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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NASSAU
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SANJANA JON ABRAHAM
Index No. 600703/2016
Plaintiff,
-against-
PRABHU PARAMATMA, THE ESTATE OF
WERNER WILHELM JUSTUS WICKER, WERNER
J. WICKER INC, and WICKER, LLC,
Defendants.
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AFFIRMATION OF PRABHU PARAMATMA IN SUPPORT OF HIS
CPLR 2221(e) MOTION FOR LEAVE TO RENEW
I, Prabhu Paramatma, pursuant to CPLR 2106(b), affirm the following to be true under
penalty of perjury:
1. I am familiar with the facts and circumstances set forth in this affirmation.
2. I submit this affirmation in support of my motion for leave to renew based on new
evidence that was obtained after my December 13, 2019 cross-motion was briefed, and for all
other purposes permitted under New York law.
Background
3. In around 1994, I met the late Werner Wicker while I was serving in a temple in
Germany. Over the years, I developed a spiritual relationship with Werner Wicker. I experienced
and helped accomplish his generosity. This included helping distribute some of Werner Wicker’s
money for causes and people I believed needed the money.
4. In 2013, I was introduced to a woman who used the name “Sanjana Jon.”
Although I know her as Sanjana, I now know that she has many aliases, including:
a. Sanjana used the alias “Sanjana Alexander” when she was found guilty
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of contempt of court in 2009 for juror misconduct. A transcript of the
September 2009 contempt hearing is attached as Exhibit 1.
b. Sanjana used the aliases “Rebeca Chalasani” and “Rebecca Chalasan”
when she conspired with Prasad Chalasani to extract millions of dollars from
Werner Wicker. As part of Sanjana and Prasad Chalasani’s scheme, Sanjana
used these alias to pretend to be Prasad Chalasani’s niece.
c. Sanjana also used the alias “Sanjana Rebecca.”
d. Several of the documents obtained in the Alpha Group subpoena response1
include Sanjana as “Ms.Sanjana alias Anjana.” A copy of a signature page
showing Sanjana’s alias Anjana is attached as Exhibit 2.
e. One of the documents in the Alpha Group subpoena response includes
Sanjana signing a document as “Sanjana Rebecca Abraham.” A screenshot
of the document containing Sanjana’s signature as Sanjana Rebecca Abraham
is attached as Exhibit 3.
f. At her March 18, 2019 deposition, Sanjana admitted to using the aliases
Sanjana Jon Abraham, Sanjana Rebecca Alexander, Sanjana Jon, and
Rebecca Jon. During her deposition, Sanjana denied using the aliases
Rebecca Dean and Rebecca Chalasani. Relevant excerpts from the March 18,
2019 deposition of Sanjana, at 46:23-49:23, is attached as Exhibit 4.
5. Many years after I met Werner Wicker, Sanjana obtained an introduction to me.
She then used me to extract millions of dollars from Werner Wicker. Sanjana used two hooks to
convince me to help her obtain “Wicker money”: (1) she claimed American racism against
Indians led to her brother Anand Jon being convicted of multiple counts of statutory rape,
forcible rape, and other sex crimes and Sanjana; (2) she pretended to be a humanitarian who
needed money to help causes like the girl child and street dogs.
6. Sanjana used me as part of her scheme to obtain millions of dollars from Werner
Wicker under false pretenses. I came to know Anand was the mastermind behind Sanjana’s
scheme.
7. By the time Sanjana had taken over $7 million from Werner Wicker, I had
realized Sanjana’s true nature. Everything for her was about “Lakshmi” and her brother Anand’s
1
See Paragraphs 18-19, below.
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legal fees. When I say “Lakshmi,” I mean that she was obsessed with the pursuit of wealth.
Money that I had sent her was not going to help the girl child or street dogs. Instead, Sanjana and
her mother were buying property and living lavishly.
8. I began avoiding Sanjana to get away from her demands for more Wicker money.
She started calling me and trying to cajole me for more Wicker money. Then she started
pressuring me for more Wicker money. She complained that Louis Beria, one of her co-
conspirators, had taken what she claimed was her Wicker money.
9. By early 2015, Sanjana was threatening me about what she would do if I did not
give her more “Wicker money.” Sanjana started claiming she would embarrass me by saying
(falsely) that she saw me in sexual relationships with other women. Then she started saying she
would accuse me of sexual harassment.
10. Then Sanjana and her co-conspirators threatened that I could be investigated for
terrorism from the United States Department of Homeland Security.
11. Finally, Sanjana and her co-conspirators (led by the plot’s mastermind Anand)
began threatening that they would accuse me of sexually assaulting Sanjana. They claimed
Sanjana had recordings where I confessed to sexual assault. This was not true. They also claimed
they had evidence proving I had sexually assaulted Sanjana. This was not true. They threatened I
would be prosecuted in multiple countries unless Sanjana received more Wicker money.
12. Even after Sanjana threatened me that she would accuse me of sexual assault, she
still begged me to visit her in Dubai and to resolve the dispute over how much Wicker money
she would receive.
My December 2019 Motion and the Chalasani Emails
13. On or about December 10, 2019, I learned that Wicker’s attorneys had obtained
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emails between Sanjana and Chalasani following a court-ordered November 2019 forensic
collection of Chalasani’s emails and computer.
14. The emails between Sanjana and Chalasani showed them concocting the claims
against me and Wicker. Sanjana’s story in the withheld Chalasani emails was inconsistent with
the story in her complaints. Specifically, the fabricated story of sexual assault discussed in the
2015 Chalasani emails was that I had drugged Sanjana using pills. By the time she filed the
complaint in this case in February 2016, she had changed her fabricated story to claim that I had
drugged her with drops from a little glass bottle under her tongue.
15. Werner Wicker filed his December 11, 2019 Order to Show Cause, Motion
Sequence 013, to dismiss Sanjana’s complaint or her willful and contumacious failure to respond
to Defendants’ discovery requests dated June 6, 2016 and January 18, 2018, or, in the alternative,
to strike and vacate the Note of Issue and compel Sanjana to make her SanjanaJon@gmail.com
email account accessible for a forensic search and compelling Sanjana to appear for further
deposition.
16. On December 13, 2019, I filed a cross-motion seeking the same relief as Wicker’s
Order to Show Cause, Motion Sequence 014.
New Facts and Evidence Not Offered on Prior Motion
17. On February 7, 2020, Werner Wicker’s attorneys sent my counsel a FedEx
package containing USB drives with materials from a subpoena response produced by non-party
Alpha Group.
18. The Alpha Group subpoena response included dozens of audio recordings created
by Sanjana or her mother Shashi, hundreds of emails to or from Sanjana or her mother Shashi,
photographs of Sanjana, and documents relating to Sanjana and her brother Anand’s efforts to
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overturn Anand’s conviction for rape and other sex crimes.
19. Thirty recordings in the Alpha Group materials included Wicker’s attorney Daniel
Weglarz, Esq. and in many of these recordings, Weglarz is conspiring with Sanjana’s mother
Shashi, Sanjana’s brother Anand, and Sanjana’s attorney Zulfiqar Menon, Esq. to extort money
from me, one of Sanjana’s co-conspirators Louis Beria, and Werner Wicker. These audio
recordings were attached as Exhibit A to the August 4, 2022 Weglarz affidavit. The Weglarz
affidavit is being contemporaneously filed with this motion.
20. The audio recordings on Exhibit A to the Weglarz affidavit can be downloaded
from this link: https://wolfelawllc.sharefile.com/d-sf606ec87dcfa425ba695e3026d9c3557.
21. The Alpha Group materials also included Sanjana’s recording of call between
herself and Saeed Sabooni, where Sabooni confronts her about the legal risks she faced from her
scheme to bilk millions of dollars from Wicker and tells her about how I had called him
distraught about how Sanjana was threatening to make accusations against me after all the
money I had helped her obtain. The audio file of Sanjana’s recorded call with Sabooni, call_10-
08-54_IN_+19176621402.AMR, was attached as Exhibit A to the July 22, 2022 affidavit of
Abdul Saeed Sabooni. The Sabooni affidavit is being contemporaneously filed with this motion.
22. The audio recordings on Exhibit A to the Sabooni affidavit can be downloaded
from this link: https://wolfelawllc.sharefile.com/d-sc195858df1e248bea8dce14ad3f3fb19.
23. Fifteen recordings in the Alpha Group materials were made by Sanjana or Shashi
of their telephone calls with me. Copies of these audio files can be downloaded from this link as
Exhibit 5 https://wolfelawllc.sharefile.com/d-s4fc1781e26314d2cb26677764859fb1d, and will
be filed with the Court on a flash drive containing a folder named “Paramatma Affidavit –
Exhibit 5.”
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24. One of the recordings in the Alpha Group materials was a call between Sanjana
and her sham-husband Richard. Specifically, the following audio file call_10-27-
05_OUT_19177493014.mp3 contains a recording of a telephone conversation between Sanjana
and Richard. A copy of this audio file can be downloaded from this link as Exhibit 6,
https://wolfelawllc.sharefile.com/d-s5ceb59be79b141f49fd929224fe263e7, and will be filed
with the Court on a flash drive containing a folder named “Paramatma Affidavit – Exhibit 6.”
25. The recordings in the Alpha Group materials included two calls involving Shashi
and Anand. In call_16-41-15_IN_17135686986.AMR, Anand directs Shashi how to proceed
with Sanjana’s claims against Wicker and me and dictates a letter for Shashi to have sent in
connection with her claims in this case. Copies of these two audio files can be downloaded from
this link as Exhibit 7, https://wolfelawllc.sharefile.com/d-
s77947462eb3b4642866c35a87c241687, and will be filed with the Court on a flash drive
containing a folder named “Paramatma Affidavit – Exhibit 7.”
26. New evidence was obtained as recently as September 2022, when my counsel
obtained four recordings made by Weglarz of calls with Sanjana and 1 recording of a call made
by Weglarz of a call with Shashi. Copies of these five audio files can be downloaded from this
link as Exhibit 8, https://wolfelawllc.sharefile.com/d-s16a5915db1d64212afc907e1fd0233dd,
and will be filed with the Court on a flash drive containing a folder named “Paramatma Affidavit
– Exhibit 8.”
27. I did not have access to the Alpha Group materials until almost two months after
Werner Wicker filed his December 11, 2019 Order to Show Cause, Motion Sequence 013, to
dismiss Sanjana’s complaint or her willful and contumacious failure to respond to Defendants’
discovery requests dated June 6, 2016 and January 18, 2018, or, in the alternative, to strike and
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vacate the note of issue and compel Sanjana to make her SanjanaJon@gmail.com email account
accessible for a forensic search and compelling Sanjana to appear for further deposition. I did
not obtain access to the Alpha Group subpoena response materials until over a month after my
December 13, 2019 cross-motion (Motion Sequence 14) had been fully briefed.
I. Sanjana’s Recordings of Her Conversations with Me.
28. One category of Sanjana’s recordings that Sanjana withheld from discovery and
that I did not obtain until after my December 2019 motion are her recordings of conversations
with me.
29. call_00-08-01_IN_+491748670070.AMR is a recording of a telephone
conversation between Sanjana and me that I have received and reviewed. I recognize my and
Sanjana’s voices on this recording. To my knowledge, the recording is a complete and accurate
recording of the conversation and has not been altered. I remember this conversation and many
conversations like this, where Sanjana would harangue me about Wicker, Beria, and the Wicker
money that had been obtained that she was demanding for herself. A copy of the translated
transcript of call_00-08-01_IN_+491748670070.AMR is attached as Exhibit 9; see also Ex. 5.
30. Sanjana was upset about Wicker money that Beria (who she calls CS for Chandra
Shaker) obtained instead of her. I complained about how Sanjana was pressuring me for money.
I complained that after I had “helped you all” (given them so much money), “I have to listen so
much.” I complained about my stress and said I felt like jumping in the Ganges. I was so upset
about all Sanjana’s calls demanding money that I was thinking of suicide. Sanjana said that Beria
had “stolen the money” and should go to jail. She told me that I was “Giving the key to the
thief.” Ex. 5; Ex. 9 at 2-7.
31. calI_00-37-49_IN_+491748670070.AMR is a recording of a telephone
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conversation between Sanjana and me that I have received and reviewed. I recognize my and
Sanjana’s voices on this recording. The recording is a complete and accurate recording of the
conversation and has not been altered. I remember this conversation. A translated transcript of
calI_00-37-49_IN_+491748670070.AMR is attached as Exhibit 43.
32. In calI_00-37-49_IN_+491748670070.AMR, Sanjana and I exchanged New
Years greetings. After I volunteered that Wickers health was not good, Sanjana asked details
about which of Wicker’s family members had come to visit him. Ex. 43 at 1-2.
33. Call_22-51-29_OUT_+491748670070.AMR is a recording of a telephone
conversation between Sanjana and me that I have received and reviewed. I recognize my and
Sanjana’s voices on this recording. The recording is a complete and accurate recording of the
conversation and has not been altered. I remember this conversation. A copy of the translated
transcript of Call_22-51-29_OUT_+491748670070.AMR is attached as Exhibit 10. See Ex. 5.
34. In Call_22-51-29_OUT_+491748670070.AMR, Sanjana called me. I complained
about all the stress I was under because of “The money.” I told Sanjana that Wicker had sent
people, through KPMG, to the Mill Neck property and Sanjana responded that “these men are
sent through Lewis [Beria]” and they must be from Beria’s team. Sanjana and I both complained
about our health, and when she said she had a “breathing problem” and some “chest congestion”
I told her “You have to take care of yourself.” I also repeated on this call that I was thinking of
suicide. See Ex. 5, Ex. 10 at 1-3 and 6.
35. call_15-33-31_IN_+491737432780.AMR is a recording of a telephone
conversation between Sanjana and me that I have received and reviewed. I recognize my and
Sanjana’s voices on this recording. The recording is a complete and accurate recording of the
conversation and has not been altered. I remember this conversation. A copy of the translated
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transcript of call_15-33-31_IN_+491737432780.AMR is attached as Exhibit 11.
36. In call_15-33-31_IN_+491737432780.AMR I again complained about the
pressure over Wicker money. Sanjana yelled at me because she wanted more money and she
complains in this recording how her co-conspirators Louis Beria and Tim House were spending
money. Sanjana lied in her lawsuit against me, and she told different lies in call_15-33-
31_IN_+491737432780.AMR. At the beginning of the call, we were arguing about the Wicker
money. I said “I didn’t take any money out of it. Did I ever take it? Did I ever take it?” and
Sanjana responded by arguing about money and the ways Beria was using the money. For
example, she yelled that “You want to save money, but when CS [Beria] spends on drinking
alcohol and flirting with girls, then money is not a problem. . . Yeah there is money for Tim
[House] and Tim’s girlfriend, there is money for the holiday that CS has to go. And then for the
rightful thing that I am doing, you have problem. What is this?” Ex. 5, Ex. 11 at 1-2.
37. When I didn’t succumb to Sanjana’s pressure for more money, she tried to create
evidence that she could use against me. This did not surprise me, because I witnessed how
Anand directed Sanjana to create evidence against Richard Bernard. When Sanjana yelled that I
had tried to “forcefully kiss somebody” and that I was “making forceful demands on people,” I
responded that she was talking nonsense and that she was “lying too much.” And then Sanjana
threatened to smear me by saying I was “roaming around with these girls, Marika or something, I
don’t know who else you roam around with.” She also said I had made “demands” on her. And
she shouted about “every woman who you have slept with.” This showed me she was ready to
smear me, and I defended myself by saying “For money, for money.” I was telling her this
was extortion and immoral. Ex. 5, Ex. 11 at 4-6.
38. Call_01-28-21_IN_+491748670070.AMR is a recording of a telephone
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conversation between Sanjana and me that I have received and reviewed. I recognize my and
Sanjana’s voices on this recording. The recording is a complete and accurate recording of the
conversation and has not been altered. I remember this conversation. A copy of the translated
transcript of Call_01-28-21_IN_+491748670070.AMR is attached as Exhibit 12.
39. In Call_01-28-21_IN_+491748670070.AMR, Sanjana complained again about
Beria getting the Wicker money. Sanjana states that “He has committed the biggest theft. . . Only
one man is getting all these things done; it is CS [Beria] who is getting all these things done.”
This call shows more of my avoidance of Sanjana. I tried to escape her pressure by saying we
needed to be very careful and use strategy with these things relating to the Wicker money. Ex. 5,
Ex. 12 at 1.
40. Call_10-06-28_IN_+491748670070.AMR is a recording of a telephone
conversation between Sanjana and me that I have received and reviewed. I recognize my and
Sanjana’s voices on this recording. The recording is a complete and accurate recording of the
conversation and has not been altered. I remember this conversation. A copy of the translated
transcript of Call_10-06-28_IN_+491748670070.AMR is attached as Exhibit 13.
41. In Call_10-06-28_IN_+491748670070.AMR, Sanjana again pressured me for
Wicker money. Sanjana was worried about Wicker money that Beria had already taken relating
to the Atlanta portion of the scheme, and how she would get her cut of the Wicker money if
Beria had already taken money. Sanjana also complained that Beria was a “criminal” with a
“criminal track record” and a “criminal brain” and that I was allowing him to play with the
Wicker money. Ex. 5, Ex. 13 at 2-7.
42. CalI_02-10-11_OUT_+491748670070 is a recording of a telephone conversation
between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices
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on this recording. The recording is a complete and accurate recording of the conversation and has
not been altered. I remember this conversation and other conversations like this. A copy of the
translated transcript of CalI_02-10-11_OUT_+491748670070 is attached as Exhibit 14. See Ex.
5.
43. I had shared with people close to Sanjana that she was demanding more and more
“Wicker money” and she was making threats at me. After Sanjana had already been making
threats at me, she started this call by saying “Can we at least from today maintain a positive note
from whatever we talk or do, can we do that please?” But when Sanjana did not get what she
wanted from me, she escalated and threatened me that she would make accusations to embarrass
me. For example, she tried to insult me with claims that I had a “mental issue” or was a “sexual
pervert.” I warned her to stop saying “filthy” things, she made her threats against me even more
explicit: “If you do this, I’m telling you, I will not sit quiet. I’m telling you this. I will not sit
quiet. Every day all these holy people go to jail because they sexually assault the people. I’m
telling you. You’ve tried all the nonsense. Don’t try it with me. . . In ISKCON also, you went
around. . . sexually torturing all the women out there. Now you’re trying it on me?” Ex. 5; Ex. 14
at 1, 4-5.
44. Then Sanjana continued her threats against me by saying “Listen, you stole all
the money from the godfather [Werner Wicker] and even now . . . All the money that you’ve
stolen . . . don’t try these tricks, you give me what’s rightfully mine.” Ex. 5; Ex. 14 at 1, 4-5.
45. In CalI_02-10-11_OUT_+491748670070, I repeated my response to Sanjana’s
threats that this was all extortion: “You did it for the money, for the money.” Ex. 5; Ex. 14 at 5.
46. Call_10-19-58_IN_+491748670070.AMR is a recording of a telephone
conversation between Sanjana and me that I have received and reviewed. I recognize my and
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Sanjana’s voices on this recording. The recording is a complete and accurate recording of the
conversation and has not been altered. I remember this conversation. A copy of the translated
transcript of Call_10-19-58_IN_+491748670070.AMR is attached as Exhibit 15.
47. In Call_10-19-58_IN_+491748670070.AMR, Sanjana again pressured me for
Wicker money, spoke about how Beria was a criminal, and complained about how Beria was
spending money. This was yet another call where Sanjana pressured me to get Wicker money
back from Beria for her. And it was yet another call where I stated I was considering suicide. Ex.
5, Ex. 15 at 1-3.
48. call_03-34-52_IN_+491748670070 is a recording of a telephone conversation
between Sanjana and me. I recognize my and Sanjana’s voices on this recording. The recording
is a complete and accurate recording of the conversation and has not been altered. I remember
that this call took place after I had spoken to Saeed Sabooni about Sanjana threatening to accuse
me of assault unless I gave her more Wicker money. A copy of the translated transcript of
call_03-34-52_IN_+491748670070 is attached as Exhibit 16.
49. In call_03-34-52_IN_+491748670070, Sanjana was angry that I spoke to Sabooni
about the millions of dollars I helped her obtain from Wicker. She was worried that Sabooni
could “blackmail” her with this information. Sanjana warned me against speaking about her with
others, and she threatened to say bad things about me. Sanjana was upset that I had spoken about
the amount of “Wicker money” that she had obtained. Sanjana warned me “Who is he to talk
about the money or business or you and me are working together? Who is he? Tomorrow if he
starts to blackmail me and you, what will you do? If he calls tomorrow and says that I know it all
and I will tell him that, I will do that, then what will you do? Why are you intentionally giving a
sword in the hands of people.” Ex. 5, Ex. 16 at 4.
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50. Sanjana told me that the Wicker money scheme was “our important thing, this is
our thing.” Yet she also also referred to what people could see on the Internet about “you, who is
GF [Wicker], what about the house.” Sanjana then threatened me with how she would spread
rumors about me by asking “Should I call ten people and tell about this and that.” Ex. 5, Ex. 16
at 4.
51. By this call, I was done with Sanjana’s extortion attempts. I told: “You always
keep the gun on me and talk to me, ‘Where is the money, where is the money, where is the
money?’” and I told her that “When you got your money, everything was okay, but then after
that you also started to threaten me.” Ex. 5, Ex. 16 at 19-20.
52. In this call, which took place after Sanjana had started threatening to accuse me of
sexual assault, she begged me to come visit her in Dubai. She warned me that “this thing will
just keep increasing” unless I met her in Dubai. I refused and told her she had already escalated
so much with her threats. Ex. 5, Ex. 16 at 22.
II. Sanjana’s Mother’s Recordings of Her Conversations with Me.
53. Another category of Sanjana’s recordings that were discovered in the Alpha
Group materials were recordings that Shashi made of her conversations with me.
54. Call_09-32-47_OUT_+491748670070.AMR is a recording of a conversation
between Shashi and me. I recognize my and Shashi’s voices on this recording. The recording is a
complete and accurate recording of the conversation and has not been altered. I remember this
conversation and other conversations like this. I was telling Shashi about the awful accusations
that Sanjana was threatening to make about me. A copy of the translated transcript of Call_09-
32-47_IN_+491748670070.AMR is attached as Exhibit 17.
55. In Call_09-32-47_OUT_+491748670070.AMR Shashi referred to the fight
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between Sanjana and me as “like a small little mosquito bite.” I interrupted and said, “No it is not
about mosquito bite. It’s all about Lakshmi [money] you know. It’s all about millions and
trillions.” Ex. 5; Ex. 17 at 2.
56. Sanjana was threatening to malign me by accusing me of sexual assault. Shashi
tried to use this as both a threat, by saying Sanjana could be “going and talking to ten different
people” which “doesn’t help us,” and I interrupted that “such allegations that means we are not
thankful for the eight million what we got here.” When I described Sanjana’s threatened
allegations as “such demonic, devil accusations,” Shashi replied: “We can always solve our
difference of opinion or any small fights or anything, you know. . . This is the money that is due
to us.” I responded that “These are not small fights. These are big, big accusations, no?” I
complained to Shashi about how Sanjana and her only cared about money and how many
millions more I could give them from Wicker. Ex. 5; Ex. 17 at 4.
57. Shashi, like Sanjana, also complained about how Beria was keeping what she
considered “our money” from Wicker. “Why should Louis [Beria] keep our money? It is our
money and Louis is keeping it.” Ex. 5; Ex. 17 at 6-7.
58. call_00-57-29_OUT_+919996400085.AMR is a recording of a conversation
between Shashi and me. I recognize my and Shashi’s voices on this recording. The recording is a
complete and accurate recording of the conversation and has not been altered. I remember this
conversation and other conversations like this. A copy of the translated transcript of call_00-57-
29_OUT_+919996400085.AMR is attached as Exhibit 18.
59. In call_00-57-29_OUT_+919996400085.AMR, Shashi referred to Sanjana’s
threats against me as “tensions and, you know, unnecessary fights” as part of her efforts to get
me to see Sanjana again. During this time Sanjana and Shashi were trying to get me to meet with
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Sanjana and I was avoiding such a meeting because, based on how I witnessed Anand direct
Sanjana to trap Richard, I expected this to be a trap. I also did not want to see Sanjana again after
the ways she tried to extort more Wicker money from me. Ex. 5; Ex. 18 at 2-3
60. call_09-47-28_OUT_+491748670070.mp3 is a recording of a conversation
between Shashi and me. I recognize my and Shashi’s voices on this recording. The recording is a
complete and accurate recording of the conversation and has not been altered; however, to be
clear, the conversation was cutoff as I started to respond to Shashi. I remember this conversation.
A copy of the transcript of call_09-47-28_OUT_+491748670070.mp3 is attached as Exhibit 19.
61. I remember the conversation on call_09-47-28_OUT_+491748670070.mp3 as an
obvious attempt to manufacture evidence in favor of Sanjana’s false accusations. Shashi and
Sanjana had been playing roles as “good cop/bad cop,” Sanjana would call with threats and
Shashi would pretend to be a neutral trying to get everything resolved. On this call, Shashi stated
that Sanjana was “telling that you have molested her” and I was starting to respond by saying
“Yeah she would say this, because she wants money.” But Shashi hung up the phone when I
started to say I didn’t understand what she was saying. Ex. 5; Ex. 19 at 1.
62. call_09-50-26_IN_+491748670070.AMR is a recording of the conversation
between Shashi and me that started in call_09-47-28_OUT_+491748670070.mp3. I recognize
my and Shashi’s voices on this recording. The recording is a complete and accurate recording of
the conversation and has not been altered; however, to be clear, the conversation was cutoff as I
started to respond to Shashi. I remember this conversation. A copy of the transcript of call_09-
50-26_IN_+491748670070.AMR is attached as Exhibit 20.
63. After Shashi called and repeated Sanjana’s threatened accusation, I rejected the
accusation. When Shashi pretended to be in pain over Sanjana’s accusation, I responded: “No,
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tell me what is the pain and what is the reason. If she’s speaking something nonsense, then that is
Preview
FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NASSAU -----------------------------------------------------------------X SANJANA JON ABRAHAM Index No. 600703/2016 Plaintiff, -against- PRABHU PARAMATMA, THE ESTATE OF WERNER WILHELM JUSTUS WICKER, WERNER J. WICKER INC, and WICKER, LLC, Defendants. ------------------------------------------------------------------X AFFIRMATION OF PRABHU PARAMATMA IN SUPPORT OF HIS CPLR 2221(e) MOTION FOR LEAVE TO RENEW I, Prabhu Paramatma, pursuant to CPLR 2106(b), affirm the following to be true under penalty of perjury: 1. I am familiar with the facts and circumstances set forth in this affirmation. 2. I submit this affirmation in support of my motion for leave to renew based on new evidence that was obtained after my December 13, 2019 cross-motion was briefed, and for all other purposes permitted under New York law. Background 3. In around 1994, I met the late Werner Wicker while I was serving in a temple in Germany. Over the years, I developed a spiritual relationship with Werner Wicker. I experienced and helped accomplish his generosity. This included helping distribute some of Werner Wicker’s money for causes and people I believed needed the money. 4. In 2013, I was introduced to a woman who used the name “Sanjana Jon.” Although I know her as Sanjana, I now know that she has many aliases, including: a. Sanjana used the alias “Sanjana Alexander” when she was found guilty 1 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 of contempt of court in 2009 for juror misconduct. A transcript of the September 2009 contempt hearing is attached as Exhibit 1. b. Sanjana used the aliases “Rebeca Chalasani” and “Rebecca Chalasan” when she conspired with Prasad Chalasani to extract millions of dollars from Werner Wicker. As part of Sanjana and Prasad Chalasani’s scheme, Sanjana used these alias to pretend to be Prasad Chalasani’s niece. c. Sanjana also used the alias “Sanjana Rebecca.” d. Several of the documents obtained in the Alpha Group subpoena response1 include Sanjana as “Ms.Sanjana alias Anjana.” A copy of a signature page showing Sanjana’s alias Anjana is attached as Exhibit 2. e. One of the documents in the Alpha Group subpoena response includes Sanjana signing a document as “Sanjana Rebecca Abraham.” A screenshot of the document containing Sanjana’s signature as Sanjana Rebecca Abraham is attached as Exhibit 3. f. At her March 18, 2019 deposition, Sanjana admitted to using the aliases Sanjana Jon Abraham, Sanjana Rebecca Alexander, Sanjana Jon, and Rebecca Jon. During her deposition, Sanjana denied using the aliases Rebecca Dean and Rebecca Chalasani. Relevant excerpts from the March 18, 2019 deposition of Sanjana, at 46:23-49:23, is attached as Exhibit 4. 5. Many years after I met Werner Wicker, Sanjana obtained an introduction to me. She then used me to extract millions of dollars from Werner Wicker. Sanjana used two hooks to convince me to help her obtain “Wicker money”: (1) she claimed American racism against Indians led to her brother Anand Jon being convicted of multiple counts of statutory rape, forcible rape, and other sex crimes and Sanjana; (2) she pretended to be a humanitarian who needed money to help causes like the girl child and street dogs. 6. Sanjana used me as part of her scheme to obtain millions of dollars from Werner Wicker under false pretenses. I came to know Anand was the mastermind behind Sanjana’s scheme. 7. By the time Sanjana had taken over $7 million from Werner Wicker, I had realized Sanjana’s true nature. Everything for her was about “Lakshmi” and her brother Anand’s 1 See Paragraphs 18-19, below. 2 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 legal fees. When I say “Lakshmi,” I mean that she was obsessed with the pursuit of wealth. Money that I had sent her was not going to help the girl child or street dogs. Instead, Sanjana and her mother were buying property and living lavishly. 8. I began avoiding Sanjana to get away from her demands for more Wicker money. She started calling me and trying to cajole me for more Wicker money. Then she started pressuring me for more Wicker money. She complained that Louis Beria, one of her co- conspirators, had taken what she claimed was her Wicker money. 9. By early 2015, Sanjana was threatening me about what she would do if I did not give her more “Wicker money.” Sanjana started claiming she would embarrass me by saying (falsely) that she saw me in sexual relationships with other women. Then she started saying she would accuse me of sexual harassment. 10. Then Sanjana and her co-conspirators threatened that I could be investigated for terrorism from the United States Department of Homeland Security. 11. Finally, Sanjana and her co-conspirators (led by the plot’s mastermind Anand) began threatening that they would accuse me of sexually assaulting Sanjana. They claimed Sanjana had recordings where I confessed to sexual assault. This was not true. They also claimed they had evidence proving I had sexually assaulted Sanjana. This was not true. They threatened I would be prosecuted in multiple countries unless Sanjana received more Wicker money. 12. Even after Sanjana threatened me that she would accuse me of sexual assault, she still begged me to visit her in Dubai and to resolve the dispute over how much Wicker money she would receive. My December 2019 Motion and the Chalasani Emails 13. On or about December 10, 2019, I learned that Wicker’s attorneys had obtained 3 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 emails between Sanjana and Chalasani following a court-ordered November 2019 forensic collection of Chalasani’s emails and computer. 14. The emails between Sanjana and Chalasani showed them concocting the claims against me and Wicker. Sanjana’s story in the withheld Chalasani emails was inconsistent with the story in her complaints. Specifically, the fabricated story of sexual assault discussed in the 2015 Chalasani emails was that I had drugged Sanjana using pills. By the time she filed the complaint in this case in February 2016, she had changed her fabricated story to claim that I had drugged her with drops from a little glass bottle under her tongue. 15. Werner Wicker filed his December 11, 2019 Order to Show Cause, Motion Sequence 013, to dismiss Sanjana’s complaint or her willful and contumacious failure to respond to Defendants’ discovery requests dated June 6, 2016 and January 18, 2018, or, in the alternative, to strike and vacate the Note of Issue and compel Sanjana to make her SanjanaJon@gmail.com email account accessible for a forensic search and compelling Sanjana to appear for further deposition. 16. On December 13, 2019, I filed a cross-motion seeking the same relief as Wicker’s Order to Show Cause, Motion Sequence 014. New Facts and Evidence Not Offered on Prior Motion 17. On February 7, 2020, Werner Wicker’s attorneys sent my counsel a FedEx package containing USB drives with materials from a subpoena response produced by non-party Alpha Group. 18. The Alpha Group subpoena response included dozens of audio recordings created by Sanjana or her mother Shashi, hundreds of emails to or from Sanjana or her mother Shashi, photographs of Sanjana, and documents relating to Sanjana and her brother Anand’s efforts to 4 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 overturn Anand’s conviction for rape and other sex crimes. 19. Thirty recordings in the Alpha Group materials included Wicker’s attorney Daniel Weglarz, Esq. and in many of these recordings, Weglarz is conspiring with Sanjana’s mother Shashi, Sanjana’s brother Anand, and Sanjana’s attorney Zulfiqar Menon, Esq. to extort money from me, one of Sanjana’s co-conspirators Louis Beria, and Werner Wicker. These audio recordings were attached as Exhibit A to the August 4, 2022 Weglarz affidavit. The Weglarz affidavit is being contemporaneously filed with this motion. 20. The audio recordings on Exhibit A to the Weglarz affidavit can be downloaded from this link: https://wolfelawllc.sharefile.com/d-sf606ec87dcfa425ba695e3026d9c3557. 21. The Alpha Group materials also included Sanjana’s recording of call between herself and Saeed Sabooni, where Sabooni confronts her about the legal risks she faced from her scheme to bilk millions of dollars from Wicker and tells her about how I had called him distraught about how Sanjana was threatening to make accusations against me after all the money I had helped her obtain. The audio file of Sanjana’s recorded call with Sabooni, call_10- 08-54_IN_+19176621402.AMR, was attached as Exhibit A to the July 22, 2022 affidavit of Abdul Saeed Sabooni. The Sabooni affidavit is being contemporaneously filed with this motion. 22. The audio recordings on Exhibit A to the Sabooni affidavit can be downloaded from this link: https://wolfelawllc.sharefile.com/d-sc195858df1e248bea8dce14ad3f3fb19. 23. Fifteen recordings in the Alpha Group materials were made by Sanjana or Shashi of their telephone calls with me. Copies of these audio files can be downloaded from this link as Exhibit 5 https://wolfelawllc.sharefile.com/d-s4fc1781e26314d2cb26677764859fb1d, and will be filed with the Court on a flash drive containing a folder named “Paramatma Affidavit – Exhibit 5.” 5 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 24. One of the recordings in the Alpha Group materials was a call between Sanjana and her sham-husband Richard. Specifically, the following audio file call_10-27- 05_OUT_19177493014.mp3 contains a recording of a telephone conversation between Sanjana and Richard. A copy of this audio file can be downloaded from this link as Exhibit 6, https://wolfelawllc.sharefile.com/d-s5ceb59be79b141f49fd929224fe263e7, and will be filed with the Court on a flash drive containing a folder named “Paramatma Affidavit – Exhibit 6.” 25. The recordings in the Alpha Group materials included two calls involving Shashi and Anand. In call_16-41-15_IN_17135686986.AMR, Anand directs Shashi how to proceed with Sanjana’s claims against Wicker and me and dictates a letter for Shashi to have sent in connection with her claims in this case. Copies of these two audio files can be downloaded from this link as Exhibit 7, https://wolfelawllc.sharefile.com/d- s77947462eb3b4642866c35a87c241687, and will be filed with the Court on a flash drive containing a folder named “Paramatma Affidavit – Exhibit 7.” 26. New evidence was obtained as recently as September 2022, when my counsel obtained four recordings made by Weglarz of calls with Sanjana and 1 recording of a call made by Weglarz of a call with Shashi. Copies of these five audio files can be downloaded from this link as Exhibit 8, https://wolfelawllc.sharefile.com/d-s16a5915db1d64212afc907e1fd0233dd, and will be filed with the Court on a flash drive containing a folder named “Paramatma Affidavit – Exhibit 8.” 27. I did not have access to the Alpha Group materials until almost two months after Werner Wicker filed his December 11, 2019 Order to Show Cause, Motion Sequence 013, to dismiss Sanjana’s complaint or her willful and contumacious failure to respond to Defendants’ discovery requests dated June 6, 2016 and January 18, 2018, or, in the alternative, to strike and 6 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 vacate the note of issue and compel Sanjana to make her SanjanaJon@gmail.com email account accessible for a forensic search and compelling Sanjana to appear for further deposition. I did not obtain access to the Alpha Group subpoena response materials until over a month after my December 13, 2019 cross-motion (Motion Sequence 14) had been fully briefed. I. Sanjana’s Recordings of Her Conversations with Me. 28. One category of Sanjana’s recordings that Sanjana withheld from discovery and that I did not obtain until after my December 2019 motion are her recordings of conversations with me. 29. call_00-08-01_IN_+491748670070.AMR is a recording of a telephone conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices on this recording. To my knowledge, the recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation and many conversations like this, where Sanjana would harangue me about Wicker, Beria, and the Wicker money that had been obtained that she was demanding for herself. A copy of the translated transcript of call_00-08-01_IN_+491748670070.AMR is attached as Exhibit 9; see also Ex. 5. 30. Sanjana was upset about Wicker money that Beria (who she calls CS for Chandra Shaker) obtained instead of her. I complained about how Sanjana was pressuring me for money. I complained that after I had “helped you all” (given them so much money), “I have to listen so much.” I complained about my stress and said I felt like jumping in the Ganges. I was so upset about all Sanjana’s calls demanding money that I was thinking of suicide. Sanjana said that Beria had “stolen the money” and should go to jail. She told me that I was “Giving the key to the thief.” Ex. 5; Ex. 9 at 2-7. 31. calI_00-37-49_IN_+491748670070.AMR is a recording of a telephone 7 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation. A translated transcript of calI_00-37-49_IN_+491748670070.AMR is attached as Exhibit 43. 32. In calI_00-37-49_IN_+491748670070.AMR, Sanjana and I exchanged New Years greetings. After I volunteered that Wickers health was not good, Sanjana asked details about which of Wicker’s family members had come to visit him. Ex. 43 at 1-2. 33. Call_22-51-29_OUT_+491748670070.AMR is a recording of a telephone conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation. A copy of the translated transcript of Call_22-51-29_OUT_+491748670070.AMR is attached as Exhibit 10. See Ex. 5. 34. In Call_22-51-29_OUT_+491748670070.AMR, Sanjana called me. I complained about all the stress I was under because of “The money.” I told Sanjana that Wicker had sent people, through KPMG, to the Mill Neck property and Sanjana responded that “these men are sent through Lewis [Beria]” and they must be from Beria’s team. Sanjana and I both complained about our health, and when she said she had a “breathing problem” and some “chest congestion” I told her “You have to take care of yourself.” I also repeated on this call that I was thinking of suicide. See Ex. 5, Ex. 10 at 1-3 and 6. 35. call_15-33-31_IN_+491737432780.AMR is a recording of a telephone conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation. A copy of the translated 8 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 transcript of call_15-33-31_IN_+491737432780.AMR is attached as Exhibit 11. 36. In call_15-33-31_IN_+491737432780.AMR I again complained about the pressure over Wicker money. Sanjana yelled at me because she wanted more money and she complains in this recording how her co-conspirators Louis Beria and Tim House were spending money. Sanjana lied in her lawsuit against me, and she told different lies in call_15-33- 31_IN_+491737432780.AMR. At the beginning of the call, we were arguing about the Wicker money. I said “I didn’t take any money out of it. Did I ever take it? Did I ever take it?” and Sanjana responded by arguing about money and the ways Beria was using the money. For example, she yelled that “You want to save money, but when CS [Beria] spends on drinking alcohol and flirting with girls, then money is not a problem. . . Yeah there is money for Tim [House] and Tim’s girlfriend, there is money for the holiday that CS has to go. And then for the rightful thing that I am doing, you have problem. What is this?” Ex. 5, Ex. 11 at 1-2. 37. When I didn’t succumb to Sanjana’s pressure for more money, she tried to create evidence that she could use against me. This did not surprise me, because I witnessed how Anand directed Sanjana to create evidence against Richard Bernard. When Sanjana yelled that I had tried to “forcefully kiss somebody” and that I was “making forceful demands on people,” I responded that she was talking nonsense and that she was “lying too much.” And then Sanjana threatened to smear me by saying I was “roaming around with these girls, Marika or something, I don’t know who else you roam around with.” She also said I had made “demands” on her. And she shouted about “every woman who you have slept with.” This showed me she was ready to smear me, and I defended myself by saying “For money, for money.” I was telling her this was extortion and immoral. Ex. 5, Ex. 11 at 4-6. 38. Call_01-28-21_IN_+491748670070.AMR is a recording of a telephone 9 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation. A copy of the translated transcript of Call_01-28-21_IN_+491748670070.AMR is attached as Exhibit 12. 39. In Call_01-28-21_IN_+491748670070.AMR, Sanjana complained again about Beria getting the Wicker money. Sanjana states that “He has committed the biggest theft. . . Only one man is getting all these things done; it is CS [Beria] who is getting all these things done.” This call shows more of my avoidance of Sanjana. I tried to escape her pressure by saying we needed to be very careful and use strategy with these things relating to the Wicker money. Ex. 5, Ex. 12 at 1. 40. Call_10-06-28_IN_+491748670070.AMR is a recording of a telephone conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation. A copy of the translated transcript of Call_10-06-28_IN_+491748670070.AMR is attached as Exhibit 13. 41. In Call_10-06-28_IN_+491748670070.AMR, Sanjana again pressured me for Wicker money. Sanjana was worried about Wicker money that Beria had already taken relating to the Atlanta portion of the scheme, and how she would get her cut of the Wicker money if Beria had already taken money. Sanjana also complained that Beria was a “criminal” with a “criminal track record” and a “criminal brain” and that I was allowing him to play with the Wicker money. Ex. 5, Ex. 13 at 2-7. 42. CalI_02-10-11_OUT_+491748670070 is a recording of a telephone conversation between Sanjana and me that I have received and reviewed. I recognize my and Sanjana’s voices 10 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation and other conversations like this. A copy of the translated transcript of CalI_02-10-11_OUT_+491748670070 is attached as Exhibit 14. See Ex. 5. 43. I had shared with people close to Sanjana that she was demanding more and more “Wicker money” and she was making threats at me. After Sanjana had already been making threats at me, she started this call by saying “Can we at least from today maintain a positive note from whatever we talk or do, can we do that please?” But when Sanjana did not get what she wanted from me, she escalated and threatened me that she would make accusations to embarrass me. For example, she tried to insult me with claims that I had a “mental issue” or was a “sexual pervert.” I warned her to stop saying “filthy” things, she made her threats against me even more explicit: “If you do this, I’m telling you, I will not sit quiet. I’m telling you this. I will not sit quiet. Every day all these holy people go to jail because they sexually assault the people. I’m telling you. You’ve tried all the nonsense. Don’t try it with me. . . In ISKCON also, you went around. . . sexually torturing all the women out there. Now you’re trying it on me?” Ex. 5; Ex. 14 at 1, 4-5. 44. Then Sanjana continued her threats against me by saying “Listen, you stole all the money from the godfather [Werner Wicker] and even now . . . All the money that you’ve stolen . . . don’t try these tricks, you give me what’s rightfully mine.” Ex. 5; Ex. 14 at 1, 4-5. 45. In CalI_02-10-11_OUT_+491748670070, I repeated my response to Sanjana’s threats that this was all extortion: “You did it for the money, for the money.” Ex. 5; Ex. 14 at 5. 46. Call_10-19-58_IN_+491748670070.AMR is a recording of a telephone conversation between Sanjana and me that I have received and reviewed. I recognize my and 11 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation. A copy of the translated transcript of Call_10-19-58_IN_+491748670070.AMR is attached as Exhibit 15. 47. In Call_10-19-58_IN_+491748670070.AMR, Sanjana again pressured me for Wicker money, spoke about how Beria was a criminal, and complained about how Beria was spending money. This was yet another call where Sanjana pressured me to get Wicker money back from Beria for her. And it was yet another call where I stated I was considering suicide. Ex. 5, Ex. 15 at 1-3. 48. call_03-34-52_IN_+491748670070 is a recording of a telephone conversation between Sanjana and me. I recognize my and Sanjana’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember that this call took place after I had spoken to Saeed Sabooni about Sanjana threatening to accuse me of assault unless I gave her more Wicker money. A copy of the translated transcript of call_03-34-52_IN_+491748670070 is attached as Exhibit 16. 49. In call_03-34-52_IN_+491748670070, Sanjana was angry that I spoke to Sabooni about the millions of dollars I helped her obtain from Wicker. She was worried that Sabooni could “blackmail” her with this information. Sanjana warned me against speaking about her with others, and she threatened to say bad things about me. Sanjana was upset that I had spoken about the amount of “Wicker money” that she had obtained. Sanjana warned me “Who is he to talk about the money or business or you and me are working together? Who is he? Tomorrow if he starts to blackmail me and you, what will you do? If he calls tomorrow and says that I know it all and I will tell him that, I will do that, then what will you do? Why are you intentionally giving a sword in the hands of people.” Ex. 5, Ex. 16 at 4. 12 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 50. Sanjana told me that the Wicker money scheme was “our important thing, this is our thing.” Yet she also also referred to what people could see on the Internet about “you, who is GF [Wicker], what about the house.” Sanjana then threatened me with how she would spread rumors about me by asking “Should I call ten people and tell about this and that.” Ex. 5, Ex. 16 at 4. 51. By this call, I was done with Sanjana’s extortion attempts. I told: “You always keep the gun on me and talk to me, ‘Where is the money, where is the money, where is the money?’” and I told her that “When you got your money, everything was okay, but then after that you also started to threaten me.” Ex. 5, Ex. 16 at 19-20. 52. In this call, which took place after Sanjana had started threatening to accuse me of sexual assault, she begged me to come visit her in Dubai. She warned me that “this thing will just keep increasing” unless I met her in Dubai. I refused and told her she had already escalated so much with her threats. Ex. 5, Ex. 16 at 22. II. Sanjana’s Mother’s Recordings of Her Conversations with Me. 53. Another category of Sanjana’s recordings that were discovered in the Alpha Group materials were recordings that Shashi made of her conversations with me. 54. Call_09-32-47_OUT_+491748670070.AMR is a recording of a conversation between Shashi and me. I recognize my and Shashi’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation and other conversations like this. I was telling Shashi about the awful accusations that Sanjana was threatening to make about me. A copy of the translated transcript of Call_09- 32-47_IN_+491748670070.AMR is attached as Exhibit 17. 55. In Call_09-32-47_OUT_+491748670070.AMR Shashi referred to the fight 13 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 between Sanjana and me as “like a small little mosquito bite.” I interrupted and said, “No it is not about mosquito bite. It’s all about Lakshmi [money] you know. It’s all about millions and trillions.” Ex. 5; Ex. 17 at 2. 56. Sanjana was threatening to malign me by accusing me of sexual assault. Shashi tried to use this as both a threat, by saying Sanjana could be “going and talking to ten different people” which “doesn’t help us,” and I interrupted that “such allegations that means we are not thankful for the eight million what we got here.” When I described Sanjana’s threatened allegations as “such demonic, devil accusations,” Shashi replied: “We can always solve our difference of opinion or any small fights or anything, you know. . . This is the money that is due to us.” I responded that “These are not small fights. These are big, big accusations, no?” I complained to Shashi about how Sanjana and her only cared about money and how many millions more I could give them from Wicker. Ex. 5; Ex. 17 at 4. 57. Shashi, like Sanjana, also complained about how Beria was keeping what she considered “our money” from Wicker. “Why should Louis [Beria] keep our money? It is our money and Louis is keeping it.” Ex. 5; Ex. 17 at 6-7. 58. call_00-57-29_OUT_+919996400085.AMR is a recording of a conversation between Shashi and me. I recognize my and Shashi’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered. I remember this conversation and other conversations like this. A copy of the translated transcript of call_00-57- 29_OUT_+919996400085.AMR is attached as Exhibit 18. 59. In call_00-57-29_OUT_+919996400085.AMR, Shashi referred to Sanjana’s threats against me as “tensions and, you know, unnecessary fights” as part of her efforts to get me to see Sanjana again. During this time Sanjana and Shashi were trying to get me to meet with 14 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 Sanjana and I was avoiding such a meeting because, based on how I witnessed Anand direct Sanjana to trap Richard, I expected this to be a trap. I also did not want to see Sanjana again after the ways she tried to extort more Wicker money from me. Ex. 5; Ex. 18 at 2-3 60. call_09-47-28_OUT_+491748670070.mp3 is a recording of a conversation between Shashi and me. I recognize my and Shashi’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered; however, to be clear, the conversation was cutoff as I started to respond to Shashi. I remember this conversation. A copy of the transcript of call_09-47-28_OUT_+491748670070.mp3 is attached as Exhibit 19. 61. I remember the conversation on call_09-47-28_OUT_+491748670070.mp3 as an obvious attempt to manufacture evidence in favor of Sanjana’s false accusations. Shashi and Sanjana had been playing roles as “good cop/bad cop,” Sanjana would call with threats and Shashi would pretend to be a neutral trying to get everything resolved. On this call, Shashi stated that Sanjana was “telling that you have molested her” and I was starting to respond by saying “Yeah she would say this, because she wants money.” But Shashi hung up the phone when I started to say I didn’t understand what she was saying. Ex. 5; Ex. 19 at 1. 62. call_09-50-26_IN_+491748670070.AMR is a recording of the conversation between Shashi and me that started in call_09-47-28_OUT_+491748670070.mp3. I recognize my and Shashi’s voices on this recording. The recording is a complete and accurate recording of the conversation and has not been altered; however, to be clear, the conversation was cutoff as I started to respond to Shashi. I remember this conversation. A copy of the transcript of call_09- 50-26_IN_+491748670070.AMR is attached as Exhibit 20. 63. After Shashi called and repeated Sanjana’s threatened accusation, I rejected the accusation. When Shashi pretended to be in pain over Sanjana’s accusation, I responded: “No, 15 of 25 FILED: NASSAU COUNTY CLERK 10/12/2022 10/17/2022 07:40 11:30 AM PM INDEX NO. 600703/2016 NYSCEF DOC. NO. 698 794 RECEIVED NYSCEF: 10/12/2022 10/17/2022 tell me what is the pain and what is the reason. If she’s speaking something nonsense, then that is