2011-12-22 Rothstein Scott AM

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IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA Case No. 09-062943 (07) _____________________________________________________ RAZORBACK FUNDING, LLC, et al., Plaintiffs, vs. SCOTT W. ROTHSTEIN, et al., Defendants. ____________________________________________________

DAY 9 - MORNING SESSION DEPOSITION OF SCOTT W. ROTHSTEIN

DATE TAKEN: TIME: PLACE:

December 22, 2011 8:37 a.m. - 12:00 p.m. James Lawrence King Federal Justice Building 99 N.E. Fourth Street Courtroom 11-3 Miami, Florida 33128

Examination of the witness taken before: Michele L. Savoy, Registered Professional Reporter United Reporting, Inc. 1218 S.E. Third Avenue Fort Lauderdale, Florida 33316 (954) 525-2221

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IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA

2 3

____________________________________________________ Case No. 10-24110 CACE(19)

4 5

EDWARD J. MORSE and CAROL A. MORSE, and MORSE OPERATIONS, INC.

6

Plaintiffs,

7

vs.

8

SCOTT W. ROTHSTEIN, et al.,

9 10

Defendants. _____________________________________________________ Case No. 11-CV-61688-JIC/LSS

11

AMY ADAMS, et. al,

12

Plaintiffs, vs.

13 14 15

SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTAR PRIVATE BANK AND TRUST COMPANY, Defendants.

16

_____________________________________________________

17

10-03767-RBR Stettin v. Gibraltar Private Bank & Trust Co.

18 19

10-03802-RBR Stettin v. Centurion Structured Growth, LLC, et al

20

11-02368-RBR Stettin v. TD Bank, N.A.

21

11-02288-RBR Stettin v. Fidelity Charitable Gift Fund

22

11-02473-RBR Stettin v. Regent Capital Partners, LLC, et al

23 24

11-02604-RBR Stettin v. Maple Leaf Drilling Partners, et al

25

11-02605-RBR Stettin v. Don King Productions, Inc.

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(Counsel appearing on the foregoing appearance pages reflect counsel that attended at least one day during the deposition. It does not reflect their appearance each and every session.)

3 4 5 6 7

APPEARANCES FOR SCOTT ROTHSTEIN: LAW OFFICE OF MARC S. NURIK 1 East Broward Boulevard Suite 700 Fort Lauderdale, Florida 33301 BY: MARC S. NURIK, ESQUIRE

8 9 10 11 12 13 14 15 16

APPEARANCES FOR THE CHAPTER 11 TRUSTEE, HERBERT STETTIN: BERGER SINGERMAN 350 East Las Olas Boulevard Suite 1000 Fort Lauderdale, Florida 33301 BY: CHARLES H. LICHTMAN, ESQUIRE and GENOVESE, JOBLOVE & BATTISTA, P.A. 100 S.E. 2nd Street Suite 4400 Miami, Florida 33131 By: JOHN. H. GENOVESE, ESQUIRE DAVID C. CIMO, ESQUIRE THERESA M.B. VAN VLIET, ESQUIRE JESUS SUAREZ, ESQUIRE

17 18 19 20 21 22 23 24 25

APPEARANCES FOR RAZORBACK: CONRAD & SCHERER, LLP 633 South Federal Highway Eighth Floor Fort Lauderdale, Florida 33302 By: WILLIAM R. SCHERER, ESQUIRE ERIC RAYMAN, ESQUIRE IVAN J. KOPAS, ESQUIRE and KOZYAK, TROPIN & THROCKMORTON, P.A. 2525 Ponce de Leon Boulevard Ninth Floor Coral Gables, Florida 33134 By: HARLEY S. TROPIN, ESQUIRE

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APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE CENTURION STRUCTURED GROWTH, LLC:

2 3 4

GOLDSTEIN, TANEN & TRENCH, P.A. One Biscayne Tower, Suite 3700 Two South Biscayne Boulevard Miami, Florida 33131 By: SUSAN E. TRENCH, ESQUIRE

5 6 7 8 9 10

APPEARANCES FOR THE COMMITTEE OF UNSECURED CREDITORS: AKERMAN, SENTERFITT One Southeast Third Avenue 25th Floor Miami, Florida 33131-1704 By: MICHAEL GOLDBERG, ESQUIRE JONATHAN S. ROBBINS, ESQUIRE

11 12 13 14 15

APPEARANCES FOR TD BANK: GREENBERG TRAURIG, P.A. 401 E Las Olas Blvd Ste 2000 Fort Lauderdale, Florida 33301 By: HOLLY SKOLNICK, ESQUIRE DONNA EVANS, ESQUIRE MARK SCHNAPP, ESQUIRE

16 17

APPEARANCES FOR RLI ZURICH INSURANCE COMPANY, COLUMBIA INC. & ZURICH INSURANCE:

18 19 20

CLAUSIN MILLER One Chase Manhattan Plaza 39th Floor New York, New York 10005 BY: SCOTT L. SCHMOOKLER, ESQUIRE

21 22 23 24 25

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APPEARANCES FOR FEDERAL INSURANCE COMPANY:

2

ALEX HOFRICHTER, P.A 1430 South Dixie Highway Suite 204 Coral Gables, Florida 331463127 By: ALEX HOFRICHTER, ESQUIRE

3 4 5

APPEARANCES FOR MORSES:

6 7 8 9 10 11

TRIPP SCOTT, P.A. 110 S.E. Sixth Street,15th Floor Fort Lauderdale, Florida 33301 By: GEORGE WALKER, ESQUIRE JOHN M. MULLIN, ESQUIRE and LAW OFFICES OF ROBERTA DEUTSCH 2499 Glades Road Suite 110 Boca Raton, Florida 33431 By: ROBERTA M. DEUTSCH, ESQUIRE

12 13 14 15

APPEARANCES FOR EMESS CAPITAL, LLC: KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL 201 S Biscayne Blvd Fl 17 Miami, Florida 33131 BY: CASEY H. CUSICK, ESQUIRE

16 17 18 19

APPEARANCES FOR ST. PAUL FIRE & MARINE: MILLS PASKERT DIVERS P.A. 100 N Tampa St Ste 2010 Tampa, Florida 33602 BY: JOHN A. BLACK, JR., ESQUIRE

20 21 22 23 24

APPEARANCES FOR ROSANNE CARETSKY: BILLING COCHRAN LYLES 515 E Las Olas Blvd Floor Six Fort Lauderdale, Florida 333012296 By: DAN GELBER, ESQUIRE TUCKER CRAIG, ESQUIRE

25

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APPEARANCES FOR PLATINUM & CENTURION: CURTIS, MALLET-PREVOST, COLT & MOSLE, LLP 101 Park Avenue New York, NY 10178-0061 By: GABRIEL HERTZBERG, ESQUIRE ELIOT LAUER, ESQUIRE

5 6 7

APPEARANCES FOR MURRAY HUBERFELD, DAVID BODNER & MARK NORDLICHT: By:

HARVEY WERBLOWSKY, ESQUIRE

8 APPEARANCES FOR FEPICT, MS GROUP:

9 10 11

NYSTROM, BECKMAN & PARIS One Marina Park Dr., 15th Flr. Boston, MA 02210 By: JACK SEIGAL, ESQUIRE

12 APPEARANCES FOR MICHAEL SZAFRANKSI:

13 14 15 16

LYDECKER, DIAZ 1221 Brickell Avenue Floor 19 Miami, Florida 33131 BY: CHRISTOPHER G. BERGA, ESQUIRE MIGUEL J. CHAMORRO, ESQUIRE

17 APPEARANCES FOR GIBRALTAR:

18 19 20

STEARNS WEAVER MILLER, et al. 150 W Flagler St Ste 2200 Miami, Florida 331301545 BY: MARY BARZEE-FLORES, ESQ. MATTHEW DATES, ESQUIRE

21 22 23 24

APPEARANCES FOR FRANK PREVE: PODHURST ORSEK 25 W Flagler St Ste 800 Miami, Florida 331301720 BY: RAMON A. RASCO, ESQUIRE

25

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APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES, WATCH U-WANT, INC.:

2 3 4

KOPELOWITZ OSTROW 200 SW 1st Ave Ste 1200 Fort Lauderdale, Florida 33301 By: BART A. HOUSTON, ESQUIRE JAN ATLAS, ESQUIRE

5 6 7 8 9

APPEARANCES FOR THE US GOVERNMENT: U.S. DEPARTMENT OF JUSTICE UNITED STATES ATTORNEY'S OFFICE 500 E. Broward Blvd., Ste. 700 Ft. Lauderdale, Florida 33394 BY: CYNTHIA STONE, ESQUIRE

10 APPEARANCES FOR FRANK SPINOSA:

11 12 13 14 15 16

SCHLESINGER AND COTZEN, P.L. 799 Brickell Plz Ste 700 Miami, Florida 33131 BY: MICHAEL J. SCHLESINGER, ESQUIRE and MICHAEL COTZEN, ESQUIRE and SAMUEL J. RABIN, ESQUIRE 799 Brickell Plaza Suite 606 Miami, Florida 33131

17 18 19 20 21 22 23 24 25

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INDEX

2

CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

3 DIRECT

4

FURTHER DIRECT 2356

5

Mr. Rasco Ms. Barzee-Flores Mr. Rabin

6

Mr. Rasco

2510

CERTIFICATE OF OATH CERTIFICATE OF REPORTER

2516 2517

2393 2458

7 8 9 10 11 12

PREVE'S EXHIBIT INDEX NO. 272 273 274

DESCRIPTION FP112310-0143388/1 FP112310-0134610/1 FP112310-0145380/1

PAGE NO 2368 2393 2393

13 14 15 16 17 18 19 20 21 22 23 24 25

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Thereupon, the following proceedings were had:

2

MR. RASCO:

3

THE WITNESS:

4

You represent who again?

5

MR. RASCO:

6

MR. CUSICK:

Ready to go? I'm ready.

I represent Frank Preve. Counsel, before you begin,

7

I'm just going to put an objection on the

8

record.

9

On behalf of Emess Capital, as to not

10

being permitted time in this deposition to

11

depose Mr. Rothstein, I object to the counsel

12

for the trustee's violation of the protocol

13

orders, an order permitting Emess to depose

14

Mr. Rothstein at this deposition by trying to

15

shut us out of the deposition.

16

THE COURT REPORTER:

17 18

hearing you, sir. MR. CUSICK:

I'm having trouble

Maybe you move closer. We object to counsel for the

19

trustee's violation of the various protocol

20

orders in trying to shut us out of the

21

deposition by refusing us time to depose Mr.

22

Rothstein, by failing to timely send over his

23

exhibits, in accordance with the protocol

24

orders.

25

On the same basis, we move to strike the

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testimony taken by the Trustee and also the

2

testimony taken by TD Bank, based upon the

3

inability to cross-examine Mr. Rothstein as to

4

that testimony, also the failure to abide by

5

the court order by sending over exhibits

6

timely.

7

We reserve the right to depose

8

Mr. Rothstein at a future date, and we reserve

9

all rights against the Trustee and TD Bank.

10

We further object on behalf of all other

11

entities which are represented by the Law Firm

12

of Kluger Kaplan to the extent that the

13

Trustee served notices of taking deposition

14

that were filed in those cases prior to those

15

entities being served with the complaint; and

16

we move to strike those notices of taking

17

deposition.

18 19 20

Thank you very much.

Sorry to eat into

your time. MR. LICHTMAN:

Let the record reflect in

21

the underlying Rothstein, Rosenfeldt & Adler

22

case pending before Judge Cohn, as well as in

23

the protocol orders, neither of them afforded

24

Emess Capital any entitlement whatsoever to

25

take or participate in the questioning of

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Mr. Rothstein.

2

order; and, indeed, Emess came late to the

3

table, and as we have told Emess, and numerous

4

other parties, we are hopeful that there will

5

be another round of discrete depositions that

6

don't focus on what we call "the big case" or

7

the other two limited depositions that are

8

commencing today.

9

objections are all completely frivolous and

10

It was a tightly negotiated

So I think that the

baseless and in bad faith.

11

MR. CUSICK:

Also let the record reflect

12

that prior to the first date of the

13

deposition, the Court entered an order

14

permitting Emess to depose Mr. Rothstein and

15

that we were not privy to any discussions

16

concerning the protocols that the depositions

17

and --

18

COURT REPORTER:

I can't hear you, sir.

19

MR. SCHLESIGNER:

Guys, we can do all

20

this during lunch time.

21

MR. LICHTMAN:

22 23 24 25

record later.

We can put this on the

Let's get going.

Whereupon, SCOTT W. ROTHSTEIN, acknowledged having been duly sworn to tell the truth

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and testified upon his oath as follows:

2

THE WITNESS:

3

MR. NURIK:

4

I do. Counsel, did you send me the

documents?

5

MR. RASCO:

No.

I only have very limited

6

exhibits.

7

actually, you know what, I'll bring them to

8

you right now.

9

probably not going to use them.

10

Mr. Nurik.

I'll bring them up to you -- well,

I only have a few, and I'm I apologize,

Here you go.

11

MR. NURIK:

Thank you.

12

MR. RASCO:

And I'm not going to even get

13

into those just yet.

14 15 16 17 18

FURTHER DIRECT EXAMINATION BY MR. RASCO: Q

Mr. Rothstein, my name is Ray Rasco.

I

represent Frank Preve. I, again, state for the record that we don't

19

feel that this is sufficient time to fully depose you

20

based on the amount of contact between you and Frank

21

Preve by email, 7,000 emails, and the seriousness of the

22

statements you have been making in your testimony

23

regarding Mr. Preve over the past eight days.

24 25

I just want to try and, with the limited time that I have, clarify some of the issues that we

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discussed on Monday when I first spoke with you about

2

Mr. Preve.

3

The first thing that I want to ask is, you

4

said yesterday in your testimony that one of the things

5

that you learned in this massive crime was that you

6

would keep your co-conspirators in the dark as to who

7

the other co-conspirators were.

8

Does that apply to Mr. Preve?

9

A

To a certain extent.

10

Q

Can you explain that a little bit more?

11

A

People on the -- what I'll call "outer

12

circle," people who were doing very specific things,

13

were isolated from other co-conspirators.

14

I'll give you an example.

Frank Preve had a

15

very limited purpose for me.

16

what we were doing; I told him what needed to be done.

17

He did it.

18

I didn't explain to do him

I did not ever sit down with Frank and tell

19

him Deb knows what's going on.

20

Frank and tell him David Boden knows what's going on.

21

That's not the way it worked.

I did not sit down with

Okay.

22

With other people, a guy like Mr. Preve, okay,

23

there was need for him to know about certain people; but

24

there was also need, because I knew he was also having

25

conversations with other people and I didn't now -- you

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know, it's not like I knew this man for two decade,

2

okay, I tried to limit, as best as I could, given all

3

the vagaries of a crime of this size, people's knowledge

4

to what they needed to know.

5 6 7

Q

I didn't always succeed.

Well, would that apply to Mr. Preve?

You

tried to limit his knowledge; is that fair to say? A

On certain issues, yes; and the unique thing

8

about Mr. Preve is, is his knowledge grew over time.

9

You can tell by his emails.

If read his email traffic,

10

you know it's clear that there was a point in time where

11

he really didn't know what was going on; and there's a

12

point in time where he is clearly committing fraud after

13

fraud after fraud.

14

Q

And that's based on some of the indicators

15

that you discussed with me on Monday, from his email

16

traffic, as well as certain conversations, for example,

17

that you had with Frank Preve?

18

A

You'd have to be more specific with me.

19

can't remember every word I said on Monday.

20

sit and read the transcript.

21

Q

Okay.

I

I'd have to

Well, let me ask you this, then:

The

22

point at which he began to commit fraud, in your words

23

just this morning, when was that?

24 25

A

You'd have to lay all the email traffic out in

front of me, and I would be able to give you an estimate

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of the date.

2

Q

3

Would it go back to December of 2008 or would

it be later, if you recall?

4

A

By December of 2008, he was involved.

5

Q

By December of 2008 he was involved in what

A

I don't recall.

6 7 8 9

way? Again, I'd have to see all

the email traffic. Q

Okay.

What was his role?

You said yesterday

10

that you tried to limit each co-conspirator's role in

11

the crime; can you explain what you limited Frank's role

12

to be?

13

A

I'll have to look at all the email traffic.

14

Q

Okay.

15

A

He was in command of a major feeder fund.

16

Q

Okay.

17 18

Okay.

Was he aware of any other

co-conspirators? A

19

To a limited extent, yes. Would you like me to explain?

20

Q

Yes, please.

21

A

Okay.

22

an example.

23

Okay.

Let's use -- let's use Jack Simony, as

Jack's involvement was simply, whether

24

he knew there was a fraud going on or not, to lie to our

25

upcoming investor.

Frank knew we needed Jack to lie.

I

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knew we needed Jack to lie, and Jack knew he had to lie.

2

That's all Jack, to my knowledge, knew.

3

other conversations with Frank about what was really

4

going on; I don't know.

5

He may have had

That's what he was limited to.

If you read emails about -- between me and

6

Frank about John Harris, you'll see there are multiple

7

emails from Frank telling me to get control of John,

8

that he was creating problems.

9

So Frank knew that John was doing things for

10

me that were illegal.

11

of it, I didn't get into it anymore than I needed to.

12

We had discussed it.

The extent

The auditor, Tracy Weintraub, is probably one

13

of the best examples.

14

pocket.

15

balance-sheet audit statements for me, instructed me to

16

scribble on them to make them look like they were

17

real -- and this is all documented in email, okay -- and

18

then to forward them to Tracy.

Frank knew that Tracy was in my

Frank, knowing that, prepared phony

19

There were other times when Tracy sent in

20

questions.

21

we can't answer these questions, that I needed to rein

22

Tracy in, that I needed to get control of him.

23 24 25

Frank would tell me, in email traffic, that

Those are examples of control of certain people, control of the flow of information. Q

Well, just going to John Harris, I don't

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recall seeing any emails with respect to Mr. Preve

2

asking to you rein John Harris in; but I do recall the

3

email that we discussed on Monday, which is the email

4

where he discussed where there was a $20-million trust

5

balance in -- for Banyan at Gibraltar Bank.

6

Do you recall that discussion?

7 8

A

Who indicated there was a $20-million trust

balance?

9

Q

Mr. Preve emailed John Harris stating --

10

asking for a line of credit requests, enclosing

11

documents, and saying that this was based on a

12

$21-million trust account that they had, trust account,

13

or trust proceeds that they had at Gibraltar that --

14 15

A off.

I recall something -- I didn't mean to cut you Sorry.

16

Q

-- that they were seeking a line of credit?

17

A

I remember them seeking a line of credit.

I

18

remember there being an issue about the trust balance.

19

I remember Frank being aware, through Mr. Harris, that

20

the money was not there.

21

I don't recall the other specifics of it.

22

You'd have to show me the email traffic around that

23

event.

24

Q

25

Do you recall emailing Mr. Preve and asking

him not to further seek a line of credit at Gibraltar

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because John Harris was asking you for settlement

2

documentation?

3

A

It's certainly possible.

I don't have a

4

specific recollection of it, but it sounds like

5

something I would do.

6

Q

Okay.

Moving to Tracy Weintraub, there is the

7

packet of emails that I just handed Mr. Nurik.

8

one that's dated January 15th, 2009, 11:05 a.m., and

9

it's Bate number FP 112310-0143388/1.

10

There is

Your email to him -- it begins with your email

11

to him stating:

12

banking data from me, re: Banyan, for your audit.

13

cannot give him anything from my records, nada, zero,

14

zippo.

15

and audited financials, other than causing a massive

16

explosion that might -- et cetera, et cetera.

17 18

Why is Tracy Weintraub asking for I

My law firm's records have nothing to do Banyan

And that is -A

That's not bad.

It says "burn my wee-wee."

19

It's -- actually, it's not only funny, but it's also

20

clear that Frank and I know that:

21

as little information floating around as possible

22

because the more information that floats, the more

23

information that is passed between parties, the more

24

likely we will have a detection.

25

Q

Okay, we want to have

If Frank knew that, then why does he have over

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7,000 emails between you and him?

2

that, there is -- he is --

3

A

I mean, if Frank knew

Well, I understand what you're asking me.

4

MR. SCHERER:

Object to form.

5

THE WITNESS:

I'm sorry?

6

MR. SCHERER:

I just put an objection to

7

form.

8

A

9

You really have to ask your client, because if

you recall my earlier testimony over the last eight

10

days, I was amazed at the level of inculpatory things

11

that Frank would write to me on a regular basis, I mean,

12

right down to the end where he said to me, if he doesn't

13

hear from me, we're going to assume we're on our own.

14

Do you expect us to just sit around and wait to be

15

incarcerated, talking about money missing, talking about

16

the fact that he's given me $25 million without any

17

paper; I mean, one illegal activity after another.

18 19 20

You are going to have to ask him why there is so much email traffic. Q

Well, I mean, why would he put so much into

21

email and seek so much information from you and seek so

22

much information from third parties, if he was in on the

23

fraud?

24

A

25

You would have to ask him that question; I

would be guessing.

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Q

And if he knew how much money you were making

2

and if he was in on the fraud, why didn't he make so

3

much money?

4

results that you had?

5

A

Why didn't he have the same financial

6

I was always -MR. SCHERER:

7

A

Object to form.

I was under the impression, and this just my

8

opinion, that he was making plenty of money.

9

BY MR. RASCO:

10 11 12

Q

Making plenty of money through Banyan, you

mean? A

Him, George, other deals, yes, he seemed, to

13

me, to be very well financially situated, and he

14

benefited from our crime.

15

Q

Okay.

Going back to the email that we were

16

just discussing about Tracy Weintraub, the -- Frank

17

responds to that email to January 15th, 2009, at

18

11:00 a.m.:

19

you to confirm our outstanding receivables, just like

20

last year.

The only thing he should be asking is for

21

A

Yes.

22

Q

And is that what you did?

23

A

Do you want me to explain that?

24

Q

Yes, I would like you to explain that, please.

25

A

Okay.

The year before, Berenfeld Spritzer,

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through Tracy, tried to get a real significant amount of

2

detailed data from us.

3 4

Frank knew and I knew that that was a big no-no.

5

I went ahead and met with Tracy, explained to

6

him what I needed to explain to him relative to the fact

7

that we're not turning over these documents; that if he

8

wants to be in this game, he needs to go ahead and

9

simply do as little as possible, okay, and get what we

10

needed out; that if he couldn't do the Banyan audit, we

11

would find someone else to do it.

12

He agreed to do it.

So when Frank is here saying, "just like last

13

year," okay, he's telling me:

14

to the deal we established previously, which is a simple

15

confirmation, in letter form, just like last year.

16

That's it, nothing more.

17

Q

Tracy should be adhering

And was that a conversation that you had only

18

with Tracy or that you later indicated to Frank that you

19

had that conversation with Tracy or entered into that

20

deal with Tracy?

21 22

A

I had conversations with both Frank and Tracy

about it.

23

Q

Separately?

24

A

Never together.

25

Q

And you indicated that if he did not -- if he

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sought too much information, he was not going to have

2

the job next year; is that accurate?

3

A

I told him that on more than one occasion: my

4

law firm's business, personal business and the Banyan

5

business, yes.

6 7

Q

Okay.

And are you suggesting that Frank at

any time submitted false financials to Tracy?

8

A

He did.

9

Q

Can you explain that?

10

A

You'd have to show me all the records.

11

Q

Are you saying that they audited -- the -- any

12

of Frank's financial information that he sent to Tracy,

13

some of that was fraudulent?

14

A

To my knowledge, yes.

15

Q

With Frank's awareness?

16

A

To my knowledge, yes.

17

Q

And what do you base that knowledge on?

18

A

You'd have to show me all the financial data,

19

and I could show it to you.

20

I can give you a good example:

21

wasn't money in a lot of those accounts, and he was

22

saying that the money existed, and he wanted Tracy to

23

say the money existed.

24

exist because he was my accountant.

25

Q

He knew there

Tracy knew the money didn't

He knew in January of 2009 there wasn't money

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in the trust accounts?

2

A

Certain accounts, correct.

3

Q

Based on those emails that we discussed on

4

Monday where there were certain mistakes?

5

A

Emails and many conversations with him.

6

Q

Okay.

If you turn further, there's another

7

email on that subject that I handed you, or to

8

Mr. Nurik.

9

"Level 3 verification."

10

It's dated January 26, 2009, the subject is

It's an emailed, on the bottom, from Michael

11

Szafranski to Ari Glass, indicating that he had met with

12

you, and then indicating that trust account 5104

13

contained $178,857.

14 15

Frank responds to that email saying, Mike, is it 187,000, or 17,000,800 or 178 million.

16 17

Do you see that? A

18

I do. MR. RABIN:

If I could just ask, for the

19

record, are you making these exhibits part of

20

the record and identifying --

21

MR. RASCO:

Yes.

I'm sorry.

22

be -- we had one just now.

23

at?

This will

What number are we

24

MR. RABIN:

The next exhibit is 272.

25

MR. RASCO:

Thanks.

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(Thereupon, the document was marked as Preve's Exhibit 272 for Identification.)

3 4

MR. SCHLESIGNER:

Sam, just read it out

so everybody knows.

5

MR. RABIN:

All right.

272 is an email

6

from Preve to Rothstein dated January 15th,

7

2009, at 11:05 a.m.

8 9

BY MR. RASCO: Q

You see the response from Mr. Szafranski

10

stating, I'm sorry, the numbers aren't thousands of

11

dollars, indicating that the proper balance is

12

178 million?

13

A

And this will be Exhibit 273.

14

Q

Yes.

15

A

Okay.

I do see that, yes, sir.

16

Q

Okay.

And are you indicating -- are you

17

saying that that was an indicator that Mr. Preve

18

believed that the money was not in the trust accounts?

19

A

Without seeing email traffic on either side of

20

this, I can't tell you for certain.

21

Mike wrote that.

22 23 24 25

I don't know if

On occasion Mike would write dollars in thousands, dollars in millions. At this point in time, in January 26, 2009, I don't know what Frank was thinking by reading that.

I

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would really have to see the email traffic going before

2

that; and for some reason, the email traffic that would

3

have been directed to me right around this time is not

4

here.

5

So without that, I really can't tell you. Q

Okay.

But you agree that Frank's financial

6

statements, to the extent that he produced financial

7

statements to you, were accurate, generally?

8

A

I can't say one way or the other.

9

Q

Did you rely on him for accurate financial

10

information?

11

A

No.

I relied on him to tell me what we were

12

supposed to have in the accounts, minimum.

13

he sends me a lot of emails, in fact you handed me one,

14

where he's telling me what the minimum balance is.

15

There is no investment that I've ever heard of -- maybe

16

you have and you can tell me what it was -- where the

17

investor tells the person handling all the money how

18

much money he should have.

19

You'll see

Generally you ask me what the balance is.

20

tell what the balance is, and if I'm wrong, you pull

21

your investment.

22

Q

I

That's not how we worked.

If there are occasions where the trust

23

balances were not reflecting what Mr. Preve thought they

24

were -- well, first of all, he was telling you what he

25

thought they were based on the deals that you were

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entering into the bank, correct? A

Based on the amount of money he was sending

3

me -- you have got to remember, there came a long period

4

of time where there really was no deal paperwork at all;

5

he was simply relying on that little deal blurb and how

6

much money he was sending me and how much, based upon

7

that little blurb, I was sending him back.

8

a lot of confusion.

9

So there was

There was also confusion because he would

10

regularly send me money.

11

then he would send me half back.

12

just tell me where you apply.

13

and say, tell me what old deals we're going to apply

14

this to or should I have -- great example:

15

have Centurion fund this again, or is that just going to

16

create too much of a headache trying to reverify the

17

plaintiff receiving the money?

I would send him payments, and Then he would say,

Then he would come back

Should I

18

Q

Are you referring to a specific email there?

19

A

No, not -- that email is in the prior

20 21 22

emails -Q

Okay.

Not in the ones that I handed you this

morning?

23

A

No, I didn't see it here.

24

Q

Okay.

25

Didn't you indicate to Mr. Preve

that -- well, first of all, he was accounting for, on

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his end, what he thought the deals were that Banyan had

2

entered into, whether they were funding them

3

specifically or somebody else was funding them?

4

A

You'd have to ask him what he was doing.

5

would send me what he thought needed to be in the

6

accounts, and I would instruct Irene to correct it.

7

On many occasions he would actually write

He

8

directly to Irene and say these balances are off, fix

9

it.

10

Q

If there were instances where there were

11

balances that were less than the minimum requirement, do

12

you recall if you indicated to Mr. Preve that that was

13

as a result of you not having -- that was as a result of

14

you putting the money in the wrong Banyan trust account?

15

A

I did that once or twice.

16

Q

And if the balances sometimes weren't

I remember that.

17

accurate, did you indicate to Mr. Preve that could be

18

because you had not paid experts or you had not taken

19

your attorney's fees out?

20

A

On certain occasions I did.

You have to look

21

at the timing.

22

look at the timing, and then look at the emails around

23

it to determine the full extent of Mr. Preve's knowledge

24

at the time because at a point in time when he's fully

25

aware of what's going on.

You have to look at specific emails,

There's a lot of Ponzi-speak

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there.

2

We are talking about "transferring money," for

3

example.

4

changing balances.

5

We're not transferring money; we're just Okay.

We talk about me "putting money someplace."

6

"Putting money someplace," is simply putting the number

7

someplace.

8

Q

I understand.

9

The email that I just showed you regarding the

10

178 million, you testified on Monday about an email that

11

indicated that there was a mistake of a billion dollars

12

or about a billion dollars; do you recall that email?

13

A

I recall those emails.

14

Q

This is not that email, correct?

15

A

No.

16

Q

The second email in the packet that I just

17

gave you is dated November 18th, 2008, 11:06 a.m.

18

from -- the bottom is from Frank to you, and it's

19

subject matter is "stuff."

20

A

Okay.

21

Q

The third point on that email, it states:

It's

22 23

Need Commerce balance numbers. And you respond above:

See below.

And you

24

indicate the responses to the question is right after.

25

Do you agree that those responses behind the

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questions are your writing?

2

A

Yes.

3

Q

Okay.

You indicate that you're going to

4

provide him the balances in Commerce Bank when you get

5

back to the office this afternoon?

6

A

Yes, the fake balance numbers, correct.

7

Q

And on number four, it says, do I get to sign

8

in, quote, unquote, online like milk toast does?

9

And you respond:

Nope, I should not be

10

showing him; but if you want to stand over his shoulder

11

while he and I hold hands --

12

COURT REPORTER:

I need you to slow down:

13

"If you want to stand over his shoulder while

14

he and I hold hands...

15 16

BY MR. RASCO: Q

17 18

"-- and sign on, be my guest." Is that your writing there, as well?

A

19

Yes. Would you like me to explain that?

20

Q

Yes, I would.

21

A

Look at the way he writes this:

22 23 24 25

Do I get to

sign, and the word "online" is in quotes. The word "online" is in quotes because he knows we're not going online. What Frank was pushing me to do was have

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Curtis and Bill sets up a fake website for him so that

2

he could use it with investors over at his office.

3

It's my, also, humorous response to him.

4

Q

Well, you're indicating, now, that Frank knew

5

that there was a fake website and that he wanted you to

6

create a fake website for him?

7

A

I'll answer that with a question:

Can you

8

think of any reason why he would put the word "online"

9

in quotes if we were really going online?

10

Q

I'm not sure why he wrote "online" in quotes,

11

but I do know that he was seeking verification of trust

12

balances from you, not just through this email, but

13

through hundreds of emails.

14 15

My question is:

Was he aware that this --

that TD Bank/Commerce Bank website was a fake website?

16

A

Yes.

17

Q

How do you know?

18

A

I told him.

19

Q

You told him in a conversation or by email?

20

A

In a conversation.

21

Q

Was anybody else present?

22

A

Never.

23

Q

Do you know if he ever discussed that fact

24 25

with Szafranski? A

I have no idea one way or the other.

I doubt

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it. Q

Okay.

And you're indicating that by --

3

certainly by this time, November of 2008, he would have

4

known that the trust balances either were nonexistent or

5

not -- were certainly inaccurate?

6

A

Yes.

7

Q

And he knew that from this time, through the

8

end of the Ponzi in October of 2009, right?

9

A

Yes.

10

Q

Okay.

And we talked about an email on Monday

11

relating to a $300-million shortage.

12

October 30th or 31st.

13

amount that was in the trust balances.

14

left for Morocco.

15 16 17 18

It was

He was asking you exactly the You had already

Do you recall that discussion? A

I don't.

You'd have to show me the email

traffic. THE WITNESS:

And just -- I don't mean to

19

interrupt you, but just for your own

20

record-keeping and since there is so many days

21

and so many exhibits, you need to mark these.

22

MR. RASCO:

23

in sequential order?

Can we mark them on break and

24

UNKNOWN SPEAKER:

25

THE WITNESS:

Yes.

It's okay with me.

I just

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don't want you to get documents -- because we

2

have a lot of documents floating around here

3

without stickers.

4

MR. LICHTMAN:

Does the record clearly

5

indicate what the document is so it can be

6

matched and there's clarity in the record?

7

MR. RASCO:

I specifically stated the

8

dates in the emails and the subject each time

9

I've asked about them.

10 11

COURT REPORTER:

Are you going to be

marking more documents?

12

MR. RASCO:

13

COURT REPORTER:

Maybe one or two. Okay.

Because if it

14

gets too far afield, that's how exhibits get

15

out of order.

16 17

MR. RASCO:

I'm almost done with the

exhibits.

18

Can you read where I left off?

19

(Whereupon, the requested portion of the

20

record was read back by the court reporter as recorded

21

above.)

22 23 24 25

MR. RASCO:

Okay.

Thank you.

BY MR. RASCO: Q

And there was an email -- and I'm not going to

go into it now, but I marked it as an exhibit in the

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composite exhibit binder that I handed you on Monday --

2

stating that Frank was asking you, you know, what's

3

the -- what's the amount -- he had asked you to

4

authorize Debra to give him an account balances.

5

You said you already did.

6

And then you asked -- and then he said, she

7

has, it she doesn't have the authority.

8 9

He then asked you, what's the shortage, is it 300 million, something to that effect.

10 11

And you said, that's not the shortage. the amount of money to repay the investors.

12

Do you recall that?

13

A

I do.

14

Q

Okay.

15 16 17 18

That's

My question:

referring to as the shortage? A

Do you have an idea?

Without seeing the email, I don't want to

render a guess. Q

What do you think he's

Okay.

I would be completely guessing. Do you think it might be shortage in

19

funding; in other words, funding from sources like the

20

Von Allmen Group or the hedge funds?

21

A

No.

I think the shortage -- and I'm

22

speculating, but I think the shortage he's referring to

23

is, is how much money do we need to put into the trust

24

accounts so that we could pay out everything we were

25

supposed to pay out, had this all been real.

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Q

Did you often indicate --

2

A

But I'm guessing.

3

Q

Okay.

4

MR. NURIK:

5

Excuse me, Counsel.

If you

have it there, why don't you show it to him?

6

MR. RASCO:

7

but give me a second.

8

on this.

9

BY MR. RASCO:

10

Q

I -- I'm happy to show it, I'm going from memory

I'm sorry, I have don't have it in front of

11

me.

12

asking you, specifically:

13

"shortage" in the past, during the Bar issue, indicating

14

that the hedge funds weren't funding at the same levels

15

that they were before?

16

I don't want to take anymore time, but I'm just

A

If you had used the word

I actually -- and I would have to see the

17

email traffic; but I actually don't recall using the

18

word "shortage" to describe money that hadn't been

19

funded by the hedge funds.

20

"they haven't funded."

21

shortage in funding.

Normally I would just say

I wouldn't say there's a

22

"Shortage," the way Frank is writing it to me

23

is: what is the shortage in the accounts, how much have

24

you stolen, what's missing.

25

But, again, I'm just guessing.

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Q

Okay.

You used, on various occasions, with

2

Frank and other parties, starting with the April 2009

3

Bar issue, the fact that the hedge funds weren't funding

4

at previous levels --

5

A

Correct.

6

Q

-- you used that as an excuse to not pay out

7

to Banyan or to other investors; is that fair?

8

A

Correct.

9

Q

Okay.

10

Allmen group and Barry Bekkedam's group?

11 12

A

Q

14

You'd have to show me

Okay.

I will show you this email.

This is the Composite Exhibit 206, which I marked on Monday.

16 17

I don't recall that.

that email traffic.

13

15

And you used that again with the Von

A

All right.

Are you talking about the

October 31st, 2009, email --

18

Q

Yes.

19

A

-- from me to George?

20

Q

Correct, from you to George.

21

A

Yes.

22

Q

We have.

23 24 25

We have talked about this extensively. I have a few more questions about

it. You indicated that email was a false exculpation of Frank, not of George, right?

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A

Well, I've testified over and over that I'm

2

not sure what George knew.

3

don't know what he knew.

As I sit here today, I still So --

4

Q

Well, you did indicate.

5

A

Hang on.

6

It would clearly be an exculpation of Frank --

7

Q

It --

8

A

-- and George, if he needed it.

9

Q

Okay.

It would clearly be a false

10

exculpation?

11

A

Yes, a false exculpation.

12

Q

Okay.

You testified on Monday the latter part

13

of the time about being a liar, thief and scum bag; that

14

was true, in your mind at the time?

15

A

Yes.

16

Q

Okay.

And the part about you either going to

17

jail or dying, that was true or accurate in your mind at

18

the time, as well, right?

19

A

Yes.

20

Q

Okay.

And the -- that email was written, if

21

you recall, in response to an email or various emails

22

from George Levin trying to, quote, unquote, bail you

23

out, trying to help you resolve the issues that you were

24

in, without him fully understanding what was going on?

25

A

In part, yes.

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Q

And so the part about him asking you -- about

2

you telling him, don't try to bail me out of this, that

3

was accurate in your mind, as well, wasn't it?

4

already knew that it would be impossible for him to bail

5

you?

6 7

A

I don't how what was possible or not possible.

You'd have to define "bail" me out.

8 9

You

If he could get access to a lot of money, he could bail out the financial part; but he certainly

10

wasn't going to bail me out of the fact that I had

11

committed a giant crime.

12

Q

So the only part of that email that is untrue

13

is the part about the exculpation; you and George did

14

nothing wrong?

15

A

The only part in here that I know for certain

16

that is false is:

17

false.

18 19 20

Frank did nothing wrong.

That is

It is all together possible that to a great extent, George did, in fact, do nothing wrong. Q

You've testified that this was the first time

21

in your life that -- or at least the several past years,

22

that you were coming clean, that you were being honest

23

with yourself; is that fair, in this time period?

24 25

A

At this moment?

I don't think at this moment

I was coming clean with myself.

I think I was trying

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to.

2

Until I made the decision to step foot on a

3

plane and leave a non-extradition country, knowing that

4

I was coming back to go to prison, I don't think until I

5

made that ultimate decision that I had fully reconciled

6

with myself that it was time to completely change the

7

person that I am, to change my life and to do the right

8

thing.

9

Q

10 11

And this was the only email that you recall

that you were falsely exculpating Frank; is that right? A

I don't recall.

You'd have to show me the

12

email traffic.

13

see the traffic to tell you one way or the other.

14 15 16

Q

I have sent so many emails, I need to

Did you -- do you recall falsely exculpating

anybody else? A

We looked at emails the other day.

I don't

17

want to speculate when we have definitive email traffic

18

to establish one way or the other.

19

see the emails and answer based upon emails, instead of

20

guessing.

21 22 23 24 25

Q

So I would like to

Just your independent recollection, anybody

else that you were trying to falsely exonerate? A

I don't recall.

I believe there were, but the

names are escaping me right at this moment. Q

Okay.

And to your recollection now, as you

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sit here, was there anything else that you may have done

2

to falsely exculpate Frank or anybody else?

3

A

Oh, wait.

5

Q

Was that through email?

6

A

I'm -- yes, I think there was -- there was an

7

email.

8

Q

Okay.

9

A

I think -- again, it makes no sense to me to

4

I tried -- I falsely exculpated

Stu.

10

try to have me guess when we have email traffic that

11

establishes definitively one way or the other.

12

Q

I'm only asking you because I haven't seen any

13

email traffic that establishes you sending any other

14

emails that would falsely exculpate anybody else.

15

A

On, no, I did.

16

Q

Okay.

And in doing so, when you did do so, do

17

you recall if it was a simple statement like this one

18

with respect to Frank, or was it more detailed?

19

A

I would be guessing.

20

Q

Okay.

And you were aware, by that time, that

21

there were thousands of emails between you and Mr. Preve

22

that indicated that he may have known something was

23

amiss?

24

A

You're asking me my opinion?

25

Q

Yes.

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A

At that point in time I believed that there

2

were thousands of emails proving clearly that Frank was

3

involved in a major fraud.

4 5 6

Q

Then why would you think that such a simple

statement would be any help to Frank? A

Fortunately for you, you've never had to be in

7

a situation where your mind is as mine was.

8

multi-billion-dollar Ponzi scheme is collapsing around

9

you,you're picturing destroying your family and all the

When a

10

people that you love.

11

dying in prison.

12

stress that your body goes through at the time is not

13

something that I can describe in words.

And coming back to potentially

The emotional and actually physical

14

Why I was doing exactly what I was doing in

15

those final days, I would have to sit and really read

16

all these emails again, carefully.

17

something good --

I was trying to do

18

Q

Okay.

19

A

-- that I perceived as good.

20

The truth is, now, as I sit here today, after

21

having made the decision to come clean and admit

22

everything I've done wrong, I don't think that trying to

23

falsely exculpate those people was the right thing.

24

What I should have done was picked up the

25

phone called them, called Mr. Preve and the others that

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I knew was involved and said, I'm doing the right thing.

2

You need to do the right thing.

3

Let's tell everybody what we did.

4

thing.

5 6

Turn yourself in. Let's do the right

That's what I should have done. Q

Do you remember that both Frank and George

7

were calling you and texting you or emailing you

8

repeatedly?

9

A

Yes.

10

Q

And you indicated on Monday that you did not

11

Yes.

want to speak with them?

12

A

Correct.

13

Q

And why was it that you didn't want to speak

14 15

with them? A

I was very emotionally attached to them.

I

16

was very emotional at the time, okay, and I did not want

17

to speak to them.

18

myself to do it.

19

was away.

20 21

Q

I -- I just -- I couldn't bring I spoke to very limited people while I

Are you suggesting that Frank in any way

created fake documents in the Ponzi scheme?

22

A

Yes.

23

Q

Can you explain that?

24

A

You'd have to show me the documents.

25

I could

tell you then whether they were fake or not.

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Q

Can you give me a time frame?

2

A

From -- I would be guessing.

3 4 5 6

Throughout 2009

we created false documents together. Q

You actually sat with Mr. Preve to create

false documents together? A

No.

He created fake things and sent them to

7

me, and I created fake things and sent them to him.

8

Sometimes we were on the phone together.

9

Q

Do you mean agreements or trust balances?

10

A

Trust balances is a good example, but to me

11

that's not creating it, you know.

12

define the word "created" for me.

13

Again, you'd have to

If I create the document through Debra or

14

Irene and then I send it to him and he doesn't like the

15

balances and he wants me to change them to a different,

16

false number, by your definition, is that him creating

17

the document?

18

He's giving me false input to help me create

19

the false document, which is what he did; but you've got

20

to be more precise with me.

21

Q

Okay.

Well, just to be specific, are you

22

talking about only deal documents here?

23

talking about anything outside of the deals that you

24

were entering into with Banyan?

25

A

Well, sure.

We're not

Sure I am, because Frank helped

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me create, at length, fake opinion letters that I then

2

had other lawyers put on their letterhead.

3

knew nothing, like Ken Padowitz knew nothing about this

4

type of law, knows nothing about this type of business;

5

he is a criminal defense lawyer.

6

letter that we put together -- me, Boden, Preve.

7

People who

He took a fake opinion

We put all this crazy stuff in there, okay,

8

that we needed to perpetrate this scheme and to keep it

9

going and to get people to invest more dollars in the

10

fraud.

11

And then, he knows -- he knows Ken Padowitz is

12

a criminal defense lawyer.

13

Padowitz put it on his letterhead, have Padowitz sign it

14

and then we take it and I give it to Frank.

15

starts handing it out, and I handed it out.

16

Q

I put this thing on -- had

And Frank

So Frank handed it out, but in addition to

17

handing it out, you're saying he actually helped you

18

create that document?

19

A

Absolutely.

20

Q

How did he do so?

21

A

He gave me language that went in there.

Yes.

I --

22

I wasn't an expert in those areas.

23

knew banking, people who knew that area of the corporate

24

finance, helping me prepare that letter.

25

Q

I had people who

What was the letter opining on?

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A

You'd have to show me the letter.

2

It was on the legal nature of the settlement

3

structure.

4

documents, which he hadn't.

5

letter.

6

letter, including Mr. Preve, had never reviewed anything

7

in order to come to the, quote, unquote, legal

8

conclusions that the strategy was legal.

It was that he had reviewed all these It was a fake opinion

All of the people that gave input into that

9

Q

Did he provide input verbally or in writing?

10

A

I don't recall whether he did some in writing.

11

You'd have to take a look through the email traffic, but

12

definitely verbally and definitely on paper in some

13

format.

14 15 16

Q

Whether it was handwritten or by email or on

the document itself, you're not clear? A

There were times when Frank and I would sit

17

down and scribble on documents that we had, notes, that

18

type of thing.

19

We were sitting together.

If I was sitting in the office and we were

20

doing something nefarious, I don't think he needed to

21

send me an email to confirm what we just discussed.

22

could do it on paper there; but, again, I would need to

23

see the documents.

24 25

Q

We

Any other documents, outside of just the

settlement funding, that Frank would have been involved

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in falsely creating?

2

A

I just said the opinion letters.

3

Q

Just the opinion, I'm asking beyond the

4 5 6

opinion letters. A

I have to see all the documents, and then I

could tell you one by one whether he had input into it.

7

Q

Were you aware that Banyan --

8

A

Wait a second.

9

He helped put -- with Tracy, he helped put

10

together that audit letter.

11

the contents of the audit letter.

12

if you look at the email traffic, one of the things that

13

is completely off the charts with regard to a, quote,

14

unquote, independent audit of books and records, is that

15

Tracy, pursuant to my request, forwarded a copy --

16

provided a copy of the audit letter to Frank Preve for

17

his comments before completing it, which is a big no-no

18

as I understand it in the financial audit world.

19 20 21

Q

He had direct input into As a matter of fact,

But what did Frank do that was wrong, as far

as providing Tracy comments? A

He had added false information, corrected

22

information that would have led potential investors to

23

believe that there was a fraud, cleaned it up so that we

24

wouldn't get in trouble and gave it back to Tracy.

25

Tracy then corrected the document and put it in final

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form. Q

Can you point to specifically anything that he

added that was false?

4

A

Sure.

5

Q

I don't have it with me today.

6

Show me the letter. I'll save that

for another day.

7

Are you aware that Banyan was obtaining

8

opinion letters from legal -- from their own legal

9

counsel?

10

A

Sure.

I helped them formulate certain

11

information that they provided that was false to

12

Greenspoon Marder so that they could get them to write

13

an opinion letter.

14 15 16

Q

And you're aware they also obtained opinion

letters from Hutchinson Steffen? A

I remember at least one or two other firms

17

that they went to, but you have got to remember

18

something:

19

starters, contain nothing about the payment

20

irregularities that were going on.

21

Look at those opinion letters.

They, for

So just from that small spot of illegality,

22

okay, he was providing false information, because there

23

was all kinds of problems with trust balances not being

24

right and payments being missed and payments being late

25

and documents not being prepared; and then we get these

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audit letters and opinion letters saying everything is

2

just hunky-dory, everything is beautiful, there is no

3

problems, everything is paid on time, everything is

4

properly papered.

5

information.

6

Q

That's all based upon false

You indicated that -- on Monday that one of

7

the indicators that you knew Frank was aware of the

8

fraud was the fact that he was using money from the

9

deals to pay certain bills of Levin's?

10

A

Yes.

11

Q

You're not aware that he was using it for his

12

own purposes, other than that?

13

A

14

doing.

15

money that was supposed to be investor money and paying

16

Levin's personal bills with it.

17

I don't know one way or the other what he was I do not know.

I just know that he was taking

As a matter of fact, I think there is an email

18

that we looked at yesterday where he says he needs $10

19

million out of all the money we have to pay George's

20

personal bills.

21

Q

After 2009, essentially, the hedge funds were

22

cut off and Banyan was cut off getting the payments that

23

they were supposed to receive, at least the scheduled

24

payments they were supposed to receive, right?

25

A

April of '09?

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Q

Yes.

2

A

Yes.

3

Q

And you were indicated that the trust accounts

4

were blocked, right?

5

A

Yes.

6

Q

Did you tell Frank that because that was

7

occurring and because certain bills were due for Banyan

8

and the Levins, that you were going to bring your own

9

money from New York and pay them out of that money?

10

Yes.

I told him I would borrow the money or

11

bring my own money in, which should have been a giant

12

red flag; but money was money to us at that point in

13

time.

14

MR. RASCO:

Okay.

I'm going to reserve

15

some time and take a break, but I'm done for

16

now.

17

MR. SCHLESIGNER:

Can we make sure the

18

record is clear when he mentioned "Frank,"

19

it's not Mr. Spinosa?

20

THE WITNESS:

On, no, it's not

21

Mr. Spinosa.

22

questioning by Mr. Preve's counsel of me,

23

every time I said "Frank," it was Frank Preve.

All the times during the

24

MR. SCHLESIGNER:

25

MR. NURIK:

Thank you.

And also for the record, the

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only exhibit that we have marked is 272.

2

we have no identification for any of those

3

other emails.

So

4

MR. RASCO:

Let me --

5

MR. NURIK:

Excuse me.

6

We don't know what his answers related

7

to.

8 9 10

MR. RASCO:

what the dates and subjects were of each of the emails.

11 12

I can mark them in -- they're all in chronological order.

13 14

(Thereupon, documents were marked as Preve's Exhibits 273 and 274, respectively, for identification.)

15 16 17 18

Well, I specifically stated

DIRECT EXAMINATION BY MS. BARZEE-FLORES: Q

Scott Rothstein, you sure fooled a lot of

people, didn't you?

19

A

Yes.

20

Q

You conned lawyers, right?

21

A

Yes.

22

Q

Greenspoon Marder, correct?

23

A

Well, that con was actually by Mr. Preve, with

24 25

my assistance. Q

Clifford Chance?

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A

Yes.

2

Q

Morgan Lewis?

3

A

Yes.

4

Q

In fact, no firm that did a due diligence

5

investigation of you, discovered what you were up to and

6

advised their clients not to invest in you?

7 8 9

A

I would be guessing as to what they advised

their client. Q

Didn't you say on December 12th, in the

10

afternoon session, that no firm that did due diligence,

11

as far as you knew, discovered what you were up to and

12

advised the client not to invest in you?

13 14 15 16

A

That's the key to your question:

As far as I

knew, yes. Q

You conned innocent lawyers at your firm who

didn't know what you were up to?

17

A

I did.

18

Q

You conned innocent investors, didn't you?

19

A

Some, yes, I did.

20

Q

You conned politicians, as well, right?

21

MR. LAVECCHIO:

You can answer the

22

question without specifics.

23

A

24 25

Yes.

BY MS. BARZEE-FLORES: Q

You fooled Senator John McCain?

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A

Yes.

2

Q

You fooled United States Senator Mel Martinez?

3 4 5 6

MR. LAVECCHIO:

Objection.

BY MS. BARZEE-FLORES: Q

You fooled United States Senator Joe

Lieberman?

7

A

Yes.

8

Q

You fooled Florida Governor Charlie Crist?

9 10 11 12

MR. LAVECCHIO:

Objection.

BY MS. BARZEE-FLORES: Q

You fooled California Governor Arnold

Schwarzenegger?

13

A

Yes.

14

Q

You fooled presidential candidate Sarah Palin?

15

A

Yes.

16

Q

You fooled the president, George W. Bush?

17

A

Yes.

18

Q

You conned the Florida Bar, didn't you?

19

A

No, I never got them involved in anything.

20

utilized the name of the Florida Bar to further my

21

fraud.

22

Q

23 24 25

I

You were on the Florida Bar Grievance

Committee, weren't you? A

Oh, you mean I fooled them into thinking I was

an ethical lawyer?

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Q

Well, tell me:

Were you on the Florida Bar

Grievance Committee?

3

A

I certainly was.

4

Q

And what were you supposed to be doing on that

5

We discussed that.

committee?

6

A

Hearing grievances.

7

Q

And what does that mean for the jury?

8

Explain

what you were supposed to be doing on that committee.

9

A

Judging the ethics of other lawyers.

10

Q

You conned the Broward Judicial Nominating

11

Commission, didn't you?

12 13 14

MR. LAVECCHIO: BY MS. BARZEE-FLORES: Q

15 16 17 18

21 22 23 24 25

Did you corrupt that process, sir? MR. LAVECCHIO:

A

Without specifics.

Yes.

BY MS. BARZEE-FLORES: Q

19 20

Objection.

Did people pay you to get on the bench? MR. LAVECCHIO:

Objection.

BY MS. BARZEE-FLORES: Q

What were you supposed to be doing on that

commission, Scott Rothstein? A

Vetting candidates for the 4th District Court

of Appeal to send to the government. Q

Who appointed you to that position?

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A

The governor, then-governor, Charlie Crist.

2

Q

You conned your own friends, didn't you?

3

A

Yes.

4

Q

You had a close circle of friends that you

5

often socialized with, right?

6

A

Yes, ma'am.

7

Q

Some of them knew you were a criminal?

8

A

Some did, yes, sir -- yes, yes, ma'am.

9

Q

Some of them didn't?

10

A

Some didn't, many didn't.

11

Q

You conned "your own girl Friday," didn't you?

12

A

"Girl Friday," who?

13

Q

How do you describe Debra Villegas?

14

A

One of my closest friends and confidantes.

15

Q

And an employee?

16

A

Yes, ma'am.

17

Q

Who worked right alongside you?

18

A

Yes, ma'am.

19

Q

Who learned that you were a criminal?

20

A

Yes, ma'am.

21

Q

Who participated in your criminal conduct with

23

A

Yes, ma'am.

24

Q

Who you could ask to do just about anything

22

25

you?

and she would, for you?

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A

Yes, ma'am.

2

Q

You conned your own best friend, didn't you?

3

A

To some extent.

4

Q

You convinced Ted Morse that you had

5

Judge Seltzer in your pocket?

6

A

That's true.

7

Q

And by the way, when you conned Ted Morse, you

8

were a conning a con, weren't you?

9 10

ALL PRESENT: A

Object.

If you mean to say that Ted knew I was

11

committing crimes and participated in some of those

12

crimes, that's correct; and that I also conned him as to

13

certain things, that's correct.

14

BY MS. BARZEE-FLORES:

15

Q

16

world?

17

A

18

You conned the people closest to you in the

That's true.

I hurt a lot of very innocent,

good, decent people.

19

Q

You conned your own mother?

20

A

I certainly did.

21

I hurt my family terribly.

22

Q

She worked at the firm with you, didn't she?

23

A

Yes, from time to time my mom worked there.

24 25

My dad worked there, my sister. Q

And she had no idea what her son had become?

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A

No, she didn't.

2

Q

You conned your wife?

3

A

I certainly did.

Q

You did the things you did and then crawled

4

lot.

5 6

I hurt a very good person a

into bed with that woman?

7

A

That's correct.

8

Q

At your sentencing you tried to con the judge,

9

didn't you?

10

A

Absolutely not.

11

Q

Sir, you wrote him a 12-page letter,

12

typewritten, right?

13 14

A

it, yes, ma'am.

15 16

I hand wrote it and then someone else typed

Q

It started off talking about the tough

financial times you had growing up, right?

17

A

You have to show me the letter, ma'am.

I know

18

that I talked about difficult financial times, that kind

19

of thing, yes, ma'am.

20 21

Q

you were for all of your crimes?

22 23 24 25

It ended talking about how, very, very sorry

A

Yes, ma'am.

I am.

That's why I turned myself

Q

That letter didn't work, did it,

in.

Mr. Rothstein?

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A

It wasn't meant to work.

It was meant to be

2

an honest appraisal of myself and my criminality to the

3

judge.

4

Q

5

What sentence did your lawyer ask the judge to

impose on you, sir?

6

A

Forty years.

7

Q

What sentence --

8

A

I'm sorry, no, that was the government asked

9

for 40 years; my lawyer asked for 30.

10

Q

And what sentence did the judge impose on you?

11

A

Fifty years.

12

Q

You're good at the con, aren't you?

13

A

I was, yes.

14

Q

You're not anymore?

15

A

No, ma'am.

16

Q

Why don't we let the jury be the judge of

17

that.

18 19 20 21

ALL PRESENT:

Object to form.

BY MS. BARZEE-FLORES: Q

Let's talk about the psychological tools that

you used to fool people, to con them.

22

First, you're a good salesman, right?

23

A

I was.

24

Q

You know how to get a sense from people before

25

you do business with them?

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A

2

yes, ma'am.

3

Q

4

That is one of the tools I used to operate,

Some people you wouldn't do business with

because you sensed you couldn't trust them?

5

A

That's correct.

6

Q

You know how to create a perception of power?

7

A

That's correct.

8

Q

And you know that the perception of power

9

yields actual power?

10

A

It does.

11

Q

You know how to convince people that you're

12

legit, right?

13

A

That's one of the tools I used, yes, ma'am.

14

Q

You convinced people that you were legitimate

15 16

by associating with politicians, right? A

I convinced people that I was legitimate by

17

associating with certain legitimate politicians and by

18

corrupting and engaging in corruption with some corrupt

19

politicians.

20

Q

21 22

You knew how to convince people that you were

legit by associating with law enforcement? A

I utilized law enforcement to convince people

23

I was legitimate both by associating with legitimate law

24

enforcement and by engaging in corruption with corrupt

25

law enforcement.

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Q

You knew how to convince people you were

legitimate by associating with judges? A

I convinced people I was legitimate by

4

associating with good and decent legitimate members of

5

the judiciary, and I convinced people I was legitimate

6

by engaging in corruption with corrupt members of the

7

judiciary.

8 9

Q

You knew it was crucial to the success of your

criminal scheme to keep an air of legitimacy around you?

10

A

Yes, ma'am.

11

Q

And you worked hard to make people feel secure

12

in their relationship with you, right?

13

A

Yes, ma'am.

14

Q

You used the trappings of wealth to give

15

people the impression of your success?

16

A

I did.

17

Q

And you worked to convince people that there

18

would be real returns, real returns on their

19

investments?

20

A

Certain people, yes, ma'am.

21

Q

You made large and very public donations to

22

worthy causes, right?

23

A

I did.

24

Q

And you pretended to be devout in your

25

religion?

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A

I am not going to justify that comment with a

response.

3

Q

In 2000 --

4

A

I was -- excuse me.

5

Q

Go ahead.

6

A

Excuse me.

Excuse me.

MR. NURIK:

Hold on.

7

We're not going it

8

to allow any questions concerning his

9

religious beliefs, period.

10 11 12 13 14

BY MS. BARZEE-FLORES: Q

You made public statements regarding your

religiosity, haven't you? A

My religion has nothing to do with the fact

that I was a very bad person.

15

Q

You manipulated people, didn't you?

16

A

I did.

17

Q

You're good at manipulating them, aren't you?

18

A

I was.

19

Q

You were?

20

A

Yes.

21 22

25

When

you tell the truth, it's very, very simple. Q

23 24

I don't need to do that anymore.

You're the tiger who changed his stripes? ALL PRESENT:

A

Objection to form.

If you're asking me if I am a good example of

a changed person and how much you can change, the answer

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is absolutely yes.

2

BY MS. BARZEE-FLORES:

3 4 5

Q

On a scale of one to ten, you're a ten at

manipulating people? A

6

I was. I have no need manipulate anyone anymore.

7

When you're telling the truth, you don't need to worry

8

about manipulating people.

9

Q

You've said that you can spend time with

10

someone and get a feel for what they might be

11

susceptible to?

12

A

13

yes, ma'am.

14

Q

15 16 17

That's something that I was capable of doing,

And that you could spend time with someone and

get a feel for how malleable a person he or she is? A

That was something I was capable of doing as

well, yes, ma'am.

18

Q

You're not capable of getting that sense now?

19

A

No, I'm not.

20

Q

That --

21

A

I don't care.

22

Q

You lost your sense to -- to see if somebody

23 24 25

is susceptible to BS? A

No.

I shut it down.

I decided it was no

longer something that I wanted to be.

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Do you not believe that people can change?

2

Q

You are able to turn off like a switch your

3

ability to determine after meeting with a person how

4

malleable they are?

5

A

I have no need to do it anymore.

When you're

6

telling the truth, you don't need to do any of those

7

things.

8

Q

If you had a need, could you do it, sir?

9

A

My body, my psyche, my mind, my beliefs would

10

never allow me to do that again.

11

came back and turned myself in knowing I was going to

12

prison.

13

Q

14

16

A

That's why I

That's your pitch? ALL PRESENT:

15

Ever.

Objection.

Form.

That's the truth.

BY MS. BARZEE-FLORES:

17

Q

During the days of your con, when people

18

questioned you about these deals, you would give them

19

whatever information you thought you needed to give

20

them?

21 22

A

Depending upon whether they were involved in

the crime or not.

23

Q

All right.

24

A

Sometimes I lied to them and sometimes I told

25

them the truth.

Sometimes you lied to them?

It just depended upon whether they were

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involved in the crime or not.

2

Q

Sometimes you told them half-truths?

3

A

It's the same answer.

4

level involvement they had in the crime.

5

Q

6

as possible?

7

A

8

Depending upon what

To some people, you gave as little information

Depending upon their level of involvement in

the crime.

9

Q

And to other folks, you exaggerated?

10

A

Again, it's the same answer.

11

the level of the individual's involvement in the fraud.

12 13

It depended upon

Q

Sometimes you played the attorney-client

confidentiality card?

14

A

Yes, my co-conspirators and I used that

15

regularly to create a transparency block during the

16

course of the fraud.

17 18

Q

And you played the confidential settlement

card?

19

A

The same answer.

20

Q

Meaning yes?

21

A

No.

Meaning that my co-conspirators and I

22

used the confidentiality -- all of those things to

23

create a transparency block so people would not be able

24

to detect the fact that we were committing a crime.

25

Q

Sometimes when you were pressed, you played

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offense in defense, right?

2

A

I'm sorry.

3

Q

Well, for example, when Ed and Carol Morse

I don't understand your question.

4

would start pressing you and asking too many questions,

5

wasn't it the case that you would respond with what you

6

testified on December 12th was, quote/unquote, the

7

standard, where you rant about:

8

embarrassed me, I'm making you money, I've done

9

everything right.

10

A

11

How dare you, you've

Now I understand. Yes.

What I would do is, when someone was

12

pushing me on a matter of illegality, if the person

13

was -- if it suited my needs, I would play their

14

emotions to try to get them to stop.

15 16

Q

And you also referred to this technique of

yours as using a person's pressure point, right?

17

A

Yes.

18

Q

Of course, you agreed you don't need to apply

19

pressure to people who are criminals, right?

20

A

That's right.

Sometimes -- well, that's not

21

true.

22

let me give specific examples.

23

were co-conspirators of my crime that I needed them to

24

do something outside of the criminality they were

25

currently involved in, I might use pressure points or

Sometimes when you have someone who is a -- well, When I had people that

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inducements.

2

It just depended upon what I required for the crime at

3

the time.

4

people needed less.

5

Q

I did that frequently with the bankers.

Some people needed more inducement, some

So, for example, when the innocent fund

6

investors started asking too many questions about

7

payments being late, you cooked up a story about having

8

a Florida Bar grievance?

9

A

10 11 12 13 14

Correct. MR. SCHERER:

Objection to form.

BY MS. SPEAKER?: Q

You used law enforcement to throw people off,

you said? A

I used legitimate law enforcement to do

15

legitimate things and I used corrupt law enforcement to

16

do corrupt things.

17 18

Q

You've rewarded the people who were in on your

scheme, didn't you?

19

A

Very well.

20

Q

You rewarded them with houses, right?

21

A

Yes.

22

Q

Cars?

23

A

Yes.

24

Q

Trips?

25

A

Yes.

Right?

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Q

Women?

2

A

Yes.

3

Q

Cigars?

4

A

Yes.

5

Q

Concerts?

6

A

Yes.

7

Q

Sporting events?

8

A

Yes.

9

Q

You emailed them a lot?

10

A

Some I emailed a lot.

11

Some I emailed a

little.

12

Q

You gave them nicknames?

13

A

Both, people that were involved in the crime

14

and not involved in the crime.

15

nicknames.

16 17

Q

Everyone in my world had

And you also gave money and gifts to people

who were not in on your schemes?

18

A

That's correct.

19

Q

You told folks the gospel according Scott?

20 21

MR. SCHERER: A

Object to form.

I don't know what -- I'm sorry, I don't know

22

what that means, the gospel according Scott.

23

BY MS. BARZEE-FLORES:

24 25

Q

On December 14th, in the afternoon session,

page 886 of the transcript, you didn't testify that you

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told people, quote/unquote, the gospel according Scott?

2 3 4 5 6

MR. NURIK:

Actually, what was the

question before that answer? BY MS. BARZEE-FLORES: Q

7

My question is -MR. NURIK:

No.

What was the question

8

before?

9

answer was in response to a particular

10 11

Why don't you say -- ask him what his

question so we can identify the record. BY MS. BARZEE-FLORES:

12

Q

Have you ever said that, sir?

13

A

My recollection is, is I was joking around

14

with some people in here when I said "the gospel

15

according to Scott."

16 17

You'd have to give me the context of it so it's not taken out of context.

18

Q

You used that phrase, sir?

19

A

Yes.

20

Q

On the record?

21

A

Yes.

22

Q

You used other tools, tangible tools to ply

23

your trade too, didn't you?

24

A

I don't understand the question.

25

Q

You masterminded the use of phony lawsuits?

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A

I masterminded -- the way you're asking it,

2

yes, I utilized phony lawsuits to continue to perpetrate

3

the fraud.

4

Q

Phony court orders?

5

A

Yes, ma'am.

6

Q

Phony settlement agreements?

7

A

Yes, ma'am.

8

Q

Phony promissory notes?

9

A

Yes, ma'am.

10

Q

Forged emails?

11

A

Yes, ma'am.

12

Q

Phony case file documents?

13

A

Yes, ma'am.

14

Q

Phony flight manifests?

15

A

No, we didn't phony up flight manifests.

16 17

We

used -Q

You didn't phony up a flight manifest where

18

you added Bill Clinton and Prince Andrew and young

19

girls' names to a Jeffrey Epstein flight manifest for

20

purposes of showing perspective investors how the

21

settlement system worked and why important people might

22

want confidentiality in exchange for large sums of money

23

to be paid to the plaintiff?

24 25

A

My best recollection is, is we used -- I think

I testified to this yesterday or the day before -- we

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used real flight manifests during that meeting with

2

the -- Mr. Scherer's clients.

3

fake flight manifests.

4

one.

5

refresh my recollection, but I actually don't recall

6

that being a document that I created.

And I told them about

I don't recall that we created

If you have one, you can show it to me, that would

7

Q

Phony bank websites?

8

A

Yes.

9

Q

Phony bank statements?

10

A

Yes.

11

Q

Phony opinion letters?

12

A

Yes.

13

Q

Phony audit letters?

14

A

Yes.

15

Q

Fake legal bills?

16

A

Yes.

17

Q

Phony court case bonds?

18

A

Yes.

19

Q

Fake law enforcement investigations?

20

A

Yes.

21

Q

Phony attorney's fees statements?

22

A

Yes.

23

Q

Fictitious loans?

24

A

Yes.

25

Q

And, of course, being a successful con means

Screen shots.

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you have to be a pretty good actor, right?

2

A

I was.

3

Q

Let's talk about you and your co-conspirators'

4

acting skills.

5 6

You orchestrated phony telephonic court hearings, didn't you?

7

A

I did.

8

Q

Now, a real telephonic court hearing is where

9 10

a judge allows the participants to participate by telephone, right?

11

A

Yes.

12

Q

But in your phony telephonic hearings, you

13

would have your firm's lawyers or other lawyers fake

14

like they were the participants in a real hearing,

15

right?

16

A

17

Marra.

18

Q

19 20

I had Scott Goldstein pretend to be Judge

And who, for example, would be attending a

fake hearing with a fake Judge Marra? A

In this case, one of my co-conspirators, Ted

21

Morse, and his father, who was an innocent, Edward

22

Morse.

23

Q

And what part did you play?

24

A

The lawyer.

25

Q

Other times you used people to play the part

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of plaintiffs, right?

2

A

That's correct.

3

Q

Steve Caputi played the plaintiff?

4

A

Steve Caputi played the plaintiff, and one of

5 6 7

the firm's secretaries played another plaintiff. Q

I assume you played the part of an honest

attorney?

8

A

Yes, ma'am.

9

Q

You were acting, of course?

10

A

I was.

11

Q

Caputi also played the part of a reporter to

12

harass one of your victims, right?

13

A

He did.

14

Q

Another time Caputi played the banker?

15

A

Several times, yes, ma'am.

16

Q

And he had to dress up for that part?

17

A

I asked him to put on a shirt and tie because

18

he usually dressed in jeans and a t-shirt.

19

Q

And you played the honest attorney again?

20

A

I did.

21

Q

Another time you had Caputi pretend to be the

22

owner of 800 numbers that had sent your firm lots of

23

business?

24

A

I did.

25

Q

And you had a woman in your office play the

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part of a Florida Bar official, right?

2

A

I did.

3

Q

You had other lawyers play the part of a case

4

and client referral sources, right?

5

A

Yes.

6

Q

And you would participate --

7

A

A series of lawyers.

8

Q

And you would participate in these little

9

scenarios with them?

10 11

A

You mean the fake due diligence with the

lawyers?

12

Q

Yes.

13

A

Yes.

14

Q

So you were acting quite a bit during this

15

I took them there.

time?

16

A

Myself and my co-conspirators, yes, ma'am.

17

Q

And then there were the shows, what you call

18

"the shows," right?

19

A

Yes, ma'am.

20

Q

Where everybody had a role?

21

A

Yes, ma'am.

22

Q

And you had lines?

23

A

It was a lot of ad lib but, yes, some specific

24 25

things that needed to be said and done, yes, ma'am. Q

These shows were coordinated?

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A

Yes, ma'am.

2

Q

And thought out?

3

A

Correct.

4

Q

You were a master of fraud, weren't you,

5 6 7 8 9

Mr. Rothstein? A

Unfortunately, I was very good at what I was

doing, yes, ma'am. Q

By the way, before you got caught up in all of

this, had you read up on con-artists and the tricks of

10

their trade?

11

A

I'm certain that somewhere along the line I

12

had read about cons but if you're asking me if I did

13

research for the role, no, I did not.

14

Q

It came naturally?

15

A

It's not that it came naturally.

It's just I

16

developed, unfortunately, an ability to fool people.

17

That's what I was doing.

18

co-conspirators were doing.

19

based upon.

20

Q

21

fraud.

22

A

I certainly do.

23

Q

I'm going to read you some of the things Judge

That's what all my That's what a fraud is

Judge Cohn, after sentencing, described your Do you remember that?

24

Cohn said and ask you if the judge was right.

25

understand?

You

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A

I can tell you right now he was right on

2

everything he said.

3

was 100 percent correct.

4 5

Q

Every single word that he said he

Judge Cohn said that your case was about

selling fake financial products.

True?

6

A

Yes.

7

Q

He said, "The marketing, however, was anything

8

but simple.

9

Madison Avenue's advertising elite."

It was sophisticated, rivaling that of

10

A

Correct.

11

Q

"It was all about image, wealth, power, and

12

influence."

13

A

Correct.

14

Q

WPI.

15 16

Is that all true? A

I told you two questions ago that every single

17

thing that Judge Cohn said about me and my crimes was

18

100 percent correct.

19

Q

Judge Cohn, "The marketing component of the

20

fraud focused on attracting investors with deep

21

pockets."

22 23 24 25

Is that what you did? A

Yes, ma'am.

That's -- I just testified to

that now three questions ago. Q

You displayed all the trappings of success:

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The multi-million dollar homes, the expensive cars, and

2

boats, restaurants and jewelry and a 70-lawyer law firm

3

that appeared to be thriving?

4

A

Yes, ma'am.

5

Q

You maintained political connections

6

stretching from the Broward Sheriff's office on one end

7

of Broward Boulevard, all the way down to the Fort

8

Lauderdale Police Department on the other end of Broward

9

Boulevard, correct?

10

A

Yes, and all the way out to Plantation.

11

Q

To the governor's mansion in Tallahassee and

12

all the way to the United States Congress in Washington

13

and down Pennsylvania Avenue to the White House?

14

A

I did.

15

Q

"The local society page," Judge Cohn, "was

16

constantly adorned with photographs of you and your wife

17

arm-in-arm with sports celebrities, politicians,

18

community leaders, and socialites."

19

Is that right?

20

A

That's correct.

21

Q

The political contributions, which were

22

funneled through your law firm's attorneys, their wife's

23

and other employees, placed the Rothstein brand in much

24

demand?

25

A

That's correct.

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Q

The philanthropy, which included donations to

2

hospitals, religious and charitable organizations

3

endeared you as one of Broward County's most prolific

4

benefactors?

5

A

That's correct.

6

Q

And the police security details, the dinners

7

with law enforcement, and the trips to sporting events

8

with BSO brass created an appearance of legitimacy?

9

A

That's correct.

10

Q

Judge Cohn, "But we now know it was all a

11

fraud."

12

A

That's correct.

13

Q

Let's talk about your various schemes and

14

crimes.

15

embezzled from his employer, Silversea, right?

Besides the Ponzi scheme, you and Albert Peters

16

A

Correct.

17

Q

How much in total did you-all embezzle?

18

A

I don't know.

19

Q

More than 10 million?

20

A

I don't recall.

21

Q

More than ten bucks?

22

A

Yes.

23

Q

You and Ted Morse embezzled from Morse

24 25

I don't recall.

Operations, didn't you? A

We did.

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Q

How much?

2

A

In excess of $59 million.

3

Q

You laundered money through your law firm?

4

A

I did.

5

Q

You laundered money for Albert Peters?

6

A

I did.

7

Q

You laundered money for Ted Morse?

8

A

I did.

9

Q

You laundered money for the mob?

10

A

I did.

11

Q

You committed tax fraud?

12

A

I committed the wrong kind of tax fraud.

13

increased my taxes instead of decreasing it.

14

know what you actually call that.

15

way.

16 17

I

I don't

It's tax evasion one

I guess I was tax invasion. Q

You lied under penalty of perjury under tax

forms, right?

18

A

Yes, I did.

19

Q

Friends -- your friends called you Robin Hood?

20

A

Certain of them, yes.

21

Q

And Robin Hood usually means a steal --

22 23 24 25

stealing from the rich to give to the poor, right? A

That's normally what it means.

I was stealing

from the rich to give to the richer. Q

Including yourself?

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A

Yes.

2

Q

And back to the tax fraud, your participation

3

in tax fraud was not necessarily only, if at all, for

4

your benefit but it was also for other folks' benefits,

5

right?

6

A

Right.

7

Q

You helped other people commit tax fraud,

8

right?

9

A

10

Yes.

My tax fraud was unique to me.

I helped

other people avoid taxes.

11

Q

Evade them?

12

A

Avoid, evade, not pay.

13

Q

You engaged in public corruption with

14

politicians?

15

A

Yes.

16

Q

You engage in public corruption with law

17

enforcement?

18

A

Yes.

19

Q

You participated in the purchase of political

20

positions?

21

A

Yes.

22

Q

You bribed judges?

23

A

Yes.

24

Q

You were involved in the --

25

ALL PRESENT:

Object.

Form.

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BY MS. SPEAKER?: Q

3

-- manipulation, you say, of the judicial --

4 5 6 7

THE WITNESS:

I'm sorry.

Can you repeat

that? BY MS. BARZEE-FLORES: Q

You were involved in the manipulation of the

judiciary?

8

A

Yes.

9

Q

You engaged in mob crime?

10

A

I don't know what you mean.

11

MR. LAVECCHIO:

Could I have a point of

12

clarification by what you mean by "mob

13

crimes"?

14 15 16

BY MS. SPEAKER?: Q

Sure.

You've already said you laundered money

for the mob, right?

17

A

Yes.

18

Q

Were you involved in extortion?

19 20 21 22

MR. SCHERER: repeat that?

I'm sorry.

Would you

I didn't hear the question.

BY MS. BARZEE-FLORES: Q

Were you involved in extortion?

23

MR. SCHERER:

24

MS. BARZEE-FLORES:

25

MR. LAVECCHIO:

Thank you. You're welcome.

As a general crime?

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A

2

crime, yes.

3

BY MS. BARZEE-FLORES:

4

Q

I was involved in extortion as a general

Did you extort anybody?

5

You're pausing, Mr. Rothstein.

6

I'm not going to ask you who if Mr. Lavecchio

7

doesn't want me to know that.

8

MR. NURIK:

9

MR. SCHERER:

10

MR. NURIK:

Let -- hold on.

Hold on.

Objection to form. Let the record reflect that

11

the reason he's pausing is because there is

12

the anticipation of a possible objection based

13

on law enforcement privilege, so he's giving

14

the government the opportunity to decide

15

whether or not to interpose that objection.

16

No other reason.

17 18 19

MS. BARZEE-FLORES:

So noted.

BY MS. BARZEE-FLORES: Q

And I know that, which is what I meant to

20

suggest to you when I said I'm not going to ask you who

21

you extorted, if Mr. Lavecchio has an objection to that

22

question.

23 24 25

But I'm asking you, not who you extorted, but just admit that you did. A

I'm waiting to make sure there's no --

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Q

Okay.

2

A

-- objection.

3

MR. LAVECCHIO:

My objection is just

4

point of clarification.

5

participated in extortion.

6

differentiated from extorting people, I don't

7

understand and I don't think he understands

8

it.

9 10 11

Q

Did you threaten somebody that if they didn't

give you money, you would do something? THE WITNESS:

13

MR. LAVECCHIO:

15

As that is somehow

BY MS. BARZEE-FLORES:

12

14

You said he

A

Go ahead? Yes.

Through other people, yes.

BY MS. SPEAKER?:

16

Q

Did you order the people who did it to do it?

17

A

Did I order them?

18

Q

Did you ask them nicely?

19 20

ALL PRESENT: A

Object to the form.

The way that particular -- without getting

21

into any details, the people that I was involved with

22

were happy to do these things, and they did them.

23

didn't need to order anyone to do anything.

24

I asked.

I paid.

I

They did.

25

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BY MS. BARZEE-FLORES: Q

And the "did" that they did, was it in

3

exchange for the money with the threat for physical

4

violence or the threat that some crime would be exposed,

5

or what?

6 7 8 9 10

MR. LAVECCHIO:

That's where I have to

object. BY MS. BARZEE-FLORES: Q

You were involved in making physical threats,

though, were you not?

11

MR. LAVECCHIO:

Again, point of

12

clarification, he's previously testified that

13

he was involved in acts that concerned certain

14

acts of violence, but as to his personally

15

participating in those, you can ask that.

16 17 18

BY MS. BARZEE-FLORES: Q

activities including the making of physical threats?

19 20 21

What did you do to involve yourself in

MR. LAVECCHIO:

I have to object.

BY MS. SPEAKER?: Q

Did you threaten anybody with physical harm?

22

MR. LAVECCHIO:

23

THE WITNESS:

24 25

Personally? Personally?

BY MS. BARZEE-FLORES: Q

Yeah.

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A

I may have said I was going to beat the crap

2

out of someone when they aggravated me but that's not

3

related to the criminality.

4

in a bar saying, I would like to sleep with your wife,

5

and me saying, I'll beat the crap out of you if you go

6

near her.

That's like someone sitting

It's not the same thing.

7

Q

Right.

8

A

The criminality that I was involved in was

9 10 11 12

through other people.

15

Q

18 19 20

Sir, as you can understand, I'm really not

interested in your bar banter. ALL PRESENT:

Objection to form.

BY MS. BARZEE-FLORES: Q

16 17

I did not actually get involved

in that.

13 14

And certainly --

I'm asking you -MR. SCHERER:

Mary, we can't hear you.

BY MS. BARZEE-FLORES: Q

Did you ever threaten to break anybody's

kneecaps, for example? A

In conversations with certain people that I

21

was committing crimes with, there was discussion of

22

physical violence.

23 24

Q

What type of violence? MR. LAVECCHIO:

Objection.

25

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BY MS. SPEAKER?:

2

Q

3 4

MR. LAVECCHIO:

Objection.

BY MS. BARZEE-FLORES:

5 6

How many contacts in the mob did you have?

Q

Let me ask you about Melissa Lewis.

Melissa

Lewis was a lawyer in your firm, right?

7

A

Yes, ma'am.

8

Q

And at some point you were sleeping with her?

9

A

When she was a student of mine, yes.

10

Q

She was Debra Villegas' best friend, right?

11

A

She was.

12

Q

The same Debra Villegas that would do just

13

about anything for you if you asked her?

14

A

Yes.

15

Q

The same Debra Villegas that knew about your

We already discussed that.

16

crimes or some of them and who participated in them with

17

you?

18

A

That's correct.

19

Q

At some point Debra Villegas' best friend and

20

then your former lover was murdered?

21

A

That's correct.

22

Q

She was murdered because she knew too much,

23

right?

24

A

25

Excuse me?

She was.

Are you attempting to insinuate

that I had something to do with that poor girl's death?

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Have you lost your mind?

2

Q

You would deny that?

3

A

I would deny it?

4 5

You're disgusting. wasn't involved in it.

Everyone knows that I

That's disgusting.

6

Q

How about Julie Timmerman?

7

A

No.

8 9

Okay.

No.

That is disgusting.

I was a criminal involved in

white-collar crime, involved in fraud and the like,

10

involved with the mob and corrupt politicians and

11

corrupt law enforcement.

12 13

I'm paying for that.

Melissa Lewis was a good person. know too much.

14

She didn't

She was killed by a psychopath.

And you're disgusting for doing that.

15

Q

You gave Debra Villegas a house, right?

16

A

Why drag her family through that?

They're

17

going to have to read this, for your purposes, to defend

18

John Harris, who's guilty.

19

Q

You gave Debra Villegas a house --

20

A

You should be ashamed.

21

Q

-- right?

22

THE WITNESS:

I want five minutes.

23

should be ashamed of yourself.

24

should be in jail.

25

You

You think I

You should be ashamed.

MS. BARZEE-FLORES:

We'll talk about

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Julie Timmerman when you come back.

2

THE WITNESS:

You're a disgusting human

3

being.

4

group of lawyers.

5

disgusting human being.

You're the only one out of this entire You are truly, truly a

6

MR. NURIK:

7

(Thereupon, a recess was taken.)

8

THE WITNESS:

9 10 11 12

Scott, relax.

Whenever you're ready.

BY MS. BARZEE-FLORES: Q

When did you say you had stopped manipulating

people? A

I made a conscious decision to stop being the

13

person that I was during the course of all these crimes

14

on my return from Morocco.

15 16 17

Q

But you agree that even after you returned

from Morocco, you manipulated people? A

That is a very vague question that may impinge

18

on the government's privilege.

19

defer to them.

20 21 22

MR. LAVECCHIO:

Point of clarification.

BY MS. BARZEE-FLORES: Q

You acted in an undercover capacity?

23

MR. LAVECCHIO:

24

MS. BARZEE-FLORES:

25

I'm going to need to

Objection. I believe that was --

was that not discussed at the sentencing?

I

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believe it was.

2

MR. RABIN:

3

MS. BARZEE-FLORES:

Absolutely, it was.

4

transcript.

5

then I can come back.

6 7

Let me just hand it to you, and

MR. LAVECCHIO:

Is that the end of your

question?

8

MS. BARZEE-FLORES:

9

MR. LAVECCHIO:

MS. BARZEE-FLORES:

11

MR. LAVECCHIO:

15 16

BY MS. BARZEE-FLORES: Q

And I believe it was in your letter,

Mr. Rothstein. MR. NURIK:

18

this.

19

A

21

Did you participated in

Okay.

17

20

We defer to the government on

I'm more than happy to answer it, if the

government allows me. MR. LAVECCHIO:

We don't have to spend a

22

lot of time on this.

23

question yes or no.

24 25

Yeah.

undercover --

13 14

Yes.

That's the only question?

10

12

I have the sentencing

THE WITNESS:

You can answer the

Can you reask the question,

please?

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BY MS. BARZEE-FLORES: Q

You acted in an undercover capacity after you

came back from Morocco?

4

A

Yes.

5

Q

Let me ask you about Julie Timmerman.

6

A

Yes, ma'am.

7

Q

She was your law clerk?

8

A

She was.

9

Q

And she had been a hostess at a -- or some

10 11

type of employee at Bova, also? A

I believe she was.

12

specifically was or not.

13

she did work at Bova.

I don't recall whether she

I think at one point in time

14

Q

And in the last year --

15

A

Yeah, she did.

16

Q

And in the last year of the Ponzi scheme, you

17 18

She did.

gave her four $15,000 payments. A

I don't remember specifically whether it was

19

the last year, but there was a point in time when she

20

needed funds to complete law school and we gave her what

21

we had called "student loans" through the firm.

22

a decision that Stu Rosenfeldt and I made.

It was

23

Q

You were sleeping with her, though, right?

24

A

There was a point in time when she and I had a

25

physical relationship.

It was prior to her working for

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me.

2

It didn't continue. Q

And Ms. Timmerman, after the Ponzi scheme

3

imploded, is alleged to have committed suicide; is that

4

correct?

5 6

A

It's my understanding that she did commit

suicide, yes.

7

Q

Your bodyguard was pretty close to you, right?

8

A

I believed him to be, yes.

9

Are you talking

about Mr. Scandiffio?

10

Q

Yes.

11

A

That's what I just said, yes, ma'am.

12

Q

And he also allegedly committed suicide after

13

the Ponzi imploded, right?

14 15

A

My understanding from conversations with law

enforcement was that he did, in fact, commit suicide.

16 17

Big Bob Scandiffio, he was close to you?

Q

What did he know about you before he allegedly

shot himself in the head?

18

A

Specifically, I don't recall everything he

19

knew.

20

constantly.

21

did, in fact, know that I was committing crimes.

22

know that I was an adulterer.

23 24 25

He was a confidante of mine who was with me

Q

So I suspect he knew that I was -- well, he He did

You deny having much to do with any one of

those three deaths, right? A

I didn't have anything to do with those

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deaths. Q

Every day you've been deposed, the morning has

3

started with a discussion of the oath you're taking,

4

right?

5

A

6 7

A discussion?

I'm put under oath each

morning. Q

Put under oath or somebody asks you are you

8

still under oath, there's always something about the

9

oath before we start questioning you, right?

10 11

A

I think that's standard in a deposition, to

make my testimony be sworn testimony.

12

Q

And you took an oath to tell the truth, right?

13

A

Every day that I've been deposed.

14

Q

And the lawyers -- when I mentioned discussion

15

before, the lawyers questioning you over these days have

16

often made a point that you're under oath or reminding

17

you that you're under oath, right?

18 19 20

A

They made the point, and I made the point.

Remember this morning, I asked to be put under oath? Q

And you do that because you want folks to

21

believe that since you're taking an oath, you're saying

22

the truth, right?

23

A

No, actually.

I really want to not have to

24

repeat all this testimony again, and if I'm not under

25

oath, the deposition testimony can't be used.

I am

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telling the truth.

2 3 4 5

And yes, I do want people very much to understand that I am, in fact, telling the truth. Q

You've violated oaths before, though, haven't

you, sir?

6

A

In my prior incarnation, I certainly did.

7

Q

You violated your oath as an attorney?

8

A

I did.

9

Q

You lied to judges?

10

A

I did.

11

Q

You put money, filthy lucre, ahead of your

12

clients' interests?

13

A

Filthy lucre?

14

Q

Yes.

Money?

15

A

Yes.

I know what "lucre" is.

16

heard anyone use that in a question before.

17

Q

It's in the oath, sir.

18

A

I know it is.

I remember the oath.

19

"for lucre or malice," I remember that.

20

that oath.

21 22

I've just never

Q

I just --

Yes, I violated

Your law firm's motto was passion, integrity

and commitment, right?

23

A

That's correct.

24

Q

That was a lie?

25

A

Actually, when -- if you say that like that,

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you're actually offending a tremendous number of really

2

good decent lawyers because the bulk of the lawyers at

3

RRA believed in passion, integrity and commitment.

4

were really good and decent people.

5

Q

Not you, though?

6

A

No.

I was a very, very bad person.

I think

7

we've established that, and I think I've clearly

8

admitted that.

9

Q

You violated the oath of your marriage?

10

A

I definitely did, yes.

11

They

I already told you

that.

12

Q

How many times did you do that?

13

A

Too many to count.

14

Q

You have perjured yourself?

15

A

Prior to returning from Morocco, I certainly

Q

You have been known as the "Prince of

16 17 18 19 20 21

did.

Darkness." A

Yes.

That was a name given to me back when I

was a young lawyer. Q

Mr. Rothstein, during the time of your

22

criminal enterprise, you would agree you've been

23

charming?

24 25

A

I think some would say I was charming; I think

some would say I was a flaming A-hole.

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Q

How about narcissistic?

2

A

I definitely had a narcissistic personality,

4

Q

You repeatedly committed criminal acts?

5

A

Yes.

6

established.

7

Q

Repeatedly lied or conned people?

8

A

I did.

9

Q

You rationalized your having stolen from some

3

10

yes.

people?

11

A

12

absolutely.

13

Q

14

I'm confident that that's clearly

I did, along with my co-conspirators,

And you know, sir, that these are the classic

clinical symptoms of sociopathy?

15

A

I'm sorry.

16

Q

Have you heard of the word "sociopathy"?

17

A

I certainly have.

18

Q

You've heard people use the word "sociopath"?

19

A

I certainly have.

20

Q

And you know that these symptoms that I just

I don't understand your question.

21

went over with you, charming, narcissistic, repeatedly

22

committing criminal acts, repeatedly lying or conning

23

people and rationalizing --

24

A

You're asking me to diagnosis myself?

25

Q

Well, you're seeing -- you have seen a

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psychiatrist, have you not, sir?

2

A

For acute anxiety disorder.

3

Q

You've had this discussion with your

4

psychiatrist, have you not?

5

A

I have not.

6

Q

You've been prescribed sertraline?

7

A

For acute anxiety disorder.

8

Q

Do you know it is prescribed for sociopathy,

A

No, actually, I didn't, until you just told me

9

sir?

10 11 12

that. Q

How do you know the prison doctor isn't just

13

telling you it's an anxiety disorder to put that in your

14

prison file so the government can use you as a witness?

15

A

16 17

I've actually never -ALL PRESENT:

A

18

Objection.

No, no -MR. NURIK:

Hold on.

First of all, there

19

is a privilege with his doctors.

20

A

Without waving any medical privilege, I have

21

never -- the entire time I've been incarcerated -- ever

22

seen a prison psychologist or psychiatrist or an outside

23

psychologist or psychiatrist, ever.

24

BY MS. BARZEE-FLORES:

25

Q

You have --

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A

The sertraline was prescribed to me by a

medical doctor.

3

Q

For anxiety?

4

A

That's what it's used for, yes.

It was

5

actually the only drug, other than Paxil, that ever

6

worked for it.

7

Q

You have no intention of dying in prison?

8

A

I certainly hope not to.

9

Q

You've always had a "plan B," haven't you?

10

A

The only plan that I had is the plan I would

11

suggest your clients and the other people in here who

12

are guilty use, and that is come clean, talk to the

13

government, tell them what you did, pay for your crime,

14

hope that you get out while you still have a life to

15

live and go and be a productive member of society.

16

That's the suggestion I have for all the people that are

17

sticking their heads in the sand, including your

18

clients.

19 20

Q

Southern Grant -- I'm sorry.

Southern Grout

and Mortar, do you remember that?

21

A

I do.

22

Q

And I think we've heard the story about you

23

had a lawyer in your firm that botched some aspect of a

24

lawsuit on behalf of the owner of that company.

25

A

Yes.

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Q

And having had the problem of the botched

lawsuit, you had a "plan B," right?

3

A

Well, I don't now if I had a "plan B."

4

Q

You paid off the yacht, right?

5 6

MR. NURIK: A

Well, let him finish.

Let me finish the answer.

7

My "plan B" was the fact that the owner of the

8

company is a criminal, okay, and it was very easy to fix

9

what we needed to fix.

I paid money to him so that his

10

ex-wife wouldn't know what was going on and so that his

11

daughter and his CFO would not know what was going on.

12

It's not a "plan B."

When you're doing

13

business with criminals, you don't need to have a

14

"plan B"; you just do.

15

BY MS. BARZEE-FLORES:

16

Q

Well, how about in the Morse cases, when Ed

17

and Carol Morse had a lawsuit and there was some problem

18

going down with that, didn't you have a "plan B" where

19

you had to create fake court orders to get out of it?

20 21 22

A

You're misstating all of my prior testimony.

It's not a "plan B." I had Ed Morse's son, who is the CEO and

23

president of the company, Ted Morse, involved in

24

criminal acts was me, including assisting me in stealing

25

from his father.

I didn't need to have a "plan B."

I

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needed to talk to Ted and figure out what -- for lack of

2

a better phrase, what crime we were going to commit next

3

and do what it was.

4

continuation of a criminal enterprise.

5

Q

You call it "plan B"; I call it a

In late 2009, when you were afraid that your

6

Ponzi was going to implode without a big infusion of

7

cash, wasn't "plan B" to threaten the doctrine of mutual

8

destruction?

9

A

Yes, along with other criminals, that's

10

correct.

11

trying to say that I -- if one thing wasn't working, I

12

tried something else, the answer is yes.

13

Q

If you want to call it a "plan B" -- you're

All right.

And when the Ponzi scheme did

14

finally implode, your "plan B," rather than face the

15

failure, was to either flee to Morocco or kill yourself?

16 17 18

A

It's not a "plan B."

I don't think you're

listening to my testimony. At some point in time, all these crimes were

19

going to be exposed.

20

find a nonextradition country and flee to it.

21

I made a conscious decision to

While I was in the nonextradition country

22

sitting with plenty of money, as well as things that

23

could be sold for plenty of money, I made the

24

then-conscious decision -- maybe one of the only

25

decisions in my life I am truly, truly proud of, I made

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the decision to return to the United States, despite the

2

fact that I was in a nonextradition country, to turn

3

myself in, knowing that I was going to go to prison.

4

Q

Once you were in Morocco --

5

A

Something I suggest your clients and the other

6 7 8

guilty people do before it's too late. Q

Once you were in Morocco, you talked to your

lawyer, Mr. Nurik, right?

9

A

I'm sorry?

10

Q

Once you were in Morocco, you talked to your

11 12

lawyer, Mr. Nurik? A

I think we established on the 30th or the

13

31st, just prior to me deciding to come back, I spoke to

14

Mr. Nurik.

15 16

Q

And you communicated with some of your

co-conspirators?

17

A

I did.

18

Q

By email, correct?

19

A

Some by email, some by text.

20

Q

What --

21

A

Some by phone.

22

Q

What email addresses were you using?

23

A

I don't recall.

24

Q

You had more than the Scott Rothstein law firm

25

email address?

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A

2

using.

3

to, as well.

No.

That would mean email addresses I was writing

4 5 6

You're saying what email addresses I was

I used [email protected]. Q

You did not write from any other email

address?

7

A

I don't think I had any other email addresses.

8

Q

While you were there, your plan became to come

9 10 11 12 13 14

back to the United States, right? A

My plan?

It was a conscious decision I made

to turn myself in. Q

But it wasn't just to turn yourself in and do

your time, right? A

I made a decision to come back, turn myself

15

in, go to prison and tell the government everything I

16

knew about everyone else that had committed crimes.

17

Q

Right.

18

A

And everything about my crimes.

19

Q

So you didn't just decide to come back and,

So you did --

20

like a Bernie Madoff, take your sentence and spend the

21

rest of your life in jail --

22

A

Are you --

23

Q

-- that wasn't your plan?

24

A

Whoa, whoa, are you suggesting that Bernie

25

Madoff, who worked to help other people that were in the

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know get away with his crime, that I'm the same?

2

You're not even close.

You're not even close.

3

Mr. Madoff should have taken me, and I'm proud to say

4

this, as an example as to what you do when you want to

5

do the right thing.

6

you think he did that by himself, then you don't know

7

anything about how these crimes work.

8 9

Q

He did the wrong thing.

Because if

The point is, Mr. Madoff came back -- I mean,

Mr. Madoff got his sentence and is serving it; but

10

that's not what your plan was, right?

11

get a sentence and hopefully reduce it, right?

12

A

Your plan was to

At the time that I decided to come back, I had

13

no idea what was going to happen to me.

14

I had with my wife and other people that I was talking

15

to who were counselling me, revolved around the fact

16

that when I stepped back on U.S. soil, I could very

17

likely die in prison.

18

it was a very real possibility, I came back.

19

Q

The discussions

Despite the fact that I knew that

Before you got on that plane in Morocco to

20

return to the United States, you had decided that you

21

were going to begin cooperating with the government in

22

the hopes of reducing your sentence?

23 24 25

A

I had made a decision to come back and tell

the truth about everything I was involved in. I had already been -- without getting into

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anything that would waive attorney-client privilege,

2

okay, and my spousal privilege, okay, I was under the

3

belief that I could die in prison, regardless of what I

4

told anybody.

5 6

So I made a decision to leave what I believed was a safe haven to come back to this.

7

Okay.

Do I now hope that I will get a reduction?

8

course I do.

9

will get out someday.

Of

Every single person in prison hopes they

10

Q

What sentence did you think you were facing?

11

A

100 years.

12

Q

Before, before you left Morocco.

13

A

Before I left Morocco?

14

Q

Yes.

15

A

Life.

16

Q

But you believed at that point that you would

17

have enough information on other people that your

18

sentence might be reduced to a point where you would be

19

able to get out of jail?

20

A

I didn't have any conscious decision about

21

that one way or the other.

22

would yield a reduction in my sentence --

I hoped that my cooperation

23

Q

At what point did you decide --

24

A

-- but -- but --

25

Q

Oh, go ahead.

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A

-- but --

2

Q

I apologize.

3

A

-- given the fact that I had practiced law for

4

some time, I also knew that it was a possibility, as I

5

do know sitting here right now, that I could end up

6

dying in prison.

That is the fact of the matter.

7

Q

And you don't want that to happen?

8

A

No, ma'am.

9

Q

At what point did you decide to start

10 11

I do not wish to die in prison.

assisting the trustee and Mr. Scherer in this case? A

In order to answer that question, I would have

12

to give you attorney-client-privileged information, and

13

I'm going to --

14 15

THE WITNESS: objection?

16 17 18 19

Do you want to make this

MR. NURIK:

You already did for me, but

that's okay. BY MS. BARZEE-FLORES: Q

At what time --

20

MR. NURIK:

21

THE WITNESS:

That's your privilege. I'm invoking

22

attorney-client privilege.

23

answer.

24 25

That's your

BY MS. BARZEE-FLORES: Q

I'm not asking you what your lawyer told you;

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I wouldn't ask you that.

2

I'm asking at what point did you decide to

3

start helping the Trustee and Mr. Scherer?

4

before you left to Morocco?

Was it

5

A

No.

6

Q

It was after that, right?

7

A

Well, it would have to be after that

8

because --

9

Q

Was it before your sentence --

10

A

Hang on.

11

Wait.

I'm answering.

When I left to Morocco, there was no Trustee;

12

and even when I came back, I didn't know there was going

13

to be a trustee.

14

on the civil side of this.

15

thinking about.

16

I had no idea what was going to happen It was not something I was

I had -- I had one goal: come back, tell the

17

government everything I know, make sure the innocent

18

investors got their money back.

19

Q

That was it.

But then, at some point, you believed or came

20

to believe that if you helped the Trustee and

21

Mr. Scherer, you might get some credit for that for a

22

sentence reduction.

23 24 25

A

Actually, you're 100 percent wrong. My understanding is that while they're

certainly allowed to talk about anything that I've

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helped happen, that my cooperation is evaluated based

2

upon my cooperation in criminal investigations and

3

criminal prosecutions.

4

statute says anything about civil anything.

5

I don't think the Rule 35

My purpose in cooperating with Mr. Scherer and

6

Ms. Van Vliet and Mr. Lichtman and everyone else

7

representing innocent parties, is to make sure that, my

8

wish, that the innocent investors get all their money

9

back, actually comes to fruition.

10 11

Q

You talked about Ponzi-speak.

Let's talk

about prison-speak, since you're talking about Rule 35.

12

A

I --

13

Q

Now, you know that the government is the one

14

that files the Rule 35 motion, right?

15 16 17

MR. SCHERER: A

Object to form.

Yes.

BY MS. BARZEE-FLORES:

18

Q

And, in fact, it did, right?

19

A

Yes.

20

Q

And the Rule 35, as you just suggested, is a

21

motion that is filed when the government, in its own

22

estimation, has determined that you have provided

23

substantial assistance, right?

24

A

I understand that's what the rule says.

25

Q

Right.

And that's what you were just trying

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to cite to me a minute ago, right, what the rule or the

2

statute says, right?

3

A

Cite to you?

I was telling you what my -- you

4

asked me what my understanding was.

5

understanding.

6

Q

Okay.

I gave you my

But you know, sir, that once the

7

government has filed the Rule 35 and you get back in

8

front of a judge, anybody can get up and talk about how

9

wonderful you are in the hopes that that might get the

10

judge to reduce your sentence, right?

11

A

I believe it's up to the judge.

12

Q

Right.

13 14

And it's up to the judge, just like it was up to the judge the last time you were before him, right?

15

A

It is completely in his hands.

16

Q

Right.

17

And the last time you were before him,

18

although it was totally in the judge's hands, you had

19

somebody get up and speak on your behalf, did you not?

20

A

I'm sorry, who spoke on my behalf, other than

22

Q

Mr. Nurik spoke on your behalf, did he not?

23

A

He's my lawyer.

24

Q

Okay.

21

25

me?

And he was there and he spoke on your

behalf, right?

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MR. NURIK: A

I would hope so.

If he got up and said things that were not on

3

my behalf, that would have been a little problematic,

4

right?

5

BY MS. BARZEE-FLORES:

He's my lawyer.

6

Q

And the --

7

A

Hang on.

His job --

I'm answering questions, and I know

8

you want to stay on your roll, but I want to make sure

9

the record is clear.

10 11 12

He got up representing me.

Okay.

And make no

mistake about it, Mr. Nurik was furious with me. Q

And the reason he got up and argued on your

13

behalf was to attempt to convince the judge that what

14

you deserved was a sentence of 30 years not 40 years

15

like Mr. Lavecchio was asking?

16 17 18 19

A

Yes.

BY MS. BARZEE-FLORES: Q

Okay.

And you had a letter from Herb Stettin

that was presented to the judge, right?

20

A

I don't recall.

21

Q

Do you know who Herb Stettin is?

22

A

I do.

23

Q

And you don't recall him having written Judge

24 25

Cohn a letter for you? A

It's kind of a blur.

I remember my mom wrote

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a letter.

2

because we talked about it earlier in testimony,

3

Mr. Scherer wrote a letter.

My sister wrote a letter.

I remember now,

4

Q

And the point --

5

A

I remember that there was a really -- now,

6

because I hadn't seen it before -- nasty letter written

7

by Coquina.

8

Q

9 10 11

The point of all those letters, the good and

the nasty, were to influence the judge in the judge's sentencing determination, right? A

I believe the purpose is to properly educate

12

the judge so he can make as informed decision as

13

possible, yes.

14

Q

So, now that the government has filed a

15

Rule 35, you'll have another sentencing hearing before

16

Judge Cohn, right?

17 18

A

I don't know.

I don't know if there's going

to be a hearing or not.

19

I understand it could be done by the Court; it

20

could be done without me there.

21

happen.

I don't know what will

22

Q

Do you hope to have a hearing?

23

A

I hope to get a Rule 35 reduction for my

24 25

substantial assistance -Q

You want somebody to tell the judge what you

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did? A

Why are you cutting me off?

Just let me

finish, please.

4

I hope to have a Rule 35 substantial

5

assistance reduction.

6

the judge and the government; it's not up to me.

7

Q

How we get there, that's up to

Don't you hope that there's a hearing that

8

Mr. Lavecchio gets up, asks and tells the judge about

9

how much you've done?

10

A

If that is going to help educate the Court,

11

then yes, I hope there's a hearing.

12

doesn't require that information or to hear from me or

13

to hear from other people, then that's what will happen.

14

Q

If the Court

And you hope that at such a hearing, your

15

lawyer will have an opportunity to tell the judge what

16

you've done and how you deserve to have your sentence

17

reduced?

18

A

I hope that all the information about

19

everything that I've done since my return from Morocco

20

is presented in full to the Court; and I hope that he's

21

fair with me, that he considers everything that I've

22

done before and after and comes to a fair determination

23

for me.

24 25

Q

That's my hope. And you hope Herb Stettin provides the judge

with information that the judge might find favorable to

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you?

2

A

3

I think I've answered this over and over. I hope that every single person that has

4

something to offer about anything positive that I have

5

done since my return from Morocco is heard so that the

6

judge can make a fair decision based upon everything

7

that he should consider to determine whether or not I'm

8

entitled to a reduction.

9

Q

And you believe that the more the judge hears

10

that's favorable about you, the more likely it will be

11

that the judge will reduce your sentence?

12

MR. SCHERER:

13

A

Object to form.

I don't know that it's like a "more" thing.

I

14

think it's the -- an examination of my cooperation.

15

don't know that it's like you stack all the cooperation

16

up.

17

BY MS. BARZEE-FLORES:

18

I

It's based upon the quality of my cooperation.

Q

Let's talk about that, Mr. Rothstein.

19

When you talk about the quality of your

20

cooperation and the quantity of your cooperation,

21

certainly, if your cooperation entails nothing more than

22

advising the government about somebody who had passed a

23

fake check once at a bank, you could not expect a

24

sentence reduction as large as you might expect if you

25

provided information that led to the indictment of five

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people, including a politician or a judge, including a

2

lawyer or a doctor, correct?

3

A

4 5

Or a banker. ALL PRESENT:

A

Object to form.

I believe that that is a fair statement, that

6

the judge -- that the government, first, will evaluate;

7

and then the judge will evaluate it, based upon the

8

quantity, but more importantly, the quality of my

9

cooperation.

10 11

BY MS. BARZEE-FLORES: Q

And certainly, if Judge Stettin (sic) and

12

Mr. Scherer and Mr. Lichtman come in and say to the

13

judge, not only did he help the government, but he

14

helped us, and he helped our clients, who deserve to be

15

helped, that that may help you get your sentence reduced

16

further?

17

A

Assuming that the Court wishes to consider

18

that, that would be helpful; but I can't guess as to

19

what he's going to consider or not consider.

20

Q

But you can tell us --

21

A

The only thing I know about --

22

Q

-- what you hope.

23

A

Yes, I hope he considers everything that I've

24

done, sure.

25

MR. SCHERER:

Object to form.

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BY MS. BARZEE-FLORES: Q

Who bought the clothes you've been wearing

these last two weeks?

4

UNKNOWN SPEAKER:

Object to fashion.

5

A

6

watch.

7

belt, and he brought me a pair of jeans and this shirt.

8

BY MS. BARZEE-FLORES:

9

I bought the sneakers. I bought my underwear.

Q

MR. NURIK:

11

add to my bill.

13 14 15

18 19 20 21 22 23

Which, for the Court, I will

BY MS. BARZEE-FLORES: Q

You've had more than one shirt; Mr. Nurik

bought you the shirts you've been wearing? A

16 17

Mr. Nurik loaned me my

You've had more than one shirt --

10

12

My wife bought me the

Three. MR. NURIK:

Target.

BY MS. BARZEE-FLORES: Q

You said you bought your sneakers; is that

with money out of your commissary account? A

It's money I earned, actually, in prison,

teaching. Q

Does anybody put money in your commissary

account?

24

A

Yes.

25

Q

Who?

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A

My wife.

2

Q

How old are you?

3

A

49.

4

Q

And you've been in for a couple of years,

5

right?

6

A

Two years this past December 1st.

7

Q

Assuming you have the opportunity to get up

My parents.

My sister.

8

before Judge Cohn for a resentencing, what do you hope

9

for?

10

A

Say this again?

11

Q

Assuming you have the opportunity to get up

I lost you.

12

before Judge Cohn for resentencing, what do you hope to

13

get?

14 15

A is.

16 17

I don't -- I don't know what a resentencing

Are you talking about -Q

A second sentencing, sir; you've been

sentenced once, have you not?

18

A

Yeah, but I don't think it works that way.

I

19

think that there's a Rule 35 hearing, and then he enters

20

an order on the Rule 35.

21

I don't think -- I've read some of the case

22

law.

23

resentencing.

I don't think you actually go through a

24

Q

What do you hope the sentence is --

25

A

As a matter of fact, I think there's case law

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that says it's not a resentencing because that would

2

trigger certain other things that they don't want to

3

trigger.

4

Q

What do you hope your sentence is?

5

A

Whatever is fair.

I mean, I would love to get

6

out as soon as possible.

7

Okay.

8

stuff, and I can't talk about that; but make no mistake

9

about it, I'm in prison, okay.

Prison is a very bad place.

I know there's a lot of talk about where I am and

It's a very bad place,

10

and I can tell you with 100 percent certainty there is

11

nobody in there that does not want to go home today.

12

I would like to go home today.

13

unrealistic.

14

Q

15

right?

16 17 18 19

22 23

I would like to go home today.

Before your incarceration, you lied for money,

MR. SCHERER: A

Object, form.

Yes.

BY MS. BARZEE-FLORES: Q

20 21

Okay.

That is wholly

And you used a pitch to get what you wanted? ALL PRESENT:

A

Object, form.

Yes.

BY MS. BARZEE-FLORES: Q

Your hope to get out of prison today is a

24

reason for you to lie, isn't it?

25

MR. SCHERER:

Object to form.

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A

You apparently are not paying attention to

2

what Judge Cohn is all about, the magnitude of my crime

3

and what I'm facing.

4

attention to what's going on.

5 6

upon my telling the truth about everything I know. MR. SCHERER:

Q

10

BY MS. BARZEE-FLORES: Q

You have at least 50 reasons to lie, don't

you?

15

17

We object to that

question.

13

16

You have -MR. LICHTMAN:

11

14

Withdraw my objection.

BY MS. BARZEE-FLORES:

9

12

Okay.

My hope to get out is solely, solely based

7 8

You're -- you've got to pay

ALL PRESENT: A

Object to form.

In prison we actually count it by days.

BY MS. BARZEE-FLORES:

18

Q

How many days have you got?

19

A

I don't know.

20

think.

21

Q

22 23 24 25

No.

Over 10,000, I

Object to form.

You, again --

MR. NURIK: A

A lot.

So over 10,000 reasons to lie? MR. SCHERER:

A

A lot.

Just answer.

The answer is no.

I have the opposite of what

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you're saying.

2

10,000-something reasons, okay, to tell the truth.

Okay.

I have every reason,

3

MS. BARZEE-FLORES:

4

THE WITNESS:

5

Nothing further.

Sam, do you mind if we take

five minutes?

6

MR. RABIN:

7

(Whereupon, a recess was had.)

8

MR. SCHERER:

9

No, that's fine.

This record closes at

12:00.

10

MR. NURIK:

Let's go.

I'm going to ask a

11

few questions at the end just to clarify some

12

points so -- but we -- go ahead.

13 14

FURTHER DIRECT EXAMINATION BY MR. RABIN:

15

Q

Okay.

16

A

Good morning, Mr. Rabin.

17

Q

All right.

18

few points.

19

area.

20

Good morning again, Mr. Rothstein.

First I just want to pick up on a

Then I want to go into a completely new

You said in response to questions this morning

21

that you were amazed that people would write so many

22

incriminating things in emails, correct?

23

A

Yes.

24

Q

All right.

25

Was it your conscious desire to

try to avoid writing incriminating things in emails?

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A

2

It was and it wasn't. There were times when I was very careful not

3

to put incriminating things in emails, and looking back

4

on it, there were times when I wrote things I probably

5

shouldn't have written.

6

Q

Would it be fair to say that you were

7

conscious of the fact you were trying to leave as few

8

trails as possible of your illegal acts?

9

A

At times I was and at times I wasn't.

10

Q

The subject of tax fraud has come up at least

11

two or three times in the course of this deposition; and

12

each time, you've said that you committed fraud the

13

wrong way because, I guess, you're suggesting that you

14

paid more taxes than you should have?

15

A

I did.

16

Q

Okay.

Did you include in your taxes all of

17

the cash that you were pulling out in cash and using in

18

your various assorted and sundry matters?

19

A

Not by listing it as cash, but I more than

20

accounted for it in the income that I -- that I

21

declared.

22

Q

Okay.

So you didn't specifically indicate the

23

amount of cash on your tax return that you were -- that

24

you were using or that you had?

25

A

I didn't say it was cash.

I -- it was more

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than included.

2

What I did was, so you know, Mr. Rabin, was, I

3

wanted to avoid an audit; or if I got an audit, I wanted

4

them to, as they were going through it, determine that,

5

wait a second, this guy doesn't owe any taxes, if

6

anything we owe him money.

7 8 9

So I instructed Tracy Weintraub to inflate my income by tens of millions of dollars, which he did. Q

So, essentially, what you're saying is you

10

paid more taxes, but you lied about the manner in which

11

you did it?

12

A

Yeah.

I'm not -- by no means, Mr. Rabin, I'm

13

not trying to excuse my conduct.

14

didn't commit fraud on the IRS.

15

the fact that I kind of did it in a backwards fashion.

16

Q

I'm not saying I I'm just pointing out

Another theme that you've developed through

17

the course of this deposition in your answers is that

18

you told the people that were involved in your Ponzi

19

scheme just what you needed to tell them in order to get

20

them to do the things that you needed them to do; is

21

that fair to say?

22 23

MR. SCHERER: A

Objection.

Form.

Certain people, I told them just what they

24

needed to know.

25

too little; and certain people I told too much.

Certain people, I probably told them It just

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varied.

2

BY MR. RABIN:

3

Q

Okay.

I want to break these down into groups

4

and try and get your best recollection as to what you

5

told different people in order to engage them in your

6

scheme.

7

your law firm.

And I want to start first with the people in Okay?

8

A

Sure.

9

Q

All right.

Russell Adler, you generally

10

described the fact that he helped you round up other

11

lawyers to provide false verifications that they were

12

either sending business or cases to your firm, correct?

13

A

That is one of the things that he did, yes.

14

Q

And what was the -- what was it that you told

15

him was the reason why you needed those lawyers?

16 17

First of all, was it honest or a lie and what was the --

18

A

No, it was honest.

19

Q

Okay.

20 21

And what -- it was honest, what you

told him? A

I told Mr. Adler -- to the best of my

22

recollection, I told him that we had the hedge funds

23

coming in town and that in order to convince them to

24

continue to do business with us, that I needed these

25

people to lie about the number of cases we had.

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Q

So, essentially, what you're saying is, you

2

honestly told him aspects of the scheme or he already

3

knew aspects of the scheme and you told him the honest

4

purpose for which you were lining up these lawyers?

5

that what you're saying?

6 7

MR. SCHERER: A have --

9

BY MR. RABIN: Q

11 12 13 14

Object to form.

I don't understand the question but you

8

10

Let me rephrase it. MR. SCHERER:

Objection to form.

BY MR. RABIN: Q

I don't want you to answer a question you

don't understand.

15

Is your -- what you just summarized or just

16

testified to is that you told Adler that you needed

17

these lawyers to provide false information?

18 19 20 21 22 23 24 25

Is

A

I told Adler -- yes, I told Adler I needed

these lawyers to lie. Q

Okay.

David Boden, generally what was David

Boden's role? A

He was my general counsel, and he ran a

sub-Ponzi scheme, as we've come to call it. Q

All right.

And what was the lie that you told

or the honest information that you gave David Boden in

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order to let him get involved in your scheme?

2

MR. SCHERER:

3 4

A

Object to form.

I would have to see all the email traffic with

him to break that down for you, Mr. Rabin.

5

There were things that I told him that were

6

true about the scheme.

7

him that were false about the scheme.

8

he told me that were true about his scheme and things

9

that he told me that were false about his scheme.

10

There were things that I told There were things

There was -- David and I were engaged in so

11

much lying back and forth that without seeing that email

12

traffic, there's just no way I can pinpoint that for

13

you.

14

Q

So --

15

A

It's impossible.

16

Q

Well, you wouldn't put lies in an email,

17

though, would you?

18

A

Of course I did.

19

Q

You did?

20

A

I think I've been saying that for now eight

21 22

days and a couple of hours. Q

So without looking at the emails, is it your

23

testimony that you have no independent recollection of

24

anything that you told David Boden regarding what you

25

needed to say to get him to help you?

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A

It's not that I don't have -- I mean, I can

2

sit here and start -- try to think about it, but giving

3

me the emails would refresh my recollection and make it

4

a lot easier on all of us.

5

Q

And that also has been a common theme

6

throughout the course of the eight days or nine days;

7

but what I'm asking you for today is your best

8

recollection.

9

not be email trails as to what you told people in your

Because, as you can appreciate, there may

10

conversations with them.

11

your best recollection or what is your best recollection

12

regarding what you told Boden.

13

MR. NURIK:

14 15

So I'm asking you what was

Are we talking about in

emails or in conversations? BY MR. RABIN:

16

Q

No.

17

A

In conversations, I -- let me do it by way of

Conversations.

18

giving you some examples, and maybe you can ask me

19

questions as follow-up that will get you to where you're

20

trying to go.

21

At one point in time I had to explain to David

22

Boden how to use the fake TD website.

23

and I showed him how to utilize it, how to log in, how

24

to avoid going to the wrong places that would actually

25

take him to a real TD website.

I took him in,

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BY MR. RABIN:

2

Q

Did you --

3

A

Prior to that a --

4

Q

Just let me ask a follow-up question, and then

5

you can continue.

6

A

Sure, sure.

7

Q

Can you tell him what the purpose of the fake

8 9

TD Bank website was when you showed him that? A

I -- he knew what it was.

That's why he

10

wanted to use the fake TD website; he was going to use

11

it to induce his investors.

12

Q

Okay.

13

A

By the same token, early on, before he knew

Go ahead.

14

there was a Ponzi scheme, I told him that these were

15

legitimate investments, so he had heard both.

16

much like that with many people who originally thought

17

that what we were doing was legitimate; and as they came

18

to detect red flags, realized that there were crimes

19

going on, and they, themselves, made the decision to get

20

involved, based upon requests that I made of -- for them

21

to do various things.

22

It was

I told him in conversations to be very careful

23

what he wrote to me, that I didn't know whether Curtis

24

or Bill Corte -- and this is a specific conversation,

25

because I remember thinking at some point in time that

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someone was reading my emails because certain things

2

looked open.

3

And I remember telling him, be careful what

4

you write to me -- this was towards the end, let's say

5

from June, July, until the implosion -- be very careful

6

when he was writing to me because I was afraid that

7

someone might be reading my emails.

8

to increase the security level on our email system and

9

the encryption.

10

I was going to try

I told him to be very careful what he told

11

Pearson, Richard Pearson.

12

to worry about Pearson.

13

He told me that I didn't need

Do you want to give me some other topics with

14

him and I can give you some additional information,

15

because there's a lot more.

16

conversations.

17

I was committing with Tracy Weintraub, because David was

18

a very, very bright corporate-paper man.

19

I mean, I had a lot of

I consulted at length with him the fraud

And there was a time -- actually, I had

20

detailed conversations with him on an opinion letter

21

that he was having to prepare.

22

Florescu.

23

investors.

24 25

I think it was for Barry

It might have been for one of his other

I had detailed conversations with him -- this was about the fraud -- about how Frank Preve and I and

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the other people that were involved in putting together

2

prior opinion letters, had placed the false information

3

in there.

4

I had conversations with him about what to

5

show people and what not to show people and how best to

6

sell the product.

7 8

I gave him extensive one-on-one--- let's call them primers on how to sell product.

9 10 11

I mean, David was a confidant.

There's a lot

that I told him. Q

Okay.

Let me move on to yesterday, I believe

12

it was, you identified Adelita Cabello as a Stuart

13

Rosenfeldt's paralegal and the person that you had act

14

the part of a Florida Bar lawyer?

15

A

Correct.

16

Q

How many times did she do that?

17

A

Once.

18

Q

Okay.

19

And was that the only time you had

somebody pose as a Florida Bar lawyer?

20

A

To the best of my recollection.

21

Q

Okay.

22 23

And what was it you told Ms. Cabello in

order to get her to do that? A

I gave her some specific questions that they

24

were going to ask.

25

and I told her that if they asked anything that she

I briefed her on how to answer them,

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couldn't answer or was uncomfortable answering, to

2

simply say that that's Bar privilege or something to

3

that effect, that she couldn't get into that.

4

Q

Mr. Rothstein, that wasn't the question I

5

asked you.

6

the reason for her --

My question was:

What did you tell her was

7

A

I'm sorry.

8

Q

-- to do that?

9

A

I misheard you.

10

Q

Okay.

11

A

I didn't tell her the reason.

12

Q

And you're saying that she didn't ask why she

13 14

needed to do that? A

She may have, but a lot of my people were

15

extremely loyal, and they were, unfortunately, used to

16

being asked to do things that were not appropriate.

17

My opinion is, is that that's the way she

18

perceived this and she wanted to be a good, quote,

19

unquote, soldier, and she just did it.

20

Q

Was she given any cash?

21

A

She was not.

22

Q

Okay.

23

Marybeth Feiss was somebody that was

involved in drafting fake documents?

24

A

That's correct.

25

Q

All right.

You have already said that with

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Debra Villegas, that the lie that you told her was that

2

the Mafia was after you and that's why you needed these

3

fake documents, right?

4

A

Yeah.

Sometimes in the middle of the scheme,

5

when Debra was getting very concerned about continuing

6

it -- this was in 2009 sometime -- I told Debra that I

7

had to continue it, that the mob was involved.

8

a lie.

9

Q

10

Okay.

That was

What was the lie that you told her in

order for her to start doing it, then?

11

A

I didn't tell her any lie to start doing it.

12

Q

She just -- did she just basically, willingly

13

engage in a crime with you without any preconceived

14

misconceptions?

15

A

Actually, one of the things you're going to

16

see through -- in the entire thing, this applies to

17

Debra and many others, is that there is a very slow,

18

apparently smooth glide into the criminal activity.

19

starts with little things and it grows.

20

It

So, yes, there is nobody that I can think of

21

off the top of my head that was involved in any -- even

22

the tentacles of this massive crime, that I said, hey,

23

we're going to commit a crime or said, I'm going to

24

commit a fraud or even anything of that nature.

25

started doing things.

We just

You ask people to do things, and

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you see whether they're going to do it or not.

2

gauge their response.

3

That's --

4

Q

Okay.

You

That's what would happen.

Mr. Rothstein, I'm going to try -- and

5

if you can, just focus on my questions, rather than the

6

speeches.

7

out with each of these people, what you told them to get

8

them to work with you.

It's very narrow.

9

A

All right.

10

Q

Thank you.

11 12

All right.

A

We left off at Marybeth Feiss.

I don't recall telling her anything.

I think

Deb filled her in.

15 16

Okay?

What did you tell Marybeth Feiss?

13 14

I'm just trying to find

Q

So you don't recall any specific conversations

with her before she started preparing fake documents?

17

A

Other than asking her to hand me documents or

18

make sure I get documents on time, no.

19

filled her in on all that.

I think Deb

20

Q

Did she leave your firm?

21

A

For a period of time, yes.

22

Q

Before everything blew up?

23

A

Yes.

24

Q

When she left your firm, do you know where she

25

And then she came back, I think.

went?

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A

I don't.

She had told me that she was leaving

2

to go take care of her children, but Debra told me that

3

she was leaving because she was concerned about what was

4

going on with all these documents.

5

Q

Were you concerned when she left that she

6

might go to the authorities with the information that

7

she had?

8

A

Yes.

9

Q

Same question for Melissa Lewis, she left for

10

a period of time, correct?

11

A

Melissa had no idea what was going on.

12

Q

Okay.

13

You don't -- you know she was best

friends with Villegas, right?

14

A

Yes.

15

Q

And Villegas knew everything that was going

16

on, pretty much?

17

A

Debra knew a lot, yes.

18

Q

You really can't sit here and say what

19 20 21 22

Villegas told Lewis, could you? A

No, but I was never under the impression, in

my opinion, that Melissa knew anything. Q

Okay.

And with respect to Debra Villegas, you

23

said that she started out just doing illegal things; but

24

at some point in time, she kind of like was -- became

25

reluctant.

And then you told her, in order to keep her

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going, about the mob, correct?

2

A

She became very concerned.

Sometime in 2009

3

she became concerned, and I made up the story about my

4

life being in danger.

5

Q

Did you know that her -- at Ms. Villegas'

6

sentencing, that she told the judge that the reason she

7

got involved in this from start to finish was because of

8

your story about the mob?

9

A

That would actually be incorrect.

10

Q

So she would have lied, then, if she said

11

that?

12

A

That would be a false statement, sir.

13

Q

Okay.

14

Yes.

Steve Goldstein, you identified him as

the lawyer who posed as a Judge Marra?

15

A

Scott Goldstein.

16

Q

I'm sorry.

17

Scott Goldstein.

I know Steve Goldstein.

18

A

Be careful, you could hurt another lawyer.

19

Q

Scott Goldstein.

20

Change that.

21

He was the lawyer that posed as Judge Marra?

I'm sorry.

22

A

Yes.

23

Q

Did he pose as any other judges?

24

A

He posed as a circuit court judge once or

25

twice.

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Q

Well, the circuit court judge whose name you

forged on the order was a female, wasn't it?

3

A

I don't recall.

4

Q

Susan Black?

5

A

No.

6

Q

Right.

7

A

I'm sorry, Mr. Rabin, state circuit court.

8

Q

Okay.

9

Marra.

10

A

11

Morse cases.

12

Q

Okay.

13

A

Sorry.

14

Q

Did you tell Scott -- is something funny?

15

A

Actually, yes.

Susan Black was an appellate court judge.

So this Scott Goldstein posed as Judge

Do you know who else he posed as? Whoever the real male judge was in one of the

And what -- what did you --

I just remembered Ted Morse

16

saying to me when I said he posed as this other judge,

17

Ted actually said to me at the time that he played -- he

18

had played the circuit judge first; and when he played

19

Judge Marra, Ted actually said to me, you need to get

20

someone else to play one of the other judges because

21

their voices sound the same and my father said something

22

to me about it.

23 24 25

That is what was funny. Q

Were both of the roles he played, both of the

judges he played, interacted with Mr. Morse, the elder?

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A

Yes.

2

Q

Is that what you're saying?

3

A

Yes, that was the purpose.

4

Q

And what did you tell Scott Goldstein in order

5

to get him to do that?

6

A

I told Scott Goldstein that Ted did not want

7

his father involved in anymore litigation and that Ted

8

was going to ultimately fund settlements to get -- he

9

was going to funnel money through us and get back to Ed

10

to make Ed think he won these things so this could all

11

be done with, and this was part and parcel of that plan

12

and we were assisting Ted to do this.

13

Q

So you essentially fabricated an entire story

14

for Scott Goldstein in order to get him to play the

15

role --

16

A

Yes.

17

Q

-- fair enough?

18

A

Ted and I did, yes.

19

Q

I know you're saying, well, Ted did it.

I

20

understand, but I am just asking about what you did.

21

Okay.

22

A

I understand that, but what I did was with

23

somebody.

24

to tell you what I did and with whom.

25

Q

So if you're asking me what I did, I'm going

Okay.

Howard Kusnick, he was a lawyer who --

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was he with your firm at one point and then left?

2

A

Ted and I -- not Ted and I.

3 4

Howard and I were partners many years before that.

5

Then we split up, and then he joined my firm. Q

And then he ultimately participated by writing

6

fake letters and saying that he sent cases to you, a lot

7

of cases to your firm?

8 9 10

A

think he faked the referral thing.

I don't

He wrote fake

letters.

11 12

I don't think he was a referral.

Q

Okay.

What did you tell him to get him to

write fake letters?

13

A

I didn't tell him anything.

14

Q

You had to tell him something to get him to

15

write a letter.

What did you tell him?

16

A

Write this letter.

17

Q

So just it was a command from the head of the

18

firm -- write a letter -- with no explanation?

19 20

A

Howard was a criminal from way back; it

was not complicated to get him to do that.

21 22

No.

Q

Okay.

Steve Lippman was a lawyer in your

firm?

23

A

Yes.

24

Q

What generally did he do?

25

A

Commercial litigation.

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Q

What type of -- what was his involvement in

your criminal activities? A

Massive check kiting, money laundering, lying

to clients -Q

Okay.

And what did you have to tell him to

get him to play along?

7

A

-- bank fraud.

8

Q

What did you have to tell him to get him to

9

play along?

10

A

Nothing.

11

Q

Nothing?

12 13

He just was a criminal from way

back, as well? A

I don't know.

He appeared to me to have a --

14

to be what's called loosey-goosey when I first met with

15

him to join in my firm because he wanted me to engage in

16

income tax evasion as part of his compensation package.

17

Q

Okay.

You mentioned this lawyer, Ken

18

Padowitz, several times during the course of this

19

deposition as somebody who you had, I guess, write a

20

letter?

21

A

Opinion letter, yes.

22

Q

Okay.

And you indicated the opinion letter

23

was about things that you and Preve drafted that you

24

believe Padowitz had absolutely no knowledge about?

25

A

To the best of my knowledge, he had no idea

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what that letter was about, as far as the contents of

2

it.

3

that area of the law.

4 5

He didn't know the -- understand the intricacies of

Q

What was it that you told Mr. Padowitz in

order to get him to write that letter?

6

A

To best of my recollection, I simply told him,

7

I need this letter, put it on your letterhead, and I

8

paid him for it.

9

Q

How much did you pay him?

10

A

I think five grand.

11

grand.

12

Q

Check or cash?

13

A

Cash.

14

Q

And I assume there is no witnesses to the

15

payment, right?

16 17 18

A

No.

21

Adler is a witness to me asking him to do

Q

That wasn't my question.

it.

19 20

Maybe 2,500, maybe five

Were there any witnesses to the payment? A

I think I was just thinking out loud,

Mr. Rabin.

I'm sorry.

22

Q

That's all right.

23

A

I don't believe there were any witnesses to

24

the payment.

25

Q

There may have been.

Well, there may have been, that's not --

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doesn't make an absolute answer.

2

witness, then?

3

A

Who may have been a

I can't give you an absolute answer.

There

4

may have been a witness, because I handed him the

5

money -- here's the problem.

6

situated, there was a lot of foot traffic, and I simply

7

walked into his office and gave him the money.

8 9

Q

Where his office was

And did you give him any reason at all why you

needed the letter?

10

A

I did not tell him why I needed the letter.

11

Mr. Padowitz, I had known, had engaged in substantial

12

amounts of fraud previously.

13

those guys that you know, you pay him, he'll put it on a

14

letter, anything for a buck.

15 16 17

He was -- he's one of

Q

What other fraud did you know he had engaged

A

Fraud involving his judicial campaign, and he

in?

18

had lied during the course of various cases that he was

19

handling when he was a partner of Russ Adler's.

20

Q

All right.

Stuart Rosenfeldt, you talked

21

about him a lot during the course of the deposition.

22

What is it that you had to tell him in order to get him

23

involved in your scheme?

24

A

Nothing.

25

Q

So he knew from the beginning that it was

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criminal and willingly engaged in it?

2

A

At the time he discovered what was going on,

3

which was simply by looking in the accounts and asking

4

me where the money was coming from, yes, he knew I was

5

involved in criminal activity and then he knew he was

6

involved in criminal activity.

7

Q

Irene Stay was your chief financial officer?

8

A

Yes.

9

Q

And she was moving money between and among

10

your various accounts, actually doing the transactional

11

side of it?

12

A

Yes.

13

Q

Did you ever explain to her what you were

14

doing with the movement of money?

15

A

I didn't need to.

16

Q

Why not?

17

A

Because Irene was a -- involved in fraud way

18

back when I first met her when she was the bookkeeper

19

for a law firm called Phillips, Eisinger Koss.

20

became Phillips, Eisinger, Koss, Rothstein & Rosenfeldt.

21

She was regularly engaged in fraud with the senior

22

partners of that firm, Gary Phillips and with Dennis

23

Eisinger, involving accounting and tax evasion and the

24

like.

25

Q

It later

How did you know that?

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A

Because I was part of this.

2

Q

You were part of that fraud?

3

A

I received money from it.

4

Q

Okay.

5

Did you have an intimate relationship

with Irene Stay?

6

A

I'm sorry?

7

Q

Did you have an intimate relationship -- I'm

8

trying to be delicate.

9 10

A

No.

"intimate."

I didn't realize when your said

11

Nevermind what I thought you said.

No, I did not.

12

Q

How about Debra Villegas?

13

A

No.

14

Q

Okay.

And Debra Villegas, you said that --

15

about halfway through, that you mentioned that the mob

16

story to her, correct?

17

A

I don't remember if it was halfway.

My

18

recollection is it was 2009 some time, when the things

19

were getting really crazy in the office.

20 21

Q

Well, 2009 is more than halfway through,

actually, would it be?

22

A

23

be halfway.

24

Q

25

Bank.

That's why I said I don't know that it would

All right.

And now I want to talk about TD

I think you identified three different people at

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the bank who you had interaction with, if I'm not

2

mistaken, Spinosa, Caretsky and Kerstetter, correct?

3

A

You are going to have to define "interaction."

4

Q

Well, in terms of helping you with any aspects

5

of your scheme, that you were aware of?

6

A

Ms. Kerstetter, all she did was hand me an

7

envelope.

8

of her knowledge.

9

Ms. Caretsky or Mr. Spinosa.

10

Q

I do not know anything else about the extent You'd have to talk to Mr. Boockvor or

Did you have any conversations with

11

Ms. Kerstetter about what she was doing in terms of

12

helping you?

13

A

To my recollection, no.

14

Q

Okay.

With respect to Ms. Caretsky, you

15

testified previously that she was given money and helped

16

you with the switches of statements.

17

her to get her involved?

18

A

What did you tell

I told her, as I testified previously, that I

19

needed to convince clients of mine that I had more money

20

in the bank than I did in order to get them to give me a

21

substantial increase in my business.

22 23

Q

Okay.

And do you recall when you told her

that?

24

A

I do not.

25

Q

Okay.

With Mr. Spinosa, you -- he prepared a

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series of letters that have come to be known as lock

2

letters at your request, correct?

3

A

Yes.

4

Q

The first one was August 17th; do you recall

5

that?

6

A

I don't.

7

Q

Well, let's just -- let me ask the question

8

differently, then.

9

A

Sure.

10

Q

What was it you told Mr. Spinosa in order --

11

when you requested the first letter?

12

A

I don't recall, specifically.

13

Q

So as you sit here today, you don't recall

14 15

what explanation you gave him for requesting the letter? A

I would have to really sit down and read the

16

email traffic to see what I said and how I said it.

17

don't recall what reason I gave him for the letters,

18

except to tell him that I needed them.

19 20 21

Q

You would not have told him some illegal or

improper reason; is that fair to say? A

I don't know what I told him.

I don't know

22

what I told him.

23

traffic and see if it refreshes my recollection.

24 25

I

Q

I would have to look at the email

Is there anybody else at TD Bank that you can

recall that you had any interaction with?

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A

Illegal interaction?

2

Q

Yes.

3

A

No.

4

Q

Okay.

Gibraltar Bank, the other bank that you

5

testified about, I think you mentioned two different

6

names, Mr. Harris and Mr. Hayworth?

7

A

And Ms. Ellis.

8

Q

And Ms. Ellis.

9

Okay.

Ms. Ellis, generally, what was her role?

10

A

She was a bank manager.

11

Q

What did she do to help you, if anything?

12

A

She kept us apprised of problems with our

13

accounts, helped us move money around.

14

discussions with her, so the record is clear about

15

criminal activity.

I never had any

16

Q

So you never spoke to her at all?

17

A

Oh, I spoke to her a lot.

18

Q

About anything related to either criminal

19 20

activity or reasons to ask her for favors, anything? A

The only things that I said to Lisa would be

21

contained in emails, and I don't recall, other than

22

giving her carte blanche to move money around in a

23

manner that was certainly, by my way of thinking,

24

suspicious, I didn't have any conversations about

25

illegality with Ms. Ellis.

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Q

2

of the bank?

3

A

Yes.

4

Q

All right.

5

A

CEO.

6

Q

Sorry?

7

A

CEO.

8

Q

CEO.

9

All right.

Steve Hayworth, he was president

You --

You ultimately invested in that bank?

10

A

I did.

11

Q

Did you ever have any conversations with him

12

about what you were doing?

13

A

About what I was doing?

14

Q

Yes.

15

A

No.

16

Q

All right.

17

A

Only about the BSA.

18

Q

I'm sorry?

19

A

Only about the BSA AML issue.

20

Q

And that conversation, there was one of those?

21

A

One or a couple.

22 23 24 25

It was the same

conversation, though, very brief. Q

And ultimately you invested in the bank,

correct? A

I did.

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Q

You never told him the source of the funds

regarding your investment, did you?

3

A

No.

4

Q

Which were?

5

A

I took it from somebody who had sent money to

6 7 8 9

He could see the source of funds.

one of my trust accounts. Q

Essentially you concealed from him any illegal

activity that you were conducting, correct? A

No, no, no, the whole purpose of my investment

10

was based upon his illegal statement -- what I believe

11

was an illegality, telling me that they don't

12

investigate shareholders of the bank.

13

Q

Okay.

14

A

That was the triggering event.

15

Q

And based upon that claimed conversation, you

16 17 18 19 20

invested in the bank? A

It's not a claimed conversation.

It happened.

That's why I invested in the bank. Q

When you say that, there is no witnesses to it

but Scott Rothstein, correct?

21

A

And John Harris.

22

Q

Okay.

23

A

What did he do in real life or --

24 25

John Harris, what did he do?

MR. NURIK:

Hold on one second.

I'm just

a little confused.

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MR. RABIN:

Okay.

2

MR. NURIK:

We have been going on, this

3

is the ninth day.

4

parties asking questions concerning Gibraltar.

5

It's my understanding that you represent

6

Mr. Spinosa --

We have had multiple

7

MR. RABIN:

Correct.

8

MR. NURIK:

-- who works for TD Bank.

9

MR. RABIN:

Correct.

10

MR. NURIK:

We are going over ground that

11

we have gone over before several times.

12

don't understand why you're asking these

13

questions now concerning Gibraltar officials.

14

MR. RABIN:

I

Actually, really, I'm asking

15

questions about what lies he told to the

16

various people that he was -- that he engaged

17

in his scheme, and that's the context of it,

18

Mr. Nurik; and I appreciate your objection.

19 20

MR. SCHERER:

I am going to object to the

form, also.

21

MR. RABIN:

22

MR. SCHERER:

Okay. I mean, all of this is

23

really over-the-top repetitive, Sam.

24

you would finish, so there would be a little

25

bit of time left.

I wish

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MR. RABIN:

Well, okay, none of these

2

questions have been covered, because I have

3

read the transcripts, as well as sat here; and

4

nobody has asked him any questions about what

5

he specifically told people to get them

6

involved.

7

answers in any transcript, then I would be

8

happy to stand down on these questions.

9

And if you could point me to the

BY MR. RABIN:

10

Q

Mr. Rothstein?

11

A

Yes, sir.

12

Q

Regarding Mr. Harris, he was -- what was his

13 14

position at the bank? A

He was a senior or executive vice president,

15

and he was in charge of Fort Lauderdale market.

16

recall what his title was.

17

Q

Did you lie to him at all?

18

A

Yes.

19

Q

About what?

20

A

A whole variety of things.

21 22

If you show me the

email traffic, I can point them out to you. Q

I want your best independent recollection of

23

the things you lied to him about.

24

MR. SCHERER:

25

I don't

A

Object to the form.

I lied to him from time to time about where I

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was.

2

for certain business investments I had.

I lied to him about where certain money was coming

3

I really have to look at the email traffic.

I

4

just -- I told John Harris a lot of lies, and I told him

5

a lot of truths.

6

criminal activity together.

7

the email traffic, because I'm just sitting here

8

guessing because I'm poking in the dark.

9

Q

And he and I were involved in a lot of And I can't do it without

I don't want you to guess.

10

best recollection.

11

answer:

I just want your

If you don't recall, that's a fair

I don't recall.

12

A

I just don't recall at this moment.

13

Q

Okay.

Michael Szafranski is a name that has

14

come up throughout the course of the deposition.

15

hired as a, quote, unquote, independent verifier?

16

A

Yes.

17

Q

All right.

He was

What lies did you tell him in

18

order to get him to falsely verify information to his

19

investors?

20 21

MR. SCHERER: A

Object to form.

To falsely -- at the time that he became

22

involved in the Ponzi scheme, there were very few lies

23

that I needed to tell him because he was all in.

24 25

Early on I had told him -- he believed that this whole thing was real.

Once he discovered it wasn't

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real, there was no real reason to lie to him; but I'm

2

certain if you give me the email traffic, I can tell

3

you.

4 5 6

Independent recollection, at this moment, I don't recall, and I don't want to guess. Q

So, essentially, what you're saying is when he

7

first got involved, he was, what he believed to be,

8

verifying what he thought were legitimate transactions;

9

is that right?

10 11

ALL PRESENT: A

12

Object to form.

You're asking me to get inside his head. It's my opinion that early on he believed

13

that, but after a short period of time, it became clear

14

to him, because I think it would to anyone really

15

looking at stuff, that it was not real.

16

opinion.

17

BY MR. RABIN:

But that's my

18

Q

Okay.

19

A

He was part of the Boden/Pearson sub-Ponzi

20

Richard Pearson, Mr. Pearson was who?

scheme.

21

Q

Okay.

22

A

I did.

23

Q

And did you lie to him?

24

A

In the beginning, I did, yes, sir.

25

Q

And what lies did you tell him?

Did you ever meet with him?

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A

I told him whatever was necessary to make him

believe that the investment was real. Q

So it was along the lines of just telling him

4

things to deceive him into believing it was a legitimate

5

investment when it was not?

6 7 8 9

ALL PRESENT: A

Objection, form.

Correct.

BY MR. RABIN: Q

Do you have any specific recollection of lies

10

that you told him, other than that general umbrella of

11

"the investment is legitimate"?

12 13 14 15

A

be guessing, and I do not want to guess. Q

Okay.

Frank Preve, when Frank Preve first

started investing, did you have to lie to him?

16 17

Without seeing the email traffic, I would just

MR. SCHERER: A

Object, form.

Early on, I'm certain that I did lie to him

18

early on and then less and less, depending upon the

19

level of his knowledge.

20

But, again, you know, I want to be precise.

21

If I see the email traffic, I'm certain I could be

22

precise about what lies I told him and what were truths,

23

what lies we concocted together and the like; but

24

without that, I would be guessing, and I don't want to

25

muddy the record.

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BY MR. RABIN:

2

Q

3

"mushroom"?

4

A

No, milk toast.

5

Q

Well, milk toast and also, I thought,

6 7

mushroom. A

8 9 10

Wasn't Szafranski the guy that you called a

A couple of times we called him a mushroom. MR. SCHERER:

Objection.

BY MR. RABIN: Q

11

That's what I thought. And when you called him "mushroom," I think

12

you testified it was because, for lack of a more

13

delicate term, you shit on him and kept him in the dark.

14 15

MR. SCHERER: A

Object to form.

It was a conversation between either Frank

16

Preve and I or David Boden and I about him.

17

that we kept him in the dark and put shit on him, like a

18

mushroom.

19

BY MR. RABIN:

20

Q

We said

And that would be -- I assume that's -- the

21

lay way to express it, is that you lied to him and

22

misled him, right?

23 24 25

MR. SCHERER: A

Object to form.

At various points in time I lied to him, and

he lied to me.

That's what happens in a crime.

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BY MR. RABIN:

2 3

Q

No honor among thieves, is that what you are

saying?

4

ALL PRESENT:

5

A

Objection.

I have got to tell you, even now more so than

6

ever.

7

was in the middle of this horrific thing.

I knew there was no honor among thieves when I

8 9

But in going back and looking at all this over the last two years, I can assure you that there is no

10

honor among thieves at all.

11

BY MR. RABIN:

12

Q

Andrew Barnett, he recruited investors for

14

A

He did.

15

Q

And did you lie and mislead him?

16

A

I don't think that he was -- that he knew what

13

17

you?

was going on.

18

Q

What do you mean by that?

19

A

I don't think that he was involved in the

20

crime.

21

Q

Okay.

22

A

I did to a limited extent.

So -- but did you lie and mislead him? Most of that, he

23

was really recruited by David Boden, and I don't know

24

what Boden told him; but I was always of the impression

25

that he believed things were real.

I don't think that

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Mr. Barnett was involved in the crime.

2

Q

Did you ever have any conversations with him?

3

A

I talked to him all the time.

4 5 6 7 8 9

He was the son

of a very dear friend of mine. Q

Did you ever have conversations where you

pitched the legitimacy of the investment? A

I think only as follow-up questions that he

had based upon David Boden's pitch to him. Q

So, what you're essentially describing is

10

David Boden did most of the lying to him, and you might

11

have just, you know, played clean up?

12

A

13 14

MR. RABIN:

19

These guys are sleeping.

(Thereupon, a discussion was held off the record.)

17 18

There was no objection to

form on that one?

15 16

I think that's a fair statement.

MR. LICHTMAN:

Objection to form.

BY MR. RABIN: Q

Doug Bates, Doug Bates was an attorney who

20

lied to investors, potential investors about referring

21

business to you?

22 23

A

Doug Bates was a lawyer who was involved in a

significant amount of illegal activity with me.

24

Q

Okay.

25

A

Some of which I can't get into.

I'm sorry?

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Q

Okay.

2

A

You're about to find out.

3

Q

-- for what you can get into, though, you

Well --

4

described how he lied to investors in order to lead them

5

to believe he was referring you business, correct?

6

A

Him and Wayne Koppel, yes.

7

Q

Okay.

With regard to Mr. Bates, what did you

8

tell him in order to get him to make those

9

misrepresentations?

10

A

I just told him I was bringing people in that

11

I needed him to say this to.

12

Bates is one of those people that, for lack of a better

13

word -- do you need me to give you a moment?

14

MR. LICHTMAN:

I didn't -- again, Doug

I'm going to board your

15

one question.

16

you're alluding to is a lawyer in Fort

17

Lauderdale, correct?

To be sure, the Doug Bates that

18

THE WITNESS:

19

MR. LICHTMAN:

A lawyer in Plantation. Plantation.

Not a Doug

20

Bates that works at Berger Singerman in Miami,

21

right?

22 23 24 25

THE WITNESS:

Sorry, Chuck, no, it is not

your Doug Bates. MR. SCHERER:

I didn't see that on your

conflict waiver.

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BY MR. RABIN: Q

So Doug Bates, you just essentially said,

3

listen, I need you to lie to these people and tell them

4

that you send me a lot of business; is that it?

5

A

Because of things that I cannot discuss that

6

the government will object to, there was no need to get

7

into much deception with Doug Bates to get him to do

8

anything illegal.

9

Q

What else was he doing?

10

MR. LAVECCHIO:

11

MR. RABIN:

12 13 14

Objection.

Okay.

Just making sure

you're aware. BY MR. RABIN: Q

Steve Caputi, we talked a lot about Steve

15

Caputi.

16

lot of the illegal roles he played for you.

17

the first thing that he did for you?

18

the first thing?

Ms. Barzee did an excellent job summarizing a What was

Do you remember

19

A

I don't know.

20

Q

What kind of story do you have to tell

I go way back with Steve.

21

somebody to have them play a fake banker or a fake

22

plaintiff?

23 24 25

A

What did you tell him? None.

You have to understand Steve's history

to understand who you were dealing with. It would be like talking to -- knowing you're

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talking to a member of organized crime -- he wasn't a

2

member of organized crime -- but knowing you're talking

3

to a member of organized crime and knowing you don't

4

have to preface anything with any kind of nonsense to

5

get them to engage in criminal activity or to lessen

6

their knowledge.

7 8

With Steve, you could let him know everything that was going on.

9

Q

With respect to Caputi, is it your testimony,

10

then, that you don't recall having to lie to him in

11

order to get him to play any of those roles?

12

A

I certainly may have, but I didn't need to

13

tell Steve much.

14

friendship with him was such, I could pick up the phone

15

and say, Steve, I need you to play a banker.

16

wouldn't even ask me why.

Steve is the kind of guy, and my

17

Q

Okay.

18

A

-- you know.

He

He would just do it --

All I really needed to say to

19

him, Mr. Rabin was, I'll pay you for it; and he was all

20

good.

21

Q

William Cort.

22

A

Corte.

23

Q

Corte, was one of the -- your computer people,

24 25

correct? A

Yes.

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Q

Okay.

2

A

Yes.

3

Q

All right.

4

He set up a fake TD website?

What did you tell him was the

reason you needed a fake TD website?

5

A

I didn't need to tell him anything.

6

Q

So you just said, I need a fake TD website.

I

7

need it to look exactly like the real one; and, boom, he

8

did it?

9

A

Yes.

10

Q

Same thing for the other computer gentleman,

11

Curtis Renie?

12

A

Same answer.

13

Q

Okay.

14

A

I gave him money.

15

Q

Okay.

16

A

I don't recall.

17

Q

Was it in cash?

18

A

Yes.

19

Q

All right.

20

A

They were actually witnesses to each other's

21 22

And you never gave him any reason?

How much did you give each one of them?

Any witnesses to the payments?

payments, but other than that, I don't think so. Q

All right.

Wayne Koppel was another lawyer

23

who falsely claimed to -- according to you, had falsely

24

claimed to refer cases to your firm, correct?

25

A

My recollection is vague as to whether or not

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he was the one who sat in the meetings.

2

believe that he was the one who actually attended the

3

meetings with the hedge fund guys, so yes.

4 5 6 7 8 9 10

Q

All right.

I seem to

And what did you tell him in order

to get him to play that role? A

I didn't have to lie to him at all.

I believe

that Doug Bates and Russ Adler handled all that. Q

So you never made any false statements to him

in order to get him to play that role in your scheme? A

As I sit here today, other than telling him

11

what I needed him to say, I recall very little about

12

talking to him about anything having to do with this.

13

Russ Adler and Doug Bates handled that.

14

Q

All right.

Howard Herskowitz was another

15

lawyer that referred -- according to you, falsely

16

claimed to refer significant cases to you?

17 18 19 20 21 22 23 24 25

A

Not just according to me, it was according to

the people that he made the statements to. Q

What did you say to him in order to get him to

do that? A

I didn't say a word to him.

I never talked to

the man until I got there and he started lying for me. Q

All right.

And what you -- are you saying you

had to tell him nothing in order to get him to do that? A

I had Russ Adler handle it.

Russ Adler told

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him exactly what lies he needed to tell, and when he

2

showed up there, he told all the lies.

3 4 5

Q

So you had no conversations with him in terms

of what he was supposed to do; is that your testimony? A

I think, if you recall my prior testimony,

6

when I first walked in there, Mr. Herskowitz is the one

7

who said, it's nice to finally meet you, almost giving

8

me a coronary.

9

So, no, I had no prior conversations with him

10

about what he needed to do.

11

best of my knowledge, Mr. Adler.

12

Q

All right.

That was handled by, to the

Steve Rossi was another lawyer

13

that falsely claimed to refer cases, according your

14

testimony, correct?

15

A

Yes.

16

Q

All right.

17

Did you have the relationship with

him or somebody else?

18

A

Mr. Adler.

19

Q

Okay.

So did you have any conversations with

20

him about why he was to falsely verify that he sent

21

cases to your firm?

22

A

Through Mr. Adler.

23

Q

Were you witness to the conversations?

24

A

One of them.

25

Q

Tell me about that one conversation.

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A

I told Mr. Adler to call Steve Rossi and let

2

him know that I would do whatever I could to help him

3

with his political aspirations in exchange for assisting

4

us, and I was present during that conversation.

5

Q

All right.

Tracy Weintraub, you have talked

6

about him a number of times as preparing -- you talked

7

about him on a number of cases preparing false financial

8

statements?

9

A

Yes.

10

Q

What is it that you told him why you need the

11

false financial statements?

12 13

A

I told him here's $75,000; this is what I

need.

14

Q

And I assume that was cash?

15

A

It was.

16

Q

I assume there are no witnesses to it, other

17 18

than you and Mr. Weintraub? A

The only person that may be able to verify

19

that was a gentleman who brought me that cash.

20

recollection is he brought me that cash when I was ready

21

to take it up to him.

22 23

My

And I don't know if the government wants me to say the name.

24

MR. LAVECCHIO:

25

MR. RABIN:

Can I have a moment?

Sure.

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MR. SCHERER:

While we have a break, I

would like to --

3

MR. RABIN:

4

What's going on --

5

MR. SCHERER:

6 7

We don't have a break.

Well, I mean, they're just

talking, so -MR. RABIN:

Don't you want to wait until

8

the lawyers are involved can hear what you're

9

saying.

10 11 12

MR. SCHERER: administrative.

I mean, this is This is administrative.

I understand that the Pearson adversary

13

is going -- I don't know -- next, this

14

afternoon or tomorrow?

15

MR. LICHTMAN:

16

immediately after lunch.

17

the day.

18

No.

Levinson starts We'll go the rest of

And Pearson starts first thing tomorrow

19

and goes until the conclusion, when we stop at

20

1:00, and then we don't see Scott again.

21

MR. SCHERER:

Is it your --

22

THE WITNESS:

Hopefully not ever, not see

23

me again.

24

What kind of comment is that?

25

MR. LICHTMAN:

Well, in terms of this

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deposition.

2

MR. RABIN:

3

MR. LICHTMAN:

4

MR. SCHERER:

We'll see you again. In the deposition. Here's my issue:

I just

5

now have realized that we're anticipating

6

closing this record for my case; and then

7

you're going to start with Pearson, and it

8

will a separate record.

9

MR. LICHTMAN:

10 11

When we start with

Levinson. MR. SCHERER:

When you start with

12

Pearson, you intend to have that as a separate

13

record in your adversary?

14

MR. LICHTMAN:

15

MR. SCHERER:

Correct. I'm going to request that

16

when you get to Pearson, that this

17

transcript -- my record stays open, because

18

he's a defendant in this my case so that I'm

19

going to urge the Court that whatever you do

20

in that case is a part of my record.

21

MR. LICHTMAN:

I don't have any problem

22

with that, but I will not have time for

23

anybody to be questioning on the time allotted

24

that we have, except for me and for

25

Mr. Pearson's counsel.

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MR. SCHERER:

2

MR. NURIK:

Well -I'm going to ask for five

3

minutes at some time, and the basis for that

4

is because people have not complied with the

5

Court's order, as I articulated yesterday, in

6

providing their exhibits to the parties in

7

advance of this deposition in whole, being

8

that Mr. Rothstein is a party and I represent

9

him, and counsel was supposed to receive it, I

10

was denied the opportunity to have it and

11

Mr. Rothstein was denied the opportunity to

12

see it, and as such, I may have some clean-up

13

questions.

14

I will be brief, and in the process

15

Mr. Rothstein may be reviewing some of the

16

documents that were supposed to have been

17

previously provided to him.

18

And as such, I'm going to ask that the

19

record stay open and I have the opportunity

20

for five minutes.

21 22 23

MR. RABIN:

I'm going to give it to you

if we stop -MR. NURIK:

The problem, Sam, is I'm not

24

in the position to do that because he's still

25

reviewing them.

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I got a load last night of things that my

2

secretary was there very late just putting on

3

a disk, which I have now.

4

So, unfortunately, I'm going to ask that

5

at some point, since the record will remain

6

open, that I find five minutes to do that, and

7

I will be brief.

8 9

MR. RABIN: don't know.

Well, you know, again, I

The agreement is the agreement.

10

I don't know about keeping the record open

11

past the time limit set by the judge.

12

Mr. Lichtman may be able to speak to that

13

better than I can.

14

MR. LICHTMAN:

15 16

When do you think you

would be best suited to ask those question? MR. NURIK:

Ideally, by the end of the

17

day today, but certainly tomorrow morning, no

18

later than tomorrow morning.

19

have much of a chance beyond that.

20 21 22

I'm not going to

So I'll try -- endeavor to try to do it by the end of the day. MR. LICHTMAN:

I'm going to guess -- I

23

don't know -- that most people don't have an

24

interest in hearing the Levinson testimony.

25

Many people may have some interest in hearing

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the Pearson testimony. If that's the case, I'm happy to yield

3

five minutes when we begin tomorrow at 8:30 so

4

you can start and ask those questions and I

5

can go into Pearson.

6

MR. NURIK:

Okay.

7

MR. RABIN:

Thank you.

8

MR. HERTZBERG:

9 10

Okay.

All right.

On behalf of Platinum and

Centurion, this is Gabriel Hertzberg. We have no objection to what Mr. Lichtman

11

just proposed, that Mr. Nurik borrow five

12

minutes from Mr. Lichtman's time tomorrow.

13

There is a Court order that says that

14

this deposition is closed as of noon today.

15

MR. RASCO:

16

MR. HERTZBERG:

17

We have staffed this accordingly.

18 19

1:00 today. 1:00 today. We

have set travel plans accordingly. We object to any examination of

20

Mr. Rothstein by anyone, other Mr. Nurik for

21

the five minutes just discussed, tomorrow or

22

at any time after 1:00.

23 24 25

MR. SCHLESINGER:

We join in that

objection. MR. SCHNAPP:

On behalf of TD Bank, we

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also join.

2 3

MR. MULLIN:

Likewise on behalf of the

Morses.

4

MR. NURIK:

That is other than Mr. Nurik?

5

MR. RABIN:

Other than Mr. Nurik.

6

MR. HERTZBERG:

Other than Mr. Nurik for

7

the five minutes just discussed, we'd do

8

understand up Mr. Nurik and Mr. Scherer have a

9

common-interest relationship, or so they

10

purport; we would object to any examination of

11

Mr. Rothstein by Mr. Nurik as surrogate for

12

Mr. Scherer or for Mr. Lichtman or for anyone

13

else.

14 15

MR. NURIK:

Well, I can assure you -- I

can assure you he's not paying my fees.

16

MR. RABIN:

17

THE WITNESS:

18

All right.

Come on.

Go ahead, Mr. Rabin.

just ignore anybody else.

19

You go ahead and ask me questions.

20

MR. RABIN:

21 22 23

I'll

Thank you.

I appreciate

that. BY MR. RABIN: Q

Okay.

The last -- the question that was

24

pending before the government conferred with you and

25

all, can you get back to it?

I don't remember.

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A

2

witnesses --

3

Q

Tracy Weintraub?

4

A

-- to money going to Weintraub.

5

Q

Well, the last question I recall:

6 7 8

I can tell you.

You were asking me about

Did anybody

witness any of the payment of the 75,000? A

And my answer is someone witnessed me

receiving the money and taking it up to Mr. Weintraub.

9

Q

Did anybody witness the payment?

10

A

I don't believe this person was standing there

11

when I -- we only got as far as the door.

12

Q

Other --

13

A

So no.

14

Q

Other than the money that you claim that you

15

gave Mr. Weintraub, was there any other conversation

16

about what you wanted him to do or why?

17

A

As to what I wanted him to do?

18

Q

Yes.

19

A

Extensive conversation.

20

Q

Okay.

21

A

The only why that I recall giving him, without

And the why?

22

seeing the email traffic, is so that he could keep my

23

business and keep the business of Banyan and continue to

24

live well, a nice life.

25

MR. RABIN:

All right.

If I could have a

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moment, please.

2

I think --

3

MR. SCHERER:

I'm going to object to the

4

question, Sam, unless you can ask the witness

5

to identify who saw him get the cash so he can

6

have a complete answer, since I can't have any

7

more examination.

8 9

MR. RABIN: question.

10 11

I'm happy to ask that

MR. SCHERER:

Thank you.

BY MR. RABIN:

12

Q

Did you hear Mr. Scherer's question?

13

A

I'm sorry, no.

14

Q

Who was the person that witnessed you obtain

15

the cash that you claim that you gave to Mr. Weintraub?

16

MR. LAVECCHIO:

17

MR. RABIN:

18

MR. SCHERER:

19

22 23

So much for your question. Take all the joy out of

this.

20 21

Objection --

MR. LICHTMAN:

That seemed like a perfect

way to end the transcript. BY MR. RABIN: Q

One other area, just real fast, two questions.

24

You remember the Kroll project you discussed with Ken

25

Jenne?

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A

I don't.

2

Q

All right.

3

Did Ken Jenne ever propose to you

starting a business similar to Kroll's?

4

A

Yes.

5

Q

And what he -- what -- explain that to us,

6 7

what he was purposing in that. A

We were hiring a lot of retired law

8

enforcement at the time, former ABT agents, FBI agents,

9

IRS agents, and he wanted to put together something to

10

rival Kroll.

11

Q

And did that go beyond any discussions?

12

A

Other than him and I hiring people to kind of

13 14 15

get it started up, no. Q

And did Ken Jenne have any role in your

illegal activities?

16

A

No, sir.

17

Q

Other than, perhaps, that one occasion where

18

he carried boxes -- the Epstein boxes into your office

19

that people are claiming that he did?

20 21 22

A

No, sir. MR. RABIN:

He had no involvement. I'm going to cede the balance

of my time to Mr. Rasco.

23 24 25

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FURTHER DIRECT EXAMINATION BY MR. RASCO: Q

I have three or five minutes, Mr. Rothstein.

4

Is it your opinion or belief that Mr. Preve

5

was aware of the fraud, or do you know it for a fact?

6 7 8

MR. SCHERER: A

11 12

Based upon everything that I've seen and know,

it is a fact.

9 10

Object to form.

MR. SCHERER:

Withdraw my objection.

BY MR. RASCO: Q

Based on any witnesses that you can point to

that are aware that Mr. Preve knew of the fraud?

13

A

Mr. Szafranski.

14

Q

Beyond Mr. Szafranski?

15

A

Mr. Boden, Mr. Rosenfeldt.

16

Q

Is that it?

17

A

And me.

18

Q

Okay.

Do you remember the email we discussed

19

on Monday where you indicated that, Frank, you were

20

ending it; and he suggested that that was not the

21

solution and he urged you to come back and told you not

22

to run.

23

like, analogous before and asked you to come back.

24 25

He told you that he had been through something,

Do you remember that? A

Yes, I do.

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Q

If he was criminally involved, why would he do

that?

3

A

You'd have to ask him.

4

Q

Okay.

And you indicated earlier today that

5

there were literally hundreds of incriminating emails

6

between -- written by Frank; is that right?

7

A

I think there were thousands.

8

Q

Okay.

9

A

I haven't stopped to count them, but there

10 11 12

seemed to be an awful lot. Q

would he write so many emails that were incriminating?

13 14

If he was aware and involved in the crime, why

ALL PRESENT: A

Objection to form.

I told Frank on more than one occasion that I

15

thought he was going a little crazy with certain things

16

he was putting in the emails.

It never stopped him.

17

You'd have to ask him why he was doing it.

18

It seemed to me like he had some sort of

19

self-destructive mechanism because he put a lot of very

20

bad stuff in emails.

21

BY MR. RASCO:

22 23

Q

Earlier in your testimony you thought Frank

was a very smart person.

24

A

Extremely.

25

Q

If he was so smart, why would he be writing so

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many incriminating emails?

2 3

MR. LICHTMAN: A

4

Object to form.

I don't know. One thing I have learned over the course of

5

this crime, and since coming back, is that I had the

6

unfortunate experience of dealing with a lot of

7

extremely, extremely bright people who did some very,

8

very stupid things during the commission of a lot of

9

very bad crimes.

10 11 12

BY MR. RASCO: Q

You met Frank in August of 2007,

approximately, right?

13

A

I don't recall when I met him.

14

Q

Was it mid to late 2007, let's say?

15

A

Again, I don't recall the date I met him.

16

you have got to do is look and see when I started to

17

doing my very first business with George Levin and go

18

back 30 to 60 days.

19

frame.

20

me guess to it.

All

21

Q

22

years?

23

A

I would have met him in that time

We can establish it.

It makes no sense to have

Are you aware that he had known George for 30

I knew that he worked for George many years

24

before.

25

George, yes.

I knew that he left and came back to work for

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Q

And are you aware that he was friends with

George, not just working with George?

3

A

You know, I have, unfortunately, learned that

4

the word "friend" has a very interesting meaning in

5

criminal circles.

6

So, yeah, I believed that he was truly a

7

friend of George's; but the more I examine everything,

8

the more I come to realize he probably took tremendous

9

advantage of George.

10

Q

And are you aware that he, himself, invested

11

his own money and his family's money, not just his

12

immediate family's money?

13

A

Yes.

14

Q

And you knew that he knew that George stood to

15

lose hundreds of millions of dollars if this was a

16

fraud?

17

A

Yes, but his ultimate role was the same as all

18

of ours, just the like Morses and other people, that we

19

all hoped to get our money out.

20

The criminals, the people that are involved,

21

always hope to be able to be the ones recouping and, in

22

fact, gaining by the crime.

23

you know it could explode, you don't necessarily plan on

24

it.

25

MR. RASCO:

Okay.

You don't -- even though

Thank you.

No further

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questions. MR. LICHTMAN:

Why don't we then consider

3

the transcript closed, except for Mr. Nurik's.

4

examination?

5

MR. SCHERER:

And except for my request

6

to keep it open for the Pearson part of your

7

examination and the cross because I may need

8

it in my case.

9 10

MR. LICHTMAN:

Agreed.

MR. HERTZBERG:

I just want to note on

11

the record that the funds are relying on the

12

Court's order that the deposition --

13

(Court reporter interruption.)

14

MR. HERTZBERG:

The funds are relying on

15

the Court's ordered that the deposition is

16

concluded as of 1:00 p.m. today.

17

will not have representation for any further

18

examination of Mr. Rothstein in reliance on

19

that order.

20

questions asked by Mr. Nurik and reserve them

21

as such.

The funds

We object to the form of all

22

That's all.

23

(Thereupon, at 12:00 a.m., the proceedings

24 25

Thank you.

were adjourned.) -

-

-

-

-

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C E R T I F I C A T E

2 3

THE STATE OF FLORIDA, ) COUNTY OF BROWARD. )

4 5

I, Michele L. Savoy, Shorthand Reporter do

6

hereby certify that I was authorized to and did

7

report the foregoing proceedings and that the

8

transcript is a true record.

9

Dated this 22nd day of December, 2011.

10 11

______________________________

12

Michele L. Savoy, RPR Notary Public - State of Florida My Commission No. EE 113173 Expires August 6, 2015

13 14 15 16 17 18 19 20 21 22 23 24 25

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C E R T I F I C A T E THE STATE OF FLORIDA, ) COUNTY OF BROWARD. )

3 4

I, Michele L. Savoy, Shorthand Reporter,

5

do hereby certify that I was authorized to and did

6

report said deposition in stenotype; and that the

7

foregoing pages, numbered from 2345 to 2517,

8

inclusive, are a true and correct transcription of

9

my shorthand notes of said deposition.

10

I further certify that I am not an

11

attorney or counsel of any of the parties, nor am I

12

a relative or employee of any attorney or counsel or

13

party connected with the action, nor am I

14

financially interested in the action.

15

The foregoing certification of this

16

transcript does not apply to any reproduction of the

17

same by any means unless under the direct control

18

and/or direction of the certifying reporter.

19

Dated this 22nd day of December, 2011.

20 21 22 23

___________________________________ Michele L. Savoy, RPR Notary Public - State of Florida My Commission No. EE 113173 Expires August 6, 2015

24 25

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2412:21 2418:22 attracting (1) 2417:20 audit (12) 2360:15 2362:12 2365:10 2389:10,11 2389:14,16,18 2391:1 2412:13 2460:3,3 audited (2) 2362:15 2366:11 auditor (1) 2360:12 august (4) 2482:4 2512:11 2516:13 2517:23 authorities (1) 2471:6 authority (1) 2377:7 authorize (1) 2377:4 authorized (2) 2516:6 2517:5 ave (1) 2351:3 avenue (5) 2345:23 2348:8 2350:2,14 2418:13 avenues (1) 2417:9 avoid (5) 2421:10,12 2458:25 2460:3 2464:24 aware (18) 2359:16 2361:19 2371:25 2374:14 2383:20 2389:7 2390:7,14 2391:7 2391:11 2481:5 2495:12 2510:5,12 2511:11 2512:21 2513:1,10 awareness (1) 2366:15 awful (1) 2511:10 B b (15) 2347:16 2438:9 2439:2,3,7,12,14,18 2439:21,25 2440:3 2440:7,10,14,16 back (46)

United Reporting, Inc. (954) 525- 2221

2359:2 2364:15 2370:7,11,12 2373:5 2376:20 2382:4 2384:10 2389:24 2405:11 2421:2 2429:1 2430:5 2431:3 2435:19 2441:13 2442:9,14,19 2443:8,12,16,18,23 2444:6 2446:12,16 2446:18 2447:9 2448:7 2459:3 2463:11 2470:23 2474:9 2475:19 2476:12 2479:18 2492:8 2495:19 2506:25 2510:21,23 2512:5,18,24 backwards (1) 2460:15 bad (8) 2355:10 2362:18 2403:14 2435:6 2456:6,9 2511:20 2512:9 bag (1) 2380:13 bail (6) 2380:22 2381:2,4,7,9 2381:10 balance (10) 2361:5,8,18 2368:11 2369:14,19,20 2372:22 2373:6 2509:21 balances (14) 2369:23 2371:8,11,16 2372:4 2373:4 2374:12 2375:4,13 2377:4 2386:9,10 2386:15 2390:23 balancesheet (1) 2360:15 bank (33) 2346:13,14,17,20 2348:12 2354:2,9 2361:5 2370:1 2373:4 2374:15,15 2412:7,9 2452:23 2465:8 2476:7 2480:25 2481:1,20 2482:24 2483:4,4 2483:10 2484:2,9 2484:23 2485:12,16

2485:18 2486:8 2487:13 2505:25 banker (4) 2414:14 2453:3 2495:21 2496:15 bankers (1) 2408:1 banking (2) 2362:12 2387:23 banter (1) 2426:12 banyan (15) 2361:5 2362:12,14 2364:10 2365:10 2366:4 2371:1,14 2379:7 2386:24 2389:7 2390:7 2391:22 2392:7 2507:23 bar (13) 2378:13 2379:3 2395:18,20,22 2396:1 2408:8 2415:1 2426:4,12 2467:14,19 2468:2 barnett (2) 2492:12 2493:1 barry (2) 2379:10 2466:21 bart (1) 2351:4 barzee (1) 2495:15 barzeeflores (59) 2350:20 2352:4 2393:16 2394:24 2395:4,10 2396:13 2396:17,20 2398:14 2400:19 2403:10 2404:2 2405:16 2409:23 2410:5,11 2422:5,21,24 2423:3,17,18 2424:9 2425:1,8,16 2425:24 2426:14,17 2427:4 2428:25 2429:9,21,24 2430:3,8,10,14 2431:1 2437:24 2439:15 2445:18,24 2447:17 2449:5,17 2452:17 2453:10 2454:1,8,12,17 2456:18,22 2457:8 2457:12,17 2458:3

Page 3 base (1) 2366:17 based (23) 2354:2 2356:20 2358:14 2361:11 2367:3 2369:25 2370:2,6 2382:19 2391:4 2416:19 2423:12 2447:1 2452:6,16 2453:7 2457:5 2465:20 2485:10,15 2493:8 2510:7,11 baseless (1) 2355:10 basically (1) 2469:12 basis (3) 2353:25 2363:11 2503:3 bate (1) 2362:9 bates (12) 2493:19,19,22 2494:7 2494:12,15,20,23 2495:2,7 2498:7,13 battista (1) 2347:13 beat (2) 2426:1,5 beautiful (1) 2391:2 beckman (1) 2350:9 bed (1) 2399:6 began (1) 2358:22 beginning (2) 2478:25 2489:24 begins (1) 2362:10 behalf (12) 2353:9 2354:10 2438:24 2448:19,20 2448:22,25 2449:3 2449:13 2505:8,25 2506:2 bekkedams (1) 2379:10 belief (2) 2444:3 2510:4 beliefs (2) 2403:9 2405:9 believe (22)

2382:23 2389:23 2405:1 2429:24 2430:1,15 2431:11 2433:21 2446:20 2448:11 2450:11 2452:9 2453:5 2467:11 2476:24 2477:23 2485:10 2490:2 2494:5 2498:2,6 2507:10 believed (12) 2368:18 2384:1 2432:8 2435:3 2444:5,16 2446:19 2488:24 2489:7,12 2492:25 2513:6 believing (1) 2490:4 belt (1) 2454:7 bench (1) 2396:18 benefactors (1) 2419:4 benefit (1) 2421:4 benefited (1) 2364:14 benefits (1) 2421:4 berenfeld (1) 2364:25 berga (1) 2350:15 berger (2) 2347:10 2494:20 bernie (2) 2442:20,24 best (20) 2358:2 2360:13 2398:2 2411:24 2427:10,19 2461:4 2461:21 2464:7,11 2464:11 2467:5,20 2471:12 2476:25 2477:6 2487:22 2488:10 2499:11 2504:15 better (3) 2440:2 2494:12 2504:13 beyond (4) 2389:3 2504:19 2509:11 2510:14 big (5)

2355:6 2365:3 2389:17 2432:10 2440:6 bill (4) 2374:1 2411:18 2454:11 2465:24 billing (1) 2349:22 billion (2) 2372:11,12 bills (5) 2391:9,16,20 2392:7 2412:15 binder (1) 2377:1 biscayne (3) 2348:3,3 2349:14 bit (3) 2357:10 2415:14 2486:25 black (3) 2349:19 2473:4,5 blanche (1) 2483:22 blew (1) 2470:22 block (2) 2406:15,23 blocked (1) 2392:4 blur (1) 2449:25 blurb (2) 2370:5,7 blvd (4) 2348:13 2349:14,22 2351:8 board (1) 2494:14 boats (1) 2418:2 bob (1) 2432:10 boca (1) 2349:11 boden (13) 2357:20 2387:6 2462:20,25 2463:24 2464:12,22 2489:19 2491:16 2492:23,24 2493:10 2510:15 bodens (2) 2462:21 2493:8 bodner (1) 2350:5

United Reporting, Inc. (954) 525- 2221

body (2) 2384:12 2405:9 bodyguard (1) 2432:7 bonds (1) 2412:17 boockvor (1) 2481:8 bookkeeper (1) 2479:18 books (1) 2389:14 boom (1) 2497:7 borrow (2) 2392:10 2505:11 boston (1) 2350:10 botched (2) 2438:23 2439:1 bottom (2) 2367:10 2372:18 bought (6) 2454:2,5,5,6,14,18 boulevard (6) 2347:5,10,23 2348:3 2418:7,9 bova (2) 2431:10,13 boxes (2) 2509:18,18 brand (1) 2418:23 brass (1) 2419:8 break (7) 2375:22 2392:15 2426:18 2461:3 2463:4 2501:1,3 bribed (1) 2421:22 brickell (3) 2350:14 2351:12,15 brief (3) 2484:22 2503:14 2504:7 briefed (1) 2467:24 bright (2) 2466:18 2512:7 bring (5) 2356:6,7 2385:17 2392:8,11 bringing (1) 2494:10

brought (3) 2454:7 2500:19,20 broward (11) 2345:2 2346:2 2347:5 2351:8 2396:10 2418:6,7,8 2419:3 2516:3 2517:2 bs (1) 2404:23 bsa (2) 2484:17,19 bso (1) 2419:8 buck (1) 2478:14 bucks (1) 2419:21 building (1) 2345:17 bulk (1) 2435:2 burn (1) 2362:18 bush (1) 2395:16 business (19) 2366:4,4,5 2387:4 2400:25 2401:3 2414:23 2439:13 2461:12,24 2481:21 2488:2 2493:21 2494:5 2495:4 2507:23,23 2509:3 2512:17 C c (5) 2347:15 2516:1,1 2517:1,1 cabello (2) 2467:12,21 cace (1) 2346:3 california (1) 2395:11 call (10) 2355:6 2357:11 2415:17 2420:14 2440:3,3,10 2462:23 2467:7 2500:1 called (9) 2384:25,25 2420:19 2431:21 2476:14 2479:19 2491:2,7

Page 4 2491:11 calling (1) 2385:7 campaign (1) 2478:17 candidate (1) 2395:14 candidates (1) 2396:23 cant (15) 2355:18 2358:19 2360:21 2368:20 2369:4,8 2426:16 2433:25 2453:18 2456:8 2471:18 2478:3 2488:6 2493:25 2508:6 capable (3) 2404:12,16,18 capacity (2) 2429:22 2431:2 capital (4) 2346:22 2349:13 2353:9 2354:24 caputi (8) 2414:3,4,11,14,21 2495:14,15 2496:9 card (2) 2406:13,18 care (2) 2404:21 2471:2 careful (6) 2459:2 2465:22 2466:3,5,10 2472:18 carefully (1) 2384:16 caretsky (4) 2349:21 2481:2,9,14 carol (3) 2346:4 2407:3 2439:17 carried (1) 2509:18 cars (2) 2408:22 2418:1 carte (1) 2483:22 case (19) 2345:3 2346:3,10 2354:22 2355:6 2407:5 2411:12 2412:17 2413:20 2415:3 2417:4 2445:10 2455:21,25

2502:6,18,20 2505:2 2514:8 cases (13) 2354:14 2439:16 2461:12,25 2473:11 2475:6,7 2478:18 2497:24 2498:16 2499:13,21 2500:7 casey (1) 2349:15 cash (15) 2440:7 2459:17,17,19 2459:23,25 2468:20 2477:12,13 2497:17 2500:14,19,20 2508:5,15 caught (1) 2416:8 causes (1) 2402:22 causing (1) 2362:15 cede (1) 2509:21 celebrities (1) 2418:17 centurion (5) 2346:18 2348:1 2350:1 2370:15 2505:9 ceo (4) 2439:22 2484:5,7,8 certain (31) 2357:9,23 2358:7,16 2360:23 2367:2,4 2368:20 2371:20 2381:15 2390:10 2391:9 2392:7 2398:13 2401:17 2402:20 2416:11 2420:20 2425:13 2426:20 2456:2 2460:23,24,25 2466:1 2488:1,2 2489:2 2490:17,21 2511:15 certainly (20) 2362:3 2375:3,5 2381:9 2396:3 2398:20 2399:3 2416:22 2426:7 2434:6 2435:15 2436:17,19 2438:8 2446:25 2452:21 2453:11 2483:23

2496:12 2504:17 certainty (1) 2456:10 certificate (2) 2352:8,8 certification (1) 2517:15 certify (3) 2516:6 2517:5,10 certifying (1) 2517:18 cetera (2) 2362:16,16 cfo (1) 2439:11 chamorro (1) 2350:16 chance (2) 2393:25 2504:19 change (6) 2382:6,7 2386:15 2403:25 2405:1 2472:20 changed (2) 2403:22,25 changing (1) 2372:4 chapter (1) 2347:8 charge (1) 2487:15 charitable (2) 2346:21 2419:2 charles (1) 2347:12 charlie (2) 2395:8 2397:1 charming (3) 2435:23,24 2436:21 charts (1) 2389:13 chase (1) 2348:19 check (3) 2452:23 2476:3 2477:12 chief (1) 2479:7 children (1) 2471:2 christopher (1) 2350:15 chronological (1) 2393:12 chuck (1)

United Reporting, Inc. (954) 525- 2221

2494:22 cigars (1) 2409:3 cimo (1) 2347:15 circle (2) 2357:12 2397:4 circles (1) 2513:5 circuit (8) 2345:1,1 2346:1,1 2472:24 2473:1,7 2473:18 cite (2) 2448:1,3 civil (2) 2446:14 2447:4 claim (2) 2507:14 2508:15 claimed (6) 2485:15,17 2497:23 2497:24 2498:16 2499:13 claiming (1) 2509:19 clarification (4) 2422:12 2424:4 2425:12 2429:20 clarify (2) 2356:25 2458:11 clarity (1) 2376:6 classic (1) 2436:13 clausin (1) 2348:18 clean (5) 2381:22,25 2384:21 2438:12 2493:11 cleaned (1) 2389:23 cleanup (1) 2503:12 clear (7) 2358:10 2362:20 2388:15 2392:18 2449:9 2483:14 2489:13 clearly (7) 2358:12 2376:4 2380:6,9 2384:2 2435:7 2436:5 clerk (1) 2431:7 client (4)

2363:8 2394:8,12 2415:4 clients (9) 2394:6 2412:2 2434:12 2438:11,18 2441:5 2453:14 2476:4 2481:19 clifford (1) 2393:25 clinical (1) 2436:14 clinton (1) 2411:18 close (5) 2397:4 2432:7,10 2443:2,2 closed (2) 2505:14 2514:3 closer (1) 2353:17 closes (1) 2458:8 closest (2) 2397:14 2398:15 closing (1) 2502:6 clothes (1) 2454:2 cochran (1) 2349:22 coconspirators (14) 2357:6,7,13 2359:10 2359:17 2406:14,21 2407:23 2413:3,20 2415:16 2416:18 2436:11 2441:16 cohn (13) 2354:22 2416:20,24 2417:4,17,19 2418:15 2419:10 2449:24 2450:16 2455:8,12 2457:2 collapsing (1) 2384:8 colt (1) 2350:2 columbia (1) 2348:17 com (1) 2442:4 come (23) 2370:12 2384:21 2388:7 2429:1 2430:5 2438:12 2441:13 2442:8,14

Page 5 2442:19 2443:12,23 2444:6 2446:16 2453:12 2459:10 2462:23 2482:1 2488:14 2506:16 2510:21,23 2513:8 comes (2) 2447:9 2451:22 coming (8) 2381:22,25 2382:4 2384:10 2461:23 2479:4 2488:1 2512:5 command (2) 2359:15 2475:17 commencing (1) 2355:8 comment (2) 2403:1 2501:24 comments (2) 2389:17,20 commerce (3) 2372:22 2373:4 2374:15 commercial (1) 2475:25 commissary (2) 2454:19,22 commission (5) 2396:11,22 2512:8 2516:13 2517:23 commit (8) 2358:22 2421:7 2432:5,15 2440:2 2460:14 2469:23,24 commitment (2) 2434:22 2435:3 committed (8) 2381:11 2420:11,12 2432:3,12 2436:4 2442:16 2459:12 committee (5) 2348:6 2395:23 2396:2,5,8 committing (7) 2358:12 2398:11 2406:24 2426:21 2432:21 2436:22 2466:17 common (1) 2464:5 commoninterest (1) 2506:9 communicated (1) 2441:15

community (1) 2418:18 company (6) 2346:14 2348:17 2349:1 2438:24 2439:8,23 compensation (1) 2476:16 complaint (1) 2354:15 complete (2) 2431:20 2508:6 completely (6) 2355:9 2377:17 2382:6 2389:13 2448:15 2458:18 completing (1) 2389:17 complicated (1) 2475:20 complied (1) 2503:4 component (1) 2417:19 composite (2) 2377:1 2379:14 computer (2) 2496:23 2497:10 con (7) 2393:23 2398:8 2399:8 2400:12,21 2405:17 2412:25 conartists (1) 2416:9 concealed (1) 2485:7 concerned (6) 2425:13 2469:5 2471:3,5 2472:2,3 concerning (4) 2355:16 2403:8 2486:4,13 concerts (1) 2409:5 concluded (1) 2514:16 conclusion (1) 2501:19 conclusions (1) 2388:8 concocted (1) 2490:23 conduct (2) 2397:21 2460:13 conducting (1)

2485:8 conferred (1) 2506:24 confidant (1) 2467:9 confidante (1) 2432:19 confidantes (1) 2397:14 confident (1) 2436:5 confidential (1) 2406:17 confidentiality (3) 2406:13,22 2411:22 confirm (2) 2364:19 2388:21 confirmation (1) 2365:15 conflict (1) 2494:25 confused (1) 2485:25 confusion (2) 2370:8,9 congress (1) 2418:12 connected (1) 2517:13 connections (1) 2418:5 conned (15) 2393:20 2394:15,18 2394:20 2395:18 2396:10 2397:2,11 2398:2,7,12,15,19 2399:2 2436:7 conning (2) 2398:8 2436:22 conrad (1) 2347:19 cons (1) 2416:12 conscious (6) 2429:12 2440:19 2442:10 2444:20 2458:24 2459:7 consider (5) 2452:7 2453:17,19,19 2514:2 considers (2) 2451:21 2453:23 constantly (2) 2418:16 2432:20 consulted (1)

United Reporting, Inc. (954) 525- 2221

2466:16 contact (1) 2356:20 contacts (1) 2427:2 contain (1) 2390:19 contained (2) 2367:13 2483:21 contents (2) 2389:11 2477:1 context (3) 2410:16,17 2486:17 continuation (1) 2440:4 continue (6) 2411:2 2432:1 2461:24 2465:5 2469:7 2507:23 continued (1) 2352:2 continuing (1) 2469:5 contributions (1) 2418:21 control (5) 2360:7,22,23,24 2517:17 conversation (14) 2365:17,19 2374:19 2374:20 2465:24 2484:20,22 2485:15 2485:17 2491:15 2499:25 2500:4 2507:15,19 conversations (26) 2357:25 2358:16 2360:3 2365:21 2367:5 2426:20 2432:14 2464:10,14 2464:16,17 2465:22 2466:16,20,24 2467:4 2470:15 2481:10 2483:24 2484:11 2493:2,5 2499:3,9,19,23 convince (8) 2401:11,20,22 2402:1 2402:17 2449:13 2461:23 2481:19 convinced (5) 2398:4 2401:14,16 2402:3,5 cooked (1) 2408:7

cooperating (2) 2443:21 2447:5 cooperation (10) 2444:21 2447:1,2 2452:14,15,16,20 2452:20,21 2453:9 coordinated (1) 2415:25 copy (2) 2389:15,16 coquina (1) 2450:7 coral (2) 2347:24 2349:3 coronary (1) 2499:8 corporate (1) 2387:23 corporatepaper (1) 2466:18 correct (59) 2367:2 2370:1 2371:6 2372:14 2373:6 2379:5,8,20 2385:12 2393:22 2398:12,13 2399:7 2401:5,7 2408:9 2409:18 2414:2 2416:3 2417:3,10 2417:13,18 2418:9 2418:20,25 2419:5 2419:9,12,16 2427:18,21 2432:4 2434:23 2440:10 2441:18 2453:2 2458:22 2461:12 2467:15 2468:24 2471:10 2472:1 2480:16 2481:2 2482:2 2484:24 2485:8,20 2486:7,9 2490:7 2494:5,17 2496:24 2497:24 2499:14 2502:14 2517:8 corrected (2) 2389:21,25 corrupt (8) 2396:14 2401:18,24 2402:6 2408:15,16 2428:10,11 corrupting (1) 2401:18 corruption (5) 2401:18,24 2402:6

Page 6 2421:13,16 cort (1) 2496:21 corte (3) 2465:24 2496:22,23 cotzen (2) 2351:11,13 couldnt (5) 2365:10 2385:17 2401:4 2468:1,3 counsel (14) 2347:1,1 2353:6,11 2353:18 2356:3 2378:4 2390:9 2392:22 2462:22 2502:25 2503:9 2517:11,12 counselling (1) 2443:15 count (3) 2435:13 2457:16 2511:9 country (4) 2382:3 2440:20,21 2441:2 county (4) 2345:2 2346:2 2516:3 2517:2 countys (1) 2419:3 couple (4) 2455:4 2463:21 2484:21 2491:7 course (15) 2406:16 2407:18 2412:25 2414:9 2429:13 2444:8 2459:11 2460:17 2463:18 2464:6 2476:18 2478:18,21 2488:14 2512:4 court (29) 2345:1 2346:1 2353:16 2354:5 2355:13,18 2373:12 2376:10,13,20 2396:23 2411:4 2412:17 2413:5,8 2439:19 2450:19 2451:10,11,20 2453:17 2454:10 2472:24 2473:1,5,7 2502:19 2505:13 2514:13 courtroom (1)

2345:18 courts (3) 2503:5 2514:12,15 covered (1) 2487:2 craig (1) 2349:24 crap (2) 2426:1,5 crawled (1) 2399:5 crazy (3) 2387:7 2480:19 2511:15 create (11) 2370:16 2374:6 2386:4,13,18 2387:1,18 2401:6 2406:15,23 2439:19 created (8) 2385:21 2386:3,6,7 2386:12 2412:3,6 2419:8 creating (4) 2360:8 2386:11,16 2389:1 credit (5) 2361:10,16,17,25 2446:21 creditors (1) 2348:7 crime (35) 2357:5 2358:3 2359:11 2364:14 2381:11 2405:22 2406:1,4,8,24 2407:23 2408:2 2409:13,14 2422:9 2422:25 2423:2 2425:4 2428:9 2438:13 2440:2 2443:1 2457:2 2469:13,22,23 2491:25 2492:20 2493:1 2496:1,2,3 2511:11 2512:5 2513:22 crimes (16) 2398:11,12 2399:21 2417:17 2419:14 2422:13 2426:21 2427:16 2429:13 2432:21 2440:18 2442:16,18 2443:7 2465:18 2512:9

criminal (27) 2387:5,12 2397:7,19 2397:21 2402:9 2428:8 2435:22 2436:4,22 2439:8 2439:24 2440:4 2447:2,3 2469:18 2475:19 2476:2,11 2479:1,5,6 2483:15 2483:18 2488:6 2496:5 2513:5 criminality (4) 2400:2 2407:24 2426:3,8 criminally (1) 2511:1 criminals (4) 2407:19 2439:13 2440:9 2513:20 crist (2) 2395:8 2397:1 cross (1) 2514:7 crossexamine (1) 2354:3 crucial (1) 2402:8 currently (1) 2407:25 curtis (4) 2350:2 2374:1 2465:23 2497:11 cusick (4) 2349:15 2353:6,18 2355:11 cut (3) 2361:14 2391:22,22 cutting (1) 2451:2 cynthia (1) 2351:9 D dad (1) 2398:24 dan (1) 2349:24 danger (1) 2472:4 dare (1) 2407:7 dark (4) 2357:6 2488:8 2491:13,17 darkness (1)

United Reporting, Inc. (954) 525- 2221

2435:18 data (3) 2362:12 2365:2 2366:18 date (5) 2345:16 2354:8 2355:12 2359:1 2512:15 dated (6) 2362:8 2367:8 2368:6 2372:17 2516:9 2517:19 dates (3) 2350:20 2376:8 2393:9 daughter (1) 2439:11 david (15) 2347:15 2350:5 2357:20 2462:20,20 2462:25 2463:10,24 2464:21 2466:17 2467:9 2491:16 2492:23 2493:8,10 day (13) 2345:12 2347:1 2382:16 2390:6 2411:25 2433:2,13 2486:3 2501:17 2504:17,21 2516:9 2517:19 days (12) 2356:23 2363:10 2375:20 2384:15 2405:17 2433:15 2457:16,18 2463:21 2464:6,6 2512:18 de (1) 2347:23 deal (5) 2365:14,20 2370:4,5 2386:22 dealing (2) 2495:24 2512:6 deals (7) 2364:12 2369:25 2370:13 2371:1 2386:23 2391:9 2405:18 dear (1) 2493:4 death (1) 2427:25 deaths (2) 2432:24 2433:1

deb (3) 2357:19 2470:14,18 debra (18) 2377:4 2386:13 2397:13 2427:10,12 2427:15,19 2428:15 2428:19 2469:1,5,6 2469:17 2471:2,17 2471:22 2480:12,14 decade (1) 2358:1 deceive (1) 2490:4 december (10) 2345:16 2359:2,4,5 2394:9 2407:6 2409:24 2455:6 2516:9 2517:19 decent (4) 2398:18 2402:4 2435:2,4 deception (1) 2495:7 decide (5) 2423:14 2442:19 2444:23 2445:9 2446:2 decided (3) 2404:24 2443:12,20 deciding (1) 2441:13 decision (16) 2382:2,5 2384:21 2429:12 2431:22 2440:19,24 2441:1 2442:10,14 2443:23 2444:5,20 2450:12 2452:6 2465:19 decisions (1) 2440:25 declared (1) 2459:21 decreasing (1) 2420:13 deep (1) 2417:20 defend (1) 2428:17 defendant (1) 2502:18 defendants (3) 2345:9 2346:9,15 defense (3) 2387:5,12 2407:1 defer (2)

Page 7 2429:19 2430:17 define (3) 2381:7 2386:12 2481:3 definitely (4) 2388:12,12 2435:10 2436:2 definition (1) 2386:16 definitive (1) 2382:17 definitively (1) 2383:11 delicate (2) 2480:8 2491:13 demand (1) 2418:24 denied (2) 2503:10,11 dennis (1) 2479:22 deny (3) 2428:2,3 2432:23 department (2) 2351:7 2418:8 depended (3) 2405:25 2406:10 2408:2 depending (4) 2405:21 2406:3,7 2490:18 depose (6) 2353:11,13,21 2354:7 2355:14 2356:19 deposed (2) 2433:2,13 deposition (25) 2345:13 2347:2 2352:2 2353:10,14 2353:15,21 2354:13 2354:17 2355:13 2433:10,25 2459:11 2460:17 2476:19 2478:21 2488:14 2502:1,3 2503:7 2505:14 2514:12,15 2517:6,9 depositions (3) 2355:5,7,16 describe (3) 2378:18 2384:13 2397:13 described (3) 2416:20 2461:10 2494:4

describing (1) 2493:9 description (1) 2352:11 deserve (2) 2451:16 2453:14 deserved (1) 2449:14 desire (1) 2458:24 despite (2) 2441:1 2443:17 destroying (1) 2384:9 destruction (1) 2440:8 detailed (4) 2365:2 2383:18 2466:20,24 details (2) 2419:6 2424:21 detect (2) 2406:24 2465:18 detection (1) 2362:24 determination (2) 2450:10 2451:22 determine (4) 2371:23 2405:3 2452:7 2460:4 determined (1) 2447:22 deutsch (2) 2349:9,11 developed (2) 2416:16 2460:16 devout (1) 2402:24 diagnosis (1) 2436:24 diaz (1) 2350:13 didnt (67) 2357:15,25 2358:4,11 2360:11 2361:14 2364:2,3 2366:23 2370:23,24 2385:13 2393:18 2394:9,16 2394:18 2395:18 2396:11 2397:2,9 2397:10,10,11 2398:2,22 2399:1,9 2399:24 2403:15 2408:18 2409:25 2410:23 2411:15,17

2413:6 2419:24 2422:20 2424:10,23 2428:12 2432:1,25 2437:10 2439:18,25 2442:19 2444:20 2446:12 2459:22,25 2460:14 2465:23 2466:11 2468:11,12 2469:11 2475:13 2477:2 2479:15 2480:9 2483:24 2494:11,24 2496:12 2497:5 2498:6,21 die (3) 2443:17 2444:3 2445:8 different (4) 2386:15 2461:5 2480:25 2483:5 differentiated (1) 2424:6 differently (1) 2482:8 difficult (1) 2399:18 diligence (3) 2394:4,10 2415:10 dinners (1) 2419:6 direct (8) 2352:3,3 2356:14 2389:10 2393:15 2458:13 2510:1 2517:17 directed (1) 2369:3 direction (1) 2517:18 directly (1) 2371:8 discovered (4) 2394:5,11 2479:2 2488:25 discrete (1) 2355:5 discuss (1) 2495:5 discussed (15) 2357:1 2358:15 2360:10 2361:3,4 2367:3 2374:23 2388:21 2396:3 2427:14 2429:25 2505:21 2506:7 2508:24 2510:18

United Reporting, Inc. (954) 525- 2221

discussing (1) 2364:16 discussion (8) 2361:6 2375:15 2426:21 2433:3,5 2433:14 2437:3 2493:15 discussions (4) 2355:15 2443:13 2483:14 2509:11 disgusting (6) 2428:4,5,7,14 2429:2 2429:5 disk (1) 2504:3 disorder (3) 2437:2,7,13 displayed (1) 2417:25 district (1) 2396:23 divers (1) 2349:18 dixie (1) 2349:2 doctor (3) 2437:12 2438:2 2453:2 doctors (1) 2437:19 doctrine (1) 2440:7 document (9) 2368:1 2376:5 2386:13,17,19 2387:18 2388:15 2389:25 2412:6 documentation (1) 2362:2 documented (1) 2360:17 documents (26) 2356:4 2361:11 2365:7 2376:1,2,11 2385:21,24 2386:3 2386:5,22 2388:4 2388:17,23,24 2389:5 2390:25 2393:13 2411:12 2468:23 2469:3 2470:16,17,18 2471:4 2503:16 doesnt (7) 2363:12 2377:7 2386:14 2423:7

2451:12 2460:5 2478:1 doing (33) 2357:12,16 2360:9 2371:4 2383:16 2384:14,14 2385:1 2388:20 2391:14 2396:4,8,21 2404:12,16 2416:7 2416:17,18 2428:14 2439:12 2465:17 2469:10,11,25 2471:23 2479:10,14 2481:11 2484:12,13 2495:9 2511:17 2512:17 dollar (1) 2418:1 dollars (8) 2368:11,22,23 2372:11,12 2387:9 2460:8 2513:15 don (1) 2346:25 donations (2) 2402:21 2419:1 donna (1) 2348:15 dont (141) 2355:6 2356:18 2359:7 2360:4,25 2361:21 2362:3 2368:20,25 2375:16 2375:18 2376:1 2377:16 2378:5,10 2378:11,17 2379:11 2380:3 2381:2,6,24 2382:4,11,16,23 2384:22 2388:10,20 2390:5 2391:13 2393:6 2400:16 2403:20 2404:7,21 2405:6 2407:2,18 2409:21,21 2410:8 2410:24 2412:3,5 2419:18,18,20 2420:13 2422:10 2424:6,7 2430:21 2431:11,18 2432:18 2436:15 2439:3,13 2440:16 2441:23 2442:7 2443:6 2445:7 2447:3 2449:20,23 2450:17 2450:17,20 2451:7

Page 8 2452:13,15 2455:14 2455:14,18,21,22 2456:2 2457:13,19 2462:7,13,14 2464:1 2470:13,15 2471:1,12 2473:3 2475:8,8 2476:13 2477:23 2480:17,22 2482:6,12,13,17,21 2482:21 2483:21 2485:11 2486:12 2487:15 2488:9,10 2488:11,12 2489:5 2489:5 2490:24 2492:16,19,23,25 2495:19 2496:3,10 2497:16,21 2500:22 2501:3,7,13,20 2502:21 2504:9,10 2504:23,23 2506:25 2507:10 2509:1 2512:3,13,15 2513:22,23 2514:2 door (1) 2507:11 doubt (1) 2374:25 doug (11) 2493:19,19,22 2494:11,15,19,23 2495:2,7 2498:7,13 dr (1) 2350:10 drafted (1) 2476:23 drafting (1) 2468:23 drag (1) 2428:16 dress (1) 2414:16 dressed (1) 2414:18 drilling (1) 2346:23 drug (1) 2438:5 due (4) 2392:7 2394:4,10 2415:10 duly (1) 2355:25 dying (4) 2380:17 2384:11 2438:7 2445:6

E e (12) 2345:18,23 2347:13 2348:4,13 2349:7 2349:22 2351:8 2516:1,1 2517:1,1 earlier (4) 2363:9 2450:2 2511:4 2511:22 early (5) 2465:13 2488:24 2489:12 2490:17,18 earned (1) 2454:20 easier (1) 2464:4 east (2) 2347:5,10 easy (1) 2439:8 eat (1) 2354:18 ed (5) 2407:3 2439:16,22 2474:9,10 educate (2) 2450:11 2451:10 edward (2) 2346:4 2413:21 ee (2) 2516:13 2517:23 effect (2) 2377:9 2468:3 eight (4) 2356:23 2363:9 2463:20 2464:6 eighth (1) 2347:20 eisinger (3) 2479:19,20,23 either (7) 2368:19 2375:4 2380:16 2440:15 2461:12 2483:18 2491:15 elder (1) 2473:25 eliot (1) 2350:4 elite (1) 2417:9 ellis (4) 2483:7,8,9,25 email (80) 2356:21 2358:9,15,24

2359:8,13 2360:17 2360:20 2361:3,3 2361:22 2362:10,10 2363:19,21 2364:15 2364:17 2367:7,14 2368:5,19 2369:1,2 2370:18,19 2372:9 2372:10,12,14,16 2372:21 2374:12,19 2375:10,16 2376:24 2377:16 2378:17 2379:12,13,17,24 2380:20,21 2381:12 2382:9,12,17 2383:5,7,10,13 2388:11,14,21 2389:12 2391:17 2441:18,19,22,25 2442:1,2,5,7 2463:3 2463:11,16 2464:9 2466:8 2482:16,22 2487:21 2488:3,7 2489:2 2490:12,21 2507:22 2510:18 emailed (5) 2361:9 2367:10 2409:9,10,10 emailing (2) 2361:24 2385:7 emails (42) 2356:21 2358:9 2360:5,7 2361:1 2362:7 2363:1 2367:3,5 2369:13 2370:20 2371:21,22 2372:13 2374:13 2376:8 2380:21 2382:12,16,19,19 2383:14,21 2384:2 2384:16 2393:3,10 2411:10 2458:22,25 2459:3 2463:22 2464:3,14 2466:1,7 2483:21 2511:5,12 2511:16,20 2512:1 embarrassed (1) 2407:8 embezzle (1) 2419:17 embezzled (2) 2419:15,23 emess (7) 2349:13 2353:9,13 2354:24 2355:2,3 2355:14

United Reporting, Inc. (954) 525- 2221

emotional (2) 2384:11 2385:16 emotionally (1) 2385:15 emotions (1) 2407:14 employee (3) 2397:15 2431:10 2517:12 employees (1) 2418:23 employer (1) 2419:15 enclosing (1) 2361:10 encryption (1) 2466:9 endeared (1) 2419:3 endeavor (1) 2504:20 ended (1) 2399:20 enforcement (14) 2401:21,22,24,25 2408:12,14,15 2412:19 2419:7 2421:17 2423:13 2428:11 2432:15 2509:8 engage (5) 2421:16 2461:5 2469:13 2476:15 2496:5 engaged (8) 2421:13 2422:9 2463:10 2478:11,15 2479:1,21 2486:16 engaging (3) 2401:18,24 2402:6 entails (1) 2452:21 entered (3) 2355:13 2365:19 2371:2 entering (2) 2370:1 2386:24 enterprise (2) 2435:22 2440:4 enters (1) 2455:19 entire (4) 2429:3 2437:21 2469:16 2474:13 entities (2)

2354:11,15 entitled (1) 2452:8 entitlement (1) 2354:24 envelope (1) 2481:7 epstein (2) 2411:19 2509:18 eric (1) 2347:21 escaping (1) 2382:24 esq (1) 2350:20 esquire (39) 2347:7,12,15,15,16 2347:16,21,21,22 2347:25 2348:4,10 2348:10,14,15,15 2348:20 2349:4,8,8 2349:11,15,19,24 2349:24 2350:3,4,7 2350:11,15,16,20 2350:24 2351:4,4,9 2351:13,13,14 essentially (8) 2391:21 2460:9 2462:1 2474:13 2485:7 2489:6 2493:9 2495:2 establish (2) 2382:18 2512:19 established (4) 2365:14 2435:7 2436:6 2441:12 establishes (2) 2383:11,13 estimate (1) 2358:25 estimation (1) 2447:22 et (10) 2345:5,8 2346:8,11 2346:19,22,24 2350:18 2362:16,16 ethical (1) 2395:25 ethics (1) 2396:9 evade (2) 2421:11,12 evaluate (2) 2453:6,7 evaluated (1)

Page 9 2447:1 evans (1) 2348:15 evasion (3) 2420:14 2476:16 2479:23 event (2) 2361:23 2485:14 events (2) 2409:7 2419:7 everybody (3) 2368:4 2385:3 2415:20 exactly (4) 2375:12 2384:14 2497:7 2499:1 exaggerated (1) 2406:9 examination (12) 2345:22 2356:14 2393:15 2452:14 2458:13 2505:19 2506:10 2508:7 2510:1 2514:4,7,18 examine (1) 2513:7 example (13) 2357:14 2358:16 2359:22 2366:20 2370:14 2372:3 2386:10 2403:24 2407:3 2408:5 2413:18 2426:19 2443:4 examples (4) 2360:13,23 2407:22 2464:18 excellent (1) 2495:15 excess (1) 2420:2 exchange (3) 2411:22 2425:3 2500:3 exculpate (3) 2383:2,14 2384:23 exculpated (1) 2383:3 exculpating (2) 2382:10,14 exculpation (5) 2379:25 2380:6,10,11 2381:13 excuse (8) 2378:4 2379:6 2393:5

2403:4,6,6 2427:24 2460:13 executive (1) 2487:14 exhibit (8) 2352:10 2367:24 2368:2,13 2376:25 2377:1 2379:14 2393:1 exhibits (9) 2353:23 2354:5 2356:6 2367:19 2375:21 2376:14,17 2393:14 2503:6 exist (1) 2366:24 existed (2) 2366:22,23 exonerate (1) 2382:22 expect (3) 2363:14 2452:23,24 expensive (1) 2418:1 experience (1) 2512:6 expert (1) 2387:22 experts (1) 2371:18 expires (2) 2516:13 2517:23 explain (14) 2357:10,15 2359:11 2359:19 2364:23,24 2365:6 2366:9 2373:19 2385:23 2396:7 2464:21 2479:13 2509:5 explained (1) 2365:5 explanation (2) 2475:18 2482:14 explode (1) 2513:23 explosion (1) 2362:16 exposed (2) 2425:4 2440:19 express (1) 2491:21 extensive (2) 2467:7 2507:19 extensively (1) 2379:21

extent (10) 2354:12 2357:9 2359:18 2360:10 2369:6 2371:23 2381:19 2398:3 2481:7 2492:22 extort (1) 2423:4 extorted (2) 2423:21,23 extorting (1) 2424:6 extortion (4) 2422:18,22 2423:1 2424:5 extremely (4) 2468:15 2511:24 2512:7,7 exwife (1) 2439:10 F f (2) 2516:1 2517:1 fabricated (1) 2474:13 face (1) 2440:14 facing (2) 2444:10 2457:3 fact (30) 2363:16 2365:6 2369:13 2374:23 2379:3 2381:10,19 2389:11 2391:8,17 2394:4 2403:13 2406:24 2432:15,21 2434:3 2439:7 2441:2 2443:15,17 2445:3,6 2447:18 2455:25 2459:7 2460:15 2461:10 2510:5,8 2513:22 failing (1) 2353:22 failure (2) 2354:4 2440:15 fair (14) 2358:6 2379:7 2381:23 2451:21,22 2452:6 2453:5 2456:5 2459:6 2460:21 2474:17 2482:20 2488:10 2493:12

United Reporting, Inc. (954) 525- 2221

faith (1) 2355:10 fake (36) 2373:6 2374:1,5,6,15 2385:21,25 2386:6 2386:7 2387:1,5 2388:4 2412:3,15 2412:19 2413:13,19 2413:19 2415:10 2417:5 2439:19 2452:23 2464:22 2465:7,10 2468:23 2469:3 2470:16 2475:6,9,12 2495:21,21 2497:1 2497:4,6 faked (1) 2475:9 false (25) 2366:7 2379:24 2380:9,11 2381:16 2381:17 2386:3,5 2386:16,18,19 2389:21 2390:3,11 2390:22 2391:4 2461:11 2462:17 2463:7,9 2467:2 2472:12 2498:8 2500:7,11 falsely (15) 2382:10,14,22 2383:2 2383:3,14 2384:23 2389:1 2488:18,21 2497:23,23 2498:15 2499:13,20 family (3) 2384:9 2398:21 2428:16 familys (2) 2513:11,12 far (6) 2376:14 2389:19 2394:11,13 2477:1 2507:11 fashion (2) 2454:4 2460:15 fast (1) 2508:23 father (4) 2413:21 2439:25 2473:21 2474:7 favorable (2) 2451:25 2452:10 favors (1) 2483:19

fbi (1) 2509:8 federal (3) 2345:17 2347:19 2349:1 feeder (1) 2359:15 feel (4) 2356:19 2402:11 2404:10,15 fees (3) 2371:19 2412:21 2506:15 feiss (3) 2468:22 2470:11,12 female (1) 2473:2 fepict (1) 2350:8 fictitious (1) 2412:23 fidelity (1) 2346:21 fifty (1) 2400:11 figure (1) 2440:1 file (2) 2411:12 2437:14 filed (4) 2354:14 2447:21 2448:7 2450:14 files (1) 2447:14 filled (2) 2470:14,19 filthy (2) 2434:11,13 final (2) 2384:15 2389:25 finally (2) 2440:14 2499:7 finance (1) 2387:24 financial (14) 2364:3 2366:12,18 2369:5,6,9 2381:9 2389:18 2399:16,18 2417:5 2479:7 2500:7,11 financially (2) 2364:13 2517:14 financials (2) 2362:15 2366:7 find (6)

Page 10 2365:11 2440:20 2451:25 2470:6 2494:2 2504:6 fine (1) 2458:6 finish (5) 2439:5,6 2451:3 2472:7 2486:24 fire (1) 2349:17 firm (26) 2354:11 2394:4,10,15 2398:22 2414:22 2418:2 2420:3 2427:6 2431:21 2438:23 2441:24 2461:7,12 2470:20 2470:24 2475:1,4,7 2475:18,22 2476:15 2479:19,22 2497:24 2499:21 firms (7) 2362:14 2366:4 2390:16 2413:13 2414:5 2418:22 2434:21 first (24) 2355:12 2357:1,3 2369:24 2370:25 2381:20 2400:22 2437:18 2453:6 2458:17 2461:6,16 2473:18 2476:14 2479:18 2482:4,11 2489:7 2490:14 2495:17,18 2499:6 2501:18 2512:17 five (13) 2428:22 2452:25 2458:5 2477:10,10 2503:2,20 2504:6 2505:3,11,21 2506:7 2510:3 fix (3) 2371:8 2439:8,9 fl (1) 2349:14 flag (1) 2392:12 flagler (2) 2350:19,23 flags (1) 2465:18 flaming (1) 2435:25

flee (2) 2440:15,20 flight (6) 2411:14,15,17,19 2412:1,3 floating (2) 2362:21 2376:2 floats (1) 2362:22 floor (7) 2347:20,24 2348:9,19 2349:7,23 2350:14 florescu (1) 2466:22 florida (38) 2345:2,19,24 2346:2 2347:6,11,14,20,24 2348:4,9,14 2349:3 2349:7,11,15,19,23 2350:15,19,24 2351:3,8,12,16 2395:8,18,20,22 2396:1 2408:8 2415:1 2467:14,19 2516:3,12 2517:2 2517:22 flow (1) 2360:24 flr (1) 2350:10 focus (2) 2355:6 2470:5 focused (1) 2417:20 folks (4) 2406:9 2409:19 2421:4 2433:20 following (1) 2353:1 follows (1) 2356:1 followup (3) 2464:19 2465:4 2493:7 fool (2) 2400:21 2416:16 fooled (9) 2393:17 2394:25 2395:2,5,8,11,14,16 2395:24 foot (2) 2382:2 2478:6 foregoing (4) 2347:1 2516:7 2517:7 2517:15

forged (2) 2411:10 2473:2 form (41) 2363:4,7 2364:6 2365:15 2390:1 2400:18 2403:23 2405:14 2408:10 2409:20 2421:25 2423:9 2424:19 2426:13 2447:15 2452:12 2453:4,25 2456:16,20,25 2457:15,22 2460:22 2462:6,11 2463:2 2486:20 2487:24 2488:20 2489:10 2490:6,16 2491:14 2491:23 2493:14,17 2510:6 2511:13 2512:2 2514:19 format (1) 2388:13 former (2) 2427:20 2509:8 forms (1) 2420:17 formulate (1) 2390:10 fort (11) 2345:24 2347:6,11,20 2348:14 2349:7,23 2351:3 2418:7 2487:15 2494:16 forth (1) 2463:11 fortunately (1) 2384:6 forty (1) 2400:6 forward (1) 2360:18 forwarded (1) 2389:15 four (2) 2373:7 2431:17 fourth (1) 2345:18 fp (1) 2362:9 fp1123100134610 (1) 2352:12 fp1123100143388 (1) 2352:11 fp1123100145380 (1) 2352:12

United Reporting, Inc. (954) 525- 2221

frame (2) 2386:1 2512:19 frank (68) 2350:22 2351:10 2353:5 2356:17,20 2357:14,18,20 2358:17 2359:25 2360:3,6,7,9,13,14 2360:20 2361:19 2362:20,25 2363:1 2363:11 2364:16 2365:3,12,18,21 2366:6 2367:14 2368:25 2372:18 2373:25 2374:4 2377:2 2378:22 2379:2,25 2380:6 2381:16 2382:10 2383:2,18 2384:2,5 2385:6,20 2386:25 2387:14,14,16 2388:16,25 2389:16 2389:19 2391:7 2392:6,18,23,23 2466:25 2490:14,14 2491:15 2510:19 2511:6,14,22 2512:11 franks (4) 2359:11 2366:12,15 2369:5 fraud (43) 2358:12,13,13,22 2359:24 2363:23 2364:2 2384:3 2387:10 2389:23 2391:8 2395:21 2406:11,16 2411:3 2416:4,18,21 2417:20 2419:11 2420:11,12 2421:2 2421:3,7,9 2428:9 2459:10,12 2460:14 2466:16,25 2469:24 2476:7 2478:12,15 2478:17 2479:17,21 2480:2 2510:5,12 2513:16 fraudulent (1) 2366:13 frequently (1) 2408:1 friday (2) 2397:11,12 friend (6)

2398:2 2427:10,19 2493:4 2513:4,7 friends (7) 2397:2,4,14 2420:19 2420:19 2471:13 2513:1 friendship (1) 2496:14 frivolous (1) 2355:9 front (3) 2358:25 2378:10 2448:8 fruition (1) 2447:9 ft (1) 2351:8 full (2) 2371:23 2451:20 fully (4) 2356:19 2371:24 2380:24 2382:5 fund (6) 2346:21 2359:15 2370:15 2408:5 2474:8 2498:3 funded (2) 2378:19,20 funding (9) 2345:5 2371:2,3 2377:19,19 2378:14 2378:21 2379:3 2388:25 funds (12) 2377:20 2378:14,19 2379:3 2391:21 2431:20 2461:22 2485:1,3 2514:11 2514:14,16 funnel (1) 2474:9 funneled (1) 2418:22 funny (3) 2362:19 2473:14,23 furious (1) 2449:11 further (13) 2352:3 2354:10 2356:14 2361:25 2367:6 2395:20 2453:16 2458:3,13 2510:1 2513:25 2514:17 2517:10 future (1)

Page 11 2354:8 G g (1) 2350:15 gables (2) 2347:24 2349:3 gabriel (2) 2350:3 2505:9 gaining (1) 2513:22 game (1) 2365:8 gary (1) 2479:22 gauge (1) 2470:2 gelber (1) 2349:24 general (4) 2422:25 2423:1 2462:22 2490:10 generally (6) 2369:7,19 2461:9 2462:20 2475:24 2483:9 genovese (2) 2347:13,15 gentleman (2) 2497:10 2500:19 george (20) 2349:8 2364:12 2379:19,20,25 2380:2,8,22 2381:13,19 2385:6 2395:16 2512:17,21 2512:23,25 2513:2 2513:2,9,14 georges (2) 2391:19 2513:7 getting (6) 2391:22 2404:18 2424:20 2443:25 2469:5 2480:19 giant (2) 2381:11 2392:11 gibraltar (9) 2346:13,17 2350:17 2361:5,13,25 2483:4 2486:4,13 gift (1) 2346:21 gifts (1) 2409:16 girl (2)

2397:11,12 girls (2) 2411:19 2427:25 give (26) 2357:14 2358:25 2362:13 2366:20 2377:4 2378:7 2386:1 2387:14 2402:14 2405:18,19 2407:22 2410:16 2420:22,24 2424:11 2445:12 2466:13,14 2478:3,8 2481:20 2489:2 2494:13 2497:15 2503:21 given (6) 2358:2 2363:16 2435:19 2445:3 2468:20 2481:15 giving (7) 2386:18 2423:13 2464:2,18 2483:22 2499:7 2507:21 glades (1) 2349:10 glass (1) 2367:11 glide (1) 2469:18 go (31) 2353:2 2356:10 2359:2 2365:8 2376:25 2382:4 2403:5 2424:12 2426:5 2438:15 2441:3 2442:15 2444:25 2455:22 2456:11,12,13 2458:10,12,18 2464:20 2465:12 2471:2,6 2495:19 2501:16 2505:5 2506:17,19 2509:11 2512:17 goal (1) 2446:16 goes (2) 2384:12 2501:19 going (99) 2353:7 2355:22 2356:9,12 2357:19 2357:20 2358:11 2359:24 2360:4,25 2363:13,18 2364:15 2366:1 2369:1

2370:13,15 2371:25 2373:3,24 2374:9 2376:10,24 2378:7 2380:16,24 2381:10 2387:9 2390:20 2392:8,14 2403:1,7 2405:11 2416:23 2423:6,20 2426:1 2428:17 2429:18 2439:10,11,18 2440:2,6,19 2441:3 2443:13,21 2445:13 2446:12,13 2450:17 2451:10 2453:19 2457:4 2458:10 2460:4 2464:24 2465:10,19 2466:7 2467:24 2469:15,23 2469:23 2470:1,4 2471:4,11,15 2472:1 2474:8,9,23 2479:2 2481:3 2486:2,10,19 2492:8,17 2494:14 2496:8 2501:4,13 2502:7,15,19 2503:2,18,21 2504:4,18,22 2507:4 2508:3 2509:21 2511:15 goldberg (1) 2348:10 goldstein (11) 2348:2 2413:16 2472:13,15,16,17 2472:19 2473:8 2474:4,6,14 good (21) 2366:20 2384:17,19 2386:10 2398:18 2399:3 2400:12,22 2402:4 2403:17,24 2413:1 2416:6 2428:12 2435:2,4 2450:8 2458:15,16 2468:18 2496:20 gospel (4) 2409:19,22 2410:1,14 government (22) 2351:6 2396:24 2400:8 2423:14 2430:17,20 2437:14 2438:13 2442:15 2443:21 2446:17 2447:13,21 2448:7

United Reporting, Inc. (954) 525- 2221

2450:14 2451:6 2452:22 2453:6,13 2495:6 2500:22 2506:24 governments (1) 2429:18 governor (3) 2395:8,11 2397:1 governors (1) 2418:11 grand (2) 2477:10,11 grant (1) 2438:19 great (2) 2370:14 2381:18 greenberg (1) 2348:13 greenspoon (2) 2390:12 2393:22 grew (1) 2358:8 grievance (3) 2395:22 2396:2 2408:8 grievances (1) 2396:6 ground (1) 2486:10 group (5) 2350:8 2377:20 2379:10,10 2429:4 groups (1) 2461:3 grout (1) 2438:19 growing (1) 2399:16 grows (1) 2469:19 growth (2) 2346:19 2348:1 guess (11) 2377:17 2383:10 2420:15 2453:18 2459:13 2476:19 2488:9 2489:5 2490:13 2504:22 2512:20 guessing (11) 2363:25 2377:17 2378:2,25 2382:20 2383:19 2386:2 2394:7 2488:8 2490:13,24

guest (1) 2373:16 guilty (3) 2428:18 2438:12 2441:6 guy (4) 2357:22 2460:5 2491:2 2496:13 guys (4) 2355:19 2478:13 2493:14 2498:3 H h (3) 2347:12,15 2349:15 hadnt (3) 2378:18 2388:4 2450:6 half (1) 2370:11 halftruths (1) 2406:2 halfway (4) 2480:15,17,20,23 hand (4) 2399:13 2430:4 2470:17 2481:6 handed (8) 2362:7 2367:7 2369:13 2370:21 2377:1 2387:15,16 2478:4 handing (2) 2387:15,17 handle (1) 2498:25 handled (3) 2498:7,13 2499:10 handling (2) 2369:17 2478:19 hands (4) 2373:11,14 2448:15 2448:18 handwritten (1) 2388:14 hang (3) 2380:5 2446:10 2449:7 happen (7) 2443:13 2445:7 2446:13 2447:1 2450:21 2451:13 2470:2 happened (1) 2485:17

Page 12 happens (1) 2491:25 happy (6) 2378:6 2424:22 2430:19 2487:8 2505:2 2508:8 harass (1) 2414:12 hard (1) 2402:11 harley (1) 2347:25 harm (1) 2425:21 harris (12) 2360:6,25 2361:2,9 2361:19 2362:1 2428:18 2483:6 2485:21,22 2487:12 2488:4 harvey (1) 2350:7 haven (1) 2444:6 havent (6) 2378:20 2383:12 2403:12 2434:4 2438:9 2511:9 hayworth (2) 2483:6 2484:1 head (4) 2432:17 2469:21 2475:17 2489:11 headache (1) 2370:16 heads (1) 2438:17 hear (8) 2355:18 2363:13 2422:20 2426:16 2451:12,13 2501:8 2508:12 heard (7) 2369:15 2434:16 2436:16,18 2438:22 2452:5 2465:15 hearing (14) 2353:17 2396:6 2413:8,14,19 2450:15,18,22 2451:7,11,14 2455:19 2504:24,25 hearings (2) 2413:6,12 hears (1)

2452:9 hedge (7) 2377:20 2378:14,19 2379:3 2391:21 2461:22 2498:3 held (1) 2493:15 hell (1) 2478:13 help (10) 2380:23 2384:5 2386:18 2442:25 2451:10 2453:13,15 2463:25 2483:11 2500:2 helped (15) 2386:25 2387:17 2389:9,9 2390:10 2421:7,9 2446:20 2447:1 2453:14,14 2453:15 2461:10 2481:15 2483:13 helpful (1) 2453:18 helping (4) 2387:24 2446:3 2481:4,12 herb (3) 2449:18,21 2451:24 herbert (1) 2347:9 heres (3) 2478:5 2500:12 2502:4 herskowitz (2) 2498:14 2499:6 hertzberg (7) 2350:3 2505:8,9,16 2506:6 2514:10,14 hes (18) 2363:16 2365:13 2369:14 2371:24 2377:14,22 2386:18 2423:11,13 2425:12 2448:23 2449:4 2451:20 2453:19 2478:12 2502:18 2503:24 2506:15 hey (1) 2469:22 highway (2) 2347:19 2349:2 hired (1) 2488:15 hiring (2)

2509:7,12 history (1) 2495:23 hofrichter (2) 2349:2,4 hold (7) 2373:11,14 2403:7 2423:8,8 2437:18 2485:24 holly (1) 2348:14 home (3) 2456:11,12,13 homes (1) 2418:1 honest (9) 2381:22 2400:2 2414:6,19 2461:16 2461:18,19 2462:3 2462:25 honestly (1) 2462:2 honor (3) 2492:2,6,10 hood (2) 2420:19,21 hope (24) 2438:8,14 2444:7 2449:1 2450:22,23 2451:4,7,11,14,18 2451:20,23,24 2452:3 2453:22,23 2455:8,12,24 2456:4,23 2457:5 2513:21 hoped (2) 2444:21 2513:19 hopeful (1) 2355:4 hopefully (2) 2443:11 2501:22 hopes (3) 2443:22 2444:8 2448:9 horrific (1) 2492:7 hospitals (1) 2419:2 hostess (1) 2431:9 hours (1) 2463:21 house (3) 2418:13 2428:15,19 houses (1)

United Reporting, Inc. (954) 525- 2221

2408:20 houston (1) 2351:4 howard (4) 2474:25 2475:3,19 2498:14 huberfeld (1) 2350:5 human (2) 2429:2,5 humorous (1) 2374:3 hundreds (3) 2374:13 2511:5 2513:15 hunkydory (1) 2391:2 hurt (4) 2398:17,21 2399:3 2472:18 hutchinson (1) 2390:15 I id (2) 2358:19 2359:7 idea (7) 2374:25 2377:15 2398:25 2443:13 2446:13 2471:11 2476:25 ideally (1) 2504:16 identification (3) 2368:2 2393:2,14 identified (3) 2467:12 2472:13 2480:25 identify (2) 2410:10 2508:5 identifying (1) 2367:20 ignore (1) 2506:18 ill (11) 2356:6,7 2357:11,14 2359:13 2374:7 2390:5 2426:5 2496:19 2504:20 2506:17 illegal (12) 2360:10 2363:17 2459:8 2471:23 2482:19 2483:1 2485:7,10 2493:23

2495:8,16 2509:15 illegality (4) 2390:21 2407:12 2483:25 2485:11 im (105) 2353:3,7,16 2356:8 2356:12 2363:5 2367:21 2368:10 2369:20 2374:10 2376:16,24 2377:21 2378:2,6,7,10,11,25 2380:1 2383:6,12 2385:1 2389:3 2392:14,15 2400:8 2404:19 2407:2,8 2409:21 2416:11,23 2422:3,19 2423:6 2423:20,23,25 2426:11,15 2428:11 2429:18 2430:19 2433:5,24 2436:5 2436:15 2438:19 2441:9 2443:1,3 2445:13,21,25 2446:2,10 2448:20 2449:7 2452:7 2456:9 2457:3 2458:10 2460:12,12 2460:13,14 2464:7 2464:10 2468:7 2469:23 2470:4,6 2472:16,20 2473:7 2474:23 2477:21 2480:6,7 2481:1 2484:18 2485:24 2486:14 2488:7,8 2489:1 2490:17,21 2493:24 2494:14 2502:15,18 2503:2 2503:18,21,23 2504:4,18,22 2505:2 2508:3,8,13 2509:21 image (1) 2417:11 immediate (1) 2513:12 immediately (1) 2501:16 impinge (1) 2429:17 implode (2) 2440:6,14 imploded (2) 2432:3,13

Page 13 implosion (1) 2466:5 important (1) 2411:21 importantly (1) 2453:8 impose (2) 2400:5,10 impossible (2) 2381:4 2463:15 impression (4) 2364:7 2402:15 2471:20 2492:24 improper (1) 2482:20 inability (1) 2354:3 inaccurate (1) 2375:5 incarcerated (2) 2363:15 2437:21 incarceration (1) 2456:14 incarnation (1) 2434:6 include (1) 2459:16 included (2) 2419:1 2460:1 including (7) 2388:6 2420:25 2425:18 2438:17 2439:24 2453:1,1 inclusive (1) 2517:8 income (3) 2459:20 2460:8 2476:16 incorrect (1) 2472:9 increase (2) 2466:8 2481:21 increased (1) 2420:13 incriminating (6) 2458:22,25 2459:3 2511:5,12 2512:1 inculpatory (1) 2363:10 independent (6) 2382:21 2389:14 2463:23 2487:22 2488:15 2489:4 index (2) 2352:1,10

indicate (8) 2370:24 2371:17 2372:24 2373:3 2376:5 2378:1 2380:4 2459:22 indicated (13) 2361:7 2365:18,25 2371:12 2372:11 2379:24 2383:22 2385:10 2391:6 2392:3 2476:22 2510:19 2511:4 indicating (7) 2367:11,12 2368:11 2368:16 2374:4 2375:2 2378:13 indicator (1) 2368:17 indicators (2) 2358:14 2391:7 indictment (1) 2452:25 individuals (1) 2406:11 induce (1) 2465:11 inducement (1) 2408:3 inducements (1) 2408:1 inflate (1) 2460:7 influence (2) 2417:12 2450:9 information (28) 2360:24 2362:21,22 2362:23 2363:21,22 2366:1,12 2369:10 2389:21,22 2390:11 2390:22 2391:5 2405:19 2406:5 2444:17 2445:12 2451:12,18,25 2452:25 2462:17,25 2466:14 2467:2 2471:6 2488:18 informed (1) 2450:12 infusion (1) 2440:6 innocent (8) 2394:15,18 2398:17 2408:5 2413:21 2446:17 2447:7,8 input (5)

2386:18 2388:5,9 2389:6,10 inside (1) 2489:11 insinuate (1) 2427:24 instances (1) 2371:10 instruct (1) 2371:6 instructed (2) 2360:15 2460:7 insurance (3) 2348:17,17 2349:1 integrity (2) 2434:21 2435:3 intend (1) 2502:12 intention (1) 2438:7 interacted (1) 2473:25 interaction (4) 2481:1,3 2482:25 2483:1 interest (2) 2504:24,25 interested (2) 2426:12 2517:14 interesting (1) 2513:4 interests (1) 2434:12 interpose (1) 2423:15 interrupt (1) 2375:19 interruption (1) 2514:13 intimate (3) 2480:4,7,10 intricacies (1) 2477:2 invasion (1) 2420:15 invest (3) 2387:9 2394:6,12 invested (5) 2484:9,23 2485:16,18 2513:10 investigate (1) 2485:12 investigation (1) 2394:5 investigations (2)

United Reporting, Inc. (954) 525- 2221

2412:19 2447:2 investing (1) 2490:15 investment (8) 2369:15,21 2485:2,9 2490:2,5,11 2493:6 investments (3) 2402:19 2465:15 2488:2 investor (3) 2359:25 2369:17 2391:15 investors (17) 2374:2 2377:11 2379:7 2389:22 2394:18 2408:6 2411:20 2417:20 2446:18 2447:8 2465:11 2466:23 2488:19 2492:12 2493:20,20 2494:4 invoking (1) 2445:21 involve (1) 2425:17 involved (52) 2359:4,5 2384:3 2385:1 2388:25 2395:19 2405:21 2406:1 2407:25 2409:13,14 2421:24 2422:6,18,22 2423:1 2424:21 2425:9,13 2426:8,9 2428:5,8,9,10 2439:23 2443:24 2460:18 2463:1 2465:20 2467:1 2468:23 2469:7,21 2472:7 2474:7 2478:23 2479:5,6 2479:17 2481:17 2487:6 2488:5,22 2489:7 2492:19 2493:1,22 2501:8 2511:1,11 2513:20 involvement (6) 2359:23 2406:4,7,11 2476:1 2509:20 involving (2) 2478:17 2479:23 irene (6) 2371:6,8 2386:14 2479:7,17 2480:5 irregularities (1)

2390:20 irs (2) 2460:14 2509:9 isnt (2) 2437:12 2456:24 isolated (1) 2357:13 issue (5) 2361:18 2378:13 2379:3 2484:19 2502:4 issues (3) 2356:25 2358:7 2380:23 ivan (1) 2347:22 ive (18) 2369:15 2376:9 2380:1 2384:22 2407:8 2433:13 2434:15 2435:7 2437:15,21 2446:25 2451:19,21 2452:2 2453:23 2455:21 2463:20 2510:7 J j (5) 2346:4 2347:22 2350:16 2351:13,14 jack (6) 2350:11 2359:21,25 2360:1,1,2 jacks (1) 2359:23 jail (4) 2380:17 2428:24 2442:21 2444:19 james (1) 2345:17 jan (1) 2351:4 january (6) 2362:8 2364:17 2366:25 2367:8 2368:6,24 jeans (2) 2414:18 2454:7 jeffrey (1) 2411:19 jenne (3) 2508:25 2509:2,14 jesus (1) 2347:16 jewelry (1)

Page 14 2418:2 job (3) 2366:2 2449:4 2495:15 joblove (1) 2347:13 joe (1) 2395:5 john (15) 2347:15 2349:8,19 2360:6,7,9,25 2361:2,9 2362:1 2394:25 2428:18 2485:21,22 2488:4 join (3) 2476:15 2505:23 2506:1 joined (1) 2475:4 joking (1) 2410:13 jonathan (1) 2348:10 joy (1) 2508:18 jr (1) 2349:19 judge (58) 2354:22 2398:5 2399:8 2400:3,4,10 2400:16 2413:9,16 2413:19 2416:20,23 2416:24 2417:4,17 2417:19 2418:15 2419:10 2448:8,10 2448:11,13,14 2449:13,19,23 2450:9,12,16,25 2451:6,8,15,24,25 2452:6,9,11 2453:1 2453:6,7,11,13 2455:8,12 2457:2 2472:6,14,21,24 2473:1,5,8,10,16,18 2473:19 2504:11 judges (8) 2402:2 2421:22 2434:9 2448:18 2450:9 2472:23 2473:20,25 judging (1) 2396:9 judicial (5) 2345:1 2346:1 2396:10 2422:2

2478:17 judiciary (3) 2402:5,7 2422:7 julie (3) 2428:6 2429:1 2431:5 july (1) 2466:5 june (1) 2466:5 jury (2) 2396:7 2400:16 justice (2) 2345:17 2351:7 justify (1) 2403:1 K kaplan (2) 2349:14 2354:12 katzen (1) 2349:14 keep (7) 2357:6 2387:8 2402:9 2471:25 2507:22,23 2514:6 keeping (1) 2504:10 ken (6) 2387:3,11 2476:17 2508:24 2509:2,14 kept (3) 2483:12 2491:13,17 kerstetter (3) 2481:2,6,11 key (1) 2394:13 kill (1) 2440:15 killed (1) 2428:13 kind (10) 2399:18 2420:12 2449:25 2460:15 2471:24 2495:20 2496:4,13 2501:24 2509:12 kinds (1) 2390:23 king (2) 2345:17 2346:25 kiting (1) 2476:3 kluger (2) 2349:14 2354:12 kneecaps (1)

2426:19 knew (58) 2357:24 2358:1 2359:24,25 2360:1 2360:1,2,9,13 2362:25 2363:1 2364:1 2365:3,3 2366:20,23,25 2374:4 2375:7 2380:2,3 2381:4 2385:1 2387:3,3,23 2387:23 2391:7 2394:11,14 2397:7 2398:10 2401:20 2402:1,8 2427:15 2427:22 2432:19,20 2442:16 2443:17 2445:4 2462:3 2465:9,13 2471:15 2471:17,21 2478:25 2479:4,5 2492:6,16 2510:12 2512:23,24 2513:14,14 know (102) 2356:7 2357:23 2358:1,4,10,11 2360:4 2362:20 2368:20,25 2374:11 2374:17,23 2377:2 2380:3 2381:15 2386:11 2391:13,14 2391:14 2393:6 2394:16 2399:17 2400:24 2401:6,8 2401:11 2409:21,21 2419:10,18 2420:14 2422:10 2423:7,19 2428:13 2432:16,21 2432:22 2434:15,18 2436:13,20 2437:8 2437:12 2439:10,11 2443:1,6 2445:5 2446:12,17 2447:13 2448:6 2449:7,21 2450:17,17,20 2452:13,15 2453:21 2455:14 2456:7 2457:6,19 2460:2 2460:24 2465:23 2470:24 2471:12 2472:5,17 2473:9 2474:19 2476:13 2477:2 2478:13,15 2479:25 2480:22 2481:7 2482:21,21

United Reporting, Inc. (954) 525- 2221

2490:20 2492:23 2493:11 2495:19 2496:7,18 2500:2 2500:22 2501:13 2504:8,9,10,23 2510:5,7 2512:3 2513:3,23 knowing (7) 2360:14 2382:3 2405:11 2441:3 2495:25 2496:2,3 knowledge (14) 2358:3,6,8 2360:2 2366:14,16,17 2371:23 2476:24,25 2481:8 2490:19 2496:6 2499:11 known (6) 2375:4 2383:22 2435:17 2478:11 2482:1 2512:21 knows (8) 2357:19,20 2368:4 2373:24 2387:4,11 2387:11 2428:4 kopas (1) 2347:22 kopelowitz (1) 2351:2 koppel (2) 2494:6 2497:22 koss (2) 2479:19,20 kozyak (1) 2347:23 kroll (2) 2508:24 2509:10 krolls (1) 2509:3 kusnick (1) 2474:25 L l (7) 2345:22 2348:20 2351:11 2516:5,12 2517:4,22 lack (3) 2440:1 2491:12 2494:12 language (1) 2387:21 large (3) 2402:21 2411:22 2452:24

las (3) 2347:10 2348:13 2349:22 late (7) 2355:2 2390:24 2408:7 2440:5 2441:6 2504:2 2512:14 lauderdale (12) 2345:24 2347:6,11,20 2348:14 2349:7,23 2351:3,8 2418:8 2487:15 2494:17 lauer (1) 2350:4 laundered (5) 2420:3,5,7,9 2422:15 laundering (1) 2476:3 lavecchio (29) 2394:21 2395:3,9 2396:12,15,19 2422:11,25 2423:6 2423:21 2424:3,13 2425:6,11,19,22 2426:24 2427:3 2429:20,23 2430:6 2430:9,11,21 2449:15 2451:8 2495:10 2500:24 2508:16 law (33) 2347:5 2349:9 2354:11 2362:14 2366:4 2387:4 2401:21,22,23,25 2408:12,14,15 2412:19 2418:2,22 2419:7 2420:3 2421:16 2423:13 2428:11 2431:7,20 2432:14 2434:21 2441:24 2445:3 2455:22,25 2461:7 2477:3 2479:19 2509:7 lawrence (1) 2345:17 lawsuit (3) 2438:24 2439:2,17 lawsuits (2) 2410:25 2411:2 lawyer (30) 2387:5,12 2395:25 2400:4,9 2413:24

Page 15 2427:6 2435:20 2438:23 2441:8,11 2445:25 2448:23 2449:4 2451:15 2453:2 2467:14,19 2472:14,18,21 2474:25 2475:21 2476:17 2493:22 2494:16,18 2497:22 2498:15 2499:12 lawyers (20) 2387:2 2393:20 2394:15 2396:9 2413:13,13 2415:3 2415:7,11 2429:4 2433:14,15 2435:2 2435:2 2461:11,15 2462:4,17,19 2501:8 lay (2) 2358:24 2491:21 lead (1) 2494:4 leaders (1) 2418:18 leaf (1) 2346:23 learned (4) 2357:5 2397:19 2512:4 2513:3 leave (4) 2382:3 2444:5 2459:7 2470:20 leaving (2) 2471:1,3 led (2) 2389:22 2452:25 left (13) 2375:14 2376:18 2444:12,13 2446:4 2446:11 2470:11,24 2471:5,9 2475:1 2486:25 2512:24 legal (6) 2388:2,7,8 2390:8,8 2412:15 legit (2) 2401:12,21 legitimacy (3) 2402:9 2419:8 2493:6 legitimate (16) 2401:14,16,17,23,23 2402:2,3,4,5 2408:14,15 2465:15 2465:17 2489:8

2490:4,11 length (2) 2387:1 2466:16 leon (1) 2347:23 lessen (1) 2496:5 letter (37) 2365:15 2387:6,24,25 2388:1,5,6 2389:10 2389:11,16 2390:4 2390:13 2399:11,17 2399:24 2430:15 2449:18,24 2450:1 2450:1,3,6 2466:20 2475:15,16,18 2476:20,21,22 2477:1,5,7 2478:9 2478:10,14 2482:11 2482:14 letterhead (3) 2387:2,13 2477:7 letters (18) 2387:1 2389:2,4 2390:8,15,18 2391:1,1 2412:11 2412:13 2450:8 2467:2 2475:6,10 2475:12 2482:1,2 2482:17 level (7) 2363:10 2367:9 2406:4,7,11 2466:8 2490:19 levels (2) 2378:14 2379:4 levin (2) 2380:22 2512:17 levine (1) 2349:14 levins (3) 2391:9,16 2392:8 levinson (4) 2351:1 2501:15 2502:10 2504:24 lewis (6) 2394:2 2427:5,6 2428:12 2471:9,19 liar (1) 2380:13 lib (1) 2415:23 lichtman (25) 2347:12 2354:20 2355:21 2376:4

2447:6 2453:12 2457:10 2493:17 2494:14,19 2501:15 2501:25 2502:3,9 2502:14,21 2504:12 2504:14,22 2505:10 2506:12 2508:20 2512:2 2514:2,9 lichtmans (1) 2505:12 lie (26) 2359:24,25 2360:1,1 2434:24 2456:24 2457:13,21 2461:16 2461:25 2462:19,24 2469:1,8,9,11 2487:17 2489:1,23 2490:15,17 2492:15 2492:21 2495:3 2496:10 2498:6 lieberman (1) 2395:6 lied (17) 2405:23,24 2420:16 2434:9 2436:7 2456:14 2460:10 2472:10 2478:18 2487:23,25 2488:1 2491:21,24,25 2493:20 2494:4 lies (11) 2463:16 2486:15 2488:4,17,22 2489:25 2490:9,22 2490:23 2499:1,2 life (9) 2381:21 2382:7 2438:14 2440:25 2442:21 2444:15 2472:4 2485:23 2507:24 likewise (1) 2506:2 limit (4) 2358:2,6 2359:10 2504:11 limited (9) 2355:7 2356:5,24 2357:15 2359:11,18 2360:4 2385:18 2492:22 line (5) 2361:10,16,17,25 2416:11 lines (2)

United Reporting, Inc. (954) 525- 2221

2415:22 2490:3 lining (1) 2462:4 lippman (1) 2475:21 lisa (1) 2483:20 listen (1) 2495:3 listening (1) 2440:17 listing (1) 2459:19 literally (1) 2511:5 litigation (2) 2474:7 2475:25 little (15) 2357:10 2362:21 2365:9 2370:5,7 2406:5 2409:11 2415:8 2449:3 2460:25 2469:19 2485:25 2486:24 2498:11 2511:15 live (2) 2438:15 2507:24 llc (5) 2345:5 2346:19,22 2348:1 2349:13 llp (2) 2347:19 2350:2 load (1) 2504:1 loaned (1) 2454:6 loans (2) 2412:23 2431:21 local (1) 2418:15 lock (1) 2482:1 log (1) 2464:23 long (1) 2370:3 longer (1) 2404:25 look (14) 2359:13 2360:16 2371:20,21,22,22 2373:21 2388:11 2389:12 2390:18 2482:22 2488:3 2497:7 2512:16

looked (3) 2382:16 2391:18 2466:2 looking (5) 2459:3 2463:22 2479:3 2489:15 2492:8 looseygoosey (1) 2476:14 lose (1) 2513:15 lost (3) 2404:22 2428:1 2455:10 lot (37) 2366:21 2369:13 2370:8 2371:25 2376:2 2381:8 2393:17 2398:17 2399:4 2409:9,10 2415:23 2430:22 2456:7 2457:19,19 2464:4 2466:15,15 2467:9 2468:14 2471:17 2475:6 2478:6,21 2483:17 2488:4,5,5 2495:4 2495:14,16 2509:7 2511:10,19 2512:6 2512:8 lots (1) 2414:22 loud (1) 2477:20 love (2) 2384:10 2456:5 lover (1) 2427:20 loyal (1) 2468:15 lss (1) 2346:10 lucre (4) 2434:11,13,15,19 lunch (2) 2355:20 2501:16 lydecker (1) 2350:13 lying (5) 2436:22 2463:11 2476:3 2493:10 2498:22 lyles (1) 2349:22

Page 16 M m (11) 2345:16,16 2347:16 2349:8,11 2362:8 2364:18 2368:7 2372:17 2514:16,23 ma (1) 2350:10 maam (38) 2397:6,8,16,18,20,23 2398:1 2399:14,17 2399:19,22 2400:15 2401:2,13 2402:10 2402:13,20 2404:13 2404:17 2411:5,7,9 2411:11,13 2414:8 2414:15 2415:16,19 2415:21,24 2416:1 2416:7 2417:23 2418:4 2427:7 2431:6 2432:11 2445:8 madison (1) 2417:9 madoff (5) 2442:20,25 2443:3,8 2443:9 mafia (1) 2469:2 magnitude (1) 2457:2 maintained (1) 2418:5 major (2) 2359:15 2384:3 making (9) 2356:22 2364:1,8,10 2367:19 2407:8 2425:9,18 2495:11 male (1) 2473:10 malice (1) 2434:19 malleable (2) 2404:15 2405:4 malletprevost (1) 2350:2 man (3) 2358:1 2466:18 2498:22 manager (1) 2483:10 manhattan (1) 2348:19 manifest (2)

2411:17,19 manifests (4) 2411:14,15 2412:1,3 manipulate (1) 2404:6 manipulated (2) 2403:15 2429:16 manipulating (4) 2403:17 2404:4,8 2429:10 manipulation (2) 2422:2,6 manner (2) 2460:10 2483:23 mansion (1) 2418:11 maple (1) 2346:23 marc (2) 2347:5,7 marder (2) 2390:12 2393:22 marina (1) 2350:10 marine (1) 2349:17 mark (5) 2348:15 2350:5 2375:21,22 2393:11 marked (5) 2368:1 2376:25 2379:15 2393:1,13 market (1) 2487:15 marketing (2) 2417:7,19 marking (1) 2376:11 marra (6) 2413:17,19 2472:14 2472:21 2473:9,19 marriage (1) 2435:9 martinez (1) 2395:2 mary (2) 2350:20 2426:16 marybeth (3) 2468:22 2470:11,12 massive (4) 2357:5 2362:15 2469:22 2476:3 master (1) 2416:4 masterminded (2)

2410:25 2411:1 matched (1) 2376:6 matter (6) 2372:19 2389:11 2391:17 2407:12 2445:6 2455:25 matters (1) 2459:18 matthew (1) 2350:20 mccain (1) 2394:25 mean (24) 2361:14 2363:1,11,17 2363:20 2364:11 2375:18 2386:9 2395:24 2396:7 2398:10 2415:10 2422:10,12 2442:2 2443:8 2456:5 2464:1 2466:15 2467:9 2486:22 2492:18 2501:5,10 meaning (3) 2406:20,21 2513:4 means (6) 2409:22 2412:25 2420:21,23 2460:12 2517:17 meant (3) 2400:1,1 2423:19 mechanism (1) 2511:19 medical (2) 2437:20 2438:2 meet (2) 2489:21 2499:7 meeting (2) 2405:3 2412:1 meetings (2) 2498:1,3 mel (1) 2395:2 melissa (6) 2427:5,5 2428:12 2471:9,11,21 member (4) 2438:15 2496:1,2,3 members (2) 2402:4,6 memory (1) 2378:7 mentioned (5) 2392:18 2433:14

United Reporting, Inc. (954) 525- 2221

2476:17 2480:15 2483:5 met (8) 2365:5 2367:11 2476:14 2479:18 2512:11,13,15,18 miami (11) 2345:19 2347:14 2348:4,9 2349:15 2350:15,19,24 2351:12,16 2494:20 michael (6) 2348:10 2350:12 2351:13,13 2367:10 2488:13 michele (5) 2345:22 2516:5,12 2517:4,22 mid (1) 2512:14 middle (2) 2469:4 2492:7 miguel (1) 2350:16 mike (3) 2367:14 2368:21,22 milk (3) 2373:8 2491:4,5 miller (2) 2348:18 2350:18 million (8) 2363:16 2367:15 2368:12 2372:10 2377:9 2391:19 2419:19 2420:2 millions (3) 2368:23 2460:8 2513:15 mills (1) 2349:18 mind (7) 2380:14,17 2381:3 2384:7 2405:9 2428:1 2458:4 mine (5) 2384:7 2427:9 2432:19 2481:19 2493:4 minimum (3) 2369:12,14 2371:11 minute (1) 2448:1 minutes (10) 2428:22 2458:5 2503:3,20 2504:6

2505:3,12,21 2506:7 2510:3 misconceptions (1) 2469:14 misheard (1) 2468:9 mislead (2) 2492:15,21 misled (1) 2491:22 misrepresentations ... 2494:9 missed (1) 2390:24 missing (2) 2363:15 2378:24 misstating (1) 2439:20 mistake (3) 2372:11 2449:11 2456:8 mistaken (1) 2481:2 mistakes (1) 2367:4 mob (10) 2420:9 2422:9,12,16 2427:2 2428:10 2469:7 2472:1,8 2480:15 mom (2) 2398:23 2449:25 moment (8) 2381:24,24 2382:24 2488:12 2489:4 2494:13 2500:24 2508:1 monday (13) 2357:1 2358:15,19 2361:3 2367:4 2372:10 2375:10 2377:1 2379:15 2380:12 2385:10 2391:6 2510:19 money (81) 2361:20 2363:15 2364:1,3,8,10 2366:21,22,23,23 2366:25 2368:18 2369:17,18 2370:2 2370:6,10,17 2371:14 2372:2,3,5 2372:6 2377:11,23 2378:18 2381:8 2391:8,15,15,19

Page 17 2392:9,9,10,11,12 2392:12 2407:8 2409:16 2411:22 2420:3,5,7,9 2422:15 2424:11 2425:3 2434:11,14 2439:9 2440:22,23 2446:18 2447:8 2454:19,20,22 2456:14 2460:6 2474:9 2476:3 2478:5,7 2479:4,9 2479:14 2480:3 2481:15,19 2483:13 2483:22 2485:5 2488:1 2497:14 2507:4,8,14 2513:11,11,12,19 morgan (1) 2394:2 morning (11) 2345:12 2358:23 2370:22 2433:2,6 2433:19 2458:15,16 2458:20 2504:17,18 morocco (16) 2375:14 2429:14,16 2431:3 2435:15 2440:15 2441:4,7 2441:10 2443:19 2444:12,13 2446:4 2446:11 2451:19 2452:5 morse (17) 2346:4,4,5 2398:4,7 2407:3 2413:21,22 2419:23,23 2420:7 2439:16,17,23 2473:11,15,25 morses (4) 2349:5 2439:22 2506:3 2513:18 mortar (1) 2438:20 mosle (1) 2350:2 mother (1) 2398:19 motion (2) 2447:14,21 motto (1) 2434:21 move (6) 2353:17,25 2354:16 2467:11 2483:13,22

movement (1) 2479:14 moving (2) 2362:6 2479:9 muddy (1) 2490:25 mullin (2) 2349:8 2506:2 multibilliondollar (1) 2384:8 multimillion (1) 2418:1 multiple (2) 2360:6 2486:3 murdered (2) 2427:20,22 murray (1) 2350:5 mushroom (5) 2491:3,6,7,11,18 mutual (1) 2440:7 N n (4) 2345:18 2346:13,20 2349:18 nada (1) 2362:13 name (6) 2356:16 2395:20 2435:19 2473:1 2488:13 2500:23 names (3) 2382:24 2411:19 2483:6 narcissistic (3) 2436:1,2,21 narrow (1) 2470:6 nasty (2) 2450:6,9 naturally (2) 2416:14,15 nature (2) 2388:2 2469:24 near (1) 2426:6 necessarily (2) 2421:3 2513:23 necessary (1) 2490:1 need (35) 2357:23,24 2372:22 2373:12 2375:21

2377:23 2382:12 2385:2 2388:22 2403:20 2404:6,7 2405:5,6,8 2407:18 2424:23 2429:18 2439:13,25 2466:11 2473:19 2477:7 2479:15 2494:13 2495:3,6 2496:12 2496:15 2497:5,6,7 2500:10,13 2514:7 needed (42) 2357:16 2358:4 2359:25 2360:1,11 2360:21,22 2365:6 2365:10 2371:5 2380:8 2387:8 2388:20 2405:19 2407:23 2408:3,4 2415:24 2431:20 2439:9 2440:1 2460:19,20,24 2461:15,24 2462:16 2462:18 2463:25 2468:13 2469:2 2478:9,10 2481:19 2482:18 2488:23 2494:11 2496:18 2497:4 2498:11 2499:1,10 needs (3) 2365:8 2391:18 2407:13 nefarious (1) 2388:20 negotiated (1) 2355:1 neither (1) 2354:23 never (17) 2365:24 2374:22 2384:6 2388:6 2395:19 2405:10 2434:15 2437:15,21 2471:20 2483:13,16 2485:1 2497:13 2498:8,21 2511:16 nevermind (1) 2480:10 new (5) 2348:20,20 2350:3 2392:9 2458:18 nice (2) 2499:7 2507:24 nicely (1)

United Reporting, Inc. (954) 525- 2221

2424:18 nicknames (2) 2409:12,15 night (1) 2504:1 nine (1) 2464:6 ninth (2) 2347:24 2486:3 nominating (1) 2396:10 nonexistent (1) 2375:4 nonextradition (4) 2382:3 2440:20,21 2441:2 nono (2) 2365:4 2389:17 nonsense (1) 2496:4 noon (1) 2505:14 nope (1) 2373:9 nordlicht (1) 2350:6 normally (2) 2378:19 2420:23 notary (2) 2516:12 2517:22 note (1) 2514:10 noted (1) 2423:17 notes (3) 2388:17 2411:8 2517:9 notices (2) 2354:13,16 november (2) 2372:17 2375:3 number (9) 2362:9 2367:22 2372:6 2373:7 2386:16 2435:1 2461:25 2500:6,7 numbered (1) 2517:7 numbers (4) 2368:10 2372:22 2373:6 2414:22 numerous (1) 2355:3 nurik (53) 2347:5,7 2356:3,10

2356:11 2362:7 2367:8 2378:4 2392:25 2393:5 2403:7 2410:3,7 2423:8,10 2429:6 2430:17 2437:18 2439:5 2441:8,11 2441:14 2445:16,20 2448:22 2449:1,11 2454:6,10,13,16 2457:24 2458:10 2464:13 2485:24 2486:2,8,10,18 2503:2,23 2504:16 2505:6,11,20 2506:4,4,5,6,8,11 2506:14 2514:20 nuriks (1) 2514:3 ny (1) 2350:3 nystrom (1) 2350:9 O oath (18) 2352:8 2356:1 2433:3 2433:5,7,8,9,12,16 2433:17,19,21,25 2434:7,17,18,20 2435:9 oaths (1) 2434:4 object (39) 2353:11,18 2354:10 2363:4 2364:6 2398:9 2400:18 2409:20 2421:25 2424:19 2425:7,19 2447:15 2452:12 2453:4,25 2454:4 2456:16,20,25 2457:10,15,22 2462:6 2463:2 2486:19 2487:24 2488:20 2489:10 2490:16 2491:14,23 2495:6 2505:19 2506:10 2508:3 2510:6 2512:2 2514:19 objection (36) 2353:7 2363:6 2395:3 2395:9 2396:12,19 2403:23 2405:14

Page 18 2408:10 2423:9,12 2423:15,21 2424:2 2424:3 2426:13,24 2427:3 2429:23 2437:16 2445:15 2457:7 2460:22 2462:11 2486:18 2490:6 2491:8 2492:4 2493:13,17 2495:10 2505:10,24 2508:16 2510:9 2511:13 objections (1) 2355:9 obtain (1) 2508:14 obtained (1) 2390:14 obtaining (1) 2390:7 occasion (4) 2366:3 2368:22 2509:17 2511:14 occasions (4) 2369:22 2371:7,20 2379:1 occurring (1) 2392:7 october (3) 2375:8,12 2379:17 offending (1) 2435:1 offense (1) 2407:1 offer (1) 2452:4 office (11) 2347:5 2351:7 2373:5 2374:2 2388:19 2414:25 2418:6 2478:5,7 2480:19 2509:18 officer (1) 2479:7 offices (1) 2349:9 official (1) 2415:1 officials (1) 2486:13 oh (4) 2383:3 2395:24 2444:25 2483:17 okay (132) 2357:21,22 2358:2,21

2359:9,14,14,16,21 2359:23 2360:17 2362:6,20 2364:15 2364:25 2365:9,13 2366:6 2367:6 2368:15,16 2369:5 2370:21,24 2372:4 2372:20 2373:3 2375:2,10,25 2376:13,22 2377:14 2377:18 2378:3 2379:1,9,13 2380:9 2380:12,16,20 2382:25 2383:8,16 2383:20 2384:18 2385:16 2386:21 2387:7 2390:22 2392:14 2424:1 2428:8 2430:13 2439:8 2444:2,2,6 2445:17 2448:6,24 2449:10,18 2456:7 2456:9,13 2457:4 2458:1,2,15 2459:16,22 2461:3 2461:7,19 2462:20 2465:12 2467:11,18 2467:21 2468:10,22 2469:9 2470:4,8 2471:12,22 2472:13 2473:8,12 2474:21 2474:25 2475:11,21 2476:5,17,22 2480:4,14 2481:14 2481:22,25 2483:4 2483:8 2485:13,22 2486:1,21 2487:1 2488:13 2489:18,21 2490:14 2492:21 2493:24 2494:1,7 2495:11 2496:17 2497:1,13,15 2499:19 2505:6,7 2506:23 2507:20 2510:18 2511:4,8 2513:25 olas (3) 2347:10 2348:13 2349:22 old (2) 2370:13 2455:2 once (10) 2371:15 2441:4,7,10 2448:6 2452:23 2455:17 2467:17

2472:24 2488:25 oneonone (1) 2467:7 ones (2) 2370:21 2513:21 online (7) 2373:8,22,23,24 2374:8,9,10 open (6) 2466:2 2502:17 2503:19 2504:6,10 2514:6 operate (1) 2401:1 operations (2) 2346:5 2419:24 opining (1) 2387:25 opinion (23) 2364:8 2383:24 2387:1,5 2388:4 2389:2,3,4 2390:8 2390:13,14,18 2391:1 2412:11 2466:20 2467:2 2468:17 2471:21 2476:21,22 2489:12 2489:16 2510:4 opportunity (7) 2423:14 2451:15 2455:7,11 2503:10 2503:11,19 opposite (1) 2457:25 orchestrated (1) 2413:5 order (39) 2353:13 2354:5 2355:2,13 2375:23 2376:15 2388:7 2393:12 2424:16,17 2424:23 2445:11 2455:20 2460:19 2461:5,23 2463:1 2467:22 2469:10 2471:25 2473:2 2474:4,14 2477:5 2478:22 2481:20 2482:10 2488:18 2494:4,8 2496:11 2498:4,9,19,24 2503:5 2505:13 2514:12,19 ordered (1) 2514:15

United Reporting, Inc. (954) 525- 2221

orders (6) 2353:13,20,24 2354:23 2411:4 2439:19 organizations (1) 2419:2 organized (3) 2496:1,2,3 originally (1) 2465:16 orsek (1) 2350:23 ostrow (1) 2351:2 outer (1) 2357:11 outside (4) 2386:23 2388:24 2407:24 2437:22 outstanding (1) 2364:19 overthetop (1) 2486:23 owe (2) 2460:5,6 owner (3) 2414:22 2438:24 2439:7 P p (10) 2345:16 2347:13,23 2348:2,13 2349:2,6 2349:18 2351:11 2514:16 package (1) 2476:16 packet (2) 2362:7 2372:16 padowitz (8) 2387:3,11,13,13 2476:18,24 2477:4 2478:11 page (3) 2352:11 2409:25 2418:15 pages (2) 2347:1 2517:7 paid (9) 2371:18 2391:3 2411:23 2424:24 2439:4,9 2459:14 2460:10 2477:8 pair (1) 2454:7

palin (1) 2395:14 paper (3) 2363:17 2388:12,22 papered (1) 2391:4 paperwork (1) 2370:4 paralegal (1) 2467:13 parcel (1) 2474:11 parents (1) 2455:1 paris (1) 2350:9 park (2) 2350:2,10 part (24) 2367:19 2380:12,16 2380:25 2381:1,9 2381:12,13,15 2413:23,25 2414:6 2414:11,16 2415:1 2415:3 2467:14 2474:11 2476:16 2480:1,2 2489:19 2502:20 2514:6 participants (2) 2413:9,14 participate (4) 2354:25 2413:9 2415:6,8 participated (7) 2397:21 2398:11 2421:19 2424:5 2427:16 2430:11 2475:5 participating (1) 2425:15 participation (1) 2421:2 particular (2) 2410:9 2424:20 parties (8) 2355:4 2362:23 2363:22 2379:2 2447:7 2486:4 2503:6 2517:11 partner (1) 2478:19 partners (5) 2346:22,24 2348:1 2475:3 2479:22 party (2)

Page 19 2503:8 2517:13 paskert (1) 2349:18 passed (2) 2362:23 2452:22 passion (2) 2434:21 2435:3 paul (1) 2349:17 pausing (2) 2423:5,11 paxil (1) 2438:5 pay (13) 2377:24,25 2379:6 2391:9,19 2392:9 2396:18 2421:12 2438:13 2457:3 2477:9 2478:13 2496:19 paying (4) 2391:15 2428:11 2457:1 2506:15 payment (6) 2390:19 2477:15,19 2477:24 2507:6,9 payments (9) 2370:10 2390:24,24 2391:22,24 2408:7 2431:17 2497:19,21 pearson (15) 2351:1 2466:11,11,12 2489:18,18,19 2501:12,18 2502:7 2502:12,16 2505:1 2505:5 2514:6 pearsons (1) 2502:25 penalty (1) 2420:16 pending (2) 2354:22 2506:24 pennsylvania (1) 2418:13 people (109) 2357:11,12,22,23,25 2360:24 2384:10,23 2385:18 2387:2,9 2387:22,23 2388:5 2393:18 2396:18 2398:15,18 2400:21 2400:24 2401:3,11 2401:14,16,20,22 2402:1,3,5,11,15,17 2402:20 2403:15

2404:4,8 2405:1,17 2406:5,23 2407:19 2407:22 2408:3,4 2408:12,17 2409:13 2409:16 2410:1,14 2411:21 2413:25 2416:16 2421:7,10 2424:6,14,16,21 2426:9,20 2429:11 2429:16 2434:2 2435:4 2436:7,10 2436:18,23 2438:11 2438:16 2441:6 2442:25 2443:14 2444:17 2451:13 2453:1 2458:21 2460:18,23,24,25 2461:5,6,25 2464:9 2465:16 2467:1,5,5 2468:14 2469:25 2470:7 2480:25 2486:16 2487:5 2494:10,12 2495:3 2496:23 2498:18 2503:4 2504:23,25 2509:12,19 2512:7 2513:18,20 peoples (1) 2358:3 perceived (2) 2384:19 2468:18 percent (4) 2417:3,18 2446:23 2456:10 perception (2) 2401:6,8 perfect (1) 2508:20 period (6) 2370:3 2381:23 2403:9 2470:21 2471:10 2489:13 perjured (1) 2435:14 perjury (1) 2420:16 permitted (1) 2353:10 permitting (2) 2353:13 2355:14 perpetrate (2) 2387:8 2411:2 person (18) 2369:17 2382:7 2399:3 2403:14,25

2404:15 2405:3 2407:12 2428:12 2429:13 2435:6 2444:8 2452:3 2467:13 2500:18 2507:10 2508:14 2511:23 personal (3) 2366:4 2391:16,20 personality (1) 2436:2 personally (3) 2425:14,22,23 persons (1) 2407:16 perspective (1) 2411:20 peters (2) 2419:14 2420:5 philanthropy (1) 2419:1 phillips (3) 2479:19,20,22 phone (4) 2384:25 2386:8 2441:21 2496:14 phony (18) 2360:14 2410:25 2411:2,4,6,8,12,14 2411:15,17 2412:7 2412:9,11,13,17,21 2413:5,12 photographs (1) 2418:16 phrase (2) 2410:18 2440:2 physical (7) 2384:11 2425:3,9,18 2425:21 2426:22 2431:25 pick (2) 2458:17 2496:14 picked (1) 2384:24 picturing (1) 2384:9 pinpoint (1) 2463:12 pitch (3) 2405:13 2456:19 2493:8 pitched (1) 2493:6 pl (1) 2349:14

United Reporting, Inc. (954) 525- 2221

place (3) 2345:17 2456:6,9 placed (2) 2418:23 2467:2 places (1) 2464:24 plaintiff (6) 2370:17 2411:23 2414:3,4,5 2495:22 plaintiffs (4) 2345:6 2346:6,12 2414:1 plan (23) 2438:9,10,10 2439:2 2439:3,7,12,14,18 2439:21,25 2440:3 2440:7,10,14,16 2442:8,10,23 2443:10,10 2474:11 2513:23 plane (2) 2382:3 2443:19 plans (1) 2505:18 plantation (3) 2418:10 2494:18,19 platinum (3) 2348:1 2350:1 2505:8 play (14) 2407:13 2413:23,25 2414:25 2415:3 2473:20 2474:14 2476:6,9 2495:21 2496:11,15 2498:5 2498:9 played (17) 2406:12,17,25 2414:3 2414:4,5,6,11,14,19 2473:17,18,18,24 2473:25 2493:11 2495:16 plaza (2) 2348:19 2351:15 please (5) 2359:20 2364:24 2430:25 2451:3 2508:1 plenty (4) 2364:8,10 2440:22,23 ply (1) 2410:22 plz (1) 2351:12 pocket (2) 2360:14 2398:5

pockets (1) 2417:21 podhurst (1) 2350:23 point (40) 2358:10,12,22 2368:24 2371:24 2372:21 2384:1 2390:2 2392:12 2407:16 2422:11 2424:4 2425:11 2427:8,19 2429:20 2431:12,19,24 2433:16,18,18 2440:18 2443:8 2444:16,18,23 2445:9 2446:2,19 2450:4,8 2464:21 2465:25 2471:24 2475:1 2487:6,21 2504:5 2510:11 pointing (1) 2460:14 points (4) 2407:25 2458:12,18 2491:24 poking (1) 2488:8 police (2) 2418:8 2419:6 political (4) 2418:5,21 2421:19 2500:3 politician (1) 2453:1 politicians (7) 2394:20 2401:15,17 2401:19 2418:17 2421:14 2428:10 ponce (1) 2347:23 ponzi (12) 2375:8 2384:8 2385:21 2419:14 2431:16 2432:2,13 2440:6,13 2460:18 2465:14 2488:22 ponzispeak (2) 2371:25 2447:10 poor (2) 2420:22 2427:25 portion (1) 2376:19 pose (2) 2467:19 2472:23

Page 20 posed (6) 2472:14,21,24 2473:8 2473:9,16 position (3) 2396:25 2487:13 2503:24 positions (1) 2421:20 positive (1) 2452:4 possibility (2) 2443:18 2445:4 possible (11) 2362:3,21 2365:9 2381:6,6,18 2406:6 2423:12 2450:13 2456:6 2459:8 potential (2) 2389:22 2493:20 potentially (1) 2384:10 power (4) 2401:6,8,9 2417:11 practiced (1) 2445:3 precise (3) 2386:20 2490:20,22 preconceived (1) 2469:13 preface (1) 2496:4 prepare (2) 2387:24 2466:21 prepared (3) 2360:14 2390:25 2481:25 preparing (3) 2470:16 2500:6,7 prescribed (3) 2437:6,8 2438:1 present (17) 2374:21 2398:9 2400:18 2403:23 2405:14 2421:25 2424:19 2426:13 2437:16 2453:4 2456:20 2457:15 2489:10 2490:6 2492:4 2500:4 2511:13 presented (2) 2449:19 2451:20 president (4) 2395:16 2439:23 2484:1 2487:14

presidential (1) 2395:14 pressed (1) 2406:25 pressing (1) 2407:4 pressure (3) 2407:16,19,25 pretend (2) 2413:16 2414:21 pretended (1) 2402:24 pretty (3) 2413:1 2432:7 2471:16 preve (36) 2350:22 2353:5 2356:17,21,23 2357:2,8,14,22 2358:5,8,17 2361:1 2361:9,24 2368:6 2368:17 2369:23 2370:24 2371:12,17 2383:21 2384:25 2386:4 2387:6 2388:6 2389:16 2392:23 2393:23 2466:25 2476:23 2490:14,14 2491:16 2510:4,12 preves (5) 2352:10 2368:1 2371:23 2392:22 2393:13 previous (1) 2379:4 previously (6) 2365:14 2425:12 2478:12 2481:15,18 2503:17 primers (1) 2467:8 prince (2) 2411:18 2435:17 prior (12) 2354:14 2355:12 2370:19 2431:25 2434:6 2435:15 2439:20 2441:13 2465:3 2467:2 2499:5,9 prison (19) 2382:4 2384:11 2405:12 2437:12,14 2437:22 2438:7

2441:3 2442:15 2443:17 2444:3,8 2445:6,8 2454:20 2456:6,9,23 2457:16 prisonspeak (1) 2447:11 private (2) 2346:14,17 privilege (9) 2423:13 2429:18 2437:19,20 2444:1 2444:2 2445:20,22 2468:2 privy (1) 2355:15 probably (5) 2356:9 2360:12 2459:4 2460:24 2513:8 problem (5) 2439:1,17 2478:5 2502:21 2503:23 problematic (1) 2449:3 problems (4) 2360:8 2390:23 2391:3 2483:12 proceedings (3) 2353:1 2514:23 2516:7 proceeds (1) 2361:13 process (2) 2396:14 2503:14 produced (1) 2369:6 product (2) 2467:6,8 productions (1) 2346:25 productive (1) 2438:15 products (1) 2417:5 professional (1) 2345:22 project (1) 2508:24 prolific (1) 2419:3 promissory (1) 2411:8 proper (1) 2368:11

United Reporting, Inc. (954) 525- 2221

properly (2) 2391:4 2450:11 propose (1) 2509:2 proposed (1) 2505:11 prosecutions (1) 2447:3 protocol (4) 2353:12,19,23 2354:23 protocols (1) 2355:16 proud (2) 2440:25 2443:3 provide (4) 2373:4 2388:9 2461:11 2462:17 provided (5) 2389:16 2390:11 2447:22 2452:25 2503:17 provides (1) 2451:24 providing (3) 2389:20 2390:22 2503:6 proving (1) 2384:2 psyche (1) 2405:9 psychiatrist (4) 2437:1,4,22,23 psychological (1) 2400:20 psychologist (2) 2437:22,23 psychopath (1) 2428:13 public (6) 2402:21 2403:11 2421:13,16 2516:12 2517:22 pull (1) 2369:20 pulling (1) 2459:17 purchase (1) 2421:19 purport (1) 2506:10 purpose (7) 2357:15 2447:5 2450:11 2462:4 2465:7 2474:3

2485:9 purposes (3) 2391:12 2411:20 2428:17 purposing (1) 2509:6 pursuant (1) 2389:15 pushing (2) 2373:25 2407:12 put (28) 2353:7 2355:21 2363:6,20 2374:8 2377:23 2387:2,6,7 2387:12,13 2389:9 2389:9,25 2414:17 2433:5,7,19 2434:11 2437:13 2454:22 2459:3 2463:16 2477:7 2478:13 2491:17 2509:9 2511:19 putting (7) 2371:14 2372:5,6,6 2467:1 2504:2 2511:16 Q quality (3) 2452:16,19 2453:8 quantity (2) 2452:20 2453:8 question (40) 2363:24 2372:24 2374:7,14 2377:14 2394:13,22 2407:2 2410:4,6,7,10,24 2422:20 2423:22 2429:17 2430:7,9 2430:23,24 2434:16 2436:15 2445:11 2457:11 2462:7,13 2465:4 2468:4,5 2471:9 2477:18 2482:7 2494:15 2504:15 2506:23 2507:5 2508:4,9,12 2508:17 questioned (1) 2405:18 questioning (5) 2354:25 2392:22 2433:9,15 2502:23 questions (28) 2360:20,21 2373:1

Page 21 2379:22 2403:8 2407:4 2408:6 2417:16,24 2449:7 2458:11,20 2464:19 2467:23 2470:5 2486:4,13,15 2487:2,4,8 2493:7 2503:13 2505:4 2506:19 2508:23 2514:1,20 quite (1) 2415:14 quote (8) 2373:8 2380:22 2388:7 2389:13 2407:6 2410:1 2468:18 2488:15 quotes (4) 2373:22,23 2374:9,10 R r (3) 2347:21 2516:1 2517:1 rabin (57) 2351:14 2352:5 2367:18,24 2368:5 2430:2 2458:6,14 2458:16 2460:2,12 2461:2 2462:9,12 2463:4 2464:15 2465:1 2473:7 2477:21 2486:1,7,9 2486:14,21 2487:1 2487:9 2489:17 2490:8 2491:1,9,19 2492:1,11 2493:13 2493:18 2495:1,11 2495:13 2496:19 2500:25 2501:3,7 2502:2 2503:21 2504:8 2505:7 2506:5,16,17,20,22 2507:25 2508:8,11 2508:17,22 2509:21 ramon (1) 2350:24 ran (1) 2462:22 rant (1) 2407:7 rasco (32) 2350:24 2352:4,6 2353:2,5 2356:5,12 2356:15,16 2364:9

2367:21,25 2368:8 2373:15 2375:22 2376:7,12,16,22,23 2378:6,9 2392:14 2393:4,8 2505:15 2509:22 2510:2,10 2511:21 2512:10 2513:25 rationalized (1) 2436:9 rationalizing (1) 2436:23 raton (1) 2349:11 ray (1) 2356:16 rayman (1) 2347:21 razorback (2) 2345:5 2347:18 read (14) 2358:9,20 2360:5 2368:3 2376:18,20 2384:15 2416:9,12 2416:23 2428:17 2455:21 2482:15 2487:3 reading (3) 2368:25 2466:1,7 ready (4) 2353:2,3 2429:8 2500:20 real (20) 2360:17 2365:1 2377:25 2402:18,18 2412:1 2413:8,14 2443:18 2464:25 2473:10 2485:23 2488:25 2489:1,1 2489:15 2490:2 2492:25 2497:7 2508:23 realize (2) 2480:9 2513:8 realized (2) 2465:18 2502:5 really (22) 2358:11 2360:3 2363:8 2369:1,4 2370:4 2374:9 2384:15 2426:11 2433:23 2435:1,4 2450:5 2471:18 2480:19 2482:15 2486:14,23 2488:3

2489:14 2492:23 2496:18 reask (1) 2430:24 reason (17) 2369:2 2374:8 2423:11,16 2449:12 2456:24 2458:1 2461:15 2468:6,11 2472:6 2478:8 2482:17,20 2489:1 2497:4,13 reasons (4) 2457:13,21 2458:2 2483:19 recall (55) 2359:3,7 2361:1,2,6 2361:14,21,24 2363:9 2371:12 2372:12,13 2375:15 2377:12 2378:17 2379:11 2380:21 2382:9,11,14,23 2383:17 2388:10 2412:3,5 2419:18 2419:20 2431:11 2432:18 2441:23 2449:20,23 2470:13 2470:15 2473:3 2481:22 2482:4,12 2482:13,17,25 2483:21 2487:16 2488:10,11,12 2489:5 2496:10 2497:16 2498:11 2499:5 2507:5,21 2512:13,15 receivables (1) 2364:19 receive (3) 2391:23,24 2503:9 received (1) 2480:3 receiving (2) 2370:17 2507:8 recess (2) 2429:7 2458:7 recollection (24) 2362:4 2382:21,25 2410:13 2411:24 2412:5 2461:4,22 2463:23 2464:3,8 2464:11,11 2467:20 2477:6 2480:18 2481:13 2482:23

United Reporting, Inc. (954) 525- 2221

2487:22 2488:10 2489:4 2490:9 2497:25 2500:20 reconciled (1) 2382:5 record (30) 2353:8 2354:20 2355:11,22 2356:18 2367:19,20 2376:4 2376:6,20 2392:18 2392:25 2410:10,20 2423:10 2449:9 2458:8 2483:14 2490:25 2493:16 2502:6,8,13,17,20 2503:19 2504:5,10 2514:11 2516:8 recorded (1) 2376:20 recordkeeping (1) 2375:20 records (4) 2362:13,14 2366:10 2389:14 recouping (1) 2513:21 recruited (2) 2492:12,23 red (2) 2392:12 2465:18 reduce (3) 2443:11 2448:10 2452:11 reduced (3) 2444:18 2451:17 2453:15 reducing (1) 2443:22 reduction (7) 2444:7,22 2446:22 2450:23 2451:5 2452:8,24 refer (3) 2497:24 2498:16 2499:13 referral (3) 2415:4 2475:8,9 referred (2) 2407:15 2498:15 referring (5) 2370:18 2377:15,22 2493:20 2494:5 reflect (5) 2347:1,2 2354:20 2355:11 2423:10

reflecting (1) 2369:23 refresh (2) 2412:5 2464:3 refreshes (1) 2482:23 refusing (1) 2353:21 regard (2) 2389:13 2494:7 regarding (7) 2356:23 2372:9 2403:11 2463:24 2464:12 2485:2 2487:12 regardless (1) 2444:3 regent (1) 2346:22 registered (1) 2345:22 regular (1) 2363:11 regularly (3) 2370:10 2406:15 2479:21 rein (2) 2360:21 2361:2 related (3) 2393:6 2426:3 2483:18 relating (1) 2375:11 relationship (6) 2402:12 2431:25 2480:4,7 2499:16 2506:9 relative (2) 2365:6 2517:12 relax (1) 2429:6 reliance (1) 2514:18 relied (1) 2369:11 religion (2) 2402:25 2403:13 religiosity (1) 2403:12 religious (2) 2403:9 2419:2 reluctant (1) 2471:25 rely (1) 2369:9

Page 22 relying (3) 2370:5 2514:11,14 remain (1) 2504:5 remember (26) 2358:19 2361:17,18 2361:19 2370:3 2371:15 2385:6 2390:16,17 2416:21 2431:18 2433:19 2434:18,19 2438:20 2449:25 2450:1,5 2465:25 2466:3 2480:17 2495:17 2506:25 2508:24 2510:18,24 remembered (1) 2473:15 reminding (1) 2433:16 render (1) 2377:17 renie (1) 2497:11 repay (1) 2377:11 repeat (3) 2422:3,20 2433:24 repeatedly (5) 2385:8 2436:4,7,21 2436:22 repetitive (1) 2486:23 rephrase (1) 2462:10 report (2) 2516:7 2517:6 reporter (13) 2345:22 2352:8 2353:16 2355:18 2373:12 2376:10,13 2376:20 2414:11 2514:13 2516:5 2517:4,18 reporting (1) 2345:23 represent (5) 2353:4,5 2356:17 2486:5 2503:8 representation (1) 2514:17 represented (1) 2354:11 representing (2) 2447:7 2449:10

reproduction (1) 2517:16 request (4) 2389:15 2482:2 2502:15 2514:5 requested (2) 2376:19 2482:11 requesting (1) 2482:14 requests (2) 2361:10 2465:20 require (1) 2451:12 required (1) 2408:2 requirement (1) 2371:11 research (1) 2416:13 resentencing (5) 2455:8,12,14,23 2456:1 reserve (4) 2354:7,8 2392:14 2514:20 resolve (1) 2380:23 respect (5) 2361:1 2383:18 2471:22 2481:14 2496:9 respectively (1) 2393:14 respond (3) 2372:23 2373:9 2407:5 responds (2) 2364:17 2367:14 response (7) 2368:9 2374:3 2380:21 2403:2 2410:9 2458:20 2470:2 responses (2) 2372:24,25 rest (2) 2442:21 2501:16 restaurants (1) 2418:2 result (2) 2371:13,13 results (1) 2364:4 retired (1) 2509:7

return (6) 2429:14 2441:1 2443:20 2451:19 2452:5 2459:23 returned (1) 2429:15 returning (1) 2435:15 returns (2) 2402:18,18 reverify (1) 2370:16 reviewed (2) 2388:3,6 reviewing (2) 2503:15,25 revolved (1) 2443:15 rewarded (2) 2408:17,20 rich (2) 2420:22,24 richard (2) 2466:11 2489:18 richer (1) 2420:24 right (139) 2354:7 2356:8 2363:12 2368:5 2369:3 2372:24 2375:8 2379:16,25 2380:18 2382:7,10 2382:24 2384:23 2385:1,2,3 2390:24 2391:24 2392:4 2393:20 2394:20 2397:5,17 2399:12 2399:16 2400:22 2401:12,15 2402:12 2402:22 2405:23 2407:1,9,16,19,20 2408:20,20 2413:1 2413:10,15 2414:1 2414:12 2415:1,4 2415:18 2416:24 2417:1,1 2418:19 2419:15 2420:17,22 2421:5,6,8 2422:16 2426:7 2427:6,10 2427:23 2428:15,21 2431:23 2432:7,13 2432:24 2433:4,9 2433:12,17,22 2434:22 2439:2,4 2440:13 2441:8

United Reporting, Inc. (954) 525- 2221

2442:9,13,17 2443:5,10,11 2445:5 2446:6 2447:14,18,23,25 2448:1,2,10,12,14 2448:16,25 2449:4 2449:19 2450:10,16 2455:5 2456:15 2458:17,24 2461:9 2462:24 2468:25 2469:3 2470:9,11 2471:13 2473:6 2477:15,22 2478:20 2480:24 2484:1,4 2484:16 2488:17 2489:9 2491:22 2494:21 2497:3,19 2497:22 2498:4,14 2498:23 2499:12,16 2500:5 2505:7 2506:16 2507:25 2509:2 2511:6 2512:12 rights (1) 2354:9 rival (1) 2509:10 rivaling (1) 2417:8 rli (1) 2348:17 road (1) 2349:10 robbins (1) 2348:10 roberta (2) 2349:9,11 robin (2) 2420:19,21 role (12) 2359:9,10,11 2415:20 2416:13 2462:21 2474:15 2483:9 2498:5,9 2509:14 2513:17 roles (3) 2473:24 2495:16 2496:11 roll (1) 2449:8 rosanne (1) 2349:21 rosenfeldt (5) 2354:21 2431:22 2478:20 2479:20

2510:15 rosenfeldts (1) 2467:13 rossi (2) 2499:12 2500:1 rothstein (40) 2345:8,13 2346:8,13 2347:4 2352:2 2353:11,14,22 2354:3,8,21 2355:1 2355:14,24 2356:16 2368:6 2393:17 2396:22 2399:25 2416:5 2418:23 2423:5 2430:16 2435:21 2441:24 2452:18 2458:15 2468:4 2470:4 2479:20 2485:20 2487:10 2503:8,11 2503:15 2505:20 2506:11 2510:3 2514:18 round (2) 2355:5 2461:10 rpr (2) 2516:12 2517:22 rra (1) 2435:3 rralaw (1) 2442:4 rule (12) 2447:3,11,14,20,24 2448:1,7 2450:15 2450:23 2451:4 2455:19,20 run (1) 2510:22 russ (5) 2478:19 2498:7,13,25 2498:25 russell (1) 2461:9 S s (10) 2345:23 2347:5,7,13 2347:25 2348:10 2349:7,14 2351:7 2443:16 safe (1) 2444:6 salesman (1) 2400:22 sam (5)

Page 23 2368:3 2458:4 2486:23 2503:23 2508:4 samuel (1) 2351:14 sand (1) 2438:17 sarah (1) 2395:14 sat (3) 2386:4 2487:3 2498:1 save (1) 2390:5 savoy (5) 2345:22 2516:5,12 2517:4,22 saw (1) 2508:5 saying (27) 2361:11 2365:12 2366:11,22 2367:14 2368:17 2387:17 2391:1 2426:4,5 2433:21 2442:1 2458:1 2460:9,13 2462:1,5 2463:20 2468:12 2473:16 2474:2,19 2475:6 2489:6 2492:3 2498:23 2501:9 says (8) 2362:18 2373:7 2391:18 2447:4,24 2448:2 2456:1 2505:13 scale (1) 2404:3 scandiffio (2) 2432:9,10 scenarios (1) 2415:9 scheduled (1) 2391:23 scheme (27) 2384:8 2385:21 2387:8 2402:9 2408:18 2419:14 2431:16 2432:2 2440:13 2460:19 2461:6 2462:2,3,23 2463:1,6,7,8,9 2465:14 2469:4 2478:23 2481:5 2486:17 2488:22 2489:20 2498:9

schemes (2) 2409:17 2419:13 scherer (54) 2347:19,21 2363:4,6 2364:6 2408:10 2409:20 2422:19,23 2423:9 2426:16 2445:10 2446:3,21 2447:5,15 2450:3 2452:12 2453:12,25 2456:16,25 2457:7 2457:22 2458:8 2460:22 2462:6,11 2463:2 2486:19,22 2487:24 2488:20 2490:16 2491:8,14 2491:23 2494:24 2501:1,5,10,21 2502:4,11,15 2503:1 2506:8,12 2508:3,10,18 2510:6,9 2514:5 scherers (2) 2412:2 2508:12 schlesigner (4) 2355:19 2368:3 2392:17,24 schlesinger (3) 2351:11,13 2505:23 schmookler (1) 2348:20 schnapp (2) 2348:15 2505:25 school (1) 2431:20 schwarzenegger (1) 2395:12 scott (28) 2345:8,13 2346:8,13 2347:4 2348:20 2349:6 2352:2 2355:24 2393:17 2396:22 2409:19,22 2410:1,15 2413:16 2429:6 2441:24 2472:15,16,19 2473:8,14 2474:4,6 2474:14 2485:20 2501:20 screen (1) 2412:10 scribble (2) 2360:16 2388:17 scum (1) 2380:13

second (6) 2372:16 2378:7 2389:8 2455:16 2460:5 2485:24 secretaries (1) 2414:5 secretary (1) 2504:2 secure (1) 2402:11 security (2) 2419:6 2466:8 see (28) 2359:7 2360:6 2367:16 2368:9,15 2369:1,12 2370:23 2372:23 2378:16 2382:13,19 2388:23 2389:5 2404:22 2463:3 2469:16 2470:1 2482:16,23 2485:3 2490:21 2494:24 2501:20,22 2502:2 2503:12 2512:16 seeing (7) 2361:1 2368:19 2377:16 2436:25 2463:11 2490:12 2507:22 seek (3) 2361:25 2363:21,21 seeking (3) 2361:16,17 2374:11 seen (5) 2383:12 2436:25 2437:22 2450:6 2510:7 seigal (1) 2350:11 selfdestructive (1) 2511:19 sell (2) 2467:6,8 selling (1) 2417:5 seltzer (1) 2398:5 senator (3) 2394:25 2395:2,5 send (10) 2353:22 2356:3 2370:10,10,11 2371:5 2386:14 2388:21 2396:24

United Reporting, Inc. (954) 525- 2221

2495:4 sending (6) 2354:5 2370:2,6,7 2383:13 2461:12 sends (1) 2369:13 senior (2) 2479:21 2487:14 sense (5) 2383:9 2400:24 2404:18,22 2512:19 sensed (1) 2401:4 sent (9) 2360:19 2366:12 2382:12 2386:6,7 2414:22 2475:6 2485:5 2499:20 sentence (20) 2400:4,7,10 2442:20 2443:9,11,22 2444:10,18,22 2446:9,22 2448:10 2449:14 2451:16 2452:11,24 2453:15 2455:24 2456:4 sentenced (1) 2455:17 sentencing (8) 2399:8 2416:20 2429:25 2430:3 2450:10,15 2455:16 2472:6 senterfitt (1) 2348:8 separate (2) 2502:8,12 separately (1) 2365:23 sequential (1) 2375:23 series (2) 2415:7 2482:1 seriousness (1) 2356:21 sertraline (2) 2437:6 2438:1 served (2) 2354:13,15 serving (1) 2443:9 session (4) 2345:12 2347:2 2394:10 2409:24 set (3)

2497:1 2504:11 2505:18 sets (1) 2374:1 settlement (6) 2362:1 2388:2,25 2406:17 2411:6,21 settlements (1) 2474:8 shareholders (1) 2485:12 sheriffs (1) 2418:6 shirt (4) 2414:17 2454:7,9,13 shirts (1) 2454:14 shit (2) 2491:13,17 short (1) 2489:13 shortage (12) 2375:11 2377:8,10,15 2377:18,21,22 2378:13,18,21,22 2378:23 shorthand (3) 2516:5 2517:4,9 shot (1) 2432:17 shots (1) 2412:10 shoulder (2) 2373:10,13 shouldnt (1) 2459:5 show (18) 2361:22 2366:10,18 2366:19 2375:16 2378:5,6 2379:11 2379:13 2382:11 2385:24 2388:1 2390:4 2399:17 2412:4 2467:5,5 2487:20 showed (4) 2372:9 2464:23 2465:8 2499:2 showing (2) 2373:10 2411:20 shows (3) 2415:17,18,25 shut (3) 2353:15,20 2404:24 sic (1)

Page 24 2453:11 side (3) 2368:19 2446:14 2479:11 sign (4) 2373:7,16,22 2387:13 significant (3) 2365:1 2493:23 2498:16 silverman (1) 2349:14 silversea (1) 2419:15 similar (1) 2509:3 simony (1) 2359:21 simple (5) 2365:14 2383:17 2384:4 2403:21 2417:8 simply (8) 2359:23 2365:9 2370:5 2372:6 2468:2 2477:6 2478:6 2479:3 singerman (2) 2347:10 2494:20 single (4) 2417:2,16 2444:8 2452:3 sir (23) 2353:17 2355:18 2368:15 2396:14 2397:8 2399:11 2400:5 2405:8 2410:12,18 2426:11 2434:5,17 2436:13 2437:1,9 2448:6 2455:16 2472:12 2487:11 2489:24 2509:16,20 sister (3) 2398:24 2450:1 2455:1 sit (14) 2357:18,19 2358:20 2363:14 2380:2 2383:1 2384:15,20 2388:16 2464:2 2471:18 2482:13,15 2498:10 sitting (6) 2388:18,19 2426:3 2440:22 2445:5

2488:7 situated (2) 2364:13 2478:6 situation (1) 2384:7 six (1) 2349:23 sixth (1) 2349:7 size (1) 2358:3 skills (1) 2413:4 skolnick (1) 2348:14 sleep (1) 2426:4 sleeping (3) 2427:8 2431:23 2493:14 slow (2) 2373:12 2469:17 small (1) 2390:21 smart (2) 2511:23,25 smooth (1) 2469:18 sneakers (2) 2454:5,18 socialites (1) 2418:18 socialized (1) 2397:5 society (2) 2418:15 2438:15 sociopath (1) 2436:18 sociopathy (3) 2436:14,16 2437:8 soil (1) 2443:16 sold (1) 2440:23 soldier (1) 2468:19 solely (2) 2457:5,5 solution (1) 2510:21 somebody (14) 2371:3 2404:22 2424:10 2433:7 2448:19 2450:25 2452:22 2467:19

2468:22 2474:23 2476:19 2485:5 2495:21 2499:17 someday (1) 2444:9 someplace (3) 2372:5,6,7 son (3) 2398:25 2439:22 2493:3 soon (1) 2456:6 sophisticated (1) 2417:8 sorry (28) 2354:18 2361:15 2363:5 2367:21 2368:10 2378:10 2399:20 2400:8 2407:2 2409:21 2422:3,19 2436:15 2438:19 2441:9 2448:20 2468:7 2472:16,20 2473:7 2473:13 2477:21 2480:6 2484:6,18 2493:24 2494:22 2508:13 sort (1) 2511:18 sought (1) 2366:1 sound (1) 2473:21 sounds (1) 2362:4 source (2) 2485:1,3 sources (2) 2377:19 2415:4 south (3) 2347:19 2348:3 2349:2 southeast (1) 2348:8 southern (2) 2438:19,19 speak (5) 2385:11,13,17 2448:19 2504:12 speaker (8) 2375:24 2408:11 2422:1,14 2424:15 2425:20 2427:1 2454:4

United Reporting, Inc. (954) 525- 2221

specific (12) 2357:12 2358:18 2362:4 2370:18 2371:21 2386:21 2407:22 2415:23 2465:24 2467:23 2470:15 2490:9 specifically (11) 2371:3 2376:7 2378:12 2390:2 2393:8 2431:12,18 2432:18 2459:22 2482:12 2487:5 specifics (3) 2361:21 2394:22 2396:15 speculate (1) 2382:17 speculating (1) 2377:22 speeches (1) 2470:6 spend (4) 2404:9,14 2430:21 2442:20 spinosa (8) 2351:10 2392:19,21 2481:2,9,25 2482:10 2486:6 split (1) 2475:4 spoke (8) 2357:1 2385:18 2441:13 2448:20,22 2448:24 2483:16,17 sporting (2) 2409:7 2419:7 sports (1) 2418:17 spot (1) 2390:21 spousal (1) 2444:2 spritzer (1) 2364:25 srothstein (1) 2442:4 st (4) 2349:17,18 2350:19 2350:23 stack (1) 2452:15 staffed (1) 2505:17 stand (3)

2373:10,13 2487:8 standard (2) 2407:7 2433:10 standing (1) 2507:10 start (13) 2407:4 2433:9 2445:9 2446:3 2461:6 2464:2 2469:10,11 2472:7 2502:7,9,11 2505:4 started (10) 2399:15 2408:6 2433:3 2469:25 2470:16 2471:23 2490:15 2498:22 2509:13 2512:16 starters (1) 2390:19 starting (2) 2379:2 2509:3 starts (4) 2387:15 2469:19 2501:15,18 state (6) 2356:18 2473:7 2516:3,12 2517:2 2517:22 stated (2) 2376:7 2393:8 statement (6) 2383:17 2384:5 2453:5 2472:12 2485:10 2493:12 statements (12) 2356:22 2360:15 2369:6,7 2403:11 2412:9,21 2481:16 2498:8,18 2500:8 2500:11 states (8) 2351:7 2372:21 2395:2,5 2418:12 2441:1 2442:9 2443:20 stating (4) 2361:9 2362:11 2368:10 2377:2 statute (2) 2447:4 2448:2 stay (4) 2449:8 2479:7 2480:5 2503:19 stays (1) 2502:17

Page 25 ste (7) 2348:13 2349:18 2350:19,23 2351:3 2351:8,12 steal (1) 2420:21 stealing (3) 2420:22,23 2439:24 stearns (1) 2350:18 steffen (1) 2390:15 stenotype (1) 2517:6 step (1) 2382:2 stepped (1) 2443:16 stettin (12) 2346:17,18,20,21,22 2346:23,25 2347:9 2449:18,21 2451:24 2453:11 steve (15) 2414:3,4 2472:13,17 2475:21 2484:1 2495:14,14,19 2496:7,13,13,15 2499:12 2500:1 steves (1) 2495:23 stickers (1) 2376:3 sticking (1) 2438:17 stolen (2) 2378:24 2436:9 stone (1) 2351:9 stood (1) 2513:14 stop (4) 2407:14 2429:12 2501:19 2503:22 stopped (3) 2429:10 2511:9,16 story (7) 2408:7 2438:22 2472:3,8 2474:13 2480:16 2495:20 strategy (1) 2388:8 street (3) 2345:18 2347:13 2349:7

stress (1) 2384:12 stretching (1) 2418:6 strike (2) 2353:25 2354:16 stripes (1) 2403:22 structure (1) 2388:3 structured (2) 2346:18 2348:1 stu (2) 2383:4 2431:22 stuart (2) 2467:12 2478:20 student (2) 2427:9 2431:21 stuff (5) 2372:19 2387:7 2456:8 2489:15 2511:20 stupid (1) 2512:8 suarez (1) 2347:16 subject (5) 2367:7,8 2372:19 2376:8 2459:10 subjects (1) 2393:9 submitted (1) 2366:7 subponzi (2) 2462:23 2489:19 substantial (5) 2447:23 2450:24 2451:4 2478:11 2481:21 succeed (1) 2358:4 success (3) 2402:8,15 2417:25 successful (1) 2412:25 sufficient (1) 2356:19 suggest (3) 2423:20 2438:11 2441:5 suggested (2) 2447:20 2510:20 suggesting (4) 2366:6 2385:20 2442:24 2459:13

suggestion (1) 2438:16 suicide (4) 2432:3,6,12,15 suite (7) 2347:6,11,14 2348:3 2349:3,10 2351:15 suited (2) 2407:13 2504:15 summarized (1) 2462:15 summarizing (1) 2495:15 sums (1) 2411:22 sundry (1) 2459:18 supposed (11) 2369:12 2377:25 2391:15,23,24 2396:4,8,21 2499:4 2503:9,16 sure (22) 2374:10 2380:2 2386:25,25 2390:4 2390:10 2392:17 2393:17 2422:15 2423:25 2446:17 2447:7 2449:8 2453:24 2461:8 2465:6,6 2470:18 2482:9 2494:15 2495:11 2500:25 surrogate (1) 2506:11 susan (3) 2348:4 2473:4,5 susceptible (2) 2404:11,23 suspect (1) 2432:20 suspicious (1) 2483:24 sw (1) 2351:3 switch (1) 2405:2 switches (1) 2481:16 sworn (2) 2355:25 2433:11 symptoms (2) 2436:14,20 system (2) 2411:21 2466:8

United Reporting, Inc. (954) 525- 2221

szafranksi (1) 2350:12 szafranski (7) 2367:11 2368:9 2374:24 2488:13 2491:2 2510:13,14 T t (4) 2516:1,1 2517:1,1 table (1) 2355:3 take (11) 2354:25 2378:11 2387:14 2388:11 2392:15 2442:20 2458:4 2464:25 2471:2 2500:21 2508:18 taken (8) 2345:16,22 2354:1,2 2371:18 2410:17 2429:7 2443:3 talk (16) 2372:5 2400:20 2413:3 2419:13 2428:25 2438:12 2440:1 2446:25 2447:10 2448:8 2452:18,19 2456:7 2456:8 2480:24 2481:8 talked (13) 2375:10 2379:21 2399:18 2441:7,10 2447:10 2450:2 2478:20 2493:3 2495:14 2498:21 2500:5,6 talking (18) 2363:15,15 2372:2 2379:16 2386:22,23 2399:15,20 2432:8 2443:14 2447:11 2455:15 2464:13 2495:25 2496:1,2 2498:12 2501:6 tallahassee (1) 2418:11 tampa (2) 2349:18,19 tanen (1) 2348:2 tangible (1) 2410:22

target (1) 2454:16 tax (13) 2420:11,12,14,15,16 2421:2,3,7,9 2459:10,23 2476:16 2479:23 taxes (6) 2420:13 2421:10 2459:14,16 2460:5 2460:10 td (17) 2346:13,20 2348:12 2354:2,9 2374:15 2464:22,25 2465:8 2465:10 2480:24 2482:24 2486:8 2497:1,4,6 2505:25 teaching (1) 2454:21 technique (1) 2407:15 ted (18) 2398:4,7,10 2413:20 2419:23 2420:7 2439:23 2440:1 2473:15,17,19 2474:6,7,12,18,19 2475:2,2 telephone (1) 2413:10 telephonic (3) 2413:5,8,12 tell (66) 2355:25 2357:18,20 2358:9 2360:20 2368:20 2369:4,11 2369:16,20 2370:12 2370:13 2382:13 2385:3,25 2389:6 2392:6 2396:1 2403:21 2417:1 2433:12 2438:13 2442:15 2443:23 2446:16 2450:25 2451:15 2453:20 2456:10 2458:2 2460:19 2465:7 2468:5,11 2469:11 2470:12 2473:14 2474:4,24 2475:11 2475:13,14,15 2476:5,8 2478:10 2478:22 2481:16 2482:18 2488:17,23

Page 26 2489:2,25 2492:5 2494:8 2495:3,20 2495:22 2496:13 2497:3,5 2498:4,24 2499:1,25 2507:1 telling (17) 2360:7 2365:13 2369:14,24 2381:2 2404:7 2405:6 2434:1,3 2437:13 2448:3 2457:6 2466:3 2470:13 2485:11 2490:3 2498:10 tells (2) 2369:17 2451:8 ten (3) 2404:3,3 2419:21 tens (1) 2460:8 tentacles (1) 2469:22 term (1) 2491:13 terms (4) 2481:4,11 2499:3 2501:25 terribly (1) 2398:21 testified (14) 2356:1 2372:10 2380:1,12 2381:20 2407:6 2411:25 2417:23 2425:12 2462:16 2481:15,18 2483:5 2491:12 testify (1) 2409:25 testimony (21) 2354:1,2,4 2356:22 2357:4 2363:9 2433:11,11,24,25 2439:20 2440:17 2450:2 2463:23 2496:9 2499:4,5,14 2504:24 2505:1 2511:22 text (1) 2441:19 texting (1) 2385:7 thank (11) 2354:18 2356:11 2376:22 2392:24 2422:23 2470:10

2505:7 2506:20 2508:10 2513:25 2514:22 thanks (1) 2367:25 thats (87) 2357:21 2358:14 2360:2,4 2362:8,18 2365:16 2369:21 2376:14 2377:10,10 2385:5 2386:11 2391:4 2394:13 2398:6,12,13,17 2399:7,22 2401:5,7 2401:13 2404:12 2405:10,13,15 2407:20,20 2409:18 2414:2 2416:17,17 2416:18 2417:23 2418:20,25 2419:5 2419:9,12 2420:23 2425:6 2426:2,3 2427:18,21 2428:5 2430:9 2432:11 2433:10 2434:23 2436:5 2438:4,16 2440:9 2443:10 2445:17,20,22 2447:24,25 2451:5 2451:13,23 2452:10 2458:6 2465:9 2468:2,17,24 2469:2 2470:2,3 2477:22,25 2480:22 2485:18 2486:17 2488:10 2489:15 2491:10,20,25 2493:12 2505:2 2514:22 theme (2) 2460:16 2464:5 thenconscious (1) 2440:24 thengovernor (1) 2397:1 theres (16) 2358:11 2367:6 2371:25 2376:6 2378:20 2423:25 2433:8 2450:17 2451:7,11 2455:19 2455:25 2456:7 2463:12 2466:15 2467:9 theresa (1)

2347:16 theyre (5) 2393:11 2428:16 2446:24 2470:1 2501:5 thief (1) 2380:13 thieves (3) 2492:2,6,10 thing (27) 2357:3 2358:7 2364:18 2382:8 2384:23 2385:1,2,4 2387:12 2388:18 2399:19 2417:17 2426:6 2440:11 2443:5,5 2452:13 2453:21 2469:16 2475:9 2488:25 2492:7 2495:17,18 2497:10 2501:18 2512:4 things (49) 2357:4,12 2360:9 2363:10 2386:6,7 2389:12 2398:13 2399:5 2405:7 2406:22 2408:15,16 2415:24 2416:23 2424:22 2440:22 2449:2 2456:2 2458:22,25 2459:3 2459:4 2460:20 2461:13 2463:5,6,7 2463:8 2465:21 2466:1 2468:16 2469:15,19,25,25 2471:23 2474:10 2476:23 2480:18 2483:20 2487:20,23 2490:4 2492:25 2495:5 2504:1 2511:15 2512:8 think (65) 2355:8 2374:8 2377:14,18,21,22 2381:24,25 2382:4 2383:6,9 2384:4,22 2388:20 2391:17 2411:24 2424:7 2428:23 2431:12 2433:10 2435:6,7 2435:24,24 2438:22 2440:16 2441:12 2442:7 2443:6

United Reporting, Inc. (954) 525- 2221

2444:10 2447:3 2452:2,14 2455:18 2455:19,21,22,25 2457:20 2463:20 2464:2 2466:21 2469:20 2470:13,18 2470:23 2474:10 2475:8,9 2477:10 2477:20 2480:25 2483:5 2489:14 2491:11 2492:16,19 2492:25 2493:7,12 2497:21 2499:5 2504:14 2508:2 2511:7 thinking (6) 2368:25 2395:24 2446:15 2465:25 2477:20 2483:23 third (4) 2345:23 2348:8 2363:22 2372:21 thought (13) 2369:23,25 2371:1,5 2405:19 2416:2 2465:16 2480:10 2489:8 2491:5,10 2511:15,22 thousands (5) 2368:10,23 2383:21 2384:2 2511:7 threat (2) 2425:3,4 threaten (4) 2424:10 2425:21 2426:18 2440:7 threats (2) 2425:9,18 three (6) 2417:24 2432:24 2454:15 2459:11 2480:25 2510:3 thriving (1) 2418:3 throckmorton (1) 2347:23 throw (1) 2408:12 tie (1) 2414:17 tiger (1) 2403:22 tightly (1) 2355:1 time (84)

2345:16 2353:10,21 2354:19 2355:20 2356:19,24 2358:8 2358:10,12 2366:7 2368:24 2369:3 2370:4 2371:24,24 2375:3,7 2376:8 2378:11 2380:13,14 2380:18 2381:20,23 2382:6 2383:20 2384:1,12 2385:16 2386:1 2391:3 2392:13,15,23 2398:23,23 2404:9 2404:14 2408:3 2414:14,21 2415:15 2430:22 2431:12,19 2431:24 2435:21 2437:21 2440:18 2442:13 2443:12 2445:4,19 2448:14 2448:17 2459:12 2464:21 2465:25 2466:19 2467:18 2470:18,21 2471:10 2471:24 2473:17 2479:2 2480:18 2486:25 2487:25,25 2488:21 2489:13 2491:24 2493:3 2502:22,23 2503:3 2504:11 2505:12,22 2509:8,22 2512:18 timely (2) 2353:22 2354:6 times (18) 2360:19 2388:16 2392:21 2399:16,18 2413:25 2414:15 2435:12 2459:2,4,9 2459:9,11 2467:16 2476:18 2486:11 2491:7 2500:6 timing (2) 2371:21,22 timmerman (4) 2428:6 2429:1 2431:5 2432:2 title (1) 2487:16 toast (3) 2373:8 2491:4,5 today (17) 2355:8 2380:2 2384:20 2390:5

Page 27 2456:11,12,13,23 2464:7 2482:13 2498:10 2504:17 2505:14,15,16 2511:4 2514:16 token (1) 2465:13 told (83) 2355:3 2357:16 2366:3 2374:18,19 2392:10 2405:24 2406:2 2409:19 2410:1 2412:2 2417:16 2435:10 2437:10 2444:4 2445:25 2460:18,23 2460:24,25 2461:5 2461:14,20,21,22 2462:2,3,16,18,18 2462:24 2463:5,6,8 2463:9,24 2464:9 2464:12 2465:14,22 2466:10,10,11 2467:10,21,25 2469:1,6,9 2470:7 2471:1,2,19,25 2472:6 2474:6 2477:4,6 2481:18 2481:22 2482:10,19 2482:21,22 2485:1 2486:15 2487:5 2488:4,4,24 2490:1 2490:10,22 2492:24 2494:10 2498:25 2499:2 2500:1,10 2500:12 2510:21,22 2511:14 tomorrow (7) 2501:14,18 2504:17 2504:18 2505:3,12 2505:21 tools (5) 2400:20 2401:1,13 2410:22,22 top (1) 2469:21 topics (1) 2466:13 total (1) 2419:17 totally (1) 2448:18 tough (1) 2399:15 tower (1)

2348:3 town (1) 2461:23 tracy (28) 2360:12,13,18,19,22 2362:6,11 2364:16 2365:1,5,13,18,19 2365:20,21 2366:7 2366:12,22,23 2389:9,15,20,24,25 2460:7 2466:17 2500:5 2507:3 trade (2) 2410:23 2416:10 traffic (33) 2358:9,16,24 2359:8 2359:13 2360:20 2361:22 2363:19 2368:19 2369:1,2 2375:17 2378:17 2379:12 2382:12,13 2382:17 2383:10,13 2388:11 2389:12 2463:3,12 2478:6 2482:16,23 2487:21 2488:3,7 2489:2 2490:12,21 2507:22 trails (2) 2459:8 2464:9 transactional (1) 2479:10 transactions (1) 2489:8 transcript (9) 2358:20 2409:25 2430:4 2487:7 2502:17 2508:21 2514:3 2516:8 2517:16 transcription (1) 2517:8 transcripts (1) 2487:3 transferring (2) 2372:2,3 transparency (2) 2406:15,23 trappings (2) 2402:14 2417:25 traurig (1) 2348:13 travel (1) 2505:18 tremendous (2) 2435:1 2513:8

trench (2) 2348:2,4 tricks (1) 2416:9 tried (7) 2358:2,6 2359:10 2365:1 2383:3 2399:8 2440:12 trigger (2) 2456:2,3 triggering (1) 2485:14 tripp (1) 2349:6 trips (2) 2408:24 2419:7 tropin (2) 2347:23,25 trouble (2) 2353:16 2389:24 true (11) 2380:14,17 2398:6,17 2407:21 2417:5,15 2463:6,8 2516:8 2517:8 truly (5) 2429:4,4 2440:25,25 2513:6 trust (23) 2346:14,17 2361:4,7 2361:12,12,13,18 2367:1,12 2368:18 2369:22 2371:14 2374:11 2375:4,13 2377:23 2386:9,10 2390:23 2392:3 2401:4 2485:6 trustee (9) 2347:8 2354:1,9,13 2445:10 2446:3,11 2446:13,20 trustees (2) 2353:12,19 truth (14) 2355:25 2384:20 2403:21 2404:7 2405:6,15,25 2433:12,22 2434:1 2434:3 2443:24 2457:6 2458:2 truths (2) 2488:5 2490:22 try (11) 2356:24 2381:2 2383:10 2407:14

United Reporting, Inc. (954) 525- 2221

2458:25 2461:4 2464:2 2466:7 2470:4 2504:20,20 trying (16) 2353:14,20 2370:16 2380:22,23 2381:25 2382:22 2384:16,22 2440:11 2447:25 2459:7 2460:13 2464:20 2470:6 2480:8 tshirt (1) 2414:18 tucker (1) 2349:24 turn (7) 2367:6 2385:2 2405:2 2441:2 2442:11,12 2442:14 turned (2) 2399:22 2405:11 turning (1) 2365:7 twice (2) 2371:15 2472:25 two (12) 2348:3 2355:7 2358:1 2376:12 2390:16 2417:16 2454:3 2455:6 2459:11 2483:5 2492:9 2508:23 type (6) 2387:4,4 2388:18 2426:23 2431:10 2476:1 typed (1) 2399:13 typewritten (1) 2399:12 U u (2) 2351:7 2443:16 ultimate (2) 2382:5 2513:17 ultimately (4) 2474:8 2475:5 2484:9 2484:23 umbrella (1) 2490:10 uncomfortable (1) 2468:1 undercover (3) 2429:22 2430:12

2431:2 underlying (1) 2354:21 understand (23) 2363:3 2372:8 2389:18 2407:2,10 2410:24 2416:25 2424:7 2426:11 2434:3 2436:15 2447:24 2450:19 2462:7,14 2474:20 2474:22 2477:2 2486:12 2495:23,24 2501:12 2506:8 understanding (7) 2380:24 2432:5,14 2446:24 2448:4,5 2486:5 understands (1) 2424:7 underwear (1) 2454:6 unfortunate (1) 2512:6 unfortunately (5) 2416:6,16 2468:15 2504:4 2513:3 unique (2) 2358:7 2421:9 united (8) 2345:23 2351:7 2395:2,5 2418:12 2441:1 2442:9 2443:20 unknown (2) 2375:24 2454:4 unquote (8) 2373:8 2380:22 2388:7 2389:14 2407:6 2410:1 2468:19 2488:15 unrealistic (1) 2456:13 unsecured (1) 2348:7 untrue (1) 2381:12 upcoming (1) 2359:25 urge (1) 2502:19 urged (1) 2510:21 use (13) 2356:9 2359:21,21

Page 28 2374:2 2407:25 2410:25 2434:16 2436:18 2437:14 2438:12 2464:22 2465:10,10 usually (2) 2414:18 2420:21 utilize (1) 2464:23 utilized (3) 2395:20 2401:22 2411:2 uwant (1) 2351:1 V v (7) 2346:17,18,20,21,22 2346:23,25 vagaries (1) 2358:3 vague (2) 2429:17 2497:25 value (1) 2348:1 van (2) 2347:16 2447:6 varied (1) 2461:1 variety (1) 2487:20 various (10) 2353:19 2379:1 2380:21 2419:13 2459:18 2465:21 2478:18 2479:10 2486:16 2491:24 verbally (2) 2388:9,12 verification (2) 2367:9 2374:11 verifications (1) 2461:11 verifier (1) 2488:15 verify (3) 2488:18 2499:20 2500:18 verifying (1) 2489:8 vetting (1) 2396:23 vice (1) 2487:14 victims (1)

2414:12 villegas (15) 2397:13 2427:10,12 2427:15,19 2428:15 2428:19 2469:1 2471:13,15,19,22 2472:5 2480:12,14 violated (4) 2434:4,7,19 2435:9 violation (2) 2353:12,19 violence (4) 2425:4,14 2426:22,23 vliet (2) 2347:16 2447:6 voices (1) 2473:21 von (2) 2377:20 2379:9 vs (3) 2345:7 2346:7,12 W w (9) 2345:8,13 2346:8,13 2350:19,23 2352:2 2355:24 2395:16 wait (6) 2363:14 2383:3 2389:8 2446:10 2460:5 2501:7 waiting (1) 2423:25 waive (1) 2444:1 waiver (1) 2494:25 walked (2) 2478:7 2499:6 walker (1) 2349:8 want (45) 2356:24 2357:3 2362:20 2364:23 2373:10,13 2376:1 2377:16 2378:11 2382:17 2385:11,13 2385:16 2411:22 2423:7 2428:22 2433:20,23 2434:2 2440:10 2443:4 2445:7,14 2449:8,8 2450:25 2456:2,11 2458:17,18 2461:3 2461:6 2462:13

2466:13 2474:6 2480:24 2487:22 2488:9,9 2489:5 2490:13,20,24 2501:7 2514:10 wanted (12) 2366:22 2374:5 2404:25 2456:19 2460:3,3 2465:10 2468:18 2476:15 2507:16,17 2509:9 wants (3) 2365:8 2386:15 2500:22 washington (1) 2418:12 wasnt (20) 2366:21,25 2381:3,10 2387:22 2400:1 2407:5 2428:5 2440:7,11 2442:12 2442:23 2459:1,9 2468:4 2473:2 2477:18 2488:25 2491:2 2496:1 watch (2) 2351:1 2454:6 waving (1) 2437:20 way (32) 2357:21 2359:6 2369:8 2373:21 2374:25 2378:22 2382:13,18 2383:11 2385:20 2391:13 2398:7 2411:1 2416:8 2418:7,10 2418:12 2420:15 2424:20 2444:21 2455:18 2459:13 2463:12 2464:17 2468:17 2475:19 2476:11 2479:17 2483:23 2491:21 2495:19 2508:21 wayne (2) 2494:6 2497:22 wealth (2) 2402:14 2417:11 wearing (2) 2454:2,14 weaver (1) 2350:18 website (12) 2374:1,5,6,15,15

United Reporting, Inc. (954) 525- 2221

2464:22,25 2465:8 2465:10 2497:1,4,6 websites (1) 2412:7 wed (1) 2506:7 weeks (1) 2454:3 weewee (1) 2362:18 weintraub (13) 2360:12 2362:6,11 2364:16 2460:7 2466:17 2500:5,17 2507:3,4,8,15 2508:15 welcome (1) 2422:24 went (5) 2365:5 2387:21 2390:17 2436:21 2470:25 werblowsky (1) 2350:7 weve (3) 2435:7 2438:22 2462:23 whats (10) 2357:19,20 2371:25 2377:2,3,8 2378:24 2457:4 2476:14 2501:4 whatsoever (1) 2354:24 white (1) 2418:13 whitecollar (1) 2428:9 whoa (2) 2442:24,24 wholly (1) 2456:12 whos (1) 2428:18 wife (6) 2399:2 2418:16 2426:4 2443:14 2454:5 2455:1 wifes (1) 2418:22 william (2) 2347:21 2496:21 willingly (2) 2469:12 2479:1 wish (3)

2445:8 2447:8 2486:23 wishes (1) 2453:17 withdraw (2) 2457:7 2510:9 witness (29) 2345:22 2353:3 2356:2 2363:5 2375:18,25 2392:20 2422:3 2424:12 2425:23 2428:22 2429:2,8 2430:24 2437:14 2445:14,21 2458:4 2477:16 2478:2,4 2494:18 2494:22 2499:23 2501:22 2506:17 2507:6,9 2508:4 witnessed (2) 2507:7 2508:14 witnesses (9) 2477:14,19,23 2485:19 2497:19,20 2500:16 2507:2 2510:11 woman (2) 2399:6 2414:25 women (1) 2409:1 won (1) 2474:10 wonderful (1) 2448:9 word (13) 2358:19 2373:22,23 2374:8 2378:12,18 2386:12 2417:2 2436:16,18 2494:13 2498:21 2513:4 words (3) 2358:22 2377:19 2384:13 work (6) 2399:24 2400:1 2431:13 2443:7 2470:8 2512:24 worked (12) 2357:21 2369:21 2397:17 2398:22,23 2398:24 2402:11,17 2411:21 2438:6 2442:25 2512:23 working (3) 2431:25 2440:11

Page 29 2513:2 works (3) 2455:18 2486:8 2494:20 world (3) 2389:18 2398:16 2409:14 worry (2) 2404:7 2466:12 worthy (1) 2402:22 wouldnt (7) 2378:20 2389:24 2401:3 2439:10 2446:1 2463:16 2496:16 wpi (1) 2417:14 write (14) 2363:11 2368:22 2371:7 2390:12 2442:5 2458:21 2466:4 2475:12,15 2475:16,18 2476:19 2477:5 2511:12 writes (1) 2373:21 writing (10) 2373:1,17 2378:22 2388:9,10 2442:2 2458:25 2466:6 2475:5 2511:25 written (5) 2380:20 2449:23 2450:6 2459:5 2511:6 wrong (12) 2369:20 2371:14 2381:14,16,19 2384:22 2389:19 2420:12 2443:5 2446:23 2459:13 2464:24 wrote (10) 2368:21 2374:10 2399:11,13 2449:25 2450:1,3 2459:4 2465:23 2475:9 X Y yacht (1) 2439:4 yeah (7)

2425:25 2430:10 2431:15 2455:18 2460:12 2469:4 2513:6 year (8) 2364:20,25 2365:13 2365:15 2366:2 2431:14,16,19 years (13) 2381:21 2400:6,9,11 2444:11 2449:14,14 2455:4,6 2475:3 2492:9 2512:22,23 yesterday (6) 2357:4 2359:9 2391:18 2411:25 2467:11 2503:5 yield (2) 2444:22 2505:2 yields (1) 2401:9 york (4) 2348:20,20 2350:3 2392:9 youall (1) 2419:17 youd (18) 2358:18,24 2361:22 2366:10,18 2371:4 2375:16 2379:11 2381:7 2382:11 2385:24 2386:11 2388:1,11 2410:16 2481:8 2511:3,17 youll (3) 2360:6 2369:12 2450:15 young (2) 2411:18 2435:20 youre (70) 2363:3 2373:3 2374:4 2375:2 2383:24 2384:9 2387:17 2388:15 2390:14 2391:11 2400:12,14 2400:22 2401:11 2403:17,22,24 2404:3,7,18 2405:5 2411:1 2416:12 2422:24 2423:5 2428:4,14 2429:2,3 2429:8 2433:3,16 2433:17,21,21 2435:1 2436:24,25 2439:12,20 2440:10

2440:16 2442:1 2443:2,2 2446:23 2447:11 2457:3 2458:1 2459:13 2460:9 2462:1,5 2464:19 2468:12 2469:15 2474:2,19 2474:23 2486:12 2489:6,11 2493:9 2494:2,16 2495:12 2495:25 2496:2 2501:8 2502:7 youve (25) 2381:20 2384:6 2386:19 2404:9 2407:7 2408:17 2422:15 2433:2 2434:4 2435:22 2436:18 2437:3,6 2438:9 2451:9,16 2454:2,9,13,14 2455:4,16 2457:3 2459:12 2460:16 Z zero (1) 2362:13 zippo (1) 2362:14 zurich (2) 2348:17,17 0 00 (9) 2345:16 2364:18 2458:9 2501:20 2505:15,16,22 2514:16,23 000 (9) 2356:21 2363:1 2367:15,15 2431:17 2457:19,21 2500:12 2507:6 000something (1) 2458:2 02210 (1) 2350:10 05 (2) 2362:8 2368:7 06 (1) 2372:17 07 (1) 2345:3 09 (1) 2391:25

United Reporting, Inc. (954) 525- 2221

09062943 (1) 2345:3 1 1 (10) 2347:5 2352:11,12,12 2362:9 2501:20 2505:15,16,22 2514:16 10 (5) 2391:18 2419:19 2457:19,21 2458:2 100 (7) 2347:13 2349:18 2417:3,18 2444:11 2446:23 2456:10 1000 (1) 2347:11 10005 (1) 2348:20 1003767rbr (1) 2346:17 1003802rbr (1) 2346:18 101 (1) 2350:2 101780061 (1) 2350:3 1024110 (1) 2346:3 11 (5) 2347:8 2362:8 2364:18 2368:7 2372:17 110 (2) 2349:7,10 1102288rbr (1) 2346:21 1102368rbr (1) 2346:20 1102473rbr (1) 2346:22 1102604rbr (1) 2346:23 1102605rbr (1) 2346:25 1123100143388 (1) 2362:9 113 (1) 2345:18 113173 (2) 2516:13 2517:23 11cv61688jic (1) 2346:10 12 (3)

2345:16 2458:9 2514:23 1200 (1) 2351:3 1218 (1) 2345:23 1221 (1) 2350:14 12page (1) 2399:11 12th (2) 2394:9 2407:6 1430 (1) 2349:2 14th (1) 2409:24 15 (1) 2431:17 150 (1) 2350:19 15th (5) 2349:7 2350:10 2362:8 2364:17 2368:6 17 (2) 2349:14 2367:15 178 (4) 2367:13,15 2368:12 2372:10 17th (3) 2345:1 2346:1 2482:4 187 (1) 2367:15 18th (1) 2372:17 19 (2) 2346:3 2350:14 1st (2) 2351:3 2455:6 2 2 (1) 2477:10 200 (1) 2351:3 2000 (2) 2348:13 2403:3 2007 (2) 2512:11,14 2008 (5) 2359:2,4,5 2372:17 2375:3 2009 (16) 2362:8 2364:17 2366:25 2367:8

Page 30 2368:7,24 2375:8 2379:2,17 2386:2 2391:21 2440:5 2469:6 2472:2 2480:18,20 201 (1) 2349:14 2010 (1) 2349:18 2011 (3) 2345:16 2516:9 2517:19 2015 (2) 2516:13 2517:23 204 (1) 2349:3 206 (1) 2379:14 20million (2) 2361:4,7 21million (1) 2361:12 22 (1) 2345:16 2200 (1) 2350:19 22nd (2) 2516:9 2517:19 2345 (1) 2517:7 2356 (1) 2352:4 2368 (1) 2352:11 2393 (3) 2352:4,12,12 2458 (1) 2352:5 2499 (1) 2349:10 25 (2) 2350:23 2363:16 2510 (1) 2352:6 2516 (1) 2352:8 2517 (2) 2352:8 2517:7 2525 (1) 2347:23 25th (1) 2348:9 26 (2) 2367:8 2368:24 272 (5)

2352:11 2367:24 2368:2,5 2393:1 273 (3) 2352:12 2368:13 2393:14 274 (2) 2352:12 2393:14 2nd (1) 2347:13 3 3 (1) 2367:9 30 (5) 2400:9 2449:14 2505:3 2512:18,21 300 (1) 2377:9 300million (1) 2375:11 30th (2) 2375:12 2441:12 31st (3) 2375:12 2379:17 2441:13 33128 (1) 2345:19 331301545 (1) 2350:19 331301720 (1) 2350:24 33131 (6) 2347:14 2348:4 2349:15 2350:15 2351:12,16 331311704 (1) 2348:9 33134 (1) 2347:24 331463127 (1) 2349:3 33301 (5) 2347:6,11 2348:14 2349:7 2351:3 333012296 (1) 2349:23 33302 (1) 2347:20 33316 (1) 2345:24 33394 (1) 2351:8 33431 (1) 2349:11 33602 (1)

2349:19 35 (10) 2447:3,11,14,20 2448:7 2450:15,23 2451:4 2455:19,20 350 (1) 2347:10 37 (1) 2345:16 3700 (1) 2348:3 39th (1) 2348:19 4 40 (2) 2400:9 2449:14 401 (1) 2348:13 4400 (1) 2347:14 49 (1) 2455:3 4th (1) 2396:23 5 50 (1) 2457:13 500 (2) 2351:8 2477:10 5104 (1) 2367:12 515 (1) 2349:22 5252221 (1) 2345:24 59 (1) 2420:2 6 6 (2) 2516:13 2517:23 60 (1) 2512:18 606 (1) 2351:15 633 (1) 2347:19 7 7 (2) 2356:21 2363:1 700 (3) 2347:6 2351:8,12

United Reporting, Inc. (954) 525- 2221

70lawyer (1) 2418:2 75 (2) 2500:12 2507:6 799 (2) 2351:12,15 8 8 (2) 2345:16 2505:3 800 (3) 2350:23 2367:15 2414:22 857 (1) 2367:13 886 (1) 2409:25 9 9 (1) 2345:12 954 (1) 2345:24 99 (1) 2345:18

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