2011-12-14 Rothstein Scott AM

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 3 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN:
TIME:
PLACE:
December 14, 2011

8:30 a.m. - 12:02 p.m.
James Lawrence King Federal
Justice Building
99 N.E. Fourth Street
Courtroom 11-3
Miami, Florida 33128
Examination of the witness taken before:

Michele L. Savoy, Registered Professional Reporter
United Reporting, Inc.
1218 S.E. Third Avenue
Fort Lauderdale, Florida 33316
(954) 525-2221

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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
2
3
____________________________________________________
4
5
Case No. 10-24110 CACE (19)

EDWARD J. MORSE and CAROL A. MORSE,
and MORSE OPERATIONS, INC.
6
Plaintiffs,
7
vs.
8
9
SCOTT W. ROTHSTEIN, et al.,
10
11
Defendants.
_____________________________________________________
12
13
Case No. 11-CV-61688-JIC/LSS

AMY ADAMS, et. al,
14
Plaintiffs,
15
vs.
16
SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTAR

PRIVATE BANK AND TRUST COMPANY,
17
18
19
Defendants.
_____________________________________________________
10-03767-RBR Stettin v. Gibraltar Private
Bank & Trust Co.
20
11-03802-RBR Stettin v. Fidelity Gift Fund
21
11-02368-RBR Stettin v. TD Bank, N.A.
22
23
24
25

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APPEARANCE FOR SCOTT ROTHSTEIN:

LAW OFFICE OF MARC S. NURIK
1 East Broward Boulevard
Suite 700
BY: MARC S. NURIK, ESQUIRE
APPEARANCE FOR THE TRUSTEE:
BERGER SINGERMAN
350 East Las Olas Boulevard
Suite 1000
BY: CHARLES H. LICHTMAN, ESQUIRE
APPEARANCES FOR THE TRUSTEE:
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
APPEARANCES FOR RAZORBACK:
CONRAD & SCHERER, LLP
633 South Federal Highway
Eighth Floor
By: WILLIAM R. SCHERER, ESQUIRE
REID A. COCALIS, ESQUIRE
IVAN J. KOPAS, ESQUIRE
KOZYAK, TROPIN & THROCKMORTON, P.A.
2525 Ponce de Leon Boulevard
Ninth Floor
Coral Gables, Florida 33134
By: ADAM MOSKOWITZ, ESQUIRE
22
23
24
25

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APPEARANCE FOR PLATINUM PARTNERS VALUE ARBITRAGE

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

One Biscayne Tower, Suite 3700
Two South Biscayne Boulevard
By: SUSAN E. TRENCH, ESQUIRE
5
6
7
8
9
10
11
12
13
14
15
16
APPEARANCE FOR LEVINSON'S JEWELERS:

KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL
200 SW 1st Ave
Suite 1200
Fort Lauderdale, Florida 33301-2073
BY: JAN ATLAS, ESQUIRE
APPEARANCE FOR THE COMMITTEE OF UNSECURED:
AKERMAN, SENTERFITT
One Southeast Third Avenue
25th Floor
Miami, Florida 33131-1704
By: MICHAEL GOLDBERG, ESQUIRE
APPEARANCE FOR T.D. BANK:
GREENBERG TRAURIG, P.A.
401 E Las Olas Blvd Ste 2000
By: DONNA M. EVANS, ESQUIRE
17
18
19
20
21
22
23
24
25
APPEARANCE 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
APPEARANCE FOR FEDERAL INSURANCE COMPANY:
Alex Hofrichter, P.A
1430 South Dixie Highway
Suite 204
Coral Gables, Florida 33146-3127
By: ALEX HOFRICHTER, ESQUIRE

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APPEARANCES FOR MORSE:

TRIPP SCOTT, P.A.
110 S.E. Sixth Street,15th Floor
By: GEORGE WALKER, ESQUIRE
JOHN M. MULLIN, ESQUIRE
APPEARANCE FOR EMESS CAPITAL, LLC:
Kluger Kaplan Silverman
Katzen & Levine PL
201 S Biscayne Blvd Fl 17
BY: CASEY CUSICK, ESQUIRE
APPEARANCE FOR ST. PAUL FIRE & MARINE:
Mills Paskert Divers P A
100 N Tampa St Ste 2010
Tampa, Florida 33602-5145
JOHN A. BLACK, JR., ESQUIRE
12
13
14
15
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APPEARANCE FOR ROSEANNE CARETSKY:

Billing Cochran Lyles
515 E Las Olas Blvd
Floor Six
Fort Lauderdale, Florida 33301-2296
By: W. TUCKER CRAIG, ESQUIRE
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INDEX
CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN
3
4
5
CONT. DIRECT
439
MR. Lichtman
CERTIFICATE OF OATH
CETIFICATE OF REPORTER
613
614
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
TRUSTEE'S EXHIBITS INDEX

NO.
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
DESCRIPTION
PAGE NO
Scott_RothsteinFBI 113444
518
Trustee_Coquina 000104-107
520
TD Bank Letter
524
Scott_RothsteinFBI_009340
530
531
Debra_VillegasFBI_002821
533
534
540
Trustee/Spinosa 000001
541
544
547
TD Bank Letter
548
TD/Razor 001257
549
Trustee_Coquina Multiple Docs 552
Trustee_Coquina 000063-64
557
TD/Razor 001241-1242
558
TD/Razor 000268-270
563
TD/Razor Multiple Docs
564
Trustee_TD 000258 and 260
568
Trustee_TD 000319-321
573
TD/Razor 000080-81
574
Trustee/Spinosa 000333 and 347 577
TD/Razor Multiple Docs
579
TD/Razor 000046
582
TD/Razor 000364 and 112
588
Trustee/Spinosa 000837
590
22
23
24
25

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Thereupon, the following proceedings were had:
2
3
CONTINUED DIRECT EXAMINATION

BY MR. LICHTMAN:
today?
Good morning.
You realize you're still under oath,
Good morning, Mr. Rothstein.
I'm well.
How are you
Thank you.
correct?
I do.
10
And to pick up from the point of
11
yesterday, Mr. Nurik is not with you and you consent
12
to proceeding in his absence until he gets here
13
today, correct?
14
I consent to proceeding in his absence so
15
long as -- since I've already met with you,
16
Mr. Lichtman, I'm comfortable speaking to you
17
without him being here, but I'm not comfortable with
18
being questioned by anybody else until he arrives.
19
But you're okay with me questioning you?
20
Yes.
21
Okay.
I can't help myself on this first
22
question; I want to start the day off on the right
23
foot.
24
25
You realize that your fist mistake in what

you did was that you were Republican and I assume

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you realized if you were Democrat, then the good
side of your brain would have kicked in and none of
this would have happened to you?
that?
Do you concede
That's -- I --
MR. SCHERER:
of that question.
THE WITNESS:
Thank you, Bill.
MR. SCHERER:
Because it is ridiculous.
I would object to the form
10
It assumes facts that have never been in
11
evidence, that would never go into evidence,
12
and it suspends reality.
13
the only reason he's where he is now is because
14
he wrote a big check to Alex Sink.
15
MR. LICHTMAN:
16
THE WITNESS:
As a matter of fact,
That's it, right?

I'm just going to refrain
17
for comment for fear that someone else may end
18
up in jail.
19
MR. LICHTMAN:
The record should reflect
20
that everybody is laughing, so now we will
21
actually get serious and get started.
22
BY MR. LICHTMAN:
23
I want to start off with Frank Spinosa.
24
Okay.
25
Yesterday, in the questioning by

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Mr. Scherer, you referenced that there was a point
in time that he received an envelope from you at the
Bova restaurant.
contained between $50- and $75,000 cash?
I think that you said that it
That's correct.
Okay.
What I want to do, actually, is
work backwards, because I think that you said that
but didn't attribute it to a time frame.
really want to do is start kind of at the beginning
10
of the process of the relationship with Spinosa and
11
history, and then work our way up to that cash
12
payment.
So what I
13
All right.
14
About how long into the point in time that
15
you were conducting your banking arrangements at TD
16
Bank was it before you started working with
17
Mr. Spinosa?
18
19
When you say working, you mean both
legitimately and illegitimately.
20
Let's start with legitimately.
21
Almost -- to the best of my recollection,
22
it was almost at the beginning.
23
that was -- our first contact, as I said yesterday,
24
was John Tolomer, who was Mr. Spinosa's boss.
25
have a vague recollection of Mr. Spinosa possibly
I'm fairly certain

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even being at that first meeting with us, that first
dinner meeting.
that.
It's vague, so don't hold me to
But very shortly after our decision to
start banking with TD, Mr. Spinosa was injected into
the equation.
Okay.
You have used the term "player"
repeatedly through the course of your deposition so
far, and I take it to mean that "player" refers to
10
somebody, a third party, that would be interested in
11
some kind of inducement to go along with whatever it
12
was that you needed?
13
14
ALL PRESENT:
Object to form.
Predicate.
BY MR. LICHTMAN:
15
So, what I would like to do, is have you
16
tell me, in your mind, what does the term "player"
17
mean?
18
The word "player" was utilized with me and
19
several of the other people that were
20
co-conspirators in the Ponzi scheme for the purpose
21
of identifying someone who we believed, at least at
22
some level, would be interested in earning money,
23
having a better lifestyle, in exchange for doing
24
things that were illegal.
25
Who would the other people be that you

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2
referenced just now?

A
Regularly, when I talked to Frank, when we
were having conversations over the phone, he or I
would say, don't worry he's a player.
Frank Preve?
Frank Preve.
Who else?
That conversation was had with Mr. Boden
9
10
and I when we were talking; we would say, he is a

player, don't worry about it.
11
Szafranski, not so much; from time to
12
time, but he was a little more -- I think you'll see
13
him described as "milk toast" in the emails.
14
didn't really speak that way.
15
He
When I had conversations with Steve
16
Caputi, we used the word "player."
17
conversations with Stu or Steve Lippman, probably
18
more towards Russ Adler's side, when he was
19
introducing Rossi and Herskowitz in, I would have
20
asked him if they were players, those people.
21
22
23
24
25
When I had
So "player" was a common term that was
used among those that were working with you?

A
Sure.
I think it was a common:
"player."
I remember using the word with Mr. Morse,

Ted Morse, when I was discussing things with him.

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said, can we trust these people, especially when I
had him go to Bank of America and we had some
conversations outside Bova in the Caputi
check-hiding mess that we got our ourselves into.
When Ted was telling me he was going to go
speak to someone, the normal conversation would be,
is this guy a player, can we trust him.
8
9
Okay.
Now, a few answers ago you said
that a player would get involved for purposes of
10
earning money; I think those two words you used
11
exactly.
12
money, that were typical inducements that you used?
13
14
15
16
17
Was there anything else, besides earning
Yes.
I think I said earning money and
bettering their lifestyle.

Q
Can you give me examples of "bettering
their lifestyle"?
A
Sure.
It's what we were talking about the
18
last two days, which is what we -- what we referred
19
to as living the rock-star lifestyle --
20
Yes.
21
-- and that is, they would have access to
22
all of our tickets to all sporting events.
We had a
23
box on the 50-yard line at Dolphin Stadium.
Suite.
24
We had excellent seats at the Arena and, naturally,
25
a box at the Bank Atlantic Center.
We had floor

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seats for the Miami Heat.
available for the Marlins and for the New York
Yankees.
there was an event, they went on our dime.
We always had tickets
So with regard to sporting events, if
Dinners for all the people that were
closely involved with us at Bova, 99 percent of the
time they were comped.
up.
put on my tab, boxes of cigars, lighters and the
10
Their drink tabs were picked
Trips to Ultimate Cigars, Moe Sohail's place,
like.
11
Trips down to -- after I got involved with
12
Casa Casuarina with Peter Loftin, at the Versace
13
mansion.
People would be comped down at the Versace
14
mansion.
People wanted to go to concerts; we were
15
always able to get them tickets through brokers, the
16
first three rows.
17
They flew on chartered planes with us to
18
sporting events outside the state.
19
the Super Bowl that were involved in the Ponzi
20
scheme.
21
championship.
22
I took people to
I took people to the BCS game, national
You name it, we were doing it.
If it --
23
it pertained to that rock-star lifestyle, things
24
that people could not ordinarily do, $1,000 a plate
25
charity cigar smokers, that type of stuff.

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Okay.
That's the type of thing we would do to
keep the people in the game.
Now let me focus on Mr. Spinosa.
Sure.
Was there a point in time where you
7
8
9
10
thought that he would be a player?

A
thought he would be, but there had to be, because he

became one.
11
12
Well, I don't remember the time that I
The one thing I do need to clarify, since

you're going to try to get into time frames --
13
Yes.
14
-- is that it's not an on-off switch when
15
someone becomes involved in a criminal enterprise of
16
this magnitude, even at the small levels, that
17
certain people were involved, and at the major
18
levels, other people were involved.
19
thing.
20
It's a gradual
People see what's going on.
They get a
21
feel for what's going on, and they gradually become
22
involved.
23
So, with respect to Mr. Spinosa, I think
24
what I'm hearing you say is that there was no on-off
25
switch as it pertained to Mr. Spinosa?

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I can tell you that the only people --
actually, the only person that I can think of off
the top of my head that there was an on-off switch
with, was Steve Caputi.
fore close to two decades, and I trusted him
implicitly.
Because I had known Steve
So, Steve would be someone that I could go
to, as I did, and say, listen, Steve, I need you to
pretend to be a banker for me.
This is what is
10
going on.
11
just be a very easy conversation; as opposed to a
12
lot of the other people who, over time, like
13
Szafranski -- you can judge, Mr. Lichtman, as
14
someone is going on, as you'll see from through
15
going through all the emails, that someone is
16
interested:
17
This is what I need to you do.
It would
They see the red flags and ignore them.
What was there with respect to Mr. Spinosa
18
that told you that he was interested or red flags,
19
as you mentioned, so that you believed he would be a
20
player?
21
We immediately started off with an
22
extremely high velocity of transactions in our
23
accounts, and he didn't flinch, except to tell me
24
that if we had any problems, when I inquired of him
25
as to whether there were any problems with what we

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were doing, don't worry about it; we'll take care of
it.
When you say he didn't flinch, you had
this high velocity of transactions, can you go into
a little bit more detail?
Sure.
Well, I have the experience of
dealing with Gibraltar Bank, which was very high
intensity from certain individuals down.
scrutiny.
There's
10
So I knew at that stage what to look for.

With regard to Mr. Spinosa, I mean, there
11
should have been, in my eyes, red flags, just by
12
shear volume, overdrawing accounts from the
13
beginning of the relationship.
14
me that I could continue to take it steps further,
15
because every time I asked him if there was a
16
problem -- and in the beginning of the relationship,
17
Mr. Lichtman, I asked him frequently: any problems
18
with what's going on, any problems with the wire
19
transfers?
It became evident to
20
What did he say?
21
He said absolutely not, and if there were,
22
23
don't worry about it, I'll handle it.

Q
So how did you respond in terms of -- I'll
24
use the term inducements, to determine that he was a
25
player and so that you could keep this going with

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him?
I started inviting him to events.
What kind of events?
Political functions at my home that were
fairly expensive events, expensive dinners, sporting
events.
Dinners at Bova?
Yes.
Do you recall any of the sporting events
10
11
that you took him to?

A
12
I don't.
I remember him coming to Dolphins' games,
13
but I don't recall any other specifics.
14
given him tickets to a Heat game, but I don't
15
remember off the top of my head.
16
I may have
And would you, say, give, meaning that
17
they literally were gifted; he did not have to pay
18
you for them?
19
No.
20
Do you have any knowledge as to whether he
21
He never paid me for anything.
reported any of these things to the bank?
22
He didn't report it.
23
How do you know?
24
Because I had a conversation with him at
25
one point in time when -- it was around the time

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that I had given something -- we were joking around
about something I had given to a politician, and I
don't remember who it was; but I remember laughing
with him about the fact that you could give -- there
were certain people in town who you couldn't do
anything with, and there were certain people you
could sign over your property to and they wouldn't
flinch.
Did you give me the laundry list of the
10
inducements that you recall Mr. Spinosa receiving
11
from you?
12
Yeah.
14
Do you recall which concerts?
15
No, I don't.
13
He received concert tickets from
me.
I don't; but, again, if he
16
calls and asks for concert tickets, it's never:
17
Well, we should do it?
18
19
It's always yes.
Is that typically how it would work:
If
he wanted concert tickets, he would call you --
20
Yes.
21
-- as opposed to you calling him?
22
If I thought it was something he would be
23
interested in, I would call him; otherwise, he would
24
contact me.
25
From your recollection, what --

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COURT REPORTER:
I'm sorry.
I'm getting
thrown off track by some whispering.
repeat your question again?
4
5
Could you
BY MR. LICHTMAN:
Q
From the quality -- from your
recollection, what were the quality of the tickets
that you typically procured from Mr. Spinosa?
First three rows.
Did you get those from brokers?
10
Always through brokers, yes.
11
Do you recall the brokers that you used?
12
No, but it is in our financial records.
13
Okay.
14
It should be -- excuse me.
15
16
17
What other -It should be
on our American Express bill.

Q
Okay.
What other inducements do you
specifically recall --
18
I specifically --
19
-- with respect to Mr. Spinosa?
20
-- recall attending Dolphin games.
21
22
23
I have
a vague recollection of giving him -Q
Let me take them one by one.

The Dolphin games, you mentioned before
24
that you had a box at the Dolphin -- at the -- I'll
25
call it Joe Robbie stadium?

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That's correct.
Was he a regular visitor at the Dolphin
games?
Call him a semi-regular visitor.
He
certainly wasn't as frequent as Mr. Harris.
Mr. Harris came to just about every game, but he was
a regular visitor.
Okay.
Yes.
10
Okay.
11
The box, food and drink, yes.
12
Parking?
13
Parking.
14
What else?
15
He asked -- I think it was just once --
And, again, that was for free?
16
for Heat tickets and we gave him our floor seats to
17
the Heat tickets.
18
19
20
Were there other sporting events that you
recall him going to?

A
You know, I don't remember if he did.
21
don't remember.
22
traveling with us anywhere.
I don't have a recollection of him
23
Meaning to sporting events?
24
Yeah, away to sporting events.
25
He came to a number of our -- actually, he

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came to probably the bulk of our political events,
when we had John McCain at the home, Charlie Crist,
Senator Leiberman.
Sink.
I believe he was there for Alex
Did he --
There were events down in Miami.
remember we had John Henson and somebody else down
at the Havana Club.
that, also.
10
11
John McCain might have been at
Spinosa attended that.
Do you recall him traveling on private
jets with you anywhere?
12
I don't have a specific recollection of
13
it.
14
easiest way to check that, instead of relying on my
15
memory, is just to just check the manifests.
16
don't think that they did.
17
I don't -- I don't think he did, but the
Okay.
And how about dinners, what do you
18
recall with respect to him having free dinners
19
from --
20
I recall him eating dinner on more than
21
several occasions with me at Bova.
22
eating at Capital Grill, both for lunch and dinner,
23
with me, on my tab.
I recall him
24
Versace mansion?
25
I don't recall whether he was one of the

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takers for the Casa Casuarina.
Probably.
There was a dinner at a restaurant in
Miami called Barton G that we went to.
guys' dinner.
He attended that.
Who else was there?
It would --
Same --
It would -- no.
It was a
It would have been a
dinner where my -- where I was taking my friends.
10
What I generally did with guys like
11
Harris, Spinosa, is I took them -- if I was going
12
with my general group of friends out some place, I
13
would invite them from time to time.
14
15
The guys that you mentioned a couple of
days ago, that group of friends?
16
Yes.
17
Okay.
18
Yes.
19
20
Oh, he attended -- he attended boys

gatherings at Solid Gold with us, as well --
21
All right.
22
-- usually on Wednesday nights.
23
By the way, do you recall approximately
24
how much the concert tickets typically cost per
25
seat?

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It varied anywhere from $500 to $600 a
seat into the thousands of dollars per seat,
depending upon the ticket, how close to the actual
concert date we were getting them, whether the
concert was sold out or not, whether I was getting
back-stage passes along with the tickets.
All right.
And with respect to the
political events, you mentioned McCain, Crist,
Leiberman, Alex Sink, was it typical that when we
10
attended those events, he had his picture taken with
11
the candidates or politician?
12
I don't know if it was typical, but it
13
should have occurred on several occasions because he
14
wanted to have his picture taken so he could put it
15
on his office wall, so I am sure I arranged for it
16
to happen on at least one or two occasions.
17
Did he attend the Schwarzenegger events?
18
I don't believe he did.
That was a very,
19
very, close group.
20
people to that because it was a lunch at my home for
21
him, and I don't recall him being there.
22
23
24
25
I think I only invited 25 or 30
Did he attend any of the events that you
helped host or participated in at the Levinsons'?

A
I don't have an independent recollection
as to whether or not he -- he did or not.
Really,

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the easiest way to check for a Levinsons' event is
to go look at the pictures because, as you know,
they took a lot of pictures of a lot of the people
that were there.
5
6
Did he ever travel with you to New York or
other locations?
I don't think that he did, no.
So, how did it work with respect to these
9
10
11
inducements and him being a player in terms of

getting something that you needed?
A
The way it works is this -- and you'll see
12
that this is consistent with almost everybody I was
13
working with or began to work with.
14
asking them to do little things, watching our
15
account, for example.
16
17
Okay.
You start by
As you give the example, let's use
Spinosa, so --
18
Okay.
19
Yeah.
20
It really doesn't vary from person to
This is Spinosa.
I mean, this --
21
person.
22
contrary to what appears to be popular belief, you
23
do not say to someone:
24
and would you like to help me, I'll pay you some
25
money.
It's a feel thing.
You don't walk up,
Hey, I am committing a fraud

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I mean, you just stay away from that.
You'll find in the emails that Mr. Preve was
probably more open than most about what was going
on; Mr. Spinosa, not so much.
5
6
So, it was very limited conversation:

What's going on with my account, any problems?
No, don't worry.
handle.
We're good to go.
10
Any problems, I'll
You just continue to do your business.
He was constantly saying things, if I took
11
him out for drinks, we were having an exceptionally
12
good night, I would say something to Mr. Spinosa
13
like, having a great time?
14
Yep, yep, yep.
15
I -- and he would always say something
16
like, I don't know how to thank you.
17
I always said, yeah, you know how to thank
18
me, just take care of me.
19
of me, just continue to take care of me.
20
21
22
You're taking great care
That would be consistent with what you
said to Ms. Caretsky in the parking lot?

A
Yeah.
But -- I was very big on saying
23
things like, just do the right thing.
24
of my favorite phrases:
25
okay, make sure you take care of me, do the right
That was one
Just do the right thing,

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thing.
2
3
I never had anyone turn around and say,

well, what is the right thing?
The people I was dealing with -- for the
most part, I can't think of anyone who didn't.
were going along with what we were doing.
All
I think the turning with Mr. Spinosa was
when I sent him that lock letter -- that thing that
became known as the lock letter; and, you know,
10
Mr. Preve and I had talked about it before, because
11
we had gotten a request -- I had gotten a request, I
12
think, through one of the Szafranski plaintiffs, if
13
I'm not mistaken, and I sent him that letter.
14
said, hey, can you do this?
15
And Preve and I had -- the conversations
16
we had had was Preve had been banking on, he said, I
17
don't know if he's going to be able to do that and
18
that's a really big bank.
19
20
And I sent it to him and he said, sure,

just send it to me and I'll sign it.
21
It was that simple?
22
I may be making it more complicated than
23
24
25
it actually was.
Q
Okay.
Is there anything that you can tie
in time to the point where you gave him the envelope

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2
at Bova -- to an event?
A
No, sir.
It was early on.
I generally
gave money once a person -- I have got to break it
down for you.
5
6
7
8
9
With Mr. Spinosa, I gave him money, okay,

once we were already going.
Q
When you say "already going," what do you
mean by that?
A
It would have been around the time that he
10
had first started doing the lock letters.
11
Likely before I had to have him draft the actual
12
letter, probably around the time -- and I'm just
13
giving you my best guesstimate, okay -- around the
14
time that he was simply signing off on the letters.
15
It was clear, at that point in time, that he was in,
16
and I had the belief that he would take the money.
Okay?
17
Locked in, no pun intended?
18
No pun intended, locked in, yes.
19
Was there ever a point in time that you
20
asked him to do something that you could think of
21
where he said, no, I can't do that, that's pushing
22
it too far?
23
No, sir.
24
And how long did this process of
25
inducements with Mr. Spinosa continue?

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I would be guessing.
Did it go all the way to the point in time
3
4
5
where the Ponzi collapsed?

A
You mean how long did I continue to do
illegal activity with him?
Yes.
Until the Ponzi collapsed.
And that would be reflected by the wire
transfer that they sent to Morocco for you, correct?
10
11
ALL PRESENT:
predicate.
12
13
14
15
Objection to form,
MS. EVANS:
A
Objection.
Yes.
BY MR. LICHTMAN:
Q
Mr. Spinosa approved the wire transfer
16
that you asked for that was sent to Morocco at the
17
time that you left the country, correct?
18
He did.
He assisted.
19
ALL PRESENT:
20
facts not in evidence.
21
Objection to form, assumes
BY MR. LICHTMAN:
22
Okay.
23
With regard to the wire transfer,
You can answer.
24
Mr. Spinosa approved it; and he was also -- if you
25
look at the emails, he was the one who assisted me

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in expediting it.
believe we saw it yesterday -- asking him to make
sure this went right through.
4
5
I actually sent him an email -- I
You would agree that your departure to
Morocco was, in fact, the end of the Ponzi, correct?
Yes.
With respect to Ms. Caretsky, how was it
8
9
10
that you determined that she would be a player?

A
I asked Mr. Spinosa if she could be
trusted and if she was a player.
11
Do you recall approximately when that was?
12
It would have been just prior -- if you
13
got -- you can do this all by documents.
14
even need my testimony for it.
15
You don't
Go look at the first time she gives me
16
that letter to go on top of the fake bank
17
statements.
18
The screen shot, you mean?
19
Yes.
20
The first time that she does that --
The first time she does that, that would
21
have been just after the time that I asked
22
Mr. Spinosa if I could trust her.
23
Is your testimony that you used the term
24
"player" with Mr. Spinosa, as well as it pertained
25
to Ms. Caretsky?

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I don't want to mislead you.
have a specific recollection.
spoke.
4
5
I do not
It's simply the way I
I did say to business people that I was

dealing with:
Can I trust her?
Okay.
Once someone was involved in the
criminal enterprise and I asked, can I trust them,
it wasn't can I trust them to safeguard my money.
It was, can I trust them to do the right thing by
10
us.
11
12
So, effectively that's what you asked
Mr. Spinosa about Ms. Caretsky?
13
Yes.
14
What kind of inducements did she receive,
15
besides the envelope that you recall in the parking
16
lot?
17
From me, nothing, other than the envelope.
18
Are there others at RRA or that were
19
involved in the Ponzi with you that provided
20
inducements her?
21
It's my recollection that she did go to
22
dinner or lunch with several of the other people
23
from the firm, but I don't have a specific
24
recollection of it.
25
Was there a point in time that you felt it

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was appropriate to give her the envelope?
Yes, but I don't recall when it was.
She kept the envelope, right?
She did, yes.
Is there anybody besides you that knew
about you giving the cash to Spinosa?
To my knowledge, no.
Is there anybody that you knew that you
gave cash to Caretsky?
10
To my knowledge, no.
11
Was it your practice to give gifts or
12
inducements to people for a particular occasion or a
13
piece of illegal activity, or was it to keep people
14
happy?
15
You want me to discuss my gift giving?
16
Well, I'm talking about --
17
Very broad topic.
18
-- yes.
19
I gave gifts to people that I loved and
20
21
Tell me how that actually worked.
cared about that were doing nothing for me.

Q
I am thinking more along in terms of the
22
inducements as it pertained to the Ponzi, as opposed
23
to actual gifts.
24
25
Okay.
Okay.
It was my general
practice -- by "general," I mean a very frequent

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occasion -- that anyone that I sought to influence
in any way, anyone that was doing things for me with
regard to the Ponzi scheme and any of its tentacles
or anyone who I thought in the future I would need
to do something for me, would receive gifts and all
the other things that went with it that we were just
talking about.
8
9
10
11
Would maybe the phrase "money before
morality" sound applicable to what you were doing?

A
Yes.
point in time.
I think that it was my phase at some

It was greed before morality, yes.
12
Okay.
13
Greed before morality, yes.
14
In your opinion, and based on the activity
15
that you conducted in the Ponzi scheme, if Spinosa
16
and Caretsky did not cooperate with you from the
17
beginning, what would have happened to the Ponzi?
18
19
20
It would have collapsed.

MS. EVANS:
Objection.
BY MR. LICHTMAN:
21
And tell me why you say that.
22
Well, let's deal with Spinosa first.
23
Spinosa and Caretsky I think you can put, I guess,
24
in the same package.
25
We were being basically told by our main

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feeder fund, at that point in time, that we needed
to have a big bank.
options.
some connection to through Mr. Tolomer or through
Mr. Lippman.
It's not like we had a lot of
We went to the bank that we had at least
Had they not agreed -- once we started
banking with them, I mean, you know, it was -- it
was a calculated risk.
them, they were either going to blow the Ponzi up --
Once we started banking with
10
more specifically Mr. Spinosa, than anybody else --
11
or they were going to go along with it.
12
And I think your testimony as to
13
Mr. Spinosa was, from the very beginning, once you
14
started with overdrafts and this velocity of flow of
15
money, he had no objection to that?
16
That's correct.
Let me just add this to
17
that, just so you can understand.
18
before -- except with a guy like Caputi, before I
19
started trying to get someone to engage in the
20
illegal activity, they had already be introduced to
21
the lifestyle.
22
Normally,
It was not, do something illegal for me,
23
and then I'll make things nice for you.
24
had already started making things really nice for
25
them, and that was my methodology of softening them
It was, I

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up so that they would be ready to do something
illegal, if that makes sense to you.
3
4
5
Do you recall how often your accounts were
overdrawn at TD Bank?
A
I really paid very little attention to it
because Mr. Spinosa was taking care of it, but I
would gather to say, from a technical standpoint,
between, you know, uncollected items and checks just
flying all over the place, wires doing the same
10
thing, that it was overdrawn, I suspect, hundreds of
11
times.
12
13
overdrafts?
14
15
What was the bank's reaction to your
I don't know what the bank's reaction was
because Mr. Spinosa was running interference for me.
16
17
overdrafts?
18
Don't worry about it; I've got it.
19
You understood, at this time, that he was
What was Mr. Spinosa's reaction to the
20
also the senior vice president -- the regional vice
21
president for TD Bank?
22
Yes.
23
What did Mr. Spinosa understand your
24
25
business to be?
A
I don't think he understood what my

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business was, other than owning a law firm and being
an investor into is a lot of different businesses
and all kinds of what probably he would describe as
crazy business deals.
5
6
Did he ever ask you about the nature of
RRA's law practice?
We did discuss that from time to time when
he was trying to send clients to us, and I guess he
was being questioned, I don't know; but it wasn't a
10
major focal point of our conversation.
11
12
13
What kind of clients did he try to send
I don't recall.
you?
I think they were
14
business clients.
15
was trying to make sure that TD Bank did business
16
with Steve Lippman on the commercial side.
17
I think more than anything, he
Did Mr. Spinosa, to the best of your
18
knowledge, or anyone else from TD Bank, perform any
19
due diligence on RRA?
20
I have no idea.
21
Did he ever -- okay.
22
Do you know if they
ever performed any due diligence on you?
23
I have no idea.
24
Did they ask you for any information as
25
you opened the accounts, any financial information

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2
or other information about the firm?

A
I don't recall them asking me directly.
They may have asked Irene, and she would have
furnished the little bit that we allowed to go out;
but I don't have a specific recollection of them
asking me anything in depth about anything.
If they had asked you for that type of
information, isn't that the type of issue that Irene
would have said to you:
Scott, you should be aware
10
that TD Bank is asking for the following
11
information?
12
She certainly would have.
13
And you just said the limited information
14
that you would have allowed out; what did you mean
15
by that?
16
The best way to judge that is to look what
17
I do with Gibraltar Bank.
18
furnishing information.
19
scant information in little dribs and drabs and hope
20
they would go away.
21
22
23
24
25
I was not big on

I would have given just
And regardless, your recollection is that
they didn't ask for any information?

A
As I sit here today, Mr. Lichtman, I have
no recollection of them asking me for anything.

Q
Okay.
Did anyone from the bank ever come

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to RRA to perform any kind of inspection of records?
No, sir, not to my knowledge.
While the Ponzi scheme was being
perpetrated, describe for me the changes in the
banking structure required to run the Ponzi scheme
at TD Bank?
7
8
MS. EVANS:
A
Objection to form.
We had to have numerous trust accounts.
At the point in time we were doing business with TD
10
Bank, it coincided with a lot of our investors that
11
were coming in asking for segregated trust accounts.
12
Back when we were dealing with Gibraltar,
13
it was more just a few account.
14
having -- I believe the number that was told to me
15
yesterday was 22 trust accounts.
16
drastic difference from the way we did business
17
before.
18
We ended up
So it was a
When you increased up to 22 trust
19
accounts, what did you explain to the bank was the
20
reason why you were expanding the number of trust
21
accounts?
22
23
24
25
They never asked me.
I explained nothing
to them.
Q
Did they ever send you any letters or any
emails asking you for an explanation?

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2
To my knowledge, I never received nothing
from them.
Did Mr. Spinosa ever raise the issue with
Absolutely not.
Caretsky?
No, sir.
Any internal bank examiners or other
you?
personnel at TD Bank?
10
To me, no, sir.
11
Okay.
What was the reaction of the bank,
12
from your observation, as to the hundreds of
13
millions, if not billions of dollars that flew
14
through the RRA trust accounts at TD Bank?
15
16
There was no reaction at all, as far as I
could see.
17
Nobody ever questioned you about what the
18
purpose was behind all this money going through the
19
funds?
20
21
24
25
As a matter of fact, Mr. Spinosa
seemed thrilled by it.
22
23
No, sir.
So...
What did you mean by that, when you say
he -A
He would say, yeah, yeah, we have got all
this money in, yeah, yeah.
That's great.
Keep it

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coming.
Nothing more than that.
Frank Spinosa was great that way.
very peppy, really on top of things, as far as
protecting us.
was.
It was always -He always was
That's -- that's just the way he
What's your understanding as to why he was
pleased about the velocity of -- and amount of funds
flowing through the account?
10
From speaking to him, I understood that it
11
made him look good with the bank because we were a
12
very large depositor of, though it was very fast
13
deposits, in and out.
14
tremendous amount of money in and out of the bank.
15
It was still moving a
Did he ever suggest to you that his rise
16
to the position of senior vice president for the
17
southeast region had any relation to the amount of
18
deposits that were you making?
19
20
ALL PRESENT:
A
No.
No.
Object to form.
I don't recall him suggesting
21
anything, anything of that nature.
22
BY MR. LICHTMAN:
23
24
25
Did Mr. Spinosa or Ms. Caretsky ever ask
you to make a charitable contribution to anyone -A
I don't --

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-- to any entity?
Yes.
I don't remember Mr. Spinosa ever
asking me, but I do remember either Ms. Caretsky or
Ms. Kerstetter asking me to contribute money to
something, and we did; I don't remember how much or
what entity it was.
I just thought of something.
There was a
point in time where Ms. Caretsky, I think she
adopted a baby; is that right?
10
Sure.
11
Yeah.
12
Did you give her a present for
that?
13
We did.
14
Do you recall if it was a material
15
16
17
18
I don't remember what it was.
present?
A
It should have been.
I mean, I just don't
recall one way or the other.

Q
Okay.
Was your understanding that the
19
operating and trust accounts at TD Bank were
20
comingled during the Ponzi scheme, in terms of how
21
money switched around from your accounts?
22
Absolutely.
23
Did anyone at the bank ever question you
24
about that?
25
Yes.
No, sir.

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Did they ever send you any documents
asking you to give them information about those
transactions?
To my recollection, no, sir.
With respect to the overdrafts, did the
6
7
bank charge you a fee for those overdrafts?

A
No.
Irene handled that, and unless it got
out of hand, she wouldn't have contacted me, like
what was happening with Gibraltar and us having to
10
reverse that twenty-something-thousand dollars in
11
charges.
12
I do recall a series of emails where
13
Spinosa was trying to make sure we weren't getting
14
charged for certain things, but I don't know what
15
the outcome of that was.
16
17
you recall?
18
I do not recall.
19
When there were overdrafts, do you recall
How is it that that issue popped up; do
20
if Spinosa mentioned to you that there were going to
21
be suspicious activity reports at the bank that they
22
would have to deal with?
23
No.
The entire time that I did business
24
with Mr. Spinosa, he never told me that we were
25
going to have any SARs.
He always -- don't worry

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about it.
business.
I'm handling everything.
Just go do your
And is it correct to say, then, that you
never learned about there being any suspicious
activity reports while TD was your banker?
That is correct.
How about any other kind of reports that
would have seemed to indicate that the bank had
flagged your conduct, such as money laundering
10
reports; did you ever hear about any of those?
11
No, sir.
12
Were you ever requested to provide
13
information about transactions that gave rise to the
14
deposits?
15
No, sir.
16
Do you know what the bank's understanding
17
was of where the funds came from to bring the
18
accounts into compliance once there were overdrafts?
19
20
MS. EVANS:
A
Objection to form.
The only conversations I had ever had with
21
Frank about where the money was coming from was not
22
in response to covering overdrafts.
23
general pertaining to our business model.
24
investors.
25
BY MR. LICHTMAN:
It was just in
It was

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Okay.
And I'm going to get to that.
When you say the general business model
investors, there was a point in time where you
described for him what you were doing, correct?
Not criminally.
With the investors?
Yes, from a settlement standpoint --
Settlement standpoint?
-- I explained to him what the business
10
model was, not the Ponzi model.
11
I'm going to get to that.
12
Okay.
13
Did the bank ever ask you to sign any loan
14
agreements of any nature with respect to overdrafts?
15
No, sir.
16
Indeed, did RRA -- was it a borrower of
17
the bank in any capacity?
18
No, sir.
19
Were you a borrower of the bank in any
20
capacity?
21
No, sir.
22
Did anyone from the bank's compliance
23
department ever reach out to you about any of the
24
operations of RRA?
25
No, sir.

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Did anyone from the bank's compliance
department reach out to you with respect to the
settlement business?
No, sir.
Did you ever have any discussions with
anyone from TD Bank about, sort of like, in quotes,
know-your-customer, end quote, obligations or
issues?
Except for the conversation that I had
10
with Frank where we were talking about settlement
11
business, and that was more just in passing, I don't
12
recall anyone asking any questions to know my
13
business at all.
14
Okay.
So now let's talk about your
15
conversations with Mr. Spinosa about the settlement
16
process.
17
that conversation?
Do you recall approximately when you had
18
No, sir.
19
Do you recall why you had the
20
21
conversation?
A
It does not stick out in my head as to
22
why, which leads me to surmise that it was simply a
23
conversation we were having.
24
needed to know the information.
25
conversation.
It wasn't like he
It was just a

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2
What is it that you recall explaining to
him about the settlement process?
I explained to him that we were selling
prefunded settlements, the same thing I would have
explained to a -- to a potential investor.
As a matter of fact, you know what time
frame -- I guess you could lock it in -- it was
pre-the in-office meeting Mr. Damson, Ms. Kathleen
White, myself and Mr. Spinosa.
It was before that
10
because I did want him to understand what was going
11
on.
12
That would have been Coquina?
13
Coquina, yes.
14
Did you have any discussions with him
15
about the money that was being deposited into RRA
16
trust accounts being investor money?
17
I may have, from time to time.
You should
18
be able to find emails where I say we have a big
19
investment coming or money from a big investor or we
20
are courting a big investor.
21
22
23
24
25
Do you recall what questions, if any, he
asked you about the investments?

A
The only thing he ever inquired of me,
Mr. Lichtman, was how much money is coming.

Q
Why do you -- what -- from your working

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with him, what was it that you perceived was
important when he asked that question?
3
4
He's a
banker.
5
6
The more money, the better.
And tell me how that correlates to benefit
to him or the bank?
As I understood it from speaking to him,
the bigger the money flowing through the bank, the
better it made it look for him because he was
10
responsible for bringing in a very large customer of
11
the bank.
12
Did he ever comment to you the impact of
13
the sheer dollars at the bank having any relation to
14
how he was perceived at the bank?
15
ALL PRESENT:
16
Object to form.
Only in the positive.
I don't even
17
remember specific conversations, but he was always
18
very, very complimentary on how we dealt with him,
19
and I was always complimentary as how he dealt with
20
us --
21
BY MR. LICHTMAN:
22
23
24
25
Did he ever say to you, for instance, that
you made him a star?

A
I don't think he used those words.
It was
pretty clear from seeing us together that they

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appreciated, you know, what we were doing.
You mentioned, I think it was yesterday,
that Mr. Harris at Gibraltar wanted to come work for
you.
Mr. Spinosa?
Yes, sir.
Did you have any specific discussions with
Was that the same situation with respect to
him about that?
Yes, sir.
10
What was it that you said to him?
11
I told him at the appropriate point in
12
time, if he wanted to leave the bank, there would be
13
a position for him, an extremely high-paying
14
position, involved on the business side outside the
15
law firm.
16
Harris.
17
18
19
I actually told him along with Mr.
How far into the banking relationship with
TD were you before you said that; do you recall?

A
I don't want to guess.
It wouldn't have
20
been that far in, because our relationship grew we
21
were pretty fast.
22
So I don't want to guess.
Would be a fair statement you weren't in a
23
position at that time to identify a particular
24
position, just that there would be a position?
25
No.
It was at the time when he realized

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that I could hire anyone for any position and pay
them a lot of money, just because of the shear
magnitude of the funds that I had access to.
4
5
And he saw what was going through the
account, to the best of your understanding, correct?
To the best of my knowledge, sure.
How do you know that?
He -- he was regularly approving wires for
us, approving movement of money, watching, looking
10
at deposits.
11
his business was.
12
13
We discussed deposits.
That's what
How often would you say you spoke to him
on a weekly basis?
14
A few times every week.
15
Okay.
Did Mr. Spinosa ever work with
16
Mr. Harris on anything related to your banking
17
relations?
18
To the best of my knowledge, no.
19
Did they ever meet?
20
Yes.
21
I assume that would have been probably at
22
23
some of your political events?

A
Actually, I think the very first time they
24
met was at Bova.
25
outside, in our -- the place where we smoked cigars
We were sitting downstairs

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out in front of the restaurant; and the only thing
that I recall is making a comment, oh, my two
favorite money people are here.
They were together.
That's all.
I don't know that
they actually liked each other.
felt threatened by Mr. Spinosa, but I remember them
meeting.
8
9
10
11
12
I know Mr. Harris
With respect to large deposits, did you
ever have issues on getting those large deposits

cleared quickly?
A
I had instances where they were not
cleared.
13
And then what happened?
14
And then I contacted Mr. Spinosa, who did
15
whatever it made -- needed to be done to make sure
16
it cleared immediately.
17
18
So, I mean, let me make sure I'm answering

your question clearly.
19
Ultimately, I never had an issue.
Every
20
issue that came up, that arose, was handled by
21
Mr. Spinosa.
22
23
Did he ever question a need for why you
had this immediate availability of deposits?
24
No, sir.
25
Is that the case, even on huge amounts

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2
that were deposited?

A
I don't -- I don't recall him ever asking
me what the money was for.
what money was for, I volunteered it in advance of
ever being asked any question; but, again, it was
always:
it's from a big investor.
It's for a real estate deal, it's for --
8
9
10
11
Any time that I told him
It would have just been in an email.
You
can tell what I was telling him because it would

have been in the emails; other than that, nothing.
Q
I spent just a couple of moments yesterday
12
talking about the issue of the accounts.
13
all named, or were they numbered; do you recall?
14
Were they
You know, like, for instance, you
15
mentioned that one of your patterns, you might have
16
had like an employment case trust account, and --
17
18
No, no, it wasn't like that.

These were all -- I want to say that we
19
had an internal name for them.
20
numbered.
21
Mr. Lichtman, that says, RRA Sochet or RRA IS; I
22
just don't remember how we were doing it, but
23
internally --
I think they were
There should be a chart somewhere,
24
Yeah, that's internally, right?
25
Yeah, that's internally.

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I don't recall ever naming the accounts
for TD Bank.
and I remember even sending emails to Irene,
saying -- and to Bill, saying, just send Sochet the
money from whatever account -- this I do know
because I remember seeing the email -- just send it
from whatever account we normally send it from.
I have no specific recollection of it;
So, as an example --
It wasn't that easily identified, so I
10
11
12
doubt they had names on them.

Q
For example, like with Sochet, where there
was lock letters, correct?
13
Mhm-mhm.
14
Okay.
15
Yes.
16
There was no account that was actually
17
18
titled Sochet Trust Account at the bank?

A
Oh, I don't think so.
You have to look at
19
the bank records, but I don't recall doing that.
20
It's possible Irene did, but I don't recall ever
21
doing it.
22
23
Who at RRA had access to TD Bank account
information, besides you?
24
TD Bank?
25
TD Bank.

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Okay.
Except for me, Debra Villegas, when
she needed it; Irene Stay; Bill Brock; Stu
Rosenfeldt; David Boden, at various points in time;
Russ Adler, with regard to the personal injury
funds.
into Gibraltar.
But I believe most of those were still going
I think that's pretty much it.
The IT people may have had access, but it
9
10
11
wasn't authorized access.
I always had the feeling
that they had access, but...

Q
Tell me what you mean by might have had
12
access, meaning they would have actually seen
13
account balances?
14
Yes.
Well, Curtis Renie -- and I don't
15
know this for certain, I just always had it in the
16
back of my head, because they were so good at what
17
they did for us, on both the legal and illegal side
18
of computerized banking, that -- I used to talk to
19
Irene and to Debra about it:
20
looking at our bank balances?
Do you think they're
21
We would kind of just slough it off.
22
But the people I knew: Irene, Bill, Stu,
23
Boden, at certain points in time, and Adler, at
24
certain points in time.
25
When you say --

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Also, Les Striker had access from a
reporting standpoint, because he was taking care of
monitoring what attorneys were doing.
Does that mean that Les --
Not online banking.
Does that mean that Les knew there were
trust account defalcations?
I don't believe he did.
Okay.
10
Which lawyers knew about the trust
account defalcations?
11
I can only tell you to my knowledge.
12
That's all I am asking for is your
13
14
15
16
17
18
personal knowledge.
A
Stu Rosenfeldt, David Boden and Russ
Adler, to a limited extent.

Q
Wouldn't you agree that if you know one,
that is one too many.

A
The only reason I'm asking it that way --
19
answering it that way -- the answer to your question
20
is yes, but the only reason I'm answering it that
21
way is you said "the trust account defalcations" --
22
Yes.
23
-- and to me, "the" is the shear magnitude
24
of it.
25
Okay.

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Russ and I had discussed trust account
issues, specifically pertaining to personal injury
accounts, and I said -- always would tell him just,
the checks are coming, just wait, okay, Irene is
taking care of things.
conversations would go.
And that's the way the
So your question, yes, one is too many.
What he actually knew, the extent of it, I don't
know.
10
Rosenfeldt I can tell you for certain.
11
David Boden I can tell you for certain, and myself I
12
can tell you for certain.
13
And when you mentioned Stu and David and
14
yourself, that pertains to the Ponzi-related trust
15
problems, correct?
16
Sure.
Well, Stu had access to the TD Bank
17
records.
18
TD Bank utilizing my password, so I am assuming they
19
looked.
David Boden had the ability to sign on to
20
And in fact --
21
I didn't sit with Stu and David and say,
22
go look and see what we're doing.
23
that curiosity would have them log on from time to
24
time.
25
I am assuming
And as we'll get to in a couple of days,

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Boden and Pearson had their own subPonzi that were
utilizing TD accounts, as well?
That's correct.
Yesterday you said that Irene was
responsible for the trust accounting functions as it
pertained to the handling of the money in the Ponzi.
What was --
Ninety to 95 percent of the time, yes.
Right.
10
11
What was Debra Villegas', you know,

defined role?
What was she actually doing?
12
For the Ponzi scheme?
13
Yes.
14
Paperwork.
15
Okay.
16
deals?
17
Meaning documenting the settlement
Putting together the settlement packets,
18
eventually coming up with plaintiff and defendant
19
names.
20
Curtis Renie and Bill Corte eventually added to our
21
online -- our fake online TD Banking system,
22
preparing the folders for people's review, helping
23
David Boden with his subPonzi, preparing fake bank
24
statements for me.
25
She helped create the phony wire sheets that
Let's describe -- have you describe with

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particularity, to the extent you can remember,
conversations with Spinosa as to the need for the
lock letters; do you recall what you said to him?
4
5
A
letters.
6
7
I have investors that need these lock

Can you do it?
Yes, send it over to me.
Did you describe what the purpose of the
lock letter would be before you sent over the actual
paper document?
10
My recollection is, as I just said, the
11
accounts need to be so that the money could only go
12
out to one place, and then I would have sent him the
13
letter.
14
description, if I'm recalling correctly, what we
15
were trying to do.
16
17
The letter, I think, was the best
Did he ever question you as to what the
purpose would be for him signing that letter?
18
Not to my knowledge, no.
19
Did you ever have any understanding that
20
there was actual -- actually a banking procedure
21
that constituted a lock-letter process.
22
Not to my knowledge, no.
23
Did you ever discuss that with Spinosa?
24
Not to my recollection.
25
Did he ever say to you, you know, there is

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no such procedure as a lock-letter process at TD
Bank?
laugh.
Not when we were first -- I don't mean to
Not when we were first discussing it, but
at some point in time, he had told me -- I had asked
him about -- Caretsky or Kerstetter, one of them,
questioned him about the lock letters, and he and I
were kidding around about the fact that you can't
10
lock the accounts because I have treasury direct; I
11
could move the money anytime I wanted just by
12
signing onto Treasury Direct and moving it.
13
would have been the extent of the conversation.
14
That
Was there a point in time where, in your
15
state of mind, you concluded that Spinosa knew that
16
you were involved in illegal activity?
17
Yes.
18
How is that?
19
Everything I was doing appeared illegal.
20
Give me specifics for the record, please.
21
Just the shear volatility of the money
22
that is moving and the fact that it is going around
23
in little circles -- not little circles, big
24
circles.
25
scientist to lay out all my finances and see that
Money is -- it doesn't take a rocket

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money was flying out of Commerce Bank, flying to
Gibraltar Bank.
One of the key things that I think was a
huge red flag is he was locking accounts that had
not much in them.
until the very day the payment was going out.
if I have lock account number one to Ira Sochet,
there is nothing in it:
might be.
They never had any money in them
$100, $200, whatever it
The day -- then on -- suddenly, on a day,
10
$5 million goes into that account, and minutes
11
later, $5 million goes out of that account.
12
13
So,
Okay.
What about his role in meeting with
investors?
14
Now you're talking later down the road.
15
Yes, I understand.
16
Okay.
17
I just want to make sure.
I'm
trying to get it --
18
What I am focused on, as I'm asking this
19
series of questions, is that would have made clear
20
to you Mr. Spinosa's understanding that there was
21
illegal activity going on.
22
23
24
25
Okay.
I'm just going to go in any order
then.
The fact that when I was having a
telephone call with Barry Damson and Mel Klein --

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Kathleen White may have been on that call -- I sent
him the questions that were going to be asked, but
more importantly, I sent him the answers.
As you covered with Mr. Scherer yesterday?
Yes.
Okay.
-- he didn't even balk at that:
And --
This is
the question that is going to be asked.
the answers I want you to give, don't say anything
10
else, end of call.
11
These are
We'll be done.
When we were having the meeting, I gave
12
him brief prep.
13
knew the routine already, but I told him, this is
14
where we need to be accountwise, balance-numberwise.
15
You have got to make sure that these people are
16
comfortable.
17
150 percent secure in my banking relationship with
18
you so that they can feel secure in their
19
relationship with me.
20
I mean, he was -- he pretty much
When they leave, they need to feel
Okay.
When it came to these meetings, did
21
he ever fail to attend any meetings that you
22
requested?
23
No, sir.
24
Were there meetings, ever, that you had a
25
substitute for a TD banker present?

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When I had to substitute?
Yeah.
Let me be more specific.
As I recall, there was a meeting that
Steve Caputi attended where he acted as if he was a
TD banker?
6
7
8
9
Oh, I thought you meant substituting for
someone like Mr. Spinosa.

Q
No.
That's why I wanted to reclarify my
question.
10
There was a meeting that Mr. Caputi
11
attended and he acted as a TD banker; is that
12
correct?
13
14
15
16
17
Yeah.
There were several meetings where
he played a bank officer.

Q
Do you recall the name of the bank officer
that he played?
A
He played two.
He played Ricardo Mejia at
18
the Weston branch, and Mr. Garces, I believe, at the
19
Deerfield Beach -- at the Deerfield Beach branch.
20
When he played Mr. Mejia, what were the
21
circumstance of him playing that role, for lack of a
22
better phrase?
23
24
25
It's twofold -- well, actually, it's
several-fold.
I had meetings coming up with investors

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that required the ability to have a banker there to
answer questions, not simply to just give a bank
statement.
illegal business with, Steve Caputi was up there in
the top three to five people that I trusted
implicitly.
Out of all the people that I did this
So I asked him to come in and play the
banker.
what to discuss, what not to discuss, how to play
10
I gave him very specific instructions as to
off.
11
How did he get in the room?
12
Ms. Caretsky or Ms. Kerstetter let him in.
13
He arrived there early, usually with Uncle Bill.
14
Had they met Caputi beforehand?
15
No.
16
When I say "they," let me be clear:
No, sir.
17
Caretsky or Kerstetter, had they met Caputi
18
beforehand?
19
Through me and to my knowledge, no.
20
Okay.
21
22
And to be sure, the investors
hadn't met Caputi, correct?

A
The investors, no.
The only person who
23
had met Caputi was our independent verifier,
24
Mr. Szafranski.
25
Do you recall what you said to Kerstetter

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or Caretsky as to why you needed somebody in the
room or why you needed a conference room?
3
4
A
meeting.
I have clients coming and I have to have a

I need a conference room.
Did they question that at all?
No, no, they were very accommodating.
By that point in time, had they already
been involved, though, in the screen-shot process
that you described yesterday with Mr. Scherer?
10
You know, I don't want to guess as to
11
that, Mr. Lichtman.
12
of when all that was going on.
13
thousands of things going on all at the same time,
14
and I can't quite place it in line.
15
down and do a time line for you.
16
I don't recall the time frames

We had, literally,
I need to sit
Do you recall who was in the room with
17
Mr. Caputi when he played Mr. Mejia in the Weston
18
branch?
19
I don't recall which of the people -- if
20
you ask them, I'm sure they'll tell you that they
21
meet with banker who they found out later to be
22
Mr. Caputi.
23
Actually, I can tell you, the easiest way
24
to do it, any time anyone says that they met with
25
Ricardo Mejia, it was Caputi.
Because I never had a

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meeting with any investors with the real Ricardo
Mejia.
So is it a fair statement that Mr. Caputi
played Mr. Mejia more than once?
I believe it was two or three times, yes.
Always in the Weston branch?
Mejia was Weston branch, yes.
Did Caputi have Mejia's business card?
He took it.
I told him when he got to the
10
bank, make sure you get one of the cards; and I
11
remember joking around with him because he
12
originally picked up a female's card.
13
sure this time it's a male's card and make sure you
14
have a stack of them so it looks like you're taking
15
out a stack to hand the card to the people that come
16
in.
17
18
19
20
21
22
I said make
Did Spinosa know that Caputi was going to
the Weston branch for a meeting?

A
For a meeting, yes, but not for the
purpose of the meeting.

Q
Did you tell Spinosa, Caretsky or
Kerstetter, that Caputi was a lawyer at RRA?
23
No, sir.
24
Did they ever ask you why, given the RRA
25
offices are in downtown Fort Lauderdale, you needed

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to use their conference room?
2
3
No, sir.
I had carte blanche at the --
carte blanche at the TD branches.
What did you mean by that?
What is that expression, mi casa es su
casa, their house is my house?
depositor.
there.
do, they would allow me to do, and that's what I
10
11
12
I was a big
I took very good care of the people
It appeared to me that anything I wanted to
did.
Q
Well, on that note, did they ever tell you
that you were a, quote, VIP, end quote, customer?
13
Yes.
14
Who told you that?
15
I saw it in emails, and they introduced
16
me -- I remember Ms. Caretsky introducing me to
17
people at the bank saying, this is Mr. Rothstein;
18
he's one of the bank's largest customers.
19
20
21
Do you recall at what branch that
occurred?
A
That occurred at the Weston branch, and
22
then there was an email saying VIP, large customer,
23
that went up to the Deerfield Branch when we were
24
doing the show up there.
25
We have heard that your picture was

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circulated around so that when you went into the
bank, people would know who you were.
if that's true?
4
5
I heard that.
Do you know
I don't know if it was
true.
Do you recall who you heard that from?
I heard it from Mr. Brock.
All right.
9
10
11
to the point of some double hearsay, possibly, but

do you know where Brock heard it?
A
12
13
Do I know?
MR. SCHERER:
Object to the form of the
question.
14
15
I know that we're now getting
Ask him so we can use it.

BY MR. LICHTMAN:
16
Do you know where Brock heard it from?
17
It became --
18
How he learned it?
19
I don't know how he learned it.
He had to
20
have learned it -- actually, he would have learned
21
it from Ms. Caretsky because that's who his main
22
point of contact -- or Ms. Kerstetter.
23
24
25
But...
Would i be a fair statement, if I just
asked real quick -A
Sure.

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2
3
-- that Brock didn't deal with
Mr. Spinosa; you dealt with Spinosa, right?

A
I was the main contact with Spinosa.
Unless there was an emergency, they -- no one else
contacted Spinosa.
Okay.
But what I was saying with regard to the
picture, just so you have a clear picture of what
was going on, once it became known in the firm that
10
my picture was being circulated, they kept joking
11
around that there was going to be like an
12
employee-of-the-month-type picture that you are
13
going to walk in the bank, and they were going to
14
take down the founder of the TD Bank and put my
15
picture up, and it was going to be in all the
16
branches.
That was the big joke around the firm.
17
And when you say "the firm," you mean RRA?
18
Yes.
19
So, that was, it sounds like, common
20
knowledge?
21
It was common knowledge, yes.
22
All right.
With respect to when
23
Mr. Caputi played Mr. Garces, do you recall the
24
circumstances behind that occurrence?
25
Yes.
I believe I discussed it yesterday.

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2
3
I do.
Q
Is there anything more to add to that
testimony because I don't want to be repetitive.
No, sir.
Okay.
One thing I don't think that you
answered was, did Mr. Caputi also have Mr. Garces'
business card?
Yes.
And, again, he got there because of
10
Caretsky and Kerstetter --
11
12
13
ALL PRESENT:
Form.
BY MR. LICHTMAN:
Q
-- correct?
He was allowed access to the
14
room through Kerstetter or Caretsky; is that your
15
understanding?
16
To my knowledge, I told Spinosa, and the
17
people at my firm, Bill Brock and Irene Stay,
18
because we were changing locations, if you recall
19
from yesterday, from Weston, up to Deerfield; and I
20
said, do whatever you need to do to get the
21
Deerfield Branch ready.
22
23
Okay.
Do you recall, did Blandin Wright
ever prepare any documents for TD at all?
24
25
what it was.
I believe he did.
I just don't recall

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Do you have anything you can show me, sir?
No.
I recall him preparing something, but he
I am looking.
was preparing a lot of documents for us for
different things.
for something else.
for TD Bank.
9
10
He prepared financial statements

I don't know what he prepared
Were you ever told what percentage of TD
Bank's branch business at Weston was attributable to

RRA?
11
I was not directly told, no, sir.
12
With respect to Ms. Caretsky, how many
13
14
15
16
17
times did you meet her?

A
A dozen, two dozen, I don't have a -- I
don't have a specific recollection.

Q
But it would be safe to say at least 12
and probably less than 24?
18
Yeah, I think that would be safe to say.
19
Do you recall the general nature of
20
21
22
23
24
25
reasons why you met her?

A
On nearly every occasion, it would have
been for the purposes of doing the show.

Q
And these meetings would have occurred at
RRA offices or TD Bank or -A
I don't have independent recollection of

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meeting her at RRA.
Weston branch.
It would have occurred at the
And now that I'm really trying to put a
number on it, I think it would be a dozen or less
times that I actually had face-to-face contact with
her; but, again, I'm really guessing.
Okay.
So, you said before, 12 to 24, now
you're down to a dozen or less.
out as to why you -- why you're a little hesitant on
10
that number?
11
What is it stands
What I said -- when I was just describing
12
to you the reasons for me having face-to-face
13
meetings with her --
14
Yes.
15
-- and I realized that the only time I
16
really had any face-to-face meetings with her were
17
pertaining to doing the show; there weren't more
18
than a dozen of those, that I recall, so it would
19
have been right around that number or a few less.
20
What did she do with respect to your
21
settlement business that justified your belief that
22
she was a player?
23
24
25
ALL PRESENT:
Form.
BY MR. LICHTMAN:
Q
Did you understand the question?

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No, I really don't, Mr. Lichtman.
Okay.
3
4
5
6
7
You indicated earlier that you
believed Ms. Caretsky was a player, correct?

A
Yes.
I asked Mr. Spinosa if I could trust
her, and he said yes.

Q
And, indeed, there was a point where you
had given her an envelope of money, correct?
Yes.
Okay.
What activities besides -- were
10
there, that justified your belief that she would
11
assist you, as needed, at TD Bank?
12
13
14
15
You have got to remember, before she ever

receives any money from me, the first -Q
16
17
Really it was just Frank's word.
I did a bad job on the question.

What did she do?
Okay.
What Ms. Caretsky did for us was,
18
early on -- perhaps the best place for me to start
19
is me approaching her.
20
Mr. Spinosa tells me that I can trust her, I go to
21
her and I explain that we're going to have people
22
coming into the bank, that I need these people to
23
believe that our bank balances are much higher than
24
they are, okay, and that what I need her to do is --
25
that Bill was going to come in with these bank
Once Frank tells me,

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statements; we will prepare them.
do was give us a cover letter to go with it.
All she needs to
When Bill gives her the bank statements,
put them in with her cover letter, seal it up, and
when I come in with the investor, be polite and hand
over the bank statements.
our banks statements.
off and running.
9
10
11
12
13
I'll ask her are these
She'll say yes, and we are
That's all we needed.
This is a conversation that did occur,
correct?
A
That is a conversation that absolutely
occurred.
Q
And, indeed, then, afterwards, her conduct
14
was consistent with what you requested her to do, as
15
you described yesterday, correct?
16
Yes, sir.
17
Okay.
18
Bank statements, did she challenge
you as to why you would do that?
19
No, sir.
20
Was there ever a time that she refused to
21
participate?
22
No, sir.
23
She ever ask you exactly what you were
24
25
doing in asking her to go through this process?

A
No, sir.

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2
3
4
How about Ms. Kerstetter, did you have any
reason to believe that she was a player?

A
No.
Actually, the very first time that I
heard she was going to be involved, I panicked.
Tell me why.
Because I heard that Ms. Caretsky was not
going to be at the bank and that we were going to go
doing this with someone new.
a large criminal conspiracy, and you don't want to
10
We're in the middle of
inject new players, unless you have to.
11
I was then told by Mr. Spinosa and by Bill
12
Brock that everything was fine, that Ms. Caretsky
13
had talked to Ms. Kerstetter, that she was all a go;
14
and it went fine.
15
Let's back up now.
16
Sure.
17
So, when you learned that Ms. Caretsky was
18
not going to be present and that Ms. Kerstetter was
19
going to step in, you had a conversation with
20
Mr. Spinosa?
21
Yes.
22
Describe that conversation, please.
23
It was probably something around, Frank,
24
25
what the hell is going on?

I mean, that's basically the conversation

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we had.
That's not very descriptive:
Frank, what
the hell is going on; you can be talking about Iraq,
for all we know, at that time.
No, that's not what we were talking about.

I called Frank, and I told him that we
needed to have people come into the bank again, that
Ms. Caretsky was not going to be there.
He said he would talk to Ms. Kerstetter
10
and make sure that it was being handled, be sure
11
that she would not -- if she wasn't going to be
12
there, she had taken steps to do what needed to be
13
done.
14
I contacted Mr. Brock, told him, you have
15
got to make sure someone is going to cover for us or
16
Ms. Caretsky needs to come in for us.
17
What was it that Mr. Spinosa said with
18
respect to the conversation on Ms. Caretsky, I guess
19
it was, lining up Ms. Kerstetter; is that what
20
you're saying?
Making sure she was on board?
21
He didn't say Ms. Kerstetter.
22
He said somebody else?
23
He said, I'm sure she'll get it handled.
24
25
He went and checked because I spoke to him

more than once that day; it was several

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conversations --
Tell me the everything that you can
remember about what you said to him and what he said
to you about getting her to handle?
5
6
A
you.
Let me see if I can put it in order for

We will do it that way.
Okay.
bank visit.
do the show.
We knew there was going to be a
We needed to take people to the bank to
10
Do you recall who it was?
11
No.
12
I don't have a clue.
We -- I tell Bill, we're going to go do
13
this.
14
just the way we always did before we went to do the
15
show at the bank.
16
I've got Debra preparing the bank statements
And at some point in time, I learned from
17
Bill that -- I believe it was Bill, that she --
18
Ms. Caretsky is not going to be there.
19
remember whether we were prepping it that day or
20
prepping it a day before; normally we would never
21
prep it more than a day or so before.
22
I don't
And it turned out Ms. Caretsky was not
23
going to be there, and I went into what I'll call
24
semi-panic mode:
25
to be there?
What do you mean she's not going
I -- I may need to change the date.

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It could be that the people were flying in and I
can't change the date.
Bill told me, I'll handle it.
I let him go and do whatever he was going
to do.
At the same time, I contacted Mr. Spinosa
and said, listen, I need to do one of these bank
visits and Caretsky is not going to be there.
9
10
Frank told me, I'll contact the bank, talk

to Ms. Caretsky, make sure we're all good to go.
11
I later spoke to Mr. Spinosa who had told
12
me that we're all set to go, that Ms. Caretsky's
13
assistant was going to be there.
14
And Bill had already told me the same
15
thing: that everything was fine, that Kerstetter was
16
going to handle it and Caretsky had gone through
17
everything with her step by step.
18
So that was, effectively, the first time
19
that Ms. Kerstetter was involved in facilitating
20
anything relating to your settlement transaction
21
with TD Bank?
22
To my knowledge, yes; and you can probably
23
figure out who it was, Mr. Lichtman, just by looking
24
at the first time she signed a cover letter and
25
seeing who the bank visitors were that day.

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Do you have any reason to believe that --
other than there possibly being red flags as to the
nature of what she was doing -- that she knew she
was involved in illegal activity that day?
Well, she was -- the only way I knew she
was involved in illegal activity is she was taking
fake bank statements and putting them in with her
cover letter and handing it to me in front of what
she would have believed was investors or clients.
10
Did anyone report back to you that
11
Ms. Kerstetter had acted improperly or out-of-script
12
that day?
13
No, not at all.
14
Did Ms. Kerstetter participate in the
15
16
17
future?
A
I believe she did one or two more times,
but I don't recall how many.
18
Did you ever meet Ms. Kerstetter?
19
I met her on the occasions that I went to
20
21
22
the bank, yes.

Q
Okay.
How many times was that,
approximately?
23
A very small handful.
24
Did she ever receive any inducements from
25
you of any kind?

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Not from me, sir, no.
How about from anybody else?
I do not know.
Okay.
No, sir.
Did Spinosa or Caretsky ever tell you that
So you never gave her cash?
they took care of her?
No, sir.
Did Ms. Kerstetter ever talk to you about
10
overdrafts?
11
No, sir.
12
Did Ms. Caretsky ever talk to you about
13
overdrafts?
14
15
No, sir.
I have no recollection of either
one of them ever talking to me about overdrafts.
16
Did you ever have any discussions at TD
17
Bank with Ellen Elia, E-l-i-a?
18
name?
19
Do you know that
I don't recognize the name.
If I spoke to
20
her, it had to have been an in-passing thing.
21
don't know who she is.
22
How about Karen Zuckerberg?
23
The name is not ringing any bells for me.
24
Hector Ortiz?
25
No, sir.

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Holly Kruppa, K-R-U-P-P-A?
I remember seeing that name on something.
I don't think I talked to her.
seeing her name appearing on something that was
floating through the office.
6
7
8
9
I just remember
So you have no recollection of any facts
about her?
A
All the people that you named so far, I
don't have a clue who they are and, I don't have any
10
independent recollection of speaking to them or
11
meeting them.
12
Victoria Mason?
13
No independent recollection, sir.
14
Susan Manano?
15
No recollection.
16
Brian Keller?
17
No recollection.
18
Jerrod Jones?
19
No recollection.
20
William Reese?
21
No recollection, sir.
22
Did you ever refer business to TD Bank?
23
I believe we did, but I don't have an
24
independent recollection of it.
25
course when we had someone involved in the Ponzi at
It was our normal

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1
any level to try to do as much as we could for them,
so it would not be out of the ordinary.
independent recollection of it.
4
5
MR. LICHTMAN:
Give me one second to talk
to Mr. Scherer about something.
THE WITNESS:
MR. LICHTMAN:
Do you want to take a break?
12
Sure.
Okay.
Thank you.
I have been
requested that we take a short break.
10
11
But no
Right?
(Whereupon, a recess was had.)

BY MR. LICHTMAN:
Q
Mr. Rothstein, was there ever a time that
13
Mr. Spinosa or Ms. Kerstetter asked you for more
14
money?
15
No, sir.
16
Did Mr. Spinosa ever ask you what his role
17
was in the bigger picture of the settlement business
18
you were involved in?
19
20
21
I don't really understand what you're
asking me, Mr. Lichtman.

Q
Did he just kind of like say -- well, in a
22
general sense, what's going on, in the big picture?
23
How do I fit into all of this?
24
25
No.
The only thing we ever discussed was
after I told him he would certainly be welcome to

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have a high-paying job with my companies outside the
law firm, that type of stuff we discussed.
3
4
5
I don't know that if that's responsive to

what you're asking me.
Q
Let me rephrase it a different way.
Was
he just sort of acting within his own self-contained
unit and didn't really know what other people were
doing to assist you?
Yes.
10
Okay.
11
12
13
14
Same thing with respect to
Ms. Caretsky?
A
Ms. Caretsky and Mr. Spinosa, yeah, we'll
call them self-contained Ponzi co-conspirators, yes.

Q
And is it a fair statement that they
15
therefore did not know what Mr. Harris was doing for
16
you at Gibraltar?
17
18
19
I don't think they had any idea what he
was doing for me.

Q
And, likewise, to the best of your
20
knowledge, Mr. Harris did not know what Spinosa and
21
Caretsky were doing for you?
22
That would be correct.
23
Okay.
Did Mr. Spinosa ever ask you why it
24
was necessary for a TD banker to act as if they were
25
delivering those -- the envelope with the statements

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to you when you were there meeting with the
investors in the show?
MR. SCHLESINGER:
misstates prior testimony.
Did they ever ask me why?
Yes.
No.
Let me -- did you understand the question?
Why don't you go ahead and reask it,
10
11
Object to form,
Did they ever --
Mr. Lichtman.
Q
Okay.
Did Mr. Spinosa ever ask you why it
12
was necessary for someone from TD Bank to deliver
13
that envelope into the room that you were present at
14
with the investor?
15
MR. SCHLESINGER:
Again, same objection,
16
please.
17
No.
18
Did you ever tell them why it was
19
20
21
22
23
important for them to do it?

A
No.
And just so you are clear, it wasn't
always delivered in the room.

Most of the time, actually, with me, it
24
was delivered to me, actually, in the central area
25
of the bank, standing there with Ms. Caretsky or

(954) 525- 2221
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1
2
Ms. Kerstetter, with the investor.

Q
Okay.
So when my question presupposed in
the room, it was really in the presence of the
investor in a different location of the bank?
Correct.
Is it your presumption that when this show
occurred with the TD banker -- whether it was
Caretsky or, in some instances, Kerstetter -- who
handed you the envelope, that they knew the contents
10
11
12
13
of the envelope, correct?

A
They absolutely knew the contents of the
envelope.
Q
And they knew that the people that you
14
were going to be meeting with were investors,
15
correct?
16
Yes, sir.
17
And I think it's fairly obvious, but tell
18
me why you say they absolutely knew what was in the
19
envelope.
20
Because the phony bank statements were
21
handed by someone from my firm, in most cases, Bill
22
Boockvor, to them to place in the envelope.
23
no other way to get them into the envelope.
24
25
There's
And they were the ones that folded the
fake statement with the letter into the envelope,

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2
"they" being the TD Bank official, correct?

A
To my understanding -MR. SCHLESINGER:
Object to form.
To my understanding, yes.
Okay.
Did Caretsky ever ask you about the
contents of the screen shot or bank statement that
was furnished to her to put into the envelope?
No.
I -- what you need to recall is that when
10
I first started doing this with Caretsky, I told her
11
that she was going to be getting bank statements
12
that reflected much higher balances in them because
13
I needed to establish for these people, so I could
14
do future business with them, the accounts had much
15
more money in them than they actually had.
16
Okay.
And if I asked this, and I might
17
have, I apologize for reasking it.
18
question why that was happening, correct?
19
No, sir.
20
Okay.
21
22
She didn't
I think I did ask you.
Were you ever contacted by the Florida Bar

about overdrafts at TD Bank?
23
No, sir.
24
You mentioned yesterday that Sara Coen --
25
and, for the record, it's C-O-E-N, I believe.

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That's correct.
One of your employees is who introduced
you to Ahnick, A-H-N-I-C-K, Kahlid, K-A-H-L-I-D.
That's correct.
Who was or who is Mr. Kahlid?
To my knowledge, he was a friend of
Ms. Coen's.
9
10
11
12
What was it that made you trust him so
that you would send to him the wire transfer that

you did at the end of October of 2009?
A
I trusted Ms. Coen to lead me in the right
direction.
13
Understanding, Mr. Lichtman, I want to
14
make sure the record is clear, Ms. Coen had nothing
15
to do with this and did not know what I was doing.
16
I had lied to her about what I was going to do.
17
Right.
I think that the emails that you
18
sent around the firm, you know, are already in the
19
record.
20
Mr. Kahlid went with you to Morocco?
21
He did.
22
Did he receive any kind of payment or
23
remuneration?
24
Several million dollars.
25
Did you work that out with him before you

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2
left for Morocco?

A
I worked out the fact that I was going to
be paying him something before we left for Morocco.
The actual amount we actually discussed on the plane
ride over, and once we got to the hotel we were
staying at, we came to an agreement.
Did he get his money?
He did.
Do you know if his money was forfeited or
10
11
returned to the government?

A
I thought he returned it.
I don't have
12
specific knowledge that he did, but I believe that I
13
was told that the arrangement was he was going to
14
return it and did, in fact, return it.
15
16
And I know that the bulk of the money that
was wired to Morocco was forfeited, correct?
17
That's correct.
18
Okay.
I'm going to now go through
19
documents.
20
try to do this as quickly as I possibly can.
21
I have a stack.
I'm going to want it
Yesterday -- I'm going to hand to the
22
court reporter Exhibit 64 -- I was asked to be the
23
custodian of it, since we switched off court
24
reporters in the morning and the afternoon, but I'm
25
now going to return the original of Exhibit 64 to

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1
the court reporter.
2
3
I'm going to put it here because we night

get to it.
Okay.
(Thereupon, a document was
marked as Trustee's Exhibit 65 for
Identification.)
BY MR. LICHTMAN:
8
9
10
Q
65.
Showing you what's been marked as Exhibit
It's an email from you to Paolo Casabone.
C-a-s-a-b-o-n-e, dated April 29, 2008?
11
Yes, sir.
12
It's got a Bates stamp at the bottom of
13
Scott underscore Rothstein, FBI underscore 113444.
14
I ask you to take a look at that email.
15
Yes, sir.
16
Do you recall this email?
17
I do.
18
Okay.
In this email, there's a request
19
for Mr. Casabone for information at the bottom about
20
your business, and then at the top of the email, you
21
identify a number of entities that you are involved
22
with including RRA Jewel River Cruises, Q Task,
23
Bova, Edify, a WWW -- WAWW entity, in a general
24
sense, and so on.
25
You see that?

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I do.
Okay.
Did TD Bank ever ask you what these
entities are?
From this email, looking at the email
chain, it appears that Mr. Casabone asked me for a
brief explanation of the liens listed and I just --
it looks like I covered more than the liens.
just listed everything that was on the list he gave
me.
10
11
12
13
Right.
That I
I understand that.
But, also, did he ever ask you what the

entities were?
A
I don't recall doing anything -- I didn't
14
even -- until you showed this, I didn't recall even
15
doing this letter.
16
Okay.
Do you recall them ever asking you
17
where the money came from for you to acquire these
18
entities?
19
No, sir.
20
Do you recall whether or not TD Bank
21
conducted any investigation about these entities?
22
To my knowledge, no, sir.
23
If TD Bank back in April of 2008 had
24
conducted an investigation to find out how these
25
entities had been funded, what do you believe they

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would have found based on your knowledge of the
finances and how these entities were acquired?
3
4
MS. EVANS:
A
Object to form.
They would not have been able to trace the
money to any legal source.
BY MR. LICHTMAN:
Describe what you mean by that.
Well, most of the money was -- if you
track the flow of where the funds came from, they
10
either came through the Banyan 1030-32 account or
11
from the TD Bank O923 account, flowing then into an
12
operating account; and then out of the operating
13
account into one these -- either one my personal
14
accounts to pay for this or into one of these entity
15
accounts that I used to purchase these items.
16
MR. LICHTMAN:
17
I'm going to show you another exhibit.
18
19
Okay.
Great.
For the record, it's Exhibit Number 66.

20
21
Identification.).
22
MR. LICHTMAN:
I have only have one copy
23
with me for some reason, so I'm going to stand
24
by you with the marshal's approval just to go
25
over the document with him.
Is that okay?

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THE MARSHAL:
MR. LICHTMAN:
THE WITNESS:
MR. LICHTMAN:
the record.
BY MR. LICHTMAN:
Yes.
Thank you.
You want this one back?
This is going to go with
Showing you Exhibit 66, this is an email
dated October 29th, 2008, from Ms. Kerstetter to Mr.
Brock with a copy to Ms. Caretsky.
10
You see this?
11
Yes.
12
It references that you are going to be at
13
the bank this afternoon.
14
Do you see that?
15
I do, sir.
16
Do you recall the instance of why you
17
would have been going to the bank on October 29th,
18
2008?
19
I do not, sir.
I'm sure it's a visit with
20
investors but I don't have an independent
21
recollection.
22
Okay.
On the second page it lists some
23
accounts.
24
DG -- DJB Financial Holding, LLC.
25
The first account that it reference is
Do you know what that account was used

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for?
My recollection is that's the account we
utilized to purchase Cafe Iguana.
recollection.
That is my
What does DJB stand for?
I believe that is David Boden's initials.
Did David Boden own DJB Financial Holding,
He was the was the punitive owner, for all
LLC?
9
10
intents and purposes.
11
standpoint, yes, he was.
From a legal, technical
12
And who was the de facto owner?
13
I was.
14
Okay.
15
Sure.
16
And was that account used for anything
17
Did Mr. Boden know that?
other than the acquisition of the bar?
18
Other than the acquisition of the bar, the
19
only other thing it could have been used for would
20
be illegal campaign contributions.
21
no.
22
23
Okay.
Other than that,
Did Mr. Boden know that this
account was used for illegal campaign contributions?
24
25
known.
If we utilized it, he may or may not have

I don't know -- I don't who had access to

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the checkbook.
2
3
The next account is SJM Consulting Group,
LLC.
What is that?
I actually don't recall.
Okay.
The next account is RRA-B.
Do you know what that account means?
No, sir.
Okay.
10
And at the bottom there's an
RRA-Merchant account.
11
Do you know what that was for?
12
That was our credit card clearing account.
13
And what credit card -- meaning law firm
14
15
clients that paid through credit card?

A
16
Yes.
My recollection is that Irene and Bill
17
made it so that our clients at the law firm could
18
pay by credit card if they wished to.
19
Do you have any reason to know whether the
20
account balances that are on the right side column
21
are accurate balances as of that date?
22
I have no way of knowing.
23
They're not very large.
The largest is
24
1.9 million, almost $2 million and the second
25
largest is only 1 million.

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2
Did you have other accounts at TD Bank at

that time?
I don't recall one way or the other.
From seeing the small amount of the
balances, including those in the three trust
accounts, does that possibly spur your memory as to
what you might have been doing at the bank that day?
Nope.
Okay.
10
No.
11
12
or the other.
Q
13
14
I think that's it.
Thank you.
Sorry for standing over you.

A
15
16
I don't have a recollection one way
That's okay.
MR. LICHTMAN:
Showing you next what has
been marked as Exhibit 67.
17
18
19
Identification.)
20
MR. LICHTMAN:
For the record, it's a
21
letter on TD Bank letterhead dated March 20th
22
to your attention, signed by Ms. Kerstetter.
23
24
25
BY MR. LICHTMAN:
Q
You see that?

MR. LICHTMAN:
And for the record, it was

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also previously identified at the Kerstetter
Rule 2004 Exam as Exhibit 50.
MR. SCHLESINGER:
THE WITNESS:
MR. LICHTMAN:
THE WITNESS:
for one second, please?
MR. LICHTMAN:
THE WITNESS:
What was the date?
Mr. Lichtman -It's March 22, '09?

Can I see the prior exhibit
It's right in front of you.

Oh.
It is.
10
Just give me one second.
11
I would like to clarify something I said
12
13
to you earlier.
BY MR. LICHTMAN:
14
Yes.
15
Just so we're clear, when I look at the
16
second page, which is that balance sheet --
17
18
19
MR. LICHTMAN:
A
May I approach?
-- in conjunction with the first page --
BY MR. LICHTMAN:
20
Yes.
21
Okay -- it clearly appears to me that I
22
was going there to do a bank visit, a bank show, as
23
we discussed yesterday.
24
Right.
25
But you got to look at both those pages
Okay.

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together to realize that.
Drawing your attention to Exhibit 50.
Yes, sir.
Are you familiar with that document?
I know what it is.
Okay.
it is.
9
10
Yes, sir.
Tell me your understanding of what
It's one of the real bank cover sheets
with the fake bank statements attached to it.

Q
Okay.
So to be sure, the first page of
11
the exhibit is an authentic letter from Ms.
12
Kerstetter with your signature?
13
To be clear, for me to know that for
14
100 percent certainty, I would have to see the email
15
traffic surrounding this.
16
Yes.
17
But 90 percent of the time, maybe
18
99 percent of the time, all of the cover letters, so
19
long as they don't actually contain balance numbers
20
on them, when it's just attached please find your
21
trust accounts statements, those are all original,
22
real letters that either Kerstetter or Caretsky
23
created.
24
25
With Ms. Kerstetter do you recall there
being any forged cover letters by her?

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That we forged with her signature?
Yes.
one way or the other.
Look at the second page of the document.
Yes, sir.
Okay.
This is a fake bank statements.
10
That would have been prepared by who?
11
It would have been prepared by Debra
And tell me what that second page
is.
12
Villegas and myself and in conjunction with Bill
13
Brock.
14
15
Okay.
been a fake bank statement?
16
Yes.
17
Okay.
18
19
And the third page, that would also
Same exact answer.

At the top left corner it says
"account number."
A
By the way, it just important for you, for
20
your clarification, the way to tell whether this is
21
forged or not --
22
"This" being?
23
The front letter.
24
Yes.
25
Is if there was an actual bank visit that

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day and Ms. Kerstetter was there that day, then it's
a real letter.
ever forge a cover letter for these is when we were
doing bank statements and not actually going to the
bank.
bank, there was no reason for us to prepare the
letter in house.
8
9
Because the only reason we had to
If we were actually going to appear in the
Okay.
The last four numbers on account
number, do you know what those represent?
10
What page am I looking at?
11
Second page, top left corner.
12
1258 you're talking about?
13
Yes.
14
I don't know which account that was but
15
it's one of our trust accounts that we used for the
16
investors.
17
Is it your recollection that in house at
18
RRA you kept track of different accounts by the last
19
four digits of an account number?
20
Yes.
Every one of our investor accounts
21
and our legitimate accounts all were by -- Irene
22
kept a list by last four digits and then who the
23
account belonged to, so to speak.
24
25
So, by example then, we could trace the
activity of account 1258 through the RRA internal

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ledger to match account number 1258?
Absolutely.
The balance of the 110,331,000 that you
see in the right both time page of two?
Yes, sir.
Do you know how that figure was selected?
Specifically, no.
Okay.
Typically, would this -- would an
amount on a screen shot such as this of
10
$110 million, is it a fair statement that when the
11
numbers on the statement reached large sums like
12
that, that they were forged documents?
13
14
15
16
MS. EVANS:
A
Object to form.
Yes, sir.
BY MR. LICHTMAN:
Q
This is the type of document that would be
17
inserted with the real TD letter and handed to the
18
investor, correct?
19
Yes.
20
Okay.
21
Sixty-seven.
22
Okay.
23
Let me clarify my answer, Mr. Lichtman.
24
25
That was exhibit -- what number?
As far as the amounts, they were generally

arrived at one of two ways.
It may make your

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questioning me easier.
by Mr. Preve as to what the balance needed to be or
we would look at what we're supposed to have in the
account, attempt to calculate it, bump it up a
little bit so we had some cushioning and place that
number on the sheet.
Exhibit 68.
Okay.
It was either provided to me
Showing you what's been marked as
10
11
Identification.)
12
BY MR. LICHTMAN:
13
14
It's an email from Lisa Hirschenson.
S- I
-- H-I-R-S-C-H-E-N-S-O-N, for the record.
15
Yes, sir.
16
To you dated April 8, 2009?
17
Okay.
18
It's Bates stamped Scott Rothstein FBI 93
19
40, and the subject is "Frank Spinosa is here to see
20
you."
21
Yes, sir.
22
Do you recall why Mr. Spinosa -- I assume
23
that when Ms. Hirschenson wrote this, she was an
24
employee of RRA?
25
Yes, sir.

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Do you recall her position?
One of the things she did was she acted as
receptionist.
4
5
Okay.
Do you recall why Mr. Spinosa was
coming to see you on or about April 8th, 2009?
No, sir.
At the RRA offices?
Yes, sir.
Do you recall approximately how many times
10
He came to see me frequently.
you had taken him to lunch or dinner at Bova?
11
Lunch and dinner?
12
Lunch or dinner.
13
Dozen, two dozen, three dozens.
14
15
know.
Or.
And/or.
I don't
A lot.
Q
Was it customary when he came to his visit
16
you at the office, that you would typically --
17
whether it was for lunch, dinner or cocktails -- run
18
down to Bova as well?
19
Yes.
20
Okay.
21
22
23
And when you went to Bova, he never
paid, correct?
A
No, sir.
24
25
Identification.)

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BY MR. LICHTMAN:
Showing you Exhibit 69.
It's an email
from Frank Spinosa to yourself, dated April 15,
2009.
It's Bates stamped Scott Rothstein FBI 10886.
Yes, sir.
This references at the very first
sentence, "Scott, spoke with David Boden and
requested financial information."
Yes, sir.
10
"We have not heard from Bill on new
11
accounts for wires coming in or the rapid deposit
12
machine you want to start using."
13
Do you know what financial information Mr.
14
Spinosa was referring to when he said that he spoke
15
to David Boden?
16
No, sir.
17
Do you know what accounts and wires for
18
the rapid deposit machine Mr. Spinosa was
19
referencing in the second sentence?
20
No, sir.
21
When he says in the fourth sentence, "We
22
are very proud to be #1," do you know what that
23
means?
24
Yes.
25
What?

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There came a point in time when someone at
TD Bank was looking at our firm website and our
client list and noted that TD Bank wasn't on there,
even though we were doing work for them.
brought it to my attention.
Frank
And you should actually have an email
where I am instructing some people at the law firm
to add them and make sure they are added in the very
first spot.
10
11
12
13
And his comment, "Let me know what I can
do for you," what was he telling you there?

A
Exactly what it says:
Let me know what I
can do for you.
14
15
And that's what he was talking about.
Frank was very accommodating.

Q
Let me next show you Exhibit 70.
16
17
18
Identification.)
19
20
BY MR. LICHTMAN:
Q
It's a email from Bill Brock to Roseanne
21
Caretsky, Jennifer Kerstetter and Debra Villegas,
22
dated May, 14, 2009, Bates stamped Debra Villegas
23
FBI 2821.
24
Yes, sir.
25
Are you familiar with this letter?
This

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email?
I don't recall ever seeing it before.
Okay.
Notwithstanding in the sentence
right at the top of it, it says, "Need letter and
printouts for Friday AM.
way in."
Debra will pick up on her
Would just reading that sentence tell you
what the subjecting matter is about, what they're
talking about?
10
I know exactly what it is.
11
What is it?
12
The letter is the cover letter similar to
13
the one that you saw.
14
the bank printouts.
15
16
And the printouts would be
In this particular case, it would be the

screen shots that she actually would print up.
17
This is one of those circumstances
18
where -- that I described yesterday where Deb is
19
picking up the stuff, which means we're not going to
20
do a bank visit.
21
the letter and the screen shots to somebody in house
22
or scan it and send it to somebody from in house.
23
24
25
Okay.
That I'm actually going to hand
Next, Exhibit 71.


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2
3
4
Identification.)
BY MR. LICHTMAN:
Q
This is from Frank Spinosa to you, dated
May 27, 2009.
Okay.
It's Bates stamped Trustee/Spinosa, 007.
I would like you to quickly skim this
email.
Does it run from back to front?
10
It does.
11
Okay.
12
Showing -- I draw your attention to at the
13
It's four pages long but it's all short.
top it says page four of five.
14
You write to Spinosa, quote, Follow-up to
15
our call, check was deposited to RRA trust account
16
0923 for 2,209,000.
17
I can close this deal.
18
assistant as always.
19
$15 million deposit this week.
20
Please clear it immediately so

Thanks for all your kind
You have earned your
Love ya, Scott.
21
Yes, I do.
22
Tell me what you recall about the email.
23
I -- it was one of the unusual
24
circumstances where instead of getting a wire in, we
25
got -- received a check.

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As I'm certain you can imagine, a check
for 2,200,000 and change doesn't generally clear,
immediately, the bank.
volatility of the movement of the movement of the
money in and out of the Ponzi scheme, I obviously
need all checks to clear immediately.
Because of the high
I called upon Frank -- first I called him
and told him what was going to be happening, and
then I followed up with the email to make sure that
10
the email was going to be -- was -- excuse me -- to
11
make sure that the check was going to clear
12
immediately so I could utilize the funds.
13
Bless you.
14
15
immediately?
16
17
18
19
20
Did he facilitate clearing the check
Yes, he did.
MR. SCHLESINGER:
Object to the form.
BY MR. LICHTMAN:
Q
Did he know whether or not -- how do you
know that he did that?
21
Because the check cleared immediately.
22
Did Mr. Spinosa note this related to an
23
24
25
investment transaction?
A
I actually don't know what he knew.

The fact that I used the word "deal",

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should have told him that, but I can't get inside
his head and tell you what he was actually thinking
at the moment.
4
5
He knew you were doing these settlements
at that point in time, correct?
MR. SCHLESINGER:
By May of '09, yes.

MR. SCHLESINGER:
objection to form?
10
MR. LICHTMAN:
11
Did you catch my
Yes.
BY MR. LICHTMAN:
12
13
right?
14
15
Objection to form.
Wire transfers did clear immediately.

Once the money is sent by wire -Yeah.
The wire was automatically
available for us.
16
Actually, you know, we had one instance, I
17
think, where wire got hung up, but, general rule,
18
wires cleared immediately.
19
You'll see the next email at page two of
20
five.
21
check?
22
Yes.
23
You wrote, "Did everything work?"
At the bottom, Frank to you regarding the
24
25
You see that?

A
Yeah.
Frank wrote that to me:
"Did

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everybody work?"
And do you see that you wrote back on page
one:
If they only knew how truly impressive you are.
will make certain they do -- with a lot of O's
there.
"Nice title.
Regional VP sounds impressive.

I
You see that?
I do.
Okay.
10
I do.
11
What was the point that you were making
12
there?
13
And you recall that?
I was teasing him about his title, and the
14
"if they only knew how truly impressive you are" was
15
a reference to the illegal activity he was doing for
16
me.
17
Okay.
At the top of the email he writes
18
to you:
19
Some Jersey vultures flying around.
20
over a vodka and cigar."
"Thanks, I need all the help I can get.

I will explain
21
Yes.
22
Do you recall that?
23
I do.
24
Did you guys actually get together and
25
share a cigar and have some vodka, or something

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2
3
along these lines?

A
I'm sorry.
You have to repeat that
question.
Did you actually get together after that?
At some point in time shortly after that,
6
7
8
because I remember the Jersey vulture conversation.

Q
Do you recall or did you speak with him
about what Jersey vultures meant?
I did.
10
What did he say?
11
He told me that there were people in from
12
the home office from Cherry Hill, New Jersey,
13
attempting to interfere in general with the way he
14
was running his end of the business, meaning his
15
business.
16
And anything that I could do to help
17
bolster his credibility within the bank, bolster his
18
importance to the bank would be most appreciated.
19
And I did.
20
Did he suggest that people in New Jersey
21
were asking questions about you your accounts and
22
the volatility of the transfer of money?
23
24
25
MR. SCHLESINGER:
A
Object to form.
No, sir.
As I testified yesterday, he was very good

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at taking care of all the problems without having to
get me involved.
BY MR. LICHTMAN:
Let me rephrase my question to you.

Did he say anything to you at all about TD
Bank officials from New Jersey questioning anything
about RRA accounts?
No, sir.
10
11
12
Identification.)
13
14
THE WITNESS:
BY MR. LICHTMAN:
15
16
Thank you.
This is an email from Frank Spinosa to
yourself, dated May 27th, 2009.
17
Yes.
18
And it says, "Here are Fred's title and
19
address.
You are the" -- in big capital letters,
20
"best."
Three explanation points and it references
21
Frank Graziano, President, Regional Banking, TD
22
Bank.
23
Yes.
24
Do you recall receiving this?
25
I do.

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What did you do after you got it?
I wrote a letter to Mr. Graziano about Mr.
3
4
Spinosa.
Q
I note that Exhibit 71 was dated May 27,
and Exhibit 72 is dated May 27th.
right out?
Did you send it
Within a day or so, yes.
Did you ever hear back from Mr. Graziano
about your comments concerning Mr. Spinosa?
10
I don't recall one way or other.
11
Did Mr. Spinosa ever comment to you that
12
13
he had heard from Mr. Graziano?

A
He commented to me that he heard back
14
from -- I don't remember him saying Graziano, but
15
just things were going well and he thanked me
16
profusely for the letter I had written.
17
18
inducements?
19
Absolutely.
20
Another way to ingratiate yourself with
21
22
23
Would you consider that letter one of your
Spinosa; would that be a fair statement?

A
Sure.
(Thereupon, the document was
24
marked as Trustee's Exhibit No. 73
25
for Identification.)

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BY MR. LICHTMAN:
I am showing you Exhibit 73.
Thank you.
It's an email dated May 28, 2009, from
Spinosa to yourself.
Trustee/Spinosa 0001.
It's Bates stamped
Yes.
If you would take a look at this email and
tell me if you remember this email?
10
I do, actually.
11
Okay.
It starts from the bottom, up.
12
Actually, really, all you need to focus is on page
13
one, because page two is, you know, the standard
14
disclaimer message, and page three is sort of a
15
duplicate of page one.
16
I have read the whole thing, Mr. Lichtman.
17
Okay.
At the bottom of the email, Spinosa
18
writes to you, at 10:44 a.m.: "Wende is taking
19
off" -- just for the court reporter's purposes,
20
Wende is W-E-N-D-E, not with a "Y."
21
22
"Wende is taking off hold.

on system soon."
23
24
25
Should show up
Do you know what that means?

A
Yes.
That there was still a problem with
that -- I think it was a reference back to the day

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before, to that same check.
Okay.
There was still a hold on it.
Something
had gone awry, and I had called Mr. Spinosa and let
him know that there was a problem trying to move the
funds from account to account, and it got taken care
of.
8
9
10
Indeed, that's what you reference in the
emails of six minutes later.
It says, "Spinosa,"
correct?
11
Yes.
12
And then it did get cleared up, right?
13
Yes.
14
Ms. Wende writes, as part of her email,
15
her home address:
16
Circle, Weston, Florida 33327.
17
18
19
20
21
22
My address is 1126 Sunflower
Why did she furnish you with her home

address?
A
No, no, this is Frank's home address.
This is an email from Frank Spinosa.

Q
I'm sorry, Frank's address.
I'm sorry.
apologize.
23
Why did Frank give you his home address?
24
I was sending a limo to pick him up.
25
For what?

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An event.
Just look right around this date and see
whether it was a political event, what we were
doing.
give me his address because I was sending a limo to
get him.
I was sending -- I remember him having to
Did he have to pay for the limo?
No, sir.
You paid for the limo?
10
Always.
11
Out of RRA funds, obviously?
12
Correct.
13
Yes -- well, they weren't RRA
funds; they were Ponzi funds --
14
Okay.
15
-- that were in RRA.
16
17
18
Identification.)
19
20
21
BY MR. LICHTMAN:
Q
Showing you Exhibit 74, it's an email from
Bill Brock to Ricardo Mejia, M-e-j-i-a --
22
Yes.
23
-- copy to Caretsky, Kerstetter, Jerrod
24
25
Jones, and Villegas -A
Yes.

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2
-- dated July 2nd, 2009.
It's Bates
stamped Debra Villegas/FBI 7191.
Okay.
The actual email, no.
I -- you know, you have got to remember,
Mr. Lichtman, I have seen literally, over the last
two years of my cooperation with the government,
hundreds of thousands of documents.
10
Okay.
11
But there would be no reason for me to
12
ever have been sent this email by Mr. Brock or any
13
of the people copied because it was, what I'll refer
14
to, as back-office work that was getting signature
15
cards and accounts opened.
16
Did --
17
It does pertain, though, to the DJB
18
account.
19
Do -- and how do you know that?
20
I just correlated it with one of the other
21
documents you gave me and saw that the 2200 account
22
is, in fact, the DJB Financial Holding account.
23
24
25
You are talking about the exhibit that we
only had one copy of?

A
Exhibit No. 66.

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Sixty-six.
Second page.
Right.
Correct.
Okay.
Did Mr. Mejia, to the best of your
knowledge, know that you were engaged in any illegal
activity?
I have no idea.
Okay.
9
10
Did he participate, to the best of
your knowledge, in anything that you asked him to

do?
11
I never asked him to do anything --
12
Okay.
13
-- illegal.
14
I never asked him to do
anything illegal.
15
Did you ever ask him to do anything legal?
16
I may have.
I told -- I think I testified
17
in the last two days about contacting Mr. Mejia and
18
telling him that he might get a call from one of our
19
clients, just because we had been using his business
20
card in Mr. Caputi's charade playing Mr. Mejia, and
21
I wanted to make sure that Ricardo remembered at
22
least talking to me.
23
my contact with him throughout the entire
24
relationship.
25
I think that was the extent of
It's an email

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from Rosanne Caretsky to yourself dated July 8,
2009.
It's Bates stamped Scott Rothstein/FBI 39753.
BY MR. LICHTMAN:
Showing you this email, does this refresh
your recollection as to you being solicited by the
bank to participate in Special Olympics?
10
Yes.
11
And did you participate?
12
We did.
13
Did you consider that an inducement?
14
As far as I was concerned it was, yes.
15
Do you recall what your participation
16
level was?
17
18
I don't.
You'd have to look for the
checks.
19
Is this email at the top, where
20
Ms. Caretsky references that she just adopted a baby
21
girl, is that the first time that you learned about
22
that?
23
I may have learned about it before from
24
Bill Brock, but I don't have an independent
25
recollection one way or the other.

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Who would be the person with the most
knowledge, to the best of your recollection, as to
what kind of gift she was given for the adoption of
the baby?
5
6
7
Her; other than her, Bill Brock or Irene
or Debra.
Q
Showing you what has been marked as
Exhibit 76 for the record, it's a letter dated
July 13th, 2009, signed by Jennifer Kerstetter to
10
11
yourself?
A
Yes.
12
13
14
15
BY MR. LICHTMAN:
16
Do you recognize this document?
17
It's one of the various bank statement
18
documents we utilized.
19
recollection of this specific one, but I do
20
recognize the letter and its attachment.
21
22
This would be the same letter consistent
with Exhibit 67, correct?
23
Yes, sir.
24
Okay.
25
I don't have an independent
It would be your best information,
as of now, that this is an authentic letter on top?

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Judging from the letter, the attachment
and the lack of email traffic showing us forging it,
yeah.
this letter, if she would provide it for us.
There was no reason for us to have to forge
Taking a look at the second page --
Yes, sir.
-- based on the amount that is listed in
the screen shot there of 14,286,000, do you believe
that's an authentic or a forged document?
10
Forged.
11
And why do you say that?
12
I never had the need for a screen shot of
13
a bank statement.
14
illicit purpose to an investor or a verifier or
15
someone involved with the Ponzi scheme, I could very
16
easily find out what my bank balance was by going
17
online.
18
Unless I was providing it for an
And this is a document that, whether it
19
was Ms. Kerstetter or Ms. Caretsky, would have
20
folded in the envelope to hand to you in the
21
presence of an investor, correct?
22
23
Yes.
24
25

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2
3
BY MR. LICHTMAN:
Q
Showing you what's been marked as
Exhibit 77 --
Thank you.
-- it's an email from you to Mr. Spinosa
Bates stamped TD/Razor 1257, previously marked at a
deposition on 6/10/2010 of 74, but the record should
reflect this is Exhibit 77.
10
I do.
11
Tell me your understanding of what this
12
13
email was reflecting.

A
I was sending Frank one of the initial
14
lock letters that we created.
15
that he was going to sign and send back to me before
16
I had him actually doing the letters and sending
17
them to me so it didn't need his cosignature.
18
These are the ones
And I had sent it to him, and it's clear
19
from the email that I had left off the place for him
20
to sign it.
21
asking him to go ahead and execute it, scan it and
22
send it back to me.
23
24
25
So I was sending it back to him and
Okay.
You'll see in the second line, it
says, after you tell him to email it back to you -A
Yes.

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-- we can then do the call.
Versace folks
are calling you at 2:00 p.m -- and let's stop there.
Tell me what that meant.
Yeah, I was in the process of attempting
to secure for TD Bank the Casa Casuarina and Peter
Loftin bank account.
And the next portion of that sentence
says, "Renato will call you in the morning.
fire."
10
11
I am on
What does that mean?

A
Renato was the watch company that I owned
12
one-third of, and I was in the process of working
13
with my partners, Ovadia Levy and Daniel Minkowitz,
14
to move our account to TD Bank.
15
16
17
Okay.
And would you consider moving
accounts to TD Bank an inducement for them?

A
18
That was the purpose of it, yes.

When you say "them," by the way, I am
19
specifically referring to Frank Spinosa, inducement
20
for him.
21
22
23
24
25
Thank you.
Showing you Exhibit -- Composite
Exhibit 78.

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for Identification.).
MR. LICHTMAN:
For the record, it's a
lengthy email trail, all of which are on
August 17th, 2009, and they have a series of
Bates stamps that are out of order, so as I go
by each page, I will reference them.
7
8
9
BY MR. LICHTMAN:
Q
I would ask that you take a quick look at
this exhibit.
10
Okay.
11
Let me know when you're done.
12
Sure.
13
14
Okay.
Q
Before I ask questions on this, let me ask
15
one follow-up:
16
at TD?
17
18
How about Renato?
19
20
Do you recall if the liquor company opened
21
Did Versace actually open an account
an account at --
22
I have no independent recollection.
23
Okay.
That can be verified elsewhere.
24
Let's go back to Exhibit 78.
25
About the fifth or sixth page in, if you

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take a look at Bates stamp, Trustee_Coquina 13; do
you see that?
I do.
Okay.
In that email from you to
Mr. Spinosa, you state the contents of a letter that
he could read on a Blackberry, and then it appears
to be a lock letter.
Do you see that, to Coquina?
I do.
10
Okay.
11
And that carries over to the next
page?
12
Yes, sir.
13
Do you recall accepting that email?
14
I do.
15
Okay.
Now, if you would jump to a few
16
pages in, to Trustee_Coquina 0009.
17
letterhead, dated August 17, 2009?
18
19
That's on RRA
I don't have page -- let's see, maybe it's
out of order.
20
I hope not.
21
Yeah.
22
Mine is in the back here.
Yeah, I got it.
23
24
the letter?
25
Okay.
And 0009, is that your signature on
Yes.

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That language is the same as the language
in the email that we just referenced at Bates stamp
0013, an email of the 17th at 2:37 p.m., correct?
It is, sir, yes.
Okay.
letterhead?
Why did you put this onto your
Because Frank was going to sign it.
This
is one of those letters that you can see from the
letter that I forgot to put his signature line on
10
there.
11
12
Right.
All right.
Okay.
Now jump in a
couple of pages to Bates stamp 22.
13
Yes, sir.
14
That's from 2:59 p.m., an email from you
15
to Spinosa.
16
sign and email back, Thanks, pal."
17
It says, "Hey, Frank please print and
Do you see that?
18
Yes, sir.
19
Is that correcting the issue of having him
20
21
sign the letter?

A
One of them is.
I can't tell from the
22
attachments which one, but I did see one in here, a
23
couple of pages back, Trustee_Coquina 28, he
24
actually drew a line on there and wrote "received"
25
and the date --

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I'm going to get there in one second.

You reference Tony Bova being the contact
at Versace; do you know if Tony Bova contacted
him --
He --
-- to move accounts?
He did speak to him, sure.
Tony was
running the restaurant and the hotel for us out
there.
10
Okay.
Now let's go back to that email you
11
were referencing that's at Bates stamp page 0028,
12
correct?
13
Yes, sir.
14
The signature -- the handwriting in the
15
bottom right corner says, "received 8/17/09"?
16
Yes.
17
Okay.
18
Was that Mr. Spinosa's signature,
or was that you forging his signature?
19
No, no, that was his signature.
20
Okay.
Then the next page is 0024, and
21
that actually has a printed or a typed signature
22
line for Mr. Spinosa that's blank.
23
Do you see that?
24
I do.
25
Is that the document that you forwarded by

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the other email to Mr. Spinosa to ask him to sign?
Yes, the corrected letter.
Okay.
And now I'm going to come back to
the page 31, so if you would hold that and then look
at page 46, which is at the end.
Okay.
There's a signature there that purports to
be Mr. Spinosa's.
that Mr. Spinosa's signature?
10
11
12
13
To the best of my knowledge, is
Yes, to the best of my knowledge, it
absolutely is.
Q
It is not a forgery by you or anyone in
your firm, correct?
14
No, it doesn't appear to be at all.
15
Okay.
Then if we go back to page 31, the
16
email -- this is Coquina 31, the email trail is
17
chronological above the 48 --
18
Yes, sir.
19
-- and it is from you to Spinosa, subject,
20
"for telephone call," correct?
21
Yes, sir.
22
And I think you covered this with
23
24
25
Mr. Scherer yesterday.

These are the questions that you were
having that were going to be asked, correct?

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Yes, sir.
Okay.
And then he referenced after that
he was going to be at lunch and you were going to
set up a call for a specific time, and that's
reflected later on at a 4:30 call, correct?
Yes, sir.
10
11
BY MR. LICHTMAN:
Q
Showing you Exhibit 79, it's a letter
12
dated August 17th, 2009, from Ana Tarazona,
13
T-a-r-a-z-o-n-a.
14
Yes.
15
Do you know who Ana Tarazona is?
16
No clue.
17
Okay.
Do you know how it came to be that
18
Ana Tarazona sent a letter to you on August 17th and
19
attached the screen shot for $22 million appended to
20
this letter?
21
No, sir.
22
Have you seen this before?
23
I may have.
24
25
I don't have an independent
recollection of it, Mr. Lichtman.

Q
Do you have any recollection of this

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document or the events surrounding the document?
That's kind of a vague question because we
were doing these on a regular basis.
don't have an independent recollection of seeing
this letter or the balance statement, but it looks
just like the form that I know TD Bank put on their
computer to use as our cover letter, and it looks
like one of our forged bank statements.
So I -- I
Do you have any reason to believe whether
10
or not this letter was possibly forged, or it's
11
authentic, or do you not know?
12
I have no independent recollection at all
13
of ever forging a signature of an Ana Tarazona or
14
having Debra or any of my other co-conspirators do
15
that.
16
Do you even know who she is?
17
Not a clue.
18
Okay.
19
It's an
email trial from involving you Frank Spinosa.
20
21
22
Identification.)
23
24
25
THE WITNESS:
One second Mr. Lichtman.
BY MR. LICHTMAN:
Q
Yes.

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Just for your reference, because you asked
me about this earlier, if you take a look at
Trustee -- Trustee Coquina 13, you can see --
remember, you were talking to me about titling the
accounts?
Yes.
Okay.
There's an example of -- I don't
know whether it was external title or internal
title, but this is an example of the way we
10
reference the accounts for our own use.
11
Coquina 11 trust account.
12
It says ROA
I don't know that that was ever provided
13
as a formal bank title.
14
there -- that was a reference that we utilized,
15
because I know you asked me about that earlier.
16
All right.
Just so you know that
I got it.
17
Thank you for that clarification.
18
Exhibit 80, are you familiar with Exhibit
19
20
21
22
23
80?
A
Give me one second, Mr. Lichtman.

MR. LICHTMAN:
If I didn't identify it for
the record, I apologize to my colleagues.

The principal email is August 17th, 2009,
24
and it was Bates stamped TD/Razor 1241,
25
previously marked as Exhibit 59, and I believe

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2
3
4
it's Caretsky's 2004 Exam.

BY MR. LICHTMAN:
Q
You'll see in the middle, it talks about
making notes on the account.
Well, first off, do you recall the email?
Yes, I do.
Making notes on the account, do you know
8
9
what that meant?

A
Yeah.
There was a whole thing going on
10
around this point in time where -- I don't remember
11
whether it was Caretsky.
12
the ability -- what the heck this whole lock letter
13
thing was all about, and Frank was running around
14
trying to clarify for people how, internally, it was
15
supposed to work, even though everyone kept asking
16
questions saying it really can't work because he has
17
TD Direct/Treasury Direct, he can just move the
18
money when he wants.
19
Okay.
Someone was questioning
Was Spinosa involved in trying to
20
at least assist in putting notes on the account, so
21
that the --
22
23
He was, when they started asking
questions, sure.
24
How do you know that?
25
You can see it from the email, and I had

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discussions with him about it.
2
3
Was there any issue that -- at that time,
relating to investor concern, as well?
When you say notes --
Yes, adding the notes, did it have
anything to do with investor concern?
I'm certain it did, otherwise it would not
have -- I mean, I don't have an independent
recollection, Mr. Lichtman, of the investor concern,
10
other than the investors demanding that these
11
accounts be truly, irrevocably locked, such as their
12
money could only be sent to their designated
13
account.
14
And we know that could not be done, and
15
you can see from the email and the comments made.
16
Even Frank's comment is kind of a hodgepodge.
17
tells Rosanne that I'm supposed to be notified of
18
any attempted debits from this account without them
19
being initiated by me, which is really completely
20
contrary to the contents of the letter.
21
22
He
And then it says that Caretsky -- no one

can debit the account without Scott's permission.
23
That's contrary to what the letter says,
24
also.
25
to a very specific place.
The letter says the money can only be moved

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And, indeed, did you come to learn that
there was no process, internally, for them being
able to put notes on the account because of the
Treasury Direct program?
5
6
7
MS. EVANS:
A
of time.
Yes.
Object to the form.
I knew that for an extended period
That wasn't a concern.
In your experience --
Actually, it would have been a concern if
10
11
12
they could lock it.

Q
Because that would have prevented you from
using the money as you saw fit?
13
That would have created a problem for us.
14
And Mr. Spinosa knew that?
15
Of course.
16
When you say "of course," tell me why you
17
18
say "of course."

A
19
20
It was never, Frank, can you lock the

account?
21
22
Because he was involved in the process.
It was, Frank, can you sign this letter

saying the account is locked?
23
Those are two drastically different
24
statements.
25
Let me show you Exhibit 81.

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4
5
BY MR. LICHTMAN:
Q
Exhibit 81, for the record, is an email
from Matthew Brennan to Caretsky with a copy to
Spinosa.
8
9
10
11
12
Have you seen this email before?

A
It looks like -- pieces of
it look like the email we were just looking at.

Q
Yes.
The second page is the email we just
looked at.
13
14
Pieces of it.
Do you recall ever having any

conversations with Matthew Brennan --
15
No.
16
-- about these issues?
17
No, sir.
18
How about Ricardo, who I assume is Mejia?
19
No, sir.
20
Okay.
21
22
23
24
25
I don't know.
Do you know anything about this
page of the email?

A
No, sir.
It looks internal to me; meaning internal
to TD Bank, not me.


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3
4
BY MR. LICHTMAN:
Q
Showing you Composite Exhibit 82, it's a
series of letters -- I'm going to identify them
quickly for the record -- that appear to all be lock
letters.
Yes, sir.
The first one is -- to make it easy for
10
the record, they're all purportedly authored by
11
Spinosa?
12
Yes, sir.
13
And the first one is dated August 17th,
14
regarding Coquina, 11.
15
16
That's Razor 1331.
The second one is August 17th, 2009,

regarding Coquina.
17
That's 1329.
Third is August 25th, 2009, regarding Ira
18
Sochet.
19
S-O-C-H-E-T.
20
Yes, sir.
21
TD/Razor 1328.
22
For the record, that's Ira Sochet,
The fourth is dated September 9th, 2009,
23
regarding Emess, capital -- that's E-m-e-s-s.
24
That's a TD/Razor 1332.
25
Next is September 16th, 2009, regarding

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RRA SL2.
2
3
The next is Coquina.
That's
September 18th, TD/Razor 124.
4
5
That's TD/Razor 132.
The next is September 18th, '09; Ira

Sochet, TD/Razor 1336.
Yes, sir.
Next is September 18th, 2009; Ira Sochet,
1335.
This is getting tiring.
10
11
12
13
14
15
16
17
18
19
Next is Coquina, September 18th, 2009;

1334.
The next is September 24, 2009, RRA-BIF,
which we know is Banyan Income Fund, TD/Razor 1065.
The next is October 1, 2009, RRA-EUSBI.
Next is October 1, 2009; RRA-BUSDI,
TD/Razor 1060.
Next is October 15th, 2009; RRA-D3.
20
Next is RRA-BFM -- BFMC, TD/Razor 934.
21
And last is October 15th, 2009, RRA-D3,
22
23
24
25
TD/Razor 116.
From looking at these lock letters, can
you tell whether or not they are authentic?
MR. SCHLESINGER:
Just note my objection.

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2
MR. LICHTMAN:
question.
3
4
MR. SCHLESINGER:
question.
5
6
Well, there wasn't a
You said authentic letters.
I object to that paraphrase, and I object

to the form.
7
8
Let me restate the
If you withdraw the question, then I'll

withdraw the objection.
MS. EVANS:
Mr. Lichtman, I wanted to know
10
if you had an extra copy of the exhibit, by any
11
chance?
12
MR. LICHTMAN:
It was produced to me.
13
don't have an extra copy with me, but this was
14
in my production.
15
Just for the record, the protocol order
16
provided that if I didn't have an exhibit -- if
17
I had an exhibit that was not listed, then I
18
was to bring copies to the deposition.
19
MS. EVANS:
20
MR. LICHTMAN:
21
22
23
24
25
Right.
Everything that we have
today was in my production.

BY MR. LICHTMAN:
Q
Taking a look at the first -- at the first
letter -A
Yes, sir.

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-- do you know who authored that letter?
I authored that letter.
And then you gave it to -- you put it on
RRA letterhead and furnished it to Mr. Spinosa,
correct?
Here's what you need to do, Mr. Lichtman,
because otherwise we're not to be able to tell
between the ones that I forged and the ones that
were actually signed by Mr. Spinosa.
10
If it's a lock letter, okay, and it was
11
forged, there will generally be email traffic
12
showing me actually sending the letter I needed to
13
have forged to Ms. Villegas for her to forge.
14
Correct?
15
I know those are in existence.
16
Right.
17
Absent those emails, it's impossible for
18
me to tell one way or the other whether it's a real
19
one or a fake one.
20
I can tell you that since, from the
21
beginning of the lock letter scenario, with
22
Mr. Spinosa and TD Bank, it was his general course
23
of business to sign these for me, he never refused
24
to sign one for me.
25
There were occasions when I needed them

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1
when he was not going to be around; those were
forged.
There were other occasions where I needed
a balance in the actual letter; those were forged.
The rest are all his actual signature.
7
8
Exactly.
So I want to show you Exhibit 83, which
I'm taking out of chronological sequence.
MR. LICHTMAN:
For the record, Exhibit 83
10
is an email from yourself to you; subject:
11
"this is a test," dated September 24, 2009.
12
13
14
Identification.)
15
16
17
THE WITNESS:
Okay.
BY MR. SCHLESINGER:
Q
The lock letters that would be forgeries
18
would be emails that would look -- if you see where
19
it says "original message" about two inches down or
20
even attachments scanned; do you see the attachment
21
scan there?
22
Yes.
23
The forgeries would be emails that have
24
Ms. Villegas' email address on it somewhere, as well
25
as that scan notation, correct?

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Yes, you're exactly right.
Where it has original emails that were
actually used, in other words, what you got down
here on the September 16, 2009, under original
message.
Yes.
You have a email from Mr. Spinosa that was
previously used to send a real lock letter to me --
well, not real, a fake lock letter that he really
10
signed, okay, that we were then using a subsequent
11
date to forge his signature, either on a lock letter
12
or a balance letter; and that is how you tell --
13
you'll see all of that attached to an email from
14
Ms. Villegas to me or from me to Ms. Villegas.
15
And that's the hard test?
If the
16
Villegas's name is on it with the PDF insignia on
17
the tope left and the language then would follow to
18
appear or purport to be a Spinosa-sent email, that's
19
a forgery?
20
Yes, if it's from Debra to me.
21
Okay.
22
She's forwarding it to me so I can then
23
24
25
forward it on to investors, yes.

Q
And, therefore, any other email that would
have been transmitted, including those by Spinosa,

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would, indeed, be authentic?
MS. EVANS:
Objection.
They should absolutely be authentic, so
long as there's not a -- a matching email involving
Debra, because she was the one who assisted me with
the forgeries.
Right.
Now, as it pertains to Exhibit 82, is your
memory such that you're able to look at any of these
10
and remember from the transaction which ones were
11
authentic?
12
No, because I might have two accounts for
13
the same -- I may have one account for Coquina, then
14
another account for Coquina or a secondary lock
15
letter for them: one where Frank actually wrote his
16
signature, and one where I had to later forge it
17
just to get it off to them because I had no access
18
to Frank.
19
When it came to the forgery, who actually
20
copied Mr. Spinosa's signature and put it on the
21
letter?
22
Ms. Villegas.
She would cut and paste the
23
entire -- what she did was, she would cut and paste
24
the entire block.
25
name.
She didn't actually sign his
She took the entire "sincerely Frank Spinosa"

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piece.
term.
It was a Photoshopped, for lack of a better
I don't know the actual mechanics she
used, but she removed that entire block and then
replaced that entire block on the forged letter.
Do you know where the original of each of
these letters is or where it was kept in the
ordinary course of RRA's business or your business?
9
10
Ms. Villegas's office.
11
12
MR. LICHTMAN:
15
Okay.
I need one quick
moment.
13
14
The original letters were kept in
Sure.
BY MR. LICHTMAN:
Q
Mr. Rothstein, to the best of your
16
knowledge, did the government seize those letters at
17
the time that you were arrested out at the RRA
18
offices?
19
I don't know who was in the -- here's the
20
problem with asking me that.
21
government getting in there, I had partners, like
22
Mr. Rosenfeldt, Mr. Adler and Mr. Boden, who were
23
involved in the Ponzi scheme that had what I later
24
learned to be fairly extensive access to all of
25
these offices, and a lot of things went missing.
Prior to the

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So assuming that they did not take
anything, the answer to the question would be yes,
the government took it, absent someone else taking
it.
But we do know, now, that there was a lot
of deleting and removal of things going on.
can't say one way or the other for certain.
8
9
10
13
In the course of the past two years, have
you actually seen any original lock letters, not

xeroxed, but originals?
11
12
So I
I don't recall ever seeing an original,
Did you ever come to learn who was
no.
14
responsible for deleting information off of the RRA
15
servers?
16
I was told that Curtis Renie had deleted
17
things, along with Bill Corte.
18
Irene Stay had deleted things off.
19
Mr. Rosenfeldt and Mr. Adler and Mr. Boden all
20
deleted items.
21
22
I was told that

I was told that
Obviously you weren't there so this is
just simply what you have learned?
23
I was not there so I don't know.
24
Would it be a fair statement that since
25
the time that you turned yourself in, in early

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November 2009, you have had no contact with
Mr. Boden, Mr. Rosenfeldt, Mr. Adler or Mr. Lippman?
Right.
From the date that I came back
from Morocco, I have had no contact with Mr. Boden,
Mr. Rosenfeldt, Mr. Adler, none of them.
Would it be a fair statement that the only
RRA attorney that you did speak to would have been
Mr. Nurik?
From the time I came back, yes.
10
11
12
Identification.)
13
BY MR. LICHTMAN:
14
Okay.
Showing you Exhibit 84, this is
15
from Debra Villegas to yourself regarding Coquina
16
11.
17
Yes.
18
September 25th.
19
Would this combination of the email and
20
the lock letter that's attached as Trustee 321
21
indicate to you this is forged?
22
I could have told you it was a forgery
23
just by looking at the last page; but, yes, this
24
three-page document is a forgery.
25
What is it on the last page that tells you

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that?
Because Mr. Spinosa had never authored a
balance letter for us.
balances live to our clients.
to paper and lie about the balance in writing.
6
7
He did not put a pen
And, also, it's got the insignia of
the PDF at the top, right, in the latest email?
9
10
Okay.
He only lied about the
Yes.
That's the most effective tell, is that
it's attached to something from Debra to me.
11
12
13
Identification.)
14
BY MR. LICHTMAN:
15
Showing you what's been marked as Exhibit
17
Yes.
18
It's an email chain, September 17th, 2009.
19
Yes, sir.
20
Okay.
16
21
85.
RRA SL 2, with a potential lock letter.
22
23
And this references transaction for
You're asking Mr. Spinosa to put it on his

letterhead and sign and send it to you?
24
Yes, sir.
25
And he says, thanks -- you say -- no, no.

(954) 525- 2221
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He says to you, will be back in the office first
thing tomorrow.
all you do.
4
5
6
7
8
9
10
11
Will get it out to you.
Thanks for
Do you know what he meant by that on

September 17th?
A
Yes.
It's the way -- it's a reference to
how I take care of him.

Q
Do you recall anything particular on
September 17th?
A
Something specific that I did to him -- I
mean for him?
12
Yes.
13
No.
14
Okay.
15
much, Frank.
16
And then you write back, Thanks so
U R DA MAN.
And at the top he says to you, "I think it
17
was about three years ago I meet you and committed
18
the best service you will ever have and that I would
19
become your banker.
20
proud to know you and be there for you."
21
Did you discuss that with him?
22
23
We are well on our way.
I am
of discussing it with him.
24
Okay.
25
But it certainly wasn't out of the

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Page 576
1
ordinary for him to write that to me.
3
4
Go back to Exhibit 82, if you would.

If you go about five pages from the
back --
Yes, sir.
-- you'll see that there is a lock letter
dated September 18th, 2009.
What's the Bates stamp number?
10
11
Hold on.
1335.
Take a look at 1335 and 1334 and
1336.
12
Here's 1334.
13
Okay.
Here's 1335, 1336.
Got it.
Now, from looking at those lock
14
letters that were all issued the day after
15
September 17th, is there anything that you can tell
16
from the email and his lock letters as to their
17
authenticity?
18
Yeah.
It looks that -- certainly the one
19
dated -- well, let's see.
20
There's a letter -- there are three letters dated
21
the 17th, and there's a matching -- me telling him
22
what to put on.
23
24
25
This is the 17th.
So, certainly that says SL 2 on it, which

is the September 18th, 2009.
Q
1336 --
Yes.

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-- is his actual signature.
Right.
So that would lead me to believe that
since he was doing one, that he would do all three
for me on the different accounts.
Actually, you probably have an email
floating around that says, can you also do it for
these other two accounts.
Right.
10
Same thing:
Okay.
Just change the "re" and
11
change the "shall only" -- I remember having emails
12
where I told Mr. Spinosa -- same letter, just change
13
the "re" and change the "shall only be distributed
14
to" portion of the letter.
15
So absent emails from Debra, which I don't
16
believe there are any for that particular series of
17
letters, those are original lock letters executed
18
for me by Mr. Spinosa.
19
I think the next exhibit is 86, correct?
20
Do I have that, or are you going giving it
21
to me?
22
No, I think the next number is --
23
I have 85 here.
24
25


(954) 525- 2221
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Page 578
1
2
3
4
Identification.)
BY MR. LICHTMAN:
Q
Showing you Exhibit 86, this is an email
of September 18th, 2009.
Yes.
There's some language -- it's Bates
stamped Spinosa 333.
Yes.
Okay.
This is an email that suggests --
10
the comments from Mr. Spinosa is that he's
11
uncomfortable with having you parade people in and
12
out of the bank --
13
Yes.
14
-- correct?
This is a forgery.
15
That's what I wanted you to confirm.
16
The letter, the language by Spinosa there,
17
18
19
20
21
22
23
is a forgery, right?
A
The letter on the second page, 347, is a
forgery.
Q
That would be the lock letters, also a
forgery?
A
No, that's not a lock letter; this is a
balance letter.
24
A balance letter?
25
That's a forgery.

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Page 579
1
2
3
And that's a forgery because you know that
by looking at it because of the dollar amount?

A
Right.
Again, I only asked him to lie
directly to the clients.
pen to paper, lying about the balances.
I never asked him to put
The first page --
And why didn't you?
Because I didn't want that floating around
in the email system.
10
I tried to be, as best as I could, careful
11
when I was dealing with the banks in what I put in
12
emails.
13
deniability when I send over a lock letter; but
14
having him alter a balance statement on a -- run it
15
through his email system was -- would not have been
16
on the list of the brightest things that I've ever
17
done -- not that any of this actually qualifies as
18
bright.
19
20
21
22
23
I could always have what's called plausible
THE WITNESS:
Are we done with this
exhibit?
MR. LICHTMAN:
Yeah.
I'm getting another
one together for you.

24
25
Identification.)

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BY MR. LICHTMAN:
2
3
Now, here we were September 24th -- let me
show you Exhibit 87.
Yes, sir.
This is an email trail that does not have
Ms.
Villegas on it.
7
8
9
This is Mr. Spinosa and Wende Litterio,

and then references a Coquina lock letter.
A
Okay.
Just so we're clear, in the back,
10
starting with page 267, there is a Debra Villegas --
11
there is two pages with fraud on it.
12
13
Right.
So let me ask you, because I want to tie
14
this together, the first, September 24th of 2009, it
15
says, "Another letter.
16
back in August.
17
We already did the original
First one."
So do you believe that we can tie an
18
authentic lock letter of September 24th to this
19
letter?
20
MS. EVANS:
Objection, form.
21
Yes.
22
Yes.
23
-- and here's the reason, and it really --
This whole -- this thing here --
24
if you just focus on who the things are going back
25
and forth to, you can tell, I think, to 100 percent

(954) 525- 2221
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Page 581
1
certainty, whether it's a forgery or not.
Frank -- it starts with Frank actually sending this
to Ms. Litterio.
Here's
This has nothing to do with me, so he's
actually asking Ms. Litterio to go ahead and do
another letter.
So all of that that follows, it only
follows suit, that that letter that corresponds to
that is a real, nonforged letter.
10
And in Exhibit 82, which is Bates stamped
11
1065 of September 24th, 2009, that's a RRA-EIF
12
letter.
13
the authentic letter that ties --
You have reason to believe that would be
14
Sorry.
15
1065 of Exhibit 82, that's the one that
16
17
18
What am I looking at now?
has all the lock letters attached.

A
Hold on a second.
Yes.
That appears to be the authentic
19
letter that goes with Mr. Spinosa's email to
20
Ms. Litterio.
21
And I have another reason, just so you
22
understand, as to why this is not a forged letter,
23
and that is that the email traffic that precedes is
24
all about me getting ready to come up and see
25
Mr. Spinosa with Ms. Damson and Ms. Kathleen White.

(954) 525- 2221
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That's all going on at the same time.
I'm
trying to get letters together for some people, and
I'm also talking to them about the fact that Barry
wants to see them.
5
6
And then, indeed, at the last two pages of
that exhibit --
I'm sorry.
The last two pages, that would the Debra
The last two?
Villegas final test email of September 24th --
10
Yes.
11
-- and then the September 25th Coquina
12
lock letter.
13
14
15
16
Yes.
That's not a lock letter; balance letter.
Balance letter, excuse me.
letter is a forgery?
17
Correct.
18
The rest is authentic?
19
Yes.
20
this is it.
21
22
23
The balance
To the best of my knowledge, yeah,
This talks about -- yeah, all the rest of

this is authentic.
24
25

(954) 525- 2221
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Page 583
1
2
BY MR. LICHTMAN:
Q
Okay.
Now we are at September 30th, and
this is the letter from you to Spinosa -- email.
And then, at the bottom, there's an email from
Spinosa to you.
6
7
Are you familiar with this email?

A
8
9
Sure.
MR. LICHTMAN:
This is, for the record,
is -- if I didn't say, September 30, 2009, and
10
it's Bates stamped TD/Razor 046.
11
introduced at, I believe, Mr. Spinosa's Rule
12
2004 Exam as Exhibit 83A.
13
14
This was also
BY MR. LICHTMAN:
Q
At the bottom, Spinosa references to you
15
that, "I also need to go over your timetable on
16
deposits and these letters."
17
"If we are going to do a lot, I would
18
probably need to get a standard letter approved and
19
that will take time."
20
That was in response to your email from
21
earlier where you said, are you around to do another
22
lock letter for me?
23
Yes.
24
Okay.
25
Do you recall the circumstance of
him sending you that email?

(954) 525- 2221
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Page 584
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I do.
This is an authentic email, right?
It is.
Okay.
you recall?
What were the circumstances that
I needed to do another lock letter, from
conversations I had with him, following my initial
request to him; and around that time, he was telling
me that if we were going to do a lot more of these,
10
that we would have to go get the bank involved, so
11
to speak.
12
need to be careful as to how many of these that we
13
were doing.
It was a way of letting me know that we
14
And I sent him an email back, as you can
15
see, saying, we're almost done for the time being.
16
Let's just do this.
17
approval process.
18
I don't want to deal with any
So did you take Mr. Spinosa's comments to
19
you as a red flag that he was starting to get
20
concerned?
21
MR. SCHLESINGER:
Object to form.
22
Yes.
23
Did you discuss that with him
24
25
specifically?
A
I did.

(954) 525- 2221
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Page 585
1
What did you say to him?
I told him not to worry about it.
I said
that we would take it easy on the letters, and if he
heard anything, to let me know.
And what did he say to you?
Not a problem, same thing he would always
say to me.
8
9
And up to September 30th, 2009, he was
still doing authentic lock letters for you, correct?
10
Sure, absolutely.
11
And post-September 30th, he continued to
12
do authentic lock letters for you, didn't he,
13
correct?
14
I don't -- I don't know the dates but,
15
yes.
16
contain the Debra Villegas -- what's called a badge
17
of fraud -- yeah, they would be authentic lock
18
letters.
If there are any more lock letters that don't
19
They certainly didn't stop because of
20
this.
21
but perhaps not.
22
23
We just continued perhaps at a lesser pace,
The top of the email says, "I
prefer not to use the standard approved letter."
24
25
Okay.
You see that?

A
Yes.

(954) 525- 2221
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1
Okay.
That was my way of telling him, do not get
3
4
What did you mean by that?
anyone else involved in what's going on.

Q
Even though you did have a standard
approved letter that you guys had been using for
quite some time?
7
8
11
12
15
16
other levels of the bank.

Q
Meaning that he was fine with what you
were doing and you read the message loud and clear?
MR. SCHLESINGER:
Object to form.
BY MR. LICHTMAN:
Q
Would that be a fair statement as to what
you were thinking?
17
18
It was
In other words, I didn't want to go to any
13
14
We had no approved letter.
approved only by him.
9
10
Yes.
MR. SCHERER:
Objection to form.
BY MR. LICHTMAN:
19
Well, tell me what you were thinking.
20
The conversations that I had with him when
21
this was going on, was this is obviously a concern
22
to me, when he writes to me and says, if we're going
23
to do a lot of these, and I would have a
24
conversation with him.
25
I had a conversation with him, actually

(954) 525- 2221
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1
several, now that I'm thinking about it, regarding
these lock letters, and told him not to worry about
it.
involved.
letter approved, okay, so that we could use that.
didn't want to do anything else.
what's working.
I didn't want to get anyone else in the bank

I didn't want to try to get another
Let's stick with
He said fine, and that was it.
And my recollection is it was never
10
11
brought up again.
Q
All right.
On the top of this
12
September 30 email, you say, "I will get you a
13
deposit timetable."
14
Yes.
15
Did you?
16
I may have.
17
Do you recall him raising the issue of
18
19
20
21
I don't have a clue.
deposits after that, though?

A
He may have.
You'd have to show me an
email, Mr. Lichtman.

I mean, Frank bothered me so little about
22
anything that I just don't have -- nothing is
23
sticking out.
24
relationship.
25
It was the opposite of the Gibraltar
Everything that I was to doing criminally

(954) 525- 2221
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Page 588
1
with TD was nice and smooth; everything with
Gibraltar was crazy.
Identification.)
6
7
BY MR. LICHTMAN:
Q
Let me show you Exhibit 89 dated
October 7th, 2009.
Spinosa to Paolo Casabone; Rosanne Caretsky, Joseph
This is an email from Frank
10
Ercolino, William Jones, and some other -- another
11
person.
12
13
Again, October 7th, it's Bates stamped

TD/Razor 364.
14
15
At the bottom it also shows an email

forwarded by Spinosa.
16
17

A
18
of the emails.
19
going on.
20
Okay.
I have a recollection of what was
The top email for October 7th,
21
says, "Paolo and Rosanne, Bill tells me you guys are
22
doing everything you can but what you are being told
23
isn't happening.
24
levels.
25
deposits.
We need to escalate to the highest
As you know, they carry very large

Please fill me in on the details of what

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I can to do support your efforts.
and then "Spinosa."
Thanks, Frank"
Right.
Tell me what you understood was going on.
In reviewing both pages, 364 and 112 --
Yes.
-- what was occurring was, we needed to
have -- for reasons related to the Ponzi scheme, we
needed to have several of their online systems
10
available to us.
11
The -- I don't remember what each one did,
12
but there were various cash managers and Treasury
13
Direct, there was business direct, there was -- they
14
had some different things with different cash
15
management levels and different functionalities.
16
And for Ponzi-scheme purposes, I needed to have
17
availability for all of them.
18
19
As of October 7th, 2009, this was three
weeks before the Ponzi collapsed, correct?
20
October 7th, yes.
21
Did you take it at that time that you were
22
still being supported by Mr. Spinosa in connection
23
with your relationship and how you were handling
24
your banking at TD Bank?
25
Absolutely.

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2
And this letter would evidence that; do
you agree?
Based upon what I'm reading, sure.

Mr. Spinosa is telling them, you have got
to do whatever you can to support these people and
I'll do whatever I can to support your efforts to
make sure this happens for RRA.
MR. LICHTMAN:
So yes.
Exhibit 90.
10
11
Identification.)
12
BY MR. LICHTMAN:
13
14
15
Now, we're about two weeks out from the

collapse of the Ponzi.
16
17
This is a letter of October 13th.
This email from Spinosa to yourself of

October 13th is Bates Stamped Trustee Spinosa 837.
18
You see that?
19
I do.
20
Okay.
It reference, "Couldn't find" --
21
Spinosa writes to you, "Couldn't find you when I
22
left.
23
you can do lunch, love you."
24
25
You have a beautiful home.
Let me know when
"Love you" was a colloquialism you used

with a lot of people that you were close to, right?

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Correct.
And was it common for him to return that
show of affection in his emails to you?
Yes.
Okay.
When he references you have a
beautiful home, do you recall why he was at your
home?
I'm certain.
10
11
Do you know how many times he was at your
I don't recall any specific number, no.
More than once, different homes but more than once.
14
15
It was -- it was one of the events,
home?
12
13
No.
Where were you living at the time of
October 2009?
16
30 Isla Bahia.
17
Okay.
18
now.
19
20
Let go back to the complaint that we

started on yesterday.
21
22
MR. LICHTMAN:
25
For the record, it's
Exhibit 64.
23
24
We're done with the documents for a
THE WITNESS:
Yes, sir.
BY MR. LICHTMAN:
Q
I think that we have covered a lot of

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this, so I'm going to be careful to try to not go
over areas that we have covered, but if you would
bear with me.
Paragraph 22 says:
"In the course of
Rothstein's Ponzi scheme, he regularly transferred,
commingled, and used money from one bank account
into another, in order to cover up his thefts."
Do you admit that allegation as being
true?
10
I do.
11
The next sentence says, "in the process,
12
he stole" -- and that refers to you -- "stole
13
investor, lender and law firm client funds,
14
frequently out of accounts that were titled as
15
true."
16
17
18
19
You admit that statement is true?

A
accounts."
It says "frequently were titled as trust
You said "true."

If I misspoke, I -- well, as you read that
20
sentence in paragraph 22, do you agree that's a
21
correct statement?
22
Yes.
23
Okay.
24
25
It also says that you stole RRA's
fee income from its operating account.

Do you agree that's true?

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Yes.
The next statement says that you stole
funds from other bank accounts, which you controlled
related to Rothstein entities, which is a defined
term as being the companies that you had wired the
Ponzi money to.
Do you agree that's true?
Yes.
The next sentence says:
"These transfers
10
were accomplished by Rothstein with the substantial
11
assistance and cooperation of others, including
12
employees at TD Bank, who approved and affected all
13
transfers whenever requested to do so, regardless of
14
the circumstances or the existence of the 'red
15
flags' described below."
16
17
Forget about the last qualifying sentence

there, part of the sentence "regardless."
18
Yes, sir.
19
Up to "to do," do you agree with that
20
statement?
21
I do.
22
And the employees that we're alluding to
23
there would be Spinosa, Caretsky and Kerstetter,
24
correct?
25
That's correct.

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Can you think of a single objection to a
transfer or a transaction that was evoked by any of
those three persons?
No, sir.
Was there ever a time that they refused to
sign a lock letter?
No, sir.
Was there every a time that they refused
9
10
to push through an overdraft without it prejudicing

your business?
11
No, sir.
12
Paragraph 23 says:
"This bank account
13
manipulation enabled Rothstein to cover the
14
continuously --" excuse me.
15
Let me start over.
"This bank account manipulation enabled
16
Rothstein to cover the continuously increasing
17
personal and RRA expenses by creating the appearance
18
that sufficient funds were on hand to pay expenses,
19
including settlement monies due Ponzi scheme
20
investors and lenders."
21
Do you agree that that statements is true?
22
I do.
23
Did TD Bank ever say to you, through any
24
of its employees, that your law firm's trust account
25
maintained at TD Bank were being used in a manner

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2
inconsistent with law firm trust account activity?

A
No, sir.
MS. EVANS:
MR. LICHTMAN:
8
9
10
What's wrong with that
form?
6
7
Objection to form.
MS. EVANS:
You're asking him to
speculate.
BY MR. LICHTMAN:
Q
My question did say:
Did they ever state
to you?
11
They never did, sir, no.
12
Did TD Bank ever state to you that TD
13
Bank -- excuse me.
14
Did TD Bank employees ever state to you
15
that RRA trust accounts appeared to be outside the
16
normal practices and operations of a law firm?
17
No, sir.
18
Take a look at paragraph 31, please.
I'm
19
going to break it down so you don't need to read it
20
right now.
21
But paragraph 31 articulates certain red
22
flags that the trustee contends existed respecting
23
your behavior in RRA's operations, that Spinosa and
24
TD Bank were aware of and put them on notice about
25
know your customer obligations.

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2
That's basically what we start out with

there.
3
4
So I'm going to ask you if the following

facts are true or false.
Is it correct that you never provided any
detailed financial data about RRA's business
operations to TD Bank?
That's correct.
Would you agree that you flaunted the
10
multi millions of dollars that you spent on jewelry,
11
watches, multiple homes, business interests, an
12
exotic car collection and a large yacht?
13
Yes, sir.
14
Do you agree that you used RRA funds to
15
purchase high-end automobiles, including Maserati
16
Ferrari, Mercedes, Corvette, for RRA attorneys and
17
staff?
18
Yes.
19
Do you agree that for the time period that
20
you had what was called the "inner sanctum," that
21
was locked down to anyone from the outside, unless
22
special access was granted?
23
24
25
Yes.
For that limited period of time,
yes, that's correct.

Q
You acknowledge that you were protected by

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bodyguards and an elaborate electronic surveillance
systems in both your office and home?
That is correct.
You acknowledge that RRA attached its name
to three sports arenas, two performing arts centers
and spent huge amounts of money sponsoring
charitable events?
That's correct.
You acknowledge using -- purchasing the
10
Rothstein entities, sometimes through accounts at TD
11
Bank, including Bova restaurant; Casa Casaurina,
12
formerly known as the Versace mansion, Renato watch
13
company, Georgio Vodka Company and others?
14
I don't know which were purchased through
15
which bank; but yes, I used TD Bank accounts to
16
purchase certain of my entities.
17
And the purchase of those entities came
18
from funds that were illegally obtained as a result
19
of your criminal activities, correct?
20
Correct.
21
You acknowledge that virtually all of your
22
air fare was by personal jet?
23
Yes.
24
Subparagraph I, do you acknowledge that
25
you went from virtually having no political

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involvement to becoming a major Republican
fundraiser and donor quickly with close connections
to prominent local, state and national politicians?
Yes.
Excepting Gary Farmer's case that he
brought with you, can you recall RRA handling or
winning any multi-million-dollar substantial cases
in the employment law area?
No, sir.
10
Do you know of any facts that would have
11
suggested RRA was able to generate fee income to
12
create the sizeable balances and activity now
13
reflected in the RRA accounts at TD Bank?
14
No, sir.
15
Did TD Bank ever require you or RRA to
16
reveal and explain the sources of the funds in those
17
accounts?
18
No, sir.
19
Did TD Bank ever ask you as to why
20
transfers from Gibraltar Bank into TD Bank bank
21
accounts occurred.
22
No, sir.
23
Did TD Bank ever ask you why transfers
24
25
from TD Bank to Gibraltar Bank occurred?

A
No, sir.

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2
Did they ever ask you why there were so
many transfers?
No, sir.
I'm going to read to you a sentence out of
Paragraph 33 of the complaint.
tell me if you factually agree with it.
I would like to you
Okay.
"Spinosa and other TD Bank officers and
employees ignored these facts" -- that pertains to
10
the account information I just said to you -- "and
11
substantially assisted Rothstein and RRA in
12
repeatedly making significant transfers between and
13
RRA trust accounts and Rothstein personal accounts."
14
Do you agree with that?
15
16
17
I do.
MS. EVANS:
Okay.
Objection.
Do you agree that they ignored
18
those transfers without regard to the source of the
19
funds or their purpose?
20
I do.
21
And do you agree that those activities
22
enabled you to misappropriate RRA funds and to
23
continue the life of the Ponzi scheme?
24
25
I do.
MS. EVANS:
Objection.

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Had they raised with you the issue as to
the source of the funds, what do you believe -- at
any point in time, what did you believe would have
happened?
5
6
7
MS. EVANS:
A
If they had just raised it, if they had
raised it, I believe Spinosa would have quashed it.
8
9
Objection.
If they had gone in depth and shut us

down, if they shut down our banking relationship or
10
stymied it, it would have shut down the Ponzi
11
scheme.
12
Let me rephrase the question.
13
If they asked for supporting -- if people
14
other than Spinosa, senior officials at the bank or
15
those that were in charge of compliance asked you
16
for documents to support the basis of the transfers
17
that you were making at the entity -- making being
18
in and out of the accounts, what do you believe
19
would have happened?
20
MS. EVANS:
21
Objection.
Eventually it would have cut off our
22
relationship and the Ponzi scheme would have
23
exploded earlier than it did.
24
25
As it pertains to what actually happened,
that never -- that -- strike that.

(954) 525- 2221
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2
Take a look at Paragraph 41 -- actually,

paragraph 40.
Okay.
Paragraph 40, if you would read that to
yourself, please.
No, we will put in the record, excuse me.
"TD Bank established restricted bank
accounts for investors as a convenience for the
investor and RRA."
10
11
12
To the best of your knowledge, is that

true?
A
No, that's not true because the bank
13
accounts were never restricted.
14
accounts that looked like they were restricted but
15
were not.
16
Okay.
They established
So the intent was to create a
17
circumstance where the accounts looked as if they
18
were restricted but indeed they were not.
19
MS. EVANS:
Objection.
20
That's correct.
21
Okay.
Paragraph 41, the second sentence,
22
it says, "TD Bank received and sent wire transfers
23
of large sums of money to and from investors' bank
24
accounts throughout the United States, often on a
25
priority basis."

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2
To the best of your knowledge, is that

true?
Yes, it is.
The third sentence says, "TD Bank allowed
RRA to send wires" sometimes -- it doesn't say
"sometimes."
Let me start over.
"TD Bank allowed RRA to send wires by
merely sending an email requesting a wire transfer
be affected, in violation of its own banking
10
policies."
11
Do you have any knowledge about that?
12
MS. EVANS:
13
Objection.
I do, but the bulk of time that was
14
correct.
15
them to do it, just by sending them an email; but
16
more frequently, we did the emails ourselves.
We just initiated wires, when we needed
17
You mean the transfers yourselves?
18
At TD Bank, no, we actually initiated
19
wires through --
20
That's what I am saying.
21
Yes, yes, mhm-mhm.
22
Yes, and that was through the direct
23
Treasury Direct program?
24
Correct.
25
Okay.
The last sentence of Paragraph 41,

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"TD Bank also regularly transferred money among
several TD Bank accounts at Rothstein's direction,
to increases balances in accounts, depending on the
account and Rothstein's needs for that day."
Do you agree with that?
I do.
So the first sentence of paragraph 41,
says, "In addition, TD Bank performed certain of the
day-to-day functions that were required to execute
10
and conceal the fictitious settlement scheme."
11
Do you agree with that statement
12
predicated on the other three causes of paragraph 41
13
that you just admitted was true?
14
MS. EVANS:
Object to form.
15
I do.
Yes, I do.
16
Okay.
Paragraph 42, references that
17
"Spinosa and other TD Bank officials met or spoke on
18
the telephone with investors, assuring them of the
19
security of their funds and of the procedures used
20
by TD Bank relating to protect their money."
21
You see that?
22
I do.
23
Do you know if there is anybody else at TD
24
Bank, besides Spinosa, that had such telephone
25
calls?

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2
MS. EVANS:
A
Object.
I don't now of any.
I know Spinosa did,
but I don't know who else may have.
involvement with anyone else for that purpose.
5
6
Did you have any involvement with Banyon,
meeting with TD Bank, to set up accounts?
I don't recall any, no.
Okay.
9
10
I had no
Do you agree that the relationship
with TD Bank was not a typical bank/customer

arms-lengths or debtor/creditor relationship?
11
Yes.
12
You relied on TD Bank significantly in
13
connection with the commission of your illicit
14
activity, correct?
15
Yes, sir.
16
And even though the activities that you
17
described over the course of the past few days
18
appear to be illegal, would you agree that there was
19
a relationship of deep trust that evolved between
20
you and Mr. Spinosa?
21
MS. EVANS:
Objection.
22
Yes, there absolutely was.
23
Okay.
24
Yes, there absolutely was.
25
Okay.
And you depended in Mr. Spinosa?
And you depended on Mr. Spinosa?

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2
Yes, we were literally trusting each other
with our lives.
Mr. Spinosa?
I did.
You understood him to be a senior vice
And you placed great confidence in
president or regional vice president of --
That's correct.
-- TD Bank?
10
That's correct.
11
In fact, he asked for that responsibility,
12
didn't he?
13
14
15
MR. SCHLESINGER:
A
Object to form.
I don't know what you mean:
in a responsibility.
He asked for
You mean he asked me for it?
16
Yes, he asked for your trust?
17
Yes, he did, and he earned it.
18
We understand that Mr. Spinosa is going to
19
deny that he received anything in the form of money
20
or other inducements from you.
21
response to that?
22
23
24
25
Do you have any
I -- I have no idea what you mean, do I
have a response to that.

Q
Yeah.
What do you think about his
statement that he never got anything from you?

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That -- that would classify him in the
gang that couldn't shoot straight because that would
mean he did a whole lot of illegal activity for me
without any remuneration at all.
those.
Let me see if I can go through some of
Mr. Spinosa knew that there were large
amounts of money -- excuse me, large dollar
transfers between various accounts, correct?
10
MR. SCHLESINGER:
11
answered about three times.
12
Objection, asked and
BY MR. LICHTMAN:
13
You can answer.
14
Yes.
15
Mr. Spinosa knew about the velocity of all
16
17
of these transfers?
A
18
19
20
Yes.
MR. SCHLESINGER:
Same objection.
Mr. Spinosa knew the quantity of dollars
being transferred?
21
Yes, he did.
22
Mr. Spinosa knew that you were requesting
23
lock letters from him?
24
Yes, sir.
25
Mr. Spinosa know -- Mr. Spinosa knew that

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there was no internal procedure such as a lock
letter?
4
5
6
That's correct.
ALL PRESENT:
Object to form.
Mr. Spinosa knew that he couldn't lock an
account, correct?
MR. SCHLESINGER:
Object to form.
That's correct.
Mr. Spinosa new that third parties,
10
investors, were relying on the lock letters,
11
correct?
12
13
14
15
16
That's correct.
MR. SCHLESINGER:
Object to form.
Mr. Spinosa never complained to you about
any of this activity, correct?

A
The only time he ever said anything to me
17
was in that one email.
18
saying, if we're going to do a lot more lock
19
letters, we're going to need some kind of form,
20
other than that, he never said a word to me about
21
anything I was doing at the bank, except to stay, I
22
have got your back, do your business.
23
Other than that one email
And to the best of your knowledge, no
24
compliance officer or other representative of the TD
25
Bank complained to you about what you were doing?

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No, sir, they did not.
To the best of your knowledge, you weren't
advised there were SARs reports being issued against
your accounts; is that correct?
I was never told that, correct.
Mr. Spinosa knew that RRA had multiple
trust accounts, correct?
Yes.
And he never asked the purpose of those
10
account?
11
That's correct.
12
He knew the balances could range from $100
13
to multiple millions of dollars on a given day?
14
ALL PRESENT:
Object to form.
15
Yes, sir.
16
Mr. Spinosa knew that Bill Brock was
17
coming in with screen shots to have TD Bank
18
employees come into the bank and have those screen
19
shots with a letter puts into an envelope, correct?
20
He knew what we were doing with regard to
21
coming in with the screen shots, yes.
22
MR. SCHLESINGER:
23
Note my objection.
Mr. Spinosa knew that Rosanne Caretsky
24
was -- or sometimes Kerstetter were stuffing those
25
screen shots into an envelope which effectively

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verified dollars in an account, even though the
dollars on the screen shot were not real; is that
correct?
ALL PRESENT:
Object to form.
That is correct.
Mr. Spinosa knew that investors were being
handled -- handed those envelopes, correct?
ALL PRESENT:
Object to form.
Yes.
10
He knew there were overdrafts?
11
Yes, sir.
12
He knew that RRA was not a borrower of TD
13
Bank?
14
Yes, sir.
15
He knew all those red flags that we
16
identified from the complaint --
17
ALL PRESENT:
Object to form.
18
-- correct?
19
He knew about all of them, yes, he did,
20
21
and we discussed them.

Q
So if Mr. Spinosa and Ms. Caretsky were
22
not players and they didn't take any money from you,
23
or other inducements, can you explain, from your
24
understanding of what was going on in the
25
transaction, the Ponzi, why they would let you do

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all that stuff and not complain?
2
3
MS. EVANS:
A
Objection to form.
From my perspective there is no rational
reason to do it if they are not getting something
out of it.
It makes no sense to me.

Everyone knows -- skip -- just skip over
the fact that they are going to deny receipt of
money, there are probably 50 people, if not more,
that have seen Frank Spinosa at things that he could
10
not have otherwise afforded to do, that were --
11
became part of his lifestyle, courtesy of me and my
12
law firm.
13
And you were at the center of the Ponzi?
14
Yes, sir.
15
And if I get it correct, based on your
16
statement to Mr. Scherer yesterday, the Ponzi could
17
not have occurred but for Mr. Spinosa, correct?
18
19
MR. SCHLESINGER:
A
Object to form.
It would not have survived at the level
20
that it did without Mr. Spinosa's assistance, that's
21
correct.
22
MR. LICHTMAN:
We're just going to take a
23
couple quick moments here and let me talk with
24
my colleagues.
25
(Whereupon, a recess was had.)

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2
BY MR. LICHTMAN:
Q
I just have a couple of quick questions.

With regard to the testimony you provided
concerning Gibraltar Bank, I believe it was
yesterday, you said that the overdrafts served as
a -- I think the quote was a running line of credit
without a credit line.
Correct.
Okay.
10
Do you agree the same holds true
with respect to TD Bank?
11
I do.
12
Would you agree that the movement of money
13
between and among the accounts was -- at TD Bank was
14
in furtherance of the Ponzi scheme?
15
Yes, it was.
16
Would you agree that the covering of
17
overdrafts by TD Bank occurred and was used in
18
furtherance of the Ponzi scheme?
19
Yes, sir.
20
Would you agree that the immediate
21
clearing of funds by TD Bank was used in the further
22
of the Ponzi scheme?
23
24
25
Yes, sir, it was.

MS. EVANS:
Objection.
(Mr. Nurik enters the deposition

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1
in progress.)
MR. LICHTMAN:
I'm so pleased that
Mr. Nurik is walking if for me to have exactly
one last question.
5
6
7
MR. NURIK:
Good times.
BY MR. LICHTMAN:
Q
Banyon accounts maintained at TD Bank, did
you ever have any conversations with Mr. Spinosa
about overdrafts or TD Bank activity?
10
11
12
I'm sorry, Mr. Lichtman, you have to
clarify that for me.

Q
The Banyon accounts that were maintained
13
at TD Bank, did you ever have any conversations with
14
Mr. Spinosa about the activity within those accounts
15
or overdrafts?
16
17
Whenever you say "Banyon," you mean
Levin's accounts?
18
Yes.
19
No.
20
21
22
23
MR. LICHTMAN:
Why don't we break for
lunch.
(Thereupon, a recess was taken.)
-
24
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C E R T I F I C A T E
2
3
THE STATE OF FLORIDA, )

COUNTY OF BROWARD.
)
4
5
I, Michele L. Savoy, Shorthand Reporter do
hereby certify that I was authorized to and did
report the foregoing proceedings and that the
transcript is a true record.
Dated this 14th day of December, 2011.
10
11
12
13
______________________________
14
15
16
Michele L. Savoy, RPR

Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
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18
19
20
21
22
23
24
25

(954) 525- 2221
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2
C E R T I F I C A T E
THE STATE OF FLORIDA, )
COUNTY OF BROWARD.
)
3
4
I, Michele L. Savoy, Shorthand Reporter, do
hereby certify that I was authorized to and did
report said deposition in stenotype; and that the
foregoing pages, numbered from 171 to 280,
inclusive, are a true and correct transcription of
my shorthand notes of said deposition.
10
I further certify that I am not an attorney or
11
counsel of any of the parties, nor am I a relative
12
or employee of any attorney or counsel or party
13
connected with the action, nor am I financially
14
interested in the action.
15
The foregoing certification of this transcript
16
does not apply to any reproduction of the same by
17
any means unless under the direct control and/or
18
direction of the certifying reporter.
19
Dated this 14th day of December, 2011.
20
21
22
23
___________________________________
Michele L. Savoy, RPR
Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
24
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balancenumber...
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balances 484:13,20
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B
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banker 447:9 474:5
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chronological
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538:20,25
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434:1,1
circulated 497:1
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Z
zuckerberg 509:22
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0
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581:15
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573:16
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11cv61688jic
434:12
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1
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(954) 525- 2221
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Page 641
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4
4 557:5
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5
5 490:10,11
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7
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8
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8th 531:5
9
9 523:24
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590:8,10
93 530:18
934 565:20

(954) 525- 2221
95 487:8
954 433:24
99 433:18 445:6
526:18
9th 564:22

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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR

DAY 3 - MORNING SESSION

December 14, 2011

Examination of the witness taken before:

United Reporting, Inc.

IN THE CIRCUIT COURT OF THE 17TH

Case No. 10-24110 CACE (19)

SCOTT W. ROTHSTEIN, et al.,

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

SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTAR

United Reporting, Inc.

APPEARANCE FOR SCOTT ROTHSTEIN:

United Reporting, Inc.

APPEARANCE FOR PLATINUM PARTNERS VALUE ARBITRAGE

GOLDSTEIN, TANEN & TRENCH, P.A.

APPEARANCE FOR LEVINSON'S JEWELERS:

APPEARANCE FOR RLI ZURICH INSURANCE COMPANY,

United Reporting, Inc.

APPEARANCES FOR MORSE:

APPEARANCE FOR ROSEANNE CARETSKY:

United Reporting, Inc.

CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

TRUSTEE'S EXHIBITS INDEX

United Reporting, Inc.

Thereupon, the following proceedings were had:

CONTINUED DIRECT EXAMINATION

You realize you're still under oath,

Good morning, Mr. Rothstein.

How are you

And to pick up from the point of

yesterday, Mr. Nurik is not with you and you consent

to proceeding in his absence until he gets here

I consent to proceeding in his absence so

long as -- since I've already met with you,

Mr. Lichtman, I'm comfortable speaking to you

without him being here, but I'm not comfortable with

being questioned by anybody else until he arrives.

But you're okay with me questioning you?

I can't help myself on this first

question; I want to start the day off on the right

You realize that your fist mistake in what

United Reporting, Inc.

you realized if you were Democrat, then the good

side of your brain would have kicked in and none of

this would have happened to you?

Thank you, Bill.

I would object to the form

It assumes facts that have never been in

evidence, that would never go into evidence,

and it suspends reality.

the only reason he's where he is now is because

he wrote a big check to Alex Sink.

That's it, right?

for comment for fear that someone else may end

The record should reflect

that everybody is laughing, so now we will

actually get serious and get started.

I want to start off with Frank Spinosa.

Yesterday, in the questioning by

United Reporting, Inc.

Mr. Scherer, you referenced that there was a point

in time that he received an envelope from you at the

contained between $50- and $75,000 cash?