2011-12-22 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 9 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN:
TIME:
PLACE:
December 22, 2011

8:37 a.m. - 12:00 p.m.
James Lawrence King Federal
Justice Building
99 N.E. Fourth Street
Courtroom 11-3
Miami, Florida 33128
Examination of the witness taken before:

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

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IN THE CIRCUIT COURT OF THE 17TH

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

and MORSE OPERATIONS, INC.
Plaintiffs,
vs.
SCOTT W. ROTHSTEIN, et al.,
9
10
Defendants.
_____________________________________________________
Case No. 11-CV-61688-JIC/LSS
11
AMY ADAMS, et. al,
12
Plaintiffs,
vs.
13
14
15
SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTAR

PRIVATE BANK AND TRUST COMPANY,
Defendants.
16
_____________________________________________________
17
10-03767-RBR Stettin v. Gibraltar Private

Bank & Trust Co.
18
19
10-03802-RBR Stettin v. Centurion Structured

Growth, LLC, et al
20
11-02368-RBR Stettin v. TD Bank, N.A.
21
11-02288-RBR Stettin v. Fidelity Charitable Gift Fund
22
11-02473-RBR Stettin v. Regent Capital

Partners, LLC, et al
23
24
11-02604-RBR Stettin v. Maple Leaf Drilling

Partners, et al
25
11-02605-RBR Stettin v. Don King Productions, Inc.

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2
(Counsel appearing on the foregoing appearance pages

reflect counsel that attended at least one day during
the deposition. It does not reflect their appearance
each and every session.)
3
4
5
6
7
APPEARANCES FOR SCOTT ROTHSTEIN:

LAW OFFICE OF MARC S. NURIK
1 East Broward Boulevard
Suite 700
BY: MARC S. NURIK, ESQUIRE
8
9
10
11
12
13
14
15
16
APPEARANCES FOR THE CHAPTER 11 TRUSTEE,

HERBERT STETTIN:
BERGER SINGERMAN
350 East Las Olas Boulevard
Suite 1000
BY: CHARLES H. LICHTMAN, ESQUIRE
and
GENOVESE, JOBLOVE & BATTISTA, P.A.
100 S.E. 2nd Street
Suite 4400
By: JOHN. H. GENOVESE, ESQUIRE
DAVID C. CIMO, ESQUIRE
THERESA M.B. VAN VLIET, ESQUIRE
JESUS SUAREZ, ESQUIRE
17
18
19
20
21
22
23
24
25
APPEARANCES FOR RAZORBACK:

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

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APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

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

One Biscayne Tower, Suite 3700
Two South Biscayne Boulevard
By: SUSAN E. TRENCH, ESQUIRE
5
6
7
8
9
10
APPEARANCES FOR THE COMMITTEE OF

UNSECURED CREDITORS:
AKERMAN, SENTERFITT
One Southeast Third Avenue
25th Floor
Miami, Florida 33131-1704
By: MICHAEL GOLDBERG, ESQUIRE
JONATHAN S. ROBBINS, ESQUIRE
11
12
13
14
15
APPEARANCES FOR TD BANK:

GREENBERG TRAURIG, P.A.
401 E Las Olas Blvd Ste 2000
By: HOLLY SKOLNICK, ESQUIRE
DONNA EVANS, ESQUIRE
MARK SCHNAPP, ESQUIRE
16
17
APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

COLUMBIA INC. & ZURICH INSURANCE:
18
19
20
CLAUSIN MILLER
One Chase Manhattan Plaza
39th Floor
New York, New York 10005
BY: SCOTT L. SCHMOOKLER, ESQUIRE
21
22
23
24
25

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APPEARANCES FOR FEDERAL INSURANCE COMPANY:
ALEX HOFRICHTER, P.A

1430 South Dixie Highway
Suite 204
Coral Gables, Florida 331463127
By: ALEX HOFRICHTER, ESQUIRE
3
4
5
APPEARANCES FOR MORSES:
6
7
8
9
10
11
TRIPP SCOTT, P.A.

110 S.E. Sixth Street,15th Floor
By: GEORGE WALKER, ESQUIRE
JOHN M. MULLIN, ESQUIRE
and
LAW OFFICES OF ROBERTA DEUTSCH
2499 Glades Road
Suite 110
Boca Raton, Florida 33431
By: ROBERTA M. DEUTSCH, ESQUIRE
12
13
14
15
APPEARANCES FOR EMESS CAPITAL, LLC:

KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL
201 S Biscayne Blvd Fl 17
BY: CASEY H. CUSICK, ESQUIRE
16
17
18
19
APPEARANCES FOR ST. PAUL FIRE & MARINE:

MILLS PASKERT DIVERS P.A.
100 N Tampa St Ste 2010
Tampa, Florida 33602
BY: JOHN A. BLACK, JR., ESQUIRE
20
21
22
23
24
APPEARANCES FOR ROSANNE CARETSKY:

BILLING COCHRAN LYLES
515 E Las Olas Blvd
Floor Six
By: DAN GELBER, ESQUIRE
TUCKER CRAIG, ESQUIRE
25

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APPEARANCES FOR PLATINUM & CENTURION:

CURTIS, MALLET-PREVOST, COLT & MOSLE, LLP
101 Park Avenue
New York, NY 10178-0061
By: GABRIEL HERTZBERG, ESQUIRE
ELIOT LAUER, ESQUIRE
5
6
7
APPEARANCES FOR MURRAY HUBERFELD, DAVID BODNER & MARK

NORDLICHT:
By:
HARVEY WERBLOWSKY, ESQUIRE
8
APPEARANCES FOR FEPICT, MS GROUP:
9
10
11
NYSTROM, BECKMAN & PARIS

One Marina Park Dr., 15th Flr.
Boston, MA 02210
By: JACK SEIGAL, ESQUIRE
12
APPEARANCES FOR MICHAEL SZAFRANKSI:
13
14
15
16
LYDECKER, DIAZ
1221 Brickell Avenue
Floor 19
BY: CHRISTOPHER G. BERGA, ESQUIRE
MIGUEL J. CHAMORRO, ESQUIRE
17
APPEARANCES FOR GIBRALTAR:
18
19
20
STEARNS WEAVER MILLER, et al.

150 W Flagler St Ste 2200
BY: MARY BARZEE-FLORES, ESQ.
MATTHEW DATES, ESQUIRE
21
22
23
24
APPEARANCES FOR FRANK PREVE:

PODHURST ORSEK
25 W Flagler St Ste 800
BY: RAMON A. RASCO, ESQUIRE
25

(954) 525- 2221
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APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

WATCH U-WANT, INC.:
2
3
4
KOPELOWITZ OSTROW
200 SW 1st Ave Ste 1200
By: BART A. HOUSTON, ESQUIRE
JAN ATLAS, ESQUIRE
5
6
7
8
9
APPEARANCES FOR THE US GOVERNMENT:

U.S. DEPARTMENT OF JUSTICE
UNITED STATES ATTORNEY'S OFFICE
500 E. Broward Blvd., Ste. 700
Ft. Lauderdale, Florida 33394
BY: CYNTHIA STONE, ESQUIRE
10
APPEARANCES FOR FRANK SPINOSA:
11
12
13
14
15
16
SCHLESINGER AND COTZEN, P.L.

799 Brickell Plz Ste 700
BY: MICHAEL J. SCHLESINGER, ESQUIRE and
MICHAEL COTZEN, ESQUIRE
and
SAMUEL J. RABIN, ESQUIRE
799 Brickell Plaza
Suite 606
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18
19
20
21
22
23
24
25

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INDEX
CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN
3
DIRECT
FURTHER DIRECT
2356
Mr. Rasco
Ms. Barzee-Flores
Mr. Rabin
Mr. Rasco
2510
CERTIFICATE OF OATH
CERTIFICATE OF REPORTER
2516
2517
2393
2458
7
8
9
10
11
12
PREVE'S EXHIBIT INDEX

NO.
272
273
274
DESCRIPTION
FP112310-0143388/1
FP112310-0134610/1
FP112310-0145380/1
PAGE NO
2368
2393
2393
13
14
15
16
17
18
19
20
21
22
23
24
25

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Thereupon, the following proceedings were had:
MR. RASCO:
THE WITNESS:
You represent who again?
MR. RASCO:
MR. CUSICK:
Ready to go?
I'm ready.
I represent Frank Preve.

Counsel, before you begin,
I'm just going to put an objection on the
record.
On behalf of Emess Capital, as to not
10
being permitted time in this deposition to
11
depose Mr. Rothstein, I object to the counsel
12
for the trustee's violation of the protocol
13
orders, an order permitting Emess to depose
14
Mr. Rothstein at this deposition by trying to
15
shut us out of the deposition.
16
THE COURT REPORTER:
17
18
hearing you, sir.

MR. CUSICK:
I'm having trouble
Maybe you move closer.

We object to counsel for the
19
trustee's violation of the various protocol
20
orders in trying to shut us out of the
21
deposition by refusing us time to depose Mr.
22
Rothstein, by failing to timely send over his
23
exhibits, in accordance with the protocol
24
orders.
25
On the same basis, we move to strike the

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testimony taken by the Trustee and also the
testimony taken by TD Bank, based upon the
inability to cross-examine Mr. Rothstein as to
that testimony, also the failure to abide by
the court order by sending over exhibits
timely.
We reserve the right to depose
Mr. Rothstein at a future date, and we reserve
all rights against the Trustee and TD Bank.
10
We further object on behalf of all other
11
entities which are represented by the Law Firm
12
of Kluger Kaplan to the extent that the
13
Trustee served notices of taking deposition
14
that were filed in those cases prior to those
15
entities being served with the complaint; and
16
we move to strike those notices of taking
17
deposition.
18
19
20
Thank you very much.
Sorry to eat into
your time.
MR. LICHTMAN:
Let the record reflect in
21
the underlying Rothstein, Rosenfeldt & Adler
22
case pending before Judge Cohn, as well as in
23
the protocol orders, neither of them afforded
24
Emess Capital any entitlement whatsoever to
25
take or participate in the questioning of

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Mr. Rothstein.
order; and, indeed, Emess came late to the
table, and as we have told Emess, and numerous
other parties, we are hopeful that there will
be another round of discrete depositions that
don't focus on what we call "the big case" or
the other two limited depositions that are
commencing today.
objections are all completely frivolous and
10
It was a tightly negotiated
So I think that the
baseless and in bad faith.
11
MR. CUSICK:
Also let the record reflect
12
that prior to the first date of the
13
deposition, the Court entered an order
14
permitting Emess to depose Mr. Rothstein and
15
that we were not privy to any discussions
16
concerning the protocols that the depositions
17
and --
18
COURT REPORTER:
I can't hear you, sir.
19
MR. SCHLESIGNER:
Guys, we can do all
20
this during lunch time.
21
MR. LICHTMAN:
22
23
24
25
record later.
We can put this on the
Let's get going.
Whereupon,
SCOTT W. ROTHSTEIN,
acknowledged having been duly sworn to tell the truth

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and testified upon his oath as follows:
THE WITNESS:
MR. NURIK:
I do.
Counsel, did you send me the
documents?
MR. RASCO:
No.
I only have very limited
exhibits.
actually, you know what, I'll bring them to
you right now.
probably not going to use them.
10
Mr. Nurik.
I'll bring them up to you -- well,
I only have a few, and I'm

I apologize,
Here you go.
11
MR. NURIK:
Thank you.
12
MR. RASCO:
And I'm not going to even get
13
into those just yet.
14
15
16
17
18
FURTHER DIRECT EXAMINATION

BY MR. RASCO:
Q
Mr. Rothstein, my name is Ray Rasco.
represent Frank Preve.

I, again, state for the record that we don't
19
feel that this is sufficient time to fully depose you
20
based on the amount of contact between you and Frank
21
Preve by email, 7,000 emails, and the seriousness of the
22
statements you have been making in your testimony
23
regarding Mr. Preve over the past eight days.
24
25
I just want to try and, with the limited time

that I have, clarify some of the issues that we

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discussed on Monday when I first spoke with you about
Mr. Preve.
The first thing that I want to ask is, you
said yesterday in your testimony that one of the things
that you learned in this massive crime was that you
would keep your co-conspirators in the dark as to who
the other co-conspirators were.
Does that apply to Mr. Preve?
To a certain extent.
10
Can you explain that a little bit more?
11
People on the -- what I'll call "outer
12
circle," people who were doing very specific things,
13
were isolated from other co-conspirators.
14
I'll give you an example.
Frank Preve had a
15
very limited purpose for me.
16
what we were doing; I told him what needed to be done.
17
He did it.
18
I didn't explain to do him
I did not ever sit down with Frank and tell
19
him Deb knows what's going on.
20
Frank and tell him David Boden knows what's going on.
21
That's not the way it worked.
I did not sit down with
Okay.
22
With other people, a guy like Mr. Preve, okay,
23
there was need for him to know about certain people; but
24
there was also need, because I knew he was also having
25
conversations with other people and I didn't now -- you

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know, it's not like I knew this man for two decade,
okay, I tried to limit, as best as I could, given all
the vagaries of a crime of this size, people's knowledge
to what they needed to know.
5
6
7
I didn't always succeed.
Well, would that apply to Mr. Preve?
You
tried to limit his knowledge; is that fair to say?

A
On certain issues, yes; and the unique thing
about Mr. Preve is, is his knowledge grew over time.
You can tell by his emails.
If read his email traffic,
10
you know it's clear that there was a point in time where
11
he really didn't know what was going on; and there's a
12
point in time where he is clearly committing fraud after
13
fraud after fraud.
14
And that's based on some of the indicators
15
that you discussed with me on Monday, from his email
16
traffic, as well as certain conversations, for example,
17
that you had with Frank Preve?
18
You'd have to be more specific with me.
19
can't remember every word I said on Monday.
20
sit and read the transcript.
21
Okay.
I'd have to
Well, let me ask you this, then:
The
22
point at which he began to commit fraud, in your words
23
just this morning, when was that?
24
25
You'd have to lay all the email traffic out in
front of me, and I would be able to give you an estimate

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of the date.
Would it go back to December of 2008 or would
it be later, if you recall?
By December of 2008, he was involved.
By December of 2008 he was involved in what
I don't recall.
6
7
8
9
way?
Again, I'd have to see all
the email traffic.

Q
Okay.
What was his role?
You said yesterday
10
that you tried to limit each co-conspirator's role in
11
the crime; can you explain what you limited Frank's role
12
to be?
13
I'll have to look at all the email traffic.
14
Okay.
15
He was in command of a major feeder fund.
16
Okay.
17
18
Okay.
Was he aware of any other
co-conspirators?
A
19
To a limited extent, yes.

Would you like me to explain?
20
Yes, please.
21
Okay.
22
an example.
23
Okay.
Let's use -- let's use Jack Simony, as
Jack's involvement was simply, whether
24
he knew there was a fraud going on or not, to lie to our
25
upcoming investor.
Frank knew we needed Jack to lie.

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knew we needed Jack to lie, and Jack knew he had to lie.
That's all Jack, to my knowledge, knew.
other conversations with Frank about what was really
going on; I don't know.
He may have had
That's what he was limited to.
If you read emails about -- between me and
Frank about John Harris, you'll see there are multiple
emails from Frank telling me to get control of John,
that he was creating problems.
So Frank knew that John was doing things for
10
me that were illegal.
11
of it, I didn't get into it anymore than I needed to.
12
We had discussed it.
The extent
The auditor, Tracy Weintraub, is probably one
13
of the best examples.
14
pocket.
15
balance-sheet audit statements for me, instructed me to
16
scribble on them to make them look like they were
17
real -- and this is all documented in email, okay -- and
18
then to forward them to Tracy.
Frank knew that Tracy was in my
Frank, knowing that, prepared phony
19
There were other times when Tracy sent in
20
questions.
21
we can't answer these questions, that I needed to rein
22
Tracy in, that I needed to get control of him.
23
24
25
Frank would tell me, in email traffic, that
Those are examples of control of certain

people, control of the flow of information.
Q
Well, just going to John Harris, I don't

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recall seeing any emails with respect to Mr. Preve
asking to you rein John Harris in; but I do recall the
email that we discussed on Monday, which is the email
where he discussed where there was a $20-million trust
balance in -- for Banyan at Gibraltar Bank.
Do you recall that discussion?
7
8
Who indicated there was a $20-million trust
balance?
Mr. Preve emailed John Harris stating --
10
asking for a line of credit requests, enclosing
11
documents, and saying that this was based on a
12
$21-million trust account that they had, trust account,
13
or trust proceeds that they had at Gibraltar that --
14
15
A
off.
I recall something -- I didn't mean to cut you

Sorry.
16
-- that they were seeking a line of credit?
17
I remember them seeking a line of credit.
18
remember there being an issue about the trust balance.
19
I remember Frank being aware, through Mr. Harris, that
20
the money was not there.
21
I don't recall the other specifics of it.
22
You'd have to show me the email traffic around that
23
event.
24
25
Do you recall emailing Mr. Preve and asking
him not to further seek a line of credit at Gibraltar

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because John Harris was asking you for settlement
documentation?
It's certainly possible.
I don't have a
specific recollection of it, but it sounds like
something I would do.
Okay.
Moving to Tracy Weintraub, there is the
packet of emails that I just handed Mr. Nurik.
one that's dated January 15th, 2009, 11:05 a.m., and
it's Bate number FP 112310-0143388/1.
10
There is
Your email to him -- it begins with your email
11
to him stating:
12
banking data from me, re: Banyan, for your audit.
13
cannot give him anything from my records, nada, zero,
14
zippo.
15
and audited financials, other than causing a massive
16
explosion that might -- et cetera, et cetera.
17
18
Why is Tracy Weintraub asking for

I
My law firm's records have nothing to do Banyan
And that is -A
That's not bad.
It says "burn my wee-wee."
19
It's -- actually, it's not only funny, but it's also
20
clear that Frank and I know that:
21
as little information floating around as possible
22
because the more information that floats, the more
23
information that is passed between parties, the more
24
likely we will have a detection.
25
Okay, we want to have
If Frank knew that, then why does he have over

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7,000 emails between you and him?
that, there is -- he is --
I mean, if Frank knew
Well, I understand what you're asking me.
MR. SCHERER:
Object to form.
THE WITNESS:
I'm sorry?
MR. SCHERER:
I just put an objection to
form.
You really have to ask your client, because if
you recall my earlier testimony over the last eight
10
days, I was amazed at the level of inculpatory things
11
that Frank would write to me on a regular basis, I mean,
12
right down to the end where he said to me, if he doesn't
13
hear from me, we're going to assume we're on our own.
14
Do you expect us to just sit around and wait to be
15
incarcerated, talking about money missing, talking about
16
the fact that he's given me $25 million without any
17
paper; I mean, one illegal activity after another.
18
19
20
You are going to have to ask him why there is

so much email traffic.
Q
Well, I mean, why would he put so much into
21
email and seek so much information from you and seek so
22
much information from third parties, if he was in on the
23
fraud?
24
25
You would have to ask him that question; I
would be guessing.

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And if he knew how much money you were making
and if he was in on the fraud, why didn't he make so
much money?
results that you had?
Why didn't he have the same financial
I was always -MR. SCHERER:
Object to form.
I was under the impression, and this just my
opinion, that he was making plenty of money.
BY MR. RASCO:
10
11
12
Making plenty of money through Banyan, you
mean?
A
Him, George, other deals, yes, he seemed, to
13
me, to be very well financially situated, and he
14
benefited from our crime.
15
Okay.
Going back to the email that we were
16
just discussing about Tracy Weintraub, the -- Frank
17
responds to that email to January 15th, 2009, at
18
11:00 a.m.:
19
you to confirm our outstanding receivables, just like
20
last year.
The only thing he should be asking is for
21
Yes.
22
And is that what you did?
23
Do you want me to explain that?
24
Yes, I would like you to explain that, please.
25
Okay.
The year before, Berenfeld Spritzer,

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through Tracy, tried to get a real significant amount of
detailed data from us.
3
4
Frank knew and I knew that that was a big

no-no.
I went ahead and met with Tracy, explained to
him what I needed to explain to him relative to the fact
that we're not turning over these documents; that if he
wants to be in this game, he needs to go ahead and
simply do as little as possible, okay, and get what we
10
needed out; that if he couldn't do the Banyan audit, we
11
would find someone else to do it.
12
He agreed to do it.
So when Frank is here saying, "just like last
13
year," okay, he's telling me:
14
to the deal we established previously, which is a simple
15
confirmation, in letter form, just like last year.
16
That's it, nothing more.
17
Tracy should be adhering
And was that a conversation that you had only
18
with Tracy or that you later indicated to Frank that you
19
had that conversation with Tracy or entered into that
20
deal with Tracy?
21
22
I had conversations with both Frank and Tracy
about it.
23
Separately?
24
Never together.
25
And you indicated that if he did not -- if he

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sought too much information, he was not going to have
the job next year; is that accurate?
I told him that on more than one occasion: my
law firm's business, personal business and the Banyan
business, yes.
6
7
Okay.
And are you suggesting that Frank at
any time submitted false financials to Tracy?
He did.
Can you explain that?
10
You'd have to show me all the records.
11
Are you saying that they audited -- the -- any
12
of Frank's financial information that he sent to Tracy,
13
some of that was fraudulent?
14
To my knowledge, yes.
15
With Frank's awareness?
16
To my knowledge, yes.
17
And what do you base that knowledge on?
18
You'd have to show me all the financial data,
19
and I could show it to you.
20
I can give you a good example:
21
wasn't money in a lot of those accounts, and he was
22
saying that the money existed, and he wanted Tracy to
23
say the money existed.
24
exist because he was my accountant.
25
He knew there
Tracy knew the money didn't
He knew in January of 2009 there wasn't money

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in the trust accounts?
Certain accounts, correct.
Based on those emails that we discussed on
Monday where there were certain mistakes?
Emails and many conversations with him.
Okay.
If you turn further, there's another
email on that subject that I handed you, or to
Mr. Nurik.
"Level 3 verification."
10
It's dated January 26, 2009, the subject is
It's an emailed, on the bottom, from Michael
11
Szafranski to Ari Glass, indicating that he had met with
12
you, and then indicating that trust account 5104
13
contained $178,857.
14
15
Frank responds to that email saying, Mike, is

it 187,000, or 17,000,800 or 178 million.
16
17
Do you see that?

A
18
I do.
MR. RABIN:
If I could just ask, for the
19
record, are you making these exhibits part of
20
the record and identifying --
21
MR. RASCO:
Yes.
I'm sorry.
22
be -- we had one just now.
23
at?
This will
What number are we
24
MR. RABIN:
The next exhibit is 272.
25
MR. RASCO:
Thanks.

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2
(Thereupon, the document was marked as Preve's

Exhibit 272 for Identification.)
3
4
MR. SCHLESIGNER:
Sam, just read it out
so everybody knows.
MR. RABIN:
All right.
272 is an email
from Preve to Rothstein dated January 15th,
2009, at 11:05 a.m.
8
9
BY MR. RASCO:
Q
You see the response from Mr. Szafranski
10
stating, I'm sorry, the numbers aren't thousands of
11
dollars, indicating that the proper balance is
12
178 million?
13
And this will be Exhibit 273.
14
Yes.
15
Okay.
I do see that, yes, sir.
16
Okay.
And are you indicating -- are you
17
saying that that was an indicator that Mr. Preve
18
believed that the money was not in the trust accounts?
19
Without seeing email traffic on either side of
20
this, I can't tell you for certain.
21
Mike wrote that.
22
23
24
25
I don't know if
On occasion Mike would write dollars in

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

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would really have to see the email traffic going before
that; and for some reason, the email traffic that would
have been directed to me right around this time is not
here.
So without that, I really can't tell you.

Q
Okay.
But you agree that Frank's financial
statements, to the extent that he produced financial
statements to you, were accurate, generally?
I can't say one way or the other.
Did you rely on him for accurate financial
10
information?
11
No.
I relied on him to tell me what we were
12
supposed to have in the accounts, minimum.
13
he sends me a lot of emails, in fact you handed me one,
14
where he's telling me what the minimum balance is.
15
There is no investment that I've ever heard of -- maybe
16
you have and you can tell me what it was -- where the
17
investor tells the person handling all the money how
18
much money he should have.
19
You'll see
Generally you ask me what the balance is.
20
tell what the balance is, and if I'm wrong, you pull
21
your investment.
22
That's not how we worked.
If there are occasions where the trust
23
balances were not reflecting what Mr. Preve thought they
24
were -- well, first of all, he was telling you what he
25
thought they were based on the deals that you were

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2
entering into the bank, correct?

A
Based on the amount of money he was sending
me -- you have got to remember, there came a long period
of time where there really was no deal paperwork at all;
he was simply relying on that little deal blurb and how
much money he was sending me and how much, based upon
that little blurb, I was sending him back.
a lot of confusion.
So there was
There was also confusion because he would
10
regularly send me money.
11
then he would send me half back.
12
just tell me where you apply.
13
and say, tell me what old deals we're going to apply
14
this to or should I have -- great example:
15
have Centurion fund this again, or is that just going to
16
create too much of a headache trying to reverify the
17
plaintiff receiving the money?
I would send him payments, and

Then he would say,
Then he would come back
Should I
18
Are you referring to a specific email there?
19
No, not -- that email is in the prior
20
21
22
emails -Q
Okay.
Not in the ones that I handed you this
morning?
23
No, I didn't see it here.
24
Okay.
25
Didn't you indicate to Mr. Preve
that -- well, first of all, he was accounting for, on

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his end, what he thought the deals were that Banyan had
entered into, whether they were funding them
specifically or somebody else was funding them?
You'd have to ask him what he was doing.
would send me what he thought needed to be in the
accounts, and I would instruct Irene to correct it.
On many occasions he would actually write
He
directly to Irene and say these balances are off, fix
it.
10
If there were instances where there were
11
balances that were less than the minimum requirement, do
12
you recall if you indicated to Mr. Preve that that was
13
as a result of you not having -- that was as a result of
14
you putting the money in the wrong Banyan trust account?
15
I did that once or twice.
16
And if the balances sometimes weren't
I remember that.
17
accurate, did you indicate to Mr. Preve that could be
18
because you had not paid experts or you had not taken
19
your attorney's fees out?
20
On certain occasions I did.
You have to look
21
at the timing.
22
look at the timing, and then look at the emails around
23
it to determine the full extent of Mr. Preve's knowledge
24
at the time because at a point in time when he's fully
25
aware of what's going on.
You have to look at specific emails,
There's a lot of Ponzi-speak

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there.
We are talking about "transferring money," for
example.
changing balances.
We're not transferring money; we're just

Okay.
We talk about me "putting money someplace."
"Putting money someplace," is simply putting the number
someplace.
I understand.
The email that I just showed you regarding the
10
178 million, you testified on Monday about an email that
11
indicated that there was a mistake of a billion dollars
12
or about a billion dollars; do you recall that email?
13
I recall those emails.
14
This is not that email, correct?
15
No.
16
The second email in the packet that I just
17
gave you is dated November 18th, 2008, 11:06 a.m.
18
from -- the bottom is from Frank to you, and it's
19
subject matter is "stuff."
20
Okay.
21
The third point on that email, it states:
It's
22
23
Need Commerce balance numbers.

And you respond above:
See below.
And you
24
indicate the responses to the question is right after.
25
Do you agree that those responses behind the

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questions are your writing?
Yes.
Okay.
You indicate that you're going to
provide him the balances in Commerce Bank when you get
back to the office this afternoon?
Yes, the fake balance numbers, correct.
And on number four, it says, do I get to sign
in, quote, unquote, online like milk toast does?
And you respond:
Nope, I should not be
10
showing him; but if you want to stand over his shoulder
11
while he and I hold hands --
12
COURT REPORTER:
I need you to slow down:
13
"If you want to stand over his shoulder while
14
he and I hold hands...
15
16
BY MR. RASCO:
Q
17
18
"-- and sign on, be my guest."

Is that your writing there, as well?
19
Yes.
Would you like me to explain that?
20
Yes, I would.
21
Look at the way he writes this:
22
23
24
25
Do I get to
sign, and the word "online" is in quotes.

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

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Curtis and Bill sets up a fake website for him so that
he could use it with investors over at his office.
It's my, also, humorous response to him.
Well, you're indicating, now, that Frank knew
that there was a fake website and that he wanted you to
create a fake website for him?
I'll answer that with a question:
Can you
think of any reason why he would put the word "online"
in quotes if we were really going online?
10
I'm not sure why he wrote "online" in quotes,
11
but I do know that he was seeking verification of trust
12
balances from you, not just through this email, but
13
through hundreds of emails.
14
15
My question is:
Was he aware that this --
that TD Bank/Commerce Bank website was a fake website?
16
Yes.
17
How do you know?
18
I told him.
19
You told him in a conversation or by email?
20
In a conversation.
21
Was anybody else present?
22
Never.
23
Do you know if he ever discussed that fact
24
25
with Szafranski?
A
I have no idea one way or the other.
I doubt

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2
it.
Q
Okay.
And you're indicating that by --
certainly by this time, November of 2008, he would have
known that the trust balances either were nonexistent or
not -- were certainly inaccurate?
Yes.
And he knew that from this time, through the
end of the Ponzi in October of 2009, right?
Yes.
10
Okay.
And we talked about an email on Monday
11
relating to a $300-million shortage.
12
October 30th or 31st.
13
amount that was in the trust balances.
14
left for Morocco.
15
16
17
18
It was
He was asking you exactly the

You had already
Do you recall that discussion?

A
I don't.
You'd have to show me the email
traffic.
THE WITNESS:
And just -- I don't mean to
19
interrupt you, but just for your own
20
record-keeping and since there is so many days
21
and so many exhibits, you need to mark these.
22
MR. RASCO:
23
in sequential order?
Can we mark them on break and
24
UNKNOWN SPEAKER:
25
THE WITNESS:
Yes.
It's okay with me.
I just

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don't want you to get documents -- because we
have a lot of documents floating around here
without stickers.
MR. LICHTMAN:
Does the record clearly
indicate what the document is so it can be
matched and there's clarity in the record?
MR. RASCO:
I specifically stated the
dates in the emails and the subject each time
I've asked about them.
10
11
COURT REPORTER:
Are you going to be
marking more documents?
12
MR. RASCO:
13
COURT REPORTER:
Maybe one or two.

Okay.
Because if it
14
gets too far afield, that's how exhibits get
15
out of order.
16
17
MR. RASCO:
I'm almost done with the
exhibits.
18
Can you read where I left off?
19
(Whereupon, the requested portion of the
20
record was read back by the court reporter as recorded
21
above.)
22
23
24
25
MR. RASCO:
Okay.
Thank you.
BY MR. RASCO:
Q
And there was an email -- and I'm not going to
go into it now, but I marked it as an exhibit in the

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composite exhibit binder that I handed you on Monday --
stating that Frank was asking you, you know, what's
the -- what's the amount -- he had asked you to
authorize Debra to give him an account balances.
You said you already did.
And then you asked -- and then he said, she
has, it she doesn't have the authority.
8
9
He then asked you, what's the shortage, is it

300 million, something to that effect.
10
11
And you said, that's not the shortage.

the amount of money to repay the investors.
12
Do you recall that?
13
I do.
14
Okay.
15
16
17
18
That's
My question:
referring to as the shortage?

A
Do you have an idea?
Without seeing the email, I don't want to
render a guess.
Q
What do you think he's
Okay.
I would be completely guessing.

Do you think it might be shortage in
19
funding; in other words, funding from sources like the
20
Von Allmen Group or the hedge funds?
21
No.
I think the shortage -- and I'm
22
speculating, but I think the shortage he's referring to
23
is, is how much money do we need to put into the trust
24
accounts so that we could pay out everything we were
25
supposed to pay out, had this all been real.

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Did you often indicate --
But I'm guessing.
Okay.
MR. NURIK:
Excuse me, Counsel.
If you
have it there, why don't you show it to him?
MR. RASCO:
but give me a second.
on this.
BY MR. RASCO:
10
I -- I'm happy to show it,

I'm going from memory
I'm sorry, I have don't have it in front of
11
me.
12
asking you, specifically:
13
"shortage" in the past, during the Bar issue, indicating
14
that the hedge funds weren't funding at the same levels
15
that they were before?
16
I don't want to take anymore time, but I'm just
If you had used the word
I actually -- and I would have to see the
17
email traffic; but I actually don't recall using the
18
word "shortage" to describe money that hadn't been
19
funded by the hedge funds.
20
"they haven't funded."
21
shortage in funding.
Normally I would just say
I wouldn't say there's a
22
"Shortage," the way Frank is writing it to me
23
is: what is the shortage in the accounts, how much have
24
you stolen, what's missing.
25
But, again, I'm just guessing.

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Okay.
You used, on various occasions, with
Frank and other parties, starting with the April 2009
Bar issue, the fact that the hedge funds weren't funding
at previous levels --
Correct.
-- you used that as an excuse to not pay out
to Banyan or to other investors; is that fair?
Correct.
Okay.
10
Allmen group and Barry Bekkedam's group?
11
12
14
You'd have to show me
Okay.
I will show you this email.
This is the Composite Exhibit 206, which I

marked on Monday.
16
17
I don't recall that.
that email traffic.
13
15
And you used that again with the Von
All right.
Are you talking about the
October 31st, 2009, email --
18
Yes.
19
-- from me to George?
20
Correct, from you to George.
21
Yes.
22
We have.
23
24
25
We have talked about this extensively.

I have a few more questions about
it.
You indicated that email was a false
exculpation of Frank, not of George, right?

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Well, I've testified over and over that I'm
not sure what George knew.
don't know what he knew.
As I sit here today, I still

So --
Well, you did indicate.
Hang on.
It would clearly be an exculpation of Frank --
It --
-- and George, if he needed it.
Okay.
It would clearly be a false
10
exculpation?
11
Yes, a false exculpation.
12
Okay.
You testified on Monday the latter part
13
of the time about being a liar, thief and scum bag; that
14
was true, in your mind at the time?
15
Yes.
16
Okay.
And the part about you either going to
17
jail or dying, that was true or accurate in your mind at
18
the time, as well, right?
19
Yes.
20
Okay.
And the -- that email was written, if
21
you recall, in response to an email or various emails
22
from George Levin trying to, quote, unquote, bail you
23
out, trying to help you resolve the issues that you were
24
in, without him fully understanding what was going on?
25
In part, yes.

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And so the part about him asking you -- about
you telling him, don't try to bail me out of this, that
was accurate in your mind, as well, wasn't it?
already knew that it would be impossible for him to bail
you?
6
7
I don't how what was possible or not possible.
You'd have to define "bail" me out.
8
9
You
If he could get access to a lot of money, he

could bail out the financial part; but he certainly
10
wasn't going to bail me out of the fact that I had
11
committed a giant crime.
12
So the only part of that email that is untrue
13
is the part about the exculpation; you and George did
14
nothing wrong?
15
The only part in here that I know for certain
16
that is false is:
17
false.
18
19
20
Frank did nothing wrong.
That is
It is all together possible that to a great

extent, George did, in fact, do nothing wrong.
Q
You've testified that this was the first time
21
in your life that -- or at least the several past years,
22
that you were coming clean, that you were being honest
23
with yourself; is that fair, in this time period?
24
25
At this moment?
I don't think at this moment
I was coming clean with myself.
I think I was trying

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to.
Until I made the decision to step foot on a
plane and leave a non-extradition country, knowing that
I was coming back to go to prison, I don't think until I
made that ultimate decision that I had fully reconciled
with myself that it was time to completely change the
person that I am, to change my life and to do the right
thing.
10
11
And this was the only email that you recall
that you were falsely exculpating Frank; is that right?

A
I don't recall.
You'd have to show me the
12
email traffic.
13
see the traffic to tell you one way or the other.
14
15
16
I have sent so many emails, I need to
Did you -- do you recall falsely exculpating
anybody else?
A
We looked at emails the other day.
I don't
17
want to speculate when we have definitive email traffic
18
to establish one way or the other.
19
see the emails and answer based upon emails, instead of
20
guessing.
21
22
23
24
25
So I would like to
Just your independent recollection, anybody
else that you were trying to falsely exonerate?

A
I don't recall.
I believe there were, but the
names are escaping me right at this moment.

Q
Okay.
And to your recollection now, as you

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sit here, was there anything else that you may have done
to falsely exculpate Frank or anybody else?
Oh, wait.
Was that through email?
I'm -- yes, I think there was -- there was an
email.
Okay.
I think -- again, it makes no sense to me to
I tried -- I falsely exculpated
Stu.
10
try to have me guess when we have email traffic that
11
establishes definitively one way or the other.
12
I'm only asking you because I haven't seen any
13
email traffic that establishes you sending any other
14
emails that would falsely exculpate anybody else.
15
On, no, I did.
16
Okay.
And in doing so, when you did do so, do
17
you recall if it was a simple statement like this one
18
with respect to Frank, or was it more detailed?
19
I would be guessing.
20
Okay.
And you were aware, by that time, that
21
there were thousands of emails between you and Mr. Preve
22
that indicated that he may have known something was
23
amiss?
24
You're asking me my opinion?
25
Yes.

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At that point in time I believed that there
were thousands of emails proving clearly that Frank was
involved in a major fraud.
4
5
6
Then why would you think that such a simple
statement would be any help to Frank?

A
Fortunately for you, you've never had to be in
a situation where your mind is as mine was.
multi-billion-dollar Ponzi scheme is collapsing around
you,you're picturing destroying your family and all the
When a
10
people that you love.
11
dying in prison.
12
stress that your body goes through at the time is not
13
something that I can describe in words.
And coming back to potentially
The emotional and actually physical
14
Why I was doing exactly what I was doing in
15
those final days, I would have to sit and really read
16
all these emails again, carefully.
17
something good --
I was trying to do
18
Okay.
19
-- that I perceived as good.
20
The truth is, now, as I sit here today, after
21
having made the decision to come clean and admit
22
everything I've done wrong, I don't think that trying to
23
falsely exculpate those people was the right thing.
24
What I should have done was picked up the
25
phone called them, called Mr. Preve and the others that

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I knew was involved and said, I'm doing the right thing.
You need to do the right thing.
Let's tell everybody what we did.
thing.
5
6
Turn yourself in.

Let's do the right
That's what I should have done.

Q
Do you remember that both Frank and George
were calling you and texting you or emailing you
repeatedly?
Yes.
10
And you indicated on Monday that you did not
11
Yes.
want to speak with them?
12
Correct.
13
And why was it that you didn't want to speak
14
15
with them?
A
I was very emotionally attached to them.
16
was very emotional at the time, okay, and I did not want
17
to speak to them.
18
myself to do it.
19
was away.
20
21
I -- I just -- I couldn't bring

I spoke to very limited people while I
Are you suggesting that Frank in any way
created fake documents in the Ponzi scheme?
22
Yes.
23
Can you explain that?
24
You'd have to show me the documents.
25
I could
tell you then whether they were fake or not.

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Can you give me a time frame?
From -- I would be guessing.
3
4
5
6
Throughout 2009
we created false documents together.

Q
You actually sat with Mr. Preve to create
false documents together?

A
No.
He created fake things and sent them to
me, and I created fake things and sent them to him.
Sometimes we were on the phone together.
Do you mean agreements or trust balances?
10
Trust balances is a good example, but to me
11
that's not creating it, you know.
12
define the word "created" for me.
13
Again, you'd have to
If I create the document through Debra or
14
Irene and then I send it to him and he doesn't like the
15
balances and he wants me to change them to a different,
16
false number, by your definition, is that him creating
17
the document?
18
He's giving me false input to help me create
19
the false document, which is what he did; but you've got
20
to be more precise with me.
21
Okay.
Well, just to be specific, are you
22
talking about only deal documents here?
23
talking about anything outside of the deals that you
24
were entering into with Banyan?
25
Well, sure.
We're not
Sure I am, because Frank helped

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me create, at length, fake opinion letters that I then
had other lawyers put on their letterhead.
knew nothing, like Ken Padowitz knew nothing about this
type of law, knows nothing about this type of business;
he is a criminal defense lawyer.
letter that we put together -- me, Boden, Preve.
People who
He took a fake opinion
We put all this crazy stuff in there, okay,
that we needed to perpetrate this scheme and to keep it
going and to get people to invest more dollars in the
10
fraud.
11
And then, he knows -- he knows Ken Padowitz is
12
a criminal defense lawyer.
13
Padowitz put it on his letterhead, have Padowitz sign it
14
and then we take it and I give it to Frank.
15
starts handing it out, and I handed it out.
16
I put this thing on -- had
And Frank
So Frank handed it out, but in addition to
17
handing it out, you're saying he actually helped you
18
create that document?
19
Absolutely.
20
How did he do so?
21
He gave me language that went in there.
Yes.
I --
22
I wasn't an expert in those areas.
23
knew banking, people who knew that area of the corporate
24
finance, helping me prepare that letter.
25
I had people who
What was the letter opining on?

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You'd have to show me the letter.
It was on the legal nature of the settlement
structure.
documents, which he hadn't.
letter.
letter, including Mr. Preve, had never reviewed anything
in order to come to the, quote, unquote, legal
conclusions that the strategy was legal.
It was that he had reviewed all these

It was a fake opinion
All of the people that gave input into that
Did he provide input verbally or in writing?
10
I don't recall whether he did some in writing.
11
You'd have to take a look through the email traffic, but
12
definitely verbally and definitely on paper in some
13
format.
14
15
16
Whether it was handwritten or by email or on
the document itself, you're not clear?

A
There were times when Frank and I would sit
17
down and scribble on documents that we had, notes, that
18
type of thing.
19
We were sitting together.
If I was sitting in the office and we were
20
doing something nefarious, I don't think he needed to
21
send me an email to confirm what we just discussed.
22
could do it on paper there; but, again, I would need to
23
see the documents.
24
25
We
Any other documents, outside of just the
settlement funding, that Frank would have been involved

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in falsely creating?
I just said the opinion letters.
Just the opinion, I'm asking beyond the
4
5
6
opinion letters.
A
I have to see all the documents, and then I
could tell you one by one whether he had input into it.
Were you aware that Banyan --
Wait a second.
He helped put -- with Tracy, he helped put
10
together that audit letter.
11
the contents of the audit letter.
12
if you look at the email traffic, one of the things that
13
is completely off the charts with regard to a, quote,
14
unquote, independent audit of books and records, is that
15
Tracy, pursuant to my request, forwarded a copy --
16
provided a copy of the audit letter to Frank Preve for
17
his comments before completing it, which is a big no-no
18
as I understand it in the financial audit world.
19
20
21
He had direct input into

As a matter of fact,
But what did Frank do that was wrong, as far
as providing Tracy comments?

A
He had added false information, corrected
22
information that would have led potential investors to
23
believe that there was a fraud, cleaned it up so that we
24
wouldn't get in trouble and gave it back to Tracy.
25
Tracy then corrected the document and put it in final

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2
3
form.
Q
Can you point to specifically anything that he
added that was false?
Sure.
I don't have it with me today.
Show me the letter.

I'll save that
for another day.
Are you aware that Banyan was obtaining
opinion letters from legal -- from their own legal
counsel?
10
Sure.
I helped them formulate certain
11
information that they provided that was false to
12
Greenspoon Marder so that they could get them to write
13
an opinion letter.
14
15
16
And you're aware they also obtained opinion
letters from Hutchinson Steffen?

A
I remember at least one or two other firms
17
that they went to, but you have got to remember
18
something:
19
starters, contain nothing about the payment
20
irregularities that were going on.
21
Look at those opinion letters.
They, for
So just from that small spot of illegality,
22
okay, he was providing false information, because there
23
was all kinds of problems with trust balances not being
24
right and payments being missed and payments being late
25
and documents not being prepared; and then we get these

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audit letters and opinion letters saying everything is
just hunky-dory, everything is beautiful, there is no
problems, everything is paid on time, everything is
properly papered.
information.
That's all based upon false
You indicated that -- on Monday that one of
the indicators that you knew Frank was aware of the
fraud was the fact that he was using money from the
deals to pay certain bills of Levin's?
10
Yes.
11
You're not aware that he was using it for his
12
own purposes, other than that?
13
14
doing.
15
money that was supposed to be investor money and paying
16
Levin's personal bills with it.
17
I don't know one way or the other what he was

I do not know.
I just know that he was taking
As a matter of fact, I think there is an email
18
that we looked at yesterday where he says he needs $10
19
million out of all the money we have to pay George's
20
personal bills.
21
After 2009, essentially, the hedge funds were
22
cut off and Banyan was cut off getting the payments that
23
they were supposed to receive, at least the scheduled
24
payments they were supposed to receive, right?
25
April of '09?

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Yes.
Yes.
And you were indicated that the trust accounts
were blocked, right?
Yes.
Did you tell Frank that because that was
occurring and because certain bills were due for Banyan
and the Levins, that you were going to bring your own
money from New York and pay them out of that money?
10
Yes.
I told him I would borrow the money or
11
bring my own money in, which should have been a giant
12
red flag; but money was money to us at that point in
13
time.
14
MR. RASCO:
Okay.
I'm going to reserve
15
some time and take a break, but I'm done for
16
now.
17
MR. SCHLESIGNER:
Can we make sure the
18
record is clear when he mentioned "Frank,"
19
it's not Mr. Spinosa?
20
THE WITNESS:
On, no, it's not
21
Mr. Spinosa.
22
questioning by Mr. Preve's counsel of me,
23
every time I said "Frank," it was Frank Preve.
All the times during the
24
MR. SCHLESIGNER:
25
MR. NURIK:
Thank you.
And also for the record, the

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only exhibit that we have marked is 272.
we have no identification for any of those
other emails.
So
MR. RASCO:
Let me --
MR. NURIK:
Excuse me.
We don't know what his answers related
to.
8
9
10
MR. RASCO:
what the dates and subjects were of each of

the emails.
11
12
I can mark them in -- they're all in

chronological order.
13
14
(Thereupon, documents were marked as Preve's

Exhibits 273 and 274, respectively, for identification.)
15
16
17
18
Well, I specifically stated
DIRECT EXAMINATION
BY MS. BARZEE-FLORES:
Q
Scott Rothstein, you sure fooled a lot of
people, didn't you?
19
Yes.
20
You conned lawyers, right?
21
Yes.
22
Greenspoon Marder, correct?
23
Well, that con was actually by Mr. Preve, with
24
25
my assistance.
Q
Clifford Chance?

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Yes.
Morgan Lewis?
Yes.
In fact, no firm that did a due diligence
investigation of you, discovered what you were up to and
advised their clients not to invest in you?
7
8
9
I would be guessing as to what they advised
their client.
Q
Didn't you say on December 12th, in the
10
afternoon session, that no firm that did due diligence,
11
as far as you knew, discovered what you were up to and
12
advised the client not to invest in you?
13
14
15
16
That's the key to your question:
As far as I
knew, yes.
Q
You conned innocent lawyers at your firm who
didn't know what you were up to?
17
I did.
18
You conned innocent investors, didn't you?
19
Some, yes, I did.
20
You conned politicians, as well, right?
21
MR. LAVECCHIO:
You can answer the
22
question without specifics.
23
24
25
Yes.
Q
You fooled Senator John McCain?

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Yes.
You fooled United States Senator Mel Martinez?
3
4
5
6
MR. LAVECCHIO:
Objection.
Q
You fooled United States Senator Joe
Lieberman?
Yes.
You fooled Florida Governor Charlie Crist?
9
10
11
12
MR. LAVECCHIO:
Objection.
Q
You fooled California Governor Arnold
Schwarzenegger?
13
Yes.
14
You fooled presidential candidate Sarah Palin?
15
Yes.
16
You fooled the president, George W. Bush?
17
Yes.
18
You conned the Florida Bar, didn't you?
19
No, I never got them involved in anything.
20
utilized the name of the Florida Bar to further my
21
fraud.
22
23
24
25
You were on the Florida Bar Grievance
Committee, weren't you?

A
Oh, you mean I fooled them into thinking I was
an ethical lawyer?

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2
Well, tell me:
Were you on the Florida Bar
Grievance Committee?
I certainly was.
And what were you supposed to be doing on that
We discussed that.
committee?
Hearing grievances.
And what does that mean for the jury?
Explain
what you were supposed to be doing on that committee.
Judging the ethics of other lawyers.
10
You conned the Broward Judicial Nominating
11
Commission, didn't you?
12
13
14
MR. LAVECCHIO:
Q
15
16
17
18
21
22
23
24
25
Did you corrupt that process, sir?

MR. LAVECCHIO:
Without specifics.
Yes.
Q
19
20
Objection.
Did people pay you to get on the bench?

MR. LAVECCHIO:
Objection.
Q
What were you supposed to be doing on that
commission, Scott Rothstein?

A
Vetting candidates for the 4th District Court
of Appeal to send to the government.

Q
Who appointed you to that position?

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The governor, then-governor, Charlie Crist.
You conned your own friends, didn't you?
Yes.
You had a close circle of friends that you
often socialized with, right?
Yes, ma'am.
Some of them knew you were a criminal?
Some did, yes, sir -- yes, yes, ma'am.
Some of them didn't?
10
Some didn't, many didn't.
11
You conned "your own girl Friday," didn't you?
12
"Girl Friday," who?
13
How do you describe Debra Villegas?
14
One of my closest friends and confidantes.
15
And an employee?
16
Yes, ma'am.
17
Who worked right alongside you?
18
Yes, ma'am.
19
Who learned that you were a criminal?
20
Yes, ma'am.
21
Who participated in your criminal conduct with
23
Yes, ma'am.
24
Who you could ask to do just about anything
22
25
you?
and she would, for you?

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Yes, ma'am.
You conned your own best friend, didn't you?
To some extent.
You convinced Ted Morse that you had
Judge Seltzer in your pocket?
That's true.
And by the way, when you conned Ted Morse, you
were a conning a con, weren't you?
9
10
ALL PRESENT:
A
Object.
If you mean to say that Ted knew I was
11
committing crimes and participated in some of those
12
crimes, that's correct; and that I also conned him as to
13
certain things, that's correct.
14
15
16
world?
17
18
You conned the people closest to you in the
That's true.
I hurt a lot of very innocent,
good, decent people.
19
You conned your own mother?
20
I certainly did.
21
I hurt my family terribly.
22
She worked at the firm with you, didn't she?
23
Yes, from time to time my mom worked there.
24
25
My dad worked there, my sister.

Q
And she had no idea what her son had become?

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No, she didn't.
You conned your wife?
I certainly did.
You did the things you did and then crawled
lot.
5
6
I hurt a very good person a
into bed with that woman?
That's correct.
At your sentencing you tried to con the judge,
didn't you?
10
Absolutely not.
11
Sir, you wrote him a 12-page letter,
12
typewritten, right?
13
14
it, yes, ma'am.
15
16
I hand wrote it and then someone else typed
It started off talking about the tough
financial times you had growing up, right?
17
You have to show me the letter, ma'am.
I know
18
that I talked about difficult financial times, that kind
19
of thing, yes, ma'am.
20
21
you were for all of your crimes?
22
23
24
25
It ended talking about how, very, very sorry
Yes, ma'am.
I am.
That's why I turned myself
That letter didn't work, did it,
in.
Mr. Rothstein?

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It wasn't meant to work.
It was meant to be
an honest appraisal of myself and my criminality to the
judge.
What sentence did your lawyer ask the judge to
impose on you, sir?
Forty years.
What sentence --
I'm sorry, no, that was the government asked
for 40 years; my lawyer asked for 30.
10
And what sentence did the judge impose on you?
11
Fifty years.
12
You're good at the con, aren't you?
13
I was, yes.
14
You're not anymore?
15
No, ma'am.
16
Why don't we let the jury be the judge of
17
that.
18
19
20
21
ALL PRESENT:
Object to form.
Q
Let's talk about the psychological tools that
you used to fool people, to con them.
22
First, you're a good salesman, right?
23
I was.
24
You know how to get a sense from people before
25
you do business with them?

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yes, ma'am.
That is one of the tools I used to operate,
Some people you wouldn't do business with
because you sensed you couldn't trust them?
That's correct.
You know how to create a perception of power?
That's correct.
And you know that the perception of power
yields actual power?
10
It does.
11
You know how to convince people that you're
12
legit, right?
13
That's one of the tools I used, yes, ma'am.
14
You convinced people that you were legitimate
15
16
by associating with politicians, right?

A
I convinced people that I was legitimate by
17
associating with certain legitimate politicians and by
18
corrupting and engaging in corruption with some corrupt
19
politicians.
20
21
22
You knew how to convince people that you were
legit by associating with law enforcement?

A
I utilized law enforcement to convince people
23
I was legitimate both by associating with legitimate law
24
enforcement and by engaging in corruption with corrupt
25
law enforcement.

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2
3
You knew how to convince people you were
legitimate by associating with judges?

A
I convinced people I was legitimate by
associating with good and decent legitimate members of
the judiciary, and I convinced people I was legitimate
by engaging in corruption with corrupt members of the
judiciary.
8
9
You knew it was crucial to the success of your
criminal scheme to keep an air of legitimacy around you?
10
Yes, ma'am.
11
And you worked hard to make people feel secure
12
in their relationship with you, right?
13
Yes, ma'am.
14
You used the trappings of wealth to give
15
people the impression of your success?
16
I did.
17
And you worked to convince people that there
18
would be real returns, real returns on their
19
investments?
20
Certain people, yes, ma'am.
21
You made large and very public donations to
22
worthy causes, right?
23
I did.
24
And you pretended to be devout in your
25
religion?

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2
I am not going to justify that comment with a
response.
In 2000 --
I was -- excuse me.
Go ahead.
Excuse me.
Excuse me.
MR. NURIK:
Hold on.
We're not going it
to allow any questions concerning his
religious beliefs, period.
10
11
12
13
14
Q
You made public statements regarding your
religiosity, haven't you?

A
My religion has nothing to do with the fact
that I was a very bad person.
15
You manipulated people, didn't you?
16
I did.
17
You're good at manipulating them, aren't you?
18
I was.
19
You were?
20
Yes.
21
22
25
When
you tell the truth, it's very, very simple.

Q
23
24
I don't need to do that anymore.
You're the tiger who changed his stripes?

ALL PRESENT:
Objection to form.
If you're asking me if I am a good example of
a changed person and how much you can change, the answer

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is absolutely yes.
3
4
5
On a scale of one to ten, you're a ten at
manipulating people?
A
I was.
I have no need manipulate anyone anymore.
When you're telling the truth, you don't need to worry
about manipulating people.
You've said that you can spend time with
10
someone and get a feel for what they might be
11
susceptible to?
12
13
yes, ma'am.
14
15
16
17
That's something that I was capable of doing,
And that you could spend time with someone and
get a feel for how malleable a person he or she is?

A
That was something I was capable of doing as
well, yes, ma'am.
18
You're not capable of getting that sense now?
19
No, I'm not.
20
That --
21
I don't care.
22
You lost your sense to -- to see if somebody
23
24
25
is susceptible to BS?
A
No.
I shut it down.
I decided it was no
longer something that I wanted to be.

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Do you not believe that people can change?
You are able to turn off like a switch your
ability to determine after meeting with a person how
malleable they are?
I have no need to do it anymore.
When you're
telling the truth, you don't need to do any of those
things.
If you had a need, could you do it, sir?
My body, my psyche, my mind, my beliefs would
10
never allow me to do that again.
11
came back and turned myself in knowing I was going to
12
prison.
13
14
16
That's why I
That's your pitch?

ALL PRESENT:
15
Ever.
Objection.
Form.
That's the truth.
17
During the days of your con, when people
18
questioned you about these deals, you would give them
19
whatever information you thought you needed to give
20
them?
21
22
Depending upon whether they were involved in
the crime or not.
23
All right.
24
Sometimes I lied to them and sometimes I told
25
them the truth.
Sometimes you lied to them?
It just depended upon whether they were

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involved in the crime or not.
Sometimes you told them half-truths?
It's the same answer.
level involvement they had in the crime.
as possible?
Depending upon what
To some people, you gave as little information
Depending upon their level of involvement in
the crime.
And to other folks, you exaggerated?
10
Again, it's the same answer.
11
the level of the individual's involvement in the fraud.
12
13
It depended upon
Sometimes you played the attorney-client
confidentiality card?
14
Yes, my co-conspirators and I used that
15
regularly to create a transparency block during the
16
course of the fraud.
17
18
And you played the confidential settlement
card?
19
The same answer.
20
Meaning yes?
21
No.
Meaning that my co-conspirators and I
22
used the confidentiality -- all of those things to
23
create a transparency block so people would not be able
24
to detect the fact that we were committing a crime.
25
Sometimes when you were pressed, you played

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offense in defense, right?
I'm sorry.
Well, for example, when Ed and Carol Morse
I don't understand your question.
would start pressing you and asking too many questions,
wasn't it the case that you would respond with what you
testified on December 12th was, quote/unquote, the
standard, where you rant about:
embarrassed me, I'm making you money, I've done
everything right.
10
11
How dare you, you've
Now I understand.
Yes.
What I would do is, when someone was
12
pushing me on a matter of illegality, if the person
13
was -- if it suited my needs, I would play their
14
emotions to try to get them to stop.
15
16
And you also referred to this technique of
yours as using a person's pressure point, right?
17
Yes.
18
Of course, you agreed you don't need to apply
19
pressure to people who are criminals, right?
20
That's right.
Sometimes -- well, that's not
21
true.
22
let me give specific examples.
23
were co-conspirators of my crime that I needed them to
24
do something outside of the criminality they were
25
currently involved in, I might use pressure points or
Sometimes when you have someone who is a -- well,

When I had people that

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inducements.
It just depended upon what I required for the crime at
the time.
people needed less.
I did that frequently with the bankers.
Some people needed more inducement, some
So, for example, when the innocent fund
investors started asking too many questions about
payments being late, you cooked up a story about having
a Florida Bar grievance?
10
11
12
13
14
Correct.
MR. SCHERER:
Objection to form.
BY MS. SPEAKER?:
Q
You used law enforcement to throw people off,
you said?
A
I used legitimate law enforcement to do
15
legitimate things and I used corrupt law enforcement to
16
do corrupt things.
17
18
You've rewarded the people who were in on your
scheme, didn't you?
19
Very well.
20
You rewarded them with houses, right?
21
Yes.
22
Cars?
23
Yes.
24
Trips?
25
Yes.
Right?

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Women?
Yes.
Cigars?
Yes.
Concerts?
Yes.
Sporting events?
Yes.
You emailed them a lot?
10
Some I emailed a lot.
11
Some I emailed a
little.
12
You gave them nicknames?
13
Both, people that were involved in the crime
14
and not involved in the crime.
15
nicknames.
16
17
Everyone in my world had
And you also gave money and gifts to people
who were not in on your schemes?
18
That's correct.
19
You told folks the gospel according Scott?
20
21
MR. SCHERER:
A
Object to form.
I don't know what -- I'm sorry, I don't know
22
what that means, the gospel according Scott.
23
24
25
On December 14th, in the afternoon session,
page 886 of the transcript, you didn't testify that you

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told people, quote/unquote, the gospel according Scott?
2
3
4
5
6
MR. NURIK:
Actually, what was the
question before that answer?

Q
My question is -MR. NURIK:
No.
What was the question
before?
answer was in response to a particular
10
11
Why don't you say -- ask him what his
question so we can identify the record.

12
Have you ever said that, sir?
13
My recollection is, is I was joking around
14
with some people in here when I said "the gospel
15
according to Scott."
16
17
You'd have to give me the context of it so

it's not taken out of context.
18
You used that phrase, sir?
19
Yes.
20
On the record?
21
Yes.
22
You used other tools, tangible tools to ply
23
your trade too, didn't you?
24
I don't understand the question.
25
You masterminded the use of phony lawsuits?

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I masterminded -- the way you're asking it,
yes, I utilized phony lawsuits to continue to perpetrate
the fraud.
Phony court orders?
Yes, ma'am.
Phony settlement agreements?
Yes, ma'am.
Phony promissory notes?
Yes, ma'am.
10
Forged emails?
11
Yes, ma'am.
12
Phony case file documents?
13
Yes, ma'am.
14
Phony flight manifests?
15
No, we didn't phony up flight manifests.
16
17
We
used -Q
You didn't phony up a flight manifest where
18
you added Bill Clinton and Prince Andrew and young
19
girls' names to a Jeffrey Epstein flight manifest for
20
purposes of showing perspective investors how the
21
settlement system worked and why important people might
22
want confidentiality in exchange for large sums of money
23
to be paid to the plaintiff?
24
25
My best recollection is, is we used -- I think
I testified to this yesterday or the day before -- we

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used real flight manifests during that meeting with
the -- Mr. Scherer's clients.
fake flight manifests.
one.
refresh my recollection, but I actually don't recall
that being a document that I created.
And I told them about
I don't recall that we created
If you have one, you can show it to me, that would
Phony bank websites?
Yes.
Phony bank statements?
10
Yes.
11
Phony opinion letters?
12
Yes.
13
Phony audit letters?
14
Yes.
15
Fake legal bills?
16
Yes.
17
Phony court case bonds?
18
Yes.
19
Fake law enforcement investigations?
20
Yes.
21
Phony attorney's fees statements?
22
Yes.
23
Fictitious loans?
24
Yes.
25
And, of course, being a successful con means
Screen shots.

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you have to be a pretty good actor, right?
I was.
Let's talk about you and your co-conspirators'
acting skills.
5
6
You orchestrated phony telephonic court

hearings, didn't you?
I did.
Now, a real telephonic court hearing is where
9
10
a judge allows the participants to participate by

telephone, right?
11
Yes.
12
But in your phony telephonic hearings, you
13
would have your firm's lawyers or other lawyers fake
14
like they were the participants in a real hearing,
15
right?
16
17
Marra.
18
19
20
I had Scott Goldstein pretend to be Judge
And who, for example, would be attending a
fake hearing with a fake Judge Marra?

A
In this case, one of my co-conspirators, Ted
21
Morse, and his father, who was an innocent, Edward
22
Morse.
23
And what part did you play?
24
The lawyer.
25
Other times you used people to play the part

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of plaintiffs, right?
That's correct.
Steve Caputi played the plaintiff?
Steve Caputi played the plaintiff, and one of
5
6
7
the firm's secretaries played another plaintiff.

Q
I assume you played the part of an honest
attorney?
Yes, ma'am.
You were acting, of course?
10
I was.
11
Caputi also played the part of a reporter to
12
harass one of your victims, right?
13
He did.
14
Another time Caputi played the banker?
15
Several times, yes, ma'am.
16
And he had to dress up for that part?
17
I asked him to put on a shirt and tie because
18
he usually dressed in jeans and a t-shirt.
19
And you played the honest attorney again?
20
I did.
21
Another time you had Caputi pretend to be the
22
owner of 800 numbers that had sent your firm lots of
23
business?
24
I did.
25
And you had a woman in your office play the

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part of a Florida Bar official, right?
I did.
You had other lawyers play the part of a case
and client referral sources, right?
Yes.
And you would participate --
A series of lawyers.
And you would participate in these little
scenarios with them?
10
11
You mean the fake due diligence with the
lawyers?
12
Yes.
13
Yes.
14
So you were acting quite a bit during this
15
I took them there.
time?
16
Myself and my co-conspirators, yes, ma'am.
17
And then there were the shows, what you call
18
"the shows," right?
19
Yes, ma'am.
20
Where everybody had a role?
21
Yes, ma'am.
22
And you had lines?
23
It was a lot of ad lib but, yes, some specific
24
25
things that needed to be said and done, yes, ma'am.

Q
These shows were coordinated?

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Yes, ma'am.
And thought out?
Correct.
You were a master of fraud, weren't you,
5
6
7
8
9
Mr. Rothstein?
A
Unfortunately, I was very good at what I was
doing, yes, ma'am.

Q
By the way, before you got caught up in all of
this, had you read up on con-artists and the tricks of
10
their trade?
11
I'm certain that somewhere along the line I
12
had read about cons but if you're asking me if I did
13
research for the role, no, I did not.
14
It came naturally?
15
It's not that it came naturally.
It's just I
16
developed, unfortunately, an ability to fool people.
17
That's what I was doing.
18
co-conspirators were doing.
19
based upon.
20
21
fraud.
22
I certainly do.
23
I'm going to read you some of the things Judge
That's what all my

That's what a fraud is
Judge Cohn, after sentencing, described your

Do you remember that?
24
Cohn said and ask you if the judge was right.
25
understand?
You

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I can tell you right now he was right on
everything he said.
was 100 percent correct.
4
5
Every single word that he said he
Judge Cohn said that your case was about
selling fake financial products.
True?
Yes.
He said, "The marketing, however, was anything
but simple.
Madison Avenue's advertising elite."
It was sophisticated, rivaling that of
10
Correct.
11
"It was all about image, wealth, power, and
12
influence."
13
Correct.
14
WPI.
15
16
Is that all true?

A
I told you two questions ago that every single
17
thing that Judge Cohn said about me and my crimes was
18
100 percent correct.
19
Judge Cohn, "The marketing component of the
20
fraud focused on attracting investors with deep
21
pockets."
22
23
24
25
Is that what you did?

A
Yes, ma'am.
That's -- I just testified to
that now three questions ago.

Q
You displayed all the trappings of success:

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The multi-million dollar homes, the expensive cars, and
boats, restaurants and jewelry and a 70-lawyer law firm
that appeared to be thriving?
Yes, ma'am.
You maintained political connections
stretching from the Broward Sheriff's office on one end
of Broward Boulevard, all the way down to the Fort
Lauderdale Police Department on the other end of Broward
Boulevard, correct?
10
Yes, and all the way out to Plantation.
11
To the governor's mansion in Tallahassee and
12
all the way to the United States Congress in Washington
13
and down Pennsylvania Avenue to the White House?
14
I did.
15
"The local society page," Judge Cohn, "was
16
constantly adorned with photographs of you and your wife
17
arm-in-arm with sports celebrities, politicians,
18
community leaders, and socialites."
19
Is that right?
20
That's correct.
21
The political contributions, which were
22
funneled through your law firm's attorneys, their wife's
23
and other employees, placed the Rothstein brand in much
24
demand?
25
That's correct.

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The philanthropy, which included donations to
hospitals, religious and charitable organizations
endeared you as one of Broward County's most prolific
benefactors?
That's correct.
And the police security details, the dinners
with law enforcement, and the trips to sporting events
with BSO brass created an appearance of legitimacy?
That's correct.
10
Judge Cohn, "But we now know it was all a
11
fraud."
12
That's correct.
13
Let's talk about your various schemes and
14
crimes.
15
embezzled from his employer, Silversea, right?
Besides the Ponzi scheme, you and Albert Peters
16
Correct.
17
How much in total did you-all embezzle?
18
I don't know.
19
More than 10 million?
20
I don't recall.
21
More than ten bucks?
22
Yes.
23
You and Ted Morse embezzled from Morse
24
25
I don't recall.
Operations, didn't you?

A
We did.

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How much?
In excess of $59 million.
You laundered money through your law firm?
I did.
You laundered money for Albert Peters?
I did.
You laundered money for Ted Morse?
I did.
You laundered money for the mob?
10
I did.
11
You committed tax fraud?
12
I committed the wrong kind of tax fraud.
13
increased my taxes instead of decreasing it.
14
know what you actually call that.
15
way.
16
17
I don't
It's tax evasion one
I guess I was tax invasion.

Q
You lied under penalty of perjury under tax
forms, right?
18
Yes, I did.
19
Friends -- your friends called you Robin Hood?
20
Certain of them, yes.
21
And Robin Hood usually means a steal --
22
23
24
25
stealing from the rich to give to the poor, right?

A
That's normally what it means.
I was stealing
from the rich to give to the richer.

Q
Including yourself?

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Yes.
And back to the tax fraud, your participation
in tax fraud was not necessarily only, if at all, for
your benefit but it was also for other folks' benefits,
right?
Right.
You helped other people commit tax fraud,
right?
10
Yes.
My tax fraud was unique to me.
I helped
other people avoid taxes.
11
Evade them?
12
Avoid, evade, not pay.
13
You engaged in public corruption with
14
politicians?
15
Yes.
16
You engage in public corruption with law
17
enforcement?
18
Yes.
19
You participated in the purchase of political
20
positions?
21
Yes.
22
You bribed judges?
23
Yes.
24
You were involved in the --
25
ALL PRESENT:
Object.
Form.

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2
BY MS. SPEAKER?:
Q
-- manipulation, you say, of the judicial --
4
5
6
7
THE WITNESS:
I'm sorry.
Can you repeat
that?
Q
You were involved in the manipulation of the
judiciary?
Yes.
You engaged in mob crime?
10
I don't know what you mean.
11
MR. LAVECCHIO:
Could I have a point of
12
clarification by what you mean by "mob
13
crimes"?
14
15
16
BY MS. SPEAKER?:
Q
Sure.
You've already said you laundered money
for the mob, right?
17
Yes.
18
Were you involved in extortion?
19
20
21
22
MR. SCHERER:
repeat that?
I'm sorry.
Would you
I didn't hear the question.
Q
Were you involved in extortion?
23
MR. SCHERER:
24
MS. BARZEE-FLORES:
25
MR. LAVECCHIO:
Thank you.
You're welcome.
As a general crime?

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crime, yes.
I was involved in extortion as a general
Did you extort anybody?
You're pausing, Mr. Rothstein.
I'm not going to ask you who if Mr. Lavecchio
doesn't want me to know that.
MR. NURIK:
MR. SCHERER:
10
MR. NURIK:
Let -- hold on.
Hold on.
Objection to form.
Let the record reflect that
11
the reason he's pausing is because there is
12
the anticipation of a possible objection based
13
on law enforcement privilege, so he's giving
14
the government the opportunity to decide
15
whether or not to interpose that objection.
16
No other reason.
17
18
19
MS. BARZEE-FLORES:
So noted.
Q
And I know that, which is what I meant to
20
suggest to you when I said I'm not going to ask you who
21
you extorted, if Mr. Lavecchio has an objection to that
22
question.
23
24
25
But I'm asking you, not who you extorted, but

just admit that you did.
A
I'm waiting to make sure there's no --

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Okay.
-- objection.
MR. LAVECCHIO:
My objection is just
point of clarification.
participated in extortion.
differentiated from extorting people, I don't
understand and I don't think he understands
it.
9
10
11
Did you threaten somebody that if they didn't
give you money, you would do something?

THE WITNESS:
13
MR. LAVECCHIO:
15
As that is somehow
12
14
You said he
Go ahead?
Yes.
Through other people, yes.
BY MS. SPEAKER?:
16
Did you order the people who did it to do it?
17
Did I order them?
18
Did you ask them nicely?
19
20
ALL PRESENT:
A
Object to the form.
The way that particular -- without getting
21
into any details, the people that I was involved with
22
were happy to do these things, and they did them.
23
didn't need to order anyone to do anything.
24
I asked.
I paid.
They did.
25

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2
Q
And the "did" that they did, was it in
exchange for the money with the threat for physical
violence or the threat that some crime would be exposed,
or what?
6
7
8
9
10
MR. LAVECCHIO:
That's where I have to
object.
Q
You were involved in making physical threats,
though, were you not?
11
MR. LAVECCHIO:
Again, point of
12
clarification, he's previously testified that
13
he was involved in acts that concerned certain
14
acts of violence, but as to his personally
15
participating in those, you can ask that.
16
17
18
Q
activities including the making of physical threats?
19
20
21
What did you do to involve yourself in
MR. LAVECCHIO:
I have to object.
BY MS. SPEAKER?:
Q
Did you threaten anybody with physical harm?
22
MR. LAVECCHIO:
23
THE WITNESS:
24
25
Personally?
Personally?
Q
Yeah.

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I may have said I was going to beat the crap
out of someone when they aggravated me but that's not
related to the criminality.
in a bar saying, I would like to sleep with your wife,
and me saying, I'll beat the crap out of you if you go
near her.
That's like someone sitting
It's not the same thing.
Right.
The criminality that I was involved in was
9
10
11
12
through other people.
15
18
19
20
Sir, as you can understand, I'm really not
interested in your bar banter.

ALL PRESENT:
Objection to form.
Q
16
17
I did not actually get involved
in that.
13
14
And certainly --
I'm asking you -MR. SCHERER:
Mary, we can't hear you.
Q
Did you ever threaten to break anybody's
kneecaps, for example?

A
In conversations with certain people that I
21
was committing crimes with, there was discussion of
22
physical violence.
23
24
What type of violence?

MR. LAVECCHIO:
Objection.
25

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BY MS. SPEAKER?:
3
4
MR. LAVECCHIO:
Objection.
5
6
How many contacts in the mob did you have?
Let me ask you about Melissa Lewis.
Melissa
Lewis was a lawyer in your firm, right?
Yes, ma'am.
And at some point you were sleeping with her?
When she was a student of mine, yes.
10
She was Debra Villegas' best friend, right?
11
She was.
12
The same Debra Villegas that would do just
13
about anything for you if you asked her?
14
Yes.
15
The same Debra Villegas that knew about your
We already discussed that.
16
crimes or some of them and who participated in them with
17
you?
18
That's correct.
19
At some point Debra Villegas' best friend and
20
then your former lover was murdered?
21
That's correct.
22
She was murdered because she knew too much,
23
right?
24
25
Excuse me?
She was.
Are you attempting to insinuate
that I had something to do with that poor girl's death?

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Have you lost your mind?
You would deny that?
I would deny it?
4
5
You're disgusting.
wasn't involved in it.
Everyone knows that I
That's disgusting.
How about Julie Timmerman?
No.
8
9
Okay.
No.
That is disgusting.
I was a criminal involved in
white-collar crime, involved in fraud and the like,
10
involved with the mob and corrupt politicians and
11
corrupt law enforcement.
12
13
I'm paying for that.
Melissa Lewis was a good person.

know too much.
14
She didn't
She was killed by a psychopath.
And you're disgusting for doing that.
15
You gave Debra Villegas a house, right?
16
Why drag her family through that?
They're
17
going to have to read this, for your purposes, to defend
18
John Harris, who's guilty.
19
You gave Debra Villegas a house --
20
You should be ashamed.
21
-- right?
22
THE WITNESS:
I want five minutes.
23
should be ashamed of yourself.
24
should be in jail.
25
You
You think I
You should be ashamed.
MS. BARZEE-FLORES:
We'll talk about

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Julie Timmerman when you come back.
THE WITNESS:
You're a disgusting human
being.
group of lawyers.
disgusting human being.
You're the only one out of this entire

You are truly, truly a
MR. NURIK:
(Thereupon, a recess was taken.)
THE WITNESS:
9
10
11
12
Scott, relax.
Whenever you're ready.
Q
When did you say you had stopped manipulating
people?
A
I made a conscious decision to stop being the
13
person that I was during the course of all these crimes
14
on my return from Morocco.
15
16
17
But you agree that even after you returned
from Morocco, you manipulated people?

A
That is a very vague question that may impinge
18
on the government's privilege.
19
defer to them.
20
21
22
MR. LAVECCHIO:
Point of clarification.
Q
You acted in an undercover capacity?
23
MR. LAVECCHIO:
24
MS. BARZEE-FLORES:
25
I'm going to need to
Objection.
I believe that was --
was that not discussed at the sentencing?

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believe it was.
MR. RABIN:
MS. BARZEE-FLORES:
Absolutely, it was.
transcript.
then I can come back.
6
7
Let me just hand it to you, and
MR. LAVECCHIO:
Is that the end of your
question?
MS. BARZEE-FLORES:
MR. LAVECCHIO:
MS. BARZEE-FLORES:
11
MR. LAVECCHIO:
15
16
Q
And I believe it was in your letter,
Mr. Rothstein.
MR. NURIK:
18
this.
19
21
Did you participated in
Okay.
17
20
We defer to the government on
I'm more than happy to answer it, if the
government allows me.

MR. LAVECCHIO:
We don't have to spend a
22
lot of time on this.
23
question yes or no.
24
25
Yeah.
undercover --
13
14
Yes.
That's the only question?
10
12
I have the sentencing
THE WITNESS:
You can answer the
Can you reask the question,
please?

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2
3
Q
You acted in an undercover capacity after you
came back from Morocco?
Yes.
Let me ask you about Julie Timmerman.
Yes, ma'am.
She was your law clerk?
She was.
And she had been a hostess at a -- or some
10
11
type of employee at Bova, also?

A
I believe she was.
12
specifically was or not.
13
she did work at Bova.
I don't recall whether she
I think at one point in time
14
And in the last year --
15
Yeah, she did.
16
And in the last year of the Ponzi scheme, you
17
18
She did.
gave her four $15,000 payments.

A
I don't remember specifically whether it was
19
the last year, but there was a point in time when she
20
needed funds to complete law school and we gave her what
21
we had called "student loans" through the firm.
22
a decision that Stu Rosenfeldt and I made.
It was
23
You were sleeping with her, though, right?
24
There was a point in time when she and I had a
25
physical relationship.
It was prior to her working for

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me.
It didn't continue.
Q
And Ms. Timmerman, after the Ponzi scheme
imploded, is alleged to have committed suicide; is that
correct?
5
6
It's my understanding that she did commit
suicide, yes.
Your bodyguard was pretty close to you, right?
I believed him to be, yes.
Are you talking
about Mr. Scandiffio?
10
Yes.
11
That's what I just said, yes, ma'am.
12
And he also allegedly committed suicide after
13
the Ponzi imploded, right?
14
15
My understanding from conversations with law
enforcement was that he did, in fact, commit suicide.
16
17
Big Bob Scandiffio, he was close to you?
What did he know about you before he allegedly
shot himself in the head?
18
Specifically, I don't recall everything he
19
knew.
20
constantly.
21
did, in fact, know that I was committing crimes.
22
know that I was an adulterer.
23
24
25
He was a confidante of mine who was with me
So I suspect he knew that I was -- well, he

He did
You deny having much to do with any one of
those three deaths, right?

A
I didn't have anything to do with those

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2
deaths.
Q
Every day you've been deposed, the morning has
started with a discussion of the oath you're taking,
right?
6
7
A discussion?
I'm put under oath each
morning.
Q
Put under oath or somebody asks you are you
still under oath, there's always something about the
oath before we start questioning you, right?
10
11
I think that's standard in a deposition, to
make my testimony be sworn testimony.
12
And you took an oath to tell the truth, right?
13
Every day that I've been deposed.
14
And the lawyers -- when I mentioned discussion
15
before, the lawyers questioning you over these days have
16
often made a point that you're under oath or reminding
17
you that you're under oath, right?
18
19
20
They made the point, and I made the point.
Remember this morning, I asked to be put under oath?

Q
And you do that because you want folks to
21
believe that since you're taking an oath, you're saying
22
the truth, right?
23
No, actually.
I really want to not have to
24
repeat all this testimony again, and if I'm not under
25
oath, the deposition testimony can't be used.
I am

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telling the truth.
2
3
4
5
And yes, I do want people very much to

understand that I am, in fact, telling the truth.
Q
You've violated oaths before, though, haven't
you, sir?
In my prior incarnation, I certainly did.
You violated your oath as an attorney?
I did.
You lied to judges?
10
I did.
11
You put money, filthy lucre, ahead of your
12
clients' interests?
13
Filthy lucre?
14
Yes.
Money?
15
Yes.
I know what "lucre" is.
16
heard anyone use that in a question before.
17
It's in the oath, sir.
18
I know it is.
I remember the oath.
19
"for lucre or malice," I remember that.
20
that oath.
21
22
I've just never
I just --
Yes, I violated
Your law firm's motto was passion, integrity
and commitment, right?
23
That's correct.
24
That was a lie?
25
Actually, when -- if you say that like that,

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you're actually offending a tremendous number of really
good decent lawyers because the bulk of the lawyers at
RRA believed in passion, integrity and commitment.
were really good and decent people.
Not you, though?
No.
I was a very, very bad person.
I think
we've established that, and I think I've clearly
admitted that.
You violated the oath of your marriage?
10
I definitely did, yes.
11
They
I already told you
that.
12
How many times did you do that?
13
Too many to count.
14
You have perjured yourself?
15
Prior to returning from Morocco, I certainly
You have been known as the "Prince of
16
17
18
19
20
21
did.
Darkness."
A
Yes.
That was a name given to me back when I
was a young lawyer.

Q
Mr. Rothstein, during the time of your
22
criminal enterprise, you would agree you've been
23
charming?
24
25
I think some would say I was charming; I think
some would say I was a flaming A-hole.

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How about narcissistic?
I definitely had a narcissistic personality,
You repeatedly committed criminal acts?
Yes.
established.
Repeatedly lied or conned people?
I did.
You rationalized your having stolen from some
10
yes.
people?
11
12
absolutely.
13
14
I'm confident that that's clearly
I did, along with my co-conspirators,
And you know, sir, that these are the classic
clinical symptoms of sociopathy?
15
I'm sorry.
16
Have you heard of the word "sociopathy"?
17
I certainly have.
18
You've heard people use the word "sociopath"?
19
I certainly have.
20
And you know that these symptoms that I just
I don't understand your question.
21
went over with you, charming, narcissistic, repeatedly
22
committing criminal acts, repeatedly lying or conning
23
people and rationalizing --
24
You're asking me to diagnosis myself?
25
Well, you're seeing -- you have seen a

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psychiatrist, have you not, sir?
For acute anxiety disorder.
You've had this discussion with your
psychiatrist, have you not?
I have not.
You've been prescribed sertraline?
For acute anxiety disorder.
Do you know it is prescribed for sociopathy,
No, actually, I didn't, until you just told me
sir?
10
11
12
that.
Q
How do you know the prison doctor isn't just
13
telling you it's an anxiety disorder to put that in your
14
prison file so the government can use you as a witness?
15
16
17
I've actually never -ALL PRESENT:
18
Objection.
No, no -MR. NURIK:
Hold on.
First of all, there
19
is a privilege with his doctors.
20
Without waving any medical privilege, I have
21
never -- the entire time I've been incarcerated -- ever
22
seen a prison psychologist or psychiatrist or an outside
23
psychologist or psychiatrist, ever.
24
25
You have --

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2
The sertraline was prescribed to me by a
medical doctor.
For anxiety?
That's what it's used for, yes.
It was
actually the only drug, other than Paxil, that ever
worked for it.
You have no intention of dying in prison?
I certainly hope not to.
You've always had a "plan B," haven't you?
10
The only plan that I had is the plan I would
11
suggest your clients and the other people in here who
12
are guilty use, and that is come clean, talk to the
13
government, tell them what you did, pay for your crime,
14
hope that you get out while you still have a life to
15
live and go and be a productive member of society.
16
That's the suggestion I have for all the people that are
17
sticking their heads in the sand, including your
18
clients.
19
20
Southern Grant -- I'm sorry.
Southern Grout
and Mortar, do you remember that?
21
I do.
22
And I think we've heard the story about you
23
had a lawyer in your firm that botched some aspect of a
24
lawsuit on behalf of the owner of that company.
25
Yes.

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2
And having had the problem of the botched
lawsuit, you had a "plan B," right?
Well, I don't now if I had a "plan B."
You paid off the yacht, right?
5
6
MR. NURIK:
A
Well, let him finish.
Let me finish the answer.
My "plan B" was the fact that the owner of the
company is a criminal, okay, and it was very easy to fix
what we needed to fix.
I paid money to him so that his
10
ex-wife wouldn't know what was going on and so that his
11
daughter and his CFO would not know what was going on.
12
It's not a "plan B."
When you're doing
13
business with criminals, you don't need to have a
14
"plan B"; you just do.
15
16
Well, how about in the Morse cases, when Ed
17
and Carol Morse had a lawsuit and there was some problem
18
going down with that, didn't you have a "plan B" where
19
you had to create fake court orders to get out of it?
20
21
22
You're misstating all of my prior testimony.

I had Ed Morse's son, who is the CEO and
23
president of the company, Ted Morse, involved in
24
criminal acts was me, including assisting me in stealing
25
from his father.
I didn't need to have a "plan B."

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needed to talk to Ted and figure out what -- for lack of
a better phrase, what crime we were going to commit next
and do what it was.
continuation of a criminal enterprise.
You call it "plan B"; I call it a
In late 2009, when you were afraid that your
Ponzi was going to implode without a big infusion of
cash, wasn't "plan B" to threaten the doctrine of mutual
destruction?
Yes, along with other criminals, that's
10
correct.
11
trying to say that I -- if one thing wasn't working, I
12
tried something else, the answer is yes.
13
If you want to call it a "plan B" -- you're
All right.
And when the Ponzi scheme did
14
finally implode, your "plan B," rather than face the
15
failure, was to either flee to Morocco or kill yourself?
16
17
18
I don't think you're
listening to my testimony.
At some point in time, all these crimes were
19
going to be exposed.
20
find a nonextradition country and flee to it.
21
I made a conscious decision to
While I was in the nonextradition country
22
sitting with plenty of money, as well as things that
23
could be sold for plenty of money, I made the
24
then-conscious decision -- maybe one of the only
25
decisions in my life I am truly, truly proud of, I made

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the decision to return to the United States, despite the
fact that I was in a nonextradition country, to turn
myself in, knowing that I was going to go to prison.
Once you were in Morocco --
Something I suggest your clients and the other
6
7
8
guilty people do before it's too late.

Q
Once you were in Morocco, you talked to your
lawyer, Mr. Nurik, right?
I'm sorry?
10
Once you were in Morocco, you talked to your
11
12
lawyer, Mr. Nurik?

A
I think we established on the 30th or the
13
31st, just prior to me deciding to come back, I spoke to
14
Mr. Nurik.
15
16
And you communicated with some of your
co-conspirators?
17
I did.
18
By email, correct?
19
Some by email, some by text.
20
What --
21
Some by phone.
22
What email addresses were you using?
23
I don't recall.
24
You had more than the Scott Rothstein law firm
25
email address?

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using.
to, as well.
No.
That would mean email addresses I was writing
4
5
6
You're saying what email addresses I was
I used SRothstein@RRA-law.com.
Q
You did not write from any other email
address?
I don't think I had any other email addresses.
While you were there, your plan became to come
9
10
11
12
13
14
back to the United States, right?

A
My plan?
It was a conscious decision I made
to turn myself in.

Q
But it wasn't just to turn yourself in and do
your time, right?

A
I made a decision to come back, turn myself
15
in, go to prison and tell the government everything I
16
knew about everyone else that had committed crimes.
17
Right.
18
And everything about my crimes.
19
So you didn't just decide to come back and,
So you did --
20
like a Bernie Madoff, take your sentence and spend the
21
rest of your life in jail --
22
Are you --
23
-- that wasn't your plan?
24
Whoa, whoa, are you suggesting that Bernie
25
Madoff, who worked to help other people that were in the

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know get away with his crime, that I'm the same?
You're not even close.
You're not even close.
Mr. Madoff should have taken me, and I'm proud to say
this, as an example as to what you do when you want to
do the right thing.
you think he did that by himself, then you don't know
anything about how these crimes work.
8
9
He did the wrong thing.
Because if
The point is, Mr. Madoff came back -- I mean,
Mr. Madoff got his sentence and is serving it; but
10
that's not what your plan was, right?
11
get a sentence and hopefully reduce it, right?
12
Your plan was to
At the time that I decided to come back, I had
13
no idea what was going to happen to me.
14
I had with my wife and other people that I was talking
15
to who were counselling me, revolved around the fact
16
that when I stepped back on U.S. soil, I could very
17
likely die in prison.
18
it was a very real possibility, I came back.
19
The discussions
Despite the fact that I knew that
Before you got on that plane in Morocco to
20
return to the United States, you had decided that you
21
were going to begin cooperating with the government in
22
the hopes of reducing your sentence?
23
24
25
I had made a decision to come back and tell
the truth about everything I was involved in.

I had already been -- without getting into

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anything that would waive attorney-client privilege,
okay, and my spousal privilege, okay, I was under the
belief that I could die in prison, regardless of what I
told anybody.
5
6
So I made a decision to leave what I believed

was a safe haven to come back to this.
Okay.
Do I now hope that I will get a reduction?
course I do.
will get out someday.
Of
Every single person in prison hopes they
10
What sentence did you think you were facing?
11
100 years.
12
Before, before you left Morocco.
13
Before I left Morocco?
14
Yes.
15
Life.
16
But you believed at that point that you would
17
have enough information on other people that your
18
sentence might be reduced to a point where you would be
19
able to get out of jail?
20
I didn't have any conscious decision about
21
that one way or the other.
22
would yield a reduction in my sentence --
I hoped that my cooperation
23
At what point did you decide --
24
-- but -- but --
25
Oh, go ahead.

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-- but --
I apologize.
-- given the fact that I had practiced law for
some time, I also knew that it was a possibility, as I
do know sitting here right now, that I could end up
dying in prison.
That is the fact of the matter.
And you don't want that to happen?
No, ma'am.
At what point did you decide to start
10
11
I do not wish to die in prison.
assisting the trustee and Mr. Scherer in this case?

A
In order to answer that question, I would have
12
to give you attorney-client-privileged information, and
13
I'm going to --
14
15
THE WITNESS:
objection?
16
17
18
19
Do you want to make this
MR. NURIK:
You already did for me, but
that's okay.
Q
At what time --
20
MR. NURIK:
21
THE WITNESS:
That's your privilege.

I'm invoking
22
attorney-client privilege.
23
answer.
24
25
That's your
Q
I'm not asking you what your lawyer told you;

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I wouldn't ask you that.
I'm asking at what point did you decide to
start helping the Trustee and Mr. Scherer?
before you left to Morocco?
Was it
No.
It was after that, right?
Well, it would have to be after that
because --
Was it before your sentence --
10
Hang on.
11
Wait.
I'm answering.
When I left to Morocco, there was no Trustee;
12
and even when I came back, I didn't know there was going
13
to be a trustee.
14
on the civil side of this.
15
thinking about.
16
I had no idea what was going to happen

It was not something I was
I had -- I had one goal: come back, tell the
17
government everything I know, make sure the innocent
18
investors got their money back.
19
That was it.
But then, at some point, you believed or came
20
to believe that if you helped the Trustee and
21
Mr. Scherer, you might get some credit for that for a
22
sentence reduction.
23
24
25
Actually, you're 100 percent wrong.

My understanding is that while they're
certainly allowed to talk about anything that I've

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helped happen, that my cooperation is evaluated based
upon my cooperation in criminal investigations and
criminal prosecutions.
statute says anything about civil anything.
I don't think the Rule 35
My purpose in cooperating with Mr. Scherer and
Ms. Van Vliet and Mr. Lichtman and everyone else
representing innocent parties, is to make sure that, my
wish, that the innocent investors get all their money
back, actually comes to fruition.
10
11
You talked about Ponzi-speak.
Let's talk
about prison-speak, since you're talking about Rule 35.
12
I --
13
Now, you know that the government is the one
14
that files the Rule 35 motion, right?
15
16
17
MR. SCHERER:
A
Object to form.
Yes.
18
And, in fact, it did, right?
19
Yes.
20
And the Rule 35, as you just suggested, is a
21
motion that is filed when the government, in its own
22
estimation, has determined that you have provided
23
substantial assistance, right?
24
I understand that's what the rule says.
25
Right.
And that's what you were just trying

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to cite to me a minute ago, right, what the rule or the
statute says, right?
Cite to you?
I was telling you what my -- you
asked me what my understanding was.
understanding.
Okay.
I gave you my
But you know, sir, that once the
government has filed the Rule 35 and you get back in
front of a judge, anybody can get up and talk about how
wonderful you are in the hopes that that might get the
10
judge to reduce your sentence, right?
11
I believe it's up to the judge.
12
Right.
13
14
And it's up to the judge, just like it was up

to the judge the last time you were before him, right?
15
It is completely in his hands.
16
Right.
17
And the last time you were before him,
18
although it was totally in the judge's hands, you had
19
somebody get up and speak on your behalf, did you not?
20
I'm sorry, who spoke on my behalf, other than
22
Mr. Nurik spoke on your behalf, did he not?
23
He's my lawyer.
24
Okay.
21
25
me?
And he was there and he spoke on your
behalf, right?

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2
MR. NURIK:
A
I would hope so.
If he got up and said things that were not on
my behalf, that would have been a little problematic,
right?
He's my lawyer.
And the --
Hang on.
His job --
I'm answering questions, and I know
you want to stay on your roll, but I want to make sure
the record is clear.
10
11
12
He got up representing me.
Okay.
And make no
mistake about it, Mr. Nurik was furious with me.

Q
And the reason he got up and argued on your
13
behalf was to attempt to convince the judge that what
14
you deserved was a sentence of 30 years not 40 years
15
like Mr. Lavecchio was asking?
16
17
18
19
Yes.
Q
Okay.
And you had a letter from Herb Stettin
that was presented to the judge, right?
20
I don't recall.
21
Do you know who Herb Stettin is?
22
I do.
23
And you don't recall him having written Judge
24
25
Cohn a letter for you?

A
It's kind of a blur.
I remember my mom wrote

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a letter.
because we talked about it earlier in testimony,
Mr. Scherer wrote a letter.
My sister wrote a letter.
I remember now,
And the point --
I remember that there was a really -- now,
because I hadn't seen it before -- nasty letter written
by Coquina.
9
10
11
The point of all those letters, the good and
the nasty, were to influence the judge in the judge's

sentencing determination, right?
A
I believe the purpose is to properly educate
12
the judge so he can make as informed decision as
13
possible, yes.
14
So, now that the government has filed a
15
Rule 35, you'll have another sentencing hearing before
16
Judge Cohn, right?
17
18
I don't know.
I don't know if there's going
to be a hearing or not.
19
I understand it could be done by the Court; it
20
could be done without me there.
21
happen.
I don't know what will
22
Do you hope to have a hearing?
23
I hope to get a Rule 35 reduction for my
24
25
substantial assistance -Q
You want somebody to tell the judge what you

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2
3
did?
A
Why are you cutting me off?
Just let me
finish, please.
I hope to have a Rule 35 substantial
assistance reduction.
the judge and the government; it's not up to me.
How we get there, that's up to
Don't you hope that there's a hearing that
Mr. Lavecchio gets up, asks and tells the judge about
how much you've done?
10
If that is going to help educate the Court,
11
then yes, I hope there's a hearing.
12
doesn't require that information or to hear from me or
13
to hear from other people, then that's what will happen.
14
If the Court
And you hope that at such a hearing, your
15
lawyer will have an opportunity to tell the judge what
16
you've done and how you deserve to have your sentence
17
reduced?
18
I hope that all the information about
19
everything that I've done since my return from Morocco
20
is presented in full to the Court; and I hope that he's
21
fair with me, that he considers everything that I've
22
done before and after and comes to a fair determination
23
for me.
24
25
That's my hope.
And you hope Herb Stettin provides the judge
with information that the judge might find favorable to

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you?
I think I've answered this over and over.

I hope that every single person that has
something to offer about anything positive that I have
done since my return from Morocco is heard so that the
judge can make a fair decision based upon everything
that he should consider to determine whether or not I'm
entitled to a reduction.
And you believe that the more the judge hears
10
that's favorable about you, the more likely it will be
11
that the judge will reduce your sentence?
12
MR. SCHERER:
13
Object to form.
I don't know that it's like a "more" thing.
14
think it's the -- an examination of my cooperation.
15
don't know that it's like you stack all the cooperation
16
up.
17
18
It's based upon the quality of my cooperation.
Let's talk about that, Mr. Rothstein.
19
When you talk about the quality of your
20
cooperation and the quantity of your cooperation,
21
certainly, if your cooperation entails nothing more than
22
advising the government about somebody who had passed a
23
fake check once at a bank, you could not expect a
24
sentence reduction as large as you might expect if you
25
provided information that led to the indictment of five

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people, including a politician or a judge, including a
lawyer or a doctor, correct?
4
5
Or a banker.
ALL PRESENT:
Object to form.
I believe that that is a fair statement, that
the judge -- that the government, first, will evaluate;
and then the judge will evaluate it, based upon the
quantity, but more importantly, the quality of my
cooperation.
10
11
Q
And certainly, if Judge Stettin (sic) and
12
Mr. Scherer and Mr. Lichtman come in and say to the
13
judge, not only did he help the government, but he
14
helped us, and he helped our clients, who deserve to be
15
helped, that that may help you get your sentence reduced
16
further?
17
Assuming that the Court wishes to consider
18
that, that would be helpful; but I can't guess as to
19
what he's going to consider or not consider.
20
But you can tell us --
21
The only thing I know about --
22
-- what you hope.
23
Yes, I hope he considers everything that I've
24
done, sure.
25
MR. SCHERER:
Object to form.

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2
3
Q
Who bought the clothes you've been wearing
these last two weeks?
UNKNOWN SPEAKER:
Object to fashion.
watch.
belt, and he brought me a pair of jeans and this shirt.
I bought the sneakers.

I bought my underwear.
MR. NURIK:
11
add to my bill.
13
14
15
18
19
20
21
22
23
Which, for the Court, I will
Q
You've had more than one shirt; Mr. Nurik
bought you the shirts you've been wearing?

A
16
17
Mr. Nurik loaned me my
You've had more than one shirt --
10
12
My wife bought me the
Three.
MR. NURIK:
Target.
Q
You said you bought your sneakers; is that
with money out of your commissary account?

A
It's money I earned, actually, in prison,
teaching.
Q
Does anybody put money in your commissary
account?
24
Yes.
25
Who?

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My wife.
How old are you?
49.
And you've been in for a couple of years,
right?
Two years this past December 1st.
Assuming you have the opportunity to get up
My parents.
My sister.
before Judge Cohn for a resentencing, what do you hope
for?
10
Say this again?
11
Assuming you have the opportunity to get up
I lost you.
12
before Judge Cohn for resentencing, what do you hope to
13
get?
14
15
A
is.
16
17
I don't -- I don't know what a resentencing
Are you talking about -Q
A second sentencing, sir; you've been
sentenced once, have you not?
18
Yeah, but I don't think it works that way.
19
think that there's a Rule 35 hearing, and then he enters
20
an order on the Rule 35.
21
I don't think -- I've read some of the case
22
law.
23
resentencing.
I don't think you actually go through a
24
What do you hope the sentence is --
25
As a matter of fact, I think there's case law

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1
that says it's not a resentencing because that would
trigger certain other things that they don't want to
trigger.
What do you hope your sentence is?
Whatever is fair.
I mean, I would love to get
out as soon as possible.
Okay.
stuff, and I can't talk about that; but make no mistake
about it, I'm in prison, okay.
Prison is a very bad place.
I know there's a lot of talk about where I am and
It's a very bad place,
10
and I can tell you with 100 percent certainty there is
11
nobody in there that does not want to go home today.
12
I would like to go home today.
13
unrealistic.
14
15
right?
16
17
18
19
22
23
I would like to go home today.
Before your incarceration, you lied for money,
MR. SCHERER:
A
Object, form.
Yes.
Q
20
21
Okay.
That is wholly
And you used a pitch to get what you wanted?

ALL PRESENT:
Object, form.
Yes.
Q
Your hope to get out of prison today is a
24
reason for you to lie, isn't it?
25
MR. SCHERER:
Object to form.

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You apparently are not paying attention to
what Judge Cohn is all about, the magnitude of my crime
and what I'm facing.
attention to what's going on.
5
6
upon my telling the truth about everything I know.

MR. SCHERER:
10
Q
You have at least 50 reasons to lie, don't
you?
15
17
We object to that
question.
13
16
You have -MR. LICHTMAN:
11
14
Withdraw my objection.
12
Okay.
My hope to get out is solely, solely based
7
8
You're -- you've got to pay
ALL PRESENT:
A
Object to form.
In prison we actually count it by days.
18
How many days have you got?
19
I don't know.
20
think.
21
22
23
24
25
No.
Over 10,000, I
Object to form.
You, again --
MR. NURIK:
A
A lot.
So over 10,000 reasons to lie?

MR. SCHERER:
A lot.
Just answer.
The answer is no.
I have the opposite of what

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you're saying.
10,000-something reasons, okay, to tell the truth.
Okay.
I have every reason,
MS. BARZEE-FLORES:
THE WITNESS:
Nothing further.
Sam, do you mind if we take
five minutes?
MR. RABIN:
(Whereupon, a recess was had.)
MR. SCHERER:
No, that's fine.
This record closes at
12:00.
10
MR. NURIK:
Let's go.
I'm going to ask a
11
few questions at the end just to clarify some
12
points so -- but we -- go ahead.
13
14

BY MR. RABIN:
15
Okay.
16
Good morning, Mr. Rabin.
17
All right.
18
few points.
19
area.
20
Good morning again, Mr. Rothstein.
First I just want to pick up on a
Then I want to go into a completely new
You said in response to questions this morning
21
that you were amazed that people would write so many
22
incriminating things in emails, correct?
23
Yes.
24
All right.
25
Was it your conscious desire to
try to avoid writing incriminating things in emails?

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It was and it wasn't.

There were times when I was very careful not
to put incriminating things in emails, and looking back
on it, there were times when I wrote things I probably
shouldn't have written.
Would it be fair to say that you were
conscious of the fact you were trying to leave as few
trails as possible of your illegal acts?
At times I was and at times I wasn't.
10
The subject of tax fraud has come up at least
11
two or three times in the course of this deposition; and
12
each time, you've said that you committed fraud the
13
wrong way because, I guess, you're suggesting that you
14
paid more taxes than you should have?
15
I did.
16
Okay.
Did you include in your taxes all of
17
the cash that you were pulling out in cash and using in
18
your various assorted and sundry matters?
19
Not by listing it as cash, but I more than
20
accounted for it in the income that I -- that I
21
declared.
22
Okay.
So you didn't specifically indicate the
23
amount of cash on your tax return that you were -- that
24
you were using or that you had?
25
I didn't say it was cash.
I -- it was more

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than included.
What I did was, so you know, Mr. Rabin, was, I
wanted to avoid an audit; or if I got an audit, I wanted
them to, as they were going through it, determine that,
wait a second, this guy doesn't owe any taxes, if
anything we owe him money.
7
8
9
So I instructed Tracy Weintraub to inflate my

income by tens of millions of dollars, which he did.
Q
So, essentially, what you're saying is you
10
paid more taxes, but you lied about the manner in which
11
you did it?
12
Yeah.
I'm not -- by no means, Mr. Rabin, I'm
13
not trying to excuse my conduct.
14
didn't commit fraud on the IRS.
15
the fact that I kind of did it in a backwards fashion.
16
I'm not saying I

I'm just pointing out
Another theme that you've developed through
17
the course of this deposition in your answers is that
18
you told the people that were involved in your Ponzi
19
scheme just what you needed to tell them in order to get
20
them to do the things that you needed them to do; is
21
that fair to say?
22
23
MR. SCHERER:
A
Objection.
Form.
Certain people, I told them just what they
24
needed to know.
25
too little; and certain people I told too much.
Certain people, I probably told them

It just

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varied.
BY MR. RABIN:
Okay.
I want to break these down into groups
and try and get your best recollection as to what you
told different people in order to engage them in your
scheme.
your law firm.
And I want to start first with the people in

Okay?
Sure.
All right.
Russell Adler, you generally
10
described the fact that he helped you round up other
11
lawyers to provide false verifications that they were
12
either sending business or cases to your firm, correct?
13
That is one of the things that he did, yes.
14
And what was the -- what was it that you told
15
him was the reason why you needed those lawyers?
16
17
First of all, was it honest or a lie and what

was the --
18
No, it was honest.
19
Okay.
20
21
And what -- it was honest, what you
told him?
A
I told Mr. Adler -- to the best of my
22
recollection, I told him that we had the hedge funds
23
coming in town and that in order to convince them to
24
continue to do business with us, that I needed these
25
people to lie about the number of cases we had.

(954) 525- 2221
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So, essentially, what you're saying is, you
honestly told him aspects of the scheme or he already
knew aspects of the scheme and you told him the honest
purpose for which you were lining up these lawyers?
that what you're saying?
6
7
MR. SCHERER:
A
have --
BY MR. RABIN:
Q
11
12
13
14
Object to form.
I don't understand the question but you
10
Let me rephrase it.

MR. SCHERER:
Objection to form.
BY MR. RABIN:
Q
I don't want you to answer a question you
don't understand.
15
Is your -- what you just summarized or just
16
testified to is that you told Adler that you needed
17
these lawyers to provide false information?
18
19
20
21
22
23
24
25
Is
I told Adler -- yes, I told Adler I needed
these lawyers to lie.

Q
Okay.
David Boden, generally what was David
Boden's role?
A
He was my general counsel, and he ran a
sub-Ponzi scheme, as we've come to call it.

Q
All right.
And what was the lie that you told
or the honest information that you gave David Boden in

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order to let him get involved in your scheme?
MR. SCHERER:
3
4
Object to form.
I would have to see all the email traffic with
him to break that down for you, Mr. Rabin.
There were things that I told him that were
true about the scheme.
him that were false about the scheme.
he told me that were true about his scheme and things
that he told me that were false about his scheme.
10
There were things that I told

There were things
There was -- David and I were engaged in so
11
much lying back and forth that without seeing that email
12
traffic, there's just no way I can pinpoint that for
13
you.
14
So --
15
It's impossible.
16
Well, you wouldn't put lies in an email,
17
though, would you?
18
Of course I did.
19
You did?
20
I think I've been saying that for now eight
21
22
days and a couple of hours.

Q
So without looking at the emails, is it your
23
testimony that you have no independent recollection of
24
anything that you told David Boden regarding what you
25
needed to say to get him to help you?

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It's not that I don't have -- I mean, I can
sit here and start -- try to think about it, but giving
me the emails would refresh my recollection and make it
a lot easier on all of us.
And that also has been a common theme
throughout the course of the eight days or nine days;
but what I'm asking you for today is your best
recollection.
not be email trails as to what you told people in your
Because, as you can appreciate, there may
10
conversations with them.
11
your best recollection or what is your best recollection
12
regarding what you told Boden.
13
MR. NURIK:
14
15
So I'm asking you what was
Are we talking about in
emails or in conversations?
BY MR. RABIN:
16
No.
17
In conversations, I -- let me do it by way of
Conversations.
18
giving you some examples, and maybe you can ask me
19
questions as follow-up that will get you to where you're
20
trying to go.
21
At one point in time I had to explain to David
22
Boden how to use the fake TD website.
23
and I showed him how to utilize it, how to log in, how
24
to avoid going to the wrong places that would actually
25
take him to a real TD website.
I took him in,

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BY MR. RABIN:
Did you --
Prior to that a --
Just let me ask a follow-up question, and then
you can continue.
Sure, sure.
Can you tell him what the purpose of the fake
8
9
TD Bank website was when you showed him that?

A
I -- he knew what it was.
That's why he
10
wanted to use the fake TD website; he was going to use
11
it to induce his investors.
12
Okay.
13
By the same token, early on, before he knew
Go ahead.
14
there was a Ponzi scheme, I told him that these were
15
legitimate investments, so he had heard both.
16
much like that with many people who originally thought
17
that what we were doing was legitimate; and as they came
18
to detect red flags, realized that there were crimes
19
going on, and they, themselves, made the decision to get
20
involved, based upon requests that I made of -- for them
21
to do various things.
22
It was
I told him in conversations to be very careful
23
what he wrote to me, that I didn't know whether Curtis
24
or Bill Corte -- and this is a specific conversation,
25
because I remember thinking at some point in time that

(954) 525- 2221
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someone was reading my emails because certain things
looked open.
And I remember telling him, be careful what
you write to me -- this was towards the end, let's say
from June, July, until the implosion -- be very careful
when he was writing to me because I was afraid that
someone might be reading my emails.
to increase the security level on our email system and
the encryption.
10
I was going to try
I told him to be very careful what he told
11
Pearson, Richard Pearson.
12
to worry about Pearson.
13
He told me that I didn't need
Do you want to give me some other topics with
14
him and I can give you some additional information,
15
because there's a lot more.
16
conversations.
17
I was committing with Tracy Weintraub, because David was
18
a very, very bright corporate-paper man.
19
I mean, I had a lot of
I consulted at length with him the fraud
And there was a time -- actually, I had
20
detailed conversations with him on an opinion letter
21
that he was having to prepare.
22
Florescu.
23
investors.
24
25
I think it was for Barry
It might have been for one of his other
I had detailed conversations with him -- this

was about the fraud -- about how Frank Preve and I and

(954) 525- 2221
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the other people that were involved in putting together
prior opinion letters, had placed the false information
in there.
I had conversations with him about what to
show people and what not to show people and how best to
sell the product.
7
8
I gave him extensive one-on-one--- let's call

them primers on how to sell product.
9
10
11
I mean, David was a confidant.
There's a lot
that I told him.

Q
Okay.
Let me move on to yesterday, I believe
12
it was, you identified Adelita Cabello as a Stuart
13
Rosenfeldt's paralegal and the person that you had act
14
the part of a Florida Bar lawyer?
15
Correct.
16
How many times did she do that?
17
Once.
18
Okay.
19
And was that the only time you had
somebody pose as a Florida Bar lawyer?
20
To the best of my recollection.
21
Okay.
22
23
And what was it you told Ms. Cabello in
order to get her to do that?

A
I gave her some specific questions that they
24
were going to ask.
25
and I told her that if they asked anything that she
I briefed her on how to answer them,

(954) 525- 2221
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couldn't answer or was uncomfortable answering, to
simply say that that's Bar privilege or something to
that effect, that she couldn't get into that.
Mr. Rothstein, that wasn't the question I
asked you.
the reason for her --
My question was:
What did you tell her was
I'm sorry.
-- to do that?
I misheard you.
10
Okay.
11
I didn't tell her the reason.
12
And you're saying that she didn't ask why she
13
14
needed to do that?
A
She may have, but a lot of my people were
15
extremely loyal, and they were, unfortunately, used to
16
being asked to do things that were not appropriate.
17
My opinion is, is that that's the way she
18
perceived this and she wanted to be a good, quote,
19
unquote, soldier, and she just did it.
20
Was she given any cash?
21
She was not.
22
Okay.
23
Marybeth Feiss was somebody that was
involved in drafting fake documents?
24
That's correct.
25
All right.
You have already said that with

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Debra Villegas, that the lie that you told her was that
the Mafia was after you and that's why you needed these
fake documents, right?
Yeah.
Sometimes in the middle of the scheme,
when Debra was getting very concerned about continuing
it -- this was in 2009 sometime -- I told Debra that I
had to continue it, that the mob was involved.
a lie.
10
Okay.
That was
What was the lie that you told her in
order for her to start doing it, then?
11
I didn't tell her any lie to start doing it.
12
She just -- did she just basically, willingly
13
engage in a crime with you without any preconceived
14
misconceptions?
15
Actually, one of the things you're going to
16
see through -- in the entire thing, this applies to
17
Debra and many others, is that there is a very slow,
18
apparently smooth glide into the criminal activity.
19
starts with little things and it grows.
20
It
So, yes, there is nobody that I can think of
21
off the top of my head that was involved in any -- even
22
the tentacles of this massive crime, that I said, hey,
23
we're going to commit a crime or said, I'm going to
24
commit a fraud or even anything of that nature.
25
started doing things.
We just
You ask people to do things, and

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you see whether they're going to do it or not.
gauge their response.
That's --
Okay.
You
That's what would happen.
Mr. Rothstein, I'm going to try -- and
if you can, just focus on my questions, rather than the
speeches.
out with each of these people, what you told them to get
them to work with you.
It's very narrow.
All right.
10
Thank you.
11
12
All right.
We left off at Marybeth Feiss.
I don't recall telling her anything.
I think
Deb filled her in.
15
16
Okay?
What did you tell Marybeth Feiss?
13
14
I'm just trying to find
So you don't recall any specific conversations
with her before she started preparing fake documents?
17
Other than asking her to hand me documents or
18
make sure I get documents on time, no.
19
filled her in on all that.
I think Deb
20
Did she leave your firm?
21
For a period of time, yes.
22
Before everything blew up?
23
Yes.
24
When she left your firm, do you know where she
25
And then she came back, I think.
went?

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I don't.
She had told me that she was leaving
to go take care of her children, but Debra told me that
she was leaving because she was concerned about what was
going on with all these documents.
Were you concerned when she left that she
might go to the authorities with the information that
she had?
Yes.
Same question for Melissa Lewis, she left for
10
a period of time, correct?
11
Melissa had no idea what was going on.
12
Okay.
13
You don't -- you know she was best
friends with Villegas, right?
14
Yes.
15
And Villegas knew everything that was going
16
on, pretty much?
17
Debra knew a lot, yes.
18
You really can't sit here and say what
19
20
21
22
Villegas told Lewis, could you?

A
No, but I was never under the impression, in
my opinion, that Melissa knew anything.

Q
Okay.
And with respect to Debra Villegas, you
23
said that she started out just doing illegal things; but
24
at some point in time, she kind of like was -- became
25
reluctant.
And then you told her, in order to keep her

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going, about the mob, correct?
She became very concerned.
Sometime in 2009
she became concerned, and I made up the story about my
life being in danger.
Did you know that her -- at Ms. Villegas'
sentencing, that she told the judge that the reason she
got involved in this from start to finish was because of
your story about the mob?
That would actually be incorrect.
10
So she would have lied, then, if she said
11
that?
12
That would be a false statement, sir.
13
Okay.
14
Yes.
Steve Goldstein, you identified him as
the lawyer who posed as a Judge Marra?
15
Scott Goldstein.
16
I'm sorry.
17
Scott Goldstein.
I know Steve Goldstein.
18
Be careful, you could hurt another lawyer.
19
Scott Goldstein.
20
Change that.
21
He was the lawyer that posed as Judge Marra?
I'm sorry.
22
Yes.
23
Did he pose as any other judges?
24
He posed as a circuit court judge once or
25
twice.

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2
Well, the circuit court judge whose name you
forged on the order was a female, wasn't it?
I don't recall.
Susan Black?
No.
Right.
I'm sorry, Mr. Rabin, state circuit court.
Okay.
Marra.
10
11
Morse cases.
12
Okay.
13
Sorry.
14
Did you tell Scott -- is something funny?
15
Actually, yes.
Susan Black was an appellate court judge.
So this Scott Goldstein posed as Judge
Do you know who else he posed as?

Whoever the real male judge was in one of the
And what -- what did you --
I just remembered Ted Morse
16
saying to me when I said he posed as this other judge,
17
Ted actually said to me at the time that he played -- he
18
had played the circuit judge first; and when he played
19
Judge Marra, Ted actually said to me, you need to get
20
someone else to play one of the other judges because
21
their voices sound the same and my father said something
22
to me about it.
23
24
25
That is what was funny.

Q
Were both of the roles he played, both of the
judges he played, interacted with Mr. Morse, the elder?

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Yes.
Is that what you're saying?
Yes, that was the purpose.
And what did you tell Scott Goldstein in order
to get him to do that?
I told Scott Goldstein that Ted did not want
his father involved in anymore litigation and that Ted
was going to ultimately fund settlements to get -- he
was going to funnel money through us and get back to Ed
10
to make Ed think he won these things so this could all
11
be done with, and this was part and parcel of that plan
12
and we were assisting Ted to do this.
13
So you essentially fabricated an entire story
14
for Scott Goldstein in order to get him to play the
15
role --
16
Yes.
17
-- fair enough?
18
Ted and I did, yes.
19
I know you're saying, well, Ted did it.
20
understand, but I am just asking about what you did.
21
Okay.
22
I understand that, but what I did was with
23
somebody.
24
to tell you what I did and with whom.
25
So if you're asking me what I did, I'm going
Okay.
Howard Kusnick, he was a lawyer who --

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was he with your firm at one point and then left?
Ted and I -- not Ted and I.
3
4
Howard and I were partners many years before

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

Q
And then he ultimately participated by writing
fake letters and saying that he sent cases to you, a lot
of cases to your firm?
8
9
10
think he faked the referral thing.
I don't
He wrote fake
letters.
11
12
I don't think he was a referral.
Okay.
What did you tell him to get him to
write fake letters?
13
I didn't tell him anything.
14
You had to tell him something to get him to
15
write a letter.
What did you tell him?
16
Write this letter.
17
So just it was a command from the head of the
18
firm -- write a letter -- with no explanation?
19
20
Howard was a criminal from way back; it
was not complicated to get him to do that.
21
22
No.
Okay.
Steve Lippman was a lawyer in your
firm?
23
Yes.
24
What generally did he do?
25
Commercial litigation.

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2
3
4
5
6
What type of -- what was his involvement in
your criminal activities?

A
Massive check kiting, money laundering, lying
to clients -Q
Okay.
And what did you have to tell him to
get him to play along?
-- bank fraud.
What did you have to tell him to get him to
play along?
10
Nothing.
11
Nothing?
12
13
He just was a criminal from way
back, as well?
A
I don't know.
He appeared to me to have a --
14
to be what's called loosey-goosey when I first met with
15
him to join in my firm because he wanted me to engage in
16
income tax evasion as part of his compensation package.
17
Okay.
You mentioned this lawyer, Ken
18
Padowitz, several times during the course of this
19
deposition as somebody who you had, I guess, write a
20
letter?
21
Opinion letter, yes.
22
Okay.
And you indicated the opinion letter
23
was about things that you and Preve drafted that you
24
believe Padowitz had absolutely no knowledge about?
25
To the best of my knowledge, he had no idea

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what that letter was about, as far as the contents of
it.
that area of the law.
4
5
He didn't know the -- understand the intricacies of
What was it that you told Mr. Padowitz in
order to get him to write that letter?
To best of my recollection, I simply told him,
I need this letter, put it on your letterhead, and I
paid him for it.
How much did you pay him?
10
I think five grand.
11
grand.
12
Check or cash?
13
Cash.
14
And I assume there is no witnesses to the
15
payment, right?
16
17
18
No.
21
Adler is a witness to me asking him to do
That wasn't my question.
it.
19
20
Maybe 2,500, maybe five
Were there any witnesses to the payment?

A
I think I was just thinking out loud,
Mr. Rabin.
I'm sorry.
22
That's all right.
23
I don't believe there were any witnesses to
24
the payment.
25
There may have been.
Well, there may have been, that's not --

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doesn't make an absolute answer.
witness, then?
Who may have been a
I can't give you an absolute answer.
There
may have been a witness, because I handed him the
money -- here's the problem.
situated, there was a lot of foot traffic, and I simply
walked into his office and gave him the money.
8
9
Where his office was
And did you give him any reason at all why you
needed the letter?
10
I did not tell him why I needed the letter.
11
Mr. Padowitz, I had known, had engaged in substantial
12
amounts of fraud previously.
13
those guys that you know, you pay him, he'll put it on a
14
letter, anything for a buck.
15
16
17
He was -- he's one of
What other fraud did you know he had engaged
Fraud involving his judicial campaign, and he
in?
18
had lied during the course of various cases that he was
19
handling when he was a partner of Russ Adler's.
20
All right.
Stuart Rosenfeldt, you talked
21
about him a lot during the course of the deposition.
22
What is it that you had to tell him in order to get him
23
involved in your scheme?
24
Nothing.
25
So he knew from the beginning that it was

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criminal and willingly engaged in it?
At the time he discovered what was going on,
which was simply by looking in the accounts and asking
me where the money was coming from, yes, he knew I was
involved in criminal activity and then he knew he was
involved in criminal activity.
Irene Stay was your chief financial officer?
Yes.
And she was moving money between and among
10
your various accounts, actually doing the transactional
11
side of it?
12
Yes.
13
Did you ever explain to her what you were
14
doing with the movement of money?
15
I didn't need to.
16
Why not?
17
Because Irene was a -- involved in fraud way
18
back when I first met her when she was the bookkeeper
19
for a law firm called Phillips, Eisinger Koss.
20
became Phillips, Eisinger, Koss, Rothstein & Rosenfeldt.
21
She was regularly engaged in fraud with the senior
22
partners of that firm, Gary Phillips and with Dennis
23
Eisinger, involving accounting and tax evasion and the
24
like.
25
It later
How did you know that?

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Because I was part of this.
You were part of that fraud?
I received money from it.
Okay.
Did you have an intimate relationship
with Irene Stay?
I'm sorry?
Did you have an intimate relationship -- I'm
trying to be delicate.
9
10
No.
"intimate."
I didn't realize when your said
11
Nevermind what I thought you said.
No, I did not.
12
How about Debra Villegas?
13
No.
14
Okay.
And Debra Villegas, you said that --
15
about halfway through, that you mentioned that the mob
16
story to her, correct?
17
I don't remember if it was halfway.
My
18
recollection is it was 2009 some time, when the things
19
were getting really crazy in the office.
20
21
Well, 2009 is more than halfway through,
actually, would it be?
22
23
be halfway.
24
25
Bank.
That's why I said I don't know that it would
All right.
And now I want to talk about TD
I think you identified three different people at

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the bank who you had interaction with, if I'm not
mistaken, Spinosa, Caretsky and Kerstetter, correct?
You are going to have to define "interaction."
Well, in terms of helping you with any aspects
of your scheme, that you were aware of?
Ms. Kerstetter, all she did was hand me an
envelope.
of her knowledge.
Ms. Caretsky or Mr. Spinosa.
10
I do not know anything else about the extent

You'd have to talk to Mr. Boockvor or
Did you have any conversations with
11
Ms. Kerstetter about what she was doing in terms of
12
helping you?
13
To my recollection, no.
14
Okay.
With respect to Ms. Caretsky, you
15
testified previously that she was given money and helped
16
you with the switches of statements.
17
her to get her involved?
18
What did you tell
I told her, as I testified previously, that I
19
needed to convince clients of mine that I had more money
20
in the bank than I did in order to get them to give me a
21
substantial increase in my business.
22
23
Okay.
And do you recall when you told her
that?
24
I do not.
25
Okay.
With Mr. Spinosa, you -- he prepared a

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series of letters that have come to be known as lock
letters at your request, correct?
Yes.
The first one was August 17th; do you recall
that?
I don't.
Well, let's just -- let me ask the question
differently, then.
Sure.
10
What was it you told Mr. Spinosa in order --
11
when you requested the first letter?
12
I don't recall, specifically.
13
So as you sit here today, you don't recall
14
15
what explanation you gave him for requesting the letter?

A
I would have to really sit down and read the
16
email traffic to see what I said and how I said it.
17
don't recall what reason I gave him for the letters,
18
except to tell him that I needed them.
19
20
21
You would not have told him some illegal or
improper reason; is that fair to say?

A
I don't know what I told him.
I don't know
22
what I told him.
23
traffic and see if it refreshes my recollection.
24
25
I would have to look at the email
Is there anybody else at TD Bank that you can
recall that you had any interaction with?

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Illegal interaction?
Yes.
No.
Okay.
Gibraltar Bank, the other bank that you
testified about, I think you mentioned two different
names, Mr. Harris and Mr. Hayworth?
And Ms. Ellis.
And Ms. Ellis.
Okay.
Ms. Ellis, generally, what was her role?
10
She was a bank manager.
11
What did she do to help you, if anything?
12
She kept us apprised of problems with our
13
accounts, helped us move money around.
14
discussions with her, so the record is clear about
15
criminal activity.
I never had any
16
So you never spoke to her at all?
17
Oh, I spoke to her a lot.
18
About anything related to either criminal
19
20
activity or reasons to ask her for favors, anything?

A
The only things that I said to Lisa would be
21
contained in emails, and I don't recall, other than
22
giving her carte blanche to move money around in a
23
manner that was certainly, by my way of thinking,
24
suspicious, I didn't have any conversations about
25
illegality with Ms. Ellis.

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of the bank?
Yes.
All right.
CEO.
Sorry?
CEO.
CEO.
All right.
Steve Hayworth, he was president
You --
You ultimately invested in that bank?
10
I did.
11
Did you ever have any conversations with him
12
about what you were doing?
13
About what I was doing?
14
Yes.
15
No.
16
All right.
17
Only about the BSA.
18
I'm sorry?
19
Only about the BSA AML issue.
20
And that conversation, there was one of those?
21
One or a couple.
22
23
24
25
It was the same
conversation, though, very brief.

Q
And ultimately you invested in the bank,
correct?
A
I did.

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2
You never told him the source of the funds
regarding your investment, did you?
No.
Which were?
I took it from somebody who had sent money to
6
7
8
9
He could see the source of funds.
one of my trust accounts.

Q
Essentially you concealed from him any illegal
activity that you were conducting, correct?

A
No, no, no, the whole purpose of my investment
10
was based upon his illegal statement -- what I believe
11
was an illegality, telling me that they don't
12
investigate shareholders of the bank.
13
Okay.
14
That was the triggering event.
15
And based upon that claimed conversation, you
16
17
18
19
20
invested in the bank?

A
It's not a claimed conversation.
It happened.
That's why I invested in the bank.

Q
When you say that, there is no witnesses to it
but Scott Rothstein, correct?
21
And John Harris.
22
Okay.
23
What did he do in real life or --
24
25
John Harris, what did he do?
MR. NURIK:
Hold on one second.
I'm just
a little confused.

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MR. RABIN:
Okay.
MR. NURIK:
We have been going on, this
is the ninth day.
parties asking questions concerning Gibraltar.
It's my understanding that you represent
Mr. Spinosa --
We have had multiple
MR. RABIN:
Correct.
MR. NURIK:
-- who works for TD Bank.
MR. RABIN:
Correct.
10
MR. NURIK:
We are going over ground that
11
we have gone over before several times.
12
don't understand why you're asking these
13
questions now concerning Gibraltar officials.
14
MR. RABIN:
Actually, really, I'm asking
15
questions about what lies he told to the
16
various people that he was -- that he engaged
17
in his scheme, and that's the context of it,
18
Mr. Nurik; and I appreciate your objection.
19
20
MR. SCHERER:
I am going to object to the
form, also.
21
MR. RABIN:
22
MR. SCHERER:
Okay.
I mean, all of this is
23
really over-the-top repetitive, Sam.
24
you would finish, so there would be a little
25
bit of time left.
I wish

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MR. RABIN:
Well, okay, none of these
questions have been covered, because I have
read the transcripts, as well as sat here; and
nobody has asked him any questions about what
he specifically told people to get them
involved.
answers in any transcript, then I would be
happy to stand down on these questions.
And if you could point me to the
BY MR. RABIN:
10
Mr. Rothstein?
11
Yes, sir.
12
Regarding Mr. Harris, he was -- what was his
13
14
position at the bank?

A
He was a senior or executive vice president,
15
and he was in charge of Fort Lauderdale market.
16
recall what his title was.
17
Did you lie to him at all?
18
Yes.
19
About what?
20
A whole variety of things.
21
22
If you show me the
email traffic, I can point them out to you.

Q
I want your best independent recollection of
23
the things you lied to him about.
24
MR. SCHERER:
25
I don't
Object to the form.
I lied to him from time to time about where I

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was.
for certain business investments I had.
I lied to him about where certain money was coming
I really have to look at the email traffic.
just -- I told John Harris a lot of lies, and I told him
a lot of truths.
criminal activity together.
the email traffic, because I'm just sitting here
guessing because I'm poking in the dark.
And he and I were involved in a lot of

And I can't do it without
I don't want you to guess.
10
best recollection.
11
answer:
I just want your
If you don't recall, that's a fair
I don't recall.
12
I just don't recall at this moment.
13
Okay.
Michael Szafranski is a name that has
14
come up throughout the course of the deposition.
15
hired as a, quote, unquote, independent verifier?
16
Yes.
17
All right.
He was
What lies did you tell him in
18
order to get him to falsely verify information to his
19
investors?
20
21
MR. SCHERER:
A
Object to form.
To falsely -- at the time that he became
22
involved in the Ponzi scheme, there were very few lies
23
that I needed to tell him because he was all in.
24
25
Early on I had told him -- he believed that

this whole thing was real.
Once he discovered it wasn't

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real, there was no real reason to lie to him; but I'm
certain if you give me the email traffic, I can tell
you.
4
5
6
Independent recollection, at this moment, I

don't recall, and I don't want to guess.
Q
So, essentially, what you're saying is when he
first got involved, he was, what he believed to be,
verifying what he thought were legitimate transactions;
is that right?
10
11
ALL PRESENT:
A
12
Object to form.
You're asking me to get inside his head.

It's my opinion that early on he believed
13
that, but after a short period of time, it became clear
14
to him, because I think it would to anyone really
15
looking at stuff, that it was not real.
16
opinion.
17
BY MR. RABIN:
But that's my
18
Okay.
19
He was part of the Boden/Pearson sub-Ponzi
20
Richard Pearson, Mr. Pearson was who?
scheme.
21
Okay.
22
I did.
23
And did you lie to him?
24
In the beginning, I did, yes, sir.
25
And what lies did you tell him?
Did you ever meet with him?

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2
3
I told him whatever was necessary to make him
believe that the investment was real.

Q
So it was along the lines of just telling him
things to deceive him into believing it was a legitimate
investment when it was not?
6
7
8
9
ALL PRESENT:
A
Objection, form.
Correct.
BY MR. RABIN:
Q
Do you have any specific recollection of lies
10
that you told him, other than that general umbrella of
11
"the investment is legitimate"?
12
13
14
15
be guessing, and I do not want to guess.

Q
Okay.
Frank Preve, when Frank Preve first
started investing, did you have to lie to him?
16
17
Without seeing the email traffic, I would just
MR. SCHERER:
A
Object, form.
Early on, I'm certain that I did lie to him
18
early on and then less and less, depending upon the
19
level of his knowledge.
20
But, again, you know, I want to be precise.
21
If I see the email traffic, I'm certain I could be
22
precise about what lies I told him and what were truths,
23
what lies we concocted together and the like; but
24
without that, I would be guessing, and I don't want to
25
muddy the record.

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BY MR. RABIN:
"mushroom"?
No, milk toast.
Well, milk toast and also, I thought,
6
7
mushroom.
A
8
9
10
Wasn't Szafranski the guy that you called a
A couple of times we called him a mushroom.

MR. SCHERER:
Objection.
BY MR. RABIN:
Q
11
That's what I thought.

And when you called him "mushroom," I think
12
you testified it was because, for lack of a more
13
delicate term, you shit on him and kept him in the dark.
14
15
MR. SCHERER:
A
Object to form.
It was a conversation between either Frank
16
Preve and I or David Boden and I about him.
17
that we kept him in the dark and put shit on him, like a
18
mushroom.
19
BY MR. RABIN:
20
We said
And that would be -- I assume that's -- the
21
lay way to express it, is that you lied to him and
22
misled him, right?
23
24
25
MR. SCHERER:
A
Object to form.
At various points in time I lied to him, and
he lied to me.
That's what happens in a crime.

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BY MR. RABIN:
2
3
No honor among thieves, is that what you are
saying?
ALL PRESENT:
Objection.
I have got to tell you, even now more so than
ever.
was in the middle of this horrific thing.
I knew there was no honor among thieves when I
8
9
But in going back and looking at all this over

the last two years, I can assure you that there is no
10
honor among thieves at all.
11
BY MR. RABIN:
12
Andrew Barnett, he recruited investors for
14
He did.
15
And did you lie and mislead him?
16
I don't think that he was -- that he knew what
13
17
you?
was going on.
18
What do you mean by that?
19
I don't think that he was involved in the
20
crime.
21
Okay.
22
I did to a limited extent.
So -- but did you lie and mislead him?

Most of that, he
23
was really recruited by David Boden, and I don't know
24
what Boden told him; but I was always of the impression
25
that he believed things were real.
I don't think that

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Mr. Barnett was involved in the crime.
Did you ever have any conversations with him?
I talked to him all the time.
4
5
6
7
8
9
He was the son
of a very dear friend of mine.

Q
Did you ever have conversations where you
pitched the legitimacy of the investment?

A
I think only as follow-up questions that he
had based upon David Boden's pitch to him.

Q
So, what you're essentially describing is
10
David Boden did most of the lying to him, and you might
11
have just, you know, played clean up?
12
13
14
MR. RABIN:
19
These guys are sleeping.
(Thereupon, a discussion was held off the

record.)
17
18
There was no objection to
form on that one?
15
16
I think that's a fair statement.
MR. LICHTMAN:
Objection to form.
BY MR. RABIN:
Q
Doug Bates, Doug Bates was an attorney who
20
lied to investors, potential investors about referring
21
business to you?
22
23
Doug Bates was a lawyer who was involved in a
significant amount of illegal activity with me.
24
Okay.
25
Some of which I can't get into.
I'm sorry?

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Okay.
You're about to find out.
-- for what you can get into, though, you
Well --
described how he lied to investors in order to lead them
to believe he was referring you business, correct?
Him and Wayne Koppel, yes.
Okay.
With regard to Mr. Bates, what did you
tell him in order to get him to make those
misrepresentations?
10
I just told him I was bringing people in that
11
I needed him to say this to.
12
Bates is one of those people that, for lack of a better
13
word -- do you need me to give you a moment?
14
MR. LICHTMAN:
I didn't -- again, Doug
I'm going to board your
15
one question.
16
you're alluding to is a lawyer in Fort
17
Lauderdale, correct?
To be sure, the Doug Bates that
18
THE WITNESS:
19
MR. LICHTMAN:
A lawyer in Plantation.
Plantation.
Not a Doug
20
Bates that works at Berger Singerman in Miami,
21
right?
22
23
24
25
THE WITNESS:
Sorry, Chuck, no, it is not
your Doug Bates.

MR. SCHERER:
I didn't see that on your
conflict waiver.

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2
BY MR. RABIN:
Q
So Doug Bates, you just essentially said,
listen, I need you to lie to these people and tell them
that you send me a lot of business; is that it?
Because of things that I cannot discuss that
the government will object to, there was no need to get
into much deception with Doug Bates to get him to do
anything illegal.
What else was he doing?
10
MR. LAVECCHIO:
11
MR. RABIN:
12
13
14
Objection.
Okay.
Just making sure
you're aware.
BY MR. RABIN:
Q
Steve Caputi, we talked a lot about Steve
15
Caputi.
16
lot of the illegal roles he played for you.
17
the first thing that he did for you?
18
the first thing?
Ms. Barzee did an excellent job summarizing a

What was
Do you remember
19
I don't know.
20
What kind of story do you have to tell
I go way back with Steve.
21
somebody to have them play a fake banker or a fake
22
plaintiff?
23
24
25
What did you tell him?

None.
You have to understand Steve's history
to understand who you were dealing with.

It would be like talking to -- knowing you're

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talking to a member of organized crime -- he wasn't a
member of organized crime -- but knowing you're talking
to a member of organized crime and knowing you don't
have to preface anything with any kind of nonsense to
get them to engage in criminal activity or to lessen
their knowledge.
7
8
With Steve, you could let him know everything

that was going on.
With respect to Caputi, is it your testimony,
10
then, that you don't recall having to lie to him in
11
order to get him to play any of those roles?
12
I certainly may have, but I didn't need to
13
tell Steve much.
14
friendship with him was such, I could pick up the phone
15
and say, Steve, I need you to play a banker.
16
wouldn't even ask me why.
Steve is the kind of guy, and my
17
Okay.
18
-- you know.
He
He would just do it --
All I really needed to say to
19
him, Mr. Rabin was, I'll pay you for it; and he was all
20
good.
21
William Cort.
22
Corte.
23
Corte, was one of the -- your computer people,
24
25
correct?
A
Yes.

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Okay.
Yes.
All right.
He set up a fake TD website?
What did you tell him was the
reason you needed a fake TD website?
I didn't need to tell him anything.
So you just said, I need a fake TD website.
need it to look exactly like the real one; and, boom, he
did it?
Yes.
10
Same thing for the other computer gentleman,
11
Curtis Renie?
12
Same answer.
13
Okay.
14
I gave him money.
15
Okay.
16
I don't recall.
17
Was it in cash?
18
Yes.
19
All right.
20
They were actually witnesses to each other's
21
22
And you never gave him any reason?
How much did you give each one of them?
Any witnesses to the payments?
payments, but other than that, I don't think so.

Q
All right.
Wayne Koppel was another lawyer
23
who falsely claimed to -- according to you, had falsely
24
claimed to refer cases to your firm, correct?
25
My recollection is vague as to whether or not

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he was the one who sat in the meetings.
believe that he was the one who actually attended the
meetings with the hedge fund guys, so yes.
4
5
6
7
8
9
10
All right.
I seem to
And what did you tell him in order
to get him to play that role?

A
I didn't have to lie to him at all.
I believe
that Doug Bates and Russ Adler handled all that.

Q
So you never made any false statements to him
in order to get him to play that role in your scheme?

A
As I sit here today, other than telling him
11
what I needed him to say, I recall very little about
12
talking to him about anything having to do with this.
13
Russ Adler and Doug Bates handled that.
14
All right.
Howard Herskowitz was another
15
lawyer that referred -- according to you, falsely
16
claimed to refer significant cases to you?
17
18
19
20
21
22
23
24
25
Not just according to me, it was according to
the people that he made the statements to.

Q
What did you say to him in order to get him to
do that?
A
I didn't say a word to him.
I never talked to
the man until I got there and he started lying for me.
Q
All right.
And what you -- are you saying you
had to tell him nothing in order to get him to do that?

A
I had Russ Adler handle it.
Russ Adler told

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him exactly what lies he needed to tell, and when he
showed up there, he told all the lies.
3
4
5
So you had no conversations with him in terms
of what he was supposed to do; is that your testimony?

A
I think, if you recall my prior testimony,
when I first walked in there, Mr. Herskowitz is the one
who said, it's nice to finally meet you, almost giving
me a coronary.
So, no, I had no prior conversations with him
10
about what he needed to do.
11
best of my knowledge, Mr. Adler.
12
All right.
That was handled by, to the
Steve Rossi was another lawyer
13
that falsely claimed to refer cases, according your
14
testimony, correct?
15
Yes.
16
All right.
17
Did you have the relationship with
him or somebody else?
18
Mr. Adler.
19
Okay.
So did you have any conversations with
20
him about why he was to falsely verify that he sent
21
cases to your firm?
22
Through Mr. Adler.
23
Were you witness to the conversations?
24
One of them.
25
Tell me about that one conversation.

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I told Mr. Adler to call Steve Rossi and let
him know that I would do whatever I could to help him
with his political aspirations in exchange for assisting
us, and I was present during that conversation.
All right.
Tracy Weintraub, you have talked
about him a number of times as preparing -- you talked
about him on a number of cases preparing false financial
statements?
Yes.
10
What is it that you told him why you need the
11
false financial statements?
12
13
I told him here's $75,000; this is what I
need.
14
And I assume that was cash?
15
It was.
16
I assume there are no witnesses to it, other
17
18
than you and Mr. Weintraub?

A
The only person that may be able to verify
19
that was a gentleman who brought me that cash.
20
recollection is he brought me that cash when I was ready
21
to take it up to him.
22
23
My
And I don't know if the government wants me to

say the name.
24
MR. LAVECCHIO:
25
MR. RABIN:
Can I have a moment?
Sure.

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2
MR. SCHERER:
While we have a break, I
would like to --
MR. RABIN:
What's going on --
MR. SCHERER:
6
7
We don't have a break.
Well, I mean, they're just
talking, so -MR. RABIN:
Don't you want to wait until
the lawyers are involved can hear what you're
saying.
10
11
12
MR. SCHERER:
administrative.
I mean, this is
This is administrative.
I understand that the Pearson adversary
13
is going -- I don't know -- next, this
14
afternoon or tomorrow?
15
MR. LICHTMAN:
16
immediately after lunch.
17
the day.
18
No.
Levinson starts
We'll go the rest of
And Pearson starts first thing tomorrow
19
and goes until the conclusion, when we stop at
20
1:00, and then we don't see Scott again.
21
MR. SCHERER:
Is it your --
22
THE WITNESS:
Hopefully not ever, not see
23
me again.
24
What kind of comment is that?
25
MR. LICHTMAN:
Well, in terms of this

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deposition.
MR. RABIN:
MR. LICHTMAN:
MR. SCHERER:
We'll see you again.

In the deposition.
Here's my issue:
I just
now have realized that we're anticipating
closing this record for my case; and then
you're going to start with Pearson, and it
will a separate record.
MR. LICHTMAN:
10
11
When we start with
Levinson.
MR. SCHERER:
When you start with
12
Pearson, you intend to have that as a separate
13
record in your adversary?
14
MR. LICHTMAN:
15
MR. SCHERER:
Correct.
I'm going to request that
16
when you get to Pearson, that this
17
transcript -- my record stays open, because
18
he's a defendant in this my case so that I'm
19
going to urge the Court that whatever you do
20
in that case is a part of my record.
21
MR. LICHTMAN:
I don't have any problem
22
with that, but I will not have time for
23
anybody to be questioning on the time allotted
24
that we have, except for me and for
25
Mr. Pearson's counsel.

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MR. SCHERER:
MR. NURIK:
Well -I'm going to ask for five
minutes at some time, and the basis for that
is because people have not complied with the
Court's order, as I articulated yesterday, in
providing their exhibits to the parties in
advance of this deposition in whole, being
that Mr. Rothstein is a party and I represent
him, and counsel was supposed to receive it, I
10
was denied the opportunity to have it and
11
Mr. Rothstein was denied the opportunity to
12
see it, and as such, I may have some clean-up
13
questions.
14
I will be brief, and in the process
15
Mr. Rothstein may be reviewing some of the
16
documents that were supposed to have been
17
previously provided to him.
18
And as such, I'm going to ask that the
19
record stay open and I have the opportunity
20
for five minutes.
21
22
23
MR. RABIN:
I'm going to give it to you
if we stop -MR. NURIK:
The problem, Sam, is I'm not
24
in the position to do that because he's still
25
reviewing them.

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I got a load last night of things that my
secretary was there very late just putting on
a disk, which I have now.
So, unfortunately, I'm going to ask that
at some point, since the record will remain
open, that I find five minutes to do that, and
I will be brief.
8
9
MR. RABIN:
don't know.
Well, you know, again, I
The agreement is the agreement.
10
I don't know about keeping the record open
11
past the time limit set by the judge.
12
Mr. Lichtman may be able to speak to that
13
better than I can.
14
MR. LICHTMAN:
15
16
When do you think you
would be best suited to ask those question?

MR. NURIK:
Ideally, by the end of the
17
day today, but certainly tomorrow morning, no
18
later than tomorrow morning.
19
have much of a chance beyond that.
20
21
22
I'm not going to
So I'll try -- endeavor to try to do it

by the end of the day.
MR. LICHTMAN:
I'm going to guess -- I
23
don't know -- that most people don't have an
24
interest in hearing the Levinson testimony.
25
Many people may have some interest in hearing

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2
the Pearson testimony.

If that's the case, I'm happy to yield
five minutes when we begin tomorrow at 8:30 so
you can start and ask those questions and I
can go into Pearson.
MR. NURIK:
Okay.
MR. RABIN:
Thank you.
MR. HERTZBERG:
9
10
Okay.
All right.
On behalf of Platinum and
Centurion, this is Gabriel Hertzberg.

We have no objection to what Mr. Lichtman
11
just proposed, that Mr. Nurik borrow five
12
minutes from Mr. Lichtman's time tomorrow.
13
There is a Court order that says that
14
this deposition is closed as of noon today.
15
MR. RASCO:
16
MR. HERTZBERG:
17
We have staffed this accordingly.
18
19
1:00 today.
1:00 today.
We
have set travel plans accordingly.

We object to any examination of
20
Mr. Rothstein by anyone, other Mr. Nurik for
21
the five minutes just discussed, tomorrow or
22
at any time after 1:00.
23
24
25
MR. SCHLESINGER:
We join in that
objection.
MR. SCHNAPP:
On behalf of TD Bank, we

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also join.
2
3
MR. MULLIN:
Likewise on behalf of the
Morses.
MR. NURIK:
That is other than Mr. Nurik?
MR. RABIN:
Other than Mr. Nurik.
MR. HERTZBERG:
Other than Mr. Nurik for
the five minutes just discussed, we'd do
understand up Mr. Nurik and Mr. Scherer have a
common-interest relationship, or so they
10
purport; we would object to any examination of
11
Mr. Rothstein by Mr. Nurik as surrogate for
12
Mr. Scherer or for Mr. Lichtman or for anyone
13
else.
14
15
MR. NURIK:
Well, I can assure you -- I
can assure you he's not paying my fees.
16
MR. RABIN:
17
THE WITNESS:
18
All right.
Come on.
Go ahead, Mr. Rabin.
just ignore anybody else.
19
You go ahead and ask me questions.
20
MR. RABIN:
21
22
23
I'll
Thank you.
I appreciate
that.
BY MR. RABIN:
Q
Okay.
The last -- the question that was
24
pending before the government conferred with you and
25
all, can you get back to it?
I don't remember.

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witnesses --
Tracy Weintraub?
-- to money going to Weintraub.
Well, the last question I recall:
6
7
8
I can tell you.
You were asking me about
Did anybody
witness any of the payment of the 75,000?

A
And my answer is someone witnessed me
receiving the money and taking it up to Mr. Weintraub.
Did anybody witness the payment?
10
I don't believe this person was standing there
11
when I -- we only got as far as the door.
12
Other --
13
So no.
14
Other than the money that you claim that you
15
gave Mr. Weintraub, was there any other conversation
16
about what you wanted him to do or why?
17
As to what I wanted him to do?
18
Yes.
19
Extensive conversation.
20
Okay.
21
The only why that I recall giving him, without
And the why?
22
seeing the email traffic, is so that he could keep my
23
business and keep the business of Banyan and continue to
24
live well, a nice life.
25
MR. RABIN:
All right.
If I could have a

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moment, please.
I think --
MR. SCHERER:
I'm going to object to the
question, Sam, unless you can ask the witness
to identify who saw him get the cash so he can
have a complete answer, since I can't have any
more examination.
8
9
MR. RABIN:
question.
10
11
I'm happy to ask that
MR. SCHERER:
Thank you.
BY MR. RABIN:
12
Did you hear Mr. Scherer's question?
13
I'm sorry, no.
14
Who was the person that witnessed you obtain
15
the cash that you claim that you gave to Mr. Weintraub?
16
MR. LAVECCHIO:
17
MR. RABIN:
18
MR. SCHERER:
19
22
23
So much for your question.

Take all the joy out of
this.
20
21
Objection --
MR. LICHTMAN:
That seemed like a perfect
way to end the transcript.

BY MR. RABIN:
Q
One other area, just real fast, two questions.
24
You remember the Kroll project you discussed with Ken
25
Jenne?

(954) 525- 2221
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I don't.
All right.
Did Ken Jenne ever propose to you
starting a business similar to Kroll's?
Yes.
And what he -- what -- explain that to us,
6
7
what he was purposing in that.

A
We were hiring a lot of retired law
enforcement at the time, former ABT agents, FBI agents,
IRS agents, and he wanted to put together something to
10
rival Kroll.
11
And did that go beyond any discussions?
12
Other than him and I hiring people to kind of
13
14
15
get it started up, no.

Q
And did Ken Jenne have any role in your
illegal activities?
16
No, sir.
17
Other than, perhaps, that one occasion where
18
he carried boxes -- the Epstein boxes into your office
19
that people are claiming that he did?
20
21
22
No, sir.
MR. RABIN:
He had no involvement.
I'm going to cede the balance
of my time to Mr. Rasco.
23
24
25

(954) 525- 2221
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2
3

BY MR. RASCO:
Q
I have three or five minutes, Mr. Rothstein.
Is it your opinion or belief that Mr. Preve
was aware of the fraud, or do you know it for a fact?
6
7
8
MR. SCHERER:
A
11
12
Based upon everything that I've seen and know,
it is a fact.
9
10
Object to form.
MR. SCHERER:
Withdraw my objection.
BY MR. RASCO:
Q
Based on any witnesses that you can point to
that are aware that Mr. Preve knew of the fraud?
13
Mr. Szafranski.
14
Beyond Mr. Szafranski?
15
Mr. Boden, Mr. Rosenfeldt.
16
Is that it?
17
And me.
18
Okay.
Do you remember the email we discussed
19
on Monday where you indicated that, Frank, you were
20
ending it; and he suggested that that was not the
21
solution and he urged you to come back and told you not
22
to run.
23
like, analogous before and asked you to come back.
24
25
He told you that he had been through something,
Do you remember that?

A
Yes, I do.

(954) 525- 2221
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2
If he was criminally involved, why would he do
that?
You'd have to ask him.
Okay.
And you indicated earlier today that
there were literally hundreds of incriminating emails
between -- written by Frank; is that right?
I think there were thousands.
Okay.
I haven't stopped to count them, but there
10
11
12
seemed to be an awful lot.

Q
would he write so many emails that were incriminating?
13
14
If he was aware and involved in the crime, why
ALL PRESENT:
A
Objection to form.
I told Frank on more than one occasion that I
15
thought he was going a little crazy with certain things
16
he was putting in the emails.
It never stopped him.
17
You'd have to ask him why he was doing it.
18
It seemed to me like he had some sort of
19
self-destructive mechanism because he put a lot of very
20
bad stuff in emails.
21
BY MR. RASCO:
22
23
Earlier in your testimony you thought Frank
was a very smart person.
24
Extremely.
25
If he was so smart, why would he be writing so

(954) 525- 2221
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many incriminating emails?
2
3
MR. LICHTMAN:
A
Object to form.
I don't know.
One thing I have learned over the course of
this crime, and since coming back, is that I had the
unfortunate experience of dealing with a lot of
extremely, extremely bright people who did some very,
very stupid things during the commission of a lot of
very bad crimes.
10
11
12
BY MR. RASCO:
Q
You met Frank in August of 2007,
approximately, right?
13
I don't recall when I met him.
14
Was it mid to late 2007, let's say?
15
Again, I don't recall the date I met him.
16
you have got to do is look and see when I started to
17
doing my very first business with George Levin and go
18
back 30 to 60 days.
19
frame.
20
me guess to it.
All
21
22
years?
23
I would have met him in that time
We can establish it.
It makes no sense to have
Are you aware that he had known George for 30
I knew that he worked for George many years
24
before.
25
George, yes.
I knew that he left and came back to work for

(954) 525- 2221
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2
And are you aware that he was friends with
George, not just working with George?
You know, I have, unfortunately, learned that
the word "friend" has a very interesting meaning in
criminal circles.
So, yeah, I believed that he was truly a
friend of George's; but the more I examine everything,
the more I come to realize he probably took tremendous
advantage of George.
10
And are you aware that he, himself, invested
11
his own money and his family's money, not just his
12
immediate family's money?
13
Yes.
14
And you knew that he knew that George stood to
15
lose hundreds of millions of dollars if this was a
16
fraud?
17
Yes, but his ultimate role was the same as all
18
of ours, just the like Morses and other people, that we
19
all hoped to get our money out.
20
The criminals, the people that are involved,
21
always hope to be able to be the ones recouping and, in
22
fact, gaining by the crime.
23
you know it could explode, you don't necessarily plan on
24
it.
25
MR. RASCO:
Okay.
You don't -- even though
Thank you.
No further

(954) 525- 2221
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2
questions.
MR. LICHTMAN:
Why don't we then consider
the transcript closed, except for Mr. Nurik's.
examination?
MR. SCHERER:
And except for my request
to keep it open for the Pearson part of your
examination and the cross because I may need
it in my case.
9
10
MR. LICHTMAN:
Agreed.
MR. HERTZBERG:
I just want to note on
11
the record that the funds are relying on the
12
Court's order that the deposition --
13
(Court reporter interruption.)
14
MR. HERTZBERG:
The funds are relying on
15
the Court's ordered that the deposition is
16
concluded as of 1:00 p.m. today.
17
will not have representation for any further
18
examination of Mr. Rothstein in reliance on
19
that order.
20
questions asked by Mr. Nurik and reserve them
21
as such.
The funds
We object to the form of all
22
That's all.
23
(Thereupon, at 12:00 a.m., the proceedings
24
25
Thank you.
were adjourned.)
-

(954) 525- 2221
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(954) 525- 2221
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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 22nd day of December, 2011.
10
11
______________________________
12
Michele L. Savoy, RPR

Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
13
14
15
16
17
18
19
20
21
22
23
24
25

(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 2345 to 2517,
inclusive, are a true and correct transcription of
my shorthand notes of said deposition.
10
I further certify that I am not an
11
attorney or counsel of any of the parties, nor am I
12
a relative or employee of any attorney or counsel or
13
party connected with the action, nor am I
14
financially interested in the action.
15
The foregoing certification of this
16
transcript does not apply to any reproduction of the
17
same by any means unless under the direct control
18
and/or direction of the certifying reporter.
19
Dated this 22nd day of December, 2011.
20
21
22
23
___________________________________
Michele L. Savoy, RPR
Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
24
25

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abide (1)
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Page 16
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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR

DAY 9 - MORNING SESSION

December 22, 2011

Examination of the witness taken before:

United Reporting, Inc.

IN THE CIRCUIT COURT OF THE 17TH

EDWARD J. MORSE and CAROL A. MORSE,

SCOTT W. ROTHSTEIN, et al.,

AMY ADAMS, et. al,

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

10-03767-RBR Stettin v. Gibraltar Private

10-03802-RBR Stettin v. Centurion Structured

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

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

11-02473-RBR Stettin v. Regent Capital

11-02604-RBR Stettin v. Maple Leaf Drilling

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

United Reporting, Inc.

(Counsel appearing on the foregoing appearance pages

APPEARANCES FOR SCOTT ROTHSTEIN:

APPEARANCES FOR THE CHAPTER 11 TRUSTEE,

APPEARANCES FOR RAZORBACK:

United Reporting, Inc.

APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

GOLDSTEIN, TANEN & TRENCH, P.A.

APPEARANCES FOR THE COMMITTEE OF

APPEARANCES FOR TD BANK:

APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

United Reporting, Inc.

APPEARANCES FOR FEDERAL INSURANCE COMPANY:

ALEX HOFRICHTER, P.A

APPEARANCES FOR MORSES:

TRIPP SCOTT, P.A.

APPEARANCES FOR EMESS CAPITAL, LLC:

APPEARANCES FOR ST. PAUL FIRE & MARINE:

APPEARANCES FOR ROSANNE CARETSKY:

United Reporting, Inc.

APPEARANCES FOR PLATINUM & CENTURION:

APPEARANCES FOR MURRAY HUBERFELD, DAVID BODNER & MARK

HARVEY WERBLOWSKY, ESQUIRE

NYSTROM, BECKMAN & PARIS

STEARNS WEAVER MILLER, et al.

APPEARANCES FOR FRANK PREVE:

United Reporting, Inc.

APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

APPEARANCES FOR THE US GOVERNMENT:

SCHLESINGER AND COTZEN, P.L.

United Reporting, Inc.

CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

PREVE'S EXHIBIT INDEX

United Reporting, Inc.

Thereupon, the following proceedings were had:

You represent who again?

I represent Frank Preve.

I'm just going to put an objection on the

On behalf of Emess Capital, as to not

being permitted time in this deposition to

depose Mr. Rothstein, I object to the counsel

for the trustee's violation of the protocol

orders, an order permitting Emess to depose

Mr. Rothstein at this deposition by trying to

shut us out of the deposition.

THE COURT REPORTER: