1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 2 FOR THE COUNTY OF LOS ANGELES CERTIFIED 3 COPY 4 5 ALEXANDER BURTON; MARK RYAN; and 6 MICHAEL E., a minor, by and through 7 his Guardian ad Litem, BONNIE MOUND,) Case No. Plaintiffs, 8 LC 053 103 9 vs. 10 ) 11 12 MARC COLLINS-RECTOR; CHAD SHACKLEY; 13 BROCK PIERQE; DIGITAL ENTERTAINMENT 14 NETWORK, INC.; et al., ) ) Defendants. 15 16 17 18 19 DEPOSITION OF MICHAEL EGAN 20 TAKEN ON 21 Monday, November 24, 2003 22 23 24 Reported by: 25 Susan B. Sautman C.S.R. No. 4770 1 LegaLink - Los Angeles 800-826-0277 818-986-5270 Fax 818-783-7310 <=ii'3"~---::::;:::> www.legalink.com 1 DEPOSITION OF MICHAEL EGAN, taken on behalf of . ~ ~ . 2 the Defendant Brock Pierce at 2450 Colorado Avenue, 3 suite 400E, Santa Monica, ·california, on Monday, 4. November 24, 2003 1 at.i:24'p,m., before Susan B. 5 Sautman, Certified Shorthand Reporter No. 4770, pursuant 6 to Notice. 7 8 APPEARANCES: 9 ~0 FOR THE PLAINTIFFS: ~ 11 DANIEL J. CHEREN, ESQ. 12 1"6055 Ventura Boulevard 13 Suite 525 14 Encino, California 15 . (818) 990-7700 91436 17 18 FOR THE DEFENDANT BROCK PIERCE: 19 GREENBERG TRAUR,IG 20 BY: 21 2450 Colorado Avenue 2-2 suite 400E 23 Santa Monica, California 24 (310) 586-7700 GREGORY D. TRIMARCHE, ESQ. 9040.4 25 2 800-826-0277 LegaLink - Los Angeles 818-986-5270 Fax 818-783-7310 www.legalink.com ' ~~-----~~--- INDEX 1 2 3 WITNESS EXAMINATION PAGE 4 MICHAEL EGAN (By Mr. Trimarche) 4, 79 (By . Mr. Cheren) 78 5 6 7 8 9 PAGE DEFENDANTS• EXHIBITS 10 (None) .11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 LegaLink - Los Angeles 800-826-0277 818-986-5270 Fax 818-783-7310 www.legalink.com ' Q.. 1 2 We're talking about sometime in early 2000 when everybody moved to Florida? 3 A. Correct. 4 Q. Didlllll 5 A. They went down to Florida right away; they came move down there with them essentially? 6 back and forth a couple of times. 7 and then the next time they wouldn't let 8 the house at M&C by himself. 9 have no decision but to go back down to wherever it was 10 in Florida. Q. 11 12 Went down to Florida IIIII stay in They pretty much let him I think it was Miami Beach, South Beach. Do you know if - w e n t to the·caribbean with them at all? 13 A. I don't know. 14 Q. Did you ever take any trips with them? 15 A. Yes. 16 Q. Where to? 17 A. Las Vegas, Lake Havasu. 18 Q. Anything outside the continental U.S.? 19 A. Never had any trips outside the continental 20 u.s., several trips. no. 21 Q. Do you know i f - did? 22 A. Yes, I know he did. 23 Q. Where do you know that he went? 24 A. From what I recollect, I believe he went to 25 Hawaii, went to -- 43 800-826-0277 LegaLink - Los Angeles Fax 818-783-7310 818-986-5270 --............ ::::::::::::> u~-- www.legalink.com .• ' MR. CHEREN: 1 2 United States. 3 BY MR. TRIMARCHE: 4 5 6 That is technically part of the I am talking about continental U.S. right now Q. so include Hawaii, Alaska, Caribbean. A. Hawaii. Mexico~ I don't remember. 7 they had a trip for one of their birthdays. 8 was'Chad's birthday in San Martin. I know I think it I can't remember if 9 - w a s a part of it. 10 11· 12 Do you have any idea why - Q. went on those · trips and you didn't? A. Pretty much if we would go on a smaller trip to 13 maybe like Lake Havasu or Las Vegas I still had to go 14 and get the approval of my mom, still had to get her 15 approval which on certain times I was so out of my mind 16 that I would just -- they would make me leave and my mom 17 would think I disappeared for three days, two days. 18 trip that I ever asked to go anywhere within any far 19 amount of distance to Mexico, any of those my mo~ would 20 say no and pretty much lock the door and not let me go. Any 21 Q. This was before she knew what was going on? 22 A. She didn't want me going anywhere outside the 23 24 25 United States, really. So when Shackley, Pierce, and Collins-Rector Q. moved to Florida at the beginning of 2000, they didn't 44 LegaLink - Los Angeles 800-826-0277 818-986-5270 ! I 5 Fax 818-783-7310 'btr"'!::r'----:::;:::>- www.legalink.com 1 I, SUSAN B. SAUTMAN, Certified Shorthand 2 Reporter, in and for the State of California, ·do hereby. 3 certify: -4 Tbat prior to being examined, MICHAEL EGAN, the 5 witness named in the foregoing deposition, was by me 6 duly affirmed to tes.tify the truth, the whole truth, and 7 nothing but the truth. 8 9 That said deposition was then taken before me pursuant to Notice, at the time a~d place herein set 10 forth, that the testimony and proceedings were reported 11 . s~;:enog·raphically. by me and later transcribed into 12 typewriting via computer-aided tr~scription under my 13 direction. 14 I further certify that I am neither counsel 15 for,·nor related to, any party to said action, nor in 16 anywise interested in the outcome thereof. 17 18 IN WITNESS WHEREOF, I have subscribed my name this 2nd d~y of December, 2003. 19 20 21 22 23 Susan B. Sautman, CSR No. 4770 24 25 84 800-826-0277 LegaLink - Los Angeles Fax 818-783-7310 818~986-5270 :::::::;:> www.legalink.com '