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Deposition of Michael Imani

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Deposition of Michael Imani · · · · · · IN THE SUPERIOR COURT OF FULTON COUNTY · · · · · · · · · · · ·STATE OF GEORGIA · · , · · · · · · · · · · · · · · · · · · · · Civil Action · · · · · Plaintiff,· · · · · · · · · · File No. · · · · · · · · · · · · · · · · · · · · 2013-CV-236705 · · ·vs. · · ·MICHAEL K. IMANI, · · ·Individually, and THE · · ·NILE WELLNESS CENTER, INC., · · · · · Defendants. · · · · · · · · DEPOSITION OF MICHAEL K. IMANI · · · · · · · · ·February 6, 2014, 10:10 a.m. · · · · · · · · · · Hall Booth Smith, P.C. · · · · · · · · · 191 Peachtree Street NE · · · · · · · · · · · · · Suite 2900 · · · · · · · · · · · ·Atlanta, Georgia · · · · · · · ·Michelle R. Lowe, RPR, CCR-2748 . ·1· ·APPEARANCE OF COUNSEL: ·2· ·On behalf of the Plaintiff: ·3· · · · · · ·GREGORY F. HARLEY ·4· · · · · · ·Attorney at Law ·5· · · · · · ·BURR FORMAN LLP ·6· · · · · · ·171 Seventeenth Street, NW ·7· · · · · · ·Suite 1100 ·8· · · · · · ·Atlanta, Georgia· 30363 ·9· · · · · · ·404-685-4243 10· · · · · · ·[email protected] 11 12· ·On behalf of the Defendants: 13· · · · · · ·RICHARD SHEINIS 14· · · · · · ·Attorney at Law 15· · · · · · ·HALL BOOTH SMITH, P.C. 16· · · · · · ·191 Peachtree Street NE 17· · · · · · ·Suite 2900 18· · · · · · ·Atlanta, Georgia 30303 19· · · · · · ·404-954-5000 20· · · · · · ·[email protected] 21 22 23 24 25 ·1· · · · · · ·(Pursuant to Article 10(B) of the Rules ·2· ·and Regulations of the Georgia Board of Court ·3· ·Reporting, a written disclosure statement was ·4· ·submitted by the court reporter to all counsel ·5· ·present at the proceeding.) ·6· · · · · · · · · · MICHAEL K. IMANI, ·7· ·having been first duly sworn, was examined and ·8· ·testified as follows: ·9· · · · · · · · · · · ·EXAMINATION 10· ·BY MR. HARLEY: 11· · · · Q· · State your name for the record, please. 12· · · · A· · Michael Imani. 13· · · · Q· · Mr. Imani, I'm Greg Harley.· We just met. 14· ·I represent the plaintiff, , in the case of 15· · versus Imani and Nile Wellness Center.· We're 16· ·here today to take your deposition pursuant to 17· ·notice and agreement of counsel. 18· · · · · · ·I'll just get into a little bit of 19· ·background with you.· Can you give me your date of 20· ·birth, please. 21· · · · · · ·MR. SHEINIS:· Greg, are we going to 22· ·reserve objections, other than those going to the 23· ·form of the question -- 24· · · · · · ·MR. HARLEY:· That's fine with me. 25· · · · · · ·MR. SHEINIS:· -- and responsiveness of the ·1· ·answer? ·2· · · · · · ·MR. HARLEY:· Sure. ·3· · · · A· · 2/23/61. ·4· ·BY MR. HARLEY: ·5· · · · Q· · Where do you currently reside? ·6· · · · A· · Atlanta, Georgia. ·7· · · · Q· · Can you give me an address. ·8· · · · A· · 221-6 16th Street, Atlanta, 30363. ·9· · · · Q· · And how long have you lived there? 10· · · · A· · Approximately six, seven years. 11· · · · Q· · Okay.· Where did you live before that? 12· · · · A· · 170 Boulevard, Southeast. 13· · · · Q· · That's in Atlanta as well? 14· · · · A· · That's in Atlanta as well. 15· · · · Q· · How long have you resided in Atlanta? 16· · · · A· · Approximately 30 -- 30-plus years. 17· · · · Q· · Where were you born? 18· · · · A· · Mount Vernon, New York. 19· · · · Q· · Are you married, Mr. Imani? 20· · · · A· · I am. 21· · · · Q· · Who are you married to? 22· · · · A· · Deborah Imani. 23· · · · Q· · How long have y'all been married? 24· · · · A· · '89 to the present.· 1989 we got married. 25· · · · Q· · Do y'all have any children? ·1· · · · A· · We do not. ·2· · · · Q· · Were you ever married to anybody before ·3· ·Deborah Imani? ·4· · · · A· · No. ·5· · · · Q· · Okay.· Does she reside with you here in ·6· ·Atlanta? ·7· · · · A· · She does. ·8· · · · Q· · All right.· Are you under any medication ·9· ·that would affect your ability to testify truthfully 10· ·today? 11· · · · A· · Don't take any medication whatsoever. 12· · · · Q· · Have you ever been deposed before? 13· · · · A· · No.· It's the first time. 14· · · · Q· · Have you ever been a party to a lawsuit 15· ·before? 16· · · · A· · No. 17· · · · Q· · All right.· How about has Nile ever been a 18· ·party to a lawsuit? 19· · · · A· · No. 20· · · · Q· · All right.· You might -- she may have 21· ·better ears than me.· You might need to speak up 10 22· ·percent, not a ton. 23· · · · A· · All right. 24· · · · Q· · Have you ever testified in court before? 25· · · · A· · I have not, no. ·1· · · · Q· · Have you ever given a deposition before? ·2· · · · A· · I have not. ·3· · · · Q· · Okay.· Well, in that case, I'm sure that ·4· ·your attorney gave you a little bit of background, ·5· ·but I'll throw some in there as well. ·6· · · · · · ·If at any point you don't understand a ·7· ·question, feel free to ask me to clarify it.· If you ·8· ·do, I'll be glad to try to do so. ·9· · · · A· · Okay. 10· · · · Q· · Otherwise, I'll assume you've understood 11· ·it. 12· · · · A· · Okay. 13· · · · Q· · If possible, let me get the question out 14· ·of my mouth before you answer. 15· · · · A· · Yes. 16· · · · Q· · And try to avoid the shaking of the head 17· ·and that type of stuff.· It's much easier for her to 18· ·take down verbal responses instead of that and the 19· ·uh-huhs and the uh-uhs. 20· · · · · · ·Did you do anything to prepare for this 21· ·deposition today? 22· · · · A· · I'm not sure I understand what you mean. 23· · · · Q· · Well, did you read any documents to get 24· ·ready for the deposition? 25· · · · A· · Read any documents?· When you say ·1· ·documents -- ·2· · · · Q· · Documents that have something to do with ·3· ·this case.· Did you read them in order to kind of ·4· ·jog your memory on what this case is about? ·5· · · · A· · I read the interrogatories -- ·6· · · · Q· · Yeah. ·7· · · · A· · -- that I think your firm sent over. ·8· · · · Q· · Any other documents -- when was the last ·9· ·time that you looked at the interrogatories? 10· · · · A· · A couple weeks ago. 11· · · · Q· · So you didn't go through anything in the 12· ·last couple of days, in terms of reading material? 13· · · · A· · No. 14· · · · · · ·MR. SHEINIS:· I will add, I've cautioned 15· ·Dr. Imani that anything we've discussed is 16· ·attorney-client-type privilege.· We've of course met 17· ·and gone through things. 18· · · · · · ·MR. HARLEY:· Right. 19· ·BY MR. HARLEY: 20· · · · Q· · Without getting into any of your 21· ·communications with your lawyer, did you, in fact, 22· ·meet with your lawyer in anticipation of this 23· ·deposition? 24· · · · A· · Yes. 25· · · · Q· · When did y'all meet? ·1· · · · A· · Yesterday. ·2· · · · Q· · For how long? ·3· · · · A· · It was about -- it seemed like about an ·4· ·hour and 15 minutes yesterday.· The day before we ·5· ·maybe spent an hour-and-a-half. ·6· · · · Q· · So two separate meetings? ·7· · · · A· · Yeah. ·8· · · · Q· · All right.· Anything beyond what we've ·9· ·talked about, in terms of getting ready for the 10· ·deposition? 11· · · · A· · That's it. 12· · · · Q· · Okay.· I want to go through your education 13· ·and work experience beginning with high school, if 14· ·we could. 15· · · · A· · Sure. 16· · · · Q· · I guess start off -- tell me, did you go 17· ·to high school? 18· · · · A· · Yes. 19· · · · Q· · Where did you go? 20· · · · A· · Went to Glen Hills High School in Augusta, 21· ·Georgia. 22· · · · Q· · And did you graduate from there? 23· · · · A· · Yes, sir. 24· · · · Q· · What year did you graduate? 25· · · · A· · 1979. ·1· · · · Q· · Okay.· And so from there, tell me, what ·2· ·did you do next? ·3· · · · A· · What'd I do next?· The next thing I did ·4· ·after -- after high school graduation I went to the ·5· ·military, the Naval Reserve; so you went to boot ·6· ·camp and then you went to a training program for the ·7· ·Navy after that. ·8· · · · Q· · Are you still in the Reserve? ·9· · · · A· · No. 10· · · · Q· · Did you ever obtain any -- what was the 11· ·highest rank you attained? 12· · · · A· · I think it was petty officer third class. 13· ·It's been so many years, because I did six years and 14· ·I was out. 15· · · · Q· · I apologize for the ignorances.· The 16· ·Reserve is more of a part-time deal; is that right? 17· · · · A· · At that time in the late '70s and early 18· ·'80s it was part-time.· It's changed since that 19· ·time. 20· · · · Q· · Okay.· What did you do in Reserves? 21· · · · A· · I was a CB, construction battalion. 22· · · · Q· · Okay. 23· · · · A· · I was attached to a construction battalion 24· ·unit. 25· · · · Q· · Anything that you did in the Reserves that ·1· ·relates to the digestive system or health, that type ·2· ·of thing? ·3· · · · A· · No.· CBs don't do anything like that. ·4· · · · Q· · Okay.· I take it from approximately '79 to ·5· ·'85 you were in the Reserves. ·6· · · · A· · I was in Reserves for about that, yes. ·7· · · · Q· · Were you honorably discharged? ·8· · · · A· · Yes. ·9· · · · Q· · What else were you doing during that time 10· ·frame? 11· · · · A· · I was going to college. 12· · · · Q· · All right.· And where were you going? 13· · · · A· · West Georgia College, Carrollton, Georgia. 14· · · · Q· · And did you declare a major there? 15· · · · A· · I did.· Psychology and biology, I think. 16· · · · Q· · From when to when did you attend West 17· ·Georgia? 18· · · · A· · The fall of 1980 through the spring, I 19· ·believe, of '85. 20· · · · Q· · Did you obtain a degree from there? 21· · · · A· · I did not. 22· · · · Q· · And why did you cease going to college at 23· ·West Georgia prior to obtaining a degree? 24· · · · A· · My mother got sick.· I was the oldest of 25· ·five kids; so I needed to stop school and try to ·1· ·help out. ·2· · · · Q· · Okay.· And was she back in Augusta? ·3· · · · A· · Yes. ·4· · · · Q· · And when you were at West Georgia were you ·5· ·living in Carrollton? ·6· · · · A· · Yes.
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