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Plaintiff Mix's Deposition of Defendant Runyon .pdf



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IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT
IN AND FOR INDIAN RIVER COUNTY, FLORIDA
CASE NUMBER: 312015 CA 000961
THOMAS MIX,
Plaintiff,
vs.
JEANETTE TYE RUNYON,
Defendant.
_____________________/
DEPOSITION OF JEANETTE TYE RUNYON
DATE:

August 31, 2016

TIME:

9:30 a.m.

PLACE:

Rooney & Rooney, PA

TAKEN BY:

Plaintiff

REPORTER:

Michelle Ting, Vero Beach Court Reporters
APPEARANCES

FOR PLAINTIFF:
Rooney & Rooney, PA
2145 14th Avenue, Suite 20
Vero Beach, Florida 32960
BY: MATHEW RANDALL GROOM, ESQUIRE
BY: J. GARRY ROONEY, ESQUIRE
FOR DEFENDANT:
Jeanette Tye Runyon, Pro Se
686 S Happy Hill Road
Lexington, NC 27295

VERO BEACH COURT REPORTERS
772-231-2231

2
1

INDEX

2
3

WITNESS: JEANETTE TYE RUNYON

4

Direct Exam by Mr. Groom ............................. 3

5

By Mr. Rooney ........................................ 58

6
7
EXHIBITS
8
9

Exhibit 1 ................... 62

10

Exhibit 2 ................... 62

11

Exhibit 3 ................... 62

12

Exhibit 4 ................... 62

13

Exhibit 5 ................... 62

14

Exhibit 6 ................... 62

15

Exhibit 7 ................... 113

16

Exhibit 8 ................... 140

17
18
19
20
21
22
23
24
25
VERO BEACH COURT REPORTERS
772-231-2231

3
1

AND THEREUPON,

2

JEANETTE TYE RUNYON,

3

called as a witness on behalf of the Plaintiff herein, after

4

having been duly sworn, was examined and testified as follows:

5

DIRECT EXAMINATION

6

BY MR. GROOM:

7

Q.

All right. Good morning.

8

A.

Good morning.

9

Q.

Please state your name.

10

A.

Jeanette Runyon.

11

Q.

All right. Have you ever had a deposition before?

12

A.

It has been a very long time but, yes, but it has

13

been decades.

14

Q.

So you know the gist of it?

15

A.

Vaguely, I mean it has been a long time ago.

16

Q.

Okay. All right.

17

A.

And I was on the other side.

18

Q.

Okay. All right. Are you on any drugs or --

19

A.

No.

20

Q.

-- or anything that --

21

A.

None. Well --

22

Q.

Sorry. Excuse me. Generally the way this will work

23

and I will go through it real quick. We have got to talk one

24

at a time.

25

A.

Uh-uh.
VERO BEACH COURT REPORTERS
772-231-2231

4
1

Q.

So that the nice court reporter here can take down

2

all of our information on her nice lavender machine there and

3

if I ask you a question, I need you to answer either in the

4

affirmative with yes or no, head nods or anything won't work

5

because she can't write it down.

6

A.

She can't take it down.

7

Q.

Right, I need something that we can read later

8

potentially. All right. So first question. Are you any

9

drugs or anything that would affect your mental condition?

10

A.

No.

11

Q.

Any sort of mental illness that would affect

12

your mental --

13

A.

No.

14

Q.

Okay. So nothing is affecting your mental

15

condition?

16

A.

No.

17

Q.

Okay. All right. And then have you ever been

18

arrested?

19

A.

Yes, I have been arrested.

20

Q.

Okay. What for?

21

A.

It was a long time ago. Well, if you want to talk

22

in Kiev, I got arrested for supposedly human trafficking

23

nothing happened of it.

24

Q.

Okay.

25

A.

And then in the United States I got arrested for
VERO BEACH COURT REPORTERS
772-231-2231

5
1
2
3
4

passport fraud.
Q.

Okay. And then in Kiev, I mean just because that is

fairly unusual, what were you doing in Kiev?
A.

I was having a child by surrogacy and for some very

5

odd reason I brought documents to show that, proof of that.

6

For some very odd reason the special agent in the consulate

7

decided that I bought some woman's child and refused to look

8

at my documentation so I got -- I was never really clear if I

9

was arrested, or if I was detained. They never really made it

10

quite clear but what happened was my daughter was taken and

11

given to an SPU Former KGB agent, and I was falsely accused of

12

committing a crime that did not exist. I have documentation

13

from the Ukraine that says it is on the web. It is perfectly

14

clear that says that I committed no criminal act, but I never

15

got my daughter back. She was kidnapped essentially.

16

Newborns apparently are very rare in Ukraine. The state has

17

some thing where they keep them and won't allow them to be

18

adopted until they are older.

19

Q.

20

general?

21

A.

22

Okay. Had you ever been in the Ukraine or Europe in

I have been the Ukraine eight times. I have been to

Germany once so, yeah, I have travelled a lot.

23

Q.

So you are a world traveller?

24

A.

Yeah, I can read Russian. I can't read Ukrainian or

25

speak it either.
VERO BEACH COURT REPORTERS
772-231-2231

6
1
2

Q.

That is a unique one. All right. So have you ever

been convicted?

3

A.

Of what exactly?

4

Q.

Well, any kind of arrest?

5

A.

Just a misdemeanor, one misdemeanor.

6

Q.

What was that?

7

A.

Filling out a passport form incorrectly. I put down

8

as I was told by my lawyer that I was her legal mother and

9

apparently there is a conflict between citizenship laws

10

between Ukraine and the US.

11

Q.

Okay.

12

A.

That is the result of it so I had a misdemeanor.

13

Q.

Okay.

14

A.

It is on Pacer. You can find it.

15

Q.

Okay. That was based on the Kiev incident?

16

A.

Yeah, the special agent was very angry at me and

17

told me he was going to arrest me because we called up Senator

18

Dole and said, "Hey, what the heck is going on." You know,

19

and then senator Dole got back to them and not more than

20

15 minutes later a warrant was out or actually a criminal

21

complaint. A criminal complaint which Mr. Mix keeps insisting

22

is a conviction, and I have asked him repeatedly to stop

23

calling me a convicted human trafficker and he has refused to

24

do that.

25

Q.

Okay. All right. Oh, no, sorry -VERO BEACH COURT REPORTERS
772-231-2231

7
1

A.

I was going to say it is not. All it is is a

2

criminal complaint. He is calling it an indictment. He is

3

calling me a convicted trafficker. He is calling me a

4

criminal.

5

Q.

Uh-uh.

6

A.

And of course, I don't know. I mean I was fined

7

ten -- I wasn't even fined. I had to pay a $10 processing fee

8

for a minor misdemeanor that probably makes me an ex-con.

9

Q.

10

involved?

11

A.

12

Uh-uh. All right. And then you said a senator was

Yeah, Senator Dole. Well, not really her, her staff

and they tried.

13

Q.

Bob Dole's daughter?

14

A.

No, wife, Elizabeth Dole.

15

Q.

Okay. Okay. Elizabeth Dole?

16

A.

She was my senator in North Carolina.

17

Q.

Okay.

18

A.

Okay. And her staff tried to intervene with the

19

Ukraine authority and basically they just stole me blind and

20

took my daughter; that is what it boils down to so I got a

21

bird's eye view of inside a Russian prison for two and a half

22

days.

23

Q.

Right.

24

A.

So it turned out on a personal level one of the

25

better things that happened to me but on one level spiritually
VERO BEACH COURT REPORTERS
772-231-2231

8
1

but on another level, I lost my other daughter so, no.

2

Q.

Other daughter?

3

A.

Yeah, well, cause I had a daughter by surrogacy that

4

is Victoria and they stole her. They kidnapped her. I mean I

5

can get you, I had a lawyer sue. We went up to the Supreme

6

Court of Ukraine and then my lawyers disappeared with the

7

uprising, and I think they are dead because they were pushing.

8

We were suing the SPU for false arrest.

9

Q.

When did all this happen?

10

A.

This has been going on. Well, the lawsuit that is

11

probably several years ago, you know, the uprising was two

12

years ago and they disappeared around three years ago so that

13

was that.

14

Q.

And they were in the part that was annexed?

15

A.

No, they are in Kiev.

16

Q.

Okay.

17

A.

And they are actually near Independent Square and

18

that turned into be a war zone. I mean I really like Ukraine.

19

I would live there if I could have but it is not the same

20

place anymore. I wouldn't go there now, but I do have

21

friends, and I do have friends in the media there so.

22

Q.

Okay. So where do you live?

23

A.

I live in North Carolina, Lexington, North Carolina.

24

Q.

Okay. That is a nice area?

25

A.

It is very rural which is what I like.
VERO BEACH COURT REPORTERS
772-231-2231

9
1
2

Q.

Okay. And then so is this your first time in

Florida?

3

A.

Yes.

4

Q.

Okay. All right. I apologize it is not very sunny.

5

A.

And my train got cancelled.

6

Q.

You were going to take a train here?

7

A.

I am an Amtrak officinale so. Yes. And some poor

8

fool, soul killed herself on the way down so we were on the

9

tracks for four hours while they were investigating it.

10

Q.

Okay. And so did you drive the rest of the way?

11

A.

No, no, no, I don't drive. I never drive out of

12

state.

13

Q.

Okay. Why?

14

A.

Because my husband doesn't want me to so I just let

15

him do it.

16

Q.

Okay. What is your husband's name?

17

A.

Larry Michael Woolslayer. We didn't, you know, keep

18

the same last names. I have too many.

19

Q.

Uh-uh.

20

A.

Woolslayer, like sheep killer, W-o-o-l-s-l-a-y-e-r.

21

Q.

Is there a history behind that last name?

22

A.

It is Woolslaughter. It is German.

23

Q.

Okay.

24

A.

He doesn't really know that much. He is adopted so.

25

Q.

Okay. It is just unusual.
VERO BEACH COURT REPORTERS
772-231-2231


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