2011-12-19 Rothstein Scott PM

Page 1
IN THE CIRCUIT COURT OF THE

17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO: 09-062943 07
RAZORBACK FUNDING, LLC, et al,
Plaintiffs,
vs.
SCOTT W. ROTHSTEIN, et al,
Defendants.
________________________________/
DAY 6 - P.M. SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN:
TIME:
PLACE:
Thursday, December 19, 2011

12:45 p.m. - 5:00 p.m.
James Lawrence King Federal
Justice Building
99 Northeast Fourth Street
Miami, Florida 33124
Examination of the witness taken before:
Terri Wright
United Reporting, Inc.
1218 Southeast Third Avenue
Fort Lauderdale, Florida 33316
(954)525-2221

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2
IN THE CIRCUIT COURT OF THE

17TH JUDICIAL CIRCUIT IN AND
FOR BROWARD COUNTY, FLORIDA
CASE NO:
EDWARD J. MORSE, CAROL A. MORSE,

and MORSE OPERATIONS, INC.,
10-2411 CACE (19)
5
Plaintiffs,
6
vs.
7
SCOTT W. ROTHSTEIN, et al,
8
9
Defendants.
________________________________/
10
11
AMY ADAMS, ET AL, PLAINTIFF VS. SCOTT ROTHSTEIN, ET AL.

CASE NO: 11-CV-61688-JIC/LSS
12
Case No:
10-03767 RBR
Case No:
10-03802-RBR
Case No:
11-02288-RBR
Case No:
11-02368-RBR
Case No:
11-02473-RBR
Case No:
11-02604-RBR
Case No:
11-02605-RBR
13
STETTIN VS. GIBRALTAR PRIVATE

BANK & TRUST CO.
14
STETTIN VS. CENTURION STRUCTURED
GROWTH LLC, ET AL.
15
16
STETTIN VS. FIDELITY CHARITABLE

GIFT FUND
17
18
STETTIN VS. TD BANK, N.A.
19
20
STETTIN VS. REGENT CAPITAL

PARTNERS, LLC ET AL
21
STETTIN VS. MAPLE LEAF DRILLING
PARTNERS, ET AL
22
23
STETTIN VS. DON KING PRODUCTIONS
24
25

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APPEARANCES FOR SCOTT ROTHSTEIN:

LAW OFFICE OF MARC S. NURIK
1 East Broward Boulevard
Suite 700
BY: MARC S. NURIK, ESQUIRE
APPEARANCES FOR THE CHAPTER 11 TRUSTEE,
HERBERT STETTIN:
6
7
8
BERGER SINGERMAN
350 East Las Olas Boulevard
Suite 1000
BY: CHARLES H. LICHTMAN,, ESQUIRE
9
APPEARANCES FOR THE TRUSTEE:
10
11
12
13
14
GENOVESE, JOBLOVE & BATTISTA, P.A.

100 S.E. 2nd Street
Suite 4400
By: JOHN. H. GENOVESE, ESQUIRE
DAVID C. CIMO, ESQUIRE
THERESA M.B. VAN VLIET, ESQUIRE
JESUS SUAREZ, ESQUIRE
ROBERT F. ELGIDELY, ESQUIRE
15
APPEARANCES FOR RAZORBACK:
16
17
18
19
20
21
22
CONRAD & SCHERER, LLP

633 South Federal Highway
Eighth Floor
By: WILLIAM R. SCHERER, ESQUIRE
ERIC RAYMAN, ESQUIRE
IVAN J. KOPAS, ESQUIRE
and
KOZYAK, TROPIN & THROCKMORTON, P.A.
2525 Ponce de Leon Boulevard
Ninth Floor
Coral Gables, Florida 33134
By: HARLEY S. TROPIN, ESQUIRE
23
24
25

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APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

CENTURION STRUCTURED GROWTH, LLC:
2
3
4
5
GOLDSTEIN, TANEN & TRENCH, P.A.

One Biscayne Tower, Suite 3700
Two South Biscayne Boulevard
By: SUSAN E. TRENCH, ESQUIRE
and
HARVEY WERBLOWSKY, ESQUIRE
6
APPEARANCES FOR LEVINSON'S JEWELERS:
7
8
9
KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL

200 SW 1st Ave
Suite 1200
BY: JAN ATLAS, ESQUIRE
10
11
12
13
14
15
16
17
18
APPEARANCES FOR THE COMMITTEE OF

UNSECURED CREDITORS:
AKERMAN, SENTERFITT
One Southeast Third Avenue
25th Floor
Miami, Florida 33131-1704
By: MICHAEL GOLDBERG, ESQUIRE
APPEARANCES FOR T.D. BANK:
GREENBERG TRAURIG, P.A.
401 E Las Olas Blvd Ste 2000
By: HOLLY SKOLNICK, ESQUIRE
DONNA EVANS, ESQUIRE
MARK P. SCHNAPP, ESQUIE
19
20
21
22
23
APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

COLUMBIA INC. & ZURICH INSURANCE:
CLAUSIN MILLER
One Chase Manhattan Plaza
39th Floor
New York, New York 10005
BY: SCOTT L. SCHMOOKLER, ESQUIRE
24
25

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APPEARANCES FOR FEDERAL INSURANCE COMPANY:

1430 South Dixie Highway
Suite 204
Coral Gables, Florida 331463127
By: ALEX HOFRICHTER, ESQUIRE
4
APPEARANCES FOR MORSE:
5
6
7
TRIPP SCOTT, P.A.

110 S.E. Sixth Street,15th Floor
By: JOHN M. MULLIN, ESQUIRE
GEORGE WALKER, ESQUIRE
8
9
10
11
12
13
14
15
APPEARANCES FOR CAROL MORSE, TED MORSE & MORSE

OPERATIONS:
LAW OFFICES OF ROBERTA DEUTSCH
2499 Glades Road
Suite 110
Boca Raton, Floridan 33431
By: ROBERTA M. DEUTSCH, ESQUIRE
APPEARANCES FOR EMESS CAPITAL, LLC:
KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL
201 S Biscayne Blvd Fl 17
BY: CASEY H. CUSICK, ESQUIRE
16
APPEARANCES FOR ST. PAUL FIRE & MARINE:
17
18
19
20
21
22
23
MILLS PASKERT DIVERS P.A.

100 N Tampa St Ste 2010
Tampa, Florida 336025145
BY: JOHN A. BLACK, JR., ESQUIRE
APPEARANCES FOR ROSANNE CARETSKY:
BILLING COCHRAN LYLES
515 E Las Olas Blvd
Floor Six
By: TUCKER CRAIG, ESQUIRE
DANIEL S. GELBER, ESQUIRE
24
25

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APPEARANCES FOR FEPICT, MS GROUP:

NYSTROM, BECKMAN & PARIS
One Marina Park Dr., 15th Flr.
Boston, MA 02210
By: JACK SEIGAL, ESQUIRE
4
APPEARANCES FOR MICHAEL SZANFRANKSI:
5
6
7
8
9
10
11
12
13
14
15
LYDECKER, DIAZ
1221 Brickell Avenue
Floor 19
BY: CHRISTOPHER G. BERGA, ESQUIRE
MIGUEL J. CHAMORRO, ESQUIRE
APPEARANCES FOR GIBRALTAR:
STEARNS WEAVER MILLER, et al.
150 W Flagler St Ste 2200
BY: MARY BARZEE-FLORES, ESQ.
MATTHEW DATES, ESQUIRE
APPEARANCES FOR FRANK PREVE:
PODHURST ORSEK
25 W Flagler St Ste 800
BY: RAMON A. RASCO, ESQUIRE
16
17
18
19
APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

WATCH U-WANT, INC.:
KOPELOWITZ OSTROW
200 SW 1st Ave Ste 1200
By: BART A. HOUSTON, ESQUIRE
20
APPEARANCES FOR THE US GOVERNMENT:
21
22
99 N.E. 4th Street

BY: LAWRENCE LAVECCHIO, ESQUIRE
23
24
25

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APPEARANCES FOR FRANK SPINOSA:

SCHLESINGER AND COTZEN, P.L.
799 Brickell Plz Ste 700
BY: MICHAEL J. SCHLESINGER, ESQUIRE and
MICHAEL COTZEN, ESQUIRE
and
SAMUEL J. RABIN, ESQUIRE
799 Brickell Plaza
Suite 606
7
8
9
10
11
12
EXAMINATION INDEX
13
PAGE
14
15
16
SCOTT W. ROTHSTEIN
DIRECT BY MR. RASCO
DIRECT BY MR. CRAIG
FURTHER DIRECT BY MR. GELBER
1545
1605
1681
17
18
19
20
21
22
23
24
25

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EXHIBIT INDEX
PAGE
PREVE'S
3
206
Binder of e-mails.
1548
207
E-mail dated 7/27/07.
1606
4
5
6
CARETSKY'S
7
208
Portion of the Third Amended Complaint.
209
Ira Sochet Answers & Objection.
1611
8
1616
9
10
11
210
ROTHSTEINS 001132-11315, Four Still Shots
from TD Bank.
211
TD/Razor 001855-1860, E-mail dated
10/29/08.
1631
1635
13
212
TD/Razor 001841-1851, E-mail dated
12/17/08.
14
213
1650
15
214
1662
16
215
1665
17
216
Trustee/Spinosa 000422-423, E-mail dated
9/17/09.
1624
12
1666
18
217
1668
218
PRODA 018604, Letter dated 10/29/2008.
219
TD/Razor 001863, Letter dated 12/10/2008.
220
12/17 Investor Meeting.
19
1683
20
1686
21
1690
22
23
24
221
Page 30 of Scott Rothsteins's deposition
taken 12/13/2011.
222
Page 1181 and 1182 of Scott Rothstein's
deposition taken 12/16/2011.
1703
1703
25

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DIRECT EXAMINATION
BY MR. RASCO:
Q
Back on the record.
I'm going to mark as
Composite Exhibit 206 the whole binder that I've handed
to you, including all the e-mails you signed.
sure?
Do you want to put a label on it just to make
I think we already did it on one of them or we
can label that one.
10
11
(Whereupon, Preve's Exhibit No. 206 was marked
12
13
14
15
Whatever your preference.
for identification.)
BY MR. RASCO:
Q
So, the last e-mail that we were discussing was
in Tab One?
16
Yes.
17
The "sit tight" e-mail from October 31, 2009.
18
And my question is brief, it's just the second paragraph
19
of Frank's e-mail to you, the last one from the top
20
says:
21
Yes, sir.
22
Do you recall if Frank Preve did indeed call
23
24
25
I will call in 10 minutes.
you 10 minutes after that e-mail?

A
My recollection is is that he may have, but my
recollection is also that I never had a conversation

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with him.
3
4
5
6
7
You don't recall having a conversation with
either him or George Levin while you were in Morocco?

A
I don't have any specific recollection of
talking to them.
Q
No phone calls while you were there, just
e-mails and text messages?
Just e-mails and text messages.
If you go back to the beginning of Tab One, the
10
second e-mail there is titled "me and you"?
11
Yes, sir.
12
And it's the October 30, 2009 e-mail.
13
states:
14
only by me.
15
as it seems, I love you.
16
to me and I let you down.
17
All my love, forever, Scott.
It
I am at the lowest point in my life, caused

Just know as F'd up as I am and as F'd up
You have been a true brother
I can never be sorry enough.
Do you recall this e-mail?
18
19
I do.
20
Were you being sincere when you wrote that
21
e-mail?
22
Yes.
23
So, what are you sorry for?
24
I let the entire Ponzi scheme blow up.
25
And what do you mean by him being a true

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brother to you?
A
He was -- I mean, if you look at all the e-mail
traffic you can tell that other than Debra he was
probably the person closest to me in the entire Ponzi
scheme.
us, at least that's what I was led to believe during the
course of our relationship.
a real relationship.
9
10
11
I mean, it was very little that stood between
I thought we had developed
Did you have any cause to doubt this at any
time in your relationship with Frank Preve?

A
No, not during the course of it.
You know,
12
afterwards, hindsight is always 20/20 when you are privy
13
to e-mails afterwards between other people.
14
simple thing as thinking someone is on board with
15
something like the Ari Glass thing, not knowing where
16
his head was and then learning afterwards by reading
17
e-mails and hearing things that he was actually trying
18
to play me.
19
It's a
The truth is, you never really know who's
20
involved in fraud and at what level until you get to
21
look at everything.
22
23
Are you suggesting that Frank Preve was trying
to play you?
24
No.
25
Okay.

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No.
I mean to some extent.
Listen, on the
business level, even an illegal business level of what
we were doing we were all playing each other.
what happens in a fraud, I mean, especially a fraud of
this magnitude.
That's
Szafranski is the perfect example.
When I read his e-mails after I got done, after
I came back and I was in the middle of cooperating and
read e-mails, he's adding things to this Ponzi scheme
that I didn't tell him to add.
He just decided, I
10
suspect, that they were good sales techniques for him.
11
He's lying about being the only person selected by the
12
bar to review these files and talking about his ability
13
to look at things.
14
and doing whatever it takes to bring in investors.
15
16
17
18
19
He's just kind of running with it
And so you see those kind of things.
So
everyone is really playing everybody.

Q
During the course of the Ponzi, do you know if
Frank Preve ever lied to you?

A
I'm pretty sure he did.
I mean, I don't have
20
the specific lies he told me.
21
e-mails and we compare them to what was going on behind
22
the scenes, again, hindsight is 20/20.
23
where he sent an e-mail to me and then forwarded it
24
surreptitiously to somebody else with a comment on it
25
contrary to what he told me.
If you pull out all the
Now I'm seeing

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Yes, that happened from time to time.
again, in a fraud of this magnitude, I mean, you have to
understand that when you're dealing with people who are
lying at the get-go people also tend, fortunately or
unfortunately depending on how you look at it, to lie to
each other.
7
8
9
But,
It's just what happens.
As you sit here today do you recall a specific
instance where Frank Preve lied to you?

A
Let me think about it for a second.
You're
10
asking me to rehash years and thousands and thousands of
11
e-mails and a specific sentence.
12
13
I understand.
I don't have a specific e-mail
about it, just asking your recollection.
14
If I run across one I'll let you know.
15
Turning a little further down Tab One to a
16
November 1, 2009 e-mail from Frank Preve to Frank
17
Spinosa.
18
Yes.
19
The subject is R.A.A. trust accounts.
It has some account numbers in it.
It
20
states:
Frank, I'm a little concerned about Scott's
21
well-being at the moment and how that might impact the
22
integrity of the trust accounts whose proceeds have been
23
assigned to Banyon.
24
housekeeping, I think you ought to flag any unusual
25
activity in the following accounts.
Just for the sake of good
He lists them and I

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will have our legal counsel contact you shortly.

You never saw this e-mail, I take it?
2
3
Only after the Ponzi scheme exploded.
And the statement that he makes about the
integrity of the trust accounts, do you disagree with
this statement about him being concerned about the
integrity of the trust accounts?
8
9
I wasn't privy to this e-mail.
what he was honestly concerned about.
I don't know
I think he's
10
writing an e-mail to Spinosa to stop me from taking any
11
more money out of the accounts.
12
would just be guessing.
13
Okay.
Other than that, I
Moving a little further down there we
14
talked about the "sit tight" e-mail that had Exhibit A
15
on the front of it?
16
Right.
17
The following one has Exhibit B.
18
Sure.
19
And there's an e-mail right after, you know,
20
lower down on that first page, there's the one you said
21
you explained to him that's not the shortage.
22
above that Frank responds to you - it's a November 1,
23
2008 e-mail:
24
tight:"
25
simply because of his lack of knowledge he wasn't very
Right
As you know - and the subject is "sit
As you know we met with Mark last night but

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helpful.
In your opinion, do the investors have much of
a case against TD Bank given lock letters, balance
reports, et cetera.
everyone this morning.
Just trying to give direction to

Hope to see you soon.
I know you've already testified to a certain
5
6
extent about this e-mail, but my first question is:
Frank the first person that you're aware of that
suggested the possibility of a case against TD Bank?
To the best of my recollection, yes.
10
Did you have additional follow-up
Was
11
correspondence and e-mails and text messages regarding
12
the possibility of a case against TD Bank?
13
I don't have any specific recollection, other
14
than if you have some e-mails that would refresh my
15
recollection, but I don't recall writing to him very
16
much more.
17
believe, after I returned on the 2nd or the 3rd.
18
Certainly I didn't write to him, I don't
Right.
So, on November 1st, the one -- you did
19
respond though, right above it stating:
20
have a case.
21
we meet Tuesday afternoon around three?
22
never occurred, right?
Yes, they do
I will explain how when I get back.
Can
That meeting
23
No, sir, it never occurred.
24
And did you ever explain to him at a later date
25
after that e-mail was sent, what case he had against TD

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Bank?
No, sir.
Do you recall sending a text message while you
were in Morocco to both George and Frank indicating that
you had just completed a list of info that they need to
go after TD Bank?
7
8
9
It's very possible that I did.
If you have a
copy of it, it would help.

Q
Just assuming that that's what it said, that
10
I've completed a list of what's needed to go after TD
11
Bank .
12
Does that sound familiar to you?

I can't -- I may have, I may not have.
You're
13
asking me to assume something, without seeing it I can't
14
tell you for certain.
I need to see it.
15
Okay.
You don't independently recall?
16
I don't have an independent recollection, no.
17
But it's not a possibility you rule out?
18
I don't rule it out.
19
The next e-mail after that Exhibit B is the
20
November 3rd, exchange between George Levin and Howard
21
Gruverman.
22
that you had confirmed that he had an accomplice at TD
23
Bank.
24
25
The 10:33 p.m. e-mail from George indicates
Do you recall in what manner you would have

informed George of that?

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The only thing that I recall writing to George
and Frank about at as I sit here today is that e-mail we
just looked at.
more of it, I would need to see the text message to tell
you.
If I sent a text message detailing any
You don't recall a specific conversation or
anything like that where you may have indicated to
George or Frank that you had an accomplice at TD Bank?
10
them.
11
I remember them being on the list of people that I just
12
did not want to speak to.
There wasn't one.
I don't recall speaking to
As a matter of fact, I recall just the opposite.
When I say list, mental list.
13
Why were they on that list?
14
I don't really know, but in my head I didn't
15
want to speak to them.
16
terrible frame of mind and I did not.
17
18
19
20
I just didn't.
I was in a
Do you recall the last time you spoke to either
George or Frank over the phone?

A
To the best of my recollection it was before I
left for Morocco.
21
Do you recall either conversation with the
22
specifics?
23
At this moment I do not.
24
If you can turn to Tab Two, please.
25
Okay.

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It's six pages in, Tab Two, this is the e-mail
we were discussing earlier.
said it was April 29th and I was looking for April 29th,
but it was an April 20th e-mail from you to Frank with a
subject being, Centurion.
few, I'm working on another bar response from Adria so I
can continue this farce.
And it states:
Give me a
You had indicated on Friday in your testimony
8
9
I didn't -- the transcript
that that was an indication to you that Frank by that
10
time knew that the bar thing was something you had made
11
up; is that right?
12
It was one of many indicators.
13
Okay.
14
15
16
17
And the farce that you're referring to
in that e-mail is the Ponzi scheme generally?

A
No, I think the farce I'm referring to is the
nonsense with the bar that didn't exist.

Q
Did you ever have a conversation with Frank
18
telling him that Adria wasn't a real person, that you
19
weren't actually meeting with Adria?
20
I didn't have a conversation specifically
21
saying -- well, first of all I never would have said
22
Adria wasn't a real person because she was a real
23
person.
24
kind of business.
25
I just wasn't doing business with her, not this
I had conversations with Mr. Preve regarding --

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I don't know the best way to really relate this to you.
I never said to Frank the bar thing is a scam.
along after the beginning of it we were kind of in the
middle of it, I knew that Frank knew it was a scam.
All
Because you have to understand when Frank, and
here's how you measure this, when Frank really wants
something he didn't know; in other words, he is really
chasing a piece of information, the man is far from
stupid, he knows how to get it.
10
He knows there are all
kinds of ways.
11
He joked around with me from time to time on,
12
do you think we're ever going to be able to produce any
13
letters about this bar thing to anyone?
14
know.
15
That was a conversation?
16
Yeah.
17
I said no, you
He also told me he spoke to George and
then speaking to a guy name Mac Melville or Melvin.
18
Yeah.
19
And that Mac wanted to speak to the bar and Mac
20
wanted to jump in.
21
we're not getting anyone else involved.
22
25
I mean,
Well, hold on a second.

Go ahead, you can finish.
23
24
And I said absolutely not.
Go ahead.
That's really the end of the
conversation.

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Q
Okay.
But based on the various indicators,
some of which we've discussed, I'd say middle 2009 or
April of 2009 Frank knows the bar thing is not real?
By April of 2009?
Yeah.
Yes, Frank, I'm confident, knew it was not
real.
Based on the --
I don't know what he was telling George.
10
Based on the indicators that we've discussed so
11
12
far?
A
Just based upon his overall knowledge of
13
everything and the fact that he didn't push me for
14
information that would have disclosed whether or not it
15
was or was not real and he just kind of played along
16
with it.
17
Okay.
18
Yes.
19
context.
20
sit here today, I don't have a specific recollection of
21
saying the bar thing is a scam.
22
I did during the course of the conversation, but I just
23
don't have, as I sit here with so much in my brain, I
24
just don't have a specific recollection.
25
You have to take the whole thing in
You can't take individual pieces out.
Okay.
As I
It's very possible that
If you could turn - it's quite a few

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pages in - November, sorry, September 22nd, 2009
e-mail.
Same tab?
Same tab, yeah.
the fan".
That's descriptive.
You joked around a lot in your e-mails with
The subject is, "the shit hit
I got it.
Frank, is that fair?
We joked around all the time.
10
Both of you did.
11
With a lot of underlying truthfulness in it.
12
The second page by the bottom e-mail, it's the
13
page marked, FP112310.
14
the e-mail is September 22, 2009, you to Frank:
15
Bro, but I walked into a shit storm of insane magnitude
16
this morning.
17
auditors and they were all over me about the
18
inconsistent funding and they were contemplating
19
shutting me down on the deal funding.
22
The subject is -Sorry,
Adria was waiting for me with two
Why would you send an e-mail like that to Frank
20
21
You state:
if you he knew that it was not a real thing?

A
I sent a lot of e-mails to Frank that were
23
meant for other's eyes.
24
Frank that Frank and I had discussed some of them and
25
some I just sent gratuitously.
I sent a lot of e-mails to
I sent a lot of e-mails

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to Frank that I assumed that he would be passing on to
others who were asking a lot of questions.
Including George Levin; correct?
Very possibly George, yes.
The next one says, Frank says:
have to ask for a meeting with the bar.
Broward or Tallahassee?
We're going to
And then you respond that you're going to set
8
9
Should it be
up a conference call with Adria and her boss.

And then Frank mentions Mac.
10
He says:
Can we
11
have Mac Melvin, George's litigator, on the conference
12
call?
Then your response is:
13
Not really a great idea
14
but if you think it will help, sure.
15
not.
I take it it's fair to say you were bluffing
16
17
Don't see why
there?
18
Yes.
19
Do you think Frank --
20
Bluffing for people other than Frank.
I mean,
21
at this stage it's pretty clear to me that, again, you
22
have to put everything in context, there's clearly a
23
massive fraud going on that Frank is clearly aware of.
24
Go back and look at the e-mails.
25
At this time - and you can see it develops into

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all of a sudden exactly what I thought could happen is
happening, Frank is sending this to George.
way the e-mail traffic works the second you put George's
name on the CC all the prior e-mails go to him.
Because the
So, it gives George a picture of, I suspect,
the picture that Frank wanted to paint for George or
that Frank wanted to paint for the hedge funds, that I
wanted to paint for the hedge funds.
9
10
11
Would this be something that would give comfort
to both George and Frank?

A
Give comfort to Frank?
I don't think anything
12
was going to give comfort to Frank at this stage.
13
in September and I'm scrambling for huge money.
14
We're
Then you do respond -- Sorry, then Frank
15
responds, CCing George:
16
pulls this BS about the accounts not being blocked.
17
how she has no nexus to us as the assigned beneficiary
18
of the matured funds.
19
We need an attorney when she
And then you -- sorry, George responds:
20
we don't need Mac.
21
her then we might or might not need Mac?
22
Or
Frank,
What we need is a face-to-face with
By this time, the conference call, the
23
conference call with Adria where there were certain
24
members from the hedge fund group present in your
25
office; do you recall that?
That was from April.

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Yes.
And Frank and George were both present, right?
I don't recall who was present.
You don't recall whether either of them was
present?
I don't recall who was present.
You do know some of the hedge fund guys were
8
9
there?
A
10
11
12
13
I do recall that, yes.

I think at least Frank was on the call.
Okay.
Do you know if he was in your office or
was he on the call itself?

A
You know, I don't recall one way or the other.
14
I recall originating the call from my office, but I
15
don't recall where all the players were.
16
17
And who was the person that was acting as
Adria?
18
That, I don't remember.
19
You don't remember?
20
Was it somebody in your
office?
21
Oh, yes.
22
But you don't remember specifically the name of
23
24
25
the person?
A
For some reason I do not remember.
It was a
female, more likely than that a lawyer, but I don't

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1
2
remember who it was.

Q
Is that the only call like that that you had
with that person who was pretending to be Adria
Quintela?
To my recollection, yes.
When somebody walked into your office was there
a sign-in sheet?
No.
There wasn't a sign-in sheet at your office at
10
the front desk?
11
No.
12
Was there one downstairs in the lobby of the
13
building where your office was located?
14
No.
15
Anything that would indicate and create any
16
sort of paper trail about when somebody went to your
17
office and didn't go to your office other than the
18
e-mails you would get from your secretary or somebody
19
waiting for you in the lobby?
20
21
Other than the surveillance video that might
have existed, no.
22
Does that still exist?
23
I have no idea.
24
Do you know how long the tapes would be
25
recorded on the surveillance video?

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I don't know anything about it.
I heard at one
point in time that our surveillance video was saved,
then I heard at another point in time it erases over
every few days.
5
6
I don't have a clue.
You haven't looked at it since you came back
from Morocco?
I hadn't even looked at it when I was there.
Is that something you had installed yourself,
the surveillance video in your office?
10
I don't know what you mean by myself.
11
I mean, not yourself, at your direction?
12
I'm the one who wanted surveillance in the
13
14
15
16
17
18
office, yes.
Q
You indicated that it was dozens of times that
Frank Preve came to your office; is that right?

A
There were, there were dozens of times that
Frank came to my office.

Q
Dozens.
And in one of those visits it became clear to
19
him that there were no settlements, he looked at
20
unredacted documents.
21
I never said it was during one of those visits.
22
It was a meeting in your office?
23
No.
24
25
You're thinking about me showing him the
unredacted documents.
Q
Right.
That's what I'm asking about.

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1
2
3
4
5
One thing has nothing to do with the other.
It's just another little notch of the many.

Q
So, was Frank aware that there weren't any
actual settlements?
A
At some point in time, yes.
All you have to do
is look at the e-mail traffic to realize that he knew
these people didn't exist.
8
9
Do you know -- did you -- can you give me a
little -- I understand what you're saying, can you give
10
me a little more specificity when he was aware there
11
were no settlements?
12
When?
13
Yes.
14
No.
15
Okay.
16
Sometime in '08.
17
Okay.
18
Maybe before that.
19
You don't recall what the number was --
20
Now that I'm thinking about it, here's the
21
thing with Frank, as I'm recalling his e-mail traffic
22
with me, if you look at it, there are points in time
23
where it's clear to me, and I think clear to anyone
24
reading it, that he was a player.
25
fooling around with things, just a legitimate investment
Okay, because he's

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guy just does not mess around with, balances and things
are a little wishy-washy, he's skating on the due
diligence, saying things like, I just need to make it
look like I'm doing due diligence.
on.
That's fairly early
So, it would be - as you go through that and
you could see things escalating, you should be able to
pinpoint a time when it's clear, maybe not the day he
knew, but certainly within the 30- or 60-day time frame
10
that he knew that there was a massive fraud going on
11
because things just made no sense.
12
And then you take out - if you make a list for
13
yourself of what you would do if you were investing
14
money, which is one of the things I did when I was
15
evaluating people on whether they would come into the
16
fraud or not - and did they ask for things.
17
difference between, for example, of the AJ Discala group
18
and the Clockwork people were asking for and as opposed
19
to what Frank asked for.
20
no comparison.
21
22
diligence?
23
Look at the
It's night and day.
There's
Are you saying that Frank didn't conduct due
Didn't conduct thorough due diligence.
He of
24
all people, because of his closeness to the law firm,
25
should have had access if he wanted it to more telling

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documentation than anyone else and they did very
little.
In the beginning they talked to me about it.
And other than -- after that they basically rode on
other people's due diligence.
of things that he could have asked me for, if he didn't
know what was going on, that would have exposed the
entire thing, something as simple as a paper bank
statement.
I mean, there were a lot
10
Wasn't he getting bank statements?
11
No, sir, he was getting photocopies and scans
12
of screen shots.
13
never asked me for one, and it was one of my big
14
indicators.
15
been very difficult for me to duplicate, and I talked to
16
Mr. Renie and Corte about it, is the bank paper.
17
Because the way the bank has that paper, the way it
18
looks and everything, all he had to do was say, let me
19
just see the last 10 months, the last two months, the
20
last three months, bank statements, I couldn't produce
21
that.
22
23
He never asked me for - early on,
Because one of the things that would have
Did Frank ever ask you to take him on a bank
visit?
24
I don't know if I ever took Frank.
25
Did he ever ask you about the bank visits that

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you did go on?
Only to ask me how they went.
And is it fair to say that Frank was concerned
and interested in learning -- let me rephrase that.

Is it fair to say that Frank asked about other
5
6
due diligence conducted by third parties such as the
hedge funds or Szafranski on a regular basis?
8
9
Not in the way that you're intimating.
He
asked more frequently than not with regard to how it
10
went.
11
earlier when he was saying in his testimony - I think we
12
were discussing this before lunch - about him saying
13
that he knew nothing about me going to see those
14
lawyers.
15
It's kind of like what we were talking about
But in reading your packet I found an e-mail
16
where he is actually writing to Brian Jedwab saying to
17
him, you came down here, you did all this due diligence,
18
you went to see several referral sources.
19
Now, if Frank isn't lying in his testimony,
20
then you have to believe he did no due diligence in that
21
regard, but he could have very easily asked me, who are
22
the referral sources you went to see.
23
If I take it the way you're painting this, he
24
didn't ask me that, when I know he did and it makes only
25
sense that he would have.

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Wasn't he asking for the results of their due
diligence?
Wasn't he looking to see what they produced?
Think about how telling this is.
He's only
asking Brian Jedwab in that e-mail, he doesn't send me
an e-mail because I've already told him if he didn't
know at that point in time how it went, really knew, if
he didn't know that I had gone and it was all a fraud
and that I thought it went well, when he writes to Brian
and Brian doesn't give him anything, how about just
10
writing to me and saying, Scott, I want to know who the
11
heck you guys met with; Scott, I want to know what was
12
said; Scott, I want to know how it went out, I can't get
13
this information from the hedge funds.
14
knew so he's not asking.
But he already
15
Did you always respond to Frank's e-mails?
16
Always is a big word.
I tried to respond to
17
his e-mails as best as I could.
18
me if it was something I considered ultrasensitive I
19
would call him.
20
Sometimes when he wrote
Now that we're talking about it, I forget
21
exactly -- here it is, it's the Jedwab e-mail, it's at
22
Tab Four, dated January 27, 2009.
23
Got it.
24
He's saying in the third sentence, I'm sorry I
25
can't read it.

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Second sentence:
You will recall that we
stopped all the lending activity because
Centurion/Platinum had not done a thorough due
diligence.
reviewing intake procedures, speaking to referral
sources, et cetera, and evidently came away satisfied.
Ari and you then spent two or three days
Do you know if he's basing that on the
conversation you had with him or on a conversation that
he had with Ari?
10
I would be guessing and I don't want to guess.
11
But you did call him from one of those
12
attorneys' offices to tell him everything was going
13
fine?
14
I may have called him.
You'd have to look at
15
my cell phone records and the office records from the
16
various places, but my recollection is that I called him
17
more than once as the day was progressing.
18
19
20
And do you know if Frank considered the hedge
fund guys to be sophisticated investors?

A
I think he considered most of them to be
21
sophisticated.
22
have some that are sophisticated and some that are not.
23
I think as with any organization you
Let's go back to Tab Three, beginning of Tab
24
Three, there's a variety of e-mails here that I want to
25
go through.
The first one is April 13, 2009 e-mail.

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Is it the first page?
It's the first page, yes.
Okay.
The title is:
Frank says:
"Be careful".
George knows nothing about Regent.
And then you respond:
And it's April --
Sorry, I did not think I
sent anything to you regarding them.
with the bar, so I'm a big upset right now.

Do you know if Frank and you regularly kept
9
10
I am on the phone
things from George Levin?
11
I believe we did, yes.
12
And is it fair to say that there's probably
13
quite a few e-mails indicating that George Preve was
14
unaware of certain things that you and Frank
15
acknowledged that George Levin was being kept in the
16
dark on certain things?
17
I believe so, yes.
18
And did you indicate earlier in your testimony,
19
I think on Friday or actually earlier last week, that
20
George was monitoring Frank Preve's e-mails?
21
What I said was, I believe that George had
22
access to the e-mails.
23
I had access to all of my employees' e-mails, did I read
24
them, no.
25
looking at his e-mails, there were times when I was
Now, I'll give you an example.
Too much traffic.
George may have been

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having conversations with George that he just seemed to
be divining things that he couldn't otherwise know.
3
4
But do I know for a fact that he actually read

the e-mails, no, I don't.
There were certainly times when Frank
intentionally copied him on things and then later on I
saw e-mails, after the Ponzi exploded, where it was
clear that Frank was sending him things.
know what he knew or what he didn't know.
So, I don't
He certainly
10
wrote a lot of e-mails, George, that indicated he didn't
11
know.
12
That he did not know?
13
That he did not know certain things.
14
The e-mail that you responded -- the April 13th
15
e-mail where you respond to Frank:
Sorry, I did not
16
think I sent anything to you regarding them and I am the
17
on the phone with the bar so I am a bit upset right
18
now.
19
Yes.
20
Who did you intend for that to be seen by other
21
than Frank?
22
I didn't know who was going to see it.
23
But at that point you thought there was a
24
25
possibility that George could see it?

A
I think all along I thought that Frank might

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send things to George or George might look.
look at the bar thing, you have to get inside my head to
do this, okay.
that bar thing up to the hilt the entire time this was
going on.
But if you
If you look at the bar thing, I played
Initially, I wanted to be believed.
Later on
with Frank I couldn't have cared less whether he
believed it or not.
believe it, okay.
After that I was sure he didn't

It was just one of the ministrations
10
going on at the time.
11
money out initially to them and then ultimately to the
12
hedge funds because I was spending too much of the money
13
we were taking into the scam.
14
It was my reason for not paying
So, there's a lot that goes into it.
You can't
15
take one e-mail out of thousands and try to read
16
something into it.
17
You won't get the proper context.
There was questioning on Friday relating to the
18
fake judicial order that was drafted in your office and
19
I believe Mr. Scherer talked about the metadata.
20
don't have any evidence like that that George was
21
looking at Frank's e-mails when you see the metadata -
22
you didn't see any metadata, anything like that, since
23
you've come back from Morocco?
24
No, sir.
25
I'm asking.
You
So, what I want to know is whether

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you know for a fact that George was looking at Frank's
e-mails?
I believe I already told you no.
I don't know
that for a fact.
Okay.
Did you -- you met in August with --
You know, while I'm thinking about this, one of
the other things that always, I guess, led me to believe
that he might have access to it, and this is the flip
side of it, is that when Frank did certain things to me
10
he wrote to me on that gsteinbauch e-mail.
11
imagine - unless he believed that someone had access to
12
his fpreve e-mails why he would use that for certain
13
nefarious transactions.
14
Now, I can't
But again, I really don't know, you know,
15
there's a lot of e-mails there, sir, that indicate to me
16
that George did not know what was going on at various
17
levels, it's still a question in my mind.
18
The fpreve e-mail is an AOL account; right?
19
Yes.
20
And do you know if that was on the Banyon
21
network?
22
You're asking the wrong guy, no.
23
When you met in August with the Trustee, is
24
that something that you indicated to the Trustee's
25
Counsel as to George's potential ability to have been

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reviewing Frank's e-mails?
I have no idea.
You don't recall one way or the other?
I don't recall one way or the other.
If you go further down that same tab.
Yes.
A September 30, e-mail 2009, 11:42 am, from
8
9
Frank to you.
A
10
What time?
11
MR. SCHERER:
Q
It's probably the --
12
13
Where are we, Counsel?
MR. SCHERER:
Q
Tab Three?
Tab Three, it's a few pages from the back.
14
September 30, 2009 e-mail.
15
0112310-0189124/1.
The Bates is
Subject is a new Banyon.
16
Got it.
17
Did you suggest to Frank that a lock letter
18
could be provided on certain Banyon accounts, trust
19
accounts?
20
It came up in conversation.
I don't know if I
21
suggested it to him or we had just talked about the fact
22
that I was utilizing it with other investors.
23
But that's something that you generally, you
24
testified earlier, did not offer to most people or did
25
not want to offer to most people?

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I tried not to.
Personally I tried not to have
to use it because it was, I believed, a strain on Frank
Spinosa and what was going on with him, so I tried not
to but where people wanted it I put it into play.
Would it be fair to say that Frank and George
wanted a lock letter for their Banyon related trust
accounts?
At some point in time Frank asked me for a lock
letter for various accounts.
10
Okay.
Okay.
11
Frank knew it wasn't going to do anything but I
12
guess for paper purposes and for audit purposes when
13
other people were looking at it I suspect that was
14
something good to have.
15
Did you have a specific conversation with Frank
16
about the lock letters where you indicated that he knew
17
that it wasn't going to have any real effect?
18
I think I testified earlier, I don't know if it
19
was last week or earlier with you, but I believe I
20
testified earlier that Frank was one of the people that
21
told me that with all his banking, it's the craziest
22
thing he's ever heard simply because of the wire
23
transfer capabilities.
24
25
bit more?
What do you mean, can you explain that a little

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Yes.
The lock letter professed to lock this
account so that the funds would be specifically sent to
a specific place when only requested by me or Stuart
Rosenfeldt.
5
6
7
That was crazy.
You want to know why?
That was crazy because of the ability to get on
it on-line?
A
That was crazy number one because in a wire
system, the way Treasury Direct works, as long as I give
that little - I used to call it the magic decoder ring,
10
that little T file that gives you the different security
11
numbers, anyone that had our TD Bank sign-on and had
12
that little decoder thing, could go in and wire
13
anything.
14
As a matter of fact, the bulk of the time -
15
actually all of the time, neither Stu nor I, I don't
16
think ever initiated a wire.
17
entire time we were doing this.
18
were never initiated by Stu or I, they were initiated by
19
Irene who had the decoder thing or by Bill Boockvor, who
20
had the decoder thing.
Maybe one or two in the

So, the bulk of them
21
Did you have this conversation with Frank?
22
That in depth?
23
No, not in that depth, but about his knowing
24
25
that the lock letters did not have any real effect?
A
I recall conversations with Frank where he was,

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for lack of a better term, he was saying to me, What is
this cockamamie lock letter thing you guys were talking
about.
I explained it to him.
I mean, even if you
look at -- It's clear if you look at Mr. Spinosa's
e-mails with Ms. Caretsky and Mr. Mejia and all those
people, you can see that they didn't even know what the
heck to do.
e-mail sent that says, This needs to be restricted to
Because at one point in time there's an
10
transfers only made by Scott.
11
someone else tries to transfer the money out of here,
12
you should notify Scott.
13
And then it says, If
There's all kinds of different entries.
14
There's nothing consistent.
15
no process to do this actual thing.
And the reason is there was
16
Okay.
17
It's just like the dual signature thing.
If
18
you look at some of them from Preve, I remember seeing
19
an e-mail recently where Mr. Preve is sending an e-mail
20
to some other due diligence person, and they're saying,
21
I hope I never hear this out of Scott's mouth.
22
And it was about some big fraud where an
23
attorney had stolen a bunch of money out of trust
24
accounts.
25
person's inquiring about this is, That's why we require
And Frank's response to that due diligence

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dual signatures.
2
3
There are no dual signatures.

signatures on anything.
Q
4
5
There are no
Do you recall what due diligence person that
was?
Jim something.
Who is he?
I have no idea, just some due diligence person
Headman?
I can get it for you.
they were working with.
10
A potential investor?
11
Either a potential investor or one of the many
12
13
14
different funds Frank was talking to.

Q
Okay.
If you turn two pages from the e-mail
that we were just looking at.
15
Two pages forward?
16
Two pages forward, yeah, towards Tab Four.
17
There's an e-mail there from you dated September 30,
18
2009, to Frank and --
19
What's the time.
20
The time is 10:12 a.m.
21
01?
22
01 a.m., exactly
23
Got it.
24
On the second paragraph it says:
25
into completing what needs to be completed.
Debra is well
I am

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sitting here papering deals myself for the 40 million as
she's having a biopsy today.
Do you recall if Debra was actually having a
3
4
5
biopsy that day?

A
There were many, many occasions where Debra was
out on medical visits.
problematic medical issues.
8
9
10
She will be in later.
She had some very real
You weren't actually papering any deals that
day, though, were you?

A
Oh, no.
I actually may have been inserting
11
information and getting it as ready as I could for her,
12
sure.
13
14
Do you recall specifically on that day whether
you were papering?
15
I have no clue.
16
Did you ever make up excuses for Debra for lack
17
of papering?
18
Sure.
19
To Frank and George?
20
To Frank, to George, to just about everyone
21
involved in this, yes.
22
Can you turn to Tab Five, please.
23
Okay.
24
And I'm looking at, it's the fourth e-mail in
25
there, January 11, 2009, an 11:11 a.m. e-mail from

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Frank.
Tab Five?
Yes, Tab Five.
I have one e-mail and a bunch of invoices.
No, that's Tab Six.
I have no Tab Six.
I'm sorry.
MS. TRENCH:
10
12
13
I apologize.
I was
reading the 5 as a 6.
11
Tab Four.
I'm sorry.
MR. RASCO:
Can we have the date?

It's January 11, 2009, 11:11 a.m.
BY MR. RASCO:
Q
And there's a table on it with trust balances
on it.
14
Yes.
15
Okay.
You were talking earlier about an
16
indication that Frank knew that there were trust
17
issues.
18
where there was a significant amount of money that was
19
not in one of the trust accounts?
20
Was this the e-mail you were talking about
It's not the one I was addressing.
It's
21
another one.
22
earlier.
23
I was addressing earlier was one where he said, This is
24
impossible.
25
It's not the one I was addressing
It is pertaining to the same account.
The one
Okay.

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This is similar.
The 9146 account?
That's the best of my recollection.
You did mention that this morning, so that was
the other one then, the "This is impossible" e-mail,
which I don't have here with me.
Yes.
There's an e-mail where it's a more
significant shortage.
This only appears to be a
$35 million shortage.
The other one was close to a
10
billion dollar shortage.

Q
11
And in this e-mail, if you look at the total
12
balance, 700 -- I can't read that number very well.
13
731 million and required --
14
It looks like 751.
15
I'm sorry, 751, and required 516.
Do you
16
recall having a conversation with Frank or anything
17
other than just this e-mail about this trust account
18
issue?
19
20
Do I recall having a specific conversation with
him?
21
Yeah.
22
No, but it's likely we did.
23
Why do you say that?
24
Because normally when there would be problems
25
with this kind of thing I would pick up the phone and

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talk to Frank and ask him what he needed these things to
reflect.
going to be more money coming in?
changing these balance sheets.
large deposits coming in, let me know about them now and
I'll go ahead and I'll bolster the balance sheets now so
I don't have to have Deb and Irene keep changing the
thing.
Sometimes we'd discuss the fact that, Is there
Okay.
I don't want to keep
If there's going to be
Turning a few e-mails down, it's the
10
second of -- three pages or five pages from the end.
11
April 13, 2009, from Frank to you, 6:17 p.m.
12
Hold on.
13
The subject is Banyon wires.
14
No.
15
It's like four pages towards Tab Five.
16
4?
17
April 13, 2009, 6:17 p.m.
18
Hold on.
19
6:17 p.m.
20
Okay.
21
The second paragraph in that e-mail Frank to
22
you says:
23
problem with the trust funds; is this the case?
24
is we need to deal with it but don't send me off dealing
25
with Platinum and Centurion if the issue is really the
Got it?
How many pages in?
6:17 p.m.?
The other issue is if there's a cash flow

If it

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trust accounts.
Do you recall that e-mail?
2
3
I can't see it on here.
Second paragraph.
UNKNOWN SPEAKER:
MR. RASCO:
7
8
9
10
Where is it?
The Bates number?
The Bates number is
112310-0162270/1, part of the Preve production.

BY MR. RASCO:
Q
It's the paragraph that begins, "The other
issue is" --
11
Okay.
12
Okay.
13
I recall this.
14
You recall this e-mail?
15
I do.
16
And why was Frank inquiring if there was an
17
issue with the trust account funds.
18
disingenuous e-mail on his part?
19
No.
Is this an
From time to time Frank would tell me,
20
scold me over the telephone and in person that I was
21
spending too much of the money.
22
whether or not there's a problem with the amount of
23
money.
24
there enough money in here to make our payments?
25
there enough money to keep everything going?
And he's asking me here
Because, again, all we're concerned about is, is

Is
Is there

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enough money to ultimately make sure we're making lots
of money, which we were at the time.
And --
But you're misinterpreting, you're saying
because he's saying "trust funds," that that means
legitimate trust funds.
What he's asking me here is basically, Hey,
Dummy, have you spent too much money?
Is there enough
in there to cover all these payments?
That's what he's
10
asking me.
11
12
And you have conversations by phone or in
person that would back up that statement?
13
Yes.
14
And he would tell you that you were spending
15
too much money.
16
in person?
17
18
Is that something he actually told you
More than once.
He told me I spent money like
I hated it.
19
He told you you spent money like you hated it?
20
Yes.
21
Did he know how much you were spending?
22
I spent money like I hated it.
23
Do you know if he had a specific idea of how
24
25
much you were spending or -A
Frank knew probably as well as anybody that I

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was literally out of control.
once wrote me a note when I was -- You'll see an e-mail
when we were short on money, and Frank was quite
aggravated with me that I had drained accounts to the
extent that they were drained.
money to fund, which was regularly a problem.
As a matter of fact, he
We didn't have enough
This is an e-mail relating to that?
There are all kinds of e-mails like this.
But specifically about you having spent too
10
11
much money?
A
I'm getting to it.
His comment was, If you'd
12
stop buying every empty restaurant and bar and some
13
other thing in town, maybe we'd have some money left
14
over to fund some of these things.
15
Do you recall the approximate date that e-mail?
16
I don't.
17
There's an e-mail two pages in from the one
18
that -- I'll give you exact.
19
When you say in, you mean forward or back?
20
Towards 5.
It's an April 27, 2009, e-mail.
21
It's from Frank to you.
22
Frank and you.
It's an e-mail chain between
23
It starts out on the bottom with my e-mail?
24
Correct.
25
Okay.

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Q
The third paragraph says, "Jack was here with
me.
bank officer as to the balance.
their money is in the bank.
their court, I proved that we have their money.
they need to step up and do their part to get me out of
this mess.
the first large deposit as I will not touch their funds
until I can represent to the bar that the dispute with
10
Went to the bank and received verification from a

Thus, he knows all
Now that the ball is in

Now
In order to save my ass they need to make
the funding sources is over and settled."

This is an e-mail from April 27th.
11
12
Okay.
13
Why would you send an e-mail like this just to
14
Frank if he's aware that the money is not in the bank
15
and that the bar issue doesn't really exist?
16
For his use sending it to other people, cutting
17
and pasting it, using the entire e-mail.
18
look at all my e-mail traffic.
19
you'll see that I regularly - with everybody, not just
20
with Frank - I regularly provided people who were
21
clearly involved in the fraud with e-mails providing
22
both myself and others with what I'll call plausible
23
deniability.
24
25
You have to
Put it all together and
But you do know that Jack was with you and that
you did take him in the bank, correct?

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I understand that.
But there are things in
here, if you look at it, I paid off all outstanding
clients.
Platinum and Centurion and Level 3 current.
Frank, you have the list.
I then bring
To me, as I sit here today, that's something I
wrote expecting Frank to forward that or at least pieces
of it off to the hedge funds.
had no intention at this stage in April of bringing them
current.
Because, number one, we
We had too many other things to fund.
But if
10
they didn't believe they were going to be brought
11
current they weren't going to fund anything.
12
We were just trying to get them -- if you look
13
at the e-mail history, you'll see there's plenty of
14
e-mails where we're trying to come up with various ways
15
to put them in a trick box to get them to fund.
16
So, again, you can't take -- unfortunately
17
because of the sheer voluminous nature of the paper in
18
this case, you can make anything look like anything by
19
pulling one e-mail out or pulling a few e-mails out.
20
All the e-mails need to be read all together and you get
21
a pretty clear picture as to who was involved and who
22
wasn't, what they knew, what they didn't know.
23
very telling story.
24
25
It's a
If I told you that you have about over 7,000
e-mails between you and Frank where you and Frank were

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2
both copied, does that sound accurate to you?

A
I would have thought there was more.
I think I
was told at one point in time there were over a million
e-mails involved in this case in total.
e-mail --
8
9
The last e-mail -- sorry, the second to last
Is that the second to last under Tab Five,
meaning the end of the book?

Q
The second to last e-mail in Tab Four.
10
subject is "Unknown."
11
from you to Mike Szafranski.
12
about this e-mail this morning.
13
14
It's October 1, 2009, 2:41 p.m.,

I believe you testified
This is me writing one of those fake
verification letters for Mr. Szafranski.
15
16
correct?
17
18
Yes.
The
Right.
No.
And this one is addressed to Mr. Preve,
I write it first -- I don't know which one
you're looking at.
At 2:41 I sent it to Mike.
19
Right.
20
And then at 2:45 Mike sends it to Frank.
21
Yeah.
I just mean, "Dear, Mr. Preve."
You
22
wrote, Dear Mr. Preve at the 2:41, sent it toke, and
23
then Mike sends it to Frank?
24
Yes.
25
I take it that you're suggesting that this

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would be something that Mike is sending to Frank for
other people's eyes?
Well, that's what it's for.
You can tell by
the way it's written that it doesn't look anything like
what I would write to Frank.
6
7
Well, does Frank know that you're the drafter
of this e-mail?
Yes.
Frank knew that you were the drafter of this
10
11
e-mail when he received it?

A
What had occurred was, if I recall correctly,
12
Szafranski had sent an earlier e-mail, whether this one
13
or it was another one, either to Frank or to some other
14
investor that he did verification for, and Frank did not
15
like the format.
16
Frank.
17
amounts, gave him the deal numbers.
18
and paste it over, change who's signing it and zip it
19
over to Preve.
20
21
22
And I discussed the format with
I formatted the letter for Mike, gave him the

Just said, You cut
Why didn't Frank like the format, if you
recall?
A
I don't recall.
But if this was -- if you look
23
at this, this is going to -- this is BS, BUS V1 and V2.
24
And I recall that we had some pretty heavyweight
25
investors.
I don't recall who they were at the time in

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those two.
I think one was Mr. Scherer's investors.
and Frank wanted, a very formal verification letter.
There was some pretty heavyweight investors,

And I wanted,
A matter of fact, I think this is the most
formal verification letter that Szafranski, through me,
ever wrote.
7
8
9
Did Frank specifically discuss this
verification letter with you?

A
I recall discussing with him verifications in
10
general regarding the Von Allmen, Clockwork, et cetera,
11
investors.
12
tell you, but it certainly fits Frank's and my mold,
13
that we would have discussed it before it came over
14
because otherwise I wouldn't have known exactly what he
15
wanted into it.
Whether this was the specific one, I can't
16
17
together?
18
A few times, yes.
19
Socially or for the investment strategy, let's
20
call it?
21
Both.
22
Was Frank ever present at the verifications
23
24
25
Did you, Frank, and Mike Szafranski ever meet
that Szafranski was conducting at your office?

A
He may have been in my office while Mike was
doing that.
But, again, I wouldn't have put them both

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together at any point in time to go pushing through
things.
You --
As I told you earlier, I tried to discourage
people involved in the fraud from talking to one
another.
8
9
Again, you said there was never a sign-in sheet
at your office?
A
You testified to that earlier.
There was no sign-in sheet in my office.
Maybe
10
Bova has records of Frank coming over because Frank used
11
to come over - probably a dozen of the times he came
12
over he would come over and he'd just go directly to the
13
bar at Bova and he'd say, Get your ass down here.
14
down at the bar waiting for you.
15
16
17
18
I'm
We would do our business down there.

Q
Would you meet him there more often than you
met in your office?

A
No.
We would generally head there after
19
meeting in the office, but not necessarily starting
20
there more often than not, no.
21
22
Okay.
Do you know if Frank ever drafted any
deal documents for you?
23
You have to rephrase the question.
24
Was Frank ever involved in the drafting of deal
25
documents?

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Yes.
Can you be more specific as to how he was
involved?
At the time that we were creating the initial
packet increased, the look and appeal of our settlement
documents, he came up with some ideas along with me
regarding the Purchase and Sale Agreements, the Transfer
Agreements.
I, at one point in time, wanted to do an
10
assignment.
He said, No, the assignment's not going to
11
look right.
Let's do this kind of document.
12
yes, he participated in the drafting and creation of
13
what came to be known as our final deal packet.
14
15
16
And so,
He was doing it from a business deal structure
perspective, though, wasn't he?

A
I don't know what that means.
We were doing
17
everything from a business deal structure perspective.
18
When you're conducting a fraud and you want it to pass
19
muster, you conduct everything as if it's real, as close
20
as possible.
21
I'm just asking whether he was involved in the
22
actual writing of the legal documents, in other words,
23
writing what was --
24
25
Yes, I just answered that question.
He was
involved in the -- let me look at the names of the

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documents and I'll tell you specifically.
In the contract of employment he was not
involved, I don't think he gave me, because we used our
standard contract of employment.
The Confidential Settlement Agreement and
General Release, he gave me some wording to add into
that, especially with regard to the financial advisor
stuff.
The Acknowledgment of Assignment, Purchase of
10
Settlement Proceeds, he and I went back and forth on
11
that document extensively regarding the language, so he
12
was heavily involved in that.
13
14
The Sale and Transfer Agreement, same answer.

He was involved.
15
Was this all in 2007?
16
I don't remember when it was.
Whenever the
17
first -- Look at the date we have the first full deal
18
packet that looks like this, that's when it was.
19
20
into it?
21
22
23
24
25
Okay.
Do you recall if that was about 13 deals
I don't recall.
Agreement, same answer.

Q
The other Sales and Transfer

So, yes, he was involved.
And at that time was he aware that anything
illegal was going on?

A
Again, you have to look at the entire set of

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e-mails to know what he knew when.
Assuming we're talking about 2007.
What time in 2007?
You know, early on when -- let's say early to
5
6
mid 2007, April, March, April.

A
By mid 2007 it's my opinion that Frank had a
good idea as to what was going on or at least started to
sense it.
through the e-mails for you and making a timeline, which
Again, I can't without sitting and going
10
I suggest you do, you're not going to be able to
11
pinpoint it exactly.
12
The way this worked with Frank and everybody
13
else is I kept putting feelers out there.
14
little bit.
15
react.
16
opening the Ponzi door little by little until they are
17
in in whatever role they wish to be involved in.
18
19
20
21
22
They pick up on something.
Take it to the next step.
Give them a
See how they
And, again, keep
As I said, some people didn't take the bait.

Some people took it hook, line, and sinker.
Q
Did Frank ever fill in the blanks as far as the
names of parties on any of these settlement agreements?

A
No.
But he did from time to time call me and
23
tell me that I had the wrong names in there.
24
I had the wrong amounts in there.
25
wrong deal numbers in there.
He told me
He told me I had the
And this is very telling

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because this is after these plaintiffs and defendants
have allegedly signed these documents.
And one of the other things you should look at
is the timing of these documents.
that it would be physically impossible, if you look at
the turn-around time from the time that we allegedly
settled the case to the time that the documents are
produced and signed, in many cases it's physically
impossible unless I had some kind of transporting
What you realize is
10
machine to transport defendants all over the country
11
into my office.
12
13
Did you ever have that kind of discussion with
Frank?
14
No.
15
Okay.
16
Not to my knowledge, no.
17
Did you ever tape record any of the meetings in
18
your office?
19
No, sir.
20
Do you recall regularly sending Mr. Preve
21
e-mails that you were meeting with clients or working on
22
settling a case in 2008, 2009?
23
Especially when I was trying to generate
24
attraction for deal flow, I would send him all kinds of
25
crazy e-mails about negotiating, what was going on.

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Sure.
3
4
Explain what you mean by, when you were trying
to generate attraction for deal flow?

A
Well, initially before he knew what was going
on I was trying to attract deal flow with him.
knew what was going on I wanted him to be able to
utilize the e-mails to attract deal flow from others.
8
9
After he
There were times when, if you look at what was

going on, there were times when I actually sent Frank
10
e-mails telling him that I was someplace where it's
11
clear to Frank knew that I wasn't there because, for
12
example, I would say I was out of state handling
13
something, and then an hour later Frank and I were
14
meeting downstairs at Bova.
15
Can you point to a specific date or e-mail?
16
Again, I would need to see all the e-mails.
17
could tell you - and we could actually match it to my
18
travel manifest and the like.
19
Coral, Florida, negotiating a big deal with seven
20
plaintiffs or something.
21
a receipt from me being in Bova with Frank for several
22
hours.
23
I'm saying I'm in Cape
And then an hour later there's
That's not something that Frank would raise in
24
an e-mail, like, I'm meeting you in a half an hour, I
25
know you're not there?

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No, no, no.
Is it fair to say that Frank was regularly on
your back about the fact that deals weren't always
papered on time?
Yes.
Frank thought that the major weakness in
everything we were doing was the fact that he was giving
me tens of millions of dollars without paper and he
thought that would come back to bite us in the ass some
day, and he expressed that on more than several
10
occasions.
11
Did he express that in e-mails?
12
Yes.
13
How so?
14
Bite in the ass, not of.
15
Is that in an e-mail?
16
Yes, it is.
Do you mean the biting of the ass?
As a matter of fact, I think it's
17
the same, turn around and bite us in the ass.
18
all kinds.
19
those e-mail segments where he and I are going back and
20
forth about the lack of paper - well, not going back and
21
forth.
22
documents.
I thought Deb was going to do the old
23
documents.
He keeps putting old documents.
24
kind of stuff there.
25
There's
Look at those e-mail tracks -- excuse me --
He's kind of writing to me saying, Where's my
There's all
If you put the e-mails out, you'll see what I'm

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talking about.
back and creating.
backdate documents.
that he did that indicate the level of his knowledge.

Q
He's asking for things that we're going

He asked me at one point how to
There's a whole plethora of things
You talked yesterday or on Friday, I believe it
was, about the fact that you were diagnosed in college
with acute anxiety disorder; is that right?
Yes.
And since you've returned from Morocco have you
10
had any psychological evaluations?
11
No.
12
Have you taken any polygraph exams?
13
No.
14
Since you returned --
15
Oh, yes.
MR. LaVECCHIO:
16
Actually I did.
I have to object at this
point.
17
MR. RASCO:
18
Can we take a five minute break,
please?
19
(Thereupon, a short break was taken.)
20
3]
21
BY MR. RASCO:
22
Ready to go?
23
I am.
24
Mr. Rothstein, I'm going to hand you an e-mail
25
that was not included in my binder.

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Okay.
Here's two copies.
If anybody wants a copy, I
have copies.
It's a July 27, 2007 e-mail from Frank to you
4
5
and the subject is lunch.
And it states:
I would love
to come but I have to do my unlicensed practicing of law
for most of today.
next Friday as George will be out of town and I will
have my feet up on my desk thinking about what kind of
I will take a rain check.
10
problems I can create for him.
11
Get me my documents.
How is
Thanks anyways.
P.S.
Do you remember this e-mail?
12
13
Yes.
14
Doesn't this e-mail indicate to you that
15
George - there's no way George Levin would be looking at
16
Frank's e-mails?
17
18
What, you think because he's making a joke
about this?
19
You think that's a joke?
20
Listen, as I sit here today, again, I don't
21
know if George was looking.
22
read, I think, most of the e-mails indicate that George
23
was not looking at them.
24
had access to; but access and actually doing are two
25
completely different things.
Based upon everything I've
I do recall being told that he
There are better e-mails,

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I think, than this that would indicate that George was
not looking at e-mails.
believe me, me and George and Frank joked around all the
time about who was working, who was not, what Frank did
when George was out of town.
I understand what you're trying to do, it's not
the greatest example.
will help you better.
9
10
11
12
13
14
15
This one is just -- I mean,
I think there's other ones that
You agreed there's several e-mails that would
indicate that George was not looking?

A
I testified to that numerous occasions.
There
are a lot of e-mails out there.

Q
You had a conversation, did you say, that
indicated to you that George was looking at his e-mails?

A
There were times when I was talking to George
16
when he seemed to have knowledge about something that he
17
either would have to have devined, gotten directly from
18
Preve, or had been reading the e-mails.
19
something just hits you funny when someone says
20
something and it seems to quote something you said
21
recently?
22
Yes.
23
Those kind of things.
24
25
You know how
It wasn't like a crazy
suspicion that I had.

Q
Didn't you say you were joking with Frank about

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that, that the fact that he was looking at his e-mails
you were laughing with Frank Preve about that?
Just now?
No, earlier in your testimony last week.
I certainly may have.
Do you recall a specific conversation with
Frank where he indicated to you that George was looking
at his e-mails?
9
10
11
I recall Frank telling me that George had
access to it.
Q
You've talked about the rock-star lifestyle and
12
referencing several people.
13
beneficiaries of the rock-star lifestyle that you've
14
talked about?
15
16
George had his own rock-star lifestyle.
didn't need me.
17
Were George and Frank
He
And Frank, not really, no.
No, Frank was getting direct money.
18
Frank was getting direct money from who?
19
From me.
20
In the form of cash?
21
No, in the form of me pushing through deals
22
that were extraordinary like the 11 million in and 22
23
million out on the Regent deal and some multiple $50,000
24
invoices that we paid to him.
25
And what were those --

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He was also being well taken care of by
George.
million dollars during the course of this.
My understanding was he made well over two
From George?
So, George wasn't -- from George and from me
6
7
8
and from the side deals he was doing, yes.

Q
And the invoices, was that for consulting -
bank consulting work Frank was doing for you?
That may be what he wrote on it.
10
Do you recall having a discussion with him
11
about that?
12
About what to call it?
13
Well, no.
14
15
Was he ever doing any actual bank
consulting work for you?

A
Frank did all kinds of -- I guess you would
16
call it consulting, answering questions for me, I
17
answered questions for him.
18
of what he was doing for George, Centurion, and any
19
other investors he brought in.
20
separately that he was doing for me.
21
But it was part and parcel
It wasn't something
From time to time I may have had a banking
22
question for him, but I can tell you that all of the
23
times that I talked to him, even if he was billing me
24
$10,000 an hour it wouldn't add up to $50,000 worth of
25
work.

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2
All the payments for those invoices, they're
all in Tab Five, I believe.
I saw that.
All those payments were made by check or wire
5
6
to him or -I don't know, you'd have to look.
I don't know
which ones were paid, which ones were not.
I don't know
how much it was.
certain monies that we sent to other investors that he
10
I was under the impression that
was getting kickbacks.
11
From what I could tell he was very well
12
compensated.
13
about the amount of money he was making.
14
He never - he rarely complained to me
Were there -- there's never any instance where
15
Frank was getting paid cash directly though; is that
16
right?
17
I don't recall giving him any cash directly.
18
Same with George obviously, right?
19
I never gave George cash, no, sir.
20
And as far as, you know, women, strip clubs,
21
escorts we talked about, nothing like that with Frank
22
and George; is that right?
23
24
25
No.
MR. RASCO:
Okay.
I just want to state on the
record one more time that we don't agree that the

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two and a half hours with Mr. Rothstein is
sufficient time to properly cross examine him, but
because I've been allotted two and a half hours,
I'm going to close now.
THE DEPONENT:
MR. SCHERER:
MR. RASCO:
10
11
12
Thank you, sir.
Would you like
your notebook back?
Thank you.
That should be made an exhibit?

Yes.
Actually the last one that I
just gave him.

THE WITNESS:
If you want to put stickers on
all this stuff before we get too deep in exhibits.

(Whereupon, Preve's Exhibit No. 207 was marked
13
14
MR. CRAIG:
All the documents I'm using are
15
either from the exhibits that TD circulated or the
16
exhibits that Spinosa circulated or from the
17
750,000 documents that were produced on Thursday,
18
Plaintiff's notice of production, the restored,
19
deleted e-mails.
That's not --
20
UNKNOWN SPEAKER:
21
MR. CRAIG:
We can't hear you too well.
All the documents that I'm going
22
to use today as exhibits either came from TD Bank's
23
exhibits that they circulated, Spinosa's exhibits
24
or there's a single exhibit that I'm going to be
25
using that came from the production on Thursday,

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Plaintiff's production, restored, deleted e-mails.
And another, excerpts from your Third Amended
Complaint.
4
5
MR. SCHERER:
those.
THE WITNESS:
7
8
9
No objection to either one of
Whenever you're ready, sir.
DIRECT EXAMINATION
BY MR. CRAIG:
Q
Good afternoon, Mr. Rothstein.
My name is
10
Tucker Craig and I represent Rosanne Caretsky.
11
along with my co-counsel Mr. Dan Gelber.
I'm here
12
Mr. Craig, Mr. Gelber.
13
First of all, I haven't been here every day,
14
but I don't believe anybody has gone over any ground
15
rules with you.
What I'm referring to are ground rules
16
for deposition.
I assume that you're familiar with them
17
from your practice as a lawyer?
18
I am.
19
And one of the ground rules that I would like
20
to stress with you before we get started is, it has to
21
do with speculation.
22
you don't want any witness to guess or speculate; is
23
that a fair statement?
You know as a former lawyer that
24
Depends upon what you're looking for.
25
Well, I'm looking for the truth and I don't

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want you to guess or speculate, okay?
Understood.
If you don't know the answer to any question I
ask, would you just tell me so?
You got it.
If you don't remember or recall the answer to
any question I ask you, tell me that also.
Okay?
Yes, sir.
During your responses to Mr. Scherer's
10
questions on direct you prefaced a lot of your answers
11
with I think, I believe, I suspect, perhaps, and then
12
you would follow up with an answer.
13
answer like that in my mind is a guess or a speculative
14
response.
15
Yes, sir.
16
Now, what have you reviewed by way of
Built into an
I don't want you to do that.
Okay?
17
deposition transcripts in preparation for your testimony
18
here today?
19
I don't recall.
20
Have you reviewed any deposition transcripts?
21
Yes.
22
Have you reviewed any deposition transcripts of
23
my client, Ms. Caretsky?
24
I don't recall.
25
When was the last time you reviewed a

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deposition?
Several weeks ago.
Prior to the commencement of your deposition
last Monday?
Yes, several weeks prior to that.
Have you reviewed, other than during your
deposition I just marked as exhibits, have you reviewed
any documents since your deposition began on the 12th?
Yes.
10
What documents have you reviewed since your
11
deposition began?
12
A few hundred e-mails.
13
Pertaining to what?
14
Pertaining to all sorts of things.
Some of it
15
is pertaining to my continuing cooperation with the
16
government.
17
cooperation with the government.
18
In fact, all of it was with my continuing
Have you reviewed any documents or e-mails or
19
correspondence or pleadings or papers having to do with
20
the Razorback case, Mr. Scherer's case?
21
Not in the last several weeks, no, sir.
As I
22
want to make sure, with regard to the big 2000-something
23
page complaint that Mr. Scherer filed, I haven't
24
reviewed that for many weeks.
25
course of my deposition, reviewed parts of a Complaint
I recently, during the

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2
filed against Ted Morse.

Q
When you say "during the course of your
deposition," are you talking about during a break or at
night in between segments?
In the evening.
Is that the only thing --
Some during a break.
Is that the only thing that you reviewed since
9
10
11
your deposition started other than what you told me

about the e-mails relating to your cooperation?
A
Other than something that might be
12
attorney/client privilege, I haven't reviewed anything
13
else.
14
15
Do you recall the first time you met my client
Ms. Caretsky?
16
I do not.
17
Do you recall what the context was of your
18
initial meeting with her, that is where were you, what
19
did it have to do with?
20
I have no specific recollection.
21
Do you recall your initial meeting with meet
22
and greet with TD Bank representatives when your
23
relationship began back in early November of 2007?
24
25
My first recollection is a dinner I had with
John Tolomer.

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Is that at Saint Regis?
No, that was in a restaurant in Boca Raton.
Do you ever recall meeting my client during one
4
5
6
7
of those initial meetings?

A
I recall meeting your client, I don't recall
specifically the date.

Q
Let me see if I can help refresh your
recollection.
There's been testimony in this case by
more than one person that she was present during the
10
initial meeting at your law office in early November.
11
Do you remember that?
12
13
14
I don't remember whether it was in November or
not but I do remember her being in my office.

Q
Actually there were two meetings in your law
15
office.
16
walked out; and a couple weeks later there was a meeting
17
when lenders from TD Bank came in and that meeting
18
lasted and you had sat down and attended that meeting,
19
that meeting lasted 30 minutes or less.
20
that meeting?
21
One you walked in and said hi to everybody and
Do you recall
I recall being at a lender's meeting.
22
know if it was that lender's meeting.
23
me that was only one.
I don't
If you're telling
24
No, I'm not telling you that.
25
Then I don't have a specific recollection of

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2
attending that meeting.

Q
More specifically you don't have a specific
recollection of meeting my client at a meeting such as
that?
I recall seeing your client at the Weston
branch.
Bova restaurant.
times, I have no reason to doubt what you're saying.
just don't have a specific recollection of it.
10
11
I recall seeing your client once or twice at

I don't recall seeing her any other
Fair enough.
You said you saw my client once
or twice at Bova restaurant?
12
That's correct.
13
Was that when she was there having lunch with
14
15
Uncle Bill?
A
I don't recall who she was having lunch with
16
but I was in the restaurant as I was frequently and she
17
was there.
18
19
correct?
20
I said hello.
You said a hello from across the restaurant,
I couldn't tell you whether it was across the
21
restaurant or not but I said hello.
22
looking for is there was no further conversation other
23
than hello.
24
That was at lunch, correct?
25
I believe it was lunch, yes.
I think what you're

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As far as the other contact or I guess only
contact that you do have independent recollection of
with my client, were the shows that you've talked about
for the past week or so.
statement?
7
8
9
10
Would that be a fair
Yes.
(Whereupon, Caretsky's Exhibit No. 208 was
marked for identification.)

BY MR. CRAIG:
Q
Let me go ahead and show you a couple of
11
documents before we go any further.
Let me show you
12
what's been marked as Defendant's Exhibit 208 for
13
identification.
14
Plaintiff's third amended complaint, it's titled
15
Paragraph Roman Numeral IX:
16
97 of 2210 through 101.
It is an extension certificate from
Devastating Fallout.
Pages
May I approach?
17
Thank you.
18
Take a look at that document and tell me if you
19
20
21
22
23
24
25
recognize it and if so, how?

A
I remember seeing this.
I read it at the time
that I was reviewing the original Razorback Complaint.

Q
When you say original Razorback Complaint, are
you talking about an initial complaint?

A
Sorry.
For me, the first time I saw a
Razorback Complaint I think, thankfully, was the Third

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2
3
Amended Complaint.
Q
Thankfully because it has 2210 pages plus a
couple of 1000 pages of exhibits?
Yes.
That was a lot of homework; wasn't it?
That is the understatement of the millennium
7
8
9
along with some others, yes.

Q
As you sit here today -- Let me ask you, did
you read it cover to cover?
10
Not in one sitting but, yes.
11
Over time?
12
Over many weeks.
13
And did you find anything inaccurate about the
14
allegations contained in the Third Amended Complaint?
15
Some things, yes.
16
Tell me about those.
17
I don't remember what they are.
18
Tell me about --
19
I can give you a couple examples that pop into
20
my head.
There was a thing in there about Frank Preve
21
having an office with me, he didn't have an office in my
22
offices.
23
24
25
Did you tell anybody about that inaccuracy?

MR. NURIK:
I'm going to object on privilege
grounds.

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MR. CRAIG:
THE WITNESS:
And instruct?
Yes, obviously.
BY MR. CRAIG:
Okay.
You know what, I don't want to obviously go
through 2210 pages.

Q
7
8
Got another example?
I'm not asking you to.
Off the top of your
head --
Nothing is popping out.
But for some reason
10
that office thing is popping out in my head, probably
11
because we just discussed it and I remember it also
12
being in the Complaint.
13
yes.
14
There were some inaccuracies,
Let's try to speed this up a little.
I want to
15
call your attention to the second page of this exhibit,
16
which is Page 98, which would be Paragraph Roman Numeral
17
IX, A, little "e," period.
18
19
20
21
You lost me.

MR. NURIK:
Nine what?
You see the top of the first page it says Roman
Numeral IX Devastating Fallout?
22
Yes.
23
The next Subsection is letter A.
24
I got that.
25
TD Bank?

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Yes, sir.
Then 308 is the next paragraph?
Yes, sir.
And then the little letter "e".
Got it.
Could you read that out loud, please?
E:
"On or about the summer of 2009 Rothstein
delivered to Caretsky $25,000 in cash for her continued
cooperation and participation in the Ponzi."
10
You maintain that as a true statement?
11
Time frame I'm still vague on, but the delivery
12
of the funds, yes, sir.
13
Well --
14
And the exact amount I'm a little vague on.
15
I believe there's been testimony about how the
16
allegation regarding a payment, alleged payment, to
17
Mr. Spinosa came about.
18
an interrogatory in this case in which the Plaintiffs,
19
Mr. Scherer and his clients, filed a response indicating
20
that the answer to a question about where and when the
21
payment to Mr. Spinosa was made came from a discussion
22
Mr. Nurik had with you and in turn what he related to
23
Mr. Scherer about his discussion with you.
24
I lost you.
25
Okay.
In fact, there's an answer to
Does the allegation contained in

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Paragraph 308e, that you just read, is that information
consistent with what you told your attorney who - and
authorized him to tell Mr. Scherer with regard to any
payment to my client, Ms. Caretsky?
5
6
7
8
9
It is consistent with what I've been saying
since the day I returned, so, yes.

Q
Including the time period in which that payment
was allegedly made, that being the summer of 2009?

A
No.
I've never locked in any time period since
10
I've come back for the very specific reason that I don't
11
recall certain specific time frames.
12
narrow it down as best I could but I don't know for
13
certain the exact time frame.
14
I have tried to
Well, the summer of 2009 is not a specific
15
time, that's a period, a three-month period at least,
16
correct?
17
Correct.
18
Now, are you saying you weren't the source of
19
the information referencing the time period in which the
20
payment was allegedly made as reflected in Paragraph
21
308e?
22
23
24
25
All I'm saying is that it could be incorrect as
to time frame.

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BY MR. CRAIG:
Q
2
3
I'm going to next show you a document marked as
Defendant's 209 for identification.
Am I done with this exhibit for now?
Yeah, you can set that aside.

For the record, this is Plaintiff's, Ira Sochet
6
7
as Trustee of the Ira Sochet Revocable Inter Vivos
Trust, Revised Answers and Objections to Defendants'
common set of interrogatories, under certificate date
10
February 17, 2011.

Could you take a look through those, please,
11
12
sir?
13
You want me to read this whole thing?
14
No.
15
Okay.
16
Have you ever seen it before?
17
No, sir.
18
We'll speed this up too, turn to Page 19.
19
Sure.
20
Up at the top of the page is Interrogatory No.
21
2.
I want you to read the Interrogatory, that single
22
paragraph first.
23
You want me to read it out loud?
24
However you would prefer.
25
All right.
If you don't want me to read it

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into the record, I prefer to read it to myself.
Okay.
Read it to yourself.
Okay.
Turn to the next page.
Page 20.
That would be correct.
Yes, sir.
Could you read that out loud?
I can.
Third full paragraph.
"Rothstein indicated that there was
10
several hundred million dollars in trust accounts held
11
by TD Bank for the settlements.
12
Szafranski and Sochet in Rothstein's Bentley, one of the
13
many cars he showed to Sochet during his visit, to TD
14
Bank in Weston.
15
advised Sochet that the managers of that branch would
16
help demonstrate the overall safety of the proposed
17
deals by personally handing Sochet an envelope verifying
18
the balances in one of our trust accounts and the wires
19
into the accounts."
Rothstein then drove
Before entering TD Bank, Rothstein
20
Let me stop you there.
21
Sure.
22
So far, is what you have read consistent with
23
the protocol for what has been described by you as a
24
show?
25
Except for the car, yes.

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Bentley?
4
5
Continue reading aloud, please.

THE WITNESS:
He's cross-examining me, I'm
being careful.
8
9
I don't even recall having a Bentley then, I
think he meant the Rolls Royce.
6
7
You mean sometimes you weren't driving the
MR. SCHERER:
A
10
They look the same.
They don't look the same.

"Rothstein cautioned Sochet not to open the
11
envelope verifying the balances in the RRA trust
12
accounts and the wires into the account until Sochet
13
left the bank as Rothstein did not want the other
14
general employees of that branch knowing his
15
confidential business, because of the confidentiality
16
requirements under the Florida Bar Rules regarding these
17
confidential settlement investments."
18
Was the second part of that paragraph which you
19
just read into the record consistent with the protocol
20
for the shows?
21
I'm not certain that that's the exact reason I
22
gave for not opening it but, yes, that is part of the
23
protocol, yes.
24
25
Regardless of the reason the protocol was for
the investors not to open the envelope until he had

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2
3
4
5
6
left - he or she had left the bank, correct?

A
The protocol was to wait until we left the
bank, yes, sir.

Q
Can you continue reading on the following
paragraph out loud, please, sir?

A
Yes.
"Sochet accompanied Rothstein and
Szafranski into TD Bank where Rosanne Caretsky, Caretsky
and Matthew Brennan, Brennan were waiting for Rothstein,
Szafranski, Sochet and Rothstein.
Introduced Sochet as
10
an important client.
11
themselves as officers of the bank and Rothstein asked
12
Caretsky and Brennan whether they had the envelope for
13
Sochet."
14
Caretsky and Brennan introduced
Let me stop you there.
Was that, what you just
15
read from the fourth paragraph, consistent with the
16
protocol for the show?
17
18
When you say the "protocol for the show," you
mean the way I wanted it to go?
19
Yes, sir.
20
I don't know who Matthew Brennan is.
21
actually thought it was someone that worked for
22
Szafranski, I am apparently wrong.
23
as coming in, introducing the people to Caretsky,
24
getting the envelope, yes, that's correct.
25
But it was -- as far
But, there were other TD Bank representatives

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who were involved in these so- called shows other than
Ms. Caretsky, correct?
To my knowledge, it was Caretsky and
Kerstetter.
Mr. Mejia did it.
There may have been an occasion where
How about Mr. Garces in Deerfield Beach?
Yes, Deerfield.
branch, yes.
was played by Mr. Caputi.
10
11
12
13
14
I'm thinking just the Weston
Mr. Garces in Deerfield Beach, I believe
Are you sure about that?
You just prefaced
that answer with -A
Yes.
I get what you're saying.
In Deerfield
Beach, Caputi played Garces.

Q
I don't know if you're getting what I'm
15
saying.
16
you at the beginning of the deposition, I don't want --
17
I don't care what you believe, I don't care what you
18
think, I don't care what you surmise, I don't care what
19
you assume.
20
guess.
21
that, sir?
22
What I'm saying is when I tried to go over with
All I want are facts.
I don't want you to
Too much at stake here, wouldn't you agree with
MR. SCHERER:
Objection, form.
23
Sure.
24
You wouldn't want -- people's liberty is
25
potentially at stake.
Do you agree with that based on

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what you had to say last week and this?
To some extent, sure.
You wouldn't want a decision about their
liberty to be based upon one of your guesses; would you?
No, sir.
That wouldn't be fair; would it?
Unless my guess leads to information showing
the culpability, that would be fair.
You mean unless you guessed correctly?
10
No.
11
12
I mean that if my --
MR. SCHERER:
A
Object to the form.
-- if my information - whether I'm taking a
13
guess or speculating about something or giving my
14
opinion on something - if that leads investigators to
15
solid information regarding culpability then, yes, that
16
would be helpful and certainly be something upon which
17
their culpability should be based, yes.
18
So, as far as TD Bank representatives other
19
than Ms. Caretsky who you recall as being involved with
20
the so-called shows in which you participated, there
21
would be Ms. Kerstetter, correct?
22
Correct.
23
Mr. Mejia?
24
I seem to recall him once, but I don't have
25
specific recollection so the answer is, I do not recall

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at this moment.
Q
I think you seemed to recall him when
Mr. Scherer was asking you questions also; does that
ring a bell?
No, because when I was discussing with
Mr. Scherer I was also discussing Caputi.
to guess.
You recall the meeting with Mr. Garces at
Deerfield now?
10
11
I don't want
No.
I recall when I went to Deerfield, Caputi
being there.
12
How many times --
13
If I met Mr. Garces it would have just been to
14
say hello.
15
Do you recall taking Jack Simony - planning to
16
take Mr. Simony to the Weston branch and Mr. Simony
17
receiving a call from his office in New York and a
18
request was made apparently from up there to go to a
19
different branch and then all of a sudden plans had to
20
be changed and arrangements had to be made for the show
21
to be done at the Deerfield branch; do you recall that
22
occurring?
23
I do.
24
And Mr. Caputi had nothing to do with that; did
25
he?

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Nothing to do with changing the plans?
Nothing to do with that show at Deerfield on
that occasion where there were last minute changes at
the request of Mr. Simony?
At this time I don't specifically recall.
That portion of the first part of the fourth
paragraph that you read where you indicated that you
would -- strike that -- where it indicates that you
would introduce Mr. Sochet as an important client; is
10
that accurate?
11
Yes.
12
Whenever you did these shows you didn't
13
introduce any of the people that you brought with you,
14
the so-called investors as such?
15
No, sir.
16
Could you read the last part of that paragraph
17
18
please, sir?
A
"Thereafter, Caretsky and Brennan personally
19
and directly handed Sochet a sealed envelope in front of
20
Scott Rothstein and Mr. Szafranski.
21
TD Bank he opened the envelope and read the balances in
22
the account.
23
24
25
After Sochet left
See attached copies."
Is what you just read in that last portion an
accurate reflection of the protocol for the show?

A
With the exception of Mr. Brennan's

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involvement, yes.
3
4

BY MR. CRAIG:
Q
Mr. Rothstein, I'm showing you what's been
marked as Defendant's Exhibit 210 for identification.
And for the record, these four pages are taken from your
power point.
You looked at these last week, I believe.
9
10
Okay.
11
Do you remember looking at these last week?
12
I remember looking at the last two pages, I
13
don't remember seeing the first two.
14
fact, I didn't see the first two pages.
15
16
17
18
As a matter of
Actually, I think, the only one I saw was Page

3.
So no, I saw those last two pages.

Q
We know you saw Page 3.
You said something
about dancing with Ms. Kerstetter?
19
Yes.
20
Now, why don't we take a look at Page 1?
21
Okay.
22
Do you recognize any of the individuals who are
23
depicted on Page 1 of Exhibit 210?
24
Yes, the man off to the left is Bill Boockvor.
25
That would be Uncle Bill?

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Uncle Bill, correct.
And I believe you identified this series of
photographs or they were identified by Mr. Scherer as
stills taken from a video depicting one of the shows,
that being the show on September 15, 2009 at the
Weston - excuse me, at the 17th Street branch of TD
Bank?
9
10
The first two pages I would call pre show, the
second two pages show.

Q
And you call the first two pages pre show
11
because they depict Mr. Brock, Uncle Bill's early
12
arrival with an envelope in his hand before you arrived
13
with the investor, correct?
14
15
16
17
18
He should be carrying a manilla folder with the
balance statements in it.

Q
Isn't that what he has in his hand on Page 1,
that being his left hand?

A
I can't tell what it is in his left hand.
It's
19
something sticking out of his left hand but it's
20
sideways, it actually looks like his finger is really
21
long.
22
Two feet long?
23
Yes.
24
25
Obviously it's not his finger.
He's holding
something in his hand but I can't tell what it is.

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2
Fair enough.
Do you recognize anybody else in
that photograph?
In the first photograph?
Yes.
No, I can't make anyone else out.
Top right, does that appear to be
Ms. Kerstetter?
I have no idea who that is.
Second page, who do you recognize in that
10
photograph?
11
Second page I recognize Bill Boockvor.
12
He's in the middle holding a piece of paper?
13
He is.
14
Glasses half way down his nose?
15
Yes, sir.
16
The third page you've already identified?
17
I have.
18
The gentleman standing directly behind you with
19
a sports jacket and looks like a sport shirt on, do you
20
know who that individual is?
21
22
I think we figured out it was Chris Padaras but
I don't recognize him specifically.
23
It resembles Mr. Padaras?
24
Yes, in the limited extent I can tell from
25
this, yes.

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The last page?
Yes.
Does that photo - does that more clearly depict
and enable you to identify that individual as
Mr. Padaras?
No.
And who is standing to your left?
To my left, Ms. Kerstetter.
And you have a manilla envelope in your hand?
10
Yes, but that's odd.
11
That's odd?
12
Yes.
13
What is odd about it?
14
Because normally, as I recall, at every show
15
the statements were handed to me in a letter size,
16
meaning the kind you put a letter in and fold it up,
17
white TD Bank envelope.
18
given to me in this envelope.
19
I would normally get from Ms. Caretsky or what I
20
remember getting from Ms. Kerstetter at the other
21
branch.
22
So, I'm not sure why it's being

It's different than what
Again, I'll stand corrected, but as I recall
23
from your testimony last week, you indicated, I guess,
24
initially that you thought there were 24, couple dozen
25
shows and you backed that number down to a dozen and

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then I think you settled on 10 to 12.
correct, I'm talking about in total?
12, yes.
Does that sound
I would say in total somewhere between six and
Now, how many of those shows did you bring the
false balance statement with you and put it in the
envelope with the letter?
My recollection, I don't specifically recall.
Did you do that?
10
I don't recall ever doing that.
11
Let me see if I can help refresh your
12
recollection.
13
Okay.
14
Mr. Nurik, could you hand him the transcript
15
from the Day One afternoon session?
16
I have it here.
17
125 beginning Line 6 through Line 15.
18
Sure.
20
Six.
21
23
Could
you read it out loud, please, sir?
19
22
What page?
Hang on.
Page 125, line what?
"Let me ask you this, do you have a
recollection as to how that statement got there?

Answer:
Well, one of two things happened, or
24
one of several things; either Bill Brock brought it to
25
Ms. Caretsky as the normal process was, that's Boockvor,

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he goes by Brock.
Question:
Answer:
Right.
As was our normal process when we were
doing this - or I brought it with me and put it in the
letter, one or the other."
Does that help refresh your recollection of you
having brought the fake account balance sheet with you
and you putting it in the envelope with the letter?
The only time that I did that, to the best of
10
my recollection, was when I was meeting Mr. Caputi.
11
don't recall doing that any other time.
12
13
Have you had an opportunity to review Caputi's
deposition testimony in this case?
14
No, sir.
15
Have you had an opportunity to review the
16
transcript of his testimony in the Coquina trial last
17
week?
18
No, sir.
19
Are you aware that Mr. Caputi has testified
20
that on all three visits, he identified there being
21
three visits only, which is consistent with the charging
22
documents, I believe, information, the stipulated
23
statement of facts, plea agreement, and the sentencing
24
colloquy, that he went there on three occasions and on
25
each occasion he was handed an envelope by a

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co-conspirator, which he subsequently identified as
Mr. Brock.
I was not aware of that.
Is that true?
It's certainly possible, yes.
That would mean that you never handed
7
8
9
10
Are you aware of that?
Mr. Caputi an envelope?

A
That's why I said, "to the best of my
recollection."
Q
So, were you guessing?
11
MR. SCHERER:
Object to form.
12
THE WITNESS:
I was giving you my best
13
14
15
16
recollection.
BY MR. CRAIG:
Q
Well, if your best recollection means you're
not sure or you're guessing, I don't want it.
17
MR. SCHERER:
18
19
20
21
Objection, form.

BY MR. CRAIG:
Q
Mr. Rothstein, let me show you what's been
22
marked as Exhibit 211 for identification.
23
please take a look.
24
numbered TD/Razor 001855 through 1860.
25
If you would,
It's a composite exhibit Bates
Yes.

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And the last page of it is a, I think what you
previously identified as an account letter, dated
October 29, 2008.
Yes.
Could you review these documents and tell me
whether you recognize them or have ever seen them
before?
Give me one minute.

MR. SCHERER:
10
MR. CRAIG:
11
MR. SCHERER:
Is that marked as an exhibit?
12
to have it, yes.
13
14
15
Yes, 211.
Do you want a copy?
If you have an extra I would like

I'll share it with Chuck.
THE WITNESS:
Okay.
BY MR. CRAIG:
Q
My question or questions regarding this
16
particular exhibit are brief.
17
have already testified to this when Mr. Scherer was
18
examining you.
Was this the October 29, 2008, was that the
19
20
And I believe you may
date of the first show?
21
I don't specifically recall.
22
You indicated that there came a point in time
23
when my client was on board, so to speak, or became a
24
player.
25
Do you recall that testimony?

There was a point in time when I enlisted her

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assistance, yes.
that.
And when was that point in time?
Or strike
Was that point in time when you asked
4
5
Mr. Spinosa if he could have Ms. Caretsky sign what's
been come to known as an account letter?
It was subsequent to the three Caputi visits.
It was after the three Caputi visits?
When was the first Caputi visit and the last
10
11
12
13
14
15
16
one?
Q
According to Mr. Caputi he posed as a plaintiff
in your law office on September 25, 2009.

A
No.
My apologies.
I'm not talking about plaintiff visits.
Q
either.
Okay.
I'm talking about bank visits.

I wasn't talking about plaintiff visits
I don't even know what they are.
17
You just said one.
18
I'm giving you a point of reference in time.
19
Mr. Caputi has testified and all of the charging
20
documents and documents associated with his plea
21
indicate that he posed as a plaintiff in your office on
22
September 25, 2009.
23
month before that was the third visit that he made to
24
the Weston branch, which would have been August of
25
2009.
He testified that approximately a

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When was the first?
Somewhere around June or July of 2009.
I just don't have a specific recollection of
the date.
Okay.
Were there shows that took place before
June of 2009?
It doesn't seem probable.
Why doesn't it seem probable?
I really need to put it in context.
No, sir.
The very
10
first -- June of 2009 is the first one you're saying
11
Caputi testified to?
12
He had no exact date.
13
Well, I'm relying on you giving me an exact
14
date.
15
16
He backed it --
I apologize.
No.
let me finish.
I gave you what I gave you.
You didn't
I'll do it again for you.
17
I'm sorry?
18
You don't know when the first show was; is that
19
correct?
20
I don't.
21
Do you know what year it was in?
22
My recollection is it was in '08 sometime.
23
Does October 29th of 2008 help refresh your
24
25
I don't recall specifically.
recollection?
A
No.

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Do these documents that comprise Composite
Exhibit 211, are they consistent with the run up to the
show?
This particular set I don't recall seeing
before.
seen regarding the run-up to the show, yes.
But it looks like other documents that I've
So they are consistent with the run up to the
show?
They seem to be, yes.
10
So, if there was a show -- Strike that.

So, if these in fact are referencing a show,
11
12
there had to be a show on or about October 29th of 2008,
13
correct?
14
Yes.
Judging from the fact that there is a
15
letter here signed by Ms. Caretsky dated October 29,
16
2008, there had to be a show on or about that date.
17
And if there was a show on or about that date,
18
that would have been about the time that Ms. Caretsky
19
came on board, in your words?
20
I can't say that for certain because of
21
Mr. Brock's involvement and Mr. Caputi's involvement as
22
well, and I'm not certain that they are correct as to
23
their dates.
24
25
Well, didn't you testify last week in response
to Mr. Scherer's questions that the first time

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Ms. Caretsky became involved or a player was when you
had Frank - he assured you that you could trust her to
write one of these account letters; isn't that a fact?
4
5
6
7
8
9
It is a fact that Frank told me I could trust
Ms. Caretsky, yes.

Q
At that point in time that was when you decided
that she was a player, correct?

A
It was subsequent to that call that I
specifically told Ms. Caretsky that I needed to show
10
inflated bank statements to clients to secure additional
11
business.
12
13
14
And that would have been subsequent to the
October 29, 2008 letter that's before you, correct?

A
You're assuming that.
I don't know.
We would
15
have to get exact testimony or documentary evidence as
16
to what date the first show was.
17
18
19
20
I don't want to guess.

BY MR. CRAIG:
Q
I'm showing you what's been marked as
21
Defendant's 212 for identification, it's a composite
22
exhibit TD/Razor 001841 through 1851.
23
look at those documents and tell me if you recognize
24
them, and if so, how?
25
Could you take a
I've seen some of these pages before but not

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2
3
the entire set of documents.

Q
Does this appear to be the run up for the show
that took place at the Deerfield branch?
It does.
And I believe you previously testified that it
was at this point in time that you believed that
Jennifer Kerstetter was participating in these shows?
8
9
10
11
12
13
14
I don't recall the date that she got involved
at that level.
Q
You don't recall that you testified to those
facts last week?

A
You are saying, "those facts."
I've been
testifying for six days.

Q
Pertaining to my last -- Did you testify last
15
week that the first time you believed Jennifer
16
Kerstetter was involved in the show to the extent she
17
was replacing real account balances with fake ones that
18
you created or had created was on or about the time that
19
the show took place at the Deerfield branch?
20
21
I don't recall saying that.

MR. CRAIG:
I don't have another copy of this.
22
Let me ask you if you recall this exchange.
23
was from on Page 72.
24
the morning, the first day morning?
25
MR. SCHERER:
This
Does anybody have a copy of
Morning or afternoon?

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MR. CRAIG:
2
3
BY MR. CRAIG:
Q
Let me read it to you and see if we can speed
it up, and I'll hand it to you after.
6
7
That's fair enough.
MR. SCHERER:
MR. CRAIG:
What page?
72.
if it's actually 72.
11
paginated my --
That would be Monday morning
10
12
MR. SCHERER:
13
MR. CRAIG:
15
16
17
18
I trust you to read it to
me.
14
Mr. Lichtman got
through more than 72 pages in the morning.
4
5
Morning, I think.
But my co-counsel has not
Which part?
What part?
Morning.
BY MR. CRAIG:
Q
Line one:
Question:
"How about Ms. Kerstetter, did you
have any reason to believe that she was a player?"

Answer:
"No.
Actually the very first time
19
that I heard she was going to be involved I
20
panicked."
21
Question:
22
Answer:
"Tell me why."
"Because I heard that Ms. Caretsky was
23
not going to be at the bank and that we were going
24
to go doing this with someone new.
25
middle of a large criminal conspiracy and you don't
We're in the

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want to inject new players unless you have to.
was then told by Mr. Spinosa and by Bill Brock that
everything was fine.
Ms. Kerstetter and that she was all a go, and it
went fine."
Ms. Caretsky had talked to
Does that help refresh your recollection as to
6
7
when it was that Ms. Kerstetter became a player, in your
words?
No, because my recollection is that that
10
actually occurred at the Weston branch, not the
11
Deerfield branch.
12
Deerfield incident.
13
That doesn't say anything about the
My recollection is that there was a prior
14
occasion where Ms. Caretsky was not going to be
15
available.
I was very concerned, as I previously
16
testified.
And when I went to the Weston branch it was
17
actually handled by Ms. Kerstetter.
18
my recollection.
19
all - the letter by Mr. Garces and possibly Mr. Caputi's
20
involvement.
21
22
That's the best of
But not Deerfield.
I think that was
Now, during these shows I believe you narrowed
them down to six to 12; is that correct?
23
I'm guessing.
24
You have no idea how many shows there were?
25
MR. SCHERER:
Objection, form.
You asked him

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not to guess.
THE WITNESS:
You don't need to rely on my
testimony that way.
the number of letters and the number of fake bank
statements.
shows there were.
7
8
9
All you need to do is look at
That will tell you exactly how many
BY MR. CRAIG:
Q
How long were you in the presence of the TD
Bank representatives during these shows; that is, from
10
the point you walked in with an investor, greeted them,
11
until the point you were handed an envelope, you turned
12
around and walked out?
13
It was very quick, several minutes.
14
Two or three minutes?
15
16
And --
17
Might have been more sometimes, might have been
18
less.
19
20
Several minutes.
Can you tell me whether my client was involved
in more than 10 shows?
21
I would be guessing.
22
More than 20?
23
I'd be guessing.
24
More than a 1000?
25
That's crazy.

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Twenty is not crazy?
Given the extent of this crime, I don't
believe - I know you don't care what I believe, but I
don't believe she did 20 of these things.
believe I did 20 of them.
I don't
Okay.
So --
Let's assume you did 20 of them with my
client.
10
MR. SCHERER:
11
MR. NURIK:
12
15
I thought we weren't going to
assume anything.
13
14
Object to form.
MR. SCHERER:
Or believe.
BY MR. CRAIG:
Q
I want you to assume you did 20 of them.
16
MR. SCHERER:
17
MR. CRAIG:
18
21
Why don't you let me finish my
question?
19
20
Objection.
MR. SCHERER:
You told him you didn't want him
to assume.
BY MR. CRAIG:
22
I'm asking you a hypothetical question.
23
Go ahead.
24
You know what they are?
25
I do.

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Okay.
Assume, indulge me and Mr. Scherer, that
you participated in 20 shows with my client.
fact, that's true and they lasted two to three minutes
apiece, then you would have spent a total of 60 minutes
in the presence of my client; is that a fair statement?
6
7
During the actual conduct of criminal activity
where the documents changed hands, fair statement.
MR. NURIK:
THE WITNESS:
10
If, in
Don't assume anything.

I'm assuming.
The question said
assume.
11
Assuming what you're saying is correct,
12
assuming that I spent that many minutes, assuming
13
that she did it 20 times, your math is assumingly
14
correct, I assume.
15
16
BY MR. CRAIG:
Q
Would it be a fair statement, Mr. Rothstein,
17
that your total contact with Ms. Caretsky over the
18
approximately two years of banking relationship you had
19
with TD was an hour or less?
20
I'd be guessing.
21
Ms. Caretsky never knew you were involved in a
22
Ponzi scheme; isn't that true, sir?
23
I don't believe she knew that.
24
She didn't know you were involved in any type
25
No, sir.
of fraud, correct?

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Well, showing fake bank statements to anybody,
even if it's just for the purpose of inducing them to do
more business with you and facilitating that by placing
it with a TD Bank letter, I believe, and I only believe,
constitutes fraud.
But if you're asking me, was she aware of the
investment scam that I was running?
knowledge, no.
9
10
To the best of my
Let's move on to the alleged payment that you
made to her.
11
Okay.
12
You claim that you gave her $25,000 on a single
13
occasion; is that correct?
14
Between 25 and 30,000, yes.
15
Where did the money come from?
16
Me.
17
Where did you keep the money?
18
In my office.
19
What denominations?
20
Hundreds.
21
All hundreds?
22
Always.
23
Where did you get the money from?
24
Banks, organized crime, clients, law
25
enforcement.

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What kind of --
All kinds of different places.
What kind of envelope did you place it in?
It was a large accordion type envelope.
kept them in the office.
the side.
is letter, right?
We
They had a big accordion on
A little bit -- What's that size?
8 1/2 x 11
Correct.
Bigger than that, legal and accordion.
10
And this occurred after a show; is that
11
accurate?
12
I don't recall whether it occurred after a show
13
or it was a separate visit out there.
14
it either happening -- I don't recall which one it was.
15
I seem to recall
Didn't you tell me earlier and tell Mr. Scherer
16
last week that the only contact you had with my client
17
was during the course of a show?
18
No, that's what you said.
19
Didn't you tell Mr. Scherer that last week?
20
21
It's a question.
A
I thought I testified in the beginning of this
22
that I had contact with her in my office, at Bova, and
23
at the bank.
24
driving out there for any other reason, so --
25
It's very -- you know, I don't recall
That wasn't my question.
My question was,

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didn't you tell Mr. Scherer last week that the only
contact that you had with my client ever was in the
course of the so-called shows?
That sounds correct.
Are you changing your testimony now?
No, sir.
Well, you made a special visit or an extra
visit other than a show to deliver the $25,000.
testimony is different than your testimony last week in
10
That
that regard, correct?
11
My statement is --
12
Correct?
13
-- what my statement is.
I understand what
14
you're trying to do, but I'm not going down that road.
15
My statement is what my statement is.
16
During this visit, whether it was part of a
17
show, after a show, or whatever, you claim you asked my
18
client to step outside for a chat; is that accurate?
19
that what happened?
Is
20
I did ask her to come outside, yes.
21
That means you were in the bank when you asked
22
her to step outside?
23
Yes.
24
Where were you in the bank when you asked her
25
that?

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I don't recall.
I believe you testified that you're aware that
there were surveillance cameras in the bank?
Sure.
Did you know it at the time or you've come
to --
I knew it before we did the very first show.
Had you scouted the bank to see where the
cameras were?
10
Yes, sir.
11
Where were they located?
12
I don't recall.
13
Are you aware that there was a camera located
14
behind the tellers' counter that was trained on the
15
front doors?
16
I don't recall.
I assumed every time I went in
17
that bank that every single thing that I did was filmed
18
whether I was walking to the bathroom or walking in and
19
out of the front door or in and out of the conference
20
room or in and out of the back offices.
21
If this occurred in the summer of 2009 --
22
No, no.
23
Wait, wait.
24
Go ahead.
25
I understand that you're not accepting that
Let me finish my question.

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premise.
But I'm saying, if it occurred --
Fair enough.
-- in the summer of 2009 as you have indicated,
that is, you asked her to step outside for a chat while
you're inside the bank, then you and her stepping
outside together would have been captured by the
surveillance camera behind the tellers' counter?
8
9
I don't think so because my recollection is
that I went out -- I didn't walk in there with the
10
envelope.
11
car, and she met me outside.
12
through the doors together.

Q
13
14
I walked out, retrieved the envelope from my

I don't recall walking
When you walked outside were you alone with
her?
15
Eventually, yes.
16
Eventually as you walked away from the
17
building?
18
Yes.
19
Which direction did you walk?
20
I don't recall.
21
Did you drive there yourself or did you have a
22
driver drive you there?
23
24
me there.
25
My recollection is that I had my driver drive
So this was not part of a show?

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2
No.
There were times when I did a show that I
had a driver.
I'm talking about this particular occasion.
I just don't recall.
It's possible that I
stayed there, but I don't think so.
and I'm trying to recollect it, it seems to me that it
was not part of a show and it was a very specific visit
for a specific purpose.
9
10
As I'm sitting here
Was there anybody around when you handed her
the envelope?
11
No, sir.
12
There are no witnesses to you doing that,
13
correct?
14
No, sir.
15
And you indicated that after you handed her the
16
envelope that you told her it was a gift for you taking
17
such good care of us.
18
Is that what you told her?
I believe the words I used with her were
19
something to the effect of, Thanks for taking such good
20
care of us.
21
So this was a gift from you?
22
It was payment for doing something illegal, but
23
I suppose you could consider it whatever you wish to
24
consider it.
25
She never asked for this money, did she?

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No.
Actually I don't recall -- I recall very
few people during the entire course of the Ponzi scheme
asking me for payoffs.
13 million I gave him.
Mike didn't even ask me for the
did she?
No, sir.
The only thing she ever asked you for was a
9
10
11
She didn't know anything about a Ponzi scheme,
$2,500 donation for the Special Olympics, which I

believe was July of that year; do you remember that?
A
Yes.
She never asked me for money for doing
12
what she was doing.
13
beginning when she did it, she wasn't being paid.
As a matter of fact, in the
14
She was doing it for free then?
15
Initially, yes.
16
For the first eight or nine months?
17
I don't know the time period.
18
Doesn't that sound silly?
19
No, sir.
20
Far fetched?
21
No, sir.
Not at all.
Not at all, not given
22
the context of everything that was going on at that
23
bank.
24
25
No, sir.
I believe you mentioned the fact that you were
aware that Rosanne adopted a little girl along the way?

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I was.
How did you become aware of that?
Someone in my office told me, and she also
4
5
wrote it to me in an e-mail.
Q
And you thought - you didn't commit to this -
that you or your office may have sent her a present.
you remember that testimony last week?
Do
I do.
Would you be surprised to find out that you or
10
your office did not send her a present?
11
I would be shocked.
12
Were you also aware that she adopted the little
13
girl, Reese (phonetic), towards the end of June of the
14
summer of 2009?
15
I don't recall.
16
That she was on maternity leave the rest of the
17
summer, the next nine weeks and wasn't in the office?
18
I do recall her being on leave.
19
So you couldn't have had any contact with her
Yes, sir.
20
during the period of time that you recall her being on
21
leave, correct?
22
23
No.
I think you can safely rule that out as
the time I paid her.
24
Let's talk a little bit about Uncle Bill.
25
Sure.

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2
MR. CRAIG:
another exhibit.
3
4
5
6
Before we do this, let's mark

BY MR. CRAIG:
Q
I'm showing you what's been marked as
Defendant's Composite 213 for identification.
This
consists of four pages which are not Bates stamped.
Okay.
10
Could you take a look at that document and tell
11
12
13
me if you recognize it.

A
Is Page 3 supposed to have something on it,
because it doesn't?
14
This is how it was produced to me.
15
Okay.
16
A waste of paper, right?
17
I do recognize it.
18
What do you recognize it as?
19
A series of e-mails between Mr. Damson,
Yes, I recognize it.
20
Mr. Spinosa, and I.
21
of e-mails between Mr. Damson, Spinosa, and I.
22
23
Well, actually no.
Yes, a series
The last page of which is a so-called lock
letter dated August 17, 2009, on RRA letterhead?
24
Yes.
25
Signed by yourself?

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Yes.
Counter-signed purportedly by Mr. Spinosa?
Yes.
Do you recognize that as being the first lock
letter?
6
7
8
9
10
11
12
I don't recall what date the first lock letter
was.
Q
Do you have reason to doubt that that was the
first lock here?

A
I don't have a reason to think either way.
don't recall the first date.

Q
If that was in fact the first lock letter, that
13
would have been the occasion in which you testified that
14
Ms. Caretsky questioned Mr. Spinosa.
15
testified you had a discussion with her about, What's
16
the purpose of this lock letter?
17
view of the fact that you can move the money on-line
18
from Treasury Direct at any time you want.
19
remember that?
And I believe you
I don't get it, in
Do you
20
I had a conversation with her about lock
21
letters.
I don't recall which lock letter I was
22
discussing.
But it was our form of lock letter, yes.
23
Okay.
24
I think it was more directed towards the ones
25
that Frank was ultimately drafting.

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In fact, if this was the first lock letter,
this discussion would have occurred a year to nine
months after she was on board as a player, correct?
4
5
I don't know when the conversation occurred.
don't want to guess.
Getting the hang of it, huh?
You don't want any guessing.
8
9
I'm not giving
you any guessing.

Q
Let's talk about Uncle Bill.
How is Uncle Bill
10
related to you other than being your uncle?
11
mother's brother?
Is he your
12
My mother's brother.
13
Your mother's brother?
14
My mother's brother.
15
How old is Uncle Bill?
16
Uncle Bill is in his mid 60s.
17
Is he originally from South Florida or did he
18
move down here at some time?
19
From New York.
20
When did he move down here?
21
I don't recall.
22
Was he married?
23
He is married right now, yes.
24
Was he married during the operative period of
25
time, 2006 or '07 through 2009?

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2
He was married the entire time, but he may have
been separated from time to time.
Tell me about his background.
college?
What kind of work did he do?
High school.
He was in the car business for
many years.
Used car salesmen?
Used car salesman?
Did he go to
I suppose, yes, at some
point in time he sold used cars.
He was the director of
10
leasing for Braman, for all the Braman car dealerships
11
for many years.
12
13
Did he work in the car sales business all the
way up to the point in time he came to work for you?
14
15
that.
16
But the bulk of the time of his employment was always in
17
some form of the car business.
I don't remember if he had jobs in between

He was always involved in one job or another.
18
Okay.
19
Except for a time when he owned a night club
20
many years ago in New York.
21
A night club like a gentleman's club or --
22
No, no.
23
-- the regular kind?
24
A regular night club.
25
When was it that he came to work for you?

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2
You'd have to check the financial records.
don't want to guess.
Do you know the year he came to work for you?
No.
Do you know the circumstances surrounding how
it was he came to work for you?
I asked him to come to work for me.
And at that point in time you asked him to come
9
10
to work for you, did you have a plan to involve him in

your Ponzi scheme?
11
Nope.
12
When he came to work for you what was his job
13
title and what were his job duties?
14
When he originally came to work for me?
15
Correct.
16
for you?
17
It was on and off.
18
Did he have another job during this period of
19
time?
20
He may have.
21
During let's say the last year of your Ponzi,
22
23
How many times did he come to work
I don't specifically recall.
what was his title and what were his job duties?
A
He was some type of director.
Director of law
24
office management, director of something.
25
at that point in time was to assist Irene with some
And his job

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basic bookkeeping stuff, just basically help the law
firm keep running.
Irene Stay was your CFO?
Yes.
And when was it that Uncle Bill first became
involved in your Ponzi scheme on any level of illegal
activity?
Now you're getting into all the tentacles.
You're including the political stuff, everything else?
10
Yes.
11
I don't recall a specific date.
12
What tentacle did he first become involved in?
13
I'd be guessing.
14
When did he first become involved in the Ponzi?
15
It would have been at the time that money was
16
being moved from account to account and Irene wasn't
17
there.
18
19
Would that be during the time where the
majority of your money was at Gilbraltar or TD or --
20
Gilbraltar.
21
Was he actively involved in the Ponzi while the
22
money was at Gilbraltar?
23
I don't recall specifically.
24
Was he involved in the Ponzi while the money
25
was at Gilbraltar?

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I don't recall.
It's hard to pinpoint because
a lot of what he was doing initially was just doing
whatever I asked him to do without questioning me.
think there came a point in time later on where he
realized that what I was doing was illegal and just
continued to assist me.
7
8
You emphasized "without questioning you."
No.
10
He's a loyal soldier?
11
Yeah.
12
You wouldn't have expected him to act as a
That's just the way he was.
He was a good soldier.
Yes, sir.
rogue employee, so to speak?
14
No, sir.
15
It would have shocked you for him to do
16
something that you either told him not to do or you
17
disapproved of?
18
19
That
was part of his job duty, to just do as you say?
13
So I
It wouldn't have shocked me if he had said
something to me about what I was doing, but he didn't.
20
Did you keep him on a short leash?
21
No.
22
with Bill.
23
Did he have access to money?
24
I'm certain that he did, yes.
25
Large sums of money?
There was no such thing as a short leash

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2
law firm's money or access to -Q
3
4
When you say access, do you mean access to our
Strike that.
I'll get back to that in a
second.
Okay.
What was his salary or what was his wage?
I don't recall.
between a hundred and $150,000 a year.

Q
9
10
Straight salary, no end of the year bonus,
commission?
11
12
I think we were paying him
I may have given him a bonus.
The records will
speak to what I gave him exactly.

Q
13
You have spoken on numerous occasions about
14
your stash or stashes; one in your office, one in your
15
credenza?
16
My credenza was in my office, yes.
17
Did you have a credenza at home with a stash in
19
I didn't keep very much cash at home relatively
20
speaking.
21
That was your stash, correct?
22
Which one?
23
The one in your credenza in the office.
24
That was, for lack of a better term, Ponzi
18
25
it?
money.

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2
Was it a community stash?
Did more people than
you have access to it?
No.
You're making a face like that's a ridiculous
question.
Given the way - I had some partners that spent
money much like I did, well not close to what I did, but
in the same vein as I did, and giving them access to
that much cash probably would not have been a good idea.
10
11
In addition to your partners, Bill Brock didn't
have access to your stash either, did he?
12
No, sir.
13
So, if he ever gave money or claims to have
14
given money to Ms. Caretsky, that would have come from
15
someplace else other than your stash, correct?
16
17
18
He would have taken it from -- yeah, it would
have come from someplace else.

Q
And you've already told us the only money
19
you're aware of Ms. Caretsky receiving in connection
20
with your illegal activity in the Ponzi scheme was the
21
$25,000 on that one occasion?
22
23
24
25
It was between 25 and $30,000 on one occasion.
She never took anything else from me.

Q
No, sir.
And she never took anything else on your behalf
to your knowledge, correct?

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To my knowledge, no.
And if Bill had given her a large sum of cash,
3
4
you would have known about it, wouldn't you?

A
No, I wouldn't have known.
Bill was always
looking out for me and always looking out for the law
firm and looking out for its best interest even on the
illegal stuff.
8
9
10
So is it possible that he greased some wheels

somewhere?
Sure.
But the truth is I don't know one way
or the other.
11
Let's talk about the shows some more.
12
Okay.
13
I believe you testified, and I may be wrong
14
about this, that the way that you could tell whether any
15
of the account letters, the cover letters that had the
16
account information that accompanied the account balance
17
statements, were fraudulent or had been created by you
18
or on your behalf, was if they had account balances in
19
the letter itself; is that a fair statement?
20
That's one of the ways.
21
What was the other way?
22
We discussed the other day -- I don't know
23
which day it was.
24
you look at the e-mail traffic surrounding the
25
particular letter, you can see the ones that Deb created
We discussed the other day that if

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for me because you'll see an e-mail from me to Deb
generally giving her the contents.
creating the whole scan font thing with it, and then her
sending it back to me, and then me forwarding it out to
whoever I needed to send it to.
ways.
Then you'll see Deb
That's one of the other
Did you ever fraudulently create a so-called
lock letter?
I may have, sure.
Yeah.
Mr. Spinosa was -- As
10
a matter of fact, I do recall an instance, and if you
11
depose Ms. Villages she'll attest to this, I do recall
12
an instance when I was on the speakerphone with
13
Mr. Spinosa and I needed a lock letter.
14
available and he told me to just sign his name.

Q
15
He was not
Now, would it be a fair statement that since
16
you weren't present at the time when any of the real
17
account balances were printed up in connection with
18
these shows, you had no idea as you sit here today who
19
actually went into the TD Bank computer and printed them
20
up?
21
I have no idea who went in there.
22
Prior to the shows, Uncle Bill's job was to get
23
there before you did with an envelope with the fake
24
account balance and ensure that the fake account balance
25
was switched out with the real account balance

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underneath the cover letter, correct?
He was the deliveryman, yes.
Now, I believe you've already testified that as
part of this process that the bank representative,
whether it be Ms. Caretsky or Ms. Kerstetter, I believe
you've indicated that both of them were involved, they
would print up a letter, the standard account balance
letter, sign it indicating the existence of the account,
and initially underneath that place in the envelope the
10
real account balance statement, correct?
11
No, sir.
12
They would not print up the real account
13
balance?
14
15
There was a lot to that question.
Part of what
you said was inaccurate.
16
What part of what I asked you was inaccurate?
17
My understanding is that they printed up the
18
original letter.
19
asked them to keep as a form.
20
the balance statements, the real ones.
21
them.
22
Bill arrived with the fake bank statements.
23
24
25
It was a form that we created that we

That they would print up
They would keep
But nothing would be put in the TD envelope until
Do you recall last week giving testimony
inconsistent with that?

A
If you show me my testimony maybe it will

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2
refresh my recollection.
Q
Let me ask you this question and see if this
refreshes your recollection.
Do you recall in an answer
to one of Mr. Scherer's questions or it could have been
Mr. Lichtman's questions that the TD Bank
representative, whether it be Ms. Caretsky or somebody
else as part of this show process, when they printed up
the real account balance statements that go along with
the cover letter they would put both of them inside an
10
envelope?
11
I never testified to that.
12
That did not occur?
13
I never testified to that.
I never said they
14
put the fake bank statements in and the real bank
15
statements in the same envelope.
16
17
18
19
No, sir.

BY MR. CRAIG:
Q
Let me show you what's been marked as
20
Defendant's Exhibit 214 for identification.
21
record, this is an e-mail I guess starting on
22
September 15, 2009, at 9:02 a.m.
23
marked as Exhibit 21 to Caretsky's deposition on
24
January 14, 2011.
25
For the
It's previously been
Could you take a look at this e-mail and tell

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me whether you recognize it.
I do.
And how do you recognize it?
I remember receiving it and responding.
The initial e-mail as part of this chain you
received was from Mr. Szafranski?
Yes.
Also known as Mikey?
Yes.
10
And what did this have to do with?
11
Ira wanted to go to TD Bank, and I was telling
12
him if Mike has explained the process, because Ira was
13
very lovingly -- he was a motor-mouth and I did not want
14
him to engage Rosanne in significant conversation in the
15
middle of the bank.
16
difficult position, nor did I want her to realize that
17
Mr. Sochet was an investor and not a client.
18
I did not want to put her in a
That was the reason for you indicating in the
19
e-mail -- or Mike indicating in the e-mail to me
20
Mr. Sochet, "Okay.
21
process.
22
No, no.
23
I stand corrected.
24
-- to Mike, not Mr. Sochet.
25
The top one is from you to Mike.
No problem.
Have you explained the
No freaking Rosanne out.
Love ya."
That's me --
And you are

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indicating that you don't want to freak Rosanne out?
Yes.
That seems a little nonsensical in view of the
fact that at that point in time, September 2009,
according to you, Rosanne had been on board and been a
player for about a year.
by anything?
8
9
No, no.
Why would she be freaked out
You don't understand.
Rosanne
believed that the phony bank statements that she was
10
providing to the people I walked into the bank with was
11
solely for the
12
that there was more money in the bank than there was so
13
that I could get future business from them.
14
purpose of me convincing these people
She did not know what was going on as far as
15
the investment scam and the like.
16
significant concern that Mr. Sochet, who I lovingly
17
referred to as a motor-mouth might engage her in all
18
kinds of conversation other than what we were
19
specifically going to the bank for.
20
him in.
21
MR. CRAIG:
And I had a
So I had Mike reel
Mr. Scherer, this is an e-mail that
22
I know has a Bates stamp.
23
with a Bates stamp.
24
marked as an exhibit to the deposition.
25
produced as part of the Szafranski Onyx Capital
I could not find a copy
I know it's previously been

And it was

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production without a Bates number.
MR. SCHERER:
MR. CRAIG:
I have lots of copies.
It's

7
8
Yes.
being marked as Exhibit 215.
5
6
Do you have a copy?
THE WITNESS:
Thank you.
BY MR. CRAIG:
Q
Could you take a look at that, please,
10
Mr. Rothstein, and tell us whether you can identify it
11
or recognize it.
12
I've never seen this before.
13
Do you doubt its authenticity?
14
I don't doubt it one way or the other.
15
I've
never seen it before.
16
Could you read it out loud, please?
17
From Michael Szafranski, sent Thursday,
18
September 17, 2009, at 9:35 a.m., to Mel E. Lifshitz.
19
Subject:
20
Second 10.
"Apparently I am verifying the other 10mm
21
today.
22
docs.
23
regarding your request.
24
constant activity at the bank, a constant letters are
25
being viewed by the bank with some suspicion, so we are
I have instructed them to have the correct

I am going to the bank today and spoke to Scott
He is a bit concerned about his

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figuring out a way to get it done.
President, Onyx Capital Management", with his address.
Michael Szafranski,
the time?
I don't understand your question.
Okay.
that.
That was a bad question.
I'll give you
Is the verbiage that you just read into the
8
9
Is that consistent with what was going on at
record consistent with the concerns that you had about
10
the bank being suspicious of your activities on or about
11
September 17th of 2009?
12
No, sir.
13
Did you ever have any concern in September of
14
2009 or any other time that the bank was becoming
15
suspicious of your activities?
16
17
20
21
That was a sham we set up to get
people to stop asking for bank visits.
18
19
No, sir.

BY MR. CRAIG:
Q
Showing you what I'm going to mark as
22
Defendant's Exhibit Composite 216 for identification
23
consisting of two pages, Bates Trustees/Spinosa 00422
24
and 423.
25
Mr. Lifshitz dated September 17, 2009.
It's an e-mail exchange between you and

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Do you recall this e-mail exchange?
1
2
Give me one second to read it.
I do recognize this and recall except for this
Grubman, Rita thing across the top.
that is.
Ignoring the Grubman, Rita up top --
Yes.
-- do you otherwise recognize this e-mail
exchange?
I don't know who
10
I do.
11
I guess the one at the bottom preceded the one
12
at the top.
13
at the bottom of that page?
14
Could you read your e-mail to Mr. Lifshitz
"Looks like I pulled it off.
Spinosa will do
15
the letter.
16
and answer his questions.
17
Rosanne to see if she would do it.
18
later today if she is comfortable with it after I just
19
came in and got statements, but I think she will."
20
Meeting with him in the morning to discuss
Next paragraph.
Also call the bank manager,

She will let me know
"Please wire the 3m in the
21
morning so I can get the rest of the first 10
22
distributed tomorrow.
23
late Monday.
24
Monday...
25
good.
I don't need the second 10m until
So we have tomorrow and most of the day
So long as it hits by 5 p.m. I should be
If you need until Tuesday I can pull it off if

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you can get me half, 5m Monday afternoon, so I can
spread some bucks around to the masses.
posted.
Love ya.
Call me when you can.
Keep me
Scottito."
Mr. Lifshitz responds, "Awesome, buddy.
Thanks.
Really appreciate it.
back home, but with people.
Just landed and headed
Will call you later."
Yes.
The second line of your e-mail to Mr. Lifshitz
after indicating that it looks like you pulled it off.
10
Spinosa will do the letter.
11
bank manager, Rosanne, to see if she will do it.
12
will let me know later today if she's comfortable with
13
it after I just came in and got statements, but I think
14
she will.
17
She
What are you referring to her, you thinking
15
16
You indicate, Also called
that she will do?

A
I have no idea.
I'd need to see the e-mail
18
traffic before this and after it.
19
her to see if she would do something, that's a lie.
20
21
You never talked to her on the phone in
connection --
22
23
no, sir.
24
25
But as far as calling
About something connected to Mel E. Lifshitz,
Okay.
Let me see if I can help you out in that
regard.

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2
3
4
5
Thank you.

BY MR. CRAIG:
Q
Showing you what's been marked Defendant's
Exhibit 217 for identification.
It's a two-page e-mail
that's been previously marked as Exhibit 22 to
Caretsky's January 14, 2011 deposition marked as an
exhibit by the Plaintiffs.
Back page is a September 17,
10
2009 account letter which includes a $60 million
11
balance.
12
yourself and I believe Debra Villegas and also from
13
Mr. Spinosa to you.
And there is an e-mail exchange between
Do you recognize these documents?
14
15
I do.
16
What are they?
17
The back letter is a fraudulent letter that we
18
created in my office.
19
e-mail sequence that we created to add authenticity to
20
the fraudulent letter.
21
The top section is a fraudulent
Does that help refresh your recollection as to
22
what you were referring to in Exhibit 216 regarding
23
calling Rosanne to see if she would do it?
24
It does.
25
That is, create a false account letter with a

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balance?
No, no.
How is that wrong?
Because Rosanne was not involved in creating
5
6
7
That's wrong.
any false account letters that contained balances.

Q
Then I asked you a bad question or that was not
the intent of my question.
Okay.
I don't doubt that for a second.
10
Go ahead.
11
The reference you have to see if Rosanne would
That's what the question was.
It's getting late.
Go ahead.
12
do it, that refers to providing a letter referencing an
13
account.
14
Fair enough?
Yes.
What was occurring was, this is more of
15
our sham trying to get investors to stop having us make
16
so many bank visits.
17
would do it, that whole kind of thing is all a lie, to
18
stop Mel and others from regularly asking us to do bank
19
visits.
20
The whole Rosanne, to see if she
I then tell Mel, looks like we pulled it off.
21
And this is what we pulled off.
22
nothing to do with this particular letter.
23
24
25
But Ms. Caretsky had
And the letter you're referring to is the
second page of Exhibit 217?

A
That's correct.

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Q
Which is the account letter that contains a 60
million dollar balance, which was created by you or on
your behalf in your office?
That's correct.
That would have been created by Mr. Corte or
Mr. Renie?
No, that would have been created by
Ms. Villegas.
Q
Based upon a computer program set up by either
10
Mr. Corte or Mr. Renie or could she have done that
11
without their help?
12
13
help.
14
By the way, who are Mr. Corte and Mr. Renie?
15
Mr. Renie was the director of information
She probably could have done it without their

I have no recollection one way or the other.
16
technology at the law firm; and Mr. Corte was the
17
assistant director.
Q
18
Was he already an employee for some time before
19
he got involved in creating the false TD website and
20
false documents?
21
22
23
24
25
They had been employed for some time before,
yes.
Q
And were you the one that initially approached
them about becoming involved in your illegal activity?

A
Yes.

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Tell me about Mr. Corte?
Did you hire him
specifically to come in and assist Mr. Renie in creating
a false TD Website?
No, they weren't hired specifically for the TD
thing.
information technology work for us.
him both to us at separate points in time.
8
9
They were actually hired to really do

Somebody referred
Mr. Corte's main role in the Ponzi scheme was

to create the more sophisticated, like the web page, the
10
fake TD web page.
11
website, that kind of stuff was done by Mr. Renie.
12
although their duties interchanged, there was a
13
particular piece of software we needed to use to create
14
the fake website and Mr. Corte was far better versed at
15
using that software than Mr. Renie was.
16
17
The updates and the like to the

So
How long did you know Mr. Caputi before he
became involved in your illegal activity?
18
15, 20 years.
19
You were business partners with him?
20
That was during and after the illegal activity.
21
I believe during the first day of your
22
testimony you referenced either also being involved with
23
check kiting or money laundering with him in the past;
24
is that correct?
25
Yes, um-hmm.

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2
3
Was he indebted to you at the time that he
became involved in your Ponzi scheme?

A
I don't know if he was indebted to me.
I don't
think I made Steve feel like he was indebted to me for
anything.
relationship.
7
8
We always had a mutually beneficial
Would that be in the legal context or the
illegal context or both?
Both, both.
10
Was he intimidated by you?
11
No.
12
Why did you need him involved?
13
Say it again.
14
Why did you need to involve Mr. Caputi in your
15
16
Ponzi scheme?
A
I needed people to play certain roles and I
17
went to the people that I know were willing to do just
18
about anything for money.
19
Well, what specifically was his role?
20
Pretend to be a banker, pretend to be a
21
Plaintiff.
22
Let's talk about --
23
That's in the direct Ponzi, not the tentacles,
24
25
not the check kiting and not the thing with Silverseas.
Q
Let's talk about the pretend to be a banker

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part; why did you need Mr. Caputi to pretend to be a
banker?
Certain investors wanted to meet a banker at TD
Bank , to be able to speak directly with the banker.
Caputi was the person I solicited to do that.
6
7
And this was after Ms. Caretsky was already on
board and a player, in your mind?
I'd be guessing as to the time frame.
Well, if that was so, you still wanted to hire
10
11
Mr. Caputi even she was on board at the time?

A
I had -- I only involved Ms. Caretsky to the
12
extent of taking the fake bank statements, putting them
13
with her real letter, and handing it to me or my
14
investor.
15
16
17
That is the full extent of her involvement.

How did that differ from Mr. Caputi's
involvement?
A
Mr. Caputi answered extensive questions
18
regarding banking from investors, completely different,
19
completely different level.
20
Are you aware that's diametrically opposed to
21
his deposition testimony in this case and his sworn
22
testimony in the trial in the Coquina case?
23
Are you asking me if that would surprise me?
24
No, I'm asking you are you aware of it?
25
I'm not aware of it and it wouldn't surprise

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2
me.
Q
Do you have a specific recollection as you sit
here today of any of those bank visits involving
Mr. Caputi?
Sorry, say the question again.
Do you have an independent recollection as you
sit here today of any of those bank visits involving
Mr. Caputi?
I recall sitting with Mr. Caputi in the Weston
10
branch and discussing accounts with him, but I can't
11
picture who's asking the questions.
12
Okay.
13
But I remember him answering questions about
14
15
our account balances.

Q
Do you remember you telling him, Steve, this is
16
what I want you to do, I want you to go home and put a
17
suit on and I want you to meet me at the TD Bank at a
18
certain time, I want you to go inside, there will be an
19
individual, Uncle Bill, who's going to hand you an
20
envelope and a business card.
21
in the conference room.
22
investor and I'm going to ask questions and all I want
23
you to do is follow my lead.
24
25
I want you to go sit down
I'm going to come in with an
Do you recall that happening; you giving him

those instructions?

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It sounds incomplete to me.
What part of it is incomplete?
Because I had him actually verify bank balances
during the meeting that I can recall speaking to him.
And I also recall - and I may have been -- Well, I don't
know if it was Jack Simony or not, whoever the investor
was that was in the bank with us, they specifically
talked to him.
And I specifically recall at some point in time
10
the conversation to me appearing to go too long.
11
said, okay, we got to go, as it was putting Caputi in a
12
difficult spot.
13
participation that I had him do when he did the whole
14
Plaintiffs, playing the Plaintiff, but it was more than
15
simply handing an envelope.
16
It wasn't near the level of
According to you, when Ms. Caretsky was, who
17
you I believe described as an integral part - piece to
18
the survival of your Ponzi scheme, she didn't just hand
19
an envelope, as you allege, she handed an envelope that
20
contained a fake account balance that she put in there;
21
correct?
22
Correct.
23
If she was willing to do that, it doesn't make
24
sense why she wasn't willing to sit in the conference
25
room and tell an investor that there was 60 million

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dollars in an account that didn't exist.
nonsensical; doesn't it?
No, not at all.
That seems
You don't understand the
dynamics involved in a fraud of this magnitude.
you involve people -- if you look at everyone I
involved, okay, there are a tremendous number of people
who were involved in tiny little pieces that were
integral to the Ponzi survival, but it was still just a
tiny little piece, something that they had to do,
When
10
whether it be changing the stock ticker symbol on the TD
11
website, changing one number in a balance, forging a
12
signature, some people simply created plaintiffs' and
13
defendants' names.
14
involved here.
15
not nonsensical at all.
16
All kinds of different players
The answer to your question is, no, it's
You only involve people to a limited extent as
17
you require of that particular purpose, at least that
18
was my rule of thumb.
19
20
strike it.
21
Can we take five minutes?
22
Sure.
(Thereupon, a short break was taken.)
23
24
25
Your answer is non responsive and I'm moving to
BY MR. CRAIG:
Q
Back on the record.

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I want to clarify a couple of matters that you
1
2
testified about earlier during my examination.
asked you during the shows when the envelope was
handed -- strike that.
I just
Who did Ms. Caretsky or Ms. Kerstetter or
5
6
Mr. Mejia or Mr. Garces hand the envelope to during the
show; you or your client/investor?
Either one.
You specifically recall as you sit here today
10
the envelope being handed to directly to the
11
client/investor on one or more occasions?
12
13
the other.
14
15
I don't have a specific recollection one way or
So, as you sit here today, you don't ever
recall it being handed to the investor/client?
16
17
the other.
18
19
20
21
It was either me or them.
I don't have a specific recollection one way or
Wouldn't your answer to that question more
appropriately be, I don't remember or I don't know?

A
don't.
I don't have a specific recollection.
That's -- I don't have a specific recollection.
22
Okay.
23
It's not that I don't know, I knew at some
24
25
point in time, I just don't recall at this moment.

Q
Didn't you initially answer either/or?

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2
MR. SCHERER:
A
Objection, form.
To me either/or, it had to have gotten into one
of our hands somehow.
It either went directly from Ms. Caretsky or whoever was
giving it to the investor or to me.
I have a specific recollection of it.
if I know for certain.
handed it to.
Ultimately the investor got it.
You're asking me if
I don't know which one they
I just don't remember.
Did you just tell us that you paid Caputi to
10
pose as a TD Bank representative?
11
last question, right before the break.
12
You're asking me
That I paid him?
Not in answer to my
I'm not sure -- in my mind I
13
always paid Caputi because I was always giving him
14
money.
15
matter of fact, I think there may be checks to him right
16
around the time that he was doing this.
17
take a look at the bank records to see.
18
Yes, he was paid to do whatever it was -- as a
You have to
Are you aware of the fact that he testified in
19
deposition in this case and in the trial in the Coquina
20
case that you in fact did not pay him --
21
Well --
22
-- to pose as a TD Bank representative and a
23
Plaintiff in your Ponzi scheme?
24
That he just did it because he loved me?
25
No.
As I recall he said when he questioned you

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about it you responded by saying, just shut up and do
it.
First of all, Steve --
Does that sound familiar?
No. Steve wouldn't have taken that answer from
me.
but not Steve.
enough to understand how that dialogue would have
occurred.
Other people may have taken that answer from me,
10
You apparently don't know Steve well
Mr. Caputi and I had a very long-standing
11
business relationship.
12
whether it was legal or illegal, I took care of it.
13
I needed something from him legal or illegal, he would
14
take care of it.
15
16
17
If he needed something from me,

If
No more complicated than that.
I think I'm about finished.
one or two more questions.
I do have at least
This is my last question.
After having a total of no more than an hour,
18
hour and a half total contact - face-to-face contact
19
with my client Ms. Caretsky, over the course of two
20
years, you would have a jury believe and perhaps others
21
believe that Rosanne would sacrifice her job, her career
22
her family, her newly adopted daughter, her freedom, her
23
life for a couple of lunches, a $2,500 campaign
24
contribution - or excuse me, contribution to Special
25
Olympics, a baby gift that you never gave her, and

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$25,000 in cash she never asked for; assuming that ever
happened; is that what you want a jury to believe?
3
4
MR. SCHERER:
A
Yes.
Object to form.
And I don't believe that she ever
perceived that type of risk from this.
was doing what she believed she had to do at that point
in time based upon my relationship with TD Bank.
8
9
MR. CRAIG:
I have nothing further
at this time.
10
11
Thank you.
I believe she
FURTHER DIRECT EXAMINATION

BY MR. GELBER:
12
I'm Dan Gelber, Mr. Rothstein.
13
All right, sir.
14
MR. GELBER:
How are you?
Mr. Nurik, these are the
15
exhibits.
16
don't have a separate -- I'm going to give him his
17
own, but they are also in there.
18
19
I'm going to give him parts of these.
BY MR. GELBER:
Q
Mr. Rothstein, my understanding is that you've
20
worked with the Trustee as part of your cooperation; is
21
that right?
22
I was ordered to talk to him.
I don't know if
23
you consider -- my understanding of Rule 35 is that the
24
civil stuff doesn't come in, so --
25
I don't mean cooperation.
You've been little C

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cooperating, you've been helping him make a case;
correct?
Yes.
How many times have you met with him and how
5
6
7
many hours?
A
Chuck would be the little C.
It's been a lot?
I met with them over three days, it was really
more like two and a half days.
When was that?
In August.
10
Now, in their complaint, on Paragraph 36 of the
11
Trustee's Complaint it says:
TD Bank then generated a
12
screen shot of RRA's account balance in a specific
13
account, prepared a cover letter verifying and enclosing
14
the account balance, deposited the cover letter and the
15
screen shot into an envelope which was furnished to
16
Rothstein in the presence of one or more investors.

That's not accurate, is it?
17
18
Not accurate.
19
That's an absolute falsehood that's in their
20
21
22
23
complaint, right?
A
Well, it's not absolutely false.
It's just
missing pieces.
Q
A critical piece of your Ponzi scheme and your
24
fraud was getting my client Ms. Caretsky, according to
25
you, to take these invoices that you created at

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Rothstein headquarters and -- not invoices, these
accounts statements, and put them in a letter, a real
letter at the bank.
That was a critical piece, right?
Yes.
And they got that critical piece absolutely
wrong in the Trustee's complaint, correct?
It's not perfectly correct, no, sir.
Well, perfectly correct might be a spelling
error or a grammar error.
They have TD Bank creating
10
the false account statements and you created the false
11
account statements; is that correct?
12
That's correct.
13
That's not a little error.
14
That's a major
error, correct?
15
16
occurred.
17
don't know -- I can't explain it any further than that
18
because I wasn't part of drafting that complaint.
19
20
21
22
That is a significant misstatement as to what

It doesn't contain the critical part.

BY MR. GELBER:
Q
Let's go to what these investor meetings or
23
what you and other people have called the shows.
24
first I'm going to ask you to look at 218.
25
MR. GELBER:
And at
And you all have that package

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there.
meeting.
3
4
218 is going to be the October 29th
BY MR. GELBER:
Q
Okay.
This is the meeting, and it's already
been presented to you, on October 29th.
This was the
letter.
the first investor meeting you had at TD Bank, right?
And it's been said that this might have been
That's -- we're guessing.
Yeah.
And if you look at the second page,
10
Jennifer Kerstetter says to Brock and copies it to
11
Rosanne, Here is a rundown of the accounts and available
12
balances, right?
13
Yes.
14
And then attached are the actual balances that
15
are put together with the amounts on them?
16
17
balances.
18
blank, and then the next ones are the fake statements.
19
The first page looks like the actual account

The subsequent page -- Well, one is almost
Right.
First of all, at this point Jennifer
20
Kerstetter is asking them to put actual balances
21
together because someone attaches the actual, not the
22
fake balances, right?
23
24
25
I don't know what she's asking.
I wasn't
there.
Q
Well, the words are here:
Here's a rundown of

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the accounts and available balances.
are the available balances.
those balances, is there?
And attached to it
There's nothing fake about
I don't know what the balances were, but they
seem to be correct.
to her, so I don't know what anyone was asking for or
whether she just provided them.
the other.
What I don't have is Bill's e-mail
I don't know one way or
First of all, if Jennifer Kerstetter was
10
involved, why would she send them an e-mail with the
11
actual account balances?
12
provide fake balances later that day or Rosanne was
13
going to be presenting fake balances, why would she send
14
them the actual balances?
15
If she knew she was going to
Do you want me to go ahead and speculate
16
because that's the only way I can answer that?
17
asking me why, what she's thinking.
18
This was your Ponzi scheme.
You're
This was one of
19
your operators.
20
telling Rosanne to prepare account statements with
21
actual real balances rather than fake ones?
22
23
else.
24
opinion, I will.
25
Tell me why Jennifer Kerstetter is
I don't know what anyone is saying to anyone

I'm asking, if you want me to give you my
But --
Let me ask you this way:
Do you think that

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putting the actual balances in the letter, in that
e-mail, is consistent with actually doing it the right
way and not the way that you might have wanted them to
do it?
No.
It's actually consistent with the way I
was under the impression they were doing it the whole
time, which was they were always printing the actual
account balances for their own internal plausible
deniability.
The second thing is, as I've testified
10
over and over again, I don't know specifically what date
11
Ms. Kerstetter became involved.
12
So, her putting the actual balances in an
13
e-mail could either be evidence of innocent conduct or
14
evidence of criminal participation depending when she
15
was involved?
16
17
don't know.
18
19
20
21
I can't answer that one way or the other.
I'd be guessing.

BY MR. GELBER:
Q
On December 10th, this is the second one and
22
it's marked 219, on this one you have Bill Brock on the
23
second page asking Rosanne Caretsky to print up account
24
numbers and she lists the account numbers.
25
says:
I'm not going to be in the office.
And then she

What accounts

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do you want printed out.

That actually came before it.
And then
actually early on on the third page it's Bill Brock
saying:
on a separate page.
I need those DOS reports again.
Yes.
Do you remember all this?
8
9
10
Each account
Does this all look
familiar to you?
A
No.
But this sounds familiar to -- it looks
like what we did on an as needed basis.
11
Now, it makes no sense --
12
But I have seen this e-mail string before.
13
Makes no sense for Bill Brock to tell Rosanne
14
Caretsky they're going to need those DOS reports again
15
on a separate page and use of your conference room if he
16
knows she's not going to use the DOS reports she prints
17
up, right?
18
No.
19
Tell me why it makes perfect sense.
20
to know.
21
It makes perfect sense to me.

I do want
Because we were in the habit of whenever we
22
sent out e-mails, all of us, to make sure that every
23
e-mail comported with what would be, especially with the
24
bank, comported with what we were attempting to appear
25
to be doing.

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says:
e-mail is full of these participants looking like
they're doing something totally innocent.
you said the scheme was intending to do?
So, what your testimony is, on the next page it

What accounts do you want printed out?
The
Is that what
I'd be guessing as to what all these people
were trying to do.
what I understand occurred or at least know occurred at
the bank.
I can only testify factually from
10
I understand.
11
I didn't instruct these people to just write
12
e-mails like this.
13
occasion tell certain people, Be careful what you put in
14
e-mails.
15
And it's your guess that --
16
I can't imagine -- Just let me finish.
Okay?
But I did on more than one
I can't
17
imagine how Bill would get any of this from these people
18
without asking for these statements.
19
he would write unless he was going to write something
20
about a crime about to be committed.
21
I don't know what
It's interesting, in this actual e-mail he
22
could have just listed the ones he wanted if he just
23
wanted to look like he was covering up or creating a
24
false trail, but he actually said, I need them each on a
25
separate page.

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So, is it your testimony that Bill is trying to
1
2
look like he's asking for something honest even though
something dishonest is going on?
It's my testimony that he's trying to provide
backup documentation to what we ultimately are going to
provide to an investor, which is statements on separate
pages.
8
9
10
11
We want everything to match.

But you would agree with me that at no point
were any of those actual account statements going to be

put in with the letter in the envelope, right?
A
No.
It's my understanding that they took those
12
and placed them along with a copy of the letter in some
13
folder some place.
14
We'll get to that in a second.
But the Ponzi
15
scheme you were running, you had absolutely no use for
16
accurate real account statements?
17
Unless we were looking for what the real
18
balances were, and that makes no sense because I could
19
have pulled them up on the screens.
20
You could have pulled them up at Rothstein
21
headquarters and you could print up the ones you wanted
22
at Rothstein headquarters.
23
for Rosanne Caretsky or Kerstetter or anyone else over
24
at TD Bank to print up an actual balance at any time,
25
you never needed it?
You had absolutely no need

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What you're saying begs the question because
they would also know that I could get these balances in
my office.
If they don't know what's going on, why not simply send
me back an e-mail saying, Why don't you just print the
screen shots up.
So why bother providing this to me at all.
Well, we'll talk about that in a moment.
But
the truth of the matter is, in every one of these -- in
fact, let's go to the December 17 one.
10
MR. GELBER:
11
MR. RABIN:
12
THE WITNESS:
What is the number on it?

220.
Just also in the context of the
13
e-mail, you know, I don't recall -- I know that I
14
saw it after the Ponzi scheme exploded.
15
saw Bill calling this "the show" repeatedly, I
16
probably would have told him, Let's stop calling it
17
that because that doesn't match the whole -- Let's
18
try to keep the e-mail -- you know, we don't know
19
who's reading e-mails at a bank.
20
the e-mail businesslike.
21
22
23
But if I
Let's try to keep

BY MR. GELBER:
24
25
meeting.
220, which is the December 17 investor

In fact, there's a string of e-mails before it

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where they're not just talking to Rosanne, I think
they're talking to folks at the bank, Jamie Bond, Jose
Garces, other people who aren't part, according to your
previous testimony, of your conspiracy, right?
Correct.
And, in fact, some of those people actually
used in the investor meetings, right?
I don't know what you mean, "used."
Well, they actually were people who had letters
10
created that they wrote that you put account statements
11
in.
12
13
14
15
16
There were other people other than -A
I never put account statements in any of these
that I recall.
Q
People who worked for you did that were part of
this conspiracy, right?

A
I can't tell you for certain, because I was not
17
there, who actually placed the document in with the
18
letter.
19
I wasn't there.
But you agree with me it was important that
20
whoever that person was, according to you, that they
21
were prepared to go along with the conspiracy, whatever
22
part of it they knew?
23
All they had to do was ultimately place the
24
fake bank statement in the envelope and hand it to me or
25
allow someone else possession of the envelope, allow

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them to place the fake bank statements in and then take
it from that person and still hand it to me.
matter which way you slice it, they were doing something
they should not have been doing.
5
6
So, no
Matthew Brennan, later in '09 -- you said you
didn't know who that person was.
As I sit here today I can't remember who he is.
He's actually one of the people that handed
you, or was in the vicinity, handed you an account
10
statement that was fabricated by your office.
11
no idea who he is?
You have
12
I don't know what you mean, "in the vicinity."
13
Well, during his deposition Matthew Brennan
14
said he actually was part of one of these investor
15
meetings.
16
statement in a letter and handed it to you to an
17
investor -- handed it to you or handed it to an
18
investor.
19
20
Mr. Brock came to him, and he put an account
Mr. Brennan said he put the statements in
there?
21
Mr. Brennan.
22
I didn't know he was involved.
23
Mr. Garces did the same thing, didn't he?
24
You're telling me that they placed the fake
25
bank statements in there?

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What I'm telling you is that you relied on a
lot of people to commit this fraud, but apparently you
relied on some people who weren't in, as they say, the
circle of trust.
you've said.
were receiving some of these account statements and they
were the ones that were providing them to you and
investors.
People who had nothing to do with what
They didn't receive bribes.
They actually
If they were putting the fake bank statements
10
in there, then they were involved at some level without
11
my knowledge.
12
Is that possible?
Are you saying that
13
Mr. Brock and others were involving people other than
14
Ms. Caretsky and Ms. Kerstetter without you knowing it?
15
To my knowledge, no.
But in viewing e-mails
16
all this time between people that I didn't see prior to
17
the explosion of the Ponzi scheme, there apparently were
18
many things going on I didn't know about.
19
I've never heard that Mr. Brock involved
20
someone else.
21
that these people actually put the fake bank statements
22
in there --
23
Is it possible?
If you're telling me
Actually, what I'm telling you is that they
24
were -- I don't think that any of the TD Bank officers
25
put fake bank statements.
What I think happened is I

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think your guy did a substitution and that's why --
In their presence?
Without them knowing it.
4
5
6
Because by the way, a
couple of these people -A
Think about that.
Does that really make sense
to you?
Let me ask you a question.
Let me ask you
this:
they actually weren't part of your conspiracy, yet you
A couple of the people who you're talking about,
10
actually received things from them.
11
involved?
12
were going to put false statements with their own
13
letters?
Nobody paid them.
How did they get
They just decided they
Jennifer Kerstetter didn't get a single dime
14
15
from you, according to your own testimony, not a single
16
dime.
17
UNKNOWN SPEAKER:
18
THE WITNESS:
Objection to form.
This is what you're missing.
19
don't believe that Ms. Kerstetter or Ms. Caretsky
20
had any clue as to the significance of what they
21
were doing.
22
they were, yes, committing a fraud, that they
23
simply believed that they were assisting a valuable
24
TD Bank customer.
25
I believe that despite the fact that
That's my belief.
These other people, this is the first time I'm

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hearing about them giving me envelopes that they
may have put fake bank statements in.
3
4
BY MR. GELBER:
Q
In that e-mail series, in a couple of the
e-mail series you see Mr. Brock and Ms. Caretsky and
Ms. Kerstetter actually saying, Mr. Rothstein is
coming.
of that is consistent with giving you an actual real
bonafide account statement.
Here are the account statements you need.
10
UNKNOWN SPEAKER:
11
THE WITNESS:
All
Objection to form.
Except for the fact that what
12
banker in their right mind, if they're not actually
13
involved in a fraud, is going to allow a letter, an
14
original letter from TD Bank with bank statements,
15
out of their control to the point where someone
16
you're saying could actually walk away, put
17
something unbeknownst to them in it, then stroll
18
back and they're going to take that sealed envelope
19
and pass it off to me?
20
participant in a fraud.
21
it, there's a problem.
22
23
That sounds like a

So either way you slice
BY MR. GELBER:
Q
They have to know that, though.
Is it your
24
assumption that you're a customer of a bank, they give
25
you an envelope with a letter in it, that their customer

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is going to go a switch?
At the time they didn't assume
that you were running a Ponzi scheme.
were a credible customer.
UNKNOWN SPEAKER:
THE WITNESS:
They thought you
Object to the form.
I don't want to argue with you
about it.
understand of any circumstance -- and I wasn't
there.
they had to substitute in the statements or they
10
allowed someone to substitute in the statements.
11
I'm just telling you that I don't
One of two things had to happen.
Both are problematic.
12
Ponzi scheme.
13
fraud.
14
BY MR. GELBER:
15
Either
Both facilitated the
Both allowed me to carry out the
There are videos of Mr. Brock actually leaving
16
with a letter and doing a switch elsewhere or throwing
17
away the actual account statements that was put in there
18
and then coming back.
19
UNKNOWN SPEAKER:
20
MR. SCHERER:
21
22
Objection.
Object to the form.
BY MR. GELBER:
Q
Why isn't it just as easy an alternative that
23
Mr. Brock during the course of these meetings with the
24
TD Bank folks when he left the room just simply did the
25
switch himself?

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UNKNOWN SPEAKER:
THE WITNESS:
Objection, form.
I don't know any banker in their
right mind who's not involved in a fraud that would
allow a customer to walk out with bank statements
so that they could switch something and then bring
it back, I suppose sealed, and then hand it back to
the person and that person is just going to hand it
to them?
aided my fraud.
10
If they don't know, either way to me it

I wasn't there.
My understanding was that on the bulk of
11
occasions they, meaning Ms. Caretsky at the very
12
least, substituted in my fraudulent bank statements
13
for the originals.
14
BY MR. GELBER:
15
Now, you --
16
But I was not there.
17
You understand some of those e-mail circuits,
18
they're talking to other folks other than Ms. Caretsky
19
and Ms. Kerstetter, who have, from your testimony,
20
absolutely nothing to do with your fraud.
21
understand that they're involved in the e-mail chain,
22
they're involved in the investor shows.
23
evidence from anyone that they've been criminally
24
involved in this.
25
must have happened through other people's actions on
Do you
There's no
And your testimony is that it just

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your behalf?
MR. SCHERER:
Objection, form.
THE WITNESS:
I'm guessing, but it would have
to be someone asking for their assistance, yes.
Because it just seems to me to violate every level
of smart banking protocol to allow someone to walk
away with a balance letter and then bring it back
all sealed up and say, Here, hand this off, will
you?
That just makes no sense to me one way or the
10
other.
11
BY MR. GELBER:
12
Earlier --
13
That's like allowing me behind the teller booth
14
15
16
and allow me to give people balances.

Q
I understand your point.
The point is, at that
point you were a trusted customer of the bank, correct?
17
18
the bank.
19
a gazillion red flags going off and I shouldn't have
20
been a trusted anything.
21
I was attempting to be a trusted customer of

I've since learned that apparently there were
At that point you were trying and pretending to
22
be a trusted customer of the bank; can you not answer
23
that yes or no?
24
I can.
25
In the community you were a very important
The answer is yes.

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member of the community, correct?
2
3
Some people thought I was, and I understand now
other people thought I was up to something.

Q
Why would they constantly, according to your
testimony, Ms. Caretsky was printing up actual bank
statements even though she knew you were substituting
out fake ones?
8
9
I can only tell you what I was told.
know for certain.

Q
10
Well, I want to go over the explanations that
11
you told us.
12
some questions.
13
It's December 13th in the morning.
14
30.
On December 13th Mr. Scherer asked you

I'm going to show you the transcript.
15
Thank you.
16
The question was:
17
I don't
I think it's Page
"Do you have information that every time you
18
would ask for a balance, that Ms. Caretsky or
19
Ms. Kerstetter would actually have the -- what was
20
in the account printed up for them so that there
21
would be a record in the computer at TD Bank of
22
them asking for a --"
23
"Yes"
24
"-- balance statement?"
25
Answer:
"Yes.
I didn't mean to cut you off."

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Question:
Answer:
"Yes."
Yes, yes."
Ms. Caretsky actually told
me that they needed to do that."
That's correct.
So it's your testimony that Ms. Caretsky told
you that the way she was going to create a sort of proof
of innocence in this would be by printing up an actual
bank statement so that the computer had a record of
somewhere that screen shot being printed?
10
No.
11
Well, when you said printed up for them so that
12
there would be a record in the computer at TD Bank, what
13
does "there would be a record in the computer at TD
14
Bank" mean?
15
It was a very simple conversation.
I said, You
16
know, we don't need the original bank statements because
17
Bill kept bringing them back to the office.
18
don't need these.
19
up for our own records.
20
I said, I
She said, Well, we have to print them

End of conversation.
I understand that was a second time.
That was
21
story number two later in the week.
I'm asking you
22
about this one.
23
beginning of last week was, "so that there would be a
24
record in the computer at TD Bank."
25
those words or didn't she?
The words out of your mouth at the
Did she tell you

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MR. SCHERER:
Object to form.
THE WITNESS:
What Ms. Caretsky told me is what
my answer is, not what Mr. Scherer was feeding me.
Ms. Caretsky actually told me that they needed to
do that.
That's as much as she told me.
BY MR. GELBER:
Q
So, when Mr. Scherer fed you this question, you
didn't say, That's not what she said.
yes.
You said, "Yes,
Ms. Caretsky actually told me that they needed to
10
do that."
11
Well, Mr. Scherer's questions are a lot like
12
some of my answers.
13
have balance information that every time you would ask
14
for a balance that Ms. Caretsky or Ms. Kerstetter would
15
actually have the - what was in the account printed up
16
for them so there would be a record in the computer?
Some of them are very long.
Do you
17
That was my understanding of it.
18
figure out why anyone else would be printing it up.
19
she did tell me that we have to do it anyway for our
20
records.
21
22
23
I couldn't
But
End of conversation.
There wasn't anything further.
There wasn't a
detailed explanation of it.

Q
So, on December 13th when you said yes, as to
24
the question, She was doing it so there would be a
25
record in the computer at TD Bank?
You didn't mean that

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there would be a record in the computer.
they were actually printing up hard copies?
accurate, is what you're telling me?
You meant that

This is not
I can't tell you whether it's specifically
accurate or not.
you're telling me right now that if you have to print up
something off your computer, that we have to do it
anyway, I would surmise that it's for a record in the
computer.
10
The record in the computer -- if
So, yes, what he asked me is accurate.
Okay?
11
But what you're trying to do is twist my words up.
12
You're talking about very lengthy conversations.
13
trying to play a little impeachment game by trying to
14
twist my words up.
15
what she said to me.
16
You're
The point is that she said to me
Listen, I understand you're accusing me of
17
twisting your words, but they happen to be your words.
18
And the term record in the computer means a footprint in
19
the computer.
Is it your testimony here today right now, not
20
21
last week, that when Ms. Caretsky came to you and
22
said -- that Ms. Caretsky did not say to you that she
23
needed to print them up to keep a record in the
24
computer?
25
Ms. Caretsky said to me, We need to print them

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up anyway.
needed a record of it.
that.
incorrect?
You have to show me the testimony.
You have it right in front of you.
The piece I'm looking at right now, Page 30?
Look, I don't know why this is so problematic.
10
11
12
13
I surmised that that meant because they
Okay.
I surmised that, she did not say
So, what you said last week was
You answered a question, "Ms. Caretsky said that -MR. LICHTMAN:
Objection, the witness is trying
to confirm what document.

THE WITNESS:
Let me do it this way:
On Page
14
30 you handed me, I stand by my answer as it reads
15
from the beginning of the question highlighted to
16
the end of the highlight.
I stand by my answer.
17
MR. SCHERER:
Was that an exhibit?
18
THE WITNESS:
It doesn't have an exhibit number
19
on it, Mr. Scherer.
20
MR. SCHERER:
21
MR. GELBER:
22
proceeding.
Mark that, please.

Oh, it's a transcript of this
All right.
That's fair.
23
What's the next number?
24
MR. RABIN:
25
(Whereupon, Caretsky Exhibit No. 221 was marked
221.

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(A discussion was had off the record.)
MR. GELBER: That is 222.
(Whereupon, Caretsky Exhibit No. 222 was marked
5
6
7
Mark this.
BY MR. GELBER:
Q
On December 16th in the morning you addressed
this same issue again.
recollection we never faked a cover letter.
10
And you said, "To my

We didn't
need to."
Question:
11
"Yeah.
And is it -- it's your
12
understanding that every time they gave you a fake cover
13
letter they asked the banks - they made a printed screen
14
shot from the bank of the actual balance to go along
15
with the cover letter?"
16
Answer:
17
Question:
18
"Yes, sir."
"So they would have some
deniability?"
Answer:
19
"Yes.
At one point in time I asked
20
Ms. Caretsky, I said, You know, I don't need these.
21
Just stick it in a file.
22
that they were printed out at the time that I wrote this
23
letter so we have a complete record."

Is that actually what you're saying happened?
24
25
She said, No, I need to show
To my way of thinking, this is completely

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consistent with the other record you just showed me.
It's a completely consistent answer.
But this has a printed document, and earlier in
the week it was keeping a blueprint in the computer like
in the cache or something like that.
6
7
8
9
In my mind both answers are completely
consistent.
Q
Let me ask you, What is the reason -- I mean,
are you saying that from your understanding Ms. Caretsky
10
was actually bringing actual account balances, real
11
ones, to the investor meetings that you had set up with
12
your investors?
13
the meetings?
She's actually bringing real ones to
14
No.
15
Well, at the actual investor shows that you had
16
been talking about, when she gave you that envelope with
17
the letter on top of it, you know that she was printing
18
up actual account statements at the same time?
19
I learned that --
20
UNKNOWN SPEAKER:
21
THE WITNESS:
Objection to form.
-- from speaking to Bill, yes,
22
and from seeing that he kept bringing these
23
original bank statements back with him and leaving
24
them for me and Deb.
25
BY MR. GELBER:

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Other than your claim that she told you this
was part of her coverup, it would make no sense for her
if she was part of your conspiracy to print up actual
account statements and give them to Mr. Brock while they
were doing these investor meetings?
6
7
8
9
I'm not going to guess what she thought made
sense or didn't.
Q
What possible sense could it have made to print
up the actual account statement and bring it to a
10
meeting where she's going to actually put in the
11
envelope a fake account statement.
12
UNKNOWN SPEAKER:
13
THE WITNESS:
14
15
Objection to form.
I never said she brought it to
the meeting.
BY MR. GELBER:
16
You said you learned that from Mr. Brock?
17
My best recollection is that we kept getting
18
the documents in the office.
19
some point it time I said that to Ms. Caretsky.
20
the end of it.
21
22
We didn't need them.
At
That's
It's not complicated.
When did you tell her, Please stop sending us
all these real account statements?
23
I didn't say it like that.
24
What did you say?
25
I said exactly what's in the record.

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And you said, Just stick them in the file?
I may have said something to that effect, yes.
So what you're saying is that Ms. Caretsky was
willing to give somebody she didn't know a fraudulent
balance statement - she was willing to give somebody she
didn't know a fraudulent balance statement, and her
deniability would be that she had printed up the actual
one and given it to you?
9
10
11
this level.
Q
12
13
I don't think she ever thought it would get to

Again, I'm telling you --
Then why was she creating a -MR. NURIK:
Let him finish the answer.
BY MR. GELBER:
14
Go ahead.
15
I already told you what I thought was in her
16
mind.
I don't think she or Ms. Kerstetter understood
17
the gravity what they were getting involved in.
18
think anyone thought it would get that far.
19
thought she was helping me.
20
21
22
23
24
25
MR. SCHNAPP:
I don't
I think she
I'm going to move to strike that
answer on behalf of TD Bank as not responsive.

BY MR. GELBER:
Q
You are saying -MR. LICHTMAN:
Speculation, too.
BY MR. GELBER:

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-- that Ms. Caretsky didn't think this was that
big a deal.
trail to make it look like otherwise innocent conduct
was actually innocent?
thinking.
7
8
But she was creating this sort of false
You're asking me to guess what she was

I don't think.
MR. LICHTMAN:
Objection to form.
BY MR. GELBER:
Now --
10
She could have avoided this all in the first
11
place by simply not doing any of this, by saying, I'll
12
print up the bank statements.
13
No, Mr. Brock, you can't have these.
14
them to him.
15
that either.
16
I'll hand them to them.

I need to hand
She could have done that.
MR. SCHNAPP:
She didn't do
On behalf of TD Bank I move to
17
strike that answer also as not responsive.
18
request that the witness respond only to those
19
questions that he's asked.
20
21
22
And I
BY MR. GELBER:
Q
right?
Mr. Rothstein, you don't want to go to jail,

I mean, your don't want to stay in jail.
23
Excuse me.
24
In fact, though, you think the judge was
25
I was sentenced to 50 years.
actually unfair to you in the sentence, don't you?

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2
3
I don't think that he was unfair given the
gravity of what I did, no, sir.

Q
You didn't say previously that you hope you're
going to get a reduction in sentence and mention that --
Well, let me read you what you said.

"I have to hope that Judge Cohn who has already
6
7
sentenced me to 50 years, which is 10 more than the
government was asking for, decides to be fair with me".

Are you not suggesting that the Judge was
9
10
11
unfair with you when you -A
No.
Again, you're trying to put words in my
12
mouth.
13
hopeful that - at the time that the government hopefully
14
asks for the actual reduction, that he is fair with me.
15
That's the best I can hope for.
16
One thing does not mean the other thing.
I am
As part of that you have to - part of what
17
you're trying to do with the Court is you're trying to
18
convince Mr. LaVecchio and the Court that you have made
19
everybody whole in this; have you not?
20
I'm trying to convince people --
21
MR. LICHTMAN:
22
MR. GELBER:
23
24
25
Objection to the form.

Let me rephrase that.
BY MR. GELBER:
Q
You promised the Court you are going to make
all legitimate investors whole; have you not

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And I will.
You've promised him that?
from you?
It's still a promise from me.
And you probably spent hundreds of millions of
That's a promise
dollars as part of this, that's just to the wind right
now?
Part of this?
In the course of your scheme you spent hundreds
10
of millions of dollars?
11
Sure.
12
It's going to be very hard to make your
13
investors whole unless you find ways to tag a deep
14
pocket with some liability?
15
I believe that if I'm released where I can
16
still be productive that I have the capacity to generate
17
significant amounts of money legally and pay these
18
people back.
19
And you're hoping - my understanding is you're
20
hoping that in fact a Court is going to look at this and
21
give you a substantial sentence reduction, whatever
22
cooperation you give.
23
Look at what?
24
Look at all your cooperation and give you a
25
I don't understand.
substantial sentence reduction?

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I'm hopeful that Judge Cohn treats me fairly.
If that means a substantial sentence reduction -- who
sentenced to 50 years wouldn't want a substantial
reduction?
You're expecting, absent that reduction, to
probably die in jail?
Yes.
Now, you understand your cooperation with the
9
10
government that you're not going to get credit for

exonerating people, you know that, right?
11
That's not true.
12
So, in other words, if your cooperating does
13
not lead to the investigation or prosecution of
14
somebody, you would get credit for the people that you
15
exonerated?
16
It's my understanding that my providing of
17
truthful testimony to them, both inculpatory and
18
exculpatory, aids me in my substantial assistance
19
because by exonerating certain people, it allows them to
20
focus their investigative energies in the proper
21
direction.
22
So, you think if you just exonerated people you
23
would get a reduction in sentence or isn't it really the
24
investigation of people with criminal liability that
25
gets you the reduction?

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I don't think I understand your question.
When you stand up in Court at some point,
you're hoping Mr. LaVecchio stands up and says he's
really helped us and he's made a lot of cases for us.
You're hoping that he says that?
I'm hoping that he outlines all my cooperation.
You're hoping that Mr. Scherer, the Trustee
stand up and say the same things, although he was a
horrible guy when he did this, he's really been a
10
stand-up guy now and we got all the money back?
11
12
don't know how the actual Rule 35 process works.

Q
13
14
I don't know what they are permitted to do.
You've given a lot of thought to this; haven't
you?
15
To my Rule 35?
16
You've given a tremendous amount of thought to
17
18
how you're going to get your sentence reduced?

A
My main focus right now is living a healthy
19
life, making sure family is okay, and telling the truth
20
to the government.
21
22
23
I understand that, but I understand what you're
saying what.
A
That's my focus.
I'm asking you --
Actually that's not just what I'm saying.
24
That's what I'm doing.
25
thing, okay, Ms. Caretsky played a very small part in
In the scheme of this total

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this.
about what everybody did.
Okay, it's part of me telling them the truth
If I could have hid it from them, okay, and not
been penalized for it, if I could have said,
Mr. LaVecchio, please don't go after this lady, she
played a very small part.
it to him right now.
said, you must tell us everything you did.
understand I turned my uncle in?
I would say that.
I'll say
That's not my decision.
They
Do you
I've told them about
10
things that people - all kinds of people close to me
11
did.
12
I've not left anyone out.
13
Family members, very, very close friends, okay,
Okay.
My question was this, you fully -- you're
14
hoping to get the sentence reduction at some point.
15
in order to do that you're going to have to -- you're
16
going to have to find a way to get TD Bank or other
17
folks to pay back all the money that you stole; right?
18
Isn't that --
19
No, that's not true.
And
My understanding is that
20
the civil component of it is not part and parcel of the
21
government's Rule 35.
22
prosecution of criminal investigations.
23
understanding.
24
25
That it's the investigation or

That's my
You don't think -- you're not going to have
Mr. Scherer or the Trustee stand up and tell the Judge

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they he should be lenient on you because you helped them
get money for the innocent investors?
3
4
I would like them to come in and speak on my
behalf.
Wasn't Mr. Scherer at the first sentencing?
Yes.
When I ask you that question -- you fully
expect and hope that they will be there to tell the
Judge how terrifically helpful you were in getting back
10
money for innocent investors and that you will hope that
11
the Judge uses that to reduce your sentence?
12
Yes.
13
So, this notion that this has nothing to do
I'm hopeful of that, sure.
14
with your sentence is preposterous, you're hoping it
15
plays a part in your sentence reduction?
16
That's two completely different statements.
17
You're trying to twist my words.
18
and what the Court will consider are two completely
19
different things.
20
the Court is supposed to consider pertains to the
21
criminal cases.
22
What I hope they do
It's my understanding that the stuff
Do I still hope that they come in and tell them
23
what I've done in the civil cases?
24
does with that, that's up to the Judge, not me.
25
Yes.
What the Judge
Now, your testimony against my client, your

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testimony against Ms. Kerstetter, your testimony against
others, basically says that the e-mails to and from were
actually, as you've described it, they were trying to
pretend like they were doing something innocent but in
fact they were part of something that was guilty.
that -- am I misdescribing what you said?
7
8
Is
Understanding the parameters of your
questioning I would be guessing to tell you that.
Go ahead.
10
That's my best guess.
11
Your best guess is yes?
12
My best guess is yes.
13
And the only thing that --
14
-- that they were creating their own paper
15
16
trail.
Q
But, that explanation which you gave us that
17
came from Ms. Caretsky, nobody else - you're the only
18
person that's told us that at this point?
19
20
spoke to.
21
I have no idea.
I have no idea who else you
It's your word that says otherwise innocent
22
behavior is actually evidence of guilt because they are
23
just pretending to be innocent while they're sending
24
those e-mails.
25
It's your word that's saying that?
MR. SCHERER:
Object to the form.

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I think the fact that these fraudulent bank
statements were handed to investors by TD Bank officials
speaks for itself, regardless of how the statements
ended up getting in there.

Q
I understand that, but the e-mails to and from,
we've talked about now - other than your explanation
that they are really evidence of a guilty mind, they
look like folks are just talking to each other about
actual legitimate account statements they have to print
10
up.
11
12
MR. SCHERER:
A
Object to form.
No, it actually looks bizarre to me because if
13
they weren't in on it how about at least one e-mail
14
saying, what do you need this for?
15
Print it up yourself, we can't have you keep coming to
16
the bank.
17
statements with you.
What are you doing?
Or if you'd like to come, bring your own

I don't know what to tell you.
18
So, that's --
19
You're arguing the same point with me over and
20
over.
21
Your point seems to be ultimately that well,
22
it's just ridiculous for them to take care of a really
23
important customer; that is what your argument is over
24
and over again and I guess --
25
MR. SCHERER:
Object to form.

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No, I think ignoring bright red flags that were
going off for a really good customer, that's really what
was occurring.
At the end of the day that conversation you had
with Ms. Caretsky where she says:
keep a record, I have to do this to keep a file -- by
the way, have you heard of any file anywhere with all of
these other account statements that were kept for just
this moment, I guess?
10
11
I have to do this to
I don't -MR. SCHERER:
Object to form.
12
I haven't heard either way, no, sir.
13
So, nobody has produced it from anyone and they
14
didn't produce it from your office, nobody has produced
15
these legitimate account statements that were being
16
produced particularly for the purpose of showing
17
consciousness of innocence?
18
19
MR. SCHERER:
A
Object to the form.
I have seen numerous productions of the real
20
bank statements and numerous productions of the fake
21
bank statements.
22
certainly can't tell you whatever that consciousness of
23
innocence thing is.
24
25
I can't tell you who produced it.
MR. LICHTMAN:
I'm just pointing out per the
Court Order calls that we quit at 5:00.
The

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Marshal --
2
3
MR. GELBER:
Q
I have two more minutes.
But at the end of the day, it's going to be
your word about Ms. Caretsky's conversation with you;
isn't it?
6
7
8
9
MR. SCHERER:
Q
Objection, form.
It's your word that she told you she was
keeping this to create a record of innocence?

A
I think unfortunately for Ms. Caretsky it's
10
going to be my word, her actions, and the statements of
11
other people that interacted with her.
12
13
And it's also going to be your word that you
gave her $25,000?
14
That's going to be my word, yes.
15
There's no evidence anywhere of that?
16
My word.
17
Okay.
18
19
And you would agree with me that, you
know, your word has extremely little value in the world?

A
I wouldn't agree with that, no.
I agree that's
20
people's perception at this time, but if you take a look
21
at my testimony, which I'm sure you are, and you take a
22
good look through all the e-mails, that you'll see a
23
massive fraud and that a substantial amount of what I'm
24
testifying to is easily corroborated by tons of written
25
documentation --

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Mr. Rothstein --
-- and by people's actions.
You called yourself a liar, a thief and a
scumbag?
Correct.
And you were a liar, a thief and a scumbag?
Correct.
And is it your testimony that you're just
9
10
11
simply no longer acting like a liar, a thief and a

scumbag now?
A
I am no longer a liar.
I will always be a
12
thief, not that I will steal anymore, but I will always
13
carry that label.
14
certainly spent, up until the point I decided to come
15
back from Morocco, a good portion of my life as what I
16
would call a scumbag, yes.
17
that I shouldn't have taken advantage of.
18
19
And I spent -- let me finish.
I took advantage of people
We are to rely on the word of a liar, a thief,
and a scumbag that
Ms. Caretsky received $25,000?
20
Coupled with all the documentary evidence.
21
Is there documentary evidence to that?
22
Not to that specific thing, but a lot of
23
documentary evidence that says that people were
24
tremendously stupid, which I don't think they were - she
25
certainly is not a stupid individual, or they were

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engaged in something they shouldn't have been engaged
in.
MR. GELBER:
(The proceedings were concluded at 5:00 p.m.)
I'm done.
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25

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C E R T I F I C A T E
2
3
4
STATE OF FLORIDA
COUNTY OF BROWARD )
6
7
8
I, TERRI L. WRIGHT, Notary Public in and for
the State of Florida at Large, certify that I was
10
authorized to and did stenographically report the
11
foregoing proceedings and that the transcript is a true
12
and complete record of my stenographic notes.
13
14
Dated this 19TH day of December, 2011.
15
16
17
18
______________________________________
Terri L. Wright
19
20
21
22
23
24
25

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Page 1

IN THE CIRCUIT COURT OF THE

DAY 6 - P.M. SESSION

Thursday, December 19, 2011

Examination of the witness taken before:

United Reporting, Inc.

IN THE CIRCUIT COURT OF THE

EDWARD J. MORSE, CAROL A. MORSE,

10-2411 CACE (19)

AMY ADAMS, ET AL, PLAINTIFF VS. SCOTT ROTHSTEIN, ET AL.

STETTIN VS. GIBRALTAR PRIVATE

STETTIN VS. FIDELITY CHARITABLE

STETTIN VS. TD BANK, N.A.

STETTIN VS. REGENT CAPITAL

STETTIN VS. DON KING PRODUCTIONS

United Reporting, Inc.

APPEARANCES FOR SCOTT ROTHSTEIN:

GENOVESE, JOBLOVE & BATTISTA, P.A.

CONRAD & SCHERER, LLP

United Reporting, Inc.

APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

GOLDSTEIN, TANEN & TRENCH, P.A.

KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL

APPEARANCES FOR THE COMMITTEE OF

APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

United Reporting, Inc.

APPEARANCES FOR FEDERAL INSURANCE COMPANY:

TRIPP SCOTT, P.A.

APPEARANCES FOR CAROL MORSE, TED MORSE & MORSE

MILLS PASKERT DIVERS P.A.

United Reporting, Inc.

APPEARANCES FOR FEPICT, MS GROUP:

APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

99 N.E. 4th Street

United Reporting, Inc.

APPEARANCES FOR FRANK SPINOSA:

United Reporting, Inc.

E-mail dated 7/27/07.

Portion of the Third Amended Complaint.

Ira Sochet Answers & Objection.

E-mail dated 8/17/2009.

E-mail dated 9/15/2009.

E-mail dated 9/17/2009.

E-mail dated 9/17/2009.

PRODA 018604, Letter dated 10/29/2008.

TD/Razor 001863, Letter dated 12/10/2008.

12/17 Investor Meeting.

United Reporting, Inc.

Back on the record.

I'm going to mark as

Composite Exhibit 206 the whole binder that I've handed

to you, including all the e-mails you signed.

Do you want to put a label on it just to make

I think we already did it on one of them or we

can label that one.

(Whereupon, Preve's Exhibit No. 206 was marked

Whatever your preference.

So, the last e-mail that we were discussing was

The "sit tight" e-mail from October 31, 2009.

And my question is brief, it's just the second paragraph

of Frank's e-mail to you, the last one from the top

Do you recall if Frank Preve did indeed call

I will call in 10 minutes.

you 10 minutes after that e-mail?