Murdaugh Murder Trial: Witness spars with defense during cross examination

[00:00:00] Speaker 1: You testified at length to the state grand jury based for this similar testimony you're giving her today, is that correct? [00:00:10] John Taylor: The testimony I gave today is included in what I said to the state grand jury, yes. [00:00:15] Speaker 1: And it seems like the gist of this is that you were suing Alex Murdoch, who you believed was underinsured for this incident, and you were going to go after his personal assets, and that was going to put some financial pressure on him. Is that correct? [00:00:35] John Taylor: Probably not exactly. I mean, I don't mean to quibble with you over the words you used, but I don't think it was financial pressure because I didn't – I mean, I was holding him personally accountable. I was insistent that he pay. I didn't see how a payment plan on a settlement would put any pressure on Alex. I think it was sort of a deal that he couldn't turn down from where I sat. [00:01:01] Speaker 1: But you were asking for money. Oh, sure. And the inquiry here today is about money, his money, his finances, correct? [00:01:09] John Taylor: I don't think so, but it certainly concerns his money. [00:01:14] Speaker 1: And you're anticipating you're going to go to trial, is that correct? Yes. You're going to go to trial and get a verdict against Alex, correct? That was what you thought, where this was going? [00:01:28] John Taylor: No, I mean, I didn't see how any reasonable person wouldn't settle the case, especially Alec. So I expected the case to settle. Ninety percent of cases settled. Maybe 99. But if we had to try it, yes, we were going to try it. [00:01:42] Speaker 1: And if he were unable to offer more money, then your expectation on, say, on June 7th, you know, before these murders, your expectation was, if he doesn't offer more money, we're going to trial. Any money. Right. It was no money. No money had been offered. So your expectation then was, we're going to trial. [00:02:02] John Taylor: If you offer me no money in a case that I'm pursuing against you, then the response is, we are going to trial. [00:02:11] Speaker 1: And you were pretty far from trial on June 7th, 2021, were you not? No. You believe you were close to taking it to trial? [00:02:19] John Taylor: There was an urgency because John Taylor knew that he had about a year to live. And we were going to try that case, my expectation was, early fall, late summer. [00:02:34] Speaker 1: You expected to try the boat case in the summer of 2020, late summer of 2021? August, September, October, sometime in that time. You felt like you were only two or three months away from trial? Sure. Even though we had all these pending motions that hadn't even been heard, including what venue to have? [00:02:55] John Taylor: I had tried the case two times with a Buford jury during COVID. I was ready to go to trial. [00:03:04] Speaker 1: On that day, on June 7th, you hadn't even yet asserted a negligent entrustment claim against Alex A. [00:03:11] John Taylor: Well, I had with John Tiller. John Tiller knew and had agreed to the amendment. There were a number of things that Alex Counsel had agreed to, including knowing that there was substantial punitive evidence in the case. [00:03:23] Speaker 1: And at that time, you hadn't even asserted that claim to the court. That wasn't before the court, was it? That was just a conversation with John Tiller. [00:03:32] John Taylor: That's the conversation that mattered, because John Tiller would be the one who would object to the late presentation of the evidence, the late presentation of an expert, and he had agreed to all those things. But he had objected to the financial discovery you asked for. Well, there was an objection posed, correct? But he did object to that. When that answer was given in October or September of 2020, it was an objection. [00:03:57] Speaker 1: And the hearing that motioned to compel the financial detail, the testimonies, that's just one of many motions that needed to be heard. Is that correct? Correct. There were many motions that had piled up and needed to be heard. There were several. There were several. Do you remember what they all were? [00:04:15] John Taylor: There was a motion to change venue. There was a motion to compel against Parkers. Parkers had one or two motions. Some of the motions got resolved, one of which was this motion to assert admiralty in the case and with the agreement that I would amend to assert your neglect and trustment claim to get in all of the evidence that they knew I had. That was resolved that way. [00:04:48] Speaker 1: You've had a lot of motions practiced in this case with Parkers, haven't you? More so since the murder. But has that motions practiced with Parkers been about the murders of Maggie and Paul? [00:05:01] John Taylor: Well, I mean, it's about it in the sense that it certainly created a lot of additional issues to deal with, but not specifically. [00:05:13] Speaker 1: There was a lot of motion practice about allegations of leaking a video from mediation, for example, correct? [00:05:19] John Taylor: I don't know about a lot, but I had filed a motion that I ultimately withdrew. [00:05:26] Speaker 1: And you believe that you were going to drag Parkers to a trial within two or three months, late summer of June 7th, even though we have all these fairly preliminary motions that haven't been heard, change of venue, asking to amend pleadings, motions to compel discovery. [00:05:47] John Taylor: Yeah, maybe you've never tried a civil case. So when COVID happened and everything was shut down for two months, I got my case together. My case is not dependent on, if I'm forced to try it, the bank institutions where he has accounts. My case is not dependent on the leaked video. That's a separate matter and it ended up being a separate lawsuit. So the answer is yes. [00:06:15] Speaker 1: I was ready to try my case. And you didn't need, for example, an answer on the motion to compel that was pending against Parkers. You didn't actually need any of that stuff to go to trial against Parkers. Is that what you're saying? [00:06:26] John Taylor: You're talking about the percentage of financials, I mean percentage of sales that alcohol made up in his profits? No, I didn't need that. Well, let's pick that up. I wanted it, but I didn't need it. [00:06:58] Speaker 1: Should he have been marked as defendant certificate 82? Recognize that. [00:07:05] John Taylor: It appears to be my motion to compel against Greg Parker's company. [00:07:18] Speaker 1: Can we pull up 82, please? And this is the document on the screen that I've handed to you. So we have, it's not just a, buried in here is some requests for financial information, but you're requesting answers to request for production 3, request for production 11, request for production 16, request for production 17, which is financial information, request for production 18, request for production 19, request for production 20, request for production 22, request for production 19, request for production 19, request for production 19, request for production 19, request for production 19, request for production 19, request for production 19, request for production 19. It seems like it's quite a bit of discovery you're demanding from Parkers in this motion. [00:08:19] John Taylor: Which I would have had the answer to on June 10th. Either I was getting it or I wasn't getting it, but my case wasn't dependent on these things. They may have helped my case, they may have put pressure on Parker's camp like I was trying to put pressure on Ellick, but it wasn't, the trial wasn't dependent on these things. [00:08:41] Speaker 1: And turning to the motion to compel Alex, first, do you believe that the Judge Hall's initial request in May to go forward to pending motion hearings was telegraphing a ruling on that specific motion, or do you believe that that was him looking at these motions piling up and wanting to get some movement? [00:09:09] John Taylor: Yeah, I think so. No, there's nobody in the courtroom, maybe even including me, that wants the case resolved more than Judge Hall. [00:09:23] Speaker 1: When the late Mr. Tiller asked for a continuance, you don't believe that was any kind of stalling tactic, do you? [00:09:34] John Taylor: No. [00:09:35] Speaker 1: That was a legitimate health-based concern. [00:09:38] John Taylor: And if you read my emails, you would see that I immediately agreed to it. John Tiller was my friend. [00:09:50] Speaker 1: With regards to what you're asking for from Alex, let's maybe pull that up. I believe the state is already off. Mark, this is an exhibit, but this is the motion to compel. Can we pull up 80, please? It's already been shown to you, but I'll show you when it could mark this. It's 80 for your reference. So this is asking for an order of compelling production on interagatories 9 and 10, and then a set of supplemental interagatories and supplemental requests for production. Is that correct? [00:10:49] John Taylor: It is. [00:10:50] Speaker 1: And if we turn to... [00:10:55] John Taylor: And 9 and 10 are important as well. We didn't cover that, but I'm happy to speak to 9 and 10 because, you know, 9 and 10 asked ELEC about... [00:11:03] Speaker 1: No one's asked you about 9 and 10. And we'll get to it, but first let's turn to answers to the first supplemental interagatories. This is the first page of Exhibit B. So we can see what it is that is being asked for. There's no D in mine, I'm sorry. Oh, B. It's the first page of what's Exhibit B in here. It's right there. That's it. It's the first page after the motion, so it'd be page 9 of the PDF. So, Mr. Waters asked you about this list of all checking, savings accounts, retirement accounts. And then, you don't have to highlight or expand this stuff. I'll start in the number two, all stock certificates, and we go to the next page. All property, interest of property of every kind whatsoever from February 24, 2019 forward. All life insurance policies, four or five, all personal financial statements submitted to any bank, etc. Profit sharing plans, pension plans, etc. Doesn't this look like supplemental discovery after you get a judgment? Supplemental proceedings? [00:12:26] John Taylor: I've never had been involved in supplemental proceedings. No, I don't think so. This is what my people needed answers to before they would agree to take anything that ELEC would have offered. [00:12:38] Speaker 1: In tort cases against individuals, in this case, a negligence in entrusting a boat in an alcohol-related incident, before there's even motions for summary judgment, before there's any consideration of whether a case has been made for punitive damages, do you typically get this level of financial discovery of defendants? [00:13:01] John Taylor: I think so. [00:13:01] Speaker 1: I think the judge ultimately agreed to give it to me. He agreed to give it to you? Sure. But I thought the hearing didn't happen. [00:13:10] John Taylor: Well, you thought wrong. There's a lot of papers, so maybe you got confused. He granted this motion? I think so. You want to see the order? [00:13:17] Speaker 3: Yeah. [00:13:22] John Taylor: It's the record. It's October 7, 2021. [00:13:34] Speaker 1: Kirk, if I'm wrong, what you've highlighted here is that Mr. Tiller, because the circumstances beyond his control, unable to gather, provide necessary information, answer request in our auditories, once the information is made available to Attorney Tiller, the court will schedule a hearing. If necessary. You forgot the last part. If necessary. If Mr. Tiller, the attorney on the case, can from his own client get the information. This is no way says that the court granted this motion, does it, sir? Only to you, I think. [00:14:07] John Taylor: I mean, it's clear that John said that Ellick was unavailable because he was in rehab at the time. He couldn't get the material. He's going to get the material and the judge ordered to get the material. And if we need to schedule a hearing, because you don't have the answers that you want, Mr. Tinsley, then we'll reschedule the hearing. [00:14:27] Speaker 1: This is an order that says the court will schedule a hearing on this motion to compel if necessary. It's not granting the motion to compel, sir, is it? [00:14:35] John Taylor: Oh, I think so. I think if he was just going to deny it as you suggest, then it would have just said denied. Or it's premature. [00:14:42] Speaker 1: If it was granted, wouldn't he say granted? [00:14:44] John Taylor: Well, I think that's what it says. It's a practical matter when parties have discovery motions, oftentimes, like Ellick in his own statement said he was working on getting the answers. The reason is you give the answers because you don't want to face what could happen in the argument with the judge. So my point is that if the judge were going to say it's premature, you're not going to get it, it's denied, any of the things you suggested in your motion, he would have said that. That's not what he did. That's not what happened. That's not what happened. [00:15:31] Speaker 1: You asked for financial information in the motion that was pending against Parker's that was also going to be heard on June 10th. [00:15:48] John Taylor: It was different and for different reasons. [00:15:52] Speaker 1: You asked for alcohol sales, correct? [00:15:56] John Taylor: What I explained to Judge Hall was is that they say he's broke. And before my – [00:16:02] Speaker 1: No, no, no, sir. I'm asking what you asked for from Parker's. I'm pretty sure that wasn't they say he's broke. What were you asking for from Parker's? [00:16:11] John Taylor: I asked for, among other things, the percent of alcohol sales that made up his net profit, I believe. [00:16:18] Speaker 1: And this was like a dram shop action against Parker's, correct? They sold the alcohol. [00:16:22] John Taylor: Like a dram shop action, yes. [00:16:24] Speaker 1: And did you get a ruling on that request for that financial information from Parker's that was going to be heard on that June 10th? They just – along with all these other motions that had piled up in a case that apparently wasn't moving very quickly. [00:16:42] John Taylor: Well, I understand you don't want to acknowledge what I've handed you, but – [00:16:46] Speaker 1: Sir, I asked you what the ruling was on the motion from Parker's. [00:16:50] John Taylor: It was very limited, and as it related to the percent of sales of alcohol that made up his profit, it was premature. The judge ruled, unlike he did in that order I handed you, that it was premature at the time. Why was it premature? Well, the difference between Parker's and Ellick is, is that Ellick had – and his lawyers had 25 videos of alcohol. They had the punitive damages evidence. You didn't see that with Parker's. It was just a straight-up transaction in sale. So to the extent you're suggesting that there wasn't this evidence, there were these mere allegations of negligent parenting, that wasn't the case. That wasn't the argument. You didn't have to present that evidence to the court? I didn't have to present it to the court. That's what you don't understand. John Tiller knew about it. John Tiller is the one who's responding because John Tiller knows ultimately he's going to be in front of the judge. [00:17:41] Speaker 1: So you're saying the court was granting your motion, though obviously it was saying there might be a hearing on the motion, and maybe at that hearing you would present some evidence and support. I don't think that's what it says at all. I mean, you asked for financial information for Parker's. It was deemed premature because it related to punitive damages, correct? [00:18:06] John Taylor: It was different than the motion that it related to Ellick. [00:18:10] Speaker 1: Because the law is how much money you have is a factor for punitive damages, correct? [00:18:17] John Taylor: Well, you're making statements of law. I'm telling you what was happening. And what was happening was is that Ellick's lawyers knew what the evidence was. They knew what the amendment was going to be and the allegations. And he knew ultimately he was going to be back in front of Judge Hall making some ridiculous argument that I appear you're suggesting now. [00:18:39] Speaker 1: And, again, the gist of this is that there was perhaps going to be this judgment day, I think is a term the state has used. But that was going to be trial, right? That was going to be the verdict. That was going to be judgment day, not this motion hearing where there's a pile of motions that have piled up and we saw the one that asked for financial information was deemed premature. [00:19:05] John Taylor: Not at all. Well, you know, what was going on is, as I've said a number of times, Danny Henderson was very involved. Danny Henderson was a shareholder. Before I would have gotten the bank account information, before I would have seen the records, Danny Henderson would have seen those records. And I've seen the records. I've seen all the bank statements now. It would have been apparent to Danny Henderson, and I believe it would have been apparent to me what Ellick had been doing. So that's the judgment day is the discovery. And there were a lot of threads that were being pulled, and it was subject to unraveling at any moment. And if those records were disclosed, if Danny Henderson reviewed those records, he would have known there's no way Ellick's getting these checks. There's no way these checks are going to forge. There's no way that this money should be transferred. [00:19:51] Speaker 1: Even if, hypothetically, had this hearing on the 10th, and you got a different ruling regarding Alex Murdaugh than you got against Parker's, that for some reason it's not premature to him, isn't it true all you could have gotten would have been a net worth statement, financial statement? Not even remotely close. Isn't that, in your opinion, there's no case law out there saying that's what you get, you know, that's the measure for punitive damages net worth. There's no such case, in your opinion, as an attorney. [00:20:25] John Taylor: I had seven circuit court orders where the circuit court had ruled that you don't bifurcate discovery, that it wouldn't be proper to have denied the motion, and then what are we going to do? We're going to try the case, and suddenly we're going to stop the trial and go and do the discovery? No. And so I had seven circuit court orders that I handed up to Judge Hall that supported our position. I think that that's what Judge Hall did in his order. And, again, you know, the issue is not that complicated. It's does he have the ability to pay? Is he broke such that these people should accept this pitiful offer if he could cobble it together? [00:21:06] Speaker 1: But, sir, that's not what you get on a motion to compel, is it? Right. You just said ability to pay so your client can make a decision on whether to accept a settlement offer, but that is not what the motion to compel is about, is it? It's about evidence for trial. That's the legal standard, is it not? [00:21:23] John Taylor: No. The motion to compel was about putting pressure on ELEC. I didn't really give two cents about whether or not he ultimately had money because I knew he had money. I didn't need those things. The fact that he didn't want me to have them is the reason that I'm pushing it. I just didn't know why he didn't want me to have them at the time. I do now. [00:21:41] Speaker 1: So the motion to compel was to put pressure on ELEC. It wasn't about an expectation the judge was actually going to give you this stuff on June 10th? [00:21:52] John Taylor: If you're a good plaintiff's lawyer, everything you do in a case is to put pressure on the other side. [00:21:58] Speaker 1: But the expectation of the outcome of a hearing on June 10th was not that you're going to get to launch a full-scale forensic audit because you had a conversation with someone who said, whose lawyer said, oh, he's broke, and you didn't believe it. Not at that stage of the litigation, sir, is it? That's not what's going to happen, is it? [00:22:16] John Taylor: I don't think you need a full-scale forensic audit for something a five-year-old could see. So, no. [00:22:25] Speaker 1: You wanted pre-trial ability to pay discovery to inform whether or not to accept a compulsive discovery, compelled, so that your client could decide whether or not to take a settlement offer. [00:22:40] John Taylor: I know you don't like the answer, but I'm telling you, I did not care about the answer. What I cared about was putting pressure on ELEC. I think that your assessment of the law is wrong, and I didn't really care whether I got it at the end of the day. I knew he didn't want me to have it. And so that's what I was doing was putting pressure on him. It would have suited me fine not to have ever gotten anything and to leverage it into a settlement and go on about my way. But that's not what happened. [00:23:07] Speaker 1: So the motion was not about obtaining information that may have been relevant at trial. It was about getting information to inform whether or not your client would take a settlement offer. [00:23:25] John Taylor: What I told Judge Hall was they say he's broke. My people have lived in Hampton their entire lives. They do not believe he's broke. If he's broke, we need to open the books and let them see it so that they can then form an informed opinion about what they should do. It didn't have anything to do with the trial. It had to do with the case and resolving the case. [00:23:54] Speaker 1: And then I think we briefly touched on Satterfield. Just to be clear, they came to you the first time they came into your office, was September 21? [00:24:05] John Taylor: It's either late August or early September, but very early September. And since now I'm thinking that since the roadside shooting, whatever that ridiculousness was, was the 4th, it could have been August. [00:24:24] Speaker 1: But it was after, well after June 7th. It was after June 7th. Thank you. If the hearing had gone forward on June 10th, this was a Thursday, what outcome did you expect? [00:25:20] John Taylor: The same one that we got when it went forward. The judge hadn't seen. [00:25:25] Speaker 1: Well, I mean, the outcome wouldn't have been the court will schedule a hearing. I mean, if the hearing had gone forward, what outcome would you have expected? [00:25:34] John Taylor: Well, you know, now I know that Ellick was working on Monday to get the information together. If the objection was sufficient, there's no reason he would be getting the information together on Monday. So I could have gotten the information, but since that didn't happen, if we had argued it, I think I would have had the same outcome. [00:25:57] Speaker 1: Because he didn't get... Let me just make it a little simpler. Would the court have issued an order, right? Some order would have issued on the motion. Yeah, I would expect an order to issue. Break it down. An order would have issued at some point later, and what, if it were granting your motion, what would that order say? I think it would say the same thing as... Well, sir, that says a motion hearing will be scheduled if necessary. It obviously wouldn't say that. So what would the order granting the motion say? [00:26:28] John Taylor: Look, again, what it says is that once Mr. Tiller gets the information from Ellick, gives it to me, if necessary, if I deem it insufficient, then we'll have another hearing and we'll argue about it. So that's what I expect. [00:26:45] Speaker 1: It's a voluntary disclosure, and then if you deem that insufficient, we go have a motion to compel hearing? [00:26:49] John Taylor: That's the way motions to compel go every single day. [00:26:52] Speaker 1: So, if you deemed it insufficient, if the court actually had to issue an order on your motion, you would have gotten his, would the law firm books have been open to you? I don't know that I'm asking for the law firm books. I'm asking for Ellick's accounts. Right. Would you have gotten, what, a financial statement? No. The court would have ordered every account detail listed to you, all his personal accounts? Just because you asked for it to inform a settlement decision? [00:27:25] John Taylor: I was asking for the names of the institutions where he had accounts. I told you that. [00:27:29] Speaker 1: Right, to subpoena. [00:27:31] John Taylor: Sure. But that's different. [00:27:33] Speaker 1: And that would have been resisted, and there would have been further litigation. This process would have taken some time, wouldn't it, if it was resisted, right? I'm not sure what was resisted. If you got the names of the banks and issued subpoenas, there would be motions to quash the subpoenas. [00:27:48] John Taylor: Well, you know, you're speculating the same as you're asking me to speculate. I'm trying to talk to you about what the judge actually did and what was actually in front of the judge. I get you don't want to talk about that, but, you know, we can speculate any number of things could have happened. [00:28:04] Speaker 1: That at some point in the future, you would maybe get a voluntary disclosure, and if you didn't like it, then the motion would be heard. The motion to compel. That's what you say it says, right? [00:28:16] John Taylor: Well, if we had shown up and they had made the argument that you're advancing here, then maybe in this imaginary world, there's things that didn't happen. The judge would have actually ruled on it. We would have a ruling on whether or not it was relevant, whether or not I was entitled to it. It would have been relevant for Alex, but not for Parker's. Look, there are different things that are being asked here. And to your point, if it were the same, why didn't the judge sign the same order that you say he would have done? That's not what he did. At the same time we argued the Parker's motion, we argued the motion for Ellick. And so he came to two different conclusions on those issues. One is he said it's premature. The other is that Mr. Tiller is going to get the information, give it to the plaintiffs, and if it's not sufficient, we'll have another hearing. I don't know how you can be any clearer than that. [00:29:15] Speaker ?: Thank you. [00:29:43] Speaker 1: So just maybe you can agree on this. If the hearing had gone forward, June 10th, that day would not have been some sort of judgment day when everything unravels, correct? There would have been further activity, maybe a voluntary disclosure, an analysis by you, whether it's adequate, another hearing if you thought it wasn't, maybe some penance would go out. There was going to be some time after that. Is that fair? [00:30:43] John Taylor: I think it's fair to say that there wouldn't have been an explosion on June the 10th, but the fuse was lit the moment that that information became available in the case. Not as much to me, but certainly to Danny Henderson, who would have, like the phone records, like some of the other materials, reviewed it before I got it. And Ellick would have known that. [00:31:10] Speaker 1: I mean, in that analogy, aren't you really saying that the fuse was lit when you were going after his assets, and that fuse is going to go down until trial because you're going to go to trial against him, and that's when the fuse would burn down? [00:31:26] John Taylor: I think the fuse was lit when he started stealing money. Yeah. [00:31:31] Speaker 1: So it wasn't lit on, it wasn't going to be lit on June the 10th. [00:31:36] John Taylor: It was certainly getting a lot more oxygen. [00:31:38] Speaker 1: Right, but it was lit way before, and it was going to keep burning well after June the 10th. [00:31:43] John Taylor: I don't know about well after, but it wouldn't have been Judgment Day on June the 10th, but he would have known it was beginning to unravel. Not Judgment Day. [00:31:56] Speaker 1: No further questions. [00:31:58] Speaker 3: Yes, sir. And that's really the point, isn't it, though, that had that hearing taken place on June 10th, 2021, that it could potentially set in motion or was going to set in motion a process that ultimately would not have ended until there was either settlement or disclosure of that information, correct? [00:32:19] John Taylor: I believe so. [00:32:21] Speaker 3: And so just the fact of that hearing taking place, and whether it's an order or representations by the defense or whatever it is, that process, if it occurs, starts and it has an inevitable conclusion, correct? [00:32:33] Speaker 1: Objection. There's only one objection, y'all. Leave. [00:32:37] Speaker 3: I'm going to leave the witness. If the hearing takes place on June 10th, 2021, what is the net effect of what could happen at that point? [00:32:49] John Taylor: The discovery of everything he's done. [00:32:52] Speaker 3: Whether it happens that day or some point in time. [00:32:55] John Taylor: Correct. [00:33:00] Speaker 3: You had filed this motion to compel, or had you filed this motion to compel because you had been advised supposedly that Al was broke and you didn't believe it? Exclusively for that reason. And you believed that if he was broke, he had to be hiding assets? [00:33:18] John Taylor: And if he were hiding assets, he didn't want me to discover it, which would be the pressure point. [00:33:30] Speaker 3: Were you merely asking for a financial declaration at this June 10th, 2021 hearing? [00:33:36] John Taylor: No, I was, it's broader than that, but I wanted the institutions because I knew I couldn't trust the number I would have gotten. From Alec? From Alec. [00:33:46] Speaker 3: You were asked a little bit about having not pledged certain theories yet at this point in time, such as negligent and trustment. Can you explain a little bit about why that was, if that was still out there? [00:33:58] John Taylor: It was only out there in the sense of the pleadings that were on file. I mean, we, John Tiller had already agreed to the amendment. It was already coming. I had shown him the videos a long time before that of alcohol, the Facebook, social media, likes of Paul consuming alcohol, having alcohol. So, only on the documents that were filed. [00:34:27] Speaker 3: Sir, were those issues, though, in play in your conversations with the defense? I'm sorry? Were those issues already in play in your conversations with the defense? I'm not quite following you. [00:34:38] John Taylor: Which issues? [00:34:40] Speaker 3: Additional theories of liability that might not have been filed. Oh, absolutely. [00:34:43] John Taylor: No, I mean, those were, all I'm saying is, is that the black ink wasn't on the white paper, but John Tiller knew, we had discussed, these are the issues. [00:35:07] Speaker 3: I'm going to hand this back to you, but I'll show you what's been marked as states 407, so you can recognize that. [00:35:32] John Taylor: Yes, this is the order that I handed, whatever that lawyer's name was. [00:35:37] Speaker 3: Mr. Barber? [00:35:38] John Taylor: Yes. [00:35:39] Speaker 3: Okay. And that's from October of 2021, is that correct? [00:35:52] John Taylor: It is. [00:36:00] Speaker 3: You had previously testified that $1 million, you know, was not really, was not going to be enough, at least prior to the murders, is that correct? [00:36:12] John Taylor: Correct. [00:36:14] Speaker 3: Had you come up with a number that had been conveyed that was far, far in excess of that? A demand to ELEC? Yes. Yes. And that also included signing over Moses-Ellen and Edistone? It was an option. As well as a payment plan? [00:36:30] John Taylor: Payment plan was an option. I mean, it was, you could pay this amount, you can sign over these properties, work out a payment plan on the balance. I didn't care how we got it done. It was just a matter of him doing it. [00:36:44] Speaker 3: Was the payment plan an option because you believed that he still would have a lucrative law practice from which he could generate money to pay your clients? Yes. Thank you, Your Honor. [00:36:57] Speaker 1: Anything further? Nothing, Your Honor. [00:37:00] Speaker 3: Thank you. Thank you, Your Honor. Step down.