V I R G I N I A: IN THE CIRCUIT COURT FOR THE COUNTY OF FAIRFAX AMERICO FINANCIAL LIFE AND ) ANNUITY INSURANCE COMPANY, ) Plaintiff, ) vs. ) ABID A. AWAN, et al, ) Defendants. Case No.:CL-2017-05488 ) Thursday, October 4, 2017 Fairfax, Virginia Deposition of SAMINA ASHRAF GILANI a Defendant, called for examination by counsel on behalf of the Defendant Abid Awan, pursuant to notice, in the law offices of ALLRED, BACON, HALFHILL & YOUNG, P.C, 11350 Random Hills Road, Suite 700, Fairfax, Virginia, beginning at approximately 10:00 o'clock a.m., before Courtney Sebastian, a Verbatim Reporter and Notary Public in and for the Commonwealth of Virginia at large, when there were present on behalf of the respective parties: Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 2 APPEARANCES: On Behalf of the Defendant Abid A. Awan: JAMES T. BACON, ESQUIRE and MATTHEW WILLIAMS, ESQUIRE ALLRED, BACON, HALFHILL & YOUNG, P.C. 11350 RANDOM HILLS ROAD Suite 700 Fairfax, Virginia 22030 (703)353-1300 On Behalf of the Defendant Samina Gilani: MICHAEL HADEED, JR., ESQUIRE HADEED LAW GROUP 510 King Street Suite 400 Alexandria, Virginia 22314 (703) 967-7452 On Behalf of the Plaintiff: (No appearance.) Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 3 * * * * * C O N T E N T S EXAMINATION BY: WITNESS SAMINA ASHRAF GILANI MR. BACON: MR. HADEED: 4 ---- * * * * * E X H I B I T S MARKED FOR IDENTIFICATION AWAN EXHIBIT NUMBER 1 9 AWAN EXHIBIT NUMBER 2 63 AWAN EXHIBIT NUMBER 3 108 AWAN EXHIBIT NUMBER 4 109 AWAN EXHIBIT NUMBER 5 110 AWAN EXHIBIT NUMBER 6 111 AWAN EXHIBIT NUMBER 7 112 AWAN EXHIBIT NUMBER 8 113 AWAN EXHIBIT NUMBER 9 116 AWAN EXHIBIT NUMBER 10 117 AWAN EXHIBIT NUMBER 11 122 AWAN EXHIBIT NUMBER 12 123 AWAN EXHIBIT NUMBER 13 125 (All exhibits retained by Mr. Bacon, copies provided to Mr. Hadeed at time of deposition.) Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 4 1 2 P R O C E E D I N G S (Whereupon, the interpreter was duly sworn by the 3 notary public.) 4 Whereupon, 5 SAMINA ASHRAF GILANI 6 a witness, was called for examination by counsel for 7 the Commonwealth, and, after being duly sworn by the 8 Court, was examined and testified as follows: 9 EXAMINATION ON BEHALF OF THE PLAINTIFF 10 11 12 BY MR. BACON: Q Okay. Good morning. will be asking you questions today. 13 INTERPRETER: 14 MR. BACON: 15 INTERPRETER: 16 MR. BACON: 17 INTERPRETER: 18 MR. BACON: 19 pads. Okay. I need a pad. Oh, you need a pad? Yes, please. I got another one. Here. Oh, thank you so much. There you go. So we have extra So we're good? 20 INTERPRETER: 21 MR. BACON: 22 My name is Jim Bacon. Yes. Did you tell her that I'll be asking her questions today under oath? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 I 5 1 THE WITNESS: 2 MR. BACON: 3 And she understands what an oath is, is that right? 4 INTERPRETER: 5 BY MR. BACON: 6 7 Okay. Q Yes. That means that you're swearing to tell the truth under penalty of perjury. 8 A Okay. 9 Q So if you don't tell the truth, you could be 10 held responsible for that. 11 A Okay. 12 Q If you don't understand any of my questions at 13 any time, please ask me to clarify. 14 A Okay. 15 Q Otherwise, I will assume you do understand 16 each of my questions and are answering truthfully and 17 to the best of your ability. 18 A Okay. 19 Q If you need to take a break at any time, 20 please let us know. 21 A Okay. 22 Q And the other word of advice I would offer is Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 6 1 given that we have an interpreter, I will try not to 2 ask a question while you or the interpreter are 3 talking, if you would also try not to answer when the 4 interpreter or I are asking you a question. 5 A Okay. 6 Q Oftentimes we engage in conversation and don't 7 realize that we talk over each other, and it is 8 difficult for our court reporter to take everybody's 9 words down. 10 A Okay. 11 Q Lastly, is there any medication that you are 12 on that could affect your ability to accurately testify 13 and tell the truth here today? 14 A No, nothing like that. 15 Q Okay. So there's no reason why you are not 16 able to testify under oath to the best of your ability 17 today, correct? 18 A Okay. 19 Q Let's start first with your full name. 20 A Samina Ashraf Gilani. 21 Q Can you spell that? 22 A Samina, S-a-m-i-n-a, Ashraf, A-s-h-r-a-f, Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Gllani, Geleleaenel. Okay. Are you known by any allases or A Mona, Meoenea. Okay. What's your Social Security number? A --. Do you speak A No. Have you ever spoken English? A No, never. when you speak with your lawyer, do you speak ln A No. I'm uSlng someone else to speak on my behalf. Okay. who do you use? A My frlend. What's your frlend's name? A Razia. Reaezelea. where does she 77 R3213. What's her last name? A Sultana. seueleteaenea. Vcrlaalinl Reporting, LLC 5684 General le Centreville, v.1 211120 703 932 (1654- 8 1 Q Okay. 2 A She lives on Canyon Drive. 3 Q In what city? 4 A Alexandria. 5 Q Does she live close to you? 6 A Yes. 7 Q Okay. 8 A Yes. 9 Q Okay. 10 A I can just write it down. 11 Q Please write it down so that the interpreter 12 Where does she live? Do you live in the same complex? What's your address? can put it on the record for us. 13 A It's not coming in my mind right now. 14 Q Do you have a driver's license? 15 A No, I don't drive. 16 Q Do you have any information in your purse that 17 18 would help you recall where you live? A 19 20 21 22 Okay. I will check. Here's my address. (Pause.) Samina Gilani, 6834 Canyon Drive, Alexandria, Virginia 22307. Q Great. MR. BACON: This will be my first exhibit. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 9 1 (Whereupon, a document was marked 2 Awan Exhibit Number 1 for 3 identification.) 4 BY MR. BACON: 5 Q 6 excuse me. 7 8 Ma'am, I'm showing you Plaintiff's Exhibit -- MR. BACON: Let's say Awan Exhibit Number 1, and we'll use that Awan designation throughout. 9 BY MR. BACON: 10 Q Have you seen Awan Exhibit Number 1 before, 11 ma'am? 12 A Yes. 13 Q Okay. 14 A This document, it says when we came from Yes, I've seen that. What is it? 15 Pakistan we went to hospital and then these change. 16 When my husband came from Pakistan, he was not feeling 17 well. 18 changed beneficiary and ownership. Then he went to the hospital. 19 Q Who typed Exhibit Number 1? 20 A My cousin. 21 Q What's your cousin's name? 22 A Syed Ahmed. Then it was Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 10 1 2 Q How do you spell your cousin's name? S-y-e-d, last name A-h-m-e-d? 3 A Yes. 4 Q Okay. 5 woman? 6 A He. 7 Q Okay. 8 A He doesn't live here. 9 Q He lives in Canada? 10 Is it Is that a she or a he? A man or a Where does he live? He's in Canada. So he prepared this Exhibit Number 1, is that right? 11 A Yes. 12 Q You told him all of the words here and he made A When we came back from Pakistan, the date and 13 14 I told him and he made it. it? 15 when we went to the hospital, date, and when these 16 things happen. 17 Q Okay. That's not my question. My question is 18 did you tell him everything that is identified in 19 Exhibit Number 1? 20 A Yes. 21 Q Okay. 22 A I don't remember the date. When did you do that? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 11 1 Q Okay. Did you do that in person? 2 A Yes. 3 Q Where did you do that in person? 4 A In Canada. 5 Q You went to Canada? 6 A Yes. 7 Q When did you go to Canada? 8 A End of January. 9 Q End of January 2017? 10 A Yes, start of 2017. 11 Q Okay. 12 A End of January 2017. 13 Q Okay. 14 A After his death, two week after his death. 15 Q Two weeks after your husband's death? 16 A Yes. 17 Q Your husband's name is? 18 A Mohammad Shah. It's the beginning of 2017? 19 INTERPRETER: 20 BY MR. BACON: S-h-a-h. 21 Q And did you fly or did you drive to Canada? 22 A Fly. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 12 1 Q And who paid for the plane ticket? 2 A My cousin. 3 Q Your cousin, Mr. Ahmed? 4 A Yes. 5 Q Okay. 6 7 8 Why were you going to Canada, to prepare this Exhibit 1? A I was feeling so lonely. I was in tension, so that's why I went to see my cousin. 9 Q Okay. And how long were you there in Canada? 10 A Two weeks. 11 Q And how was it decided that your cousin -- 12 A Two or three or maybe four weeks. 13 Q Okay. Well, this is dated February the 9th. 14 So were you in Canada on February the 9th, 2017, when 15 Exhibit 1 was prepared? 16 A Yes. 17 Q Okay. 18 Whose decision was it to type up Exhibit Number 1? 19 A Mine. 20 Q Why did you want to type Exhibit Number 1? 21 A Because I found out the insurance my husband 22 purchase, Mr. Abid Awan took that insurance. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 13 1 2 Q Okay. So you found out Mr. Abid Awan got the insurance your husband had taken out, is that correct? 3 A That was under my name. 4 Q How do you know it was under your name? 5 A Because I was a beneficiary. 6 He told me about that. 7 Q He told you about that? 8 A Yes. 9 Q Did you ever see any documentation about that? 10 A They took those documents. 11 Q No, that's not my question. 12 My question is did you, ma'am, -- 13 A Yes. 14 Q -- ever see -- you sound like you can 15 understand me, but maybe I'm mistaken. 16 Did you ever see any written documentation 17 that you were the beneficiary of your husband's life 18 insurance? 19 A Yes. 20 Q Okay. 21 22 And were you able to read it and understand it? A Yes. I could read my name and some other Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 14 1 stuff. 2 Q 3 What did you read in English and understand in English at the time that you read it? 4 A My husband told me -- 5 Q I'm not asking what your husband told you. 6 I'm asking what you read in English and understood in 7 English regarding your name and anything else related 8 thereto. 9 10 A There was name insurance and also they asked me to sign that paper. 11 Q Who asked you? 12 A When they prepare the insurance, then they 13 14 asked me to sign. Q As I understand your testimony, you don't read 15 English, so you would not know what any of that 16 information said in writing, correct? 17 18 19 A What do you mean by that? Could you please rephrase? Q Because you don't speak English, you did not 20 understand any of the words on the paperwork that you 21 signed, correct? 22 MR. HADEED: I'm going to object to that. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 15 1 Hold on a second. 2 your question? 3 4 5 Objection. Reading and -- what was Because you don't speak English? BY MR. BACON: Q Because you don't speak English, you can't understand the words on that paper, isn't that right? 6 MR. HADEED: Well, she testified earlier she 7 saw her name and she saw the word insurance. 8 what she understood. 9 MR. BACON: 10 11 That's Okay. MR. HADEED: And that was her testimony earlier. 12 MR. BACON: I know. 13 now, but I'm not deposing you. 14 MR. HADEED: And that's your testimony So please. All right. All right. Go ahead. 15 16 17 INTERPRETER: question? 18 19 Could you please repeat your BY MR. BACON: Q Isn't it true, ma'am, that other than the word 20 insurance, which is an English word, that you are now 21 saying under oath you can read, you did not understand 22 or read any of the other words on the document that you Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 16 1 said your husband asked you to sign? 2 A My husband told me -- 3 Q I don't want to know what your husband told 4 you. Please answer my question. 5 about what your husband said. 6 Do you understand? 7 MR. BACON: 8 Did she understand what I just asked her? 9 10 My question was not INTERPRETER: Would you repeat -- she keeps saying that my husband told me. 11 MR. BACON: I know. And I want to try to make 12 it as clear as possible to her that I am not, 13 underscore not, asking her about what her husband said. 14 I don't want an answer about that at this time. 15 want is an answer to my question. 16 THE WITNESS: What I I'm telling you my answer is I 17 just signed, and I just saw the paper that these are 18 insurance paper. 19 20 BY MR. BACON: Q Okay. That's what I wanted to make clear. 21 all you saw was that this was an insurance paper and 22 you did not understand it, correct? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 So 17 1 A No. 2 Q So you understood what was written in English. 3 4 5 6 7 I understood what was written there. Is that what you're telling me now under oath? A All I can understand these are the paper for insurance, but I don't know what is that there. Q Okay. So you did not understand the words that you saw, correct? 8 A Some words I understood. 9 Q Some English words you understood? 10 A Yes. 11 Q Okay. 12 13 Do you understand English words on Exhibit Number 1? A (Reading in broken English.) "During his 14 visit Pakistan, Pakistan (speaking foreign language) in 15 sick Pakistan. 16 and got admit in a hospital or (speaking foreign 17 language) in October due to his health condition. 18 Health condition (speaking foreign language) he was 19 brought back to U.S.A. and was take to local hospital." Pakistan (speaking foreign language) 20 21 22 INTERPRETER: Okay. She translate correctly. During his visit in Pakistan, he got sick and he was -- Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 18 1 2 BY MR. BACON: Q Okay. So what's the answer to my question? 3 Yes, you understand the words, the English words, on 4 Exhibit Number 1 or no, you do not? 5 A Yes, I understand. 6 Q Okay. So you do understand English and you do 7 understand the words on Exhibit Number 1, isn't that 8 right? 9 A Yes. 10 Q And Exhibit Number 1 has a signature on it, on 11 the first page and on each page after that, right? 12 you see that? 13 A Yes. 14 Q Okay. 15 A Yes. 16 Q So you understood English and you read 17 18 19 20 English. A Do That's your signature, isn't it? Is that what you're telling me under oath? I used to not understand, but now I understand little better. Q Did this understanding just happen today or 21 when did you first learn and understand how to read and 22 speak English? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 19 1 2 3 4 A Before I couldn't understand, but now I'm reading and I can see the meanings. Q Okay. So do you understand English when I talk to you in English? 5 A No. 6 Q But you can read English, is that what you're 7 telling me? 8 A Yes. 9 Q Okay. 10 When someone talk, no. and can read that in English? 11 A Yes. 12 Q Okay. 13 And so you understand Exhibit Number 1 I'm going to get back to that in a minute, but let me just get some quick background. 14 Did you come to the U.S. in about 2009? 15 A Is it written here? 16 Q My question is did you come to the United 17 States of America in 2009 with your husband, Mr. Shah? 18 A No, in 2010. 19 Q 2010, okay. 20 And when you came to America with your husband Mr. Shah in 2010, did you have a job? 21 A No. 22 Q Am I correct that you have not had a job since Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 20 1 you've been in the United States since 2010, correct? 2 A No, I never. 3 Q Okay. 4 No, you never had a job and you currently do not have a job, is that right? 5 A No, I don't have job. 6 Q You are not working? 7 A No. 8 Q And when you came with your husband in 2010 to 9 America, he was not working, was he? 10 A No, he was not. 11 Q Okay. 12 came to the United States, isn't that correct? 13 A No. 14 Q Okay. 15 He was receiving disability at that time. So he never had a job while he was in the United States? 16 A Me? 17 Q Him. 18 So neither of you had a job when you He never had a job in the United States when he came here, correct? 19 A Yes. 20 Q And you say he was on disability? 21 A Yes. 22 Q Who was paying him disability? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 21 1 A I don't know about that. 2 Q Okay. So you're saying he was on disability, 3 but you have no information he was on disability, isn't 4 that correct? 5 A No. 6 Q No, it's correct or no, it isn't correct? 7 A I don't know about that. 8 Q Okay. 9 disability or he didn't have disability, isn't that 10 right? 11 A 12 about that. 13 Q 14 So you have no idea whether he had He had disability, but how much I don't know Okay. was disabled. So when you say he had a disability, he Is that what you're saying? 15 A No, he was not disabled. 16 Q Okay. 17 18 So he had some disability money coming from somewhere? A When he was working, he hurt his knee 19 somewhere, and he told me that he's receiving money for 20 that. 21 Q Okay. But that was in Pakistan, wasn't it? 22 A No, here. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 22 1 Q Okay. You told me just a few minutes ago 2 under oath swearing that he was not working and was not 3 working in the United States when he came. 4 correct? 5 6 MR. HADEED: MR. BACON: 8 MR. HADEED: didn't work. 10 11 That's a mischaracterization of her answer. 7 9 I'm going to object. Am I Okay. In 2010, her testimony was they He didn't work and she didn't work. THE WITNESS: I told you because since he hurt himself so he was taking disability. 12 BY MR. BACON: 13 Q Where did he hurt himself? 14 A On his knee. 15 Q What country was he living in? 16 A Here. 17 Q Where did he hurt his knee? 18 A I don't know about that, but he told me that 19 he hurt himself. 20 married. 21 Q Okay. 22 A 2008. Because he hurt himself before we got And when did you get married? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 23 1 Q In the United States? 2 A No, in Pakistan. 3 Q Okay. 4 So before 2008, were you and your husband living in Pakistan? 5 A No. 6 Q And did you come with him? 7 A Yes. 8 Q Okay. 9 10 11 He went there and then we came back. From the time that you got married with your husband, did your husband ever have a job in the United States before he died? A He never work after wedding, after our 12 marriage, but he put an extra basement on rent. 13 place we was living, the basement and a small portion 14 of that house was on rent. Okay. The 15 Q Who owned the house that you were 16 living in? 17 A His name. 18 Q Are you saying that your husband owned the 19 house that you were living in in the United States when 20 you came here after you were married? 21 A Yes. 22 Q Okay. He told me the house is mine. And you're saying that he rented part Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 24 1 of the house? 2 A Yes, basement and annex or small portion. 3 Q Okay. 4 A Ever since I came to U.S. 5 Q So that would be 2010, 2011? 6 A Yes. 7 Q 2012? 8 A Yes. 9 Q 2013? 10 A (Nodding head.) 11 Q 2014? 12 A (Nodding head.) 13 Q I didn't hear her answer. 14 A Yes. 15 Q 2015? 16 A Yes. 17 Q And 2016? 18 A Yes. 19 Q Until he passed away? 20 A Yes. 21 Q Okay. 22 For what years? Now, did you both file tax returns here in the United States for all of those years you rented? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 25 1 A Yes, we did. 2 Q And did you report that rental income on your 3 taxes? 4 A I don't know about that. 5 Q Okay. 6 A I will check and then find out. 7 Q Now, isn't it a fact that when you and your Do you have your tax returns? 8 husband came to the United States, you were given 9 support by your husband's sons? 10 A 11 phone. 12 Q No. They never even picked up their father's Okay. So they didn't pay any plane tickets 13 for you to Pakistan? 14 oath? 15 16 17 Is that what you're saying under A I don't know about that, but they were always Q Wait a minute. -Ma'am, you just swore under 18 oath that the sons of your husband paid nothing 19 including a phone, not even a phone. 20 the truth from you to the best of your ability. 21 22 So I need to know My question is are you swearing here under oath that your husband's sons did not support you and Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 26 1 your husband when you arrived here together in the 2 United States from 2010 forward? 3 4 A I don't know about that, what kind of help they were doing. 5 Q So you're not swearing that you have 6 information that proves that they did not support you, 7 you're saying you just don't know, isn't that right? 8 A Yes. 9 Q Okay. I don't know. Let's go back to Exhibit Number 1. In 10 the first paragraph, which I understand you can read in 11 English, there is a sentence that says, "Between 12 12/31/16 and 01/16/17, I was completely denied by 13 Mr. Ashraf's children to visit him in the hospital." 14 Do you see that? 15 INTERPRETER: 16 MR. BACON: 17 BY MR. BACON: 19 Q All right. Well, if you can read it in English, then my question is do you see it? 21 22 Well, I thought she said she could read it under oath. 18 20 Would you like to translate? A Completely -- I was completely denied by. Yes. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 27 1 2 3 4 5 Q Okay. So my question is who completely denied you visitation with your husband in the hospital? A Every time I was calling, since I couldn't drive, they were not picking up my phone. Q Okay. Ma'am, isn't it an absolute fact that 6 in early January of 2017, you visited your husband at 7 the hospital in Reston? 8 A I went with someone else. 9 Q So you did visit your husband in the hospital 10 in early January of 2017, correct? 11 first few days of January '17. Early January, the 12 A No, I did not go in January. 13 Q Did you go in December? 14 A Yes, I went in December. 15 Q Okay. And you're telling me here under oath, 16 and the nurses there will confirm, you're saying that 17 you were never there at the hospital in January of 2017 18 visiting your husband, is that correct? 19 20 THE INTERPRETER: question? 21 22 Could you please repeat the Because she want me to translate. BY MR. BACON: Q Are you telling me under oath here today that Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 28 1 you never went to Reston Hospital in January of 2017 to 2 visit your husband? 3 A Yes. 4 Q Okay. 5 I didn't go in January. Do you know when your husband was admitted to Reston Hospital? 6 A No, I don't. 7 Q All right. Let's go to the second paragraph 8 of Exhibit Number 1, which I understand you read 9 English. So I'm going to ask you about that portion of 10 the second paragraph that says, and I'm quoting, 11 "During Mr. Ashraf's illness while he was admitted to 12 the hospital, my telephone conversations were taped." 13 Do you see that? 14 A Yes. 15 Q Okay. 16 When you say Mr. Ashraf, that's your husband? 17 A Yes. 18 Q Who's Mr. Shah? 19 A That's also -- he has -- that's his second 20 21 22 name. Q Mohammad Ashraf Shah. Okay. So we're talking about your husband when we see the word Mr. Ashraf, and we're talking Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 29 1 about your husband when we see the word Mr. Shah? 2 A Yes. 3 Q Okay. 4 5 So why do you claim that your telephone conversations were taped? A Because when I was going to the hospital and 6 when he was asking who came today at that time, the 7 children were listening to my conversation. 8 9 10 Q They were listening to your conversation with your husband? A My husband or anyone else. When I went to see 11 him, he told me they are listening to your 12 conversation. 13 Q Oh, he told you? 14 A Yes. 15 Q But you didn't put that in Exhibit Number 1, 16 did you? 17 A Yes. 18 Q Okay. There's some stuff missing. So the only reason why you're saying in 19 Exhibit Number 1 that your conversations were taped was 20 because you claim your husband told you your 21 conversations were taped, correct? 22 A Yes. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 30 1 2 Q And that was what you solemnly stated under oath pursuant to Exhibit Number 9, isn't that right? 3 A Yes. 4 Q You also state in that same second paragraph 5 some other recording devices were also 6 installed/planted in your house. Do you see that? 7 A Installed in my home. 8 Q Yes, you see that? 9 A Yes. 10 Q Why did you swear to that in Exhibit Number 1? 11 A What are you trying to ask? 12 Q You swore in Exhibit Number 1 that some other 13 recording devices were also installed and planted in 14 your house. 15 that? And my question is why did you swear to 16 A 17 found out. 18 Usually daughter call at that time. 19 Q Because at any time I have some visitor, they And they usually call, they have to call. Okay. Is there any other reason you can give 20 me for why you swore to that language other than what 21 you've just told me? 22 A No, no other reason. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 31 1 Q Okay. So there's no other reason other than 2 what you just said for why you swore that recording 3 devices were also installed and planted in your home, 4 correct? 5 A Yes, only reason. They always find out. 6 Q Okay. Again in the same paragraph All right. 7 of Exhibit Number 1, which children of Mr. Ashraf 8 directed you not to go out or visit him without their 9 permission? 10 11 12 13 A His daughter. She told me you can only come with us, not with anybody else. Q Okay. Is that anybody else or just the daughter? 14 A No, no one else. 15 Q What's the daughter's name? 16 A Adeela Awan. 17 Q Spell it. 18 A A-d-double e-l-a, Awan. 19 Q So Mr. Awan who's seated here with me, he 20 21 22 never said that, did he? A No. up my phone. But every time I called, he never picked He always tell me he was busy. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 32 1 Q Okay. Now, did you tell anybody that 2 Mr. Awan, who's seated here with me, told you that you 3 were not to see your husband at the hospital? 4 A Is it written on this paper? 5 Q No, I'm asking a simple question. Did you 6 tell anybody else that Mr. Awan said, "You cannot go to 7 the hospital without our permission?" 8 A No. 9 Q Okay. 10 A No. 11 Q Have you ever spoken to any reporters? 12 A No. 13 Q You've never spoken to any reporters that do You didn't tell this to any reporters? 14 any media reporting? 15 under oath? 16 A No. 17 Q Have you ever asked anybody to speak on your 18 Is that what you're telling me behalf to any reporters that report in the media? 19 A No. 20 Q Has anybody spoken on your behalf to any 21 reporters that report in the media, whether newspaper, 22 online, or anything like that? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 33 1 A Maybe someone. 2 Q Who? 3 A I don't know who's that. 4 Q Do you know whether it's a man or a woman? 5 A No. 6 Q Did the reporter talk to you? 7 A No. 8 Q Did he talk to your friends? 9 A (Shaking head.) 10 Q Then why do you think that there's a reporter 11 involved? 12 A I don't think so. 13 Q Have you heard from a reporter at the Daily 14 Caller? 15 A Never. 16 Q Have you heard of a guy named Luke, and I'll 17 spell the last name, R-o-z-i-a-k? 18 19 INTERPRETER: please spell one more time? 20 21 22 Just the last name, could you MR. BACON: R-o-z-i-a-k. That's the last name. THE WITNESS: No. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 34 1 2 BY MR. BACON: Q Okay. Have you ever spoken with anybody that 3 works for the government about the Awan brothers or any 4 problems you had at the hospital? 5 A No. 6 Q Well, you did speak with somebody at the 7 government. 8 government, right? You called the police. They're a 9 A No -- 10 Q You're swearing to me you didn't call the 11 police? 12 A That was in his life, when he was live. 13 Q I'm not asking about his life. 14 I'm asking a very simple question about what you did. 15 Are you telling me that you have never 16 contacted anybody working for the government regarding 17 the Awan brothers? 18 A No. 19 Q No. 20 A No. 21 Q Okay. 22 Okay. Including the police? Now, Exhibit 1 specifically swears on your behalf that you contacted the police, doesn't it? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 35 1 MR. HADEED: 2 characterization. 3 second. Swears? I'm going to object to the The question is -- now, hold on a This is not sworn to. 4 MR. BACON: 5 MR. HADEED: 6 BY MR. BACON: 7 8 9 Q It says solemnly states. Solemnly states -- You solemnly stated that you contacted the police, isn't that correct, in Exhibit 1? A Yes. That happened when he was alive. 10 they were not taking me to see him. 11 January -- 12 Q Okay. And Because on 6 So contrary to your previous sworn 13 testimony here today, you're now saying that you did 14 communicate with government people, including the 15 police as referenced in Exhibit Number 1, isn't that 16 right? 17 A I called only on 6 January. And only on 18 January 6th because I wanted to see my husband at that 19 time. 20 police. 21 domestic matter, so she left. 22 Q Mr. Abid came. He's the one who spoke to the And she said this is -- since this is your Okay. Now, in Exhibit Number 1, with respect Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 36 1 to that, you claim in the third paragraph down, "I 2 called the police to find out the whereabouts of my 3 husband since I was completely blacked out." 4 So you are solemnly affirming and stating in 5 Exhibit Number 1 that you didn't know where your 6 husband was and that's why you called the police, 7 right? 8 A 9 Yes. I called on 6 January since I didn't see my husband for a long period of time and they were not 10 picking up my phone. 11 police. 12 Q Okay. So that's why I called the But the statement that you were 13 completely blacked out about your husband is not true. 14 You knew where your husband was when you called, isn't 15 that right? 16 A Completely blacked out. 17 Q You were not completely blacked out, were you? 18 A When I called the police, I didn't know at 19 that time. 20 Q 21 22 You did know because you said when you called, it was between December 31 and January 16, 2017, right? A (No response.) Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 37 1 Q Right? 2 A (No response.) 3 Q That's when you say you were blacked out and 4 5 6 7 you didn't know where your husband was. A I don't understand. Correct? Could you please rephrase your question? Q Okay. You have solemnly stated in Exhibit 8 Number 1 that sometime between 12/31/2016 and 9 January 16, 2017 you called the local police to find 10 out where your husband was since you were completely 11 blacked out and didn't know where he was. 12 A Yes. 13 Q But you did know where he was, didn't you? 14 A No, I did not. 15 Q Look at your first paragraph. You say 16 solemnly, "Between December 31, 2016 and January 16, 17 2017, I was completely denied by Mr. Ashraf's children 18 to visit him." 19 20 Where? "In the hospital." You knew he was in the hospital. 21 A (No response.) 22 Q Ma'am, can you answer the question? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 You knew 38 1 he was in the hospital even though you called the 2 police and said you were completely blacked out and 3 didn't know where he was, didn't you? 4 A When this document was prepared, he died like 5 two, three weeks ago. 6 time. 7 8 9 10 11 Q So I was very disturbed at that So you were so disturbed that this document has a lot of inaccurate statements in it, right? A No. Everything is right. Could you please again ask me the question? Q Okay. So which statement is not true? The 12 statement that you were completely denied by the 13 children to visit him in the hospital during the 14 December 31 to January 16 period, or the statement that 15 between December 31 to January 16 you were completely 16 blacked out and didn't know where he was? 17 18 19 Which one was the untruth? A In the third statement, I didn't know what hospital he was. 20 Q Oh, okay. 21 A What hospital? 22 So that explains it all, right? What's the name of the hospital? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 39 1 Q Okay. Let's go back to your conversations 2 with government officials. You first denied that you 3 had any, and then you admit that you called the police. 4 You have denied, if I'm not mistaken, and you 5 correct me if I'm wrong, you have denied having any 6 conversations directly or indirectly with any 7 reporters, is that right? 8 9 10 A Maybe someone else did, but I never talked to any reporter. Q Okay. And you don't know the name Luke 11 Rosiak? And I'll spell the last name because I think I 12 might have misspelled it previously. 13 R-o-s-i-a-k. You've never had him see you or meet with you 14 or meet with anybody on your behalf; is that what 15 you're saying here under oath today? 16 A 17 Never. MR. HADEED: I would like to have the record 18 reflect, Jim, if I could that this gentleman Rosiak was 19 apparently at the hearing we had in Fairfax, and he 20 followed us out of the courthouse. 21 was with us. 22 accurate. To that extent, he I want to just make sure the record is Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 40 1 2 MR. BACON: Well, I know you want to testify and try to help her, but -- 3 MR. HADEED: 4 MR. BACON: No, I'm not trying to help her. How in the world did what you just 5 say -- how is that appropriate? 6 MR. HADEED: 7 mean by conference or meeting. 8 MR. BACON: 9 She reads English. She may not understand what you I think she has an interpreter. There's a lot of issues here. 10 MR. HADEED: 11 MR. BACON: 12 BY MR. BACON: 13 Q that you spoke with. 15 with. 17 Okay. Okay? So let me get back to government officials 14 16 It's absolutely not. Or that you're denying you spoke Let me ask it this way. Did you speak with any FBI agents regarding the Awan brothers? 18 A Yes. 19 Q Okay. 20 A It's been a long time. 21 Q What year? 22 A This year, March or April. When? I don't remember. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 41 1 2 Q Okay. March or -- hold on. Let's get this as clear as we can lay it out. 3 You are swearing under oath today that during 4 the time period of March 2017 through April 2017, in 5 that time frame roughly, you met with FBI agents, is 6 that correct? 7 A Yes. 8 Q Okay. 9 A Yes. 10 Q Did you speak with them after that? 11 A No. 12 Q So you've only spoken with FBI agents one 13 Was that the first time? time? 14 A Yes, one. 15 Q Okay. 16 them? And how many days did you speak with Was it one day? 17 A Only one day. 18 Q Okay. 19 A One hour. 20 Q What were the names of the agents that you 21 spoke with? 22 A How many hours? No, no names. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 42 1 Q How many agents were there? 2 A Only one. 3 Q What was his name? 4 A I don't know his name. 5 Q Okay. 6 A Where I live. 7 Q Okay. 8 A Yes. 9 Q Okay. Where did you meet? They came to your house? Separate from the FBI, did you ever 10 meet with any Capitol Police regarding the Awan 11 brothers? 12 A No. 13 Q What did you talk about with the FBI when they 14 15 16 17 18 19 20 came to your house? A They were asking something. I told them I don't know about anything. Q Whoa, whoa, whoa, whoa. What were they asking specifically as you recall? MR. HADEED: I'm just going to object based on relevance. 21 But you have to answer. 22 MR. BACON: Well, I'm trying to understand Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 43 1 what she was -- 2 MR. HADEED: 3 MR. BACON: Sure. -- who she was calling regarding 4 the Awan brothers including insurance issues. 5 she wanted the FBI to investigate. 6 MR. HADEED: 7 MR. BACON: 8 MR. HADEED: 9 MR. BACON: 10 I don't know. Maybe I want to know. Go ahead. It's all relevant. I don't know anything about it. All right. Let's do it. BY MR. BACON: 11 Q So what did they want to know? 12 A They wanted to know about the money, where did 13 they send that. 14 that. And I told them I don't know about 15 Q What money? 16 A No, no. 17 Q The life insurance? 18 A No, no, no. 19 Q What money are you talking about? 20 A They asked me, wanted to know the money, where 21 22 The life insurance proceeds? are they sending. Q Where are they sending money. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Who is they? 44 1 2 3 4 A Imran and -- it's been a long time. talking about Imran and everyone else. Q All right. Hold up. Did they ask questions about Imran Awan? 5 A Yes. 6 Q Okay. 7 They were And you're telling me that the questions they asked were about where he sent money? 8 A Yes. 9 Q You mean in the United States or overseas or 10 what? 11 A Overseas. 12 Q Where overseas? 13 A It's not in my mind. 14 Q Did they show you any papers? 15 A No. 16 Q Okay. 17 So they didn't show you anything, no papers, is that right? 18 A No, they did not show me any papers. 19 Q Other than asking where Imran sent money 20 overseas, did they ask any other questions about Imran? 21 A No, nothing else. 22 Q Okay. Did they ask any questions about Hina? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 45 1 Hina Awan? 2 A Yes, they asked but I told them I don't know. 3 Q What questions did they ask about her? 4 A They asked me where is she at that time. 5 Q At what time? 6 A When they came to my house. 7 Q They wanted to know where Hina was in March of 8 9 10 2017? A Yes. They asked whether she's in Pakistan or here. 11 Q Okay. 12 A I told them I don't know. 13 Q What other questions did they ask about Hina? 14 A Nothing else. 15 Q Did they ask any questions about Mr. Awan 16 What did you tell them? who's here next to me? Abid? 17 A Yes. How long he's working here. 18 Q How long he's working where? 19 A Where he works. 20 Q Where he works? 21 works? 22 A Did they ask where Hina Did they ask where Imran works? Oh, they didn't ask where they're working, Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 46 1 just how long they're working there. How long. 2 Q Working where? 3 A Wherever they're working. 4 Q Capitol Hill? 5 A Yes. 6 Q Did they ask anything about any of their 7 financial affairs? 8 A Yes, they asked but I said I don't know. 9 Q Do you know anything about Imran's financial 10 affairs? 11 A No, I don't. 12 Q Do you know anything about Hina's financial 13 affairs? 14 A No. 15 Q Do you know anything about Mr. Awan's, Abid 16 Awan's, financial affairs? 17 A No. 18 Q Do you know anything about any money that any 19 of these individuals I just named might have sent 20 overseas? 21 A No. 22 Q Did you ever claim to know anything about any Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 47 1 of their financial affairs? 2 A No. 3 Q Did you ever complain to the FBI that Mr. Awan 4 somehow fraudulently obtained this insurance money that 5 you're complaining about? 6 A Yes. 7 Q Okay. 8 9 I told them about what they did with me. So what did you tell the FBI that they, who they is, did with you about the insurance money? A Yes. I told them it was under my name, but 10 when he went to the hospital, they changed the 11 ownership and beneficiary. 12 13 Q What did they say? What did the FBI say about that? 14 A Nothing. 15 Q Why not? 16 A (No response.) 17 Q Did they believe you? 18 A I don't know. 19 Q So you told them all about how you were I just told them. 20 fraudulently bilked out of this money for the life 21 insurance and how they did bad to you and the FBI did 22 nothing? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 48 1 2 3 A They just said they did not do good to you. It's not good. Q Okay. Did you ever say to the FBI or Capitol 4 Police or anybody, "If you help me get this money, I 5 will help you, and I'll try to do what I can to say 6 things that will help you." 7 A No. 8 Q Did you ever testify anywhere about any of the 9 Awan brothers? 10 A No. 11 Q Did you ever file any documents like Exhibit 12 Number 1 that are declarations, or solemn statements, 13 or affidavits for the FBI or anybody? 14 A No. 15 Q Did the FBI or any Capitol Police or any 16 government official ever ask you to sign any papers? 17 A No. 18 Q Do you know what a grand jury is? 19 A No. 20 Q Did you ever testify in court about the Awan 21 22 brothers anywhere? A No. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 49 1 Q Did you ever testify in any rooms before 2 anybody about the Awan brothers or your insurance claim 3 or anything about the financial affairs of the Awan 4 brothers or families? 5 A No. 6 Q Do you know somebody by the name of George 7 Will? 8 A No. 9 Q Okay. 10 Let me just ask you, do you know anybody by the name of Mr. Webb? 11 A No. 12 Q Okay. I'm going to ask you a little bit about 13 your education background. 14 around. 15 16 I'm kind of shifting Could you tell me your formal education after high school, if any? 17 A I have a bachelor degree from Pakistan. 18 Q In what area? 19 A Islamic studies. 20 Q Islamic studies? 21 22 Do you have any other degrees? A No. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 50 1 Q Do you have any medical degrees? 2 A No. 3 Q Do you have any psychology degrees? 4 A No. 5 Q Any psychiatry degrees? 6 A No. 7 Q Do you have any formal education in dementia? 8 A No. 9 Q Do you have any formal education in psychosis? 10 A No. 11 Q Do you have any formal education in brain 12 science? 13 A No. 14 Q Do you have any opinion on these topics with 15 respect to this case? 16 A What case? 17 Q This case here that you're involved in now. 18 A Yes. 19 20 21 22 About this I know the insurance my husband took, and it was changed in the hospital. Q Okay. I understand that. Everybody knows that. My question is do you have some opinion as to Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 51 1 your husband's state of mind at the hospital when he 2 changed the insurance information? 3 A I'm not sure whether I was going there or not. 4 Q Okay. So what facts are you relying upon to 5 say that Mr. Awan here, seated to my left, defrauded 6 you out of the insurance proceeds? 7 8 A Because it was under my name for last seven, eight years. 9 Q Okay. Anything else? 10 A No, I don't know. 11 Q Okay. What facts are you relying upon to 12 claim that your husband had undue influence put upon 13 him by Mr. Awan? 14 A 15 ownership. 16 Q 17 18 Because when it came, he wrote change of Okay. Just because there was a change of ownership, is that right? A Yes. Beneficiary was changed and also he 19 died on 16th, and they claim on 17th to get that 20 insurance. 21 Q 22 Okay. But is there any other facts you're relying upon that Mr. Awan, seated here today, unduly Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 52 1 influenced his father into changing the beneficiary 2 designation and owner? 3 A Maybe he has done, that's why he changed. 4 Q Maybe he has what? 5 A Maybe he pressurized him. 6 Q Maybe? 7 8 MR. BACON: other than maybe? 9 10 (The interpreter spoke to the witness in a foreign language.) 11 12 Does she have any information THE WITNESS: Since he was not feeling well, he pressurized him to change. 13 BY MR. BACON: 14 Q How do you know that if you weren't there? 15 A So how did it change? 16 MR. BACON: Well, I'm asking her. She's the 17 one making the claim. 18 than what she already gave me that it was changed? 19 20 (The interpreter spoke to the witness in a foreign language.) 21 22 So does she have any facts other THE WITNESS: You can see the paper in front of you. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 53 1 2 BY MR. BACON: Q Okay. But other than the fact that there was 3 a change in ownership and a change in designation, are 4 you able to give me, ma'am, any other facts to support 5 your claim that we've been discussing? 6 A Here's the evidence that you can see. 7 Q The change? 8 A Yes. 9 Q Okay. So because there was a change in 10 ownership and because there was a change in 11 designation, that means that it was done fraudulently, 12 right? 13 A Yes. 14 Q Okay. 15 And that also means that it was done by undue influence because there were those changes? 16 A Yes. 17 Q Okay. We know according to your testimony 18 that because there were changes in ownership and 19 because there were changes in designation necessarily, 20 that meant it was done fraudulently and with undue 21 influence by Mr. Awan. 22 Do I have that clear? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 54 1 A Yes. 2 Q Okay. 3 4 I just wanted to make sure. Let's go back to Exhibit 1 that you have in front of you. 5 MR. HADEED: 6 MR. BACON: 7 MR. HADEED: 8 MR. BACON: 9 Thank you. Mine says nine. I marked it one. Oh, you did? If you have a nine, I want you to put one on it, please. 10 MR. HADEED: 11 MR. BACON: 12 want any more water? Okay. No problem. Oh, yeah, help yourself. 13 INTERPRETER: 14 MR. BACON: Do you No, I'm good. Okay. So we'll take a few minute 15 break in a little bit if you want so you can get some 16 refreshments or if you want to get food or whatever. 17 Because we'll be here for weeks, no doubt. 18 19 20 21 22 Does she know that we're going to be here for weeks? Make sure you tell her that. (The interpreter spoke to the witness in a foreign language.) THE WITNESS: What do you mean by weeks? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 55 1 2 BY MR. BACON: Q Okay. Let me ask you to go to the second page 3 of Exhibit Number 1. 4 make clear, all of these pages, you've initialed and 5 signed. 6 right? 7 A Yes. 8 Q Okay. 9 10 Just so I'm clear, and I want to And the last page you signed your full name, So on page two about halfway down you state solemnly that Mr. Shadid, S-h-a-h-i-d -- did I say that right? 11 INTERPRETER: 12 BY MR. BACON: 13 Q Shahid. "Shahid Imran Awan demanded me to sign a power 14 of attorney for my Pakistani matters." 15 that? Do you see 16 A Yes. 17 Q What were your Pakistani matters that are 18 19 referred to in there? A The property he has in Pakistan, Mr. Shahid 20 told me to give him the power of attorney for that 21 property. 22 Q Okay. So it's not your property, it's his Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 56 1 property. Is that what you're saying? 2 A Yes, his property. 3 Q Okay. 4 I'm confused. So when you say my Pakistani matters, you're talking about his, Mr. Shahid's property? 5 A My husband's property. 6 Q And so if I understand, you then left Pakistan 7 with your sister's help, is that right? 8 A Where is I left Pakistan? 9 Q Okay. "I was going to sign, but then I 10 decided to leave my house and requested my sisters to 11 arrange my departure from that location." 12 A That's -- we are talking about Canada. 13 Q Okay. 14 So you left Pakistan and you went to Canada? 15 A No. 16 Q You left here and went to Canada? 17 A Yes, from here to Canada -- 18 Q All right. 19 I have that clear. All right. And then at the very bottom of page two, the 20 last sentence, "There are many people who have this 21 knowledge that my phone conversations were taped and my 22 conversations inside my house were being listened." Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 57 1 2 Do you see that on page two of Exhibit 1 that you solemnly stated? 3 A Yes. 4 Q All right. So who are the many people who 5 have the knowledge that your phone conversations were 6 taped? 7 8 INTERPRETER: She said the people who was visiting me at that time. 9 10 Let me get a notepad because there's so many. BY MR. BACON: Q Well, who are all these many, many people that 11 have knowledge that your phone conversations were taped 12 that you solemnly stated to in Exhibit Number 1? 13 A (Not translated.) 14 Q That's not true, is it? 15 16 INTERPRETER: She said the names are not in my mind at this time. 17 BY MR. BACON: 18 Q Okay. That's a false statement, isn't it? 19 A Okay. That's fine. 20 Q It's also not true and false where you say on 21 that same page at the bottom, "My conversations inside 22 my house were listened." That's a false statement too, Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 58 1 isn't it? 2 A Yes, that was listened. 3 Q Who listened? 4 A Children. 5 Q Children? 6 A Shahid Imran. 7 Q Okay. 8 Your conversations in your house were being listened to? 9 A Yes. 10 Q Okay. 11 A I'm talking about Shahid Imran. 12 Q Oh, he was listening? 13 14 15 By who? Children? How was he listening? Through a secret machine or something? A He has connected my phone, my house phone with his own phone. 16 Q How did he do that? 17 A I don't know. 18 Q How do you know if he did that if you don't 19 20 21 22 know that he did it? A Because what I was talking about, later on he was telling me that you said this. Q Oh, so he knew some of what you were talking Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 59 1 about so that automatically meant he must have been 2 secretly listening to your conversations in the house, 3 is that right? 4 A No, they were listening to my conversations. 5 Q How? 6 A I don't know how, but they were. 7 Q Okay. So can you tell me any information you 8 can rely upon to help me understand why you believe 9 they were secretly listening to your conversations? 10 11 12 A Whenever I talked to someone in Pakistan, he told me later on that you told this, you said this. 13 Q Okay. 14 A Yes. 15 Q Okay. And that's the only reason? Let's go to the next page. This is the 16 third page of Exhibit Number 1, second sentence in the 17 second paragraph. 18 with "there is." 19 quoting, "There is a whole lot to tell which I can't 20 put in one email." 21 22 It's just one sentence beginning You see that where it says, and I'm Do you see that? A Yes. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 60 1 Q Okay. So my question is what else is there to 2 tell that you couldn't put into this one particular 3 email? 4 A All these things like -- things like this, 5 when did you say this, when did you say that. 6 Something like that what they're talking about. 7 8 Q Okay. You sent this email, Exhibit Number 1, to the insurance company, didn't you? 9 A Yes. 10 Q Okay. So did you ever have a subsequent 11 conversation with the insurance company to give them 12 all of the whole lot that you wanted to tell them that 13 you couldn't put in this one email? 14 A No, never. 15 Q Did they ever call you or contact you and say, 16 "We really would like to know about this whole lot of 17 other information that you have about this fraud and 18 this undue influence. 19 please explain it to us?" It's really juicy. Can you 20 A No. 21 Q Other than this Exhibit Number 1, did you send 22 any other follow-up emails or communications with the Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 61 1 insurance company to help them understand why there was 2 this fraud by Mr. Awan and the undue influence by 3 Mr. Awan as you've outlined it here today for us? 4 A No. 5 Q No? 6 A What? 7 Q What happened after this email was sent with 8 9 10 11 So what happened? all these claims you've asserted solemnly? A The insurance told me since there's two claimers, so court will decide. Q All right. Let me ask you again going down 12 again that third page, last paragraph, just so I have 13 an understanding. 14 Are you telling me that your husband in the 15 last paragraph, third line down, as per Mr. Ashraf, 16 your husband told you that his son Shahid Imran Awan 17 took your husband's money fraudulently by signing legal 18 documents with phony/fake signatures pretending to be 19 your husband? Is that what your husband told you? 20 A Yes. 21 Q Ah. 22 A About 2011-12. When did he tell you that? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 62 1 Q 2011 and '12. And did your husband ever do 2 anything to get all of the money back that was taken by 3 phony/fake signatures? 4 5 6 7 A I don't know about that, but he told me about this. Q Okay. Did he ever show you any documents that had phony or fake signatures on them? 8 A Yes, he showed me. 9 Q What did he show you? 10 A He showed me a paper that you can see that 11 12 13 there's a signature. Q Okay. Now, does any of that have anything to do with the insurance money in this case? 14 A No. 15 Q Does any of that have to do with Mr. Awan 16 who's here seated with me today? 17 A No. 18 Q Then why did you send it to the insurance 19 company in which Mr. Awan was involved when it had 20 nothing whatsoever to do with that issue? 21 A 22 and -- He told me Shahid signed the paper, the check Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 63 1 Q No, that's not my question. My question is 2 if, as you've just stated under oath, none of that has 3 anything whatsoever to do with this matter involving 4 you and Mr. Awan, why did you send those kinds of 5 statements to the insurance company? 6 A (No response.) 7 Q Why did you do it? 8 A So they could find out they have done 9 10 something like fraud like this before. Q Oh, so you were trying to make Mr. Awan, who's 11 seated with me, look bad to the insurance company, 12 weren't you? 13 A Yes. 14 Q Of course. 15 MR. BACON: 16 This is number two. (Whereupon, a document was marked 17 Awan Exhibit Number 2 for 18 identification.) 19 20 BY MR. BACON: Q Before I leave number one, let me go to the 21 last page of number one. Your last sentence says you 22 authorize that your cousin, that's your cousin Syed Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 64 1 Ahmed, to be your legal advisor to deal with all your 2 legal matters. 3 Do you see that? 4 A Yes. 5 Q Is he still your legal advisor? 6 A No. 7 Q Okay. 8 Now I'm here. What's his telephone number so I can talk to him? 9 A I don't have phone number. 10 Q You don't have a phone number for him? 11 calls you. 12 A I have at home, not here. 13 Q Okay. 14 A Yes. 15 Q It's in your purse, isn't it? 16 He Do you have a cell phone? THE INTERPRETER: Oh, this phone doesn't have 17 card that does the long distance, so she use land line. 18 Oh, the phone doesn't -- oh, I'm sorry. 19 don't have card so it's not working. 20 21 22 This phone BY MR. BACON: Q Now, did you ever tell any police officers or government officials that the Awan brothers were paying Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 65 1 the police officers? 2 INTERPRETER: 3 MR. BACON: 4 BY MR. BACON: 5 6 Q Anybody. And that they had a cousin whose name was Police Officer Ashar (ph) Awan? 7 MR. AWAN: 8 BY MR. BACON: 9 10 FBI? Q Aser. Aser Awan. Since they were paying him, the police were on their side? 11 A No. 12 Q You never said anything like that? 13 A No, I never said that. 14 Q You didn't tell anybody that? 15 A (Shaking head.) 16 Q Are you positive? 17 A Yes. 18 Q All right. Let me show you Exhibit Number 2. 19 Do you know what Exhibit 2 is? Have you ever seen it 20 before, since you read English but don't speak it? 21 A This is Americo's life insurance. 22 Q Have you seen this before? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 66 1 A Yes, this paper came to my house. 2 Q Oh, it did come to your house? 3 A Yes. 4 Q When? 5 A I don't remember the date. 6 Q What kind of paper is this? 7 Is this your husband's or was this your husband's insurance policy? 8 A Similar to that. 9 Q Well, do you know whether this is a copy of 10 your husband's insurance policy? 11 A I don't know about that. 12 Q Okay. Will you agree with me that the owner 13 of this policy can assign this policy to whoever he 14 wants? 15 16 MR. HADEED: Objection. The policy speaks for itself. 17 BY MR. BACON: 18 Q Go ahead. 19 A (No response.) 20 Q Do you see that? 21 THE INTERPRETER: 22 MR. BACON: (Unintelligible.) No, no. I'm just asking a Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 67 1 question. 2 3 4 BY MR. BACON: Q Will you agree with me that the policy may be assigned by the owner to whoever he wants? 5 A No. 6 Q You say no. Let me ask you -- go to 7 page eleven of Exhibit 2. 8 you to read since you read English but don't speak it. 9 About almost halfway down there's a heading called 10 Assignment of Policy. 11 There's a section I'd like Assignment of Policy, bold. Do you see that? Do you see where it says, 12 this policy may be assigned? 13 true, isn't it? 14 that right? 15 A (No response.) 16 Q Do you agree with that or do you disagree with 17 18 19 20 21 22 Do you see that? This policy may be assigned. That's Isn't that? A When if somebody assigned already, why they going to assign someone else? Q That's not my -- you can't ask me questions, I'm deposing you. So you have to answer the question. Will you agree with me or will you not agree Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 68 1 with me that this Exhibit 2 may be assigned pursuant to 2 that reference I just showed you? 3 4 5 A If someone is assigned already, so you can not reassign. Q Will you agree with me that at page eleven 6 under the assignment of policy of Exhibit Number 2 that 7 the assignment shall take effect on the date the notice 8 is signed by the owner, in that case your husband? 9 A (No response.) 10 Q Will you agree with me that that's the way 11 this works? 12 INTERPRETER: 13 BY MR. BACON: 14 Q Could you please repeat? Will you agree with me that with respect to 15 this insurance policy, which is Exhibit Number 2, that 16 the assignment takes effect on the date the notice of 17 assignment is signed by the owner? 18 A Yeah, they can. The assignment should take 19 date notice of assignment is signed. 20 by that? 21 22 Q What do you mean I'm just asking whether you'll agree that this language is the language of your husband's policy. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Can 69 1 we agree on that? 2 MR. HADEED: We can stipulate if this is a 3 true and complete copy of the policy, that this policy 4 speaks the words it says. 5 6 MR. BACON: Well, she seems to think otherwise, Counsel, so I'm going to ask her. 7 MR. HADEED: 8 THE WITNESS: The policy speaks for itself. 9 this while he was sick. 10 BY MR. BACON: 11 Q Okay. If that's the case, he signed I understand that. A lot of people -- 12 I've signed a lot of things when I'm sick. 13 today. 14 sick, and I'm still going. I got sick about two hours ago and I've been 15 16 17 18 19 Okay? So that doesn't affect -- sickness doesn't affect it, does it? A He should have done that when he was feeling all okay. Q Okay. 20 policy. 21 is that right? 22 I'm sick A So that's your understanding of the You can't sign anything unless you feel good, If something belong to someone, it should -- Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 70 1 MR. BACON: No, no, no, no. 2 about what she just said previously. 3 focus on my question. 4 let me know. 5 paperwork when he was not sick. 6 7 We're asking Please ask her to If she doesn't understand it, But she said he should have signed BY MR. BACON: Q So my question is are you saying that anytime 8 someone signs paperwork when they're sick and not in 9 good health it's not valid? 10 A Yes. 11 Q Okay. 12 And that's why you claim that there was fraud and undue influence in this case, right? 13 A Yes. 14 Q Okay. So even though your husband knew what 15 he was doing, the fact that he was sick makes what he 16 did invalid, correct? 17 MR. HADEED: 18 The policy speaks for itself. 19 20 Objection. BY MR. BACON: Q Go ahead. I'm talking about -- 21 MR. HADEED: 22 MR. BACON: The policy governs -She can answer. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 71 1 2 BY MR. BACON: Q 3 4 MR. HADEED: No, not yet she can't until I finish my objection for the record. 5 6 Go ahead. MR. BACON: Well, you have an objection. It's noted. 7 MR. HADEED: No. The objection is the policy 8 speaks for itself, and any comments she makes otherwise 9 are irrelevant. 10 BY MR. BACON: 11 Q Go ahead. 12 A If there was something before, if it was 13 changed later on, so that's fraud. 14 Q Okay. It's automatic, correct? 15 A Because it's changed. 16 Q Okay. 17 have email? 18 A No. 19 Q Do you have a place where people send you 20 email? 21 A No. 22 Q Have you ever had an email address? So why did it change? Let me ask you this question. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Do you 72 1 A No. 2 Q So if I wanted to send you an email to invite 3 you to a nice party, a family event at my house, I 4 couldn't email you? 5 MR. HADEED: 6 THE WITNESS: 7 BY MR. BACON: 8 9 Q I think she already said that. No. So there's no way to communicate with you other than through telephone? 10 A Yes. 11 Q And when you sent this email, which is Exhibit 12 Number 1, what email address was used to send this 13 email that's referenced to the insurance company? 14 15 16 17 A My brother -- my cousin brother send it to them. Q Okay. So what's your brother Syed Ahmed's email address? 18 A I don't know about that. 19 Q Okay. 20 21 22 We may get some documents from the insurance company that have that. Okay. Have you ever had your cousin or anybody email reporters or anybody with the press? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 73 1 A It's been a long time he did, but not now. 2 Q You mean Syed Ahmed? 3 A Yes. 4 Q So when he would email the press, would he 5 tell them about things that were happening with you as 6 your legal representative? 7 A Yes. 8 Q Okay. 9 So if you needed to or were going to speak to the press, you would use his email and he 10 would send emails on your behalf as your legal 11 representative, is that right? 12 A No, I didn't do that. 13 Q Okay. For all matters? Well, you just told me that he would 14 email the press on your behalf and talk to the press 15 about you, isn't that right? 16 17 18 19 A Only this report he has sent to insurance. Only insurance. Q Okay. He email this report to insurance. And you're saying you have never emailed anybody at the press? 20 A No. 21 Q And they've never emailed you, from the press 22 to you? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 74 1 A No. 2 Q And have you ever emailed anybody at the FBI? 3 A No. 4 Q Have you ever emailed with the Capitol Police? 5 A No. 6 Q And have you ever had anybody email on your 7 behalf to the FBI or the Capitol Police? 8 A No. 9 Q Have you had conversations with the press by 10 phone? 11 A No. 12 Q Have you had conversation with anybody in the 13 press in person? 14 A No. 15 Q Other than the one time you had a meeting with 16 the FBI, have you had any phone conversations with the 17 FBI? 18 A No. 19 Q Other than that one meeting you had with the 20 FBI, have you ever had any phone conversations with any 21 other government officials including the Capitol 22 Police? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 75 1 A No. 2 Q Okay. What, if any, facts are you relying 3 upon to assert that any Awan brother has committed any 4 crime? 5 A No. 6 Q Have you ever told anybody that you think the 7 8 9 10 11 Awan brothers have committed any crime whatsoever? A Whatever happened to me, I told that, nothing else. Q No. But did you ever say that Mr. Awan, who's seated with me, committed any crime including fraud? 12 A No. 13 Q Have you ever told anybody that Mr. Imran Awan 14 committed any crime? 15 A No. 16 Q Have you ever told anybody that Hina Alvi 17 committed -- 18 A No. 19 Q -- any crime? 20 A No. 21 Q You understand me, don't you? 22 MR. HADEED: I'm going to object on this Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 76 1 irrelevant questioning. 2 MR. BACON: 3 MR. HADEED: 4 It's very relevant to her -The only relevance in this case -- 5 THE WITNESS: 6 MR. HADEED: No, never told anyone. It's just simple, man. 7 interpretation of a contract. 8 ahead. 9 10 C'mon. It's just Anyway, go BY MR. BACON: Q Okay. Have you ever told the police, when you 11 called the police about your husband, or the FBI, or 12 the Capitol Police, or anybody that Mr. Awan was 13 involved in any radical Islam or radical Islamic 14 activities? 15 A No, never. 16 Q You've never said anything like that? 17 A (No response.) 18 Q Has anybody ever asked you that question? 19 Anybody? 20 A FBI asked me when they came. 21 Q The FBI asked -- whoa, whoa, whoa. 22 I said no. The FBI asked you about the Awan brothers and whether they were Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 77 1 2 involved in any radical Islamic activities, right? A No. 3 MR. BACON: She just said -- 4 THE INTERPRETER: 5 THE WITNESS: She said no. I'm just telling you whatever 6 FBI -- they never asked me about the radical Islamic 7 question and never replied anything. 8 BY MR. BACON: 9 Q Okay. Did they ask about any crimes? 10 A No. 11 Q And the press never asked about any crimes or 12 any radical Islamic activities? 13 saying here under oath today? 14 A No. 15 Q Okay. 16 Let's go back to Exhibit Number 2. I would like to see if you can go to page 23. 17 18 Is that what you're MR. BACON: break? You want to take a bathroom Let's take a bathroom break. 19 (Brief recess.) 20 MR. BACON: Back on the record after a break. 21 And during the break, there was a request by Ms. Gilani 22 to talk to Mr. Awan. And hopefully they had progress Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 78 1 2 in discussions about resolving this case. But one thing was very clear to my client from 3 her statements in conversations, and that was that she 4 did acknowledge speaking with the press, although she 5 has under oath denied it. 6 her in light of her most recent conversation with my 7 client during the break that she did, in fact, speak 8 with the press. 9 10 MR. AWAN: So I'm going to re-examine You noticed the statement. MR. BACON: And I think you also heard that 11 and you are the interpreter. 12 statement that I just made? 13 14 INTERPRETER: Do you agree with that I'm going to translate first whatever you said. 15 MR. BACON: 16 (The interpreter spoke to the witness in a 17 18 19 Okay. foreign language.) (The witness spoke to the interpreter in a foreign language.) 20 MR. BACON: 21 INTERPRETER: 22 What did she say? She said, "I never talked to the press, the other people are asking." Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 79 1 2 3 4 BY MR. BACON: Q about this case? A 5 6 11 This is the statement about yesterday. THE WITNESS: Yesterday were not press people. 9 10 (Not translated.) MR. AWAN: 7 8 What other people other than press were asking BY MR. BACON: Q Okay. Yesterday you had a conversation with somebody about this case and the Awan brothers? 12 A Yes. 13 Q Okay. 14 yesterday? 15 A (No response.) 16 Q Because I've asked you whether you had a All right. Who did you speak with 17 conversation with anybody about the Awan brothers. 18 anybody means anybody at any time up to today. 19 Who did you speak with yesterday, ma'am? 20 A The people from Capitol Hill. 21 Q Capitol Hill police? 22 A No, no. Not police. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 And 80 1 Q People from Capitol Hill. 2 A Someone attorneys. 3 Q Some attorneys from Capitol Hill? 4 A Attorney's assistant. 5 Q And did they come to your house? 6 A Yes. 7 Q Okay. 8 this case? 9 A They were asking about him. 10 Q What were they -- when you say him, you're 11 Which people? And what did they want to know? About referring to my client, Mr. Awan? 12 A About all of them. 13 Q Okay. So 14 MR. AWAN: I'm having very much difficulty -- 15 MR. HADEED: All right. I want the record to 16 reflect that I am now learning about this myself for 17 the first time, too. 18 don't know. 19 20 21 22 So examine her. I'm sorry. I (The interpreter spoke to the witness in a foreign language.) MR. BACON: Okay. So you want to go downstairs? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 81 1 MR. AWAN: Yeah, yeah. 2 MR. BACON: 3 you to come back -- 4 MR. AWAN: 5 MR. BACON: 6 And then I'll wait for Yeah. Because I think this is important. So what are we going to take, however many minutes? 7 8 All right. MR. HADEED: It doesn't have anything to do with the insurance case, but it's -- 9 MR. BACON: I don't know if it does or 10 doesn't, but she could have said a million different 11 things. 12 didn't have conversations. 13 she did. 14 15 foreign language.) THE WITNESS: 20 But I told you I didn't tell anything about them. 18 19 And now we're seeing that (The interpreter spoke to the witness in a 16 17 But she previously has sworn under oath she BY MR. BACON: Q All right. approximately? Hold on. Before lunch? So yesterday, what time After lunch? 21 A It's not yesterday. It was last week. 22 Q So how many times did you have visitors come Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 82 1 to your house last week and/or yesterday? 2 A Only one time. 3 Q One time. 4 A I'm not sure, 2:00 or 3:00 p.m. 5 Q What day? 6 A I don't remember the day. 7 Q But it was last week? 8 A Yeah, yeah. 9 Q Okay. 10 A Two people. 11 Q Okay. 12 When? How many people came to your house? A man and a woman, two men, two women? What? 13 A Both woman. 14 Q Two women. And did they give you a card? 15 they show you a card of who they were and give you 16 something? 17 A Yes. 18 Q Do you have the cards? 19 cards? 20 A 21 22 Did They showed me card. Can you give me the They were wearing -INTERPRETER: I think she's talking about the ID. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 83 1 2 3 BY MR. BACON: Q Oh, they had a badge. you a business card? 4 A No. 5 Q All right. 6 But they didn't give And they said they were from Capitol Hill and they were attorneys? 7 A Yes, they said attorneys. 8 Q Okay. 9 And they told you they wanted to talk about something? 10 A Yes. 11 Q All right. Now, I'm sure, but you correct me 12 if I'm wrong, they did not just show up out of the 13 clear blue at 2:00 or 3:00 o'clock last week. 14 contacted you to set up a time and come see you, didn't 15 they? They 16 A Yes. They told me they will come. 17 Q Okay. 18 A Yes. 19 Q Did they call your land line or your cell 20 phone? 21 A Cell phone. 22 Q Is it the cell phone, the cell phone you have And did they call you to tell you this? On my cell phone. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 84 1 2 3 4 5 in your purse? A I can receive calls on this phone but cannot make call on this phone. Q Okay. But if you pull up your phone, will you be able to see the phone number that called you? 6 A No. 7 Q All right. 8 see you. 9 house, is that right? So they called and asked to come They set up a time and then they came to your 10 A Yes. 11 Q All right. 12 INTERPRETER: 13 BY MR. BACON: 14 Q Okay. She said they said second day. So when they arrived, were you the only 15 one at your house and those two, or was somebody else 16 also present? 17 A Only me. 18 Q Okay. 19 A Yes. 20 Q And this was at your house? 21 A Altogether three people at my house. 22 Q All right. So you and two women met, right? What did they want to know? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 85 1 A About them. 2 Q What about the Awan brothers did they ask you? 3 A What is this? What is this? 4 Q What is what? Did they show you papers? 5 6 MR. HADEED: Just tell them everything. have to -- just answer. 9 10 Don't worry. You It's okay. (The interpreter spoke to the witness in a foreign language.) 11 12 Tell her just to be more responsive. 7 8 How is this? BY MR. BACON: Q 13 Come clean. That's the best. MR. HADEED: Yeah. 14 whatever they ask. 15 tell a grand jury. Tell them whatever -- I mean, unless you're under oath to 16 THE WITNESS: 17 BY MR. BACON: What they have done to you. 18 Q What who have done to you? 19 A They changed the insurance paper and also on 20 21 22 The Awan brothers? the death certificate they put the divorce. Q Who was asking these questions? These people? Or were you -- they were asking about the death Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 86 1 certificate, these Capitol Hill police? 2 A They ask me what they have done to you. 3 Q Okay. 4 A They asked me to tell us something about them, So the -- 5 but I told them I don't know. 6 have done to me. Okay. Only this thing they 7 Q 8 very sorry. 9 please tell us all the bad things those Awan brothers They must have done something. 10 did to you?" 11 the insurance. 12 else." 13 14 15 A Yes. that's it. 18 you said that? 22 I said I don't know anything else only about the insurance. 17 21 I don't know anything about anything Is that what you said? Q 20 Can you And you said, "I can only tell you about 16 19 So they were coming in saying, "We're A Only insurance and the death certificate, And what did they say when you told them, They told me they want to help me, but I said I don't need your help. Q How long was the meeting? THE INTERPRETER: First she said Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 87 1 forty-five minutes to one and a half hours. 2 3 4 BY MR. BACON: Q Okay. And did you talk about anything else other than the insurance and the death certificate? 5 A No. 6 Q Did they give you any papers and ask you to go 7 somewhere like a subpoena? 8 A No. 9 Q Okay. When they asked you to tell them some 10 things and they said they could help you, did they 11 explain what kind of help they were willing to give you 12 that they wanted to help you with? 13 A They didn't say anything about help, but I 14 told them before they offered me the help, I don't need 15 their help. 16 Q But did they ever indicate what the 17 possibilities or the kind of help they could give you; 18 whether they could take care of you, whether they can 19 put you somewhere else so you can get away from them or 20 anything like that? 21 22 A Since I didn't ask them for any help, so that's why they did not. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 88 1 2 Q Okay. Did they tell you they would get back with you or they would contact you again? 3 A No. 4 Q And when they called to talk to you, they 5 didn't tell you what they wanted to talk about? 6 just said they wanted to come see you? They 7 A Yes. 8 Q Did you tell them you had already talked to 9 the FBI? 10 A Yes. 11 Q Did they ask you what you told the FBI? 12 A I told them I don't know. 13 Q Do you know why anybody would say that you 14 spoke with the Capitol Hill police and the FBI and told 15 them that the Awan brothers committed crimes? 16 know why people would say that? 17 A (No response.) 18 Q Do you know why people might say -- 19 A No, I just told them about myself. 20 Q Okay. 21 22 And your stuff is the insurance and the death certificate? A Do you Yes. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 89 1 2 Q Did they ever indicate to you why they wanted to talk to you? 3 A They have some kind of problem. 4 Q Did they say they were doing an investigation? 5 A Yeah, investigation. 6 Q Did they say how far along it was; whether it 7 That's why. was almost finished or whether it was just starting? 8 A No. 9 Q Did they tell you anybody else they spoke 10 11 with? A No. 12 MR. HADEED: 13 (Brief discussion off the record.) 14 BY MR. BACON: 15 16 Q Off the record. So you understood from them that they were doing an investigation, right? 17 A Yes. 18 Q So did they explain to you what they were 19 specifically investigating or generally what they were 20 investigating? 21 A 22 money. They wanted to know where they are sending the Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 90 1 Q 2 who's they? 3 A Imran. 4 Q Where is Imran sending money? 5 A Yes. 6 Q Did they say when this money was sent that 7 Okay. So they still are asking where they -- Which Awan brothers or which people? they were asking where it went to? 8 A No, I don't know that. 9 Q So you don't know whether this was recent 10 money that they were asking about or money from, you 11 know, previous years, is that right? 12 13 14 15 A I don't know about that whether they were asking about recent -- recently or previously. Q Why did they think you knew where Imran is sending money? 16 A Because they know I'm the stepmother. 17 Q Okay. 18 money? 19 A No. 20 Q Okay. 21 22 Do you know where Imran is sending And they did not ask any questions when they met you about anybody else, or did they? A About Hina. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 91 1 Q So they asked questions about Hina? 2 A Yes. 3 Q And they asked questions about Imran? 4 A Yes. 5 Q Did they ask questions about anybody else? 6 A Abid and Jamal. 7 Q Okay. 8 So what questions did they ask about Hina? 9 A Whether she's in Pakistan or here. 10 Q Okay. 11 A I don't know about that. 12 Q All right. 13 about Hina? 14 A Nothing else. 15 Q And what questions did they ask about Abid? 16 A How long he's working here. 17 Q In the U.S.? 18 A Yes. 19 Q Okay. 20 A I don't know about that. 21 Q Okay. 22 And what did you tell them? What other questions did they ask What did you tell them? Now, did they ask if Hina was sending any money or was it just Imran that they were asking Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 92 1 about sending money? 2 A Only Imran. 3 Q Were there any other questions that were asked 4 about any other family members that you can recall and 5 tell me about? 6 A No, nothing else. 7 already. 8 That's all. 9 Q 10 The only things I told you I already told you they asked me about that. Okay. Were these questions the same questions that the FBI asked you in March or April of 2017? 11 A Yes. 12 Q Were there any different questions? 13 A No. 14 Q Did you tell them that you already answered 15 these questions when the FBI spoke to you? 16 A Yes. 17 Q Did you ask them any questions? 18 A No. 19 Q How was your conversation left before they 20 I told them I don't know. left your house? 21 A Nothing. 22 Q Okay. They just said we are leaving. Did they ask you to get them any Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 93 1 information or find out anything for them? 2 A No. 3 Q If they want to speak to you again, will you 4 ask them what's going on with their investigation? 5 A I don't think so they would contact me. 6 Q Well, if they do contact you, will you ask 7 8 9 10 them when the investigation is going to conclude? A I don't think so I will talk to them and no, I would ask them it. Q And other than saying what they said about 11 this insurance matter that you raised with them, did 12 they give you any other advice about this insurance 13 matter? 14 A No. 15 Q Did they tell you that anybody would 16 financially support you? 17 A No. 18 Q Okay. 19 currently? 20 A My friend. 21 Q Which friend? 22 A Someone. How are you financially supported Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 94 1 Q What's the name? 2 A I don't want to give you a name. 3 Q I'm sorry, but you have to. 4 A No, I don't want to tell you. 5 MR. BACON: Counsel? 6 THE WITNESS: 7 MR. BACON: Sorry. She can't refuse or I'm going to 8 go to court and ask the judge to order a response. 9 hope you explained to her she has to answer the 10 questions. 11 MR. HADEED: I'm going to object to the 12 relevance of the question. 13 the issues in the case, but -- 14 MR. BACON: It has nothing to do with Well, we don't know until we 15 have a name. 16 to the discovery of very relevant and admissible 17 information. 18 19 And if we have a name, that might lead BY MR. BACON: Q So I need the name, ma'am. 20 me the name. 21 supporting you financially? 22 I You have to give What's the name of the person that is MR. HADEED: Maybe I should talk to her, you Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 95 1 know, privately for a second and see if I can get it 2 myself or -- 3 MR. BACON: 4 MR. HADEED: 5 MR. BACON: 6 -- encourage her to. Do you want to step out into the other office? 7 8 Okay. MR. HADEED: Yeah. minute? 9 INTERPRETER: Yeah. 10 MR. BACON: 11 (Off the record.) 12 BY MR. BACON: 13 Q All right. Yeah. So what do we have? 14 answer to my question? 15 INTERPRETER: 16 Yes. MR. BACON: 18 THE INTERPRETER: 19 MR. BACON: 20 THE INTERPRETER: 22 I'm sorry. Do we have an She told me the name. 17 21 But can you help me a Okay. What's the name? Razia. What's the name? Razia. She told you earlier. MR. BACON: Oh, okay. The previous name. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 96 1 2 3 BY MR. BACON: Q Okay. Do you know somebody named U-s-i-f-o, c-h-o-d-r-i-a? 4 MR. AWAN: 5 INTERPRETER: 6 MR. BACON: 7 THE WITNESS: 8 the policy from. 9 10 11 Usifo Chodria. Usifo Chodria? Yes. He is the one my husband bought Mr. Usifo Chodria. BY MR. BACON: Q Okay. And this Razia, she's supporting you financially, is that right? 12 A Yes. 13 Q She's paying all of your bills? 14 A I don't have any bills. 15 Q You don't have any bills including lawyer's 16 bills? You don't have to pay, is that right? 17 A That money I borrowed from someone. 18 Q Who? 19 A From Pakistan. 20 Q Who's the person in Pakistan that gave you the 21 money? 22 A My sister. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 97 1 Q What's her name? 2 A Nida. 3 Q What's her last name? 4 A Nida Holit [ph.]. 5 Q And she gave you some money? 6 A Uhm-hm. 7 Q Did she wire it? 8 A Someone was coming from Pakistan. 9 N-i-d-a. (Nodding head.) She sent through him. 10 Q How much did they give you for that? 11 A Ten -- 12 Q $10,000? 13 INTERPRETER: She's saying 10,000 rupees. 14 THE WITNESS: No, no, no. 15 MR. BACON: 16 INTERPRETER: She doesn't know? She said -- first she said 17 10,000 rupees, which is equal to like a hundred 18 dollars -- 19 THE WITNESS: Ten lakh. 20 INTERPRETER: Okay. 21 22 So ten lakh which is equal to $10,000. MR. BACON: Okay. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 MR. BACON: And Ms. Razla who is supporting you financially, she does not work and is not employed, isn't that right? A No, she not working. Okay. But yet she supports you financially, A Only food. Okay. Now, ma'am, you swore under oath you do not have an email account or address, is that A NO. Are you familiar with an email address ashrafgilani@yahoo.com? MR. HADEED: Ashraf Gllani. BY MR. BACON: -- ss smsu isn't it? And you send emails from that address including two emails to the FBI, didn't you? A yes, a long time ago. No, not a long time ago. March 5th, 2017. March 6th, 2017 . A {Not translatedJ verbatim Reporting, LLC 5684 General Plast- Va 20120 703 932 "(754 99 1 2 3 4 Q Ma'am, you lied to me, didn't you? to me, didn't you? A You're a liar, aren't you? I forgot about that. MR. BACON: Ah. 5 break before I explode. 6 lunch break. 7 You lied It was not in my mind. I think we need to take a Let's take a twenty minute (Recess.) 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 100 1 A F T E R N O O N 2 MR. BACON: S E S S I O N We'll be here another couple of 3 days. So what time do you have to leave tonight? 4 not leaving until I get everything I need out of you. 5 6 INTERPRETER: I'm She can stay until you want her to. 7 MR. BACON: Okay. Well, we're going to break 8 at like 4:00, and then you're going to be back here 9 tomorrow, and I'm going to take another day on you. 10 THE WITNESS: 11 MR. BACON: 12 However many days it takes until you start telling the truth. 13 14 How many days? MR. HADEED: Well, just ask questions that relate to the case and maybe we can get on faster. 15 MR. BACON: Well, maybe if she tells the 16 truth, we don't have to keep going around and around 17 and around. 18 reality to them, we wouldn't have to deal with this 19 nonsense. 20 21 22 And maybe if the allegations had some MR. HADEED: is all about. That's what the discovery process It's a learning process. MR. BACON: You don't just file willy-nilly Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 101 1 craziness and hurt people's reputations and damage 2 their business by saying they commit fraud, Counsel, 3 like you did. 4 didn't have a shred of evidence to support it. 5 6 COURT REPORTER: MR. BACON: Did you want that all on the Oh, yeah. There's no off the BY MR. BACON: 10 Q Okay. 11 you. 12 Exhibit 2. Look at Exhibit 2 which is in front of I would like you to turn to page 88 of 127 on 13 INTERPRETER: 14 MR. BACON: 15 INTERPRETER: 16 MR. BACON: 17 INTERPRETER: 18 BY MR. BACON: 20 You record. 9 19 You filed it. record? 7 8 That's what you did. Q Page 88? I can find it. Did you find it? No. That's it. That's it. Okay. Ma'am, I'm showing you page 88 of 127 which is a part of Exhibit 2. Do you have that in front of you? 21 A (No response.) 22 Q Do you have that in front of you? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 102 1 A Yes. 2 Q This is the insurance information that your 3 husband filled out for the $50,000 insurance policy, 4 correct? 5 A Yes. 6 Q Do you know whose handwriting is on this page? 7 A I don't know. 8 Q Okay. 9 10 Turning to the next page, which is 89 of 127, otherwise known as page two of four, do you know whose handwriting is on that page? 11 A My husband's. 12 Q Okay. Turn to the next page which is 92 of 13 127, otherwise known as page three of four, which is a 14 part of Exhibit Number 2. 15 handwriting and some information there. 16 who wrote that? There's also some 17 A I don't know about this. 18 Q Okay. Do you know The following page is page 94 of 127 19 which is a part of Exhibit Number 2. 20 signature line and a date. There's a Do you see that? 21 A My husband's signature. 22 Q So he signed this on May the 9th, 2012? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Do 103 1 you see that? 2 A Yes. 3 Q And you see where it says, "signature of 4 proposed insured?" 5 A Yes. 6 Q That's your husband's signature, right? 7 A Yes. 8 Q And then there's a witness. 9 Signature of witnessing agent. 10 A Agent. 11 Q So that's the agent that you talked about 12 earlier that you mentioned. 13 name? 14 A Usifo Chodria. 15 Q Usifo Chodria. His name is -- what's his Let's follow the next page, 16 page 96 of 127 which is a part of Exhibit Number 2. 17 This is a questionnaire. 18 filled out this questionnaire? 19 A Agents write. 20 Q Okay. Do you know whose handwriting So this at the bottom of page 96 of 21 127, which is a part of Exhibit Number 2, is the 22 proposed insured. That's your husband's signature, Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 104 1 isn't it? 2 A Yes. 3 Q And then under the witness it's Farak Hamad? 4 A Farak Hamad. 5 Q And who is that? 6 A He works with Mr. Usifo Chodria. 7 Q Okay. Is there anything that you're relying 8 upon in Exhibit 2? 9 language? 10 11 INTERPRETER: Could you rephrase the question? 12 13 Any provision, any section, any BY MR. BACON: Q Is there any wording that you're relying upon 14 in Exhibit 2 that you can point to to support your 15 position? 16 A I did not read this yet. 17 Q Hold on. Don't answer until I finish my 18 question. 19 when we went over the instructions. 20 I'm finished, and I'll ask a question only after you're 21 finished. 22 We made that clear at the very beginning So you answer when Now, the question again is is there any Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 105 1 language in Exhibit 2 that you can show me that you 2 rely upon to support your claim that you, and not Abid 3 Awan, are the rightful owner of the $50,000 insurance 4 proceeds from this life insurance policy? 5 6 MR. HADEED: Objection to the question to the witness. 7 BY MR. BACON: 8 Q 9 Go ahead. MR. HADEED: Objection is based on numerous 10 factors, including but not limited to the entire 11 contract hasn't been translated for her. 12 13 MR. BACON: BY MR. BACON: 15 Q 16 it. 18 now. 21 22 So go ahead. MR. HADEED: 17 20 She said she under oath swore that she read English. 14 19 Okay. You didn't give her time to read You need about an hour for her to read this right MR. BACON: Take whatever time you need. We'll come back in another hour. MR. HADEED: You can read it. Furthermore, she's not a judge or a lawyer, and the contract speaks for itself. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 106 1 2 BY MR. BACON: Q 3 4 MR. HADEED: INTERPRETER: 9 10 BY MR. BACON: Q Okay. I'm not asking him. I'm asking you. Because you've claimed it in your case that you're the rightful owner. 11 12 She's saying my attorney can tell you. 7 8 And if you don't know, you can say you don't know. 5 6 Go ahead. MR. HADEED: You're not a contract expert. you don't know, say you don't know. 13 Can you translate that for her? 14 (The interpreter spoke to the witness in a 15 foreign language.) 16 17 MR. BACON: Counsel, quit telling her how to answer. 18 MR. HADEED: 19 MR. BACON: 20 If She doesn't know. You're testifying now. Don't do it again. 21 MR. HADEED: 22 MR. BACON: Don't trick her. Don't do it again. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Don't do that 107 1 again. 2 THE WITNESS: 3 BY MR. BACON: 4 5 Q Okay. No. So you're not aware of any provisions. Okay. 6 A I don't know about that. 7 Q Okay. Can you tell me any facts that you rely 8 upon to support your claim? 9 whatsoever to support your claim that you are entitled 10 11 12 13 Any facts of any nature to the insurance money and not Mr. Awan? A My husband purchase this for me under my name. And it was under my name for so many years. Q Anything else that you would like to tell me 14 other than that to support your position that you're 15 the rightful owner and not Mr. Awan? 16 A Because I'm his wife. 17 Q Okay. 18 A Yes. 19 Q Anything else whatsoever? 20 A Okay. Is that it? Yes. This he bought it for me. 21 my name before, and also I'm his wife. 22 things. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 All these It had 108 1 Q Okay. 2 A No, nothing else. 3 Q Okay. 4 All that. MR. BACON: 5 And that's it? This will be the next Exhibit 3. (Whereupon, a document was marked 6 Awan Exhibit Number 3 for 7 identification.) 8 9 10 BY MR. BACON: Q Let me show you Exhibit Number 3. Have you seen this before? 11 A Yes, I have seen that. 12 Q All right. 13 A It has policy number. 14 Q And it's to your husband? 15 A And the change they made. 16 Q What change was made? 17 A (No response.) 18 Q Do you know? 19 A What are you asking? 20 Q You said it relates a change that was made. What is it? 21 My question is do you know what the change was that was 22 made? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 109 1 A That paper I didn't see. 2 Q So you did not see Exhibit 3 even though you 3 just a minute ago swore that you saw it before? 4 A I have seen something like this. 5 Q Okay. 6 right? 7 A No. 8 Q All right. Let me show you the next exhibit. MR. BACON: Exhibit 4. 9 10 But you haven't seen this before, (Whereupon, a document was marked 11 Awan Exhibit Number 4 for 12 identification.) 13 BY MR. BACON: 14 Q Have you seen Exhibit 4 before, ma'am? 15 A No. 16 Q Okay. It makes it nice and easy. 17 you this about Exhibit 4. 18 signature on Exhibit 4? 19 A Yes. 20 Q Oh, you do. 21 22 Do you see your husband's Okay. Let me show you the next exhibit. MR. BACON: Let me ask Exhibit 5. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 110 1 (Whereupon, a document was marked 2 Awan Exhibit Number 5 for 3 identification.) 4 BY MR. BACON: 5 Q Have you seen this before? 6 A Yes, this I've seen. 7 Q Okay. 9 A Yes. 10 Q Okay. 11 A When this paper came to my house. 12 Q Okay. 13 A Sometime in March. 14 Q Okay. 8 15 This has your husband's signature on it? When did you see this? When did it come to your house? And this paper has your husband's signature on it and some other signatures, doesn't it? 16 A Yes. 17 Q Okay. That's Abid's wife. So Abid's wife is on here. Your 18 husband is on this Exhibit Number 5 and then there's a 19 witness on this Exhibit Number 5 -- or I'm sorry. 20 witness is Mr. Abid's wife, correct? 21 A Yes. 22 Q Okay. So we see two signatures. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Your The 111 1 husband's signature and Abid's wife's signature on 2 Exhibit 5, correct? 3 A Yes. 4 Q And this is dated 16 November 2016, right? 5 A Okay. 6 MR. BACON: 7 THE WITNESS: 8 MR. BACON: 9 Did she say yes? Yes. The next exhibit is -- what are we, six? 10 (Whereupon, a document was marked 11 Awan Exhibit Number 6 for 12 identification.) 13 14 15 BY MR. BACON: Q I'm showing you Exhibit Number 6. Have you seen this before? 16 A Yes. 17 Q When? 18 A When it came to my home. 19 Q When did it come to your home? 20 A March, somewhere in March. 21 Q Did it come to your home the same time 22 Exhibit 5 came to your home? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 112 1 A The whole package came together. 2 Q Okay. 3 So these, Exhibit 5 and 6, were together with some other documents, is that right? 4 A Yes. 5 Q And Exhibit 6 is dated -- signed 12/16/16, 6 right? 7 A Yes. 8 Q Who signed Exhibit 6? 9 A It says signature of policy owner, so whoever 10 changed that, that's the signature of that person. 11 12 13 Q top. Well, it says who the policy owner is at the Policy owner. A 14 Yes, it's a policy, Abid's signature. MR. BACON: 15 Okay. Next Exhibit 7. (Whereupon, a document was marked 16 Awan Exhibit Number 7 for 17 identification.) 18 BY MR. BACON: 19 Q Can you identify this exhibit? 20 A Yes, I've seen this. 21 Q Where? 22 A These all came together on same date. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 113 1 Q At your house? 2 A Yes. 3 Q Okay. 4 So do you understand Exhibit 7 to be a letter to the owner of the insurance? 5 A Yes, okay. 6 Q Okay. The owner is identified on Exhibit 6, 7 Mr. Abid Awan. He's the person who received the letter 8 on Exhibit 7, right? 9 A Okay. 10 Q Yes? 11 A Yes. 12 Q All right. And you said you received a copy 13 of this with a package and other documents at your 14 home, correct? 15 A 16 Yes. MR. BACON: 17 Is this eight? (Whereupon, a document was marked 18 Awan Exhibit Number 8 for 19 identification.) 20 21 22 BY MR. BACON: Q Let me show you Exhibit 8. Is this another part of the documentation that you received at your Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 114 1 house? 2 A This one not in my mind. 3 Q Okay. 4 A Maybe I have it, but I didn't remember to see 5 6 You don't have a copy of this one? this. Q Okay. If you look at Exhibit 7, there's a 7 reference to enclosure and it says, "Beneficiary change 8 form individual." 9 And do you see Exhibit 8 says beneficiary 10 change request? Is that the form, to your 11 recollection, that was in the letter that you received 12 at your house in March of 2017? 13 A Maybe, yes. 14 Q Okay. 15 Exhibit 8? 16 A Which one? 17 Q Where it says -- 18 And do you see the signature on MR. HADEED: They have different numbers on 19 the exhibits. Maybe you can -- oh, you have eight on 20 your exhibit. I have seven on mine. 21 MR. BACON: 22 MR. HADEED: Exhibit 8. Okay. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 115 1 BY MR. BACON: 2 Q Exhibit 8? 3 A Yes. 4 Q You see the signature? 5 A Uhm-hm. 6 Q Who's the signature? 7 A I don't know. 8 Q You don't know. 9 MR. AWAN: 10 11 14 This is the one. MR. HADEED: It's been asked and answered. BY MR. BACON: Q You say signature of the current policyholder. Do you know who that is on Exhibit 8? 15 A Abid signed. 16 Q Okay. 17 (Indicating.) Next question. 12 13 (Nodding head.) So Abid was the current policyholder that signed that, right? 18 A Okay. 19 Q Now your husband passed away on January the 20 16th, 2017, is that correct? 21 A Yes, 16 January 2017. 22 Q And he passed away of cancer, is that right? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 116 1 A 2 3 Yes. MR. BACON: This will be my next exhibit. This is nine. 4 (Whereupon, a document was marked 5 Awan Exhibit Number 9 for 6 identification.) 7 BY MR. BACON: 8 Q Have you seen Exhibit 9 before? 9 A Yes. 10 Q What is it? 11 A That's my husband's name, Social Security 12 13 14 number, and also Pakistan. Q Okay. came to your house in March of 2017? 15 A Yes. 16 Q Okay. 17 Was this part of the documentation that Look to the last page of Exhibit 9 where it says signature. Whose signature is that? 18 A Beneficiary signature? 19 Q Yes. 20 A I don't know. 21 Q It's Abid Awan, isn't it? 22 MR. HADEED: She said she didn't know. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 117 1 2 MR. BACON: But I'm entitled to explore her recollection, Counsel. 3 4 I know. BY MR. BACON: Q That's Abid Awan, isn't it? 5 MR. HADEED: 6 BY MR. BACON: If you don't know -- 7 Q You need to say yes or no. 8 A Abid Awan. 9 MR. BACON: What did she say? 10 INTERPRETER: 11 BY MR. BACON: 12 Q 13 14 So, please. Okay. Thank you. MR. BACON: we on? Eleven? She's saying Abid Awan. This will be the next. What are Ten? 15 (Whereupon, a document was marked 16 Awan Exhibit Number 10 for 17 identification.) 18 19 20 BY MR. BACON: Q Okay. Let me show you Exhibit 10. seen this before? 21 A Yes. 22 Q When did you see this? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 Have you 118 1 A All these paper came together. 2 Q Okay. 3 Let's talk about Exhibit Number 10. Who is Robert Seigal [ph.]? 4 A I don't know. 5 Q Okay. Who is he? Now, it says in the first page of 6 Exhibit Number 1 about two-thirds of the way down, it 7 begins with the deceased's wife, Mrs. Gilani, that's 8 you? 9 A Yes. 10 Q You claim the ownership and the beneficiary 11 changes were done fraudulently. 12 ownership and beneficiary changes done fraudulently? 13 14 A Okay. How were the Because it was under my name and they transferred to someone else. 15 Q Okay. Any other reason other than that? 16 A No, nothing else. 17 Q Okay. And it says you planned to report this 18 to the insurance commissioner of Virginia. 19 that? 20 A Yes. 21 Q Okay. 22 Did you do What happened when you reported that the ownership and beneficiary change was done Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 119 1 2 fraudulently? A I already told you they said this will be 3 decided -- and since there's two claimers, so you have 4 to go to the Court. 5 6 Q Okay. Now, did you also report the ownership and beneficiary changes were fraudulent to your lawyer? 7 A Yes. 8 Q And did you explain to him the reason why you 9 10 said they were fraudulent as you have done to me here under oath today? 11 A Yes. 12 Q And so the reason that you said the changes 13 were done fraudulently was only because the changes 14 were made; that's what you told him, right? 15 A (Not translated.) 16 Q And based upon that, he filed a lawsuit 17 claiming the fraud just because the changes were made, 18 isn't that right? 19 A During hospital they did it. 20 Q Yeah. They made a change at the hospital. 21 And so you said the fraud is they made a change at the 22 hospital, and he said -- Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 120 1 2 MR. HADEED: client privilege. 3 4 MR. BACON: about it. MR. HADEED: 6 MR. BACON: not to do. MR. HADEED: 9 MR. BACON: 11 MR. HADEED: Well, from here on -You can't tell her what to do and No. Yes. Don't answer -You can't tell her -- -- any more questions between our conversations. 12 MR. BACON: 13 MR. HADEED: 14 Please. She can waive whatever she wants. 8 10 She's already waived it by talking C'mon, Counsel. 5 7 I'm going to object to attorney- Whoa, whoa, whoa. That's attorney-client privilege. 15 MR. BACON: Counsel, you can't just interrupt. 16 She's in the middle of a conversation. 17 her what to do. 18 19 MR. HADEED: You can't tell I can object on attorney-client privilege. 20 MR. BACON: 21 BY MR. BACON: 22 Counsel. Q All right. No, you can't. Gosh. After you told your lawyer that Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 121 1 the only fraud was the fact that there was a change, 2 did he say anything like, "I don't really think that's 3 fraud. We shouldn't file that." 4 5 MR. HADEED: privilege. 6 7 Objection, attorney-client Don't answer that question. MR. BACON: She's already opened the door, Counsel. 8 BY MR. BACON: 9 Q Go ahead. 10 A No, he didn't say anything like that that this 11 12 is not fraud. Q He said it is fraud and it's a great case and 13 he'll take it, right? 14 MR. HADEED: 15 the question. Object to the leading nature of Object to a leading question. 16 THE WITNESS: 17 BY MR. BACON: 18 19 Q Yeah, he did. Yes, yes. And I can't wait. to happen when they come after him? What's going After you? 20 A (Not translated.) 21 Q Let me ask you again about the first page of 22 Exhibit Number 10, last paragraph. Mr. Chodria and Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 122 1 Mr. Syed Ahmed, your cousin, they were helping you with 2 this fraudulent claim that you were making, is that 3 right? 4 A Yes. 5 Q And did Mr. Chodria and Mr. Ahmed, did they 6 meet with your lawyer and give them all the key, juicy 7 fraud that he then filed in this case? 8 9 A No, they didn't meet my attorney. But since Mr. Chodria's the one who filled up paper for insurance 10 -- insurance papers, so he said, yes, it's been 11 changed. 12 MR. BACON: 13 Eleven. (Whereupon, a document was marked 14 Awan Exhibit Number 11 for 15 identification.) 16 17 BY MR. BACON: Q Let me show you Exhibit Number 11. And this 18 is an email from your cousin and lawyer, legal person, 19 Syed Ahmed, to Melanie Neighbor [ph.]. 20 familiar with this? Are you 21 A (Not translated.) 22 Q And this is in February of 2017. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 123 1 2 3 A This is the email he send it to insurance company about the change. Q And he said he's reporting the issue to the 4 police as insurance fraud and something more. And this 5 is his threat on your behalf to the insurance company? 6 A Yes, correct. 7 Q And then he attaches at the bottom it says, 8 "Hi, Melanie. Please find the attached police report 9 dated January 5th." 10 A Yes. The 5th I called the police. 11 Q So on January 5th you called the police, 12 reported to the police and said there was all kinds of 13 fraud going on, is that right? 14 15 A husband. 16 No. That time I told them I want to see my I don't know where is he. MR. BACON: 17 And that was because -- This will be the next. Twelve. (Whereupon, a document was marked 18 Awan Exhibit Number 12 for 19 identification.) 20 21 22 BY MR. BACON: Q Let me show you Exhibit Number 12. This is again the email from your cousin regarding the police Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 124 1 report? 2 A Yes. 3 Q Did you cause any stress to the family by 4 constantly badgering your husband while he was getting 5 cancer treatments? 6 A No, I did not -- 7 Q You just kept going to the hospital? The 8 hospital you said you didn't know where it was located, 9 you went to that hospital? 10 A I just went in October. 11 Q You went in October. 12 A (Not translated.) 13 Q But yet you filed the report on January the 15 A (Not translated.) 16 Q So you were complaining on January the 5th 14 5th? 17 about going to the hospital in October. 18 you're saying? 19 20 A I only went in October. After that I didn't go to the hospital. 21 Q Which hospital? 22 A Georgetown Hospital. Is that what Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 125 1 Q Georgetown Hospital. 2 MR. BACON: 3 THE WITNESS: 4 Okay. This will be the next one. I was going to Georgetown Hospital. 5 MR. BACON: 6 This is what? Thirteen. (Whereupon, a document was marked 7 Awan Exhibit Number 13 for 8 identification.) 9 10 11 BY MR. BACON: Q Let me show you Exhibit 13. Have you seen this before? 12 A Yes. 13 Q What is it? 14 A It has Abid's name written on this one, also 15 16 17 my name. Q Okay. Did you read this since you read English? 18 A Only my name. 19 Q Did you ever read anything else about this 20 other than your name? 21 A No. 22 Q So you have no idea what was in this -- what Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 126 1 was prepared in this document, Exhibit 13, other than 2 your name; is that what you're telling me? 3 A Yes, I don't know. 4 Q And no one explained this document to you; is 5 6 that what you're telling me here under oath? A 7 No. MR. BACON: Why don't I give you this 13. 8 That seems to have my own personal notes. 9 know what to ask myself. 10 11 (Mr. Bacon retrieved a document from the witness and handed another document to the witness.) 12 MR. HADEED: 13 MR. BACON: Which one? No, that's good. 14 You can have this one. 15 Let me put this here. 16 17 18 Now I don't This is good. So let's give her -- I got it. BY MR. BACON: Q Okay. So the answer to my question is no one explained anything in Exhibit 13 to you, is that right? 19 A No. 20 Q And you don't know what this is, is that 21 22 correct? A Yes, I know this answer. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 127 1 2 Q Okay. Well, let me ask you if you know. to page two of Exhibit 13, the answer. 3 A Yes, page two. 4 Q Okay. Go Are you there? You claim in paragraph four that 5 neither your husband, Mohammad Ashraf Shah, or Abid 6 Awan effectuated a valid change of beneficiary prior to 7 his death. 8 A Yes. 9 Q Okay. Do you see that? What facts are you relying upon to make 10 that claim that neither your husband nor his son 11 validly made the change? 12 13 A I have told you so many times. That was a different papers before, and later on they change. 14 Q Okay. 15 A Yes. 16 Q Okay. 17 A You keep asking me the same question. 18 Q I'll just keep -- 19 20 21 22 And that's the sole reason? MR. HADEED: Okay? We don't need the extra comments. Tell her just to answer the questions. (The interpreter spoke to the witness in a foreign language.) Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 128 1 BY MR. BACON: 2 Q Okay. Let me ask you to go to page three of 3 Exhibit 13. 4 A (No response.) 5 Q Paragraph five says, "Defendant Abid Awan Are you there? 6 obtained complete control over the free will and mind 7 of the deceased." 8 9 What facts do you have to rely upon and tell me to support your allegation that Defendant Abid 10 obtained complete control over the free will and mind 11 of the deceased, your husband? 12 A Can you rephrase question? 13 Q What facts are you relying upon to support 14 your claim in paragraph five of your answer, which is 15 identified as Plaintiff's Exhibit 13, under where it 16 says at page three, answer and cross-bill, against Abid 17 Awan? 18 A My husband never told me, it's just original 19 here. 20 the -- my husband didn't tell me. 21 22 Q But my husband never told me that he give him Okay. So if your husband didn't tell you that he gave control of everything to Awan, including his Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 129 1 mind, why are you claiming that your husband's mind was 2 given over to his son? 3 4 MR. HADEED: Let me say for the record now that we have -- 5 MR. BACON: 6 MR. HADEED: There's no -Listen. I have a right to say 7 this because it makes the case simpler. 8 this claim at this juncture is based on the contract. 9 And if the -- And I said that earlier in the day in order to 10 try to avoid all this, but here we are. 11 ahead and continue to ask her, but I'm telling you -- 12 13 MR. BACON: paragraph five? 14 Are you moving to strike If you're not, then I'm going to ask. MR. HADEED: I'm going to do it in a, you 15 know, in a written amended document. 16 to -- 17 MR. BACON: 18 in this case or not? 19 20 You can go MR. HADEED: And I'm going Is paragraph five going to remain I don't -- you know, my case, our case -- 21 MR. BACON: 22 MR. HADEED: No, no, no. -- as far as what I know now -- Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 130 1 MR. BACON: Is paragraph five in this case or 2 not? Read the whole thing including the last part 3 which I'm going to get into next. 4 MR. HADEED: (Reading.) No. This case is 5 based solely on the January 16th date of death and the 6 January 17th attempt to change the beneficiary. 7 contract -- 8 MR. BACON: 9 MR. HADEED: 10 it's based on. 11 So let me -The contract itself. That's what And that's what I've told you -- BY MR. BACON: 12 Q 13 claiming -- So, ma'am, am I correct that you're not 14 MR. HADEED: 15 BY MR. BACON: 16 The Q -- so many times. -- anything now that I've had to prepare and 17 get ready and deal with press releases that have 18 challenged this poor man's -- and claimed fraud, you're 19 not claiming any fraud or any undue influence in this 20 case? 21 MR. HADEED: 22 MR. BACON: I told you that months ago, Jim. You didn't tell me that months Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 131 1 ago. 2 3 THE WITNESS: I'm telling you that he did fraud and also made a change. 4 BY MR. BACON: 5 Q Okay. So contrary to your lawyer who said 6 there's no fraud and no undue influence, you're still 7 claiming undue influence and fraud here today under 8 oath, isn't that correct? 9 10 A before. 11 12 Q So what is this? Why did it change in the hospital? I don't know. MR. HADEED: 14 BY MR. BACON: 16 Q So would you answer my question one last time? MR. HADEED: And I want the record to reflect that -- 19 20 I would like to -- Your lawyer has said there's no fraud today. 17 18 That's what I'm trying to find out. 13 15 It was something else BY MR. BACON: Q And your lawyer has said there's no undue 21 influence today. But yet, you have testified today on 22 numerous occasions that there has been fraud and there Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 132 1 has been undue influence. 2 belief about that. 3 And you explained to me your So my question is do you agree with your 4 lawyer that there is no fraud and no undue influence in 5 your claim, or are you going to continue to swear under 6 oath that there is fraud and undue influence? 7 A 8 9 Ms. Gilani -- go ahead, finish answering the question. THE WITNESS: Yes. I'm still telling you it was changed in -- 12 13 It was -- MR. HADEED: 10 11 Yes. BY MR. BACON: Q No, no, no. I'm not asking whether it was 14 changed. I'm asking whether there was fraud and undue 15 influence even though your own lawyer says there's no 16 fraud and there's no undue influence. 17 MR. HADEED: 18 MR. BACON: 19 MR. HADEED: 20 21 22 I want the record to reflect -Let her -Okay, let her finish translating. THE WITNESS: He's saying that this happened and it was wrong. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 133 1 BY MR. BACON: 2 Q No, I'm talking about fraud and undue 3 influence. 4 there's none. 5 undue influence? Answer that question. 6 A Yes. 7 Q Okay. 8 9 I would like the record to reflect -MR. BACON: No, you can do that later. I'm asking the next question. 12 13 Are you telling me there is fraud and MR. HADEED: 10 11 Your lawyer said BY MR. BACON: Q So based upon that sworn testimony that I just 14 heard, how did Mr. Awan take control of your husband's 15 mind? 16 MR. HADEED: 17 MR. BACON: 18 21 22 No, not while there's a question pending. 19 20 Can I talk to her for a minute? MR. HADEED: It's going to save a lot of time. THE WITNESS: He has done something. Otherwise, why did he change that? Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 134 1 2 BY MR. BACON: Q Okay. Are there any other facts you can give 3 me that would explain how Mr. Awan took the free will 4 and mind of your husband? 5 A Because he was not letting me go there. 6 Q Okay. 7 Perfect. Thank you. Now, you also claim in paragraph five, under 8 answer and cross-bill of Exhibit 13, that Mr. Awan 9 caused undue influence against your husband 10 persistently and consistently. 11 12 13 How did Mr. Awan bring about undue influence on your husband persistently and consistently? A My conversation I was talking to someone else. 14 They used to, they make him to listen to that 15 conversation. 16 Q Oh, by listening that did it, is that right? 17 A By phone conversation. 18 Q Oh, by phone conversations, Mr. Awan took 19 control of your husband's mind and caused undue 20 influence persistently and consistently, correct? 21 22 MR. HADEED: I need to have a talk with my client, Jim. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 135 1 MR. BACON: 2 MR. HADEED: 3 MR. BACON: 5 What else can you do? 6 MR. HADEED: 7 MR. BACON: She's already buried herself. I need to -She has to answer. Q Go ahead. MR. HADEED: Go ahead and answer the question and then I'll break. 13 THE WITNESS: 14 BY MR. BACON: 15 16 17 18 19 You cannot BY MR. BACON: 11 12 But if I can go off the leave when there's a question pending. 9 10 I know. record -- 4 8 She has to answer the question. Q Yes? Okay. MR. HADEED: Come here. Yes. That's what I needed. Let me talk to you a minute. With the interpreter. MR. BACON: Whoa, whoa, whoa, whoa. You guys can't have secret conversations. 20 MR. HADEED: It's not a secret conversation. 21 MR. BACON: 22 Madam Interpreter, please tell me what's going It's a secret conversation. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 136 1 on over there, shenanigans and all. 2 THE INTERPRETER: 3 MR. HADEED: 4 (Brief recess.) 5 MR. AWAN: 6 Okay. Real quick. Just two minutes. Put it on the record what happened there. 7 INTERPRETER: He just discussed that he has 8 given her some kind of document which she is not 9 talking about. That's all. 10 (Off the record.) 11 MR. BACON: She has some papers. So here's what we're going to do, 12 ma'am. 13 your lawyer and to listen to what he tells you and to 14 do what he says so you don't dig a hole deeper and 15 deeper to the point where you can't get out of the hole 16 that you dug for yourself. 17 I'm going to give you time to get right with Okay? Because there are a lot of other claims that 18 are now going to be pursued as a result of certain 19 things that were said that were written in the public 20 domain and public by newspapers who were more 21 unknowledgeable than you because they wanted a 22 narrative to look good. Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 137 1 So we're going to take a deep breath and let 2 you talk with your lawyer, and we're going to come back 3 here another time and we're going to have the 4 interpreter help you out. 5 And hopefully, we'll focus on the narrow 6 issues that are remaining in this case after we hear 7 from your lawyer filing his paperwork for you after he 8 talks to you and you understand it, hopefully, and 9 agree to allow him to file it. 10 11 Okay? * * * * * (Whereupon, at approximately 3:33 o'clock 12 p.m., the taking of the deposition in the above- 13 entitled matter was concluded.) 14 15 16 17 18 19 20 21 22 Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 138 I have read the foregoing deposition, pages 1-137 inclusive, which contains a correct transcript of the answers made by me to the questions therein recorded. ___________________ _______________________ Date SAMINA GILANI Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654 139 * * * * * CERTIFICATE OF NOTARY PUBLIC I, COURTNEY A. SEBASTIAN, the officer before whom the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken stenographically by me to the best of my ability and reduced to typewriting under my direction; that said deposition is a true record of the testimony given by said witness; that I am neither counsel for, related to, nor employed by any of the parties to the action in which this deposition was taken; and further, that I am not a relative or employee of any attorney or counsel employed by the parties thereto, nor financially or otherwise interested in the outcome of the action. _____________________ COURTNEY A. SEBASTIAN COURTNEY A. SEBASTIAN NOTARY PUBLIC COMMONWEALTH OF VIRGINIA 7075456 MY COMMISSION EXPIRES FEBRUARY 28, 2022 Verbatim Reporting, LLC 5684 General Johnston Place Centreville, Va 20120 703 932 0654