2011-12-16 Rothstein Scott AM

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(954) 525- 2221United 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 5 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN

DATE TAKEN: December 16, 2011 TIME: 8:36 a.m. - 10:54 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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Page 1128

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, ESQUIREAPPEARANCES FOR THE TRUSTEE:

5 BERGER SINGERMAN 350 East Las Olas Boulevard

6 Suite 1000 Fort Lauderdale, Florida 33301

7 BY: CHARLES H. LICHTMAN,, ESQUIREAPPEARANCES FOR THE TRUSTEE:

8 GENOVESE, JOBLOVE & BATTISTA, P.A. 100 S.E. 2nd Street

9 Suite 4400 Miami, Florida 33131

10 By: JOHN. H. GENOVESE, ESQUIRE DAVID C. CIMO, ESQUIRE

11 THERESA M.B. VAN VLIET, ESQUIREAPPEARANCES FOR RAZORBACK:

12 CONRAD & SCHERER, LLP 633 South Federal Highway

13 Eighth Floor Fort Lauderdale, Florida 33302

14 By: WILLIAM R. SCHERER, ESQUIRE REID A. COCALIS, ESQUIRE

15 IVAN J. KOPAS, ESQUIREAPPEARANCES FOR RAZORBACK:

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

17 Ninth Floor Coral Gables, Florida 33134

18 By: ADAM MOSKOWITZ, ESQUIRE

19ON BEHALF OF PLATINUM PARTNERS VALUE ARBITRAGE

20 Centurion Structured Growth, LLC

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

22 Two South Biscayne Boulevard Miami, Florida 33131

23 By: SUSAN E. TRENCH, ESQUIRE

24

25

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1 APPEARANCES FOR LEVINSON'S JEWELERS: KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL

2 200 SW 1st Ave Suite 1200

3 Fort Lauderdale, Florida 333012073 BY: JAN ATLAS, ESQUIRE

4 APPEARANCES FOR THE COMMITTEE OF UNSECURED: AKERMAN, SENTERFITT

5 One Southeast Third Avenue 25th Floor

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

7

8 APPEARANCES FOR T.D. BANK:

9 GREENBERG TRAURIG, P.A. 401 E Las Olas Blvd Ste 2000

10 Fort Lauderdale, Florida 33301 By: DONNA EVANS, ESQUIRE

11APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

12 COLUMBIA INC. & ZURICH INSURANCE:

13 CLAUSIN MILLER One Chase Manhattan Plaza

14 39th Floor New York, New York 10005

15 BY: SCOTT L. SCHMOOKLER, ESQUIRE

16 APPEARANCES FOR FEDERAL INSURANCE COMPANY:

17 ALEX HOFRICHTER, P.A 1430 South Dixie Highway

18 Suite 204 Coral Gables, Florida 331463127

19 By: ALEX HOFRICHTER, ESQUIRE

20 APPEARANCES FOR MORSE:

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

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

23 JOHN M. MULLIN, ESQUIRE

24

25

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1 APPEARANCES FOR EMESS CAPITAL, LLC:

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

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

4 APPEARANCES FOR ST. PAUL FIRE & MARINE:

5 MILLS PASKERT DIVERS P.A. 100 N Tampa St Ste 2010

6 Tampa, Florida 336025145 JOHN A. BLACK, JR., ESQUIRE

7 APPEARANCES FOR THE DEFENDANT:

8 ROSEANNE CARETSKY

9 Billing Cochran Lyles 515 E Las Olas Blvd

10 Floor Six Fort Lauderdale, Florida 333012296

11 By: W. TUCKER CRAIG, ESQUIRE

12 APPEARANCES FOR THE DEFENDANT: FRANK SPINOSA

13 SCHLESINGER AND COTZEN, P.L.

14 799 Brickell Plz Ste 700 Miami, Florida 33131

15 BY: MICHAEL J. SCHLESINGER, ESQUIRE

16

17

18

19

20

21

22

23

24

25

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1 INDEX

2 CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

3 DIRECT FURTHER DIRECT

4 Mr. Scherer 1133Mr. Lichtman 1222

5 Mr. Rabin 1224

6 CERTIFICATE OF OATH 1250CETIFICATE OF REPORTER 1251

7

8 PLAINTIFF'S EXHIBITS INDEX

9 NO. DESCRIPTION PAGE NO168 Metadata and Email Trail 1147

10 169 Emails and Deal Documents 1159170 Exhibit to the Complaint 1168

11 171 Multiple Emails 1217

12 DEFENDANT'S EXHIBITS INDEXNO. DESCRIPTION PAGE NO

13 172 October 31, 2009, Email 1236

14

15

16

17

18

19

20

21

22

23

24

25

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1 Thereupon, the following proceedings were had:

2 FURTHER DIRECT EXAMINATION

3 BY MR. SCHERER:

4 Q Good morning, Mr. Rothstein.

5 A Good morning.

6 Q I'm continuing on with my direct examination.

7 We bring it up here because of the way we have tried to

8 divide our time. I have got some time this morning, and

9 I'm going to try to be efficient. It's going to be sort

10 of in the nature of a redirect, a little bit, because I

11 don't know --

12 A Okay.

13 Q -- I don't know if I have any time to redirect

14 next week, and that is also just a little bit of direct

15 examination.

16 If you don't mind -- well, we might as well go

17 through the drill: You know you're still under oath?

18 A I do.

19 Q All right. And I would like this to kind of

20 be a lightning round. I would like you to keep your

21 answers as brief as possible, consistent with you

22 telling the truth, of course.

23 A Okay.

24 Q Obviously, if you want to explain, you can

25 explain, but these questions are kind of like follow-up

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Page 1134

1 questions. I'm going to try not to re-cover things that

2 have been covered before or multiple times before.

3 A Okay.

4 Q You know, I don't know if you have a TV where

5 you are. Do they let you watch FOX news, you know, how

6 they do the lightning round?

7 A I actually have a group of dancers in there --

8 please don't put that on the record.

9 Q I was going to say, if you watch FOX news --

10 Lichtman doesn't watch it, so he wouldn't know what I'm

11 talking about, but I am going to get you the question

12 and you get the answer back so we get a lot of

13 information out. Okay?

14 A I have got that. I watch one of the sports

15 channels, so I'm good to go.

16 Q Unlike MSNBC where Lichtman watches, they kind

17 of go a little slow and move along.

18 MR. KOPAS: They get caught up on the

19 truth there.

20 BY MR. SCHERER:

21 Q By the way, from time to time, you know, we

22 have kidded around, like right now, and it looks like

23 each and every time --

24 MR. LICHTMAN: You weren't serious?

25 MR. SCHERER: Right.

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1 BY MR. SCHERER:

2 Q Each and every time, you appear to have

3 laughed, and did you take offense at any of the little

4 small chit-chat that has gone on here?

5 A Not at all.

6 Q Okay. And did any of it in any way interfere

7 with you telling it the way you remember it?

8 A Not at all, Mr. Scherer.

9 Q All right. Thanks.

10 So, and it hasn't affected your testimony in

11 any way, I don't think?

12 A Not in the least, not at all.

13 Q You were questioned by Ms. Morse's counsel

14 about my motion to get the court -- a bankruptcy court

15 to pay Mr. Nurik for his work in this deposition as a

16 court cost.

17 Do you remember her questions -- I started to

18 say her testimony -- but her questioning you about that?

19 A Yes, sir.

20 MR. NURIK: It was almost testimonial.

21 BY MR. SCHERER:

22 Q Is the fact that I filed that, is that

23 influencing your testimony here --

24 A Not at all.

25 Q -- in favor of my clients?

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1 A Not at all.

2 Q Why not?

3 A Because I'm not bargaining my life with

4 anything. Okay? I have a -- promised the government I

5 would be here. I promised the government I would tell

6 the truth. I promised the government I would not hide

7 anything and I have not been promised anything in

8 exchange for that, at all.

9 Q So you wouldn't risk a Rule 35 situation that

10 may be in the cards for you by trying to help my clients

11 recover?

12 A No, not -- not at all. There is no reason to.

13 The people that did bad things, did bad things, and

14 that's what they did.

15 Q One last thing on getting Mr. Nurik paid, if

16 that ultimately happens -- and I asked you this, but I

17 would like to reiterate it again -- by the way,

18 Mr. Nurik has been with you from the beginning, as I

19 recall?

20 A From before my return from Morocco, yes.

21 Q And he had something to do with you coming

22 back, I think?

23 A Yes.

24 Q I mean, you obviously made the decision, but

25 he helped you --

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1 A But he was --

2 Q -- make that?

3 A He was instrumental in counselling me and

4 guiding me through a very, very tough period of time.

5 Q And he has continued to be with you when you

6 have been questioned and when you have been involved in

7 this process for the last two years?

8 A Yes.

9 Q Knows a lot about the case?

10 A Yes.

11 Q You talk to him frequently?

12 A Yes.

13 Q If he wasn't here, would you be testifying?

14 A No, sir.

15 Q Thanks.

16 MR. SCHLESINGER: Just note my objection

17 to that question. Mr. Rothstein already

18 testified with Mr. Nurik not here.

19 BY MR. SCHERER:

20 Q Well, there was a time yesterday when

21 Mr. Nurik was in court on another matter, and you did

22 testify for the Trustee's questions for a few hours,

23 correct?

24 A That's correct.

25 Q Would you have given a -- this deposition to

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1 me, and to the other people here who want to know your

2 story, if Mr. Nurik was not available?

3 A I have known some of the lawyers in this room

4 for two decades, okay, but I don't care about how long

5 I've known them; the only reason I testified for

6 Mr. Lichtman, answering his questions when Mr. Nurik was

7 not here, is that I had already spent three full days

8 with him at another undisclosed location, okay, being

9 debriefed pursuant to court order; and I was extremely

10 comfortable that they were not going to attempt to take

11 advantage of me during that time period, that they were

12 going to be fair.

13 I don't know everybody who is going to be

14 questioning me. I don't know what anyone's actual

15 intention is. I'm not going to answer questions of

16 other people, unless Mr. Nurik is with me, just to

17 protect myself -- not even you, Mr. Scherer, and I have

18 known you a long time.

19 Q All right, sir. Thank you.

20 We're going to take your testimony here then.

21 Thanks.

22 I would like to have you focus a little bit on

23 the order that -- the fake order, as we have called

24 it -- and you have talked about it, and you testified

25 about it -- that was entered that you -- you forged

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Page 1139

1 Judge Marra's signature on this order that you concocted

2 or drafted.

3 A Okay. The Marra order, yes.

4 Q The Marra order.

5 And in that order, essentially, you ruled that

6 the Morses are entitled to $23 million, I think:

7 21 million, punitive damages, and a million dollars,

8 compensatory; or maybe 2 million compensatory and

9 21 million punitive?

10 A I believe that's correct, sir, yes.

11 Q And you also discussed that there was

12 $10 million that you had -- your firm had found through

13 investigators in various bank accounts for Jan Jones in

14 the United States, in South Florida; is that right?

15 A That sounds correct, yes.

16 Q And $20 million in the Cayman Islands, I

17 think, was in that order?

18 A There was money referenced about us finding

19 money in the Cayman Islands, yes, sir.

20 Q And was there a -- did you have any telephone

21 call hearings, fake telephone call hearings with --

22 allegedly with Judge Marra leading up to the entry of

23 that order?

24 A Yes, sir.

25 MR. MULLINS: Can I just raise -- I don't

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1 want to interrupt you too often, Mr. Scherer;

2 but I just want to make sure that I am

3 asserting a standing, continuing objection to

4 questions that you're asking about the Morses,

5 about Ted Morse.

6 You do not have a pending case that has

7 been noticed in this deposition in which you

8 have a protocol order allowing to you take

9 that deposition; and the fact that I asked

10 questions of the depo that I properly got

11 permission for, I don't think gives you an

12 opportunity to redirect on the Morses.

13 So, I don't want to interrupt you all

14 day, but I want it to be clear that we have a

15 continuing objection to this line of

16 questioning; and we're going to move to strike

17 it, and we're going to certainly oppose it

18 being used in any new case that you have not

19 been given permission to question the witness

20 on.

21 MR. SCHERER: Thank you.

22 BY MR. SCHERER:

23 Q I believe counsel for Morse testified --

24 examined you yesterday about that -- about that Judge

25 Marra order.

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1 You remember that?

2 A Yes, two different attorneys did. Yes.

3 Q I don't think they asked you about whether or

4 not there were any fake hearings, telephone hearings,

5 that preceded the entry of that fake order that -- the

6 drafting of that fake order.

7 MR. MULLINS: Object to the form.

8 A I don't know that they asked me, but somebody

9 questioning me yesterday at the hearings did come up,

10 briefly, at some point in time. At some point in time

11 it did.

12 BY MR. SCHERER:

13 Q And the hearings where they -- tell us about

14 the hearings.

15 A Okay. At various points in time during the --

16 what's called the "fake proceedings," leading up to and

17 probably subsequent to those orders, there were multiple

18 telephone hearings where Ed Morse, Ted Morse, myself,

19 and someone playing the Judge Marra was on the telephone

20 pretending to conduct a hearing, actually questioning

21 Mr. Ed Morse with Mr. Ted Morse on the phone, with me on

22 the phone, me actually making argument, and the fake

23 Judge Marra actually ruling.

24 Q And who was -- was there an actual person that

25 played like Judge Marra?

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1 A Yes, sir.

2 Q And who was that?

3 A An attorney with my firm, Scott Goldstein.

4 Q And did anybody on the phone on the Morse side

5 know that Mr. Goldstein was acting, pretending to be

6 Judge Marra?

7 A Yes.


9 BY MR. SCHERER:

10 Q And who was that?

11 MR. SCHERER: Well, excuse me, what's the

12 objectionable about that?

13 MR. MULLINS: You're asking him what

14 other people knew. You're calling for

15 speculation.

16 BY MR. SCHERER:

17 Q Okay. Do you have any information that

18 anybody on the phone -- I mean, obviously Mr. Goldstein

19 knew he wasn't Judge Marra, right?

20 A Yes.

21 Q Okay. And you knew it was a fake hearing,

22 right?

23 A Yes.

24 Q You set it up?

25 A I did.

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1 Q And you said Ted Morse was on each of those

2 calls?

3 A He was.

4 Q And do you know whether Ted knew that it was a

5 fake hearing?

6 A I do know.

7 Q All right. And how do you know that?

8 A Okay. Ted knew it was fake for several

9 reasons. One, I told him what was going to go on.

10 Number two -- and I had a specific reason for

11 telling him what was going on, because Ted -- anyone who

12 does business with Ted knows, he is a bulldog. When he

13 really needs information about something, thinks

14 something is going sideways that could affect him or his

15 family, he is a bulldog, and I needed to make sure he

16 laid back.

17 The second thing was -- and more than one

18 person saw this -- Ted knew Scott Goldstein. He had

19 spoken to him many times before. Scott used to come

20 down from time to time and sit outside with us outside

21 Bova and smoke cigars with us.

22 On more than several occasions, as Scott

23 Goldstein was approaching us, Ted would take his cigar

24 out of his mouth and say, oh, here comes the judge now.

25 Here comes Judge Goldstein -- I mean, Judge Marra.

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1 Q I would like to talk to you about the 11th

2 Circuit Court of Appeals order, fraudulent, that was

3 entered and drafted by you; and there seemed to be some

4 confusion yesterday about that, about that order.

5 A Mr. Scherer, one other important point on the

6 fake hearings --

7 Q Sure. Do you have another important point on

8 the fake hearing?

9 A I do.

10 Q Okay. I would like to hear it. What is it?

11 MR. MULLINS: Objection to form.

12 BY MR. SCHERER:

13 Q Wait a minute. He's objected to form. Let me

14 start off again.

15 Did we cover everything that was important on

16 the fake hearings or on Judge Marra?

17 A No. There was another hearing or two where

18 Mr. Goldstein also pretended to be a circuit court judge

19 in the actual case filed in circuit court on behalf of

20 the Morses. I just wanted to make sure the record is

21 clear.

22 Q And I think you might have said, and I may

23 have missed it, that there were some other people that

24 were aware of this fake hearing, phone hearing, other

25 than the people that we mentioned?

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1 A Well, the people who were sitting around with

2 us at the time, I'm sure, would have heard Ted saying

3 that, because he wasn't bashful about it.

4 Q Do you have any recollection of any people

5 that were around you that may have overheard that?

6 A No. I have to think about who was actually

7 there during that time period. It would have been our

8 regular group of friends that I mentioned earlier.

9 Q Okay. Do you recall how many of these fake

10 telephone hearings were conducted?

11 A I would say between four and seven, eight,

12 something to that effect.

13 Q And would they have all been before the date

14 of the Marra order?

15 A Most likely, but I can't be certain that we

16 didn't have some afterwards. I know the circuit court

17 one was before the Marra order because it was before I

18 allegedly have the case elevated to federal court.

19 Q And then you had the case elevated to the

20 court of appeal, and there was some testimony about that

21 yesterday?

22 A Yes, sir.

23 Q There seemed to be a little bit of confusion

24 about when that fake Judge Black order was prepared. Do

25 you recall the confusion?

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1 A Yes.

2 Q As I understand -- and it's in the document

3 there -- that the document bore a date of August

4 something?

5 A Correct.

6 Q And there was some email forwarding it to the

7 Morses in October?

8 A Correct.

9 Q And you said you didn't know exactly when you

10 did that order, couldn't remember?

11 A I don't, without seeing the email traffic and

12 the metadata, I have no way of remembering that.

13 Q Let's see if we can't show you the metadata.

14 Well, let me ask this: Would it refresh your

15 recollection to remind you that perhaps you drafted that

16 order on the eighth of September, the same day you did

17 the Seltzer order?

18 MR. MULLINS: Objection, form.

19 A That certainly is possible.

20 BY MR. SCHERER:

21 Q I mean, were you in the fake-order-drafting

22 mode on the 8th, correct?

23 MR. MULLINS: Objection.

24 A Yes, I was.

25

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1 BY MR. SCHERER:

2 Q According your testimony, you were drawing the

3 Seltzer order on the 8th?

4 A Correct.

5 Q Okay. And there is quite a bit in the record

6 on that already.

7 Let me show you the -- what the metadata looks

8 like, and we'll mark that as our next --

9 MR. KOPAS: Plaintiff's 168 is the

10 printout of the metadata from the fake 11th

11 Circuit court order. There is no Bates

12 stamped number on that. It's a composite

13 exhibit, also with an email trail from

14 September 8th, 2009, Bates labeled Rothstein

15 1180 to 1182.

16 And I have copies for counsel.

17 (Thereupon, the document was marked as

18 Plaintiff's Exhibit No. 168 for Identification.)

19 BY MR. SCHERER:

20 Q Have you ever seen what the metadata looks

21 like from your computer before?

22 A No. The only time I saw it was the other day

23 in here when somebody showed me some.

24 Q Yeah. Okay.

25 You can see the document that's got the 11th

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1 Circuit order data on it, and you have got the related

2 dates, and it shows when it was last modified, when it

3 was created, last printed.

4 Do you see that?

5 A I do.

6 Q And go ahead and tell us when was it created

7 and when was it modified and when it was printed?

8 A It was created at 8:21 a.m. on September 8th,

9 2009. It was modified on September 8th, 2009, and 10:13

10 a.m.; and it was last printed on September 18, 2009 at

11 10:13 a.m., right after the modification, apparently.

12 Q Okay. And the -- do you know when -- can you

13 recall when Ted Morse came into your office that

14 morning?

15 A Yeah, it was around 10:00 or so. Ted was

16 always on time for everything, so I -- someone sent me

17 an email saying he's here.

18 Q Yeah, there was an email that said Ted's here.

19 I think we put that in the record, at 10:00.

20 Do you have a recollection of whether Ted --

21 whether you shared the Judge Black recently-created

22 order with Ted when he was in your office?

23 It looks like you printed it after he was

24 there, 10:13; he arrived at 10:00.

25 A My recollection, Mr. Scherer, is that I gave

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1 it to him while we were sitting in my office just to

2 read.

3 Q Now, there was a little questioning -- there

4 was some questioning yesterday concerning when you

5 started drawing the Judge Seltzer order and the exact

6 order of what you did that day.

7 A Yes.

8 Q But let me -- before I ask that, was this

9 Judge Black court of appeals, 11th Circuit Court of

10 Appeals order that you forged on the 8th, the same day

11 that you forged the Seltzer order in response to Carol's

12 email, Carol Morse's email to you of a couple of days

13 before, that asked for the orders in a threatening tone?

14 A Yes.


16 BY MR. SCHERER:

17 Q What was this order -- why was this court of

18 appeals order done on the 8th of September?

19 A Because I was in a panic over Carol creeping

20 around, looking to try to figure out what I was actually

21 doing.

22 Q Yeah, and I think you testified, but I'll ask

23 you again, you received that email from her, and you got

24 the impression that she don't draw -- write that thing

25 by herself, correct?

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1 A That's correct. I already knew that she had

2 been talking to her sister-in-law extensively about

3 this. So it was clear to me that someone else had

4 involvement, and it appeared to me to be a lawyer.

5 Q Well, it was kind of drafted like a lawyer

6 would draft an order?

7 A It had language in it that I hadn't

8 particularly seen in Mrs. Morse's prior emails.

9 Q From her behavior from that point, on, did you

10 have the belief, at that time, that she had a legal

11 counsel that was advising her?

12 A I did.

13 MR. MULLINS: Objection. Asked and

14 answered.

15 BY MR. SCHERER:

16 Q Okay. Did you ever discuss that with Ted

17 during that period of time from September the 6th, when

18 you received her threatening email, to the crash at the

19 end of October, that you thought Carol might have a

20 lawyer?

21 A Yes.

22 Q And would you describe your concern about her

23 having a lawyer?

24 A Yes. I told -- I called Ted immediately after

25 getting the email. I asked him -- I'll save you the

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1 language. I asked him what the "F" was going on. I

2 said, she is all over me. We need to do something to

3 stop this. You need to talk to your dad. You need to

4 quell the situation. I can't function like this. She's

5 going to blow this whole thing up, and we're all going

6 down over it.

7 Q So would that have been one of those mutual

8 destruction talks that you talked about here in the

9 last --

10 A DOMAD. Yes. Ted knew what that was, the

11 doctrine of mutually assured destruction.

12 Q DOMAD. All right.

13 So, you had one of those kind of talks with

14 Ted?

15 A Yes.

16 Q Do you recall telling Ted that you thought she

17 had a lawyer?

18 A Yes.

19 Q Okay. Did you ask him who that lawyer might

20 be?

21 A No. He told me -- he said she probably does.

22 He kept telling me, she's driving my father crazy. She

23 is going to end up killing him. This whole thing is

24 getting out of hand. I'll see what I can do. She's

25 getting out of control. Even Ed can't control her

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Page 1152

1 anymore.

2 Q Well, did you have any discussions with Ted

3 about what it would take to prevent Carol and her lawyer

4 from blowing the whistle on your Ponzi scheme? Was

5 there any discussion about that?

6 MR. LAVECCHIO: I have to assert an

7 objection -- Larry LaVecchio on behalf of the

8 government. I have to assert a government

9 investigator privilege at this point.

10 MR. SCHERER: All right. Okay.

11 Let me see if I can -- I'll honor the

12 privilege, certainly, but let me see if I can

13 get around it a little bit.

14 MR. LAVECCHIO: It's a

15 question-by-question issue.

16 MR. SCHERER: Yes, sir. I understand how

17 it works. It's not my first rodeo.

18 BY MR. SCHERER:

19 Q Mr. Rothstein?

20 A Yes, sir.

21 Q If Carol Morse had blown the whistle on you at

22 that point, do you think the Ponzi scheme could have

23 continued?


25 A Absolutely not.

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Page 1153

1 BY MR. SCHERER:

2 Q And why do you say that?

3 A Because she was one of the lynch pins based

4 upon the fake court orders, the sheer amount of money

5 that I had stolen from Ed and Carol, the amount of

6 focused fraud I had levied in their direction, it just

7 would have -- the whole entire thing would have come

8 tumbling down; and I knew it and so did Ted.

9 Q Well, obviously it didn't come tumbling down

10 until the end of October, correct?

11 A Correct.

12 Q My clients put maybe $100 million into the

13 Ponzi scheme between September 6th and the end of

14 October.


16 Q And --

17 A They did.

18 Q And the financial records show -- well, let me

19 ask this: Do you know how much the Morses received --

20 the Morse operation and Ed and Carol on the phony bond

21 repayment during that last two months or so before the

22 crash of the Ponzi.

23 A I believe I gave them just shy of half their

24 money back, $25 million.

25 Q That's okay. That's right.

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Page 1154

1 And they had an expectation of the phony

2 bond -- of the phony judgment recovery, plus the

3 interest on the bonds, plus some profit on the deals, of

4 about another 25 to 30 million; is that your

5 recollection?

6 A Correct. Yes, sir.

7 MR. MULLINS: Objection, form.

8 BY MR. SCHERER:

9 Q What is your recollection of what their

10 expectation was in addition to getting their money back?


12 A Ed and Carol had an expectation, as did Ted,

13 that I would repay all of the bond money back; and Ted

14 expected me to be able to not only repay the bond money

15 back, but to repay all the deals with interest.

16 BY MR. SCHERER:

17 Q Okay.

18 A And because of my relationship with Ted, I

19 will tell you that it was absolutely my goal at that

20 point in time to do everything I could to make sure

21 that, at the least, Ed and Carol were made completely

22 whole and hopefully I would be able to get Ted all his

23 interest.

24 Q Well, then he had a $23 million phony

25 judgment. Was it your intention to pay him that, if you

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Page 1155

1 had the money?

2 A Absolutely.

3 Q So that his expectation would have been some

4 25 to 30 million more from September to the end of

5 October?


7 A At that stage of the Ponzi scheme, in order to

8 keep it from blowing up, I would have had to continue to

9 make all the payments to everybody.

10 As you know, from reviewing the history, as it

11 got closer and closer to blowing up, I focused the

12 payments towards the people that I wanted to make sure

13 were made whole.

14 BY MR. SCHERER:

15 Q And were the Morses in that group of people

16 you wanted to make whole?

17 A They were at the top of the list.

18 Q And Mr. Von Allmen, my client was at the

19 bottom?

20 A That's correct, Mr. Scherer.

21 Q Any reason that he was at the bottom?

22 A He was not anywhere near my best friend. He

23 was to me, an acquaintance, who was certainly becoming a

24 friend; but he was an acquaintance, and I viewed him as

25 someone who was extremely wealthy who could withstand

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Page 1156

1 the loss.

2 Q I would ask during that time frame, from

3 September the 6th, when Carol Morse wrote you that

4 disturbing email, until the crash, did she continue to

5 press you for repayment?

6 A You know, I don't have an independent

7 recollection. You'd have to show me emails. I mean,

8 every -- during that period of time, I can tell you I

9 was getting continuing pressure from the Morses to get

10 as much money to them as possible.

11 Q And you were doing that?

12 A I was. I believe I was sending them money

13 right up to the last minute.

14 Q So, their silence in not blowing the whistle

15 on the Ponzi scheme benefited them in the money that

16 they got back between September the 6th and the end

17 of -- and the crash, correct?

18 MR. MULLINS: Objection to form.

19 A Of course it did.

20 MR. SCHERER: What's wrong with the form?

21 MR. MULLINS: You're assuming that the

22 Morses all knew about the Ponzi scheme and

23 kept silent about it. Assumes facts not in

24 evidence.

25 BY MR. SCHERER:

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Page 1157

1 Q Well, did the Morses know about the Ponzi

2 scheme?

3 A Ted did, and Carol certainly suspected it -- I

4 don't know that she suspected it was a Ponzi scheme, but

5 she certainly suspected that I was stealing her money

6 and committing fraud.

7 Q And, so, rather than blow the whistle on what

8 she suspected, what did she do?

9 A She continued to receive money from me.

10 Q Now, you know that my clients, Razorback and

11 D3, put approximately 50 million in the Ponzi Scheme in

12 October. Those are the dates of Razorback and D3?

13 A Right. They were at the very end of the Ponzi

14 scheme, correct.

15 Q Right. 50 million in and Mr. Sochet was

16 putting money in at the same time; do you recall that?

17 A He was, sir.

18 Q So, the 100 million that I represent that my

19 clients had invested in your Ponzi scheme from September

20 to the end of the crash, I said it was about one-hundred

21 million, plus or minus, you know, millions, I don't

22 know, but a lot of money?

23 A Yes, sir.

24 Q Was any of that money used to repay the Morses

25 back the 20 or 25 million that you paid them back

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Page 1158

1 between September 6th and the crash at the end of

2 October?

3 A Yes, sir.

4 Q Now, I asked you whether Ted Morse knew the

5 settlements were fake, and there was some discussion of

6 that; and I'm asking you again, did Ted Morse know at

7 some point in time that these settlements that you were

8 doing or your settlement business was a fraud?

9 A Yes.

10 MR. MULLINS: Objection, asked and

11 answered.

12 BY MR. SCHERER:

13 Q I'm going to show you some paperwork, I don't

14 think I did that. Do you remember when I examined you

15 about the two deals that Mr. Morse invested in, 700 cash

16 with 300 back and then 700 cash and 300 back by two of

17 the deals twice; do you remember that?

18 A Yes, I recall that.

19 Q And then you recall that when you did the

20 Ponzi paper, as I called it, the settlement paper, that

21 you didn't do two $1 million deals; you did one

22 $2 million deal.

23 Do you remember questions about that?

24 A I do, sir.

25 Q Let me show you those documents and just put

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Page 1159

1 those in the record.

2 MR. KOPAS: All right. Plaintiff's 169

3 is a composite exhibit, four emails relative

4 to four deals in March of 2008, and then deal

5 documents for what are RRA M1 and RRA M2, two

6 deals, no Bates numbers, but these actually

7 were produced before.


9 Plaintiff's Exhibit No. 169 for Identification.)

10 BY MR. SCHERER:

11 Q Mr. Rothstein, take a look at that. I think

12 those are the documents on the two $700,000 money-in

13 deals with punitive payments of -- no, they weren't

14 punitive they were actual payments of $300,000 profit?

15 A Correct.

16 Q You see that, paid in ten weeks?

17 A I do, sir.

18 Q Okay. And that's on the email traffic back

19 and forth, the email dated Tuesday, March 18th, 2008,

20 right?

21 A Yes, sir.

22 Q Now, I would like you to go -- look at the --

23 what I call the Ponzi paper there or the deal documents

24 that are attached in that composite. Do you see those?

25 That would be RRA M1; I guess that's Morse 1?

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Page 1160

1 A Yes. Morse 1 and Morse 2.

2 Q Okay. Did you combine the two of those

3 settlements into one set of papers?

4 A Yes.

5 Q And that's what these documents represent?

6 A Yes. Neither Ted, nor I, nor Debra was

7 creating -- could have cared less as to what the paper

8 looked like, as long as it passed muster with the

9 auditors.

10 Q Plus Ted knew there were no settlements and

11 this was all fake?

12 MR. MULLINS: Objection to the form.

13 A Yes. Ted asked me to create the paperwork, so

14 absolutely, yes.

15 BY MR. SCHERER:

16 Q But knowing that there was no settlement, that

17 there were no -- or accepting that there were no

18 punitive funds held in trust, you know, the whole spiel,

19 he knew it was a fraud?

20 A Of course. I mean this paperwork was created

21 after he had already started receiving his money, so it

22 must be fake.

23 Q Got it. Thank you.

24 You testified on my direct examination a few

25 days ago that Ted knew that Doug was in -- Doug Von

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Page 1161

1 Allmen was an investor and vice versa; do you remember

2 that testimony?

3 A I do.

4 Q You testified yesterday, or you were

5 questioned yesterday, about whether Ted talked to any of

6 the investors; and you said, yes, Razorback. Then

7 counsel went on to another subject.

8 Let me see if we can explore that a little

9 more.

10 A Okay.

11 Q The question is, did Ted ever talk to any of

12 the Ponzi investors, and your answer is?

13 A Yes.

14 Q And who did he speak with, that you know of,

15 regarding the Ponzi investors?

16 A Of all the Ponzi investors?

17 Q Yes?

18 A Oh, lord, okay.

19 Q Let's start with my clients first and then

20 we'll -- well, let's talk about the Razorback first,

21 because you talked about that yesterday and then didn't

22 follow up on it.

23 A Okay. Ted spoke to Doug Von Allmen. He met

24 and spoke with A.J. Discala. He spoke with Barry

25 Bekkedam. He spoke with Dean Kretschmar. He spoke with

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Page 1162

1 Mike Szafranski. He spoke with -- he didn't speak with

2 Ira Sochet. I don't think he ever met Ira -- oh, he

3 spoke with Barry Damson. That happened at Bova a couple

4 of times.

5 He met with -- he spoke with -- at various

6 points in time all of the hedge fund guys, I think,

7 except for Gil Kalter; and let me see if I can name them

8 so the record is clear for you.

9 He definitely, as I said, spoke with Mike

10 Szfranski. He definitely spoke on multiple occasions

11 with Jack Simony. He spoke with -- I don't believe he

12 spoke with Mr. Nordlicht.

13 Q Ari Glass?

14 A I don't recall him speaking with Mr. Glass.

15 He only actually did speak with Gil Kalter

16 because Gil was a voracious Miami Dolphins fan. In

17 fact, he came from New York -- and Ted is a big Dolphins

18 fan -- and I remember we were all together. It was

19 actually at one of the games that I brought Gil to.

20 Who else? There are -- two of the other

21 investors that are -- were also in the know on the

22 thing. Gary Lipsitz and Domenick Tonacchio, who were

23 early and late investors. He knew them very well.

24 Q And by knowing them, did he know they were

25 investing in the fraud? Did Ted know that the people

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Page 1163

1 that you just identified were investors in the Ponzi

2 scheme?

3 A All of the ones that I mentioned, Ted knew

4 about, yes.

5 Q Did you overhear their discussions? Did they

6 talk about the Ponzi at all or the investments or the

7 settlement investments?

8 A Okay. We never discussed the Ponzi scheme.

9 Q I understand that. That was a bad question.

10 You have already told us that a bunch, and I'll try not

11 to do that.

12 Did he talk about the structured -- the

13 settlement, confidential settlement program?

14 A Let me clarify my statement so this is not

15 misconstrued.

16 When I say we never talked about the Ponzi

17 scheme, I mean that when we are sitting around in a

18 group, like a meeting with me, Domenick and Barry, we

19 didn't say, how is the Ponzi going.

20 Q Right.

21 A Okay. We certainly, individually, frequently

22 talked about the fraud and things that were going on;

23 but that out-loud group thing, that did not occur.

24 So, your question now is?

25 Q Well, my question now is, what -- did Ted also

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Page 1164

1 talk with investors in the confidential settlement

2 program that did not know they were investing in a

3 fraud?

4 A Sure.

5 Q Like some of my clients?

6 A Sure. Ted would say to various people, I told

7 you it was -- it was one of his favorite comments:

8 Scott is -- especially during the downturn of the car

9 business: Scott is our most-profitable car dealership.

10 We're going to give him a sign, you know, the Scott

11 Rothstein -- I'm going to get the award for the

12 most-profitable car dealership.

13 Q Do you have a recollection of him making

14 comments like that, or similar to that, to A.J. Discala

15 and Dean Kretschmar, Doug Von Allmen?

16 A The comments to Doug Von Allmen were not of

17 that nature. The comments -- the conversations, to the

18 best of my recollection, with Doug Von Allmen were very,

19 very simple as to how the investment is going, nothing

20 more complicated than that.

21 Doug is not the -- there was not that kind of

22 jovial thing back and forth between Doug and I and Ted

23 and I.

24 Q How did Ted say the investment was going to

25 Mr. Von Allmen or to my clients, to your knowledge?

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Page 1165

1 A I believe he said that he was very satisfied

2 with it. It was a very -- I recall, only because it was

3 a very business-like answer. It wasn't Ted's normal,

4 you know: He's our most profitable car dealership kind

5 of thing.

6 Q It wouldn't be a flamboyant answer; it would

7 have been a business answer?

8 A It would have been a business answer.

9 Q Because Mr. Von Allmen is more of a

10 business-type man?

11 A Yes. He's extremely proper.

12 Q He is extremely?

13 MR. LAVECCHIO: Proper.

14 A He's extremely proper.

15 In fact, he once wrote me an email, before we

16 were getting ready to talk to some investors on the

17 phone reminding me there was a lady on the phone.

18 I actually wrote him back something to the

19 effect of: Got it, language to be adjusted properly.

20 Q He doesn't use swear words, does he?

21 A No, he doesn't, not -- I have never heard him

22 curse before, no.

23 Q I'm going to get back to the September 6th

24 date, '09, Seltzer order in a minute.

25 A Is that the 6th or the 8th?

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Page 1166

1 Q I'm sorry, the 8th, precipitated by the email

2 of the 6th, the --

3 A Yes.

4 Q -- order on the 8th. Thank you.

5 But we're trying to get some documents.

6 Do we have them?

7 Just give me a second here.

8 A Yes, sir.

9 Q All right. Let me go ahead and try to do this

10 now so we can keep this all in context.

11 On the 8th of September, Mr. Morse is in your

12 office at 10:00 a.m.?

13 A Correct.

14 Q There's an email that says to you, Morse is in

15 reception?

16 A Correct.

17 Q And then you and Mr. Morse -- what did you do

18 when he first got there? Do you have a recollection of

19 what you did before you went to judge -- well, let me

20 see if I can get the broad strokes first and then I'll

21 fill in.

22 A Okay.

23 Q After he arrived at 10:00 a.m., thereafter,

24 you have testified that you went to Judge Seltzer, the

25 two of you, and then you went to Weston to get the

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Page 1167

1 bank -- the phony bank balance. Then you came back to

2 your office.

3 You then talked to Ed on the telephone and

4 said, send me authorization for Ted to testify. And

5 then he sent you authorization for Ted to testify.

6 Then you, at 4:30 in the afternoon, sent Ed

7 and Carol the Seltzer order and there was a phone call

8 at that time where Ted told them about the order and

9 read parts of that to them.

10 Is that a correct restatement of your

11 testimony?

12 A To the best of my recollection, yes, sir.

13 Q Okay. What I want to do is, I want to show

14 you some composite exhibits, and we'll put those in as

15 our next exhibit so that you can refer to them and we

16 can maybe shorten the times, although we don't need to

17 shorten them much.

18 A Okay.

19 MR. KOPAS: Plaintiff's 170 is a

20 composite exhibit, and these are the exhibits

21 to the complaint we filed against the Morses

22 on Tuesday.

23 MR. MULLINS: Objection, move to strike,

24 and asked and answered.


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Page 1168

1 Plaintiff's Composite Exhibit No. 170 for

2 Identification.)

3 BY MR. SCHERER:

4 Q Well, I don't mean to -- if it's been asked

5 and answered, Mr. Rothstein, you just say that, and I'll

6 accept it. But I think we need a little more clarity on

7 it.

8 A No. I can tell you that, based upon the

9 series of questions I have been asked so far, it

10 definitely requires clarity. People have been kind of

11 jumping all over the place with this.

12 Q Now, between ten -- and you see that -- you

13 see a picture of you and Ted at the bank there.

14 What is the date of that?

15 A It's September 8th, 2009, at 12:45.

16 Q So we know at 12:45 you're in Weston getting

17 the phony bank balance?

18 A Correct.

19 Q Now, and we know that Ted was in your office

20 at 10:00?

21 A Yes.

22 Q Now, between 10:00 and 12:45, what did you do?

23 A Okay. Ted gets to the office at 10:00. I go

24 get Ted immediately, because as anyone that that's done

25 business with Ted knows: You don't leave him waiting.

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Page 1169

1 So I went -- even as my best friend, I don't

2 want to hear it. So I went and got him. We went back

3 to the office.

4 At that point in time -- you should have the

5 metadata somewhere -- but we are messing around with the

6 order, initially. That's when it's initially being

7 created.

8 Q And is he helping you?

9 A He's helping me to the extent that I'm asking

10 him -- you know, we talked about his -- what his role

11 was going to be --

12 Q Okay.

13 A -- and how much of that I was going to put in

14 the order, because I was not going to put him in a

15 position where he had to say something to his father

16 that he himself was not comfortable saying.

17 So we went ahead, and I finished up the order.

18 Following finishing up the order, I gave the

19 order to Deb. Deb and -- this part is unbeknownst to

20 Ted. I give that to Deb. Deb goes ahead and cuts and

21 pastes Judge Seltzer's signature on to the order, puts

22 it in an envelope for me and gives me the order.

23 Ted and I leave to go to Judge Seltzer's.

24 We arrived at Judge Seltzer's. When I get to

25 Judge Seltzer's chambers, after his secretary announces

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Page 1170

1 me, I go in with Ted. I introduce Judge Seltzer to Ted.

2 The remainder of the time that Ted is in there

3 with me, we are simply talking -- Judge Seltzer had

4 upcoming nuptials; we were talking about that. Judge

5 Seltzer and I generally talk about skiing, we talk about

6 some sports, and then I excused Ted.

7 At that moment, I wanted Ted, for my own

8 purposes, to believe that I had Judge Seltzer in my

9 pocket; and Ted, having known that I had a lot of

10 politicians, law enforcement people and the like in my

11 pocket, it was not very difficult to believe because he

12 had used those people before.

13 So I went ahead and had Ted step out. I then,

14 while Ted is obviously thinking I'm getting Judge

15 Seltzer to sign the order, I talk to Judge Seltzer about

16 his upcoming potential eventual nomination to the

17 federal bench by the president, and we are just

18 kibitzing about general stuff, talking about general

19 stuff.

20 I then take the order. I then take the order.

21 Judge Seltzer had given me -- I asked him for a notebook

22 of all his, you know, resumes, his CV, all of his

23 accomplishments, because I wanted to send that off for

24 him to people regarding the federal judgeship.

25 I took the order and placed it inside the

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Page 1171

1 inside sleeve of the notebook. I then went out with

2 Ted. I took Ted, said good bye the judge. We left.

3 As we were walking over there, I pulled the

4 order out, at some point in time. I don't remember

5 whether it was while walking over there or later; but at

6 some point in time I take the order out of there and

7 give it to Ted.

8 Q Now, did you discuss with Ted the purpose of

9 going to Judge Seltzer? I mean, why did you do that if

10 he was going to go along with the farce anyway?

11 A For whatever reason, at that point in time, I

12 wanted Ted to believe that I had a member of the federal

13 judiciary in my pocket.

14 Q Okay. Did --

15 A Which I obviously did not.

16 Q You know the order referred to Ted testifying.

17 Did you attempt to give Ted some kind of alibi

18 that he thought what you did with Judge Seltzer was a

19 hearing?

20 A No.

21 Please allow me to explain what occurred while

22 we were in there.

23 Ted, during the course of this, barely said

24 anything at all. It was the quietest I had ever heard

25 Ted. He was actually the most demure I had ever seen

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Page 1172

1 him during my entire friendship with him. He barely

2 said anything, which was really not like him.

3 But there was no way in the world that Ted

4 thought a hearing was occurring, okay, nothing of the

5 sort, nothing to lead him to believe it. There wasn't

6 even any discussion about Ted being involved in any type

7 of litigation. Nothing of that nature happened.

8 What Ted believed was that I went in there

9 privately and somehow got Judge Seltzer to sign that

10 order.

11 Q Now, I'd like you to look at the next document

12 in that composite. You've got the --

13 A Let me just --

14 Q Go ahead.

15 A Which, by the way --

16 Q Have you finished?

17 A No.

18 Which, by the way, is consistent with Ted's

19 understanding of my influence in the community in

20 general. It would have elevated what was my actual

21 level of influence over and above what it actually was,

22 because I did not have any federal judges in my pocket,

23 certainly not Judge Seltzer or anybody else involved.

24 Q Okay. I'd like you to look at the -- you've

25 got the bank visit, and I think we have already talked

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Page 1173

1 about that; but the document shows you in the bank, and

2 I'm interested in the timing.

3 A Yes.

4 Q And it's 12:45?

5 A Correct.

6 Q Then look at the next couple of documents,

7 those -- that is the phony statement and the Caretsky

8 cover letter.

9 A Yes.

10 Q And then there's the metadata. I would like

11 you to look at that. It looks to me like you did some

12 more drafting of that order. If you can see the

13 metadata up at the top, the -- go back to the -- may I

14 show you the -- let me do this. I haven't done this. I

15 haven't walked over.

16 MR. SCHERER: May I, Marshal, go over

17 here close?

18 MR. NURIK: You can come around. You can

19 come around.

20 BY MR. SCHERER:

21 Q This appears to be a -- a drafting and then a

22 printing of the final, so it looks like --

23 A Okay.

24 Q And then you have the metadata that actually

25 shows the date of the final printing of the order.

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Page 1174

1 Do you see that?

2 A I do.

3 Q Now, after you -- apparently more drafting on

4 that order took place after you returned from the bank.

5 Do you recall that?

6 A I have a vague recollection of me making

7 certain corrections to the order.

8 Q Okay.

9 A I don't know exactly what they were.

10 Q You can pretty much tell by looking at those

11 successive copies there. It's pretty much the same

12 thing, it looks like, only one was in regular form and

13 one was in final form. And then somewhere along the

14 line, you had to cut and paste judge's signature?

15 A Yes. What -- at some point in time, okay,

16 prior to me giving -- it looks like Pam was working on

17 it, which makes sense because --

18 Q Pam?

19 A Pam Dominicis.

20 Q Right.

21 A It looks like she was working on it at some

22 point in time.

23 Q At what time?

24 A At 1:54 p.m.

25 Q Okay.

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Page 1175

1 A And then this -- it says "last modified," it

2 looks like some kind of modification was made actually

3 after it was last printed.

4 That's correct, because it says September 8,

5 2009, 2:24 p.m. last printed; it says last modified two

6 minutes after that, which may have just been the

7 methodology that Pam was using to notate it for later

8 purposes to be able to access it. It could have been

9 anything the way that works.

10 Q It's at 2:25 p.m., correct, or around that

11 time, around 2:30?

12 A Yes.

13 Q And Ted is still with you, correct?

14 A Yes.

15 Q And then do you see an email from Ed

16 authorizing Ted to testify? I think that's in there,

17 right?

18 A Yes.

19 Q Okay. What time was that?

20 A Mr. Scherer, bear with me one second. I just

21 want to make sure that we got this from the right order.

22 Q Right. Can I help you?

23 A No.

24 Okay. We're in the right order.

25 Q All right. And what time does Ed email you

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Page 1176

1 back that it's okay for Ted to testify in the hearing

2 before Judge Seltzer that you -- you know, that you

3 already had the visit for?

4 A 2:25 p.m.

5 Q And Ted is still there at that point, right?

6 A Yes. Ted was with me the entire day, yes.

7 Q Ted and then you, apparently, waited a few

8 hours before you emailed Judge Seltzer's order; do you

9 see that? Do you see the date or the time of the email

10 or the order?

11 A I do.

12 Q What time was that?

13 A I emailed the order at 4:11 p.m.

14 Q And was there a phone call between you and Ed,

15 you and Ted and Ed and Carol at that time that you

16 emailed the phony order to them? Do you recall that?

17 A A telephone call, sure, there was, yes.

18 Q And do you recall what happened on that phone

19 call, what you said, what Ted said to Ed and Carol?

20 A I do.

21 Q What was that, please?

22 A I called up Ed on the phone. I had Ted

23 sitting with me. We were actually sitting at the

24 conference room table at my office. I had the speaker

25 phone on. I told Ed Ted was with me.

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Page 1177

1 We did a conference call. We dialed -- I

2 don't know if we dialed Carol in or not, actually. I

3 have to look at her telephone records.

4 But in any event, I know Ed was on the phone

5 with Ted.

6 I told Ed we won. I explained the basis of

7 it. I told him that he should be very proud of Ted, I

8 said, because without Ted's sworn testimony, there was

9 no way that the judge was ruling in our favor, that he

10 really was the star of the order and the hearing and not

11 me.

12 I said -- told him -- I think I actually wrote

13 it in a subsequent email, something about that I would

14 love to take the credit for this but I can't; it really

15 all goes to his son, to Ted, for his testimony.

16 Ed then spoke to Ted while we were there and

17 asked Ted some very specific and pointed questions about

18 the hearing, specifically what the judge asked him and

19 the like. Ted answered all the questions by lying to

20 his father, and we wrapped up the call. And I gave Ted

21 a copy of the order to take with him, and I also emailed

22 the copy to Ed and Carol.

23 Q There were some more emails in the days that

24 followed between you and Ed and Carol, and you -- where

25 you, again, invited the father to talk to his son, if he

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Page 1178

1 didn't believe you about the hearing and Ted's

2 testimony. You do recall that?

3 A Yes. It was more directed to Carol. I

4 repeatedly told Carol, because she -- she sent me that

5 very terse email back at one point in time saying, well,

6 that's amazing how you got this whole thing handled, the

7 IRS and the hearing, you know, the bond funds in eight

8 hours, isn't that amazing. Something to that effect.

9 Q Right.

10 A So I wrote her a strong email back, and I

11 invited her, in that email and on multiple other

12 occasions, if you don't believe me as to what happened,

13 ask Ted --

14 Q Did --

15 A -- Ted was there. Ted testified. Talk to

16 him.

17 Q Do you know whether they actually spoke about

18 it? Did she ask Ted?

19 A Ted hated Carol. He probably avoided her, so

20 I don't know; but I know Ted spoke to his father.

21 Q Okay. And what do you know about that

22 conversation?

23 A I know that Ted told him repeatedly about his

24 testimony. He was using it to bolster his own worth in

25 his father's eyes. I mean, it was clear that was going

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Page 1179

1 on during the course of the initial conversation.

2 Q And during those conversations, Ted would lie

3 to his father that he testified at a hearing before

4 Judge Seltzer when you guys visited Seltzer that day on

5 the 8th, correct?

6 A That's absolutely correct.

7 Q All right.

8 A I mean, the order is clear that -- it says Ted

9 testified. It says, under oath, that he testified under

10 oath; and I believe the word -- either "at length" or

11 "extensively."

12 Q Who was keeping track of the mathematics, the

13 accounting on the -- all of the payments that were due

14 under the bonds, under the deals, and the interest, et

15 cetera, for Morse operation and Ed and Carol under the

16 bonds?

17 A Dennis McGinnis and Michael Kelly; and

18 internally, my office, either Irene or Deb. I don't

19 know which one.

20 Q I'm not sure we're doing lightning rounds,

21 but -- it's going fast for me, but they tell me I'm

22 going slow. So I would like to kind of see if I can't

23 move it along because others need an opportunity.

24 Let me direct -- I have a few questions to TD

25 Bank that's more in the nature of redirect, I think.

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Page 1180

1 A Okay.

2 Q The -- on the cover letters that Caretsky, and

3 on a few occasions Kerstetter, did to accompany, the

4 fake statements, and I believe that you have testified

5 pretty completely about that whole process, correct?

6 A Yes, sir.

7 Q And I asked you this, but I don't think it was

8 100 percent clear, that every time that they did a cover

9 letter, the cover letter was original; you never faked

10 any cover letters?

11 A To my recollection, we never faked a cover

12 letter. We didn't need to.

13 Q Yeah. And is your understanding that every

14 time they gave you a fake cover letter, they asked the

15 bank's -- they made a -- printed a screen shot from the

16 bank of the actual balance to go along with the cover

17 letter?

18 A Yes, sir.

19 Q So they would have some deniability?

20 A Yes.

21 At one point in time I asked Ms. Caretsky, I

22 said, you know, I don't need these, just stick them in

23 the file.

24 She said, no, I need to show that they were

25 printed at the time that I wrote this letter so we have

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Page 1181

1 a complete record.

2 Q And, of course, those printed, actual bank

3 statements nowhere near matched the fraudulent

4 statements that you were providing for the switch,

5 correct?

6 A No, sir.

7 Q Now, with Mr. Spinosa, I know that he met with

8 some investors to talk to them about your business and

9 to vouch for you and to vouch for the authenticity of

10 the lock letters, correct?

11 A Yes, sir.

12 Q And I know that he also had meetings with some

13 investors that you talked about: Barry Damson and

14 Kathleen White for Coquina, where Mr. Spinosa actually

15 affirmed false balances in the falsely locked account,

16 correct?

17 MR. SCHLESINGER: Objection to form.

18 A Correct.

19 BY MR. SCHERER:

20 Q What did Mr. Spinosa tell Barry Damson and

21 Kathleen White on Coquina when they visited his office

22 in Cypress Creek with you concerning the bank balances?

23 A He told them that we had -- it was in

24 excess -- I don't remember what amount we were looking

25 at the time, but whatever the amount was, several tens

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1182

1 of millions of dollars, he verified to them that we had

2 in excess of that amount in the account.

3 Q And that was a lie, of course?

4 A Yes, sir.

5 Q Now, do you have a recollection of Mr. Spinosa

6 meeting with Ira Sochet?

7 A He may have. I don't have a specific

8 recollection of it.

9 Q Now -- okay.

10 A He may have had a telephone call with

11 Mr. Sochet. I don't recall whether Ira did or not.

12 Q Ira Sochet, nice man?

13 A Yes. Wonderful man.

14 Q In his 80s?

15 A Yes, sir.

16 Q Did you take advantage of him?

17 A I did, sir.

18 Q Well, would you describe how you took

19 advantage -- let me ask this: Did you take advantage,

20 also, of his age in any regard?

21 A I did, sir.

22 Q How?

23 A He was in a stage in his life where he was --

24 from what I understand from Mr. Szfranski, who had known

25 him a lot longer than I had, he had mellowed, and he was

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Page 1183

1 very trusting; very sharp but very trusting, and I took

2 advantage of that.

3 Q Did he know that you were running a scam or a

4 fraud?

5 A He did not, sir.

6 Q In your mind?

7 A No, sir.

8 Q Same question for Mr. Von Allmen, did he know?

9 A No, sir.

10 Q Now, would you describe your relationship at

11 TD Bank as atypical, as an atypical banking

12 relationship?

13 A That's one word, "atypical," not; "a typical."

14 Q No, no, no. Was it atypical. That would be

15 one word, A-T-Y-P-I-C-A-L. Was it an atypical

16 relationship?

17 A Yes, it was an extremely unusual relationship.

18 Q Unusual or atypical?

19 A Yes.

20 Q Would you say that TD provided you with

21 special accommodations --

22 MR. SCHLESINGER: Objection.

23 BY MR. SCHERER:

24 Q -- in the way they handled your accounts and

25 you as a customers?

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Page 1184

1 A Yes, sir.

2 Q Without TD Bank's help and Mr. Spinosa's help

3 and TD Bank, in general, could your Ponzi scheme have

4 survived?

5 ALL PRESENT: Object, asked and answered

6 several times.

7 MR. SCHERER: It's been asked and

8 answered?

9 MR. RABIN: Several times.

10 MR. SCHERER: Fine.

11 A It couldn't have.

12 MR. RABIN: Move to strike.

13 MR. SCHERER: Well, you don't need to

14 move to strike. All you need to do is object

15 to form.

16 MR. RABIN: I did it anyway.

17 MR. SCHERER: That's all you have got to

18 do.

19 MR. RABIN: Thank you.

20 MR. SCHERER: I don't think you're going

21 to coach this guy.

22 BY MR. SCHERER:

23 Q Would you describe your relationship with

24 Gibraltar Bank as an atypical banking relationship?

25 That would one word, "atypical."

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Page 1185

1 A Yes.

2 Q And did they provide you with special

3 accommodations? I'm talking about the people at

4 Gibraltar.

5 A Yes, sir.

6 Q Let me talk to you about your testimony the

7 other day that I should have followed up on and didn't,

8 concerning A.J. Discala of Clockwork and my clients and

9 your dinner with him in Bova where you guys were excited

10 and even toasted some drink to some event.

11 Do you recall that testimony?

12 A Yes, sir.

13 Q Would you tell me about that a little bit, and

14 then I'll ask you some follow-up questions.

15 A Can you give me the time frame again? Who was

16 with me?

17 Q Yes. It was before the Razorback investment

18 while Clockwork was doing its due diligence, and that

19 would be sometime in, probably, September or maybe the

20 summer, June, July, August, September, somewhere in that

21 line, when they were doing their due diligence about

22 investing in your fund. Is that -- I can't get more

23 precise than that because it's your memory.

24 A Yes. I recall -- the problem is that I recall

25 having dinner with them on several occasions there. I

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Page 1186

1 also recall a time when we were sitting off to the side

2 tables, closer to the bar, where, actually, Thane

3 Ritchie was there and some of the other guys, and we

4 were sitting there having drinks, toasting.

5 Q What I'm interested in is A.J.'s statements to

6 you about his due diligence and investigation of the

7 performance of the New York hedge funds and their past

8 performance with your investment scene.

9 A Okay.

10 MS. TRENCH: Object to form.

11 A I remember what you're talking about now.

12 MR. SCHERER: I have an objection there.

13 If it's from Susan, it's probably pretty good

14 and I'll change the question.

15 What is it?

16 MS. TRENCH: It's testifying. It's

17 asking him to speculate, talking about what

18 other people knew.

19 BY MR. SCHERER:

20 Q Well, okay. I'm asking you if you were

21 present when A.J., when there were discussions

22 concerning his diligence.

23 A Yes, I was.

24 Q And tell -- and by the way, did you have

25 similar conversations with either Mr. Simony or

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Page 1187

1 Mr. Nordlicht from the funds about --

2 A Yes, sir.

3 Q -- their positive references to Mr. Discala

4 and the Clockwork people?

5 A Yes, sir.


7 BY MR. SCHERER:

8 Q Tell us about those discussion, please.

9 A You want me to start with the A.J.

10 discussions?

11 Q Yeah. Start with A.J., and then we will go

12 onto the others.

13 A At the -- at one of the dinners we were

14 having, we were toasting the fact that their due

15 diligence people, whoever was making the call -- I don't

16 know who it was, someone on behalf of the Clockwork, Von

17 Allmen, that whole group -- had spoke to the folks in

18 New York at the New York hedge funds, and they had given

19 us a sterling recommendation, both with regard to

20 consistency of payment and the type of investment

21 strategy we were representing.

22 There were also conversations prior to that

23 where I spoke to Jack Simony and I spoke once or twice

24 to Mr. Nordlicht about the fact that they were looking

25 forward to getting their money because they had done

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1188

1 what they were supposed to do in giving me a positive

2 reference to our new investors.

3 Q And that "new investors" would have been the

4 Clockwork people?

5 A Yes, sir, among them, yes.

6 Q And did you have any conversations with Simony

7 or Nordlicht about A.J., in particular, or anybody else

8 in my client group --

9 A I did.

10 Q -- that you recall?

11 A I did.

12 Q All right. And tell us about that, please.

13 A I remember -- the conversation with Discala

14 sticks out because he was at one point in time married

15 to Meadow Soprano -- I forget her name. What is her

16 real name?

17 Q Jamie Sigler.

18 A Right. Jamie Sigler.

19 So somehow it had come up in the conversation

20 with the hedge funds, because Simony -- I don't remember

21 whether Nordlicht asked me, but Simony was asking me, he

22 said, I didn't know he was married to her. So that's

23 why it sticks out.

24 Other than that, that's all I can tell you.

25 Q Do you think that conversation occurred prior

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Page 1189

1 to the time of the Razorback investment in your

2 investment -- settlement investment scheme?

3 A I was told both by Doug Von Allmen and by A.J.

4 Discala, specifically, that without the blessing of our

5 large -- largest investors, they were not going to be

6 able to invest. That was key.

7 Q Well, let me ask you this: Who, in doing due

8 diligence, would ever invest without the positive

9 reference of a fund that was primarily funding the

10 investment for 18 months? Wouldn't that be absolutely

11 critical to any kind of diligence?


13 A Yes. Based on my experience in running a

14 Ponzi scheme for four or five years, the only people

15 that ever invested without doing that type of due

16 diligence were people who were in the know about the

17 fact that we were committing a fraud.

18 BY MR. SCHERER:

19 Q Do any of my clients, A.J. -- and A.J. Discala

20 and Parrish or any of those other fellows have a -- how

21 did you rephrase that -- how did you phrase that? Did

22 they have an escort issue? Did you ever provide escorts

23 to any of my clients?

24 A No, sir.

25 Q And you can't say the same thing about some of

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Page 1190

1 those fellows at Platinum, though, can you?


3 A No. No, sir.

4 BY MR. SCHERER:

5 Q As inducements to Simony, Nordlicht and Glass,

6 did you provide them tickets to concerts, Super Bowl,

7 BCS, political events, dinners, charter flights, the

8 things that you have been talking about?

9 A I did.

10 ALL PRESENT: Object to form.

11 BY MR. SCHERER:

12 Q And escorts, same thing?

13 A Some them, yes, sir.

14 MS. TRENCH: Objection.

15 BY MR. SCHERER:

16 Q And how often would you provide -- would they

17 partake in your rock-star lifestyle that you have been

18 talking about here for a few days?

19 MS. TRENCH: Same objection.

20 A I would say it was on a regular basis.

21 Certainly whenever they were in Florida, they were; and

22 whenever I traveled to New York, they were; and whenever

23 we traveled together, they were.

24 Q Okay. Did you do that to induce them into

25 treating you more favorably, or why did you do that?

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Page 1191

1 A I did that because that is the way I took care

2 of people that were involved -- I -- I don't really know

3 how to put this. I mean, you do -- the guys at the

4 hedge funds -- there's two methodologies of rewards.

5 You were rewarding guys that were in on it; but at the

6 hedge funds, I was really just trying to make them

7 comfortable with me so they would invest.

8 Q Well, and some of them were in on it, though,

9 right?


11 BY MR. SCHERER:

12 Q Like Simony?

13 A I believe -- here's the way you have got to

14 break this down, Mr. Scherer. I believe that Jack

15 Simony had some knowledge of the fraud. That is my

16 opinion. Okay. I do not know it for a fact.

17 On the other side, Brian Jedwab, I believe had

18 no knowledge -- thought about it, and had he found out,

19 he would have shut us down in a second.

20 As I said, he would have gone running down the

21 hall, calling the police on the way. I don't think

22 Simony would have done that.

23 Q And Nordlicht?

24 A That is based on my dealings with him. That's

25 my opinion.

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Page 1192

1 Q Okay. Nordlicht?

2 A I believe at some point in time Nordlicht

3 knew. It's my opinion that he knew that there was a

4 fraud in the works.

5 Q Well, and some of them were in on it, though,

6 right?


8 A I don't --

9 Q Like Simony?

10 A I believe -- here's the way you've got to

11 break this down, Mr. Scherer, okay. I believe that Jack

12 Simony had some knowledge of the fraud. That is my

13 opinion. Okay. I do not know it for a fact.

14 On the other side, Brian Jedwab I believe had

15 no knowledge, thought about it, and had he found out he

16 would have shut us down in a second. As I said, he

17 would have gone running down the hall calling the police

18 on the way.

19 I don't think Simony would have done that.

20 Q And Nordlicht --

21 A That's based on my dealings with them. That's

22 my opinion.

23 Q Okay. Nordlicht?

24 A I believe at some point in time Nordlicht

25 knew. It's my opinion that he knew that there was a

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Page 1193

1 fraud in the works.

2 Q Well, and then -- let's see -- why do you say

3 that?

4 Yeah. And then I'm going to ask you about

5 what they got out of their actions thereafter.

6 A Well, it's based on a conversation --


8 A -- that I had with him in my office.

9 Q You have talked about that.

10 A That I went through. So, you know, listen, as

11 you're going through this thing, there are people that

12 you know are involved because they're involved. They're

13 actually -- like Szafranski, bringing in investors to

14 something he knows doesn't exist.

15 David Boden, creating paperwork. Those are

16 people you know. I want to clearly differentiate

17 between that and my opinion.

18 Then there are people that you think know.

19 Okay. I know Mr. Spinosa knowed (sic) because he lied

20 for me. I know Harris knowed because he lied for me.

21 Okay.

22 I know Ted Morse knowed.

23 I don't know whether or not Simony or

24 Nordlicht knew. It was my opinion that he knew and

25 looked the other way because they wanted to get their

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Page 1194

1 money out.

2 Q Okay.

3 A They were making a lot of money and then they

4 were almost making no money and they wanted to get all

5 their money out.

6 Q They had a hundred million dollars in it

7 approximately, in April. They had, in December, when

8 they started slow paying or ramping down the payment,

9 they had about $180 million. I would like you to assume

10 that. I think that's pretty accurate.

11 A I believe that's accurate, sir.


13 BY MR. SCHERER:

14 Q And the positive references that Platinum and

15 Centurion and their -- Simony, Nordlicht, Glass,

16 provided -- and anybody else there, provided to our

17 investors -- enabled your scheme to continue on through

18 the end of October, correct?


20 MR. SCHERER: What is wrong with the

21 form?

22 MS. TRENCH: It assumes facts not in

23 evidence.

24 BY MR. SCHERER:

25 Q Okay. Well, we -- that's all deposit

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Page 1195

1 information, so that is in evidence or will be in

2 evidence.

3 I want you to assume that they had about

4 $100 million outstanding in April.

5 A I don't need to assume it. They did have

6 approximately that amount of money.

7 Q Okay. You remember that?

8 A Yes.

9 Q And at the end of the crash, they got it all

10 back except about $18 million?

11 A Yes, I believe -- my recollection is, is they

12 were just $18 million shy.

13 Q Okay. So they made about $80 million back for

14 their fund and that -- between April and the end of

15 October, correct?

16 A Yes, sir.


18 BY MR. SCHERER:

19 Q And what did they do to get that back other

20 than remain silent? They did more than remain silent,

21 didn't they?

22 A Yes.


24 A They looked the other way and they gave us a

25 positive credit reference to our new investors.

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Page 1196

1 BY MR. SCHERER:

2 Q All right. Now, did Nordlicht partake in the

3 inducements also: Tickets, concerts, escorts, flights,

4 charter flights, hotels, food, drink?

5 A Not --


7 A Food and drink, yeah, but not so much.

8 Nordlicht was more of a family guy.

9 BY MR. SCHERER:

10 Q Okay.

11 A Did his thing on the side.

12 Q Simony and Glass more so?

13 A Yes. Very much Simony and, you know, Glass

14 was a little squeamish about it from time to time but he

15 got over it.

16 Q Okay. How about how many -- how many -- what

17 are we talking about? How many times? Multiple times?

18 A For a --

19 Q For both of those guys.

20 A Simony liked the escorts and Glass liked more

21 to go to strip clubs and then get --

22 Q Serviced?

23 A Serviced. Extra special treatment at the

24 strip clubs. He felt secure in the strip clubs for some

25 reason.

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Page 1197

1 Q And did he ever pay for it or did you pay for

2 it?

3 A No. I always paid.

4 Q And where did you get the money to pay for it?

5 A Ponzi scheme.

6 Q Now, you flew Glass to the islands, to the

7 Bahamas in order to -- for him to do some due diligence

8 and approve some settlements offshore because some other

9 business was offshore, correct?

10 MS. TRENCH: Object to the form.

11 A That is why I thought we were going there,

12 yes, sir.

13 BY MR. SCHERER:

14 Q But what did you do when you were there? He

15 didn't do any business, did he?


17 A No. We did monkey business. We did no real

18 business.

19 BY MR. SCHERER:

20 Q And monkey business meaning?

21 A We drank and we had women at our disposal

22 there.

23 Q Okay. And do you think that the requirement

24 to do business offshore was satisfied by the monkey

25 business that you guys engaged in when you were in the

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Page 1198

1 Bahamas?


3 A No. One thing had nothing -- one thing had

4 nothing to do with other.

5 BY MR. SCHERER:

6 Q The deals that you were actually -- or that he

7 was actually looking at there were being really looked

8 at back in New York, right?

9 A Yes. Because when we got there, Mr. Scherer,

10 I said, "Okay, what do we have to do?" He said, "What

11 do you mean we have to do?" He said, "Everything's

12 already been approved." Go downstairs and drink. Later

13 on we'll get a call. I'll go upstairs and just type in

14 that everything's -- that I've reviewed all the

15 documents and it's been approved.

16 We had no way to receive the documents. We

17 had no documents with us. We had his laptop. Wallets

18 and bathing suits. We were good to go.

19 Q Okay. Let me talk to you about the bar

20 grievance procedure.

21 A Okay.

22 Q You actually had a -- had the Platinum guys

23 come in, and you used this contrivance that you had a

24 Bar problem tying up your trust accounts, and therefore,

25 you were slow paying them or no paying them because

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1199

1 ostensibly the Bar had tied up your trust accounts,

2 right?

3 A Correct.


5 BY MR. SCHERER:

6 Q And is there anything incorrect about that

7 predicate statement?

8 A No, sir.

9 Q Okay. And at one point you got somebody from

10 your office on the phone who played like a lawyer for

11 the Bar?

12 A Yes, sir. A female at the office.

13 Q Okay. And I guess -- what, did you use a

14 speakerphone or something like that?

15 A Yes.

16 Q And who was in the office to witness this

17 spectacle?

18 A I don't remember, Mr. Scherer.


20 BY MR. SCHERER:

21 Q Okay. Who was in the office to -- was it

22 Simony? Was he there; do you recall?

23 A I really don't recall. I recall there being

24 somebody there from the hedge funds and someone on the

25 call also that had been conferenced in. But I don't

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Page 1200

1 recall who was there.

2 Q So you -- I mean, you put on this charade

3 about the Bar grievance to justify withholding money

4 that was due to the funds, correct?

5 A Yes. I -- it was twofold. I wanted to

6 pressure them into potentially settling -- not

7 settling -- I wanted to pressure them into potentially

8 funding more cases, and I needed to have a -- at least

9 semi viable reason why I was not paying them.

10 Q The Bar grievance ruse was for the funds, not

11 anybody else? I mean, were there any other investors

12 that were -- that you used this Bar -- this fictional

13 Bar problem with?

14 A No. It was utilized for the purpose of

15 controlling the New York hedge funds.

16 Q Did you have a concern that they would pick up

17 the telephone and call the Florida Bar?

18 A Terrified.

19 Q They didn't do that, though, obviously.

20 A Not to my knowledge.

21 MS. TRENCH: Object to form on that one.

22 BY MR. SCHERER:

23 Q Did the person that was on the phone acting

24 like a Bar lawyer use a Bar lawyer's name?

25 A Yes.

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Page 1201

1 Q Adrianna something?

2 A Adria Quintela.

3 Q Adria Quintela. Who is actually a lawyer for

4 the Bar?

5 A Yeah. She actually ran the Fort Lauderdale

6 office.

7 Q So were you fearful that somebody from the

8 fund would call Adria and say, is this true?

9 A Terrified.

10 Q Didn't happen, though, did it?

11 A No, sir.


13 BY MR. SCHERER:

14 Q Now, when the funds did their due diligence in

15 December at Steve Rossi's office --

16 A Yes.

17 Q Doesn't Mr. Rossi have a relatively modest

18 office?


20 A Extremely modest. Yes.

21 BY MR. SCHERER:

22 Q Were you concerned that whoever was doing the

23 due diligence in talking to Mr. Rossi would look around

24 the office and have a little bit of a problem believing

25 that he could send you hundreds of cases a month?

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Page 1202

1 A When I arrived there, having never been there

2 before, yes. I was very concerned. I actually joked

3 around about it later but we made it through it.

4 Q Well, yeah, you did.

5 Were you concerned that Mr. Glass and

6 Mr. Jedwab would do the Plaintiff/Defendant Index at

7 Broward and Palm Beach and Dade County and find out that

8 Mr. Rossi has only but a handful of cases?


10 A Yes, sir.

11 BY MR. SCHERER:

12 Q That didn't happen either, though, did it?

13 A To my knowledge, no.

14 Q Now, Mr. Herskowitz -- is that how you

15 pronounce it?

16 A It's either Herskovitz (phonetic) or

17 Herskowitz (phonetic).

18 Q Okay. His office is modest as well, isn't it?

19 A Yes. Comparatively so, yes.

20 Q And same question. Were you concerned that

21 they would look around that office and say, how did this

22 guy -- how can this guy send hundreds of cases worth

23 hundreds of thousands of dollars?

24 A Yes.

25 Q And I don't know Doug Bates. What does his

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Page 1203

1 office look like?

2 A Same. Modest.

3 Q Same concern?

4 A Yes, sir.

5 Q Did you have the same concern that they would

6 run the Plaintiff/Defendant Index to see if those

7 fellows had any cases?

8 A I did, sir.

9 Q Because you knew they didn't have very many

10 cases, right?

11 A That's correct, sir.

12 Q They have very modest practices?

13 A Yeah. If you ran Bates, you would know; you

14 would find a bunch of personal injury cases and a lot of

15 workers' comp cases.

16 MR. SCHLESINGER: Mr. Scherer, there's

17 one minute left in the plaintiff's time.

18 MR. SCHERER: I'm going to take more than

19 that. I'm going to finish.

20 MR. SCHLESINGER: That wasn't stipulated

21 to.

22 MR. SCHERER: Read the court order.

23 I'm taking -- I'm going to finish this.

24 I'll be done in a few minutes.

25 BY MR. SCHERER:

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Page 1204

1 Q Let me ask you about Mr. Levin.

2 A Okay.

3 Q Was he a player as you've defined "player" in

4 this deposition this week?

5 A Mr. Levin I considered to be a player, yes,

6 sir.

7 Q Do you think he was in on the fraud?

8 A I do. However, I have to qualify it. I never

9 had direct conversations with George Levin about the

10 fraud. But there were -- let me break it down this way

11 for you. Okay. I knew he had the ability to monitor

12 Frank's emails. Frank and I had discussed that.

13 Q Right.

14 A He would read Frank's emails. I don't need to

15 tell you. I'm sure you read them all. It's clear that

16 there's a fraud going on.

17 Q Right.

18 A That's one.

19 Q I agree.

20 A Two, there was with a key moment in time in

21 '08, key moment, there's an email -- I think it was May

22 of '08 -- where Frank Preve has called -- where Frank

23 Preve has called TD Bank, and he has discussed the trust

24 balance, okay, with Frank Spinosa. And Frank Spinosa,

25 bobbles the ball and says we don't have as much in the

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Page 1205

1 trust account and then rushes and excuses himself and

2 gets off the phone.

3 Now, how do I know that happened? Because

4 Mr. Preve confirmed all that in an email to Mr. Levin.

5 I think the email title is "Idiots" and it's Frank

6 writing to George Levin and he says, "I was -- are these

7 people at Commerce Bank idiots? It was Commerce at the

8 time. He's going through the -- what he did, that

9 they're telling me about telephone calls he had with

10 them. It's clear I've got Spinosa in my pocket because

11 Frank's referencing him. In the email he's saying -- I

12 tell him not to tell Scott something and he picks up the

13 phone and tells Scott immediately, because Scott's

14 telling me about the conversations he had with Spinosa.

15 The second paragraph of the email is the key.

16 In that particular paragraph, he says during the

17 conversation, Spinosa tells him that Rothstein doesn't

18 have that much money in the trust account. Then

19 basically panics and hangs up and says, "I'll have to

20 get back to you." Never gets back to him.

21 When Preve tries to follow up with him to try

22 to figure out how much money I have, he -- Frank,

23 unfortunately -- and I had never seen these emails until

24 I came back and in reviewing emails you see that Frank

25 bobbled the ball again. He says, "I don't have access

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Page 1206

1 to customer balances. I got to wait until my girl gets

2 back on Tuesday, something to that effect.

3 Q Frank Spinosa?

4 A Frank Spinosa.

5 So at that moment, it's -- now looking at

6 these emails, it's crystal clear to me what was going on

7 because Preve had relayed this to me earlier on. Once,

8 Preve and I were speaking -- you'll see emails back and

9 forth where Preve is talking to me about what an idiot

10 Spinosa is and I need to watch him.

11 It's clear from that email and from the

12 behavior that George, to my knowledge, knew what was

13 going on. But George, the way he always did his

14 business -- okay, George and I became very close. The

15 way George did his business was Frank was his Chinese

16 wall. Frank -- he used Frank to try to insulate him

17 from liability, that is clear in everything he did. Go

18 back to the classic motor cars thing; it's the exact

19 same thing. It's the way he does his banking business.

20 It's the, I don't know, someone else takes care of it.

21 The exact same thing, by the way, if you look

22 through the email traffic, happened with John Harris and

23 Gibraltar, where Frank made a call over and said -- he

24 was trying to get --

25 Q Frank Preve?

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Page 1207

1 A Frank Preve was trying to get a line of credit

2 with Gibraltar for the Banyon people. And he said,

3 well -- and in the email he mentions, he says, "Well,

4 you've got $21 million in the trust account." And now

5 Harris follows the ball, okay, and says, uh, yeah, okay,

6 something -- and you can tell by the email Frank knows

7 the money is not there and he's writing -- and George is

8 copied on the email. You can see that they know the

9 money is not there. Okay.

10 And the way John Harris recovers, you see, is

11 he continues to attempt to put through Levin's Banyon's

12 request for a line of credit.

13 Preve keeps pushing him. Keeps pushing

14 Spinosa and Levin -- excuse me, Spinosa and Harris to

15 try to get these lines in place. But you can see from

16 the emails that everyone knew that the trust account

17 balances were not there.

18 Q When you --

19 MR. RABIN: Mr. Scherer, just -- for a

20 moment. I want to put on the record, it's now

21 five after ten.

22 Although you say you don't care about

23 whatever --

24 MR. SCHERER: Let me finish.

25 SPEAKER?: Let me just put this on the

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1208

1 record, please.

2 MR. SCHERER: Sure.

3 MR. RABIN: There was an agreement

4 reached by all counsel. I think Mr. Lichtman

5 actually coordinated the agreement, that the

6 plaintiffs would stop today at 10:00, because

7 this was going to be a shortened day, and in

8 order to be assured that we would get all of

9 our time in that was guaranteed by the court

10 order that you referred to, that you would

11 stop by 10:00 so that we could start.

12 It's now five past 10:00. You've now

13 violated the agreement.

14 So I'm not sure if it's the court order

15 that you're going by or ignoring the agreement

16 that all the lawyers in this case reached, but

17 I think you should be a man of your word and

18 abide by the agreement that all the lawyers

19 reached.

20 MR. SCHERER: I'm about finished, so --

21 MR. RABIN: Okay.

22 MR. SCHERER: -- just give me a few more

23 minutes.

24 MR. RABIN: All right.

25 MR. SCHERER: Okay? And the court order

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Page 1209

1 gives me the right to take all morning if I

2 want.

3 MR. RABIN: The problem with that, of

4 course, is that the court order didn't take

5 into account --

6 MR. SCHERER: Don't take --

7 MR. RABIN: I understand the court didn't

8 take into account the change of schedule.

9 MR. SCHERER: Well, that change of

10 schedule will be the same next Friday.

11 MR. LICHTMAN: Rather than fight about

12 it --

13 MR. SCHERER: We don't need a referee.

14 Let's go.

15 BY MR. SCHERER:

16 Q Do you recall receiving emails, correspondence

17 from Mr. Levin late in the game, let's say as your Ponzi

18 scheme was crumbling in the fall of 2009, that made you

19 think that he still felt there was money in -- actual

20 money in trust accounts?

21 A I do.

22 Q And actual defendant's money in trust accounts

23 that were held up by the Bar?

24 A Yes. I recall receiving something along those

25 lines.

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Page 1210

1 Q Did that make you concerned that maybe this

2 guy doesn't know?

3 A I couldn't decide because it was like a civil

4 thing. There were things that were discussed that made

5 me think one way and then I would receive something like

6 that that would make me think the other way.

7 Q When you got back from the Ponzi scheme,

8 initially you weren't sure, were you?

9 A No. No, I wasn't. I'm still not sure as I

10 sit here. I mean, looking back on reading emails I have

11 tremendous hindsight and there were clearly things that

12 say this man knows that something was wrong or at the

13 very least just wants to look the other way. But I --

14 to this day I have no way of knowing for certain. It's

15 my opinion.

16 Q Do you recall a fatherly email that he wrote

17 you late in October where he said, Take a deep breath --

18 something. Take a deep breath. Don't get yourself into

19 this situation where you promise plaintiffs you'll

20 settle the case until we get the money in-house.

21 A Yes.

22 Q And then you've got the defendants' money

23 in-house, and we'll be all right?

24 A Yes, sir.

25 Q You remember that?

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Page 1211

1 A I do.

2 Q Well, when you got that, did you think, well,

3 he still thinks this Ponzi scheme is real?

4 A To some extent, sure.

5 Q Defendants' money in-house locked up,

6 plaintiffs' money coming in, plaintiffs' money promised,

7 investor money coming in --

8 A Yes.

9 Q -- he said, Scott, don't promise the

10 plaintiffs anymore until you get the investor money

11 in-hand?

12 A Sure.

13 Q Remember that?

14 A Sure. Absolutely.

15 Q And we've got all that defendants' money, it's

16 already in there, we can wait and get the periodic

17 payments?

18 A Yes, sir.

19 Q I mean, he wrote you that in October?

20 A Yes, sir.

21 Q Did you think when he wrote you that, that he

22 was just covering up for the record or that he actually

23 believed it?

24 A At that point in time I really didn't know one

25 way or the other.

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Page 1212

1 Again, the problem always was that I couldn't

2 tell. He kept himself so isolated for everything I

3 couldn't tell.

4 For all I knew, he wasn't; and for all I knew,

5 he was.

6 You know, just -- I guess the emails that I

7 saw him writing me said he wasn't aware. At least if he

8 was aware, it was to a limited extent.

9 The email traffic between him and Mr. Preve

10 and the conversations Preve is telling me he's having,

11 speak to the other side of the coin, that he was aware.

12 So it's very difficult for me to tell.

13 Q Well, and aren't there some emails between you

14 and Preve that "we're going to keep the old man in the

15 dark" and Preve said he's going back to the islands and,

16 I'm going to put my feet up on his desk and think about

17 how to screw him and -- remember that --

18 A Yes.

19 Q -- email?

20 A Yes, sir.

21 Q And that was late in the game?

22 A It was, sir.

23 Q I mean, that email would make you think that

24 maybe Mr. Levin isn't -- didn't know.

25 MS. TRENCH: Objection. Form.

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Page 1213

1 A Yes, but I have to tell you, Mr. Scherer, as I

2 sit here today, what I'm telling you is merely my

3 opinion. Okay. I do not know for certain whether or

4 not Mr. Levin knew there was a Ponzi scheme going on. I

5 just do not know. The emails and all the evidence

6 that's floating around in my brain over the last couple

7 of years is contradictory.

8 BY MR. SCHERER:

9 Q Let me show you this -- I'm going to -- I've

10 got one more email and I'll be done in just a minute,

11 fellows.

12 BY MR. SCHERER:

13 Q Your testimony about the other tentacles to

14 your fraud operation, that involved more than just the

15 confidential settlements? That was one branch of your

16 fraud?

17 A Correct.

18 Q But your fraud had other branches?

19 A Correct.

20 Q You had the -- as you discussed, Ron Picou and

21 his grout company that you were using to get money and

22 give him money fraudulently -- or Ponzi scheme money and

23 putting his money into the Ponzi scheme?

24 A He wasn't involved in the Ponzi scheme but I

25 was using funds from him to fund the Ponzi scheme, while

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1214

1 at the same time laundering money for him for the things

2 he needed money for and to help him hide money from

3 his -- at that point in time soon-to-be ex-wife.

4 Q And -- well, you know, I thought in the

5 beginning you might have said that the Ponzi was bigger

6 than just the settlement because all of the money came

7 in from all of these multi-faceted frauds --

8 A I did say that.

9 Q -- and then was paid out on a multi -- out of

10 Ponzi money or fraudulent money, without regard to who

11 was owed what on the basis of some contract or illegal

12 contract or agreement?

13 A Yes.

14 Let me make sure you understand that I

15 believe -- actually I'm confident as I sit here today

16 that every one of the tentacles of the criminal

17 enterprise that I was running, all flowed back in some

18 way to benefit the Ponzi. Whether it was power -- in

19 any phase, judiciary, law enforcement, banking. Whether

20 it was laundering money for organized crime and all the

21 myriad of things that occurred in between. They were

22 all involved at some way ultimately funding or assisting

23 the Ponzi scheme.

24 Q Was Mel and Barry Lifshitz involved with you

25 early on?

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Page 1215

1 A Mel Taylor?

2 Q No, no, Mel -- is it -- is there a Mel

3 Lifshitz also. Mely?

4 A You're getting them -- Mely -- there's Mel

5 Taylor --

6 Q Okay.

7 A Or Thaler, who's Barry Lipsitz -- excuse me,

8 Barry Lipsitz's --

9 Q Lipsitz's.

10 A -- partner in Flashdancers in New York and in

11 some other businesses.

12 Q Okay.

13 A Then there's Menachem, Mely, Lifshitz, who

14 is -- who is an investor through Szafranski.

15 Q Okay. All right.

16 A That wasn't easy. That's okay.

17 Q All right. So those are -- the Barry Lipsitz

18 was not a settlement Ponzi investor? Barry and Mel

19 Taylor, the Flashdance guys, did they --

20 A To my knowledge, Mel wasn't involved in it.

21 Mel was involved in some kind of money laundering thing

22 with Barry to get cash to build a home in Fort

23 Lauderdale -- actually to redo a home in Fort

24 Lauderdale.

25 Barry was an investor, just like Tanachio, in

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Page 1216

1 the -- just the promissory notes, like Morse.

2 Q Right. The -- Mely or Menachem was in the

3 structured settlement --

4 A The full-blown deals, full-blown -- you know,

5 everything. Through Szafranski.

6 Q That would be the Emess Group? Is that Emess?

7 A The Emess Group, yes.

8 Q All right. Thank you. Thank you.

9 Now, did the Tanachio frauds, as you have

10 discussed, and Ronnie Picou's fraud that you discussed

11 and the Peters Silversea, was that also during the time

12 of the Ponzi -- the settlement Ponzi business?

13 A Yes.

14 Q Let me show you some emails. I'm going to do

15 it as a composite.

16 MR. RABIN: For the record, it's 10:15,

17 Mr. Scherer. You have now said you would be

18 wrapping up since about five after when you

19 made the first --

20 MR. SCHERER: Pretty soon.

21 MR. RABIN: I understand but pretty

22 soon -- you're violating the order the

23 lawyers, the agreements of the lawyers --

24 MR. SCHERER: Look, you're not going to

25 take all next week. You'll have plenty of

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1217

1 time. Just hold your horses.

2 MR. RABIN: Unfortunately, it's not just

3 me. There's a lot of lawyers that want to

4 take time, so --

5 MR. SCHERER: You'll have time all next

6 week.

7 MR. RABIN: You're cutting into that

8 time.

9 (Multiple conversation.)

10 MR. SCHERER: Well, I'm sure I won't. So

11 I'm going to do this right now because I may

12 not get to see this man again.

13 MR. KOPAS: All right. Plaintiff's

14 Composite Exhibit 171. First thing is an

15 email that was Exhibit 28 to Nordlicht's

16 deposition. Bates Stamp FP ends in 167641/1;

17 another email TCL 60572; another email begins

18 FP -- Bates number FP 156116/1; another email,

19 FP Bates-labeled ends 167761/1.

20 (Thereupon, the documents were marked as

21 Plaintiff's Composite Exhibit No. 171 for

22 Identification?)

23 A Thank you, sir.

24 BY MR. SCHERER:

25 Q Look at that first email. It says, "Jack

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Page 1218

1 asked you to send something to the other two funds to

2 keep them quiet."

3 May 6th.

4 You see that?

5 A Yes, sir.

6 Q And was this part of your DOMAD, doctrine of

7 mutually -- mutually assured destruction?

8 A Yes, sir.

9 Q And --


11 BY MR. SCHERER:

12 Q Okay. Why were you sending something to the

13 other funds to keep them quiet?

14 A Because Preve and Mr. Simony and I had a

15 concern that if I didn't get money over to all the

16 various parts of the New York hedge funds, that one of

17 them might explode and blow the whistle on us.

18 Q Okay. I would like you to look at that next

19 email, October 15th. A couple of weeks before you go to

20 Morocco you met with Simony.

21 You see that? Take a look at that email,

22 October 15th email.

23 A I see that.

24 Q And when we took his deposition, he couldn't

25 remember anything you discussed at that late, late

c0b92300-38eb-4196-9c0f-58abe77bb0aa


Page 1219

1 meeting in October, but in the email, you see where it

2 says "please email me the docs we spoke about"?


4 A Yes.

5 BY MR. SCHERER:

6 Q You see that?

7 And then he also says, "Please let me know

8 wire sent and I will shred."

9 You see that?

10 A Yes.

11 Q Do you remember what that was all about?

12 A I don't remember what the documents were but I

13 had given him a check to hold for an amount that I was

14 promising to send them. And if I was going to send --

15 if I sent the wire, he was going to shred the check.

16 Q Do you know whether --

17 A He wanted to know whether to deposit it or

18 not.

19 Q Did you send the wire?

20 A I don't recall one way or the other.

21 Q Okay. And then look at the March 20th, '09,

22 email, please.

23 A Yes, sir.

24 Q And what was the -- you see the reference to

25 Murray's trust there --

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Page 1220

1 A Yes.

2 Q -- on that email?

3 A Yes.

4 Q Do you know what Murray's trust referred to?

5 A I do not.

6 Q You know who the Murray is, right?

7 A Yes. It's Murray Huberfeld.

8 MS. TRENCH: Form.

9 BY MR. SCHERER:

10 Q And you know that Murray's had some kind of a

11 trust that was owning the Regent's or part of the

12 Regent's deal?

13 A I don't know if that's what was associated.

14 I'm not familiar with that backroom information.

15 MS. TRENCH: Objection to form.

16 BY MR. SCHERER:

17 Q The Regent's money came into you, 11 million,

18 paid out 22 million.

19 Do you remember that?

20 A I do.

21 Q That money came in in January of '09.

22 Was that money important in maintaining and

23 continuing the Ponzi scheme at that period of time,

24 January '09?

25 A Absolutely it was, sir.

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Page 1221

1 MS. TRENCH: Form.

2 BY MR. SCHERER:

3 Q Without that $11 million infusion, do you know

4 what would have happened?

5 A Yeah. I believe if you look at the finances,

6 financial records and ledgers at the time, the Ponzi

7 would have exploded and I wouldn't have been able to

8 make payments to other investors.

9 Q Okay. Would you look at that last email,

10 May 6th, and then these guys can have the floor?

11 A Yes, sir.

12 Q And these amounts that you are discussing in

13 this email, you can see that with -- this was to

14 Mr. Nordlicht, right?

15 A Yes, sir.

16 Q Did you fund these amounts of money in order

17 to keep the hedge funds quiet?

18 A All of the money that I sent them was to keep

19 the hedge funds quite, yes, sir.


21 BY MR. SCHERER:

22 Q Why did you send them the money that you

23 referenced in that email on May 6th, '09?

24 A I didn't want anyone exploding and blowing the

25 whistle and blowing up the Ponzi scheme.

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Page 1222

1 MR. SCHERER: Okay. Thank you. No

2 further questions.

3 MR. LICHTMAN: Sam, while they're

4 switching tables, I'm going to ask five very

5 quick questions that make clear the Magistrate

6 Seltzer had no complicity in the fraud.

7 So do that, and by the time you get here,

8 I'll be done.

9 MR. RABIN: I think that's clear.

10 MR. LICHTMAN: I'm going to ask the

11 questions.

12 FURTHER EXAMINATION

13 BY MR. LICHTMAN:

14 Q Scott, you weren't on the Federal JNC,

15 correct?

16 A No, sir.

17 Q You had zero ability to play any role in

18 assisting Magistrate Seltzer in reaching aspirations of

19 becoming a federal judge; is that correct?

20 THE REPORTER: Hold on a second. I'm

21 having trouble hearing you with all the

22 shuffling. Maybe you want to come over this

23 way.

24 BY MR. LICHTMAN:

25 Q You had zero ability to play any role in

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Page 1223

1 assisting Magistrate Seltzer in becoming a federal

2 judge, correct?

3 A I really don't know the answer to that

4 question. I don't know how deep my influence in

5 Washington ran, but I can tell you that Judge Seltzer

6 wasn't expecting anything illegal from me.

7 Q In 2008 and 2009, there was a democratic

8 president, correct?

9 A Yes.

10 Q Okay. When you went in to see Magistrate

11 Seltzer with Ted Morse, you were playing Judge Seltzer

12 that day, correct?

13 A I --

14 Q You were manipulating Judge Seltzer?

15 A I was manipulating Judge Seltzer, yes.

16 Q And Judge Seltzer had no idea he was being

17 manipulated, correct?

18 A Absolutely. He had no idea.

19 Q Would you agree that your knowledge of

20 Magistrate Seltzer is that he's a judge of the highest

21 character and integrity?

22 A Say that again. I'm sorry.

23 Q Would you agree that Magistrate Seltzer, from

24 your knowledge of him, is a judge of the highest

25 character and integrity?

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Page 1224

1 A Absolutely.

2 Q So no one should draw the slightest inference

3 by his use of the name in this thing with Ted Morse,

4 that he knew of or participated in any wrongdoing,

5 right?

6 A Judge Seltzer knew nothing about anything that

7 was going on --

8 Q All right.

9 A -- and I took advantage of him, yes.

10 And I'm not sure that a democrat was in office

11 when you're saying that, just so we're clear.

12 Q 2008? Oh, 2009.

13 A Yeah, 2009.

14 MR. LICHTMAN: Okay. All right. Thank

15 you.

16 THE WITNESS: I think you're wrong.

17 MR. RABIN: We have to take a ten-minute

18 break.

19 (Thereupon, a recess was taken.)

20 DIRECT EXAMINATION

21 BY MR. RABIN:

22 Q All right. Good morning, Mr. Rothstein.

23 A Good morning, Mr. Rabin.

24 Q All right. You and I, although you know my

25 name and we spoke briefly at the beginning of or during

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Page 1225

1 this deposition, we never met before, correct?

2 A Not to my knowledge, no, sir.

3 Q You have never represented me in any matters?

4 A No, sir.

5 Q I have not participated in your rock-star

6 lifestyle?

7 A No, sir.

8 Q Okay. First of all I want to dispel this myth

9 that seems to have been created that you wouldn't be

10 testifying without Mr. Nurik here. You understand,

11 first of all, that you're here pursuant to court order,

12 don't you?

13 A Yes, sir.

14 Q And a subpoena?

15 A I've never seen a subpoena, but I know the

16 judge ordered me to be here, yes, sir.

17 Q And you know that this is -- also, that the

18 government expects you to cooperate in any and all

19 proceedings that you're required to be at, right?

20 A Yes, sir.

21 Q Okay. So you're not saying that you would

22 risk your Rule 35? You're not saying that you would

23 violate a court order and be held in contempt by

24 refusing to go testify if Mark Nurik weren't sitting

25 next to you, are you?

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Page 1226

1 A I believe that I have a right to have counsel

2 at all times that I'm testifying regarding any of these

3 matters, so I don't believe a judge would order me to be

4 here without counsel. So I can't answer your question.

5 You're asking me to guess about something that is not

6 going to happen.

7 Q All right. Well, you have access to Lexis,

8 don't you?

9 A Yes, sir.

10 Q Take a look, when you get back, do one of your

11 searches on your right to counsel post-sentencing; you

12 may find that you don't have a right to counsel. But

13 let's go on from there.

14 I want to ask you some questions about your

15 conditions of confinement; and in asking you these

16 questions, I want to make it clear from the beginning,

17 so there is no objections from the government and

18 marshals, I do not want to know anything about your

19 location.

20 Do you understand that?

21 A I do.

22 Q I have noticed that you come to court every

23 day in street clothes and new outfits every day; is that

24 correct?

25 A That's not correct.

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Page 1227

1 Q Okay. Well, fresh shirts?

2 A Yes.

3 Q Okay. And when you leave here, do you change

4 into prison garb?

5 MR. LAVECCHIO: Objection, privilege.

6 MR. RABIN: As to whether he changes into

7 prison garb?

8 MR. LAVECCHIO: Yes, sir.

9 BY MR. RABIN:

10 Q All right. You indicated you have access to

11 Lexis?

12 A Yes, sir.

13 Q Okay. And I assume that that's unlimited

14 access?

15 A There's actually a time frame that you can go

16 on. I can do research for a certain number of time and

17 then it shuts me off so someone else can use it. So

18 it's not unlimited, but I have access. It's the way we

19 have our prison library. It's instead of books.

20 Q All right. And is there any restrictions on

21 the types of searches that you can do on Lexis?

22 A I don't believe so, but I don't know. I never

23 had it stop me from searching; but then again, I was

24 only searching me.

25 Q In addition, have you -- do you also have a

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Page 1228

1 television?

2 MR. LAVECCHIO: You can answer.

3 BY MR. RABIN:

4 Q I mean, it's a simple question: You either

5 have a television or you don't.

6 A Yes.

7 Q Okay.

8 MR. NURIK: Let the record reflect that

9 the time that he spent to pause was not for

10 any other reason than to determine whether or

11 not the government was going to interpose a

12 privilege objection.

13 MS. TRENCH: I'm sorry. I'm having

14 trouble hearing.

15 MR. NURIK: The time he spent to pause is

16 for no other reason than for him to determine

17 whether or not the government was going to

18 interpose a privilege objection.

19 BY MR. RABIN:

20 Q Do you also have access to some exercise

21 equipment?

22 A Yes.

23 Q Okay. And I notice that you seem to have lost

24 some weight, right?

25 A Yes.

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Page 1229

1 Q Okay. About how many pounds have you lost?

2 A Thirty-five.

3 Q Okay. You've cut your hair, and you have

4 grown a little facial hair, correct?

5 A Yes.

6 Q Okay. Other than that, your appearance has

7 been the same?

8 A Yes, sir.

9 Q Okay. Now, the lawyers that have questioned

10 you earlier in this week, you met with Mr. Lichtman, who

11 you call "Chuck," for approximately three days, you

12 said, much earlier in the year, I guess?

13 A Yeah. I spent two or three days with Mark,

14 prepping, and Mr. Nurik, prepping; and then I met with

15 Mr. Lichtman and his people for three days.

16 Q Okay. And then since that time, have you met

17 with him additional times?

18 A No, sir.

19 Q Okay. So a total of three days?

20 A Yes, sir.

21 Q And before the deposition, how many times did

22 you have the opportunity to meet with Mr. Scherer or

23 anybody that works with him?

24 A The very first time that I spoke with

25 Mr. Scherer was when he started questioning me here. I

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Page 1230

1 haven't spoken with him or met with him.

2 Q But you did speak with him through Mr. Nurik,

3 who you spoke to and authorized Mr. Nurik to speak with

4 Mr. Scherer on your behalf, correct?

5 A It's too many questions in one question.

6 Q Fair enough. Let me break it down.

7 You did authorize Mr. Nurik to speak to Mr.

8 Scherer on your behalf, correct?

9 A Yes, I did.

10 Q Okay. And there was essentially a dialogue

11 that was going on where Mr. Scherer would want to know

12 things, and those things were, essentially, asked of you

13 by Mr. Nurik and then answered back to Mr. Scherer by

14 Mr. Nurik, correct?

15 A No, sir. To the best of my recollection that

16 is exactly not the way it was occurring.

17 Q Well, tell us how it occurred then.

18 A As part and parcel of my review of things that

19 are part of my cooperation, I would provide information

20 to Mr. Nurik and I gave him authorization that, as he

21 saw fit, he could share it with Mr. Scherer.

22 Q Okay. Let's talk -- that brings us right into

23 what you were reviewing. You said earlier that you

24 reviewed hundreds of thousands of documents, correct?

25 A I have never stopped to count them, but I have

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Page 1231

1 been literally reviewing documents since the day I set

2 foot back on US soil.

3 Q And the documents that you have reviewed

4 include emails from you, correct?

5 A Yes.

6 Q And so that gives you benefit of refreshing

7 your recollection as to certain events, right?

8 A Yes.

9 Q And the documents you have reviewed include

10 emails that you weren't even a party to, correct?

11 A Correct.

12 Q And that gives you the benefit of not only

13 refreshing your recollection of events, but learning

14 about what other people were saying and doing, correct?

15 A Sure.

16 Q Okay. And did you ever review the Coquina

17 complaint that was filed in one of the cases that

18 revolves around you?

19 A I don't recall one way or the other whether I

20 did.

21 Q Have you --

22 A After having reviewed so many documents, I

23 don't remember specifically. Certain ones stick out in

24 my mind. That one is not sicking out.

25 Q Have you reviewed any depositions or trial

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Page 1232

1 transcripts as part of the documents you were reviewing?

2 A Depositions?

3 Q Depositions or trial transcripts.

4 A No trial transcripts.

5 Q Okay.

6 A Deposition transcripts, yes.

7 Q Okay. Approximately, how many deposition

8 transcripts have you had the opportunity to review?

9 A I don't recall.

10 Q Okay. Let's talk about before you left for

11 Morocco. Would it be fair to say that you lied and

12 deceived everyone you knew?

13 A At least to some extent, yeah, sure, I did.

14 Q You lied to your law partners?

15 A Yes, sir.

16 Q You lied to investors?

17 A Yes, sir.

18 Q You lied to your friends?

19 A Yes, sir.

20 Q You lied to your family members?

21 A I did.

22 Q You lied to professionals that you employed,

23 including bankers?

24 A The ones that weren't involved, yes, sir.

25 Q Well, you -- you didn't tell any banker what

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Page 1233

1 you were doing, did you?

2 A Well, you're assuming that they asked me.

3 Q Well, I am asking you, did you tell any banker

4 what you were doing?

5 A To a limited extent, to the extent that they

6 needed to know, yes; and otherwise, no.

7 Q Otherwise you kept them in the dark about what

8 you were doing, correct?

9 A I didn't tell them anything that I didn't

10 think they needed to know in order to fulfill their

11 obligations to me.

12 Q Accountants, same thing, you didn't tell them

13 what you were doing?

14 A I told one accountant a lot; everything, no.

15 Q And as part of your lies --

16 A And I also told one banker a lot, also, and a

17 few lies, but a lot of -- a lot of detailed information.

18 Q As part of your lies, you used the court --

19 essentially incorporated the court in your lies and in

20 your deception, correct?

21 A I did.

22 Q All levels of federal court, starting at the

23 magistrate level, district court level, into the circuit

24 court level, right?

25 A I did.

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Page 1234

1 Q Okay. And not only forging court orders but

2 having people pretend to be judges?

3 A Yes.

4 Q And even incorporating Judge Seltzer, as -- he

5 was unaware, but incorporating him into your scheme, so

6 actually visiting him and incorporating him into your

7 scheme?

8 A Yes, sir.

9 Q And you did all this for one purpose, right?

10 A Multiple purposes.

11 Q Well, the one singular purpose, though, was to

12 make money, right?

13 A Multiple purposes.

14 Q Did you use charities in a way to give

15 yourself the air of legitimacy?

16 A No.

17 Q You never used charities to give yourself

18 legitimacy?

19 A I discussed this in my testimony the other

20 day. I --

21 Q I understand that, but you understand I can

22 ask you questions about your testimony, don't you?

23 A Yes.

24 Q So I am asking you, did you use the charities

25 in order to give yourself legitimacy?

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Page 1235

1 A It turns out that it did give me legitimacy,

2 but this is one of those times that I'm going to differ

3 with you on it, okay. It was not my intention. With a

4 lot of things that's I spent money on and a lot of

5 things that I did, I intended to create a specific air

6 around me.

7 When I was giving money to the charities, like

8 Joe DiMaggio Children's Hospital, I was actually trying

9 to help the children there -- with stolen money, but I

10 was trying to help them.

11 Q Well, certainly you deceived the charities by

12 not letting them know it was stolen money; and more

13 importantly, it did have the effect of giving the air of

14 legitimacy, correct?

15 A That's two questions. Let me answer both of

16 them.

17 Yes, I deceived charities; and yes, it

18 absolutely added to the air of legitimacy.

19 Q You used the political process in order to

20 further your scheme, correct?

21 A That I absolutely did, yes, sir.

22 Q And there were times when you either falsely

23 exculpated people, didn't you?

24 A I falsely exculpated people? Yes, I tried to

25 save a bunch of my co-conspirators from jail, I did.

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Page 1236

1 Q You falsely created the persona that you were

2 a successful lawyer when you were not, correct?

3 A That's correct.

4 Q You pretended to have a successful law firm,

5 when you didn't?

6 A That's correct.

7 Q You pretended to be a legitimate lawyer,

8 correct?

9 A That's correct.

10 Q And a legitimate investor?


12 Q And, in fact, you really were, to quote you --

13 let me show you an exhibit...


15 Defendant's Exhibit No. 172 for Identification.)

16 MR. RABIN: I am showing what is marked

17 as Plaintiff's -- or Defendant's Exhibit -- we

18 are going in order, 172. It's an email, Scott

19 Rothstein, October 31st, 2009, to George

20 Levin?

21 THE WITNESS: Give me one second. I

22 can't see.

23 MR. RABIN: Take your time.

24 UNIDENTIFIED SPEAKER: What page is that

25 email?

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Page 1237

1 MR. RABIN: Mr. Rothstein -- it's from

2 Scott Rothstein to George Levin dated

3 October 31, 2009, at 3:33.

4 BY MR. RABIN:

5 Q Why don't you read it out loud, Mr. Rothstein.

6 A Sure.

7 It's from me to George, subject, me: Do not

8 try to bail me out of this. Save yourself. You and

9 Frank did nothing wrong. I did. I am the liar. I am

10 the thief. I am the scum bag. I either go to jail or

11 die. Why should I put my family through watching me go

12 to jail. Love forever, Scott.

13 Q So, the way you describe yourself was as a

14 scum bag, correct?

15 A I absolutely was.

16 Q Okay. Now, let's move forward to your --

17 let's move forward to your sentencing.

18 At your sentencing, you -- you made some

19 promises, didn't you?

20 A I believe I did, yes, sir.

21 Q You promised to help people recover money,

22 your investors recover money?

23 A Innocent investors, yes, sir.

24 Q Okay. You pledged to help Mr. Scherer, didn't

25 you?

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Page 1238

1 A I -- I don't -- I haven't seen the transcript

2 from it, but if you're saying I did, if you can show me

3 something where I said that; but Mr. Scherer, since I

4 now know him to be representing a group of innocent

5 investors, if I didn't pledge to do that, I would have,

6 absolutely.

7 Q Do you remember Mr. Nurik at your sentencing

8 hearing, talking about, pointing out the fact that Mr.

9 Scherer was in the audience and that he was here and

10 that was somewhat remarkable because he was one of your

11 major protagonists prior to that?

12 A So you're saying Mr. Nurik said it on my

13 behalf? That, I believe, is correct, yes.

14 Q Okay. Well. Through --

15 A Hang on.

16 Through Mr. Nurik, I did pledge to help

17 certain people, yes.

18 Q And, in fact, Mr. Scherer even was benevolent

19 enough to write a letter on your behalf to the

20 sentencing judge?

21 A Yes, he was very kind in doing that.

22 Q And you previously -- your relationship with

23 Mr. Scherer is, in fact, he was your client once, wasn't

24 he?

25 A He was a client of the law firm at some point

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Page 1239

1 in time.

2 Q Did you represent him?

3 A I don't remember whether it was me,

4 specifically me, in conjunction with other lawyers.

5 If you have a document that you can show me,

6 it may refresh my recollection.

7 Q And, now, in helping your legitimate

8 investors, as you put it, and your former client, Bill

9 Scherer, have you identified who the deepest pocket is

10 in all this litigation?

11 A No, sir.

12 Q Yeah, well, you know that, don't you?

13 A I could tell you who I think the deepest

14 pockets are.

15 Q Who do you think it is?

16 A TD Bank.

17 Q Oh, okay. Now let's talk about your

18 cooperation. I wasn't here yesterday in the afternoon

19 for that, but I understand that the subject of a Rule 35

20 came up, and I would like to pursue that a little bit.

21 You understand what a Rule 35 is, correct?

22 A I do, sir.

23 Q You understand that there is only one person

24 or group of people that can file that motion on your

25 behalf, correct?

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Page 1240

1 A I do, sir.

2 Q And Mark Nurik can't file that motion for you?

3 A Right. The only person that can file it is

4 the government.

5 Q And you understand that the government -- in

6 order for the government to file that motion, first of

7 all, if they file it, and they, of course, will never

8 promise you that they will file it, right?

9 A They have never promised me.

10 Q They won't promise you; they will never make

11 that promise, correct?

12 A I don't know what they'll do. They have not

13 promised me. I don't know what they are going to do in

14 the future.

15 Q So, but in order for the government to

16 consider filing that motion, they have to be convinced

17 that your testimony is complete and truthful, correct?

18 A Yes.

19 Q And you understand --

20 A No truth, no Rule 35.

21 Q And you understand that there are components

22 of the cooperation that involve you helping them to

23 recover money, correct?

24 A To the extent that they would be forfeiting

25 people's property, as I understand the United States

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Page 1241

1 government, yes, to that extent, yes. This other stuff

2 is all the civil lawyers. It has nothing to do with the

3 government.

4 Q You also understand you would have to testify

5 in any court proceedings in which you could be a

6 potential witness?

7 A Yes, sir.

8 Q And as often -- as often as needed, you would

9 have to testify against as many people as they wanted

10 you to, where you had -- where you had information?

11 A My understanding, yes, on the criminal side

12 I've got to testify every time they want me to, yes.

13 Q And you also you understand that if you do

14 additional things, that that is an added arrow in your

15 quiver of cooperation? Like working undercover, that is

16 something that is looked upon as favorable, correct?

17 A I am assuming that it's looked upon as

18 favorable if they asked me to work undercover, yes, sir.

19 Q And likewise, if you were to put your life in

20 danger, that would also be a factor that would be

21 considered, right?

22 A Yes, sir.

23 Q And all of these -- all of these combined

24 together -- in the event the government files a Rule 35,

25 all of these combined together to give you the potential

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Page 1242

1 for a sentence reduction, right?

2 A Yes, sir.

3 Q Okay. Now, we already know that you

4 essentially lied in every aspects of your life in order

5 to get money; but of course, you would never lie in

6 order to get a Rule 35, right?

7 A No, sir, I absolutely would not.

8 Q And --

9 A If I lie and get caught lying, even an little

10 bit, I will die in prison.

11 Q Well, that's really the key, isn't it? You

12 could really lie, as long as you didn't get caught,

13 right?

14 A Apparently you don't know Mr. LaVecchio and

15 his co-AUSA's. I wouldn't even venture an attempt. I

16 did not come back from a non-extradition country, where

17 I was sitting with more money than I would spend in ten

18 lifetimes, okay, to come back here and lie again. That

19 was not the purpose.

20 Q That's a lie right there because, in fact, you

21 only had how much money, 15 million, 16 million? You

22 spent 200 million in the two years of your Ponzi scheme,

23 so you could easily spend that in much less than a

24 lifetime, couldn't you?

25 A Apparently you have never been in Morocco. I

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Page 1243

1 could have lived in Morocco with $15 million at least --

2 at least 100 years, very well. I had priced it all out.

3 Q Did you --

4 A I could live as I was living in Fort

5 Lauderdale for $10,000 a month with a full staff.

6 Q Did you go to Morocco before you fled there to

7 check it out?

8 A Yeah. On and on top of that, by the way, I

9 also had a watch collection with me and some jewelry

10 that was worth several million dollars.

11 Q Well, we're going to get to what you took on

12 the plane.

13 MR. RABIN: Thank you, Mr. Nurik, for

14 pointing that out to him.

15 BY MR. RABIN:

16 Q Did you go to -- did you go to Morocco before

17 you fled there in order to check it out?

18 A No, sir.

19 Q Okay. Now, you talked about drug use. What

20 drugs did you use during the time that you were running

21 around committing your crimes?

22 A During the time of the Ponzi scheme, I -- the

23 only drug I used was I smoked pot, and I took

24 prescription medication.

25 Q All right. So you're saying when you talked

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Page 1244

1 about drug use, I think as part of the rock-star

2 lifestyle, in fact, as I think one of Mr. Scherer's

3 PowerPoints, sex and drugs, the only drug you're talking

4 about that you used was marijuana?

5 A Mr. Scherer's PowerPoint regarding drug use as

6 part of the rock-star lifestyle was incorrect. I smoked

7 pot on the weekends with my wife.

8 MR. LICHTMAN: Sam, if you don't mind. I

9 know that the other court reporter just showed

10 up and I don't know --

11 MR. SCHLESINGER: They asked us to stop

12 at one, so thank you, Chuck.

13 BY MR. RABIN:

14 Q All right. So you said the only drugs you

15 used were marijuana with your wife. Is she the only --

16 you didn't -- that wasn't incorporated in the rock-star

17 lifestyle, using drugs with any of your investors or

18 co-conspirators?

19 A No, actually, never.

20 Actually, I had a lot of opportunities to

21 because there was a lot of marijuana smoking going on in

22 my office, but it wasn't something -- I prefer to drink

23 vodka.

24 Q Actually in the office it was going on?

25 A In the office, in the garage, outside the

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Page 1245

1 office, I had some partners that couldn't come to work

2 without smoking pot.

3 Q Okay.

4 A I also found out they were actually dealing

5 drugs in the office. I actually tried to put a stop to

6 that.

7 Q That was one crime you wouldn't tolerated?

8 A No, no, it's not that. I didn't want to draw

9 attention. You don't want to have marijuana dealing

10 from the middle of your law office because I was running

11 a giant Ponzi scheme out of there.

12 Q Did you ever have any of the escorts visit the

13 office?

14 A Yeah. Sure.

15 Q You had had prostitutes in the office, but you

16 wouldn't have pot?

17 A You're missing the point. The police also

18 were sleeping with my escorts. You, obviously --

19 listen, Broward Sheriff's Office, Fort Lauderdale Police

20 Department weren't going to bother me, okay, I could

21 have had all the escorts I wanted.

22 Pot, not a great idea in the office, I don't

23 know why, specifically, it bothered me; but it troubled

24 me, probably because they were actually dealing the pot

25 out of the office while I was in the middled of running

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Page 1246

1 a several-hundred-million-dollar Ponzi scheme.

2 Q Okay. You -- you indicated that you had plans

3 to kill yourself, I guess, on more than one occasion,

4 right?

5 A Twice.

6 Q Twice, once with the .357 in the shower; is

7 that one of them?

8 A Yes, sir.

9 Q Okay. Was that gun loaded, by the way?

10 A Yes, sir.

11 Q Was it registered?

12 A What do you mean "registered"?

13 Q I mean --

14 A I had a concealed weapons permit. It was a

15 legal weapon, yes.

16 Q I'm asking where did you get the gun, is

17 basically what I was asking.

18 A You don't register weapons in Florida. You

19 just purchase them, and they send off the information.

20 I didn't have to register it. It was registered when I

21 purchased it.

22 Q Actually, thank you for that tip, but you can

23 register guns in the State of Florida. Okay?

24 A I said you don't have to. I am not arguing

25 with you. I just did whatever was legally necessary to

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Page 1247

1 purchase the weapons.

2 Q And that was one of only two times you

3 attempted to kill yourself, correct?

4 A Actually, attempted to kill myself, yes, there

5 was two -- two occasions.

6 Q One was with putting the gun to your head in

7 the shower while were you dressed in a suit, and the

8 other one was pills in Morocco?

9 A Pills and vodka, yes.

10 Q Okay. And did you -- you didn't actually take

11 any of the pills, though, right?

12 A I had started to take the pills but --

13 Q Now --

14 A -- I didn't finish.

15 Q What kind of pills were they?

16 A Xanax and blood pressure medication.

17 Q That blood pressure medicine will get you.

18 Have you ever been treated by a doctor for

19 mental illness?

20 A I have been treated for anxiety disorder.

21 Q Has a doctor ever told you that you have you a

22 mental illness?

23 A No.

24 Q Okay. So when you say mental -- what anxiety

25 disorder?

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Page 1248

1 A Yeah. I was diagnosed with -- I think it's

2 called -- it wasn't -- the word wasn't severe anxiety

3 disorder. It was some -- it was some --

4 Q Acute anxiety?

5 A Acute. There we go. Acute anxiety disorder.

6 Q And that was when you came back, right?

7 A Oh, no, sir. I was --

8 Q It was before?

9 A Let me finish, please.

10 I was diagnosed with acute anxiety disorder

11 going all the way back to the time I was in college.

12 Q Okay. So back starting in college, you're

13 talking, what year would that have been?

14 A I was in college from 1980 to 1984.

15 Q So -- and you have had, I guess, multiple

16 doctors diagnose you -- diagnose you with this acute

17 anxiety disorder?

18 A Yeah, when I was the University of -- it was

19 either when I was in the University of Florida or when I

20 was in law school and I started to have very severe

21 panic attacks. I was diagnosed, actually by -- my

22 gastroenterologist diagnosed me.

23 Q Okay. What was his name?

24 A At the time, Steven Sackel.

25 Q And who was the last doctor that treated you

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Page 1249

1 for your acute anxiety disorder?

2 A Dr. Fernando Mata, a psychiatrist in Fort

3 Lauderdale.

4 Q Are you presently taking any medication for

5 depression or anxiety?

6 A I'm taking sertraline -- that's the generic

7 name; I don't know what the actual drug is. I take a

8 few milligrams of that every day for the anxiety

9 disorder.

10 Q Okay. Let's turn now --

11 Before I start that, we'll take a break.

12 (Thereupon, at 10:54, a recess was had.)

13 - - - - -

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1 C E R T I F I C A T E

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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 16th 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

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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 1127 to ,

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 16th day of December, 2011.

20

21 ___________________________________

22 Michele L. Savoy, RPR Notary Public - State of Florida

23 My Commission No. EE 113173 Expires August 6, 2015

24

25



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Aabide 1208:18ability 1204:11

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absolutely 1152:251154:19 1155:21160:14 1179:61189:10 1211:141220:25 1223:181224:1 1235:181235:21 1237:151238:6 1242:7

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answered 1150:141158:11 1167:241168:5 1177:191184:5,8 1230:13

answering 1138:6answers 1133:21anxiety 1247:20,24

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backroom 1220:14bad 1136:13,13

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ball 1204:251205:25 1207:5

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bathing 1198:18battista 1129:8bcs 1190:7beach 1202:7bear 1175:20becoming 1155:23

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bekkedam 1161:25belief 1150:10believe 1139:10

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benefited 1156:15benevolent 1238:18berger 1129:5best 1155:22

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big 1162:17bigger 1214:5bill 1239:8billing 1131:9biscayne 1129:21

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build 1215:22building 1127:17bulldog 1143:12,15bunch 1163:10

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casey 1131:3cash 1158:15,16

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certificate 1132:6certification

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clients 1135:251136:10 1153:121157:10,191161:19 1164:51164:25 1185:81189:19,23

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contrivance1198:23

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course 1133:221156:19 1160:201171:23 1179:11181:2 1182:31209:4 1240:71242:5

court 1127:11128:1 1135:141135:14,161137:21 1138:91144:2,18,191145:16,18,201147:11 1149:9,91149:17 1153:41203:22 1208:91208:14,251209:4,7 1225:111225:23 1226:221233:18,19,22,231233:24 1234:11241:5 1244:9

courtroom 1127:18cover 1144:15

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Dd 1130:8d3 1157:11,12dad 1151:3dade 1202:7damages 1139:7damson 1162:3

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dated 1159:191237:2 1250:91251:19

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david 1129:101193:15

day 1127:121140:14 1146:161147:22 1149:61149:10 1176:61179:4 1185:71208:7 1210:141223:12 1226:231226:23 1231:11234:20 1249:81250:9 1251:19

days 1138:71149:12 1160:251177:23 1190:181229:11,13,15,19

de 1129:16deal 1132:10

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deception 1233:20decide 1210:3decision 1136:24deep 1210:17,18

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depositions1231:25 1232:2,3

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description 1132:91132:12

desk 1212:16destruction 1151:8

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directed 1178:3direction 1153:6

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discussing 1221:12discussion 1152:5

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dispel 1225:8disposal 1197:21district 1233:23disturbing 1156:4divers 1131:5divide 1133:8dixie 1130:17docs 1219:2doctor 1247:18,21

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1142:21 1143:4,81143:18 1150:11151:10 1153:81156:22 1158:41160:10,19,251162:23 1163:31186:18 1192:3,31192:25,251193:24,241203:9 1204:111206:12 1207:161212:4,4 1213:41224:4,6 1232:12

know 1133:11,131133:17 1134:4,41134:5,10,211138:1,13,14

1141:8 1142:51143:4,6,71145:16 1146:91148:12 1153:191155:10 1156:61157:1,4,10,21,221158:6 1160:181161:14 1162:211162:24,251164:2,10 1165:41168:16,191169:10 1170:221171:16 1174:91176:2 1177:2,41178:7,17,20,201178:21,231179:19 1180:221181:7,12 1183:31183:8 1187:161188:22 1189:161191:2,161192:13 1193:101193:12,16,18,191193:20,22,231196:13 1202:251203:13 1205:31206:20 1207:81210:2 1211:241212:6,24 1213:31213:5 1214:41216:4 1219:7,161219:17 1220:4,61220:10,131221:3 1223:3,41224:24 1225:151225:17 1226:181227:22 1230:111233:6,101235:12 1238:41239:12 1240:121240:13 1242:31242:14 1244:91244:10 1245:231249:7

knowed 1193:19,201193:22

knowing 1160:16

1162:24 1210:14knowledge 1164:25

1191:15,181192:12,151200:20 1202:131206:12 1215:201223:19,241225:2

known 1138:3,5,181170:9 1182:24

knows 1137:91143:12 1168:251193:14 1207:61210:12

kopas 1129:151134:18 1147:91159:2 1167:191217:13

kopelowitz 1130:1kozyak 1129:16kretschmar

1161:25 1164:15

Ll 1127:22 1130:15

1131:13 1250:51250:12 1251:41251:22

labeled 1147:14lady 1165:17laid 1143:16language 1150:7

1151:1 1165:19laptop 1198:17large 1189:5largest 1189:5larry 1152:7las 1129:5 1130:9

1131:9late 1162:23

1209:17 1210:171212:21 1218:251218:25

lauderdale 1127:241129:3,6,131130:3,10,221131:10 1201:5

1215:23,241243:5 1245:191249:3

laughed 1135:3laundering 1214:1

1214:20 1215:21lavecchio 1152:6,7

1152:14 1165:131227:5,8 1228:21242:14

law 1129:2 1170:101214:19 1232:141236:4 1238:251245:10 1248:20

lawrence 1127:17lawyer 1150:4,5,20

1150:23 1151:171151:19 1152:31199:10 1200:241201:3 1236:2,7

lawyers 1138:31200:24 1208:161208:18 1216:231216:23 1217:31229:9 1239:41241:2

lead 1172:5leading 1139:22

1141:16learning 1231:13leave 1168:25

1169:23 1227:3ledgers 1221:6left 1171:2 1203:17

1232:10legal 1150:10

1246:15legally 1246:25legitimacy 1234:15

1234:18,251235:1,14,18

legitimate 1236:71236:10 1239:7

length 1179:10leon 1129:16letter 1173:8

1180:9,9,12,14,17


Page 1262

1180:25 1238:19letters 1180:2,10

1181:10letting 1235:12level 1172:21

1233:23,23,24levels 1233:22levied 1153:6levin 1204:1,5,9

1205:4,6 1207:141209:17 1212:241213:4 1236:201237:2

levine 1131:2levins 1207:11levinsons 1130:1lexis 1226:7

1227:11,21liability 1206:17liar 1237:9library 1227:19lichtman 1129:7

1132:4 1134:101134:16,241138:6 1208:41209:11 1222:31222:10,13,241224:14 1229:101229:15 1244:8

lie 1179:2 1182:31242:5,9,12,18,20

lied 1193:19,201232:11,14,16,181232:20,221242:4

lies 1233:15,17,181233:19

life 1136:3 1182:231241:19 1242:4

lifestyle 1190:171225:6 1244:2,61244:17

lifetime 1242:24lifetimes 1242:18lifshitz 1214:24

1215:3,13lightning 1133:20

1134:6 1179:20liked 1196:20,20likewise 1241:19limited 1212:8

1233:5line 1140:15

1174:14 1185:211207:1,12

lines 1207:151209:25

lipsitz 1162:221215:7,17

lipsitzs 1215:8,9list 1155:17listen 1193:10

1245:19literally 1231:1litigation 1172:7

1239:10little 1133:10,14

1134:17 1135:31138:22 1145:231149:3 1152:131161:8 1168:61185:13 1196:141201:24 1229:41239:20 1242:9

live 1243:4lived 1243:1living 1243:4llc 1127:5 1129:20

1131:1llp 1129:12loaded 1246:9location 1138:8

1226:19lock 1181:10locked 1181:15

1211:5long 1138:4,18

1160:8 1242:12longer 1182:25look 1159:11,22

1172:11,241173:6,11 1177:31201:23 1202:211203:1 1206:21

1210:13 1216:241217:25 1218:181218:21 1219:211221:5,9 1226:10

looked 1160:81193:25 1195:241198:7 1241:161241:17

looking 1149:201174:10 1181:241187:24 1198:71206:5 1210:10

looks 1134:221147:7,201148:23 1173:111173:22 1174:121174:16,211175:2

lord 1161:18loss 1156:1lost 1228:23 1229:1lot 1134:12 1137:9

1157:22 1170:91182:25 1194:31203:14 1217:31233:14,16,17,171235:4,4 1244:201244:21

loud 1237:5love 1177:14

1237:12lss 1128:12lying 1177:19

1242:9lyles 1131:9lynch 1153:3

Mm 1127:16,16

1129:11 1130:231148:8,10,111166:12,231174:24 1175:51175:10 1176:41176:13

m1 1159:5,25m2 1159:5

magistrate 1222:51222:18 1223:11223:10,20,231233:23

maintaining1220:22

major 1238:11making 1141:22

1164:13 1174:61187:15 1194:3,4

man 1165:101182:12,131208:17 1210:121212:14 1217:12

manhattan1130:13

manipulated1223:17

manipulating1223:14,15

marc 1129:2,4march 1159:4,19

1219:21marijuana 1244:4

1244:15,211245:9

marine 1131:4mark 1147:8

1225:24 1229:131240:2

marked 1147:171159:8 1167:251217:20 1236:141236:16

marra 1139:3,4,221140:25 1141:191141:23,251142:6,191143:25 1144:161145:14,17

marras 1139:1married 1188:14

1188:22marshal 1173:16marshals 1226:18mata 1249:2matched 1181:3

mathematics1179:12

matter 1137:21matters 1225:3

1226:3mcginnis 1179:17meadow 1188:15mean 1136:24

1142:18 1143:251146:21 1156:71160:20 1163:171168:4 1171:91178:25 1179:81191:3 1198:111200:2,111210:10 1211:191212:23 1228:41246:12,13

meaning 1197:20means 1251:17medication

1243:24 1247:161249:4

medicine 1247:17meet 1229:22meeting 1163:18

1182:6 1219:1meetings 1181:12mel 1214:24 1215:1

1215:2,2,4,18,201215:21

mellowed 1182:25mely 1215:3,4,13

1216:2member 1171:12members 1232:20memory 1185:23menachem 1215:13

1216:2mental 1247:19,22

1247:24mentioned 1144:25

1145:8 1163:3mentions 1207:3merely 1213:2messing 1169:5met 1161:23


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metadata 1132:91146:12,131147:7,10,201169:5 1173:101173:13,24

methodologies1191:4

methodology1175:7

miami 1127:191129:9,22 1130:61131:3,141162:16

michael 1130:61131:15 1179:17

michele 1127:221250:5,12 1251:41251:22

middle 1245:10middled 1245:25mike 1162:1,9miller 1130:13milligrams 1249:8million 1139:6,7,7

1139:8,9,12,161153:12,241154:4,24 1155:41157:11,15,18,211157:25 1158:211158:22 1194:6,91195:4,10,12,131207:4 1220:171220:18 1221:31242:21,21,221243:1,10

millions 1157:211182:1

mills 1131:5mind 1133:16

1183:6 1231:241244:8

minus 1157:21minute 1144:13

1156:13 1165:241203:17 1213:10

minutes 1175:61203:24 1208:23

misconstrued1163:15

missed 1144:23missing 1245:17mode 1146:22modest 1201:17,20

1202:18 1203:21203:12

modification1148:11 1175:2

modified 1148:2,71148:9 1175:1,5

moment 1170:71204:20,211206:5 1207:20

money 1139:18,191153:4,241154:10,13,141155:1 1156:101156:12,151157:5,9,16,22,241160:21 1187:251194:1,3,4,51195:6 1197:41200:3 1205:181205:22 1207:7,91209:19,20,221210:20,221211:5,6,6,7,101211:15 1213:211213:22,22,231214:1,2,2,6,101214:10,201215:21 1218:151220:17,21,221221:16,18,221234:12 1235:4,71235:9,121237:21,221240:23 1242:51242:17,21

moneyin 1159:12monitor 1204:11

monkey 1197:171197:20,24

month 1201:251243:5

months 1153:211189:10

morning 1127:121133:4,5,81148:14 1209:11224:22,23

morocco 1136:201218:20 1232:111242:25 1243:1,61243:16 1247:8

morse 1128:5,5,51130:20 1140:51140:23 1141:181141:18,21,211142:4 1143:11148:13 1152:211153:20 1156:31158:4,6,151159:25 1160:1,11166:11,14,171179:15 1193:221216:1 1223:111224:3

morses 1135:131139:6 1140:4,121144:20 1146:71149:12 1150:81153:19 1155:151156:9,22 1157:11157:24 1167:21

moskowitz 1129:18mostprofitable

1164:9,12motion 1135:14

1239:24 1240:2,61240:16

motor 1206:18mouth 1143:24move 1134:17

1140:16 1167:231179:23 1184:121184:14 1237:161237:17

msnbc 1134:16mullin 1130:23mullins 1139:25

1141:7 1142:8,131144:11 1146:181146:23 1149:151150:13 1152:241154:7,11 1155:61156:18,211158:10 1160:121167:23

multi 1214:9multifaceted

1214:7multiple 1132:11

1134:2 1141:171162:10 1178:111196:17 1217:91234:10,131248:15

murray 1220:6,7murrays 1219:25

1220:4,10muster 1160:8mutual 1151:7mutually 1151:11

1218:7,7myriad 1214:21myth 1225:8

Nn 1127:18 1128:16

1128:21 1131:5name 1162:7

1188:15,161200:24 1224:31224:25 1248:231249:7

nature 1133:101164:17 1172:71179:25

near 1155:221181:3

necessary 1246:25need 1151:2,3,3

1167:16 1168:61179:23 1180:12

1180:22,241184:13,141195:5 1204:141206:10 1209:13

needed 1143:151200:8 1214:21233:6,10 1241:8

needs 1143:13neither 1160:6never 1163:8,16

1165:21 1180:91180:11 1202:11204:8 1205:201205:23 1225:1,31225:15 1227:221230:25 1234:171240:7,9,101242:5,251244:19

new 1130:14,141140:18 1162:171186:7 1187:181187:18 1188:2,31190:22 1195:251198:8 1200:151215:10 1218:161226:23

news 1134:5,9nice 1182:12ninth 1129:17nomination

1170:16nonextradition

1242:16nordlicht 1162:12

1187:1,24 1188:71188:21 1190:51191:23 1192:1,21192:20,23,241193:24 1194:151196:2,8 1221:14

nordlichts 1217:15normal 1165:3notary 1250:12

1251:22notate 1175:7note 1137:16


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notebook 1170:211171:1

notes 1216:11251:9

notice 1228:23noticed 1140:7

1226:22number 1143:10

1147:12 1217:181227:16

numbered 1251:7numbers 1159:6nuptials 1170:4nurik 1129:2,4

1135:15,201136:15,181137:18,211138:2,6,161173:18 1225:101225:24 1228:81228:15 1229:141230:2,3,7,13,141230:20 1238:71238:12,161240:2 1243:13

Ooath 1132:6

1133:17 1179:91179:10

object 1141:71142:8 1149:151155:6 1184:5,141186:10 1187:61189:12 1190:21190:10 1191:101192:7 1193:71194:12,191195:17,231196:6 1197:101197:16 1198:21199:4,191200:21 1201:121201:19 1202:91218:10 1219:31221:20

objected 1144:13

objection 1137:161140:3,151144:11 1146:181146:23 1150:131152:7,24 1154:71154:11 1156:181158:10 1160:121167:23 1181:171183:22 1186:121190:14,191212:25 1220:151227:5 1228:121228:18

objectionable1142:12

objections 1226:17obligations

1233:11obviously 1133:24

1136:24 1142:181153:9 1170:141171:15 1200:191245:18

occasion 1246:3occasions 1143:22

1162:10 1178:121180:3 1185:251247:5

occur 1163:23occurred 1171:21

1188:25 1214:211230:17

occurring 1172:41230:16

october 1132:131146:7 1150:191153:10,141155:5 1157:121158:2 1194:181195:15 1210:171211:19 1218:191218:22 1219:11236:19 1237:3

offense 1135:3office 1129:2

1148:13,221149:1 1166:12

1167:2 1168:191168:23 1169:31176:24 1179:181181:21 1193:81199:10,12,16,211201:6,15,18,241202:18,211203:1 1224:101244:22,24,251245:1,5,10,13,151245:19,22,25

offshore 1197:8,91197:24

oh 1143:24 1161:181162:2 1224:121239:17 1248:7

okay 1133:12,231134:3,13 1135:61136:4 1138:4,81139:3 1141:151142:17,211143:8 1144:101145:9 1147:5,241148:12 1150:161151:19 1152:101153:25 1154:171159:18 1160:21161:10,18,231163:8,211166:22 1167:131167:18 1168:231169:12 1171:141172:4,241173:23 1174:81174:15,251175:19,241176:1 1178:211180:1 1182:91186:9,201190:24 1191:161192:1,11,13,231193:19,211194:2,25 1195:71195:13 1196:101196:16 1197:231198:10,19,211199:9,13,21

1202:18 1204:21204:11,241206:14 1207:5,51207:9 1208:211208:25 1213:31215:6,12,15,161218:12,181219:21 1221:91222:1 1223:101224:14 1225:81225:21 1227:1,31227:13 1228:71228:23 1229:1,31229:6,9,16,191230:10,221231:16 1232:5,71232:10 1234:11235:3 1237:161237:24 1238:141239:17 1242:31242:18 1243:191245:3,20 1246:21246:9,231247:10,241248:12,231249:10

olas 1129:5 1130:91131:9

old 1212:14once 1165:15

1187:23 1206:71238:23 1246:6

onehundred1157:20

ones 1163:31231:23 1232:24

operation 1153:201179:15 1213:14

operations 1128:5opinion 1191:16,25

1192:3,13,22,251193:17,241210:15 1213:3

opportunities1244:20

opportunity1140:12 1179:23

1229:22 1232:8oppose 1140:17order 1138:9,23,23

1139:1,3,4,5,171139:23 1140:81140:25 1141:5,61144:2,4 1145:141145:17,241146:10,16,171147:3,11 1148:11148:22 1149:5,61149:10,11,17,181150:6 1155:71165:24 1166:41167:7,8 1169:61169:14,17,18,191169:21,221170:15,20,20,251171:4,6,161172:10 1173:121173:25 1174:4,71175:21,241176:8,10,13,161177:10,211179:8 1197:71203:22 1208:81208:10,14,251209:4 1216:221221:16 1225:111225:23 1226:31233:10 1234:251235:19 1236:181240:6,15 1242:41242:6 1243:17

ordered 1225:16orders 1141:17

1149:13 1153:41234:1

organized 1214:20original 1180:9ostensibly 1199:1ostrow 1130:1outfits 1226:23outloud 1163:23outside 1143:20,20

1244:25outstanding 1195:4


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Pp 1129:8,16,21

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page 1132:9,121236:24

pages 1251:7paid 1136:15

1157:25 1159:161197:3 1214:91220:18

palm 1202:7pam 1174:16,18,19

1175:7panic 1149:19

1248:21panics 1205:19paper 1158:20,20

1159:23 1160:7papers 1160:3paperwork

1158:13 1160:131160:20 1193:15

paragraph 1205:151205:16

parcel 1230:18parrish 1189:20part 1169:19

1218:6 1220:111230:18,191232:1 1233:151233:18 1244:1,6

partake 1190:171196:2

participated1224:4 1225:5

particular 1188:71205:16

particularly 1150:8

parties 1251:11partner 1215:10partners 1129:19

1232:14 1245:1parts 1167:9

1218:16party 1231:10

1251:13paskert 1131:5passed 1160:8paste 1174:14pastes 1169:21paul 1131:4pause 1228:9,15pay 1135:15

1154:25 1197:1,11197:4

paying 1194:81198:25,251200:9

payment 1187:201194:8

payments 1155:91155:12 1159:131159:14 1179:131211:17 1221:8

pending 1140:6people 1136:13

1138:1,161142:14 1144:231144:25 1145:1,41155:12,151162:25 1164:61168:10 1170:101170:12,241185:3 1186:181187:4,15 1188:41189:14,161191:2 1193:111193:16,181205:7 1207:21229:15 1231:141234:2 1235:231235:24 1237:211238:17 1239:241241:9

peoples 1240:25

percent 1180:8performance

1186:7,8period 1137:4

1138:11 1145:71150:17 1156:81220:23

periodic 1211:16permission

1140:11,19permit 1246:14person 1141:24

1143:18 1200:231239:23 1240:3

persona 1236:1personal 1203:14peters 1216:11phase 1214:19phone 1141:21,22

1142:4,181144:24 1165:171165:17 1167:71176:14,18,22,251177:4 1199:101200:23 1205:21205:13

phonetic 1202:161202:17

phony 1153:201154:1,2,241167:1 1168:171173:7 1176:16

phrase 1189:21pick 1200:16picks 1205:12picou 1213:20picous 1216:10picture 1168:13pills 1247:8,9,11,12

1247:15pins 1153:3pl 1131:2place 1127:17

1168:11 1174:41207:15

placed 1170:25plaintiff 1202:6

1203:6plaintiffs 1127:6

1128:6,14 1132:81147:9,18 1159:21159:9 1167:191168:1 1203:171208:6 1210:191211:6,6,101217:13,211236:17

plane 1243:12plans 1246:2platinum 1129:19

1190:1 1194:141198:22

play 1222:17,25played 1141:25

1199:10player 1204:3,3,5playing 1141:19

1223:11plaza 1130:13please 1134:8

1171:21 1176:211187:8 1188:121208:1 1219:2,71219:22 1248:9

pledge 1238:5,16pledged 1237:24plenty 1216:25plus 1154:2,3

1157:21 1160:10plz 1131:14pocket 1170:9,11

1171:13 1172:221205:10 1239:9

pockets 1239:14point 1141:10,10

1144:5,7 1150:91152:9,221154:20 1158:71169:4 1171:4,61171:11 1174:151174:22 1176:51178:5 1180:211188:14 1192:21192:24 1199:9

1211:24 1214:31238:25 1245:17

pointed 1177:17pointing 1238:8

1243:14points 1141:15

1162:6police 1191:21

1192:17 1245:171245:19

political 1190:71235:19

politicians 1170:10ponce 1129:16ponzi 1152:4,22

1153:13,221155:7 1156:151156:22 1157:1,41157:11,13,191158:20 1159:231161:12,15,161163:1,6,8,16,191184:3 1189:141197:5 1209:171210:7 1211:31213:4,22,23,241213:25 1214:51214:10,18,231215:18 1216:121216:12 1220:231221:6,251242:22 1243:221245:11 1246:1

position 1169:15positive 1187:3

1188:1 1189:81194:14 1195:25

possible 1133:211146:19 1156:10

postsentencing1226:11

pot 1243:23 1244:71245:2,16,22,24

potential 1170:161241:6,25

potentially 1200:61200:7


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1186:21 1190:10presently 1249:4president 1170:17

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1200:6,7 1247:161247:17

pretend 1234:2pretended 1144:18

1236:4,7pretending

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preve 1204:22,231205:4,21 1206:71206:8,9,251207:1,13 1212:91212:10,14,151218:14

prevent 1152:3previously 1238:22priced 1243:2primarily 1189:9printed 1148:3,7

1148:10,23

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printing 1173:221173:25

printout 1147:10prior 1150:8

1174:16 1187:221188:25 1238:11

prison 1227:4,7,191242:10

private 1128:16,19privately 1172:9privilege 1152:9,12

1227:5 1228:121228:18

probably 1141:171151:21 1178:191185:19 1186:131245:24

problem 1185:241198:24 1200:131201:24 1209:31212:1

procedure 1198:20proceedings 1133:1

1141:16 1225:191241:5 1250:7

process 1137:71180:5 1235:19

produced 1159:7professional

1127:22professionals

1232:22profit 1154:3

1159:14profitable 1165:4program 1163:13

1164:2promise 1210:19

1211:9 1240:8,101240:11

promised 1136:4,51136:6,7 1211:61237:21 1240:91240:13

promises 1237:19

promising 1219:14promissory 1216:1pronounce 1202:15proper 1165:11,13

1165:14properly 1140:10

1165:19property 1240:25prostitutes 1245:15protagonists

1238:11protect 1138:17protocol 1140:8proud 1177:7provide 1185:2

1189:22 1190:61190:16 1230:19

provided 1183:201194:16,16

providing 1181:4psychiatrist 1249:2public 1250:12

1251:22pulled 1171:3punitive 1139:7,9

1159:13,141160:18

purchase 1246:191247:1

purchased 1246:21purpose 1171:8

1200:14 1234:91234:11 1242:19

purposes 1170:81175:8 1234:101234:13

pursuant 1138:91225:11

pursue 1239:20pushing 1207:13

1207:13put 1134:8 1148:19

1153:12 1157:111158:25 1167:141169:13,141191:3 1200:21207:11,20,25

1212:16 1237:111239:8 1241:191245:5

puts 1169:21putting 1157:16

1213:23 1247:6

Qqualify 1204:8quell 1151:4question 1134:11

1137:17 1140:191161:11 1163:91163:24,251183:8 1186:141202:20 1223:41226:4 1228:41230:5

questionbyquesti...1152:15

questioned 1135:131137:6 1161:51229:9

questioning1135:18 1138:141140:16 1141:91141:20 1149:3,41229:25

questions 1133:251134:1 1135:171137:22 1138:61138:15 1140:41140:10 1158:231168:9 1177:171177:19 1179:241185:14 1222:2,51222:11 1226:141226:16 1230:51234:22 1235:15

quick 1222:5quiet 1218:2,13

1221:17quietest 1171:24quintela 1201:2,3quite 1147:5

1221:19quiver 1241:15

quote 1236:12

Rr 1129:14 1250:1

1251:1rabin 1132:5

1184:9,12,16,191207:19 1208:31208:21,241209:3,7 1216:161216:21 1217:2,71222:9 1224:171224:21,231227:6,9 1228:31228:19 1236:161236:23 1237:1,41243:13,151244:13

raise 1139:25ramping 1194:8ran 1201:5 1203:13

1223:5razorback 1127:5

1129:11,151157:10,121161:6,201185:17 1189:1

reached 1208:4,161208:19

reaching 1222:18read 1149:2 1167:9

1203:22 1204:141204:15 1237:5

reading 1210:10ready 1165:16real 1188:16

1197:17 1211:3really 1143:13

1172:2 1177:101177:14 1191:2,61198:7 1199:231211:24 1223:31236:12 1242:111242:12

reason 1136:121138:5 1143:101155:21 1171:11


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reasons 1143:9recall 1136:19

1145:9,251148:13 1151:161157:16 1158:181158:19 1162:141165:2 1174:51176:16,181178:2 1182:111185:11,24,241186:1 1188:101199:22,23,231200:1 1209:161209:24 1210:161219:20 1231:191232:9

receive 1157:91198:16 1210:5

received 1149:231150:18 1153:19

receiving 1160:211209:16,24

recentlycreated1148:21

reception 1166:15recess 1224:19

1249:12recollection 1145:4

1146:15 1148:201148:25 1154:5,91156:7 1164:131164:18 1166:181167:12 1174:61180:11 1182:5,81195:11 1230:151231:7,13 1239:6

recommendation1187:19

record 1134:81144:20 1147:51148:19 1159:11162:8 1181:11207:20 1208:11211:22 1216:161228:8 1250:8

records 1153:181177:3 1221:6

recover 1134:11136:11 1237:211237:22 1240:23

recovers 1207:10recovery 1154:2redirect 1133:10

1133:13 1140:121179:25

redo 1215:23reduction 1242:1refer 1167:15referee 1209:13reference 1188:2

1189:9 1195:251219:24

referenced 1139:181221:23

references 1187:31194:14

referencing1205:11

referred 1171:161208:10 1220:4

reflect 1228:8refresh 1146:14

1239:6refreshing 1231:6

1231:13refusing 1225:24regard 1182:20

1187:19 1214:10regarding 1161:15

1170:24 1226:21244:5

regents 1220:11,121220:17

register 1246:18,201246:23

registered 1127:221246:11,12,20

regular 1145:81174:12 1190:20

reid 1129:14reiterate 1136:17related 1148:1

relationship1154:18 1183:101183:12,16,171184:23,241238:22

relative 1159:31251:12

relatively 1201:17relayed 1206:7remain 1195:20,20remainder 1170:2remarkable

1238:10remember 1135:7

1135:17 1141:11146:10 1158:141158:17,231161:1 1162:181171:4 1181:241186:11 1188:131188:20 1195:71199:18 1210:251211:13 1212:171218:25 1219:111219:12 1220:191231:23 1238:71239:3

remembering1146:12

remind 1146:15reminding 1165:17repay 1154:13,14

1154:15 1157:24repayment 1153:21

1156:5repeatedly 1178:4

1178:23rephrase 1189:21report 1250:7

1251:6reporter 1127:22

1132:6 1222:201244:9 1250:51251:4,18

reporting 1127:23represent 1157:18

1160:5 1239:2

represented 1225:3representing

1187:21 1238:4reproduction

1251:16request 1207:12required 1225:19requirement

1197:23requires 1168:10research 1227:16response 1149:11restatement

1167:10restrictions

1227:20resumes 1170:22return 1136:20returned 1174:4review 1230:18

1231:16 1232:8reviewed 1198:14

1230:24 1231:3,91231:22,25

reviewing 1155:101205:24 1230:231231:1 1232:1

revolves 1231:18rewarding 1191:5rewards 1191:4right 1133:19

1134:22,251135:9 1138:191139:14 1142:191142:22 1143:71148:11 1151:121152:10 1153:251156:13 1157:131157:15 1159:21159:20 1163:201166:9 1174:201175:17,21,22,241175:25 1176:51178:9 1179:71188:12,181191:9 1192:61196:2 1198:8

1199:2 1203:101204:13,171208:24 1209:11210:23 1215:151215:17 1216:2,81217:11,131220:6 1221:141224:5,8,14,22,241225:19 1226:1,71226:11,121227:10,201228:24 1230:221231:7 1233:241234:9,12 1240:31240:8 1241:211242:1,6,13,201243:25 1244:141246:4 1247:111248:6

risk 1136:91225:22

ritchie 1186:3rli 1130:11rockstar 1190:17

1225:5 1244:1,61244:16

rodeo 1152:17role 1169:10

1222:17,25ron 1213:20ronnie 1216:10room 1138:3

1176:24roseanne 1131:8rossi 1201:17,23

1202:8rossis 1201:15rothstein 1127:8,13

1128:9,16 1129:11132:2 1133:41137:17 1147:141152:19 1159:111164:11 1168:51205:17 1224:221236:19 1237:1,21237:5

round 1133:20


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1251:22rra 1159:5,5,25rule 1136:9

1225:22 1239:191239:21 1240:201241:24 1242:6

ruled 1139:5ruling 1141:23

1177:9run 1203:6running 1183:3

1189:13 1191:201192:17 1214:171243:20 1245:101245:25

ruse 1200:10rushes 1205:1

Ss 1127:23 1129:2,4

1129:8 1130:211131:2 1186:5

sackel 1248:24sam 1222:3 1244:8satisfied 1165:1

1197:24save 1150:25

1235:25 1237:8savoy 1127:22

1250:5,12 1251:41251:22

saw 1143:181147:22 1212:71230:21

saying 1145:21148:17 1169:161178:5 1205:111224:11 1225:211225:22 1231:141238:2,121243:25

says 1166:141175:1,4,5 1179:81179:9 1204:25

1205:6,16,19,251207:3,5 1217:251219:2,7

scam 1183:3scene 1186:8schedule 1209:8,10scheme 1152:4,22

1153:13 1155:71156:15,221157:2,4,11,14,191163:2,8,171184:3 1189:2,141194:17 1197:51209:18 1210:71211:3 1213:4,221213:23,24,251214:23 1220:231221:25 1234:5,71235:20 1242:221243:22 1245:111246:1

scherer 1129:12,141132:4 1133:31134:20,251135:1,8,211137:19 1138:171140:1,21,221141:12 1142:91142:11,161144:5,121146:20 1147:11147:19 1148:251149:16 1150:151152:10,16,181153:1 1154:8,161155:14,201156:20,251158:12 1159:101160:15 1168:31173:16,201175:20 1181:191183:23 1184:71184:10,13,17,201184:22 1186:121186:19 1187:71189:18 1190:41190:11,15

1191:11,141192:11 1194:131194:20,241195:18 1196:1,91197:13,191198:5,9 1199:51199:18,201200:22 1201:131201:21 1202:111203:16,18,22,251207:19,241208:2,20,22,251209:6,9,13,151213:1,8,121216:17,20,241217:5,10,241218:11 1219:51220:9,16 1221:21221:21 1222:11229:22,251230:4,8,11,13,211237:24 1238:3,91238:18,231239:9

scherers 1244:2,5schlesinger

1131:13,151137:16 1181:171183:22 1203:161203:20 1244:11

schmookler1130:15

school 1248:20scott 1127:8,13

1128:9,16 1129:11130:15,211132:2 1142:31143:18,19,221164:8,9,101205:12,131211:9 1222:141236:18 1237:21237:12

scotts 1205:13screen 1180:15screw 1212:17scum 1237:10,14

searches 1226:111227:21

searching 1227:231227:24

second 1143:171166:7 1175:201191:19 1192:161205:15 1222:201236:21

secretary 1169:25secure 1196:24see 1146:13

1147:25 1148:41151:24 1152:111152:12 1159:161159:24 1161:81162:7 1166:201168:12,131173:12 1174:11175:15 1176:9,91179:22 1193:21203:6 1205:241206:8 1207:8,101207:15 1217:121218:4,21,231219:1,6,9,241221:13 1223:101236:22

seeing 1146:11seen 1147:20

1150:8 1171:251205:23 1225:151238:1

seltzer 1146:171147:3 1149:5,111165:24 1166:241167:7 1170:1,3,51170:8,15,15,211171:9,18 1172:91172:23 1176:21179:4,4 1222:61222:18 1223:1,51223:11,11,14,151223:16,20,231224:6 1234:4

seltzers 1169:21,231169:24,25

1176:8semi 1200:9send 1167:4

1170:23 1201:251202:22 1218:11219:14,14,191221:22 1246:19

sending 1156:121218:12

sense 1174:17sent 1148:16

1167:5,6 1178:41219:8,151221:18

sentence 1242:1sentencing 1237:17

1237:18 1238:71238:20

senterfitt 1130:4september 1146:16

1147:14 1148:8,91148:10 1149:181150:17 1153:131155:4 1156:3,161157:19 1158:11165:23 1166:111168:15 1175:41185:19,20

series 1168:9serious 1134:24sertraline 1249:6serviced 1196:22

1196:23session 1127:12set 1142:24 1160:3

1231:1settle 1210:20settlement 1158:8

1158:20 1160:161163:7,13,131164:1 1189:21214:6 1215:181216:3,12

settlements 1158:51158:7 1160:3,101197:8 1213:15

settling 1200:6,7


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seven 1145:11severalhundred...

1246:1severe 1248:2,20sex 1244:3share 1230:21shared 1148:21sharp 1183:1sheer 1153:4sheriffs 1245:19shes 1151:4,22,24shirts 1227:1shorten 1167:16,17shortened 1208:7shorthand 1250:5

1251:4,9shot 1180:15show 1146:13

1147:7 1153:181156:7 1158:131158:25 1167:131173:14 1180:241213:9 1216:141236:13 1238:21239:5

showed 1147:231244:9

shower 1246:61247:7

showing 1236:16shows 1148:2

1173:1,25shred 1219:8,15shuffling 1222:22shut 1191:19

1192:16shuts 1227:17shy 1153:23

1195:12sic 1193:19sicking 1231:24side 1142:4 1186:1

1191:17 1192:141196:11 1212:111241:11

sideways 1143:14sigler 1188:17,18

sign 1164:101170:15 1172:9

signature 1139:11169:21 1174:14

silence 1156:14silent 1156:23

1195:20,20silverman 1131:2silversea 1216:11similar 1164:14

1186:25simony 1162:11

1186:25 1187:231188:6,20,211190:5 1191:121191:15,221192:9,12,191193:23 1194:151196:12,13,201199:22 1218:141218:20

simple 1164:191228:4

simply 1170:3singerman 1129:5singular 1234:11sir 1135:19

1137:14 1138:191139:10,19,241142:1 1145:221152:16,201154:6 1157:171157:23 1158:31158:24 1159:171159:21 1166:81167:12 1180:61180:18 1181:61181:11 1182:41182:15,17,211183:5,7,9 1184:11185:5,12 1187:21187:5 1188:51189:24 1190:31190:13 1194:111195:16 1197:121199:8,121201:11 1202:10

1203:4,8,111204:6 1210:241211:18,201212:20,221217:23 1218:5,81219:23 1220:251221:11,15,191222:16 1225:2,41225:7,13,16,201226:9 1227:8,121229:8,18,201230:15 1232:151232:17,19,241234:8 1235:211237:20,231239:11,221240:1 1241:7,181241:22 1242:2,71243:18 1246:81246:10 1248:7

sisterinlaw 1150:2sit 1143:20 1210:10

1213:2 1214:15sitting 1145:1

1149:1 1163:171176:23,231186:1,4 1225:241242:17

situation 1136:91151:4 1210:19

six 1131:10sixth 1130:21skiing 1170:5sleeping 1245:18sleeve 1171:1slightest 1224:2slow 1134:17

1179:22 1194:81198:25

small 1135:4smoke 1143:21smoked 1243:23

1244:6smoking 1244:21

1245:2sochet 1157:15

1162:2 1182:6,11

1182:12soil 1231:2somebody 1141:8

1147:23 1199:91199:24 1201:7

somewhat 1238:10son 1177:15,25soon 1216:20,22soontobe 1214:3soprano 1188:15sorry 1166:1

1223:22 1228:13sort 1133:9 1172:5sounds 1139:15south 1129:12,22

1130:17 1139:14southeast 1130:5speak 1161:14

1162:1,151212:11 1230:2,31230:7

speaker 1176:241207:25 1236:24

speakerphone1199:14

speaking 1162:141206:8

special 1183:211185:2 1196:23

specific 1143:101177:17 1182:71235:5

specifically1177:18 1189:41231:23 1239:41245:23

spectacle 1199:17speculate 1186:17speculation

1142:15spend 1242:17,23spent 1138:7

1228:9,151229:13 1235:41242:22

spiel 1160:18spinosa 1131:12

1181:7,14,201182:5 1193:191204:24,241205:10,14,171206:3,4,101207:14,14

spinosas 1184:2spoke 1161:23,24

1161:24,25,251162:1,3,5,9,101162:11,121177:16 1178:171178:20 1187:171187:23,231219:2 1224:251229:24 1230:3

spoken 1143:191230:1

sports 1134:141170:6

squeamish 1196:14st 1131:4,5staff 1243:5stage 1155:7

1182:23stamp 1217:16stamped 1147:12standing 1140:3star 1177:10start 1144:14

1161:19 1187:91187:11 1208:111249:11

started 1135:171149:5 1160:211194:8 1229:251247:12 1248:20

starting 1233:221248:12

state 1246:231250:3,12 1251:21251:22

statement 1163:141173:7 1199:7

statements 1180:41181:3,4 1186:5

states 1139:14


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1131:14stealing 1157:5stenotype 1251:6step 1170:13sterling 1187:19stettin 1128:19,20

1128:21steve 1201:15steven 1248:24stick 1180:22

1231:23sticks 1188:14,23stipulated 1203:20stolen 1153:5

1235:9,12stop 1151:3 1208:6

1208:11 1227:231244:11 1245:5

stopped 1230:25story 1138:2strategy 1187:21street 1127:18

1129:8 1130:211226:23

strike 1140:161167:23 1184:121184:14

strip 1196:21,24,24strokes 1166:20strong 1178:10structured 1129:20

1163:12 1216:3stuff 1170:18,19

1241:1subject 1161:7

1237:7 1239:19subpoena 1225:14

1225:15subsequent

1141:17 1177:13successful 1236:2,4successive 1174:11suit 1247:7suite 1129:3,6,9,21

1130:2,18

suits 1198:18summer 1185:20super 1190:6supposed 1188:1sure 1140:2

1143:15 1144:71144:20 1145:21154:20 1155:121164:4,6 1175:211176:17 1179:201204:15 1208:21208:14 1210:8,91211:4,12,141214:14 1217:101224:10 1231:151232:13 1237:61245:14

survived 1184:4susan 1129:23

1186:13suspected 1157:3,4

1157:5,8sw 1130:2swear 1165:20switch 1181:4switching 1222:4sworn 1177:8szafranski 1162:1

1193:13 1215:141216:5

szfranski 1162:101182:24

Tt 1130:8 1250:1,1

1251:1,1table 1176:24tables 1186:2

1222:4take 1135:3

1138:10,201140:8 1143:231152:3 1159:111170:20,201171:6 1177:141177:21 1182:161182:19 1203:18

1209:1,4,6,81210:17,181216:25 1217:41218:21 1224:171226:10 1236:231247:10,121249:7,11

taken 1127:16,221224:19

takes 1206:20talk 1137:11

1144:1 1151:31161:11,201163:6,12 1164:11165:16 1170:5,51170:15 1177:251178:15 1181:81185:6 1198:191230:22 1232:101239:17

talked 1138:241151:8 1161:5,211163:16,221167:3 1169:101172:25 1181:131193:9 1243:191243:25

talking 1134:111150:2 1170:3,41170:18 1185:31186:11,171190:8,181196:17 1201:231206:9 1238:81244:3 1248:13

talks 1151:8,13tampa 1131:5,6tanachio 1215:25

1216:9tanen 1129:21taylor 1215:1,5,19tcl 1217:17td 1128:16,21

1179:24 1183:111183:20 1184:2,31204:23 1239:16

ted 1140:5 1141:18

1141:21 1143:1,41143:8,11,12,181143:23 1145:21148:13,15,20,221150:16,241151:10,14,161152:2 1153:81154:12,13,18,221157:3 1158:4,61160:6,10,13,251161:5,11,231162:17,251163:3,25 1164:61164:22,241167:4,5,81168:13,19,23,241168:25 1169:201169:23 1170:1,11170:2,6,7,9,131170:14 1171:2,21171:7,8,12,16,171171:23,251172:3,6,81175:13,161176:1,5,6,7,151176:19,22,251177:5,7,15,16,171177:19,201178:13,15,15,181178:19,20,231179:2,8 1193:221223:11 1224:3

teds 1148:181165:3 1172:181177:8 1178:1

telephone 1139:201139:21 1141:41141:18,191145:10 1167:31176:17 1177:31182:10 1200:171205:9

television 1228:1,5tell 1136:5 1141:13

1148:6 1154:191156:8 1168:81174:10 1179:21

1181:20 1185:131186:24 1187:81188:12,241204:15 1205:121205:12 1207:61212:2,3,121213:1 1223:51230:17 1232:251233:3,9,121239:13

telling 1133:221135:7 1143:111151:16,221205:9,141212:10 1213:2

tells 1205:13,17ten 1159:16

1168:12 1207:211242:17

tenminute 1224:17tens 1181:25tentacles 1213:13

1214:16terrified 1200:18

1201:9terse 1178:5testified 1137:18

1138:5,241140:23 1149:221160:24 1161:41166:24 1178:151179:3,9,9 1180:4

testify 1137:221167:4,5 1175:161176:1 1225:241241:4,9,12

testifying 1137:131171:16 1186:161225:10 1226:2

testimonial1135:20

testimony 1135:101135:18,231138:20 1145:201147:2 1161:21167:11 1177:81177:15 1178:2


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thaler 1215:7thane 1186:2thank 1138:19

1140:21 1160:231166:4 1184:191216:8,8 1217:231222:1 1224:141243:13 1244:121246:22

thanks 1135:91137:15 1138:21

thats 1136:141137:24 1139:101147:25 1150:11153:15,25,251155:20 1159:181159:25 1160:51168:24 1169:61175:4,16 1178:61179:6,251183:13 1184:171188:22,241191:24 1192:211192:21 1194:101194:11,251203:11 1204:181213:6 1215:161220:13 1222:91226:25 1227:131235:4,15 1236:31236:6,9,111242:11,201249:6

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