Cruz, Zachary State Depo 4-29-22 StvCruz

Zachary Cruz
1 IN THE CIRCUIT COURT OF THE

17TH JUDICIAL CIRCUIT IN AND
2 FOR BROWARD COUNTY, FLORIDA
3 CASE NO. 18001958CF10A
4 JUDGE SCHERER
5
STATE OF FLORIDA
6
Plaintiff,
7
vs.
8
NIKOLAS CRUZ,
9
Defendant.
10 ______________________/
11
12
13
DEPOSITION
14
OF
15
ZACHARY CRUZ
16
17
18
19
20 April 29, 2022

9:45 a.m. - 2:10 p.m.
21 Via Videoconference
22 Reported by: Joyce Marks, Certified Stenographer
23
24
25
Prestige Reporting Service, Inc. 633 South Andrews Avenue | Suite 202 | Fort Lauderdale,
FL 33301 (954) 764-7297 | [email protected]
Zachary Cruz
2
1 A P P E A R A N C E S
2
Appearing on behalf of the State:
3
OFFICE OF THE STATE ATTORNEY
4 By: Michael J. Satz, Esquire
Jeff A. Marcus, Esquire
5 Carolyn McCann, Esquire
Nicole Chiappone, Esquire
6 Steven Klinger, Esquire
Aaron Savitski
7 201 Southeast 6th Street
7th Floor
8 Fort Lauderdale, FL 33301
(954) 831-6955
9 jmarcus @sao17.state.fl.us
10
11 Appearing on behalf of the Defendant, Nikolas Cruz:
12 LAW OFFICE OF THE PUBLIC DEFENDER

By: Melisa A. McNeill, Esquire
13 Nawal N. Bashimam, Esquire
David B. Wheeler, Esquire
14 Tamara L. Curtis, Esquire
Kate O'Shea
15 Joel Maney
Melissa Sly
16 201 Southeast 6th Street
Suite 3872
17 Fort Lauderdale, FL 33301
954-831-6746
18 [email protected]
19 THE SUZERAIN TEAM

By: Casey M. Secor, Esquire (Pro Hac Vice)
20 105 Grist Mill Court
Lexington, SC 29072-7197
21 (803) 558-9867
22
23
24
25
Zachary Cruz
3
1 Appearing on behalf of the Witness, Zachary Cruz:
2 REINER & REINER, PA

By: David Reiner, Esquire
3 9100 South Dadeland Boulevard
Suite 901
4 Miami, FL 33156
(305) 670-8282
5 [email protected]
6 THE LAW FIRM OF AMINA MATHENY-WILLARD, PLLC

By: Amina Matheny-Willard, Esquire
7 999 Waterside Drive
Suite 2525
8 Norfolk, VA 23510
(757) 777-3441
9 [email protected]
10 ALSO PRESENT: MICHAEL DONOVAN
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Zachary Cruz
4
2 I N D E X
3 WITNESS PAGE
4 ZACHARY CRUZ
5 Direct Examination By Mr. Marcus 6
7 E X H I B I T S
- None Marked -
8
9 CERTIFIED QUESTIONS
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Zachary Cruz
5
1 Deposition of ZACHARY CRUZ, a witness of lawful
2 age, taken by the State, for the purpose of discovery
3 and for use as evidence in the above-entitled matter,
4 wherein STATE OF FLORIDA is the Plaintiff and NIKOLAS
5 JACOB CRUZ is the Defendant, pending in the Circuit
6 Court of the 17th Judicial Circuit, in and for Broward
7 County, Florida, Pursuant to notice heretofore filed,
8 before JOYCE MARKS, Certified Court Reporter, a Notary
9 Public in and for the State of Florida at Large, taken
10 via videoconference, in the County of Broward, State
11 of Florida, on the 29th day of April, 2022, commencing
12 at 9:45 a.m.
13 * * *
14 MS. MATHENY-WILLARD: If we can go back to
15 what Casey Secor said, Mr. Marcus' response,
16 and then I'll respond. So Mr. Secor, if you
17 could respond. We'll go on the record at this
18 point.
19 MR. MARCUS: First of all, I'm just going
20 to ask you to swear in the witness, please,
21 Ms. Marks. This is my deposition and I'm just
22 going forward. I'm going to -- I'll make the
23 record. It's my deposition.
24 Go ahead, Ms. Marks. Would you please
25 swear in the witness.
Zachary Cruz
6
1 Whereupon,
2 ZACHARY CRUZ
3 a witness of lawful age, being called as a witness by
4 the State, having been first duly sworn, testified under
5 oath as follows:
6 DIRECT EXAMINATION
7 BY MR. MARCUS:
8 Q. Would you please state your name, sir.
9 A. Zachary -- Zachary Paul Cruz.
10 Q. Okay. And your date of birth, please?
11 A. February 21, 2000.
12 Q. And Mr. Cruz, who is in the room there
13 with you?
14 A. My lawyer Amina, Kate, and Mike.
15 Q. Okay. Is that Kate O'Shea?
16 A. Yes.
17 Q. And she is a mitigation specialist with
18 the defense team, correct?
19 A. Yes.
20 Q. Where are you located right now?
21 A. Verona, Virginia.
22 Q. Okay. And who is Mike?
23 A. My guardian.
24 Q. What's his full name?
25 A. Michael Paul Donovan.
Zachary Cruz
7
1 Q. And when you say he's your guardian, what
2 do you mean by that? Do you have any -- do you have a
3 guardianship?
4 A. Huh?
5 MS. MATHENY-WILLARD: Your Honor -- I'm
6 sorry. Not Your Honor. I'm going to object
7 at this point. You asked him what he means by
8 that. Can you allow him to answer that
9 question?
10 BY MR. MARCUS:
11 Q. Absolutely. Go ahead.
12 A. Oh, Michael Donovan puts a roof over my
13 head and makes sure that I eat every night and every
14 day.
15 Q. Okay. He has no legal status with you,
16 correct?
17 A. No.
18 Q. And how old are you?
19 A. Twenty-two.
20 Q. So you're an adult and he's an adult that
21 you live with, correct?
22 A. Yeah, but I was a teenager technically
23 when I moved up here. Eighteen.
24 Q. Okay. You were an adult at 18, too,
25 weren't you?
Zachary Cruz
8
1 A. Yeah, but --
2 Q. So at all times you were of age when you
3 were living with Michael Donovan, correct?
4 A. Yes.
5 Q. Was that a yes or correct? I couldn't
6 hear you.
7 A. Yes.
8 Q. I'm sorry. I couldn't hear that. Could
9 you respond?
10 A. I said yes.
11 Q. Okay. Thank you. Mr. Donovan is not a
12 lawyer, is he?
13 A. No.
14 Q. And does Mr. Donovan take care of you in
15 any way?
16 A. Yes.
17 Q. How does he take care of you?
18 A. Puts a roof over my head.
19 Q. Okay. And -- go ahead.
20 A. He makes sure -- he makes sure I'm able to
21 go skate whenever I want to. I guess one of the most
22 important things to me. And -- and he takes -- he
23 takes care of my dogs, both the dogs I brought up
24 here. One of them passed away. He helped me -- he
25 always helped me take care of all -- both of them.
Zachary Cruz
9
1 And to this day he still helps. He -- my dogs love
2 Mike and Richard.
3 Q. And who is Richard?
4 A. Michael's spouse. Yeah.
5 Q. And as far as you know, they're legally
6 married?
7 A. Yes.
8 Q. And Richard Moore is subpoenaed for
9 deposition after your deposition; is that correct?
10 A. I don't know. I think so. I don't know
11 the time of events.
12 Q. Okay. Do Mr. Moore and Mr. Donovan
13 equally take care of you?
14 A. Yes. Yes.
15 Q. Or help you, correct?
16 A. Yes. Richard's always there for me.
17 Richard's there -- Richard more of like my right hand,
18 my right hand man. Mike's just like -- just also
19 right hand man, but --
20 Q. Do you receive any money from Richard or
21 Michael?
22 A. Yes. They -- debit card --
23 Q. I'm sorry. It came out garbled to me and
24 Joyce is shaking her head. Say that again, please.
25 A. They've given me a debit card and make
Zachary Cruz
10
1 sure I always have enough on it to have food and
2 drinks. Give me gas for my car.
3 Q. Okay. I'm sorry. Did you say that they
4 both gave you a car? Is that what you said?
5 A. I said, they gave me -- they gave me money
6 to put gas in my car. But yes, they did give me a
7 car.
8 Q. Okay. What kind of car did they give you?
9 MS. MATHENY-WILLARD: I'm going to object
10 at this point. Don't answer that question.
11 At this point this is going beyond the scope
12 of laying any foundations to determine whether
13 or not Michael Donovan should be in here.
14 He said that he takes care of him. Simply
15 asking if he works might resolve your
16 questions. But going into too much detail --
17 he takes care of him. He -- he lives -- you
18 know, he said they put a roof over his head.
19 They feed him. So he's not working. So what
20 you're asking goes beyond the scope. So I'm
21 going to ask him not to answer that question.
22 MR. MARCUS: Okay. Ms. Matheny -- do you
23 prefer Ms. Matheny-Willard or Ms. Willard?
24 How do you like to be addressed?
25 MS. MATHENY-WILLARD: Matheny-Willard.
Zachary Cruz
11
1 MR. MARCUS: Okay. Ms. Matheny-Willard,
2 in Florida you can make an objection, but the
3 witness is still allowed to give an answer.
4 This is -- we're under Florida rules of
5 deposition and you can make your objection,
6 but you can't instruct your client not to
7 answer.
8 This is a deposition where he has been
9 subpoenaed. I am -- you know, it's a lawful
10 subpoena from the State Attorney's Office. I
11 do not have to disclose my case to you as to
12 what is relevant in a deposition before I get
13 to ask questions.
14 Now, I'm going to again request that
15 Mr. Donovan leave the room and allow me to
16 question Mr. Cruz. Otherwise, we'll have to
17 take it to a court.
18 So I'll give you a moment to discuss it
19 again with your client and then we'll come
20 back in a minute or two. And either that or
21 we'll have to suspend the deposition. Let me
22 know.
23 (Recess off the record.)
24 MS. MATHENY-WILLARD: Mr. Marcus, just to
25 respond to your first statement. It's my
Zachary Cruz
12
1 understanding of Florida law that this is a
2 deposition to preserve witness testimony. So
3 I am going to --
4 MR. MARCUS: No, it's not.
5 MS. MATHENY-WILLARD: -- continue to --
6 MR. MARCUS: No, it's not. This is a --
7 this is not to preserve witness testimony.
8 This is not a civil deposition, Mr. Reiner.
9 MR. REINER: No, this is a criminal
10 deposition. Correct?
11 MR. MARCUS: Right. And there's no --
12 it's not like a civil case where it can be
13 read into the record.
14 MR. REINER: No. Correct. What rule are
15 you taking this deposition under then? What
16 criminal rule are you taking it under?
17 MR. MARCUS: 3.220. It's a discovery
18 deposition.
19 MR. REINER: Okay. So what you're saying
20 is that she can't instruct her client not to
21 answer; that you're allowed to ask any
22 questions that the judge might not allow an
23 answer for. Is that your understanding?
24 MR. MARCUS: You can certify a question,
25 but you better state a reason why you're
Zachary Cruz
13
1 certifying a question. It's not yours to
2 determine relevancy. Because a deposition is
3 wide-ranging as to what is relevant. It's not
4 for you to determine what is relevant.
5 Certainly anything in their background is
6 relevant information in a deposition.
7 MR. REINER: Well, that's for the judge to
8 decide, right?
9 MR. MARCUS: Well, ultimately it could be.
10 You could certify a question if you'd like.
11 MR. REINER: Okay.
12 MS. MATHENY-WILLARD: Are we on the
13 record?
14 MR. MARCUS: Yes.
15 MS. MATHENY-WILLARD: Okay. So aside from
16 that, my client wants Michael Donovan in the
17 room. Other -- it's my understanding that
18 other witnesses that have been deposed have
19 been -- have had other people in the room for
20 emotional support. Treating him differently
21 is not appropriate.
22 He has been through emotional trauma as
23 well as your other witnesses and so we're --
24 I'm not going to ask Michael Donovan to leave.
25 If we need to take this to the judge, that's
Zachary Cruz
14
1 what we need to do. But again, he should not
2 be treated any differently than you've treated
3 any other witness.
4 MR. MARCUS: I will make this allowance.
5 Mr. Donovan can stay in the room if I can see
6 him and he is behind Mr. Cruz so that he can't
7 signal any answers.
8 There are many questions that are going to
9 be involved in terms of Mr. Donovan in this
10 deposition and his relationship, businesses,
11 things like that. So it's an entirely
12 different situation than emotional children.
13 You have -- you have Kate O'Shea, an attorney
14 present, and now you want the person who may
15 very well be a witness in the case himself.
16 MS. MATHENY-WILLARD: I don't have any
17 objection to him sitting behind Zack so you
18 can see him or just right there in the corner.
19 MR. MARCUS: I can't see him.
20 MS. MATHENY-WILLARD: We have to turn the
21 camera though.
22 MR. MARCUS: Can you be a little bit
23 farther away so you can't -- you're not that
24 close to him, please. Appreciate that.
25 MS. MATHENY-WILLARD: You can't reach the
Zachary Cruz
15
1 camera, can you?
2 MR. MARCUS: Mr. Cruz -- can Mr. Cruz move
3 up to the middle of the table?
4 MS. MATHENY-WILLARD: Yes. Do you want
5 him to switch?
6 MR. MARCUS: No. Where Ms. O'Shea was
7 sitting.
8 (Off the record.)
9 MR. MARCUS: Okay. Are you ready?
10 MS. MATHENY-WILLARD: We're ready.
11 BY MR. MARCUS:
12 Q. Mr. Cruz, I'm going to be going into a
13 number of areas. You've been listed as a witness by
14 the defense and, of course, because of the seriousness
15 of what occurred, I hope you understand that I have to
16 ask you sensitive questions. So in a sense, I
17 apologize in advance that I have to ask you some of
18 these questions, but given the magnitude of what
19 occurred and other evidence that's been presented, I
20 need to ask you some of these questions.
21 I'm sorry to start with the death of your
22 mother. Can you please tell me if you recall what the
23 date of her death was? And for most of the purposes
24 of this deposition, when I refer to your mother, I'm
25 referring to Lynda Cruz.
Zachary Cruz
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1 A. She died on November 1, 2017.
2 Q. 2017, correct?
3 A. Yes.
4 Q. If I'm repeating you, it's because
5 sometimes it's difficult to hear, so I'm just
6 clarifying the record. I'm not -- that's the only
7 reason I'm saying that.
8 When did you first learn of her being ill
9 that caused her to go to the hospital?
10 A. I mean, the first thing was she went to a
11 CVS mini clinic and things had escalated so much while
12 she was there that an ambulance had to pick her up at
13 the CVS. And she left her car in the parking lot and
14 they took her all the way from Coral Springs to, like,
15 a Boca hospital somewhere around West Palm, like that
16 county. Not Broward County.
17 And yeah, she was like -- I was in school.
18 I was in class when the hospital sent a van to go pick
19 me up and pretty much see her for her last hour -- her
20 last -- her last moments on Earth. So I hope that
21 answers your questions.
22 Q. So Mr. Cruz, did all of this happen in one
23 day; that is, that she went to CVS and --
24 A. No.
25 Q. Okay. Go ahead. Tell me the time span.
Zachary Cruz
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1 A. It happened -- I remember she -- I mean,
2 it's kind of a daze, but there's a day she -- she just
3 wasn't home at all, like -- for, like, a whole day she
4 wasn't home. And then, like -- I'm trying to get this
5 right. So I'm sorry if I -- if my train of thought is
6 all over.
7 But I remember, like, she wasn't at the
8 house for like a week. And then, like, she -- yeah,
9 it was after -- after she went to CVS she wasn't at
10 the house for like -- well, almost for like a week.
11 And then it was like -- just one day I was in school,
12 like -- like, me and my brother were just home alone
13 in the house for however many days.
14 And then it was just like -- just one day
15 while I was at school, like, I was at -- like, it was
16 close to, like, the last period to the day and the
17 hospital came to the main office of my school and said
18 this kid -- like, they -- they -- they said that I
19 needed to go see my mom in the hospital because she
20 wasn't in good condition and they didn't think that --
21 they told me to -- I think I'm pretty sure they said
22 that they didn't think she was gonna make it. So,
23 yeah.
24 Q. Okay. So --
25 A. (Inaudible).
Zachary Cruz
18
1 Q. Say that again, please.
2 A. I said it's hard to remember because I
3 remember crying a lot, like, while I was still in
4 school thinking about my mom was in the hospital. And
5 then knowing that I had -- like, the van -- people
6 came -- come take me to go see her. So I was just --
7 it was real emotional to, like, try to think back to.
8 Q. I understand. And I'm sorry I have to go
9 over this.
10 So it was approximately a week before she
11 died that she went to the CVS clinic?
12 A. That's a guestimate. That's just a guess,
13 estimate. I mean, I just -- right now it's just a
14 daze. I don't really remember the, like,
15 chronological times about how it happened. But I just
16 remember she was at this -- she went -- we figured out
17 she went to a CVS and then got picked up from the CVS.
18 And then she was at the hospital for a few days.
19 And then, yeah, those few days we were
20 still going to school -- still in school -- we -- and
21 then it was one of those school days that -- it was
22 like the end of the day they called and said that
23 they're at the office to take us -- take me to the
24 hospital to see my mom. So, yeah.
25 Q. Okay. Mr. Cruz, do you recall staying at
Zachary Cruz
19
1 the house without your mother there for a few days?
2 A. Yeah. Yes.
3 Q. And who was at the house with you?
4 A. It was -- it was just my brother and me
5 and my dogs. Like, my -- like, my pet animals.
6 Q. Okay. And do you recall how you cared for
7 yourselves during this time period?
8 A. Well, I mean, our mom already like --
9 like, kind of like worried -- went grocery shopping
10 and she wasn't like -- it was less than a week. So
11 it's like we were able to just eat the same stuff we
12 would -- I mean, she made -- she got a lot of
13 microwave stuff in the fridge, like chicken nuggets.
14 I remember we ate bagels, like cinnamon raisin bagels
15 with cream cheese.
16 And yeah, we just -- we had to make, like,
17 microwave and, like, peanut butter and jelly, like --
18 like, while she wasn't at the house. And we didn't
19 think nothing really of it. Like, we didn't think too
20 deep -- I heard it -- thought it was -- she was at a
21 bad state of her health because she smoked cigarettes
22 every day, like smoked packs every day. Kind of.
23 Pretty much. So, yeah.
24 Q. Okay. I'm going to try and ask you to -
25 I'm sure your attorneys would agree with me - just try
Zachary Cruz
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1 and answer my question and we'll talk about other
2 things, too, and anything else that you want to add in
3 there.
4 But was there any adults living with you,
5 any other adults living with you at the time?
6 A. It was only my mom.
7 Q. Okay. But during the time when your
8 mother wasn't there, did any adults come into the
9 house?
10 A. No. Huh-uh. Not -- not before -- not
11 before she died.
12 Q. Okay. You may have said this earlier.
13 Your birth date is February what, please?
14 A. 21, 2000.
15 Q. Okay. So it makes it very easy to figure
16 out your age. So you're 22 years old now, correct?
17 A. Yes.
18 Q. That was a yes, right?
19 A. Yes.
20 Q. Okay. And so in November of '17 or
21 October of '17 you were 17 years old then --
22 A. Yes. I was trying to --
23 Q. -- when your mother died. And I guess the
24 shooting was a week before your 18th birthday; is that
25 right?
Zachary Cruz
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1 A. Yeah.
2 Q. Okay.
3 A. Yeah.
4 Q. Okay. So when you were staying at the
5 house with your brother, were you feeding yourself
6 then?
7 A. Yes. Yeah.
8 Q. And did you and your brother sit down
9 together and eat meals together?
10 A. No. We might have. I mean, we might
11 have, like, had a few times where we started
12 discussing, like, like, what's wrong with mom. But
13 that -- that could have been the only time we sit down
14 to eat.
15 I always, like, try to keep away from --
16 especially eating. Because, like, whenever I ate food
17 next to my brother, he just had poor -- poor manners.
18 Like, not really good. He, like, wiped his hands on
19 his shirt and like just -- just real messy. So I
20 would like -- so I never could eat next to him. I
21 wouldn't be able to eat.
22 Q. Okay. So did you -- did you each make
23 your own food?
24 A. Yeah. But, I mean, it wasn't nothing
25 like -- we never -- we never used the oven or the
Zachary Cruz
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1 stove. Like, it would be the microwave or the
2 toaster.
3 Q. Okay. So you -- so Nick would use the
4 microwave and you would use the microwave, make your
5 own food? Yes?
6 A. Yes.
7 Q. And did you have a can opener there, too?
8 A. Yeah, we had -- my mom has -- had all
9 types of the cooking utensils. Like, she had, like,
10 that stuff you mix dough with. She had pans and pots,
11 everything.
12 Q. Okay. And how did you feed the dogs?
13 A. Oh, they -- they -- it was easy because
14 they eat three times a day. Like, dinner -- or
15 breakfast, lunch, and dinner, and that's how many
16 bowls we put out. And they wouldn't always -- our
17 dogs aren't -- weren't big eaters. Like, they
18 weren't, like -- like, we put the bowl down and they
19 finish it. It's like they eat really if they wanted
20 to eat.
21 Q. Who would feed the dogs?
22 A. I would put that more on Nick because I
23 just -- I just never -- I was -- I was never trying to
24 stay home. Never really, like, even -- even when my
25 mom was sick in the hospital, I just -- I would still
Zachary Cruz
23
1 just go out. Go to the skate park. Go. Just get
2 away. Clear my head.
3 Q. Okay. So Nick would take care of the
4 animals?
5 A. Yeah, he was -- he was at the house, like,
6 mostly by himself with, like, bottles of alcohol.
7 Like, because I was just keeping, like, my distance
8 because I was just in a bad place about everything
9 with my mom.
10 Q. Did you feed the dogs dry food or canned
11 goods or how --
12 A. They ate dry kibble. Kibble. Like dry
13 kibble.
14 Q. Okay.
15 A. Pedigree.
16 Q. Okay. So when -- how did you get to the
17 hospital?
18 A. A van. A transportation van from the
19 hospital -- from the hospital came and picked me up.
20 And this is while I was still in Douglas. So, like,
21 they -- they came to the front office. They sent a
22 security guard in the golf cart to come get me because
23 I had class, like, on the, like -- and then the
24 freshman building, I was on the third floor.
25 I forgot which -- it was like reading
Zachary Cruz
24
1 class or something that I was in when they came and
2 told me that I had to go to the hospital. It was like
3 one of my last periods of the day. And yeah, I just
4 remember, like -- I was like -- as soon as, like --
5 like, my teacher told me like -- like -- like, they
6 need you in the office.
7 And then I don't know when I broke down
8 and started crying. But I just remember, like, it
9 just all hit me at once, like, while I was still at
10 school. And I was just like crying in front of
11 everyone. Like, especially in the -- not in -- only
12 in the main office I was like -- just like -- I was
13 losing it. I was just crying so hard.
14 Q. Where was -- where was Nick when you were
15 at school?
16 A. Honestly, that's like -- that's kind of
17 like iffy. Because I don't -- I don't know -- I think
18 he was -- I don't -- I think he was going to Taravella
19 or like somewhere. He might not even been in school
20 that day. But I just like -- I feel like I remember I
21 got to the hospital, like, he was already there. It
22 was like -- it's not like we took a ride together. It
23 was like somebody already picked him up, brought him
24 there. And then, like, my mom's friend was already
25 waiting just to meet us basically.
Zachary Cruz
25
1 Q. What friend was that?
2 A. Her name is Rocxanne Deschamps. She was
3 like my neighbor. Became, like, best friends with my
4 mom like -- for like -- for like -- I don't know.
5 Back when I was in, like -- like, I would say middle
6 school at least. Like early elementary. Like fifth
7 grade, elementary. Like, that's when, like, my mom
8 met Rocxanne. So they were good friends. Like, my
9 mom always watched Rocxanne's, like, little ones.
10 Like, she looked out for Rocxanne.
11 Q. Your mother really liked Rocxanne?
12 A. Yeah. Yeah. She -- because -- because
13 they smoked -- they just smoked cigarettes together.
14 My mom was a big cigarette smoker. Like, she just --
15 once she found somebody else that did that that lived
16 right next to us, it was like they just connected.
17 They would drink every night. They would smoke
18 cigarettes every night.
19 Q. And did Rocxanne still live in the
20 neighborhood during this time when your mother was
21 sick in the hospital?
22 A. We -- we already moved out of that -- that
23 neighborhood, that street we lived on that was next to
24 Rocxanne. We moved to this place called Town Parc in
25 Parkland. It's like a townhouse community and that's
Zachary Cruz
26
1 where we moved to. So we were like far, far away from
2 Rocxanne. Rocxanne was living in a trailer park in
3 West Palm Beach at that time.
4 Q. Okay. Who moved from Parkland first, you
5 or Rocxanne?
6 A. Rocxanne.
7 Q. Okay. So she had moved away from
8 Parkland? Do you know -- have any idea what year she
9 might have moved?
10 A. I don't. I can't remember that.
11 Q. Okay. But your mother and her maintained
12 their friendship even after she moved?
13 A. Oh, yeah. Yeah. Uh-huh.
14 Q. Okay. And they would talk every day or a
15 lot?
16 A. They talked a lot. Like, a lot. I'm not
17 gonna say every day, but they talked a lot. And I --
18 yeah, it was -- it was like her best -- it was her
19 best friend. And, like, Rocxanne said basically that
20 my mom was like a mother to her and that, like, my
21 mom was -- she was like my mom's daughter basically.
22 That's like how she -- that's how she put it back then
23 pretty much.
24 Q. Okay. And how did you feel about Rocxanne
25 at that time?
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27
1 A. I don't know. I mean, I was just -- I
2 just wasn't -- I wasn't ready to just trust her with,
3 like, my life after my mom was gone. Like, I would --
4 Q. Excuse me. I'm not talking about after
5 your mom died. I'm talking about before.
6 A. Oh. I would say -- I don't know. I was
7 always, like, cautious of her, like, because she was
8 just like -- she was wild. Like, she wasn't like --
9 she wasn't a normal type of person. Like, she was
10 more of like a party person. Like, always in that,
11 like, a party mood. Like, always just trying to,
12 like, turn up. Like, just -- so I just never
13 really --
14 And she had yelled at me a few times
15 growing up just because like -- like, the stuff that,
16 like, I would say to my mom, the behavior I'd have
17 with my mom. Like, she would just like -- she would
18 kind of like -- she would check me for my mom. She
19 would, like, yeah, scold -- not scold but like -- she
20 would just -- she would, like, get in -- like, she
21 would just get real verbal. Not like -- not like she
22 would cuss me but, like, she was like -- she was like
23 a super-nanny almost. Like, more appropriate.
24 Like, she would say, like, stop being an
25 idiot. Respect your mom. Don't take your mom's
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28
1 stuff. She would just be real, like, point finger in
2 my face. You know, like, don't -- you know.
3 Q. Well, now that you're older, do you think
4 maybe you deserved it?
5 A. Yeah, because, I mean, I shouldn't have
6 been so -- so, like, rude to my mom I would say,
7 because she tried -- she tried hard for us, I feel
8 like.
9 Q. So Rocxanne would defend your mother, is
10 what you're telling us?
11 A. Yeah, she was --
12 Q. Is that correct?
13 A. Yeah. Yeah.
14 MS. MATHENY-WILLARD: Mr. Marcus, can you
15 hold on just one second? I need to get my
16 charger and I just didn't want the court
17 reporter to not --
18 MR. MARCUS: No problem.
19 BY MR. MARCUS:
20 Q. So going back to the hospital. When you
21 get to the hospital, is your mother conscious?
22 A. No. No, she was -- they were like -- I
23 don't know. I mean, the only thing I can really
24 remember seeing, like when I -- they tried to like --
25 I just remember, like, they were like -- like, they
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29
1 had like the thing, the IV where they pump your chest.
2 They were just like pumping her, like. And she was
3 like fully nude on the bed, like, and like blood
4 coming out of her nose. And they were trying to
5 like -- like pump her, like -- like pump her chest
6 with like that electricity stuff. I don't know. It
7 was real graphic and, like, it was just -- it
8 traumatized me to see her like that.
9 Q. Okay. But did she pass away shortly after
10 you got there then?
11 A. I would say so, yeah. It was like maybe
12 two hours to an hour, hour 30 minutes. Like, it
13 was -- it -- it happened -- yeah, they were -- they
14 were just like -- they brought us there to, like,
15 basically to pull the wire.
16 Q. Okay. Had you been to that hospital
17 before that day?
18 A. No. No.
19 Q. Okay.
20 A. Not that I know.
21 Q. Had you spoken to your mother while she
22 was in the hospital?
23 A. We -- we -- me and my -- yeah, because
24 we -- yeah, we had -- because -- yeah, when we were
25 living -- I remember we just called her on the house
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30
1 phone and, like, she was just like -- like -- like
2 barely could talk. She had like -- when she was
3 trying to talk to us on the phone, she had, like,
4 already tubes in her -- like going in her mouth. So
5 it was like really hard for her.
6 Like, she was just like -- it sounded like
7 gasp -- gasping and -- it was just like -- she called
8 us like -- I just remember that one conversation. It
9 was just like we were trying to talk to her and then,
10 like, we were telling her, like, we love you. Like,
11 we're going to still go to school. Like, just --
12 like, yeah. That was on the phone before we ever had
13 to go to the hospital. Like, while she was in the
14 hospital.
15 Q. What hospital was it?
16 A. I want to say, like -- I'm not sure. I'm
17 not a hundred percent sure, but I think it was called
18 West Boca Medical Center. I'm not sure. I'm not --
19 I'm not a hundred percent.
20 Q. Okay. And again, I'm sorry to talk about
21 this particular terrible time in your life. After she
22 passed and you're still at the hospital, do you speak
23 to Nick?
24 A. Yeah. I'm pretty sure. Yeah, I told him
25 that -- because -- yeah, I remember I took him to the
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31
1 bathroom and I said, like, she's not gonna make it.
2 And then, like, telling him like she didn't make it.
3 Like, I had to like tell him that. I remember that.
4 We were walking down the hallway or like -- we were
5 just like -- we were walking. We went to the bathroom
6 or something and it was just like -- we were just
7 looking at life, like, for what it was at that point.
8 Like, just mom's gone. Like, that was our only real
9 guardian. Like, the only guardian we could trust and
10 actually, like, love, so.
11 Q. Okay. When you saw your brother after the
12 shooting and you went into that interrogation room, I
13 think you recounted a conversation you had with him at
14 the hospital between yourselves. Do you remember what
15 that was?
16 A. Like, do I remember what I said in the
17 interrogation room or do I remember a conversation at
18 the hospital?
19 Q. At the hospital about being there for each
20 other, things like that.
21 A. Yeah. Because I remember when she was
22 dead on the bed and then we were just, like, giving
23 our good-byes. I was, like, just saying we're gonna
24 make you proud.
25 Like -- like, this was before that they
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32
1 pulled all the wires and they were like -- they were
2 saying, like, she might be able to hear you. So
3 say -- try to say something that you want to get --
4 you want to make sure she knows.
5 And then I remember, like, I was just
6 giving a little, like, a heart speech. And then,
7 like, Nick started like talking over to me -- talking
8 over me and I told him, like, be quiet. And like kind
9 of like -- like -- like -- just like -- tried to,
10 like, silence him while it was all happening. But I
11 don't know. It was just real emotional. Like, it was
12 just -- yeah.
13 Q. How about when you and Nick were together
14 as you were leaving the hospital? Is that when -- did
15 you say something to him about watching out for each
16 other, having each other's back, things like that?
17 A. Yeah, I think I told -- I think I told
18 maybe my mom that. Like on the -- when she was on the
19 bed that we're gonna stick together. Like, yeah.
20 Q. That you and Nick would stick together?
21 A. Yeah. Yeah. That we were gonna look out
22 for each other.
23 Q. Okay. All right. So you were promising
24 your mother that?
25 A. Yeah.
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33
1 Q. Okay. So how did it come that you came --
2 how did you come to live with Rocxanne, that you and
3 Nick went to live with Rocxanne? How was that
4 decided?
5 A. Basically, I mean, she was at the hospital
6 when my mom died. And they say -- they say -- because
7 I'm not even sure if I believe this, but they say at
8 the hospital that, like, my mom's last -- like, the
9 last thing she really said was to call, like, Rocxanne
10 and ask her if she could watch the boys.
11 And, yeah, so like when we were already --
12 when I -- when I showed up, like, Rocxanne was already
13 there. Like, her son was there. Like, her -- her man
14 was there. I think her kid might have been -- the
15 little kid might have been there, too. I'm not sure.
16 Her mom was there. Yeah. And, like, her, basically
17 her whole -- half -- the whole family she had with her
18 was there.
19 And like, when my mom was officially,
20 like, gone, she just like -- she just like basically,
21 like, said all right, I'm your guardian now. And
22 we're just going to go to your old house. We're going
23 to start removing furniture. Like, take clothes out
24 that you need. Get the dogs and like -- yeah.
25 Q. Is that all at the hospital?
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34
1 A. Yeah. Oh, yeah. It was all decided at
2 the hospital. I mean, it was just like -- my mom was
3 gone so it's -- she -- Rocxanne felt like she owed
4 that to my mom.
5 Q. The first thing that you said was that
6 "they" said it was your mom's last word. Who were you
7 referring to? Who is they?
8 A. I mean not by -- well, like, Rocxanne and
9 the hospital. I don't even know. But I'm -- yeah.
10 Basically. Yeah. I'm saying that.
11 Q. So you're saying the hospital personnel
12 like the nurses or doctors or --
13 A. Yeah. Yeah. I -- I -- I think that -- I
14 don't know. I just -- it's just hard for me to
15 believe that's the last thing that my mom would
16 have -- would have said. Like, oh, tell Rocxanne to
17 look after my kids. I don't know. Or, like, ask
18 Rocxanne -- I don't know. It's just -- yeah. I don't
19 know.
20 Q. I understand you may not believe it. I'm
21 just trying to figure out who told you that.
22 A. It was -- it was -- yeah, it was the
23 hospital staff I'm pretty sure. Or --
24 Q. Okay.
25 A. Yeah.
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35
1 Q. And Rocxanne -- Rocxanne agreed to it?
2 A. Yeah. Yeah. She was -- she was there the
3 whole time.
4 Q. And what did Nick say about it?
5 A. I can't really -- there's nothing, like,
6 specific I remember. It was like -- I mean, we -- we
7 both didn't like it. We didn't like -- we didn't --
8 we didn't trust it. I didn't -- yeah, I didn't trust
9 it at all. Like, I -- I just didn't like the road
10 they were going down.
11 Q. Okay. So I understand the terrible
12 dilemma you were facing at that moment, but did you
13 have another possibility of who you would live with?
14 A. No. No. I mean, I didn't have nobody
15 that would -- that would look out like that. I don't
16 think so. Like, I was trying to think of friends, but
17 I didn't -- there's nobody I asked if I could go live
18 with. None of my friends I asked that.
19 Q. Okay. So from there, where did you go
20 from the hospital and who drove you?
21 A. We went -- that's hard to remember. I
22 don't even really remember that, to be honest. When
23 we were leaving the hospital, that's just like a blur.
24 Q. Okay.
25 A. I remember going back to my house in Town
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36
1 Parc and, like, we went there. Looked at, like, all
2 the stuff there. I feel like Rocxanne was looking
3 around everywhere. Her son was looking around
4 everywhere. Just felt really, like, uncomfortable.
5 And it was -- yeah. Yeah, I just remember those type
6 of events all in like that one day --
7 Q. Okay.
8 A. -- after my mom died.
9 Q. You said that there was family of
10 Rocxanne's that were at the hospital?
11 A. Yeah.
12 Q. Could you tell me who they were, please?
13 A. I mean, I can't -- I don't know what --
14 what her mom's name is, but I know her mom was there.
15 Her son Rock was there. Her boyfriend at the time,
16 his name was, like, Chad or something. He was there.
17 And I'm pretty sure her youngest son Tyler was there.
18 So I think they had like -- that's like -- that's like
19 her whole -- her whole family basically.
20 Q. Okay. And you know who Paul Gold is,
21 right?
22 A. Yeah. Yeah. I met him. He's -- yeah,
23 he -- he used to live next to me. He used to be my
24 neighbor.
25 Q. He used to live with Rocxanne, right?
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37
1 A. Yeah. Yep.
2 Q. And he's the father of one of her kids?
3 A. Yeah. Tyler.
4 Q. Tyler?
5 A. Yeah.
6 Q. And he wasn't there, was he?
7 A. What, Paul Gold?
8 Q. Yes.
9 A. No, he wasn't at the hospital. He was at
10 my mom's funeral. He took my brother to my mom's
11 funeral. That's it.
12 Q. Okay. All right. So who is Rocky?
13 A. That is Rocxanne's oldest son.
14 Q. And how old is he?
15 A. That's something I don't know. I -- I --
16 if I could guess, I would say maybe he's like 25, 27.
17 Getting close to thirties.
18 Q. So you're 22 now. Are you saying he's
19 between 25 and 30 now?
20 A. Yes. That's a guess.
21 Q. Okay. So is your best guess is he's three
22 to seven years older than you?
23 A. Yeah. Yeah.
24 Q. Did he live next door to you?
25 A. Yeah. Yes. When we were living at 6166
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38
1 Northwest 80th Terrace, they were our neighbor to the
2 right of us.
3 Q. Right next door?
4 A. Yeah, they lived in a orange house.
5 Q. Okay. And were you ever in the same
6 school as Rocky?
7 A. No. No. I mean, maybe because he did go
8 to Westglades Middle School, but I don't -- I don't
9 think so. No. Because even when I was in sixth grade
10 I never saw him at Westglades. So, no.
11 Q. Okay. Was he a friend of yours or Nick's?
12 A. Growing up, like, when we was, like,
13 still, like, in middle -- middle -- like, elementary
14 basically, going to middle -- like, we were like --
15 we -- basically like elementary days, basically we'd
16 hang out all the time. We'd play -- we'd go to his
17 house, play video games. Or he would come -- come
18 over into our backyard and we'd just be like --
19 basically, like, playing in the backyard.
20 Q. Okay. Even though he was older, was he --
21 was he a friend?
22 A. Yeah. Yeah. Yeah. I mean, he was --
23 yeah. Even though he was older, it was like -- we
24 were like -- we just like -- we were friends.
25 Q. Okay. And your parents were friends, too,
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39
1 right?
2 A. Yeah. Yeah. Like, my mom and Rocxanne
3 were like really better than -- better friends. They
4 were like -- they're always like communicating towards
5 each other. Always like, yeah, checking on each
6 other.
7 Q. Okay. Did you ever have any problems with
8 Rocky?
9 A. No. Like, never had a fight with him.
10 Q. Okay. Did Nick ever have a problem with
11 Rocky?
12 A. After my mom died he fought him.
13 Q. Okay. Before that was there ever a
14 problem between them?
15 A. Growing up? He -- yeah. But like -- I
16 don't -- I mean, it -- it would be like Rocky would,
17 like, kick Nick out of his house. It would be stuff
18 like that.
19 Q. Why would he kick him out of the house?
20 A. He just -- maybe because he just didn't
21 like Nick's behavior. Like -- like -- because, like,
22 Rock had an Xbox 360 at his house and we didn't have
23 any type of gaming console -- gaming or anything at
24 our house. So it was like we'd go there just pretty
25 much for that.
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40
1 And then, like, Rock was like the
2 gatekeeper or he was -- everything was -- everything
3 belonged to him. So he didn't want us to watch him
4 play the game or even play the game. Because he would
5 play -- he would let us play multi-player with him.
6 So if he didn't let us do that -- if he, like, wanted
7 us to leave, we'd have to leave. So, yeah. He would
8 kick Nick out. Like, even me, I remember he would
9 kick me out, like.
10 Q. Okay. I'm sorry I have to ask you this
11 question, but I do. Did you ever have sexual
12 relations with Rocky?
13 A. No.
14 Q. Okay. Do you know if Nick ever had sexual
15 relations with Rocky?
16 A. I mean, I've -- I've heard that, like --
17 like, Rocky touched Nick. But that was like -- I
18 never -- I never knew about that while it was
19 happening or, like, during those years. I only heard
20 this, like, more recently. Like, after our mom passed
21 away. That's when this knowledge became present. It
22 was never like -- yeah.
23 But there is a chance maybe -- there is a
24 chance that maybe when I was growing up I had figured
25 something -- I might have heard about it and then,
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41
1 like -- yeah, I might have like -- like, I don't know.
2 I might have just -- I might have known about it when
3 I was growing up, but it definitely left my -- like,
4 left my head. And I like -- I couldn't even remember
5 it after my mom -- like, yeah -- yeah, it's not really
6 clear after my mom died. Like, when my mom died, I
7 didn't even, like, remember -- I couldn't remember any
8 of that. Like, but growing up, maybe. I'm saying,
9 like, that's what I'm saying. Like maybe I knew about
10 this, like, when I was growing up.
11 Q. Okay. Well, let me just ask a few more
12 questions. So you definitely never had sex with
13 Rocky, correct?
14 A. Never. Never.
15 Q. Okay. And he didn't demand sex from you
16 to play any video games?
17 A. Never. Never me.
18 Q. Never from you, right?
19 A. Yeah.
20 Q. Okay. So I think the first thing you said
21 is you didn't hear of this until after your mother
22 died?
23 A. Yeah. Yeah.
24 Q. And that was -- that was something about
25 Rocky touching Nick?
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42
1 A. Yeah. Yeah.
2 Q. Okay. And so who did you hear this from?
3 A. I mean, I saw it on -- it was a Facebook
4 post from this lady Trish. And, like, she was, like,
5 was friends with my mom. But she lived -- she
6 literally lived in the same house that Rocxanne lived
7 in before Rocxanne rented it.
8 She was, like, she was the previous person
9 in that house. So she lived in the same spot as
10 Rocxanne, just like -- but, like, we were way more
11 younger. This is like when we were still in pre-K and
12 like early elementary, like -- like, yeah. Like, it
13 was this lady that lived next to us. My mom became
14 friends with her because we were neighbors, so they
15 introduced each other. And, like, we became friends
16 with her kids. Like, had to --
17 Q. What is Trish's last name?
18 A. That's something I don't know. I mean, I
19 never -- honestly, I've never really even like -- I've
20 never talked to the woman before. But she -- she
21 knows my mom. She has baby pictures. She has, like,
22 actual legit baby pictures that my mom gave her. I
23 don't know. Like, I don't know why. Doesn't make
24 sense to me.
25 Q. And Trish lived in the same house that
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43
1 Rocxanne eventually rented?
2 A. Yeah, before -- before Rocxanne rented
3 that house, Trish was like the actual -- I think she
4 was like maybe the homeowner or maybe she was renting.
5 But I think she was like -- like, the owner of the
6 house, so.
7 Q. And she may have rented it to -- she might
8 have rented it to Rocxanne?
9 A. Yeah. Or there's a chance that Trish was
10 renting it. I don't know. I don't know.
11 Q. Okay. So the first time you hear of this,
12 is it after the shooting happens?
13 A. Yeah. This is -- oh, yeah. This is when
14 Nick's already incarcerated when I seen the -- I saw
15 the Facebook posts.
16 Q. Okay. So the first time you hear that
17 Nick might have been molested by Rocky is after Nick
18 is already arrested for these murders, correct?
19 A. Yeah. And he had already fought Rocky.
20 Q. And he had already what? And he had
21 already fought Rocky. Okay.
22 A. Yeah. And I think that's the reason why
23 he fought him.
24 Q. Okay.
25 A. Trigger point for why he wanted to fight.
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44
1 Q. Okay. So you just added that part, but
2 who told you that was the reason he fought Rocky?
3 A. No, I just -- that's just -- that's my
4 assumption. Because it was --
5 Q. Okay.
6 A. They said that Nick was just like hitting
7 the wall because he lost a picture, but I think it
8 was -- it was deeper than that. It was, like, Rock
9 was just like -- was steady, like, trying to, like,
10 boss Nick around by, like, every inch. Just like --
11 just like telling him, like, about his job and stuff.
12 Like, trying to like dictate, like, how he
13 was going to start going to his job. Like, either
14 start taking the bus, blah, blah, blah. It was just
15 like Rock was trying to, like, be like a dad to him or
16 like bossing -- just straight bossing him around and
17 then he just, like, lost it.
18 Q. Were you there for the fight?
19 A. Yeah, I was there. And like, it was -- it
20 was intense because, like, they were -- it happened --
21 it all happened in Tyler's room. Like, that little
22 kid, like he -- like -- but Tyler wasn't even in the
23 house. Tyler wasn't even at the property when the
24 fight happened. So let me get that on the record.
25 So, like -- but basically -- like, we --
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45
1 when we went to Rocxanne's, me and Nick had Tyler's
2 room to stay in. There was two twin beds in there and
3 I slept on one and Nick slept on one and that was our
4 room. So then -- then --
5 Q. Okay. Let me stop you for a second
6 because you're kind of going far afield.
7 A. I'm sorry.
8 Q. Let me just direct you and try and just
9 give me -- try to just answer the question if you
10 could. Okay?
11 A. Okay.
12 Q. So the first time you hear about any
13 sexual relations between Rocky and Nick is after he's
14 already arrested, correct?
15 A. Yes.
16 Q. Okay. And then you were present for the
17 fight between Rocky and Nick that led to Nick being
18 thrown out of Rocxanne's house, correct?
19 A. Yes.
20 Q. And you didn't hear any mention of sex
21 between them during that fight, correct?
22 A. No. No.
23 Q. Okay. So the mention of sex was in a
24 Facebook post by someone named Trisha, correct?
25 A. Yeah. Trish, yeah.
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46
1 Q. Trish. And what did Trish say in this
2 Facebook post?
3 A. She was basically calling out Rocxanne
4 and, like, saying that Lynda was -- like a summary of
5 what I remember of the post was, like -- she was,
6 like, this -- like, the reason why Rocxanne sent Rock
7 out of the country was because Nick had told Lynda
8 that Rock touched him. And then Rock -- my mom
9 confronted Rocxanne about it and then Rocxanne got
10 scared for Rocky and, yeah, like basically -- she just
11 like packed -- she packed Rock's bags and sent him
12 out.
13 Q. Okay. So let me ask you. You never knew
14 of your mother confronting Rocxanne --
15 A. Never.
16 Q. -- about Rocky, correct?
17 A. Never. Never knew that.
18 Q. Okay. That was news to you?
19 A. Yeah. In the post. I read that in the
20 post.
21 Q. Okay. You don't know that that's true?
22 A. Yeah, no.
23 Q. Okay. What did -- after the shooting, did
24 Nick talk to you about Rocky?
25 A. No. No.
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47
1 Q. Did he ever tell you anything about sex
2 with Rocky?
3 A. No. Huh-uh.
4 Q. Did you ever tell Nick anything about sex
5 with Rocky?
6 A. No. No.
7 Q. Did you and Nick ever discuss somebody
8 having sex with Rocky?
9 A. No. I mean -- no. I remember, like, from
10 growing up he had, like, girlfriends or something.
11 But it was like --
12 Q. Okay.
13 A. I don't know.
14 Q. Okay. Nick never told you he was raped by
15 Rocky?
16 A. No, he never told me that.
17 Q. Okay. Hold on just a second. Did you
18 have a relationship with Paul Gold at all?
19 A. I mean, not a relationship. Like, I mean,
20 it was like -- he would like -- when we were, like,
21 real young and stuff, like, Rocxanne and Paul, like,
22 they owned a boat and they would -- like, they
23 would -- they would take me and Nick out, like, on --
24 like, wherever we wanted to go.
25 Like, they would take us on a boat. They
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48
1 would take us jet -- not all the time. This is, like,
2 from things I could remember like -- like -- like,
3 Paul, like, made sure that we rode jet skis somewhere
4 in like, like West Palm in that, like, inlet area. I
5 can remember that.
6 Paul owned a boat or something, I'm pretty
7 sure. So, like, we would go on the boat with Rocxanne
8 and Paul and his -- and Paul's daughter. They would
9 just bring me and Nick along. And just because, like,
10 Rocxanne wanted to do something nice for my mom
11 basically, like -- like, get us out of the house. So
12 like, yeah, they would just -- they would do that for
13 my mom basically. Just like take us out.
14 Q. Do you know -- I'm sorry. Are you
15 finished? I didn't mean to interrupt you.
16 A. Yeah.
17 Q. Do you know when Paul moved out of the
18 neighborhood, like broke up with Rocxanne, how old you
19 would have been?
20 A. I think -- no, I'm not -- maybe like --
21 maybe like 13, 14 maybe. Maybe. Maybe. I'm not
22 really sure. I mean, I can remember it was probably
23 around when I was in middle school when they broke up.
24 Q. Okay. Do you know if it was a bad
25 breakup?
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49
1 A. I mean, yeah. Yeah. Because I remember,
2 like, Rocxanne -- like, one time she came like -- she,
3 like, came over to our house to hide from Paul. And,
4 like, she like ran -- like, she -- she, like, hid,
5 like, in the guest bedroom. She was like -- she was
6 like -- like -- like -- like not screaming, but she
7 was like -- like -- like, telling my mom, like -- like
8 very, like, panickly, like everything going on, like,
9 at the house.
10 And then like -- like she -- she came to
11 our house and then Paul was knocking on our front
12 door. And my mom had to lie and say, no, Rocxanne's
13 not here, Paul. And then it was like -- he, like,
14 kind of stood at the door like -- like questioning --
15 like looking at my mom, like questioning her. Like, I
16 know she's in here. Like that type of look.
17 Yeah, that was basically like -- I never
18 saw, like, anything worse than that though. Like that
19 was the only time Rocxanne just came over to hide from
20 Paul.
21 Q. Did Paul ever take you or Nick, you know,
22 out to do things?
23 A. Yeah. But like, usually it would be with
24 his daughter Bella.
25 Q. Say that again. Can you repeat yourself,
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1 please.
2 A. Yeah, I said it would usually be with his
3 daughter Bella. Like -- like -- because she was good
4 friends with me and I guess with Nick also. But that
5 was just like -- I remember they would just -- he
6 would just take us out like random places, like, and
7 Bella would ask for us to go. Just like --
8 Maybe my mom would ask. I don't know. It
9 was just -- we were almost like a family. It felt
10 like we were all like family back then in a way. So
11 it was just like we all just were cool hanging out.
12 Q. Did Paul ever pay you money to do work
13 around the house, you know, outside, pick up leaves or
14 anything like that?
15 A. No. He -- he never -- he never offered me
16 a job or nothing like that.
17 Q. How about Nick, do you know if he did that
18 with Nick?
19 A. That is a maybe. I'm not -- I'm not a
20 hundred percent sure. But I think he was like -- he
21 was more, like, trying to look out for Nick instead of
22 me I feel like.
23 Q. Okay. Let me go now back to after your
24 mom died and you moved in with Rocxanne and Nick was
25 still there. So did you have your own room or did you
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1 share one with Nick or someone else?
2 A. Me and Nick shared a room.
3 Q. Okay. And how did you guys get along at
4 that point?
5 A. I mean, we were becoming -- we were a lot
6 more closer after my mom died. So it was like -- but
7 it was also, like -- I still, like, was just, like,
8 keep -- like, I still had, like, my social life going
9 on. Like, I would go to the skate park every night
10 basically. And like, I was just like, I -- I
11 separated myself from them.
12 Q. Okay. So when you say things got better
13 between you, and I know a lot happened when you guys
14 were younger, you know, with fighting each other and
15 stuff like that. Had that ended now --
16 A. Yeah.
17 Q. -- after your mom died?
18 A. Oh, yeah. That was -- even after my mom
19 died, we never even like looked at each other sideways
20 ever again. Like, it was just like -- I don't -- it
21 was just like we're brothers. We're just brothers
22 now, right. We don't have no mom.
23 Q. Okay. So would you say that was like a
24 real awakening for you to grow up quickly?
25 A. Oh, yeah. Yeah. And like I stopped -- I
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1 stopped trying to, like, put my brother down all the
2 time. Like, it was just -- and, like, I was trying
3 to, like, encourage him to, like, be -- go out and do
4 stuff, like, and meet people. Like, just -- I tried
5 to encourage him to have a social life, but it --
6 it -- yeah. He was his own person.
7 Q. Okay. So we know that the worst thing in
8 the world happened on February 14th. But from
9 November until February, before the shooting occurred,
10 is it fair to say that that was one of the best times
11 you and him have ever had together?
12 A. Can you restate that?
13 Q. Okay. So after your mother died and
14 before the shooting, was that a period of time when
15 you and Nick got along the best in your whole life up
16 until then?
17 A. Yeah. It's like we were just both really
18 sad. So it was like -- yeah, we were just like --
19 like, he -- I thought we were trying to like, I don't
20 know, like heal each other maybe. But like, it
21 just -- I don't know. Nick was his own person. I was
22 my own person. And it's not -- it's not that we were
23 trying to talk about our feelings all day or even
24 longer than like ten minutes. It would be like --
25 like, yeah, it's sad but we're here now so, yeah.
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1 Q. But you guys stopped being jerks to each
2 other during those few months, right?
3 A. Oh, yeah. Yeah.
4 Q. Okay. Tell me about the guns at
5 Rocxanne's house, Nick's guns.
6 A. Yeah, I'm pretty sure he was never able to
7 bring a gun to that house. That's what I'm pretty
8 sure of. Because Rocxanne never approved of Nick
9 having guns.
10 Even when there was times she slept over
11 at our house when we were still living at 6166, that's
12 when my mom was alive. And then she was like
13 questioning, like, why Nick had all these guns. Like,
14 she was telling my mom, like, he doesn't need all
15 that. Like -- so. Like she -- yeah, when we moved
16 into her house there was -- Nick was -- I don't even
17 think he was allowed to have ammo or anything inside
18 the house.
19 Q. When you were living at the townhouse
20 before your mom died, and Nick had a number of guns at
21 that point, correct?
22 A. Oh, yeah. A closet full.
23 Q. What did he have?
24 A. Closet. It was like full. Like --
25 like --
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1 Q. Closet full. And that was -- and that was
2 going to be my question. Where did he keep his guns?
3 A. He just kept them in his closet, like, up
4 against the wall. Like, they all, like, were just
5 like, like spread out on the wall. Like under, like,
6 the hangers for, like, his clothes and stuff.
7 Q. Okay. And did you see them in the closet?
8 A. Yeah. Oh, yeah. It was -- it was --
9 there was so many times I just went in there and just
10 like picked one up and, like, looked at it and just
11 like -- yeah, just like -- so many times I just
12 remember, like, just going in there and, like, I had
13 full access. Like, the ammo was there. The gun's
14 there. Like, it was just out in the open. Everything
15 was.
16 Q. Did Nick let you look at his guns?
17 A. Yeah. Yeah. Sometimes he would. But
18 when it was brand new, like, he would be like, check
19 this out. And then just like -- I'd be scared but I'd
20 be like -- like, I just -- I wouldn't like -- like try
21 to, like, hype him up about it. I would just be -- I
22 was just -- I just took it for what it was.
23 It was like -- it was like, all right. He
24 has a new gun. Like, another one. And then another
25 one. So yeah, just -- just like he -- that was what
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1 he would start saving his money for. He would like
2 look up different guns. Like -- like go on YouTube.
3 He always would watch different YouTube videos about
4 guns and, like, just like gun reviews and everything.
5 Like, just like had this -- this -- this search for
6 knowledge, like, about everything. Yeah.
7 Q. So would he -- would he go on the internet
8 to learn?
9 A. Yeah. Yeah. Learning stuff he didn't
10 know. Yeah. And he was always on YouTube. Always --
11 always watching, like, a different YouTube video based
12 on --
13 Q. What kind of YouTube videos would he
14 watch?
15 A. It was a lot of, like, dark stuff.
16 Nothing like -- nothing really like -- like not -- not
17 a lot of gaming or, like, anything, like -- like you
18 would think normal. It was like -- he would search
19 stuff like memes, like funny, like, things on, like,
20 the internet. And it would be like -- it could be
21 like -- like -- like, it could be things, like,
22 about -- just like -- I don't know.
23 Mostly what I remember is, like, a lot of
24 gun reviews. Like a lot of, like -- just like this,
25 blah-blah-blah, blah-blah-blah. And it would be like
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1 a guy at a gun range like -- like showing -- like
2 shooting the gun, talking about it to the camera.
3 Like, it would be stuff like videos of stuff like
4 that.
5 Q. Okay. So do you think he was like an
6 expert in guns, he knew so much about it?
7 A. Yeah. Oh, yeah. Especially at that time.
8 Like when -- when we still lived in Town Parc and like
9 my mom was still alive, yeah. Pretty much a gun
10 expert.
11 Q. Really? Would he know how to clean a gun?
12 A. Yeah. Oh, yeah. I mean -- well, he,
13 like -- like, he would YouTube videos like that, like
14 how to clean a gun. I'm pretty sure. Because I
15 remember, like, there would be nights, like, I
16 couldn't even sleep because I would hear him. Our
17 rooms would be, like, wall-to-wall connected and,
18 like, it would be like 12:00, 1:00 o'clock in the
19 morning and he's just like cleaning out the barrel of
20 his rifle. Like, oiling it. Like, just doing all
21 this, like, loud stuff in his room.
22 And then just -- just like -- I don't
23 know. He was making like noises like -- I don't know.
24 Like, he'd scream out a curse word or something
25 like -- like, just because if he couldn't -- like, it
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1 if it was hard to do something like reach a space or
2 something, he would just let out like -- like -- just
3 like rage, I would say. Like, I don't know.
4 Q. Did he have ammunition in the room, too?
5 A. Yeah. Oh, yeah. He always, always had
6 ammo. Always.
7 Q. So we're not talking Airsoft. We're
8 talking real guns?
9 A. Real guns. Yeah. Yeah.
10 Q. And real ammunition, right?
11 A. Yeah. And he -- and that's really like --
12 he would go to Walmart and buy just, like, ammo.
13 Like, it could be shells for the shotgun. Or like --
14 just like -- I don't -- I don't -- it was like some
15 American -- it had like an eagle on it and there was
16 like these bullets. I think it was like -- just like
17 assault rifle bullets. Like, it was stuff like that.
18 And then like rifle bullets, I remember he would buy
19 that from Walmart. Or something like -- he had like a
20 rifle -- like, yeah.
21 Q. What were the coolest guns that he had?
22 A. Well, I don't think guns are cool.
23 Q. Okay.
24 A. So I mean --
25 Q. What was --
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1 A. I mean, I -- I had the -- we had -- he had
2 let me -- going back when we lived at 6166 Northwest
3 80th Terrace, we had an old TV in the garage. And,
4 like, this is when he -- he had a shotgun and he would
5 just like -- like, shoot it in the backyard, like,
6 just at the ground though, like at night. This was
7 like -- this was like midnight, or like night night.
8 He would just like shoot it into, like,
9 the ground in the backyard or -- but I remember, like,
10 one time he let me shoot it at the TV in the garage.
11 It was an old TV. And then I -- like, he did it first
12 and then I did it. Or I did it first and then it he
13 did. But, yeah.
14 Q. That was in Parkland?
15 A. Yeah. That's -- that's when my mom was
16 still alive, like.
17 Q. I bet she wasn't home, was she?
18 A. She was actually. She was -- but she was
19 like -- it's such a big house. She was like on one --
20 like the deepest, like, farthest side of the house
21 from the garage. So there's no way, like -- the sound
22 wasn't going to travel that far, like, that quickly.
23 So it was like -- it was pretty much muffled by the
24 time it, like, that sound reached that part of the
25 house. There was so much space between that.
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1 Q. She didn't know it?
2 A. No. To answer -- yeah, if she passed out
3 sleeping in the den, like, she'd be sleeping for like
4 two hours, three hours at least. An hour at most.
5 Yeah.
6 Q. What about the AR-15, were you familiar
7 with that?
8 A. Yeah. Yeah. I've seen him shoot that
9 gun. Like, in the garage. Out his window.
10 Q. Out his window?
11 A. Yeah. Yeah. We were living in Town Parc.
12 I remember I had -- I had -- yeah, I asked him to do.
13 I was like -- this was during Hurricane Irma. So it's
14 like -- it's really, like, real bad outside and like
15 everything is just like -- it's just nasty outside.
16 And it's nighttime.
17 And then I just tell him, like -- like,
18 just crack the window. Because there's no screen.
19 There's no screen over the window. And, like, I was
20 just like -- I told him -- I directed him to do it.
21 Like, it was our guestroom in Town Parc. We just
22 opened the window. It faced the backyard. And I was
23 like, just shoot straight at the grass. And, like, I
24 recorded him do it. It was like -- there used to be a
25 video of it. But, yeah.
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1 Q. You took that from inside the house, the
2 video?
3 A. Yes. Yeah. I was inside the house.
4 Q. You still have that video?
5 A. No. I lost it. I'm not -- I deleted it.
6 Q. Okay. So when did he do that?
7 A. That's when my mom was not in the
8 hospital. That's when we -- that's when we were
9 living in Town Parc. So like, yeah, when we were
10 living in Town Parc.
11 He would, like -- I would kind of say he,
12 like, shot his gun, like, three times at least. One
13 time outside the guest window at the -- at the
14 backyard, which was, like, not big at all. It was
15 like the size -- like smaller than this room.
16 Another time was -- he shot his AR in the
17 garage, like, right at the -- right at the tile and
18 put a massive dent in the tile. And then the thing is
19 he tried to, like -- he tried to -- he put the barrel
20 around, like, a pillow and inside this box trying to
21 muffle it and it was just -- it dented the ground
22 literally. And then what was -- that's twice.
23 And then, oh, third time it was like --
24 this is also during Hurricane Irma. And this is -- I
25 wish my mom was still alive because she saw this like
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1 a hundred percent. It was like -- like -- because she
2 was just there. She was right there when it happened
3 and I was right there when it happened.
4 And so basically it's pouring rain. This
5 is during Hurricane Irma. And, like, he just grabbed
6 the shotgun, goes outside while it's pouring raining
7 and then, like, points it right at the grass patch,
8 shoots the ground. And literally when he shot the
9 ground, like, like, his whole body was covered in
10 dirt. Just like -- like -- just like -- just like he
11 shot one time at the ground and, like, the ground like
12 exploded and there was dirt all over him. And then
13 literally he walks right back in the house.
14 My mom's, like, sitting there literally at
15 the door. Like where the door is, there's like a big
16 long couch and there's a TV. And then, like, I
17 recorded it, too. And you could see my mom was in the
18 video. So that -- I don't know what happened to the
19 video. But I remember, like my, mom -- as soon as he
20 walked inside the house, my mom, like, cussed at him.
21 She's like, you're a fucking idiot or something like
22 that. She said something like explicit.
23 And then he was just giggling, laughing.
24 And I was laughing, too, because I was just like --
25 like, why the -- like, what the hell? Like, that's
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1 just -- he walked outside. It's pouring rain. Like
2 covered in dirt.
3 Q. How old was he when he did that?
4 A. At least 17, 18. At least 16, 17, 18.
5 Q. Were all of those incidents in Parkland or
6 did some of that happen at the townhouse?
7 A. Well, the townhouse is in Parkland.
8 Q. Okay.
9 A. It all happened in Parkland.
10 Q. Okay. Did it happen at the big house or
11 the townhouse?
12 A. Well, the townhouse -- it was -- when we
13 moved to the townhouse, like, he -- that's when he
14 finally got his AR. He never had the AR when we were
15 living at 6166. He only like -- when we were living
16 at 6166, he would just take his shotgun out and then
17 he would just go in the backyard.
18 Like the 4th of July, I can remember,
19 like, he took his shotgun out and shot it at the
20 ground on the 4th of July. And yeah, like -- that's
21 like -- it was only there he, like, started doing it.
22 And when we got to Town Parc, he was just like -- he
23 was doing it like it was nothing, like during specific
24 times. Like during the hurricane. And it's not like
25 he would ever just, like, take his gun out and just
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1 randomly shoot the ground. It was during Hurricane
2 Irma specifically and pretty much -- pretty much all
3 that was during Hurricane Irma.
4 It all happened -- with the AR, all those
5 shots pretty much happened during Irma. But when he
6 shot into the garage, I can't really remember, like,
7 when that was. I can remember that was, like, on a
8 real sunny day and, like, it was just really nice
9 outside. He was just like -- like wanted to shoot his
10 gun so badly, he just took it to the garage and shot
11 right into the ground.
12 Q. Going back to Rocxanne's house. Did Nick
13 try to bury a gun there?
14 A. Yeah. Yeah.
15 Q. What do you know about that?
16 A. I just know, like, he was -- he was
17 planning on buying -- buying a gun from Dick's
18 Sporting Goods and I think he already had enough money
19 to get it. So he was just like -- he was like -- he
20 had dug up a space or something.
21 And then like -- I'm pretty sure I ratted
22 him out. I'm pretty sure that's what happened. I
23 think I told Rock or something. I told Rock or
24 Rocxanne that Nick's digging for like a space for his
25 gun in the backyard. So it was like -- yeah, I
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1 remember I ratted him out to, like, Rocky or Rocxanne.
2 Because, I mean, I just -- yeah. I just knew they
3 didn't want him with a gun, so I was like -- I mean,
4 I'm not gonna -- wouldn't know that he's putting a gun
5 in the backyard, so I just -- I did what I have --
6 Q. So what happened when you told them about
7 him trying to bury a gun in the backyard?
8 A. Oh, Rock -- Rock caught him digging. Like
9 Rock caught him, like, while he was trying to make the
10 hole bigger. Like, Rock just -- I just remember Rocky
11 confronted him about it and then -- yeah. Yeah.
12 Q. Is this when the fight started?
13 A. No. No. See, it could have. That could
14 have been the reason of the fight, but I don't know.
15 I don't know. I can't connect the dates like.
16 MS. MATHENY-WILLARD: Mr. Marcus, can we
17 take a bathroom break?
18 MR. MARCUS: Absolutely. Let's be back in
19 five minutes? Okay.
21 BY MR. MARCUS:
22 Q. Mr. Cruz, during this time period that
23 you're living at Rocxanne's, Nick was living there for
24 a time and then he went to live, I guess, with Caden.
25 Do you know Caden?
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1 A. Yeah. I don't want -- I mean, I knew him
2 from school and, like, we -- we definitely hung out
3 because he lived in, like, Coral Springs and I've been
4 to, like -- I've been in his neighborhood. I've hung
5 out with him.
6 Q. Okay. And did you know the Sneads, too?
7 A. Yeah. Actually, JT was in like -- we
8 actually had classes together since, like, middle
9 school. So, like, we had like a -- a sort of a
10 friend -- we were friendly. We were very friendly
11 with each other.
12 Q. JT was a good guy?
13 A. Yeah. Like we -- we did, like, group
14 projects together.
15 Q. Okay. Had you been to the Snead house?
16 A. I want to say only after the shooting to
17 pick up stuff. But a lot of the stuff there was,
18 like, damaged.
19 Q. Okay. So after your mother died and
20 before the shooting, do know about Nick taking care of
21 the banking issues, money?
22 A. We -- I can remember we used to -- we used
23 to like text -- have texts about it. We would text
24 each other about it. But that's the most I remember
25 about it.
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1 Q. Okay. Do you remember that he sent you
2 money?
3 A. Yeah. I'm pretty sure. Yeah.
4 Q. Okay. I'm going to show you on the
5 screen, and I think this is Wells Fargo records I'm
6 referring to. I think it's going to be -- first is
7 Page 120. Okay. So if you -- could you scroll to the
8 top, Aaron.
9 Okay. So I just wanted you to see that
10 this was a checking account with your mother's name
11 and Nikolas' name. Were you aware that there was a
12 checking account with Lynda and Nick's name on it?
13 A. Yeah, but I don't -- I'm not -- I don't
14 have knowledge of, like, stuff like this. Like, I
15 don't -- I don't know what any of this means. Like, I
16 never -- I never knew about money interactions, how
17 they --
18 Q. Okay.
19 A. -- my mom and my brother would handle it.
20 Q. Okay. How who would handle it, your
21 brother or your mother?
22 A. How they both would. Because my mom --
23 Nick literally had money from his job at the Dollar
24 Tree. So it was like -- my mom really, like, set up
25 banking for him and she already was going over all
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1 that with him already.
2 Q. Okay. So were you aware that your mother
3 would have your brother's Dollar Tree money deposited
4 into her account and then she would give him the cash;
5 that she would then cash -- sort of cash the check for
6 him and give him the cash? Were you aware of that?
7 A. Yeah, sounds kind of familiar. Familiar.
8 Q. So Nick had a lot of money in his pocket,
9 so to speak, right?
10 A. Yeah, because he worked.
11 Q. Okay. And so this is dated December 7,
12 2017 through January 5, 2018. So would you agree
13 that's the time period after your mother died and
14 before the shooting, right?
15 A. Yes. That's after my mom died and before
16 the shooting.
17 Q. Okay. So if we can scroll down to the
18 date of December 14, 2017. There's a note -- yeah,
19 there it is. December 14th where the -- do you see
20 where the hand is?
21 A. Yeah.
22 Q. It says, transfer to Cruz, Zachary on
23 12/14. And then reference, there's something, a
24 number. "Half of annuity minus half of attorney fee"
25 and it was $1,367. So do you recall that that was one
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1 of the transactions where Nick sent you some money?
3 at this point and the objection is a relevance
4 objection as it pertains to Zachary. I know
5 you're asking questions about Nick, but it
6 looks like these are attorney fees. If he had
7 an attorney, none of that is relevant. So I
8 would just ask -- if you could just give me
9 two minutes. Let me -- give me a few seconds.
11 MS. MATHENY-WILLARD: I'm going to
12 withdraw my objection for now.
13 BY MR. MARCUS:
14 Q. Okay. So Mr. Cruz, does this refresh your
15 recollection about -- maybe you don't remember the
16 exact amount, but this was one of the -- one of the
17 disbursements to you from your brother?
18 A. It's hard for me to remember that -- me
19 having -- getting a thousand -- I can't really
20 remember getting a thousand.
21 Q. Okay.
22 A. From my brother. I don't remember that.
23 Q. Okay. I want to show you another one.
24 It's on Page 125 of this record. And this is on
25 January 16th. It's that first line there, "transfer
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1 to Cruz, Zachary" on 1/13 of $400. Do you have any
2 recollection of that, receiving that money?
3 A. I think like -- just like -- I don't know.
4 I think my brother owed me that money so he sent it to
5 me. But I'm not -- I'm not a hundred percent sure.
6 Q. Okay. So, you know, we had talked about
7 before that this was a pretty good time between you
8 and your brother Nick. And so was he -- he was also
9 being fair with you as far as you knew about the
10 money?
11 A. Yeah, to my knowledge.
12 Q. Okay. I'm not sure if you're aware of
13 this or not. Were you aware that your mother was
14 getting something called an annuity? Maybe something
15 you learned about after the shooting. Were you
16 aware --
17 A. Is that social security for having me and
18 my brother? Like the money she --
19 Q. You're right. That is -- that is kind of
20 an annuity, social security. So you were receiving
21 social security and your brother was receiving social
22 security, correct?
23 A. Yeah, but it was me and my mom's --
24 Q. Right. So you said it was you and your
25 brother were receiving social security; is that right?
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1 A. Yeah, but it would go to my mom. She was
2 getting social security because of us. Like, she
3 would get a check because of us.
4 Q. Right. And she was using that money to
5 run the household, right?
6 A. Yes.
7 Q. Is that correct?
8 A. Yes.
9 Q. Okay. I want to show you another annuity.
10 I believe it's on Page 112, Aaron, I think. I guess
11 not. The 3,333. Okay. Right there. Okay. Right
12 there. So this is -- can we scroll to the top of the
13 page for a second so we see the date?
14 So this is October 6, 2017 through
15 November 6, 2017. And as you said, your mother died
16 November 1st. So it's during this time period. Okay?
17 A. Yeah.
18 Q. Okay. So now we'll go to the last line of
19 this bank statement from Wells Fargo and it says
20 10/27, Metropolitan, I believe that stands for annuity
21 payment, Lynda Cruz, $3,333.33 and that's money that
22 was transferred into the account. Were you aware that
23 she was receiving an annuity payment from Metropolitan
24 or did you become aware of it after the shooting?
25 A. Rocxanne -- I don't have any memory of
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1 what that is. Metropolitan payment, 3,000? I don't
2 remember that.
3 Q. Okay. After the shooting occurred, did
4 you inherit any money?
5 A. Not that I can really remember.
6 Q. You don't remember?
7 A. Yeah, I really don't really remember. I
8 mean, my mom had like MetLife things that I think I
9 might have got. Like, yeah. Just stuff from my mom
10 like after she died, like payments to me.
11 Q. Do you know if it was hundreds of
12 thousands of dollars that you inherited?
13 A. Yeah. I mean, the overall inheritance was
14 like -- it was a lot of money.
15 Q. How much?
16 A. I'm not really sure on the number. I know
17 it was like six figures.
18 Q. Okay. And where is your money?
19 A. It's, like, away. Like, I still have,
20 like, money that's supposed to be coming.
21 Q. So do you have the money or is it still
22 supposed to be coming? It's now over four years
23 later.
24 MS. MATHENY-WILLARD: Okay. I'm going to,
25 again, object at this point. And my concern
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1 is that this has -- a lot of the questioning
2 has to do with Zachary and not Nick. So I
3 will see if it's something I can resolve.
4 Give me just maybe a minute. Unless,
5 Mr. Reiner, do you want to --
6 MR. MARCUS: Well, the obvious, it's
7 because it went to both of them. So that's
8 why I'm asking.
9 MS. MATHENY-WILLARD: You're asking
10 specifically about his money though.
11 MR. MARCUS: I know, but it goes to both.
12 So learning from one gives me information on
13 another.
14 MS. MATHENY-WILLARD: Hold on one second.
16 MS. MATHENY-WILLARD: Okay. I'm back.
17 We're back on the record. I am going to ask
18 that you certify this question, this line of
19 questioning, and advise my client not to
20 respond.
21 MR. MARCUS: And what's your reason?
22 MS. MATHENY-WILLARD: It's outside the
23 scope of the questions. It's going to his
24 personal information. It has nothing to do --
25 it's after the shooting and it's not relevant.
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1 BY MR. MARCUS:
2 Q. So Mr. Cruz, what happened to the six
3 figure money? Did you receive it?
4 MS. MATHENY-WILLARD: Okay. Again, I'm
5 objecting to this line of questioning. This
6 is, again, after the shooting.
7 MR. MARCUS: Why don't you just say I
8 certify the question. I'm going to ask the
9 questions and you can say I certify. Okay?
10 That will be -- and then we can move on to the
11 next one. All right? So you certify the
12 question?
13 MS. MATHENY-WILLARD: I'm also asking him
14 not to respond to the question.
15 BY MR. MARCUS:
16 Q. Have you gotten any statements for money
17 that you have -- that you may have received from your
18 inheritance?
19 MS. MATHENY-WILLARD: Same objection. I'm
20 going to ask him not to respond. I'm going to
21 ask that the question be certified as well,
22 anything regarding the inheritance.
23 BY MR. MARCUS:
24 Q. Did you speak to your brother about your
25 brother's inheritance?
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1 A. No.
2 Q. What happened to your brother's
3 inheritance?
4 A. That's something I'm not -- I'm not a
5 hundred percent sure about. I'm not sure at all.
6 Q. Okay. Was the money donated to anybody?
7 A. Not that I know of.
8 Q. Okay. Is it fair to say you have no idea
9 where any money is that you may have inherited?
11 and ask him not to respond as it relates to
12 him, and that's what it sounds like the
13 question is.
14 MR. MARCUS: Counsel, are you representing
15 Mr. Donovan and Mr. Cruz at this hearing?
16 MS. MATHENY-WILLARD: I'm representing
17 Zachary Cruz and I'll be representing Richard
18 Moore.
19 MR. MARCUS: Okay. So you're
20 representing -- do you find that there's a
21 conflict here for you?
22 MS. MATHENY-WILLARD: There's no conflict.
23 MR. MARCUS: Okay.
24 MS. MATHENY-WILLARD: I'm not representing
25 Michael Donovan.
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1 MR. MARCUS: Okay.
2 BY MR. MARCUS:
3 Q. Hold on just a moment.
4 Prior to the shooting, when you two --
5 when you and Nick were not living together any longer,
6 were you in contact with Nick?
7 A. A little bit. A little bit.
8 Q. And how were you in contact with him?
9 A. I would say we send --
10 Q. I think you guys froze.
11 A. I said we sent text messages.
12 Q. Okay. I heard you say you sent text
13 messages. You're still frozen.
14 MS. MATHENY-WILLARD: Are we still frozen?
15 MR. MARCUS: Okay. We're all good now.
16 BY MR. MARCUS:
17 Q. So you sent text messages. How did you
18 send text messages?
19 A. Through an app, Instagram, like direct
20 message.
21 Q. Okay. Was there anyone else on that --
22 was it a group chat, more than you and him, or just
23 you and him?
24 A. What I remember, it was just me and him.
25 Q. Okay. Do you recall him talking about
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1 killing people in those Instagram messages during that
2 time period after your mother died and before the
3 shooting?
4 A. Yeah, I remember, like, him talking about
5 some -- mentioning like -- like, hurting people,
6 killing, killing people.
7 Q. Okay. And was Rocxanne mentioned as
8 somebody he wanted to kill?
9 A. I think so. And I think -- because it
10 would be like -- the description on the text would be
11 like, if they touch our money or anything, I'll go
12 over there and I'll -- I'll kill them all. It was
13 all -- it was all -- it was some -- like, had to do
14 with, like, our money. Or he had this -- this -- it
15 was about the money, about money.
16 Q. And you told him words to the effect that
17 stop talking like that, right?
18 A. Yeah, I tried to cancel it out.
19 Q. Okay. At what point in your life did you
20 learn that you were adopted?
21 A. It was probably middle school when my mom
22 sat me down and told -- told both of us that we were
23 adopted.
24 Q. Okay.
25 A. That was only because my mom got pressured
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1 from the neighbor to tell -- tell us that we were
2 adopted.
3 Q. Okay. And how did you take that news?
4 A. It's -- I can remember it didn't -- it
5 didn't -- it was never a big deal to me. It was
6 never -- I mean, it was a shock, definitely a shock.
7 But, like, I kind of like -- I figured it out myself
8 before she even, like, told me. Because I would just
9 look at pictures of Roger and I would look at pictures
10 of Lynda and then look at Nick and I just put -- I
11 pretty much put it together in my head. But then my
12 mom finally, like, sat down and confirmed it. But she
13 never --
14 Q. Okay. Are you saying that because of your
15 complexion you felt that something was not exactly
16 right here?
17 A. Yeah. Because I would just -- I would
18 look at everybody's facial features and like -- I
19 mean, I'm black. Like, they're -- they're not black.
20 Q. Okay. How did your mother explain that to
21 you before she eventually told you the truth?
22 A. Can you say that again?
23 Q. How did she account for your different
24 complexion before she finally told you the truth? Do
25 you understand complexion means color of your skin?
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1 A. She would tell me I'm white. She told me,
2 yeah, that I was white. But, like, it just -- it
3 really made no sense.
4 Q. Okay. So now you understand your father
5 was black; is that what you're told now? Or that's
6 what you were told when you -- when she finally told
7 you the truth or did she ever tell you that?
8 A. She never explained my ethnicity to me.
9 But, I mean, I've been just -- that's just -- yeah,
10 like -- that's what I go as. I'm black.
11 Q. Okay.
12 A. And my mom would try to tell me I'm not
13 black.
14 Q. Okay. Was there any -- strike that.
15 Growing up did you ever hear anything in
16 your house, any racial hatred towards blacks?
17 A. My mom called me the N word before.
18 Q. Your mother called you that?
19 A. Yeah. Because I got into a heated
20 argument and like -- I was, like, calling her things
21 way out of her -- out of her name and that's just how
22 she responded back.
23 Q. Okay. So are you saying you cursed at her
24 and she cursed back at you?
25 A. Yeah.
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1 Q. Was that after she had told you about
2 adoption -- about being adopted?
3 A. No. It was just -- for me, it was like --
4 it was just based on my regular behavior. Like, I've
5 been sent out of the home, like sent to group homes.
6 So I always had, like, behavior verbal problems with
7 my mom. And it was always intense.
8 Q. Right. Did you ever have any racial
9 issues with Nick?
10 A. I mean, I think -- nothing I could
11 remember. But I don't want to -- I don't want to,
12 like, excuse him. I think that we had some moments
13 where, like, it was just like -- it would just be like
14 I'd be calling him, like, racial things, like a
15 cracker, white, white trash or something like that.
16 And then maybe he would, like, call me the N. word.
17 It would just -- it would just -- it was
18 like giving me back the same energy, like, kind of
19 like -- from what I could, like, remember. Because I
20 remember -- I don't know.
21 There's -- there was like a kid we lived
22 with on the street that I remember, like, one time --
23 like, it was like one of -- like one of our good
24 friends. It's this black kid lived down the street.
25 I remember I had, like, threatened my brother. I was
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1 like -- I was like -- he was like, you want me to go
2 tell our friend down the street that you say the N
3 word?
4 And then, like, I remember when I told him
5 that, he had like -- become like -- I don't know.
6 Like, went into like a rage, like, because it was like
7 his good friend, like a really good friend of his. So
8 yeah.
9 Q. Okay. Did you become aware of Nick's
10 postings about killing black people but he would use
11 the N word?
12 A. No, I've never seen that.
13 Q. Okay. So did Nick ever taunt you for
14 having a black father, birth father?
15 A. No. Huh-uh. No.
16 Q. Okay.
17 A. And there's nothing I can really -- I can
18 never -- I can never remember anything of him being
19 racist towards me. Like, nothing pops up in my head.
20 Nothing that --
21 Q. How about do you know what a swastika is?
22 A. Yeah.
23 Q. What's a swastika?
24 A. It's the Nazi symbol.
25 Q. Exactly. Did you ever see your brother
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1 with a swastika symbol?
2 A. I mean, I remember growing up he spray
3 painted a swastika on a tree, like, in our back -- not
4 in our backyard. There was this thing when we were
5 living at 6166, there was like this thing behind our
6 backyard called the swells. It was like a drain for
7 the hurricanes basically and there's a bunch of trees
8 and stuff. And that was like my earliest memory of
9 him like -- like -- like -- like putting that symbol
10 on something. Like, he just spray painted on a tree
11 thinking it was --
12 Q. I'm sorry. How old was he when that
13 happened?
14 A. That was around like, I could say, like,
15 middle school days. Like, days we would just like
16 explore the neighborhood and just like explore the
17 swells and, like, just be on foot throughout our
18 neighborhood.
19 Q. Let me ask you that a little bit. So this
20 is when you lived at the big house, right?
21 A. Yeah.
22 Q. Okay. And where is this area that you
23 would go to?
24 A. It was right over our fence to our
25 backyard. Like, right -- right when you go over --
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1 when you go into our backyard, you go all the way to
2 the end of the backyard. There's a fence and you hop
3 over the fence. And it's just like -- it's just like
4 a -- like a field. Like a -- not a really big field.
5 Like -- it was like -- I don't want to say like --
6 it's just not a lot of size in it, but there's like
7 massive trees and like -- there was just all types of
8 grass and, like, high grass, like very high grass.
9 It's like a place where you would find
10 snakes and just all types of like -- like -- we'd see,
11 like, squirrels, birds, everything. It was just
12 like -- like a -- it was just like a -- it's hard to
13 explain what it was. It was like a drain pipe because
14 everybody had it in their backyard. So it's like this
15 strip of land that would go through everybody's, like,
16 backyard. It was like this behind everyone's
17 backyard.
18 Q. So it was an area that you and your
19 brother would play in together?
20 A. Yeah. And -- and we -- yeah, we had
21 friends we'd go back there with and we would just
22 like -- just like spend our outside time, like, just
23 exploring. Like, just looking through everything.
24 Q. What friends would come over for that?
25 A. I have to give you specific names?
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1 Q. Well, are they your friends or Nick's
2 friends?
3 A. Kids that live on the street. They lived
4 on 6166 --
5 Q. Okay.
6 A. -- Northwest 80th Terrace. Yeah.
7 Q. So would you all play together with Nick
8 and yourself and --
9 A. Yeah, we would just like start in the
10 backyard and just, like, be so bored. We'd just like
11 hop the fence. Like, go up -- up and -- up the
12 whole -- up all the way down to the end of the street,
13 through the swells, and then probably go the other
14 opposite way to the top of the street going through
15 the swells. Like, everywhere in the swells, that's
16 where we would like -- because we were -- from the
17 swells you could literally, like, access anybody's
18 backyard. You could, like -- because it runs through
19 everybody's yard. So yeah, it's like a path, pathway.
20 Q. How far would you and Nick travel?
21 A. Well, I mean, are you talking about like
22 just in the neighborhood or like just on foot?
23 Q. Yeah, on foot or bike.
24 A. Like --
25 Q. Where would you go?
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1 A. We really just like -- I don't know.
2 Like, just hang out with our friends, like, on the
3 street. Like, we'd go -- just really like on the
4 street mostly, the entire street. We would ride bikes
5 or scooters and just go up and down the street. Or
6 they'll be hanging out. And if we're in the backyard
7 or, like, swimming or anything like that, we'd just
8 like be on like the outs -- behind the neighborhood
9 kind of like -- just like -- because the swells,
10 that's what I mean, the swells. It's just like --
11 there's like this big area.
12 Q. How are you -- I'm trying to -- maybe
13 Joyce has picked it up. Swell, like S-W-E-L-L?
14 A. Yeah, S-W-E-L-L-S. I would add an S. to
15 that.
16 Q. Swells.
17 A. Yeah. Yeah. That's what they called it.
18 Q. Okay.
19 A. Growing up.
20 Q. Mr. Cruz, I read one time where you and
21 him went out at night, like you ended up five miles
22 away. Do you remember something like that happening?
23 A. Five miles?
24 Q. It was raining. Do you remember that?
25 A. No, I don't.
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1 Q. Okay. Would you and him sometimes sneak
2 out of the house together?
3 A. Sneak out of the house? Maybe when we
4 were, yeah, younger. Maybe when we were younger. But
5 not when we were like teenagers, never. We didn't --
6 there's no reason to sneak out. Just walk out the
7 door.
8 Q. Okay. So when you were sneaking out in
9 the middle of the night, where would you go?
10 A. Do you mean, like, if I snuck out with
11 Nick, where would we go?
12 Q. Yes.
13 A. I mean, I would say, like, nowhere. Maybe
14 like the closest would be like -- maybe -- maybe,
15 like, the Liberty Park that was right down -- like
16 literally, like, less than like a mile or so. Like --
17 like less than three miles away. That would be a
18 place we'd go a lot. I remember growing up, like,
19 we'd go there.
20 Q. How old were you at the time?
21 A. I would say, like, I was like maybe fifth
22 grade. Maybe like ten, 12, 11.
23 Q. Okay. So Nick was about a year and a half
24 older than you, right?
25 A. Yeah.
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1 Q. And so Nick would go to Liberty Park with
2 you?
3 A. Yeah, I can remember we went to Liberty
4 Park a few times together. He would go to the dog
5 park. That's not -- you're talking about sneaking
6 out. Like, I can't think of anywhere we would go that
7 we snuck out. The only place is like Walmart.
8 Q. Okay. Which -- which Walmart are you
9 talking about?
10 A. I'd say the one right next to Westglades
11 Middle School.
12 Q. Okay. So how far is that Walmart from
13 your house?
14 A. I would say -- I forgot how the miles work
15 out there. I would say it was maybe like ten miles.
16 No. No. Less than that. Eight. Seven miles.
17 Q. How would you get from your house to the
18 Walmart? Would you walk or bike or --
19 A. We could -- we would walk, ride bikes
20 maybe, if we both had a bike at the time.
21 Q. And you did this with your brother when
22 you were how old?
23 A. I mean, we got caught shoplifting at that
24 Walmart when we were real young because we had
25 traveled there together on foot. Not on foot. We
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1 both rode bikes. But then we both were like stealing
2 candy and stuff and we got caught by loss prevention.
3 And my mom had to come and pick us up. Same Walmart
4 right next to Westglades Middle School.
5 Q. How old were you about when that happened?
6 A. I was definitely like elementary school
7 days.
8 Q. Elementary school? Okay. So did Nick
9 know how to get from your house, the big house, to the
10 Walmart next to Westglades back in elementary school?
11 A. Yeah. Because we -- we had figured out it
12 was like just one road that gets there and it's the
13 main road. Like Holmberg Road, it's like as soon as
14 you get out of our neighborhood, Holmberg Road would
15 take you all the way to Walmart, just that one road.
16 So you just walk or bike ride.
17 Q. Okay. So he might have been ten, 12 years
18 old, and he was biking to Walmart from your mom's
19 house or your house?
20 A. Both of us. Yeah. Both of us.
21 Q. And where else would he bike to? You said
22 the dog park?
23 A. Well, no. He wouldn't -- no, the dog park
24 was too close. He was taking, like, Koby to the dog
25 park, he would just walk Koby all the way to the dog
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1 park and walk him back.
2 Q. Okay. Where else?
3 A. We had other dogs.
4 Q. Where else would he bike to? That was
5 pretty far a way.
6 A. Yeah. Let's see. I don't know. It's
7 hard -- it's hard to even think. I never -- I never
8 knew his -- his -- his routes. Like, I never knew
9 where he would go.
10 Q. Okay. Okay. But you know he went to
11 Walmart because you went there with him before?
12 A. Yeah. Yeah. But even when we were
13 teenagers, like, I could be like riding my skateboard
14 on the sidewalk and I would pass him on his bike and
15 we'd be going different directions. Like, I'd be
16 going back to the house. He'd be going somewhere on
17 his bike.
18 Q. Okay. Since the shooting you've spoken to
19 your brother many times, correct?
20 A. Yes, I have.
21 Q. Have you ever -- have you seen him in
22 person other than when you went to court?
23 A. No. Court's the only way I see him.
24 Q. Okay. So just in a general sense, what do
25 you usually speak to your brother about when you talk
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1 to him?
2 A. Just like childhood memories. Like,
3 things, like, we experienced growing up. Like, things
4 that just -- yeah, just -- just crazy, like, memories
5 mostly.
6 Q. Does he remember most of the stuff that
7 you bring up?
8 A. Yeah, most of the time. Most of the time.
9 I have to like -- but I have to, like, make sure. I
10 have to, like, paint a picture basically. Because I
11 have to, like -- most of it like -- there's like
12 certain things, like, that both of us never forget.
13 Q. Right. Does he remind you of things that
14 he remembers that you don't remember?
15 A. Yeah. Yeah. It works like that. Like,
16 he could remind me of certain things and I could
17 remind him of certain things.
18 Q. Okay. Did he ever tell you about the
19 shooting itself?
20 A. No. We've never talked about that.
21 Q. Why not? Just tell me why not.
22 A. Because it's -- it's not -- not -- not
23 what I want to talk to him.
24 Q. I'm sorry. What was your answer again,
25 please?
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1 A. It's not something I would want to talk to
2 him about.
3 Q. Okay. Is that true even after he pled
4 guilty?
5 A. I mean, eventually I see myself -- I could
6 see myself, like, trying to walk -- talk to him and --
7 but it's just -- it's just -- it's too -- it's too --
8 it's still too heavy for me to even -- I could never
9 even find words to start that off. Like, it just --
10 it's just so heavy. It could be so heavy, so.
11 Q. I understand. Did he ever talk to you
12 about the victims?
13 A. No. No.
14 Q. Okay. He likes to talk though, doesn't
15 he?
16 A. He could talk. Like, if he's like, I
17 would say, passionate about the topic, he could talk.
18 Q. What topics is he passionate about?
19 A. I mean, he was passionate about like --
20 like trying to join the Army back then. Like, that's
21 what I remember. Like, but he couldn't pass the
22 ASVAB.
23 Q. When he was younger he talked about
24 joining the Army?
25 A. Yeah. Not -- but not really when he was
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1 younger. It became more of like a -- like a career
2 option. It became like a thought of a career when he
3 was a teenager. Like, oh, I want to do that.
4 Q. And he --
5 A. That and guns. And he used to like --
6 like -- like want to be -- when he was younger he used
7 to want to be a veterinarian. If that's how you say
8 the word. Just take care of animals. But like, then
9 he -- then he -- like, when he became older he found
10 he liked guns and then started liking hunting.
11 Q. Okay. Did he like watching documentaries
12 about animals?
13 A. Yeah. He would, like, watch Discovery
14 Channel, Animal Planet. Like the things -- National
15 Geographic. Like, those type of shows, like.
16 Q. And could he spend like a whole day
17 watching, you know, documentaries about animals?
18 A. When he was younger. Not -- yeah, I would
19 say when he was younger. When he's like a teenager,
20 like, he would just like want to learn. He would
21 learn and then he just would like absorb the
22 information about an animal. His favorite animal back
23 then I swear was like a cheetah. He would know all
24 these facts. He would have a book about a cheetah.
25 Like, yeah. And the dinosaurs, too.
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1 Q. So if there was an hour-long documentary
2 about cheetahs, he'd sit and watch it?
3 A. Oh, yeah. Yeah.
4 Q. Okay. Or if there was a YouTube for an
5 hour about guns, he would watch it?
6 A. Yeah. Yeah.
7 Q. Okay. He didn't have any problems sitting
8 in front of a TV to watch something he was interested
9 in?
10 A. Yeah. Yeah, no. Huh-uh.
11 Q. Okay. When you talk to him, does he make
12 sense to you?
13 A. I mean, the conversations I can
14 understand. Like, yeah, we have back and forth
15 communication.
16 Q. Okay. Like if he talks about memes -- is
17 it memes, M-E-M-E-S? Is that what it is?
18 A. Yeah.
19 Q. Anime or --
20 A. Memes. It's like, yeah, internet. Like,
21 pictures. Like, jokes. Yeah.
22 Q. Okay.
23 A. And he -- he had a little bit of knowledge
24 of memes and stuff. Like, YouTube stuff. Like, he
25 would, like, put on funny YouTube videos or try not to
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1 laugh on YouTube. There's videos like that. I
2 remember he would like be interested in stuff like
3 that. Things that would make him laugh.
4 Q. Can he explain this to you? Like, if you
5 don't understand what anime is -- like I don't
6 understand what it is -- can he explain what anime is?
7 A. I mean, he watched -- I mean, he -- he
8 grew up on Naruto, like, playing the game, watching
9 episodes of Naruto. So he knows what anime is. He
10 watched Pokemon. I mean, he liked anime. He wasn't a
11 big anime person, but he could explain what anime is.
12 Q. Okay. Did he ever show -- I'm sorry. I
13 didn't mean to interrupt you. It's hard sometimes on
14 this.
15 A. I was saying, the most I could hear him
16 say is, like, it's a Japanese cartoon. That's what I
17 think anime is.
18 Q. Okay. Did he ever explain things to you?
19 Like a new video game that you didn't know how to
20 play, would he show you how to play it?
21 A. The most I -- just that one question only
22 makes -- I mean, he played a Spider-Man game that he
23 was really good at. It's called Spider-Man: Web of
24 Shadows for Xbox 360. He was obsessed with that game.
25 Literally, like, that was like -- that was like -- he
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1 like -- that was his treat, just playing -- playing
2 Spider-Man: Web of Shadows. So yeah, I mean -- did I
3 answer your answer? I'm sorry. I don't know.
4 Q. Did he explain how he got so good to you
5 and, you know, make you better at it?
6 A. Well, I mean, it was more like a kid's
7 game. It's like -- but it had like decisions, choices
8 you could make in the game that effect the score. All
9 the endings were different. So it's like -- that's
10 why he was so obsessed with the game because, like,
11 there was so many different -- different endings in
12 the game.
13 Q. When you talk to him in the jail, are
14 there like certain rules he has to follow and you have
15 to follow?
16 A. Yeah. I mean, well, yeah. I can't -- I
17 can't show him a picture or any -- a video off of my
18 phone. Like, if I wanted to show him a picture or
19 anything, it would have to be printed on paper and,
20 like, approved basically.
21 Q. Okay.
22 A. And, yeah, that's really like -- like -- I
23 don't know. There's like certain -- if I'm video
24 chatting him, like, there can't be anybody else in the
25 video chat besides me.
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1 Q. Okay. How did you learn these rules?
2 A. Just from BSO. Just like learning how to
3 use the app, the new app, Securus.
4 Q. Okay.
5 A. They just give us all these extra rules
6 because of Nick.
7 Q. Did Nick tell you about these rules, too?
8 A. I was like -- I was -- well, yeah. Yeah.
9 Because he was like -- he'd be like -- he will tell
10 me, like, don't show me nothing off your phone. Don't
11 do this. Don't do that or they're gonna turn it off.
12 Q. So he's aware of the rules at the jail,
13 right?
14 A. Yeah. Yes.
15 Q. Did he ever talk to you about that attack
16 of the guard?
17 A. Attack of the guard?
18 Q. Yeah. When he attacked the guard, did he
19 ever talk to you about that?
20 A. No, I've never -- a guard? I've never
21 heard of that.
22 Q. You don't know what I'm talking about?
23 A. No.
24 Q. You didn't know he attacked a guard and
25 took his Taser away from him?
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1 A. Oh, okay. I thought you were talking
2 about like -- like, when he was younger. No. I know
3 about the police -- yeah. Yeah. In the -- in the
4 jail? Yeah.
5 Q. Okay. Did he ever talk to you about it?
6 A. No. We -- no. No. I -- I -- no. That's
7 not something I try to talk to him about.
8 Q. You stayed away from that topic, right?
9 A. Yeah. Yeah.
10 Q. Okay. How did you find out about the
11 shooting?
12 A. I was -- Rocxanne basically. She -- she
13 came to the skate park and like -- like, I was -- I
14 was just at the skate park and she, like, came in my
15 mom's Kia. And she, like, ran into the skate park
16 like -- and like -- she was just like, Zack, you need
17 to come here now, now, now.
18 And she had, like, basically, like, pulled
19 me into -- like pulled me into, like, the car
20 basically. And then, like, she showed me, like, an
21 article that was saying like -- like shooting at
22 Marjory Stoneman Douglas. 17 dead. And then I just
23 saw like Nikolas Cruz and then a picture. And then
24 like I just remember crying.
25 And then her son started laughing me. But
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1 he's a young kid, Tyler. He was like five, six. He
2 doesn't understand what's happening. So it was -- it
3 was just all that -- it was -- it was a lot.
4 It almost feels like I blacked out, I
5 would say, because I was just -- I remember being in
6 West Palm Beach and then -- then driving -- and then,
7 yeah, just driving back to the trailer house.
8 Breaking -- I broke my phone because, like, everybody
9 was texting me. Like, sending me Snapchats and
10 like -- just like -- like people from the skate park
11 were like -- were talking crazy to me. Like -- on
12 like -- on Instagram through, like, direct messages.
13 It was a lot. It all -- it all, like -- it all, like,
14 fell down on me in, like, ten minutes. Like, it was
15 just like really intense.
16 Q. How did you end up at the police
17 department that night?
18 A. They -- they -- they called -- the FBI
19 called Rocxanne and they said, we need -- we need you
20 and Zack for -- to come here and do an interview right
21 away. And, like, they were like very, like,
22 demanding. Like, they -- they -- they -- because they
23 were -- there was already a SWAT team coming to the
24 trailer park to search -- search everywhere in
25 Rocxanne's property.
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1 Q. Right.
2 A. So the FBI was like saying, like,
3 basically you come here or we'll come there. And
4 like, yeah. Rocxanne -- as soon as, like, the SWAT
5 team and like the big SWAT truck was already in the
6 neighborhood. Rocxanne was just -- was already, like,
7 over it. She was just like losing -- losing her
8 marbles. So it's like she was --
9 Q. Right.
10 A. We hopped on the highway, me and her. And
11 then Tyler and Rocky and Rocky's girlfriend, they're
12 all still at the trailer. And then, like, an hour
13 into us just being in the -- at the interview once we
14 got there, like -- like, she FaceTimed Rocky. And
15 then like literally, like, the whole neighborhood
16 like -- like was cut off with, like, caution tape.
17 Like, they had the bomb squad. They had dogs. They
18 had like -- like, not -- no, no, I'm not going to say
19 helicopter, but they had like boots on ground all
20 around her house, like everywhere, searching.
21 Q. Right.
22 A. All of nooks and crannies, like
23 everywhere. Just searching everything.
24 Q. Right. So when you -- so you and Rocxanne
25 drove together down to the police public safety
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1 building?
2 A. Yeah, Broward County.
3 Q. Yeah. Is that what happened, you drove
4 down?
5 A. Yeah. The main jail. Yeah, the same
6 building that Nick was in. And then --
7 Q. Yeah, the police --
8 A. And when they brought me --
9 Q. The police didn't -- sorry.
10 A. I'll just give you, like, extra
11 information. Like, when they brought us to the
12 interrogation room, there was like -- like -- like --
13 like basically the waiting room that I had to sit in,
14 like the Uber driver who drove Nick to the -- to the
15 school, her son was like sitting in the -- in the
16 waiting room basically.
17 I saw, like, the lady, the actual Uber
18 driver. She came out. She was crying and stuff. Her
19 son was like hugging her, counseling her.
20 And then I saw Andrew Medina, the Stoneman
21 Douglas security guard. Like, he was there. And I'm
22 surprised he didn't say nothing to me because we were
23 in a room together and he just got done with his
24 interview and then he comes into the waiting room.
25 And I know it was him because I knew him from school.
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1 I recognized him.
2 He didn't even, like, recognize me, which
3 was just mind blowing to me because I thought if
4 anything he would -- like, he was just -- no one
5 really knew I was Nick's brother at the time in those
6 moments. But it was weird because we had this bubble
7 with people.
8 Q. I just wanted to clarify something. You
9 and Rocxanne, you didn't drive with the police. You
10 drove down yourselves together?
11 A. Yeah, we drove. Yeah, me and Rocxanne
12 drove together.
13 Q. Okay. And before -- how did it happen
14 that you went into the room with Nick?
15 A. It was like -- I did my interview and then
16 basically they were like -- after I was done with the
17 interview, they were like, so do you want to see your
18 brother? He's in the other room.
19 And then like -- it was just like they had
20 presented me with that and I didn't know if I was
21 ready or not. But then I was just -- I was just like,
22 all right. If he's in the other room, I want to see
23 him. And then they brought me to him.
24 And then -- I don't know. I tried to just
25 give him a piece of my heart. But, like, it just --
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1 it's just so many other -- like, I was just thinking
2 about everybody, everybody effected by it. So it was
3 just -- it was hard to even be there. It was just --
4 it's just -- it feels like -- I don't know. Like, it
5 feels like it was like an out-of-body -- like just --
6 just doing what I --
7 Q. I'm sure.
8 A. Yeah.
9 Q. Did the police say anything to you before
10 going into the room of what you should ask him or
11 anything like that?
12 A. No. No. They were like, do you want to
13 see him? And they kept it short like that. They
14 didn't like -- yeah, they were just like, do you want
15 to see him? He's here.
16 Like -- like this -- like in my head I was
17 thinking, I don't know when I'm ever going to be able
18 to see him again. So I just took the opportunity when
19 I had it.
20 Q. Okay. So eventually you -- well, after
21 the police station you go back with Rocxanne to her
22 house, correct?
23 A. Yeah.
24 Q. How does it end up that you stop living
25 with Rocxanne? What happened?
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1 A. So basically I started like -- I took my
2 mom's car away from her basically because, number one,
3 no one legally was able to drive that car. But no one
4 should have been driving that car ever.
5 But like, it was -- Rocxanne took me in,
6 she took in Nick, and it's like that came with my
7 mom's car. So it was just like -- I just got so
8 annoyed with, like, me just having to skate on the --
9 like ten miles every day just to get to the skate
10 park. And like -- just like -- just doing that
11 repeatedly while I knew Rocxanne was using my mom's
12 car to go here, go there, do this, get food here, do
13 that, go party or something.
14 It got to a point I was just like -- she
15 left -- she would leave the keys on the counter and I
16 was just like, I took it. And I was like, I'm not
17 giving it back to her at all. And then, like, I stood
18 on that for like a few days.
19 And then, like, my -- she called the
20 police on me to violate my probation. Because she was
21 like -- she said she was worried that, like, I was
22 going to injure somebody or kill myself like driving.
23 So she just -- she called the police while -- while I
24 took the car out.
25 And then while I was at the skate park,
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1 yeah, and then BSO -- the chief of probations came to
2 West Palm Beach and he was just was watching me at the
3 skate park while I hopped out of the car and got back
4 in the car. So that was enough for him to violate my
5 probation. And then the next day there was a warrant
6 for my arrest and they were knocking on my door
7 arresting me, taking me to West Palm Beach.
8 Q. So let me just get the order of things.
9 The probation you're talking about, was that from
10 trespassing on Stoneman Douglas?
11 A. Yes. Yes. Chief of probation of Broward
12 County.
13 Q. Okay. And I obviously don't care about
14 whether or not you were driving a car without a
15 license, but was that what that was about?
16 A. Yeah.
17 Q. You were driving a car without a driver's
18 license?
19 A. Yeah. That violated my probation.
20 Q. Okay. When you said you took the car from
21 her, did you take the keys or did you take the car?
22 A. The keys to the car.
23 Q. Okay. Okay. So you hid -- you hid the
24 keys from her I guess, right?
25 A. Yeah. Like, I kept them on me. Like, I
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1 put them in my pocket. Like, I just -- even if
2 like -- I don't know. It got to a point where I would
3 just like -- I wouldn't even, like, communicate with
4 Rocxanne. Like, I had, like, enough money on my card
5 and stuff. I knew if I could just get out in the
6 morning, like, I wouldn't have to hear from her the
7 whole day.
8 But I know she was going to be wanting to
9 use the car the whole day. So it's like I just
10 kept -- I just started doing that. I would leave real
11 early, go to the skate park with the car. And then,
12 yeah, it just came to that day where she called the
13 police while I was doing it.
14 Q. Okay. So at some point did you go
15 somewhere else, some other house?
16 A. No. No. I -- I -- it was -- I was in --
17 once I got arrested for violating my probation, I
18 waited in jail. I don't know how many days. I think
19 more than a week I was in jail. And then they had to
20 transfer me to Broward County. And once I got out of
21 jail, Rocxanne said I couldn't come back to live with
22 her.
23 And I was just lucky enough to meet Mike
24 and Richard and they offered me a job in Virginia for
25 like a whole year to just work and have a free condo
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1 to myself. Like -- so, like, I -- I had to take that.
2 I mean, it was the best thing that anybody --
3 Q. Okay. How did you meet Richard and
4 Mr. Donovan there?
6 at this point.
7 MR. MARCUS: You're going to object?
8 MS. MATHENY-WILLARD: Yes. I know that he
9 brought it up, but he's been going on -- I'm
10 going to object at this point because it's not
11 relevant and ask that it be certified. Ask
12 the question be certified and ask that he not
13 respond. It's after the shooting.
14 MR. MARCUS: You do realize bias is
15 relevant, right? You do realize that?
16 MS. MATHENY-WILLARD: But I don't know
17 what that has to do with Nick. So is there
18 some bias here in --
19 MR. MARCUS: It has to do with witnesses.
20 It has to do with any witness who testifies.
21 I'm allowed to go into bias.
22 MS. MATHENY-WILLARD: Okay. So what is
23 the bias that you're trying to prove?
24 MR. MARCUS: I don't have to tell you
25 everything. I can tell you it's a relevant
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1 topic. You do recognize bias is a relevant
2 topic?
3 MS. MATHENY-WILLARD: I do. I'm asking
4 that it be certified. I'm asking him not to
5 respond.
6 MR. MARCUS: Okay. All right. So we're
7 going to have a lot of questions here.
8 BY MR. MARCUS:
9 Q. So how did you meet Richard Moore?
10 A. I met him when -- when -- basically right
11 after I got out of jail. I went to the hotel he was
12 staying at and, like, he's the one that offered me a
13 job. He's the one that offered me to come live in
14 Virginia and get away from the madness.
15 Q. Well, how did you know to go to a hotel to
16 see Richard Moore?
17 A. With Mike. Mike got me out of jail. Mike
18 was -- was my ride out of jail.
19 Q. And did you know Mike before he got you
20 out of jail?
21 A. No. I met him like -- I mean, I --
22 Rocxanne had communicated with, like, Mike and Mike's
23 lawyers before I was in jail. But then like once,
24 like, they figured out that, like, I was -- like, I
25 wasn't even, like, on good terms with Rocxanne any
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1 more. Like, Mike came to meet me himself basically
2 and then got me out of jail. Got me -- helped keep
3 the cameras away from me. Like, made sure I felt
4 safe.
5 Q. So is that the first time you met Mike
6 Donovan was when he got you out of jail?
7 A. Yeah, when I walked out of jail.
8 Q. And you have no idea why he was getting
9 you out of jail?
10 A. No, I didn't. I didn't know nothing when
11 I was walking out early. I had met a security -- I
12 met one of Mike's security. He was the one that
13 like -- like helped me walk out of the jail. Like,
14 well, helped me get through, like, the process.
15 Like, they -- because, like, the chief of
16 probation, he didn't want me to just walk out into,
17 like, all those cameras. So, like, Mike's security
18 guard came and met me in the bathroom inside the jail
19 and basically, like, we had planned out the best time
20 to walk out. The best -- yeah. Yeah.
21 Q. Who was security?
22 A. I don't remember his name.
23 Q. Was he from the jail or --
24 A. No. Hired security.
25 Q. Whose security?
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1 A. This is Mike's -- Mike and Richard's
2 security guard.
3 Q. Mike and Richard have a security guard?
4 A. Yeah. At that time.
5 Q. And he met you at the jail?
6 A. Yeah.
7 Q. And you didn't know who this guy was? You
8 never met him before, right?
9 A. No. But he told me -- once he told me he
10 was with Mike and with my lawyers, I felt -- I -- I
11 didn't -- I didn't question him or nothing.
12 Q. Okay. And were you introduced to Mike by
13 your lawyers?
14 A. It's like I met him myself basically.
15 There was no -- like, my lawyers were there, but like,
16 they were Mike's -- they're like Mike's workers that
17 are my lawyers. Like, they work for Mike. So it was
18 like Mike's the chief.
19 Q. Okay. So these are lawyers who work for
20 Mike and they got you out of jail?
21 A. Yeah.
22 Q. Okay. And when you left the jail you went
23 to a hotel?
24 A. Yeah. To --
25 Q. And this is -- which hotel? Do you know?
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2 to relevance. This is getting far afield with
3 regard to how it concerns Nick. Again, this
4 is after the shooting. It's Zack's life after
5 the shooting. It's not relevant. So at this
6 point I'm going to ask you to certify and I'm
7 going to instruct him not to answer.
8 BY MR. MARCUS:
9 Q. And did you meet Richard Moore at the
10 hotel?
11 A. Yes, I did.
12 Q. Okay. And what was your conversation with
13 Richard Moore?
14 A. It was basically, like, he felt bad. He
15 was, like, apologizing for everything I was going
16 through. And, like, trying to make me feel like the
17 world wasn't ending.
18 Q. Okay. And did you stay at the hotel or
19 where did you go from there?
20 A. I stayed at the hotel. Yeah. They helped
21 clean me up basically. Yeah.
22 Q. Okay. And what did Richard do for you
23 there?
24 A. Like, he, like, tried to -- guarantied me
25 a future.
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1 Q. Okay. What kind of future did he
2 guarantee you?
3 A. A job as a -- basically a maintenance man
4 with a free condo for a year.
5 Q. A free condo for a year and a maintenance
6 man?
7 A. Yeah. Work as a maintenance man. Like,
8 go around with the crew. Like work, do repairs and
9 stuff. Like, you know, like maybe, like, fix a door,
10 paint a gate. You know like -- like, appliances.
11 Yeah.
12 Q. Okay. And was there anything that was
13 expected of you? You would just work and they would
14 give you a free condo? Or Richard would give you a
15 free condo?
16 A. Yeah. Yeah. I was going to work as a --
17 I would just try to, like, keep -- keep my head low
18 from all this.
19 Q. Okay. And did you understand at that
20 point that Richard and Mr. Donovan were married?
21 A. Yes.
22 Q. Okay. So they were a team?
23 A. Yeah.
24 Q. Correct?
25 A. I knew they were partners.
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1 Q. And they both helped you, correct?
2 A. Yes.
3 Q. Yes?
4 A. Yes.
5 Q. So did you leave Broward County shortly
6 thereafter or when did you leave?
7 A. Well, we had to -- first, because I --
8 because I was on an ankle monitor with Broward County,
9 I wasn't -- because I wasn't allowed to leave the
10 state. So I had to go to court and, like, Mike got me
11 a really good lawyer and, like, I was able to get it
12 approved through the judge to go work the job in
13 Virginia and get away and, like, still be on my
14 probation and, like, still follow all the rules of
15 that. And yeah, like, it all -- it all worked out.
16 The judge granted me my motion.
17 Q. Okay. And so for the last -- so do you
18 know when this was when you left Broward County?
19 A. I don't really remember.
20 Q. All right. Was it in 2018?
21 A. Yes. Yeah.
22 Q. Okay. And have you lived in Virginia
23 since then?
24 A. Yes.
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1 at this point. I'm going to ask that you
2 certify that question. I'm going to instruct
3 him not to respond.
4 Anything that has to do with after he left
5 and he's here in Virginia I'm going to be
6 objecting to. And in terms of bias, I
7 understand bias towards Nick, but the
8 relationship between Zack and Rich is not
9 relevant towards -- for bias.
10 MR. MARCUS: Well, Richard's a witness, so
11 I think it does apply. I think that's pretty
12 obvious, counselor. But if you want to waste
13 your time and certify, that's up to you.
14 That's okay with me.
15 MS. MATHENY-WILLARD: Bias regarding Nick,
16 that is relevant. Rich having a bias
17 regarding another witness is not relevant.
18 MR. MARCUS: Okay. Whatever you think.
19 Just make your objection.
20 BY MR. MARCUS:
21 Q. So where did you live in Virginia?
22 MS. MATHENY-WILLARD: Objecting to this
23 question and this entire line of questioning
24 and I'm going to ask him not to respond. I'm
25 going to ask that you certify that question as
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1 well.
2 BY MR. MARCUS:
3 Q. Do you live with Richard Moore?
4 MS. MATHENY-WILLARD: I'm objecting to
5 that. Again, anything after he moved to
6 Virginia I'm going to ask that you certify and
7 that he not respond.
8 BY MR. MARCUS:
9 Q. Do you have any business interests with
10 Richard Moore or Michael Donovan?
11 MS. MATHENY-WILLARD: I'm going to object,
12 ask him not to respond, and ask that you
13 certify that question.
14 BY MR. MARCUS:
15 Q. Have you -- did you start a charity?
17 ask that you certify that question, and ask
19 BY MR. MARCUS:
20 Q. Is the charity called We Isolate No-one?
22 ask him not to respond, and ask that question
23 be certified as well.
24 BY MR. MARCUS:
25 Q. How much money do you make from the
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1 charity?
3 ask that you certify that question, and ask
5 BY MR. MARCUS:
6 Q. How much does Richard Moore make from that
7 charity?
9 ask that you certify that question, and
10 instruct him not to respond.
11 BY MR. MARCUS:
12 Q. How much does Michael Donovan make from
13 that charity?
15 ask that you certify that question, and
16 instruct him not to respond.
17 BY MR. MARCUS:
18 Q. Have you been arrested since the -- since
19 after the -- have you been arrested while in Virginia?
21 ask that you certified the question.
22 MR. MARCUS: You're kidding me? Are you
23 serious, counselor?
24 MS. MATHENY-WILLARD: If he has pending
25 charges, obviously he has a right to remain
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1 silent. He has the Fifth --
2 MR. MARCUS: I haven't heard --
3 MS. MATHENY-WILLARD: -- I'm very serious.
4 So again --
5 MR. MARCUS: Counselor, actually, I know
6 you're not familiar with Florida law, or at
7 least you're not a Florida lawyer so I might
8 assume you're unfamiliar with Florida law.
9 And I'm going to direct you to Florida Statute
10 914.04, which is entitled: Witnesses, persons
11 not excused from testifying or producing
12 evidence in certain prosecutions on ground
13 testimony might incriminate him or use of
14 testimony given or evidence produced.
15 The statute says very clearly that a
16 witness under subpoena by the State Attorney's
17 Office has use immunity for anything he says
18 in a deposition except for perjury. I can ask
19 him any question, but I can't use it against
20 him in a subsequent action.
21 So, for example, if I asked him: Were you
22 involved in a robbery on Walnut Street, and he
23 says, yes, I committed that robbery, I can't
24 use that against him. But I can use -- I
25 could charge him with perjury if he lied about
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1 it.
2 So the fact that he's charged with a crime
3 is a matter of public record. It's not
4 incriminating, for one. But even if it was, I
5 can still ask him the question.
6 BY MR. MARCUS:
7 Q. So my question is, have you been arrested
8 in Virginia?
9 MS. MATHENY-WILLARD: I'm going to ask him
10 not to answer that question. I appreciate
11 your review of the law. I am objecting based
12 on relevance. If it's a question if he's been
13 convicted of a felony or convicted of a crime
14 of moral turpitude, I'll allow him to answer.
15 But again, this is a relevance objection.
16 BY MR. MARCUS:
17 Q. Okay. Does the charge involve Grand Jury
18 testimony you were supposed to give against Richard
19 Moore?
20 MS. MATHENY-WILLARD: I'm going to ask --
21 I'm going to ask that that be certified, ask
22 him not to answer the question.
24 MS. MATHENY-WILLARD: Object to that as
25 well.
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1 MR. MARCUS: That's fine.
2 MS. MATHENY-WILLARD: And are we able to
3 at least take a 10-minute break minute? We
4 are free all day if you want to take a lunch
5 break at this point.
6 MR. MARCUS: Well, here's the problem. I
7 realize we were supposed to do Richard Moore,
8 too, but there is another deposition at 1:30.
9 MR. KLINGER: It's at 3:00.
10 MR. MARCUS: Starts at 3:00?
11 MR. KLINGER: Yes.
12 MR. MARCUS: Okay. Well, it's certainly
13 reasonable to take a break for lunch. Is 30
14 minutes enough for you all? 1:00 o'clock
15 okay?
16 MS. MATHENY-WILLARD: That's fine.
17 MR. MARCUS: Okay. We'll be back at
18 1:00 o'clock then. Thank you.
20 BY MR. MARCUS:
21 Q. Mr. Cruz, do you own any websites?
23 ask that he not answer that question, and ask
24 that that question be certified.
25 BY MR. MARCUS:
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1 Q. Do you have any interest in any
2 businesses, Mr. Cruz?
4 ask that that question be certified, and
5 instruct him not to answer.
6 BY MR. MARCUS:
7 Q. Are you involved in any business that
8 makes money off of your brother's killing of 17
9 people?
10 A. No.
11 Q. Do you -- what is Being Zachary Cruz?
13 ask that he not answer that question, ask that
14 that question be certified.
15 BY MR. MARCUS:
16 Q. What is The System?
17 MS. MATHENY-WILLARD: I'm going to be
18 object, instruct that he not answer that
19 question, ask that that question be certified.
20 BY MR. MARCUS:
21 Q. Does the show Being Zachary Cruz make
22 money off of your brother's killing 17 people?
23 A. No.
24 Q. Do you make any money off of Being Zachary
25 Cruz?
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2 ask that he not answer that question, and ask
4 BY MR. MARCUS:
5 Q. Have you participated in any protests with
6 The System?
8 instruct him not to answer that question, ask
10 BY MR. MARCUS:
11 Q. Are you paid a salary as a result of your
12 involvement in with The System or Being Zachary Cruz?
16 Mr. Marcus, can you hold on one second.
17 Let me just close this door.
18 BY MR. MARCUS:
19 Q. Have you been involved in any protests of
20 any police officers?
24 BY MR. MARCUS:
25 Q. Have you been involved in protests of
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1 police officers who have investigated Richard Moore or
2 Michael Donovan?
6 BY MR. MARCUS:
7 Q. Are you aware of the felony records of
8 Richard Moore and Michael Donovan?
10 instruct him not to answer, ask that that
11 question be certified.
12 BY MR. MARCUS:
13 Q. Has Richard Moore been arrested during the
14 time you've lived with them?
18 BY MR. MARCUS:
19 Q. Are you aware that Richard Moore is facing
20 ten federal counts?
22 instruct him not to answer, and ask that that
24 BY MR. MARCUS:
25 Q. Are you aware Richard Moore is also facing
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1 state perjury charges for lying?
5 BY MR. MARCUS:
6 Q. Do you know if Richard Moore or Michael
7 Donovan have been to prison?
11 BY MR. MARCUS:
12 Q. Are you aware of their involvement in
13 white collar crimes?
17 BY MR. MARCUS:
18 Q. Are you aware of lawsuits being filed
19 against them by state attorney generals?
23 BY MR. MARCUS:
24 Q. Was it your idea for Michael Donovan to
25 sit through this deposition or was it his idea?
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1 A. It was my idea.
2 Q. And has Richard Moore been in the room?
3 A. No.
4 Q. Has any money been donated to the victims
5 of your brother's massacre that you're aware of?
7 ask him not to answer. Give me one --
8 MR. MARCUS: Tell my why.
9 MS. MATHENY-WILLARD: Give me one second
10 on that. Hold on. Actually, first, can you
11 repeat the question?
12 BY MR. MARCUS:
13 Q. Has any money that you know of been
14 donated to victims of your brother's massacre from
15 your family or your money or your brother's money?
16 MS. MATHENY-WILLARD: Okay. I'm going to
17 withdraw my objection. If you can repeat the
18 question for Zack.
19 BY MR. MARCUS:
20 Q. Has any money been donated to victims of
21 your brother's massacre from your family?
22 A. No.
23 MS. MATHENY-WILLARD: And -- okay. Just
24 let me say that you're talking about his
25 knowledge, right? Because your question was:
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1 Has any money been donated? You mean to his
2 knowledge? Because I guess at this point
3 I'll -- it's an objection to the form. He
4 doesn't know what money has been donated to
5 the victims. You didn't ask to his knowledge.
6 I'm just confirming that he's speaking from
7 his own knowledge.
8 BY MR. MARCUS:
9 Q. So no one has told you that money has been
10 donated from your family, you or your brother's money,
11 to victims, correct?
12 A. No.
13 Q. Do you have any memory of your adopted
14 father, Roger Cruz?
15 A. Yes.
16 Q. In general can you tell me what those
17 memories are?
18 A. He would take us to Toys-R-Us.
19 Q. Okay. So I take it pleasant memories?
20 A. Yeah.
21 Q. Okay. Do you have any recollection of him
22 actually passing away?
23 A. No. I mean, I remember being explained
24 what happened to him, kind of.
25 Q. Okay. Have you ever stated to your
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1 brother Nick that you blamed him for the passing of
2 Roger Cruz?
3 A. Not that I can remember.
4 Q. Okay. I'm going to be moving into another
5 area from your past, and I'm just going to be asking
6 what you remember of this time. And again, I
7 apologize I have to ask you these questions.
8 Do you recall the first time that you
9 started to receive therapy from Henderson?
10 A. I mean, I could remember from middle
11 school.
12 Q. Okay. If I can refresh your recollection.
13 I'm going to try to to see if any of this refreshes
14 your recollection. In 2009, October of 2009 - so you
15 would have been nine years old - you began therapy
16 with an Amanda Levison. Does that ring any bell to
17 you?
18 A. No.
19 Q. Do you recall having therapy at your house
20 from an early age?
21 A. Yes.
22 Q. Okay. And so you don't -- you don't
23 specifically recall Amanda Levison, do you?
24 L-E-V-I-S-O-N.
25 A. No, I don't.
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1 Q. Okay. At the age of almost ten,
2 January 27th of 2010, do you recall an incident where
3 they alleged that you abused a family dog with a leash
4 to anger them? Do you recall not being allowed near
5 the dogs after that?
6 A. No.
7 Q. Okay. Do you recall that there was a
8 second period of time that you began with Henderson
9 therapy in May of 2012? Do you recall that?
10 A. I don't remember.
11 Q. Do you recall a Sarah Leace, L-E-A-C-E,
12 being a therapist for you?
13 A. No. I don't remember her.
14 Q. And do you recall it was because of
15 misbehavior towards your mother, cursing, arguing?
16 A. Yeah, that's why I had therapy.
17 Q. Okay. Do you recall any diagnosis that
18 was made of you? Was it ever told to you what your
19 diagnosis was?
20 A. I think ADHD.
21 Q. Okay. Is that it?
22 A. That's like the only word I can really
23 remember from back then.
24 Q. Were you ever told you had a mood
25 disorder?
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1 A. No.
2 Q. Okay. Did you have a -- did you tell your
3 therapist back then that you wanted to "get to mom"?
4 A. What does that mean?
5 Q. Annoy her.
6 A. I probably did say that.
7 Q. Okay. Is that because you intentionally
8 wanted to annoy your mother back then?
9 A. Yes, I did.
10 Q. Okay. Were you able to control your
11 behavior; you just chose not to?
12 A. I mean, I -- I mean, I -- I don't know. I
13 mean, I wouldn't say it was controlled.
14 Q. It wasn't what? Can you repeat that? I
15 couldn't hear you.
16 A. It wasn't controlled behavior. It was
17 just however I wanted to act.
18 Q. You just wanted to act however you wanted
19 to act; is that what you're saying?
20 A. Yes.
21 Q. Okay. Did you tell your therapist at that
22 time, June of 2012, that sometimes you just wanted to
23 hurt her feelings? Is that something you would have
24 said back then?
25 A. It's probably something I would have said
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1 back then.
2 Q. Okay. Were you nice to everyone else
3 though?
4 A. Pretty much. Outside of the house I was
5 like an angel.
6 Q. Okay. So outside the house you could
7 control yourself pretty well, but not for your mother,
8 right?
9 A. No.
10 Q. Okay. Would your mother call the police
11 quite often on you?
12 A. Yes.
13 Q. And was that because you were missing from
14 home or you were just disobedient?
15 A. I would say both those reasons.
16 Q. For both of those reasons? Okay.
17 Was there a time in the summer of 2012
18 that you were asked not to return to a camp because of
19 inappropriate behavior and disrespect? Do you recall
20 that?
21 A. You said 2012?
22 Q. Yes.
23 A. No, I don't remember that.
24 Q. Were you ever at a camp?
25 A. Yeah. Me and Nick went to summer camp
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1 together.
2 Q. Where did you go to summer camp?
3 A. I can't really -- I don't remember what
4 the program is called. But there's an alternative
5 school, like somewhere passed the flea -- near the
6 flea shop in Broward County, the big main flea shop.
7 Not like the -- there's like two big ones. The one
8 near Butterfly World.
9 There's like an alternative school near
10 that flea market area. And, yeah, we went both
11 went -- went -- went to that summer camp. It was
12 pretty much for like -- like -- it was like -- I don't
13 know. I can't even say this. For kids with, like,
14 behavioral problems but it was just, like, everybody
15 had -- like everybody had their own set of problems
16 going there. Some people were aggressive. Some
17 people were just incorrigible. Some people like
18 fighting. It was just like bad -- I wouldn't say bad
19 kids. It was a summer camp for, like, misbehaved
20 kids.
21 Q. Okay. Do you recall another counselor
22 named Rachel Calister from Henderson?
23 A. No, I don't.
24 Q. 2012? No? Okay.
25 A. But the name of the summer camp -- like
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1 the school, the alternative school was at, I remember
2 the name was like Cypress Head. It was like Cypress
3 Head, somewhere in that area. An alternative school.
4 Q. Okay. So did you like that camp?
5 A. Not really. Because it was like -- it was
6 just like -- there was too many, like, people that
7 were like -- like -- like, I would say bigger than me.
8 Like, people were like more nervous than me. People
9 that could like -- that could sit down and roast each
10 other for like -- like, I would say, like, five
11 minutes and not feel anything. It was just like --
12 just like -- I don't know. It was not easy.
13 Q. Okay. On September 3rd of 2012 - and I'm
14 sure you don't remember these specific days - do you
15 recall having a session with a Rachel Calister where
16 it was discussed that you were caught the day before
17 shoplifting $75 sneakers and had to sign a no
18 trespassing affidavit? Do you recall that incident of
19 the shoplifting?
20 A. If it was from Kohl's, yes.
21 Q. Okay. Did your mother institute a plan
22 that if you cursed at her it would get you 15 minutes
23 in a time-out room?
24 A. I don't remember that ever.
25 Q. Okay. Do you have any idea of how often
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1 you received therapy at home?
2 A. Probably about -- I think it was like a
3 weekly thing.
4 Q. Okay. Was Nick also getting therapy at
5 home?
6 A. Yeah, but I think it was more for me at
7 first.
8 Q. Okay.
9 A. Then it became he had one.
10 Q. So you had therapy and he had therapy
11 sometimes, correct, at the same time?
12 A. Yeah. But even like my own therapist --
13 like, would -- like, after she was done working with
14 me, she would like try to work with Nick a little bit
15 to, like, not be too, like, touchy. Like, not like
16 overstepping boundaries. Like, not -- not, like, try
17 to like control him, but like dictate -- like, would
18 give him direction like she did with me. The
19 therapist would just like figure out -- like, try to
20 figure out who he was, like my therapist would.
21 Q. So you would have a therapy session and
22 sometimes Nick would join in, correct?
23 A. Not join in. It would be like right
24 after. Like I'm wrapping up and I'm done, like, she
25 would like -- she would, like, go spend like ten
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1 minutes, five minutes, like, with Nick, around Nick,
2 just watching, observing. And hanging out also, like
3 being a friend at the same time.
4 Q. I'm sorry. Did you say Nick was hanging
5 out and being a friend?
6 A. No, the therapist would try to be like a
7 friend and just like hang out and just, like, be --
8 Q. Okay.
9 A. -- at the moment.
10 Q. Were there also family therapy sessions?
11 A. Yeah, we had a few of those.
12 Q. And family therapy would be your mother,
13 you, and Nick together?
14 A. Yeah. Yeah.
15 Q. In some weeks there would be three, four
16 sessions in a week sometimes?
17 A. I don't remember it was like that. But it
18 could have been. It could have been.
19 Q. Is it fair to say you didn't really like
20 therapy sessions, did you?
21 A. Not at all. No.
22 Q. And oftentimes you would skip out on them?
23 A. I would want to. But I really -- like, I
24 couldn't, because then I would have the police pretty
25 much like -- yeah, like -- if I tried to like leave to
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1 go away, my mom would just call the police.
2 Q. And the police would find you
3 skateboarding somewhere, right?
4 A. Well, I mean, back then it was like -- I
5 was really into skating back then. When I was doing
6 therapy like that, I wasn't -- I only got into
7 skateboarding really when I got sent away from my
8 house. My mom sent me to a group home and, like, at
9 the group home there was skateboard and, like, I just
10 like was learning how to skateboard, like, at the
11 group home basically.
12 Q. Nick liked the therapy, didn't he?
13 A. Yeah. Well, no, no. I'm not gonna say
14 that. No. What I was gonna -- no, that's not what
15 I -- no. I would say no. He didn't like the therapy.
16 I was gonna say he probably enjoyed me being sent out
17 of the house and him not being sent out of the house.
18 Q. I'm sorry. Could you repeat that. Some
19 of -- I didn't hear who was sent out of the house.
20 A. I was just saying, like, I think he
21 enjoyed me being sent out of the house because my
22 behavior was considered worse than his at the house.
23 So I would be the one getting sent out, not him.
24 Q. Do you recall the YES team coming to your
25 house because of you on multiple occasions?
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1 A. I think I do, but I got -- I can't
2 visually remember it. But I do remember -- I remember
3 always being threatened with the YES team growing up.
4 Like, do you want me to call the YES team? They say
5 you keep acting like this, we'll call the YES team.
6 So.
7 Q. Okay. Did you understand that the YES
8 team was like -- sort of like there's an emergency
9 going on with your child and --
10 A. Yeah.
11 Q. -- and you have to deal with it at that
12 moment, so they're the ones who would come out right
13 away?
14 A. Yeah. Yeah. They're like the people --
15 it's like before the police and like the last resort.
16 Q. And sometimes the police would come with
17 them?
18 A. Well, I never remember that.
19 Q. Okay. Were there times that you destroyed
20 furniture in your own home as a child?
21 A. Yeah. I mean, I took down my own door.
22 Like, I -- I don't know. I would, like, open and
23 close my door so much that the hinges came off. So
24 it's like -- I like -- I, like, ripped the door off.
25 I ripped my carpet all apart. I, like, broke my
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1 closet door like multiple times.
2 Nick would punch holes inside the wall in
3 the den where my mom would hang out and watch her soap
4 operas. He would punch walls just in the one spot in
5 the den. Nick would break windows. I never broke a
6 window in the house, not that I can remember.
7 Q. Did you ever break a window in the car to
8 get like an electronic out of your mom's car?
9 A. I never did. Nick did.
10 Q. Nick did that? Okay.
11 A. Not to get anything out of the car, just
12 to break the window.
13 Q. Did you ever trash mom's room, throw her
14 things in the living room?
15 A. Yeah, I think I did do that before. I've
16 done that, I'm pretty sure.
17 Q. Did you ever gesture at her in a
18 threatening manner?
19 A. I would make her chase me around the
20 house.
21 Q. You'd chase her around the house?
22 A. Yeah. Like, I would -- like, I don't
23 know. I would, like, stand in a pose like come at me
24 and then she would like run at me. And then I would
25 like take her for a run around the house. Like, she
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1 could never catch me.
2 Q. Did you ever see Nick hit your mother?
3 A. No, I never saw that with my own eyes.
4 Q. How about when he punched her in the
5 mouth?
6 A. Never saw that.
7 Q. Did your mother lose some teeth?
8 A. Yeah, she did. She did.
9 Q. How did she lose her teeth?
10 A. Well, that's what I heard about. Like, he
11 hit her in the mouth and like -- it was like -- it was
12 real hush-hush in the house. Like, my mom didn't even
13 like talking about it.
14 But, like, there were times she just
15 couldn't like hold it back. Like, she would just be
16 yelling at him and then, like, she would bring up,
17 like -- like, oh, my teeth. Like, she would say
18 something like -- like mention her teeth and then --
19 yeah, like it would be like that.
20 Q. Did you see the blood coming from her
21 mouth?
22 A. No. No. I just remember it was a time
23 where she had like -- like -- like pads of, like,
24 cotton in her mouth.
25 Q. And was that from being hit by Nick?
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1 A. Yes.
2 Q. Did you or Nick ever lock her in a closet?
3 A. Yeah, we both did that before I think. I
4 would say it was mostly me though. Like, I don't
5 know. Maybe. Maybe both of us. But that's something
6 I -- I would do that. Like, I just held the door.
7 Because, like, her closet was so tight up against this
8 other wall where it's like I could press my feet up
9 against this wall and just like put all my body force
10 against the door where I had the most -- I had the
11 most force applied and she couldn't --
12 Q. How long did you keep her in the closet?
13 A. We maybe did that for like a minute, a few
14 minutes. Just to, like, show her that we could, I
15 feel like. Or just to like -- maybe it wasn't even to
16 show her. It was just like -- we thought it was
17 funny. Like, I don't know.
18 Q. Did she think it was funny?
19 A. No. She -- I'm pretty sure she probably
20 called the police. Probably that was some -- yeah.
21 Q. She never pressed charges against you or
22 Nick though, did she?
23 A. No. No. I mean, I've never hit her. I
24 know that. I never hit her. But Nick, she like -- I
25 think she called -- there was like -- the police were
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1 there over the punch in the face with the teeth coming
2 out, but it was never like a police report filed.
3 There was never charges pressed. There was never --
4 never it being, like, I want a record that he did
5 that. But there was a report of it, I know that, with
6 the department of police because they -- my mom
7 explained everything to them, I'm pretty sure.
8 Q. Your mom wanted to protect Nick from going
9 to prison, right?
10 A. Oh, yeah. She wanted to make sure that
11 his record was clean.
12 Q. Did you ever threaten to drop the garage
13 door on her?
14 A. No. No. No.
15 Q. Did Nick ever talk you into leaving the
16 house without permission?
17 A. No. No. That was free will. Like, I
18 would just leave if I wanted to leave. Yeah, it was
19 all free will.
20 Q. Do you know of your mother going to stores
21 with your picture to show them -- to leave a picture
22 of you there because you were stealing from them?
23 A. No, I never -- I never heard my mom doing
24 that.
25 Q. What were the stores you were stealing
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1 from back then?
2 A. I mean, like, Walmart, Target, Kohl's.
3 Those are the big ones.
4 Q. And you were talked to about this many
5 times by counselors, correct?
6 A. Yes. Yeah.
7 Q. And you persisted on still stealing back
8 then, right?
9 A. Yeah.
10 Q. There was nothing anyone could do to stop
11 you from stealing back then?
12 A. No, because I just -- I would just leave
13 and like I -- I -- I was fast. I'd leave. I could
14 get out of the parking quick, like, just on a bike or
15 a scooter.
16 Q. Well, I mean no one could talk sense into
17 you to stop stealing is what I was really asking.
18 A. Yeah. No, no one -- no, no one was ever
19 able to convince me not to do it.
20 Q. So up until the shooting did you continue
21 to steal?
22 A. No.
24 at this point. I just need to pause this line
25 of questioning for a second. Give me one
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1 second, Mr. Marcus.
2 MR. MARCUS: Counselor, I'll withdraw that
3 question if you want to move on.
4 MS. MATHENY-WILLARD: Okay. Thank you.
5 BY MR. MARCUS:
6 Q. Okay. Mr. Cruz, I want to ask you if you
7 remember any of these names of therapists from the
8 years that you were exposed to Henderson and other
9 treatment providers. So I already told you Amanda
10 Levison, Sarah Leace, Rachel Calister. I think I
11 mentioned those already.
12 Now, Trahern LaFavor, T-R-A-H-E-R-N, L-A
13 capital F-A-V-O-R, does that name sound familiar to
14 you?
15 A. Not at all.
16 Q. Tiffany Forest?
17 A. Not at all.
18 Q. Martha Luthen?
19 A. Nope.
20 Q. Scarlett Martin?
21 A. Nope.
22 Q. Your mother had a parent advocate named
23 Steve Sincoff. Do you recall that person?
24 A. I remember him. He would sit down and
25 drink coffee and hang out with my mom.
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1 Q. Would he talk to you, too, on occasion?
2 A. Not -- yeah, a little bit, but he would
3 just like offer me advice really. Never -- never
4 overstepping boundaries. But he was like -- became
5 like my mom's best friend. Even after the therapy,
6 they would still just hang out and talk.
7 Q. Okay. He was offering your mom help to be
8 a better parent, right?
9 A. Yeah, and she also would -- he also was
10 just like -- she was like -- he was her personal
11 therapist. Like, he was there to, like, just comfort
12 her basically.
13 Q. Okay.
14 A. He would just hang out. He would
15 sometimes just hang out at the house just to like --
16 just because like -- if someone was at the house, me
17 and Nick would never act up. We would never be
18 disrespectful, like disobedient. Never if there was
19 another person in the house that was like a friend of
20 my mom's or anybody.
21 Q. So you guys would control yourself if
22 there was another adult in the house?
23 A. Yeah. But I'm not gonna say it's the same
24 if we had a friend over. If we had a friend over,
25 then we would be like in rare form. We would act out.
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1 Q. Okay. But you -- but Nick could control
2 himself when he wanted to when there was an adult like
3 Sincoff there?
4 A. Like Steve? Yeah. If Steve was there,
5 like, yeah, Nick wasn't breaking things in the house
6 or anything. He was calm.
7 Q. Okay. Do you remember Dr. Negin, the
8 psychiatrist?
9 A. No, I don't.
10 Q. So there was a time you were placed at
11 Lutheran Services placement, do you recall that, 21
12 days?
13 A. That's the shelter I got sent to.
14 Q. Right. And then you were sent for a
15 second time to Lippman Shelter, correct?
16 A. Well, it was -- I mean, I stayed only at
17 the same shelter every time. It was the same shelter
18 every time.
19 Q. Oh, it was the same place twice?
20 A. Yeah. Oakland Park. Lippman Youth
21 Shelter in Oakland Park.
22 Q. Okay. And one time you convinced a bus
23 driver that you had a pass to leave? Do you remember
24 that?
25 A. To what, leave the shelter?
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1 Q. Yes. And you went home when you shouldn't
2 have been.
3 A. Oh, yeah. Yeah. Because I was still
4 going to my home school, so -- but, like, I was -- I
5 was staying at the Oakland youth shelter. So I took
6 my regular bus ride home, like my regular bus route
7 when I was still at home. And like -- yeah, like, I
8 took -- I took the bus back to my house.
9 Q. And you shouldn't have, right?
10 A. Yeah. Yeah. I shouldn't have.
11 Q. And you had to go back to the shelter
12 after that, right?
13 A. Yeah. They -- somebody transported me. I
14 think somebody from the shelter came and got me. I
15 don't know.
16 Q. And do you remember Jared Bienenfeld,
17 B-I-E-N-E-N-F-E-L-D?
18 A. I remember him. He had like glasses. He
19 was my middle school therapist. And, like, he was --
20 he was like -- if anything, I would say he was the
21 coolest one out of all of them. Because, like, he
22 never was really trying to make me be in trouble. He
23 was just trying to make me realize my actions, like,
24 and how they effected everybody.
25 And, like, he just taught me how to be
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1 like more like emotional. Just to think more about,
2 like, how my mom was feeling. And he was really,
3 like, cool. Like, really understanding. Like, he
4 would take me out to eat. Like, get desserts or,
5 like, just get me away from the house. Like, he was
6 just like, yeah, clear my head from --
7 Q. It didn't change your behaviors though,
8 did it?
9 A. No. And, like, he was like one of the
10 therapists that, like, sent me to the shelter I'm
11 pretty sure. So, yeah. But he had a meeting -- he
12 had a meeting at Westglades Middle School with like
13 all the -- like, my principal and they were, like,
14 basically figuring out if I'm going to get sent back
15 to the shelter or not.
16 Q. Is it fair to say that it was your
17 mother's death that changed your behaviors?
18 A. Yeah. Oh, yeah. Yeah. Once she was
19 sick, like -- it was just like -- everything, like,
20 just changed.
21 Q. Did you know Finai Browd?
22 A. Yeah. That was like my mom's -- one of my
23 mom's good, good friends. Like, she called her her
24 sister.
25 Q. Did you know her very well?
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1 A. Yeah, I -- yeah, I grew up around her.
2 Q. Okay.
3 A. She was a nice lady.
4 Q. Did you know Emilee Brenner?
5 A. I knew that was Nick's girlfriend. And I
6 had classes with her when I was in middle school and
7 high school.
8 Q. Okay. Did you know Angie Gilmartin?
9 A. No, I don't.
10 Q. Did you know that was another girlfriend
11 of your brother?
12 A. No. I don't think I ever met her.
13 Q. Okay. Did you know Hunter McCutcheon?
14 A. Yeah. We had classes together since sixth
15 grade.
16 Q. Were you friends with Hunter?
17 A. I don't want to say we were friends, but
18 like we were, like, friendly. Like, we were just
19 nice -- we'd be nicer to each other.
20 Q. Was he a friend of your brother's?
21 A. Yeah. They -- they -- once -- once I was
22 in high school, like, Nick met him somehow and they
23 started like being like -- I'm not gonna say they were
24 best friends, but they were good friends. Like, hung
25 out every weekend I felt like. Hung out a lot. He
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1 would take Nick out to, like, the Everglades and
2 stuff.
3 MR. MARCUS: Okay. Just a second.
4 Getting close. Give me just a moment. You
5 can take a break for a couple minutes and I'll
6 be back with you.
7 MS. MATHENY-WILLARD: Okay. Thank you.
9 BY MR. MARCUS:
10 Q. Okay. Just a few more questions. Thank
11 you. Mr. Cruz, what do you know of your brother
12 drinking or using drugs in his teenage years up until
13 the shooting?
14 A. I mean, I smoked weed with him. I mean,
15 we smoked weed with kids on our street.
16 Q. I'm sorry. Say that again, please.
17 A. I said, I've smoked weed with him. We
18 smoked weed with kids on the street. We've gone
19 places -- other places with kids from our street and
20 smoked weed. I remember when he was going through his
21 breakups, he would be in the closet drinking my mom's
22 wine bottle. Like, pretty much half -- whole --
23 pretty much the half of the whole bottle.
24 Q. When was this that he was drinking?
25 A. It was when -- I think it had to do
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1 something with his breakup with Emilee. Because he
2 would just have the home phone and he would go in his
3 closet and, like, he -- I don't know. He also, like,
4 had his tablet. So he would just be -- be trying to
5 like communicate towards Emilee and like -- I don't
6 know.
7 I just know, yeah, he was definitely
8 drinking a lot and he definitely was stealing my mom's
9 wine. And I just remember, like, my mom, like,
10 confronting him. And then my mom started putting the
11 wine in her car and locking her car.
12 Q. Is that when he broke a window to get into
13 the car?
14 A. No. That -- I mean, no. That was a
15 situation -- that's a whole nother story.
16 Q. Okay. So when you're saying about
17 drinking the wine, is this wine -- all the wine he
18 drank was from your mother?
19 A. Yeah. It was like Zinfandel. It's like a
20 maroon red kind of wine. Like it was -- it was wine.
21 Q. So in total, how many bottles would he
22 have drank of your mother's wine?
23 A. I mean, he did -- like, he got away with
24 it for, like, a few times. I don't know how he got --
25 I don't know how he got away with it more than once,
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1 but he definitely did. Because, like, my mom bought,
2 like, a box with the wine where you unscrew the cap
3 and it pours out.
4 I remember he took -- he had gotten -- he
5 was, like, sipping it in front of her one time. I can
6 like visually kind of remember that. He was like
7 holding the box up and drinking it while she's trying
8 to take it from him. And I could just -- the other
9 time I saw him in the closet and he had a whole wine
10 bottle. And I was just like looking at him. What are
11 you doing? Kind of basically just let him be. Like,
12 I left the scene.
13 Q. So what I'm asking is it -- was this
14 like -- maybe it was two bottles or five bottles or --
15 you know, how many --
16 A. One bottle.
17 Q. One bottle?
18 A. Yeah. And he only -- these are the times
19 I've seen it. It's not -- there's times I haven't
20 seen it. But it was intense because my mom couldn't
21 leave her wine out no more. She couldn't have cold
22 wine no more because if she put it in the fridge it
23 was dibs, like, for Nick.
24 Q. So it's not like he was an alcoholic. It
25 just happened a couple times?
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1 A. Nick?
2 Q. Is that --
3 A. Yeah, I wouldn't say Nick was an
4 alcoholic. My mom was because she drank wine every
5 day. Not -- not -- not saying she would get pitch
6 drunk and like -- but I'm not saying she wouldn't get
7 drunk every day.
8 Q. Okay. Would she have a glass or two of
9 wine, something like that?
10 A. More glasses than that. She -- she -- she
11 had to drink a whole -- she could go through a whole
12 pack of however sips -- however many glasses of wine
13 she could pour.
14 Q. Okay. In one day or a week or what are
15 you talking about?
16 A. I mean, yeah. I mean, weekly there was
17 always -- there would be gallons of wine in the fridge
18 before Nick started, like, taking like most of it. It
19 would usually just always be like -- like bottles of
20 wine in the fridge or a box of wine. And like, yeah.
21 It was just like -- I think Nick started taking, like,
22 small doses of it. And then, like, eventually just
23 started taking everything and that's when she figured
24 it out.
25 Q. What kind of girl was Emilee Brenner? Did
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1 you like her? Was she a nice girl or no?
2 A. Well, I mean, she had a crush on me when
3 we were in middle school. That's what her friends
4 told me. And she was like a very quiet girl. Because
5 I had technology class with her and I just remember
6 she was very quiet. It was like -- and like -- just
7 she was very quiet, just very quiet. But, like, would
8 always be laughing about something in class. Or she'd
9 just be giggling, like -- and, like, it was just weird
10 because, like -- I don't know. Like, just from
11 middle -- that's -- that's -- yeah, middle school I
12 was in classes with her. And then once I got to high
13 school I found out she dated my brother. So it was
14 just weird.
15 Q. Okay. I have a few questions I want to
16 ask you about Nick when he was like 10, 11, 12 years
17 old. Okay?
18 A. Okay.
19 Q. And I'll just go through them quickly and
20 just tell me if he could do this or if he couldn't do
21 it. Okay?
22 A. Okay.
23 Q. Did he know how to use a microwave oven
24 then?
25 A. Not the oven. He knew how to use a
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1 microwave.
2 Q. A microwave?
3 A. Yes.
4 Q. Yes. Okay. Did he know how to use the
5 toaster?
6 A. Yes.
7 Q. Did he know how to open a can with a can
8 opener?
9 A. I'm pretty sure, yeah. We had can openers
10 at the house.
11 Q. I'm sorry. Can you repeat your answer,
12 please?
13 A. I said, I'm pretty sure because we had --
14 yes, because we had --
15 Q. Okay.
16 A. -- can openers at the house.
17 Q. Did he know how to make a peanut butter
18 sandwich?
19 A. Yes.
20 Q. Did he know how to brush his teeth?
21 A. Yes.
22 Q. Did he know how to wash his face?
23 A. That, I can't really -- I mean, I would
24 say no.
25 Q. Ten to 12 years of age?
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1 A. I know he knew how to take a shower.
2 Q. Okay.
3 A. Yeah.
4 Q. Did he know how to blow his nose with a
5 tissue, 10 to 12 years of age?
6 A. Yeah, but he's the type to not even use a
7 tissue. He'd use his own shirt.
8 Q. Okay. Did he cover his mouth when
9 coughing or sneezing, those ages, 10 to 12?
10 A. I would say no. I mean, he had poor
11 manners. Like, table manners were horrible.
12 Q. Would he know how to zip a zipper up?
13 A. Yeah.
14 Q. Like on a jacket, put it together and put
15 it up when he's 10 to 12?
16 A. Yeah. He had a bunch of hoodies growing
17 up.
18 Q. Did he know how to use a butter knife when
19 he was 10 to 12 years of age?
20 A. Yeah. I mean, yeah. That's probably when
21 he started make peanut butter and jelly for himself.
22 Yeah, like bagels, cream cheese.
23 Q. Did he know how to button his shirt during
24 10 to 12 years of age?
25 A. Yes, but he never usually had shirts that
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1 nice. I mean, my mom would buy matching shirts for us
2 to wear to go to school when we were really young,
3 like pre-K, elementary.
4 Q. At 10 to 12 years of age did he know how
5 to wash his hair?
6 A. I think so. Yeah. I think my mom taught
7 him all that.
8 Q. At 10 to 12 years of age you think he was
9 smart enough to use a toilet before leaving the house?
10 A. Yeah. Yeah. He was good with his -- I
11 mean, I'm not gonna say he was good. Like, the
12 bathroom was never always clean, but --
13 Q. Okay. Would he apologize when he made a
14 mistake?
15 A. Yeah. He would over -- overdo it. He
16 would always -- that was like his word. Like, I'm
17 sorry was like -- my mom -- my mom -- I just
18 remember -- I could hear it in my head. My mom would
19 be like, you always say you're sorry. You always say
20 you're sorry, but then you do this. Like, she'd say,
21 don't say sorry if you don't mean it. That's what I
22 remember my mom telling Nick growing up.
23 Q. When he was 10 to 12 did he have any
24 problem going to school?
25 A. Oh, yeah. Early -- earlier than that I
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1 think.
2 Q. Okay. What was his problem?
3 A. Like, what do you mean? Like -- like, if
4 we're talking about elementary? Like, when we were
5 at, like, Coral Springs Elementary? Like, he would
6 have a room where, like, if he got so worked up
7 during, like, while he was in school, they would have
8 a room for him to go to where, like, there was like a
9 Nintendo 64, like a pool table, all these, like,
10 activities for him to, like, cool down.
11 But this is, like, in Coral Springs
12 Elementary. And it's like a room for other kids and
13 it, like, really a room for, like, special needs only.
14 Like, only the special need kids knew about the room.
15 It was only a room for the special needs kids.
16 Q. Right. Now, the question I want to ask
17 you is, like, do you know how with little kids they
18 don't want to leave their mother to go to school?
19 They're like, mommy, mommy. Do you know what I'm
20 talking about? Like little kids?
21 A. Yeah, they don't want to leave their
22 parents. Yeah.
23 Q. Right. So at 10 to 12 years of age, could
24 he leave his mother and -- even though he had problems
25 when he was at school, but could he leave to go to
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1 school?
2 A. Yeah. She would drop -- she would take us
3 to the school bus, make sure he got on the school bus.
4 Yeah.
5 Q. Okay. Now, you mentioned about marijuana
6 use when you were younger. And I saw a video of you
7 talking to your brother when he was in jail where he
8 asked you if you were high and you said you were. Did
9 you -- did you smoke marijuana when talking to Nick in
10 jail sometimes?
11 MS. MATHENY-WILLARD: Okay. Don't answer
12 that yet. Let me just -- hold on one second.
13 I'm going to object at this point, but just
14 give me one second.
16 MS. MATHENY-WILLARD: Okay. We're back.
17 I'm going to object, ask him not to --
18 instruct him not to answer. Smoking marijuana
19 is still a federal offense. Obviously I'm not
20 here to cause him to get any federal charges
21 and that immunity statute doesn't pertain to
22 federal offenses.
23 BY MR. MARCUS:
24 Q. Was Richard with you at the time that you
25 were smoking marijuana and talking to -- excuse me.
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1 You weren't smoking marijuana. Let me restate that.
2 That you were high from marijuana, was Richard in the
3 room when you were talking to Nick?
4 MS. MATHENY-WILLARD: I'm going to
5 instruct him not to answer and ask that you
6 certify that question. It's the same
7 objection.
8 MR. MARCUS: I just want to point out,
9 it's not illegal to be high. It's illegal to
10 smoke marijuana. He wasn't smoking marijuana.
11 He just claimed he was high. So do you want
12 to let him answer the question?
13 MS. MATHENY-WILLARD: No. Because if he
14 was high, at some point he had to ingest it.
15 Ingesting it is a federal offense. So I'm not
16 going to -- no, I don't want him to answer the
17 question. You can certify that question. I'm
18 going to instruct him not to answer that.
19 MR. MARCUS: Okay. That's all the
20 questions I have for you. I appreciate your
21 cooperation. I'll just turn it over if the
22 defense has any questions of Mr. Cruz.
23 MR. SECOR: No, sir. Thank you.
24 MR. MARCUS: Can we take a break and start
25 with Richard in a few minutes? We can go as
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1 far as we can go?
2 MS. MATHENY-WILLARD: Okay. Let me just
3 check one thing. Give me one second.
5 MS. MATHENY-WILLARD: Mr. Marcus?
6 MR. MARCUS: Yes.
7 MS. MATHENY-WILLARD: Okay. I had spoken
8 with Rich, I think during our first break, and
9 he indicated that after 1:30 he would not be
10 available, but I didn't know how long it was
11 going to take for Zack. Right now he is
12 getting lunch, but he's about 20 minutes away.
13 What I'm going to ask, which I think is more
14 reasonable, if we can reschedule it and do
15 this all at one time rather than bifurcate his
16 deposition.
17 MR. MARCUS: Okay. I'll have -- I'll have
18 my assistant get some dates together when we
19 can do this. And I'm just going to do it
20 under the condition that you'll continue to
21 accept service and that because -- and you
22 will -- and I'm sure you will, I have no doubt
23 of your integrity of proceeding in good faith
24 trying to get this accomplished. I wasn't so
25 convinced of your client was willing to do
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1 this, but I'm certainly convinced of yours and
2 you have been gracious and I appreciate it.
3 Just so that we agree that he's still under
4 subpoena. Okay?
5 MS. MATHENY-WILLARD: He is. I will
6 accept service. Just a heads up, I'm going to
7 be out of town May 2nd through the 9th. But
8 after that, we can get dates after that.
9 MR. REINER: And I've actually got a
10 federal trial that starts on Monday as well.
11 MR. MARCUS: Not that we don't want you,
12 Mr. Reiner, but --
13 MR. REINER: I know what you're saying.
14 No, if you have to work around me, work around
15 me.
17 MR. REINER: Or work through me. I'm
18 sorry. Let's do it that way.
19 MR. MARCUS: And that's what I mean.
20 She's working through you.
21 MR. REINER: Okay.
22 MR. MARCUS: Then that's fine. I'll have
23 Aaron email you and we'll try and work out a
24 date together. Okay?
25 MS. MATHENY-WILLARD: Sounds good. Thank
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158
1 you so much.
2 MR. MARCUS: Have a good weekend. Thank
3 you.
4 (The deposition was concluded at 2:10
5 p.m.)
6 (The reading and signing of this
7 deposition is not waived.)
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1 CERTIFICATE OF OATH
2 STATE OF FLORIDA
3 COUNTY OF BROWARD
5 I, JOYCE MARKS, Notary Public in and for the
6 State of Florida at Large, do hereby certify that
7 ZACHARY CRUZ appeared via videoconference on this 29th
8 day of April, 2022, and was by me duly sworn.
10
11
12
JOYCE MARKS, Notary Public

13 State of Florida at Large
14
15
16 My Commission: HH 189526
My Commission Expires: January 29, 2026
17 Bonded through Notary Public Underwriters
18
19
20
21
22
23
24
25
Zachary Cruz
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1 CERTIFICATE OF REPORTER
2 STATE OF FLORIDA
3 COUNTY OF BROWARD
5 I, JOYCE MARKS, Certified Court Reporter, do
6 hereby certify that I was authorized to and did
7 stenographically report the deposition of ZACHARY
8 CRUZ; that a review of the transcript was requested;
9 and that the foregoing transcript, pages 1 through
10 16j0 inclusive, is a true and correct record of my
11 stenographic notes.
12 I FURTHER CERTIFY that I am not a relative or
13 employee of any of the parties, nor relative or
14 employee of such attorney or counsel, or financially
15 interested in the foregoing action.
16 This certification does not apply to any
17 reproduction of the same by any means unless under the
18 direct control and/or direction of the reporter.
19 DATED this 7th day of May, 2022.
20
21
JOYCE MARKS, RMR

22
23
24
25
Zachary Cruz
161
1 STYLE: State of Florida vs NIKOLAS CRUZ
2 WITNESS: ZACHARY CRUZ
3 DATE: April 29, 2022
6 Under penalties of perjury, I, the undersigned,
7 do hereby certify that I have read the foregoing
8 deposition, or have had it read to me, and that to the
9 best of my knowledge said deposition is:
10 ____ True and accurate; or
11 ____ Except for changes and/or corrections
12 below, if any, as indicated by me on the DEPOSITION
13 ERRATA SHEET hereof, with the understanding that I
14 offer these changes as if still under oath.
15
16
17
18 Signed on the ____ day of ______________, 20___.
19
20
__________________________
21 ZACHARY CRUZ
22
23
24 You may email this executed form(s) to the reporter of

record: [email protected]
25
Zachary Cruz
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DATE: April 29, 2022
3
5 DEPOSITION ERRATA SHEET
7 Page No. ______ Line No. _____ Change to: ____________
8 ________________________________________________________
9 Reason for change:______________________________________
11 ________________________________________________________
14 ________________________________________________________
17 ________________________________________________________
20 ________________________________________________________
22
23
24 Signature: ___________________________ Date: __________

ZACHARY CRUZ
25
Zachary Cruz
163

DATE: April 29, 2022
3
5 DEPOSITION ERRATA SHEET
8 ________________________________________________________
11 ________________________________________________________
14 ________________________________________________________
17 ________________________________________________________
20 ________________________________________________________
22
23
24 Signature: ___________________________ Date: __________

ZACHARY CRUZ
25
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Zachary Cruz
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Prestige Reporting Service, Inc. 633 South Andrews Avenue | Suite 202 | Fort
Lauderdale, FL 33301 (954) 764-7297 | [email protected]
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168
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169
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170
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171
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Zachary Cruz
172
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53:4,5,9,13,20 94:14 69:4,8,8 76:8,14 6,7,24,24,25,25 109:20 111:1 (7)
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56:6 57:8,9,21,22 112:4 114:24,25 81:2,10,12 86:4 87 1,11,13,14 henderson 124:9
91:5,10 92:5 (17) 115:1,17 120:13 :17,18,21,23,24,25 156:9,9,11 157:5 125:8 128:22
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Zachary Cruz
173
18:6 19:21 25:2 13:20 himself 14:15 homes 79:5 104:15 124:19
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29:2,4,5,5,8,25 24:23,23 30:24,25 hinges 133:23 42:19 134:6,20,21,25
30:4,4,5,9,10 33:1 31:2,3,13 hired 107:24 honor 7:5,6 135:12 137:16
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103:23,23 132:17,23 135:16 holmberg 49:3,9,11 50:13 126:17,18
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154:8 147:8,9,10,11 127:14 130:1,5 63:12 65:15 78:16 huhuh 20:10
155:2,9,11,14 (10) 152:7 153:8,10 132:8,9,11 133:20 81:20 85:2,3 47:3 80:15 92:10
highway 98:10 154:17,18,20 142:1,4,6,7 146:2 86:13,17 (4)
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10:14,17,19,21 (179) homeowner 43:4 97:7 98:20 101:22 30:17,19 50:20
Zachary Cruz
174
61:1 69:5 74:5 (6) 95:22 98:18 99:21 inch 44:10 interest 118:1 40:23,23 41:21
hundreds 71:11 101:7,17 102:16 incident 125:2 interested 92:8 42:11,17
hung 65:2,4 105:5,9,21 106:3,4 129:18 93:2 160:15 43:12,13,13,17,18
144:24,25 (4) 109:1,6,6 111:25 incidents 62:5 interests 113:9 45:13 48:1 50:19
hunter 144:13,16 112:1,2,5,24,24 inclusive 160:10 internet 55:7,20 52:10 55:23 58:4
hunting 91:10 113:4,6,11,16,21 incorrigible 92:20 59:15 60:18,24,24
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60:24 61:5 62:24 115:3,9 incriminate 31:12,17 99:12 64:12 66:5,6
63:1,3 (6) 116:9,20,21 115:13 interrupt 48:15 67:11,19,20
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hurt 126:23 118:3,12,17 116:4 interview 97:20 69:17,19,19,25
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86:10 88:15 130:24,24 131:4 ingest 155:14 63:6,11 67:4 90:3,18
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34:9,10,20,23 idea 26:8 74:8 114:10,16 irma 59:13 60:24 160:10 161:9
36:17 40:10 107:8 121:24,25 118:5,18 61:5 63:2,3,5 (6) (162)
41:8,9 45:7 122:1 129:25 (7) 119:8,15,23 is 5:4,5,21 isolate 113:20
48:6,14,20,21 idiot 27:25 61:21 120:5,10,16,22 6:12,15,17,22 issues 65:21 79:9
50:19,19 53:6,7 iffy 24:17 121:3,9,15,21 8:11,12 9:3,8,9,24 itself 89:19
56:14 60:5 ill 16:8 154:18 155:5,18 10:4,11 iv 29:1
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77:19 78:1,10,12 inaudible 17:25 126:7 32:14 33:25 34:7 11,17,18,20,23 10
81:12 84:12 89:24 incarcerated interactions 36:14,20 7:2,6,7,9,13,18,23
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Zachary Cruz
175
154:7,10 (24) 29:2,7,14,25 98:6,7,13,23 kick 39:17,19 49:16,21

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50:16 66:23 48:9,9,12,13 49:19 127:14 kill 76:8,12 80:5,21 84:1 87:9
104:24 106:13 50:5,5,6,7,9,11,11 128:14,17,18 102:22 88:6,10 91:17,23
110:3 111:12 (8) 51:7,10,20,21,21 129:6,11,12 killing 76:1,6,6 93:19 94:3,5,23
joel 2:15 52:2,4,17,18,21 54 130:19 131:2,7,7 80:10 118:8,22 (6) 95:22,24 96:2
join 90:20 :3,4,9,9,10,11,11,1 132:1,9,20 kind 10:8 17:2 99:25 100:20,24
130:22,23 2,14,19,20,21,22,2 134:4,11 19:9,22 24:16 101:4,17
joining 90:24 2,25,25 135:14,15,22 27:18 32:8 45:6 104:2,8,18
jokes 92:21 55:4,5,22,24 136:6,9,14,15,16 49:14 55:13 60:11 105:8,16
joyce 1:22 5:8 56:19,20,22,22,25 137:18 67:7 69:19 77:7 106:15,19 107:10
9:24 84:13 57:2,2,12,14,16 138:12,12,14,24 1 79:18 84:9 110:1 108:7,25 110:9,10
159:5,12 160:5,21 58:5,6,8 59:15,15, 40:3,6,10,11,14,15 123:24 146:20 111:18 115:5
(8) 17,18,20,21,23 ,15,16 142:23,25 147:6,11 148:25 121:6 122:13
joyce@prestigere 60:21 61:2,5,10,10 143:1,5,6,19,20 (22) 123:4 126:12
portingserviceco ,10,23,24 62:1,16, 144:18 145:3,4,10 klinger 2:6 128:13 129:12
m 161:24 17,22,25,25 146:2,4,7,9 117:9,11 133:22 134:23
jt 65:7,12 63:8,9,10,16,19 147:8,10,11,25 knew 40:18 41:9 136:5,17,24
judge 1:4 12:22 64:2,2,5,10,10 148:19,21,22 149: 46:13,17 56:6 137:5,20 142:15
13:7,25 111:12,16 66:9 68:8,8 69:3 5,6,7,9,9,10,14,19, 64:2 65:1 66:16 143:21,25
(6) 71:9 72:4 73:7 20 152:17 69:9 88:8,8 99:25 144:4,8,10,13
judicial 1:17 5:6 75:3,22,24 154:12,13 100:5 102:11 145:11
july 62:18,20 77:8,10,17 155:8,11,21 104:5 110:25 146:3,6,7,24,25
june 126:22 78:2,9,9,21 156:2,19 157:3,6 144:5 149:25 147:15 149:10,23
jury 116:17 79:3,4,13,13,17,17 (412) 151:1 153:14 (20) 150:4,7,17,20,22
just 5:19,21 81:10,15,16,17 82: kate 2:14 6:14,15 knife 151:18 151:1,4,12,18,23
9:18,18 11:24 3,3,6,7,10,11,12,2 14:13 (4) knocking 49:11 152:4 153:17,19
14:18 16:5 1,22,22,23 keep 21:15 51:8 103:6 156:10 157:13
17:2,11,12,14,14 83:9,10,10,22,22 54:2 107:2 know 9:5,10,10 (152)
18:6,12,13,13,15 84:1,2,3,5,7,9,10 110:17,17 133:5 10:18 11:9,22 knowing 18:5
19:4,11,16,25 85:6 136:12 (8) 24:7,17 25:4 26:8 knowledge 40:21
21:17,19,19 87:12,15,16,25 keeping 23:7 27:1,6 28:2,2,23 55:6 66:14 69:11
22:23,23,25 88:24 kept 54:3 101:13 29:6,20 32:11 92:23 122:25
23:1,1,7,8 24:3,8,9 89:2,4,4,4,21 103:25 104:10 (4) 34:9,14,17,18,19 123:2,5,7 161:9
,10,12,13,20,25 90:7,7,9,10 keys 102:15 36:13,14,20 37:15 (10)
25:13,14,16 27:1,2 91:8,20,21 93:21 103:21,22,24 (4) 40:14 41:1 known 41:2
,2,8,11,12,12,15,1 94:1 95:2,2,5 kia 96:15 42:18,23,23 knows 32:4 42:21
7,20,21 96:14,16,22,24 kibble 43:10,10 46:21 93:9
28:1,15,16,25 97:3,5,7,10,15 23:12,12,13 47:13 48:14,17,24 koby 87:24,25
Zachary Cruz
176
kohl's 129:20 137:18,18,21 14,16,17,17,18,19, 1,22,22,25,25 21,21,22,23,23,24,

138:2 138:12,13 22 21:11,12,12,15, 46:4,4,5,6,6,10,11 24,25 63:6,7,8,9,9,
l 2:14 141:23,25 147:21 16,18,18,19,20,25 47:9,10,11,19,20,2 16,19,19,21,24,25
la 139:12 153:18,21,24,25 22:1,9,9,14,17,18, 0,20,21,21,22,23,2 64:1,3,8,9,10,15 6
lady 42:4,13 (22) 18,19,24 23:5,6,7, 4,25 48:1,2,2,2,3,4 5:2,3,4,7,8,9,9,13,
99:17 144:3 (4) leaves 50:13 7,12,20,23,23,25 2 ,4,4,7,9,11,11,12,1 13,18,23 66:14,14,
lafavor 139:12 leaving 32:14 4:2,4,4,4,5,5,5,5,8, 3,18,20,21 49:2,2, 14,15,24,24 68:6
land 82:15 35:23 137:15 9,10,11,12,12,16,1 2,3,4,4,4,4,5,5,6,6, 69:3,3,18 70:2 71:
large 5:9 152:9 (4) 7,19,20,20,21,22,2 6,6,7,7,7,7,7,8,8,8, 8,9,10,10,14,17,19
159:6,13 led 45:17 2,23,24 25:3,3,4,4, 10,10,13,13,14,14, ,19,20 74:12 75:19
last 16:19,20,20 left 16:13 41:3,4 4,5,5,6,6,7,7,8,9,1 15,15,15,16,17,18, 76:4,5,5,10,11,13,
17:16 24:3 33:8,9 102:15 108:22 0,14,16,25 26:1,16 18,23 50:3,3,5,6,6, 14,17
34:6,15 42:17 111:18 112:4 ,18,19,20,20,21,22 7,9,10,10,11,14,16 77:7,7,8,12,18,19
70:18 111:17 147:12 (8) 27:3,3,7,7,8,8,8,9, ,20,21,22 51:6,7,7, 78:2,10,20,20 79:3
133:15 (13) legal 7:15 10,10,11,11,12,12, 7,8,8,9,10,10,15,1 ,4,5,6,12,13,13,13,
later 71:23 legally 9:5 102:3 15,15,16,17,17,18, 9,20,20,21,23,25 5 14,14,15,16,18,18,
lauderdale legit 42:22 19,19,20,20,21,21, 2:1,2,2,3,3,4,4,17, 19,19,21,22,23,23,
2:8,17 less 19:10 22,22,22,23,24,24 18,18,19,19,20,20, 23,25 80:1,1,1,4,5,
laugh 93:1,3 85:16,17 86:16 (4) 28:1,2,6,8,22,24,2 24,24,25 53:12,13, 5,6,6,6,6,7,19 81:3
laughing let 11:21 40:5,6 4,25,25,25 29:1,2, 13,14,15,15,24,24, ,5,6,8,9,9,9,9,10,1
61:23,24 96:25 41:11 44:24 2,3,3,3,5,5,5,5,6,7, 25 54:3,4,4,5,5,5,5 4,14,15,15,16,17,2
149:8 (4) 45:5,8 46:13 8,11,12,14,14 30:1 ,6,10,10,11,11,12, 5 82:3,3,4,4,5,5,5,
law 2:12 3:6 12:1 50:23 54:16 57:2 ,1,1,1,2,3,4,5,6,6,6 12,13,14,18,18,19, 6,7,8,8,9,10,10,11,
115:6,8 116:11 (6) 58:2,10 68:9 ,7,8,9,10,10,10,11, 20,20,20,20,21,23, 12,12,12,13,14,15,
lawful 5:1 6:3 81:19 103:8 12,13,16 31:1,2,2, 23,24,25 55:1,2,2, 16,22,22,22,23 83:
11:9 119:17 122:24 3,3,4,5,6,7,8,8,9,1 4,4,5,5,6,11,15,16, 9,10,10,11,15,16,1
lawsuits 121:18 147:11 154:12 0,16,20,22,23,25,2 16,16,17,17,17,18, 7,18,19,21,22,24 8
lawyer 6:14 8:12 155:1,12 156:2 5 32:1,2,5,6,7,7,8, 19,19,19,19,20,21, 4:1,2,2,3,3,7,7,8,8,
111:11 115:7 (4) (23) 8,9,9,9,9,10,11,16, 21,21,21,22,23,24, 9,9,10,11,13,21,22
lawyers 106:23 1 let's 64:18 88:6 18,19 33:8,8,9,11, 24,24,25 56:1,1,1, 85:5,10,13,14,14,1
08:10,13,15,17,19 157:18 12,13,13,16,19,20, 3,3,3,5,8,8,13,13,1 5,15,16,16,16,17,1
(6) levison 20,20,21,23,24 3,13,15,15,17,18,1 8,21,21,22
laying 10:12 124:16,23,24 34:2,3,8,12,16,17 8,19,20,20,21,22,2 86:6,7,15
leace 125:11,11 139:10 (4) 35:5,6,7,7,9,9,15,1 3,23,24,25,25,25 5 87:1,6,12,13,13,24
139:10 liberty 85:15 6,23 36:1,1,2,4,6,1 7:1,2,2,3,3,11,12,1 88:8,13,13,15 89:2
learn 16:8 55:8 86:1,3 6,18,18,18 37:16 3 3,13,14,14,15,16,1 ,2,3,3,4,9,9,10,11,
76:20 91:20,21 license 103:15,18 8:12,12,13,13,14,1 6,16,17,17,18,19,1 11,11,12,15,15 90:
95:1 (6) lie 49:12 4,15,18,19,23,24,2 9,20 58:4,5,5,5,6,7 6,9,16,16,19,20,20
learned 69:15 lied 115:25 4 39:2,3,4,4,5,9,15 ,7,7,8,8,9,11,16,19 ,21 91:1,1,2,3,5,6,
learning 55:9 life 27:3 30:21 ,16,17,18,21,21,21 ,19,20,20,21,22,23 6,8,9,11,13,14,15,
72:12 95:2 132:10 31:7 51:8 52:5,15 ,21,24 40:1,1,6,8,9 ,24 59:3,3,9,13,14, 15,16,19,20,20,21,
(4) 76:19 109:4 (8) ,16,17,17,19,20,20 14,14,15,17,17,19, 23,25 92:14,16,20,
leash 125:3 like 9:17,18 ,22 41:1,1,1,3,4,5, 20,21,23,23,24 60: 20,21,24,24,25 93:
least 25:6 59:4 10:24 12:12 13:10 6,7,8,9,9,10 42:4,4 9,11,12,12,14,15,1 1,2,2,4,5,8,16,19,2
60:12 62:4,4 14:11 16:14,15,17 ,8,10,10,11,12,12, 5,17,19,20,23,25 6 5,25,25 94:1,6,7,7,
115:7 117:3 (7) 17:3,3,4,7,8,8,10,1 12,12,15,16,19,21, 1:1,1,5,7,9,9,10,10 9,10,14,18,20,22,2
leave 11:15 13:24 0,11,12,12,14,15,1 23 43:3,4,5,5 44:6, ,10,10,11,11,14,15 2,23,24
40:7,7 102:15 5,16,18 8,9,9,9,10,10,11,1 ,15,16,19,20,21,21 95:2,8,9,9,10 96:2,
104:10 111:5,6,9 18:3,5,7,14,22 19: 1,12,12,12,13,15,1 ,22,24,25,25,25 62 2,13,13,14,15,16,1
131:25 5,5,8,9,9,10,11,13, 5,15,16,17,19,20,2 :1,13,15,18,19,20, 6,16,18,18,19,19,2
Zachary Cruz
177
0,20,21,21,23,24 9 138:2,13,14 140:3, 64:24 83:3 104:21 love 9:1 30:10 22:15 54:9,11
7:1,4,8,9,10,10,10, 4,5,10,10,11,11,15 106:13 112:21 31:10 88:19 94:11 101:1
11,11,12,12,13,13, ,16,18,19,25 113:3 (15) low 110:17 104:18 129:6
14,14,15,21,21,21, 141:2,4,5 142:4,6, lived 25:15,23 lucky 104:23 138:4 146:21
22 98:2,2,4,4,5,6,7 7,7,18,19,20,21,23 38:4 lunch 22:15 147:15 148:12
,8,12,14,14,15,15, ,25 143:1,1,2,3,3,3 42:5,6,6,9,13,25 117:4,13 156:12 (14)
16,16,16,17,18,18, ,4,5,5,6,9,9,10,12, 56:8 58:2 65:3 (4) marbles 98:8
19,20,22 99:10,11, 13,13,19,19,19,22, 79:21,24 81:20 luthen 139:18 marcus 2:4 4:5
12,12,12,13,14,15, 23 144:18,18,18,2 83:3 111:22 lutheran 141:11 5:19 6:7 7:10
17,19,21 100:2,4,1 2,23,23,24,25 120:14 (18) lying 121:1 10:22 11:1,24
5,16,17,19,19,21,2 145:1,22 146:3,3,5 lives 10:17 lynda 15:25 12:4,6,11,17,24
5 101:1,4,4,5,5,5,1 ,5,9,9,19,19,20,23, living 8:3 20:4,5 46:4,7 66:12 13:9,14 14:4,19,22
1,12,13,14,14,16,1 24 147:1,2,5,6,6,1 26:2 29:25 37:25 70:21 77:10 (6) 15:2,6,9,11
6,16 102:1,5,6,7,8, 0,11,14,23,24 148: 53:11,19 59:11 m 2:19 28:14,18,19
9,10,10,14,16,16,1 6,9,18,18,19,19,20 60:9,10 62:15,15 made 19:12 48:3 64:16,18,21 68:13
7,18,19,21,21,22 ,21,21,22 149:1,4, 64:23,23 75:5 78:3 107:3 125:18 72:6,11,21
103:25,25 104:1,2, 6,6,7,9,9,10,10,16 81:5 101:24 152:13 (6) 73:1,7,15,23
3,3,4,4,6,9,25 151:11,14,22 152: 134:14 (19) madness 106:14 74:14,19,23
105:1,1 106:12,21, 3,11,16,16,17,19,2 located 6:20 magnitude 15:18 75:1,2,15,16
22,23,24,24,24,25 0 153:3,3,3,4,5,5,6 lock 136:2 main 17:17 24:12 105:7,14,19,24
107:1,3,13,13,13,1 ,7,8,8,9,9,10,11,12 locking 146:11 87:13 99:5 128:6 106:6,8 109:8
4,15,15,17,17,19 1 ,13,13,14,17,19,20 long 61:16 (5) 112:10,18,20
08:14,15,15,16,17, (1415) 136:12 156:10 maintained 113:2,8,14,19,24
18 109:14,15,16,1 liked 25:11 91:10 longer 52:24 75:5 26:11 114:5,11,17,22
6,24,24 110:7,8,9, 93:10 132:12 (4) look 32:21 34:17 maintenance 115:2,5
9,9,10,10,17 111:1 likes 90:14 35:15 49:16 50:21 110:3,5,7 116:6,16,23 117:1,
0,11,13,14,15 liking 91:10 54:16 55:2 make 5:22 9:25 6,10,12,17,20,25
125:22 127:5 128: line 4:10,10,10 77:9,9,10,18 (11) 11:2,5 14:4 17:22 118:6,15,20
5,7,7,9,12,12,12,1 68:25 70:18 72:18 looked 25:10 19:16 21:22 22:4 119:4,10,16,18,24
3,14,15,17,18,19,2 73:5 112:23 36:1 51:19 54:10 31:1,2,24 32:4 120:6,12,18,24
5 129:2,2,4,5,6,6,7 138:24 (4) 42:23 64:9 89:9 121:5,11,17,23
,7,7,8,8,9,10,10,10 162:7,10,13,16,19 looking 31:7 92:11 93:3 94:5,8 122:8,12,19 123:8
,11,12 130:2,12,13 163:7,10,13,16,19 36:2,3 49:15 109:16 112:19 139:1,2,5 145:3,9
,13,14,15,15,15,15 (19) 82:23 147:10 (6) 113:25 114:6,12 154:23
,16,16,17,17,17,18 lippman looks 68:6 118:21,24 134:19 155:8,19,24
,19,19,20,23,24,24 141:15,20 lose 135:7,9 137:10 142:22,23 156:5,6,17
,25,25,25 131:1,2, listed 15:13 losing 24:13 150:17 151:21 157:11,16,19,22
6,7,7,17,19,23,25, literally 42:6 98:7,7 154:3 (34) 158:2 (111)
25,25 132:4,6,8,9, 60:22 61:8,13,14 loss 87:2 makes 7:13 marcus' 5:15
10,10,15,20 133:4, 66:23 83:17 85:16 lost 44:7,17 60:5 8:20,20 20:15 marijuana
5,8,8,14,15,15,22, 93:25 98:15 (10) lot 16:13 18:3 93:22 118:8 (6) 154:5,9,18,25
22,24,24,24,25 13 little 14:22 25:9 19:12 making 56:23 155:1,2,10,10 (8)
4:1,8,22,22,23,23, 32:6 33:15 44:21 26:15,16,16,17 man 9:18,19 marjory 96:22
24,25,25 135:10,1 75:7,7 81:19 51:5,13 33:13 110:3,6,7 marked 4:7
1,11,12,13,14,15,1 92:23 130:14 55:15,17,23,24 (6) market 128:10
5,16,17,17,17,18,1 140:2 153:17,20 65:17 67:8 71:14 maney 2:15 marks 1:22
8,19,19,23,23,23,2 (13) 72:1 82:6 85:18 manner 134:18 5:8,21,24 159:5,12
3 136:4,6,7,8,9,13, live 7:21 25:19 97:3,13 106:7 manners 21:17 160:5,21 (8)
14,15,15,16,17,24, 33:2,3 35:13,17 144:25 146:8 (24) 151:11,11 maroon 146:20
25 137:2,4,17 36:23,25 37:24 loud 56:21 many 14:8 17:13 married 9:6
Zachary Cruz
178
110:20 50:8,19 52:20 127:25 129:7,8 104:23 105:3 (20)

martha 139:18 68:15 69:14 72:4 130:6,14,18 106:9 107:1 109:9 midnight 58:7
martin 139:20 79:16 84:12 85:3, 132:8,16,21 133:4 (7) might 10:15
massacre 4,13,14,14,21,22 134:19,23,24 meeting 12:22 21:10,10
122:5,14,21 86:15,20 110:9 135:1 136:4 143:11,12 24:19 26:9 32:2
massive 60:18 136:5,5,13,15 138:19,25 melisa 2:12 33:14,15 40:25
82:7 147:14 (40) 140:3,16 142:13,1 melissa 2:15 41:1,2,2 43:7,17
matching 152:1 mccann 2:5 4,22,23,25 memes 55:19 71:9 87:17
matheny 10:22 mccutcheon 143:4,5,10 145:4 92:16,17,17,20,24 115:7,13 (19)
mathenywillard 144:13 149:2,4,20 (6) mike 6:14,22 9:2
3:6,6 5:14 7:5 mcneill 2:12 154:12,14,25 memories 89:2,4 104:23 106:17,17,
10:9,23,25,25 me 8:22,24,25 155:1 156:2,3 123:17,19 (4) 17,19,22 107:1,5 1
11:1,24 12:5 9:16,23,25 157:14,15,17 memory 70:25 08:1,3,10,12,17,20
13:12,15 10:2,5,5,6 159:8 161:8,12 81:8 123:13 111:10 (18)
14:16,20,25 11:15,21 15:22 (186) mention 45:20,23 mike's 9:18
15:4,10 28:14 16:19,25 17:12,21 meals 21:9 135:18 106:22 107:12,17
64:16 68:2,11 18:6,23 19:4,25 mean 7:2 16:10 mentioned 76:7 108:1,16,16,18 (8)
71:24 23:19,22 24:2,5,9 17:1 18:13 139:11 154:5 mile 85:16
72:9,14,16,22 27:4,14,18,22 19:8,12 21:10,24 mentioning 76:5 miles 84:21,23
73:4,13,19 29:8,23 32:7,8 27:1 28:5,23 33:5 message 75:20 85:17 86:14,15,16
74:10,16,22,24 34:14 36:12,23 34:2,8 35:6,14 messages 102:9 (7)
75:14 40:8,9 41:11,17 36:13 38:7,22 75:11,13,17,18 mill 2:20
105:5,8,16,22 42:24 44:24 39:16 40:16 76:1 97:12 (6) mind 100:3
106:3 109:1 45:1,5,8,9 46:13 42:3,18 47:9,19,19 messy 21:19 mini 16:11
111:25 112:15,22 47:16,23 48:9 48:15,22 49:1 met 25:8 36:22 minus 67:24
113:4,11,16,21 50:4,15,22,23 51:2 51:5 56:12 57:24 106:10,21 minute 11:20
114:2,8,14,20,24 53:4 58:2,10 58:1 64:2,3 65:1 107:5,11,12,18 72:4 117:3 136:13
115:3 116:9,20,24 68:8,9,9,18,18 71:8,13 77:6,19 108:5,8,14 (4)
117:2,16,22 69:4,5,17,23 71:10 78:9 79:10 81:2 144:12,22 (13) minutes 29:12
118:3,12,17 72:4,12 75:24 83:21 84:10 metlife 71:8 52:24 64:19 68:9
119:1,7,13,21 76:22 77:5,8 85:10,13 86:23 metropolitan 97:14 117:14
120:3,9,15,21 78:1,1,8,12,17 90:5,19 92:13 70:20,23 71:1 129:11,22 131:1,1
121:2,8,14,20 79:3,16,18 80:1,19 93:7,7,10,13,22 miami 3:4 136:14 145:5
122:6,9,16,23 81:19 89:16,21 94:2,6,16 105:2 michael 2:4 3:10 155:25 156:12
138:23 139:4 90:8 94:25 106:21 123:1,23 6:25 7:12 8:3 9:21 (14)
145:7 154:11,16 95:10,10 124:10 10:13 13:16,24 misbehaved
155:4,13 156:2,5,7 96:19,19,20,25 126:4,12,12,13 74:25 113:10 128:19
157:5,25 (91) 97:9,9,11,14 98:10 132:4 133:21 114:12 120:2,8 misbehavior
matter 5:3 116:3 99:8,22 136:23 138:2,16 121:6,24 (16) 125:15
may 14:14 20:12 100:2,3,11,20,23 141:16 145:14,14 michael's 9:4 missing 127:13
34:20 43:7 73:17 102:5,8,20 146:14,23 microwave mistake 152:14
74:9 125:9 157:7 103:2,7,7,8,25 148:16,16 149:2 19:13,17 22:1,4,4 mitigation 6:17
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181
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183
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Zachary Cruz
184
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185
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Zachary Cruz
186
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Zachary Cruz
187
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188
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189
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190
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191
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192
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25:11,20 26:11 142:5 3220 12:17
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31:11 32:24 56:13 92:4,24,25 6166 37:25 53:11
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78:4,16,18 80:25 122:18 156:11 (6) 290727197
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86:13,17,21 zinfandel 146:19
87:9,18,19 zip 151:12
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123:10,10,13,25 945 5:12
124:5,12,14,19 999 3:7
125:15,18 1027 70:20
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Cruz, Zachary State Depo 4-29-22 StvCruz

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Cruz, Zachary State Depo 4-29-22 StvCruz

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Zachary Cruz

1 IN THE CIRCUIT COURT OF THE

3 CASE NO. 18001958CF10A

20 April 29, 2022

22 Reported by: Joyce Marks, Certified Stenographer

11 Appearing on behalf of the Defendant, Nikolas Cruz:

12 LAW OFFICE OF THE PUBLIC DEFENDER

19 THE SUZERAIN TEAM

1 Appearing on behalf of the Witness, Zachary Cruz:

2 REINER & REINER, PA

6 THE LAW FIRM OF AMINA MATHENY-WILLARD, PLLC

10 ALSO PRESENT: MICHAEL DONOVAN

5 Direct Examination By Mr. Marcus 6

10 Page Line Page Line Page Line

15 105 3 118 11 154 24

1 Deposition of ZACHARY CRUZ, a witness of lawful

2 age, taken by the State, for the purpose of discovery

3 and for use as evidence in the above-entitled matter,

4 wherein STATE OF FLORIDA is the Plaintiff and NIKOLAS

5 JACOB CRUZ is the Defendant, pending in the Circuit

6 Court of the 17th Judicial Circuit, in and for Broward

7 County, Florida, Pursuant to notice heretofore filed,

8 before JOYCE MARKS, Certified Court Reporter, a Notary

9 Public in and for the State of Florida at Large, taken

10 via videoconference, in the County of Broward, State

11 of Florida, on the 29th day of April, 2022, commencing

14 MS. MATHENY-WILLARD: If we can go back to

15 what Casey Secor said, Mr. Marcus' response,

16 and then I'll respond. So Mr. Secor, if you

17 could respond. We'll go on the record at this

19 MR. MARCUS: First of all, I'm just going

20 to ask you to swear in the witness, please,

21 Ms. Marks. This is my deposition and I'm just

22 going forward. I'm going to -- I'll make the

23 record. It's my deposition.

24 Go ahead, Ms. Marks. Would you please

25 swear in the witness.

3 a witness of lawful age, being called as a witness by

4 the State, having been first duly sworn, testified under

8 Q. Would you please state your name, sir.

9 A. Zachary -- Zachary Paul Cruz.

10 Q. Okay. And your date of birth, please?

11 A. February 21, 2000.

12 Q. And Mr. Cruz, who is in the room there

14 A. My lawyer Amina, Kate, and Mike.

15 Q. Okay. Is that Kate O'Shea?

17 Q. And she is a mitigation specialist with

18 the defense team, correct?

20 Q. Where are you located right now?

22 Q. Okay. And who is Mike?

24 Q. What's his full name?

25 A. Michael Paul Donovan.

1 Q. And when you say he's your guardian, what

2 do you mean by that? Do you have any -- do you have a

5 MS. MATHENY-WILLARD: Your Honor -- I'm

6 sorry. Not Your Honor. I'm going to object

7 at this point. You asked him what he means by

8 that. Can you allow him to answer that

12 A. Oh, Michael Donovan puts a roof over my