Questions for Deposition of Sarahlene Blue-Eyed Yazzie
- Do you understand that you are testifying under oath?
- Do you understand that you must tell the truth during this deposition?
- Do you understand the consequences of lying or giving false information under oath?
- Have you taken a deposition prior to this one?
- Are you prepared to answer all questions asked during this deposition?
- Is there anything that might distract you during the course of this deposition?
- Are you under any medication that might distract or interrupt this deposition?
- What is your name, date of birth and social security number?
- Where do you currently live?
- Do you understand that Plot No. 150 T.F. will be referred to as the “subject land” during the course of this deposition?
- Have you discovered the names of any of the John Does you have listed as defendants?
- When did your late father pass away?
- Did you try to gain control of the subject land after your father passes away?
- Prior to your first visit to the subject land in 2020, for how long had you been away from the subject land?
- What sparked your sudden interest to visit the subject land?
- How did you procure the services of Colin Bradley, your attorney?
- Are you the one paying Colin Bradley’s attorney fees?
- Have you communicated with anyone from Navajo Nation’s Department of Justice in regard to this case?
- Does Navajo Nation’s Department of Justice have any interest in this case?
- How has Farley Blue-Eyes refused to allow you access, control and/or decision-making regarding the Land Use Permit?
- Is there anyone who can corroborate your claim that Farley Blue-Eyes refused to allow you access, control and/or decision-making regarding the Land Use Permit?
- Do you believe that Farley Blue-Eyes continued operations and development on the subject land after the issuing of the Temporary Restraining Order and Preliminary Injunction of the Shiprock District Court?
- Do you have proof that Farley Blue-Eyes continued operations and development on the subject land after the issuing of the Temporary Restraining Order and Preliminary Injunction of the Shiprock District Court?
- How has hemp farming on the subject land caused damage to it?
- You allege that you verbally requested Farley Blue-Eyes to use a portion of the subject land to plant some crops. What exactly did you say to him?
- How exactly did Farley Blue-Eyes treat the subject land as his own to the exclusion of the trustees and beneficiaries?
- Did Farley Blue-Eyes expressly state by word of mouth or in writing that he would not attend Peacemaking with you as ordered by this court?
- Do you have financial records to prove that Farley Blue-Eyes made profits from your alleged cultivation of hemp on the subject land?
- Assuming that Farley Blue-Eyes illegally cultivated hemp on the subject land, why would you want profits of an illegal operation shared with you?
- Do you have a copy of the lease that Scott Lam has to plant hemp on the subject land?
- How have you suffered significant and irreparable harm as a result of the alleged hemp cultivation by Farley Blue-Eyes?
- Do you have a copy of any contract, lease or agreement that is permitting Farley Blue-Eyes to lease the subject land?
- How has Farley Blue-Eyes represented that he is the sole owner of the subject land?
- How has Farley Blue-Eyes failed to cooperate with you?
- Which benefit has Farley Blue-Eyes receive from the illegal hemp cultivation that you allege?
- Which losses have you accrued from Farley Blue-Eyes’ illegal cultivation of hemp that you allege?
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