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other insurance on the home, which is contained in Exhibit 5
-- or account 524 and Exhibit 116 again, and I’ve allocated
it equally to each one of these business activities based on
conversations with Mr. Kurzet on -- on his purpose for
purchasing that additional insurance.
THE COURT: This is umbrella liability on -- on their
activities or on the home, the Orange County --
THE WITNESS: It’s on -- my understanding, Your Honor,
is it’s activities that happen at four -- essentially four
locations: the home in Orange County, the timber farm, the
investment property in Tahiti, and the industrial building
in Orange County, and I simply allocated it equally to each
of those.
THE COURT: Not the home, not the Orange County home?
THE WITNESS: It does include the Orange County home.
THE COURT: Where is that on your schedule?
THE WITNESS: It would be the consulting.
THE COURT: Consulting you labeled as "home"? It’s in
fact the home, and you labeled it consulting? How do you
get the "consulting" label for the home in Orange County?
THE WITNESS: Because that’s where the activity was
carried out.
THE COURT: I’m missing something here. There were
many activities carried on at the home --
THE WITNESS: Right.
THE COURT: -- 20 percent of which allegedly is
consulting and business related, and 80 percent of which is
personal?
THE WITNESS: Right.
THE COURT: So where -- where is the personal aspect of
the allocation? Where is the allocation --
THE WITNESS: We have not --
THE COURT: -- of the umbrella liability to the
personal activities?
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