2011-12-16 Rothstein Scott AM
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Transcript of 2011-12-16 Rothstein Scott AM
c0b92300-38eb-4196-9c0f-58abe77bb0aa
(954) 525- 2221United Reporting, Inc.
IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA
Case No. 09-062943 (07)
_____________________________________________________
RAZORBACK FUNDING, LLC, et al.,
Plaintiffs,
vs.
SCOTT W. ROTHSTEIN, et al.,
Defendants.
____________________________________________________
DAY 5 - MORNING SESSION
DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN: December 16, 2011 TIME: 8:36 a.m. - 10:54 a.m. PLACE: James Lawrence King Federal Justice Building 99 N.E. Fourth Street Courtroom 11-3 Miami, Florida 33128
Examination of the witness taken before: Michele L. Savoy, Registered Professional Reporter United Reporting, Inc. 1218 S.E. Third Avenue Fort Lauderdale, Florida 33316 (954) 525-2221
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1 IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND FOR
2 BROWARD COUNTY, FLORIDA
3 ____________________________________________________
4 Case No. 10-24110 CACE (19)
5 EDWARD J. MORSE and CAROL A. MORSE,and MORSE OPERATIONS, INC.
6 Plaintiffs,
7vs.
8
9 SCOTT W. ROTHSTEIN, et al.,
10 Defendants.
11 _____________________________________________________
12 Case No. 11-CV-61688-JIC/LSS
13 AMY ADAMS, et. al,
14 Plaintiffs,
15 vs.
16 SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTARPRIVATE BANK AND TRUST COMPANY,
17 Defendants.
18 _____________________________________________________
19 10-03767-RBR Stettin v. Gibraltar Private Bank & Trust Co.
2011-03802-RBR Stettin v. Fidelity Gift Fund
2111-02368-RBR Stettin v. TD Bank, N.A.
22
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1 APPEARANCES FOR SCOTT ROTHSTEIN:
2 LAW OFFICE OF MARC S. NURIK 1 East Broward Boulevard
3 Suite 700 Fort Lauderdale, Florida 33301
4 BY: MARC S. NURIK, ESQUIREAPPEARANCES FOR THE TRUSTEE:
5 BERGER SINGERMAN 350 East Las Olas Boulevard
6 Suite 1000 Fort Lauderdale, Florida 33301
7 BY: CHARLES H. LICHTMAN,, ESQUIREAPPEARANCES FOR THE TRUSTEE:
8 GENOVESE, JOBLOVE & BATTISTA, P.A. 100 S.E. 2nd Street
9 Suite 4400 Miami, Florida 33131
10 By: JOHN. H. GENOVESE, ESQUIRE DAVID C. CIMO, ESQUIRE
11 THERESA M.B. VAN VLIET, ESQUIREAPPEARANCES FOR RAZORBACK:
12 CONRAD & SCHERER, LLP 633 South Federal Highway
13 Eighth Floor Fort Lauderdale, Florida 33302
14 By: WILLIAM R. SCHERER, ESQUIRE REID A. COCALIS, ESQUIRE
15 IVAN J. KOPAS, ESQUIREAPPEARANCES FOR RAZORBACK:
16 KOZYAK, TROPIN & THROCKMORTON, P.A. 2525 Ponce de Leon Boulevard
17 Ninth Floor Coral Gables, Florida 33134
18 By: ADAM MOSKOWITZ, ESQUIRE
19ON BEHALF OF PLATINUM PARTNERS VALUE ARBITRAGE
20 Centurion Structured Growth, LLC
21 GOLDSTEIN, TANEN & TRENCH, P.A. One Biscayne Tower, Suite 3700
22 Two South Biscayne Boulevard Miami, Florida 33131
23 By: SUSAN E. TRENCH, ESQUIRE
24
25
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1 APPEARANCES FOR LEVINSON'S JEWELERS: KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL
2 200 SW 1st Ave Suite 1200
3 Fort Lauderdale, Florida 333012073 BY: JAN ATLAS, ESQUIRE
4 APPEARANCES FOR THE COMMITTEE OF UNSECURED: AKERMAN, SENTERFITT
5 One Southeast Third Avenue 25th Floor
6 Miami, Florida 33131-1704 By: MICHAEL GOLDBERG, ESQUIRE
7
8 APPEARANCES FOR T.D. BANK:
9 GREENBERG TRAURIG, P.A. 401 E Las Olas Blvd Ste 2000
10 Fort Lauderdale, Florida 33301 By: DONNA EVANS, ESQUIRE
11APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,
12 COLUMBIA INC. & ZURICH INSURANCE:
13 CLAUSIN MILLER One Chase Manhattan Plaza
14 39th Floor New York, New York 10005
15 BY: SCOTT L. SCHMOOKLER, ESQUIRE
16 APPEARANCES FOR FEDERAL INSURANCE COMPANY:
17 ALEX HOFRICHTER, P.A 1430 South Dixie Highway
18 Suite 204 Coral Gables, Florida 331463127
19 By: ALEX HOFRICHTER, ESQUIRE
20 APPEARANCES FOR MORSE:
21 TRIPP SCOTT, P.A. 110 S.E. Sixth Street,15th Floor
22 Fort Lauderdale, Florida 33301 By: GEORGE WALKER, ESQUIRE
23 JOHN M. MULLIN, ESQUIRE
24
25
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1 APPEARANCES FOR EMESS CAPITAL, LLC:
2 KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL 201 S Biscayne Blvd Fl 17
3 Miami, Florida 331314 BY: CASEY H. CUSICK, ESQUIRE
4 APPEARANCES FOR ST. PAUL FIRE & MARINE:
5 MILLS PASKERT DIVERS P.A. 100 N Tampa St Ste 2010
6 Tampa, Florida 336025145 JOHN A. BLACK, JR., ESQUIRE
7 APPEARANCES FOR THE DEFENDANT:
8 ROSEANNE CARETSKY
9 Billing Cochran Lyles 515 E Las Olas Blvd
10 Floor Six Fort Lauderdale, Florida 333012296
11 By: W. TUCKER CRAIG, ESQUIRE
12 APPEARANCES FOR THE DEFENDANT: FRANK SPINOSA
13 SCHLESINGER AND COTZEN, P.L.
14 799 Brickell Plz Ste 700 Miami, Florida 33131
15 BY: MICHAEL J. SCHLESINGER, ESQUIRE
16
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1 INDEX
2 CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN
3 DIRECT FURTHER DIRECT
4 Mr. Scherer 1133Mr. Lichtman 1222
5 Mr. Rabin 1224
6 CERTIFICATE OF OATH 1250CETIFICATE OF REPORTER 1251
7
8 PLAINTIFF'S EXHIBITS INDEX
9 NO. DESCRIPTION PAGE NO168 Metadata and Email Trail 1147
10 169 Emails and Deal Documents 1159170 Exhibit to the Complaint 1168
11 171 Multiple Emails 1217
12 DEFENDANT'S EXHIBITS INDEXNO. DESCRIPTION PAGE NO
13 172 October 31, 2009, Email 1236
14
15
16
17
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21
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1 Thereupon, the following proceedings were had:
2 FURTHER DIRECT EXAMINATION
3 BY MR. SCHERER:
4 Q Good morning, Mr. Rothstein.
5 A Good morning.
6 Q I'm continuing on with my direct examination.
7 We bring it up here because of the way we have tried to
8 divide our time. I have got some time this morning, and
9 I'm going to try to be efficient. It's going to be sort
10 of in the nature of a redirect, a little bit, because I
11 don't know --
12 A Okay.
13 Q -- I don't know if I have any time to redirect
14 next week, and that is also just a little bit of direct
15 examination.
16 If you don't mind -- well, we might as well go
17 through the drill: You know you're still under oath?
18 A I do.
19 Q All right. And I would like this to kind of
20 be a lightning round. I would like you to keep your
21 answers as brief as possible, consistent with you
22 telling the truth, of course.
23 A Okay.
24 Q Obviously, if you want to explain, you can
25 explain, but these questions are kind of like follow-up
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1 questions. I'm going to try not to re-cover things that
2 have been covered before or multiple times before.
3 A Okay.
4 Q You know, I don't know if you have a TV where
5 you are. Do they let you watch FOX news, you know, how
6 they do the lightning round?
7 A I actually have a group of dancers in there --
8 please don't put that on the record.
9 Q I was going to say, if you watch FOX news --
10 Lichtman doesn't watch it, so he wouldn't know what I'm
11 talking about, but I am going to get you the question
12 and you get the answer back so we get a lot of
13 information out. Okay?
14 A I have got that. I watch one of the sports
15 channels, so I'm good to go.
16 Q Unlike MSNBC where Lichtman watches, they kind
17 of go a little slow and move along.
18 MR. KOPAS: They get caught up on the
19 truth there.
20 BY MR. SCHERER:
21 Q By the way, from time to time, you know, we
22 have kidded around, like right now, and it looks like
23 each and every time --
24 MR. LICHTMAN: You weren't serious?
25 MR. SCHERER: Right.
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1 BY MR. SCHERER:
2 Q Each and every time, you appear to have
3 laughed, and did you take offense at any of the little
4 small chit-chat that has gone on here?
5 A Not at all.
6 Q Okay. And did any of it in any way interfere
7 with you telling it the way you remember it?
8 A Not at all, Mr. Scherer.
9 Q All right. Thanks.
10 So, and it hasn't affected your testimony in
11 any way, I don't think?
12 A Not in the least, not at all.
13 Q You were questioned by Ms. Morse's counsel
14 about my motion to get the court -- a bankruptcy court
15 to pay Mr. Nurik for his work in this deposition as a
16 court cost.
17 Do you remember her questions -- I started to
18 say her testimony -- but her questioning you about that?
19 A Yes, sir.
20 MR. NURIK: It was almost testimonial.
21 BY MR. SCHERER:
22 Q Is the fact that I filed that, is that
23 influencing your testimony here --
24 A Not at all.
25 Q -- in favor of my clients?
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1 A Not at all.
2 Q Why not?
3 A Because I'm not bargaining my life with
4 anything. Okay? I have a -- promised the government I
5 would be here. I promised the government I would tell
6 the truth. I promised the government I would not hide
7 anything and I have not been promised anything in
8 exchange for that, at all.
9 Q So you wouldn't risk a Rule 35 situation that
10 may be in the cards for you by trying to help my clients
11 recover?
12 A No, not -- not at all. There is no reason to.
13 The people that did bad things, did bad things, and
14 that's what they did.
15 Q One last thing on getting Mr. Nurik paid, if
16 that ultimately happens -- and I asked you this, but I
17 would like to reiterate it again -- by the way,
18 Mr. Nurik has been with you from the beginning, as I
19 recall?
20 A From before my return from Morocco, yes.
21 Q And he had something to do with you coming
22 back, I think?
23 A Yes.
24 Q I mean, you obviously made the decision, but
25 he helped you --
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1 A But he was --
2 Q -- make that?
3 A He was instrumental in counselling me and
4 guiding me through a very, very tough period of time.
5 Q And he has continued to be with you when you
6 have been questioned and when you have been involved in
7 this process for the last two years?
8 A Yes.
9 Q Knows a lot about the case?
10 A Yes.
11 Q You talk to him frequently?
12 A Yes.
13 Q If he wasn't here, would you be testifying?
14 A No, sir.
15 Q Thanks.
16 MR. SCHLESINGER: Just note my objection
17 to that question. Mr. Rothstein already
18 testified with Mr. Nurik not here.
19 BY MR. SCHERER:
20 Q Well, there was a time yesterday when
21 Mr. Nurik was in court on another matter, and you did
22 testify for the Trustee's questions for a few hours,
23 correct?
24 A That's correct.
25 Q Would you have given a -- this deposition to
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1 me, and to the other people here who want to know your
2 story, if Mr. Nurik was not available?
3 A I have known some of the lawyers in this room
4 for two decades, okay, but I don't care about how long
5 I've known them; the only reason I testified for
6 Mr. Lichtman, answering his questions when Mr. Nurik was
7 not here, is that I had already spent three full days
8 with him at another undisclosed location, okay, being
9 debriefed pursuant to court order; and I was extremely
10 comfortable that they were not going to attempt to take
11 advantage of me during that time period, that they were
12 going to be fair.
13 I don't know everybody who is going to be
14 questioning me. I don't know what anyone's actual
15 intention is. I'm not going to answer questions of
16 other people, unless Mr. Nurik is with me, just to
17 protect myself -- not even you, Mr. Scherer, and I have
18 known you a long time.
19 Q All right, sir. Thank you.
20 We're going to take your testimony here then.
21 Thanks.
22 I would like to have you focus a little bit on
23 the order that -- the fake order, as we have called
24 it -- and you have talked about it, and you testified
25 about it -- that was entered that you -- you forged
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1 Judge Marra's signature on this order that you concocted
2 or drafted.
3 A Okay. The Marra order, yes.
4 Q The Marra order.
5 And in that order, essentially, you ruled that
6 the Morses are entitled to $23 million, I think:
7 21 million, punitive damages, and a million dollars,
8 compensatory; or maybe 2 million compensatory and
9 21 million punitive?
10 A I believe that's correct, sir, yes.
11 Q And you also discussed that there was
12 $10 million that you had -- your firm had found through
13 investigators in various bank accounts for Jan Jones in
14 the United States, in South Florida; is that right?
15 A That sounds correct, yes.
16 Q And $20 million in the Cayman Islands, I
17 think, was in that order?
18 A There was money referenced about us finding
19 money in the Cayman Islands, yes, sir.
20 Q And was there a -- did you have any telephone
21 call hearings, fake telephone call hearings with --
22 allegedly with Judge Marra leading up to the entry of
23 that order?
24 A Yes, sir.
25 MR. MULLINS: Can I just raise -- I don't
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1 want to interrupt you too often, Mr. Scherer;
2 but I just want to make sure that I am
3 asserting a standing, continuing objection to
4 questions that you're asking about the Morses,
5 about Ted Morse.
6 You do not have a pending case that has
7 been noticed in this deposition in which you
8 have a protocol order allowing to you take
9 that deposition; and the fact that I asked
10 questions of the depo that I properly got
11 permission for, I don't think gives you an
12 opportunity to redirect on the Morses.
13 So, I don't want to interrupt you all
14 day, but I want it to be clear that we have a
15 continuing objection to this line of
16 questioning; and we're going to move to strike
17 it, and we're going to certainly oppose it
18 being used in any new case that you have not
19 been given permission to question the witness
20 on.
21 MR. SCHERER: Thank you.
22 BY MR. SCHERER:
23 Q I believe counsel for Morse testified --
24 examined you yesterday about that -- about that Judge
25 Marra order.
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1 You remember that?
2 A Yes, two different attorneys did. Yes.
3 Q I don't think they asked you about whether or
4 not there were any fake hearings, telephone hearings,
5 that preceded the entry of that fake order that -- the
6 drafting of that fake order.
7 MR. MULLINS: Object to the form.
8 A I don't know that they asked me, but somebody
9 questioning me yesterday at the hearings did come up,
10 briefly, at some point in time. At some point in time
11 it did.
12 BY MR. SCHERER:
13 Q And the hearings where they -- tell us about
14 the hearings.
15 A Okay. At various points in time during the --
16 what's called the "fake proceedings," leading up to and
17 probably subsequent to those orders, there were multiple
18 telephone hearings where Ed Morse, Ted Morse, myself,
19 and someone playing the Judge Marra was on the telephone
20 pretending to conduct a hearing, actually questioning
21 Mr. Ed Morse with Mr. Ted Morse on the phone, with me on
22 the phone, me actually making argument, and the fake
23 Judge Marra actually ruling.
24 Q And who was -- was there an actual person that
25 played like Judge Marra?
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1 A Yes, sir.
2 Q And who was that?
3 A An attorney with my firm, Scott Goldstein.
4 Q And did anybody on the phone on the Morse side
5 know that Mr. Goldstein was acting, pretending to be
6 Judge Marra?
7 A Yes.
8 MR. MULLINS: Object to the form.
9 BY MR. SCHERER:
10 Q And who was that?
11 MR. SCHERER: Well, excuse me, what's the
12 objectionable about that?
13 MR. MULLINS: You're asking him what
14 other people knew. You're calling for
15 speculation.
16 BY MR. SCHERER:
17 Q Okay. Do you have any information that
18 anybody on the phone -- I mean, obviously Mr. Goldstein
19 knew he wasn't Judge Marra, right?
20 A Yes.
21 Q Okay. And you knew it was a fake hearing,
22 right?
23 A Yes.
24 Q You set it up?
25 A I did.
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1 Q And you said Ted Morse was on each of those
2 calls?
3 A He was.
4 Q And do you know whether Ted knew that it was a
5 fake hearing?
6 A I do know.
7 Q All right. And how do you know that?
8 A Okay. Ted knew it was fake for several
9 reasons. One, I told him what was going to go on.
10 Number two -- and I had a specific reason for
11 telling him what was going on, because Ted -- anyone who
12 does business with Ted knows, he is a bulldog. When he
13 really needs information about something, thinks
14 something is going sideways that could affect him or his
15 family, he is a bulldog, and I needed to make sure he
16 laid back.
17 The second thing was -- and more than one
18 person saw this -- Ted knew Scott Goldstein. He had
19 spoken to him many times before. Scott used to come
20 down from time to time and sit outside with us outside
21 Bova and smoke cigars with us.
22 On more than several occasions, as Scott
23 Goldstein was approaching us, Ted would take his cigar
24 out of his mouth and say, oh, here comes the judge now.
25 Here comes Judge Goldstein -- I mean, Judge Marra.
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1 Q I would like to talk to you about the 11th
2 Circuit Court of Appeals order, fraudulent, that was
3 entered and drafted by you; and there seemed to be some
4 confusion yesterday about that, about that order.
5 A Mr. Scherer, one other important point on the
6 fake hearings --
7 Q Sure. Do you have another important point on
8 the fake hearing?
9 A I do.
10 Q Okay. I would like to hear it. What is it?
11 MR. MULLINS: Objection to form.
12 BY MR. SCHERER:
13 Q Wait a minute. He's objected to form. Let me
14 start off again.
15 Did we cover everything that was important on
16 the fake hearings or on Judge Marra?
17 A No. There was another hearing or two where
18 Mr. Goldstein also pretended to be a circuit court judge
19 in the actual case filed in circuit court on behalf of
20 the Morses. I just wanted to make sure the record is
21 clear.
22 Q And I think you might have said, and I may
23 have missed it, that there were some other people that
24 were aware of this fake hearing, phone hearing, other
25 than the people that we mentioned?
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1 A Well, the people who were sitting around with
2 us at the time, I'm sure, would have heard Ted saying
3 that, because he wasn't bashful about it.
4 Q Do you have any recollection of any people
5 that were around you that may have overheard that?
6 A No. I have to think about who was actually
7 there during that time period. It would have been our
8 regular group of friends that I mentioned earlier.
9 Q Okay. Do you recall how many of these fake
10 telephone hearings were conducted?
11 A I would say between four and seven, eight,
12 something to that effect.
13 Q And would they have all been before the date
14 of the Marra order?
15 A Most likely, but I can't be certain that we
16 didn't have some afterwards. I know the circuit court
17 one was before the Marra order because it was before I
18 allegedly have the case elevated to federal court.
19 Q And then you had the case elevated to the
20 court of appeal, and there was some testimony about that
21 yesterday?
22 A Yes, sir.
23 Q There seemed to be a little bit of confusion
24 about when that fake Judge Black order was prepared. Do
25 you recall the confusion?
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1 A Yes.
2 Q As I understand -- and it's in the document
3 there -- that the document bore a date of August
4 something?
5 A Correct.
6 Q And there was some email forwarding it to the
7 Morses in October?
8 A Correct.
9 Q And you said you didn't know exactly when you
10 did that order, couldn't remember?
11 A I don't, without seeing the email traffic and
12 the metadata, I have no way of remembering that.
13 Q Let's see if we can't show you the metadata.
14 Well, let me ask this: Would it refresh your
15 recollection to remind you that perhaps you drafted that
16 order on the eighth of September, the same day you did
17 the Seltzer order?
18 MR. MULLINS: Objection, form.
19 A That certainly is possible.
20 BY MR. SCHERER:
21 Q I mean, were you in the fake-order-drafting
22 mode on the 8th, correct?
23 MR. MULLINS: Objection.
24 A Yes, I was.
25
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1 BY MR. SCHERER:
2 Q According your testimony, you were drawing the
3 Seltzer order on the 8th?
4 A Correct.
5 Q Okay. And there is quite a bit in the record
6 on that already.
7 Let me show you the -- what the metadata looks
8 like, and we'll mark that as our next --
9 MR. KOPAS: Plaintiff's 168 is the
10 printout of the metadata from the fake 11th
11 Circuit court order. There is no Bates
12 stamped number on that. It's a composite
13 exhibit, also with an email trail from
14 September 8th, 2009, Bates labeled Rothstein
15 1180 to 1182.
16 And I have copies for counsel.
17 (Thereupon, the document was marked as
18 Plaintiff's Exhibit No. 168 for Identification.)
19 BY MR. SCHERER:
20 Q Have you ever seen what the metadata looks
21 like from your computer before?
22 A No. The only time I saw it was the other day
23 in here when somebody showed me some.
24 Q Yeah. Okay.
25 You can see the document that's got the 11th
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1 Circuit order data on it, and you have got the related
2 dates, and it shows when it was last modified, when it
3 was created, last printed.
4 Do you see that?
5 A I do.
6 Q And go ahead and tell us when was it created
7 and when was it modified and when it was printed?
8 A It was created at 8:21 a.m. on September 8th,
9 2009. It was modified on September 8th, 2009, and 10:13
10 a.m.; and it was last printed on September 18, 2009 at
11 10:13 a.m., right after the modification, apparently.
12 Q Okay. And the -- do you know when -- can you
13 recall when Ted Morse came into your office that
14 morning?
15 A Yeah, it was around 10:00 or so. Ted was
16 always on time for everything, so I -- someone sent me
17 an email saying he's here.
18 Q Yeah, there was an email that said Ted's here.
19 I think we put that in the record, at 10:00.
20 Do you have a recollection of whether Ted --
21 whether you shared the Judge Black recently-created
22 order with Ted when he was in your office?
23 It looks like you printed it after he was
24 there, 10:13; he arrived at 10:00.
25 A My recollection, Mr. Scherer, is that I gave
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1 it to him while we were sitting in my office just to
2 read.
3 Q Now, there was a little questioning -- there
4 was some questioning yesterday concerning when you
5 started drawing the Judge Seltzer order and the exact
6 order of what you did that day.
7 A Yes.
8 Q But let me -- before I ask that, was this
9 Judge Black court of appeals, 11th Circuit Court of
10 Appeals order that you forged on the 8th, the same day
11 that you forged the Seltzer order in response to Carol's
12 email, Carol Morse's email to you of a couple of days
13 before, that asked for the orders in a threatening tone?
14 A Yes.
15 MR. MULLINS: Object to the form.
16 BY MR. SCHERER:
17 Q What was this order -- why was this court of
18 appeals order done on the 8th of September?
19 A Because I was in a panic over Carol creeping
20 around, looking to try to figure out what I was actually
21 doing.
22 Q Yeah, and I think you testified, but I'll ask
23 you again, you received that email from her, and you got
24 the impression that she don't draw -- write that thing
25 by herself, correct?
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1 A That's correct. I already knew that she had
2 been talking to her sister-in-law extensively about
3 this. So it was clear to me that someone else had
4 involvement, and it appeared to me to be a lawyer.
5 Q Well, it was kind of drafted like a lawyer
6 would draft an order?
7 A It had language in it that I hadn't
8 particularly seen in Mrs. Morse's prior emails.
9 Q From her behavior from that point, on, did you
10 have the belief, at that time, that she had a legal
11 counsel that was advising her?
12 A I did.
13 MR. MULLINS: Objection. Asked and
14 answered.
15 BY MR. SCHERER:
16 Q Okay. Did you ever discuss that with Ted
17 during that period of time from September the 6th, when
18 you received her threatening email, to the crash at the
19 end of October, that you thought Carol might have a
20 lawyer?
21 A Yes.
22 Q And would you describe your concern about her
23 having a lawyer?
24 A Yes. I told -- I called Ted immediately after
25 getting the email. I asked him -- I'll save you the
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1 language. I asked him what the "F" was going on. I
2 said, she is all over me. We need to do something to
3 stop this. You need to talk to your dad. You need to
4 quell the situation. I can't function like this. She's
5 going to blow this whole thing up, and we're all going
6 down over it.
7 Q So would that have been one of those mutual
8 destruction talks that you talked about here in the
9 last --
10 A DOMAD. Yes. Ted knew what that was, the
11 doctrine of mutually assured destruction.
12 Q DOMAD. All right.
13 So, you had one of those kind of talks with
14 Ted?
15 A Yes.
16 Q Do you recall telling Ted that you thought she
17 had a lawyer?
18 A Yes.
19 Q Okay. Did you ask him who that lawyer might
20 be?
21 A No. He told me -- he said she probably does.
22 He kept telling me, she's driving my father crazy. She
23 is going to end up killing him. This whole thing is
24 getting out of hand. I'll see what I can do. She's
25 getting out of control. Even Ed can't control her
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1 anymore.
2 Q Well, did you have any discussions with Ted
3 about what it would take to prevent Carol and her lawyer
4 from blowing the whistle on your Ponzi scheme? Was
5 there any discussion about that?
6 MR. LAVECCHIO: I have to assert an
7 objection -- Larry LaVecchio on behalf of the
8 government. I have to assert a government
9 investigator privilege at this point.
10 MR. SCHERER: All right. Okay.
11 Let me see if I can -- I'll honor the
12 privilege, certainly, but let me see if I can
13 get around it a little bit.
14 MR. LAVECCHIO: It's a
15 question-by-question issue.
16 MR. SCHERER: Yes, sir. I understand how
17 it works. It's not my first rodeo.
18 BY MR. SCHERER:
19 Q Mr. Rothstein?
20 A Yes, sir.
21 Q If Carol Morse had blown the whistle on you at
22 that point, do you think the Ponzi scheme could have
23 continued?
24 MR. MULLINS: Objection.
25 A Absolutely not.
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1 BY MR. SCHERER:
2 Q And why do you say that?
3 A Because she was one of the lynch pins based
4 upon the fake court orders, the sheer amount of money
5 that I had stolen from Ed and Carol, the amount of
6 focused fraud I had levied in their direction, it just
7 would have -- the whole entire thing would have come
8 tumbling down; and I knew it and so did Ted.
9 Q Well, obviously it didn't come tumbling down
10 until the end of October, correct?
11 A Correct.
12 Q My clients put maybe $100 million into the
13 Ponzi scheme between September 6th and the end of
14 October.
15 A That's correct.
16 Q And --
17 A They did.
18 Q And the financial records show -- well, let me
19 ask this: Do you know how much the Morses received --
20 the Morse operation and Ed and Carol on the phony bond
21 repayment during that last two months or so before the
22 crash of the Ponzi.
23 A I believe I gave them just shy of half their
24 money back, $25 million.
25 Q That's okay. That's right.
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1 And they had an expectation of the phony
2 bond -- of the phony judgment recovery, plus the
3 interest on the bonds, plus some profit on the deals, of
4 about another 25 to 30 million; is that your
5 recollection?
6 A Correct. Yes, sir.
7 MR. MULLINS: Objection, form.
8 BY MR. SCHERER:
9 Q What is your recollection of what their
10 expectation was in addition to getting their money back?
11 MR. MULLINS: Objection.
12 A Ed and Carol had an expectation, as did Ted,
13 that I would repay all of the bond money back; and Ted
14 expected me to be able to not only repay the bond money
15 back, but to repay all the deals with interest.
16 BY MR. SCHERER:
17 Q Okay.
18 A And because of my relationship with Ted, I
19 will tell you that it was absolutely my goal at that
20 point in time to do everything I could to make sure
21 that, at the least, Ed and Carol were made completely
22 whole and hopefully I would be able to get Ted all his
23 interest.
24 Q Well, then he had a $23 million phony
25 judgment. Was it your intention to pay him that, if you
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1 had the money?
2 A Absolutely.
3 Q So that his expectation would have been some
4 25 to 30 million more from September to the end of
5 October?
6 MR. MULLINS: Object to the form.
7 A At that stage of the Ponzi scheme, in order to
8 keep it from blowing up, I would have had to continue to
9 make all the payments to everybody.
10 As you know, from reviewing the history, as it
11 got closer and closer to blowing up, I focused the
12 payments towards the people that I wanted to make sure
13 were made whole.
14 BY MR. SCHERER:
15 Q And were the Morses in that group of people
16 you wanted to make whole?
17 A They were at the top of the list.
18 Q And Mr. Von Allmen, my client was at the
19 bottom?
20 A That's correct, Mr. Scherer.
21 Q Any reason that he was at the bottom?
22 A He was not anywhere near my best friend. He
23 was to me, an acquaintance, who was certainly becoming a
24 friend; but he was an acquaintance, and I viewed him as
25 someone who was extremely wealthy who could withstand
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1 the loss.
2 Q I would ask during that time frame, from
3 September the 6th, when Carol Morse wrote you that
4 disturbing email, until the crash, did she continue to
5 press you for repayment?
6 A You know, I don't have an independent
7 recollection. You'd have to show me emails. I mean,
8 every -- during that period of time, I can tell you I
9 was getting continuing pressure from the Morses to get
10 as much money to them as possible.
11 Q And you were doing that?
12 A I was. I believe I was sending them money
13 right up to the last minute.
14 Q So, their silence in not blowing the whistle
15 on the Ponzi scheme benefited them in the money that
16 they got back between September the 6th and the end
17 of -- and the crash, correct?
18 MR. MULLINS: Objection to form.
19 A Of course it did.
20 MR. SCHERER: What's wrong with the form?
21 MR. MULLINS: You're assuming that the
22 Morses all knew about the Ponzi scheme and
23 kept silent about it. Assumes facts not in
24 evidence.
25 BY MR. SCHERER:
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1 Q Well, did the Morses know about the Ponzi
2 scheme?
3 A Ted did, and Carol certainly suspected it -- I
4 don't know that she suspected it was a Ponzi scheme, but
5 she certainly suspected that I was stealing her money
6 and committing fraud.
7 Q And, so, rather than blow the whistle on what
8 she suspected, what did she do?
9 A She continued to receive money from me.
10 Q Now, you know that my clients, Razorback and
11 D3, put approximately 50 million in the Ponzi Scheme in
12 October. Those are the dates of Razorback and D3?
13 A Right. They were at the very end of the Ponzi
14 scheme, correct.
15 Q Right. 50 million in and Mr. Sochet was
16 putting money in at the same time; do you recall that?
17 A He was, sir.
18 Q So, the 100 million that I represent that my
19 clients had invested in your Ponzi scheme from September
20 to the end of the crash, I said it was about one-hundred
21 million, plus or minus, you know, millions, I don't
22 know, but a lot of money?
23 A Yes, sir.
24 Q Was any of that money used to repay the Morses
25 back the 20 or 25 million that you paid them back
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1 between September 6th and the crash at the end of
2 October?
3 A Yes, sir.
4 Q Now, I asked you whether Ted Morse knew the
5 settlements were fake, and there was some discussion of
6 that; and I'm asking you again, did Ted Morse know at
7 some point in time that these settlements that you were
8 doing or your settlement business was a fraud?
9 A Yes.
10 MR. MULLINS: Objection, asked and
11 answered.
12 BY MR. SCHERER:
13 Q I'm going to show you some paperwork, I don't
14 think I did that. Do you remember when I examined you
15 about the two deals that Mr. Morse invested in, 700 cash
16 with 300 back and then 700 cash and 300 back by two of
17 the deals twice; do you remember that?
18 A Yes, I recall that.
19 Q And then you recall that when you did the
20 Ponzi paper, as I called it, the settlement paper, that
21 you didn't do two $1 million deals; you did one
22 $2 million deal.
23 Do you remember questions about that?
24 A I do, sir.
25 Q Let me show you those documents and just put
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1 those in the record.
2 MR. KOPAS: All right. Plaintiff's 169
3 is a composite exhibit, four emails relative
4 to four deals in March of 2008, and then deal
5 documents for what are RRA M1 and RRA M2, two
6 deals, no Bates numbers, but these actually
7 were produced before.
8 (Thereupon, the document was marked as
9 Plaintiff's Exhibit No. 169 for Identification.)
10 BY MR. SCHERER:
11 Q Mr. Rothstein, take a look at that. I think
12 those are the documents on the two $700,000 money-in
13 deals with punitive payments of -- no, they weren't
14 punitive they were actual payments of $300,000 profit?
15 A Correct.
16 Q You see that, paid in ten weeks?
17 A I do, sir.
18 Q Okay. And that's on the email traffic back
19 and forth, the email dated Tuesday, March 18th, 2008,
20 right?
21 A Yes, sir.
22 Q Now, I would like you to go -- look at the --
23 what I call the Ponzi paper there or the deal documents
24 that are attached in that composite. Do you see those?
25 That would be RRA M1; I guess that's Morse 1?
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1 A Yes. Morse 1 and Morse 2.
2 Q Okay. Did you combine the two of those
3 settlements into one set of papers?
4 A Yes.
5 Q And that's what these documents represent?
6 A Yes. Neither Ted, nor I, nor Debra was
7 creating -- could have cared less as to what the paper
8 looked like, as long as it passed muster with the
9 auditors.
10 Q Plus Ted knew there were no settlements and
11 this was all fake?
12 MR. MULLINS: Objection to the form.
13 A Yes. Ted asked me to create the paperwork, so
14 absolutely, yes.
15 BY MR. SCHERER:
16 Q But knowing that there was no settlement, that
17 there were no -- or accepting that there were no
18 punitive funds held in trust, you know, the whole spiel,
19 he knew it was a fraud?
20 A Of course. I mean this paperwork was created
21 after he had already started receiving his money, so it
22 must be fake.
23 Q Got it. Thank you.
24 You testified on my direct examination a few
25 days ago that Ted knew that Doug was in -- Doug Von
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1 Allmen was an investor and vice versa; do you remember
2 that testimony?
3 A I do.
4 Q You testified yesterday, or you were
5 questioned yesterday, about whether Ted talked to any of
6 the investors; and you said, yes, Razorback. Then
7 counsel went on to another subject.
8 Let me see if we can explore that a little
9 more.
10 A Okay.
11 Q The question is, did Ted ever talk to any of
12 the Ponzi investors, and your answer is?
13 A Yes.
14 Q And who did he speak with, that you know of,
15 regarding the Ponzi investors?
16 A Of all the Ponzi investors?
17 Q Yes?
18 A Oh, lord, okay.
19 Q Let's start with my clients first and then
20 we'll -- well, let's talk about the Razorback first,
21 because you talked about that yesterday and then didn't
22 follow up on it.
23 A Okay. Ted spoke to Doug Von Allmen. He met
24 and spoke with A.J. Discala. He spoke with Barry
25 Bekkedam. He spoke with Dean Kretschmar. He spoke with
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1 Mike Szafranski. He spoke with -- he didn't speak with
2 Ira Sochet. I don't think he ever met Ira -- oh, he
3 spoke with Barry Damson. That happened at Bova a couple
4 of times.
5 He met with -- he spoke with -- at various
6 points in time all of the hedge fund guys, I think,
7 except for Gil Kalter; and let me see if I can name them
8 so the record is clear for you.
9 He definitely, as I said, spoke with Mike
10 Szfranski. He definitely spoke on multiple occasions
11 with Jack Simony. He spoke with -- I don't believe he
12 spoke with Mr. Nordlicht.
13 Q Ari Glass?
14 A I don't recall him speaking with Mr. Glass.
15 He only actually did speak with Gil Kalter
16 because Gil was a voracious Miami Dolphins fan. In
17 fact, he came from New York -- and Ted is a big Dolphins
18 fan -- and I remember we were all together. It was
19 actually at one of the games that I brought Gil to.
20 Who else? There are -- two of the other
21 investors that are -- were also in the know on the
22 thing. Gary Lipsitz and Domenick Tonacchio, who were
23 early and late investors. He knew them very well.
24 Q And by knowing them, did he know they were
25 investing in the fraud? Did Ted know that the people
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1 that you just identified were investors in the Ponzi
2 scheme?
3 A All of the ones that I mentioned, Ted knew
4 about, yes.
5 Q Did you overhear their discussions? Did they
6 talk about the Ponzi at all or the investments or the
7 settlement investments?
8 A Okay. We never discussed the Ponzi scheme.
9 Q I understand that. That was a bad question.
10 You have already told us that a bunch, and I'll try not
11 to do that.
12 Did he talk about the structured -- the
13 settlement, confidential settlement program?
14 A Let me clarify my statement so this is not
15 misconstrued.
16 When I say we never talked about the Ponzi
17 scheme, I mean that when we are sitting around in a
18 group, like a meeting with me, Domenick and Barry, we
19 didn't say, how is the Ponzi going.
20 Q Right.
21 A Okay. We certainly, individually, frequently
22 talked about the fraud and things that were going on;
23 but that out-loud group thing, that did not occur.
24 So, your question now is?
25 Q Well, my question now is, what -- did Ted also
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1 talk with investors in the confidential settlement
2 program that did not know they were investing in a
3 fraud?
4 A Sure.
5 Q Like some of my clients?
6 A Sure. Ted would say to various people, I told
7 you it was -- it was one of his favorite comments:
8 Scott is -- especially during the downturn of the car
9 business: Scott is our most-profitable car dealership.
10 We're going to give him a sign, you know, the Scott
11 Rothstein -- I'm going to get the award for the
12 most-profitable car dealership.
13 Q Do you have a recollection of him making
14 comments like that, or similar to that, to A.J. Discala
15 and Dean Kretschmar, Doug Von Allmen?
16 A The comments to Doug Von Allmen were not of
17 that nature. The comments -- the conversations, to the
18 best of my recollection, with Doug Von Allmen were very,
19 very simple as to how the investment is going, nothing
20 more complicated than that.
21 Doug is not the -- there was not that kind of
22 jovial thing back and forth between Doug and I and Ted
23 and I.
24 Q How did Ted say the investment was going to
25 Mr. Von Allmen or to my clients, to your knowledge?
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1 A I believe he said that he was very satisfied
2 with it. It was a very -- I recall, only because it was
3 a very business-like answer. It wasn't Ted's normal,
4 you know: He's our most profitable car dealership kind
5 of thing.
6 Q It wouldn't be a flamboyant answer; it would
7 have been a business answer?
8 A It would have been a business answer.
9 Q Because Mr. Von Allmen is more of a
10 business-type man?
11 A Yes. He's extremely proper.
12 Q He is extremely?
13 MR. LAVECCHIO: Proper.
14 A He's extremely proper.
15 In fact, he once wrote me an email, before we
16 were getting ready to talk to some investors on the
17 phone reminding me there was a lady on the phone.
18 I actually wrote him back something to the
19 effect of: Got it, language to be adjusted properly.
20 Q He doesn't use swear words, does he?
21 A No, he doesn't, not -- I have never heard him
22 curse before, no.
23 Q I'm going to get back to the September 6th
24 date, '09, Seltzer order in a minute.
25 A Is that the 6th or the 8th?
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1 Q I'm sorry, the 8th, precipitated by the email
2 of the 6th, the --
3 A Yes.
4 Q -- order on the 8th. Thank you.
5 But we're trying to get some documents.
6 Do we have them?
7 Just give me a second here.
8 A Yes, sir.
9 Q All right. Let me go ahead and try to do this
10 now so we can keep this all in context.
11 On the 8th of September, Mr. Morse is in your
12 office at 10:00 a.m.?
13 A Correct.
14 Q There's an email that says to you, Morse is in
15 reception?
16 A Correct.
17 Q And then you and Mr. Morse -- what did you do
18 when he first got there? Do you have a recollection of
19 what you did before you went to judge -- well, let me
20 see if I can get the broad strokes first and then I'll
21 fill in.
22 A Okay.
23 Q After he arrived at 10:00 a.m., thereafter,
24 you have testified that you went to Judge Seltzer, the
25 two of you, and then you went to Weston to get the
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1 bank -- the phony bank balance. Then you came back to
2 your office.
3 You then talked to Ed on the telephone and
4 said, send me authorization for Ted to testify. And
5 then he sent you authorization for Ted to testify.
6 Then you, at 4:30 in the afternoon, sent Ed
7 and Carol the Seltzer order and there was a phone call
8 at that time where Ted told them about the order and
9 read parts of that to them.
10 Is that a correct restatement of your
11 testimony?
12 A To the best of my recollection, yes, sir.
13 Q Okay. What I want to do is, I want to show
14 you some composite exhibits, and we'll put those in as
15 our next exhibit so that you can refer to them and we
16 can maybe shorten the times, although we don't need to
17 shorten them much.
18 A Okay.
19 MR. KOPAS: Plaintiff's 170 is a
20 composite exhibit, and these are the exhibits
21 to the complaint we filed against the Morses
22 on Tuesday.
23 MR. MULLINS: Objection, move to strike,
24 and asked and answered.
25 (Thereupon, the document was marked as
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1 Plaintiff's Composite Exhibit No. 170 for
2 Identification.)
3 BY MR. SCHERER:
4 Q Well, I don't mean to -- if it's been asked
5 and answered, Mr. Rothstein, you just say that, and I'll
6 accept it. But I think we need a little more clarity on
7 it.
8 A No. I can tell you that, based upon the
9 series of questions I have been asked so far, it
10 definitely requires clarity. People have been kind of
11 jumping all over the place with this.
12 Q Now, between ten -- and you see that -- you
13 see a picture of you and Ted at the bank there.
14 What is the date of that?
15 A It's September 8th, 2009, at 12:45.
16 Q So we know at 12:45 you're in Weston getting
17 the phony bank balance?
18 A Correct.
19 Q Now, and we know that Ted was in your office
20 at 10:00?
21 A Yes.
22 Q Now, between 10:00 and 12:45, what did you do?
23 A Okay. Ted gets to the office at 10:00. I go
24 get Ted immediately, because as anyone that that's done
25 business with Ted knows: You don't leave him waiting.
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1 So I went -- even as my best friend, I don't
2 want to hear it. So I went and got him. We went back
3 to the office.
4 At that point in time -- you should have the
5 metadata somewhere -- but we are messing around with the
6 order, initially. That's when it's initially being
7 created.
8 Q And is he helping you?
9 A He's helping me to the extent that I'm asking
10 him -- you know, we talked about his -- what his role
11 was going to be --
12 Q Okay.
13 A -- and how much of that I was going to put in
14 the order, because I was not going to put him in a
15 position where he had to say something to his father
16 that he himself was not comfortable saying.
17 So we went ahead, and I finished up the order.
18 Following finishing up the order, I gave the
19 order to Deb. Deb and -- this part is unbeknownst to
20 Ted. I give that to Deb. Deb goes ahead and cuts and
21 pastes Judge Seltzer's signature on to the order, puts
22 it in an envelope for me and gives me the order.
23 Ted and I leave to go to Judge Seltzer's.
24 We arrived at Judge Seltzer's. When I get to
25 Judge Seltzer's chambers, after his secretary announces
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1 me, I go in with Ted. I introduce Judge Seltzer to Ted.
2 The remainder of the time that Ted is in there
3 with me, we are simply talking -- Judge Seltzer had
4 upcoming nuptials; we were talking about that. Judge
5 Seltzer and I generally talk about skiing, we talk about
6 some sports, and then I excused Ted.
7 At that moment, I wanted Ted, for my own
8 purposes, to believe that I had Judge Seltzer in my
9 pocket; and Ted, having known that I had a lot of
10 politicians, law enforcement people and the like in my
11 pocket, it was not very difficult to believe because he
12 had used those people before.
13 So I went ahead and had Ted step out. I then,
14 while Ted is obviously thinking I'm getting Judge
15 Seltzer to sign the order, I talk to Judge Seltzer about
16 his upcoming potential eventual nomination to the
17 federal bench by the president, and we are just
18 kibitzing about general stuff, talking about general
19 stuff.
20 I then take the order. I then take the order.
21 Judge Seltzer had given me -- I asked him for a notebook
22 of all his, you know, resumes, his CV, all of his
23 accomplishments, because I wanted to send that off for
24 him to people regarding the federal judgeship.
25 I took the order and placed it inside the
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1 inside sleeve of the notebook. I then went out with
2 Ted. I took Ted, said good bye the judge. We left.
3 As we were walking over there, I pulled the
4 order out, at some point in time. I don't remember
5 whether it was while walking over there or later; but at
6 some point in time I take the order out of there and
7 give it to Ted.
8 Q Now, did you discuss with Ted the purpose of
9 going to Judge Seltzer? I mean, why did you do that if
10 he was going to go along with the farce anyway?
11 A For whatever reason, at that point in time, I
12 wanted Ted to believe that I had a member of the federal
13 judiciary in my pocket.
14 Q Okay. Did --
15 A Which I obviously did not.
16 Q You know the order referred to Ted testifying.
17 Did you attempt to give Ted some kind of alibi
18 that he thought what you did with Judge Seltzer was a
19 hearing?
20 A No.
21 Please allow me to explain what occurred while
22 we were in there.
23 Ted, during the course of this, barely said
24 anything at all. It was the quietest I had ever heard
25 Ted. He was actually the most demure I had ever seen
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1 him during my entire friendship with him. He barely
2 said anything, which was really not like him.
3 But there was no way in the world that Ted
4 thought a hearing was occurring, okay, nothing of the
5 sort, nothing to lead him to believe it. There wasn't
6 even any discussion about Ted being involved in any type
7 of litigation. Nothing of that nature happened.
8 What Ted believed was that I went in there
9 privately and somehow got Judge Seltzer to sign that
10 order.
11 Q Now, I'd like you to look at the next document
12 in that composite. You've got the --
13 A Let me just --
14 Q Go ahead.
15 A Which, by the way --
16 Q Have you finished?
17 A No.
18 Which, by the way, is consistent with Ted's
19 understanding of my influence in the community in
20 general. It would have elevated what was my actual
21 level of influence over and above what it actually was,
22 because I did not have any federal judges in my pocket,
23 certainly not Judge Seltzer or anybody else involved.
24 Q Okay. I'd like you to look at the -- you've
25 got the bank visit, and I think we have already talked
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1 about that; but the document shows you in the bank, and
2 I'm interested in the timing.
3 A Yes.
4 Q And it's 12:45?
5 A Correct.
6 Q Then look at the next couple of documents,
7 those -- that is the phony statement and the Caretsky
8 cover letter.
9 A Yes.
10 Q And then there's the metadata. I would like
11 you to look at that. It looks to me like you did some
12 more drafting of that order. If you can see the
13 metadata up at the top, the -- go back to the -- may I
14 show you the -- let me do this. I haven't done this. I
15 haven't walked over.
16 MR. SCHERER: May I, Marshal, go over
17 here close?
18 MR. NURIK: You can come around. You can
19 come around.
20 BY MR. SCHERER:
21 Q This appears to be a -- a drafting and then a
22 printing of the final, so it looks like --
23 A Okay.
24 Q And then you have the metadata that actually
25 shows the date of the final printing of the order.
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1 Do you see that?
2 A I do.
3 Q Now, after you -- apparently more drafting on
4 that order took place after you returned from the bank.
5 Do you recall that?
6 A I have a vague recollection of me making
7 certain corrections to the order.
8 Q Okay.
9 A I don't know exactly what they were.
10 Q You can pretty much tell by looking at those
11 successive copies there. It's pretty much the same
12 thing, it looks like, only one was in regular form and
13 one was in final form. And then somewhere along the
14 line, you had to cut and paste judge's signature?
15 A Yes. What -- at some point in time, okay,
16 prior to me giving -- it looks like Pam was working on
17 it, which makes sense because --
18 Q Pam?
19 A Pam Dominicis.
20 Q Right.
21 A It looks like she was working on it at some
22 point in time.
23 Q At what time?
24 A At 1:54 p.m.
25 Q Okay.
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1 A And then this -- it says "last modified," it
2 looks like some kind of modification was made actually
3 after it was last printed.
4 That's correct, because it says September 8,
5 2009, 2:24 p.m. last printed; it says last modified two
6 minutes after that, which may have just been the
7 methodology that Pam was using to notate it for later
8 purposes to be able to access it. It could have been
9 anything the way that works.
10 Q It's at 2:25 p.m., correct, or around that
11 time, around 2:30?
12 A Yes.
13 Q And Ted is still with you, correct?
14 A Yes.
15 Q And then do you see an email from Ed
16 authorizing Ted to testify? I think that's in there,
17 right?
18 A Yes.
19 Q Okay. What time was that?
20 A Mr. Scherer, bear with me one second. I just
21 want to make sure that we got this from the right order.
22 Q Right. Can I help you?
23 A No.
24 Okay. We're in the right order.
25 Q All right. And what time does Ed email you
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1 back that it's okay for Ted to testify in the hearing
2 before Judge Seltzer that you -- you know, that you
3 already had the visit for?
4 A 2:25 p.m.
5 Q And Ted is still there at that point, right?
6 A Yes. Ted was with me the entire day, yes.
7 Q Ted and then you, apparently, waited a few
8 hours before you emailed Judge Seltzer's order; do you
9 see that? Do you see the date or the time of the email
10 or the order?
11 A I do.
12 Q What time was that?
13 A I emailed the order at 4:11 p.m.
14 Q And was there a phone call between you and Ed,
15 you and Ted and Ed and Carol at that time that you
16 emailed the phony order to them? Do you recall that?
17 A A telephone call, sure, there was, yes.
18 Q And do you recall what happened on that phone
19 call, what you said, what Ted said to Ed and Carol?
20 A I do.
21 Q What was that, please?
22 A I called up Ed on the phone. I had Ted
23 sitting with me. We were actually sitting at the
24 conference room table at my office. I had the speaker
25 phone on. I told Ed Ted was with me.
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1 We did a conference call. We dialed -- I
2 don't know if we dialed Carol in or not, actually. I
3 have to look at her telephone records.
4 But in any event, I know Ed was on the phone
5 with Ted.
6 I told Ed we won. I explained the basis of
7 it. I told him that he should be very proud of Ted, I
8 said, because without Ted's sworn testimony, there was
9 no way that the judge was ruling in our favor, that he
10 really was the star of the order and the hearing and not
11 me.
12 I said -- told him -- I think I actually wrote
13 it in a subsequent email, something about that I would
14 love to take the credit for this but I can't; it really
15 all goes to his son, to Ted, for his testimony.
16 Ed then spoke to Ted while we were there and
17 asked Ted some very specific and pointed questions about
18 the hearing, specifically what the judge asked him and
19 the like. Ted answered all the questions by lying to
20 his father, and we wrapped up the call. And I gave Ted
21 a copy of the order to take with him, and I also emailed
22 the copy to Ed and Carol.
23 Q There were some more emails in the days that
24 followed between you and Ed and Carol, and you -- where
25 you, again, invited the father to talk to his son, if he
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1 didn't believe you about the hearing and Ted's
2 testimony. You do recall that?
3 A Yes. It was more directed to Carol. I
4 repeatedly told Carol, because she -- she sent me that
5 very terse email back at one point in time saying, well,
6 that's amazing how you got this whole thing handled, the
7 IRS and the hearing, you know, the bond funds in eight
8 hours, isn't that amazing. Something to that effect.
9 Q Right.
10 A So I wrote her a strong email back, and I
11 invited her, in that email and on multiple other
12 occasions, if you don't believe me as to what happened,
13 ask Ted --
14 Q Did --
15 A -- Ted was there. Ted testified. Talk to
16 him.
17 Q Do you know whether they actually spoke about
18 it? Did she ask Ted?
19 A Ted hated Carol. He probably avoided her, so
20 I don't know; but I know Ted spoke to his father.
21 Q Okay. And what do you know about that
22 conversation?
23 A I know that Ted told him repeatedly about his
24 testimony. He was using it to bolster his own worth in
25 his father's eyes. I mean, it was clear that was going
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1 on during the course of the initial conversation.
2 Q And during those conversations, Ted would lie
3 to his father that he testified at a hearing before
4 Judge Seltzer when you guys visited Seltzer that day on
5 the 8th, correct?
6 A That's absolutely correct.
7 Q All right.
8 A I mean, the order is clear that -- it says Ted
9 testified. It says, under oath, that he testified under
10 oath; and I believe the word -- either "at length" or
11 "extensively."
12 Q Who was keeping track of the mathematics, the
13 accounting on the -- all of the payments that were due
14 under the bonds, under the deals, and the interest, et
15 cetera, for Morse operation and Ed and Carol under the
16 bonds?
17 A Dennis McGinnis and Michael Kelly; and
18 internally, my office, either Irene or Deb. I don't
19 know which one.
20 Q I'm not sure we're doing lightning rounds,
21 but -- it's going fast for me, but they tell me I'm
22 going slow. So I would like to kind of see if I can't
23 move it along because others need an opportunity.
24 Let me direct -- I have a few questions to TD
25 Bank that's more in the nature of redirect, I think.
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1 A Okay.
2 Q The -- on the cover letters that Caretsky, and
3 on a few occasions Kerstetter, did to accompany, the
4 fake statements, and I believe that you have testified
5 pretty completely about that whole process, correct?
6 A Yes, sir.
7 Q And I asked you this, but I don't think it was
8 100 percent clear, that every time that they did a cover
9 letter, the cover letter was original; you never faked
10 any cover letters?
11 A To my recollection, we never faked a cover
12 letter. We didn't need to.
13 Q Yeah. And is your understanding that every
14 time they gave you a fake cover letter, they asked the
15 bank's -- they made a -- printed a screen shot from the
16 bank of the actual balance to go along with the cover
17 letter?
18 A Yes, sir.
19 Q So they would have some deniability?
20 A Yes.
21 At one point in time I asked Ms. Caretsky, I
22 said, you know, I don't need these, just stick them in
23 the file.
24 She said, no, I need to show that they were
25 printed at the time that I wrote this letter so we have
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1 a complete record.
2 Q And, of course, those printed, actual bank
3 statements nowhere near matched the fraudulent
4 statements that you were providing for the switch,
5 correct?
6 A No, sir.
7 Q Now, with Mr. Spinosa, I know that he met with
8 some investors to talk to them about your business and
9 to vouch for you and to vouch for the authenticity of
10 the lock letters, correct?
11 A Yes, sir.
12 Q And I know that he also had meetings with some
13 investors that you talked about: Barry Damson and
14 Kathleen White for Coquina, where Mr. Spinosa actually
15 affirmed false balances in the falsely locked account,
16 correct?
17 MR. SCHLESINGER: Objection to form.
18 A Correct.
19 BY MR. SCHERER:
20 Q What did Mr. Spinosa tell Barry Damson and
21 Kathleen White on Coquina when they visited his office
22 in Cypress Creek with you concerning the bank balances?
23 A He told them that we had -- it was in
24 excess -- I don't remember what amount we were looking
25 at the time, but whatever the amount was, several tens
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1 of millions of dollars, he verified to them that we had
2 in excess of that amount in the account.
3 Q And that was a lie, of course?
4 A Yes, sir.
5 Q Now, do you have a recollection of Mr. Spinosa
6 meeting with Ira Sochet?
7 A He may have. I don't have a specific
8 recollection of it.
9 Q Now -- okay.
10 A He may have had a telephone call with
11 Mr. Sochet. I don't recall whether Ira did or not.
12 Q Ira Sochet, nice man?
13 A Yes. Wonderful man.
14 Q In his 80s?
15 A Yes, sir.
16 Q Did you take advantage of him?
17 A I did, sir.
18 Q Well, would you describe how you took
19 advantage -- let me ask this: Did you take advantage,
20 also, of his age in any regard?
21 A I did, sir.
22 Q How?
23 A He was in a stage in his life where he was --
24 from what I understand from Mr. Szfranski, who had known
25 him a lot longer than I had, he had mellowed, and he was
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1 very trusting; very sharp but very trusting, and I took
2 advantage of that.
3 Q Did he know that you were running a scam or a
4 fraud?
5 A He did not, sir.
6 Q In your mind?
7 A No, sir.
8 Q Same question for Mr. Von Allmen, did he know?
9 A No, sir.
10 Q Now, would you describe your relationship at
11 TD Bank as atypical, as an atypical banking
12 relationship?
13 A That's one word, "atypical," not; "a typical."
14 Q No, no, no. Was it atypical. That would be
15 one word, A-T-Y-P-I-C-A-L. Was it an atypical
16 relationship?
17 A Yes, it was an extremely unusual relationship.
18 Q Unusual or atypical?
19 A Yes.
20 Q Would you say that TD provided you with
21 special accommodations --
22 MR. SCHLESINGER: Objection.
23 BY MR. SCHERER:
24 Q -- in the way they handled your accounts and
25 you as a customers?
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1 A Yes, sir.
2 Q Without TD Bank's help and Mr. Spinosa's help
3 and TD Bank, in general, could your Ponzi scheme have
4 survived?
5 ALL PRESENT: Object, asked and answered
6 several times.
7 MR. SCHERER: It's been asked and
8 answered?
9 MR. RABIN: Several times.
10 MR. SCHERER: Fine.
11 A It couldn't have.
12 MR. RABIN: Move to strike.
13 MR. SCHERER: Well, you don't need to
14 move to strike. All you need to do is object
15 to form.
16 MR. RABIN: I did it anyway.
17 MR. SCHERER: That's all you have got to
18 do.
19 MR. RABIN: Thank you.
20 MR. SCHERER: I don't think you're going
21 to coach this guy.
22 BY MR. SCHERER:
23 Q Would you describe your relationship with
24 Gibraltar Bank as an atypical banking relationship?
25 That would one word, "atypical."
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1 A Yes.
2 Q And did they provide you with special
3 accommodations? I'm talking about the people at
4 Gibraltar.
5 A Yes, sir.
6 Q Let me talk to you about your testimony the
7 other day that I should have followed up on and didn't,
8 concerning A.J. Discala of Clockwork and my clients and
9 your dinner with him in Bova where you guys were excited
10 and even toasted some drink to some event.
11 Do you recall that testimony?
12 A Yes, sir.
13 Q Would you tell me about that a little bit, and
14 then I'll ask you some follow-up questions.
15 A Can you give me the time frame again? Who was
16 with me?
17 Q Yes. It was before the Razorback investment
18 while Clockwork was doing its due diligence, and that
19 would be sometime in, probably, September or maybe the
20 summer, June, July, August, September, somewhere in that
21 line, when they were doing their due diligence about
22 investing in your fund. Is that -- I can't get more
23 precise than that because it's your memory.
24 A Yes. I recall -- the problem is that I recall
25 having dinner with them on several occasions there. I
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1 also recall a time when we were sitting off to the side
2 tables, closer to the bar, where, actually, Thane
3 Ritchie was there and some of the other guys, and we
4 were sitting there having drinks, toasting.
5 Q What I'm interested in is A.J.'s statements to
6 you about his due diligence and investigation of the
7 performance of the New York hedge funds and their past
8 performance with your investment scene.
9 A Okay.
10 MS. TRENCH: Object to form.
11 A I remember what you're talking about now.
12 MR. SCHERER: I have an objection there.
13 If it's from Susan, it's probably pretty good
14 and I'll change the question.
15 What is it?
16 MS. TRENCH: It's testifying. It's
17 asking him to speculate, talking about what
18 other people knew.
19 BY MR. SCHERER:
20 Q Well, okay. I'm asking you if you were
21 present when A.J., when there were discussions
22 concerning his diligence.
23 A Yes, I was.
24 Q And tell -- and by the way, did you have
25 similar conversations with either Mr. Simony or
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1 Mr. Nordlicht from the funds about --
2 A Yes, sir.
3 Q -- their positive references to Mr. Discala
4 and the Clockwork people?
5 A Yes, sir.
6 MS. TRENCH: Object to form.
7 BY MR. SCHERER:
8 Q Tell us about those discussion, please.
9 A You want me to start with the A.J.
10 discussions?
11 Q Yeah. Start with A.J., and then we will go
12 onto the others.
13 A At the -- at one of the dinners we were
14 having, we were toasting the fact that their due
15 diligence people, whoever was making the call -- I don't
16 know who it was, someone on behalf of the Clockwork, Von
17 Allmen, that whole group -- had spoke to the folks in
18 New York at the New York hedge funds, and they had given
19 us a sterling recommendation, both with regard to
20 consistency of payment and the type of investment
21 strategy we were representing.
22 There were also conversations prior to that
23 where I spoke to Jack Simony and I spoke once or twice
24 to Mr. Nordlicht about the fact that they were looking
25 forward to getting their money because they had done
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1 what they were supposed to do in giving me a positive
2 reference to our new investors.
3 Q And that "new investors" would have been the
4 Clockwork people?
5 A Yes, sir, among them, yes.
6 Q And did you have any conversations with Simony
7 or Nordlicht about A.J., in particular, or anybody else
8 in my client group --
9 A I did.
10 Q -- that you recall?
11 A I did.
12 Q All right. And tell us about that, please.
13 A I remember -- the conversation with Discala
14 sticks out because he was at one point in time married
15 to Meadow Soprano -- I forget her name. What is her
16 real name?
17 Q Jamie Sigler.
18 A Right. Jamie Sigler.
19 So somehow it had come up in the conversation
20 with the hedge funds, because Simony -- I don't remember
21 whether Nordlicht asked me, but Simony was asking me, he
22 said, I didn't know he was married to her. So that's
23 why it sticks out.
24 Other than that, that's all I can tell you.
25 Q Do you think that conversation occurred prior
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1 to the time of the Razorback investment in your
2 investment -- settlement investment scheme?
3 A I was told both by Doug Von Allmen and by A.J.
4 Discala, specifically, that without the blessing of our
5 large -- largest investors, they were not going to be
6 able to invest. That was key.
7 Q Well, let me ask you this: Who, in doing due
8 diligence, would ever invest without the positive
9 reference of a fund that was primarily funding the
10 investment for 18 months? Wouldn't that be absolutely
11 critical to any kind of diligence?
12 MS. TRENCH: Object to form.
13 A Yes. Based on my experience in running a
14 Ponzi scheme for four or five years, the only people
15 that ever invested without doing that type of due
16 diligence were people who were in the know about the
17 fact that we were committing a fraud.
18 BY MR. SCHERER:
19 Q Do any of my clients, A.J. -- and A.J. Discala
20 and Parrish or any of those other fellows have a -- how
21 did you rephrase that -- how did you phrase that? Did
22 they have an escort issue? Did you ever provide escorts
23 to any of my clients?
24 A No, sir.
25 Q And you can't say the same thing about some of
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1 those fellows at Platinum, though, can you?
2 MS. TRENCH: Object to form.
3 A No. No, sir.
4 BY MR. SCHERER:
5 Q As inducements to Simony, Nordlicht and Glass,
6 did you provide them tickets to concerts, Super Bowl,
7 BCS, political events, dinners, charter flights, the
8 things that you have been talking about?
9 A I did.
10 ALL PRESENT: Object to form.
11 BY MR. SCHERER:
12 Q And escorts, same thing?
13 A Some them, yes, sir.
14 MS. TRENCH: Objection.
15 BY MR. SCHERER:
16 Q And how often would you provide -- would they
17 partake in your rock-star lifestyle that you have been
18 talking about here for a few days?
19 MS. TRENCH: Same objection.
20 A I would say it was on a regular basis.
21 Certainly whenever they were in Florida, they were; and
22 whenever I traveled to New York, they were; and whenever
23 we traveled together, they were.
24 Q Okay. Did you do that to induce them into
25 treating you more favorably, or why did you do that?
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1 A I did that because that is the way I took care
2 of people that were involved -- I -- I don't really know
3 how to put this. I mean, you do -- the guys at the
4 hedge funds -- there's two methodologies of rewards.
5 You were rewarding guys that were in on it; but at the
6 hedge funds, I was really just trying to make them
7 comfortable with me so they would invest.
8 Q Well, and some of them were in on it, though,
9 right?
10 MS. TRENCH: Object to form.
11 BY MR. SCHERER:
12 Q Like Simony?
13 A I believe -- here's the way you have got to
14 break this down, Mr. Scherer. I believe that Jack
15 Simony had some knowledge of the fraud. That is my
16 opinion. Okay. I do not know it for a fact.
17 On the other side, Brian Jedwab, I believe had
18 no knowledge -- thought about it, and had he found out,
19 he would have shut us down in a second.
20 As I said, he would have gone running down the
21 hall, calling the police on the way. I don't think
22 Simony would have done that.
23 Q And Nordlicht?
24 A That is based on my dealings with him. That's
25 my opinion.
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1 Q Okay. Nordlicht?
2 A I believe at some point in time Nordlicht
3 knew. It's my opinion that he knew that there was a
4 fraud in the works.
5 Q Well, and some of them were in on it, though,
6 right?
7 MS. TRENCH: Object to form.
8 A I don't --
9 Q Like Simony?
10 A I believe -- here's the way you've got to
11 break this down, Mr. Scherer, okay. I believe that Jack
12 Simony had some knowledge of the fraud. That is my
13 opinion. Okay. I do not know it for a fact.
14 On the other side, Brian Jedwab I believe had
15 no knowledge, thought about it, and had he found out he
16 would have shut us down in a second. As I said, he
17 would have gone running down the hall calling the police
18 on the way.
19 I don't think Simony would have done that.
20 Q And Nordlicht --
21 A That's based on my dealings with them. That's
22 my opinion.
23 Q Okay. Nordlicht?
24 A I believe at some point in time Nordlicht
25 knew. It's my opinion that he knew that there was a
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1 fraud in the works.
2 Q Well, and then -- let's see -- why do you say
3 that?
4 Yeah. And then I'm going to ask you about
5 what they got out of their actions thereafter.
6 A Well, it's based on a conversation --
7 MS. TRENCH: Object to form.
8 A -- that I had with him in my office.
9 Q You have talked about that.
10 A That I went through. So, you know, listen, as
11 you're going through this thing, there are people that
12 you know are involved because they're involved. They're
13 actually -- like Szafranski, bringing in investors to
14 something he knows doesn't exist.
15 David Boden, creating paperwork. Those are
16 people you know. I want to clearly differentiate
17 between that and my opinion.
18 Then there are people that you think know.
19 Okay. I know Mr. Spinosa knowed (sic) because he lied
20 for me. I know Harris knowed because he lied for me.
21 Okay.
22 I know Ted Morse knowed.
23 I don't know whether or not Simony or
24 Nordlicht knew. It was my opinion that he knew and
25 looked the other way because they wanted to get their
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1 money out.
2 Q Okay.
3 A They were making a lot of money and then they
4 were almost making no money and they wanted to get all
5 their money out.
6 Q They had a hundred million dollars in it
7 approximately, in April. They had, in December, when
8 they started slow paying or ramping down the payment,
9 they had about $180 million. I would like you to assume
10 that. I think that's pretty accurate.
11 A I believe that's accurate, sir.
12 MS. TRENCH: Object to form.
13 BY MR. SCHERER:
14 Q And the positive references that Platinum and
15 Centurion and their -- Simony, Nordlicht, Glass,
16 provided -- and anybody else there, provided to our
17 investors -- enabled your scheme to continue on through
18 the end of October, correct?
19 MS. TRENCH: Object to form.
20 MR. SCHERER: What is wrong with the
21 form?
22 MS. TRENCH: It assumes facts not in
23 evidence.
24 BY MR. SCHERER:
25 Q Okay. Well, we -- that's all deposit
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1 information, so that is in evidence or will be in
2 evidence.
3 I want you to assume that they had about
4 $100 million outstanding in April.
5 A I don't need to assume it. They did have
6 approximately that amount of money.
7 Q Okay. You remember that?
8 A Yes.
9 Q And at the end of the crash, they got it all
10 back except about $18 million?
11 A Yes, I believe -- my recollection is, is they
12 were just $18 million shy.
13 Q Okay. So they made about $80 million back for
14 their fund and that -- between April and the end of
15 October, correct?
16 A Yes, sir.
17 MS. TRENCH: Object to form.
18 BY MR. SCHERER:
19 Q And what did they do to get that back other
20 than remain silent? They did more than remain silent,
21 didn't they?
22 A Yes.
23 MS. TRENCH: Object to form.
24 A They looked the other way and they gave us a
25 positive credit reference to our new investors.
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1 BY MR. SCHERER:
2 Q All right. Now, did Nordlicht partake in the
3 inducements also: Tickets, concerts, escorts, flights,
4 charter flights, hotels, food, drink?
5 A Not --
6 MS. TRENCH: Object to form.
7 A Food and drink, yeah, but not so much.
8 Nordlicht was more of a family guy.
9 BY MR. SCHERER:
10 Q Okay.
11 A Did his thing on the side.
12 Q Simony and Glass more so?
13 A Yes. Very much Simony and, you know, Glass
14 was a little squeamish about it from time to time but he
15 got over it.
16 Q Okay. How about how many -- how many -- what
17 are we talking about? How many times? Multiple times?
18 A For a --
19 Q For both of those guys.
20 A Simony liked the escorts and Glass liked more
21 to go to strip clubs and then get --
22 Q Serviced?
23 A Serviced. Extra special treatment at the
24 strip clubs. He felt secure in the strip clubs for some
25 reason.
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1 Q And did he ever pay for it or did you pay for
2 it?
3 A No. I always paid.
4 Q And where did you get the money to pay for it?
5 A Ponzi scheme.
6 Q Now, you flew Glass to the islands, to the
7 Bahamas in order to -- for him to do some due diligence
8 and approve some settlements offshore because some other
9 business was offshore, correct?
10 MS. TRENCH: Object to the form.
11 A That is why I thought we were going there,
12 yes, sir.
13 BY MR. SCHERER:
14 Q But what did you do when you were there? He
15 didn't do any business, did he?
16 MS. TRENCH: Object to the form.
17 A No. We did monkey business. We did no real
18 business.
19 BY MR. SCHERER:
20 Q And monkey business meaning?
21 A We drank and we had women at our disposal
22 there.
23 Q Okay. And do you think that the requirement
24 to do business offshore was satisfied by the monkey
25 business that you guys engaged in when you were in the
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1 Bahamas?
2 MS. TRENCH: Object to the form.
3 A No. One thing had nothing -- one thing had
4 nothing to do with other.
5 BY MR. SCHERER:
6 Q The deals that you were actually -- or that he
7 was actually looking at there were being really looked
8 at back in New York, right?
9 A Yes. Because when we got there, Mr. Scherer,
10 I said, "Okay, what do we have to do?" He said, "What
11 do you mean we have to do?" He said, "Everything's
12 already been approved." Go downstairs and drink. Later
13 on we'll get a call. I'll go upstairs and just type in
14 that everything's -- that I've reviewed all the
15 documents and it's been approved.
16 We had no way to receive the documents. We
17 had no documents with us. We had his laptop. Wallets
18 and bathing suits. We were good to go.
19 Q Okay. Let me talk to you about the bar
20 grievance procedure.
21 A Okay.
22 Q You actually had a -- had the Platinum guys
23 come in, and you used this contrivance that you had a
24 Bar problem tying up your trust accounts, and therefore,
25 you were slow paying them or no paying them because
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1 ostensibly the Bar had tied up your trust accounts,
2 right?
3 A Correct.
4 MS. TRENCH: Object to form.
5 BY MR. SCHERER:
6 Q And is there anything incorrect about that
7 predicate statement?
8 A No, sir.
9 Q Okay. And at one point you got somebody from
10 your office on the phone who played like a lawyer for
11 the Bar?
12 A Yes, sir. A female at the office.
13 Q Okay. And I guess -- what, did you use a
14 speakerphone or something like that?
15 A Yes.
16 Q And who was in the office to witness this
17 spectacle?
18 A I don't remember, Mr. Scherer.
19 MS. TRENCH: Object to form.
20 BY MR. SCHERER:
21 Q Okay. Who was in the office to -- was it
22 Simony? Was he there; do you recall?
23 A I really don't recall. I recall there being
24 somebody there from the hedge funds and someone on the
25 call also that had been conferenced in. But I don't
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1 recall who was there.
2 Q So you -- I mean, you put on this charade
3 about the Bar grievance to justify withholding money
4 that was due to the funds, correct?
5 A Yes. I -- it was twofold. I wanted to
6 pressure them into potentially settling -- not
7 settling -- I wanted to pressure them into potentially
8 funding more cases, and I needed to have a -- at least
9 semi viable reason why I was not paying them.
10 Q The Bar grievance ruse was for the funds, not
11 anybody else? I mean, were there any other investors
12 that were -- that you used this Bar -- this fictional
13 Bar problem with?
14 A No. It was utilized for the purpose of
15 controlling the New York hedge funds.
16 Q Did you have a concern that they would pick up
17 the telephone and call the Florida Bar?
18 A Terrified.
19 Q They didn't do that, though, obviously.
20 A Not to my knowledge.
21 MS. TRENCH: Object to form on that one.
22 BY MR. SCHERER:
23 Q Did the person that was on the phone acting
24 like a Bar lawyer use a Bar lawyer's name?
25 A Yes.
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1 Q Adrianna something?
2 A Adria Quintela.
3 Q Adria Quintela. Who is actually a lawyer for
4 the Bar?
5 A Yeah. She actually ran the Fort Lauderdale
6 office.
7 Q So were you fearful that somebody from the
8 fund would call Adria and say, is this true?
9 A Terrified.
10 Q Didn't happen, though, did it?
11 A No, sir.
12 MS. TRENCH: Object to form.
13 BY MR. SCHERER:
14 Q Now, when the funds did their due diligence in
15 December at Steve Rossi's office --
16 A Yes.
17 Q Doesn't Mr. Rossi have a relatively modest
18 office?
19 MS. TRENCH: Object to form.
20 A Extremely modest. Yes.
21 BY MR. SCHERER:
22 Q Were you concerned that whoever was doing the
23 due diligence in talking to Mr. Rossi would look around
24 the office and have a little bit of a problem believing
25 that he could send you hundreds of cases a month?
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1 A When I arrived there, having never been there
2 before, yes. I was very concerned. I actually joked
3 around about it later but we made it through it.
4 Q Well, yeah, you did.
5 Were you concerned that Mr. Glass and
6 Mr. Jedwab would do the Plaintiff/Defendant Index at
7 Broward and Palm Beach and Dade County and find out that
8 Mr. Rossi has only but a handful of cases?
9 MS. TRENCH: Object to form.
10 A Yes, sir.
11 BY MR. SCHERER:
12 Q That didn't happen either, though, did it?
13 A To my knowledge, no.
14 Q Now, Mr. Herskowitz -- is that how you
15 pronounce it?
16 A It's either Herskovitz (phonetic) or
17 Herskowitz (phonetic).
18 Q Okay. His office is modest as well, isn't it?
19 A Yes. Comparatively so, yes.
20 Q And same question. Were you concerned that
21 they would look around that office and say, how did this
22 guy -- how can this guy send hundreds of cases worth
23 hundreds of thousands of dollars?
24 A Yes.
25 Q And I don't know Doug Bates. What does his
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1 office look like?
2 A Same. Modest.
3 Q Same concern?
4 A Yes, sir.
5 Q Did you have the same concern that they would
6 run the Plaintiff/Defendant Index to see if those
7 fellows had any cases?
8 A I did, sir.
9 Q Because you knew they didn't have very many
10 cases, right?
11 A That's correct, sir.
12 Q They have very modest practices?
13 A Yeah. If you ran Bates, you would know; you
14 would find a bunch of personal injury cases and a lot of
15 workers' comp cases.
16 MR. SCHLESINGER: Mr. Scherer, there's
17 one minute left in the plaintiff's time.
18 MR. SCHERER: I'm going to take more than
19 that. I'm going to finish.
20 MR. SCHLESINGER: That wasn't stipulated
21 to.
22 MR. SCHERER: Read the court order.
23 I'm taking -- I'm going to finish this.
24 I'll be done in a few minutes.
25 BY MR. SCHERER:
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1 Q Let me ask you about Mr. Levin.
2 A Okay.
3 Q Was he a player as you've defined "player" in
4 this deposition this week?
5 A Mr. Levin I considered to be a player, yes,
6 sir.
7 Q Do you think he was in on the fraud?
8 A I do. However, I have to qualify it. I never
9 had direct conversations with George Levin about the
10 fraud. But there were -- let me break it down this way
11 for you. Okay. I knew he had the ability to monitor
12 Frank's emails. Frank and I had discussed that.
13 Q Right.
14 A He would read Frank's emails. I don't need to
15 tell you. I'm sure you read them all. It's clear that
16 there's a fraud going on.
17 Q Right.
18 A That's one.
19 Q I agree.
20 A Two, there was with a key moment in time in
21 '08, key moment, there's an email -- I think it was May
22 of '08 -- where Frank Preve has called -- where Frank
23 Preve has called TD Bank, and he has discussed the trust
24 balance, okay, with Frank Spinosa. And Frank Spinosa,
25 bobbles the ball and says we don't have as much in the
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1 trust account and then rushes and excuses himself and
2 gets off the phone.
3 Now, how do I know that happened? Because
4 Mr. Preve confirmed all that in an email to Mr. Levin.
5 I think the email title is "Idiots" and it's Frank
6 writing to George Levin and he says, "I was -- are these
7 people at Commerce Bank idiots? It was Commerce at the
8 time. He's going through the -- what he did, that
9 they're telling me about telephone calls he had with
10 them. It's clear I've got Spinosa in my pocket because
11 Frank's referencing him. In the email he's saying -- I
12 tell him not to tell Scott something and he picks up the
13 phone and tells Scott immediately, because Scott's
14 telling me about the conversations he had with Spinosa.
15 The second paragraph of the email is the key.
16 In that particular paragraph, he says during the
17 conversation, Spinosa tells him that Rothstein doesn't
18 have that much money in the trust account. Then
19 basically panics and hangs up and says, "I'll have to
20 get back to you." Never gets back to him.
21 When Preve tries to follow up with him to try
22 to figure out how much money I have, he -- Frank,
23 unfortunately -- and I had never seen these emails until
24 I came back and in reviewing emails you see that Frank
25 bobbled the ball again. He says, "I don't have access
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1 to customer balances. I got to wait until my girl gets
2 back on Tuesday, something to that effect.
3 Q Frank Spinosa?
4 A Frank Spinosa.
5 So at that moment, it's -- now looking at
6 these emails, it's crystal clear to me what was going on
7 because Preve had relayed this to me earlier on. Once,
8 Preve and I were speaking -- you'll see emails back and
9 forth where Preve is talking to me about what an idiot
10 Spinosa is and I need to watch him.
11 It's clear from that email and from the
12 behavior that George, to my knowledge, knew what was
13 going on. But George, the way he always did his
14 business -- okay, George and I became very close. The
15 way George did his business was Frank was his Chinese
16 wall. Frank -- he used Frank to try to insulate him
17 from liability, that is clear in everything he did. Go
18 back to the classic motor cars thing; it's the exact
19 same thing. It's the way he does his banking business.
20 It's the, I don't know, someone else takes care of it.
21 The exact same thing, by the way, if you look
22 through the email traffic, happened with John Harris and
23 Gibraltar, where Frank made a call over and said -- he
24 was trying to get --
25 Q Frank Preve?
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1 A Frank Preve was trying to get a line of credit
2 with Gibraltar for the Banyon people. And he said,
3 well -- and in the email he mentions, he says, "Well,
4 you've got $21 million in the trust account." And now
5 Harris follows the ball, okay, and says, uh, yeah, okay,
6 something -- and you can tell by the email Frank knows
7 the money is not there and he's writing -- and George is
8 copied on the email. You can see that they know the
9 money is not there. Okay.
10 And the way John Harris recovers, you see, is
11 he continues to attempt to put through Levin's Banyon's
12 request for a line of credit.
13 Preve keeps pushing him. Keeps pushing
14 Spinosa and Levin -- excuse me, Spinosa and Harris to
15 try to get these lines in place. But you can see from
16 the emails that everyone knew that the trust account
17 balances were not there.
18 Q When you --
19 MR. RABIN: Mr. Scherer, just -- for a
20 moment. I want to put on the record, it's now
21 five after ten.
22 Although you say you don't care about
23 whatever --
24 MR. SCHERER: Let me finish.
25 SPEAKER?: Let me just put this on the
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1 record, please.
2 MR. SCHERER: Sure.
3 MR. RABIN: There was an agreement
4 reached by all counsel. I think Mr. Lichtman
5 actually coordinated the agreement, that the
6 plaintiffs would stop today at 10:00, because
7 this was going to be a shortened day, and in
8 order to be assured that we would get all of
9 our time in that was guaranteed by the court
10 order that you referred to, that you would
11 stop by 10:00 so that we could start.
12 It's now five past 10:00. You've now
13 violated the agreement.
14 So I'm not sure if it's the court order
15 that you're going by or ignoring the agreement
16 that all the lawyers in this case reached, but
17 I think you should be a man of your word and
18 abide by the agreement that all the lawyers
19 reached.
20 MR. SCHERER: I'm about finished, so --
21 MR. RABIN: Okay.
22 MR. SCHERER: -- just give me a few more
23 minutes.
24 MR. RABIN: All right.
25 MR. SCHERER: Okay? And the court order
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1 gives me the right to take all morning if I
2 want.
3 MR. RABIN: The problem with that, of
4 course, is that the court order didn't take
5 into account --
6 MR. SCHERER: Don't take --
7 MR. RABIN: I understand the court didn't
8 take into account the change of schedule.
9 MR. SCHERER: Well, that change of
10 schedule will be the same next Friday.
11 MR. LICHTMAN: Rather than fight about
12 it --
13 MR. SCHERER: We don't need a referee.
14 Let's go.
15 BY MR. SCHERER:
16 Q Do you recall receiving emails, correspondence
17 from Mr. Levin late in the game, let's say as your Ponzi
18 scheme was crumbling in the fall of 2009, that made you
19 think that he still felt there was money in -- actual
20 money in trust accounts?
21 A I do.
22 Q And actual defendant's money in trust accounts
23 that were held up by the Bar?
24 A Yes. I recall receiving something along those
25 lines.
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1 Q Did that make you concerned that maybe this
2 guy doesn't know?
3 A I couldn't decide because it was like a civil
4 thing. There were things that were discussed that made
5 me think one way and then I would receive something like
6 that that would make me think the other way.
7 Q When you got back from the Ponzi scheme,
8 initially you weren't sure, were you?
9 A No. No, I wasn't. I'm still not sure as I
10 sit here. I mean, looking back on reading emails I have
11 tremendous hindsight and there were clearly things that
12 say this man knows that something was wrong or at the
13 very least just wants to look the other way. But I --
14 to this day I have no way of knowing for certain. It's
15 my opinion.
16 Q Do you recall a fatherly email that he wrote
17 you late in October where he said, Take a deep breath --
18 something. Take a deep breath. Don't get yourself into
19 this situation where you promise plaintiffs you'll
20 settle the case until we get the money in-house.
21 A Yes.
22 Q And then you've got the defendants' money
23 in-house, and we'll be all right?
24 A Yes, sir.
25 Q You remember that?
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1 A I do.
2 Q Well, when you got that, did you think, well,
3 he still thinks this Ponzi scheme is real?
4 A To some extent, sure.
5 Q Defendants' money in-house locked up,
6 plaintiffs' money coming in, plaintiffs' money promised,
7 investor money coming in --
8 A Yes.
9 Q -- he said, Scott, don't promise the
10 plaintiffs anymore until you get the investor money
11 in-hand?
12 A Sure.
13 Q Remember that?
14 A Sure. Absolutely.
15 Q And we've got all that defendants' money, it's
16 already in there, we can wait and get the periodic
17 payments?
18 A Yes, sir.
19 Q I mean, he wrote you that in October?
20 A Yes, sir.
21 Q Did you think when he wrote you that, that he
22 was just covering up for the record or that he actually
23 believed it?
24 A At that point in time I really didn't know one
25 way or the other.
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1 Again, the problem always was that I couldn't
2 tell. He kept himself so isolated for everything I
3 couldn't tell.
4 For all I knew, he wasn't; and for all I knew,
5 he was.
6 You know, just -- I guess the emails that I
7 saw him writing me said he wasn't aware. At least if he
8 was aware, it was to a limited extent.
9 The email traffic between him and Mr. Preve
10 and the conversations Preve is telling me he's having,
11 speak to the other side of the coin, that he was aware.
12 So it's very difficult for me to tell.
13 Q Well, and aren't there some emails between you
14 and Preve that "we're going to keep the old man in the
15 dark" and Preve said he's going back to the islands and,
16 I'm going to put my feet up on his desk and think about
17 how to screw him and -- remember that --
18 A Yes.
19 Q -- email?
20 A Yes, sir.
21 Q And that was late in the game?
22 A It was, sir.
23 Q I mean, that email would make you think that
24 maybe Mr. Levin isn't -- didn't know.
25 MS. TRENCH: Objection. Form.
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1 A Yes, but I have to tell you, Mr. Scherer, as I
2 sit here today, what I'm telling you is merely my
3 opinion. Okay. I do not know for certain whether or
4 not Mr. Levin knew there was a Ponzi scheme going on. I
5 just do not know. The emails and all the evidence
6 that's floating around in my brain over the last couple
7 of years is contradictory.
8 BY MR. SCHERER:
9 Q Let me show you this -- I'm going to -- I've
10 got one more email and I'll be done in just a minute,
11 fellows.
12 BY MR. SCHERER:
13 Q Your testimony about the other tentacles to
14 your fraud operation, that involved more than just the
15 confidential settlements? That was one branch of your
16 fraud?
17 A Correct.
18 Q But your fraud had other branches?
19 A Correct.
20 Q You had the -- as you discussed, Ron Picou and
21 his grout company that you were using to get money and
22 give him money fraudulently -- or Ponzi scheme money and
23 putting his money into the Ponzi scheme?
24 A He wasn't involved in the Ponzi scheme but I
25 was using funds from him to fund the Ponzi scheme, while
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1 at the same time laundering money for him for the things
2 he needed money for and to help him hide money from
3 his -- at that point in time soon-to-be ex-wife.
4 Q And -- well, you know, I thought in the
5 beginning you might have said that the Ponzi was bigger
6 than just the settlement because all of the money came
7 in from all of these multi-faceted frauds --
8 A I did say that.
9 Q -- and then was paid out on a multi -- out of
10 Ponzi money or fraudulent money, without regard to who
11 was owed what on the basis of some contract or illegal
12 contract or agreement?
13 A Yes.
14 Let me make sure you understand that I
15 believe -- actually I'm confident as I sit here today
16 that every one of the tentacles of the criminal
17 enterprise that I was running, all flowed back in some
18 way to benefit the Ponzi. Whether it was power -- in
19 any phase, judiciary, law enforcement, banking. Whether
20 it was laundering money for organized crime and all the
21 myriad of things that occurred in between. They were
22 all involved at some way ultimately funding or assisting
23 the Ponzi scheme.
24 Q Was Mel and Barry Lifshitz involved with you
25 early on?
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1 A Mel Taylor?
2 Q No, no, Mel -- is it -- is there a Mel
3 Lifshitz also. Mely?
4 A You're getting them -- Mely -- there's Mel
5 Taylor --
6 Q Okay.
7 A Or Thaler, who's Barry Lipsitz -- excuse me,
8 Barry Lipsitz's --
9 Q Lipsitz's.
10 A -- partner in Flashdancers in New York and in
11 some other businesses.
12 Q Okay.
13 A Then there's Menachem, Mely, Lifshitz, who
14 is -- who is an investor through Szafranski.
15 Q Okay. All right.
16 A That wasn't easy. That's okay.
17 Q All right. So those are -- the Barry Lipsitz
18 was not a settlement Ponzi investor? Barry and Mel
19 Taylor, the Flashdance guys, did they --
20 A To my knowledge, Mel wasn't involved in it.
21 Mel was involved in some kind of money laundering thing
22 with Barry to get cash to build a home in Fort
23 Lauderdale -- actually to redo a home in Fort
24 Lauderdale.
25 Barry was an investor, just like Tanachio, in
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1 the -- just the promissory notes, like Morse.
2 Q Right. The -- Mely or Menachem was in the
3 structured settlement --
4 A The full-blown deals, full-blown -- you know,
5 everything. Through Szafranski.
6 Q That would be the Emess Group? Is that Emess?
7 A The Emess Group, yes.
8 Q All right. Thank you. Thank you.
9 Now, did the Tanachio frauds, as you have
10 discussed, and Ronnie Picou's fraud that you discussed
11 and the Peters Silversea, was that also during the time
12 of the Ponzi -- the settlement Ponzi business?
13 A Yes.
14 Q Let me show you some emails. I'm going to do
15 it as a composite.
16 MR. RABIN: For the record, it's 10:15,
17 Mr. Scherer. You have now said you would be
18 wrapping up since about five after when you
19 made the first --
20 MR. SCHERER: Pretty soon.
21 MR. RABIN: I understand but pretty
22 soon -- you're violating the order the
23 lawyers, the agreements of the lawyers --
24 MR. SCHERER: Look, you're not going to
25 take all next week. You'll have plenty of
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1 time. Just hold your horses.
2 MR. RABIN: Unfortunately, it's not just
3 me. There's a lot of lawyers that want to
4 take time, so --
5 MR. SCHERER: You'll have time all next
6 week.
7 MR. RABIN: You're cutting into that
8 time.
9 (Multiple conversation.)
10 MR. SCHERER: Well, I'm sure I won't. So
11 I'm going to do this right now because I may
12 not get to see this man again.
13 MR. KOPAS: All right. Plaintiff's
14 Composite Exhibit 171. First thing is an
15 email that was Exhibit 28 to Nordlicht's
16 deposition. Bates Stamp FP ends in 167641/1;
17 another email TCL 60572; another email begins
18 FP -- Bates number FP 156116/1; another email,
19 FP Bates-labeled ends 167761/1.
20 (Thereupon, the documents were marked as
21 Plaintiff's Composite Exhibit No. 171 for
22 Identification?)
23 A Thank you, sir.
24 BY MR. SCHERER:
25 Q Look at that first email. It says, "Jack
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1 asked you to send something to the other two funds to
2 keep them quiet."
3 May 6th.
4 You see that?
5 A Yes, sir.
6 Q And was this part of your DOMAD, doctrine of
7 mutually -- mutually assured destruction?
8 A Yes, sir.
9 Q And --
10 MS. TRENCH: Object to form.
11 BY MR. SCHERER:
12 Q Okay. Why were you sending something to the
13 other funds to keep them quiet?
14 A Because Preve and Mr. Simony and I had a
15 concern that if I didn't get money over to all the
16 various parts of the New York hedge funds, that one of
17 them might explode and blow the whistle on us.
18 Q Okay. I would like you to look at that next
19 email, October 15th. A couple of weeks before you go to
20 Morocco you met with Simony.
21 You see that? Take a look at that email,
22 October 15th email.
23 A I see that.
24 Q And when we took his deposition, he couldn't
25 remember anything you discussed at that late, late
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1 meeting in October, but in the email, you see where it
2 says "please email me the docs we spoke about"?
3 MS. TRENCH: Object to form.
4 A Yes.
5 BY MR. SCHERER:
6 Q You see that?
7 And then he also says, "Please let me know
8 wire sent and I will shred."
9 You see that?
10 A Yes.
11 Q Do you remember what that was all about?
12 A I don't remember what the documents were but I
13 had given him a check to hold for an amount that I was
14 promising to send them. And if I was going to send --
15 if I sent the wire, he was going to shred the check.
16 Q Do you know whether --
17 A He wanted to know whether to deposit it or
18 not.
19 Q Did you send the wire?
20 A I don't recall one way or the other.
21 Q Okay. And then look at the March 20th, '09,
22 email, please.
23 A Yes, sir.
24 Q And what was the -- you see the reference to
25 Murray's trust there --
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1 A Yes.
2 Q -- on that email?
3 A Yes.
4 Q Do you know what Murray's trust referred to?
5 A I do not.
6 Q You know who the Murray is, right?
7 A Yes. It's Murray Huberfeld.
8 MS. TRENCH: Form.
9 BY MR. SCHERER:
10 Q And you know that Murray's had some kind of a
11 trust that was owning the Regent's or part of the
12 Regent's deal?
13 A I don't know if that's what was associated.
14 I'm not familiar with that backroom information.
15 MS. TRENCH: Objection to form.
16 BY MR. SCHERER:
17 Q The Regent's money came into you, 11 million,
18 paid out 22 million.
19 Do you remember that?
20 A I do.
21 Q That money came in in January of '09.
22 Was that money important in maintaining and
23 continuing the Ponzi scheme at that period of time,
24 January '09?
25 A Absolutely it was, sir.
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1 MS. TRENCH: Form.
2 BY MR. SCHERER:
3 Q Without that $11 million infusion, do you know
4 what would have happened?
5 A Yeah. I believe if you look at the finances,
6 financial records and ledgers at the time, the Ponzi
7 would have exploded and I wouldn't have been able to
8 make payments to other investors.
9 Q Okay. Would you look at that last email,
10 May 6th, and then these guys can have the floor?
11 A Yes, sir.
12 Q And these amounts that you are discussing in
13 this email, you can see that with -- this was to
14 Mr. Nordlicht, right?
15 A Yes, sir.
16 Q Did you fund these amounts of money in order
17 to keep the hedge funds quiet?
18 A All of the money that I sent them was to keep
19 the hedge funds quite, yes, sir.
20 MS. TRENCH: Object to form.
21 BY MR. SCHERER:
22 Q Why did you send them the money that you
23 referenced in that email on May 6th, '09?
24 A I didn't want anyone exploding and blowing the
25 whistle and blowing up the Ponzi scheme.
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1 MR. SCHERER: Okay. Thank you. No
2 further questions.
3 MR. LICHTMAN: Sam, while they're
4 switching tables, I'm going to ask five very
5 quick questions that make clear the Magistrate
6 Seltzer had no complicity in the fraud.
7 So do that, and by the time you get here,
8 I'll be done.
9 MR. RABIN: I think that's clear.
10 MR. LICHTMAN: I'm going to ask the
11 questions.
12 FURTHER EXAMINATION
13 BY MR. LICHTMAN:
14 Q Scott, you weren't on the Federal JNC,
15 correct?
16 A No, sir.
17 Q You had zero ability to play any role in
18 assisting Magistrate Seltzer in reaching aspirations of
19 becoming a federal judge; is that correct?
20 THE REPORTER: Hold on a second. I'm
21 having trouble hearing you with all the
22 shuffling. Maybe you want to come over this
23 way.
24 BY MR. LICHTMAN:
25 Q You had zero ability to play any role in
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1 assisting Magistrate Seltzer in becoming a federal
2 judge, correct?
3 A I really don't know the answer to that
4 question. I don't know how deep my influence in
5 Washington ran, but I can tell you that Judge Seltzer
6 wasn't expecting anything illegal from me.
7 Q In 2008 and 2009, there was a democratic
8 president, correct?
9 A Yes.
10 Q Okay. When you went in to see Magistrate
11 Seltzer with Ted Morse, you were playing Judge Seltzer
12 that day, correct?
13 A I --
14 Q You were manipulating Judge Seltzer?
15 A I was manipulating Judge Seltzer, yes.
16 Q And Judge Seltzer had no idea he was being
17 manipulated, correct?
18 A Absolutely. He had no idea.
19 Q Would you agree that your knowledge of
20 Magistrate Seltzer is that he's a judge of the highest
21 character and integrity?
22 A Say that again. I'm sorry.
23 Q Would you agree that Magistrate Seltzer, from
24 your knowledge of him, is a judge of the highest
25 character and integrity?
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1 A Absolutely.
2 Q So no one should draw the slightest inference
3 by his use of the name in this thing with Ted Morse,
4 that he knew of or participated in any wrongdoing,
5 right?
6 A Judge Seltzer knew nothing about anything that
7 was going on --
8 Q All right.
9 A -- and I took advantage of him, yes.
10 And I'm not sure that a democrat was in office
11 when you're saying that, just so we're clear.
12 Q 2008? Oh, 2009.
13 A Yeah, 2009.
14 MR. LICHTMAN: Okay. All right. Thank
15 you.
16 THE WITNESS: I think you're wrong.
17 MR. RABIN: We have to take a ten-minute
18 break.
19 (Thereupon, a recess was taken.)
20 DIRECT EXAMINATION
21 BY MR. RABIN:
22 Q All right. Good morning, Mr. Rothstein.
23 A Good morning, Mr. Rabin.
24 Q All right. You and I, although you know my
25 name and we spoke briefly at the beginning of or during
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1 this deposition, we never met before, correct?
2 A Not to my knowledge, no, sir.
3 Q You have never represented me in any matters?
4 A No, sir.
5 Q I have not participated in your rock-star
6 lifestyle?
7 A No, sir.
8 Q Okay. First of all I want to dispel this myth
9 that seems to have been created that you wouldn't be
10 testifying without Mr. Nurik here. You understand,
11 first of all, that you're here pursuant to court order,
12 don't you?
13 A Yes, sir.
14 Q And a subpoena?
15 A I've never seen a subpoena, but I know the
16 judge ordered me to be here, yes, sir.
17 Q And you know that this is -- also, that the
18 government expects you to cooperate in any and all
19 proceedings that you're required to be at, right?
20 A Yes, sir.
21 Q Okay. So you're not saying that you would
22 risk your Rule 35? You're not saying that you would
23 violate a court order and be held in contempt by
24 refusing to go testify if Mark Nurik weren't sitting
25 next to you, are you?
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1 A I believe that I have a right to have counsel
2 at all times that I'm testifying regarding any of these
3 matters, so I don't believe a judge would order me to be
4 here without counsel. So I can't answer your question.
5 You're asking me to guess about something that is not
6 going to happen.
7 Q All right. Well, you have access to Lexis,
8 don't you?
9 A Yes, sir.
10 Q Take a look, when you get back, do one of your
11 searches on your right to counsel post-sentencing; you
12 may find that you don't have a right to counsel. But
13 let's go on from there.
14 I want to ask you some questions about your
15 conditions of confinement; and in asking you these
16 questions, I want to make it clear from the beginning,
17 so there is no objections from the government and
18 marshals, I do not want to know anything about your
19 location.
20 Do you understand that?
21 A I do.
22 Q I have noticed that you come to court every
23 day in street clothes and new outfits every day; is that
24 correct?
25 A That's not correct.
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1 Q Okay. Well, fresh shirts?
2 A Yes.
3 Q Okay. And when you leave here, do you change
4 into prison garb?
5 MR. LAVECCHIO: Objection, privilege.
6 MR. RABIN: As to whether he changes into
7 prison garb?
8 MR. LAVECCHIO: Yes, sir.
9 BY MR. RABIN:
10 Q All right. You indicated you have access to
11 Lexis?
12 A Yes, sir.
13 Q Okay. And I assume that that's unlimited
14 access?
15 A There's actually a time frame that you can go
16 on. I can do research for a certain number of time and
17 then it shuts me off so someone else can use it. So
18 it's not unlimited, but I have access. It's the way we
19 have our prison library. It's instead of books.
20 Q All right. And is there any restrictions on
21 the types of searches that you can do on Lexis?
22 A I don't believe so, but I don't know. I never
23 had it stop me from searching; but then again, I was
24 only searching me.
25 Q In addition, have you -- do you also have a
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1 television?
2 MR. LAVECCHIO: You can answer.
3 BY MR. RABIN:
4 Q I mean, it's a simple question: You either
5 have a television or you don't.
6 A Yes.
7 Q Okay.
8 MR. NURIK: Let the record reflect that
9 the time that he spent to pause was not for
10 any other reason than to determine whether or
11 not the government was going to interpose a
12 privilege objection.
13 MS. TRENCH: I'm sorry. I'm having
14 trouble hearing.
15 MR. NURIK: The time he spent to pause is
16 for no other reason than for him to determine
17 whether or not the government was going to
18 interpose a privilege objection.
19 BY MR. RABIN:
20 Q Do you also have access to some exercise
21 equipment?
22 A Yes.
23 Q Okay. And I notice that you seem to have lost
24 some weight, right?
25 A Yes.
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1 Q Okay. About how many pounds have you lost?
2 A Thirty-five.
3 Q Okay. You've cut your hair, and you have
4 grown a little facial hair, correct?
5 A Yes.
6 Q Okay. Other than that, your appearance has
7 been the same?
8 A Yes, sir.
9 Q Okay. Now, the lawyers that have questioned
10 you earlier in this week, you met with Mr. Lichtman, who
11 you call "Chuck," for approximately three days, you
12 said, much earlier in the year, I guess?
13 A Yeah. I spent two or three days with Mark,
14 prepping, and Mr. Nurik, prepping; and then I met with
15 Mr. Lichtman and his people for three days.
16 Q Okay. And then since that time, have you met
17 with him additional times?
18 A No, sir.
19 Q Okay. So a total of three days?
20 A Yes, sir.
21 Q And before the deposition, how many times did
22 you have the opportunity to meet with Mr. Scherer or
23 anybody that works with him?
24 A The very first time that I spoke with
25 Mr. Scherer was when he started questioning me here. I
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1 haven't spoken with him or met with him.
2 Q But you did speak with him through Mr. Nurik,
3 who you spoke to and authorized Mr. Nurik to speak with
4 Mr. Scherer on your behalf, correct?
5 A It's too many questions in one question.
6 Q Fair enough. Let me break it down.
7 You did authorize Mr. Nurik to speak to Mr.
8 Scherer on your behalf, correct?
9 A Yes, I did.
10 Q Okay. And there was essentially a dialogue
11 that was going on where Mr. Scherer would want to know
12 things, and those things were, essentially, asked of you
13 by Mr. Nurik and then answered back to Mr. Scherer by
14 Mr. Nurik, correct?
15 A No, sir. To the best of my recollection that
16 is exactly not the way it was occurring.
17 Q Well, tell us how it occurred then.
18 A As part and parcel of my review of things that
19 are part of my cooperation, I would provide information
20 to Mr. Nurik and I gave him authorization that, as he
21 saw fit, he could share it with Mr. Scherer.
22 Q Okay. Let's talk -- that brings us right into
23 what you were reviewing. You said earlier that you
24 reviewed hundreds of thousands of documents, correct?
25 A I have never stopped to count them, but I have
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1 been literally reviewing documents since the day I set
2 foot back on US soil.
3 Q And the documents that you have reviewed
4 include emails from you, correct?
5 A Yes.
6 Q And so that gives you benefit of refreshing
7 your recollection as to certain events, right?
8 A Yes.
9 Q And the documents you have reviewed include
10 emails that you weren't even a party to, correct?
11 A Correct.
12 Q And that gives you the benefit of not only
13 refreshing your recollection of events, but learning
14 about what other people were saying and doing, correct?
15 A Sure.
16 Q Okay. And did you ever review the Coquina
17 complaint that was filed in one of the cases that
18 revolves around you?
19 A I don't recall one way or the other whether I
20 did.
21 Q Have you --
22 A After having reviewed so many documents, I
23 don't remember specifically. Certain ones stick out in
24 my mind. That one is not sicking out.
25 Q Have you reviewed any depositions or trial
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1 transcripts as part of the documents you were reviewing?
2 A Depositions?
3 Q Depositions or trial transcripts.
4 A No trial transcripts.
5 Q Okay.
6 A Deposition transcripts, yes.
7 Q Okay. Approximately, how many deposition
8 transcripts have you had the opportunity to review?
9 A I don't recall.
10 Q Okay. Let's talk about before you left for
11 Morocco. Would it be fair to say that you lied and
12 deceived everyone you knew?
13 A At least to some extent, yeah, sure, I did.
14 Q You lied to your law partners?
15 A Yes, sir.
16 Q You lied to investors?
17 A Yes, sir.
18 Q You lied to your friends?
19 A Yes, sir.
20 Q You lied to your family members?
21 A I did.
22 Q You lied to professionals that you employed,
23 including bankers?
24 A The ones that weren't involved, yes, sir.
25 Q Well, you -- you didn't tell any banker what
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1 you were doing, did you?
2 A Well, you're assuming that they asked me.
3 Q Well, I am asking you, did you tell any banker
4 what you were doing?
5 A To a limited extent, to the extent that they
6 needed to know, yes; and otherwise, no.
7 Q Otherwise you kept them in the dark about what
8 you were doing, correct?
9 A I didn't tell them anything that I didn't
10 think they needed to know in order to fulfill their
11 obligations to me.
12 Q Accountants, same thing, you didn't tell them
13 what you were doing?
14 A I told one accountant a lot; everything, no.
15 Q And as part of your lies --
16 A And I also told one banker a lot, also, and a
17 few lies, but a lot of -- a lot of detailed information.
18 Q As part of your lies, you used the court --
19 essentially incorporated the court in your lies and in
20 your deception, correct?
21 A I did.
22 Q All levels of federal court, starting at the
23 magistrate level, district court level, into the circuit
24 court level, right?
25 A I did.
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1 Q Okay. And not only forging court orders but
2 having people pretend to be judges?
3 A Yes.
4 Q And even incorporating Judge Seltzer, as -- he
5 was unaware, but incorporating him into your scheme, so
6 actually visiting him and incorporating him into your
7 scheme?
8 A Yes, sir.
9 Q And you did all this for one purpose, right?
10 A Multiple purposes.
11 Q Well, the one singular purpose, though, was to
12 make money, right?
13 A Multiple purposes.
14 Q Did you use charities in a way to give
15 yourself the air of legitimacy?
16 A No.
17 Q You never used charities to give yourself
18 legitimacy?
19 A I discussed this in my testimony the other
20 day. I --
21 Q I understand that, but you understand I can
22 ask you questions about your testimony, don't you?
23 A Yes.
24 Q So I am asking you, did you use the charities
25 in order to give yourself legitimacy?
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1 A It turns out that it did give me legitimacy,
2 but this is one of those times that I'm going to differ
3 with you on it, okay. It was not my intention. With a
4 lot of things that's I spent money on and a lot of
5 things that I did, I intended to create a specific air
6 around me.
7 When I was giving money to the charities, like
8 Joe DiMaggio Children's Hospital, I was actually trying
9 to help the children there -- with stolen money, but I
10 was trying to help them.
11 Q Well, certainly you deceived the charities by
12 not letting them know it was stolen money; and more
13 importantly, it did have the effect of giving the air of
14 legitimacy, correct?
15 A That's two questions. Let me answer both of
16 them.
17 Yes, I deceived charities; and yes, it
18 absolutely added to the air of legitimacy.
19 Q You used the political process in order to
20 further your scheme, correct?
21 A That I absolutely did, yes, sir.
22 Q And there were times when you either falsely
23 exculpated people, didn't you?
24 A I falsely exculpated people? Yes, I tried to
25 save a bunch of my co-conspirators from jail, I did.
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1 Q You falsely created the persona that you were
2 a successful lawyer when you were not, correct?
3 A That's correct.
4 Q You pretended to have a successful law firm,
5 when you didn't?
6 A That's correct.
7 Q You pretended to be a legitimate lawyer,
8 correct?
9 A That's correct.
10 Q And a legitimate investor?
11 A That's correct.
12 Q And, in fact, you really were, to quote you --
13 let me show you an exhibit...
14 (Thereupon, the document was marked as
15 Defendant's Exhibit No. 172 for Identification.)
16 MR. RABIN: I am showing what is marked
17 as Plaintiff's -- or Defendant's Exhibit -- we
18 are going in order, 172. It's an email, Scott
19 Rothstein, October 31st, 2009, to George
20 Levin?
21 THE WITNESS: Give me one second. I
22 can't see.
23 MR. RABIN: Take your time.
24 UNIDENTIFIED SPEAKER: What page is that
25 email?
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1 MR. RABIN: Mr. Rothstein -- it's from
2 Scott Rothstein to George Levin dated
3 October 31, 2009, at 3:33.
4 BY MR. RABIN:
5 Q Why don't you read it out loud, Mr. Rothstein.
6 A Sure.
7 It's from me to George, subject, me: Do not
8 try to bail me out of this. Save yourself. You and
9 Frank did nothing wrong. I did. I am the liar. I am
10 the thief. I am the scum bag. I either go to jail or
11 die. Why should I put my family through watching me go
12 to jail. Love forever, Scott.
13 Q So, the way you describe yourself was as a
14 scum bag, correct?
15 A I absolutely was.
16 Q Okay. Now, let's move forward to your --
17 let's move forward to your sentencing.
18 At your sentencing, you -- you made some
19 promises, didn't you?
20 A I believe I did, yes, sir.
21 Q You promised to help people recover money,
22 your investors recover money?
23 A Innocent investors, yes, sir.
24 Q Okay. You pledged to help Mr. Scherer, didn't
25 you?
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1 A I -- I don't -- I haven't seen the transcript
2 from it, but if you're saying I did, if you can show me
3 something where I said that; but Mr. Scherer, since I
4 now know him to be representing a group of innocent
5 investors, if I didn't pledge to do that, I would have,
6 absolutely.
7 Q Do you remember Mr. Nurik at your sentencing
8 hearing, talking about, pointing out the fact that Mr.
9 Scherer was in the audience and that he was here and
10 that was somewhat remarkable because he was one of your
11 major protagonists prior to that?
12 A So you're saying Mr. Nurik said it on my
13 behalf? That, I believe, is correct, yes.
14 Q Okay. Well. Through --
15 A Hang on.
16 Through Mr. Nurik, I did pledge to help
17 certain people, yes.
18 Q And, in fact, Mr. Scherer even was benevolent
19 enough to write a letter on your behalf to the
20 sentencing judge?
21 A Yes, he was very kind in doing that.
22 Q And you previously -- your relationship with
23 Mr. Scherer is, in fact, he was your client once, wasn't
24 he?
25 A He was a client of the law firm at some point
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1 in time.
2 Q Did you represent him?
3 A I don't remember whether it was me,
4 specifically me, in conjunction with other lawyers.
5 If you have a document that you can show me,
6 it may refresh my recollection.
7 Q And, now, in helping your legitimate
8 investors, as you put it, and your former client, Bill
9 Scherer, have you identified who the deepest pocket is
10 in all this litigation?
11 A No, sir.
12 Q Yeah, well, you know that, don't you?
13 A I could tell you who I think the deepest
14 pockets are.
15 Q Who do you think it is?
16 A TD Bank.
17 Q Oh, okay. Now let's talk about your
18 cooperation. I wasn't here yesterday in the afternoon
19 for that, but I understand that the subject of a Rule 35
20 came up, and I would like to pursue that a little bit.
21 You understand what a Rule 35 is, correct?
22 A I do, sir.
23 Q You understand that there is only one person
24 or group of people that can file that motion on your
25 behalf, correct?
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1 A I do, sir.
2 Q And Mark Nurik can't file that motion for you?
3 A Right. The only person that can file it is
4 the government.
5 Q And you understand that the government -- in
6 order for the government to file that motion, first of
7 all, if they file it, and they, of course, will never
8 promise you that they will file it, right?
9 A They have never promised me.
10 Q They won't promise you; they will never make
11 that promise, correct?
12 A I don't know what they'll do. They have not
13 promised me. I don't know what they are going to do in
14 the future.
15 Q So, but in order for the government to
16 consider filing that motion, they have to be convinced
17 that your testimony is complete and truthful, correct?
18 A Yes.
19 Q And you understand --
20 A No truth, no Rule 35.
21 Q And you understand that there are components
22 of the cooperation that involve you helping them to
23 recover money, correct?
24 A To the extent that they would be forfeiting
25 people's property, as I understand the United States
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1 government, yes, to that extent, yes. This other stuff
2 is all the civil lawyers. It has nothing to do with the
3 government.
4 Q You also understand you would have to testify
5 in any court proceedings in which you could be a
6 potential witness?
7 A Yes, sir.
8 Q And as often -- as often as needed, you would
9 have to testify against as many people as they wanted
10 you to, where you had -- where you had information?
11 A My understanding, yes, on the criminal side
12 I've got to testify every time they want me to, yes.
13 Q And you also you understand that if you do
14 additional things, that that is an added arrow in your
15 quiver of cooperation? Like working undercover, that is
16 something that is looked upon as favorable, correct?
17 A I am assuming that it's looked upon as
18 favorable if they asked me to work undercover, yes, sir.
19 Q And likewise, if you were to put your life in
20 danger, that would also be a factor that would be
21 considered, right?
22 A Yes, sir.
23 Q And all of these -- all of these combined
24 together -- in the event the government files a Rule 35,
25 all of these combined together to give you the potential
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1 for a sentence reduction, right?
2 A Yes, sir.
3 Q Okay. Now, we already know that you
4 essentially lied in every aspects of your life in order
5 to get money; but of course, you would never lie in
6 order to get a Rule 35, right?
7 A No, sir, I absolutely would not.
8 Q And --
9 A If I lie and get caught lying, even an little
10 bit, I will die in prison.
11 Q Well, that's really the key, isn't it? You
12 could really lie, as long as you didn't get caught,
13 right?
14 A Apparently you don't know Mr. LaVecchio and
15 his co-AUSA's. I wouldn't even venture an attempt. I
16 did not come back from a non-extradition country, where
17 I was sitting with more money than I would spend in ten
18 lifetimes, okay, to come back here and lie again. That
19 was not the purpose.
20 Q That's a lie right there because, in fact, you
21 only had how much money, 15 million, 16 million? You
22 spent 200 million in the two years of your Ponzi scheme,
23 so you could easily spend that in much less than a
24 lifetime, couldn't you?
25 A Apparently you have never been in Morocco. I
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1 could have lived in Morocco with $15 million at least --
2 at least 100 years, very well. I had priced it all out.
3 Q Did you --
4 A I could live as I was living in Fort
5 Lauderdale for $10,000 a month with a full staff.
6 Q Did you go to Morocco before you fled there to
7 check it out?
8 A Yeah. On and on top of that, by the way, I
9 also had a watch collection with me and some jewelry
10 that was worth several million dollars.
11 Q Well, we're going to get to what you took on
12 the plane.
13 MR. RABIN: Thank you, Mr. Nurik, for
14 pointing that out to him.
15 BY MR. RABIN:
16 Q Did you go to -- did you go to Morocco before
17 you fled there in order to check it out?
18 A No, sir.
19 Q Okay. Now, you talked about drug use. What
20 drugs did you use during the time that you were running
21 around committing your crimes?
22 A During the time of the Ponzi scheme, I -- the
23 only drug I used was I smoked pot, and I took
24 prescription medication.
25 Q All right. So you're saying when you talked
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1 about drug use, I think as part of the rock-star
2 lifestyle, in fact, as I think one of Mr. Scherer's
3 PowerPoints, sex and drugs, the only drug you're talking
4 about that you used was marijuana?
5 A Mr. Scherer's PowerPoint regarding drug use as
6 part of the rock-star lifestyle was incorrect. I smoked
7 pot on the weekends with my wife.
8 MR. LICHTMAN: Sam, if you don't mind. I
9 know that the other court reporter just showed
10 up and I don't know --
11 MR. SCHLESINGER: They asked us to stop
12 at one, so thank you, Chuck.
13 BY MR. RABIN:
14 Q All right. So you said the only drugs you
15 used were marijuana with your wife. Is she the only --
16 you didn't -- that wasn't incorporated in the rock-star
17 lifestyle, using drugs with any of your investors or
18 co-conspirators?
19 A No, actually, never.
20 Actually, I had a lot of opportunities to
21 because there was a lot of marijuana smoking going on in
22 my office, but it wasn't something -- I prefer to drink
23 vodka.
24 Q Actually in the office it was going on?
25 A In the office, in the garage, outside the
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1 office, I had some partners that couldn't come to work
2 without smoking pot.
3 Q Okay.
4 A I also found out they were actually dealing
5 drugs in the office. I actually tried to put a stop to
6 that.
7 Q That was one crime you wouldn't tolerated?
8 A No, no, it's not that. I didn't want to draw
9 attention. You don't want to have marijuana dealing
10 from the middle of your law office because I was running
11 a giant Ponzi scheme out of there.
12 Q Did you ever have any of the escorts visit the
13 office?
14 A Yeah. Sure.
15 Q You had had prostitutes in the office, but you
16 wouldn't have pot?
17 A You're missing the point. The police also
18 were sleeping with my escorts. You, obviously --
19 listen, Broward Sheriff's Office, Fort Lauderdale Police
20 Department weren't going to bother me, okay, I could
21 have had all the escorts I wanted.
22 Pot, not a great idea in the office, I don't
23 know why, specifically, it bothered me; but it troubled
24 me, probably because they were actually dealing the pot
25 out of the office while I was in the middled of running
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1 a several-hundred-million-dollar Ponzi scheme.
2 Q Okay. You -- you indicated that you had plans
3 to kill yourself, I guess, on more than one occasion,
4 right?
5 A Twice.
6 Q Twice, once with the .357 in the shower; is
7 that one of them?
8 A Yes, sir.
9 Q Okay. Was that gun loaded, by the way?
10 A Yes, sir.
11 Q Was it registered?
12 A What do you mean "registered"?
13 Q I mean --
14 A I had a concealed weapons permit. It was a
15 legal weapon, yes.
16 Q I'm asking where did you get the gun, is
17 basically what I was asking.
18 A You don't register weapons in Florida. You
19 just purchase them, and they send off the information.
20 I didn't have to register it. It was registered when I
21 purchased it.
22 Q Actually, thank you for that tip, but you can
23 register guns in the State of Florida. Okay?
24 A I said you don't have to. I am not arguing
25 with you. I just did whatever was legally necessary to
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1 purchase the weapons.
2 Q And that was one of only two times you
3 attempted to kill yourself, correct?
4 A Actually, attempted to kill myself, yes, there
5 was two -- two occasions.
6 Q One was with putting the gun to your head in
7 the shower while were you dressed in a suit, and the
8 other one was pills in Morocco?
9 A Pills and vodka, yes.
10 Q Okay. And did you -- you didn't actually take
11 any of the pills, though, right?
12 A I had started to take the pills but --
13 Q Now --
14 A -- I didn't finish.
15 Q What kind of pills were they?
16 A Xanax and blood pressure medication.
17 Q That blood pressure medicine will get you.
18 Have you ever been treated by a doctor for
19 mental illness?
20 A I have been treated for anxiety disorder.
21 Q Has a doctor ever told you that you have you a
22 mental illness?
23 A No.
24 Q Okay. So when you say mental -- what anxiety
25 disorder?
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1 A Yeah. I was diagnosed with -- I think it's
2 called -- it wasn't -- the word wasn't severe anxiety
3 disorder. It was some -- it was some --
4 Q Acute anxiety?
5 A Acute. There we go. Acute anxiety disorder.
6 Q And that was when you came back, right?
7 A Oh, no, sir. I was --
8 Q It was before?
9 A Let me finish, please.
10 I was diagnosed with acute anxiety disorder
11 going all the way back to the time I was in college.
12 Q Okay. So back starting in college, you're
13 talking, what year would that have been?
14 A I was in college from 1980 to 1984.
15 Q So -- and you have had, I guess, multiple
16 doctors diagnose you -- diagnose you with this acute
17 anxiety disorder?
18 A Yeah, when I was the University of -- it was
19 either when I was in the University of Florida or when I
20 was in law school and I started to have very severe
21 panic attacks. I was diagnosed, actually by -- my
22 gastroenterologist diagnosed me.
23 Q Okay. What was his name?
24 A At the time, Steven Sackel.
25 Q And who was the last doctor that treated you
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1 for your acute anxiety disorder?
2 A Dr. Fernando Mata, a psychiatrist in Fort
3 Lauderdale.
4 Q Are you presently taking any medication for
5 depression or anxiety?
6 A I'm taking sertraline -- that's the generic
7 name; I don't know what the actual drug is. I take a
8 few milligrams of that every day for the anxiety
9 disorder.
10 Q Okay. Let's turn now --
11 Before I start that, we'll take a break.
12 (Thereupon, at 10:54, a recess was had.)
13 - - - - -
14
15
16
17
18
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1 C E R T I F I C A T E
2
3 THE STATE OF FLORIDA, ) COUNTY OF BROWARD. )
4
5 I, Michele L. Savoy, Shorthand Reporter do
6 hereby certify that I was authorized to and did
7 report the foregoing proceedings and that the
8 transcript is a true record.
9 Dated this 16th day of December, 2011.
10
11 ______________________________
12 Michele L. Savoy, RPR Notary Public - State of Florida
13 My Commission No. EE 113173 Expires August 6, 2015
14
15
16
17
18
19
20
21
22
23
24
25
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1 C E R T I F I C A T E
2 THE STATE OF FLORIDA, ) COUNTY OF BROWARD. )
3
4 I, Michele L. Savoy, Shorthand Reporter,
5 do hereby certify that I was authorized to and did
6 report said deposition in stenotype; and that the
7 foregoing pages, numbered from 1127 to ,
8 inclusive, are a true and correct transcription of
9 my shorthand notes of said deposition.
10 I further certify that I am not an
11 attorney or counsel of any of the parties, nor am I
12 a relative or employee of any attorney or counsel or
13 party connected with the action, nor am I
14 financially interested in the action.
15 The foregoing certification of this
16 transcript does not apply to any reproduction of the
17 same by any means unless under the direct control
18 and/or direction of the certifying reporter.
19 Dated this 16th day of December, 2011.
20
21 ___________________________________
22 Michele L. Savoy, RPR Notary Public - State of Florida
23 My Commission No. EE 113173 Expires August 6, 2015
24
25
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1172:21 1223:4influencing
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infusion 1221:3inhand 1211:11inhouse 1210:20,23
1211:5initial 1179:1initially 1169:6,6
1210:8injury 1203:14innocent 1237:23
1238:4inside 1170:25
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1137:3insulate 1206:16insurance 1130:11
1130:12,16integrity 1223:21
1223:25intended 1235:5intention 1138:15
1154:25 1235:3interest 1154:3,15
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1228:18interrupt 1140:1
1140:13introduce 1170:1invest 1189:6,8
1191:7invested 1157:19
1158:15 1189:15investigation
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investments 1163:61163:7
investor 1161:11211:7,101215:14,18,251236:10
investors 1161:6,121161:15,161162:21,231163:1 1164:11165:16 1181:81181:13 1188:2,31189:5 1193:131194:17 1195:251200:11 1221:81232:16 1237:221237:23 1238:51239:8 1244:17
invited 1177:251178:11
involve 1240:22involved 1137:6
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joked 1202:2
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jones 1139:13jovial 1164:22jr 1131:6judge 1139:1,22
1140:24 1141:191141:23,251142:6,191143:24,25,251144:16,181145:24 1148:211149:5,9 1166:191166:24 1169:211169:23,24,251170:1,3,4,8,141170:15,211171:2,9,181172:9,23 1176:21176:8 1177:9,181179:4 1222:191223:2,5,11,14,151223:16,20,241224:6 1225:161226:3 1234:41238:20
judges 1172:221174:14 1234:2
judgeship 1170:24judgment 1154:2
1154:25judicial 1127:1
1128:1judiciary 1171:13
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Kkalter 1162:7,15kaplan 1131:2kathleen 1181:14
1181:21katzen 1131:2keechl 1130:1keep 1133:20
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1156:23 1212:21233:7
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knowed 1193:19,201193:22
knowing 1160:16
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kopelowitz 1130:1kozyak 1129:16kretschmar
1161:25 1164:15
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1131:9late 1162:23
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1215:23,241243:5 1245:191249:3
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1214:20 1215:21lavecchio 1152:6,7
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lawyers 1138:31200:24 1208:161208:18 1216:231216:23 1217:31229:9 1239:41241:2
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length 1179:10leon 1129:16letter 1173:8
1180:9,9,12,14,17
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1181:10letting 1235:12level 1172:21
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lies 1233:15,17,181233:19
life 1136:3 1182:231241:19 1242:4
lifestyle 1190:171225:6 1244:2,61244:17
lifetime 1242:24lifetimes 1242:18lifshitz 1214:24
1215:3,13lightning 1133:20
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lipsitzs 1215:8,9list 1155:17listen 1193:10
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1131:1llp 1129:12loaded 1246:9location 1138:8
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1211:5long 1138:4,18
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lord 1161:18loss 1156:1lost 1228:23 1229:1lot 1134:12 1137:9
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major 1238:11making 1141:22
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man 1165:101182:12,131208:17 1210:121212:14 1217:12
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manipulated1223:17
manipulating1223:14,15
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marra 1139:3,4,221140:25 1141:191141:23,251142:6,191143:25 1144:161145:14,17
marras 1139:1married 1188:14
1188:22marshal 1173:16marshals 1226:18mata 1249:2matched 1181:3
mathematics1179:12
matter 1137:21matters 1225:3
1226:3mcginnis 1179:17meadow 1188:15mean 1136:24
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meaning 1197:20means 1251:17medication
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medicine 1247:17meet 1229:22meeting 1163:18
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1216:2mental 1247:19,22
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1145:8 1163:3mentions 1207:3merely 1213:2messing 1169:5met 1161:23
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metadata 1132:91146:12,131147:7,10,201169:5 1173:101173:13,24
methodologies1191:4
methodology1175:7
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michael 1130:61131:15 1179:17
michele 1127:221250:5,12 1251:41251:22
middle 1245:10middled 1245:25mike 1162:1,9miller 1130:13milligrams 1249:8million 1139:6,7,7
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millions 1157:211182:1
mills 1131:5mind 1133:16
1183:6 1231:241244:8
minus 1157:21minute 1144:13
1156:13 1165:241203:17 1213:10
minutes 1175:61203:24 1208:23
misconstrued1163:15
missed 1144:23missing 1245:17mode 1146:22modest 1201:17,20
1202:18 1203:21203:12
modification1148:11 1175:2
modified 1148:2,71148:9 1175:1,5
moment 1170:71204:20,211206:5 1207:20
money 1139:18,191153:4,241154:10,13,141155:1 1156:101156:12,151157:5,9,16,22,241160:21 1187:251194:1,3,4,51195:6 1197:41200:3 1205:181205:22 1207:7,91209:19,20,221210:20,221211:5,6,6,7,101211:15 1213:211213:22,22,231214:1,2,2,6,101214:10,201215:21 1218:151220:17,21,221221:16,18,221234:12 1235:4,71235:9,121237:21,221240:23 1242:51242:17,21
moneyin 1159:12monitor 1204:11
monkey 1197:171197:20,24
month 1201:251243:5
months 1153:211189:10
morning 1127:121133:4,5,81148:14 1209:11224:22,23
morocco 1136:201218:20 1232:111242:25 1243:1,61243:16 1247:8
morse 1128:5,5,51130:20 1140:51140:23 1141:181141:18,21,211142:4 1143:11148:13 1152:211153:20 1156:31158:4,6,151159:25 1160:1,11166:11,14,171179:15 1193:221216:1 1223:111224:3
morses 1135:131139:6 1140:4,121144:20 1146:71149:12 1150:81153:19 1155:151156:9,22 1157:11157:24 1167:21
moskowitz 1129:18mostprofitable
1164:9,12motion 1135:14
1239:24 1240:2,61240:16
motor 1206:18mouth 1143:24move 1134:17
1140:16 1167:231179:23 1184:121184:14 1237:161237:17
msnbc 1134:16mullin 1130:23mullins 1139:25
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Nn 1127:18 1128:16
1128:21 1131:5name 1162:7
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nature 1133:101164:17 1172:71179:25
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necessary 1246:25need 1151:2,3,3
1167:16 1168:61179:23 1180:12
1180:22,241184:13,141195:5 1204:141206:10 1209:13
needed 1143:151200:8 1214:21233:6,10 1241:8
needs 1143:13neither 1160:6never 1163:8,16
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new 1130:14,141140:18 1162:171186:7 1187:181187:18 1188:2,31190:22 1195:251198:8 1200:151215:10 1218:161226:23
news 1134:5,9nice 1182:12ninth 1129:17nomination
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nordlichts 1217:15normal 1165:3notary 1250:12
1251:22notate 1175:7note 1137:16
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notes 1216:11251:9
notice 1228:23noticed 1140:7
1226:22number 1143:10
1147:12 1217:181227:16
numbered 1251:7numbers 1159:6nuptials 1170:4nurik 1129:2,4
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Ooath 1132:6
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object 1141:71142:8 1149:151155:6 1184:5,141186:10 1187:61189:12 1190:21190:10 1191:101192:7 1193:71194:12,191195:17,231196:6 1197:101197:16 1198:21199:4,191200:21 1201:121201:19 1202:91218:10 1219:31221:20
objected 1144:13
objection 1137:161140:3,151144:11 1146:181146:23 1150:131152:7,24 1154:71154:11 1156:181158:10 1160:121167:23 1181:171183:22 1186:121190:14,191212:25 1220:151227:5 1228:121228:18
objectionable1142:12
objections 1226:17obligations
1233:11obviously 1133:24
1136:24 1142:181153:9 1170:141171:15 1200:191245:18
occasion 1246:3occasions 1143:22
1162:10 1178:121180:3 1185:251247:5
occur 1163:23occurred 1171:21
1188:25 1214:211230:17
occurring 1172:41230:16
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offense 1135:3office 1129:2
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offshore 1197:8,91197:24
oh 1143:24 1161:181162:2 1224:121239:17 1248:7
okay 1133:12,231134:3,13 1135:61136:4 1138:4,81139:3 1141:151142:17,211143:8 1144:101145:9 1147:5,241148:12 1150:161151:19 1152:101153:25 1154:171159:18 1160:21161:10,18,231163:8,211166:22 1167:131167:18 1168:231169:12 1171:141172:4,241173:23 1174:81174:15,251175:19,241176:1 1178:211180:1 1182:91186:9,201190:24 1191:161192:1,11,13,231193:19,211194:2,25 1195:71195:13 1196:101196:16 1197:231198:10,19,211199:9,13,21
1202:18 1204:21204:11,241206:14 1207:5,51207:9 1208:211208:25 1213:31215:6,12,15,161218:12,181219:21 1221:91222:1 1223:101224:14 1225:81225:21 1227:1,31227:13 1228:71228:23 1229:1,31229:6,9,16,191230:10,221231:16 1232:5,71232:10 1234:11235:3 1237:161237:24 1238:141239:17 1242:31242:18 1243:191245:3,20 1246:21246:9,231247:10,241248:12,231249:10
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old 1212:14once 1165:15
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ones 1163:31231:23 1232:24
operation 1153:201179:15 1213:14
operations 1128:5opinion 1191:16,25
1192:3,13,22,251193:17,241210:15 1213:3
opportunities1244:20
opportunity1140:12 1179:23
1229:22 1232:8oppose 1140:17order 1138:9,23,23
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