2011-12-19 rothstein scott am

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United Reporting, Inc.

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 6 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN

DATE TAKEN: December 19, 2011 TIME: 8:35 a.m. - PLACE: 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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1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR

2 BROWARD COUNTY, FLORIDA

3 ____________________________________________________

4 Case No. 10-24110 CACE (19)

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

6 Plaintiffs,

7vs.

8

9 SCOTT W. ROTHSTEIN, et al.,

10 Defendants.

11 _____________________________________________________

12 Case No. 11-CV-61688-JIC/LSS

13 AMY ADAMS, et. al,

14 Plaintiffs,

15 vs.

16 SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTARPRIVATE BANK AND TRUST COMPANY,

17 Defendants.

18 _____________________________________________________

19 10-03767-RBR Stettin v. Gibraltar Private Bank & Trust Co.

2011-03802-RBR Stettin v. Fidelity Gift Fund

2111-02368-RBR Stettin v. TD Bank, N.A.

22

23

24

25

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1 APPEARANCES FOR SCOTT ROTHSTEIN:

2 LAW OFFICE OF MARC S. NURIK 1 East Broward Boulevard

3 Suite 700 Fort Lauderdale, Florida 33301

4 BY: MARC S. NURIK, ESQUIRE

5 APPEARANCES FOR THE CHAPTER 11 TRUSTEE, HERBERT STETTIN:

6 BERGER SINGERMAN

7 350 East Las Olas Boulevard Suite 1000

8 Fort Lauderdale, Florida 33301 BY: CHARLES H. LICHTMAN,, ESQUIRE

9APPEARANCES FOR THE TRUSTEE:

10 GENOVESE, JOBLOVE & BATTISTA, P.A.

11 100 S.E. 2nd Street Suite 4400

12 Miami, Florida 33131 By: JOHN. H. GENOVESE, ESQUIRE

13 DAVID C. CIMO, ESQUIRE THERESA M.B. VAN VLIET, ESQUIRE

14 JESUS SUAREZ, ESQUIRE

15 APPEARANCES FOR RAZORBACK:

16 CONRAD & SCHERER, LLP 633 South Federal Highway

17 Eighth Floor Fort Lauderdale, Florida 33302

18 By: WILLIAM R. SCHERER, ESQUIRE ERIC RAYMAN, ESQUIRE

19 IVAN J. KOPAS, ESQUIRE and

20 KOZYAK, TROPIN & THROCKMORTON, P.A. 2525 Ponce de Leon Boulevard

21 Ninth Floor Coral Gables, Florida 33134

22 By: HARLEY S. TROPIN, ESQUIRE

23APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

24 CENTURION STRUCTURED GROWTH, LLC:

25 GOLDSTEIN, TANEN & TRENCH, P.A. One Biscayne Tower, Suite 3700 One Biscayne Tower, Suite 3700

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1 Two South Biscayne Boulevard Miami, Florida 33131

2 By: SUSAN E. TRENCH, ESQUIRE DONNA EVANS, ESQUIRE

3 APPEARANCES FOR LEVINSON'S JEWELERS:

4 KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL 200 SW 1st Ave

5 Suite 1200 Fort Lauderdale, Florida 333012073

6 BY: JAN ATLAS, ESQUIRE

7 APPEARANCES FOR THE COMMITTEE OF UNSECURED CREDITORS:

8 AKERMAN, SENTERFITT

9 One Southeast Third Avenue 25th Floor

10 Miami, Florida 33131-1704 By: MICHAEL GOLDBERG, ESQUIRE

11APPEARANCES FOR T.D. BANK:

12 GREENBERG TRAURIG, P.A.

13 401 E Las Olas Blvd Ste 2000 Fort Lauderdale, Florida 33301

14 By: HOLLY SKOLNICK, ESQUIRE

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

16 CLAUSIN MILLER

17 One Chase Manhattan Plaza 39th Floor

18 New York, New York 10005 BY: SCOTT L. SCHMOOKLER, ESQUIRE

19APPEARANCES FOR FEDERAL INSURANCE COMPANY:

20 ALEX HOFRICHTER, P.A

21 1430 South Dixie Highway Suite 204

22 Coral Gables, Florida 331463127 By: ALEX HOFRICHTER, ESQUIRE

23APPEARANCES FOR MORSE:

24 TRIPP SCOTT, P.A. 110 S.E. Sixth Street,15th Floor

25 Fort Lauderdale, Florida 33301 By: GEORGE WALKER, ESQUIRE By: GEORGE WALKER, ESQUIRE

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1 JOHN M. MULLIN, ESQUIRE

2 APPEARANCES FOR CAROL MORSE, TED MORSE & MORSE OPERATIONS:

3 LAW OFFICES OF ROBERTA DEUTSCH

4 2499 Glades Road Suite 110

5 Boca Raton, Floridan 33431 By: ROBERTA M. DEUTSCH, ESQUIRE

6APPEARANCES FOR EMESS CAPITAL, LLC:

7 KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL 201 S Biscayne Blvd Fl 17

8 Miami, Florida 331314 BY: CASEY H. CUSICK, ESQUIRE

9APPEARANCES FOR ST. PAUL FIRE & MARINE:

10 MILLS PASKERT DIVERS P.A.

11 100 N Tampa St Ste 2010 Tampa, Florida 336025145

12 BY: JOHN A. BLACK, JR., ESQUIRE

13 APPEARANCES FOR ROSEANNE CARETSKY:

14 Billing Cochran Lyles 515 E Las Olas Blvd

15 Floor Six Fort Lauderdale, Florida 333012296

16 By: DAN GELBER, ESQUIREAPPEARANCES FOR PLATINUM & CENTURION:

17 HARVEY WERBLOWSKY, ESQUIREAPPEARANCES FOR FEPICT, MS GROUP:

18 NYSTROM, BECKMAN & PARIS One Marina Park Dr., 15th Flr.

19 Boston, MA 02210 By: JACK SEIGAL, ESQUIRE

20APPEARANCES FOR MICHAEL SZANFRANKSI:

21 LYDECKER, DIAZ 1221 Brickell Avenue

22 Floor 19 Miami, Florida 33131

23 BY: CHRISTOPHER G. BERGA, ESQUIRE MIGUEL J. CHAMORRO, ESQUIRE

24APPEARANCES FOR GIBRALTAR:

25 STEARNS WEAVER MILLER, et al. 150 W Flagler St Ste 2200 150 W Flagler St Ste 2200

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1 Miami, Florida 331301545 BY: MARY BARZEE-FLORES, ESQ.

2 MATTHEW DATES, ESQUIREAPPEARANCES FOR FRANK PREVE:

3 PODHURST ORSEK 25 W Flagler St Ste 800

4 Miami, Florida 331301720 BY: RAMON A. RASCO, ESQUIRE

5APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

6 WATCH U-WANT, INC.:

7 KOPELOWITZ OSTROW 200 SW 1st Ave Ste 1200

8 Fort Lauderdale, Florida 33301 By: BART A. HOUSTON, ESQUIRE

9APPEARANCES FOR THE US GOVERNMENT:

10 99 N.E. 4th Street

11 Miami, Florida 33132 BY: LAWRENCE LAVECCHIO, ESQUIRE

12APPEARANCES FOR FRANK SPINOSA:

13 SCHLESINGER AND COTZEN, P.L. 799 Brickell Plz Ste 700

14 Miami, Florida 33131 BY: MICHAEL J. SCHLESINGER, ESQUIRE and

15 MICHAEL COTZEN, ESQUIRE and

16 SAMUEL J. RABIN, ESQUIRE 799 Brickell Plaza

17 Suite 606 Miami, Florida 33131

18

19

20

21

22

23

24

25

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1 INDEX

2 CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

3 DIRECT

4 Mr. Berga 1395Mr. Rasco 1470

5CERTIFICATE OF OATH 1537

6 CETIFICATE OF REPORTER 1538

7

8 SZAFRANSKI'S EXHIBIT INDEX

9 NO. DESCRIPTION PAGE NO202 April 15, 2008, Email 1426

10 203 February 24, 2009, Email 1428204 August 7, 2009, Email 1431

11 205 Document 1431

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13

14

15

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1 Thereupon, the following proceedings were had:

2 MR. BERGA: Good morning?

3 THE WITNESS: Good morning.

4 Whereupon,

5 SCOTT W. ROTHSTEIN,

6 acknowledged having been duly sworn to tell the truth

7 and testified upon his oath as follows:

8 THE WITNESS: I do.

9 DIRECT EXAMINATION (SCOTT W. ROTHSTEIN)

10 BY MR. BERGA:

11 Q Good morning, Scott.

12 A Good morning.

13 Q My name is Chris Berga. I'm with the law firm

14 of Lydecker Diaz and I'm here on behalf of Michael

15 Szafranski.

16 A Good morning.

17 Q Obviously, we're going to continue on with our

18 allotment of time. So I'll try to bounce around a

19 couple of times. Just bear with me.

20 A Okay.

21 Q When did you first meet Mr. Szafranski?

22 A I don't know the time frame. I believe it was

23 sometime in 2008 when the hedge funds asked him to be

24 the third-party verifier.

25 Q Who introduced you to Mike?

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1 A The exact person, I don't recall,

2 specifically, at this moment; somebody from the hedge

3 funds.

4 Q And whose idea was it to get Szafranski

5 involved?

6 A To my knowledge, it was the hedge funds.

7 Q And when you say "hedge funds," can you be

8 specific?

9 A I'll refer to them as Centurion, Platinum and

10 Level 3, although I don't think Level 3 was involved at

11 that point in time.

12 Q Do you know who specifically from Centurion

13 Platinum requested Mr. Szafranski be involved?

14 A I have a pretty good idea.

15 Q Can you tell me?

16 A Sure. Someone in the back room, meaning, to

17 my knowledge, Mr. Jedwab, had suggest we get a

18 third-party verifier.

19 Jack Simony subsequently came to Mr. Preve and

20 I and said, the guys want a third-party verifier.

21 Jack's initial statement to me was it could be

22 anybody.

23 Quickly thereafter -- and this should be clear

24 in the emails, quickly thereafter they said it can't be

25 anybody; this is who we want to use.

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1 And so that would have come to me, likely --

2 most likely, through Jack Simony, because he was the,

3 quote, unquote, hand-holder at that point in time.

4 Q He was the hand-holder on behalf of the fund?

5 A To my knowledge, as far as I was concerned,

6 yes.

7 Q Do you recall the first time you actually met

8 Szafranski?

9 A I do not.

10 Q Do you recall where you met Szafranski the

11 first time?

12 A I do not.

13 Q When you found out about Szafranski and his

14 involvement at the request of the funds, what was it

15 that you did?

16 A Initially, I freaked out.

17 Q Why?

18 A Because I didn't want anyone doing any type of

19 verification if I didn't have to have anyone doing any

20 type of verification; and it seemed to me, okay, from

21 the landscape that I was dealing in, that more eyes --

22 the more eyes, the worse it is for what we were doing.

23 So I didn't want anyone else looking at it.

24 Q Okay. So were you opposed to it?

25 A Initially, yes, absolutely, I was.

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1 Q Did you voice your opposition to anybody?

2 A I know I voiced my opposition to Frank. I

3 recall a couple of conversations where I voiced my

4 opposition to Jack; but beyond that, no, not to my

5 knowledge. I may have dealt with someone else, but I

6 recall Frank and Jack.

7 Q When you say "Frank"...

8 A I can only give you approximate language. I

9 can't tell you exactly because it was too long ago.

10 Q Give me what the approximate language would

11 be; do you remember?

12 A What the hell are they trying to do, this is

13 going to create problems for us, something around that.

14 Q What did you say to Jack?

15 A I don't recall. It would have been along the

16 same lines.

17 I would have pointed out -- if I did, in fact,

18 say something to Jack, I would have pointed out the fact

19 that he said, originally, we could use anybody and then

20 specifically brought somebody in; but I don't have a

21 specific recollection.

22 Q Now, when they brought Szafranksi in to do the

23 verifications, what was it that Szafranski was supposed

24 to do?

25 A He was supposed to initially -- I seem to have

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1 a recollection of it changing over time, increasing, so

2 I could best give you what he was ultimately able to do.

3 Initially, I don't recall specifically. You'd

4 have check the emails. It's out in there pretty

5 clean -- pretty clear to me.

6 Q Who have been the individuals or entities that

7 would have established what Szafranski was required to

8 do?

9 A It would have been what I was calling "the

10 Murray entities." I don't know which one of the

11 entities would have done it.

12 Q When you say "Murray entities," who does that

13 mean to you?

14 A Platinum, Centurion and Level 3.

15 Q Now, was Szafranski, was he required to verify

16 that the settlement agreement contained the signature

17 for both the plaintiff and the defendant?

18 A He was. Ultimately, he was, yes.

19 Q When you say "ultimately," why do you make

20 that distinction?

21 A Because I seem to recall there being different

22 levels of due diligence before it got to what I would

23 consider the maximum due diligence by Szafranski. It

24 wasn't that far in.

25 Ultimately, his job was to verify plaintiff's

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1 signature and defendant's signature.

2 Q When you say "far in," what do you mean by

3 "far in"?

4 A I can't tell you. Without seeing emails and

5 the like, it's impossible for me to place it in time

6 frame. There was too much going on.

7 Q When you use the term "far in," are you

8 talking about timing?

9 A Timing.

10 Q Now, that would have been timing of the entire

11 scheme or timing of Szafranski's involvement?

12 A Timing of Szafranski's involvement.

13 It was like a polishing. They had given him

14 an initial job to do; and I think, as they saw potential

15 loopholes, potential things they were missing, they were

16 cleaning it up as they went.

17 Q Okay. When you say "they," you continue to

18 refer to the Murray entities?

19 A I'm referring to whoever was calling the shots

20 back at the hedge funds. Specifically, I couldn't tell

21 you.

22 Q But to the best of your belief, it would have

23 been Simony, or who would it have been, to the best of

24 your belief?

25 A Who did I believe? I believed it was Jedwab

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1 and Kalter; then Nordlicht and Glass, to a little bit of

2 a lesser extent.

3 Q You said Nordlicht?

4 A Nordlicht and Glass, to a lesser extent.

5 Q So it's your testimony that they would have

6 been the ones calling the shots as to what the

7 verification process entailed?

8 A It's my testimony that that's what it appeared

9 to me to be.

10 I have no idea what was actually going on

11 behind closed doors.

12 Q Now, was Szafranski also required to verify

13 the daily transfer agreement, changes that contained a

14 signature for the plaintiff?

15 A I would have to see the emails. I would have

16 to see the emails exactly. He was supposed to look at

17 all of the documents to make sure that documents were

18 executed.

19 Q Now, was he also required to verify that the

20 settlement amount had been wired to the purported

21 defendant's trust account?

22 A Yes, he was.

23 Q Was he also required to verify that the

24 purported plaintiff had received the amount funded by

25 the investor?

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1 A Yes. The wire went out to the plaintiff;

2 that's correct.

3 Q Was he also required to verify that the

4 balances were, in fact, in your firm's accounts?

5 A He was.

6 Q You listed about four or five things. Was he

7 required to verify any other piece of information?

8 A At various points in time, he was advised by

9 the hedge funds to do follow-up. He was -- at one point

10 in time, he was supposed to go in the court files, do

11 some kind of search to see if he could find any of the

12 plaintiffs' names or defendants.

13 There was one point in time when he was asked

14 to see if he could find a link between the plaintiffs

15 and defendants, and he made up some nonsensical story

16 that he told back to the hedge funds that he had, in

17 fact, found a link between several of the plaintiffs and

18 several of the defendants; which, of course, is

19 impossible because, at the very least, there were no

20 real plaintiffs.

21 He, additionally, at certain points in time --

22 what else was he looking at?

23 He was supposed to try to get involved in one

24 of the negotiations. I don't remember who this was for.

25 That may have been, actually, for Damson.

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1 But there was a point in time when he was

2 supposed to try to listen to some of what I was doing,

3 and he did, in fact, tell them that he did.

4 So that's all I remember at this moment.

5 Q Okay. When you say "negotiations," what

6 negotiations are you talking about?

7 Negotiations for the settlement?

8 A Yes.

9 Q And that would have been with who? Who would

10 you have been negotiating with.

11 A I don't even know who it was.

12 I think, my recollection is -- from the emails

13 was, that it was a defense lawyer, that he was actually

14 supposed to be listening to the negotiations.

15 Q Now, did there ever come a point in time that

16 Szafranski went to your office to do the verifications?

17 A He always came to my office to do the

18 verifications.

19 Q They were always done at your office?

20 A When was he was really verifying, sure.

21 Q As opposed to when he wasn't verifying?

22 A Well, there was a point in time when he was

23 really attempting to verify. Then there was a point in

24 time when he was, what I'll call "psuedo-verifying": he

25 wasn't really verifying anything.

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1 Then there was a point in time when he stopped

2 showing up at the office. I mean, there were times when

3 he did show up and times when he didn't.

4 Q Okay. So let's go back to something you said.

5 There was a point in time when he was attempting to

6 verify, and there was a point in time when he was doing

7 psuedo-verification, as you call it.

8 A Mhm-mhm. That's correct.

9 Q So how do you distinguish between attempting

10 to verify and psuedo-verification?

11 A The difference is depending upon what he knew

12 at that moment; the difference is, is whether he knew

13 there was a fraud going on or whether he didn't.

14 Q So when Frank was brought in to verify the

15 purported settlements by the hedge funds, did he know

16 that there was a fraud going on?

17 A Initially, no, not to my knowledge.

18 Q Did you do anything to prevent Szafranski from

19 knowing that the settlements were fictitious?

20 A In the beginning, sure.

21 Q What did you do?

22 A I used a -- we had the same fake TD website

23 that we had created early on, took him to the bank, did

24 the show for him there.

25 Q You took him to the Weston branch?

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1 A Yes.

2 Hang on. I want to make sure there is nothing

3 else we did.

4 We also showed him documents, but I don't know

5 that that was -- I mean, that was attempting to go make

6 it look like there was nothing going on, but

7 unfortunately, we only had one or two signors.

8 So, ultimately, I did see a couple of

9 packages. You can tell that the signatures are the

10 same.

11 But that's basically what we did.

12 And I, of course, discussed cases with him and

13 the like.

14 Q And when you discussed cases, what did you

15 talk about?

16 A Just the general nature of the case.

17 Q So from the moment you met Szafranski, did you

18 ever provide him with any benefits?

19 A From the moment?

20 Q Yes.

21 A Early on I would have done the same thing with

22 him that I had done -- I did, in fact, do the same thing

23 with him that I had done with innocent investors. That

24 is entertain them. So he was part of the -- I guess the

25 entertainment group, for lack of a better phrase. That,

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1 of course, escalated later; but early on, that's what it

2 was.

3 Q Did you ever give him any cash?

4 A Early on, no.

5 Q Later on, though?

6 A Later on -- the only time I recall giving him

7 cash was in a strip club. I didn't make any large cash

8 payments to him, as I did with other individuals.

9 Q So --

10 A Everything was done by check.

11 Q Did you give him cash in the strip club?

12 A Yes.

13 Q What was that for?

14 A A stripper.

15 Q Ever buy him any drinks?

16 A Ever?

17 Q Yeah.

18 A In the strip club or in general?

19 Q Anywhere. Generally.

20 A Sure.

21 Q How many --

22 A Frequently.

23 Q How many times?

24 A How many times?

25 Q Yeah.

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1 A I would be guessing. Over 100.

2 Q How about any meals?

3 A Again, I would be guessing. Dozens.

4 Q You ever take him to any sporting events,

5 games?

6 A Sure.

7 Q How many?

8 A You'd have to check the records. I can't tell

9 you for certain. Over a dozen, I'm certain.

10 Q Now, was anybody else present with you when

11 you took him to these games or bought him these meals or

12 bought him these drinks?

13 A Yes.

14 Q Who would have been present?

15 A At the games, you'd have to look at the list.

16 The list exists at the -- in the firm's records as to

17 who was coming to the Dolphins games.

18 Q But you can't recall independently who would

19 have been at the games with you?

20 A I can start. My wife, Kimberly. Amy Howard

21 was at a lot of games when Mike was there. John Harris

22 was there when Mike was there. Frank Spinosa was there

23 when Mike was there. Various members of law enforcement

24 were there when Mike was there.

25 Q Can you name those?

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1 A Ted Morse was there every -- every time, I

2 think, just about, that Mike was there.

3 Ron Pecou, from time to time.

4 Q And this would have been at Dolphin games?

5 A Hang on. I'm still going.

6 Yeah. These are Dolphins games.

7 Ira Sochet was there on at least one occasion

8 when Mike was there.

9 Who else did we invite?

10 You know I invited -- Frank Adderley may have

11 been there when he was there.

12 You have to look at the pictures from the

13 game. We frequently took pictures.

14 Amy Howard may have a better recollection than

15 I do, but there were lists that were circulated before

16 the game as to who we were taking. Because you have got

17 16 tickets in our suite, and then we generally purchased

18 an additional four to six additional suite passes, so it

19 was a very large crowd.

20 There was a time when Gil Kalter came. I'm

21 certain that Mr. Szafranski was there when Gil was

22 there.

23 Q How about any fundraisers or political events,

24 did you take him to any of those?

25 A Yes.

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1 Q How many times?

2 A I don't recall the specific number. You'd

3 have to look.

4 Q Is there anybody that would have been with you

5 when you took him to a political event?

6 A Likely hundreds of people. You have to look

7 at an event list.

8 Q Well, I understand that, but people that he

9 took with him?

10 A Most of the time I was throwing the event, so

11 you'd have to look at the event list.

12 Q You can't recall any event in particular,

13 though?

14 A I mean, we could be here all day if I do this.

15 The Alex Sink event he came to. I remember

16 seeing the picture not that long ago.

17 Again, you look at the donor list and who was

18 there, that will tell you, instead of having me guess.

19 He was at one of the McCain events; again,

20 same thing.

21 The easiest way for you to track it would be

22 to take a look and see who he wrote checks to and then

23 look at the guest list. You'll find plenty of people

24 that would be able to say they were there at the same

25 time he was there, but I do not want to guess.

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1 Q Well, I'm not asking to you guess.

2 A Well, the problem is -- and I don't mean to

3 give you a hard time about this. The problem is, I was

4 involved in dozens of these, and they all kind of meld

5 together after a while.

6 Which ones he was specifically at, the easiest

7 thing is to simply look at the attendance lists for each

8 event.

9 Q Now, Scott, can you identify for me, like, all

10 the people who testified Szafranski knew the settlements

11 were fictitious?

12 MR. LICHTMAN: Can I hear the question

13 back?

14 BY MR. BERGA:

15 Q Sure.

16 Can you identify all the people who would

17 testify that Szafranski knew the settlements were

18 fictitious?

19 A All the people that I know knew?

20 Q Yes.

21 A Myself.

22 This is assuming they're going to tell the

23 truth, right? I mean, because I don't know -- I could

24 tell you that Frank Preve knew, but my understanding is

25 Frank has his own issues. So I don't know what he is a

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1 going to say.

2 Q Anybody else?

3 A Just give me a moment.

4 If these people told the truth, they would be

5 able to tell you that he was in, to some extent. They

6 might not be able to tell you specific knowledge. It

7 would be Preve, Ted Morse, David Boden, Irene Stay, Stu

8 Rosenfeldt.

9 That's all I recall at the moment. There may

10 be more.

11 Q So it's your testimony, sir, that each of

12 these individuals that you listed -- Preve, Morse,

13 Boden, Irene Stay, Stuart Rosenfeldt, each of these

14 individuals knew that Szafranski knew that the

15 settlements were fictitious?

16 A No. If you listen to my answer, I said, knew

17 that there was some kind of fraud going on; I don't know

18 the extent of their knowledge.

19 Q So they knew that Szafranski knew that there

20 was some kind of fraud going on?

21 A They knew that Szafranski was involved in a

22 fraud with me.

23 Q Did you -- let's take it -- for each of the

24 individuals that you listed, same question: Did you

25 ever have any discussions with any of these individuals

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1 regarding what Szafranski purportedly knew?

2 A With Boden, yes.

3 Q When did that happen?

4 A Hang on a second. Do you want the list or did

5 you want -- I don't know --

6 Q I'm sorry. You want to give me the list? Go

7 ahead.

8 A Boden, Preve, Rosenfeldt, Morse.

9 Q But not with Irene?

10 A Hang on. I'm thinking. Hang on a second.

11 I had conversations with Irene that should

12 have indicated to her that he was involved. So, yeah,

13 I'll say Irene, also.

14 Q So let's start with Preve. What did you

15 discuss with Preve regarding Szafranski's knowledge?

16 A The only thing that I specifically recall

17 discussing with Frank is towards the middle to end of

18 2009, meaning middle of the year up until the time that

19 the Ponzi scheme exploded, at the end of October, Preve

20 and I had several conversations where we were discussing

21 whether or not we would have a problem with Szafranski

22 at any level if the thing did blow up.

23 Frank and I also used to joke around about the

24 fact that Szafranski was making a ridiculous amount of

25 money and sometimes we couldn't even get him to come to

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1 the office to do the, quote, unquote, verification.

2 Q Does that finish your answer?

3 A My recollection is, is that there are some

4 emails that indicate that Szafranski was in the know,

5 also; but I would have to see those emails to tell you.

6 At this moment, that's all I recall.

7 Q I want to go back to something that you said

8 that you discussed with Preve regarding when he would be

9 a problem.

10 When you say "a problem," what did you mean?

11 A Well, if you take a look at the email traffic

12 between Frank and I, there are at least semi-regular

13 discussions between Frank and I about particular problem

14 issues that would come up with regard to trust account

15 balances, auditors and the like. And there were several

16 conversations I had with Frank where we were discussing

17 who we could bring, for example, to meet with Larry

18 Rovin, the auditor for Bekkedam and for Ballamor.

19 And Szafranski was considered to be a solid

20 proponent of what we were doing, that he would be able

21 to pull it off if he needed to meet with the auditors to

22 explain discrepancies and the like.

23 Q And this was at the middle to late '09 when

24 the scheme was blowing up?

25 A The scheme was blowing up at the end of '09.

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1 It would have been maybe a little earlier; but, again, I

2 would be guessing.

3 Q Okay. What discussions did you have with

4 Morse?

5 A The discussions I had with Morse circled

6 around the amount of money I was paying Szafranski.

7 There were times when Mr. Szafranski was out

8 with Mr. Morse and I, whether it be a strip club or

9 dinner or something, and Ted used to joke around about

10 the fact: I mean, is Mike ever going to pick up the

11 tab? You know, is he going to pick up the tab?

12 I said, I don't know. I'm paying the guy

13 millions of dollars.

14 And Ted would joke around with me: Oh, is he

15 one of your little henchmen? That type of stuff.

16 And there were also occasions where I told --

17 and where I told Ted not to worry about Mike when it

18 came to what he knew and didn't know, because Mike was

19 frequently sitting at the table with us when we were

20 having discussions of a -- at least a semi-private

21 nature.

22 Q Sitting at the table with you and Ted Morse?

23 A Yes.

24 Q And you had discussions -- as Mike was

25 sitting, you'd be discussing parts of the fraud, parts

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1 of the scheme?

2 A No. I would be discussing other things that I

3 was doing on behalf of Morse.

4 Q Such as?

5 Why would Morse be concerned that he was at

6 the table?

7 A Morse would be concerned he was at the table

8 because, from time to time, Morse and I would discuss

9 things. For example, there was some things going on

10 with his father, with Ted's dad, okay, and there were

11 times when these conversations came up when Szafranski

12 was at the table with us.

13 Szafranski -- whenever we came downstairs --

14 you have to understand, Szafranski had an office in my

15 office. So there came a point in time that whenever I

16 was heading down to Bova to go have my cocktails with

17 friends, me, Ted, for a cigar, Szafranski was with us.

18 And I think Ted was getting a little bit

19 annoyed that Szafranski was with us constantly. And I

20 regularly had to tell Ted, don't worry about it,

21 Szafranski is a good guy. That type of stuff.

22 Other than that, I don't recall any

23 conversations, specifically.

24 Q But Mike's office, he was in the same building

25 as yours or in your office?

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1 A No. I gave him an office.

2 Q Where was that located?

3 A It was on another floor from me. I don't

4 remember what floor it was. I was on 16. He wasn't up

5 on 22. He may have been on 15.

6 What I had done was, I had given him -- as a

7 perk for his assistance, because he was bringing

8 investors in and the like, I gave him an office on one

9 of the other floors. We set him up with a computer

10 there and a TV and the like.

11 Q Same line of questioning with respect to Mr.

12 Boden.

13 A Boden, I specifically told him, I said, if you

14 need to do any of the those verifications for Ritchie's

15 people, Szafranski knows how it works, don't worry about

16 the signatures or anything. It was a much more

17 extensive conversation with Boden.

18 Q Extensive in the sense that you discussed

19 Szafranski's knowledge?

20 A Yes.

21 Q How many times did that happen?

22 A Not more than half a dozen. David wasn't the

23 kind of person you needed to repeat things to.

24 Q Anybody else that would have been present

25 during your conversations with Boden when you were

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1 talking about Szafranski?

2 A I don't recall, specifically.

3 Q How about Irene Stay?

4 A There were times when I told Irene -- when she

5 thought she had to get certain information to Mike with

6 regard to the account balances and the like, that I

7 specifically told her, don't worry about it. He's all

8 good. You don't need to get him that type of stuff.

9 She would usually say things like: Are you

10 sure? Are you sure we don't need --

11 It's fine. Mike's fine. Don't worry about

12 Mike.

13 Q Did you discuss the fact that he actually knew

14 that the settlements were a fraud?

15 A Here's what I think I need to square away for

16 you. When we are talking about the fraud, okay --

17 again, I don't know if you were present for my testimony

18 last week.

19 When you're talking about the fraud, we don't

20 say, hey, let's go talk about the fraud. Hey, how's the

21 Ponzi scheme going? Does Mike know about the fraud?

22 That's not what it is.

23 Irene is asking me about -- this is a good

24 example. Irene is asking me about a legitimate document

25 that if Mike was representing -- was legitimately doing

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1 third-party verification, he would have needed to see.

2 Irene says, I forgot. I have got to get this

3 document to -- to Mike.

4 Don't worry about Mike. Mike doesn't need to

5 see that.

6 At that moment, you know that Mike is in the

7 know.

8 David Boden says to me, We need a third party

9 to verify this. What are we going to do? Are we going

10 to bring somebody new in?

11 No, no, no. Mike is with the program. He

12 knows what to do. Just talk to Mike about what you

13 need. He'll handle.

14 It. That would be the type of conversation.

15 There were no conversations that were in details saying,

16 okay, this is what we're going to do to perpetrate the

17 fraud. That's not the way we spoke.

18 Q Okay. When you say, "you know," you talked

19 about something that you know, not necessarily something

20 Irene Stay would know?

21 A Well, Irene moved hundreds of millions of

22 dollars for me, illegally, over a several-year period of

23 time. So I have a pretty good idea that Irene had

24 definite and specific knowledge about what was going on

25 in the law firm.

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Page 1419

1 We had an investment scheme going on where

2 there were payments supposed to be made out to

3 investors. Okay. She knew she had to wait for the

4 investor -- in this case, Mr. Preve -- to tell us what

5 needed to be paid, because we failed to keep detailed

6 track of it.

7 There were lots of more-than-significant

8 indications that what we were doing was a fraud, besides

9 the fact that Irene also knew that we were laundering

10 all kinds of campaign money through the firm, checks

11 sent out.

12 There was all kinds of things that tell you

13 what level a, quote, unquote, player each person is, as

14 we were using the term last week.

15 Q And the last person you mentioned was

16 Rosenfeldt?

17 A Rosenfeldt came to me, May, June -- I'm not

18 going to remember the month; I don't want to guess --

19 but came to me after looking at our financials and

20 seeing millions of dollars in checks being written out

21 to Szafranski and wanted to know what the heck they were

22 for.

23 I said, are you happy with the amount of money

24 you're making?

25 He said, yeah.

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1 Well, that's what it's for. It's all related

2 to the money. Szafranski is providing a very valuable

3 service. Leave it at that.

4 Q How many times did that conversation happen?

5 A I don't believe it happened more than once. I

6 don't think he ever asked me again.

7 Q Did you talk about anything else?

8 A With Rosenfeldt?

9 Q Yes.

10 A About the fraud?

11 Q With respect to Szafranski.

12 A Ever?

13 I may have. I have got to think about it.

14 The best thing for you to do with regard to

15 all these people would be if you have email traffic

16 between me and him regarding them -- between me and

17 those people regarding Szafranski, it would be good to

18 refresh my recollection so that I could give you

19 accurate information.

20 Q Okay. I would like to take you through a list

21 of people.

22 A Sure.

23 Q Essentially the same question is going to be

24 posed for each individual, and that question would be

25 whether or not you ever had any discussion with this

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Page 1421

1 particular individual that Szafranski knew the

2 settlements were fake or fraud. Okay?

3 A Sure.

4 Q Debra Villegas?

5 A Specific conversation with Debra, no.

6 Q Marybeth Feiss?

7 A I don't recall any.

8 You know, I may have had conversation with

9 Deb, but I really don't recall any.

10 Deb was so deeply involved with me that I

11 think it probably would have been obvious to her; I

12 didn't need to tell her anything.

13 Q But no specific discussions?

14 A It's hard to say specific discussions, because

15 if you know how my office was set up, even when --

16 before I had that inner-sanctum thing going on, Deb's

17 office was always right outside my office, and we were

18 constantly interacting.

19 So if there would be -- it's possible, but I

20 don't -- I don't have a specific recollection as I sit

21 here today of a specific conversation, because there was

22 so much conversation.

23 Deb was the one person that I probably spoke

24 to more openly than anyone else about the nature of what

25 we had been doing.

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1 Q But as you sit here today, you don't have an

2 independent recollection of having a discussion with

3 her?

4 A No.

5 If I recall anything else, I'll let you know.

6 Q How about -- you said no to Marybeth Feiss.

7 A I don't recall any. I didn't say no.

8 Q How about William Boockvor?

9 A I wouldn't have talked to Bill about it.

10 Q So your answer is no?

11 A My answer is I wouldn't have talked to Bill

12 about it. Other than that, I can't tell you.

13 Q So -- but the question is, did you have any

14 discussion with any of these individuals?

15 A Well --

16 Q So it's either you had a conversation or you

17 didn't.

18 A No. No.

19 The problem is, is that I was dealing with a

20 lot of people. Things were moving very fast, and I had

21 a lot of conversations with a lot of people, some about

22 legitimate things, many about not-legitimate things.

23 So it's possible that I had a conversation; I

24 just don't specifically recall one.

25 Q How about Mr. Adler?

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Page 1423

1 A No.

2 Q William Corte?

3 A No.

4 Q Curtis Renie?

5 A No.

6 Q Frank Preve? We covered him already.

7 A Yeah.

8 Q George Levin?

9 A No.

10 Q Jack Simony?

11 A No.

12 Q Brian Jedwab?

13 A No.

14 Q Gillad Kalter?

15 A No.

16 Q Ari Glass?

17 A No.

18 Q Ben Radinsky?

19 A Who?

20 Q Ben Radinsky?

21 A I don't recall who that was, so no.

22 Q Murray Huberfeld?

23 A I never spoke to Murray.

24 Q So the answer is no?

25 A The answer is no.

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1 Q Mel Lifshitz? Mel Lifshitz?

2 A No.

3 There was some very odd emails going back and

4 forth between Lifshitz and Szafranski. You need to take

5 a look at those, but I didn't specifically have a

6 conversation with Mel about it.

7 Q You never had any discussions with him

8 regarding what Szafranski's knowledge was?

9 A I had discussions with Mel about Szafranski in

10 general, and I had several conversations with

11 Mr. Lifshitz where I was very concerned that he knew

12 what was going on. And my recollection is, is that

13 there are emails back and forth between Mr. Lifshitz and

14 Michael Szafranski where the questioning is fairly

15 heated and where it appears that Mr. Lifshitz may

16 believe Mr. Szafranski is involved in something

17 inappropriate. But you'd have to go read those emails.

18 I don't have a specific recollection.

19 Q Did you ever determine what Mr. Lifshitz knew?

20 A Well, I wasn't concerned about Szafranski. I

21 know what he knew.

22 So yes, Mr. Lifshitz.

23 Q How about Ira Sochet?

24 A I don't think Ira ever knew, and I certainly

25 didn't have that conversation with him.

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1 Q Barry Damson?

2 A No, sir.

3 Q Kathleen White?

4 A No, sir.

5 Q Richard Pearson?

6 A No. I never had those conversations with

7 Richard.

8 Q A.J. Discala?

9 A No, sir.

10 Q Jim Parrish.

11 A I don't know who that is.

12 Oh, wait. No, he worked for Canvass.

13 No, I never had any conversation with him

14 about Mr. Szafranski's knowledge.

15 Q How about Frank Spinosa?

16 A No.

17 Q Rosanne Caretsky?

18 A No.

19 Q Jennifer Kerstetter?

20 A No.

21 Q Ricardo Mejia?

22 A Oh, the bank guy, no.

23 Q Matthew Brennan?

24 A Who is that?

25 Q Did you have any discussions with him?

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Page 1426

1 A Matthew Brennan?

2 I think he was a friend of mine that tried to

3 sell me insurance. No.

4 THE WITNESS: Do you want to mark this?

5 MR. BERGA: Yes. Please.

6 (Thereupon, the document was marked as

7 Szafranski's Exhibit 202 for Identification.)

8 BY MR. BERGA:

9 Q Exhibit 202 for the record, it's an email

10 dated April 15th, 2008. It's Gilad Kalter to Isaac

11 Barber and Jason Pinewski, and it's -- let me know when

12 you're done reviewing it.

13 A I am.

14 Q Okay. This April '08, would this have been

15 about the time that Szafranski became involved in the

16 verification process?

17 A I don't remember specifically when he got

18 involved.

19 Q It is your testimony that he became involved

20 through the funds, correct?

21 A Correct.

22 Q And Gilad over at Centurion LOC would have

23 been one of the people involved in the fund?

24 A Sorry. Say that again.

25 Q Gilad Kalter, he was an individual involved

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1 with the funds, correct?

2 A My understanding was he was an officer of

3 Centurion.

4 Q Now, Scott, I don't know if you remember: I

5 think the first day of your depo you testified: At some

6 point in time -- and I'll read to you your testimony:

7 "At some point in time, Szafranski -- it was

8 at the time that -- it actually was at the time, if I

9 remember correctly, when the hedge funds had basically

10 cut us off.

11 Mike said to me directly, if the hedge funds

12 aren't going to fund because I believe he had some kind

13 of prohibition about or he believed there was some kind

14 of conflict about bringing in investors while they were

15 still actively investing, although I do believe they

16 were still investing. But I guess he got their

17 permission to bring in people, because he said to me,

18 dead out. If they're not going to be bringing in new

19 investors, I'll bring in my people.

20 And my response to him was, I mean, Mike you

21 know there's no plaintiffs; you still want to bring

22 people in? He goes, yeah, everybody is making a lot of

23 money. I'll bring people in. And he did."

24 Now, when did that conversation take place?

25 A Tell me the day they cut me off?

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1 Q It would have been the date they cut you off?

2 A No, not the day, it would have been around the

3 time that they either stopped or slowed their funding.

4 Q And when would that have been?

5 A I don't recall specifically.

6 Q Sometime in '09?


8 Q Would it have been sometime in '08?


10 Q How about in '07?

11 A It wasn't '07.

12 Q Did you ever tell anybody that you had that

13 conversation with Szafranski?

14 A No.

15 Q Did Szafranski ever say anything else to you?

16 A Actually, that's not true. I did tell Frank

17 Preve that they were going to be getting money in from

18 people. Szafranski knew nothing further than that.

19 You can tell when it was. All you got to do

20 is look at the first S1 deal. It would have been a

21 conversation within several weeks prior to that.

22 MR. BERGA: Okay. Give me one second.

23 I'll see if I can get that for you.

24 THE WITNESS: Sure.

25 (Thereupon, a document was marked as

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1 Szafranski Exhibit 203 for Identification.)

2 MR. CHAMORRO: Exhibit 203 for the

3 record.

4 THE WITNESS: Oh, are we done with 202?

5 MR. BERGA: Yeah, we're done with 202.

6 Thanks.

7 BY MR. BERGA:

8 Q So, for the record, this is Exhibit 202.

9 It's an email from you to Mike dated February 24th,

10 2009, and the subject matter you see there is S1. Is

11 that the document you're referring to?

12 A Yes, sir.

13 Q Okay. So this would have been the first deal,

14 as you mentioned?

15 A It looks like it is. Yes, sir. So this would

16 clarify the date.

17 The conversation that I had with Mike would

18 have occurred, let's say, a month or so prior -- maybe

19 not even that far back -- but right in this time frame.

20 Q Now, before having that conversation with you,

21 Szafranski knew the settlements were fictitious?

22 A By that time, yes.

23 Q When you say "by that time," what time is

24 that?

25 A By February 24th, 2009, Mr. Szafranski knew

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1 the settlements were fictitious.

2 Q Did you happen to have any specific

3 conversations with Szafranski discussing the fictitious

4 nature of the settlements?

5 A You are going to have to clarify that question

6 for me. I don't understand what you're asking me.

7 Q Yeah. I mean, did you ever sit down and talk

8 with Mike and say, you know, this is what's going on?

9 A I never had that conversation with anybody in

10 that nature: Hey, this is what's going on.

11 There came a point in time when Mike realized

12 that there were -- funds were not in the accounts. He

13 started asking me about the fact that all the signatures

14 looked the same.

15 That's when I knew that he knew what was going

16 on.

17 Q Okay. When would that have been?

18 A That would have been back in '08 sometime,

19 based upon what you just showed me.

20 Q And you're basing your testimony on the fact,

21 the date of the first deal?

22 How do you know it was in '08?

23 A Because it was well before Mike asked to bring

24 in investors. It was a point in time when, to my

25 knowledge, Mr. Szafranski did not know what was going

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1 on. There was a point in time when he had a pretty good

2 idea. There was a point in time when he absolutely

3 knew, and then there was a point in time when he was

4 bringing in investors into something he knew didn't

5 exist.

6 Q Okay. What would be the line of demarcation,

7 if you will, as to when he knew?

8 A I'd have to go back through all the email

9 traffic between Szafranski, me and Preve to do that,

10 because you can tell -- at least I may be able to tell,

11 based upon the language of what was going on and

12 pinpoint the date a little better for you, but it was

13 sometime in '08.

14 Q Scott, were there instances where there was

15 unredacted deal documents used and then redacted deal

16 documents used?

17 A Sure. Yes.

18 MR. BERGA: Just give me a second; I'll

19 give you some exhibits.

20 A There were a lot of times when there were no

21 deal documents used.

22 (Thereupon, documents were marked as

23 Szafranksi Exhibits 204 and 205 for Identification.)

24 MR. CHAMORRO: For the record, Exhibit

25 204 and 205.

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1 BY MR. BERGA:

2 Q Okay. So, Scott, for the record we have 0-4,

3 which is an email from Villegas to Szafranski. It's

4 dated August 7th, 2009. You were copied on it, and

5 subject matter, it says S105UN; and then, on the same

6 date, also an email from Villegas to Szafranski, copying

7 yourself, and the subject matter is S106.

8 Going back to Exhibit 0-4, does the "UN"

9 represent unredacted?

10 A Yes.

11 Q What was the purpose of preparing unredacted

12 or redacted documents in the same deal doc?

13 A Mike had to advise the people that he was

14 verifying for, that he saw unredacted documents and that

15 he was able to link these documents to names, numbers

16 and the like that were on wires and the like. That was

17 the purpose.

18 Q Now, other than to between Villegas, yourself

19 and Mr. Szafranski, who else saw these unredacted

20 versions of the settlement documents?

21 A The people that were photocopying them: Amy

22 Howard, Marybeth Feiss.

23 David Boden saw his unredacted documents, the

24 ones for his deals. He may have seen some of ours. I

25 don't know specifically.

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1 But the only people who were seeing unredacted

2 documents were supposed to be my internal group in the

3 firm and Mike.

4 Q So Mike would have seen both the unredacted

5 and the redacted versions?

6 A Yes. They both had specific purposes.

7 Q Now, Scott, at some point in your deposition,

8 I believe it was Friday, you testified that you had lied

9 to a lot of people in carrying out the fraud, correct?

10 A Yes, sir.

11 Q Was Mr. Szafranski one of the people that you

12 lied to?

13 A Initially, yes.

14 Q What did you lie to him about?

15 A I lied to him about the existence of the

16 deals.

17 Q What did you tell him exactly?

18 A He had heard the initial -- the same pitch

19 that I had given to other people, so he had heard the

20 entire thing in detail.

21 Q When would he have heard that?

22 A I don't recall the first time he heard it. I

23 mean, he heard it in total likely dozens of the times,

24 but I don't recall the first time he heard it.

25 Q He would have heard it a dozen times before he

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1 began verifying or trying to get reference --

2 A No, no, no, not before. My apology.

3 Once he was brought in -- it was my

4 understanding that at the time -- and this is only my

5 understanding from what I was told -- at the time that

6 he was brought in to do the verification, he had already

7 been explained the entire scenario by the hedge funds.

8 I was told that by Mr. Simony, and also by Mr.

9 Preve, that he knew what he was looking for, et cetera.

10 Subsequent to that, there were times when Mr.

11 Szafranski sat in on -- when I was making pitches. So

12 he heard it then, as well.

13 Q Okay. So you lied to him about the settlement

14 documents being real.

15 Anything else you lied to him about?

16 A When you say "the settlement documents being

17 real," are you talking about everything pertinent to

18 that, like the balances, everything that goes with it?

19 Q Yeah, I'm trying to -- you said he heard it

20 about a dozen times; he would have heard everything that

21 were you lying about, right?

22 A Well, let me make sure you have this in

23 context.

24 Before Mike knew there was anything going on,

25 he had heard me do the pitch. So everything contained

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1 within that pitch that was a lie, he heard it, which is

2 the bulk of the pitch.

3 Q Okay. And when were you making those pitches?

4 Who would have been present?

5 A I don't specifically recall.

6 Q But your testimony is that that happened a

7 dozen or so times?

8 A No, no. A dozen or so times in total.

9 There were times when he was hearing the pitch

10 after he knew. He had me give the pitch to people after

11 he knew what was going on. So he heard it both before

12 and after, more frequently after, than before.

13 Understand that before he got involved and

14 knew what was going on, the only time he would have

15 heard it was when he was in my office to do

16 verifications and happened to be around.

17 Q Okay. Other that the nature of the

18 settlements, is there anything else you lied to

19 Szafranski about?

20 A I'm sure there is a lot of things that I lied

21 to him about. I need to see email traffic and the like,

22 and I can tell you what's true and what's not.

23 Q Okay. But without seeing the emails, what

24 would have been something else that you lied to him

25 about?

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1 A Where I was at a particular point in time, if

2 he was looking for me; the fact that I was meeting with

3 a client who did not exist. It would have been

4 deal-pertinent items, whatever was necessary in order to

5 keep the fraud going.

6 Q Anybody else present when you made these lies?

7 A I don't specifically recall.

8 Q How about during the week that you fled to

9 Morocco, did you lie to Szafranski at that time?

10 A Yes.

11 Q What did you lie to him about?

12 A About the fact that I was trying to

13 resuscitate the deals, that I was trying to borrow the

14 money in order to pay off the investors.

15 Q Anybody else present when you were making

16 these lies to Mike?

17 A No. I was alone in a room.

18 Q How about at the time that you -- immediately

19 before you left for Morocco?

20 A To tell you specifically, I would have to see

21 my email traffic with him. I was so scatterbrained at

22 that moment, I couldn't tell you off the top of my head.

23 If you need to show -- if you show me the

24 email traffic, I would be able to tell you.

25 Q Now, Scott, when did Debra Villegas first

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1 learn that the settlements were fake?

2 A Hang on one second. There's one more person

3 you need to add to the list early on.

4 Q Which list is that?

5 A That I talked about when I was talking about

6 people that knew that Szafranski knew: John Harris.

7 John had specifically asked me if BSA needed to talk to

8 someone about the deals who was, quote, unquote,

9 independent, if I had somebody.

10 And I said, yeah, we can trust Szafranski.

11 He'll handle it.

12 Q When did that conversation take place?

13 A I don't specifically recall the time frame;

14 but if you look at the email traffic between John Harris

15 and I regarding BSA and the time when they're really

16 climbing all over me, it would have happened around that

17 time.

18 Q Is that --

19 A Prior to that, John hadn't asked me about

20 anybody independent.

21 Q That was the one-time conversation?

22 A You know, John asked me the same thing

23 repeatedly in so many different areas, I can't tell you

24 one way or the other. With him, it's possible it

25 occurred more than once.

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1 Q Repeatedly regarding Szafranski or regarding

2 issues in general?

3 A John asked me things repeatedly regarding

4 everything.

5 Q Okay. Before you jump back to Harris, my

6 question was, when did Villegas first learn that

7 settlements were fake?

8 A The first day we did one.

9 Q Which would have been?

10 A Then you go -- now, you have got to look --

11 you have got to go back. It's got to be '07 or early

12 '07, possibly '06.

13 I don't think -- when I was doing the -- what

14 we call the bridge loans, just the promissory notes

15 stuff, early on, I'm not sure whether Debra knew or not.

16 But for certain when we did the very first

17 deal, which would be, I believe, G1, by that date she

18 knew the entire scheme.

19 Q What did you tell her the purpose was in

20 preparing the fake settlement documents?

21 A I didn't give her a purpose. I just told her

22 to prepare them.

23 Q She didn't ask what they were for?

24 A To my specific recollection, no, she did not.

25 Q Was it you that told Debra that, or would it

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1 have been somebody else?

2 A Told Debra what?

3 Q That the settlements were fake.

4 A No, no. You could tell that they were fake

5 because I asked her to prepare documents and sign

6 someone's name to it.

7 Q But did you actually tell her that they were

8 fake, other than asking her to prepare these documents?

9 A It's just like with everybody else: Other

10 than hints that things were fake -- well, more than

11 hints, like saying to Szafranski, "well, you know

12 there's no plaintiffs, Mike, right?" Statements like

13 that.

14 I never said, Deb, here's some fake

15 settlements; can you sign them, please.

16 That's not the way we talk -- at least that's

17 not the way we talked.

18 Okay. This is what needs to be done.

19 She would do it. Debra was a good soldier.

20 She did what I asked her to do.

21 Q Didn't question you as to what it was for?

22 A Initially, no.

23 Q At some point in time did she?

24 A At some point in time she expressed to me her

25 concern that we were going to get in a lot of trouble,

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1 and I tried, as best as I could, to keep her calm.

2 So from time to time, yeah, she expressed her

3 concern; but most of the time, in this kind of thing,

4 when people are getting involved in a fraud, they just

5 get involved. And they may ask questions from time to

6 time, but there is really very little specific

7 conversation about the overall -- in this case, the

8 overall Ponzi scheme, just specific illegal acts that

9 were going on at different points in time.

10 Q Was there ever a point in time where you

11 discussed with her regarding the fictitious settlements,

12 that they weren't part of this scheme to launder mob

13 money.

14 A Say that again.

15 Q Yeah. Did you ever have a discussion with her

16 where she learned, and you told her, that the fake

17 settlements weren't part of scheme to launder mob money?

18 A That they weren't part of it?

19 Q Yeah.

20 A I don't know if I ever told her they weren't

21 part of it.

22 At one point in time she was in a real panic

23 over the -- just the entire -- I guess the size of what

24 we were involved in and our constant need for funds

25 coming in. She could see that I was stressed out, and

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1 she asked me why I was so stressed. We had

2 conversations about it.

3 And she also new about my connections to

4 organized-crime individuals.

5 And so I told her that we need to do this

6 because some of this money belongs to the mob -- is mob

7 money.

8 Q Prior to that, how did she learn about the

9 alleged organized-crime connection?

10 A She saw them coming into my office.

11 Q And she knew who they were?

12 A We would discuss it from time to time.

13 Certain of them were in Fort Lauderdale,

14 fairly well-known people.

15 Q So she could tell just by looking at them that

16 they were allegedly organized-crime figures?

17 A No.

18 Q How would she know that?

19 A Certain of the individuals, certain things we

20 were handling for them, would lead you to the conclusion

21 that they were organized-crime figures.

22 Q Any other conversations that you had with her,

23 other than that one regarding laundering of mob money?

24 A I don't recall specific conversations with

25 her, other than that; but there were, to my

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1 recollection, many conversations that I had with Debra,

2 just in general, about clients of ours that were

3 involved in organized crime.

4 MR. BERGA: All right. Take a

5 five-minute break.

6 MR. LEVECCHIO: Pardon me?

7 MR. BERGA: Take a five-minute break.

8 (Thereupon, a recess was taken.)

9 BY MR. BERGA:

10 Q Now, Scott, did you ever tell Szafranski that

11 you were sharing a piece of your attorney's fees with

12 anybody?

13 A Okay. I'm sorry. You're speaking a little

14 fast. Say that again. And I know I speak fast, also.

15 Go ahead. I don't listen fast; I only speak fast.

16 Q Did you ever tell Szafranski you were sharing

17 a piece of your attorney's fees with somebody else?

18 A I believe I did, yes, because I told them I

19 was sharing them with him and with his clients.

20 Q How many times did that discussion take place?

21 A Before he knew what was going on, maybe a few

22 times. After, we used it as a kicker to entice his

23 clientele into investing with us.

24 Q Anybody else who would have been present when

25 you had those discussions with him?

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1 A Not that I recall, no. I tried very hard not

2 to have these conversations with a bunch of people

3 standing around listening. But those conversations

4 regarding the attorney's fees should be laid out pretty

5 well in the email traffic.

6 Q Now, can you tell me -- can you give me a list

7 of people who received compensation for recruiting

8 investors into the scheme?

9 A These are people that knew there was a fraud

10 that brought investors in, is that what you're asking

11 me?

12 Q Was there a difference as to people that

13 didn't know?

14 A Well, there were people that I understand --

15 you're asking that I specifically compensated, right?

16 Q Right. Yes.

17 A Okay. No. The only people I would have

18 compensated were people that actually knew. The only

19 people -- let me break it down this way. Szafranski

20 would have been the main person that I was giving large

21 dollars to for bringing people into the fraud.

22 David Boden received perks, a ridiculously

23 large salary, the very low priced rental of a very

24 expensive home I owned off Las Olas. The travel, all

25 that type of stuff, what we talked about, the rock-star

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1 lifestyle.

2 So Boden was compensated in that fashion for

3 bringing people in.

4 Preve was sort -- it's hard with Preve,

5 because Preve was bringing so many people. Okay. There

6 were times when I didn't offer it to Preve but Preve

7 kind of took it.

8 If you look at the email traffic, you'll see

9 where Preve is saying -- you know, he would send me a

10 bill. There would be emails going back and forth

11 between Frank and I and you'll see a bill from Frank to

12 me for consulting. Well, that's what that was. He

13 wasn't really consulting for us. It was for bringing a

14 particular deal to the table.

15 But really the bulk of the money went to

16 Szafranski because he was the main illegitimate feeder

17 during that 2009 time period.

18 Q And before Szafranski became involved, you

19 never paid compensation to anybody to bring investors

20 into the deals?

21 A The bulk of the deals came in through Levin

22 and Banyan, so I didn't pay them. Pay A.J. I don't

23 have a specific recollection of doing that, no. Because

24 we tried to be very particular as to who was bringing

25 deals in.

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1 And Szafranski, like I said, became my main

2 feeder fund once the hedge funds cut us off, and stayed

3 being one of the main feeder funds even through the time

4 of the Von Allmens, Discala, Clockwork people came in.

5 Q So in terms of the compensation that

6 Szafranski was receiving, as you just testified, did you

7 ever tell him to conceal those payments?

8 A No. I paid him by check. I don't recall

9 telling him to conceal it.

10 Q And have all those checks been identified?

11 A I'm sorry?

12 Q How were those checks identified, what were

13 they for?

14 A I don't know what we called them. We probably

15 called them some kind of consulting thing.

16 What would happen is -- you can identify the

17 checks. All you have to do is look at our ledgers,

18 because I would give him a string of post-dated checks.

19 So you'll have sequential case number -- excuse me, not

20 case numbers -- sequential check numbers with

21 non-sequential dates, to the tune of millions of dollars

22 not tied to anything specific, without any invoices to

23 us. So you can tell he's receiving remuneration for

24 something that doesn't exist.

25 Q Regarding the compensation that you were

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Page 1446

1 paying him for bringing in deals --

2 A He did tell me one time to make sure that I

3 never brought up the amount of money that he was making

4 with Damson and Sochet, those guys, the amount of money

5 that he was making with me, because he was very

6 concerned, because he was not supposed to -- and I knew

7 that as well -- he was not supposed to be taking money

8 from me, because he was supposed to be an independent

9 verifier. And he was already receiving two different

10 types of payments from the people he was bringing in: A

11 finder's fee, some type of commission-type thing, plus a

12 verification fee.

13 Q How many times did he tell you that?

14 A It wouldn't have been more than a handful.

15 Q Anybody else present for that conversation

16 with you and him?

17 A No. Uh-uh.

18 Q And his instruction to you not to tell

19 anybody? That was just to Damson. Who else?

20 A No. I recall it because I was getting ready

21 to meet Ira. Okay. We were going to have breakfast. I

22 was meeting him for breakfast. I think the first time I

23 met Ira may have been at breakfast. But I was going to

24 one of my breakfast meetings was Ira. We had this

25 little diner he liked to go to.

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1 And I remember speaking to Mike some time

2 right before, and saying, Make sure you don't talk to

3 Ira about the money you're giving me because I'm not

4 supposed to be taking any money and I -- I'm sure I told

5 Mike don't worry about it. I know you're not supposed

6 to be taking that money. I won't discuss any of your

7 business with him, with me.

8 Q Let's switch topics then. Talk about the

9 website, TD Bank website.

10 A Sure.

11 Q Can you tell me all the people that would know

12 that the website was fake?

13 A Me, Debra Villegas, Curtis Renie, Bill Corte,

14 David Boden, Bill Boockvor, Stuart Rosenfeldt, Richard

15 Pearson, Mike Szafranski, Frank Preve.

16 That's all I recall at this moment. There may

17 be more.

18 Q How did Mr. Szafranski come to learn the

19 website was fake?

20 A I showed him how to work it so that he could

21 show it to his investor.

22 Q Where did you do that?

23 A In my office.


25 A It was at the time that Damson was

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1 investing -- it might have been with Sochet, actually.

2 It was either Socket or Damson. And they were at my

3 office, whichever one it was, and Mike wanted to do --

4 Mike was giving them, for lack of a better word, a show

5 of his own, to show them what he did in his

6 verification. He was leading a lot of the investors to

7 believe that he was actually signing on to the specific

8 website and showing -- and looking at it.

9 And there was an occasion with either Damson

10 or Socket where we were in my office, that person was

11 there, and Mike actually signed on to the website. I'm

12 pretty sure it was Damson or Socket and not one of the

13 other -- now that I'm thinking about it, it could have

14 been with one of his other potential investors. But he

15 definitely signed on, because I showed him you can just

16 enter anything into the system. You can enter

17 Ishkabbible and it will still open up into the right

18 screen and the balances and the like would be on there.

19 Q And this all would have happened in your

20 office?

21 A That's the only place it could happen. It's

22 the only place the fake website existed.

23 You know, now that I'm thinking about it, it

24 wasn't Socket and Damson. Because I remember him -- it

25 was some -- one of the other investors he had brought to

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1 my office for a show, okay, they were specifically

2 pushing on the whole -- they -- they wanted to have

3 access. If you look at Mike's emails to me -- actually,

4 if you look at Mike Szafranski's emails with other

5 people, you'll see that he's creating all these little

6 other lie scenarios, that he's using to go sell the

7 product, where he's telling; for example, people that

8 he's the person that the Bar designated -- it was an

9 email I remember seeing where he told someone that the

10 Bar designated him as the only person that could see the

11 real settlement agreements.

12 He also told people that he actually had

13 access to this website.

14 And they wanted -- this particular investor

15 was giving us a hard time.

16 So, I went ahead and had Mike actually go

17 ahead and sign on with the investor so they could see

18 what he would, quote/unquote, be doing as part of his

19 third-party verification, which obviously was really

20 nothing.

21 Q And this would have all happened in your

22 office?

23 A That's the only place that that could ever

24 occur, unless he had a -- his own little website that I

25 didn't know about.

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1 Q Who was the name of the investor?

2 A I don't recall.

3 Q But the investor would have gone -- went to

4 your office actually at that instance?

5 A There were several potential investors that

6 Mike actually brought to my office for the dog and pony

7 show.

8 Q How many times did that happen?

9 A That he actually brought people?

10 Q Yeah. Was it just that one time or was it --

11 A No. It was half a dozen or less. I mean, he

12 brought people from time to time to the office for the

13 show.

14 Q And were you always part of the show?

15 A Yes.

16 Q Anybody else part of the show when it happened

17 in your office?

18 A The only person that I recall being involved

19 from time to time and I actually remember seeing this in

20 some email traffic between Mike and Mel Lifshitz was Stu

21 Rosenfeldt. Stu was present during some of the

22 discussions that I had with investors with Mike and

23 that's pinpointed in some of Mike's emails with

24 Mr. Lifshitz.

25 Q So the scenario would have been that the

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1 investors, the -- some of which -- you can't remember

2 any of the names of investors?

3 A I met God knows how many people during the

4 course of this. Many people who did not invest. If

5 they weren't -- even some small investors, you'll recall

6 early on in my testimony, I had no idea that these

7 people were even investing. So unless they were a very

8 large feeder fund, I wouldn't have remembered their

9 name.

10 Q And you didn't have any concerns with just

11 letting anybody into your office?

12 A No, no, that's not the way it worked.

13 Q How did it work?

14 A They would have had to have at least been, for

15 lack of a better word, prescreened, and I had my own

16 methodology of prescreening them when I met them.

17 Q Which was?

18 A Start talking to them about the investment and

19 see the level of questions that they're asking; how much

20 they're pushing.

21 Some people are much more interested in what

22 I'll call the greed factor. They're much more

23 interested in the returns and don't really give a crap

24 what's behind the returns.

25 Others are really looking for documentation,

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1 substantiation.

2 If you're talking about returning in excess of

3 100 percent, sometimes often in excess of 200 percent,

4 you get a lot of questions. Some from -- some -- more

5 from some people, less from others. And so there's a

6 prescreening process. You can see how far you want to

7 go with somebody based upon the way they're asking you

8 and whether they seem sufficiently pleased with the

9 initial answers you're giving them.

10 Q So in terms of Szafranski and yourself

11 participating in this show, as you call it, this would

12 have happened at least a half a dozen times, you say?

13 A Well, you've got to include in there that I

14 did -- you know, it's not the same thing as the bank

15 show. All right? It's a different thing. I'm calling

16 it a show because it's obviously all fake.

17 Q Different kind of show?

18 A Right.

19 I did it with Damson in my office. With Mel

20 Klein in my office, I believe. I don't recall -- I

21 could swear I remember Socket being there, but I don't

22 specifically recall.

23 Q People you mentioned in there was --

24 A Kathleen White.

25 Q Not to cut you off, but was Szafranski present

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1 for all those times that you mentioned these people

2 before?

3 A For some of the times. He wasn't

4 necessarily -- every time Barry Damson came to my

5 office, I can't tell you one way or the other whether

6 Mike was there or not. There sometimes, not there other

7 times.

8 But there were times when he brought in -- I

9 have specific recollection of sitting with him -- I had

10 a couch set up in my office -- sitting with him and

11 various investors, people asking questions.

12 Q And it would be Szafranski who would be

13 manning the computer?

14 A No. I said on one occasion I remember with an

15 investor who we thought was going to be interested but

16 was pushing the point of how Mike actually verified the

17 balances.

18 Q It was that -- that was the only time that

19 Szafranski logged on to the website?

20 A I don't recall whether he did it other times

21 or not. I may have allowed him to with someone else

22 there but I have a specific recollection about someone

23 pushing the point. If you have a list of everyone that

24 he brought in, I might be able to recognize the name.

25 Q And it would have been one of his investors?

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1 A Well, when you say "his investors," he was

2 being fed people, as I understand it, by the Turetski

3 family, some other families' names that I don't recall.

4 So, I don't know how you qualify them as his investors.

5 Someone that I put under the Szafranski umbrella of

6 investors, yes.

7 Q Now, can you put a time period on it as to

8 when Szafranski first learned that the TD Bank website

9 was fake?

10 A You want to know what I think?

11 Q Well, I want to know what your testimony is,

12 your truthful testimony is, then you can tell me what

13 you think.

14 A Well, I'm only giving truthful testimony.

15 Q Okay.

16 A Okay. As far as -- I can tell you what I

17 think he knew. We were -- we were -- it was in '08

18 sometime and we were looking at the wires, and Debra or

19 whoever did the wire, she had made a mistake and the

20 wire amount was all off. There were zeros missing. It

21 was crazy, I mean, the way that sheet was set up. If

22 you look at those sheets, you'll see the way it was set

23 up. And there was a mistake on there.

24 And then as Mike was looking at it, he said,

25 "That can't be right." He was looking at his deal

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1 sheet, whatever he got from Preve or from the -- from

2 the hedge funds. He's looking at the deal sheet, he's

3 looking at the thing, and he's saying, "That can't be

4 right." And then he starts to look at the actual wire

5 numbers.

6 And Debra duplicated the exact same number

7 from page to page several times.

8 And I was kind of dumbfounded, because all I

9 could say was it's got to be a bank error. And I left

10 it at that.

11 At that moment I had -- I had a pretty good

12 idea that he knew something was amiss because those bank

13 websites, the wires are generally not incorrect. As a

14 matter of fact, all the time I was doing legitimate

15 business, I don't recall ever seeing a mistake on a wire

16 on the bank's website.

17 Q So that's what you think, but tell us about

18 what you know.

19 A At the time that he knew that there were no

20 plaintiffs when he brought his first deal in, at that

21 time I'm certain he knew the website was fake because he

22 knew there were no plaintiffs and no real money moving

23 in and out except from the investors.

24 Prior to that, I would be guessing. He knew

25 sometime prior to that, because by the time he was

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1 bringing investors in, and I said, You know there's no

2 real plaintiffs, Mike and he said, Yeah, I know, but

3 everyone is making money. You know, we're doing good.

4 That's the kind of conversation we had.

5 If you spoke to Mike, you know, he doesn't say

6 a lot. He's just kind of go-with-the-flow as long as

7 he's making money.

8 Q So it's your testimony that because he

9 allegedly knew that there were no plaintiffs, he knew

10 that the website was fake?

11 A Oh, no, no. Read the email traffic. He knew

12 there were no plaintiffs. If you read the email traffic

13 and you look at the signatures, you don't have to be a

14 handwriting expert to see it's the same person. I mean,

15 he literally looked at hundreds of signatures signed by

16 the same person.

17 As good as Deb was, it doesn't take a

18 handwriting expert to tell you it's the same person

19 signing it.

20 And he would sit down, sir, sometimes,

21 sometimes look at ten and 20 deals at the same time, all

22 with the same basic signature pattern on them.

23 Q But I'm trying to get an understanding of what

24 your -- I mean, let's put aside reading the emails,

25 you're testifying that because he, as you say, didn't

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1 know there were any plaintiffs, that he automatically

2 knew -- made him know that the TD Bank website was fake?

3 A Well, eventually he knew the TD Bank website

4 was fake because he knew that there were no plaintiffs.

5 Why would I be using -- how would I possibly -- if

6 there's no real plaintiffs and no real cases, how would

7 there possibly be a real website showing all that money

8 coming in and out from people that didn't exist. That

9 makes no sense. If he knows there's no plaintiffs, he

10 could not possibly believe that I was sending money out

11 to people that don't exist. That's what was on the

12 website. That makes no sense.

13 Q That's your testimony, right?

14 A I'm sorry?

15 Q That's your testimony?

16 A Yeah.

17 Q Did you ever ask Bill Corte or Curtis Renie to

18 update the balances before Szafranski arrived at the

19 office?

20 A I asked him to update the balances before

21 Szafranski got there, while Szafranski was there, before

22 other investors got there, sure.

23 Q And when you asked him while Szafranski was

24 there, would Szafranski have been present while you

25 communicated that to Renie or Corte?

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1 A He might have been but I did it usually by

2 getting on the computer and just sending an email to

3 Curtis or to Renie -- excuse me, to Renie or to Corte.

4 Q Now, did you ever have a conversation with

5 Szafranski about, I mean, your concern that you were

6 running short on cash to keep the scheme going?

7 A Specifically like that, no.

8 Q What would it have been like if you did have

9 that conversation?

10 A It would have been I need investors; nothing

11 more than that. The only people that I ever said I'm

12 running low on cash on -- did not include Szafranski.

13 Q Who would that conversation take place with?

14 A I said it to Boden a couple of times, I said

15 it to Irene Stay more than once, and I said it to Deb a

16 few times when we were running low on cash.

17 Q So those people you told them --

18 A And I said it to Preve frequently.

19 Q Okay. So those four people you told were

20 running low on cash, need cash to keep the scheme going,

21 as opposed to Szafranski when you told him --

22 A No.

23 Q -- you need investors?

24 A I never, ever said to anyone, "I need cash to

25 keep the scheme going."

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1 Q Okay. What did you tell them?

2 A I would say, Irene, let me know. I'm waiting

3 for money to come in. Okay. We've got payments that

4 are due. I would write to Frank or I would talk to

5 Frank: Frank, we've got payments due. You've got to

6 send me back that 2.7 million. You've got to send me

7 back that 3 million. I'm going to send you 3 million.

8 Send me back 2.7.

9 Boden, you've got to get Pearson's people to

10 pay, we've got other payments that are due.

11 So the way you tell someone, that is not --

12 we're running short on money for our scheme. What you

13 say is, we need deals to come in the door or we need

14 deals because payments are due. One of two things.

15 Q Okay. But your conversations with Szafranski

16 weren't of that nature, it's your testimony. Your

17 testimony is that you told him that you needed more

18 investors?

19 A You have to look at the email traffic to see

20 exactly what I was telling him. I don't recall having

21 specific conversations with Mike telling him: I have

22 payments due, I need cash in the door. I don't recall

23 having that conversation. It doesn't mean I didn't, but

24 I don't recall it.

25 Q But you do recall having conversations with

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1 him saying that you needed investors?

2 A Yes.

3 Q Did you tell him why?

4 A That's not -- that's not the way business was

5 done. It's always discussed as little as possible.

6 Q I'm not sure I follow your answer. What do

7 you mean? You told investors --

8 A You would have had to have been in the mix to

9 understand it completely.

10 Q I wasn't, so that's why I'm asking you.

11 A I can't explain it. When you're dealing with

12 someone -- when you have someone like Mike, for example,

13 who is taking millions of dollars in payments from me on

14 what would otherwise be nothing, if you're taking the

15 position that he had no idea what was going on, and he

16 was doing pretty good because he took, what, $13 million

17 from me to do nothing.

18 You have people who are involved. You have

19 people that are taking bribes from you, in essence.

20 People that are getting things that they are not

21 otherwise entitled to, that are seeing things that they

22 know are not real. All of that adds up to someone being

23 in the know, being a player within the Ponzi scheme.

24 Not necessarily knowing, for example, that there's a

25 Ponzi scheme, but knowing that there's a major fraud

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1 going on.

2 With those people, the conversations you have

3 are limited to what they need to know at that moment to

4 further the fraud. Nothing further.

5 We never sat down -- I never sat down with

6 anyone, even Debra Villegas, and said, "Oh, my God.

7 Let's see what's going on in our fraud," and went into

8 detail about what was going on. That's just not the way

9 business was done.

10 Q Now, you testified earlier that I think you --

11 you made some business to the bank with Szafranski?

12 A Yes.

13 Q What was the purpose of that?

14 A In the beginning, to make him think that the

15 balances were there.

16 Q And that would have been after he started

17 doing the verifications, around what time?

18 A It would have been almost immediately after he

19 started doing verifications. Whenever the hedge funds

20 demanded that we start doing bank visits, it would have

21 been at that time.

22 Take a look at the email traffic, it will tell

23 you. It's a lot easier to rely on that traffic than

24 rely on my attempt at remembering the specific date.

25 Q So when you went to the bank to do the

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1 business with Szafranski, who else met you -- met with

2 you?

3 A You mean was there another investor with me?

4 Q Anybody.

5 A The only person who would have been at the

6 bank were the bank officials and Steve Caputi.

7 Q Okay. Maybe I didn't ask the question

8 correctly. Who would you have met with when you went

9 with Szafranski?

10 A Early on, I would have -- I believe that

11 Szafranski -- I may be mistaken but I believe that

12 Szafranski was one of the people that was there when I

13 first used Caputi to pretend to be a bank official.

14 Q And he would have been there meeting with you

15 as well as Caputi?

16 A Szafranski would have drove there with me.

17 Q How many visits did you take to the bank with

18 Szafranski?

19 A In total, or with Caputi?

20 Q Let's start with in total.

21 A Five or six. Maybe less.

22 Q How many with Caputi present?

23 A Well, that's interesting because you've got to

24 remember that it's the fact that Caputi is there that

25 ultimately leads one to understand that Mike clearly

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1 knew that there was a fraud going on. Because if I took

2 Mike in the beginning, which I recall doing, Caputi was

3 playing Ricardo Mejia, a banker working for TD Bank.

4 Subsequently, Mike went to -- went to my night club with

5 me, Cafe Iguana at Pembroke Pines, where Steve Caputi

6 was the manager, and had drinks with Steve and I knowing

7 that the man's name was Steve Caputi.

8 Subsequently, Mike was at Bova on several

9 occasions with me with Steve Caputi drinking.

10 Mike went to Solid Gold on several occasions

11 with me and Steve Caputi. Steve had a very tight

12 relationship, used to be the money guy, Michael Peter,

13 who owned Solid Gold. So we used to get treated very

14 well when we went with Steve. So we went there with

15 Caputi and Mr. Szafranski.

16 So it's clear that in the beginning, while

17 Caputi was playing Mr. Mejia, it became crystal clear to

18 Mike that he was Steve Caputi, not Mr. Mejia.

19 There were times, I believe, there may have

20 been times subsequent to Mike realizing Caputi is Caputi

21 and not Mejia, that we went back to the bank with one of

22 Mike's investors and Caputi was still playing the

23 banker. But I really need to see the -- again, you

24 know, I'd hate to go back to it but I would like to see

25 the email traffic because --

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1 Q Mr. Rothstein, my question was who else was

2 present? I didn't ask you about the whole history

3 between Caputi and Szafranski. We can get to that a

4 little later. I just want to know how many visits you

5 had. You said five or six, and of those five or six,

6 how many was Caputi present with --

7 A Maybe two, if he was present at all.

8 Q Now, of the five or six times that Szafranski

9 went to the bank with you, did anybody give him any

10 documents?

11 A No.

12 It may have been more than five or six. It

13 may have been a few more than that.

14 Q Okay. Well, my question still stands: Did

15 anybody give him any documents?

16 A Either I -- no, it would have been me. I

17 would have given him the fake bank statements.

18 Q Now, when --

19 A Unless -- unless Caputi was there. I would

20 usually have Caputi hand the fake bank statements to

21 them.

22 Q Now, when you gave him the bank statements

23 while you were at the branch, did you tell him that the

24 balances were fake?

25 A No.

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1 Q Anybody else present when you handed the

2 documents to Mike?

3 A You have to look at the bank films and see

4 where I handed it to him. If I handed it to him in the

5 conference room, and Caputi was there, then it would

6 have been me, Szafranski, and Caputi. If I handed it to

7 him out in the middle of the bank floor, then whoever

8 handed me the documents would have seen me handing them

9 to him because that was part of the show.

10 Documents come to -- from the banker to me --

11 it's like creating a chain of custody. The bank goes --

12 documents go from the banker to me, and from me to the

13 putative investor or verifier in this case.

14 Q Other than yourself, did anybody else tell

15 Szafranski that the documents, the statements that he

16 was receiving at the business of the bank, that they

17 were not the actual balances in your firm's accounts?

18 Anybody other than yourself --

19 A You're asking if someone told him that?

20 Q Yeah. When they were handing him the

21 documents, did they tell him this is not the actual

22 balances?

23 A No. That was -- that was never said to

24 anybody we ever handed the documents to. We didn't hand

25 the documents to anyone and then say, "These are not the

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1 actual balances." We didn't even say that to people

2 that knew that they weren't the actual balances.

3 Q Let's talk about the lock letters. Did you

4 ever tell Szafranski that there was in reality no TD

5 Bank lock letters?

6 A Yes.


8 A When we were first putting the lock letters

9 together, we got a request -- I believe it was actually

10 from one of his feeder fund clients. It might have been

11 Damson. Someone was requesting this lock.

12 It definitely wasn't Socket because Socket

13 asked for it later.

14 And Szafranski and I were sitting around

15 BS'ing in my office and the subject of the letter came

16 up. We were talking about this, and I said this is

17 creating real issues internally for me because -- the

18 locking mechanism doesn't exist. And so I told

19 Szafranski we want to use this as little as possible.

20 Don't -- I told him specifically, Don't offer this to

21 people because I don't know how many times I'm going to

22 be able to call on Spinosa to effectively get this put

23 in place, because there's nothing to lock.

24 And it was Mike, I think, who pointed out to

25 me the fact that I could go online and move the money

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1 anyway. He was one of the people that raised that

2 issue.

3 When we are talking about locking the money,

4 all you have to do is go online and hit a wire button,

5 and you could take all the money out, assuming there was

6 any money in there to begin with.

7 Q Okay. When did that conversation take place

8 with Mike?

9 A It was early on with the lock letters. We

10 were maybe one or two lock letters in, and that was a

11 face-to-face conversation.

12 Q Where did that take place? At your office?

13 A It was either in my office or at Bova.

14 Q Anybody else present with you when you had

15 that conversation?

16 A I don't recall anyone being there.

17 As a matter of fact, I recall Szafranski

18 saying -- I don't know if he said -- he was really angry

19 with Damson at one point in time. You'll see this email

20 traffic going back and forth where Damson is breaking

21 his -- breaking his butt over some things that he was

22 either doing or not doing and he screwed up verification

23 where he had missed it by like -- like $22 million to

24 $27 million. It was a big mess-up that Mike had on his

25 thing.

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1 And Mike made a comment to me, he says, The

2 guy doesn't even understand how banking works. Why is

3 he breaking my -- excuse my language -- breaking my

4 balls over this?

5 That's the type of conversation we were

6 having. And we were talking about the lock letters and

7 the fact that they -- these people are asking for

8 something that they know, because -- and it was Damson,

9 because Damson's partners, the Hahn brothers, owned the

10 bank.

11 So here we were kind of getting a giggle out

12 of the fact that we had these bankers who were asking

13 for something that they know can't work. Or should

14 know, because I don't know what they were actually being

15 told -- though Spinosa did a pretty fine job convincing

16 these people that it did, in fact, work.

17 Q Do you recognize the name Brad Edwards?

18 A I do.

19 Q Who is that?

20 A He worked for me.

21 Q Did he know that settlements you were offering

22 were fictitious?

23 A No, sir.

24 Q Now, you testified at some point throughout

25 the last couple of weeks that you sent emails out

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1 falsely exculpating people, correct?

2 A Yes.

3 Q Did you send any emails to Szafranski

4 exonerating him?

5 A You'll have to show me the emails.

6 Q But as you remember them?

7 A As I remember, I don't recall one way or the

8 other. I would have to see emails.

9 I was sending them out because at that moment

10 I believed I was going to kill myself and I didn't want

11 to put anyone else through any further pain.

12 MR. BERGA: Give me one second, Scott.

13 THE WITNESS: Sure.

14 MR. BERGA: I'm all set, Scott. Thanks.

15 THE WITNESS: You're very welcome.


17 MR. RASCO: Good morning. My name is Ray

18 Rasco. I represent Frank Preve.

19 Let me get on the record before I start

20 that we have about two-and-a-half hours

21 allotted, pursuant to the amended protocol

22 ordered and the agreement on among defendants'

23 counsel.

24 I -- in light of the fact that there is

25 7,000 emails or more between you and Mr.

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1 Preve, we don't agree that that's sufficient

2 time to cross-examine, but we're going to do

3 the best we can in the time allotted.

4 DIRECT EXAMINATION

5 BY MR. RASCO:

6 Q I want to start off with your testimony on

7 Friday, regarding a email from April 29, 2009, regarding

8 the -- it was -- the word "farce" was used.

9 Let me just -- it's not in the booklet that I

10 gave you.

11 Do you recall the email --

12 A I do not.

13 Q -- from April 29, 2009; you discussed it on

14 Friday?

15 A Could you show it to me?

16 Q I don't have it, but I -- you testified on

17 Friday that: On April 29, 2009, Mr. Preve knew about

18 the Ponzi scheme, and he knew about the fact that the

19 Bar thing was something I had made up.

20 Do you recall that?

21 A I recall saying something to that effect, yes.

22 Q Okay. The email you described as -- usually,

23 you know, with a -- can you bear with me one second?

24 A Sure.

25 Q You read it into the record, Page 1346, could

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1 you read into the record, the -- I'm sorry, it says:

2 "Give me a few. I am working on another Bar response

3 with Adrian so I can continue this farce. Love ya."

4 Do you recall that email?

5 A I have a vague recollection of it, yes.

6 Q You indicated on Friday that that was an

7 indication that Mr. Preve knew that there was a Ponzi

8 scheme going on and that the Bar issue was fictitious?

9 A I -- I don't recall testifying that that is an

10 indicator that Mr. Preve knew there was a Ponzi scheme

11 going on.

12 Q Well, what you said, specifically, was: On

13 April 20th, 2009, Mr. Preve knew about the Ponzi scheme,

14 and he knew about the fact that the Bar thing was

15 something I had made up.

16 A Yes, but I didn't say that that email is why

17 he knew there was a Ponzi scheme going on. You are

18 putting words in my mouth.

19 Q Can you tell me the basis for that statement?

20 A Everything that leads --

21 Q As --

22 A -- me to believe that he knew there was a

23 Ponzi scheme?

24 Q On April 20th, 2009, at that time, yes.

25 A How do I know that by that time he knew?

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1 Q Yes.

2 A Unrelated to this email?

3 Q Unrelated to this email or related to this

4 email.

5 A In no particular order, on multiple occasions

6 he knew that we had extremely low amounts of money in

7 our trust account. It was verified to him both by John

8 Harris and Frank Spinosa, despite the fact that they

9 were supposed to be covering for me.

10 On --

11 Q Oh, well --

12 A Let me finishing answering.

13 On at least a dozen occasions, maybe two or

14 three dozen occasions, Mr. Preve would send me, knowing

15 that we had no idea what was supposed to be in the bank

16 accounts and that there was no money in the bank

17 account, or very little, he would send me emails

18 instructing me what amounts needed to be in the bank

19 account.

20 There were multiple occasions where Frank was

21 taking investor money to pay Mr. Levin's personal bills,

22 clearly an indication that we know that this is a giant

23 fraud, because if it was a real investing -- investment

24 program, you don't generally take the client's money and

25 do what you want with it.

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1 There were multiple occasions where Frank

2 provided fake documents to me for use, for example, with

3 the auditors. He came to me on more than several

4 occasions and said to me, specifically told me,

5 listen -- We had discussions about the fact that Tracy

6 Weintraub of Berenfeld Spritzer was the auditor, as well

7 as my accountant. He knew I had Mr. Weintraub in my

8 pocket; and wherever he had problems with Tracy, he

9 would come to me and say, listen, you need to get this

10 straightened out.

11 There were multiple the conversations with Mr.

12 Preve where we discussed all the trust accounting

13 issues -- that is evidenced in a ton of emails -- and

14 specifically dealing with the accountants where Frank

15 said -- listen, he sent me, instead of me preparing

16 balance statements and the like for the accounts, where

17 he sent me the documents; tells me, for example, to

18 scribble on the document, to make it look like someone

19 actually worked on it; and then we sent that to the

20 accountants. That's one of the indicators that I have

21 listed so far, all indicators that Frank was in on it.

22 He lied to Mr. Levin about things to cover his

23 tracks. He did side deals with me, trying to hide the

24 funds from Mr. Levin, going so far as to create a

25 pseudonym for himself, G. Steinbeck at whatever that

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1 email address was.

2 He plotted with me on a regular basis as to

3 what stories to tell the hedge funds, what stories to

4 tell other investors.

5 Probably one of the most glaring things is --

6 and I think everyone knows this by now, if you have a

7 real investment program, you don't fund deals in a real

8 investment thing, in a real investment program, without

9 paperwork; and we funded in excess of $25 million in

10 deals with Mr. Scherer clients alone with being no

11 paper.

12 There are a ton of emails where Frank is

13 talking about, we're about to have an audit and we're

14 going to go down in a -- basically in a fiery ball of

15 flames. I don't think those were his exact words; he

16 had other phrases he used.

17 He kept putting off audits. We plotted about

18 lies to tell those auditors. I mean, there's a myriad.

19 Do you want me to keep going?

20 Q That's -- I want to know -- I want to start

21 off with the first two, which are the John Harris and

22 Frank Spinosa emails, because you testified about that

23 last week, as well.

24 A Okay. Did you have those emails?

25 Q Yeah, I have those emails, and if you look at

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1 tab five in the binder -- I'm sorry, it's going to be

2 tab four in the binder I just handed you.

3 The first email is the December 4, 2007, email

4 from Frank to John Harris regarding a Banyan life

5 credit, and it's in that email that he indicates that

6 the Banyan account, which will be a source of repayment,

7 currently stands at over $21 million.

8 A Yes, this is one -- yes, this is actually one

9 of the emails. This is a good email because at this

10 points in time, I'm not certain what Frank knows; but

11 after this whole back and forth with Harris and what

12 went on, it became clear to me that, at the very least,

13 Frank was a player, because -- because he ignored a red

14 flag that looked like the Titanic sinking.

15 Q What red flag was Frank ignoring?

16 A He writes to Harris and he talks about the

17 fact that the RRA trust Banyan account will be the

18 source of repayment and currently stands at over

19 $21 million.

20 Harris at that point in time indicates, based

21 upon his refusal to do a line of credit, refusal to

22 discuss it any further with Mr. Preve, that there's no

23 such thing in that bank account.

24 Q He indicates that to who?

25 A To Mr. Preve.

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1 Q He does that in an email?

2 A I don't believe it was in an email. It was an

3 email back to Mr. Spinosa -- actually, it was in a

4 telephone call to Mr. Spinosa, confirmed later in an

5 email by Mr. Preve and Mr. Levin.

6 In this particular circumstance, it was the

7 back and forth between Banyan and the bank that

8 indicated to me, post this email, that Frank had a

9 pretty good idea of what was going on; because had they

10 really had control over $21 million, had that actually

11 really been the source of repayment, there is no reason

12 for Gibraltar Bank not to at least discuss giving them a

13 loan, but it was pushed off at every turn.

14 If you follow the email traffic, you will see

15 that it was pushed off at every turn because there was

16 not, in fact -- even if there was $21 million in that

17 account that day, and I don't believe there was, John

18 Harris knew -- which is the reason he wasn't going to do

19 any loans with Banyan, why they never did any loans with

20 them. John Harris knew that that money was highly

21 volatile, that one minute there could be $30 million in

22 the account; the next minute, there could be nothing.

23 So Harris knew that it could never be a source

24 of repayment; and that, to me, should have sent major

25 flares up to Preve, but never did.

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1 Q So you're suggesting that that was a red flag,

2 the fact that the line of credit was not approved?

3 A I don't believe they really got it off the

4 ground. I think Harris kept pushing them off for months

5 and months and months.

6 Q Did Harris call you when this email was sent

7 to him regarding $21 million dollars to say --

8 A Yes.

9 Q He called you and told you that there wasn't

10 that money in the account or that Frank was --

11 A He asked me what the heck to do.

12 Q And what did you tell him?

13 A Because they're saying -- I told him, don't

14 give him anymore information. He's not supposed to be

15 asking about my bank balances, use that as your block.

16 Q Did you tell him not to approve the

17 line-of-credit request?

18 A No. I had asked him all along to try to get a

19 line of credit approved. He wasn't going to be able to

20 do it, just by that -- just by that statement alone,

21 okay, Harris knew, at that point in time, and ultimately

22 Preve, that there were problems with our trust

23 accounting.

24 Q So as a result of the fact that this line of

25 credit was not approved, that there wasn't a lot of

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1 discussion about the line of credit in the following-up

2 email traffic, you're saying that it was a red flag, and

3 that's what led -- led you to believe that Mr. Preve was

4 a player from this time?

5 A It was one of the things.

6 Q It was one of the things?

7 A Let me put myself in their shoes.

8 If I'm investing hundreds of millions of

9 dollars in something or a hundred-million dollars or

10 even five-million dollars in something, and I get ahold

11 of the bank, okay, and tell them that we have got

12 $21 million in place for repayment; and they then give

13 me an indication that maybe those funds aren't then,

14 even a maybe those funds aren't there, I'm going to

15 start asking a lot of questions. No questions were

16 asked.

17 Q Do you know that no questions were asked of

18 John Harris?

19 A According what John told me, no further

20 questions were asked and certainly no questions were

21 asked of me.

22 Q Do you know that there is follow-up emails

23 between Frank and John Harris?

24 A Let's take a look at them. Are they in here?

25 Q Well, there is one that follows it, but I'm

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1 just asking you, generally, whether you knew that there

2 was any follow-up or Frank asking questions?

3 A It wouldn't surprise me, but ultimately, he

4 can't substantiate that the money is there.

5 So if you point me to an email that says that

6 Frank should have been calmed down and as assuaged --

7 that is not the right word, is it?

8 Q "Assuaged" is fine.

9 A Assuaged? Is that good?

10 Q That's fine.

11 A My vocabulary sometimes slows me down.

12 -- should have been assuaged by what John

13 Harris was telling him, that I would like to see.

14 Because my recollection is that -- in looking at the

15 emails, it looked to me like it would be a very large

16 red flag.

17 Q Are you aware that there was a meeting between

18 John Harris and George Levin and other people at

19 Gibraltar Bank?

20 A Yes. I was present at several of them.

21 Q What was the purpose of the meeting?

22 A They were trying to get a line of credit and

23 establish a larger banking relationship.

24 Q Was there several meetings, or do you recall

25 just one?

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1 A I recall, off the top of my head, two. There

2 may have been more that I was not present at.

3 Q Mhm-mhm.

4 A But to my understanding, and from

5 conversations that I had with Mr. Preve, himself, and

6 with Mr. Harris, the bank kept putting them off as to

7 ultimately doing a line of credit.

8 Q Okay. Going next to the email with Spinosa,

9 it's a little further in in that same tab. It's FP Bate

10 number 112310. It's May 23rd -- they're in

11 chronological order -- a May 23rd, 2008, email.

12 A 2008?

13 Q Yeah, 2008.

14 It's titled "Idiots."

15 A I don't have May 23rd, 2008. Mine jumps

16 from --

17 MR. NURIK: What's the tab number?

18 THE WITNESS: Tab four?

19 MR. RASCO: I'm sorry.

20 THE WITNESS: Tab four?

21 MR. RASCO: It's at tab four. Yeah. If

22 you don't have it, I can show it to you.

23 THE WITNESS: Hold on. Let me see if

24 it's in here.

25 MS. TRENCH: You said May, right?

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1 MR. RASCO: May 23, 2008; it's titled

2 "Idiots."

3 THE WITNESS: I remember that email.

4 MR. SCHERER: About six from the back, in

5 that section.

6 THE WITNESS: Thank you, Mr. Scherer.

7 BY MR. RASCO:

8 Q You're aware of that?

9 A Give me one second.

10 Q Go ahead. Go ahead.

11 MR. NURIK: Here it is.

12 THE WITNESS: Okay.

13 BY MR. RASCO:

14 Q You're aware that there were several meetings

15 with Frank Spinosa and other people at TD Bank?

16 A I do.

17 Q George Levin and Frank Preve were present?

18 A I was under that impression, yes.

19 Q Were you part of any of those meetings?

20 A I don't recall being, no, sir.

21 Q And do you recall that some of those meetings,

22 at least, were for the purpose of obtaining a line of

23 credit from TD Bank or Commerce Bank at the time?

24 A I do recall that.

25 Q Okay. And did you have any discussions with

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1 Frank Spinosa about the Banyan Group, let's call it,

2 trying to obtain a line of credit?

3 A I did.

4 Q And what were those conversations? Can you

5 describe them, please?

6 A There was one, specifically, that occurred

7 around the time -- probably the day of, but right around

8 the time that this email went out, and I hadn't seen

9 this email at that time.

10 But the telephone call where you have this

11 whole thing, Spinosa contacts me and tells me he thinks

12 he may have screwed up because he thought that Frank was

13 attempting to confirm a bank balance using the whole

14 line-of-credit thing, attempting to confirm the bank

15 balance that I was holding and that they told him that

16 there wasn't that much in the account.

17 And then he said he panicked and lied to Preve

18 and told Preve, I can get you the bank balance but I

19 can't get it to you next week because I don't have

20 access to that information; only my girl has access to

21 it.

22 And at a subsequent point in time, I remember

23 speaking to Mr. Preve, and Preve is telling me that he

24 thinks that Spinosa is just basically off his rocker,

25 that he's -- his ability to lie and to keep stories

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1 straight is weak at best.

2 Q Preve is telling you that he is aware of the

3 fact that Spinosa is lying to him?

4 A Yeah. I mean, you can tell from this email

5 that he thinks he's lying to him. I mean, read that

6 section of the email.

7 Q What section are you specifically referring

8 to?

9 A Let's see right here, second paragraph: And,

10 of course, after telling me that he did not have that

11 much in the RRA trust account -- I mean, at that point

12 in time, first of all, Preve, okay, gets this email and

13 doesn't know there is something going on. You would

14 think they would want an immediate audit of my trust

15 account, or at least ask some questions. But he would

16 confirm to me, and after his return to the office, he

17 doesn't call me back.

18 That is during the period of time that Frank

19 Spinosa is panicking.

20 I then called him, okay, and he told me that

21 he doesn't have personal access to the customer balance

22 system.

23 Okay. That's -- as far as Frank's way of

24 looking at it and my way of looking at it, that's a

25 little bit of a crazy comment, because you would think

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1 that the regional vice president of a bank could find

2 out a customer balance if he needed to, especially when

3 we are talking about tens of millions of dollars that

4 are supposed to be sitting in an account.

5 And, ultimately, Frank just never responds in

6 full to these comments. He just let's it go, as does

7 Frank -- excuse me, Frank Preve and Frank Spinosa; I had

8 better separate them out.

9 Q Right. Frank Spinosa never fully responds to

10 these comments; is that what you're saying?

11 A Not to my knowledge.

12 Q Well, are you --

13 A And then -- hang on.

14 Mr. Preve's last comment -- and I think this

15 is probably more indicative than anything -- and during

16 all this idiocy, I have to remain nice and smiling just

17 in case we need him.

18 So instead of calling him on it, he just kind

19 of let's it float.

20 Q Do you know if Frank Preve followed up with

21 you to talk about this issue?

22 A I just told you he did. Yes, we spoke about

23 it.

24 Q That's you and -- he indicated he knew that

25 Spinosa was lying in that conversation?

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1 A He told me that -- his comment was something

2 to the effect of -- and it was -- it was subsequent to

3 this, because it was involving other investors that

4 might have a reason to speak to Spinosa; and he told me

5 that we -- I needed to rein Spinosa in, that I needed to

6 be careful with him, don't rely on him to do too much

7 for me.

8 It was general terms like that, because he

9 tends to run at the mouth and not sound like he knows

10 what he's talking about, which is true about Frank.

11 That's one of the reasons I gave him that -- even for

12 that very simple conversation where I gave him a

13 script -- when I say "Frank," I mean Frank Spinosa.

14 Q Thank you.

15 And that's what you said, that -- I'm sorry.

16 I didn't catch the last part.

17 That's why you gave him a script?

18 A That's one of the reasons I gave him a script,

19 yes, to try to stick to the script.

20 Q Did you -- going to the first paragraph: Are

21 those guys at Commerce the stupidest people you have

22 ever met? I just got done talking to Frank Spinosa, how

23 upset you were with Tolomer for failing Scott -- telling

24 Scott about our conversation, and as soon as he leaves

25 my office, he calls Scott to ask about the conversation

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1 he just had with me.

2 Is there a reason that you didn't want Spinosa

3 talking to Frank about the trust account balances?

4 A That's not what that is talking about. This

5 is them not wanting Spinosa to talk to me. This is not

6 me not wanting -- I'm not part of this. This is between

7 Preve and Levin. I have never seen this until after my

8 arrest.

9 Q You didn't see this email until after you

10 returned from Morocco?

11 A That's correct.

12 And if you read that first paragraph, that is

13 Frank being angry -- Frank -- let me clarify.

14 That is Frank Preve being angry with Frank

15 Spinosa because he's telling Spinosa not to tell me

16 something, and then I'm getting on the phone calling

17 Preve and relying the exact conversation that Preve had

18 with Spinosa and Preve had with Tolomer -- and Levin had

19 with Tolomer.

20 Q It says: I just got done talking with Frank

21 Spinosa, how upset you were you with Tolomer for telling

22 Scott about our conversation.

23 What did Tolomer tell you?

24 A I don't remember the specifics; but, listen,

25 anytime anybody spoke about me or about this investment

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1 scheme with someone at the bank, okay, I was notified.

2 Okay?

3 Q By Tolomer or by Spinosa?

4 A By Spinosa.

5 Q Okay.

6 A Read the next sentence. You can't leave that

7 out: And as soon as he leaves my office.

8 Now, so this is what is in Preve's head,

9 because I am not having a conversation with him.

10 Preve, basically, dresses Spinosa down for

11 what Tolomer did in telling me about a conversation that

12 was had. At least he believes Tolomer is the one that

13 told me, okay?

14 Right after that, after telling Spinosa how

15 mad he is about what happened with the Tolomer

16 conversation, as soon as Preve is done talking to

17 Spinosa, Spinosa picks up the phone and tells me about

18 that conversation. And that is what has Preve and Levin

19 all up in arms -- well, really Preve, because it's from

20 Preve.

21 Q And you had a conversation with Preve; and in

22 that conversation, he indicated to you that he knew

23 Spinosa was lying. Is that what you're saying?

24 A That was on multiple occasions. There were

25 multiple times when Frank and I chatted and he was

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1 telling me that I needed to be careful with Spinosa, as

2 to what I used him for.

3 Frank and I didn't get into much detail with

4 regard to other people. Frank had his job. I had my

5 job. Other people had their jobs. But when he would

6 find out that someone was loose lips, that he thought

7 they couldn't be trusted, whatever it was, he would

8 bring that to my attention; and obviously, this is a --

9 you know, this is a glaring thing to think that you have

10 tens of millions of dollars in a bank account and the

11 regional vice president tells you it's not there.

12 Q Do you know the specific amount that they were

13 discussing, first of all?

14 A My recollection was that it was some

15 20-some-odd-million dollars, but I don't recall

16 specifically.

17 Q Your recollection was that Spinosa indicated

18 that there were 20-some-odd-million dollars?

19 A No, that there wasn't.

20 Q Oh, that there --

21 A In other words, whatever amount they were

22 looking for, Preve said, you have -- he's giving the

23 same sales pitch to Spinosa that he gave to Harris.

24 It's the same type of thing: We have got control over

25 all this money -- and this happened on several

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1 occasions. I don't know if it happened with other

2 banks.

3 But, basically, it was: You guys have got

4 control over all this money. Ultimately, this is going

5 to be the source of your repayment, and then the bank is

6 looking at it going, what are you talking about? We

7 don't have this money?

8 And since both Harris and Spinosa are on my

9 payroll, both of them are like, well, what the heck do

10 we say to them?

11 Ultimately, I told Spinosa any time someone

12 asks you about anything having to do with me, invoke

13 bank secrecy. You can't discuss my accounts with

14 anyone, even if the money comes from them to me. It's

15 my account.

16 Q Did -- do you know if the decision not to

17 extend the line of credit to the Banyan Group by

18 TD Bank, or Commerce Bank at the time, was made by

19 Spinosa himself?

20 A No. No. It was made by a credit group.

21 Q And do you know anything specific about that

22 decision?

23 A No.

24 Q Okay. How about --

25 A I know that for many -- the only thing I know,

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1 specifically, is that for many months, it basically was

2 going nowhere. It might have been up to a period of

3 year, because I remember emails between Levin and Preve

4 that Preve actually showed me where -- he may have

5 actually sent me copies of it, where he is saying,

6 George really wants this line of credit and I'm

7 basically running out of things to tell him, okay.

8 And he actually tells Spinosa put -- he either

9 told Spinosa or Harris -- I don't remember which lending

10 instance it was, but one of them tells -- Preve tells

11 one of them, listen, just at least go through the

12 motions just as a show for George so he thinks something

13 is going on, so he thinks something positive is

14 happening.

15 Q Do you know how long after this email was

16 sent, that that supposed email was written?

17 A Well, do you have the email? Then I can tell.

18 Q I don't have a copy of that email here.

19 A It's in existence. If I find it, while you're

20 here, I'll show it to you.

21 Q Do you know if for about a year Frank was

22 following up with Spinosa about the issue of obtaining a

23 line of credit from TD Bank?

24 A That wouldn't surprise me.

25 Q That wouldn't surprise you.

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1 And do you know that it was several weeks

2 after the meeting -- the email that we just discussed

3 between John Harris, that Preve sent several emails and

4 had discussions with John Harris and others at

5 Gibraltar?

6 A That would not surprise me. My understanding

7 was that the entire time, George wanted a line of

8 credit.

9 Q And Frank's concerns regarding -- not Frank

10 Spinosa, Preve's concerns regarding Spinosa, were those

11 relating to his ability or his competence, or were those

12 relating to the fact that he was concerned that he

13 wasn't going to keep his mouth shut about this?

14 A You have got to remember that the people --

15 all the people, all the various tentacles of the Ponzi

16 scheme, I tried very hard not to let people talk to each

17 other, even within my office: I kept things hidden from

18 Deb that I was doing with Boden, things hidden from

19 Boden I was doing with Szafranski, things hidden from

20 Szafranski I was doing with Deb, all the way around.

21 It was the same thing in the Preve banking

22 thing. I don't know, specifically, what was in Frank's

23 mind; I can tell you that Frank spoke to me the way he

24 normally would related to the illegal activity we were

25 doing.

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1 And that is, be careful what you use Spinosa

2 for, he'll get you tripped up, be careful, he'll put you

3 in a trick box.

4 Q My question is, though: Is that related to go

5 his competence or his ability to do his job?

6 A As opposed to his involvement in the scheme?

7 Q Correct.

8 A I think that his competence goes to his

9 ability to do the scheme. You want bright people

10 involved in the fraud, so if -- it could have been a

11 comment as to his competence in the fraud. I think it's

12 all intertwined.

13 Q Are there any emails between you and Frank,

14 specifically, indicating that he was -- that Frank was

15 aware that Spinosa was involved in the fraud?

16 A I don't think I ever put that in any email to

17 anyone. I don't think I would have.

18 Q With respect to Preve or with respect to

19 Spinosa?

20 A With respect to -- other than emails that you

21 can read and figure out that there is some fraud going

22 on -- probably more in emails between Levin and I than

23 any place; secondarily, emails between Frank Preve and

24 I -- I would never have put in an email, hey, be

25 careful, I know you told me to be careful of Spinosa

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1 because he knows about the fraud and we don't want him

2 to mess up our fraud. That is just not the way we

3 speak.

4 Q Are you aware --

5 A You use Ponzi-speak.

6 Q You're aware that after this email from May

7 23rd of 2008, and after the Harris email that we

8 discussed, that both Frank Preve and George Levin sought

9 independent verification of trust account balances on

10 several occasions, correct?

11 A They did, yes.

12 Q Okay. Through you and through other

13 independent sources, correct?

14 A Well, "independent" is an interesting word

15 because at different points in time, even the banks

16 weren't independent, so --

17 Q Well --

18 A -- yes, to your specific question, but --

19 Q Let me be --

20 A -- as what it really means...

21 Q Let's talk about the independent third-party

22 verifier, Michael Szafranski.

23 Was Preve -- well, you indicated earlier this

24 morning that Preve was aware that Szafranski was a

25 player?

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1 A At a certain point in time, yes.

2 Q Can you be more specific?

3 A No. Like I told the other gentleman this

4 morning, I don't know the time frame.

5 Q Can you tell me how Frank Preve was aware that

6 Mr. Szafranski was a player, as you called him?

7 A I can't pinpoint it for you. It's the same

8 way -- everyone kind of eases into this type of fraud.

9 They start doing little bitty things that are illegal,

10 and eventually it grows into significant things.

11 Like with Szafranski, it starts out with him

12 realizing that the money is not there; me realizing that

13 he knows that the money is not there; ultimately to the

14 point where he is bringing in investors and it escalates

15 to the point where he is taking over $10 million from me

16 for his participation in the fraud.

17 Q So you're -- so Frank became aware -- beyond

18 these -- I'm sorry, beyond these two emails, you're

19 generally pointing to other emails that Frank Preve had

20 with you relating to trust account balances and

21 irregularities in trust account balances?

22 A In order to get a full picture of my

23 relationship with Frank and to the extent of his

24 knowledge of the fraud, you can't look at this. This is

25 not even a thumbnail sketch of the email traffic.

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1 Q I understand.

2 A You need to really look at everything that's

3 going on, all the red flags, all the things that are

4 being ignored, the fraudulent things he's asking me to

5 do, the balance corrections; the one point in time when

6 he get a statement and glaring red flag, I sent him a --

7 Michael Szafranski sent him a balance statement and it's

8 completely wrong. It's off by almost a billion dollars,

9 and Frank write back: This is impossible.

10 Q Can you --

11 A You would think at that point in time maybe he

12 would do something other than write back to me "this is

13 impossible."

14 Q Can you tell me, do you recall the date of

15 that email?

16 A I don't.

17 Q If you -- if --

18 A I do remember it says, "did you find it?"

19 Q No, I didn't -- it's not -- it's not in this.

20 A It's related to the 9146 account. I remember

21 him saying, "this can't be right. You need to fix this

22 because you're supposed to have almost a billion dollars

23 in the 9146 account, alone."

24 Q Do you remember having a conversation with

25 Frank Preve about Irene Stay's ability to --

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1 A Sorry, that would be inabilities.

2 Q That is my question. What -- what was -- do

3 you recall that conversation with Frank Preve around

4 2007?

5 A I'm sorry?

6 Q Do you recall that conversation with Frank

7 about Irene Stay's inabilities, as you call it?

8 A We talked about the fact that Irene could be a

9 knuckle head, okay, when it came to her work. We talked

10 about the fact that she didn't appear to have a solid

11 grasp of what she needed to do in her overall job

12 description; but, generally, when we spoke about those

13 things, we also had to remember the fact that she was an

14 instrumental part of what we were doing in the Ponzi

15 scheme and that she did properly effectuate hundreds of

16 million dollars of transfers for us on a daily basis

17 flowing in and out of trust accounts and the like. So I

18 had to balance her ineptitude with the fact that on the

19 things that really mattered to what we were doing in the

20 scam, she was quite effective.

21 Q Was Frank aware of the fact that she was

22 involved in the scam?

23 A Eventually, yes, but I don't know the time

24 frame.

25 Q Do you know the basis for that statement?

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1 A Sure. He's actually -- he actually sends -- I

2 mean, there's a bunch of red flags, but he's sending

3 balances to Irene.

4 So picture this: This is supposed to be real

5 investment, and he's sending balances to the CFO, who is

6 supposed to really be sending the balances to him. He's

7 sending balances to her saying, send me these balances,

8 move the money around, this is how much you're supposed

9 to have in this account; this is how much you're

10 supposed to have in that account.

11 It's not the way a -- at least not any

12 investment I had that was real, that's not how you do

13 it. Generally, you ask for a balance and the CFO

14 provides it to you, not the other way around.

15 Q Did you consider Frank Preve to have more

16 financial and accounting expertise than Irene Stay?

17 A Yeah, far more.

18 Q And in the conversations that you had in 2007

19 with Mr. Preve regarding Irene Stay's inability, did --

20 A Listen, do you have something specific this

21 conversation, because this is the first time I'm hearing

22 conversation in 2007.

23 Q Well --

24 A We were talking generally before that.

25 Q -- are you talking about general conversations

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1 through 2007, '08 and '09 about her inability, or do you

2 recall that it was only in 2007?

3 A No. Throughout my relationship with

4 Mr. Preve, we had conversations on and off about Irene

5 and whether she was up to the challenges of everything

6 that was going on. You know, there were things where

7 she fell down on it.

8 But overall, as I reminded him, usually over

9 cocktails, I remind him, listen, she has got a lot on

10 her plate. She's got to run all the legitimate business

11 of the law firm, plus she has got to do all my business;

12 and all the payments ultimately get to where they are

13 going.

14 Until the Ponzi scheme exploded, every single

15 payment got to where it needed to go. So in the stuff

16 that was going to keep us all out of jail, she was doing

17 a good job.

18 Q I understand that, but did Frank indicate to

19 you early on in 2007, when you first started doing

20 business with Levin, with the Banyan Group, did he

21 indicate to you that he was going to make sure that

22 everything was accounted for properly in order to make

23 sure that Irene was not missing anything?

24 A He may have.

25 Do you have an email to show me that he says

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1 that?

2 Q I don't have a specific email, but I'm asking

3 for your recollection.

4 A That he's going to make sure?

5 I assumed -- and this is an assumption on my

6 part. I assumed the entire time that Frank would keep

7 track of the hundreds of millions of dollars we're

8 moving. That's why I relied on him.

9 But as far as the balances, I think you may be

10 missing my point.

11 No matter what, the bank balances should have

12 nothing to do with Irene. Irene should be able to hit a

13 button -- if these are real balances, hit a button, look

14 at the screen, and then print that off and send it to

15 Frank.

16 She shouldn't have to do any accounting to get

17 there. It's a matter of pushing a button and print and

18 "zzzscht," off we go.

19 Can you put that on the record, "zzzcht"?

20 Okay. Off we go.

21 What was really happening was, because Frank

22 knew this was happening, it is completely opposite:

23 Frank tells Irene, or me, or both, this is what needs to

24 be in the accounts. Okay. And then, she fixes it up

25 and sends it off to him.

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1 That's never the way it should work in a

2 legitimate investment deal, never. I can't imagine

3 calling my broker at Smith Barney and saying, I need to

4 know the balance, there's supposed to be $3 million in

5 there; can you make sure it says 3 million then send it

6 to me, please?

7 Q Can you turn to tab two, the last email in tab

8 two?

9 A Yes.

10 Q If you read the first -- if you go to the

11 bottom of that -- that string, it's an email from

12 October 1st, 2009, from Larry Lawrence King -- I'm

13 sorry, Larry King to Frank Preve.

14 A Yes, I have it. October 1st, 2009, at 8:45?

15 Q Yes, and it indicates that: Frank, my wire

16 needs to hit this AM. If they don't, I will be in the

17 penalty box with a few of my investors. Thanks, Larry.

18 Frank then responds to you at 10:52 that

19 morning --

20 A I'm sorry?

21 Q Frank then responds to you, if you go up to

22 the chain --

23 A Yeah. Let me go ahead and read that.

24 Q Okay --

25 A Okay.

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1 Q -- Frank is saying, in the middle of that

2 paragraph -- let me just read the whole thing: This

3 just doesn't smell right. So far we have payment issues

4 for three non-Florida-bar-related trust accounts: SFS,

5 LMB and BIF. The question is why? We are on the verge

6 of entering a fourth relationship with AJ, and I am

7 concerned that we are going to find ourselves in the

8 same fix in a couple of months when we have $20 million

9 in payments due. We must fix these three accounts so

10 that they never hear, smell or see any problems with

11 trust disbursements. They should be done automatically

12 and without fail; and I need your assurances that I'm

13 not committing a gross stupidity by throwing good money

14 after bad by supporting the AJ program. This is

15 important to me personally and to our ongoing sanity.

16 Please.

17 A Okay.

18 Q And then you go and you -- the previous page,

19 you have your response, where you indicate to him: You

20 are not being stupid, and LMB, according to cash

21 management, just went in new clients, more to follow and

22 close your nose. Everything is fine. Knock it off.

23 Why are you telling him on October 1st, 2009,

24 when this thing is unraveling, that he is -- that he is

25 correct, that his email below is correct?

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1 A Why am I not telling him that?

2 Q Why are you telling him? You are telling him

3 he's not being stupid.

4 A You are missing all the Ponzi-speak in these

5 two emails.

6 Q Okay. Explain that it to me.

7 A Okay. We're talking about, now, you've got

8 these. These are all notes to Mr Scherer's clients,

9 right, we're about to get in with.

10 Q Correct?

11 A We have BIF, which is Barry Bekkedam's and Mr.

12 Scherer's clients; there is money going through them.

13 What Frank is telling me here is that it

14 doesn't smell right. There are problems. Clean them

15 up.

16 He's not asking me, as someone would who

17 really didn't know what was going on, he's not asking me

18 anywhere in here: I need to see, for example, paper

19 bank statements. I need to see something more than what

20 you're sending me. I'm concerned about all the

21 balances.

22 That he is asking me in this, when I read this

23 is, he's saying: Make sure you're handling you're part

24 of what we're doing properly. I don't need these

25 additional headaches. It doesn't smell right. We must

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1 fix these three accounts so I never hear, smell or see

2 any problems with trust disbursements.

3 We have been talking about that there are

4 dozens of emails like that, where we're not sending the

5 disbursements out on time because Irene doesn't know the

6 proper balances and doesn't know where the payments are

7 going.

8 One of the key things I tell him to do, if you

9 read my email is: Close your nose. Okay. Which is my

10 indicator to him, don't worry, I've got -- you worry

11 about your side. Don't worry about my smelling what I'm

12 doing. I've got my side under control.

13 You have got to remember by this point in

14 time, sir, there is massive fraud going on. We are

15 funding tens of million dollars. Mr. Preve is funding

16 without a stitch of paper.

17 Now, Mr. Preve might have had momentary

18 lapses, okay; but you're talking about sending me in

19 excess, actually, of $25 million, in paper that you're

20 saying he didn't know was fraudulent with no paper, no

21 plaintiff, no defendant, no deal number, no assignment,

22 nothing, zero, just sending me the money because he

23 knows I have other payments to make.

24 It's glaring, so you can't take one email out

25 of the context. You're taking one email out of the

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1 context of some seven-, eight-, ten-thousand, maybe

2 more, emails and trying to put a twist on it that really

3 isn't there.

4 It's all Ponzi-speak, especially by

5 October 1st. There is so much fraud flying back and

6 forth and Frank sending more emails, it's crazy.

7 Q Isn't he indicating that the trust

8 disbursements should be done automatically and without

9 fail?

10 A That was something we talked about early on:

11 They were supposed to be done -- quote, unquote, Irene

12 is supposed to get these things out.

13 What was happening over here, what he's

14 telling me is, you're sending up too many red flags. We

15 are about to go into the business with AJ. We're about

16 to take in a whole lot of money; we can't have this same

17 thing occurring.

18 One of the themes that Frank and I were

19 discussing regularly around the time that all of

20 Mr. Scherer's clients were coming in, was the fact that

21 these people aren't playing. Where we could have gotten

22 away with certain things and smoothed things over with

23 certain of the investors we had before, we don't have

24 that same kind of thing with these -- Von Allmen,

25 Clockwork.

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1 These are serious people. They're going to be

2 investing all kinds of serious money. They are a

3 completely different level of investor. They are going

4 to be asking a completely different level of questions,

5 and we need to tighten the strings on our -- on what

6 we're doing, pulling it all in, rein it in.

7 Q And that didn't occur, correct? You weren't

8 able to rein it in when it came -- after October 2009

9 with the Von Allmen Group?

10 A Well, we reined it in enough to convince them

11 to invest with us.

12 Ultimately, the whole thing exploded, but we

13 certainly reined all the deal packaging in and the sales

14 and the fraudulent documents, we reined that in enough

15 to convince them to invest a substantial amount of money

16 with us.

17 Q Do you recall testimony earlier last week

18 regarding the conference call with --

19 Actually, before we go there, you were talking

20 about the fact that there were deals being papered --

21 not being papered, towards the end, specifically, that

22 were -- were a very large quantity?

23 Do you know if Frank ever saw unredacted

24 documents?

25 A I'm sorry?

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1 Q Any unredacted deal documents, did he ever

2 see --

3 A Does that have anything to do with that

4 first -- I lost you because you started out that there

5 were deals that were not papered.

6 Q I'm asking the issue of -- well, first of all,

7 with the papering of deals, was Frank -- did Frank ever

8 see any -- any documents that were not redacted?

9 A Yes.

10 Q When?

11 A In my office on multiple occasions.

12 Q And Frank --

13 A I may have sent some to him by email, but he

14 saw many of the deal packets in my office. He was there

15 when we created some of them.

16 Q He saw you create deal packets?

17 A Well, he was in -- at certain points in time,

18 it would be almost impossible, okay, not to see us

19 creating deal packets back there because we had some

20 days where we were creating five, ten, fifteen deal

21 packets, and that is all that was going on.

22 So if you were one of the people who was

23 allowed back into that area, yes, it's very possible

24 that you would have, and highly likely, I mean, that he

25 would have been there to see something going on.

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1 Q Who specifically did he see preparing deal

2 packets?

3 A I don't recall specifically, but he did see

4 the deal packets.

5 Q Unredacted?

6 A Unredacted, yes, sir.

7 Q In your office?

8 A In my office.

9 Q Can you tell me who would have been present

10 when he did so?

11 A Just me and Frank.

12 Q Okay. And --

13 A As a matter of fact, I recall a specific

14 occasion where he said, show me what you're showing

15 Szafranski. Okay. He wanted to get an idea of what

16 Szafranski was looking at.

17 Q What was your response to that?

18 A Okay.

19 Q So you showed him what Szafranski was seeing;

20 you showed him deal files?

21 A Yes.

22 Q Which were unredacted?

23 A Yes.

24 Q Okay. And you were the only one present at

25 that meeting?

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1 A As I said earlier, I tried to limit who was

2 there whenever I was talking about or doing something

3 related to any of this, yes. So I would have been the

4 only person in there showing him the deal packets.

5 Q Do you recall an approximate time frame?

6 A I do not.

7 Q What did Frank say in response to that, if

8 anything?

9 A He didn't say anything.

10 Q Did you ever tell Frank that --

11 A To my knowledge. I mean, he certainly didn't

12 make a comment like: What are you doing; this looks

13 like fraud. He didn't say anything like that.

14 He just looked at the deal packets, and that

15 was that. He wanted to see what Szafranski was looking

16 at.

17 Q Did you ever tell Frank Preve or George Levin

18 that they could not look at, you know, redacted deal

19 documents because they were subject to confidentiality?

20 A Early on, sure; and I told George that all the

21 way through.

22 Q And you did so in emails and verbally,

23 correct?

24 A Absolutely. And I probably wrote it to Frank

25 telling him, don't, you can't see this stuff. But what

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1 I told Frank in emails and what Frank and I actually did

2 sometimes don't match.

3 Q Okay. And --

4 A As evidenced by Frank's behavior, back.

5 Q When Brian Jedwab and Ari Glass came in

6 December of 2008 to perform additional due diligence --

7 A Yes.

8 Q -- did they look at deal files?

9 A Yes.

10 Q Redacted?

11 A My recollection is they were redacted, that

12 Ari and Brian looked at redacted files.

13 Q Did Frank speak to you at that time and ask if

14 he could join in on the due diligence and go and see the

15 files, as well?

16 A I don't recall one way or the other. If there

17 is some email traffic, it might help refresh my

18 recollection, but I don't recall one way or the other.

19 That's not sticking out. That was a very

20 tense period of time for all of us involved in this

21 scam.

22 Q December of 2008, the time frame you're

23 talking about right now?

24 A You're talking about the due diligence where

25 we're going to visit the other lawyers?

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1 Q Correct.

2 A Around the time that they wanted to do that

3 enhanced due diligence and see the other lawyers, yes,

4 that was an extremely intense period of time for all of

5 us.

6 Q Did Frank want to be involved in that

7 diligence is my question.

8 A I don't recall one way or the other.

9 I do recall that Frank -- either in an email

10 or in testimony -- said that he didn't know who we were

11 going to see, and that if he knew that we were going to

12 see Fla- -- excuse me, Bates Koppel and Rossi and

13 Herskowitz, that that would have set off a tremendous

14 red flag in his head. That was -- I think his testimony

15 or something --

16 Q That -- are you talking about his deposition

17 testimony in the Razorback matter?

18 A Could be, yeah.

19 Q Have you reviewed that deposition?

20 A I saw pieces of it, yes.

21 Q You haven't read the whole thing; you've just

22 seen portions?

23 A I don't think I've read the entire thing. I

24 was looking for specific things.

25 But I do recall him saying that, and that --

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1 the only reason I am bringing that up is because that

2 reminds me that he was at least involved at some level,

3 because I remember reading that, saying, well, that's

4 nonsensical. There is no way, at this point in time,

5 that I was going to be doing any due diligence on behalf

6 of the Banyan folks, which is really who I'm doing it on

7 behalf of because they're the borrower; and then Frank

8 is not going to be asking me every minute, what are you

9 doing.

10 Q What you're saying is nonsensical is Frank's

11 statement that he would have thought it was a red flag,

12 had he known the names of the attorneys?

13 A Sure. Because -- and I'll tell you a couple

14 of reasons.

15 One, there's a much earlier email between me

16 and Frank, maybe even George, where I'm discussing the

17 fact that I'm allegedly getting cases, okay, from Doug

18 Bates, all right, so he's heard the name before.

19 Then, when I'm going to do this due diligence,

20 generally, if you look at my cell phone records, for

21 example, and the like, email traffic, whenever I'm doing

22 anything for the hedge funds related to due diligence,

23 Frank wants regular updates.

24 So it is beyond believability, far beyond it,

25 to think that I would trot around with Brian Jedwab and

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1 Ari Glass to three different lawyers' offices and never

2 tell Frank what I was doing. It's just not possible.

3 Q So you're saying you did tell Frank what you

4 were doing or you did not?

5 A Sure. I absolutely did.

6 Q So he knew you were conducting diligence, and

7 he knew you were meeting with these people?

8 A Sure.

9 Q He knew their names?

10 A Absolutely.

11 Q So he knew the individuals that you were

12 meeting with, Brian Jedwab and Ari Glass?

13 A Yes, sir.

14 Q And through a conversation or through emails

15 you informed him?

16 A Possible through both, I don't recall; but I

17 at least told him.

18 Q Do you recall if it was personally or over the

19 phone or by email?

20 A I recall either from -- Doug Bates's office

21 phone or from my cell phone, when I got done with one of

22 those meetings, with the Bates Koppel meeting, that I

23 called Frank to update him and let him know that

24 everything was going fine. I just don't remember

25 whether I called from their office phone or from my cell

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1 phone.

2 Q You didn't give him anymore specifics than

3 that, did you?

4 A Other than to let him know that we met with

5 the lawyers and they verified everything perfectly?

6 Q Right.

7 A Just that.

8 Q Did you give him -- you gave him the names of

9 the lawyers, though?

10 A He knew ahead of time who the lawyers were. I

11 had told him that Russ Adler help me set them up.

12 Q You had told him that Russ Adler helped you

13 set up these lawyers who were going to be putting on a

14 show for these investors in New York?

15 A Yes. Here's what happened. You have got to

16 take it in order.

17 Initially, the hedge funds are sending us a

18 request for enhanced due diligence. They just want to

19 speak to some of our referring lawyers. Okay.

20 If you recall my testimony from last week, we

21 were just going to give him the names. I sent that mass

22 email out to the law firm, and we were just going to

23 give him some names of some people who would simply

24 verify, yes, they sent us labor and employment cases and

25 yes, they are pleased with us.

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1 Then Brian Jedwab wanted to do more enhanced:

2 I want to be able to talk to these people at length.

3 That ultimately morphed, grew into a coming

4 down to all actually meet with lawyers. At that point

5 in time, I needed to enlist the help of someone who knew

6 about the Ponzi scheme. So, as I testified last week, I

7 went to Adler, because Adler has been chomping at the

8 bit to get involved and to be able to make more capital

9 for himself.

10 I have him go ahead and set up the meetings

11 with Rossi and Herskowitz, the people that I didn't

12 really know at that point in time and assist me in

13 setting up the Koppel Bates meeting.

14 And, yes, I kept Frank apprised as to what I

15 was doing because both Frank and I knew that any future

16 business with the hedge funds in New York would be

17 contingent upon passing this due diligence with flying

18 colors.

19 Q And was Jedwab convinced of the authenticity

20 of the investment strategy, let's call it?

21 A He led me to believe he was, yes.

22 Q And do you believe he was?

23 A At that time I believed he was, yes.

24 Q In hindsight?

25 MR. SCHERER: Objection to the form.

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1 A Well, yes, I believe Jedwab, up until the

2 time -- I believe Jedwab had suspicions; but as I

3 testified last week, I also believe that the second

4 Jedwab knew for certain that something was wrong, if he

5 ever did, he would have been screaming at the top of his

6 lungs for the police.

7 Q Do you know if Jedwab or Ari Glass provided

8 the results they -- they prepared a due-diligence

9 memorandum; do you recall that document?

10 A I saw it subsequent to the Ponzi scheme

11 exploding, subsequent to October 2009.

12 Q Do you know if Frank Preve, around that time,

13 in December, January -- December 2008, January 2009,

14 tried to obtain that due diligence report?

15 A No. My recollection is that they actually

16 gave that document -- if we're thinking about the same

17 document, I saw it before October of 2009, actually,

18 because that document actually came to Frank through

19 Jack Simony; but if you would show me the document, I

20 would be able to not go back and forth like that.

21 Q And that came -- that was provided to Frank by

22 Jack Simony by email?

23 A Hang on a second. Are we talking about the

24 Kroll due diligence report?

25 Q We are talking about the due diligence

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1 memorandum written, by Brian Jedwab, that has as the

2 date on it, various dates.

3 A Can you show it to me?

4 Q I don't have it. I don't have it on me.

5 But you don't know if that was provided to

6 Frank Preve one way or the other, do you?

7 A One of them -- I have to see it.

8 At least one, maybe both, were provided -- and

9 when I say both, I mean the Jedwab due diligence letter

10 and the Kroll report. One or both were provided to

11 Preve by Jack Simony and showed to me.

12 But without seeing it, I can't tell you which

13 one.

14 Q Okay. The Kroll report, do you recall if that

15 was provided to Frank by Jack Simony in an email?

16 A No, no, at least to my knowledge. I don't

17 think he would be that stupid.

18 Q Okay.

19 A I mean, that was an internal document. I

20 don't think Jack would do that on an internal. I don't

21 think he would deliver it to him.

22 Q Did you ever tell Frank Preve and George Levin

23 that you were spending a million dollars in marketing

24 per month to obtain --

25 A It was some sum like that, yes.

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1 Q And that you were doing it through various

2 online advertisings and other methods, the million

3 dollars being spent; do you recall that?

4 A At various points in time, I discussed with

5 both Mr. Preve and Mr. Levin as to what we were doing to

6 market, quote, unquote, the investments, quote, unquote.

7 Q At various times --

8 A Different conversations between Preve and I

9 and Levin and I.

10 Q Is it fair to say that they asked you several

11 questions about that over the course --

12 A Give me a time frame.

13 Q 2007 to 2008.

14 A I'm sorry. Give me the time frame, again.

15 Q Let's say 2007.

16 A Well, back before Preve knew what was going

17 on, I definitely tried to sell him. So I could -- I

18 could easily picture him asking me that.

19 Do I have a specific recollection of it, no;

20 but was it something that ultimately came up, yes.

21 But, again, there's difference in

22 conversations between myself and Preve and myself and

23 Levin.

24 Q When specifically did Preve know what was

25 going on?

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1 A I can't tell you specifically.

2 Again, here's what you need to do: If you

3 look at all the email traffic, you'll see -- with almost

4 everything that was involved, probably everybody that

5 was involved, you'll see that there's -- there's a

6 change-over.

7 People -- it's not like one day you wake up

8 and say, oh, okay, I'm going to tell Frank we're

9 committing fraud today. That's not what happens.

10 People see little things, and then based upon

11 how they react, that's how you decide whether to open

12 the -- let's call the Ponzi door a little bit more.

13 Okay. You open it a little bit more. They

14 see a little bit more. You start feeding them money,

15 cash. You start giving them the rock-star lifestyle.

16 You start luring them in a little bit more. You see

17 that they are clearly players.

18 Eventually they either do or don't get

19 involved in a much higher level. That's what happens.

20 If there are people that I tried to get

21 involved that ultimately didn't get involved.

22 Q Did you ever lie to Frank Preve?

23 A Yes.

24 Q Is it fair to say that you lied to him

25 throughout the course of your dealings with him and

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1 George?

2 A About various things, yes.

3 Q Yes. Including through the time that you went

4 to Morocco?

5 A Sure. When I went to Morocco, I told him I

6 was trying to fix this through London Bankers. That was

7 a complete lie.

8 Q Why would you make up that story if Frank knew

9 what was going on?

10 A I think I was simply desperate to try to put

11 everyone at ease while I decided what to do with myself.

12 Here's the thing, given Frank's level of

13 knowledge and the fact that this thing is exploding, at

14 that point in time, I was deeply concerned about what

15 Frank might do to attempt to save himself.

16 And until I decided what I was doing, I wanted

17 to hold everybody at bay and the only way I was going to

18 do that was to lead everyone, both people involved and

19 not involved, that I was going to be able to solve the

20 situation.

21 Q What did you think Frank might do to try to

22 save himself? What were you concerned about?

23 A Go to the police.

24 Q But you were already in Morocco; why would you

25 be concerned about that?

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1 A Because I had not decided yet what I was

2 doing.

3 Q You weren't sure whether you were going to

4 return at that point?

5 A I wasn't sure whether I was going to kill

6 myself, continue to flee, return.

7 Q But --

8 A There were a whole myriad of things that were

9 going through my head at that point in time.

10 If you recall, early on, when I fled, I sent

11 emails to a bunch of people trying to figure what I

12 actually owed people to get their principal back. I

13 suppose in some warped part of my mind, I was believing

14 that maybe I can get enough money together to make these

15 people whole so that this wouldn't be as bad as it

16 ultimately turned out to be.

17 Q Do you -- you indicated earlier in your

18 testimony that you had sent emails falsely exculpating

19 certain people, and that included Frank Preve, correct?

20 A I believe I sent one to Frank. If you have

21 it, it would be easier if I could just see it, but he

22 certainly -- I think I sent one to him and George

23 together, falsely ex- -- exculpating them.

24 Q Yeah, if you -- if you go through the tab one,

25 it's -- I believe it is -- it's -- I'm sorry. It's

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1 October 31st, 2009, from you to George Levin, and it

2 says -- subject line is "me" --

3 Did you find it yet?

4 A Do you have a time?

5 Q It's chronological in tab one.

6 A Me. Okay. Yeah, I got it.

7 Q It states, do not --

8 A I'm just trying to help. There you go.

9 Q "Do not try to bail me out of this, save

10 yourself. You and Frank did nothing wrong. I did. I

11 am the liar. I am the thief. I am the scum bag. I

12 either go to jail or die. Why should I put my family

13 through watching me go to jail? Love forever, Scott."

14 A Yes.

15 Q Are you indicating to me that that email is a

16 lie?

17 A As to Frank it is.

18 Q It's not as to George, but it is as to Frank?

19 A I can't -- even as I sit here today, I still

20 don't fully understand at what level George may have

21 been involved. I just can't say one way or the other.

22 There are things that indicate to me, perhaps,

23 that he was in the know, to some extent; and there are

24 things that indicate to me that he absolutely believed

25 everything was accurate. So I can't say one way or the

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1 other.

2 But, in any event, I had tremendously deep

3 feelings for George and Frank at this point in time.

4 And I was extremely emotional, and it -- it

5 was my decision, by the time I wrote this, that I was

6 going to kill myself. And I saw no reason, at all, for

7 anyone else to have to have problems with authorities

8 and the like after I was gone. Why put them through

9 that? What -- what purpose would that serve?

10 Q So your mental state at this time, when you're

11 sending this email, is that you're going to kill

12 yourself; that's right?

13 A I think from the moment I got to -- to

14 Morocco, I had toyed with it; and there were

15 certainly -- and you can tell from email traffic, you

16 can tell where I'm more lucid than others. A lot of it

17 depended upon what I was -- what pills I was taking,

18 what I was drinking at the time.

19 Q Okay.

20 A I was more lucid than others; but you can

21 clearly tell there are times when I'm trying to fight my

22 way out of it, and there are times when I'm clearly

23 close to killing myself. So...

24 Q But at this point you know that there are,

25 literally, thousands of emails between you and Frank

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Page 1523

1 that indicate that he knew something was up, right?

2 I mean, October 31st, 2009, you know --

3 A Right. You're thinking that I went through

4 some kind of analysis while I was sitting there eating

5 Xanax and drinking vodka and thinking about killing

6 myself. I mean, you don't go through -- if you have

7 never attempted to kill yourself and been in this kind

8 of position, and you're under the strain that you're

9 under when this kind of crime is exploding, I can't -- I

10 can't explain to you what my mind-set was.

11 I wasn't sitting there going, well, there's a

12 lot of emails that say Frank is clearly guilty, so let's

13 not try to exculpate him; let's just say George.

14 I mean, I was going to send emails to anyone

15 and everyone to try to save them. There was no

16 reason -- I had already hurt enough people. There was

17 no reason to cause anymore pain.

18 Q But you knew for a fact that you had all these

19 emails with Frank. I mean, you have testified about it

20 already today and last week, that you had thousands of

21 emails with Frank indicating that he knew something was

22 up, by October 31st, 2009; isn't that right?

23 A I don't understand why that has anything to do

24 with what I just testified to.

25 Q Well, why would you falsely exculpate Frank if

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Page 1524

1 you know that you have thousands of emails with him that

2 show that he is part of it?

3 A Okay. Say the question, again?

4 Q Why would you falsely exculpate Frank if you

5 know that you have thousands of emails that clearly

6 indicate that he is part of it?

7 A Because I intended to kill myself, and I

8 didn't want anyone else to have to go through this.

9 Q And so you're -- you know you're going to kill

10 yourself or you're intending to go kill yourself and

11 you're purposely being dishonest at the moment that

12 you're about to kill yourself?

13 A Yes. I was trying to save people who I cared

14 about, yes.

15 Q If you go further down in that tab, there

16 are -- there is an exhibit, Exhibit A, at the bottom of

17 it, were emails of October 31st, 2009, between you and

18 Frank and you and George?

19 MR. SCHERER: Where are you, counsel?

20 MR. RASCO: It's just a few more pages

21 behind that October 31st email that we were

22 just discussing. The subject is "sit tight."

23 THE WITNESS: There was a lot of them

24 that say "sit tight"; which one of them?

25 MR. RASCO: It's the one that says

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Page 1525

1 "Exhibit A" on the front of it.

2 UNIDENTIFIED SPEAKER: Is there a Bates

3 number?

4 MR. RASCO: It was produced by the

5 trustee. The following one that has "Exhibit

6 B" has a Bates number on it, but I want to

7 talk about --

8 THE WITNESS: Okay. I have got one that

9 says Exhibit A.

10 BY MR. RASCO:

11 Q If you go to -- it's a three-page exhibit. If

12 you go to the last page of it, it begins with an email

13 from October 30th, 2009, 10:40 a.m. You're with --

14 you're in Morocco at this time, right?

15 A Yes.

16 Q And it's from you to Frank and to George; and

17 it says, on with my office and Adria.

18 A Yes.

19 Q Why were you indicating to Frank and George

20 that you were on a call with Adria if they knew -- if

21 Frank knew, at least, as you testified last week, that

22 Adria, the Bar issue, was fictitious and that Adria did

23 not really exist?

24 A I didn't want to talk to them about anything.

25 I was simply putting them off.

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1 Q Okay. Frank responds that -- FYI BSA rumor

2 control is saying you skipped town, need to straighten

3 out -- straighten this out quickly.

4 You asked him where he heard that.

5 You said -- he says, your office.

6 You say, me too.

7 MR. SCHERER: That email says BSO,

8 Broward Sheriff's Office?

9 MR. RASCO: BSO, correct.

10 BY MR. RASCO:

11 Q And then Frank asks you: Can you authorize

12 Deb to give me balances so we know what we are dealing

13 with. I don't want George to suffer under the illusion

14 that he has negotiating capacity when he has none?

15 A Yes.

16 Q He's asking you for trust balances, correct?

17 A I believe he was asking me to see how much

18 money we really had so he could decide whether or not

19 George could bail this thing out or not.

20 Q So you -- so Frank on October 30th, doesn't

21 know what the trust balances are, correct?

22 A What they really are?

23 Q Yes. Does he know that they don't exist?

24 A He knows they don't exist, but there is no way

25 for him to know -- he knows I am taking in money from a

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Page 1527

1 ton of other investors at this point in time. He

2 doesn't know every deal. He doesn't know what I am

3 spending, you know. You're mixing apples and oranges.

4 Q So you're saying that he thinks that there is

5 some money in the trusts accounts, or you think he

6 doesn't think there is any money in the trust accounts?

7 A I'm telling you he doesn't know what's in the

8 trust accounts. If you read the email carefully, he

9 wants to balances, because he doesn't want George to

10 suffer under the illusion that he has negotiating

11 capacity where he has none.

12 He wants to see how much money is left in

13 there so he can tell George how to proceed.

14 Q Okay.

15 A It has nothing to do with his level of

16 knowledge about anything else.

17 Q Okay. And he -- and he asked for

18 authorization for Deb to give him the balances, and you

19 indicate in the following email that you did give that

20 authorization?

21 A Yes.

22 Q And then he indicates that Deb is saying she

23 doesn't have access, and then he asks about Irene.

24 You say, "Let me try."

25 And then he responds on October 30th, 2009:

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Page 1528

1 "Scott, as a friend, can you just tell me what we are

2 facing? We understand it's a mess and a deep hole, but

3 I need a little more substance so I can figure out how

4 long it will take to make anyone whole -- everyone

5 whole. I am asking for your help so we can help

6 everyone else and thus mitigate everyone else's pain,

7 including your own, and your family's."

8 Do you agree that it would have been -- it was

9 Frank's intention at that point to make everybody whole?

10 A At that point in time?

11 Q Yes.

12 A Yes. I think he wanted to do the same thing

13 that I ultimately hoped we could do at various points in

14 time, and that is, pay everybody back so that they got

15 all their principal back.

16 Q Okay. And your response --

17 A When a Ponzi scheme explodes, that's what

18 everybody wants to do.

19 Q Okay. So you both wanted to make everybody

20 whole?

21 A Yes.

22 Q And then you responded to him on October 31st,

23 "Much of my issue does not involve you."

24 Do you see that?

25 A Yes.

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Page 1529

1 Q What does that mean?

2 A I have no idea.

3 Q You're not sure what that means?

4 A I think it was more to the effect that

5 there -- I really don't know. As I'm sitting here, for

6 the life of me, I can't even tell you. It sounds like

7 me just babbling on.

8 Q Okay. So you're not -- I mean, you're not

9 saying here that Frank was not involved with you, that

10 your issue doesn't -- this issue doesn't involve you?

11 A No. I'm saying that my issue, whatever my

12 issue was -- maybe the fact that I'm going to kill

13 myself, maybe the fact that I ran, maybe the fact that I

14 destroyed my family, it could have been anything at that

15 moment in time -- again, without being inside my head,

16 you can't understand what was going on at that time with

17 me.

18 Q So you're not sure what this email means:

19 "much of my issue does not involve you"?

20 A At this moment, I don't recollect.

21 Q Okay. The follow-up email from Frank,

22 October 31st, "We really need Irene to cooperate before

23 this thing goes public on Monday. We understand that

24 the shortage is now 300 million, which is still

25 manageable if we have your cooperation. Let me know."

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Page 1530

1 Do you know what Frank means there?

2 A Okay. Well, it's clear to me that he knows

3 that -- I mean, he's referring back to the fact that we

4 have this massive fraud going on. Because at this point

5 this time, he thinks that this money is supposed to be

6 there. As you will note, he never sends me a single

7 email saying, what do you mean there's a problem? There

8 was all this money, a billion dollars or so in all these

9 trust accounts, where is it?

10 All he's trying to do is figure out, at this

11 point in time, how much money I had left in the account,

12 if any; because he wants to try to bail us all out. I

13 mean, that is what he's trying to do.

14 But if you look -- if you read this email

15 chain and then think about what someone who didn't --

16 who wasn't in on it would have written to me at this

17 point in time, you'll see that they're night and day.

18 You're talking about a broad spectrum of potential

19 answers.

20 ALL PRESENT: Objection.

21 BY MR. RASCO:

22 Q Okay. Do you know what he means by "the

23 shortage is still manageable"?

24 A Yes.

25 Q What does it mean?

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Page 1531

1 A I believe he thought that George could come up

2 with the money to bail these people out.

3 Q And how would George be able to come up with

4 the money?

5 A George was -- to this day, I still couldn't

6 tell you how much money George really had. There were

7 points in time where I thought he was a billionaire;

8 there were points in time when I thought he was totally

9 cashed out and only had access to properties.

10 But it was my impression, at least from what

11 Frank had told me and what George had told me and what

12 Sue Levin had, in fact, told me, was that George had

13 more than enough property and the like that he could

14 have leveraged and made these people whole. At least

15 that's what I was thinking at the time.

16 Q So you're suggesting that George would -- was

17 willing, or that Frank thought George was willing to

18 sell off other unrelated assets, you know, unrelated to

19 this investment strategy, to manage that shortage?

20 A It could have been any myriad of things. I

21 don't want to guess what the thought process on it --

22 Q Do you know if Frank was under the impression

23 that there was over $300 million in the trust account at

24 this time?

25 A I have no idea. There should have been a lot

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Page 1532

1 more than that in the trust accounts.

2 I don't know.

3 Q Do you --

4 A You know, George at that point in time, may

5 have believed -- again, and this goes to me really not

6 knowing the extent of George's involvement or lack of

7 involvement -- George certainly may have believed at

8 that point in time that there was plenty of money in the

9 trust accounts. I don't know how much Frank was telling

10 him. So, again, I can't guess for you as to what they

11 were saying --

12 Q Do you --

13 A -- I can only tell you what my impression was

14 when I read it.

15 Q Okay. So certainly George had the impression

16 that there was more than that amount?

17 A When you say "certainly," again, you're asking

18 me to get inside their heads. I can only tell you -- I

19 am actually telling you now what I am thinking right at

20 this minute: At that point in time, I am certain that I

21 thought that George was just going to sell off whatever

22 it was; because I knew there was no money in the trust

23 account, so what else would I think?

24 Q But you thought that George thought there was

25 money in the trust account at this time, right?

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Page 1533

1 A I --

2 Q I mean, weren't there other sources of

3 verification that would have led George to believe that:

4 the screen shots, the independent verification from

5 Szafranski, the bank visits?

6 A I have reason to believe that George believed

7 there was still a substantial amount of money in the

8 trust accounts. I do not know how much Frank was

9 sharing with him.

10 Q Okay. Do you have the same belief as to

11 Frank? In other words, do you think, based on this

12 email or your recollection, that Frank thought there was

13 more than $300 million in the trust accounts?

14 A As I sit here today, hindsight being 20/20, I

15 don't see how he would have possibly thought that; but I

16 certainly see, in retrospect, as this was all going on,

17 given the fact that he knew that I was getting

18 substantial amounts of money from other investors that

19 he was unaware of -- Sochet, Szafranski; he had no idea

20 how much money I was taking in -- he certainly could

21 have believed that there was billions of dollars still

22 floating around somewhere or that I had taken a billion

23 dollars with me.

24 He -- I don't know what was in his head.

25 You're asking me to guess over and over again, and I

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Page 1534

1 don't want to do that.

2 Q So you respond: "That is not the shortage.

3 That is the amount of money needed to give the investors

4 back their money. I really just need to end it, Frank.

5 It will make it easier for -- for everyone."

6 Then Frank responds: "Let's do the right

7 thing for everyone involved; and your, quote, unquote,

8 ending it, doesn't sound like the solution that is going

9 to do it. Let's talk this through."

10 When you said "ending it" in that email, were

11 you talking about ending your life or ending your Ponzi

12 scheme?

13 A Ending my life.

14 Q Afterwards, you respond to Frank saying:

15 "Tell me what to do? I am at the end of my rope. Do I

16 surrender? Do I end it? Do you need me to do something

17 before I end it?"

18 Did you -- were you honestly asking for

19 Frank's advice in that email?

20 A Yes.

21 Q Okay. Did you consider Frank a friend?

22 A I did.

23 Q And Frank's response to that email is: "I ran

24 once, but people smarter than me talked sense into me by

25 pointing that my absence would destroy the ones that I

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Page 1535

1 loved and was trying to protect. By returning I had to

2 face the shame of my actions, the vengeance of my

3 enemies and the nastiness of our criminal justice

4 system; but I also incurred renewed spirit by the love

5 of my family and the support of my friends. Yes, you

6 will still have many who will support and love you. I

7 will call in ten minutes."

8 Do you recall that email?

9 A I do.

10 Q What did that email mean to you?

11 A It was a sincere email telling me that I

12 should turn myself in.

13 Q And you didn't -- you didn't doubt Frank's

14 friendship?

15 A At that moment?

16 Q At that moment, correct.

17 A No.

18 Q Okay. You mentioned earlier that there was a

19 meeting that you had with Frank in your office where he

20 saw some unredacted settlement documents.

21 A That's correct.

22 Q Do you know -- well, first of all, did Frank

23 have an office in your office?

24 A Did Frank have a what?

25 Q Did Frank have an office in your -- in RRA?

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Page 1536

1 A No, sir.

2 Q Did Frank ever have an office at RRA?

3 A No, sir.

4 Q Okay. And you testified recently that

5 Frank -- you would see Frank almost daily. I believe

6 that was on Friday you indicated something to that

7 effect.

8 A Yeah. There were points in time where I saw

9 Frank everyday, whether we met for drinks or he came to

10 my office or I went to his office or we were going out,

11 yes.

12 Q Okay. And do you recall how many times he

13 went to your office?

14 A Dozens.

15 Q Dozens?

16 A Dozens.

17 Q Can you be more specific than that, or you

18 don't recall?

19 A I can't recall.

20 MR. RASCO: Can we take ten minutes? We

21 have been going for quite a while.

22 MR. LAVECCHIO: Actually, instead of ten

23 minutes, why don't we take a lunch break.

24 MR. RASCO: That's fine.


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Page 1537

1 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 19th day of December, 2011.

10

11 ______________________________

12 Michele L. Savoy, RPR Notary Public - State of Florida

13 My Commission No. EE 113173 Expires August 6, 2015

14

15

16

17

18

19

20

21

22

23

24

25

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Page 1538

1 C E R T I F I C A T E

2 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 1388 to 1538,

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 19th day of December, 2011.

20

21

22 ___________________________________

23 Michele L. Savoy, RPR Notary Public - State of Florida

24 My Commission No. EE 113173 Expires August 6, 2015

25

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