did you spend
24 on the garage?
1 A I don't know.
2 Q Okay. Do you have any evidence showing
3 what you spent?
4 A No.
5 Q Okay. And this was all while you were
6 living there?
7 A Yep.
8 Q And this was all in the '90s?
9 A Yeah.
10 Q Okay. And who is Alex Pureco?
11 A That's Kevin's handyman who works on the
12 buildings.
13 Q On Medill and Lakeside?
14 A Um-hum.
15 Q Yes?
16 A Yes.
17 Q And has Alex Pureco been paid in full? Is
18 he owed any money?
19 A I don't know.
20 Q Okay. Do you have any retirement accounts?
21 A No.
22 Q What about American Airlines?
23 A Yeah. I have a small amount that I will
24 get -- I think it's 500 a month.
1 Q Is that a pension?
2 A Yes.
3 Q Okay. Any other retirement accounts?
4 A No.
5 Q Any investment accounts?
6 A No.
7 Q Stocks?
8 A No.
9 Q Bonds?
10 A No.
11 Q Mutual funds?
12 A No.
13 Q CDs?
14 A No.
15 Q Do you have a safe-deposit box?
16 A Yes.
17 Q Where?
18 A Glenview State Bank. I just closed it,
19 though. There's nothing in there.
20 MR. GORDON: I want to go through here -- I
21 want to show you -- what am I on, C?
22 MS. SMITH: Yes, C.
23 MR. GORDON: I am going to mark this as
24 Exhibit C.
1 (Deposition Exhibit C was

3 BY MR. GORDON:
4 Q And that's a copy of your April 17
5 financial affidavit.
6 A Okay.
7 Q Do you recognize that?
8 A I guess so.
9 Q At the time that you signed this, this was
10 true and accurate?
11 A I believe so.
12 Q Okay. Let's go to page 6. What is an
13 American Airlines line of credit?
14 A It's a loan that I have.
15 Q Okay. We talked about that earlier?
16 A Yeah.
17 Q Okay. So we have here -- that's for family
18 expenses, and then you have a Discover card here.
19 A Yes.
20 Q Same Discover card?
21 A Yeah.
22 Q With about 17,000 worth of --
23 A It's more now, but, yeah.
24 Q Right, at the time.
1 A Yes.
2 Q Turn the page, please. At the time in your
3 Glenview State Bank checking account, you had almost
4 $28,000?
5 A Um-hum.
6 Q Correct?
7 A Yes.
8 Q How come you didn't take any of that
9 $28,000 to pay any of your credit card debt?
10 A Well, because I needed money to live off.
11 Kevin wasn't paying me, and I know I need a new car.
12 My car keeps breaking down.
13 Q So did you buy a new car with that money?
14 A No.
15 Q Okay. And same question here, it says
16 Glenview State Bank savings account. You have a
17 little over 18,000 in it. How come you didn't
18 utilize any of that money to pay down your credit
19 card or pay off a line of credit?
20 A Because I wasn't sure -- I wanted to
21 maintain money in my accounts because Kevin wasn't
22 paying me.
23 Q Explain that to me.
24 A I think I just explained it to you. I
1 stand by my answer.
2 Q So why are you accumulating debt? Why
3 accumulate debt?
5 Q Okay.
6 A Actually, I will say I was making large
7 payments, you know. I wasn't just making the
8 minimum payment. I was making large payments
9 sporadically as I could.
10 Q Do you have an account ending 8308?
11 A What's that?
12 Q I don't know. I'm asking. Do you have
13 one?
14 MR. KIPNIS: Oh, there it is.
15 A Is that my savings? I don't know.
16 MR. KIPNIS: I think that was your previous
17 checking, but I'm not here to testify.
18 A No, not anymore.
19 BY MR. GORDON:
20 Q Let's go back to the checking accounts.
21 A Because the money that I got from Paradigm,
22 I put in a separate account.
23 Q What did you receive from Paradigm Malibu?
24 A I don't remember.
1 Q Was it $40,000?
3 Q When did you receive that money?
5 Q Why did you receive that money?
6 A Because they -- we prepaid with marital
7 funds and then they -- they reimbursed me when they
8 decided they would cover -- what they would cover.
9 And I was the owner of the insurance company, so the
10 check came to me. Half that money was mine to begin
11 with because it came from marital funds.
12 Q Did you spend that money on yourself?
13 A No, I didn't. On my children.
14 Q Is that money gone?
15 A Yes, it is. I mean, we had a certain
16 lifestyle, Counsel, and --
17 Q And you deposited it into a separate
18 account. Where have you disclosed that account to
19 me?
20 A I did way back -- that account I closed
21 once the money was gone.
22 Q Where did you disclose it to me? How?
23 A My first financial affidavit, I believe.
24 It was Glenview State Bank. It was just -- yeah.
1 Q Are you the beneficiary of any trusts?

2 A I am not.
3 Q Are you expecting any inheritance?
4 A I am not.
5 Q Do you own any businesses?
6 A I do not.
7 Q Do you own a car?
8 A I do.
9 Q What kind of car?
10 A It's a piece of shit. A Honda Odyssey.
11 Q What was that?
12 MR. KIPNIS: She said it's a piece of shit,
13 Counsel.
14 A It's worth nothing.
15 BY MR. GORDON:
16 Q Okay. Is it paid in full?
17 A Yeah.
18 Q Okay. Do you have any outstanding loans
19 other than the ones we have talked about?
20 A No.
21 Q When is the last time you have borrowed
22 money?
23 A Just from my mother.
24 Q Okay. Let's go back to Paradigm Malibu.
1 A Yes.
2 Q Did you consult with Kevin when you
3 deposited the money into your own account and spent
4 it on whatever you chose to spend it on?
5 A The check was written out to me, Counsel,
6 and, yes, I did tell Kevin about it.
7 Q You did.
8 A I did.
9 Q How did you tell him?
10 A I told him to his face.
11 Q When?
12 A He knew all about it.
13 Q When?
14 A Well, I can't remember that.
15 Q How about the $57,000 refund, did you
16 consult with Kevin about how to utilize that money?
17 A I told him about it.
18 Q Did you consult with him on how to utilize
19 that money?
20 A He wasn't speaking to me, so I didn't do a
21 lot of consulting with him.
22 Q So, no, you didn't?
23 A No.
24 Q Did you ever ask Kevin to lie?
1 A Pardon me?
2 Q Did you ever ask Kevin to lie in the past
3 year?
4 A No.
5 Q Okay. Have you ever asked him to lie to
6 any of Connor's treaters?
7 A To any of Connor's treaters?
8 Q Yes.
9 A I don't know. What do you mean by that?
10 Q Have you ever said I want you to lie to one
11 of Connor's caregivers?
12 A I have never used those words.
13 MR. GORDON: Okay. I am going to show
14 you -- what letter am I on --
15 MS. SMITH: D.
16 MR. GORDON: -- what I am going to mark as
17 Exhibit D.
18 (Deposition Exhibit D was
20 BY MR. GORDON:
21 Q So see that, ma'am, there? It says
22 iMessage with 1-847-257-5811? That's your cell
23 phone number?
24 A What?
1 Q Is that your cell phone number?

2 A Yes.
3 MR. KIPNIS: He is asking if that's your
4 number.
5 A Yeah, yeah, yeah, yeah.
6 BY MR. GORDON:
7 Q Okay. And so now this is a text message
8 exchange you had with Kevin?
9 A Yes.
10 Q If you look here four paragraphs down, you
11 say: Whatever happens, do not call the police.
12 Right now thanks to Connor's positive experience at
13 Lutheran General, he has three different options for
14 residential per Jamie. That could quickly dwindle
15 to nothing. For once maybe you could listen to me.
16 I told you to lie to the emergency room doctor, but
17 instead you left. Bad idea. Now you're going to
18 pay the price.
19 What do you mean by that?
20 A Okay. So Connor -- we had taken him to
21 Rosecrance, which was a treatment facility, drug
22 treatment facility, and he -- okay. Oh, wait. So
23 he -- he took some pills that he got a hold of there
24 during the intake process, and then they had to call
1 an ambulance, and he had to go to the hospital,

2 right? I wanted Connor -- I was worried about his
3 life. I wanted him stabilized and I knew -- see, in
4 order for the insurance to cover it and for the
5 hospital to take you, you have to either be a threat
6 to yourself or others. So it's a game that
7 unfortunately parents have to play when they have a
8 very ill child --
9 Q So were you committing insurance fraud?
10 A -- like we do.
11 No.
12 Q So when you say, I told you to lie to the
13 emergency room doctor --
14 A What I meant by that -- and there was a lot
15 happening. We were all scared and stressed out.
16 And what I meant was that, you know, tell him that
17 Connor has threatened to kill himself and that he's
18 a threat to himself so -- because I wanted him to be
19 stabilized so I could find another place for him.
20 Q So is that what you mean when you say in
21 the second paragraph, Tell him you're a lawyer, and
22 if Connor kills himself, he will be subject to a
23 lawsuit?
24 A Yeah.
1 Q So are you trying to intimidate the doctor?

3 question. There's no indication that this
4 transmission is to a doctor.
5 MR. GORDON: No, no, no. That's to Kevin.
7 MR. KIPNIS: Okay. So how is she
8 intimidating the doctor?
9 MR. GORDON: By telling Kevin --
10 threatening a lawsuit.
11 A We were very --
12 MR. KIPNIS: Kevin is a big boy and does
13 whatever Kevin wants.
14 BY MR. GORDON:
15 Q Ma'am?
16 A We were under a lot of stress -- and I
17 don't really want you to call me ma'am. We were
18 under a lot of stress. We had been through hell
19 with our son. All I am trying to do is protect my
20 son and keep him alive, okay? This exchange
21 happened -- you know, I said there's heroin
22 somewhere in the house. I didn't know where it was.
23 If Connor came home, he would have ended up dead.
24 And I just wanted, you know, Kevin to handle it so
1 that we could get our son hospitalized.

2 Q So when you say, and now you're going to
3 pay the price, what does that mean?
4 A Well, he then had Connor in the car with
5 him, and then he was calling me, asking -- I mean,
6 the fact that you are using this against me is
7 really --
8 MR. KIPNIS: Let him do it. This is all
9 they have. This is nonsense. Let him do it. They
10 are going to show you to be a liar because you
11 wanted to save your kid's life.
12 THE WITNESS: Yeah. I was just trying to
13 save my son's life, Counsel. And you are lucky that
14 you have never had to walk in my shoes. So it's
15 pretty immoral for you to be using this against me.
16 MR. KIPNIS: Forget all that. Just listen
17 to the question.
18 THE WITNESS: Well, it is. It's
19 outrageous.
20 BY MR. GORDON:
21 Q You now say, Wish you would have listened
22 to me when I told you to lie.
23 This is at the end. What do you mean, why?
24 MR. KIPNIS: What do you mean this is the
1 end? Where --
2 MR. GORDON: At the very end, Wish you
3 would have listened to me when I told you to lie.
4 A Because what happened is the hospital
5 wouldn't take him. So they wouldn't take him.
6 Connor was completely out of control. Kevin was
7 then in the car driving Connor back to Chicago. We
8 didn't know where he was going to go. If he came
9 home, he'd use heroin. He would end up dead. We
10 both knew it, and I'm the one who had to figure out
11 a plan. I said take him back to Lutheran General.
12 Check him into the emergency room there. And, you
13 know, Kevin finally listened to me and did what I
14 said and --
15 Q He lied?
16 A No. I mean, he just -- lie was just
17 probably not the right word to use but to -- you
18 have to be very clear about what's at stake.
19 Q How many other times have you tried to
20 commit insurance fraud?
22 form of the question. I am also going to instruct
23 you not to answer.
1 BY MR. GORDON:
2 Q Have you tried to commit it more than just
3 this one time?
5 form of the question and instruct you not to answer.
6 MR. GORDON: Let's certify those two.
7 MR. KIPNIS: She is asserting her Fifth
8 Amendment right against self-incrimination on both
9 those two questions as well.
10 BY MR. GORDON:
11 Q You have a sister?
12 A I do.
13 Q What is her name?
14 A Kathy.
15 Q Does she ever give you any money?
16 A No.
17 Q Has she in the last two years?
18 A No.
19 Q Has she loaned you any money?
20 A No.
21 Q Does your mother give her any money?
22 A No.
23 Q How do you know that?
24 A I talk to my sister often.
1 Q In the last three years, have you lent

2 anybody any money?
3 A No.
4 Q Does anybody currently owe you any money?
5 A Just some freelance projects that are --
6 Q The ones we talked about?
7 A -- outstanding. Yeah.
8 Q Let's talk about the bitcoins.
9 A Please do.
10 Q You had answered a request of mine saying
11 that you had Connor purchase bitcoins.
12 A Connor purchased bitcoins, that is correct.
13 Q Why did Connor purchase bitcoins?
14 A At first I thought he was being
15 entrepreneurial. And he's a smart kid, and he was
16 using his money, birthday money and so on, savings,
17 to buy bitcoin. He was making money on it but -- so
18 that's why.
19 Q What was he really doing with it?
20 A I found out later he was using the money to
21 buy drugs.
22 Q And did you put a stop to it?
23 A Yes. I forbid him from using my account
24 but he -- you know, it's hard to control a drug
1 addict, and he had access to my account.

2 Q How?
3 A He knew the account number and, you know --
4 Q Other than what we talked about, do you
5 have any other debts?
6 A No.
7 Q Are you dating anybody?
8 A No.
9 Q In the past two years, have you dated
10 anybody?
11 A Yes.
12 Q Okay. Who have you dated?
13 A An actor. His name is Will.
14 Q What is his last name?
15 A Kinnear.
16 Q Spell it.
17 A K-i-n-n-e-a-r.
18 Q Any relation?
19 A No.
20 Q How did you meet him?
21 A Tinder.
22 Q Okay. How long did you date him?
23 A I don't know.
24 Q I didn't mean to you. I meant to Greg
1 Kinnear.
2 MR. KIPNIS: I figured it out.
3 A A year and a half.
4 MR. KIPNIS: I'm down on my TMZ.
5 BY MR. GORDON:
6 Q When did you break up with him, or when did
7 the relationship end, I should say?
8 A September.
9 Q Okay. And anybody else?
10 A No.
11 Q Did you give him any money?
12 A No.
13 Q Did he give you any money?
14 A No.
15 Q Did he take you out on dates?
16 A Yeah.
17 Q When you would go out on dates, who paid?
18 A Him always.
19 Q Always.
20 A He's rich.
21 MR. KIPNIS: He didn't ask you about his --
22 BY MR. GORDON:
23 Q What does "rich" mean?
24 A He's rich.
1 MR. KIPNIS: It's over. It doesn't matter.

2 BY MR. GORDON:
3 Q What's that? What does "rich" mean?
4 A Like a billionaire.
5 Q But he's an actor?
6 A Yeah. His family, family money.
7 MR. KIPNIS: Brother Greg.
8 BY MR. GORDON:
9 Q Did you go to Zurich last year?
10 A With my daughter, yes.
11 Q Okay. And how long were you in
12 Switzerland?
13 A We were in Switzerland two days, and then
14 we went to Italy.
15 Q Okay. How long did you travel?
16 A Two weeks.
17 Q Who paid for that trip?
18 A I did.
19 Q How did you pay for it?
20 A Airbnb.
21 Q The Airbnb money paid for it?
22 A Yeah.
23 Q How much did you spend?
24 A Not much because we flew for free on my
1 passes, and then hotels at that time were cheap.

3 A Like Paris was a hundred a night.
5 A I don't know exactly, but basically Airbnb
6 paid for it.
7 Q Great. In the past two years, have you
8 taken -- you said you went to Los Angeles. Any
9 other times to California?
10 A I took my daughter to see her brother in
11 Utah in November, and then I took her in December
12 and then after -- in December after Utah, we went to
13 LA for the weekend.
14 Q Other than the hair treatment we talked
15 about, have you had any other cosmetic procedures in
16 the past three years?
17 A Botox. I have been getting it for my whole
18 marriage.
19 Q How often do you get Botox?
20 A Once or twice a year.
21 Q How much do you spend on Botox?
22 A 200, 300, something like that.
23 Q Even during the time that Kevin is not
24 paying support?
1 A Yeah. I cut way down, you know, but --

2 Q But you are still getting it?
3 A Yeah.
4 Q Okay. When was your marriage over?
5 A September of 2012.
6 Q Why do you say that?
7 A Kevin and I were going to an event,
8 cocktail party for the parents of eighth graders at
9 St. Francis, and right before we were about to
10 leave, he said, I don't love you anymore, and I want
11 a divorce.
12 Q But you didn't file till 2015?
13 A Right. We went to counseling and tried all
14 these other things, yeah.
15 Q So after he said that, you went to
16 counseling and tried other things. What are the
17 other things?
18 A We went to this thing called Retrouvaille
19 through the Catholic church, yeah. My --
20 MR. KIPNIS: I'm sorry, what is that
21 called?
22 THE WITNESS: Retrouvaille.
23 BY MR. GORDON:
24 Q Okay. So then was it not over until you
1 filed for divorce?

2 A What do you mean?
3 Q Like when did you decide it was time to
4 file?
5 A When I found out that Kevin had been
6 sending our money to a woman in the Philippines,
7 that was the last straw for me.
8 Q When was that?
9 A It was sometime in 2015.
10 Q How much money did Kevin send to this
11 woman?
12 A I don't know actually.
13 Q How did you find out?
14 A He told me. I saw some papers written down
15 in his office about pesos, which is the Philippine
16 money, currency.
17 Q You've had three attorneys in this
18 litigation?
19 A Correct.
20 Q What is the total amount of fees you have
21 paid them, all three?
22 A No idea.
23 Q No idea. Other than Mr. Kipnis, do you owe
24 them any money, the other two any money?
1 A I do not.
2 Q Do you owe any experts any money?
3 A I do not.
4 Q Okay. And, again, you don't know how much
5 you owe Mr. Kipnis?
6 A I do not.
7 MR. GORDON: Bob, you will get me that
8 number?
9 MR. KIPNIS: Um-hum.
10 MR. GORDON: Is that a yes, Mr. Kipnis?
11 MR. KIPNIS: In response to a relevant
12 petition, yes, but I don't know what the number is.
13 BY MR. GORDON:
14 Q Who is Edgar Martinez?
15 A He is the guy that did the work on the
16 roof.
17 Q On what roof?
18 A Of Golf Terrace. I'm pretty sure that's
19 him, yeah, yeah.
20 Q Who is Dave Rampersad?
21 A He is the guy that did work on our -- on
22 Medill when I lived there and Kevin lived there.
23 He --
24 Q In the '90s?
1 A Um-hum.
2 MR. KIPNIS: That's a yes?
3 THE WITNESS: Yes.
4 BY MR. GORDON:
5 Q Who is Robin D. Williams?
6 A What?
7 Q Who is Robin D. Williams?
8 MR. KIPNIS: These are like all
9 celebrities.
10 A Is this like a witness list or something?
11 BY MR. GORDON:
12 Q Yes.
13 A I think that was a handwriting expert that
14 we're not using.
15 Q Okay. Who is Peter Donahue?
16 A That is the husband of one of my friends.
17 Q Were you dating him?
18 A No.
19 Q Is anybody holding any money for you?
20 A No.
21 Q Does your attorney have any money in
22 escrow?
23 A Yes.
24 MR. KIPNIS: So the answer to his previous
1 question is yes, my attorney.

2 A Yes.
3 BY MR. GORDON:
4 Q And what is your attorney holding?
5 A The Dayton funds, what is left of it --
6 Q Anything else?
7 A -- after you snatched it.
8 Q After what?
9 A After you snatched 30,000 of it.
10 Q Who snatched 30,000 of it?
11 A You.
12 MR. KIPNIS: Do you see how you prompt
13 questions?
14 BY MR. GORDON:
15 Q What do you mean I snatched it?
16 MR. KIPNIS: It's 27467761.
17 BY MR. GORDON:
18 Q What do you mean I snatched it?
19 A You and Gina and everybody else. It must
20 be nice to be able to just reach into someone's bank
21 account and take money.
22 Q Do you believe the lawyers should be paid
23 in this case?
24 A Do you really want me to answer that?
1 Q I do.
2 A I'm going to have to say I'm not sure.
3 Q Okay. I have heard some rumblings that you
4 don't care for Kevin's brother.
5 A What's the question?
6 Q Do you care for Kevin's brother?
7 MR. KIPNIS: Who cares? Why are we talking
8 about Kevin's brother?
9 BY MR. GORDON:
10 Q Do you like Kevin's brother?
11 A I don't like the things that he's done.
12 Q What has he done?
13 A He has forged Kevin's signature on a line
14 of credit and took the money without Kevin's
15 permission, and we didn't know about it. And he
16 stopped making payments on the loan, and the bank
17 called in all of Kevin's loans. I was served
18 personally at my house the day before Thanksgiving
19 in 2009, and all of our funds were frozen. And
20 Kevin's brother would not return phone calls or own
21 up to anything that he did.
22 Q Did you ever report him to the police?
23 A I wanted to, but Kevin hired an attorney to
24 go after him, and the attorney said he would
1 probably go to jail for this. Kevin's family paid

2 off Bridgeview Bank and then stopped speaking to me.
3 So --
4 Q Other than this divorce, are you involved
5 in any lawsuits?
6 A No.
7 Q Were you ever involved in a slander or
8 defamation lawsuit?
9 A Not actually a lawsuit, no.
10 Q What?
11 A It never became a lawsuit.
12 Q But there was an issue?
13 A There was an issue, yes.
14 Q What was the issue?
15 A I wrote a review about my former employer
16 on glassdoor.com, which since then, hundreds of
17 employees have written bad reviews about him, and he
18 tried to sue me for slander.
19 Q Who was the employer?
20 A JWC Media.
21 Q And what did you write?
22 A The truth.
23 Q Which was?
24 A That he's a fraud. He doesn't pay people,
1 stuff like that.

2 Q And when did you leave that job?
3 A That was in 2012.
4 Q What job was that?
5 A I was editor of a magazine.
6 Q How much were you making?
7 A Forty-five, I think, when I left.
8 Q 45,000 a year?
9 A Yeah.
10 Q Benefits?
11 A None.
12 Q Okay. Do you have any potential claims
13 against anybody right now?
14 A No.
15 Q Did you ever put Nair in Kevin's shampoo?
16 A No.
17 Q Any similar product to that?
18 A No.
19 MR. KIPNIS: He has better hair than we do.
20 MR. GORDON: That's not a far cry.
21 Give me two minutes.
23 (Discussion off the record.)
24 MR. GORDON: Okay. We are done for the
1 day. You want to explain signature?

2 MR. KIPNIS: Yes. We will reserve it.
3
4 (Witness excused.)
5
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22
23
24

) SS.
3 IN THE CIRCUIT COURT OF COOK COUNTY
COUNTY DEPARTMENT - DOMESTIC RELATIONS DIVISION
4
IN RE THE MARRIAGE OF: )
5 )
KERRIN KENNEDY, )
6 )
Petitioner, ) No. 15 D 11137
7 )
and )
8 )
KEVIN MUDD, )
9 )
Respondent. )
10
11 I, KERRIN KENNEDY, being first duly sworn,

12 on oath say that I am the deponent in the aforesaid
13 deposition taken on February 6, 2018; that I have
14 read the foregoing transcript of my deposition,
15 consisting of pages 1 through 130 inclusive, and
16 affix my signature to same.
17
Corrections have been submitted
18 No corrections have been
submitted
19
20 KERRIN KENNEDY, Deponent

21 Subscribed and sworn to
before me this day of
22 , 20__
23
Notary Public
24

) SS.
3 I, SUZANNE THALJI, CSR and Notary Public in
4 and for the County of Cook and State of Illinois, do
5 hereby certify that on February 6, 2018, at
6 2:23 p.m., at 30 North LaSalle Street, Suite 3100,
7 Chicago, Illinois, the deponent KERRIN KENNEDY
8 personally appeared before me.
9 I further certify that the said KERRIN
10 KENNEDY was by me first duly sworn to testify and
11 that the foregoing is a true record of the testimony
12 given by the witness.
13 I further certify that the deposition
14 terminated at 4:41 p.m.
15 I further certify that I am not counsel for
16 nor related to any of the parties herein, nor am I
17 interested in the outcome hereof.
18 In witness whereof, I have hereunto set my
19 hand and seal of office this 12th day of February,
20 2018.
21
22 Notary Public
23
24 CSR No. 084-002337 - Expiration Date: May 31, 2019

February 19, 2018
ATTN: Robert Kipnis

Grund & Leavitt
Date Taken: February 6, 2018

Case Name: Kerrin Kennedy v. Kevin Mudd
Deponent: Kerrin Kennedy
Dear Robert Kipnis,
Please make arrangements for the deponent to read his or her transcript. If there are any transcription
errors, please have the deponent note them on the enclosed errata sheet.
When this process has been completed, the deponent must sign the signature page and each errata sheet
at the bottom, and his/her signature must be notarized. Please make a copy for your own records and
send a copy to my office and all respective counsel.
As provided by Rule 207(A) of the Supreme Court Rules, as amended, if after 28 days the deponent has
not read and signed the deposition transcript, it will be understood that the signature is waived and the
transcript may be used as though signed.
Sincerely,
Stephanie Silva
Bridges Court Reporting
10 S. LaSalle St., Ste. 1950
Chicago, IL 60603
(312) 332-6345
CC: Mitchell B. Gordon

ERRATA SHEET
PAGE LINE SHOULD BE:___________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
REASON:______________________________________________________________
SIGNATURE: ____________________________________________________

Kerrie Kennedy, Will Kinnear

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Kerrie Kennedy, Will Kinnear

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Kerrin Kennedy Kerrin Kennedy v.

13 The deposition of KERRIN KENNEDY, called by

Bridges Court Reporting Page: 1

Bridges Court Reporting Page: 2

15 Note: Exhibits not tendered for inclusion

Bridges Court Reporting Page: 3

1 Q And how long have you lived there?

1 Q Do you have any idea?

1 that. You manage the care for your son Connor,

1 went directly to Utah, and I set everything up

1 find -- the place where he's at, he cannot stay

1 THE WITNESS: It's hard for me to -- like I

1 thread. So you were talking about a waiver?

1 A That is a question I can't answer, and I

1 A Three hours a day at least.

1 to his home psychiatrist, Dr. Raden, who I have been

1 Q How did you calculate that average?

1 Q How long are the calls?

1 A A couple of months. So March -- yeah, two

1 to borrow the money from my mother to pay for --

1 you ask your mother for money to pay that retainer?

1 anything you speak to your therapist about.

1 Q You rent out your house as a bed and

1 Q I am talking about the bed and breakfast.

1 Q So you started a business?

1 A It's all on my Glenview State Bank account,

1 A More times than I can count.

1 A Quite a bit because I have to --

1 know. I couldn't even tell you. I don't know how

1 Q What are you working on right now?

1 colleagues and trying to, you know, work people that

1 Q I want to know what you are doing to look

1 Q When was this?

1 something comes up and they think of you so --

1 Q Has it been optioned?

1 THE WITNESS: Yes. It's kind of hard for

1 A And the taking care of my son obviously

1 to move into a direction that's more lucrative.

1 then it keeps it straight.

1 A How many hours a week?

1 haven't been paid for some of the work that I did

1 Q Okay. So that time is -- they don't need

1 Q You signed the affidavit ten minutes ago.

1 A I've paid some of the gas bills. I believe

1 have to supply a lot of things for the Airbnb

1 right now. Sorry.

1 A What is your question, Counsel?

1 dining out, and hobbies?

1 out of the escrow account to pay it without my

1 MR. KIPNIS: Written a check for tuition?

1 pay for Connor's hospitalization at University of

1 work, and I found insurance plans for both of my

1 A And then the other -- I have copies of

1 A It's too upsetting.

1 I said, Well, you can't do that. He goes, I'll just

1 say that? Do you see?

1 Is that the same person? Take a break. Do you want

1 They look like they're at a zoo with silly hats on.

1 Q How do you know it was $300,000?

1 to even touch them and afraid for my son's

1 the guns, I thought what is happening here? It just

1 MR. KIPNIS: Kevin?

1 it's hard to find and then --

1 THE WITNESS: Yeah.