Q.  What is your home address?
A.  888 Blossom Boulevard, Sacramento, California 98888
Q.  Do you own that home?
A.  Yes, I do.
Q.  But you are still paying a mortgage, right?
A.  Oh, yes, I am.  I meant I'm buying it.
Q.  How is title held to that house?
A.  Under my name, Virginia A. Lathan.
Q.  What is your monthly mortgage payment?
A.   880.34.
Q.   Do you know how much of that mortgage payment, per year, is applied to the interest on your residence?
A.  I would have to look that up.
Q.  Would it be the amount set forth in your income tax return for last year?
A.  Yes.
Q.  Do you have a copy of that document?
A.  Yes, but not with me today.
Q.  Will you give a copy of your tax return for last year to Ms. Hillsmith, your attorney?
A.  Yes.
       MS. TRESSFORD:  After you get that return, will you send a copy to my office?
       MS. HILLSMITH:  Sure.
Q.    BY MS. TRESSFORD:  Do you know what the fair market value of your home is?
A.  I believe it's about a hundred.
Q.  A hundred what?
A.  Oh, a hundred thousand.
Q.   How much did you purchase it for?
A.   A hundred thirty thousand.
Q.   That's not good.
        Was the home recently appraised for that amount, or is that just an estimate on your part?
A.   No, it was appraised.
Q.   By whom?
A.  A real estate agent from Soxen and Yapper Realty.
Q.  So that appraisal wasn't done by a certified real estate appraiser;  it's only a comparable done by a real estate sales agent?
A.  Yes.
Q.  Yes what?
A.  Yes, it's a comparable.

Q.  Did you put a down payment on that home?
A.  Yes, I did.
Q.  How much was the down payment?
A.   I don't remember.  I know my dad lent me some money. 
Q.  Did you repay your dad?
A.  I was in the process of repaying him before he slipped into the coma, after his accident.
Q.  Does your dad have a conservator?
A.  Yes, I'm the conservator
Q.  Let me get this straight.  So as his conservator, you're responsible for seeing that his financial affairs are taken care of?
A. Yes.
Q.  And that includes overseeing the financial agreement you have for repaying him the  money he lent you?
A.  Yes.
Q.  Is that agreement in writing, the agreement regarding the terms of your repaying him for the money he lent you to purchase your house?
A.  Yes, it is, but I don't have a copy of it.  My only copy was destroyed when the home was flooded last year.
Q.  Oh, so the home was flooded? 
A.  Yes.
Q.  Did you receive any compensation from your insurance company for flood damage done to the home?
A.  Yes,  $20,000.
Q.  Um, $20,000.  The flood occurred before the property settlement in your divorce, right?
A.  Yes.
Q.  How much of that $20,000 did you give to your former husband, Mr. Junkins, my client?
A.  Nothing.  I didn't think he was entitled to anything.
Q.  Let me be clear.  This flood occurred while he was still living with you in the family home?
A.  Yes.
Q.  That opens up another area of questioning.
      MS. TRESSFORD:  Miss Hillsmith, it looks to me like we should continue this deposition to another date.   I want to subpoena from the insurance company their records regarding the flood.