I agree about the emails and dinner. There is no city which has restaurants like New York City. I really like French cuisine. I was fortunate enought to dine at Lutece several times before it closed its doors. In fact, I was there when Soltner was still the owner/chef. He was the person who put Lutece on the map. Have you ever been to "Yellowfinger's" ? It's across the street from Bloomingdale's on the Third Avenue side. You have not eaten Caesar Salad until you have had theirs, it's fantastic!
Regarding the questions you plan to ask -
With reference to asking him to produce certain documentation, did you request it during discovery ? If so, and he did not produce it, you should bring that up in Court;
When you come to his convictions, first ask him,
"Have you ever been convicted of a crime ?" Hopefully, he will say, "No".
The you can ask him, "Have you ever been convicted of forgery?" Hopefully, he will say, "No" to that also, then you can take out his conviction record and ask him if he recognizes that and show him his conviction record. If you can, get his criminal file, it's a matter of public record, anyway. Take a look at the documents and make copies of the charges and what documents he was accused of forging. Remember, he might have been accused of forging more documents than he was convicted and although only convictions are used to impeach credibility, it is important that the judge hear all the charges because it will stay in the judge's mind,
Every so often whether he is lying or not, say, "Mr. ______ I am sure you are aware of the penalty for perjury, aren't you ? It will throw him off his square
Then ask, "What were you convicted of forging?"
Then, ask him, "Is that a felony conviction?"
"What grade of felony is that?"
"Were you incarcerated ?"
"Were you ever convicted of tax evasion?"
"Did you have to pay one-half million dollars as a penalty ?"
"And, did you have to pay another one-half million dollars in taxes that you evaded?"
Under no circumstances should you ask him , or allow him to "explain" anything. He might find a way to soften the blow and that is exactly what you don't want. Remember the 2 things I had stated in one of my previous Answers regarding questions to ask him,
1. As questions which can only be answered with a "Yes", or "No", so that he never has the opportunity to explain anything away.
2. Never ask a question, if you do not already know the answer; if you do not know the answer, find the answer before you ask him the question
Regarding the purchase price and the blank space on the Bill of Sale -
First ask him what the purchase price was - always give him the chance to lie, Then, ask him what percent of the purchase price you were supposed to pay. I think I am repeating myself because I remember saying if he lies about amounts, then none of the numbers are going to add up and they will not make sense.
lastly, if there is a chance that you will call his wife to refute his testimony, then before you start questioning him, tell the judge that you might have to call Mrs. _____ , depending on what the plaintiff testifies to and you are, therefore, asking that Mrs. ________ be sequestered. That means that she has to leave the Court room while he testifies so that she cannot coordinate her answers with his answers. So, if he lies, his wife who will be outside the Court room will not know on which questions he lied, and by telling the truth, she will prove her husband lied under oath. Then you can ask the judge at the end to charge him with perjury.