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21 contract and the deposit, the first deposit, is

22 not done on time, what happen? He told me one

23 minute — one second after midnight the deal is

24 off.

25 Q But you didn’t ask him about the second deposit?

26 A I didn’t care. What’s the point to ask when the

27 contract cannot go through?

28 Q Right. So that’s why you said to Mr. Coombe what

29 happens if there’s a problem with the first

30 deposit?

31 A What happens there, yeah.

32 Q But you didn’t tell him you were talking about

33 this deal?

34 A No.

109 Allen Coombe (for Plaintiff)Cross-exam by Mr. Davison

8 Q Is it possible and you don’t recall or you recall

9 there was no discussion about that?

10 A It — it’s possible that there could have been a

11 discussion. I just — I just don’t recall any

12 specific discussion about deposits.


Ms.Hundley’s discovery transcripts page 80

9 MR. DAVISON: Oh, I see — while Ms. Hundley is looking, I’m just

10 going to mark this as the next exhibit. It’s an

11 e-mail from Cindy Cooper, sent April 11th, 2007, at

12 12:55, to a Joan, subject Lucy Hundley.

13 EXHIBIT 3: E-mail from Cindy Cooper, sent April 11,

14 2007, at 12:55, to a Joan, subject Lucy Hundley

15 MR. DAVISON: Thank you.

16 583 Q So you can see here that you did call somebody;

17 right?

18 A I — I don’t —

19 584 Q You don’t recall?

20 A Don’t recall, no.

Page 77

9 560 Q Marny. Okay. Is that your phone number? At the

10 time, was that your phone number?

11 A That’s a friend of mine’s phone number.

12 561 Q Is that how to get a hold of you?

13 A And he would get a hold of me, yes.

78 Lucy Hundley (the Plaintiff) (Recalled)Cross-exam by Mr. Davison

4 Q So that that couldn’t be the first information

5 that you had that the Garniers were unhappy?

6 A Well —

7 Q Right.

8 A — if I got this information, but I can’t say

9 exactly when I got this. Oh, this is the 11th.