Exhibit A to United States' Sentencing Memorandum: Excerpt of Will-Darnall Deposition — United States v. Cassie Will-Darnall (Dkt. 85.1)
Summary
Exhibit A (Document 85-1, filed August 27, 2025) to the United States’ Sentencing Memorandum in United States v. Cassie Will-Darnall, Case 5:24-cr-00292-PCP. It is an excerpt of the 2021 deposition of Cassie Will-Darnall in Spieker Companies, Inc. v. Rosswood Properties, LLC, et al., in the Superior Court of the State of California for the County of Santa Clara, reported by Celeste J. Silva. In the pages reproduced, Mr. Stephenson asks about Alternative Health Services, Inc. and a Secretary of State filing listing Will-Darnall’s address. Will-Darnall answers that she was going to continue doing business but never did because of COVID, that she received no salary from the company and was never employed by it, and that she has no intention of restarting it.
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“Exhibit A to United States' Sentencing Memorandum: Excerpt of Will-Darnall Deposition — United States v. Cassie Will-Darnall (Dkt. 85.1).”
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Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 1 of 10
Exhibit A
United States v. Cassie Will-Darnall, 5:24-cr-00292-PCP
United States’ Sentencing Memorandum
Excerpt of Deposition of Will-Darnall
for Spieker Companies, Inc. v.
Rosswood Properties, LLC, et. al.
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 2 of 10
SUPERIOR COURT OF THE STATE OF CALIFORNTA
IN AI{D FOR THE COUNTY OF SA.I\TTA CLARA
SPIEKER COMPAI{IES, TNC. , A
California Corporation,
Plaintiff,
vs. NO. r_8CV33 83 08
ROSSWOOD PROPERTIES, LLC, A
california l,imited Liability
company; GASSTE WILL-DARNALL, €rI}
individual; LAURA MENICUCCI, an
individual, and DOES l- through
50, inclusiwe,
Defendants.
DEPOSITION OF CASSIE WTLL-DARNALL
APPEARING REMOTELY FROM
LOS GATOS, CALIFORNIA
AUGUST AL, 2O2L
LOz02 A.M
REPORTED BY:
Celeste J. Silva
CSR No. LOL79
APPEARING REMOTELY FROM TULARE COUNTY, CALIFORNTA
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 3 of 10
CASSIE WILL-DARNALL
August 11,2021
1 REMOTE APPEARANCES:
2
3 For the Plaintiff:
4 PAI{L & McCAY
ERf C ,J . STEPHENSON, ESQ .
5 225 West Santa Clara Street, suite 1500
San Jose, California 9511-3
6 (408) 286 -s100
e s tephenson@pah1 - mc cay . com
7
8
For ttre Def endant:
9
SILICON VALLEY LAW
10 MARC G. VAN NTEKERK, ESQ.
One North Market Street, Suite 2OO
1l- San Jose, California 95113
(408) 573 -s700
l2 mwn@swig. com
13
Also present: Tod Spieker
1,4 Don Naugle
15
1-6
L'7
t-8
L9
20
2L
22
23
24
25
First Legal Depositions - Calendar@firstlegal.com 2
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 4 of 10
CASSIE WILL-DARNALL
August 11,2021
1 INDEX TO EXAMTNATION
2
3 WTTNESS : CASSIE WrLL-DARNALL
4 PAGE
5 By Mr. Stephenson 5
6
7
8
9
10
l_ t_
1,2
1_3
1,4
l-5
1,5
L7
18
1,9
20
21,
22
23
24
25
First Legal Depositions - Calendar@firstlegal.com 3
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 5 of 10
CASSIE WILL-DARNALL
August 11,2021
1 INDEX TO EXHIBITS
2 CASSIE WTLL-DARNALL
3 SPIEKER VS. ROSSWOOD PROPERT]ES
4 AUGUST LL, 2021,
5 Celeste J. Silva CSR No. L0L79
6
7 MARKED DESCR]PTION PAGE
8 Exhibit 1 Notice 18
9 Exhibit 2 Secretary of State Filing 22
10 Exhibit 3 Example Lease 35
l- t_ Exhibit 4 Letter of Responsibility 4L
1-2 Exhibit 5 List of Units 46
13 Exhibit 6 3/25/1,8 E-mail 51
L4 Exhibit 7 /LB E-mai1
7 /Lo 69
15 Exhibit I 4/28/L9 E-mail 72
L6 Exhibit 9 Not.ice to Vacate 81
L7
l-8
L9
20
2L
22
23
24
25
First Legal Depositions - Calendar@firstlegal.com 4
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 6 of 10
CASSIE WILL.DARNALL
August 11,2021
l_ O Are you familiar with a company by the name of
2 Alternative Health Services, Inc.?
3 A Yee.
4 O And what do you associate with the name
5 Alternative Health Services, Inc.?
5 A There's no aeEociation.
7 O How are you familiar with the name?
8 A I know of the company.
9 a Okay. What is your understanding of what that
10 company does?
11 A I don't think it's in business.
l2 O Okay. So if there was a Secretary of State
13 fiting with the if t.here is a filing with the
14 California Secretary of State for a company by t.he name
15 of Alternative Health Services, Inc., it says that
t5 theyrre doing business out of your address at 1l-1
l7 Bellwood Gateway, Los Gatos.
18 Do you have any idea why that would be the
19 case?
20 A Yes.
2L 0 Okay. Why would that be?
22 A [Ie11, I was going to continue doing business,
23 but I never did because of COVID.
24 O So does that mean that you had intended t,o do
25 business with or as part of Alternative Health Services,
First Legal Depositions - Calendar@firstlegal.com 14
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 7 of 10
CASSIE WILL.DARNALL
August 11,2021
1 Inc. ?
2 A Possibly.
3 O Okay. Do you ever receive any sort of salary
4 f rom Alternat,ive Health Services, fnc. ?
5 A No.
6 O Were you ever employed at any time by
7 Alternative Health Services, Inc.?
I A No.
9 O Okay. Do you know why that company would have
10 your address listed as part of the Secretary of State
11 filings?
L2 A Like I eaid, f wae going to open to conEinue to
13 do businegs, but it, didn't work out.
l4 O Okay. So you were going to do business in the
15 name of Alternative Health Services, Inc. then?
15 A Right,.
L7 O Okay. And I know you said it didn't work out
18 I'm just going to ask you pretty briefly to explain
19 that, why that didn't work out.
20 A Ylle wenE through a pandemic.
21, O Can you be a lit,tle bit more specific what
22 exactly happened in the pandemic that resulted in you
23 not being able to open up?
24 A Nobody was traveling.
25 O What is the nature of the business of
First Legal Depositions - Calendar@firstlegal.com 15
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 8 of 10
CASSIE WILL-DARNALL
August 11,2021
t_ Alternat,ive Health Services, fnc . ?
2 A There is no bueinees. fE wae never
3 eetablished.
4 O What was the proposed business? What, was
5 what was their plan for making money as part of that
6 business?
7 A It, never got that far.
I O So what was the purpose of the Secretary of
9 State filing with your address?
10 MR. VAIiI NIEKERK: The objection to the question
l_1 it's been asked and answered.
L2 BY MR. STEPHENSON:
13 0 You can answer.
1,4 Ms. Darnall, do you need me to repeat the
L5 question?
15 A Yeg.
t7 O Okay. If there was no plan, Do business plan
1_8 at all with no idea of how you would make money through
L9 Alternative Health Services, fnc., do you know why
20 therels a Secretary of State filing with your name on
21, ir?
22 MR. VAII NIEKERK: Repeat my objection. It]s
23 been asked and answered.
24 THE WfTNESS: Yeah, I agree with my attorney.
25 I already anEwered it.
First Legal Depositions - Calendar@firstlegal.com 16
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 9 of 10
CASSIE WILL-DARNALL
August 11,2021
1 BY MR. STEPHENSON:
2 O Okay. I don't think that you did, but I think
3 that for purposes of this inquiry f don't know if it's
4 necessary to go forward.
5 Do you have plans at this point to restart that
6 business for Alternative Health Services, Inc.?
7 MR. VAN NIEKERK: Objection. That was never
I it was never started so she canrt, restart it.
9 THE WITI{ESS: I would hope at some point that I
10 would be errployed again, yes.
L1 BY MR. STEPHENSON:
L2 O OkaY.
13 A But I donrt know.
L4 O okay.
15 A At this point, I have no intention of doing
15 that.
t7 O Okay. Fair enough. When you were working with
18 Rosswood Properties, LLC, what was your job title
L9 there?
20 A EEO.
2t O And that's from formation of the LLC,
22 correct?
23 A Yee.
24 O And the LLC was formed in approximately 2015;
25 is t.hat accurate?
First Legal Depositions - Calendar@firstlegal.com 17
L.A. 855.348.4997
Case 5:24-cr-00292-PCP Document 85-1 Filed 08/27/25 Page 10 of 10
CASSIE WILL-DARNALL
August 11,2021
t_ STATE OF CALIFORNIA )
) ss.
2 COUNTY OF TU],ARE )
.3
4 I , CELESTE SILVA, a Cert.ified Short.hand
5 Reportrer of ttre State of California, do hereby
6 certify:
7 That prior to being examined, the witness
I in the foregoing proceedings was by me duly sworn to
9 testify to ttre trutrh, the whole t,ruth and not.hing
1_0 but the truth;
1t_ Ttrat said proceedings were taken remotely
L2 before me at the time and place therein set forth
13 and were take down by me in short.hand and trhereafter
L4 transcribed intro t14>ewriting under my direction and
15 superwision;
l-6 I furttrer certify that I am neither
L7 counsel for, nor related to, any parties to said
18 proceedings, rror in anyway interested j-n ttre outcome
19 thereof.
20 In wit.ness whereof , I hawe hereunto
2t subscribed my name.
22
23 DAT : August 2 2021,
24
25
CELESTE STLVA, CSR IO1-79
First Legal Depositions - Calendar@firstlegal.com 102
L.A. 855.348.4997
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