Allen Stanford Criminal Trial Transcript Volume 11 Feb. 6, 2012

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Johnny C. Sanchez, RMR, CRR - [email protected]

3143

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

UNITED STATES OF AMERICA * 09-CR-342* Houston, Texas

VS. ** February 6, 2012

ROBERT ALLEN STANFORD * 10:07 a.m.

JURY TRIAL

VOLUME 11

BEFORE THE HONORABLE DAVID HITTNERUNITED STATES DISTRICT JUDGE

APPEARANCES: APPEARANCES:

FOR THE GOVERNMENT:Gregg J. CostaAssistant US AttorneyPO Box 61129Houston, Texas 77208-1129

William StellmachAndrew Howard WarrenU.S. Department of Justice1400 New York Avenue NWWashington, DC 20005

FOR THE DEFENDANT:Ali R. FazelRobert ScardinoScardino & Fazel1004 Congress Street3rd FloorHouston, Texas 77002

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A P P E A R A N C E S: (Continued)

FOR THE DEFENDANT: (Continued)John M. ParrasAttorney at Law1018 PrestonFloor 2Houston, Texas 77002

Kenneth W. McGuireMcGuire Law FirmPO Box 79535Houston, Texas 77279

Court Reporter:Johnny C. Sanchez, RPR, RMR, CRR515 Rusk, #8016Houston, Texas 77002713.250.5581

Proceedings recorded by mechanical stenography. Transcriptproduced by computer-assisted transcription.

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3145

I N D E X

WITNESS PAGE

JAMES DAVIS

DIRECT EXAMINATION BY MR. STELLMACH............ 3146

CROSS-EXAMINATION BY MR. SCARDINO.............. 3296

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Direct-Davis/By Mr. Stellmach


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(The following was held before the jury)

THE COURT: Good morning everybody. Monday

morning, another week. We're ready to proceed. Screen is

coming down, so we're all ready to go.

Counsel, go right ahead.

MR. STELLMACH: Thank you, Your Honor.

JAMES DAVIS

CONTINUED DIRECT EXAMINATION

BY MR. STELLMACH:

Q. Good morning, Mr. Davis.

A. Good morning.

Q. When we ended on Friday, you were discussing

Mr. Hewlett, the auditor of the bank, who died on

January 1, 2009?

A. Yes, sir.

Q. And when you called Mr. Stanford, could you remind us

what he said when you told him that the auditor had died?

A. He said, "He's the lucky one."

Q. What was going on at the bank in terms of CD

redemptions at that time, end of 2008, early 2009?

A. The redemptions were --

MR. SCARDINO: Excuse me. Form of the

question. Ask that it be more narrow in scope as to what

was going on.

THE COURT: All right. Narrow it down, please.

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BY MR. STELLMACH:

Q. What was the rate of redemptions by the end of 2008

and in to early 2009?

A. At a very, very high rate compared to anytime in

history.

Q. And what about CD sales, sell of new CDs?

A. They were at a lower rate than much of the past five

years, six years.

Q. How focused was Mr. Stanford on the rate of CD sales?

A. I would say very focused.

Q. And going back a couple of years to the start-up of

the brokerage firm, Stanford Group Company, could you tell

us -- can you remind us what year that happened?

A. 1995, toward the end.

Q. And prior to 1995, had Mr. Stanford ever discussed

with you the possibility of opening a brokerage firm here

in the United States?

A. Yes. We had that discussion.

Q. And before 1995 what had Mr. Stanford told you about

his ability to open a brokerage firm?

A. Among other things, he said that it would probably be

very difficult.

Q. Did he explain why he thought it would be difficult?

A. Primarily because of his bankruptcy.

Q. From the time in the '80s when he owned those health

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clubs that failed?

A. Yes, sir.

Q. But Mr. Stanford in 1995 was, in fact, able to open a

brokerage firm here in the United States?

A. Yes, sir.

Q. Where did the money to open the brokerage firm come

from?

A. CD deposit holds.

Q. Who were Jay Comaeux and Al Truellenque?

A. Mr. Comaeux and Mr. Truellenque were the initial

hires for the new brokerage. They were hired as

co-presidents, and they came from Merrill Lynch in their

previous employ.

Q. How was Mr. Stanford able to persuade them to leave

Merrill Lynch and come to start up a new brokerage firm?

A. Better business opportunity, on a remuneration basis,

opportunity to elevate themselves in terms of position.

Q. And by "remuneration," did Mr. Stanford tell you

whether he was paying Mr. Truellenque and Mr. Comaeux

fairly well in order to leave Merrill Lynch and come to

start up the brokerage firm?

A. Yes, sir. Their pay was very competitive.

Q. Where were they based when the brokerage firm opened?

A. Baton Rouge, Louisiana.

Q. And over time did the brokerage firm open other

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branches and offices elsewhere in the United States?

A. Yes, sir.

Q. Where did the money come to do that?

A. The money came from CD deposit holders.

Q. Did the bank have any ownership interest in the

brokerage firm?

A. No, sir.

Q. Did the brokerage firm repay the bank?

A. No, sir.

Q. Who owned the brokerage firm?

A. Mr. Allen Stanford.

Q. All of it, to your knowledge?

A. Yes, sir.

Q. And, so, the brokerage firm opens 1995, 1996. How

shortly after that does it start selling CDs here in the

United States?

A. I would say four years, three to four years, maybe

five, maximum.

Q. Who made that decision, the decision to enable the

brokerage firm to sell the bank's CDs here in the U.S.?

A. Mr. Stanford. He was the chairman.

Q. What did Mr. Stanford tell you about that decision?

A. Well, that would be a huge market for the CD sales in

the United States.

Q. Are you familiar with the term "assets under

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management"?

A. Yes, sir.

Q. Could you explain what that meant or what that meant

in terms of Stanford Group Company, the brokerage firm?

A. Stanford Group Company was a broker dealer and as

such had financial advisors that represented hundreds of

clients. Those clients had investments. And those

investments would range from stocks, bonds, investment

funds, possibly metals. And those investments known as

assets would move to the brokerage when these clients

became customers of the broker dealer, and those assets,

after broker being managed by the various financial

advisors, would be known as assets under management.

Q. So by the end of 2008, 2009, how much in assets under

management did the brokerage firm have, to the best of

your recollection?

A. In the neighborhood of $40 billion.

Q. And some of that $40 billion that the brokerage firm

was managing, were those assets owned by the clients or

were they owned by Mr. Stanford?

A. They would be owned by the clients.

Q. So could Mr. Stanford take any of the assets under

management that were owned by the clients at the brokerage

firm and use them to repay CD depositors?

A. No, sir.

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Q. Mr. Stanford owned the brokerage firm, but he didn't

own all the assets under management?

A. That's correct.

Q. And when the brokerage firm first started selling CDs

here in the United States in those first couple of years,

approximately how much of the assets under management had

been put into CDs issued by Mr. Stanford's bank?

A. In the early days of the brokerage, there were

probably, in terms of dollars and cents, 20, $25 million.

Q. And overall as a percentage, to the extent you can

recall?

A. In the early days, as much as 85 percent of the

assets under management.

Q. Was Mr. Stanford comfortable with that?

A. Mr. Stanford was desirous of increased CD sales by

the broker dealer and other regions, so...

Q. And, initially, did Mr. Stanford say that he was

uncomfortable with the fact that so many of the assets of

the customers at the brokerage firm had been placed into

CDs issued by his bank?

MR. SCARDINO: Object to the leading question.

THE COURT: Sustained.

BY MR. STELLMACH:

Q. What, if anything, did Mr. Stanford tell you in the

early years about whether he was uncomfortable with having

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so many assets under management at the brokerage firm in

the CD program?

A. We had the discussion about the percentage that

you're speaking of and that it would not be an ongoing

percentage to maintain. The percentage being so high, as

related to both of us by our compliance people, was being

flagged, looked at very, very closely by the regulators.

Q. Who were the regulators that were looking at this?

A. The NASD for one, SEC.

Q. What's the NASD?

A. That is a self-regulating arm of the brokerage

industry.

Q. And what was -- could you just explain for us what

was the concern raised by the NASD regarding this amount

of CDs that customers at the brokerage firm had purchased?

A. As I understand it from speaking --

MR. SCARDINO: Your Honor, I would object.

He's asking him a question that is not established within

the knowledge of the --

THE COURT: Just find out what sort of

knowledge he has.

BY MR. STELLMACH:

Q. What was the basis for your understanding about what

the NASD was looking into at the brokerage firm?

A. My understanding was that the NASD was concerned --

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Q. I'm sorry. I'm just asking: How did you learn about

the NASD's concerns? Who were your sources?

A. Yes, sir. My sources were the compliance officer of

the broker dealer as well as the president, Mr. Jay

Comaeux.

Q. And when they shared these concerns from the

regulator with you, was Mr. Stanford also involved in

those conversations?

A. Yes, sir, Mr. Stanford was aware of those concerns.

Q. And so what were you told about the concerns by the

regulator about the amount of CDs that the brokerage firm

had put clients into?

MR. SCARDINO: Your Honor, object to the

hearsay.

THE COURT: Well, hearsay or --

MR. SCARDINO: Mr. Stanford was aware of it.

He didn't say he was present.

MR. STELLMACH: He did say he was present and

participated in the conversation.

THE COURT: Okay. He said he wasn't, you say

he was. Let's get that settled first.

BY MR. STELLMACH:

Q. Was Mr. Stanford present when these conversations

took place or participating in the conversation?

A. Yes, sir.

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Q. So what was the concern that the lawyers relayed to

Mr. Stanford from the NASD?

A. That it looked like the broker dealer was set up just

to sell foreign CDs because of the percentage being so

high.

Q. Did Mr. Stanford discuss --

THE COURT: Percentage -- you mean the interest

rate?

THE WITNESS: No, sir. Your Honor, the

percentage of revenue that came from CD sales alone.

THE COURT: Okay.

BY MR. STELLMACH:

Q. And, in fact, if we look at Government's Exhibit 668,

this is the confidential and privileged letter dated

June 9, 2005, from the SEC to Mr. Leroy King. If I could

direct you to the second page?

THE COURT: Again, what number is that?

MR. STELLMACH: This is 668. I believe --

THE COURT: We've already referenced that?

MR. STELLMACH: It has been referenced, but

it's subject to, I think, an objection by the defense. We

can only show certain portions of the document.

THE COURT: Oh, that's right. Here it is.

Yes, I see.

MR. STELLMACH: I was just asking a question

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about something in the letter, not showing the letter.

THE COURT: Okay.

BY MR. STELLMACH:

Q. Have you had an opportunity to review that,

Mr. Davis?

A. Would you repeat the focussed paragraph?

Q. Sure. It's on the second page, the second full

paragraph beginning, "SGC primarily exists to sell its

customers the CD products issued."

A. Yes, sir, I see that.

Q. Could you just take a moment to silently read that

paragraph to yourself.

MR. SCARDINO: While he's reading it, Your

Honor, I think our objection to this exhibit was foundation

and hearsay.

THE COURT: Well, it's not in evidence. It's

just for what he's doing, refreshing some recollection.

MR. STELLMACH: That is correct. And as I

understood it, I was allowed to ask the witness questions

about the document --

THE COURT: In general abstract form rather

than read it in, and the whole document has --

MR. STELLMACH: Absolutely.

THE COURT: -- been excluded, not admitted,

according to my notes.

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MR. STELLMACH: Except for those portions

identifying it as a confidential communication from the

SEC.

THE COURT: We made that ruling. I think

you're well within the bounds. Everybody understands?

MR. COSTA: All right.

BY MR. STELLMACH:

Q. Have you had an opportunity to review that paragraph,

Mr. Davis?

A. Yes, sir, I have.

Q. So was the amount of CD sales by the brokerage firm

also a concern from the -- by the SEC in its letter to

Mr. King back in 2005?

THE COURT: Yes or no.

THE WITNESS: Yes, sir.

THE COURT: Okay.

BY BY MR. STELLMACH:

Q. And, so, when you had these conversations with are

Mr. Stanford about regulatory interest in the brokerage

firm, could you tell us what he said in response?

A. Not specifically.

Q. Well, you can't recall word-for-word.

A. Yes, sir.

Q. It's been a number of years, but could you tell us

what he said?

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A. That the brokerage needed to expand in terms of

assets under management beyond the CD sales so that that

percentage that we're discussing would be a lower

percentage.

Q. And did Mr. Stanford explain why he wanted to get the

percentage of CD sales down at the brokerage firm?

A. In so many words, it was discussed.

MR. SCARDINO: Excuse me.

THE COURT: Yes, sir.

MR. SCARDINO: Nonresponsive.


BY MR. STELLMACH:

Q. What did Mr. Stanford say about why he wanted to get

the amount of CD sales down at the brokerage firm?

A. He wanted -- he said he wanted the CD sales

percentage down so that the scrutiny of the regulators

would be -- it would be an acceptable scrutiny any and

exam process so that the brokerage could continue to be an

ongoing brokerage.

Q. Did Mr. Stanford express any concerns that if the

amount of CD sales by his brokerage firm didn't go down

that could lead into an inquiry into the bank itself?

A. I don't remember that specifically.

Q. But in the SEC letter to Mr. King, that was certainly

a point that will they raised, wasn't it?

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A. Yes, it was. And by that, he would have known.

MR. SCARDINO: Object to nonresponsive.

THE COURT: Excuse me. Sustained.

BY MR. STELLMACH:

Q. Were the financial advisors at the brokerage firm

given incentives to sell the CDs over other financial

products?

A. Yes, sir, they were.

Q. Who came up with the idea of the incentives and the

bonuses and the commissions that would be paid to the

financial advisors to sell the CDs?

A. Mr. Stanford.

Q. Were you involved in deciding what the bonus

structure should be?

A. No, sir.

Q. Did Mr. Stanford track CDs by the individual

financial advisors?

A. Yes, sir, intimately.

Q. How do you know that?

A. He spoke to me very frequently on the subject, how

the sales were going by region, by country, by team, by

individual.

Q. Did he know about sales by individual financial

advisors?

A. Yes, sir.

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Q. Did you track CD sales?

A. No, sir.

Q. Why not?

A. The accounting information related to CD sales would

have been tracked by the normal bookkeeping processes that

happened day-to-day, week-to-week. It would have been

captured in the financial statements.

Q. So in terms of the day-to-day rate of CD sales, was

that something you were focused on?

A. No, sir.

Q. How frequently when you spoke with Mr. Stanford did

the issue of CD sales and the rate of growth come up?

A. Most of the time, we had conversations.

Q. Was Mr. Stanford focused on the sales of any other

financial products by the brokerage firm other than the CD

sales?

A. No, sir, he was not focused on those.

Q. Did there come a time when Mr. Stanford replaced

Mr. Comaeux and Mr. Truellenque?

A. Yes, sir.

Q. Do you remember approximately when that happened?

A. 2004, 2005.

Q. What did Mr. Stanford tell you about his decision to

replace them as heads of the brokerage firm?

A. He s that the growth wasn't happening specifically in

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the CD area of sales and primarily --

Q. Who replaced them?

A. Mr. Danny Bogar.

Q. Who was Mr. Bogar in relation to you?

A. Mr. Bogar was married to my niece.

Q. Did you recommend Mr. Bogar to Mr. Stanford?

A. Yes, I did.

Q. What was Mr. Bogar's prior experience before he was

appointed as head of the brokerage firm?

A. He was a regional executive in a wireless company,

and I believe he oversaw the North and South America

regions. It was a multiple billion dollar worldwide

wireless company.

Q. But Mr. Bogar didn't have any specific securities

industry experience before getting that job as head of the

brokerage firm?

A. No, sir.

Q. So was he qualified to run the brokerage firm?

A. From the sales point and organizational standpoint,

yes, sir.

Q. Who made the decision to actually hire Mr. Bogar?

A. Mr. Stanford.

Q. And once Mr. Bogar was in place as head of the

brokerage firm, who did he report to?

A. Mr. Stanford.

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Q. I want to step back for just a second and focus on

the fall of 2000. You've mentioned that by 2008 into

2009, there were problems with CD sales. They were down.

Had there been a similar problem like that

back in the fall of 2000?

A. Yes, sir, there was. I believe it was a problem

area. Timing was in the fall of -- yes, sir, it was 2000.

Q. Could you explain to us what the problem was with the

CDs at that point?

A. The CD sales, while steady, had not kept pace with

the amount of money being taken from the CD depositors in

paying the cost of running the other Stanford entities.

Q. So there wasn't enough money coming in from new CD

sales to pay off depositors who wanted to cash out?

A. I believe that's correct, yes.

Q. As well as whatever funds Mr. Stanford was borrowing

from the bank?


MR. STELLMACH: I'm just trying to clarify.

THE COURT: Technically correct, but overruled.

Let's get it moving. Go on.

THE WITNESS: Yes, sir, that's correct.

BY MR. STELLMACH:

Q. How much of a concern did that become for you?

A. It was at that point in time a very great concern.

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Q. How grave a concern was it for you?

A. It was impacting my health in an acute way.

Q. In what way?

A. I thought I had a heart attack. I was in Antigua at

the time. And I was quite alarmed, panic attacks and went

to the hospital emergency one midnight, 2:00 a.m.,

evening.

Q. And after you had -- was it a heart attack or was it

a panic attack?

A. Actually, it was a dehydration panic attack, yes,

sir.

Q. After that happened, did you make any attempt to

speak with Mr. Stanford?

A. Yes, sir. After I got back on my feet the next day,

I flew to Miami to attempt to find Mr. Stanford and speak

with him about my concerns.

Q. Were you successful in locating Mr. Stanford in

Miami?

A. Yes, sir, I was.

Q. Could you tell us what happened in that conversation.

Was it in person or was it over the phone?

A. No, sir. I located Mr. Stanford in Miami at his

apartment, across the Miami River from our offices, and I

shared with him my concern about the low level of

liquidity or cash available, in the event there was a

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large series of withdrawals, that there would not be

enough cash to cover them.

Q. What did Mr. Stanford say when you told him that?

A. Well, at the end of the conversation, he said that he

would focus on it and put a program together to eliminate

that problem.

Q. Did he, in fact, put together a program?

A. Yes, sir.

Q. What was the name of the program?

A. It was a quarterly sales program by the name of "Top

Performers Club."

Q. Could it have been Top Producer Club or --

A. Yes, sir, TPC, Top Producers Club.

Q. Could you tell us -- what did Mr. Stanford tell you

was the purpose of that -- of these meetings, these

quarterly meetings?

A. The purpose was to get the sales forces excited about

the CD disclosure statement product and incentivize the

salespeople to sell the CD product.

Q. After the Top Producer Club events were introduced,

what incentives were the financial advisors given to sell

CDs?

A. Of course, recognition; but most importantly, they

were given monetary incentives.

Q. Who decided what those financial incentives would be?

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3164

A. Mr. Stanford.

Q. Did you attend these top producer meetings?

A. Most of them I did, yes, sir.

Q. How large were they? How many actual people came?

A. Say, around hundred.

Q. Could any financial advisor attend?

A. Yes, sir. They did if they produced a certain level.

Q. If they produced a certain level of what?

A. Of CD sales.

Q. Were the sales of any other financial products

considered in deciding whether to invite somebody to

attend a TCP meeting?

A. Not to my knowledge.

Q. Could you just tell us what the format of these

meetings was like?

A. It was an extravaganza format, Hollywood, a lot of

sizzle, excitement. There were skits, videos, special

speakers.

Q. Who paid for all of this?

A. CD depositors.

Q. Was Mr. Stanford involved at all in organizing these

events?

A. Yes, he was. He was the organizer.

Q. Why do you say that?

A. Well, I knew he was. He led the opening. He set the

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3165

agenda. Most of the times we had meetings, he would work

with his creative services staff prior to the meeting

beginning. Most of the meetings were late beginning. He

had the doors in the meeting arenas and halls closed, and

the attendees waited out in the vestibule until he was

ready to open the doors.

Q. In addition to these TPC or Top Producer Club

meetings, were there also competitions between different

teams of financial advisors at the brokerage firms to sell

the CDs?

A. Yes, sir. That was my impression, yes, sir. There

were several teams that competed.

Q. Teams like the Superstars or the Miami Money Machine,

those types of teams?

A. Yes, sir. And the Aztec Eagles, the Thunderbirds.

Q. Who set the goals for the teams, the sales targets?

A. As far as I know, Mr. Stanford.

Q. Were you involved in setting those sales targets?

A. No, sir.

Q. And after the TPC meeting started and the sales

competition started, how did things -- how did the CD

sales perform? You had described a problem that you were

encountering in the fall of 2000. How did this new

program address it?

A. It caused a mushrooming of the sales of CDs. They

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3166

went from maybe thousands to hundreds of thousands per

quarter.

Q. Now, according to the marketing materials in the

annual report, how did the CD -- the rate that the bank

was paying on its CDs compare with the rate that U.S.

banks were paying?

A. It was percentage-wise significantly higher.

Q. And to do that, what sort of returns was the bank

reporting on its portfolio, its investment returns on its

assets?

A. 13, 13 1/2.

THE COURT: Percent?

THE WITNESS: Percent.

BY MR. STELLMACH:

Q. Was that consistent year after year, in that range?

A. Yes, sir.

Q. And we saw -- I won't go back to it, but we saw on

Friday there were a number of different crisis and events

that took place throughout the 20 years you worked for

Mr. Stanford, a lot of turmoil in the markets.

Throughout all of those events, was the

bank reporting a consistently -- a consistent profit or

return in the range of 12, 13 percent?

MR. SCARDINO: Can we narrow the scope of the

question? They were in business for 22 years.

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3167

MR. STELLMACH: I'm just saying --

THE COURT: Get a time reference.

BY MR. STELLMACH:

Q. Toward the end, after 2000, in what range were the

bank's reported financial returns?

A. The returns on the investments would have been in the

12.7 to 14 percent on average.

Q. And that was on -- involving an investment strategy,

according to the marketing materials that we saw, that

involved investing in highly liquid securities?

A. Yes, sir.

Q. Did any of the employees that worked for Mr. Stanford

in the time you worked for him ever question how that was

a possible, how could the bank earn those types of returns

consistently given a fairly liquid investment strategy?

A. Yes, sir.

Q. What would happen to those individuals?

A. Well, the reply would be made as to why those returns

were possible based on the Stanford investment model.

MR. SCARDINO: Excuse me, Mr. Davis.

I'll object to this entire line of

questioning. It is based on hearsay, what somebody else

said.

MR. STELLMACH: These are other employees --

THE COURT: Hold it. Let me hear him. Go on.

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3168

MR. SCARDINO: He asked him a question, What

did other people say about the ROI, and he's actually

relating now. And I would object as based on -- whole

information is based on hearsay.

MR. STELLMACH: These aren't other people.

These are other employees of Mr. Stanford. These are

people who work for him were relaying these concerns to

Mr. Davis and Mr. Stanford. I can be -- I'll be more

precise. I can ask him individual.

THE COURT: All right. Sustain the objection.

You may be a little more precise.

BY MR. STELLMACH:

Q. Who is Charles Hazlett?

A. Mr. Hazlett was a financial advisor working in the

Miami office.

Q. What did you tell Mr. Stanford about Mr. Hazlett in

his questioning of the financial returns of the bank?

MR. SCARDINO: Well, I'm sorry for this, but

he's assuming facts not in evidence.

THE COURT: Overruled.

Again, if he didn't state that, the

witness will so state he never said it; but if he said it,

he can relate it.

Go on.

THE WITNESS: I called Mr. Stanford and let him

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3169

know that Mr. Hazlett had had an incident with our chief

investment officer, Laura Holt, in a Miami conference room

in the Miami office.

BY MR. STELLMACH:

Q. What did you tell Mr. Stanford the incident involved?

A. Mr. Hazlett, the financial advisor, had become quite

irate in his position to express his disbelief to Ms. Holt

that those returns were possible.

Q. What did Mr. Stanford say when you told him that?

A. At the end of the day, he said we'd have to get rid

of Mr. Hazlett.

Q. Was Mr. Haslett fired?

A. Yes, sir.

Q. Who is Ron Rossi?

A. Mr. Rossi was the director of creative services,

which was the department that came after Idea Advertising

handled the promotional materials, printing of those,

other creative service efforts.

Q. So this was an individual who would have replaced Leo

Mejia, the job that Leo Mejia he was doing in the early

years?

A. Yes, sir.

Q. Was Mr. Rossi fired?

A. Yes, sir.

Q. What did Mr. Stanford tell you about why he fired

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3170

Mr. Rossi?

A. Said that he and Mr. DeMaria, Mr. Rossi's assistant,

were questioning -- again, questioning the returns that

were reported on Stanford International Bank Limited's

financial and promotional materials. He also said that

Mr. Rossi, Mr. DeMaria weren't very capable either, that

they didn't do that great a job in their promotional work.

Q. So he didn't like their promotional work and

questioning the returns?

A. Yes, sir.

Q. What happened to Mr. Rossi and Mr. DeMaria?

A. They were fired.

THE COURT: Where were they stationed?

THE WITNESS: Houston, Texas.

THE COURT: Houston.

BY MR. STELLMACH:

Q. Were you aware of potential depositors -- potential

purchases of CDs being taken down to Antigua on a tour of

the Stanford facilities?

A. Yes, sir. This was a regular practice.

Q. Was Mr. Stanford aware of that practice?

A. Yes, sir, he was.


A. Among other things that he said, he said that taking

perspective clients and present clients down to the Island

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3171

of Antigua to tour the bank was a very effective program.

In fact, no trip made had failed to produce new CD sales.

Q. Who paid for these trips down to the island?

A. CD depositors.

Q. Meaning?

A. The money came from the SIBL CD depositors.

Q. So bank money was used to pay for potential customers

to come down and see the island?

A. Bank money was used to pay for everything.

THE COURT: How did they get down there? Was

it on commercial airlines?

THE WITNESS: Not to my knowledge, Your Honor.

It was on Stanford Aviation planes.

THE COURT: In other words, the private jets.


THE COURT: Okay.

BY MR. STELLMACH:

Q. So they'd fly down in any one of the six private jets

Mr. Stanford bought with CD money?

A. That's correct.

Q. How late into the bank's existence did these visits

continue to take place?

A. I believe January of 2009.

THE COURT: When was it the SEC shut it down?

MR. STELLMACH: February.

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3172

THE COURT: Of 2009?

MR. STELLMACH: February 2009.

BY MR. STELLMACH:

Q. When visits were taken to the bank's headquarters,

were they taken to the headquarters, among other sites?

A. Yes, sir.

Q. When they were taken there, were all of the people

who were on the site working in the headquarters of the

bank actually permanently stationed at those headquarters?

A. Most of them were; some few were not.

Q. I wanted to ask about the few who were not.

Where did -- do you know where they were

based?

A. Yes, sir. They were based in Memphis, Tennessee.

Q. What did Mr. Stanford tell you about, if anything,

about why Memphis employees were down in Antigua?

A. His comments were that the research people working in

the bank on a rotating basis there in Antigua showed well

and promoted the bank well to the visitors that would

come.

Q. You say "showed well." What did you understand that

to mean?

A. Well, it showed activity in the bank with additional

individuals who were working toward investment research,

and they had a separate research officing, and that

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3173

officing was very visible in that it had -- in that it had

glass windows, very visible from the hallway passing by.

Q. Sort of like a fishbowl that people could walk by and

see the research analysts in?

A. You had the same -- same visual, yes, sir.

Q. To your knowledge, were the visitors ever told that

the employees they saw working in that fishbowl area

weren't actually stationed there all the time, that they

worked in other parts of the organization?

A. Repeat that question, please.

Q. Do you know whether the depositors or potential

customers who visited and saw the employees who had been

brought down from Memphis to work behind that glass wall,

those -- that was in that office space, whether those

potential customers were ever told that the people they

were seeing weren't actually permanent employees working

down -- working down in Antigua?

A. I don't know what they were told as the customers

came by.

Q. Coming into -- we're now past 2000, coming into 2006,

2007, did you ever express any desire to quit to

Mr. Stanford?

A. Yes, sir, I did.

Q. When did that first come up?

A. Sent him an e-mail to that subject, I believe, in

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3174

2006. Could have been 2007. I believe it was '06.

Q. Why did you want to quit?

A. I was very -- a number of reasons. The fraud that I

was participating in was killing me. The access to

Mr. Stanford and direct time in managing these institutes

was at a all-time low. There had been some decisions by

Mr. Stanford that were pretty incredible, I thought, from

my perspective, and I was just pretty fed up.

Q. You say there had been some pretty incredible

decisions by this point in 2006.

What were those decisions by Mr. Stanford

that you found incredible?

A. Well, rather than slowing down the expansion of

projects dealing with the real estate, my position in

development, and curtailing some activities in the private

aircraft area, there were by then probably 42 people in

Stanford Aviation alone.

THE COURT: That wasn't the commercial airline

or was it?

THE WITNESS: No, sir, it was not.

THE COURT: The private fleet of the six jets,

is that what you're talking about?

THE WITNESS: Yes, sir, Your Honor.

THE COURT: 42 people?


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3175

THE COURT: All right. Does that include the

pilots?


THE COURT: All right.

BY MR. STELLMACH:

Q. Had you discussed any concerns about expenses with

Mr. Stanford prior to this?

A. Yes, sir. It had been a ongoing conversation for

years about budgetary restraints, observing budgetary

restraints, setting up a budget and actually sticking to

it by component and in total.

Also, there was --

Q. When you say "component," what do you mean by

"component"?

A. By department within company, within country, within

region.

There was also one other item.

Q. What was that other item?

A. One of the frustrating items at the time as well was

that Mr. Stanford's decision to hire an additional, I

would say, sequestered staff from the other accounting

units within the company to review expense reports. There

was a staff of 11, mostly CPAs, stationed in Florida, I

believe Orlando, to monitor travel expense forms, which

was a function already being done in the accounting unit

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3176

and global, St. Croix offices as well as North America

Houston offices, by a platoon of qualified people in the

accounting field, and it was real point of contention

between the two of us.

THE COURT: Hang on one second. Stop the clock

for just a moment.

Go right ahead.

MR. STELLMACH: Yes, Your Honor.

BY MR. STELLMACH:

Q. Mr. Davis, you were saying the fact that Mr. Stanford

had set up a unit of 11 or so other accountants was a

point of contention.

Did Mr. Stanford explain why he had done

that?

A. He told me that, Jim, it's a thankless job anyway.

You don't want to do that job. It's something that nobody

really wants to do, and your people can use their time

more effectively doing other things.

Q. So this other group of accountants, were they going

to have access to information, for example, about the

slush fund in Switzerland?

A. I really didn't know. I doubt it very, very

seriously. That would have uncovered the scam, this

ongoing 21-year pyramid scam, and I don't think so. I'm

really not sure why --

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3177

MR. SCARDINO: Object to the nonresponsive.

THE WITNESS: Those people were hired.

THE COURT: Sir?

MR. SCARDINO: It's nonresponsive.


BY MR. STELLMACH:

Q. So you weren't sure why they were hired, but what did

Mr. Stanford say when you told him you wanted to quit?

A. Nothing. Just ignored it.

Q. Did you ever raise this again in the future?

A. In the late summer, early fall 2008, I did.

Q. What -- did you raise it with Mr. Stanford?

A. I raised it directly with human resources having

already shared my feelings by e-mail previously, as I

testified.

Q. You had testified earlier about a conversation you

had with Mr. Stanford about your son, Zack Davis, who was

a research analyst in Memphis. When did that conversation

take place?

A. I would say between '07, '08.

Q. And could you remind us what happened in that

conversation regarding your son?

A. Mr. Stanford asked me if my son, Zack, would continue

to cook the books. And I replied, "Absolutely not, no

circumstances." And that was the end of it.

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3178

THE COURT: Did he use those terms -- the term

"cook the books" or some other term?

THE WITNESS: Your Honor, I believe it was

would he continue to do what I was doing.

THE COURT: Okay.

BY MR. STELLMACH:

Q. And your son was working as a research analyst in

Memphis. Did he know about the fraud?

A. No, sir.

Q. After that conversation and moving into 2008, you

said you spoke to human resources?

A. Yes, sir.

Q. Did you tell them that you wanted to quit?

A. Yes, sir.

Q. So what was your plan in terms of when you were

actually going to depart Stanford Financial Group?

A. I spoke to Ms. Joan Stack, who was HR director for

Global, and a process was worked out where I would remain

to the end of 2009 and then retire.

Q. Were you concerned at all that if you left and

stopped being CFO, that the fraud could be exposed?

MR. SCARDINO: Object to the term of "fraud" by

the government.


MR. SCARDINO: Ask the Court to instruct to

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3179

discontinue using the term.

THE COURT: Let's not use that term.

MR. STELLMACH: I was only using it because

he's pled.

THE COURT: Well, if he uses it, that's one

thing, but I sustain the objection as to counsel.

BY MR. STELLMACH:

Q. Did you have any concerns that if you left Stanford

Financial Group and stopped being the CFO, that the

misappropriations that you've described would be exposed,

the theft of CD money?

A. Honestly, I really didn't. Mr. Stanford always put

someone in the necessary positions.

MR. SCARDINO: Object to nonresponsiveness to

the question.

THE COURT: Sustained. Not responsive.

BY MR. STELLMACH:

Q. Why weren't you concerned about leaving?

A. Because I knew Mr. Stanford would find someone else

to do what I was doing.

Q. Now, we've seen this before. It shows, Mr. Davis,

what the situation was at the end of '07?

A. Yes, sir.

Q. And by the end of '07, Tiers 1 and 2, the cash and

marketable securities, ended up to how much?

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3180

A. Together about 1.5 billion.

Q. And the bank owed CD depositors how much?

A. 6.6 billion.

Q. And the hole was there for how big?

A. 5 billion.

MR. STELLMACH: And if I could see Government's

Exhibit 1603, which has been previously admitted.

BY MR. STELLMACH:

Q. This shows the amount of --


BY MR. STELLMACH:

Q. -- the amount of money loaned to Mr. Stanford over

the last five years. Between 2007, when the hole was

about 5.1 billion, to 2008, how much more was taken out of

the bank?

A. 400 million from '07 to '08, if I understood your

question.

Q. That was my question.

So 400 million borrowed by Mr. Stanford

for what purpose?

A. To either establish additional or to maintain the

present Stanford companies among other things.

Q. When you say maintain the present Stanford companies,

by 2008, on a daily basis, approximately how much was it

costing to maintain those companies?

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3181

A. $1 million per day.

THE COURT: The 1 million per day relates to

what specifically again?

THE WITNESS: Maintaining the Stanford

companies across the globe.

THE COURT: Okay.

BY MR. STELLMACH:

Q. And moving into 2008, from the end of 2007 when the

hole was 5.1 billion, how were CD sales performing, the

sales of new CDs?

A. Moving from '07 to '08, they were still strong.

Q. And then going into '08, how were they performing?

A. From the end of the first quarter forward in a

diminishing way, extremely diminished by the fourth

quarter.

Q. So when you say the first quarter, by the end of the

first quarter meaning March or so?

A. Yes, sir.

Q. So new CD sales were down?

A. Yes, sir. Especially in relationship to withdrawals.

Q. And that was my next question. How were withdrawals

at this point?

A. As I indicated, the withdrawals began to increase.

Q. Did there come a point when the bank had more money

going out that it was paying for customers who were

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3182

redeeming CDs than it had coming in from new CD sales?

A. Yes, sir.

Q. And while that happens, Mr. Stanford is also spending

another million dollars a day?

A. Yes, sir.

THE COURT: What year are we talking about now?

MR. STELLMACH: This is all 2008, Your Honor.

THE COURT: 2008.

MR. STELLMACH: 2008.

THE COURT: And it was closed in 2009?

MR. STELLMACH: February of '09.

THE COURT: Okay.

BY MR. STELLMACH:

Q. So we're coming up into the final days.

So were the returns that the bank was

earning on its investments in the liquid assets, the

marketable securities in Tier 2, were those able to offset

the money Mr. Stanford was taking out to cover his

companies or the rate of CDs being redeemed?

A. No, sir.

Q. So moving into 2008, into March, into the summer, how

was the bank covering, in other words, how was it able to

pay, CD depositors?

A. Withdrawals were honored by the securities and cash

and the so-called Tiers 1 and Tiers 2.

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3183

Q. When you say covered, could you explain what that

means in terms of Tier 1, which is -- I'm sorry -- Tier 2,

which is marketable securities?

A. It would mean that if there was no cash in Tier 1,

Tier 2 securities would be sold and turned into cash, and

then that cash would be used to honor the withdrawals the

CDs holders approached the bank with.

Q. Was this situation something Mr. Stanford was told

about?

A. Oh, yes, sir.

Q. How were you communicating it to him?

A. Well, I was communicating in person, but more

importantly, the president of the bank would have been

communicating this, I would think, on a daily basis.

MR. SCARDINO: Object to hearsay and

nonresponsive.

THE COURT: Well, he said "I would think" at

the end. I sustain as to that answer. And please rephrase

the question.


MR. SCARDINO: We respectfully request the

Court to instruct the jury to disregard the part of the

answer that was nonresponsive regarding what he thought the

president of the bank --

MR. STELLMACH: I'll go back and rephrase.

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3184

THE COURT: The jury is so instructed and are

going to rephrase it.

BY MR. STELLMACH:

Q. So, Mr. Davis, were you telling Mr. Stanford about

this situation, the fact that the hole was growing in 2008

and he was taking a million dollars a day and that wasn't

helping things?

A. Yes, sir. We had that conversation several times.

Q. In addition to having the conversation, did you ever

e-mail Mr. Stanford any updates or information about the

bank's financial assets?

A. Very frequently. Text messages between the two of us

would take place.

Q. When you texted Mr. Stanford, were there -- was he

asking any questions about any particular types of assets?

A. Yes, sir. He would ask about Tier 1, Tier 2, which

were the cash and the primarily securities accounts.

Q. Was Mr. Stanford asking about the status of Tier 3,

the real estate and private equity investments of the

bank?

A. No, sir.

Q. Was the real estate or private equity owned by the

bank being sold at this point to cover redemptions?

A. No, sir.

Q. Why not?

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3185

A. Illiquid.

MR. STELLMACH: And if we could go to

Government's Exhibit 1524. Focussing on the e-mail. If we

could just enlarge the top portion.

BY MR. STELLMACH:

Q. Who received this e-mail?

A. It was received by Mr. Stanford and myself.

Q. And who was it from?

A. It was from Patricia Maldonado, who was the treasury

manager that --

Q. We talked about Ms. Maldonado before, but could you

just remind us what her job was as the treasury manager?

A. Ms. Maldonado was in charge of reporting for and

routing the cash that was in Tier 2 -- Tier 1, excuse me,

in Tier 1.

MR. STELLMACH: And if we go to the text of her

e-mail where there are two asterisks. We'll enlarge the

entire text, and if we could just highlight transfers to

Tier 1, it's at the very bottom -- I'm sorry, to second

tier. It reads: "85 million."

BY MR. STELLMACH:

Q. Do you see that, Mr. Davis?

A. Yes, sir, I do.

Q. So, on the side, on the left-hand margin, there are a

bunch of initials and letters. Could you tell us what

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3186

those represent?

A. Yes, sir. The left-hand column is SIBL, the bank; TD

represents our correspondent account at Toronto Dominion

Bank in Canada.

Q. Where you say correspondent account, what do you

mean?

A. That's an -- that is a bank account set up in the

name of Stanford International Bank, Limited, similar to a

checking account.

Q. Okay. And then the other letters beneath that, are

those also other financial institutions?

A. Yes, sir.

Q. Including HSBC?

A. Yes, sir.

Q. And BOH, what does that stand for?

A. Bank of Houston.

Q. And, so, at the bottom of Ms. Maldonado's e-mail, it

reads: "Transfers to second tier equal 85 million."

What did you understand that to mean?

A. My understanding was that in the top line to the

right of -- a little bit below and to the right of SIBL,

there is an amount disbursed, meaning withdrawals, and my

understanding would be that transfers are kind of going to

come in to cover that.

Q. Transfers are going to come in from where?

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3187

A. They would have to be from Tier 2.

Q. Turning to 1525, which is about a month later,

March 4th of 2008.

MR. STELLMACH: Your Honor, if I could have the

overhead.

THE COURT: Overhead?


Thank you, Your Honor.

THE COURT: Pull that out a little bit. It may

focus it better. Pull out the focus -- the zoom, in or

out.

BY MR. STELLMACH:

Q. And, so, Mr. Davis, this is a March 4, 2008 e-mail

from Ms. Maldonado?

A. Yes, sir.

Q. To yourself and to Mr. Stanford?

A. Yes, sir.

Q. As well as several other accountings. It reads:

"Funds request for Star/Sun"?

A. Yes, sir.

Q. Could you remind us what companies those were?

A. Commercial airlines owned by Mr. Stanford.

Q. And there's an attachment reading: "Shutdown data,"

and then an e-mail for Mr. Stanford from Ms. Maldonado.

Could you read the e-mail for us?

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3188

A. Yes, sir. "We are coming to you for funding

pertaining to the shutdown of the two airlines. Total

funding request is for $5 million. Breakdown is

1.7 million for Sun, and 3.1 million for Star. Support

for these figures is attached. May we have your approval

to fund this week?"

Q. At this point what had Mr. Stanford told you about

his plans for the commercial airlines, Caribbean Star and

Caribbean Sun?

A. The latest plans, sir?

Q. As of this point, yes, the shutdown data.

A. His instructions, as I recall, were to shut the

airlines down.

Q. What did Mr. Stanford tell you about why he was

shutting down the airlines?

A. Cash drain.

Q. Was this a topic you had discussed with Mr. Stanford

before, the fact that these two airlines were a cash

strain?

A. Yes, sir, they had lost in excess of $500 million

since they were created.

Q. What did Mr. Stanford tell you about why he was

finally shutting down the airlines in March of 2008?

A. I don't recall as to a specific -- on this date a

reason, but the reason, I gathered from earlier

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3189

conversations with Mr. Stanford, was --



BY MR. STELLMACH:

Q. Prior to this date, what, if anything, had

Mr. Stanford told you about the reason why he wanted to

shut down the airlines?

A. That they were losing too much money.

Q. And, so, it reads: "Total funding request is for

$5 million."

Why -- was there -- why is -- was there a

requirement for $5 million to shut down the airlines?

A. It's my understanding that there were windup costs,

legal, administrative, termination of employees, breaking

contracts for offices and other commitments of brick and

mortar, airplane leases, et cetera.

Q. At this point in March of '08, where would the money

have come from that was necessary to shut down the

airlines?

A. From the CD depositors.

Q. Do you know whether the airlines were ultimately shut

down by Mr. Stanford?

A. Please repeat that.

Q. Do you know whether Mr. Stanford ultimately did shut

down the airlines?

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3190

A. Yes, sir, they were shut down.

MR. STELLMACH: I was going to go back to the

laptop, Your Honor.

THE COURT: Okay.


Go to 1526.

BY MR. STELLMACH:

Q. I want to jump ahead now to October of 2008. We'll

start with the e-mail from Ms. Maldonado toward the middle

of the page.

MR. STELLMACH: If we could just highlight her

name.

BY MR. STELLMACH:

Q. It's on October 22nd of 2008. And it was an e-mail

sent to you by Ms. Maldonado, and there's a long list of

numbers. And at the very bottom, it reads, right above

where her name is highlighted at the bottom, "grand

total."

MR. STELLMACH: Could we highlight that number,

406.8 million.


BY MR. STELLMACH:

Q. What did you understand that number to represent?

A. Those were withdrawal requests from the CD holders.

Q. So as of October of '08, the bank was obligated to

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3191

pay over $400 million to depositors?

A. Yes, sir. According to this e-mail and the

identified amounts and dates of maturities in the center

of the e-mail.

Q. Okay. So if we go to TD USD, right here, these

maturities -- could you just explain what the numbers in

the left column are and the dates?

A. The numbers are millions of dollars, and the date to

the right of those numbers indicates when the customer is

expecting to receive their withdrawal.

MR. STELLMACH: And if we could enlarge the

portion of the e-mail -- your e-mail to Mr. Stanford at the

very top, dated October 23rd of '08.

BY MR. STELLMACH:

Q. And could you read for us the text, the e-mail you

sent to Mr. Stanford?

A. Yes, sir. "Regarding first tier, I project that we

have 35 to 45 banking days of funds remaining in accounts

at the present net-net withdrawal run rate. Another big

withdraw leaving Friday of 44 million."

Q. So when you wrote "we have 35 to 45 banking days of

funds remaining at the present withdrawal rate," what were

you communicating?

A. That the cash available in Tier 1 would be used up by

that date at the present withdrawal rate and the present

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3192

incoming CD sales rate netted out together incoming

against outgoing.

Q. So the bank had about another month of funds left in

cash?

A. In cash, yes, sir.

Q. Assuming the run rate continued at the rate it had

been going?

A. Yes, sir.

MR. STELLMACH: If we could jump to a clip from

a video that's already in evidence, 1532-C. This is -- I

think -- 1532-C.

BY MR. STELLMACH:

Q. Do you recall -- while we're resolving some technical

issues, Mr. Davis, do you recall in October Mr. Stanford

had a meeting with a group of people of financial advisors

regarding the bank?

A. Yes, sir. Probably the TPC meeting of October.

Q. And we have a clip from that meeting we're going to

play at this point.

MR. SCARDINO: Mr. Stellmach, what's the date?

MR. STELLMACH: It's October 2008, the same

time period as the e-mail we just saw.

MR. SCARDINO: Thank you.

MR. FAZEL: We have seen it?

MR. STELLMACH: It is in evidence. We have

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3193

played it with Mr. Green. He attended it.

BY MR. STELLMACH:

Q. Do you recall why Mr. Stanford had a TPC meeting in

October of 2008?

(Whereupon, the tape was played)

THE COURT: Again, we can't hear it. We heard

it fine the last time.

BY MR. STELLMACH:

Q. Did you recall -- did you just hear Mr. Stanford in

that clip say that the bank had 5.5 -- $5.5 billion too

much?

A. Yes, sir, I believe that's what I heard.

Q. And had you ever told Mr. Stanford at any point prior

to this that the bank was sitting on $5.5 billion too much

in cash?

A. No, sir.

Q. In fact, in the October e-mail we just saw, what had

you told him about how much money the bank had left?

A. Told him that present run rate, we had about 30 to 45

days left of cash.

Q. And had you ever told him, as we just heard in the

e-mail, that the bank was too liquid at this point in

time?

A. No, sir.

Q. I want to jump to 1527 an e-mail from November 11,

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3194

2008. And we'll start with the e-mail at the bottom of

the page from Ms. -- I'm sorry -- is it Tarrie -- Tarrie

Patlan?

A. Yes, sir.

Q. To Ms. Maldonado, reading "SIBL cash balances."

What information is shown there?

A. These are Tier 1 cash balances. Ms. Patlan was an

employee under the direction of Ms. Maldonado.

Q. And if we jump to the bottom of the second page of

the e-mail, which goes on just listing account balances,

at the bottom, it reads: "Total cash 173.6 million."

So what does that number represent?

A. This is the amount of Tier 1 cash held in the

Stanford International Bank, Limited, checking accounts as

it were at that date.

Q. All of the bank's cash as of November 11th of '08?

A. That's correct.

Q. And if we go to the e-mail that was then sent to you

in the middle of the first page, could you read for us

what Ms. Maldonado wrote to you about?

A. Yes. "Subject: SIBL cash balances. Please see

positions today. Tarrie will update me on client

outgoings for tomorrow. We are moving funds from

Comerica, 10 million, tomorrow and will most likely draw

down on Canadian and British pound positions next. When

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3195

can we get some relief from the second tier?"

Q. What do you understand Ms. Maldonado to be asking in

terms of relief from the second tier, the question she

wrote to you?

A. She's asking that the Tier 2 securities be sold and

turned into cash and that cash be transferred to Tier 1.

Q. And then if we go up toward the top of the page, you

wrote "working on it" to Ms. Maldonado and then sent an

e-mail to Mr. Stanford and you wrote "FYI"?

A. Yes, sir.

Q. Why were you notifying Mr. Stanford about the

situation?

A. Because he was a chairman and CEO and was texting

back and forth and communicating by phone back and forth

monitoring the cash flow, cash drain situation, on a --

pretty much a daily basis at that point.

Q. And if we go to Government's Exhibit 1528, the next

e-mail. This is from December 1, 2008, just a couple of

weeks later.

MR. STELLMACH: Again, at the very bottom, I

think it's the second page, if we highlight next to total.

BY MR. STELLMACH:

Q. What's the number there?

A. Total of $88.2 million.

Q. And what does that represent?

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3196

A. I believe it is the balance of cash.

Q. So by December of 2008, the bank had about

$88 million left in cash?

A. Yes, sir.

Q. And in order to cover CD redemptions throughout the

year, starting, you know, toward March when you said

redemptions picked up, where had the bank been getting the

money to do that?

A. From Tier 1 cash.

Q. And what about Tier 2?

A. At this time not a significant amount of redemptions

in Tier 2 into cash had taken place, but this is getting

close to that point where redemptions in Tier 2 was the

only place to get the funds to honor withdrawal request.

THE COURT: Tier 2, you're saying?

THE WITNESS: Yes, sir. The securities

portfolio.


BY MR. STELLMACH:

Q. The marketable securities portfolio?

A. Yes, sir.

Q. And if we go to the top of this exhibit, just your

e-mail to Mr. Stanford, again, you were providing an

update to Mr. Stanford?

A. Yes, sir, I am. I did.

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3197

Q. As these e-mails are coming in from Ms. Maldonado

reporting on the amount of cash that the bank needs to pay

out the amount of cash it has actually on hand to meet

depositor demands, were you speaking with Mr. Stanford as

well?

A. Yes, sir.

Q. Did he express any concerns to you about the

situation?

A. Yes, sir, we were both concerned.

Q. How concerned were you becoming starting in the

summer of '08?

A. I was concerned. I was very concerned. Probably

near emotional and mental -- extreme stress levels

concerned.

Q. Were you discussing the situation with the

accountants who worked for Mr. Lopez and Mr. Kuhrt?

A. Yes, sir.

Q. And you were discussing it with them as well,

Mr. Kuhrt and Mr. Lopez?

A. Yes, sir.

Q. Do you recall ever using the expression "the emperor

has no clothes"?

A. Yes, sir, I did say that.

Q. And what were you trying to communicate?

A. That among other things, there wasn't going to be any

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3198

cash infusion from the chairman of the board to cover this

massive withdrawal stream that we were seeing in these

really -- really tough economic times.

Q. In 2008 as this began, starting in March going into

the summer, into the fall, were you having any

conversations with Mr. Stanford about how to solve the

problem?

A. Yes, sir.

Q. What did -- did Mr. Stanford tell you he had any

ideas on how to do that?

A. Yes, sir.

Q. What did Mr. Stanford tell you he proposed to do?

A. He proposed to announce a shareholder equity infusion

into the bank which would strengthen the balance sheet and

very possibly for stall the insecurity of the depositors,

meaning slow down the withdrawals, and increase new CD

sales.

THE COURT: Well, times -- was the economic

downturn about that time, or was this in advance of it.

THE WITNESS: We were right in the middle of

it, and it was getting worse.

THE COURT: So people were making calls on

their CDs. Is that correct?

THE WITNESS: Minute by minute. Yes, sir.

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3199

BY MR. STELLMACH:

Q. So people are making calls, they want their money out

of the CDs, and new CD sales are down?

A. In relationship, certainly, to the rate of withdrawal

request, yes, sir.

Q. Not enough money coming in to pay the depositors who

wanted out?

A. The writing was on the wall, yes, sir.

Q. Yes, sir. So what did Mr. Stanford tell you in terms

of this equity infusion?

First of all, could you explain what the

term "equity infusion" means?

A. It means that money would come into the bank equity

section; that is, unencumbered funds to bolster the net

value, net liquidity value of the bank.

Q. Did Mr. Stanford tell you how much he proposed

announcing he had put into the bank?

A. At that point, I believe it was in the neighborhood

of $600 million.

Q. "At that point," meaning where are we in terms of

2008?

A. Late third quarter.

Q. So coming into --

A. Fourth quarter.

Q. -- October?

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3200

A. Yes, sir.

Q. Did Mr. Stanford actually have $600 million in cash

or liquid assets, to your knowledge?

A. No, sir.

Q. Did he tell you how he proposed to obtain

$600 million to sink into the bank?

A. Told me just make an entry into the accounting

records that it had been made.

THE COURT: So just on paper?

THE WITNESS: Paper entry, yes, sir, Your

Honor.

BY MR. STELLMACH:

Q. And we'll come to the paper entry.

But do you recall any specific --

THE COURT: Well, let me ask you this: How you

would that pay off people making call on the bank? In

other words, it was just a paper entry.

Again, I'm not familiar with the banking

systems.

THE WITNESS: As I understood, Mr. Stanford's

scheme or idea was that an announcement of an infusion into

the balance sheet of the bank would bolster confidence

among investors', prospective as well as current investors.

THE COURT: So they'd stop the withdrawals, and

then, you'd get more CDs coming in?

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3201

THE WITNESS: Yes, sir, that's correct.

THE COURT: At least the theory?

THE WITNESS: Yes, Your Honor.

THE COURT: Okay.

BY MR. STELLMACH:

Q. These --

THE COURT: Hold it. Times were tough at that

time; right? People needed the money out, and wasn't that

what's all is happening at that time? People needed the

money? Or were they just pulling it out because they lost

confidence in the institution, if you know?

THE WITNESS: My impression, Your Honor, was

that they had lost confidence in the world system and they

were afraid.

THE COURT: The world system.

THE WITNESS: They were afraid.

THE COURT: Okay.

BY MR. STELLMACH:

Q. So Mr. Stanford was going to announce he was adding

hundreds of millions of dollars of his own money to the

bank so that people would have confidence in Stanford

International Bank and not pull out their money and

possibly even draw in new CD customers?

A. Yes, sir, that was my understanding.

THE COURT: Because at that time, the interest

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3202

rates are starting to go down, and it was an excellent

opportunity. Is that correct?


BY MR. STELLMACH:

Q. And if we could turn to Government's Exhibit 138.

This is a monthly report dated December 2008. And if we

turn to the second full paragraph -- I'm sorry. If we

turn to the second page and the paragraph in the upper

right-hand corner beginning "Although."

And if you could just read that paragraph

to us, Mr. Davis?

A. Yes, sir. "Although our earnings will not meet

expectations in 2008, Stanford International Bank, Limited

is strong, safe and fiscally sound. We have always

believed that the depositor safety was our number one

priority. To further support the bank's growth and

provide a strong cushion for any further market

volatility, the bank's board of directors made a decision

to increase the bank's capital by 541 million on

November 28, 2008. This contribution brings total

shareholder equity to $1,020,029,802 with a

capital-to-assets ratio of 11.87 percent and a

capital-to-deposits ratio of 13.48 percent. This places

our bank in a position to well exceed Bazel II capital

requirements as we continue to grow in 2009."

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3203

Q. The number we see there, the total shareholder equity

is now, according to this document, being reported

although over a billion dollars.

Was that a number Mr. Stanford had ever

mentioned to you, before the fact that it's not enough

just to add a couple hundred million and make an

announcement, but to raise the total equity north of a

billion dollars?

A. Yes.

Q. Or to be able to announce that that had been done?

A. Yes.

Q. When do you recall him having that conversation with

you?

A. A specific time that was discussed was October 18,

2008.

Q. How do you recall that are date so specifically?

A. Mr. Stanford had visited me in my home in

Mississippi.

Q. What was the purpose for the visit?

A. Well, I had just had a 60th birthday the week before,

and there was a little celebration for that 60th birthday;

but also that we needed some face time because of the

economic dilemma and the dilemma we had with lack of cash

and liquidity at the bank.

Q. And, so, that's when -- is that Mr. Stanford tells

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3204

you, "I want to announce the bank's capital or the equity

is now north of a billion dollars"?

A. It was a plan. Actually, the announcement I learned

from, I believe it was, the accounting.


THE COURT: Excuse me?

MR. SCARDINO: Nonresponsive answer.


BY MR. STELLMACH:

Q. So what was the plan that Mr. Stanford shared with

you in October?

A. That there would be a formally announced equity

infusion by himself into the bank.

Q. And I think you said earlier -- you testified earlier

that that was just going to be a bookkeeping entry, no

actual cash or assets were going to go to the bank?

A. Yes, sir.

THE COURT: Even though it was going to be

announced publicly that at least it appeared that cash was

flowing in?


THE COURT: All right. I'm sorry. Yes, sir.

MR. SCARDINO: Excuse me, Mr. Stellmach.

I'll object to the question assuming facts

that are not in evidence, the part of the question where he

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3205

says, but no money would be infused into the bank. He said

just the announcement would be made, but no money would be.

And I would object to the "no money would be" part of the

question, assuming facts not in evidence.


BY MR. STELLMACH:

Q. And, so, after you had that conversation with

Mr. Stanford, I think you testified you were told a

bookkeeping entry had to be made?

A. Yes, sir.

Q. Was a bookkeeping entry made to support that

announcement?

A. Yes, sir.

Q. But were there any actual cash transfers or assets

actually transferred from Mr. Stanford or a company he

owned into the bank to back up that announcement?

A. No, sir, there was none.

MR. STELLMACH: Your Honor, we're at a good

point.

THE COURT: Take a break. Good break time.

We'll take about an extra five minutes. I've got some work

to do back there, and I don't want to have for take a

longer break later.

So it's now 11:30. We'll take a 20-minute

break, get back in 10 minutes to 12:00. I'll raise the

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3206

screen and see you back in 20 minutes.

(Recessed at 11:30 a.m.)


THE COURT: Thank you. Be seated.

Go right ahead.


BY MR. STELLMACH:

Q. Mr. Davis, I wanted to turn to the bookkeeping entry

that you testified before the break to back up the

announcement that Mr. Stanford had injected several

hundred million dollars into the bank in capital.

Were you involved in that bookkeeping

entry?

A. Yes, sir.

Q. And I'm showing you Government's Exhibit 5. And if

you could go to the spreadsheet that's attached.

MR. STELLMACH: And if we could just enlarge

the upper portion of the document.

BY MR. STELLMACH:

Q. Are you familiar with this spreadsheet, Mr. Davis?

A. Yes, sir.

Q. How do you recognize it?

A. This was shown to me by our accounting leadership,

Mr. Lopez, Mr. Kuhrt, and the three of us discussed it.

Q. Is this related at all to the bookkeeping entry that

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3207

you've been testifying about?

A. Yes, sir.

Q. And looking at the upper left-hand portion of the

document, which is enlarged right now, there's a line at

the very bottom reading "desired level," and the number

"1 billion" is written at the bottom.

What did that number represent?

A. This was the target level, I mentioned earlier

testimony, that Mr. Stanford was --



BY MR. STELLMACH:

Q. What did Mr. Stanford tell you in the earlier

conversation you had with him in October right before your

birthday or around your birthday about what he wanted to

announce in terms of the level of the bank's capital?

A. The level he wanted was $1 billion.

Q. And, so, here it writes -- here's it's written,

"desired level 1 billion."

What did that represent? You said it was

a target?

A. Yes, sir.

Q. And what needed to be done in order to hit that

target?

A. An entry would have to be made in two pieces. In

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3208

accounting there's a debit and there's a credit, and the

credit would go into the equity as an infusion.

Q. As a contribution by Mr. Stanford into the bank's

capital?

A. As a contribution by Mr. Stanford into the capital.

The offsetting entry would go into investments.

Q. How was it decided to do that? What assets would be

used to support the bookkeeping entry?

A. The assets in and around Antigua, Barbuda were real

estate parcels that had been purchased just months before.

Q. It might be easier, I think, Mr. Davis, if we leave

the document for now. We'll come back to it.

But if I could ask you to step down and

walk us through a diagram that shows how the transaction

was set up.

THE COURT: Sir, do you want to take the

microphone, please, the lapel mike.

MR. SCARDINO: Your Honor, I will object to the

demonstration as it is being portrayed before the jury

because it in effect does not allow me to object to what is

communicated to the jury by the witness when he's writing

dates and names on the board.

THE COURT: All right. That's generally how

it's done with an objection like that, you do one step at a

time. He explains it as he draws it out. Very often, if

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3209

it's even a big poster board, you have areas cleared --

blocked by Velcro strips, and as someone explains the next

line, then he can take that off. So that's sustained.

Mr. Davis, if you would explain in words

as to what you're doing every time you write something on

the board.

MR. STELLMACH: And if I could just walk --

maybe it would be easier if I --

THE COURT: Sure. Okay. Absolutely. Sure.

BY MR. STELLMACH:

Q. At the top you wrote: "2008 'flip.'"

THE COURT: Flip, f-l-i-p?

MR. STELLMACH: Flip, yes, Your Honor.

BY MR. STELLMACH:

Q. What was the flip that you're about to describe?

What did it involve?

A. In real estate that the bank already owned and moving

it by legal and accounting entries into the ownership of

Mr. Stanford and then returning it back from Mr. Stanford

to the bank.

Q. So the bank had purchased real estate. It was going

to be transferred to Mr. Stanford so he could send it back

to the bank?

A. Yes, sir.

Q. All right. And, so, the first circle, if you could

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3210

just walk us through that.

A. The first circle represents Stanford International

Bank, Limited. Subject here is estate.

Q. And where was the real estate located that you're

talking about?

A. Just offshore to Antigua, Barbuda.

Q. And had this real estate been designated for a

specific project?

A. Yes, sir.

THE COURT: When you say offshore, are these

the islands you were referring to or what?


THE COURT: The separate little islands --


THE COURT: -- that something was going to be

constructed upon?


THE COURT: Was that a part of the country of

Antigua, also within their territorial waters?


THE COURT: Okay.

BY MR. STELLMACH:

Q. And, so, what was the project that the land had been

acquired for originally?

A. I believe the name of the project at this point was

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3211

Islands Club.

Q. What was the Islands Club?

A. This was a project and process of Mr. Stanford, and

it involved building out a high-end resort, as I

understood it, that would appeal only to the ultra, ultra

rich of the world. They would buy parcels, pay fees, and

maintenance of grounds and entertainment and usage fees to

take place there.

Q. Mr. Davis --

THE COURT: Excuse me. How do you access those

islands, strictly by water taxi or something like that?

THE WITNESS: Yes, Your Honor, as far as I

understand it.


BY MR. STELLMACH:

Q. Actually, I do have a question about that. So the

billionaires would fly into Antigua and then take a boat

out to the club? Was that the idea?

A. That's as I understood it, yes, sir.

Q. All right. The real estate, though, was purchased by

the bank itself?

A. Yes, sir, it was.

Q. But who was going to own the club and operate the

club, assuming it was ever built?

A. My understanding, Mr. Stanford.

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3212

Q. But why did the bank -- did Mr. Stanford ever explain

to you if he ultimately was going to own the club, why the

bank had purchased the real estate that the club was going

to be built on?

A. Yes, sir.

Q. What did Mr. Stanford tell you about that?

A. As I recall, Mr. Stanford and the general counsel as

well, Maricio Alvarado, indicated there were other issues,

the major one being a marriage and divorce issue. And as

I understood it --

Q. Whose divorce?

A. Mr. Stanford and his wife.

Q. And, so, as it was explained to you by Mr. Stanford,

what was the reason why his divorce meant that the bank

had to purchase the real estate as opposed to him

personally?

A. As I was told by Mr. Stanford and the general counsel

and Harry Failing, Mr. Stanford's tax account.

MR. SCARDINO: Object to hearsay, three

different people.

MR. STELLMACH: Well, these are all agents.

THE COURT: Wait a second.

So what are you saying, he needs to break

down what he heard from each?

MR. SCARDINO: That is correct.

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3213

THE COURT: Assuming they're all admissible?

MR. SCARDINO: Right.

THE COURT: Correct?

MR. SCARDINO: Yes.

THE COURT: I'm not ruling on your objection to

admissibility. All right. Sustained as to that question.

See if we can break it down.

BY MR. STELLMACH:

Q. What did Mr. Stanford tell you about why the bank had

to purchase the real estate as opposed to why he couldn't

do it himself? How did his divorce impact that decision?

A. As I understand it from Mr. Stanford, the bank

itself --

MR. SCARDINO: I'm sorry, Mr. Davis.

I'll object to what he understands, rather

than if he specifically can answer the question asked by

Mr. Stanford.

THE COURT: Sustained as to the response. I

think you can clear -- Mr. Davis, we need to know what you

were told by Mr. Stanford, okay?


THE COURT: Go right ahead. Now you -- is

that -- state it that way. What did -- I'll ask the

question. What did Mr. Stanford tell you about this

matter? Now you may proceed.

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3214

THE WITNESS: Mr. Stanford said that the bank

itself was a gift from his father, and, therefore, in a

divorce settlement, the gift, Stanford International Bank,

Limited, would be exempt from distribution to his wife in a

divorce settlement. That's the reason he told me that it

was done that way.

BY MR. STELLMACH:

Q. As opposed to Mr. Stanford buying the land personally

and owning it in his own name?

A. Exactly.

Q. Or in the name of a shell company he had set up?



BY MR. STELLMACH:

Q. Could Mr. Stanford have used any one of his shell

companies, his numerous shell companies that he had set

up, to avoid the problem with the divorce in breaking up

the land?

A. That's beyond my understanding, sir.

Q. Fair enough.

But Mr. Stanford explained because of his

divorce, the bank had to hold title to the land?

A. Yes, sir.

Q. Okay. How much had the bank spent to buy the land?

A. Two parcels, a total of $63.5 million.

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3215

Q. When was the land purchased?

A. 2008.

Q. Do you remember approximately? Was it earlier in the

year, middle of the year?

A. Between early summer and third quarter.

Q. Did Mr. Stanford ever discuss the purchase price that

the bank had paid for the land with you?

A. Yes, sir, he did.

Q. Did he tell you whether he thought the bank had

overpaid or gotten a great deal on the purchase price?

A. He said that it was too much, that he was robbed.

Q. $63-1/2 million was too high a price?

A. Yes, sir.


THE COURT: Well, overruled as to that

question. We'll go one question at a time, although it was

leading. Go on.

BY MR. STELLMACH:

Q. And then could you show us what happened next or what

was going to happen next in this flip?

A. (Indicating) the parcel of real estate that SIBL

owned would be moved under the ownership of Mr. Stanford.

Q. And why is there an arrow, 63-1/2 mill, showing that

transfer? What does that represent?

A. That was the cost of the parcels of land.

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3216

Q. So how much on the -- in terms of bookkeeping was

Mr. Stanford going to be paying for that land to get it

from the bank?

A. As I understand the worksheet, the same price, same

cost.

Q. So he would get land at the same price the bank had

paid?

A. Yes, sir.

Q. And then what was going to happen once the land had

been transferred to Mr. Stanford?

A. (Indicating.) The real estate would be transferred

from Mr. Stanford back to the bank at $3.2 billion.

Q. When was the transfer from Mr. Stanford to the bank

going to take place?

A. The fall of 2008.

THE COURT: So it was going to him, according

to your diagram, the 63 million, and then it was going to

be transferred back to the bank at 3.2 billion?


THE COURT: Okay.

BY MR. STELLMACH:

Q. And how close in time was that transfer going to take

place from the time when the bank acquired the land at

63-1/2 million?

A. Approximately four months.

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3217

Q. Where did the value of 3.2 billion for this expected

bank asset come from?

A. There were some smaller real estate transactions in

the vicinity, and the amount per acre of those

transactions was the unit amount of money that was used in

the calculation to come up with the 3.2 billion.

THE COURT: I don't understand that. Break it

down, please.


BY MR. STELLMACH:

Q. So the land had been purchased for $63-1/2 million;

is that correct?

A. Yes, sir.

Q. Had any improvements been made to it?

A. No, sir.

Q. So nothing had been changed in the land from the time

it was purchased by the bank to the time it was going to

be transferred to Mr. Stanford and then back to the bank?


Q. Who put a value of 3.2 billion on that real estate?

A. The value was put by Mr. Stanford, the actual --

Q. Who did the calculation?

A. The calculation was done by the accounting team under

Mr. Kuhrt and Mr. Lopez.

Q. So the land that -- was about 1,500 acres,

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3218

1,600 acres?

A. I believe 1,532, maybe.

Q. And to go back to the Court's question, how was the

number used to multiple that 1,500 or so acres to get to

3.2 billion? Where did that number come from?

A. Basically the cost of $63.5 million divided by the

acreages that were purchased.

Q. I'm sorry. I'm not asking the question artfully.

Was there a comparable, another piece of

real estate, that was used to value this real estate and

arrive at a 3.2 billion valuation?

A. Yes, sir. That's my understanding, yes, sir.

Q. Who decided which real estate to use as a comparable,

as a comparison point, to value this real estate?

A. Mr. Kuhrt, Mr. Mark Kuhrt, in accounting.

Q. He was the controller?

A. Local controller, yes, sir.

Q. To your knowledge, was there any outside appraisal

done or expert who was brought in to value the land?

A. No, sir.

Q. And, so, the land that Mr. Kuhrt used as a

comparable, were you familiar with that land?

A. Somewhat, yes, sir.

Q. How did it compare to the land at issue here, the

1,500 or so acres that we're talking about?

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3219

A. Well, it was of smaller parcels, and it was in an

improved state.

Q. Well, that's the question I had. When you say it was

in an improved state, was it developed?

A. It was developed land, yes, sir.

THE COURT: Like, what was sitting on it?

MR. STELLMACH: Right.

THE WITNESS: Housing and landscaping and

utilities to it, roads --

THE COURT: Was that --

THE WITNESS: -- infrastructure.

THE COURT: Was that located on the mainland or

also on some outlying islands?

THE WITNESS: It was located on an outlying

island.

BY MR. STELLMACH:

Q. But this outlying island had roads and utilities on

it?

A. Yes, sir.

Q. And this particular parcel that we're talking about,

the 1,500 acres that the bank had purchased, did it have

buildings on it?


Q. Was it set up for utilities and roads and developed

in the same way that the comparable property on the other

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3220

island had been?

A. No, sir.

Q. And nothing had been done, as you've testified, in

the four months from when the bank purchased it to when it

was going to be transferred back to the bank at a

5,000 percent markup?

A. No, sir.

Q. And, again, this was 2008. Can you remind us in

terms of the world economy what was happening to the

markets?

A. It was the worse downturn since the Great Depression.

They were plummeting.

Q. And when the markets are plummeting, this real estate

appreciates 5,000 percent through this calculation that

Mr. Kuhrt did?

MR. SCARDINO: Your Honor, I'll object to the

leading question. He's testifying --

THE COURT: Hold it. I understand the

question. Overruled.

Is that what we've heard? Sir? From your

testimony?


THE COURT: Okay.

BY MR. STELLMACH:

Q. And this transaction that was proposed --

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3221

THE COURT: It was -- wait a second. Was it

proposed or did it actually go through?

MR. STELLMACH: That was my question.

THE COURT: I'm sorry. I'll back off.

BY MR. STELLMACH:

Q. Could you answer the Judge's question?

THE COURT: No, answer your question. You

phrase it the way you want to, please.

BY MR. STELLMACH:

Q. Was this transaction that was actually proposed

actually completed?

A. No, sir, it was not.

Q. So these transfers of the land from the bank to

Mr. Stanford and back to the bank, to your knowledge, was

the paperwork and all the necessary transactional

documents, were those completed to make that legally

happen?

A. No, sir.

Q. That didn't happen, but we saw in Government's

Exhibit 138, the December 2008 monthly report, that there

was an announcement that the capital of the bank had been

raised to over a billion dollars?

A. Yes, sir.

Q. So even this -- these entries that you're describing,

did they ever take place?

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3222

A. They were never completed, to my knowledge.

THE COURT: In other words, there were no deeds

or anything else done, it was evidenced by accounting

figures?

THE WITNESS: That's correct, Your Honor.

BY MR. STELLMACH:

Q. And I think, Mr. Davis, if you could take the stand.

And I wanted to go back to the attachment to Government's

Exhibit 5.

MR. SCARDINO: Mr. Stellmach, what exhibit are

you referring to?

MR. STELLMACH: Government's Exhibit 5, the

spreadsheet we had just been looking at, upper left-hand

portion, the same portion we had seen enlarged before. I

know we have a little more context for it.

BY MR. STELLMACH:

Q. So under "acres," there's a total of 1,500 or so

acres?

THE COURT: Where are we looking at?

MR. STELLMACH: I'm sorry, Your Honor.

THE COURT: Oh, there it is. Okay.

BY MR. STELLMACH:

Q. What did that number represent? What was that a

total of?

A. A total of the column above that number. It's a

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3223

total of the individual real estate parcels.

Q. And the number next to it under cost, 63-1/2 million?

A. It was the price actually paid for those acres.

Q. And then the 3.173 billion market number?

A. That was a calculation done of the individual

acreages line by line basically times the $2 million per

acre.

Q. Using the value for this other developed property to

value the 1,500 undeveloped acres here?

A. Yes, sir.

MR. STELLMACH: And if we turn to the right

side of this document of the spreadsheet, if we could --

yes, just enlarge that.

BY MR. STELLMACH:

Q. Could you explain to us what these breakdowns are

involved? It says Company A, Company B, Company C,

Company D.

A. Yes, sir. It's a rather complicated analysis

accounting-wise, but it basically states that the parcels

of real estate were, dollar-wise, inflated in value. And

those values, once inflated, were used to eliminate

individual capital contributions in A and B.

Q. Could I ask you to stop there, Mr. Davis, for a

moment?

A. Yes, sir.

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3224

Q. And going back to the diagram you drew. So in the

diagram you drew, you show the real estate being

transferred back from Mr. Stanford to the bank at 3.2 --

$3.1 billion. Am I reading that accurately?

A. Yes, sir.

Q. And then the breakdown here, what does this reflect

was going to happen once that value had been transferred

back to the bank?

A. Once the bookkeeping and legal was completed,

starting from the top, where it says "Company A, 200

million; Company B, 641 million," those were two announced

capital infusions that never really actually happened. No

dollars ever changed hands. And, so, part of the

3.2 billion bookkeeping contribution was going to be used

to offset those two announced fictitious capital

infusions.

Q. So the highlighted entries on this form, are those --

are those a breakdown of how the 3.2 billion was going to

be split up, once it went back to the bank, how it was

going to be treated on the books of the bank?

A. Yes, sir.

Q. And, so, the first two entries totaling 741 million,

those were going to support the capital infusion number?

A. That's correct.

Q. And then Company C, value equal to 1.7 billion loan

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3225

offset?

A. Yes, sir. Just below that high -- okay. Yes, sir.

Company C, the 1.7 billion loan pertains

to eliminating the loans that Mr. Stanford had taken out

and owed to the bank.

Q. So this was also going to be used, this real estate,

to pay off all of the loans that Mr. Stanford had taken

out?

A. Yes, sir. That was the plan.

Q. And then Company D, it reads, "733 million market

value remaining of real estate."

Was that the amount left over after the

capital contribution and the loan had been paid off?

A. Yes, sir. That would be a balance.

Q. And what was the intention of how to use that -- what

was the plan on how to use that money?

A. As I recall, it was there to use for future

bookkeeping entries similar to these.

Q. So another 700 million left in the kitty, so to

speak, to pay any future expenses or credit for future

withdrawals by Mr. Stanford?

A. Yes, sir.

Q. And, again, this was all proposed. None of it ever

actually happened? That real estate was never transferred

from the bank?

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3226

A. That's correct.

Q. Was there ever any announcement by the bank or by

Mr. Stanford that no assets had, in fact, been transferred

to the bank to support the announcement that had been made

to the financial advisors and to the depositors about him

raising the capital to over a billion dollars?

A. No, sir.

Q. If we could just go back to the e-mail that this was

attached to, very quick question. It goes from Mr. Kuhrt

to Mr. Lopez.

Could you just remind us where Mr. Kuhrt

was working at the time this was all happening?

A. Working in global headquarters in St. Croix as global

controller reporting to Mr. Stanford.

THE COURT: How come the world headquarters was

in the Virgins Islands instead of Houston? Was there a

reason for that?

THE WITNESS: Yes, Your Honor. It was done for

tax reasons.

THE COURT: Okay. That's right. I'm sorry.

You mentioned that before. Okay.

BY MR. STELLMACH:

Q. And then Mr. Lopez, where was he based?

A. In Houston, Texas.

Q. So this e-mail with this attachment would have been

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3227

sent by Mr. Kuhrt from outside the country to Mr. Lopez

here in Houston?

A. That's correct.

THE COURT: Just to fill in, St. Croix, Virgin

Islands, is that British Virgin Islands or the U.S. Virgin

Islands?

THE WITNESS: U.S.

THE COURT: And they do have tax breaks on the

Virgin Islands versus the mainland?

THE WITNESS: Yes, sir. It's known as an

economic development zone.


BY MR. STELLMACH:

Q. And moving into 2008, we've -- you've testified

before about an SEC investigation back in 2005 and 2006.

Did there come a point in 2008 when that

investigation heated up again?

A. Yes, sir.

Q. How did you find out about that?

A. From -- I found out from our general counsel.

THE COURT: By the way, did the SEC ever take

you-all up on the invitation to come down under those

conditions, I guess, to visit with Mr. King, and did they

ever come down to the islands to do that?

THE WITNESS: No, Your Honor.

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3228

THE COURT: Okay.

BY MR. STELLMACH:

Q. And what did Mr. Alvarado tell you about the

investigation?

MR. SCARDINO: Object to the hearsay.

MR. STELLMACH: May I respond?

THE COURT: Overruled. Not the exact words.

As a result of discussing with him, do it that way, please.

BY MR. STELLMACH:

Q. As a result of discussing the SEC investigation with

Mr. Alvarado, what do you understand about the seriousness

of that investigation?

THE COURT: At what stage?

MR. STELLMACH: This was -- I'm sorry.

THE COURT: 2008?

BY MR. STELLMACH:

Q. It's 2008, and I think it was December?

A. December -- first st week in January of 2009.

Q. Okay. After speaking with Mr. Alvarado, what did you

understand about the seriousness of the SEC's

investigation?

A. That it was very serious to Mr. Alvarado, for sure.

He said --

THE COURT: No, can't say what he said.


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3229

THE COURT: That's hearsay.

BY MR. STELLMACH:

Q. Although Mr. Alvarado was the general counsel of the

bank?

A. Yes, sir.

THE COURT: What he's saying is hearsay. You

can get around that.

BY MR. STELLMACH:

Q. When Mr. Alvarado told you that it was serious, what

did he tell you about the nature of the investigation,

what the investigation -- what did you understand the

investigation was focussing on?

MR. SCARDINO: That's hearsay.

THE COURT: All right. How do you get around

it, Counsel?

MR. STELLMACH: Mr. Alvarado is the general

counsel of the bank.

THE COURT: And therefore?

MR. STELLMACH: An agent of Mr. Stanford. It's

not hearsay. It's in 801(D)(2)(d).

MR. SCARDINO: I'll respectfully submit that's

not been established.

MR. STELLMACH: That Alvarado is the general

counsel? I think the witness has testified about that.

That's sufficient.

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3230


MR. SCARDINO: If, in fact, if that is -- I got

stuck. Too many facts in there.

THE COURT: Yes.

MR. SCARDINO: Then there would be a privilege

issue if he represents Mr. Stanford.

MR. STELLMACH: He represents the bank. He's

the general counsel of the bank, and the bank has waived

all privilege. They're the receiver.

MR. SCARDINO: It's been established that

Mr. Stanford owned the bank 100 percent. We would object

on the privilege issue.


MR. STELLMACH: So -- I'm trying to remember

why we even got into this argument.

THE COURT: No. No. You can ask him what the

man said.

MR. STELLMACH: Right.

THE COURT: That's where we started.

BY MR. STELLMACH:

Q. What did Mr. Alvarado tell you about the SEC's

investigation?

A. He said, quote, "Jim, this is serious shit. You've

got to get Mr. Stanford engaged. We have to have a

meeting. They have subpoenaed you -- subpoenaed you and

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3231

Mr. Stanford."

Q. Did Mr. Alvarado tell you what the investigation was

focussing on?

A. Yes, sir.

Q. And what did he tell you about that?

A. Said the focus was on their desire at the SEC in

Fort Worth office, their desire to see a complete

breakdown of the assets of Stanford International Bank,

specifically the investment assets.

Q. After that conversation with Mr. Alvarado, did you

discuss the investigation with Mr. Stanford?

A. Yes.

Q. Where did that discussion take place?

A. It took place in Mr. Stanford's offices in St. Croix,

U.S. Virgin Islands.

Q. And approximately when did it take place?

A. Early to mid January 2009.

Q. What did Mr. Stanford say in that conversation about

whether he would subpoena -- he would testify or provide

documents in response to a subpoena?

A. I don't recall what Mr. Stanford said, but at the

meeting the three of us --

MR. SCARDINO: I'll object to nonresponsive.

THE COURT: Rephrase it. Thank you.


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3232

BY MR. STELLMACH:

Q. What did you tell Mr. Stanford about whether you

would testify?

A. I told him that I wasn't going to lie to the SEC. If

I went, I was going to tell the truth.

Q. Even though you had been lying since 1991, 1992?

A. Even though I had been lying for 16, 17 years.

Q. Why not lie under oath to the SEC?

A. Number one, I drew a line in the sand. Number two,

if you lie under oath, the future is not very bright, as

far as things staying free and clear of a multitude of

issues. There's never -- I thought to myself, there's

never a time -- a bad time to tell the truth. It's never

too late. So that was my commitment then.

Q. What did Mr. Stanford say when you told him you

wouldn't testify falsely if you actually went in to speak

with the SEC?

A. Basically that Mr. Mauricio Alvarado and outside

counsel to Mr. Alvarado were working the program, the

process out, to deal with the subpoenas and the upcoming

meeting and that a future meeting would take place that

Mr. Stanford would chair and have the leadership of the

brokerage and the bank at that meeting and go ahead and

finalize the details of the upcoming SEC meeting.

Q. Did Mr. Stanford identify who this other lawyer was

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3233

who was going to represent the bank with the SEC?

A. Yes, sir. Mr. Tom Sjoblom.

Q. Where was Mr. Tom Sjoblom based?

A. United States, in the East. I believe in Washington.

Not sure, could have been New York.

Q. Did there come a time when a meeting actually did

take place involving Mr. Stanford and other executives at

the Stanford organization?

A. Yes, sir, there was a meeting held.

Q. When was that meeting held approximately?

A. Middle of January 2009.

Q. Where was the meeting?

A. At a Stanford Aviation hangar in Miami Airport.

Q. Who attended?

A. Myself; Mr. Mauricio Alvarado, general counsel;

Mr. Tom Sjoblom, consultive counsel to Mr. Alvarado and

the group; Juan Rodriguez, the president of the bank;

Mr. Danny Bogar, president of the brokerage; Ms. Lena

Stinson, global compliance officer; and Ms. Laura Holt,

the chief investment officer.

Q. What about Mr. Stanford? Was he there physically?

A. No, sir.

Q. Did he participate?

A. Yes, sir. He called in by telephone conference.

Q. And during that meeting, did Mr. Sjoblom, the lawyer

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3234

who'd been brought --

THE COURT: Is he -- with a was there's a firm

in New York or Washington?

MR. STELLMACH: Yes, he is, Your Honor.

THE COURT: I'm just going to ask you. It's a

matter of I don't think intention.

What firm was he with?

MR. STELLMACH: It was Proskauer Rose, Your

Honor, in New York. I think Mr. Sjoblom is based in the

New York and D.C. offices.

THE COURT: Okay.

BY MR. STELLMACH:

Q. So, Mr. Davis, during that meeting, did Mr. Sjoblom

explain in any more detail what the SEC was looking for by

way of information regarding the bank and its assets?

THE COURT: Hang on one second.

MR. SCARDINO: Hearsay and privilege.

THE COURT: Overruled. It's either a "yes" or

"no."


THE COURT: Counsel, why isn't it privilege?

MR. STELLMACH: Mr. Sjoblom represented the

bank, and the privilege has been waived by the receiver.

THE COURT: Privilege has been waived by who?

MR. STELLMACH: The receiver.

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3235

THE COURT: By the receiver. Okay.

MR. SCARDINO: I would submit to the Court that

there is also information that is -- that the prosecution

has shared with us, and Mr. Sjoblom at one point in time

did actually represent Mr. Stanford.

MR. STELLMACH: Well, that never actually

happened. There's a conversation that takes place much

place later, and we've taken great pains, Your Honor, to

making nobody at this table knows what happened at that

conversation for reasons I don't know if we want to discuss

in front of the jury, but I'm comfortable.

THE COURT: Okay. I'm ready to rule.

Counsel, you object. Is that correct?

MR. SCARDINO: That is correct.


BY MR. STELLMACH:

Q. What did Mr. Sjoblom tell you the SEC wanted to know?

A. Wanted to know the detail that would fully describe

the holdings of assets for Stanford International Bank,

Limited, specifically the detail of each and every detail

of the investment and the investment house or the

financial institution, where those investments were held.

Q. Did Mr. Sjoblom at any point also show you subpoenas

that the SEC had issued for your testimony and information

regarding the bank?

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3236

A. They were on the table, sir.

MR. STELLMACH: I'm showing the witness

Government's Exhibits 26A, B and C.

BY MR. STELLMACH:

Q. Do you recognize those documents, Mr. Davis?

THE COURT: Government's 26A B and C?


THE WITNESS: Yes, sir, I've seen this.

MR. STELLMACH: Your Honor, we offer those.

THE COURT: They're in.

MR. STELLMACH: They're in.

BY MR. STELLMACH:

Q. We'll turn to 726 C, which I think is the bank

subpoena.

THE COURT: This is an SEC -- a Securities and

Exchange Commission subpoena. Is that correct? Just for

the record.

MR. STELLMACH: Mr. Davis -- yes, it is.

THE COURT: It is.

THE WITNESS: Excuse me. Yes, sir.

THE COURT: I just want to get it in for the

record.

Go on.

BY MR. STELLMACH:

Q. And it's addressed to Stanford International Bank,

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3237

care of you as the CFO.

And could you read what it -- the checked

box directly beneath it, reading, "You must produce."

A. Yes, sir. "You must produce everything specified in

the attachment to the subpoena to officers of the

Securities and Exchange Commission, at the place, date and

time specified below."

MR. STELLMACH: And could we just turn to the

attachment to get a sense of what it was. Specifically

Page 2 of the attachment, the next page. Those are all

definitions. I'm sorry.

BY MR. STELLMACH:

Q. What were the documents that the SEC was seeking? In

general terms, not marching through every single item.

A. They wanted a listing, an itemized list, of the fair

value of each and every investment or financial asset in

the SIBL investment portfolio.

Q. And in addition to seeking documents, was the SEC

also seeking testimony from any officers of the

organization?

A. Yes, sir.

Q. You received a subpoena. Is that correct?

A. Yes, sir.

Q. And Ms. Holt was also subpoenaed?

A. Yes, sir, that's correct.

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3238

Q. Was there any discussion in this meeting about who

should testify before the SEC?

A. Yes, sir, there was.

Q. What was the decision made about who should actually

go in and testify?

A. Decision was made that Juan Rodriguez, the president

of the bank, and Laura Holt, the chief investment officer

of Stanford Financial Group Limited, and Inc.

Q. Now you've testified previously that --

THE COURT: Who made that decision?

THE WITNESS: That decision was made by

Mr. Stanford.

THE COURT: You mean, on the phone?

THE WITNESS: On the phone.

THE COURT: Okay. Thank you.

THE WITNESS: He was on the phone during that

meeting, Your Honor.

BY MR. STELLMACH:

Q. Was there any discussion about how Ms. Holt or

Mr. Rodriguez, the bank president, could testify about all

of the bank's assets when all they knew about was Tiers 1

and 2, the cash and the marketable securities?

MR. SCARDINO: I'll object to the leading

question.


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3239

THE WITNESS: Yes, there was.

BY MR. STELLMACH:

Q. Was there a discussion about the next steps that

would be taken so that they could testify about the entire

portfolio of the bank before the SEC?


Q. And what role were you going to play in enabling them

to testify about all the assets?

A. My role was to delineate or itemize the assets that

were held in the so-called Tier 3 investment section.

Q. Which nobody else at the meeting had seen at that

point, the people who were physically present had seen?

MR. SCARDINO: Object to leading.


THE WITNESS: That's the section that no one

else at that time had seen, yes, sir.

THE COURT: That testimony has already been

elicited many different ways already.

MR. STELLMACH: Yes.

THE COURT: The reason why it was a leading

question, but I allowed you to go ahead. Go on.

BY MR. STELLMACH:

Q. So in terms of the people who were present at this

meeting in the Miami hangar and who were participating by

phone, who actually knew of the contents of Tier 3 were?

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3240

A. Mr. Stanford and myself.

Q. Did Mr. Stanford express any concerns in this meeting

about the SEC and what they might uncover?

A. No, sir.

Q. Did he ever express any opinion to you about the

capability of the SEC in uncovering any misconduct?

A. Yes, he did.

Q. When did he -- when did that conversation take place

or that remark take place?

A. Between -- at a time between this meeting at the

hangar and the first week of February.

Q. What did Mr. Stanford say about the SEC?

A. Firstly, if I may, I asked the question of how --

THE COURT: You asked a question of who, sir?

THE WITNESS: Mr. Stanford. I asked the

question of Mr. Stanford, how this was going to take place

knowing that there is no Tier 3?

BY MR. STELLMACH:

Q. When did you ask that question of Mr. Stanford?

A. Between --

Q. After the hangar meeting?

A. After the hangar meeting, prior to the first week in

February.

His response was, "Just give them the same

report that you give to the regulators in Antigua which

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3241

lists all of the fictitious holdings per financial

institution, so they won't know the difference. They're

not that smart."

And, so, I said, "Well, they are that

smart, and they will know, and I'm not going to share that

with them."

Q. And then you said that there was another meeting that

takes place later after this in the first week of

February?

A. Yes. At the meeting at the hangar.

Q. Well, I'm sorry. Go ahead.

A. I was just going to state at the meeting at the

hangar, Mr. Stanford said, "Well, let's meet again in two

weeks, first week of February in Miami together, and we

will complete preparation for this upcoming meeting with

the SEC."

Q. And, so, also in January, were there any other

meetings of the Top Producers Club?

A. Yes, sir.

Q. Where were those held?

A. One was held in Miami with the foreign financial

advisors; that is, those in other countries working for

other Stanford companies. And there was one also in

Arizona, and that one was a directed toward the financial

advisors who were located in the United States.

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3242

Q. Were you able to speak with Mr. Stanford at either of

these meetings?

A. Yes, sir.

Q. What was discussed? Which meeting did you speak with

him, at the Miami or Phoenix meeting?

A. We had conversation at both meetings.

Q. Do you recall discussion with Mr. Stanford about

obtaining more CD sales from Libya, from the Libyan

government?

A. Yes, sir.

Q. What did Mr. Stanford tell you about the Libyan

government in those conversations?

A. Well, he said that there was connection between Libya

and the Europe office with -- through our financial

advisor by the name of Peter Siragna and that they had

been clients in the past, and that he was going to take a

trip to Libya and speak with them regarding additional

business.

Q. By "additional business," what do you understand

Mr. Stanford to be referring to?

A. Sales of certificates of deposits.

Q. Was he clear about that, that he was talking about

CDs?

A. Yes, sir.

Q. Did Mr. Stanford ever tell you later whether he

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3243

actually made that trip?

A. Yes, sir.

Q. And what did he tell you about his efforts to obtain

additional sales?

A. That no additional sales were obtained, to my

knowledge. That's what he said.

Q. So we're now turning to the first week of February.

Where did you go? Where did you travel

to?

A. Miami, Florida.

Q. And remind us, what was the purpose of going to

Miami?

A. It was a follow-up meeting to the one mentioned

earlier at the hangar a couple of weeks before. This

meeting was called to finish preparation for a

presentation to be made to the SEC in Fort Worth, Texas.

Q. Was that where the testimony was going to take place,

in Fort Worth?

A. Yes, sir.

Q. Who showed up at the meeting the first day?

THE COURT: Where?

MR. STELLMACH: In Miami.

THE WITNESS: The Miami Stanford offices,

Biscayne Bay.

Mr. Juan Rodriguez, the president of the

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3244

bank; myself; Ms. Lena Stinson, global compliance officer;

Mr. Mauricio Alvarado; general counsel; Mr. Tom Sjoblom,

consultive counsel to Mr. Alvarado and to Stanford;

Mr. Danny Bogar, president of the brokerage, Stanford

Group, headquartered in Houston. I believe -- believe that

was the ones on Monday, the people that arrived on Monday.

BY MR. STELLMACH:

Q. Was Mr. Stanford -- was the plan that Mr. Stanford

would also be there in Miami?

A. Yes, sir, of course.

Q. On the first day, though, was he present?

A. No, sir.

Q. So what happened the first day that you showed up

with these individuals and Mr. Stanford hadn't shown up

yet?

A. Late midmorning, Mr. Alvarado and Mr. Sjoblom said

that since Mr. Stanford is not there --

MR. SCARDINO: If I can have a running

objection as to what the lawyer said.

THE COURT: Absolutely. You are granted a

running objection.

THE WITNESS: It was decided to break up the

meeting since Mr. Stanford had not yet arrived.

BY MR. STELLMACH:

Q. What happened the next day?

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3245

A. In addition to the individuals that I just mentioned

that were in attendance, the chief investment officer,

Laura Holt, arrived, the meeting was convened. And about

midmorning, 10:00 or 10:30 Mr. Stanford had still not

arrived. And after a few phone calls, I was able to get

in touch with Mr. Stanford, who was still in the U.S.

Virgin Islands. And he asked what was going on, and I

said that "Well, the meeting's convened. We're waiting on

you."

MR. SCARDINO: Request it be question and

answer.

THE COURT: Okay. Question and answer.

BY MR. STELLMACH:

Q. And what did Mr. Stanford say when you told him

everyone was waiting on him?

A. He asked what was going on.

And I said, "Well, for one thing, Mr. Juan

Rodriguez has a question for you."

Q. Did you tell him what the question was?

A. I put him on speakerphone to the group, and he

said --

THE COURT: Who is "he"?

THE WITNESS: I'm sorry. That Mr. Stanford

said, "What is it, Juan?"

BY MR. STELLMACH:

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3246

Q. And what did Mr. -- did Mr. Rodriguez say anything?

A. He did.

Q. What did he say?

A. He said, "There is a queue" -- in other words, a

line -- "of client customers of Stanford International

Bank, Limited requesting withdrawals. And we need X

amount of dollars to honor those withdrawals."

Q. And what did Mr. Stanford say?

A. After Mr. Rodriguez gave him the number, he said,

"Okay. I'll be there tomorrow. I've got your money and

I'll be there tomorrow."

Q. Did you speak with Mr. Stanford later that day or no?

A. No, sir.

Q. And what day of the week are we at now? Is this

Wednesday?

A. We were speaking of Tuesday.

Q. Tuesday. What happened on Wednesday? Did

Mr. Stanford show up?

A. No, sir.

Q. Did you do anything to try to reach him or contact

him?

A. Yes, sir.

Q. What did you do?

A. I called again, as I did the previous day. I was

able to speak with his, I believe, fiancee at the time.

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3247

Q. And we're not going to get into that conversation,

but did there come a point later on Wednesday when you

were able to speak with Mr. Stanford directly?

A. Directly, yes, sir.

Q. And what did Mr. Stanford say to you?

A. He said that he had had his head up his ass and that

he was now ready to come to the meeting, fly to Miami, and

lead us out of the wilderness.

Q. Was that an expression that you recall him using, "To

lead you out of the wilderness"?

A. Verbatim.

Q. And on -- what happened the next day, Thursday?

A. Well, the meeting with the attendees to the meeting

as mentioned earlier began about 9:00 o'clock.

THE COURT: So this is on Thursday; correct?


THE COURT: Thursday, the fourth day that

you've been there?



MR. STELLMACH: And if we could pull up

Government's Exhibit 332.

Thank you, Your Honor.

BY MR. STELLMACH:

Q. Do you recognize this document, Mr. Davis?

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3248

A. Yes, sir, I do.

Q. And what was it -- or what is it?

A. This is a chart that I prepared while in Miami that

week.

Q. And reading the title of the chart, can you explain

to us -- or just read that title for us?

A. "Tier 3, 6.3 billion, private equity sectors and

asset classes."

Q. Okay. And so --

THE COURT: Since it was -- who actually had

knowledge of Tier 3? It was you and Mr. Stanford and

anyone else?

THE WITNESS: Prior to this moment?


THE WITNESS: The two of us, Your Honor.

THE COURT: So you drew this up on the computer

yourself?

THE WITNESS: I did.

THE COURT: All right. Was it distributed to

everybody or you just held on to it?

THE WITNESS: It was not distributed. I held

on to it, Your Honor, until it was similarly displayed

before the attendees at this meeting on a screen, overhead

screen.

THE COURT: Was that after Mr. Stanford

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3249

arrived?

THE WITNESS: No, sir.

THE COURT: In other words, you let them know

what tier -- that there was a Tier 3?

THE WITNESS: Yes, sir --

THE COURT: Okay.

THE WITNESS: -- I did.

THE COURT: Now, did Mr. Stanford eventually

arrive, let's put it that way?

THE WITNESS: Yes, sir, he eventually came.

THE COURT: So this was done before he arrived

there?

BY MR. STELLMACH:

Q. And, so, we're --


BY MR. STELLMACH:

Q. We're still on Wednesday. Mr. Stanford hasn't shown

up yet.

THE COURT: I thought we were on Thursday.

THE WITNESS: Thursday morning.

BY MR. STELLMACH:

Q. I'm sorry. Thursday morning. Mr. Stanford hasn't

shown up yet.

And you put together this pie chart. It

reads: "6.3 billion in Tier 3, private equity sectors and

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3250

asset classes, 30 June 2008."

This was prepared when?

A. February -- first week in February of 2009.

Q. Why were you using June 30th of 2008 as the date?

A. This was the date of the last closing of the books

for Stanford International Bank, Limited --

Q. And --

A. -- and the last published report.

THE COURT: Was that published?

THE WITNESS: It was, sir. The six-month

report.

MR. STELLMACH: Of the information.

THE WITNESS: Not this, but he asked me about

the date.

THE COURT: That's what I mean, so I'm not

following that.

BY MR. STELLMACH:

Q. All right. And, so, why do you have the values and

the information in here as of June 30th of 2008 even

though it wasn't prepared, according to your prior

testimony, until February -- January, February of '09?

Why date it as of June of '08?

A. That was the last closing of the books represented in

the bookkeeping side.

Q. Were those the most current numbers you had to work

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3251

with?

A. Yes, sir.

Q. So that's why there's a six- or seventh-month lag --

A. Right.

Q. -- from when you put it together?

A. Yes, sir, correct.

Q. And there are a number of -- of assets broken down

here. Retails -- I'm looking at the upper left-hand

quadrant showing different investments, wireless

technology, travel, entertainment, healthcare,

manufacturing. Were these private equity investments?

A. Yes, sir, they were.

Q. Owned by the bank?

A. No, sir.

Q. Well, owned by which company?

A. Stanford Venture Capital Holdings as shell company

and also somewhere owned by Stanford Financial Group

Company.

Q. But treated -- but for purposes of this chart, they

were credited to the bank?

A. For the purposes of this chart, yes, sir.

Q. And the value we see in the lower half is about --

50.7 percent is in real estate?


Q. So that according to the chart, the total is

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3252

6.3 billion. That's about 3.1 billion and change?


Q. What was the real estate being identified in the

chart?

A. In Antigua, Barbuda.

Q. Did it have any relationship to the real estate we

just looked at involving the flip?

A. The one and the same.

Q. So it's the same real estate that had been inflated

from 63-1/2 million at its purchase price to 3.2 billion

through the flip process that was never completed?

A. Correct.

MR. SCARDINO: Object to the term "inflated."

MR. STELLMACH: That was the witness.

THE COURT: Hold it. Overruled.

BY MR. STELLMACH:

Q. So, Mr. Davis, there are values placed on the private

equity investments that are seen here. Obviously if

something is 7 percent like the wireless technology in the

middle of 6.3 billion, there's been a value assigned to

them. Who came up with those valuations?

A. The answer is in pieces. The private equity came

from our earlier testimony, the valuation process that

came from Mr. Kuhrt, Mr. Lopez. And valuation of the top

private equity individual items such as travel,

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3253

entertainment, water, wireless, financial, et cetera, came

from a listing from the capital markets group. And the

third piece over on the right side notes receivable.

Those notes were the notes Mr. Stanford had made with the

bank based on the monies that he had pulled from the CD

depositors.

Q. So that's the 2 billion and change in notes he had

taken out of the bank or loans he had taken?

A. Yes, sir.

Q. But with respect to the private equity that was here

being shown as a bank asset, were the values shown

accurate or not?

A. They were inflated above cost.

Q. Who inflated them?

A. I did. They came from a listing from California

markets group, and I took the higher values on most cases

that they gave me and added some on two or three items

myself.

Q. And the real estate you've testified about before,

was it your testimony that that was also inflated?

A. Yes, sir. Above cost, approximately 5,000 percent.

Q. So the 6.3 billion value that you were showing in

Tier 3, was that an actual value?

A. It's a lie.

Q. But this was the pie chart you were showing the

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3254

people attending that meeting in Miami?

A. Yes, sir.

Q. When you showed them the pie chart, did you explain

to them that the numbers in it, the values, are a lie?

A. I showed them that they were inflated over cost at

so-called a market.

THE COURT: Where did you get those numbers

from? I mean, now that you're finally showing Tier 3 --


THE COURT: -- were those accurate?

THE WITNESS: No, sir. As I said, they were

inflated. They were a lie. It was a lie.

THE COURT: Let me ask you this: Why was it

inflated for these folks who were finally finding out that

there's a real problem?

THE WITNESS: It was, Your Honor, in an effort

to hook -- hook to the total amount reported so-called real

Tier 1, real Tier 2, plus the hole.

THE COURT: I'm not following.

THE WITNESS: Okay. It was --

THE COURT: No, no, I'll leave it to counsel.


THE COURT: Do you see what I'm saying?

MR. STELLMACH: I do, Your Honor.

BY MR. STELLMACH:

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3255

Q. So the bank's assets consisted of Tier 1 and Tier 2,

that was about 25 percent?

A. Yes, sir.

Q. That number had been dropping throughout 2008 in

order to cover CD redemptions?

A. Yes, sir.

Q. So there was now a difference between what the people

at the meeting knew, because they knew about Tiers 1 and 2

and the bank's total reported assets?

A. That is correct.

Q. And what did that 6.3 billion-dollar number that you

inflated to represent Tier 3 represent?

A. The number -- the difference between Tier 1 and

Tier 2 total in what was reported in the balance sheet of

Stanford International Bank, Limited.

Q. So --

A. It was a plug.

Q. So to cover the assets that were being reported, and

the assets that the people at the meeting actually knew,

that hole was about 6.3 billion as of January, February of

'09, in that neighborhood?

A. Yes, sir, in that neighborhood.

Q. So you backed into that number by inflating the

values?

A. That's correct.

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3256

MR. STELLMACH: One last question on this, Your

Honor.

BY MR. STELLMACH:

Q. When you showed the people at the meeting, these

executives in the organization, what the content of Tier 3

was without telling them that the numbers were a lie like

you just told us, just when they saw the content, how did

people react?

MR. SCARDINO: I'll object to form of the

question. It's generic. Which person is he referring to?


General impression.

THE WITNESS: The general impression given to

me was one of shock, mouths fell open. They were taken

back.

THE COURT: Well, was that a reaction you were

expecting or were you trying to get these folks just to be

relieved that there was some other assets somewhere around?

THE WITNESS: I think the former, Your Honor.

THE COURT: What?

THE WITNESS: That this is what is there.

THE COURT: Well, was it there or was it not

there? That's what I'm not following. In other words, it

was shown to them for a purpose. Was the purpose that you

thought you'd get, was that the reaction?

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3257

THE WITNESS: I thought that I would get that

reaction.

BY MR. STELLMACH:

Q. But you were trying to show the people -- were you

trying to show the people at the meeting that there was

actual value in Tier 3?

A. I believe so, yes, sir.

THE COURT: So was it a positive shock?


THE COURT: Okay. Let's leave it.

THE WITNESS: Negative.

THE COURT: Let's leave it right there. We can

pick up that later.


THE COURT: First thing to do, let me get the

screen up.

Ladies and gentlemen, we'll take our lunch

break. Please be back ready to resume at 2:15. We'll see

you at that time.

(Recessed at 1:01 p.m.)



Go right ahead.

MR. STELLMACH: Your Honor, replace the screen,

please?

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3258

THE COURT: Oh, absolutely. On its way.

BY:

BY MR. STELLMACH:

Q. Mr. Davis, I want to go back to this pie chart which

you showed at the Miami meeting to the other senior

executives before Mr. Stanford sowed up Thursday that

first week in February of '09?

Prior to that meeting, had people at that

meeting been led to think that there was about

$6.3 billion in value in Tier 3?


form of the question, had people been led to believe, and

ask you to narrow --

MR. STELLMACH: I think I did narrow it to the

people who were attending the meeting.

THE COURT: Okay. It's narrowed. Thank you.


BY MR. STELLMACH:

Q. And you then --

THE COURT: So -- wait a second. So these

people knew a Tier 3 existed, but they didn't know what was

in it, is that the deal?



BY MR. STELLMACH:

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3259

Q. But they had been led prior to the meeting to think

it was in the neighborhood of $6.3 billion?

A. Correct.

Q. And you -- I think you had explained that you then

used that total number when inflating the values of the

different assets shown here to back into the 6.3 billion?

A. Yes, sir.

Q. Prior to the meeting, though, what had people been

led to believe about the types of assets that were in

Tier 3?

A. That they were the same styled and content of what

was in Tier 2.

Q. So, for example, had people at the meeting been told

about any real estate investments by the bank?

A. No, sir.

Q. Had they been told about any private equity

investments by the bank?

A. No, sir.

Q. Or the existence of any loans to Mr. Stanford

Reflected in the right-hand quadrant of the -- of that

chart?

A. No, sir.

Q. So the executives who were attending this meeting in

Miami, had they been told anything different about the

assets and the value of Tier 3 than what the depositors

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3260

had been told or the financial advisors?

A. No, sir.

Q. So when you showed people this pie chart and you said

that the reaction was one of shock, what was your

understanding about what people were shocked by at the

meeting?

A. There was shareholder loans --

MR. SCARDINO: Excuse me. I would object to

him asking a question about what somebody else felt.

MR. STELLMACH: I'll clean it.

THE COURT: Okay. Sustained. In other words,

how does he know that that's why there was a problem, if

they were.

BY MR. STELLMACH:

Q. Did people express shock at the meeting?

A. They did.

Q. What specifically did people say, if you can remember

the individuals?


hearsay.

THE COURT: Sustained. You can say in essence.

BY MR. STELLMACH:

Q. In essence what did they say?

THE COURT: Well, no. In essence --

MR. STELLMACH: I had to try, Judge.

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3261

BY MR. STELLMACH:

Q. Let me ask it this way --

THE COURT: Let's see now, don't answer, sir.

Go on.

BY MR. STELLMACH:

Q. Regarding the note receivable to Mr. Stanford, which

is reflected here in the neighborhood of 1.7 to

$2 billion, that was --

THE COURT: What was the essence of what they

said, not in their exact words, but just generally.

THE WITNESS: They were taken back in a

negative way that there were notes receivable from

Mr. Scardino. They were taken back in a negative way that

there were 51 percent of the Tier 3 at least on this chart

indicative of real estate holdings.

BY MR. STELLMACH:

Q. And what about the private equity, the other piece of

Tier 3?

A. In a lesser degree, yes, they were taken back

negatively about the composition of Tier 3.

Q. Did anyone cry?

A. Several people cried, yes.

Q. Do you remember if Mr. Bogar, the president of the

brokerage firm, how he reacted?

THE COURT: Do you remember?

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3262

THE WITNESS: I certainly do.

BY MR. STELLMACH:

Q. How did he react?

A. The very next morning he reacted by sitting down

getting ready the meeting to begin and he broke down in

sobs, in tears.

Q. So on Thursday you show the pie chart, and you

testified people were shocked. At this point, did you

tell the people at that meeting that the values in this

pie chart were inflated?

A. I don't believe so, no, sir.

Q. So you were telling them in general terms what was in

Tier 3, but were you telling them the actual value of the

assets in Tier 3?

A. No, sir.

Q. After you had this presentation, what happened next?

When people had that reaction, what happened next?

A. Essentially Mr. Stanford finally arrived after that.

Q. He arrived that afternoon?

A. Middle of the day.

Q. And when Mr. Stanford arrived, what took place in the

meeting?

A. I believe he sat down with the others. I stood up

and said, "This is what was reported by myself this

morning." Put this chart up on the screen, and explained

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3263

section by section what had been shared.

Q. So you went through your presentation again with

Mr. Stanford present?

A. I did.

Q. Were the other people in the room still there?

A. Every one of them, yes, sir.

Q. At the end of your presentation, did Mr. Stanford say

anything?

A. Yes, he did.

Q. What did he say?

A. Mr. Stanford took the floor, I sat down, and he said,

"It's just as Jim has shared in this chart."

Q. Did he say, "I just learned about this myself"?

A. No, sir. He said that he was responsible for this,

it's his fault, and he's very sorry.

Q. Did he say that there were international accounting

standards that allowed him to tell the depositors one

thing about the bank's assets and to do another in

reality?

A. I don't recall that.

Q. Do you recall Mr. Stanford every saying that in the

time you worked for him, that because of some

international accounting standards, he could tell

depositors something different than what he was doing with

the assets of the bank?

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3264

A. I don't recall him saying that.

Q. And, so, does Mr. Stanford at this meeting say

anything else, after this presentation has happened, and

he says -- he confirms what you've told them, do you

recall anything else that he said?

A. Yes, sir. He said that that is, in fact, the truth

and that beyond that, there's actually much more value

that is reported in that chart.

Q. So Mr. Stanford said he believed there was more than

even 6.3 billion in value in the Tier 3 assets?

A. Yes, sir. He said that they had real brick and

mortar assets, real assets worth more than depicted in

this chart, yes.

Q. Do you remember anyone asking any questions about the

financial statements of the bank which had been issued for

years, whether there were any inaccuracies in them?

A. Mr. Juan Rodriguez.

Q. He was the president of the bank?

A. Yes, sir.

Q. What did Mr. Rodriguez say?

A. He asked if his financials were correct.

Q. His financials meaning what financials?

A. The bank's SIBL's financials, the bank that he was

president of.

Q. And who responded to that question?

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3265

A. I believe I did.

Q. And what did you tell Mr. Rodriguez?

A. I told him that financials were not correct.

Q. Did Mr. Stanford contradict you and say that's not

true?

A. No, sir.

Q. In fact, at any point in the presentation you made

when you were walking through this pie chart and showing

the types of assets, at least, that were in Tier 3, did

Mr. Stanford ever contradict anything you said other than

insisting the value was, in fact, larger?

A. No, sir.

Q. Once Mr. Stanford arrived, what happened in the

meeting?

A. Well, there was a -- there were a lot of tears, a lot

of remorse.

Q. Who was showing remorse?

A. I suppose Mr. Stanford was. He was hugging necks,

and there were tears.

Q. What happened? Did the meeting then end?

A. I believe a meeting did break for the day, and it

resumed again on Friday morning.

Q. Before the meeting resumed on Friday, did you speak

at all with Mr. Stanford privately, just the two of you?

A. I did.

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3266

Q. Where did you have that conversation?

A. Well, I know we did meet in the lobby of the hotel in

the lobby bar reception, concierge's area of the hotel,

Intercontinental, which was adjacent to the office.

Q. Now, before Mr. Stanford showed up and you had gone

through this pie chart first with the executives and then

again with him present, had you told him this is what you

were going to do?

A. I don't believe I told him that this is what I was

going to do. I told him -- we had made a -- if I might --



BY MR. STELLMACH:

Q. What had you told Mr. Stanford you would do at the

meeting?

A. Configure what was in Tier 3 as part of the

presentation to support the presenters that were going to

present at the SEC meeting.

Q. But in configuring what was in Tier 3, did you tell

him you were going to break out and identify the loans,

for example, that he had taken?

A. Not specifically, no.

Q. Or disclose the actual contents of the Tier 3

portfolio?

A. No, I did not.

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3267

Q. So that night, when you're speaking with Mr. Stanford

in the lobby bar of the hotel, what -- did he say anything

to you about what had happened during the day?

A. Yes, he said I was naive and that I had melted.

Q. Was that the word he used?

A. He said, "Jim, you melted. If I had been there, I

would have never let you have done that."

Q. What did you say to Mr. Stanford?

A. I looked at him and said, "You weren't here."

Q. And then you speak with -- then there's another

meeting the following day, the next Monday?

A. No, sir. There was a meeting --

Q. I'm sorry. The next Friday?

A. -- Friday. Friday morning we had a meeting.

Q. Who was at that meeting?

A. The individuals that I shared with you before. CIO,

the global compliance officer, the chief counsel.

Q. So Ms. Halt, Mr. Alvarado?

A. Yes, Ms. Halt, Mr. Alvarado, Mr. Rodriguez,

Mr. Bogar, Mr. Schoblum, Mr. Stanford, and myself.

Q. And --

A. Ms. Stinson as well.

Q. Who is Ms. Stinson?

A. Global compliance officer.

Q. And I think you had said this was the meeting at

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3268

which Mr. Bogar, the president of the brokerage firm,

sobbed?

A. Yes. Just before it began, he broke down at the

table.

Q. What happened when Mr. Bogar was sobbing?

A. Mr. Schoblum, at the other side of the table, got up,

walked around the table behind Mr. Bogar, put his arms --

hands on Mr. Bogar's shoulder and said a prayer.

Q. Did Mr. Stanford eventually show up at this meeting?

A. He was there, yes.

THE COURT: What day now are we talking about?

THE WITNESS: Friday, Your Honor.

THE COURT: Okay.

BY MR. STELLMACH:

Q. During the meeting, was there any decision made about

the next steps to take concerning the information that had

been disclosed?

A. There were some steps shared by Ms. Lena Stinson,

yes, the compliance officer. She stated that there had to

be a five -- I believe it was five --

MR. SCARDINO: Object to the hearsay.

BY MR. STELLMACH:

Q. Ms. Stinson was the -- I'm sorry, Mr. Davis.

MR. STELLMACH: I'll just establish the

foundation, Your Honor.

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3269

THE COURT: Go on.

BY MR. STELLMACH:

Q. Who was Ms. Stinson, again? She was the compliance

officer?

A. Yes.

Q. For what company?

A. The global group of companies, which would have put

her over the brokerage as well as chief compliance

officer.

Q. So an employee of Mr. Stanford's companies?

A. Yes.

MR. STELLMACH: So on that basis, Your Honor, I

intend to ask the witness: What did Ms. Stinson say at the

meeting?

MR. SCARDINO: I don't think there's an

objection to hearsay the way it's phrased.

THE COURT: I agree. Sustain the objection.

BY MR. STELLMACH:

Q. Which company did Ms. Stinson work for?

A. Stanford Financial Group Global, I believe, was the

titled name, a St. Croix company.

Q. And who owned that company?

A. Mr. Stanford.

Q. The entire company?

A. Yes, sir.

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3270

Q. What did Ms. Stinson say at the meeting?

MR. SCARDINO: Renew my objection.

THE COURT: How do you get around it?

MR. STELLMACH: She is an employee of

Mr. Stanford's company, acting within the scope of her role

as compliance officer.

THE COURT: But is the -- is the Company A

party to this suit?

MR. STELLMACH: Well, it's one of the companies

that's rolled into -- I mean, a number of the companies are

because of the way they were being financed, but she was

invited to this meeting for the reason of -- because of her

role as compliance officer of that company.

MR. SCARDINO: I don't remember seeing where

invitees are an exception to the hearsay.

THE COURT: That's what I mean.

MR. STELLMACH: I'll firm it up.


BY:

BY MR. STELLMACH:

Q. What was the company Ms. Stinson worked at?

A. It was either Stanford Financial Group Global or

Stanford Financial Group Company or both.

Q. And which company -- you worked for Stanford

Financial Group?

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3271

A. Yes, sir.

Q. And what was the role of Stanford Financial Group in

the Stanford organization?

A. It was to provide legal compliance advertising,

promotion, accounting and other related services to the

entire affiliated group of Stanford-owned companies.

MR. STELLMACH: Your Honor, on that basis, I

think we satisfy the exception.

THE COURT: Hang on one second. Let me look it

up. I'm reading from the evidence book.

Now, are you alleging that this woman was a

co-conspirator?

MR. STELLMACH: No, Your Honor.

THE COURT: All right. So E is out. So

looking at D --

MR. STELLMACH: That's right.

THE COURT: -- correct?

Parties, agent or servant, the parties.

The party is Mr. Stanford?

MR. STELLMACH: That's correct.

THE COURT: All right. Is she her -- is she

his agent?

MR. STELLMACH: She is through the company that

he wholly owns.

THE COURT: That's the concern I've got. I

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3272

don't mind telling you. Okay. So you see the point that

I'm making out of an abundance of caution?

MR. STELLMACH: And out of abundance of

caution, Your Honor, we could also elicit it not for the

truth but merely for the fact that this is what Ms. Stinson

said --

THE COURT: And then what?

MR. STELLMACH: Then it's not hearsay. We're

not offering it for the truth.

THE COURT: I know. But for what purpose are

you --

MR. STELLMACH: For the effect on the state of

mind of the people who were present who include

Mr. Stanford as well as this witness.

MR. SCARDINO: Well, the state of the mind of

the people present is not relevant.

THE COURT: No, you're talking about state of

mind he was present, he's a defendant --

MR. STELLMACH: Exactly.

THE COURT: -- correct?

MR. STELLMACH: That's right, Your Honor.

THE COURT: Or party?

MR. STELLMACH: Yes.

THE COURT: Don't answer, sir. What was the

question exactly? What did --

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3273

MR. STELLMACH: What did Ms. Stinson propose?

THE COURT: Concerning?

MR. STELLMACH: Concerning the information that

had just been disclosed at the meeting.

THE COURT: And now, what happened after that?

Was some action taken based upon what her suggestion was?

MR. STELLMACH: There were some decisions made.

I think she had some ideas, as well as some of the other

attendees.

THE COURT: I'm just saying was some decision

made based upon what she said?

MR. STELLMACH: I believe so, Your Honor.

MR. SCARDINO: Well, Mr. Davis isn't a party to

this case. I mean, he is a co-defendant, but that

Exception D refers to a party or an agent.

THE COURT: I understand. I'm looking at

the -- I'm looking at Mr. Stanford being the primary person

here.

MR. STELLMACH: He is the primary person, Your

Honor.

THE COURT: No, no. You just need to tell me

was some action taken based upon what this woman said?

MR. STELLMACH: Based upon what she said as

well as Mr. Schoblum, the lawyer, who had been hired for

the bank.

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3274

THE COURT: All right. I think -- overrule the

objection for that limited purpose. I understand that I've

given it the best I can, and I think it's within the Rule

that way --

MR. SCARDINO: Your Honor --

THE COURT: -- because some action was taken

based upon what she said.

MR. SCARDINO: So it's offered not for the

truth of the matter, then?

THE COURT: That's correct.

MR. STELLMACH: Merely for this is what she

proposed?

THE COURT: All right. Ladies and gentlemen of

the jury, you're so instructed. In other words, not

getting into whether it's true or accurate as to what she

said, but because of what she said, some action was either

taken or not taken. I gather some action was taken. So

just to show a statement was made and, therefore, an action

took place, I'm allowing it in for that limited purpose.

Go right ahead.

BY:

BY MR. STELLMACH:

Q. During the meeting, what did Ms. Stinson propose

should be done in light of the information that had been

shared about Tier 3?

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3275

A. She proposed that the financial statements would have

to be restated backwards, the years impacted by the amount

of time that this type of reporting in Tier 3 had taken

place.

THE COURT: You mean -- I didn't understand

by -- retrofitted, in effect?


THE COURT: What does that -- I'm sorry.

That's not the word he used. Have to be --

MR. STELLMACH: Restated.

THE COURT: Restated. What does that mean?

BY MR. STELLMACH:

Q. Could you explain why the information that you had

shared about Tier 3 meant that any action had to be taken

with the financial statements of the bank going back

before this meeting?

A. Yes, sir. This is a basic accounting fraud

reporting --


THE COURT: Sustained. We'll get -- if you

want him to characterize it as an accountant himself later

on, fine. Let's get to the facts and then --

MR. STELLMACH: If I could, I'll just --

THE COURT: The problem is that one word -- by

the way, fraud, if any, it's going to be up to you. And

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3276

I'm looking at the jury, in other words. So the ultimate

issue is relative to what is or what is not fraud.

Eventually I'll provide you that -- what is it -- the

appropriate instruction before you commence your

deliberations.

Go on.

BY MR. STELLMACH:

Q. The financial statements that have been issued by the

bank up until this moment, had you explained during that

meeting whether those statements were accurate or not?

A. Yes, I did. I said that they were not accurate.

Q. And what did Ms. Stinson propose to do regarding

these prior financial statements that had been issued

which contained inaccurate information?

A. Restate them accurately.

Q. And when you say restate them, what does that mean?

What needed to be done with the earlier financial

statements for the bank?

A. The earlier financial statements of the bank, the

numbers in the balance sheet and profit and loss statement

and the footnotes would have to be changed to reflect the

truth.

Q. And once they were changed, who then had to be told

that the financial statements had been replaced with new

accurate financial statements?

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3277

A. Well, the regulators, for one; the investors, most

importantly.

Q. By "investors," you mean the depositors in the CD

program?

A. I mean the depositors in the CD program, yes, sir.

Q. So going back and saying, "These financial statements

were inaccurate. Here are new, accurate financial

statements" --

A. Yes, sir.

Q. -- that's a restatement process?

A. Yes, sir.

Q. Were there -- was there any discussion about

continuing to sell the CDs until that information had been

corrected?


Q. And what was said regarding that?

MR. SCARDINO: Object.

THE COURT: First we need to know who.

BY MR. STELLMACH:

Q. Did Ms. Stinson address this, or did somebody else

raise this point?

A. This was Ms. Stinson.

Q. And what did Ms. Stinson say needed to be done

regarding continued sales of the CDs until there were new

financial statements?

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3278

A. Certificates of deposit could not be sold

domestically any longer.

THE COURT: "Domestically" meaning in the

United States.

THE WITNESS: Yes, sir, Your Honor.

BY MR. STELLMACH:

Q. And regarding Mr. Sjoblom, did he make any

suggestions regarding next steps that needed to be taken?

A. I believe -- yes, sir.

Q. And what did Mr. Sjoblom, the lawyer hired for the

bank, propose?

MR. SCARDINO: I would remind I have a running

objection.


THE WITNESS: Mr. Sjoblom actually concurred

with Ms. Stinson on the five points which were shared with

us by Ms. Stinson.

THE COURT: Now, it's your position that all

the folks present except, I think, probably, if I'm

correct, you and Mr. Stanford were the only ones that knew

that -- well, in your position, based upon your testimony,

there was no real backing relative to the values up there.

Is that correct? That the items were included, but not the

values you have up there; correct?

THE WITNESS: Yes, sir. It was lacking --

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3279


THE WITNESS: -- value.

THE COURT: All right. So the people up there

making these suggestions didn't know, according to your

testimony, that these things weren't worth what they said

they were being worth; right?

THE WITNESS: Yes, sir, Your Honor, that's

probability. Yes, sir.

THE COURT: Okay.

BY MR. STELLMACH:

Q. And, so, once -- and I'm sorry?

What did Mr. Sjoblom propose needed to be

done?

A. Mr. Sjoblom thought that a forensic audit should take

place to get to the bottom of the misstatements of the

Stanford Financial -- excuse me -- the Stanford

International Bank, Limited financial statements.

THE COURT: All right. In your business, what

is the understanding that a forensic accountant or forensic

accounting different than a regular accounting?

THE WITNESS: It's my understanding, Your

Honor, that it would be the regular auditors steps but more

specific to uncovering or detecting fraud that might be

taking place.

BY MR. STELLMACH:

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3280

Q. And, so, Ms. Stinson had made a number of proposals.

Mr. Sjoblom proposed an internal -- an internal audit, a

forensic audit?

What did Mr. Stanford say in reaction to

these proposals?

A. That he was not supportive of the points made. He

didn't want to do those points.

Q. But ultimately, what happened regarding continued CD

sales?

A. Continued CD sales ceased domestically. Those that

did come in after the fact were returned.

Q. But were the CDs still sold internationally to

people --

A. Yes.

Q. -- outside the United States?

A. Yes, sir.

Q. And regarding the suggestion or the proposal by

Mr. Sjoblom that there be a forensic audit, did that

actually take place?

A. No, sir, it did not.

THE COURT: What was the percentage mix of the

CDs from the United States or -- and outside the country?

Do you have just a handle generally on that, what the

percentages were?

THE WITNESS: Your Honor, I believe it would

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3281

have been in the neighborhood of 20 percent, 20 to

25 percent.

THE COURT: What?

THE WITNESS: Of U.S. CD holders to the whole.

THE COURT: Okay. So 75 percent were outside

of the United States approximately?


THE COURT: Okay.

THE WITNESS: Approximately.

BY MR. STELLMACH:

Q. Was there any decision made about going forward with

testimony before the SEC?

A. Yes, sir.

Q. I think you testified previously that Mr. Rodriguez

and Ms. Holt had been identified as the people who would

testify. Is that accurate?

A. Yes, sir, that was accurate. That was the plan.

Q. During this meeting on Friday, was there any decision

about who would still go in and testify before the SEC?

A. Yes, sir.

Q. And what was the -- who made the decision that who

should go forward and testify?

A. That Mr. Tom Sjoblom and Mr. Mauricio Alvarado,

general counsel and outside counsel's recommendation, it

was decided that --

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3282


THE WITNESS: -- Ms. Laura Holt would go.

THE COURT: Excuse me. Overruled. Go on.

THE WITNESS: It was decided at that meeting

that Ms. Laura Holt would go. Mr. Juan Rodriguez said he

was not going.

BY MR. STELLMACH:

Q. Did Mr. Rodriguez say why he wouldn't attend?

A. He could not speak to the SEC after learning what was

actually in Tier 3.

Q. When did Ms. Holt eventually testify before the SEC?

This was I think you said Friday of the first week in

February?

A. Yes, sir.

Q. This meeting is taking place in Miami.

When was Ms. Holt scheduled to testify

before the SEC in Fort Worth?

A. On Tuesday, the 10th, I believe was the date.

Q. Did she eventually testify?

A. She did, yes.

Q. Did you speak with her before she testified?

A. Yes, sir, I did.

Q. Did you call her, or did she call you?

A. I called her the night before.

Q. Why did you call her?

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3283

A. Well, I wanted to see if she got there safely, see

how she was doing. On the one hand, I didn't want her to

go in there and perjure herself. And on the other hand, I

didn't want her to go in and describe Tier 3 as she had

seen it the previous Thursday.

Q. Why not? Why not have the SEC given the same

information that you just gave the executives at the bank?

A. Because this was an accounting fraud, and what had

been reported was not actually what was there. It was

just the opposite and was a lie. It was our lie. It's

lies.

Q. And, so, what did you tell Ms. Holt, if anything, to

say during her testimony the next day?

A. I told her, "Just to tell them what you knew about

Tier 1 and Tier 2."

Q. Basically telling her not to talk about Tier 3?

A. Yes, sir.

Q. Did she mention Mr. Stanford at all in her

conversation with you?

A. She did.

Q. What did she say about him?

A. She said that she wanted to talk with him and that he

had promised to meet her Friday evening. Yet he never

showed up. And she had been trying to get in touch with

him and speak with him prior to her going in to testimony,

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3284

but he never returned her call.

Q. Do you know whether Ms. Holt ultimately did testify

before the SEC?

A. Yes, sir, she did.


A. She told me.

Q. Did you discuss what she had told the SEC?

A. I believe she gave me a recap to the effect that she

told them what was in 1 and 2 and talked about the

Stanford investment model.

Q. What about -- what did she tell you, if anything, she

had said about Tier 3?

A. That she would have to ask -- excuse me. Ms. Laura

Holt told me that she shared with SEC that they would have

to speak with Mr. Stanford and myself about Tier 3.

Q. Where were you while Ms. Holt is in Fort Worth or

preparing to go to Fort Worth to testify? You were in

Miami on Friday.

A. Yes, sir.

Q. Going into the weekend, where did you go?

A. I flew to Nashville and met my wife. And we drove --

she was there at a needle art show, and we drove from

there in our car to our home in Northeast Mississippi.

Q. Were you speaking with Mr. Stanford while you were in

Mississippi over the weekend?

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3285

A. Yes. We had conversations and texts, passing texts.

Q. What were you discussing with Mr. Stanford?

A. We were discussing, for one, finding funds to honor

the withdrawal request of clients and discussing my coming

back to Miami that particular week.

Q. While you were home over the weekend in Mississippi,

did you do anything regarding evidence or computers in

your home?

A. Yes, sir, I did. I tossed the computers and flash

drive, these thumb drives, media, into a lake in front of

my house.

Q. What information was on the computers that you

destroyed?

THE COURT: I'm sorry. Did you throw the

computers in or just the thumb drives.

THE WITNESS: Both.

THE COURT: Both. Okay.

THE WITNESS: Both, yes, sir.

It contained this information that's on

the large computer. It contained this information we're

discussing right now.

BY MR. STELLMACH:

Q. This spreadsheet, Government's Exhibit 332?

A. Yes, sir. Contained personal drafts of letters, et

cetera, basically the information that was on the Oracle

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3286

system that tied our companies together.

Q. And just to jump ahead, how soon after you decided to

cooperate with the government did you disclose this

information about the fact you threw some computers and

some thumb drives into that lake to destroy them?

MR. SCARDINO: Object to relevance.

THE COURT: What's the relevance, Counsel?

MR. STELLMACH: His credibility. He was

attacked in opening by Mr. Scardino.

MR. SCARDINO: His credibility?

MR. STELLMACH: Yes. They put it at issue.

He's entitled to address it.

THE COURT: What does that have to do with

putting a thumb drives and the computers in a body of

water?

MR. STELLMACH: How shortly he started

cooperating with the government. He came forward and

admitted that.

MR. SCARDINO: Now, the jury knows it already,

so I'll withdraw it.

THE COURT: Thank you. I'll allow it. Thank

you.

BY MR. STELLMACH:

Q. How --

A. Our first meeting I had, sir, first meeting with the

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3287

authorities.

Q. That was over the weekend.

Did you continue going into the office the

following Monday?

A. No, sir, I did not.

THE COURT: Let me ask you that: Were those

computers ever retrieved?

THE WITNESS: Yes, sir, I believe they were.

THE COURT: Go on.

BY MR. STELLMACH:

Q. You didn't go back in the office?

Were you still speaking with Mr. Stanford

going into that second week of February?

A. Yes, sir.

Q. What were up discussing with him?

A. Finding money to honor the withdrawal requests of

clients. We're talking about CD production

internationally. We're talking about my coming back to

Miami, and -- which will I did on Wednesday of that week.

THE COURT: Coming back from where, please?

THE WITNESS: My home in Northeast Mississippi,

yes, sir.

BY MR. STELLMACH:

Q. When you arrived in Miami, where did you go?

A. To the Hotel Intercontinental adjacent to our

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3288

offices.

Q. Did you meet with Mr. Stanford?

A. Yes, sir.

Q. And what did you discuss with him?

A. We discussed a number of subjects, some of which I

just shared with you. And we discussed flying to

Washington on Friday and meeting with some attorneys.

Q. Did that happen? Did you eventually go to

Washington?

A. Yes, sir, we did.

Q. And you say "we," who went?

A. Mr. Stanford and myself.

Q. What was the purpose of the meeting?

A. To meet with a consultant there in Washington who was

able to refer Mr. Stanford to an attorney, as well as

myself.

Q. When was the last time you saw Mr. Stanford?

A. Wednesday, I believe, of the following week, the 18th

of February.

Q. And, again, at any point when you were speaking with

Mr. Stanford, did he ever tell you that his understanding

was that because the bank was selling CDs that somehow

meant that the information in the marketing materials or

the bank's financial statements did not have to be

accurate?

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3289

A. Would you repeat the question, please.

Q. Sure. At any point when you're speaking with

Mr. Stanford after Miami, or before Miami for that matter,

did he ever tell you that he believed, because the bank

was selling CDs, the information they provided to

depositors about its assets and its financial performance

did not have to be accurate?

A. No, sir.

Q. And, in fact, Government's Exhibit 112, the 1999

annual report for the bank --

MR. STELLMACH: If we could just turn to that

one disclosure.

BY:

BY MR. STELLMACH:

Q. I think you testified about this earlier. This is

the disclosure that Mr. Stanford had fully repaid a loan

for $13 1/2 million to the bank?

A. Yes, sir.

Q. Do you recall when this disclosure was made

discussing it with Mr. Stanford?

A. Yes, sir.

Q. And what did Mr. Stanford tell you about why this

disclosure had to be made?

A. Said that it had been determined by then chief

counsel Yolanda Suarez that there were monies being spent

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3290

outside depositor money.

Q. I'm sorry. My question, Mr. Davis, is not why the

disclosure was made in the first place in 1996.

A. Yes, sir.

Q. My question was what Mr. Stanford told you about why

the disclosure had to be made that the note had been fully

repaid, a disclosure that you testified previously was

false?

A. Because it didn't look good to have a footnote

showing the owner of the bank with loans in terms of being

able to sell CDs to the public.

Q. How much were you getting paid --

MR. STELLMACH: We can take it down.

BY MR. STELLMACH:

Q. How much were you getting paid at Stanford Financial

Group when you first started?

A. $65,000 a year plus bonus.

Q. And over time did your salary increase?

A. Yes, it did.

Q. What did it ultimately reach by the time the bank

folded?

A. Base pay of $900,000 a year and equal bonus.

Q. What about loans from the bank? Did you take any

loans?

A. Yes, sir, I did.

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3291

Q. When did you take loans from the bank?

A. December of '08 and January of '09.

Q. Did you speak -- did you obtain Mr. Stanford's

permission to take that money from the bank?

A. Yes.

MR. STELLMACH: I want for show the witness

Government's Exhibit 1511A. I think this might be better.

Well, it's not that much better.

BY:

BY MR. STELLMACH:

Q. Let me give you a hard copy, Mr. Davis. It's

difficult to read.

A. Yes, sir.

Q. What is this?

A. It's a request I made of Mr. Stanford to draw money

in December.

MR. STELLMACH: Let me actually, if I can --

THE REPORTER: Possibly November.

MR. STELLMACH: Could I try the overhead, Your

Honor?

THE COURT: Sure. What is that?

MR. STELLMACH: Well, it's a picture of a cell

phone of a text.

MR. SCARDINO: I guess I would like for him to

prove it up.

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3292

THE COURT: Okay. Prove it up first, please.

MR. STELLMACH: Certainly.

Can we take it down?

MR. SCARDINO: I don't care if you leave it up.

It's too late for that, but I would -- for the record, I'd

like for him to prove it up.

THE COURT: All right. It's back up.

MR. STELLMACH: It's back up.

BY MR. STELLMACH:

Q. Mr. Davis, do you recognize this?

A. I do, yes, sir.

Q. How do you recognize it?

A. I wrote it.

Q. And what is this actually a picture of?

A. My iPhone.

Q. And when did you write this?

A. November, maybe the last of November 2008.

Q. And who did you send it to?

A. Mr. Allen Stanford.

Q. And could you, to the extent you can, read it for us?

Can you just read it for us?

A. "I would like to draw $800,000, not through payroll

but as a conventional loan into a company, tax otherwise

eats it up, in lieu of next bonuses or whatever for notes

payments and service on Baldwyn businesses and real estate

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3293

affairs. Also working capital for first six months of

'09. Can go through venture capital, maybe split in two

tranches, half now, half January."

Q. After you sent that text to Mr. Stanford, or that

e-mail to Mr. Stanford, did you receive a response?

A. Yes, sir, I did.

Q. By phone or did Mr. Stanford text you back?

A. Text me back directly.

Q. Did you save the text?

A. I did.

Q. Do you have it -- still have it?

A. Yes, sir, I do. I think so. Yes, sir.

Q. And did Mr. Stanford approve the loan?

A. Yes, sir.

Q. And after Mr. Stanford approved it, did you

subsequently withdraw money from the bank?

A. Yes, sir, I did.

Q. And was it in the amount of around 880,000? Could

that be a --

A. Yes, sir.

Q. What ultimately happened to that money?

A. It was put in -- as stated in the iPhone text, put

into the businesses in a town close to where I live,

Baldwyn, Mississippi, in a renovation project.

Q. Did those businesses -- did anything happen to those

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3294

businesses once this the company closed down?

A. Yes, sir.

Q. What happened?

A. They were seized by the receiver in this case.

Q. So were you able to keep any of the businesses that

you had opened?

A. No, sir.

Q. And regarding your home -- the home you lived in, in

Mississippi, what happened to that?

A. It was seized.

Q. What about your bank accounts?

A. They were all seized.

Q. Where do you live right now?

A. In Michigan.

Q. How do you support yourself?

A. I just completed two years working for a fruit farm,

and am now on Social Security and have a small pension.

Q. Have you ever calculated how much money you earned

during your time working for Mr. Stanford?

A. Yes, sir. Approximately $14 million over 21 years.

Q. Did Mr. Stanford also make any donations to churches

or charities that you asked him to make?

A. Yes, sir, he did.

Q. Could you tell us about that?

A. Made a donation of $500,000 to my church.

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3295

Q. Aside from the money you've talked about, the

bonuses, the salary, the donation to your church, the

loans you took out, did you receive any other money or

gifts from Mr. Stanford?

A. No, sir.

Q. Did you skim any money out of the accounts that you

controlled?

A. No, sir.

Q. Why not?

A. I always went through Mr. Stanford.

Q. So according to your testimony, over $2 billion in CD

money was misappropriated as a result of this scheme that

you pled guilty to. Is that right?

A. Yes. Yes, sir.

Q. Where did it go?

A. The billion of dollars?

Q. Yes, sir.

A. Mr. Stanford and some went to myself, 14 million.

MR. STELLMACH: Pass the witness, Your Honor.

THE COURT: Why don't we take a stretch in

place, shall we? I'll stop the clock.

(Brief recess)

THE COURT: All right. Be seated. Defense,

you're up.

MR. SCARDINO: Proceed, Your Honor?

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03:09:07

Cross-Davis/By Mr. Scardino


3296


CROSS-EXAMINATION

BY MR. SCARDINO:

Q. Mr. Davis, my name is Robert Scardino.

We haven't met before, have we?

A. No, sir.

Q. In fact, I've tried to talk to you over the last

year, haven't I?


Q. Your lawyer didn't tell you that I tried many times

to interview you?

A. No, sir.

Q. Never communicated that to you?

A. Well, yes, indeed, he did.

MR. STELLMACH: Objection to the privilege,

Your Honor. I think we're getting into privileged

communication.

MR. SCARDINO: Just asked him if he relayed the

message.

THE COURT: I overrule that. Overruled. I'm

sure, you know, Mr. Scardino, where the line is. I don't

think we're over it yet, so overrule the objection to that

question.

BY MR. SCARDINO:

Q. Well, you spent hours and weeks interviewing with the

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3297

government's investigators, didn't you?

A. I spent some hours, yes.

Q. You know, I get copies of all those reports.

Have you had a chance to review those

reports?

A. No, sir.

Q. But you weren't willing to talk to me or my

investigators?

A. I listened to my attorney.

Q. He told you not to talk to us?

A. He did not say talk to you.

Q. Well, can you tell the jury what it was you didn't

want me to know?

MR. STELLMACH: Objection, Your Honor.

THE COURT: All right. Approach the bench

here.

(The following was held at the bench)

THE COURT: Are we're on now? We're on now.

Okay.

At this point -- at this point -- and of

course, the client can raise it or his lawyer can, it's

Mr. Fiend. I think he's there in the back.

MR. STELLMACH: I don't know if he is here,

Your Honor.

THE COURT: Maybe it wasn't him. I thought I

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3298

saw somebody --

MR. STELLMACH: He's not here today.


MR. STELLMACH: You're right. It's the

witness's privilege to assert.

THE COURT: Exactly right.

MR. STELLMACH: But I don't know if the witness

understands that.

MR. FAZEL: Judge, you can always tell the

witness he's got the right.

THE COURT: If that's what they want.

MR. STELLMACH: I don't think we need to get

into a discussion of privilege.

THE COURT: I'll let the jury go in about a

minute or two, but I think to protect the position here,

the lawyer is not here, and none of us, in effect, can

represent him. I can look out for his rights up to a

point, but I think I agree that it's a matter of just

making -- asking him.

MR. SCARDINO: Your Honor, I'm not asking him

what he told his lawyer. I'm just asking him what it was

that he wasn't willing to talk to me about, not his lawyer.

MR. STELLMACH: And, Your Honor, I think the

witness said he didn't know Mr. Scardino wanted to speak

with him. So to ask him why he didn't want to speak with

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3299

Mr. Scardino, there's no basis for that question.

MR. SCARDINO: Well, he changed his mind and

said, "Oh, yeah he told me."

THE COURT: Okay. So where do you want to go.

What's the next question?

MR. SCARDINO: I just trying to get into --

obviously, what I'm trying to do is that he was told not to

talk to me and he didn't. It's as simple as that.

MR. STELLMACH: He didn't know that he was told

not to talk to him. His testimony was that his lawyer

didn't tell him that Mr. Scardino wanted to speak to him.

THE COURT: I understand that. I've got to

give him some leeway.

MR. STELLMACH: I understand.

THE COURT: But we've got to watch out for the

attorney-client privilege. See if -- we all know what that

is. See if you can skirt around it with the questions;

okay? But none of us can raise it. If it gets to the

point that I feel he ought to be instructed, then we'll get

the jury out and I'll instruct him. Right now, I think

it's -- you know, it's --

MR. SCARDINO: If you're more comfortable doing

that, I don't have a problem with it.

MR. STELLMACH: We can wait.

THE COURT: Let's wait. Let's see where it

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3300

goes.

I'll tell you what: He's pled guilty, but

he still has a lawyer-client privilege. I understand,

though. I think we all do. See if you can work around it;

okay? And if you can't, then I'll make had a decision and

probably get the jury out, talk to him about it and see if

he wants to talk to his lawyer. Or I can ask him, you

know, if they've talked about it, does he understand, it

may concern the -- an absolute right. If I have to give

him the warning, I will. And I'll do the best I can off

the top of my head, because you don't get it very often.

Usually someone's up making noise.

MR. SCARDINO: And he waived the privilege by

taking the witness stand. He certainly waived his

privilege against self-incrimination.

THE COURT: I don't think you waive

attorney-client privilege. I think you waived -- of

course, you know, attorney-client privilege isn't in the

Constitution, as far as I know. But it's well founded in

our law.

Skirt around it if you can; okay? If not,

someone get up or just give me a nod and I'll ask the jury

to go out and we can talk about it.

(The following was held in the presence of the jury)

THE COURT: All right, sir. Go right ahead.

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3301

BY MR. SCARDINO:

Q. How long have you had a lawyer?

A. Yes.

Q. How long have you had a lawyer regarding what you've

testified in front of this jury?

A. I've had an attorney since March of '09.

Q. And is he in the courtroom?

A. I don't see him.

Q. Is it the same lawyer you had when you negotiated the

deal you made with the government prosecutors?

A. Yes.

Q. And you hired him with your private funds?

A. Yes, I did.

Q. Tell the jury you forfeited everything. Did you keep

some money aside to hire lawyer?

A. No, I did not.

Q. So you hired him -- did you hire him with some of the

$900,000 you stole at the end of 2008? You used that

money to hire him?

A. I didn't steal that money, and I didn't use that

money. I used my mother-in-law's money.

Q. I see. So you borrowed money from your mother-in-law

to hire the lawyer?

A. Yes.

Q. Did you tell the government prosecutors that?

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3302

A. I don't recall telling them.

Q. It's nowhere in any of your reports, is it?

A. Well, that's my personal lawyer.

Q. Have you talked about this case with anybody other

than your lawyer? Don't tell me what you said or what was

discussed. But did you discuss the case and all the

things that you've told this jury about the last day and a

half with anybody other than your lawyer and these

government prosecutors?

A. No. A few things maybe with my wife.

Q. Your wife.

And how about the lady that loaned you the

money to hire the lawyer, did you talk to her about it?

A. No.

Q. How about your sons, you talk to them about it?

A. Nothing other than what's in the newspapers.

Q. In the newspapers about you talking to your sons?

A. About the case, the downfall of Stanford.

Q. So you've discussed what has been in the newspapers

with your sons?

A. Had brief summary-type dialogue, yeah, a couple of

times. They don't live near me. Sometimes phone, uh-huh.

Q. So let me -- so I can try to clear this up,

Mr. Davis, were you informed that I wanted to interview

you or not?

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3303

A. No, I was informed that you subpoenaed my attorney.

I found that out on --

MR. SCARDINO: That's nonresponsive.


BY MR. SCARDINO:

Q. I'm asking you if you were informed that since last

October, I've been trying to talk to you and interview you

just like the government has, did you know that?

A. No, sir.

Q. Your lawyer and -- withdrawn.

Nobody shared that information with you?

A. No, sir.

Q. Okay. Has the government prosecutors been talking to

you between the times you've been on the witness stand and

when you've been off the witness stand yesterday and

today?

A. No, sir.

Q. How much time did they spend with you to prepare you

for your testimony here today?

A. We've had 13, 14 visits over three years.

Q. How about right before trial. How much time was

spent with you explaining the Rules of Evidence and

procedure to you?

A. We met maybe three hours last week.

Q. That's it?

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3304

A. (Answered affirmatively.)

Q. Went over all this information in three hours?

A. What information?

Q. All the information you've been talking to this jury

about, all the financial reports, all the data you say is

phony and cooked up. You got -- took three hours to get

ready for that?

A. No. We -- you just asked me a question, sir, about

the last three years and how much time I've spent with the

prosecutors. I said we've had 12, 13 visits.

Q. Mr. Davis, you spent a lot of time with FBI agents

and IRS criminal investigators telling them your version

of what's happened. You've done that?

A. Sir, I've told them where money might be located --

MR. SCARDINO: It's nonresponsive.

THE COURT: Hold it.

MR. SCARDINO: That's nonresponsive.

THE COURT: All right. Mr. Davis, it will be a

lot easier on everyone if you answer yes or no --

THE WITNESS: Okay.

THE COURT: -- to the question. If it's a yes

or no question and you cannot answer it yes or no, let me

know and I'll ask the attorney to rephrase it. If he asks

for a narrative, or tell us the story about A, B and C,

then you're free to do so. Go a lot quicker, yes or no or

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3305

I can't answer it yes or no.


THE COURT: Okay. Go on.

BY MR. SCARDINO:

Q. You've reviewed a lot of documents in front of this

jury, and you've drawn a lot of charts on that little

easel up there. Are you telling this jury that you only

took three hours to prepare for that with Mr. Stellmach,

Mr. Costa, Mr. Warren?

MR. STELLMACH: Last week. I think the -- just

to clarify, I think the original question was last week

before he testified.

BY MR. SCARDINO:

Q. Well, let me rephrase it, then.

How long did you spend preparing your

testimony with these prosecutors?

A. I spent a number of hours over a long period of time

answering questions.

Q. Preparing to tell this jury your version of what's

happened in the years you worked at Stanford; right?

A. No, sir.

Q. Preparing to talk about your church?

A. I spent visits over three years with the government

answering questions. We had a 21-year Stanford

experience.

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3306

MR. SCARDINO: Nonresponsive. Objection.

THE COURT: Sustained. Next question.

BY MR. SCARDINO:

Q. So you've had three years to get your story together

with what you wanted to tell this jury; right?

A. I had three years answering questions with the

prosecutors.

Q. Right. You've had three years to get together the

information that you decided that you wanted to share with

this prosecutor after you made your deal with the

government, right, three years?

A. No, sir.

Q. Did you tell the government when they first started

talking to you, the United States attorneys, did you tell

them, "Hey, I'm a liar." Did you tell them that?

A. Yes, sir, I said I was a liar.

Q. Did you tell them, "I'm a crook." Did you tell them

that?

A. Told them I was a liar and a fraudster.

Q. A fraudster.

Did you tell them that you're a coward?

A. Yes, sir.

Q. And, so, after you tell them all that, they make this

deal with you, right, hoping -- you're hoping you're going

to get some time off for cooperating with them?

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3307

THE WITNESS: Not a yes or no, Your Honor.

THE COURT: Okay.

BY MR. SCARDINO:

Q. Let me break it down. We'll do it one at a time.

When you first started talking to the FBI,

that was in March of '09?

A. Yes, sir.

Q. And you sat down with the FBI and your lawyer,

Mr. Flynn, didn't you?

A. Yes, sir.

Q. And you told them -- you answered their questions

about whatever they asked you back then; isn't that

correct?

A. I answered questions, yes, sir.

Q. And is it your testimony, Mr. Davis, that in that

very first meeting with the FBI and the government

lawyers, you told them, "Hey before we get started, you

need to know that I'm a liar"? Did you tell them that?

A. Not a yes or no, sir.

Q. Well, I'll respect that it calls for a yes or no.

Did you tell them you're a liar, yes or no, or you don't

recall?

A. I did say I was a liar.

Q. Okay. Did you tell them that you had been a liar and

you had been lying about what you'd been doing with the

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3308

Stanford companies for over 16 years? Did you tell them

that?

A. Yes, sir, I did, but most of the time --


BY MR. SCARDINO:

Q. Did you tell them when -- the thrust -- the first

time you met with them, when you were making your deal

with them, did you say, "I'm a liar, and I'm a fraudster."

Did you tell them that?

A. Could you ask me one question at a time without

putting two or three --


THE WITNESS: -- to it --

MR. STELLMACH: I think it was a --

MR. SCARDINO: The government lawyers can --

THE COURT: Excuse me.

MR. STELLMACH: It was a compound question.

MR. SCARDINO: I got no objection. I would

object to the witness objecting to my -- witness as opposed

to the government lawyers objecting to my questions.

THE COURT: Overruled both of you.

Go on. You know what he's asking. A

fraudster and a liar.

MR. SCARDINO: Fraudster and a liar.

THE COURT: Break it down.

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3309

BY MR. SCARDINO:

Q. You told them you were a liar?

THE COURT: Is that correct, sir?

THE WITNESS: That's correct, yes.

BY MR. SCARDINO:

Q. Did you tell them you were a fraudster?

A. I did.

Q. And did you tell them you were a crook?

A. Probably.

Q. You don't remember your testimony of yesterday where

you said, "I'm a crook"?

A. I was, so it doesn't matter.

THE COURT: Are you referring to what he said

to them in his conferences with the government or the

attorneys or the FBI?

MR. SCARDINO: I'm referring to what he told

this jury in his first thrust on the witness stand where he

said, "I'm a liar, and I'm a crook."

BY MR. SCARDINO:

Q. And a fraudster. They knew that when they sat down

with you to get information from you; right?

A. Yes, sir, I've already pleaded guilty.

Q. I understand that. We'll get to that in a minute.

But these investigators and lawyers for

the government knew who and what you are before they made

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3310

their deal with you, didn't they?

A. I don't know, sir.

Q. Well, you told them you're a fraudster; right?

A. Told them I lied, yes.

Q. Well, lied and fraud, that kind of comes together,

doesn't it? Hard to commit to fraud unless you lie;

right?

A. Yes, sir.

Q. Okay. But knowing all of that, you still were able

to negotiate some kind of deal with the government lawyers

to testify before this jury, weren't you?

A. A plea bargain, yes, sir, a plea bargain was arrived

at some weeks, maybe a couple months later.

Q. Mr. Davis, can you tell this jury what it was you

told these prosecutors to convince them you weren't a

fraudster in telling them your story, your version of the

story? What was it, what event happened or what did you

tell them?

A. I don't understand your question.

Q. I don't either. It was complicated.

Was there an event during your relationship

with the government investigators and lawyers, like an

epiphany? You're familiar with that, right, an epiphany?

A. I know what that is, yes.

Q. A period of time in that relationship where they

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3311

decided you weren't being a fraudster with them, the

prosecutors?

MR. STELLMACH: Objection, Your Honor --

THE WITNESS: I can't think for the

prosecutors.

THE COURT: Hold it, hold it. If you see the

lawyer get up, no answer.

Yes, sir.

MR. STELLMACH: Objection, calling for the

witness to speculate about what was in the mind of the

government or the prosecutor he's dealing with.

THE COURT: Sustained as to the form.

BY MR. SCARDINO:

Q. Was there an event that you can point to, Mr. Davis,

something that you did or said where they say, "We believe

you, Mr. Davis, even though you say you're a fraudster and

a liar"?

A. No, sir.

Q. So it was never revealed to you that in spite of who

you are and what you told them, that they ever questioned

the information you were giving them?

A. My agreement was to tell the truth, nothing but the

truth, truth, truth, truth. That's what I'm doing.

Q. Something you've done for the last 16 years; right?

A. Unfortunately not, but I've told the truth since I've

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3312

been with the government in March of '09.

Q. I think you drew the line sometime before that,

though. You testified you have a -- you got some

saturation point in your life where you decided to quit

lying; right?

A. I'm telling the truth.

Q. Okay. Can you tell the jury how we can tell when

you're telling the truth? How do we know when you're

telling the truth, Mr. Davis? Are we supposed to take

your word for it?

A. I don't understand the question.

Q. Well, you said you're telling the truth now, but you

lied for 16 years. How do we know when to draw our line?

A. I believe that's up to the jury to decide, sir.

Q. I think you're exactly right. But is there something

you can point to, some tell that you might have where we

know when you're telling us the truth all of a sudden, as

opposed to not telling the truth for the last 16 years?

A. I'm telling the truth.

Q. Were you telling the truth when you told this jury --

the last thing you told them is that I didn't get any

money out of Stanford other than what I told you about,

this -- you said a 500,000-dollar donation to your church,

and then you pointed to some -- Government's

Exhibit 1511-A, which is some cellphone thing or other;

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3313

right? Do you remember that?

A. Check for the church, yes, sir, I do remember.

Q. How about the cellphone, the last thing --

MR. SCARDINO: Can we get Government's 1511 up,

please.

BY MR. SCARDINO:

Q. Do you see what I'm talking about, Mr. Davis?

A. See it very clearly.

Q. And, so, your testimony in front of this jury -- and

you're saying you're being truthful now; right?

A. That's correct.

Q. Okay. And you say this is all the money you got out

of Stanford other than the $500,000 that he donated to

your church, I guess, at your request?

A. No, sir, that's not what I said.

Q. You did not tell the jury, "I didn't get any other

money"?

A. Other than salaries, bonuses and this.

Q. Right. Okay. Other than the salaries and --

A. Bonuses --

Q. -- bonuses?

A. -- and this loan.

Q. And this is a loan?

A. It was intended to be, yes. It was approved to be by

Mr. Stanford.

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3314

Q. So when did this happen?

A. December -- November with this communication. The

money was withdrawn in December.

Q. And when did you tell the government about this?

A. When they asked me.

Q. Let's try a date, Mr. Davis. Was it yesterday?

Today? When did you tell them about it?

A. I believe last year.

Q. Last year. Okay.

Did you volunteer the information or did

they confront you with it?

A. I don't understand the question.

Q. Did you tell them, "Hey, look I've got this cellphone

I've taken a picture of, and it shows that I got almost a

million dollars at the end of 2008 and the beginning of

2009"?

A. They asked me was there any other monies that I

received other than salaries and bonuses, and I said yes.

Q. And you showed them this?

A. I told them about it.

Q. Let's look at this for a minute. This is a

picture -- I think you testified a picture of a cellphone;

is that correct?

A. It is.

Q. And who took the picture?

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3315

A. I did.

Q. And you're telling the jury that this is money that

Mr. Stanford let you have and you wanted it characterized

as a loan?

A. Yes, sir.

Q. Did you draw up a loan agreement?

A. There was a loan agreement drawn up, but it was not

conveyed to the bank as yet, but, yes, there was one

drawn.

Q. Do you have the document?

A. No.

Q. Where is it?

A. It's been seized.

Q. So the government's got it?

A. Receiver.

Q. Receiver's got it?

A. I presume.

Q. Are they keeping that a secret?

MR. STELLMACH: Objection, Your Honor. He

doesn't know what the receiver --

MR. SCARDINO: Well, if he does. I mean, he

knows the receiver's got it. How did they get it?

THE WITNESS: All my things were seized.

BY MR. SCARDINO:

Q. So a year ago you tell the government that this

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3316

cellphone picture of you getting a million dollars

skimming or getting a loan when the company is in -- is

heading south and the economy is in bad shape; right?

A. (Answered affirmatively.) It's very similar to the

million dollars a day Mr. Stanford was taking.

MR. SCARDINO: Nonresponsive, Your Honor.


MR. SCARDINO: Ask the Court to instruct the

jury to disregard.

THE COURT: Jury is so instructed.

BY MR. SCARDINO:

Q. Mr. Davis, you tell -- you tell the government about

this a year ago; right?

A. Yes, sir.

Q. And you tell the government that loan documents were

drawn up that would tend to verify that this was a

legitimate transaction and not you just stealing money at

the end of 2008; right?

A. Yes.

Q. Okay. And did you tell the government that a loan

document had been prepared that would verify and put

validity to your story of how you got this money?

A. I did tell them that, yes.

Q. Did you tell them that the loan document was in the

hands of the receiver that had come in and taken your

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3317

information and your document?

A. I didn't know where the document was, but I presume

it was with the receiver.

Q. Have they confronted you with or shown you that, oh,

yes, we were able to contact the receiver and here's the

loan document, Mr. Davis? Has that happened?

A. No, sir.

Q. So you took a picture of a cellphone. Whose

cellphone -- who owns the cellphone that this was on? Is

it yours or somebody else's?

A. It was my cellphone.

Q. Your cellphone. Okay.

And who took the picture of this to

preserve it?

A. I did.

Q. And what did you use to take the photograph?

A. Photocopy machine.

Q. Photocopy machine.

And you did that -- you just put your

cellphone down on a copy machine and ran it and it came up

like this?

A. Yes.

Q. Okay. And when did you do that?

A. Immediately after Mr. Stanford texted me back, which

is at the bottom.

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3318

Q. So you had a motive to want to be preserve this in

some way, memorialize it in some way, so you could show

that Stanford has said it was okay, your decision -- or --

what does it say? You decide -- call you on my --

A. "Drive to somewhere, call me -- call you on my drive

to somewhere," I believe that's what it said.

Q. You think that's what that says? "Call you on my"

something?

A. That's what I see, and that's what I remember.

Q. Well, you were trying to preserve this for a reason,

weren't you?

A. Yes. I memorialized the text conversation that we

had.

Q. You wanted something that might show that when the

bank was paying out way more money than they were taking

in, that Allen Stanford decided just to let you have a

million dollars; right? You wanted some proof of that?

A. I wanted to memorialize, yes, I wanted proof,

memorialize the transaction.

Q. That's in spite of the fact that you had loan

documents drawn up; right?

A. Yes.

Q. Have you tried to replicate this? In other words,

take the type of phone that was used to receive this? Was

it an iPhone?

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3319

A. Yes, it was.

Q. Have you tried to replicate this to show whether or

not you can have those bars or that rule around the top

part and then have the response in the same manner that

you see it here on this exhibit? Have you tried to do

that again?

A. I don't understand the question, sir.

Q. I guess my point is: When you have -- when you

receive -- when you send a message like that and you get a

response back on an iPhone, isn't there something between

the sending and the responding?

A. I don't know. Something -- what do you mean by

"something," sir?

Q. Some rule or spacing other than what's displayed on

Government's Exhibit 1511-A?

A. It is what it is.

Q. Mr. Davis, isn't it possible that you made all this

up and that you just put that bottom part from another

cellphone and superimposed it over the message you claim

you sent to Allen Stanford. Isn't it possible you did

this?

A. No, sir.

Q. We got to take your word for that; right?

A. (No audible answer.)

Q. Is that right?

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3320

A. It is what it is.

Q. Well --

A. I said that is --

Q. -- you're testifying --

A. I said that is real, and you should take my word for

it.

Q. We should take your word for it; is that right?

A. Yes.

Q. Do you think there's some irony in that, that you're

asking us to take your word for something?

A. No, sir.

Q. Okay. You're now working on a fruit farm?

A. I was.

Q. Not anymore?

A. No.

Q. Your home is seized?

A. Yes.

Q. All your money and assets are seized?

A. Yes.

Q. You lived in a rather grand home, did you not,

Mr. Davis?

A. Yes, it was nice.

Q. It was nice. Okay.

And, in fact, since you made your deal

with the government, you've still lived in a pretty nice

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3321

house, haven't you?

MR. SCARDINO: Have we got pictures? Have you

got photos?

THE WITNESS: Yes, I live in a nice house.

BY MR. SCARDINO:

Q. You live in a nice house.

Now, you've lived in a nice house for the

last three years, ever since you made your deal with the

government, haven't you?

A. Yes, it's clean, it's nice.

Q. It's not only nice, it's big and scenic, rustic;

right?

A. It's rustic, small, and it has a nice view, yes.

Q. In fact, since you made your deal with the government

to say you're a big crook, you've traveled and gone

wherever you want, haven't you, pending this case?

A. No, sir, I haven't.

Q. You've had restrictions on you?

A. I have.

Q. Have you been denied the right to travel?

A. Not generally, no.

Q. Not generally. Okay.

How much money has the government been

able to seize in your agreement? How much money have they

gotten back from you of the $14 million that you claim

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3322

that you got when you were with Stanford?

A. I don't know.

Q. Well, didn't you agree to forfeit a billion dollars?

A. That was part of my plea agreement.

Q. Well, I mean -- excuse me.

You testified that you were a chief

financial officer; right?

A. Yes, sir.

Q. Kept track of billions of dollars; right?

A. Yes, sir.

Q. And you can't tell this jury how much money you've

been able to turn over to the government in your

forfeiture agreement?

MR. STELLMACH: Objection as to form. Could we

be clear as to whether he's talking about the witness's

personal assets or the accounts in which a signatory by

virtue of being CFO?

THE COURT: Okay.

MR. STELLMACH: For example, the billion

dollars that the SocGen accounts were -- whatever else

he's --

MR. SCARDINO: We're going to talk a lot about

the money he transferred out of the SocGen account in a

minute.

BY MR. SCARDINO:

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3323

Q. But I'm talking about the money that you agreed in

your plea agreement. You agreed to forfeit a billion

dollars; correct?

MR. STELLMACH: Again, same objection, as to

which accounts.

MR. SCARDINO: The plea agreement doesn't

address which account, it just says agrees to forfeit a

billion dollars.

MR. STELLMACH: Which accounts? Not personal

accounts. If he can be clear.

THE COURT: Is it stated in the plea agreement?

I don't have it in front of me.

MR. STELLMACH: I don't have it in front of me

either.

MR. SCARDINO: I do. Government's 1515. I'll

be happy to show it.

MR. STELLMACH: Go forfeiture.

MR. SCARDINO: Personal checking, $1 billion.

That's what I'm talking about.

MR. STELLMACH: Ask him whether he knows where

the accounts are.

MR. SCARDINO: I'll ask the questions, if you

don't mind, Mr. Stellmach.

MR. STELLMACH: I'm just trying to help.

MR. SCARDINO: I don't think I need it.

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3324

THE COURT: What page were we looking at,

forfeitures on --

MR. SCARDINO: Right at the bottom of it, Your

Honor.

THE COURT: On the bottom of what?

MR. SCARDINO: Of that document I just handed

you. I'm sorry. The forfeiture part is towards the end

pages, last couple of pages, it's in there. It's styled

"Forfeiture Agreement."

THE COURT: Okay.

BY MR. SCARDINO:

Q. So how much money did you turn over to the government

in accordance with your agreement?

A. Well, I signed over --

Q. That would ask for a number, Mr. Davis. What's the

number?

A. I don't know the number.

Q. Okay. Was it not important to the government to have

you honor that part of your plea agreement that you turn

over some of the millions of dollars you claim you stole?

A. I didn't steal any money.

Q. You didn't?

A. I received --

Q. Are you changing your plea?

A. The money I received, sir, was salaries, wages and

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3325

bonuses and the loan that we just discussed.

Q. Is it your testimony now, Mr. Davis, that you didn't

steal any money? Is that what you're saying?

A. I've already said that I lied and I committed fraud.

Q. That's not stealing?

A. And that is stealing from the CD holders, yes.

Q. Which is it?

A. Yes.

Q. Which is it? Did you steal money or not?

A. I did.

Q. So how much of the money that you stole that the

government wanted back did you pay back? How much?

A. I helped the government find funds for --


THE WITNESS: Cd holders.



BY MR. SCARDINO:

Q. If you don't know the answer, that's okay, but please

answer.

A. Millions.

Q. You've given them back millions?

A. I've signed documents. Sir --

THE WITNESS: Your Honor, can I non-es or no?

THE COURT: Sure. He can't answer it yes or

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3326

no.

BY MR. SCARDINO:

Q. You can't answer it yes or no? You're CFO; right?

You kept track of billion dollars of dollars, and you

can't tell how much money the government got out of you?

It's none; right? They haven't gotten any

personal money out of you; right?

A. All due respect, sir, if you'd let me say -- answer

the question.

THE COURT: Excuse me. Did they get any

personal money from you yet.

THE WITNESS: I don't know the answer to that,

sir.

THE COURT: Okay.

BY MR. SCARDINO:

Q. So is that to say, then, that that part of the

agreement that you've entered into with the government has

not been consummated? You haven't turned over the money

yet?

A. My assets were seized by the receiver.

Q. How much was in a bank account?

A. I recall a number of 300 and some-odd thousand

dollars in cash.

Q. Do you have the documents to back that up?

A. It would be in the documents that were seized.

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3327

Q. And that would be with the receiver?

A. Yes, sir.

Q. And you don't know whether or not these prosecutors

were able to access that information; right?

A. I don't know.

Q. The $300,000 you're referring to was money that was

taken by the receiver. Is that correct?

A. The bank accounts which that was part of was seized.

Q. Let's back up so it's clear, Mr. Davis.

When the Securities and Exchange

Commission stepped in, a judge appointed a receiver to

take over the Stanford businesses. Isn't that correct?

A. Yes, sir.

Q. And that receiver seized all assets and documents

related to Stanford businesses. Isn't that correct?

A. That was part of it, yes, sir.

Q. And took over all bank accounts that they could

identify involving the Stanford businesses. Isn't that

correct?

A. As far as I know.

Q. Okay. So the money that you're referring to, the

$300,000 that you're referring to, is $300,000 that the

receiver was able to obtain; correct?

A. From my personal account, yes, sir.

Q. It has nothing to do with your agreement with these

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3328

government prosecutors that you were going to forfeit

money because of the crimes that you say you committed?

A. Says that there's a $1 billion in the plea agreement.

Q. Let's go back to that Government's --

MR. SCARDINO: You don't have to bring it up.

BY MR. SCARDINO:

Q. I want to talk to you about Government's 1511A which

is the cell phone picture of the, what, $990,000? Is that

what it was?

A. 880, I think.

Q. I've got the records. We'll go through it when I get

to that later on.

But it's your testimony, I believe, on

direct examination that there was -- that the company --

the bank was scrambling to get money to pay all the claims

for redemptions on the CDs; right?

A. Yes, sir.

Q. And I believe you testified on direct examination

that there was an effort made to transfer assets to

recapitalize or capitalize the bank in such a way that

these claims could be paid?

A. I don't understand that explanation you gave me.

Q. What -- didn't you testify about some consolidation

project that was your idea?

MR. STELLMACH: Objection, mischaracterizes the

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3329

testimony. He didn't testify about a consolidation

project. He testified about flips and circular

transactions.

MR. SCARDINO: I disagree with Mr. Stellmach.

The first day he testified, he talked about being involved,

and there's e-mails that they put into evidence talking

about moving assets around. He's on the --

THE COURT: Okay. I'll overrule the objection.

By the way, if you don't understand the

question or that's not what your testimony was, you'll let

us know.

MR. STELLMACH: Can I just have a moment to

confer with counsel to avoid a miscommunication.

THE COURT: Sure.

(Attorneys conferring)

THE COURT: We'll take a break in about five

minutes.

BY MR. SCARDINO:

Q. The bank was losing the money, wasn't it?

A. Yes.

Q. Regardless of whether you committed fraud or not;

right?

A. Yes.

Q. Regardless of whether you cooked the books or not;

right?

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3330

A. We cooked the books.

Q. I didn't ask you that.

Regardless -- whether you cooked the books

or not, the bank was losing the money, wasn't it?

A. Yes.

Q. At a very rapid pace. Isn't that correct, Mr. Davis?

A. Yes, for some 21 years.

Q. And the economy in 2008 was such that not just

Stanford bank, but all the banks were heading in the wrong

direction, weren't they?

A. A lot of banks seemed to be. They were reported as

such in the newspaper.

Q. A lot of them -- big banks went broke, didn't they?

A. Some did.

Q. Some did. So in spite of all of that, your testimony

in front of this jury is that Mr. Stanford, "Davis, you

can go ahead have that million dollars. Go ahead and take

it out of the bank"?

A. No, sir. He didn't say million dollars. He text me

back from the text that I sent him on 880 or 900, whatever

it was.

He said, "You decide. I'll call you on

the way to Boca."

MR. SCARDINO: Can we have Government -- I'm

going to a different subject. Would it be a good time

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3331

or --

THE COURT: That's fine.

Ladies and gentlemen, we'll take a --

check your watch. We'll take a 20-minute break. That

should bring us to 4:10, and then we'll run on and wrap it

up around 6:00.

Wait one second here. Thank you.


(The following was held out of the presence of the jury)

(HEARING HELD AT THE BENCH ORDERED SEALED BY THE COURT)

(The following was held in open court)

THE COURT: All right. Let's call the jury in,

please.



MR. SCARDINO: May I proceed, Your Honor?

BY MR. SCARDINO:

Q. Mr. Davis --

THE COURT: Hold it. We need to unmute the --

CASE MANAGER: I did.

THE COURT: Is that working now? Pull it in

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3332

then, please.

MR. SCARDINO: How's that?

THE COURT: No. Pull it in closer.

MR. SCARDINO: Like that?

THE COURT: Better. Go on.

MR. SCARDINO: Making me nervous.

BY MR. SCARDINO:

Q. Mr. Davis, I'm going to jump back to the cell phone

loan for a minute.

Do you remember -- and you may have

already told us and I don't recall -- that the date that

you took the photograph of the cell phone that showed --

that you were asking Mr. Stanford to loan you $990,000?

A. I don't recall a date.

Q. Do you remember the year?

A. I believe it was shortly after the November text

message, so '08.

Q. Okay. And the cell phone that you took a photo --

that you -- that appears in that exhibit, do you remember

the type of phone?

A. Yes.

Q. What type of phone?

A. IPhone.

Q. And was it your iPhone?

A. It was. I believe so.

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3333

Q. And do you still have that iPhone?

A. Yes.

Q. Do you have it with you?

A. No.

Q. Where is it?

A. It's in my travel bag.

Q. Okay. Is it in Houston?

A. Yeah.

Q. Will you bring it tomorrow when you come back to

court?

A. I guess.

Q. Okay. Just asking.

A. Yeah.

Q. Okay. And what year iPhone was it that you

photographed?

A. It was a --

Q. Better said not year, I mean -- or I guess maybe I

can ask you that, what year you bought it. But we're

talking about I'm something I'm not have familiar with.

Was it a iPhone 1, 2, two, 3, 4, 5, or do

you recall?

A. Probably the first generation of iPhones.

Q. Okay. And it's your testimony that that's the phone

that appears in the exhibit that the jury has seen?

A. That's the -- yes, that's the phone.

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3334

Q. Have you ever tried to take a message off of that

iPhone and erase it and then replace it with another

message? Have you ever tried to do that?

A. No, sir.

Q. Okay. Back to that the amount of money that you had

asked Mr. Stanford to advance to you, I believe the

exhibit refers to you wanted the money for a particular

purpose.

Do you remember what that was?

A. Yes, sir.

Q. Thank you. What was it?

MR. SCARDINO: Can we have the exhibit back up,

please? 1511A.

BY MR. SCARDINO:

Q. And I'll confess, Mr. Davis, I'm having a hard time

reading that. Can you read it?

A. Yes, sir.

Q. And would you read it?

A. "I'd like to draw."

Q. Stop. What does that mean? You would like to draw?

What do you mean "draw"?

A. I meant a conventional loan.

Q. A conventional loan. Okay.

And the amount that you want to draw?

A. Looks like $880,000.

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3335

Q. Okay. Is that what you ended up borrowing?

A. I believe so. It was in two tranches, two pieces:

One in December and one in January.

Q. When you told the government's prosecutors about

that, did they go and look to see if you actually accessed

that money? Do you know?


Q. Did anybody show you any documents to show that

that's exactly what happened, that you got $880,000?

A. I didn't see those documents.

Q. In talking to the government prosecutors and

preparing for your testimony here, you didn't review any

documents to see whether or not you, in fact, got the

money?

A. I know I got the money.

Q. I know you know you got the money, but did you look

at the documents? Did anybody bother to subpoena your

bank records to see if that -- that you, in fact, got the

money?

A. I don't recall.

Q. Okay. You don't remember anybody -- you don't

remember Mr. Stellmach asking you about it on direct

examination that if you had looked at a bank account to

show that that's what happened, that you got that money?

A. I don't remember that question.

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3336

Q. Okay. Let's go to the next line.

Does that say "Not through PROSPECTIVE

JUROR: "?

A. Payroll.

Q. Payroll. Okay?

A. Yes, sir.

Q. "But as a conventional loan into a company"? Is that

what it says?

A. Yes, sir.

Q. Okay. And you testified earlier that you had

actually had a lawyer draw up loan documents, but you just

don't have them; right?

A. No, sir.

Q. Would those also be in Houston in maybe your travel

bag you can bring and show us tomorrow?

A. They would not be in Houston.

Q. Okay. And where would they be located?

A. I don't know where they are.

Q. Have you tried to find them?

A. No, sir.

Q. Did the government prosecutors ask you to produce

those loan documents when you told them that you had had a

lawyer create them that would tend to verify that this is

what happened between you and Stanford?

A. They did not ask me that.

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3337

Q. Okay. And then you go to say, "Tax otherwise eats it

up"?

A. Yes, sir.

Q. Did you ever pay the money back?

A. No, sir.

Q. Okay. Well, did you then declare it as income on

your tax return?

A. No, sir.

Q. Well, did you file a 2008 tax return?

A. No, sir.

Q. Did you file a 2009 tax return?

A. No, sir.

Q. Is part of your deal with the government in your plea

bargain you don't have to file tax returns?

A. Attempted to file them, sir, but they -- with all my

other records they have been seized, I don't know where

those records are.

Q. I see. So you haven't been able to file tax returns

because the receiver's got all your records?

A. For those two years, '08 and '09 only.

Q. Do you have a person helping you prepare your tax?

A. Yes.

Q. And are you paying them with funds that are supposed

to be seized by the government?

A. I have not paid them any funds.

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3338

Q. Yes, sir. The person, your tax preparer, has not

been paid?

A. No, sir.

Q. They're just helping you out because they like you?

A. I've maybe asked them one question in three years. I

have not been billed.

Q. Has the Internal Revenue Service been in touch with

you about why you haven't filed a tax return in 2008?

A. Yes.

Q. Did you respond to that?

A. Yes.

Q. Did you tell the government prosecutors that the IRS

is knocking on your door about filing a tax return?

A. I believe I did tell them that there was

communication, yes, sir.

Q. It could create a problem with how you characterize

this money on your tax return, couldn't it?

A. It could if it was not done properly.

Q. And then you go on to say, "In lieu of next bonuses

or whatever."

Is that what that says?

A. That's -- yes, sir, exactly.

Q. And this is an e-mail you sent to a guy that you

claim is elusive and hard to get ahold of; right? Allen

Stanford?

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3339

A. Yes, sir, at times.

Q. So you're asking him for almost a million dollars and

you want the money for whatever?

A. It's a follow-up to a verbal conversation that I had

with Mr. Stanford.

Q. Oh. So we have to believe you that you had a verbal

conversation with Mr. Stanford; right?


Q. Well, I mean --

A. I'm just telling you the truth.

Q. Okay. Yes, sir. And then the next line is for -- I

can't read that. What's that say? Does that say, "For

note payments and service on Baldwyn biz"?

A. Yes, I was telling him that it was for Baldwyn

businesses.

Q. Was that true?

A. Yes, sir.

Q. Did the money go to Baldwyn businesses?

A. Yes, sir. To me, it went to me. I own those

businesses.

Q. Okay. That's different. It didn't go to the

businesses; it went to you?

A. Because I owned those business.

Q. Was the money -- did the -- was the money loans to a

business or to you?

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3340

A. It went into a business.

Q. And do you have the documents to verify that,

Mr. Davis, or do we just have to take your word for it?

A. The documents exist, and I believe all my documents

have been seized.

Q. Okay. Did you make an effort to get them from the

receiver?

A. No, sir, I haven't.

Q. Okay. You go on to say, "and RE affairs."

Is that what that says?

A. Yes.

Q. What are RE affairs?

A. Real estate.

Q. Real estate. So the money -- you needed the money

for payments and services on a business and real estate

affairs?

A. Yes, sir.

Q. What real estates affairs are you referring to?

A. Personal.

Q. Personal?

A. Related to the businesses I mentioned in Baldwyn.

Q. Okay. So you had some real estate business in

Baldwyn?

A. I owned some real estate in Baldwyn, yes.

Q. Well, was it a real estate business?

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3341

A. It wasn't a real estate buy-sell business? It was

real estate purchased?

Q. Okay. So what you say here is, it's "and real estate

affairs," and you're telling us that Stanford said, With

that information, I'll let you have a million dollars? Is

that what you're asking us to believe?

A. It is what it is, yes, sir.

Q. Okay. Are there any documents to back up the fact

that you needed the money for some real estate transaction

that you showed Mr. Stanford to try to convince him it was

a legitimate need for money?

A. Mr. Stanford was aware of my business affairs in

Baldwyn.

Q. Let's talk about what they were, Mr. Davis.

What was your business in Baldwyn that

you're referring to here?

A. There were several pieces of real estate in downtown

Baldwyn that I purchased and they had businesses located

on the real estate. They were in our studio, and there

were interior --

THE COURT: On what studio?

THE WITNESS: Art studio.

THE COURT: Oh, I see.

THE WITNESS: Art gallery. And it was a

interior design company.

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3342

BY MR. SCARDINO:

Q. These are businesses that you own?

A. Yes, sir.

Q. And when did you start these businesses?

A. 2002, '3.

Q. And where did you get the money to start the

businesses?

A. From salaries and wages. Ultimately from the CD

holders. Everything came from the CD holders for all the

companies and all the people in the companies.

Q. So when you tell the jury you didn't steal any money,

that's not exactly accurate; right?

A. Well, I believe I clarified that with you, sir. I

did steal. I stole and I lied, and I lied and stole for

many years.

Q. So you change your testimony in a matter of

10 minutes; right?

A. No, sir.

Q. First you say you didn't steal?

A. I clarified that for you when you asked the question

before the break.

Q. You have a hard time with that, don't you, Mr. Davis?

A. No, sir.

Q. So you asked Mr. Stanford for this money, and for

note paid for -- something payments and service on Baldwyn

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3343

business and real estate affairs. Okay.

So it indicates here that you need the

money for two different reasons, does it not? For service

on Baldwyn business, period, and real estate affairs;

right?

A. Yes.

Q. Okay. And then you go on to say another reason you

need the money.

What else?

A. Working capital for first six months of '09.

Q. Working for what, Mr. Davis?

A. For the businesses aforementioned.

Q. So all of this money that you're asking Mr. Stanford

for is to help you with these businesses that you started

in Baldwyn, Mississippi, that are yours alone?

A. I think you've got it, sir.

Q. Okay. And did you own these businesses with anybody

else?

A. One of them I did.

Q. Who are you in business with?

A. Other than my wife, there was a restaurant I was

50/50 owner with.

Q. Who was your partner?

A. Laura Holt.

Q. Oh, that's the lady you had the relationship with?

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3344

A. Yes. Had an affair with Ms. Holt.

Q. And, so, you also had a personal relationship and a

business relationship with her?

A. That's what I testified to. Yes, that's true.

Q. And did you live in Baldwyn, Mississippi at the time

that you started this business with Ms. Holt?

A. Yes.

Q. Okay. And you live there with your wife?

A. I live with my wife, yes.

Q. In Baldwyn, Mississippi?

A. Outside in the country, yes.

Q. So you start a relationship with a woman and you go

into business with her in the home where you live, right,

with your family?

A. Yes, sir, I had a relationship with Ms. Holt, and --

Q. Did you deceive your wife with that relationship?

A. Yes, I certainly did.

Q. And when was that?

A. 2001.

Q. 2001?

A. '2 and '3.

Q. So for three years?

A. Almost, yes.

Q. Lied to your wife?

A. Yes, sir.

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3345

Q. Let's go back to this.

What's the next line say?

A. Which one?

Q. After the highlight, it says -- what does that say?

Can you read it?

A. Yes.

Q. What's it say?

A. "It can go through Venture Capital, maybe split into

two tranches, half now, half January."

Q. Why are you asking that if -- or saying that it can

go through venture capital?

A. The loan can come from Venture Capital as a company

that is -- it was a Stanford company.

Q. Had assets, didn't it?

A. Yes, it had assets in it.

Q. You were the CFO, so you knew where the money was;

right?

A. I also knew where the money wasn't.

Q. But when you're trying to make it look like you're

borrowing this money and you generate this document, you

want it to look like you are getting it somewhere that you

know money exists?

A. Yes.

Q. Yes?

A. I committed fraud.

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3346

Q. Then you go on to say, "May be split in two" --

A. Yes, sir.

Q. -- "transactions, half now, half in January."

A. Yes, sir.

Q. Was that in the loan documents that you had your

lawyer prepare, that you would get half the money when you

generated this document and half later? Was that part of

the loan agreement?

A. I don't believe it was in the loan agreement that it

would be in two tranches.

Q. And Mr. Davis, when -- you said you got the money;

right?

A. Yes, sir.

Q. And how was it transferred, or where -- I guess

better stated, where did the money come from? Did it come

from Stanford Venture Capital?

A. I don't recall.

Q. Didn't think it was important to go back and look to

see where you got the money?

A. It came from the Houston office in terms of --

technically, it was --

Q. All right. And how was it transferred to you?

A. A wire transfer.

Q. A wire transfer. And would you explain what that is

to the jury? What's a wire transfer?

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3347

A. It's an order to a bank --

Q. Yes, sir.

A. -- to send money.

Q. Okay.

A. It's done by wire, by telephonics --

Q. Okay. And --

A. -- to another bank, one bank to another bank.

Q. A transaction that you're familiar with?

A. Yes.

Q. And it doesn't mean that currency is generated? I

mean, you don't -- you're not reaching in your pocket and

pulling out dollar bills, are you?

A. No, sir.

Q. It's a paper transaction, isn't it, in effect, or a

wire transaction?

A. It's registered on paper. It's an actual transfer of

currency, yes.

Q. So what you're asking -- when you say Mr. Stanford

says, "Your decision. Call you on my whatever," you acted

on that.

Did you act immediately or did you wait a

little while?

A. The action took place later, weeks later.

Q. Weeks later; okay?

And, so, you instruct a bank to wire the

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3348

money to another bank. Is that correct?

A. Gave the instruction to Patricia Maldonado, the

treasury manager, and she did that, yes.

Q. So when you did that, when you wired it from Bank A

to Bank B, it was just like money, though, because you got

it when it was wired. Is that correct?

A. Yes, sir.

Q. Just like the way CD holders had money when it --

money was transferred by paper, it had value; right? Same

type of thing?

A. I don't understand your last remark.

Q. When -- the money, when Mr. Stanford's venture

capital company -- what bank was used for that -- those

transactions for Stanford Venture Capital. Do you recall?

A. No. It possibly could have been Trustmark Bank.

Q. Well, you were the CFO, and you're the one that got

the money.

I mean, you don't remember the bank?

A. Had 30 or 40 bank accounts. I can't remember every

one of them.

Q. All right. So it was a bank that Stanford Venture

Capital had assets, and you instructed that bank to wire

almost a million dollars out of the bank, didn't you?

A. Yes, sir.

Q. It wasn't Mr. Stanford that instructed the bank to

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3349

wire the money out of the bank. It was you that did it,

wasn't it?

A. In this case, yes.

Q. In this case, yes.

And did you have any documents that you

submitted to the bank to demonstrate to the bank that

Mr. Stanford had given you permission to take almost a

million dollars out of a bank in a company that he owns a

hundred percent of and give it to you? Did you provide

the bank with any documents?

A. I didn't provide the bank, no.

Q. You didn't have to do that because they knew you were

Mr. Stanford's CFO and that you had the authority to do

that without any loan documents or authority from

Mr. Stanford to make that transaction?

A. I thought it was passed, sir, to Patricia Maldonado,

who actually made the transaction.

Q. Do you have documentation to show that that occurred,

that you asked the treasurer, Ms. Maldonado, to effect

this?

A. It exists. I don't have it personally.

Q. Oh, this is something else that is nobody can get

that's somewhere in the receiver's home. Is that right?

A. I don't know where it is, but it --

Q. Is that going to be the answer to all --

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3350

THE COURT: Hold it. Let him finish.

You may finish.

THE WITNESS: Let me ask you this, too, if I

could.

THE COURT: No.

BY MR. SCARDINO:

Q. You can't.

A. Sir, could I ask you a question?

MR. SCARDINO: Well, if he's going to do it,

I'd like it to be out of the presence of the jury.

THE WITNESS: It has to do with my ears. Since

the Navy, I've worn -- I can't hear well. I've got hearing

aids.

THE COURT: All right. So what would help you?

THE WITNESS: It would help if talk slower,

and --

BY MR. SCARDINO:

Q. You want me to talk slower?

A. Yeah, a little bit.

THE COURT: Okay.

BY MR. SCARDINO:

Q. We have a hearing devices here, Judge. We've got

these things --

A. I have hearing aids on.

Q. These are better.

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3351

THE COURT: Hold it. In other words, it works

okay.

THE WITNESS: Just normal tone without jumping

around and changing the inflection of your voice, et

cetera. If you could just be standard, I'll catch it all.

Otherwise, I'll have to ask you to repeat it.

THE COURT: You're asking him to be calm, in

other words?

THE WITNESS: Well, just a steady.

THE COURT: All right. See if you can modulate

your tone.

If you can't, we have some other

alternatives that might help you.

THE WITNESS: Thank you, sir.

THE COURT: We've just been electrified

including folks that do have a hearing impairment that have

extra amplification. But we're not there yet. Let's give

it a try.

THE WITNESS: Thank you, Your Honor.

MR. SCARDINO: That's like asking me to be

six-feet tall, Judge.

THE COURT: Well, give it a try.

BY MR. SCARDINO:

Q. You're uncomfortable up there, Mr. Davis?

A. No. I'm relaxed. Go ahead.

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3352

Q. So the document that would indicate that you had

asked the treasurer of Stanford companies, Betty

Maldonado --

A. Patricia Maldonado.

Q. I'm sorry. Patricia. I know a Betty Maldonado. I'm

sorry. Patricia Maldonado.

A. Sure.

Q. The document that would verify what you're telling

this jury is in the hands of the receiver; is that right?

A. The document and the computer records.

Q. Do you know whether or not these -- your Assistant

United States Attorneys with subpoena power made an effort

to obtain those documents so that we wouldn't have to take

your word for it, Mr. Davis?

A. Well, sir, I believe that they could get that

information for you.

Q. Do you know if they've tried?

A. I'm not certain of that. I believe they could get

that, though, for you, sir, if you asked them.

Q. Yes. So are you telling the jury that it wasn't you

that instructed the bank to make the wire, that it was

Ms. Maldonado that was -- instructed the bank to make the

wire transfer?

A. This is my doings. I did it. It's wrong.

MR. SCARDINO: Objection. Nonresponsive.

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3353


THE WITNESS: No, I'm not telling that -- I'm

not telling the jury that.

BY MR. SCARDINO:

Q. Because it was you that actually made -- made the

instruction to make wire transfer; correct?

A. Yes, sir. I've already said that.

Q. Now, this was a company called Stanford Venture

Capital.

Do you remember talking about that company

with Mr. Stellmach on direct examination? Remember you --

in fact, if I recall, Mr. Davis, you drew us -- somewhere

in all of this, you made a reference to Stanford Venture

Capital. Let's see if we can find it. Wow, there was a

lot of them.

See here, Stanford Venture Capital. Is

that what that is?

A. Yes.

Q. Did you draw this?

A. I drew it.

Q. You drew it. What did you tell the jury Stanford

Venture Capital was?

A. It's a shell holding company.

Q. Shell holding company.

And what do you -- explain that to the

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3354

jury. What's a shell company? Is it fake?

A. It's a real company that holds certain other

companies, passes funds through.

Q. Well, you indicated to the jury that it was some

negative connotation, that it was just some kind of a

shell company that was used to facilitate a fraud. Isn't

that right?

A. No. I said it was a shell company. It's a real

company in terms of legal -- it's a legally granted

company, articles, et cetera.

Q. Okay. So you're --

A. But it's a --

Q. Sorry?

A. -- it's a pass-through company.

Q. Pass-through company. So when you say "shell

company," you don't -- you're not telling the jury that it

was something negative about calling it a shell company,

are you?

A. It's a company, a shell company, not having

employees --

Q. Yes, sir.

A. -- basically.

Q. Okay.

A. Yes, sir.

Q. But this shell company that you referred to is the

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3355

company where you got almost a million dollars out of it;

right?

A. Well, I got the money. I'm not certain it came from

that particular company, but I did get the money. That

was the suggested source of the money.

Q. So you don't recall where you got the money?

A. Got it from an account at Stanford Financial.

Q. And the purpose of the money, of asking Mr. Stanford

for the money was to help you with funding your businesses

in Baldwyn, Mississippi. Is that right?

A. That was the purpose.

Q. Okay. And no other reason?

A. I don't think so.

Q. You said Stanford Venture Capital had no employees;

right?

A. I don't think they did.

Q. But you're the CFO. You should know; right?

A. I said I don't think they did. I don't --

Q. You testified earlier they had no employees and

that's what made it a shell company.

MR. STELLMACH: Objection. That

mischaracterizes his testimony.

THE COURT: Sustained to the extent that he can

agree or disagree with that statement.

Ask it again, if you desire.

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3356

BY MR. SCARDINO:

Q. Did it have employees?

A. Not to my recollection.

Q. You were the CFO?

A. I was.

Q. Okay. That's what I said -- that's what I asked you.

In fact, while we're on that subject,

what -- tell -- explain what a CFO is to the jury.

A. Chief financial officer or CFO is in charge of the

finance and accounting of -- generally in charge of

finance and accounting in a company, including

scorekeeping and reporting.

Q. And that's what you did for Mr. Stanford's companies;

right? Or particularly --

A. Among other things, yes.

Q. I mean, but it was particularly the bank, Stanford

bank. Is -- you were the CFO of the bank or other

companies?

A. I was CFO of Stanford Financial Group and CFO of

Stanford International Bank.

Q. So you actually had access to all of the -- all the

accounting information?

A. I had access to it. There was a local controller at

the bank who had most of the details.

Q. You keep track of the money; right?

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3357

A. The CFO responsibility down the chain, yes.

Q. Keep track of the money. Keep track of the

investments. Is that right?

A. It's in -- that's in that responsibility.

Q. Keep track of what's coming in and what's going out;

right?

A. Yes.

Q. So you basically knew what was really going on with

these companies. Is that right? Is that what you're

telling the jury?

A. Yes, generally I did.

Q. You were the conduit for all that information more

than anybody else in the organization?

A. No, sir, I wouldn't characterize it that way.

Q. Well, you were more -- you had more -- you had access

because of your title to more of that type of information

than Mr. Kuhrt; right?

A. No, sir.

Q. No? You were the CFO; right? And he wasn't. He was

below you. He reported to you, didn't he?

A. He had the same access that I did.

Q. But he reported to you?

A. He did.

Q. Mr. Lopez the same; right? He reported to you?

A. Mr. Lopez reported to me. Mr. Kuhrt reported to the

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3358

global organization, which is run by Mr. Stanford.

Q. Okay.

A. He was the global controller.

Q. But the title CFO was -- indicates that that guy is

in charge. The chief financial officer, he's in charge of

finances?

A. The bank and Stanford Financial Group.

Q. Finances?

A. I was not CFO of Stanford Global to my knowledge.

Q. So let's go back to this loan for just a second.

The money was used to fund you say some

real estate and other things.

You testified you were making -- I'm

trying to remember. Was it one point -- no. 900,000?

A. Yes sir.

Q. 900,000 a year at the end. And you got bonuses in

addition to that; right?

A. I did.

Q. Back in 2008, how much money did you make?

A. $2 million. In excess of $2 million.

Q. In excess of $2 million?

A. Yes.

Q. Does that include the money you stole, or does that

not include the money you stole?

A. I believe that includes it.

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3359

Q. Includes the money you stole. Okay.

And have you -- have you got a fundamental

tax return prepared for 2008?

A. No, sir.

Q. Y'all haven't put that together?

A. '8 or '9, I did not.

Q. So when you -- you're making this money -- I mean,

you have a total figure for 2008? What did you say? Was

it 2 million or 3 million?

A. In excess of $2 million.

Q. In excess of 2 million.

Well, does that mean it was more than 3

million?

A. It means what I said. It's in excess. I don't know

the exact number.

Q. Well, Mr. Davis, in excess of 2 million could be 10

million; right?

A. It was less than three.

Q. Less than three. Okay. So more than two and less

than three; right?

A. Probably -- keep batting it back and forth. Maybe

2.4, 2.3.

Q. Okay. So your income for 2008 was about right around

two and a half million dollars?

A. Could have been.

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3360

Q. Well, I mean --

A. I don't have the numbers. I don't recall.

Q. You were the CFO of a multibillion-dollar operation.

You can't keep track of how much money you

made?

A. I keep track of it when I have my records, yes, sir.

Q. Oh, I forgot. The receiver's got all your records.

You have access to no other records;

right?

A. No, sir.

Q. Okay. How about 2007? How much did you make then?

A. I'd say 1.8, 1.9 million.

Q. And in 2006?

A. 1.6.

Q. I mean, did you consider that a lot of money?

A. Yes, sir, I would. Very, very much.

Q. And you could live well on that; right?

A. Yes.

Q. I mean, did you have a lot of expenses, Mr. Davis?

A. Yes.

Q. I mean, what kind of expenses?

A. The monies were put into those Baldwyn projects that

you've so well covered already.

Q. Okay. The ones that you owned with Ms. Holt?

A. One of them was owned with Ms. Holt, yes.

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3361

Q. How many companies were there?

A. I believe there were five.

MR. SCARDINO: May I have just a minute, Your

Honor?

THE COURT: Yes.

BY MR. SCARDINO:

Q. Well, Mr. Davis, was it -- did you make a bad

investment with these companies that you started in

Baldwyn?

A. Did I make a bad investment? I would say so.

Q. You real estate; right?

A. Yes. It was --

Q. 2008. Real estate wasn't doing too well, was it?

A. Generally, no.

Q. Generally, no.

In fact, one of the problems Stanford was

having was because the assets that were part of the

company were -- some of them were in real estate, and some

of those assets were going one way and some were going the

other way. But real estate generally in the U.S. wasn't

doing well back then, was it?

A. No, sir.

Q. Okay. And did you need money to help fund these

companies? Did you -- were you in bad shape, or did you

save any of that two and a half million dollars you were

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3362

making and one and a half million dollars you had been

making?

A. You've got about six questions there. Would you

narrow it down for me, please.

Q. I'm get right to it, Mr. Davis.

MR. SCARDINO: Let me -- I'll offer Defense

Exhibit Number 13-83. That's the only copy I've got. Let

me give you the original.

MR. STELLMACH: No objection.

MR. SCARDINO: No objection.

THE COURT: Any objection?

MR. SCARDINO: 13-83.

MR. STELLMACH: I'm sorry, Your Honor. No

objection.

THE COURT: Defendant 13-83 is admitted.

MR. SCARDINO: Can we have it, please?

Man, I can't see that. Can you make it

any clearer? There you go.

BY MR. SCARDINO:

Q. Mr. Davis, can you -- can you see what that is?

A. Yes, sir, I can.

Q. That's -- what is it?

A. It is the statement from Merchant -- Farmers and

Merchant Bank where I had an account styled Davis

Holdings.

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3363

Q. Okay. And James M. Davis, manager/member; right?

A. Yes, sir.

Q. Post office box?

A. 70.

Q. And is this -- this is your banking account; right?

A. It is.

Q. Do you have any other bank accounts?

A. Yes, I did.

Q. How many did you have?

A. I would say six or seven.

Q. Were they all in the United States?

A. Yes, sir.

Q. Did you ever have a bank account or an account with

Guardian Bank when it was in Montserrat?


Q. Did you ever have a bank account with Stanford

International Bank, Limited located on the Island of

Antigua?


Q. So all of your bank accounts were U.S. banks?

A. Yes, sir, I believe so.

Q. No Swiss bank accounts?

A. No, sir.

Q. Now, this bank account, what was it used for?

A. It was the account for the administrative and

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3364

accounting company, Davis Holdings, and cash would flow

from this account into other businesses there in Baldwyn.

Q. Would it not have been easier to put money into those

business accounts?

A. Possibly.

Q. I mean, was your little business set up kind of like

Stanford was? Money came into one entity and flowed into

other entities? Is that what happened?

A. I guess I learned from the master.

Q. You set all those accounts up with Stanford, didn't

you?

A. Yes, sir.

Q. You're the one that set those up?

A. No, sir. No, sir.

Q. Well, let's look at your bank account here that you

say you used to put money in and then send money out.

This statement shows a balance last

statement. Can you see that on the right?

A. Yes, sir.

Q. And the date?

A. Yes, sir.

Q. That top line, balance last statement. What's the

date?

A. November 28, 2008.

Q. And what's the balance?

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3365

A. Negative, 58,000.

Q. Negative 58,000?

A. Yes, sir.

Q. In 2008; right?

A. Yes, sir.

Q. Aren't you the guy making two and a half million

dollars a year?

A. Yes, sir.

Q. Okay. And somehow your account here is minus over

58,000?

A. That's pretty clear.

Q. How long has this account been in the negative,

Mr. Davis?

A. I would say not too long. I don't know.

Q. Not too long.

So when it got negative, you needed a way

to put money in it, didn't you?

A. Makes sense.

Q. Well, yeah. You found a real easy way to put money

in it. It was from Allen Stanford, wasn't it?

A. In this case, yes, sir.

Q. Had you spent all of your two and a half million

dollars, Mr. Davis?

A. Yes, sir.

Q. All gone?

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3366

A. Apparently.

Q. Where did it go?

A. It went into investments in Baldwyn.

Q. Have you got those documents to verify that?

A. If they exist, I don't have them personally, no.

Q. So let's run down this line here from November 28,

2008. And then it keeps getting in the negative. You

keep writing hot checks, don't you? You wrote one for

$37.69, didn't you? On the next line; right?

A. Yes, sir.

Q. Guy making two and a half million dollars a year

writes a hot check for $37.69.

Can you explain that?

A. Had an overdraft provision by the bank granted. And

that's my response.

Q. That's your response?

A. Yes, it is.

Q. So you had a overdraft position with the -- provision

with the bank. You didn't just keep money in a money

market account so that you could cover your overdrafts;

right?

A. In this case, I didn't.

Q. In fact, you were in such bad shape, stayed negative

all the way down through the bottom. On 12-10 it's

negative $73,069.21.

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3367

MR. SCARDINO: And then we go to the next page,

Page 2. There you go.

BY MR. SCARDINO:

Q. The second line it shows you get all the way down to

negative -- you wrote a five thousand-dollar hot check on

the second line, $5,563. And that got you a negative

$78,722.80; right?

A. Yes, sir.

Q. And then you caused something to happen on the next

line, didn't you?

A. Yes, sir. Approved by Mr. Stanford, I did, yes.

Q. We have to believe you that it was approved by

Mr. Stanford, don't we, Mr. Davis?

A. Well, I'm telling the truth. It was also on the

exhibit that you shown me several times --

Q. Yes, sir.

A. -- with the iPhone.

Q. So there's a wire from JPW, from Stanford Venture.

Is that right?

A. That's what it says, yes, sir.

Q. For $390,000. Is that correct?

A. Yes, sir, it is correct.

Q. And then you go down and you show that right after

that you write a check for $270,000. Is that correct?

A. It was a debit, yes.

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3368

Q. Right?

A. Check Number 2283.

Q. Where did that money go?

A. Deposited it into one of the other companies, I

believe.

Q. This just wasn't a way for funnel money out of the

Stanford's money into your pocket, Mr. Davis?

A. Yes, sir.

MR. SCARDINO: I'd offer Defense Exhibit 13-84.

THE COURT: Is it 13-84?

MR. SCARDINO: That is correct, Your Honor.

MR. STELLMACH: No objection, Your Honor.

THE COURT: Thank you. It's admitted.

BY MR. SCARDINO:

Q. Would you look at the top of that, Mr. Davis? Can

you read it?

A. Farmers and Merchants Bank.

Q. That's your bank account -- your bank where you

banked?

A. Yes, sir.

Q. One of your banks; right?


Q. And it's titled Davis Holdings, LLC?

A. Yes, it is.

Q. James M. Davis, manager/member. Is that you?

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3369

A. Yes, sir.

MR. SCARDINO: Let's go to the top line there,

under commercial checking account.

BY MR. SCARDINO:

Q. Is this the same account that we just previously

referred?

A. It is, yes, sir.

Q. Okay. And, so, this is your account, and it shows

last -- balance last statement on 12-31-08 is $1,524.98;

right?

A. Yes, sir.

Q. So that means that it didn't take you long to go

through that $330,000, did it?

A. No, sir.

Q. In fact, very soon after that, you're in the negative

again. You write a check for $7,252, which puts you in

the negative once again --

A. Yes, sir.

Q. -- is that correct? Okay.

MR. SCARDINO: And then let's scroll all the

way down to the line that says, "Wire from Stanford Venture

Capital." Right there.

BY MR. SCARDINO:

Q. When did that happen?

A. Happened on the 14th of January.

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3370

Q. So now, I want to ask you: Is there any question in

your mind, Mr. Davis, that the way you got this money was

from Standard Venture Capital? Earlier you testified you

weren't sure. But any question in your mind now how you

accessed that money?

A. No, sir. No, sir. It's clear.

Q. And did you do it in the very same manner that you

had done the month before by sending wire instructions to

Stanford Venture Capital with the bank that held their

funds and instructed them to wire $600,000 into your

account at Farmers & Merchants Bank?

A. Yes, sir, I did.

Q. And how much is that, Mr. Davis? You're the CFO.

A. 990.

Q. That's 990?

A. Yes, sir.

Q. Right at a million dollars, isn't it?

A. Yes, sir.

Q. Okay. Let's look and see what you did with that

money. You started writing checks on it, did you not?

A. Yes, sir.

MR. SCARDINO: Let's scroll down to the third

page, please. And then go on -- let's just move on to the

last page.

BY MR. SCARDINO:

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3371

Q. What did you do with that money, Mr. Davis?

A. I spent it. Invested it into a business in Baldwyn,

and spent it.

Q. You needed the money, didn't you?

A. Yes. Yes, sir.

THE COURT: You can pull that mike in, if you

want.

BY MR. SCARDINO:

Q. In fact, you always needed money, didn't you,

Mr. Davis?

A. Yes. Everyone needs money. I needed money. Yes,

sir.

Q. You needed more than Mr. Stanford was paying you,

didn't you?

A. At that point, yes, sir.

Q. At the point where you had been paid -- already been

paid $14 million, and you still needed money and were

writing hot checks in the amount of $27; right?

A. Yes, sir, I did get $14 million over 21 years, yes,

sir, I did.

Q. That's pretty good money to steal money, isn't it?

A. I don't understand your question, motive.

Q. Well, the fact that you had made $14 million and had

spent it all and you find yourself broke at the end of

2008, you found a way to get some more money, didn't you?

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3372

A. I asked for it, Mr. Stanford approved it, and at the

end of the day, it was taken from the CD holders.

Q. Well, you took this money from Mr. Stanford, didn't

you? Regardless of the original source of it, it came out

of an account that he owned from a company that he owned

and you took it, didn't you?

A. At his approval, yes, sir, I did. He approved it.

Q. We have to take your word for that, don't we?

A. No, sir.

MR. SCARDINO: Let me go back. Can we go back

to Government's 1511-A again for just a second.

BY MR. SCARDINO:

Q. How much did you tell him you needed?

A. 880.

Q. You told the jury you had loan documents prepared to

borrow that much; right?

A. Whatever the amount taken.

Q. How much did you take?

A. 990.

Q. Did you change the loan documents to reflect that?

A. I believe the loan documents reflect the 990, what

came in.

Q. I'm going to shift topics on you, Mr. Davis.

Are you okay now? Are you all right?

A. I think so.

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3373

Q. My tone of voice okay?

A. Thank you.

Q. You're welcome?

A. I can hear well.

Q. Good.

How long have you been wearing hearing aids?

A. Several years.

Q. How old are you?

A. 63.

Q. You're just a young man, Mr. Davis.

A. Thank you, sir.

MR. SCARDINO: I'd like to refer to

Government's Exhibit 112. Would you bring it up, please.

BY MR. SCARDINO:

Q. Is a document -- or exhibit, Mr. Davis, that we --

lawyers use these terms. Maybe -- this is a document that

some lawyer finds. In this case, it was the government.

And then they want to bring it in before the jury to show

the jury, and the Judge decides whether it's admissible or

not. So now it's evidence. So we call it -- we refer to

it sometimes by different names. If it's confusing to

you. That was kind of confusing, wasn't it?

THE COURT: Just for my records, this was

not -- was this referred to by the government in the past?

MR. STELLMACH: It has been, Your Honor.

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3374

THE COURT: So it's in our file. Because,

remember, my notes don't go back to the first couple of

days until we started this recordkeeping.

Go right ahead.

BY MR. SCARDINO:

Q. Mr. Davis, this is a document, an exhibit, that

Mr. Stellmach, I believe, talked to you about. Do you

remember it?

A. Yes, sir.

Q. What is it?

A. It's a Stanford International Bank, Limited, annual

report for 1999 cover.

Q. Let's talk a minute about what is an annual report?

In the corporate world, what's an annual report?

A. Annual report issued at the end of a fiscal year of a

company, meaning their year end calendar or otherwise,

sums up the transactions, the financial transactions of

the business.

Q. Okay. And who prepares the annual report?

A. The accounting people.

Q. The accounting people?

A. Yes, sir.

Q. Okay. The people that have access to the information

that they put in the report?

A. That's correct.

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3375

Q. Okay. And is it something that's required to be

prepared and filed?

A. I would say most board of directors require it. A

lot of times if there is an oversight agency, they require

it.

Q. Did the Stanford board of directors require it?

A. If -- yes.

Q. They did?

A. Yes, sir.

Q. And you were on the board, weren't you?

A. I was, yes, sir.

Q. Who else was on the board?

A. Mr. Allen Stanford, Mr. James Stanford, Mr. Bill

Goswick.

Q. Stop. Let's do them one at a time.

A. Yes, sir.

Q. James Stanford?

A. Yes, sir.

Q. Tell the jury who he is.

A. That's Allen Stanford's father.

Q. So he was on the board of Stanford International

Bank?

A. Yes, sir.

Q. And what role did he play on the board?

A. He was originally the chairman, and then following

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3376

years, he became chairman emeritus.

Q. Now, I believe you told the jury that the fraud was

going on in 1999; right?

A. Yes, sir.

Q. And, so, let's jump back to the board for a minute.

Mr. James Stanford was on the board and chairman of the

board; correct?

A. Emeritus. Mr. Allen Stanford was chairman of the

board at this time.

Q. In '99?

A. I believe so, yes.

Q. Before that, it was his father, James Stanford?

Let's focus --

A. Yes, sir.

Q. -- on '99.

A. Okay.

Q. So do you remember who was chairman?

A. I believe it was Allen Stanford.

Q. Believe it --

A. Yes, sir.

Q. Besides yourself -- you got yourself and you've got

James Stanford, you've got Allen Stanford. Who else?

A. Bill Goswick.

Q. Now, who is Mr. Goswick?

A. Was a businessman from Central Texas.

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3377

Q. Did you know him?

A. Yes, sir.

Q. And how long had you known him before you were on the

board?

A. Three or four years.

Q. And what kind of business was Mr. Goswick in?

A. I believe he was in automobile sales business and

cattle ranching.

Q. Do you know anything else about his background other

than cattle and automobiles?

A. No, sir.

Q. Who else was on the board?

A. Don Caldwell.

Q. Tell us who Mr. Caldwell is. Actually, Judge

Caldwell; right?

A. He was a judge.

Q. And tell the jury about Judge Caldwell.

A. I met Judge Caldwell. I knew him. He was on the

board.

Q. How long had you known him?

A. Same amount of time I had known Bill Goswick.

Q. Okay. And had these guys, Goswick and Caldwell, been

around a while? Were they young men, middle-aged men,

elderly men?

A. Late middle age.

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3378

Q. Late middle age?

A. Yes, sir.

Q. Okay. Who else was on the board?

A. Kenneth Allen.

Q. And tell us who he was.

A. Mr. Allen was a barrister, solicitor, in the Western

Indies -- West Indies.

Q. Do you understand what a barrister and solicitor --

A. That's the equivalent in many respects to our

attorney --

Q. Okay.

A. -- in the United States.

Q. So he's really a British lawyer; right?

A. In the British system, yes, sir.

Q. So that's the Stanford board of directors in 1999;

right?

A. Yes, sir.

Q. And you say that the fraud was up and running in

1999; right?

A. Yes, sir. I know it was.

Q. You know it was because you were committing the

fraud, weren't you?

A. We, we, not you, we, Mr. Stanford --

Q. Yes, sir.

A. -- myself.

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3379

Q. We have to believe you to believe that, don't we?

A. Just follow the money. If you don't believe me --

Q. We're going to talk about that. We've got plenty of

time.

A. Good.

Q. We're going to talk about that a lot.

A. I'm ready for that, sir.

Q. Mr. James Stanford was on the board. Was he a crook?

A. I don't know.

Q. You don't know? Well, you say that it was you and

Allen Stanford that were perpetuating this fraud or

conducting this fraud --

A. Yes, sir.

Q. -- in 1999?

And this information and the annual report

had to be run by the board of directors; right? They

demanded that it be prepared and published; right, the

board, that's part of what they do?

A. It's part of it. They require it.

Q. So was Mr. James Stanford a crook, part of the fraud?

A. I don't know. Not to my knowledge.

Q. How about the judge, was he also a crook?

A. No, but Mr. Stanford was and I was. We were on the

board.

Q. And how about the British lawyer, was he a crook,

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3380

too?

A. No. But Mr. Stanford, the chairman was; I was, CFO.

Q. So it's your testimony that the board of directors

that reviewed this information and this annual report of

all the people on the board, only two of you were crooks?

A. Yes, sir.

MR. SCARDINO: Let's go to Page 12 of this

exhibit, please.

Wow, that's hard to read.

THE COURT: It will improve, I think.

MR. SCARDINO: I'm not sure my eyesight will,

though.

BY MR. SCARDINO:

Q. Can you see that, Mr. Davis?

A. I believe so.

Q. You can?

Okay. Let's look at the top line. What

does that say?

A. "Profit and loss statement for year ended 31 December

1999. Expressed in U.S. dollars."

Q. What is a profit and loss statement?

A. Captures the revenues from sales, less the expenses

that generated those sales, and the result is profit

hopefully, the difference between revenue and expenses.

Q. Okay. And it goes down -- one of the items that's

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3381

referred to is operating income; correct?

A. Yes, sir.

Q. And then it has a list of topics. And then across to

the right, it has some numbers that for 1999 it shows

interest and noninterest income 81,603,329; correct?

A. Yes, sir.

Q. And so forth and so on?

A. It's not, correct, though, it's a lie.

Q. That's what it says here, though; right?

A. It does say that, yes.

Q. It's your testimony that it's a lie; is that correct?

A. It is my testimony this is a lie, yes.

Q. And let's just go to the bottom of that line of

numbers that talks about operating profit it says is what?

A. 3.8 million.

Q. Say it again.

A. 3.8 million.

Q. 3.8 million.

Who prepared this Page 12 of this report,

Mr. Davis?

A. The Stanford Financial Group accounting department

under Mr. Gill Lopez as approved by myself and

Mr. Stanford.

Q. Let's see if we can get to the bottom of where these

numbers came from. Who gave Mr. Gill Lopez these figures?

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3382

A. They would have been generated through the accounting

transactions during each month.

Q. So I thought you said that the numbers on here are a

lie?

A. The numbers are intact through the transactions

during the month --

Q. Let's stop you there. Let me stop you there --

A. Yes, sir.

Q. -- Mr. Davis. Now, I'm confused. I thought -- when

I first started talking to you about this annual report,

it's talking about numbers, you said the numbers are a

lie, did you not say that?

A. Yes, part of the numbers are correct, the overall

effect of what you asked me about originally. Profit and

loss statement is a lie. There is no profit.

Q. Who phonied up that number?

A. I phonied up the number at Mr. --

Q. And let me stop you there.

A. -- Stanford's direction.

Q. Let me stop you right there.

A. Yes, sir.

Q. The guy that phonied up that number --

A. Yes, sir.

Q. -- is you; right?

A. At Mr. Stanford's direction.

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3383

Q. We have to believe you to believe that, don't we?

A. You said the whole truth when I came in here. I'm

telling you the whole truth.

Q. Yes.

A. He directed me from the very beginning. He took the

550 million.

MR. SCARDINO: Responsive. Object.


MR. SCARDINO: Ask the Court to instruct the

jury to disregard the --

THE COURT: Disregard it.

Please answer just the questions that you

asked. If there's any need for follow-up, I'm sure the

government will follow up if they feel it's necessary.


THE COURT: Go on.

BY MR. SCARDINO:

Q. So back in 1999, the guy that actually put his hand

on the page and put the phony number down was you?

A. At Mr. Stanford's direction.

THE COURT: No, sir. No, sir. If it was you

who did it, then the answer is yes. If it's no, no. If

you can't answer it yes or no, so be it. We understand

your theory of the case --


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3384

THE COURT: -- which basically is the

government's theory of the case. And I'm not saying --

that's the jury decision, okay? But you need -- it's very

frustrating, I understand that. It happens in every case.

You need to answer yes or no. If you can't answer yes or

no, let me know. I'm sure the government's attorney is

making notes, and if they need to follow it up, they'll do

it on redirect.

Next question, please.

THE WITNESS: I apologize, Your Honor.


BY MR. SCARDINO:

Q. So it wasn't any other member of the board that did

this, was it?

A. No, sir.

Q. It wasn't Mr. Lopez that did it, was it?

A. No, sir.

Q. It wasn't Mr. Kuhrt that did it, was it?

A. At my direction.

Q. You're the one that came up with the phony number?

A. Yes, sir.

Q. Do you have the documents, Mr. Davis, that would have

the correct number?

A. No, sir.

Q. Where are they?

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3385

A. I don't know where they are, sir.

THE COURT: Let me ask you this: Are they in

existence at all?

THE WITNESS: Yes, sir, they are.

BY MR. SCARDINO:

Q. Yeah, they would almost have to be, wouldn't they?

A. Yes, sir.

Q. Yes, sir.

Where are they? Tell us where they are,

Mr. Davis.

A. The accounting records.

Q. Where are they?

A. In the computer, wherever the computer media is.

Q. Well, did you work with the government prosecutors to

try to find the real records so that these juries could

compare them with the phony one that you cooked up? Did

anybody make any effort to try to find that?

A. I'm sure they did.

Q. You're sure they -- well, did you discuss it with

anybody?

A. I was asked questions for three years. I answered

them.

Q. Nobody from the FBI asked you that question,

Mr. Davis, "Where are the real documents?" They never

asked you that?

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3386

A. Not in those words, no.

Q. Nobody -- no lawyer for the government asked you that

question in preparing you to testify here in front of this

jury?

A. No, sir.

Q. What did you do with the real documents after you

decided to dummy-up the report that we're looking at here?

What did you do with the real documents? Did you throw

them in the lake?

A. There are no real documents beyond what we've

discussed in this courtroom, Tier 1, Tier 2, those are the

real documents.

MR. SCARDINO: Nonresponsive. Object.

THE COURT: Overruled. Overruled as to that

response.

MR. SCARDINO: Let's go to the next page.

Let's go to the bottom of the page.

BY MR. SCARDINO:

Q. It says, "Approved on behalf of the board," doesn't

it?

A. Yes, sir.

Q. That's your signature?

A. Yes, sir, it is.

Q. Director and chief financial officer?

A. Yes, sir.

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3387

MR. SCARDINO: I'm going to move to another

topic. You can take that down.

BY MR. SCARDINO:

Q. You testified on direct examination when

Mr. Stellmach asked you about a computer and a thumb drive

that you threw in a lake. Do you remember talking about

that?

A. Yes, sir.

Q. And whose computer?

A. It was mine.

Q. I mean, was it a laptop or a desktop or what kind of

computer?

A. There were two. It was a laptop and a tower.

Q. So there were two computers?

A. Yes. There was a personal computer, and a laptop

corporate computer.

Q. Okay. I'm not very computer literate, so let me --

walk through this a little bit.

There was a laptop, right, like this --

like this?

A. Yes, sir.

Q. One that looks something like this?

A. Yes, sir.

Q. You took it and threw it in the lake?

A. I did.

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3388

Q. Okay. I mean, were you standing on the shore, were

you in a boat, or what? Tell me about it.

A. I was standing on the shore.

Q. Standing on the shore.

I mean, was it near a place that you were

familiar with or -- like, your home?

A. Yes, sir.

Q. Near your home?

A. Yes, sir. Right in front of my house.

Q. Front of your house.

You have a lake in front of your house?

A. I did.

Q. Okay. Wow. Okay. How big a lake?

A. 7 acres.

Q. Was it your lake?

A. Yes, sir, mine and my wife's.

Q. Did you have a boat?

A. I had a 12-foot aluminum fishing boat, yes, sir.

Q. And you had a second computer. What kind of

computer? Was it one like you see sitting on desktops?

A. No, it was like the old kind you see sitting on the

floor.

Q. Sitting on the floor?

THE COURT: You mean -- what is it, a CPU?


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3389

THE COURT: The rectangle block on the floor --


THE COURT: -- versus that's the screen and on

the desk --


THE COURT: -- is the computer?


MR. SCARDINO: I don't know what a CPU is.

THE COURT: The central processing unit --


THE COURT: -- that's where the guts are. In

other words, you have a screen here and the guts in the

box.

BY MR. SCARDINO:

Q. Okay. Would you mind stepping down and giving us a

little bit of a -- how big this item was?

A. No, sir, I don't.

Q. You don't mind or --

A. (Indicating.)

Q. So you're indicating is about what, I don't know,

2 feet off the ground and how wide?

MR. STELLMACH: 18 inches.

THE WITNESS: I think.

BY MR. SCARDINO:

Q. About 18 inches wide?

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3390

A. No, 18 inches --

MR. STELLMACH: 18.

THE WITNESS: -- long.

BY MR. SCARDINO:

Q. You're showing it's so high and so wide; right?

A. 2 feet by 6 inches by 12 inches.

Q. All right. So that was something that you kept at

your desk?

A. At my house.

Q. At your house.

And it stored information?

A. Yes, sir.

Q. And did you have a screen that goes with that?

A. Yes, sir.

Q. And a key pad?

A. Yes, sir.

Q. Were they three separate things?

THE COURT: You mean this key pad --


THE COURT: -- big unit and the screen?

MR. SCARDINO: That's correct.

THE COURT: All right. I want to stop the

clock for a minute. Let's stand up. We've got about --

we're going to go to about 6:05. Be a good time to shake

out some of the cobwebs that are there.

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3391

(Brief recess)

THE COURT: Everybody ready? Let's continue.

BY MR. SCARDINO:

Q. So how long had you had this desktop computer,

Mr. Davis?

A. Several years.

Q. Several years.

Was it your personal computer?

A. It was my family's, yes.

Q. I mean, did you have some password to get in it?

A. Probably not.

Q. Well, I mean, did it or not? Do you recall?

A. I said probably not. I don't recall. I don't recall

ever using a password on it.

Q. How about the laptop?

A. No, sir.

Q. No password?

A. Well, it had a password if I entered the corporate

Oracle IT system, but just to use it away from that

system, no.

Q. Oracle was a system that you had designed to put in

place to keep track of employees and their sales, wasn't

it?

A. No, sir, it was not. I had nothing to do with the

installation selection of that.

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3392

Q. It was your idea to do it, though, wasn't it?

A. No, sir.

Q. It wasn't?

Oracle wasn't your idea?

A. No, sir.

Q. Okay. So how long had you been storing information

on the desktop computer?

A. Old as the computer was, maybe three, four years.

Q. And what kind of information did you store on that

computer? Was it personal?

A. It was.

Q. Was it business?

A. No, sir.

Q. Just personal?


Q. Okay. How about the laptop, how long had you had

that?

A. I would say no more than four years.

Q. Okay. So you had it a little longer than the

desktop?


Q. Okay. And what kind of information did you store on

that? Was it personal?

A. There was a lot of personnel, yes.

Q. Any business?

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3393

A. There was some business. Most of the business was

stored on the Oracle IT system that's corporate.

Q. Now you've confused me, Mr. Davis. Let's go back and

try to get it straight. Everything on the desktop was

personal; right? Isn't that what you just told us?


Q. And then stuff on the laptop was personal and

business?

A. There were some business files, letters,

communications on file there for business.

Q. Yes, sir. And if I recall on direct examination, you

talked about another device that you threw in the lake

other than those two computers. What was it?

A. Yes, sir. It was a media device that's called flash

drive.

Q. Yes, sir.

A. It plugs in and you store information on it.

Q. Okay. And, so, was that used on the desktop or the

laptop?

A. Laptop.

Q. Laptop.

And you stored information on that in

addition to the other data that you stored?


Q. Did you store personal information on the thumb drive

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3394

or business information?

A. Business information.

Q. Business.

A. Okay.

Q. All right. And you threw all of this in the lake?

A. That's correct.

Q. And approximately when did you throw it in the lake?

A. January of -- January and the first week of

February '09.

Q. It took you a couple of weeks to throw it in the

lake?

A. It was a day in that period --

Q. Oh, I see.

A. -- one of the weekends.

Q. Okay. You threw them all in at the same time?

A. It was probably on the 6th -- the 8th, I believe the

8th of February.

Q. This was after you had taken the $990,000 from

Mr. Stanford; right?

A. It's after the loan that was agreed to between

Mr. Stanford and myself, yes.

Q. And what kind of business information did you store

on the laptop?

A. E-mails, sometimes copied. Copies of some

correspondence. And on the flash drive was the -- I

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3395

believe that was the so-called IB5, a piece of the report

that went to the regulators --

Q. Did --

A. -- at Antigua.

Q. When you -- the information that you stored on the

laptop and the flash drive, you said there was some pieces

of correspondence; right? Like e-mails?

A. I believe there were some e-mails saved, yes.

Q. And some documents that might have been generated for

regulators?

A. On the flash drive, yes, sir.

Q. Okay. And, so, you would still have access to that

data, wouldn't you?

A. At that time.

Q. Now, when you -- I believe Mr. Stellmach asked you on

direct that -- didn't you turn -- didn't you inform the

government of that, just right away that you had destroyed

evidence; right?

A. That's pretty soon, yes, sir.

Q. As part of your plea agreement, you're not going to

be charged with destroying evidence or obstruction of

justice? Is that part of your plea agreement?

A. That was not one of the counts I was charged with.

Q. Nobody -- nobody talked to you about you wouldn't be

charged with that if you cooperated?

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3396

A. No, sir.

Q. But that's what you did, though; right?

A. What did I do?

Q. Destroyed evidence?

A. Yes, sir.

Q. When you told the government that you had done

that -- and I've looked at the report that you -- where

you -- that's revealed to the FBI, can you tell us what

efforts were made by the FBI to reconstruct that

information so we could see what you were trying to hide?

A. The efforts that they made, they made an effort to

retrieve the --

Q. No. No. It wasn't an artfully drafted question.

I'm not talking about what they tried to

get after they retrieved the computer. I'm talking about

what could have been reconstructed from the information

that you had put on the computer.

You got an e-mail either on the computer

or you transferred it and stored it there on the thumb

drive or your laptop; right? So there was a source of

information out there where we could go look to see what

you were trying to hide; correct?

A. I don't understand your question.

Q. Well, didn't you tell us that what was on that

computer were pieces of communication?

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3397

A. Yes. Generally, I think so. I don't know which

ones.

Q. So the information was generated from a source

outside of the computer, wasn't it?

A. I would have received from somewhere else, yes.

Q. So did you sit down with the FBI to try to

reestablish -- try to establish the source of that

information so that the FBI could see what you were trying

to hide to determine whether they wanted you as a witness

or not?

A. I appreciate the level of your question. I can hear

that very clearly.

Q. Yes, sir. I hope so.

THE COURT: You did not hear it very clearly?

THE WITNESS: I did. It was good.

THE COURT: Okay. Go right ahead.

THE WITNESS: Almost too much. But --

I'm still -- you know, it must that age

that we're talking about, sir. I need the question one

more time.

BY MR. SCARDINO:

Q. I'll say it.

THE COURT: Do you want it read back?

MR. SCARDINO: Sure.

(The requested question was read)

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3398

THE WITNESS: I told them where I thought the

source -- the sources came from, which would have been

the -- through the IT system at Stanford Financial.

BY MR. SCARDINO:

Q. Fair enough. Did they get the information and ask

you: Is this what you had on your computer, Mr. Davis?

A. I don't know whether they got the information or not.

I don't remember the question regarding --

Q. It certainly doesn't appear in any of your interviews

with them, does it?

A. I don't know.

Q. Okay. So nobody tried to find out what you were

trying to hide when you threw those computers in the lake;

right?

A. I received a lot of questions about it.

Q. But nobody tried to recreate what was in that

computer, did they?

A. I don't know.

Q. Not that you know of?

A. Not that I know of. I don't know.

Q. Nobody talked to you about it; right?

A. No, sir.

Q. Now, you told them what you thought was on it, but

nobody tried to verify it.

Did they believe you and just take you at

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3399

your word, Mr. Davis?

MR. STELLMACH: Objection.

THE WITNESS: I don't know, sir.

MR. SCARDINO: Withdrawn.

THE COURT: Hold it.

MR. SCARDINO: Withdrawn.

MR. STELLMACH: Asked and answered.

THE COURT: He's withdrawn it.

Go on.

BY MR. SCARDINO:

Q. Did they tell you they believe you?

A. I don't remember them saying that, no.

Q. It's been three years since you threw those computers

and that thumb drive in the lake, hasn't it, Mr. Davis?

A. Yes, sir, it has.

Q. And you know nobody else charged with this crime has

tried to hide evidence, don't you? Not Mr. Kuhrt? Not

Mr. Lopez? Not Ms. Holt? You know that?

MR. STELLMACH: Objection to what he knows.

THE COURT: Do you know that, sir?

MR. SCARDINO: If he knows.

THE COURT: Do you know that or not?


BY MR. SCARDINO:

Q. No. Nobody's given you information. When talking to

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3400

these government prosecutors, nobody said, "Oh, my

goodness, Holt did the same thing." Nobody's told you

that, have they? That she was trying to hide something

just like you were trying to hide?

A. I don't remember that, no, sir.

Q. Or Mr. Kuhrt or Mr. Lopez? Nobody's confronted you

with, "Hey, what were you guys sharing that you all wanted

to hide?"

You hadn't been confronted with that, have

you?

A. I've been asked questions about what was there on the

media.

Q. That's not my question, Mr. Davis.

A. Sorry. I apologize. Go ahead.

Q. That's quite all right.

You're the only one that tried to hide

evidence, aren't you?

A. I panicked and I threw those in the lake.

Q. I do believe you described yourself as a coward when

you first took the witness stand.

Do you remember that?

A. I was.

Q. Is that still true?

A. I would say absolutely not.

Q. Not a coward anymore?

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3401

A. I don't think so, no.

Q. You testified on direct examination that one of the

persons that was involved in the Stanford empire was the

chief investment officer, a woman named Laura Holt. Is

that right? Or Laura Pendergest Holt?

A. Yes, sir.

Q. And -- now help me with this. Sometimes age does

affect your memory a little bit.

Did you tell the jury on direct

examination that you had met this woman -- where did you

meet her?

A. I met her in Baldwyn, Mississippi, in a college and

career Bible class.

Q. In a Bible class?

A. Yes, sir.

Q. What were you doing in a Bible class?

A. I was teaching it.

Q. You were teaching a Bible class?

A. Yes, sir.

Q. How long had you been doing that, Mr. Davis?

A. A number of years.

Q. How many years?

A. Two.

Q. Okay. And was it at a church that you were a member?

A. Yes, sir.

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3402

Q. In fact, you were more than just a member of the

church, weren't you?

A. No, sir. I was a member.

Q. Weren't you an elder in the church?

A. No, sir.

Q. Were you ever an elder in a church?

A. I was.

Q. Not this church?

A. Correct.

Q. Was it before this church or after this church?

A. After.

Q. So you worked your way up in the church as an elder,

an example to others; right?

A. I was an elder later, after that time.

Q. Okay. So you're teaching this Bible class in the --

what was the name of the church in Baldwyn?

A. First Baptist Church.

Q. First Baptist Church.

And were you were teaching the class with

anybody else?

A. My wife.

Q. Is she in the courtroom?

A. No, sir.

Q. Okay. And that's where you met Ms. Holt.

And what was she doing there?

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3403

A. She was taking that class along with other people.

Q. How old was she?

A. I believe she was 20, 19 or 20.

Q. Is it possible she was considerably younger than

that?

A. No, sir.

Q. How long after you met her did you start the illicit

relationship with her?

A. Eight years.

Q. Eight years later?

A. Yes, sir. Approximately.

Q. Well, how old was she when you hired her?

A. Have to think about the year she was hired.

Q. Makes you a lot younger than 19 when you met her,

doesn't it?

A. No, sir. If you'll pause, I'll answer your question.

Just give me a moment.

Q. Think about it because I want to get through this

before we run out of time.

Your current wife, Ms. -- Mrs. Davis, is

not your first wife, is she?

A. No, she's not.

Q. In fact, you were married to a woman named Ruth

originally, weren't you?

A. Yes, I was.

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3404

Q. And when you were married to Ruth, you had two

children, didn't you?

A. Yes, sir.

Q. Two boys?

A. Yes, sir.

Q. In fact, the boys that you got involved in this

business, aren't they? Same boys?

A. My oldest son.

Q. Okay. Zach?

A. Yes, sir.

Q. Okay. And you had those two children with Ruth, and

you met Lori while you were married to Ruth, didn't you?

A. Yes, I did.

Q. And what -- how did you know Lori, when you were

married to Ruth?

A. She worked at the same company in the same department

that I worked in.

Q. She wasn't your babysitter?

A. No, sir.

Q. Was did ever -- she ever work in your house as a

babysitter?

A. I believe so, couple of times. Yes.

Q. So she was -- worked as a babysitter and maybe worked

in a company that you were familiar with, but how old was

Lori when you met her?

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3405

A. 17.

Q. 17?

A. Yes, sir.

Q. And she was a babysitter.

Did you start a relationship with her?

A. I did later years, yes, sir.

Q. While you were still married to Ruth?

A. I was separated, but I was married, yes, sir.

Q. Well, are you telling this jury that's not -- that's

not what broke up your marriage to Ruth?

A. Yes, sir, that's what I'm telling you.

Q. Wasn't Ruth very upset over your relationship with

Lori?

THE COURT: Is it Lori or Laura?

MR. SCARDINO: Lori, L-O-R-I, is his current

wife. L-A-U-R-A is the girlfriend.

THE COURT: Okay.

BY MR. SCARDINO:

Q. So you met Lori, your current wife, while she was

babysitter while you were married to Ruth?

A. I met her at work, as I said before, where I was

working.

Q. How old was she?

A. 17.

Q. 17. And you started a relationship with her?

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3406

A. Yes, sir, years later, as I said.

Q. You deceived your wife, didn't you?

A. I don't think so. I wasn't at home with my wife at

the time.

Q. You lied to Ruth about Lori, didn't you?

MR. STELLMACH: Objection. Asked and answered.

The witness has said he was separated.


BY MR. SCARDINO:

Q. Your marriage to Ruth ended. Isn't that correct?

A. It did.

Q. And you married Lori?

A. Yes, sir.

Q. And you had two more children; is that correct?

A. Yes, sir.

Q. And are you telling this jury that your marriage to

Ruth was such that Ruth wasn't upset with your behavior?

MR. STELLMACH: Objection, Your Honor, as to

the relevance of this.


MR. STELLMACH: Soap opera.

THE COURT: They got the message.

MR. SCARDINO: They talked about his

relationship with Laura Pendergest Holt.

MR. STELLMACH: Because it had a limited

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3407

purpose for purposes of this trial.

BY MR. SCARDINO:

Q. I guess the point, Mr. Davis, is that you're willing

to deceive and betray people, aren't you?

A. No, sir.

Q. You weren't willing to betray your first wife Ruth?

THE WITNESS: Your Honor, this is a question

that involves more than yes-no to betrayal.

MR. STELLMACH: I object.

THE COURT: On what grounds?

MR. STELLMACH: Relevance to this entire line

of inquiry.

THE COURT: I'm not going to say I sustain it

on relevance, but do you have any other objections.

MR. STELLMACH: As to form.

THE COURT: What else?


THE COURT: Asked and answered. I think we're

there already. All right?

So if there's any question you need to

ask, fine; otherwise, you may move on, Counsel.

BY MR. SCARDINO:

Q. Well, then you betrayed Lori, didn't you?

A. Yes, I did.

Q. You did. You betrayed her with this Ms. Holt, didn't

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3408

you?

A. I did.

Q. And then you betrayed Ms. Holt, didn't you?

A. How is that, sir?

Q. Well, you had a relationship with another person

while you were married to Lori and Holt was your

girlfriend.

MR. STELLMACH: Objection, Your Honor.

THE COURT: What?

MR. STELLMACH: Again, as to the relevance of

this.

THE COURT: I'm not saying it's not relevant;

okay? But I think we've heard it, and the jury give it

whatever weight it thinks applicable in this case.

Now we can move on a bit, please.

BY MR. SCARDINO:

Q. Do you know who Heather Shepherd is?

A. Yes, sir.


Mr. Davis's relationships.

THE COURT: Have we talked about Ms. Shepherd?

MR. STELLMACH: Personal assistant. I don't

know if we have yet; but again, the relevance of his

relationship.

THE COURT: Why don't you ask generally did he

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3409

have other relationships.

BY MR. SCARDINO:

Q. How about having a relationship with Heather

Shepherd?

A. Yes, sir, I did.

Q. You did. And that's Laura's cousin, Laura Holt's

cousin, isn't it?

A. Yes, she is.

Q. So you've betrayed everybody you've had a

relationship with so far, haven't you?

A. Yes, I have, committed adultery. I was a hypocrite,

and I lied.

Q. Yes, sir. How about Tamarin Lindenberg? Do you know

who that is?

A. I sure do.

Q. Who is that?

A. Outside consultant.

Q. You had a relationship with her, too, didn't you?

A. I did not.

Q. Let's shift gears, Mr. Davis.

MR. SCARDINO: Your Honor, this next topic is

going to be a little lengthy.

THE COURT: Okay. I think we can then adjourn

for the day. Let me stop the clock. Hang on one second.

Ladies and gentlemen, completes the

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3410

testimony for today. We'll see you tomorrow ready to

resume at 10:00 a.m.

Thank you and good afternoon.

(The following was held out of the presence of the jury)

MR. SCARDINO: Before you leave the bench,

we've got a matter for take up --

THE COURT: Okay.

MR. STELLMACH: Ex parte.

MR. SCARDINO: No, no, no. It's definitely not

ex parte.

MR. SCARDINO: It's "parté."

THE COURT: Okay. We're going to continue to

see what you have on your mind. Keeping it going.

Yes, sir, what do you want to talk about.

MR. FAZEL: Do you want me to go first?

MR. SCARDINO: You're the one that knows.

MR. FAZEL: Two issues: One that we need to, I

think, approach with the government. The other is: During

Mr. Scardino's cross-examination regarding the affairs, if

you will, of Mr. Davis, Mr. Costa blurted out in front of

the jury, "What about Mr. Stanford's girlfriends?"

I would object to that sidebar comment.

Mr. Costa knows better, not to do that in front of the

jury. I'd that the Court admonish him not to do that and

I'm going to ask for a mistrial.

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3411

MR. STELLMACH: I didn't hear the comment. I

was sitting closer to Mr. Costa than anyone. But --

THE COURT: First, we need to determine whether

or not it was said.

MR. FAZEL: I'm telling you as an officer of

the Court.

THE COURT: Sure. Mr. Costa.

MR. COSTA: I did mumble something. I'll

agree. And I find it quite audacious to make that attack

that somehow is a problem when Mr. Scardino now by four

counts, four times since this trial began, has violated the

motion in limine.

THE COURT: Like?

MR. COSTA: About the TARP funds. He did it

again today. He did it in opening statement. He did it

twice last week. And I told him last week, and he played

this, Oh, I'm old and dumb thing. And he was reminded at

that point, though. So he's had multiple warnings. About

that was actually in front of the jury, I doubt anyone

could hear my --

THE COURT: Well, we're going to go one thing

at a time.

Now, you were sitting there. Which way

were you facing? Away from the jury or toward the jury?

MR. STELLMACH: Away from the jury? Just like

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3412

this, basically.

THE COURT: All right. Well, I'm not going to

get -- all right. And you want a mistrial?

MR. FAZEL: I do.

THE COURT: Motion for mistrial is denied.

MR. FAZEL: And for the record, Your Honor, my

law partner is not old nor dumb?

MR. COSTA: I agree. That's his excuse when he

clearly violates Court orders.

MR. SCARDINO: I didn't say I was old and dumb.

THE COURT: Do you want a judicial finding on

that? Put him in your findings of --

MR. SCARDINO: Mischaracterization on

testimony.

THE COURT: Put him in your findings of fact

and conclusions of law, if any.

MR. COSTA: He also said he was past the bell

curve on being wise.

THE COURT: And on the other aspect that, in

other words, relative to TARP funds. You need to approach

the bench, not immediately perhaps, but at an appropriate

time, because I need it in context and if necessary have it

read back. But I'll keep watch on it. Next time you hear

anything like that, ask to approach the bench.

Yes, sir?

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3413

MR. FAZEL: The other matter, Your Honor, is

actually one that, believe it or not, the government and we

agree on; that is, the matter one of our experts that we

anticipate will be testifying has now obtained a position

with Navigant Consultant.

I don't want to go into the details of the

soap opera that's been our experts; however, Navigant

Consultant is part of the experts used by the receiver. We

obtained this expert prior to him moving to Navigant

Consultant.

MR. STELLMACH: I think with respect to --

Mr. Fazel may be mistaken. Navigant has been retained by

the Justice Department to provide some support work.

One of the new hires by Navigant, this

outside consultant, is one of the experts that they've

retained. We understand that Navigant has created a wall

and screened this new individual off.

THE COURT: The aspect of the Chinese Wall?


THE COURT: I mean, the theory of the Chinese

Wall.

All right. You're just bringing it to my

attention?

MR. FAZEL: All the government and the defense

lawyers, we all wanted to bring it -- put it on the record,

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3414

but we retained this person prior to them joining Navigant.

And given the timeframe that we're in court and trial, the

fact that he's done work and has already turned in a

report, nobody has any objection to it. We just want to

put it on the record for the Court to know that.

Did I get that right?

MR. STELLMACH: Yes.

There is one other housekeeping matter,

Your Honor.

We anticipate on the current rate, knock

on wood, we'll rest on sometime early next week. We were

wondering about the schedule for the defense to turn over

their exhibits. That's been a topic that's been a little

up in the air given issues as they've developed in the

trial.

THE COURT: What about that.

MR. SCARDINO: I'm sorry. I had his attention.

MR. FAZEL: That's correct. We were told

today, Mr. Costa was kind enough to tell us --

THE COURT: Everybody be seated. I'm sorry.

MR. FAZEL: -- today that they most likely will

rest next week sometime. They anticipate early next week,

Tuesday or Wednesday of next week. We think, given our

cross-examination, it might be a little lengthier than

that.

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3415

As the Court knows on an ex parte matter,

we are in the process of obtaining that. And we know that

as soon as they rest, then we need to provide them with our

witness list and what we anticipate their time being.

THE COURT: By the way, I cannot require you to

put down relative to Mr. Stanford. If you want to, you

can; but you're not required to.

MR. FAZEL: Right. Yes, sir.

We are diligently working on getting that

together. As a matter of fact, we did some work today.

Mr. McGuire was outside of the courtroom getting some of

that done. Mr. Parras is also helping us with all that.

And all we can say is we'll get it to them as soon as and

as quickly as we can.

MR. STELLMACH: That doesn't give me quite the

same amount of comfort given the rate by which we've been

getting the defense exhibits for cross-examination, the

night before or the morning of.

If we could have a hard and fast deadline

of when we can get the witness list, which I think is

something they're supposed to submit to us at the end of

our case. And then when we'll get our actual exhibits so

we can make any use of them. I mean, three days before

would seem -- I think that's the bare minimum.

THE COURT: Any problem with three days before?

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3416

MR. FAZEL: Before they rest?

THE COURT: Oh, before you rest?

MR. STELLMACH: Well, for the first couple of

witnesses that they'll be putting on, three days before.

We've been providing --

THE COURT: You wanted three days -- at least

three days before each witness?

MR. STELLMACH: That's right. Which is less

than half the time in which we were giving them.

THE COURT: Any problem with that?

MR. PARRAS: I think there will be. I don't

want to misrepresent anything to the Court. We've -- we

are working on identifying who we will put on, and then the

next step will be to identify what exhibits. And my goal

will be to be get that to the Court at the time they rest.

I thought that would be two weeks from now and we had some

time.

With this short time, it's going to be

tough, Judge. But we will do our best --

MR. COSTA: We have told them for about a year

that it was going to be a three-week case.

THE COURT: All right. Now, if you can't work

it out, I'll make a ruling. And the ruling, you know, may

not -- may or may not be acceptable to the defense. But

they're entitled to that based upon what we've been

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3417

discussing.

Again, I don't put it off. I can rule on

it first thing tomorrow morning. I'm ready to do it now,

but I don't think there's a necessity to. Talk to each

other after I leave today, and if you can, I will rule

first thing in the morning or when it's brought to my

attention as to how many days in advance of the defense

witnesses I think it ought to be done. Much better if you

agree. If you don't, I'll rule on it.

Yes, sir.

MR. COSTA: Your Honor, can we go back to that

issue with the expert?

THE COURT: Oh, you mean --

MR. COSTA: With their expert having gone to

the consulting firm that the government's been using, I

think Mr. Stanford needs to decide that if he still wants

to use that expert, there needs to be an on-the-record

waiver by Mr. Stanford so he can't later say, "Oh, my

defense was prejudiced because my expert had gone to work

for the same firm."

THE COURT: That's not unreasonable.

MR. COSTA: So I think he has to decide either

does he want to still use the guy. If he does, he needs to

waive the conflict.

MR. FAZEL: If Your Honor would -- I understand

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3418

the government's position. If Your Honor would give us

tonight just after this hearing to discuss it with

Mr. Stanford, and we can probably do it on the record

tomorrow.

THE COURT: That's fine. When we get back in,

we can tell the jury it will be five minutes, and we can

get that done.

MR. SCARDINO: I need to get in the motion in

limine.

MR. FAZEL: Which motion in limine?

MR. PARRAS: Valuation.

THE COURT: I knew that was coming up.

MR. FAZEL: The government has filed a motion.

We have also filed a motion.

THE COURT: Also, I have pulled out the -- what

is it -- both of your instructions on what sort of mens

rea, so to speak, is required.

I came across one sentence that was

exactly the same. All right? When do you think you want

to get into the valuation question?

MR. SCARDINO: I'm going to guess before I pass

him late tomorrow -- late tomorrow morning, maybe early

afternoon.

THE COURT: All right. Why don't we do this:

I mean, I've -- we've been working on it. When do you want

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3419

to argue it? Because the jury is going to have to stay out

of court with -- what is it -- with the clock running.

What we might do is, when you're ready to get into it, we

will tell the jury and I'll do my old write it down, and

I'll talk to you when I come in later, and we'll just have

at it. It's not something we can get over in five minutes,

because it -- first of all, it looks like it's a close

question. Cases are going both ways. It's all shades of

gray. So I'm looking at the government, if you can -- and

don't assume anything. If you can see what -- what you

could be comfortable letting in and what you absolutely

want out. And I'm just not going to split the baby unless

I feel that it's the right thing to do.

But we're working on it, and we've got

some briefs and we've got the cases and we got both of your

theories on that.

So once again, if the defense can be

comfortable with something on valuation or if you need

everything in, the government says it's out a hundred

percent, so be it, or you can announce that tomorrow

morning also. And then when the time comes appropriate

that you need to go into it, we'll excuse the jury and

we'll have, you know, a short appellate argument on that

point. But we'll be ready for it.

MR. SCARDINO: Your Honor, if -- I can be

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3420

haphazard in my approach to cross-examination, and I do not

want to run afoul of the Court's ruling.

THE COURT: Sure.

MR. SCARDINO: So I would request that we maybe

try to have a resolution of this, more I think about it,

sooner than later so that I don't step into it.

THE COURT: When do you think?

MR. SCARDINO: If it's possible to do it -- I

hate to do it to you guys. If we can do it before I get

him back. If we can meet maybe tomorrow morning and see if

we can reach some agreement. If not, ask the Court for a

little time before we start testimony.

MR. COSTA: I don't know if you have hearings

scheduled beforehand. We'd be willing to come in at 9:30.

THE COURT: No. I've got -- I've got -- what

is it?

MR. COSTA: I don't want to take away from the

jury.

THE COURT: I've got a rearraignment tomorrow

morning. We'll take it out of their time. They're know --

they're very comfortable, in effect, with they hear that

the time is running; okay? So it makes it a lot easier to

keep them sequestered or give them half-hour break and tell

them they can go down and get a snack and come back up.

So I tell you what: 10:00 a.m. tomorrow,

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3421

make some announcements on these areas. And then if

necessary, we'll just keep them in there, or we'll get

going and we can do it before they come back or have an

elongated lunch break for them and we can sit and discuss

it. I mean, everybody needs -- you know, including really

the attorneys. I'd be glad to just forgo a whole lunch

hour, but that's -- you know, it's -- we're doing fine

time-wise on both sides; okay? So don't worry about a

clock running or the amount of gross time each side has.

Because the original estimate was about 26 days.

In other words, if you go five to five and

a half hours a day, and which we've been doing, which is

about the max you can get in. I'm not talking about going

beyond 6:00 o'clock. So we're doing all right. So don't

worry about the time running even though it will continue

running t. I don't think either one of you would be in the

danger zone of my siding down your side.

MR. COSTA: One more little issue, Your Honor.

THE COURT: Yes, sir. Go on.

MR. COSTA: We have a witness from China.

We're trying to juggle the schedule, but there might be a

situation where he would have to testify by Wednesday

morning.

THE COURT: Okay.

MR. COSTA: And if we're still with Mr. Davis,

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3422

given this issue with China travel, could we -- hopefully,

we'll be done with Mr. Davis. But if not, could we --

would it be possible to call him and then resume Davis?

THE COURT: How long had a witness is he?

MR. WARREN: Depends on cross.

MR. COSTA: Not much more than hour on direct,

and then whatever they've got.

THE COURT: Do you know who they're referring

to?

MR. FAZEL: I do now. It's Mr. Rossi. Yes.

THE COURT: All right. About how much would

you -- well, I forgot to look at what you -- did -- they

say they're taking an hour, how much time ballpark do you

need? Another hour at least?

MR. SCARDINO: Maybe -- we're going to have

some questions for Mr. Rossi.

THE COURT: All right. Couple of hours?

MR. FAZEL: Yes, Your Honor.

THE COURT: All right. So we're looking at

three hours.

When is he coming in?

MR. COSTA: Well, he's here now.

THE COURT: And when does he have to get back?

MR. COSTA: Well, right now, he's scheduled to

go to New York on Wednesday. We're trying to change that.

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3423

We're -- there is some wiggle room. We might be able to

deal with this ourselves. But in the event we can't change

all the flights, it's a backup of whether we could call

him.

THE COURT: There's a number of ways to handle

it. If you can't agree on it, I'll swear him in and keep

him here. Or say, if he wants to go to New York and comes

back on my order, or we'll get him before he gets back on a

plane to China.

MR. SCARDINO: That would be our choice, Judge.

THE COURT: All right. Again, I'm not putting

it off. We can do it all tomorrow morning, if you want.

Just before we get underway, we'll take care of it. All

right? And let them stay in there a while. They'll be

fine. Another half-hour, and they're going to get another

cup of coffee downstairs.

All right. Anything further from the

government tonight?

MR. STELLMACH: Nothing, Your Honor.

THE COURT: Anything further from the defense

tonight?

MR. FAZEL: No, sir.

THE COURT: All right. Everybody remain

seated. You're excused if you want to. I'm just going to

get the time for the attorneys, and we'll be adjourned for

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3424

the day. So we are officially adjourned.


COURT REPORTER'S CERTIFICATE

I, Johnny C. Sanchez, certify that the foregoing is a

correct transcript from the record of proceedings in the

above-entitled matter.

/s/_________________________Johnny C. Sanchez, CRR, RMR

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0

09-CR-342 [1] - 3143:4

1

1 [31] - 3146:14, 3179:24, 3181:1,

3181:2, 3182:25, 3183:2, 3183:4,

3184:16, 3185:14, 3185:15, 3185:19,

3191:24, 3194:7, 3194:13, 3195:6,

3195:18, 3196:9, 3207:6, 3207:17,

3207:19, 3238:21, 3254:18, 3255:1,

3255:8, 3255:13, 3283:15, 3284:9,

3323:18, 3328:3, 3333:20, 3386:11

1,500 [6] - 3217:25, 3218:4, 3218:25,

3219:21, 3222:17, 3223:9

1,532 [1] - 3218:2

1,600 [1] - 3218:1

1.5 [1] - 3180:1

1.6 [1] - 3360:14

1.7 [4] - 3188:4, 3224:25, 3225:3,

3261:7

1.8 [1] - 3360:12

1.9 [1] - 3360:12

1/2 [2] - 3166:11, 3289:17

10 [4] - 3194:24, 3205:25, 3342:17,

3359:16

100 [1] - 3230:11

1004 [1] - 3143:22

1018 [1] - 3144:3

10:00 [3] - 3245:4, 3410:2, 3420:25

10:07 [1] - 3143:6

10:30 [1] - 3245:4

10th [1] - 3282:18

11 [4] - 3143:8, 3175:23, 3176:11,

3193:25

11.87 [1] - 3202:22

112 [2] - 3289:9, 3373:13

11:30 [2] - 3205:24, 3206:2

11th [1] - 3194:16

12 [5] - 3166:23, 3304:10, 3380:7,

3381:19, 3390:6

12-10 [1] - 3366:24

12-31-08 [1] - 3369:9

12-foot [1] - 3388:18

12.7 [1] - 3167:7

12:00 [1] - 3205:25

13 [5] - 3166:11, 3166:23, 3303:20,

3304:10

13-83 [3] - 3362:7, 3362:12, 3362:15

13-84 [2] - 3368:9, 3368:10

13.48 [1] - 3202:23

138 [2] - 3202:5, 3221:20

14 [3] - 3167:7, 3295:18, 3303:20

1400 [1] - 3143:17

14th [1] - 3369:25

1511 [1] - 3313:4

1511-A [3] - 3312:25, 3319:15,

3372:11

1511A [3] - 3291:7, 3328:7, 3334:13

1515 [1] - 3323:15Johnny C. Sanchez, RMR, CRR - [email protected]

3425

1524 [1] - 3185:3

1525 [1] - 3187:2

1526 [1] - 3190:6

1527 [1] - 3193:25

1528 [1] - 3195:17

1532-C [2] - 3192:10, 3192:11

16 [5] - 3232:7, 3308:1, 3311:24,

3312:13, 3312:18

1603 [1] - 3180:7

17 [5] - 3232:7, 3405:1, 3405:2,

3405:24, 3405:25

173.6 [1] - 3194:11

18 [5] - 3203:14, 3389:22, 3389:25,

3390:1, 3390:2

18th [1] - 3288:18

19 [2] - 3403:3, 3403:14

1991 [1] - 3232:6

1992 [1] - 3232:6

1995 [5] - 3147:14, 3147:15, 3147:19,

3148:3, 3149:14

1996 [2] - 3149:14, 3290:3

1999 [9] - 3289:9, 3374:12, 3376:3,

3378:15, 3378:19, 3379:14, 3380:20,

3381:4, 3383:18

1:01 [1] - 3257:20

2

2 [40] - 3144:4, 3179:24, 3182:17,

3182:25, 3183:2, 3183:5, 3184:16,

3185:14, 3187:1, 3195:5, 3196:10,

3196:12, 3196:13, 3196:15, 3223:6,

3237:10, 3238:22, 3253:7, 3254:18,

3255:1, 3255:8, 3255:14, 3259:12,

3261:8, 3283:15, 3284:9, 3295:11,

3333:20, 3344:21, 3358:20, 3358:21,

3359:9, 3359:10, 3359:11, 3359:16,

3367:2, 3386:11, 3389:21, 3390:6

2.3 [1] - 3359:22

2.4 [1] - 3359:22

20 [7] - 3151:9, 3166:19, 3206:1,

3281:1, 3403:3

20-minute [2] - 3205:24, 3331:4

200 [1] - 3224:10

2000 [6] - 3161:2, 3161:5, 3161:7,

3165:23, 3167:4, 3173:20

20005 [1] - 3143:18

2001 [2] - 3344:19, 3344:20

2002 [1] - 3342:5

2004 [1] - 3159:22

2005 [4] - 3154:15, 3156:13, 3159:22,

3227:15

2006 [5] - 3173:20, 3174:1, 3174:10,

3227:15, 3360:13

2007 [5] - 3173:21, 3174:1, 3180:13,

3181:8, 3360:11

2008 [59] - 3146:20, 3147:2, 3150:14,

3161:2, 3177:11, 3178:10, 3180:14,

3180:24, 3181:8, 3182:7, 3182:8,

3182:9, 3182:21, 3184:5, 3187:3,

3187:13, 3188:23, 3190:8, 3190:14,

3192:21, 3193:4, 3194:1, 3195:18,

3196:2, 3198:4, 3199:21, 3202:6,

3202:13, 3202:20, 3203:15, 3209:11,

3215:2, 3216:15, 3220:8, 3221:20,

3227:14, 3227:16, 3228:15, 3228:17,

3250:1, 3250:4, 3250:19, 3255:4,

3292:17, 3301:18, 3314:15, 3316:18,

3330:8, 3337:9, 3338:8, 3358:19,

3359:3, 3359:8, 3359:23, 3361:13,

3364:24, 3365:4, 3366:7, 3371:25

2009 [17] - 3146:14, 3146:20, 3147:3,

3150:14, 3161:3, 3171:23, 3172:1,

3172:2, 3178:19, 3182:10, 3202:25,

3228:18, 3231:17, 3233:11, 3250:3,

3314:16, 3337:11

2012 [1] - 3143:5

21 [3] - 3294:20, 3330:7, 3371:19

21-year [2] - 3176:24, 3305:24

22 [1] - 3166:25

2283 [1] - 3368:2

22nd [1] - 3190:14

23rd [1] - 3191:13

25 [2] - 3255:2, 3281:2

26 [1] - 3421:10

26A [2] - 3236:3, 3236:6

28 [3] - 3202:20, 3364:24, 3366:6

2:00 [1] - 3162:6

2:15 [1] - 3257:18

3

3 [38] - 3184:18, 3239:10, 3239:25,

3240:17, 3248:7, 3248:11, 3249:4,

3249:25, 3253:23, 3254:8, 3255:12,

3256:5, 3257:6, 3258:10, 3258:21,

3259:10, 3259:25, 3261:14, 3261:18,

3261:20, 3262:13, 3262:14, 3264:10,

3265:9, 3266:16, 3266:19, 3266:23,

3274:25, 3275:3, 3275:14, 3282:10,

3283:4, 3283:16, 3284:12, 3284:15,

3333:20, 3359:9, 3359:12

3.1 [3] - 3188:4, 3224:4, 3252:1

3.173 [1] - 3223:4

3.2 [11] - 3216:12, 3216:18, 3217:1,

3217:6, 3217:20, 3218:5, 3218:11,

3224:3, 3224:14, 3224:18, 3252:10

3.8 [3] - 3381:15, 3381:17, 3381:18

30 [3] - 3193:19, 3250:1, 3348:19

300 [1] - 3326:22

30th [2] - 3250:4, 3250:19

31 [1] - 3380:19

3146 [1] - 3145:4

3296 [1] - 3145:5

332 [2] - 3247:22, 3285:23

35 [2] - 3191:18, 3191:21

3:52 [1] - 3331:8

3rd [1] - 3143:22

4

4 [2] - 3187:13, 3333:20

40 [1] - 3348:19

400 [2] - 3180:16, 3180:19

406.8 [1] - 3190:20

42 [2] - 3174:16, 3174:24

44 [1] - 3191:20

45 [3] - 3191:18, 3191:21, 3193:19

4:10 [1] - 3331:5

4th [1] - 3187:3

5

5 [8] - 3180:5, 3188:3, 3189:10,

3189:12, 3206:15, 3222:9, 3222:12,

3333:20

5,000 [3] - 3220:6, 3220:14, 3253:21

5.1 [2] - 3180:14, 3181:9

5.5 [3] - 3193:10, 3193:14

50.7 [1] - 3251:23

50/50 [1] - 3343:22

500,000-dollar [1] - 3312:23

51 [1] - 3261:14

515 [1] - 3144:12

541 [1] - 3202:19

550 [1] - 3383:6

58,000 [3] - 3365:1, 3365:2, 3365:10

6

6 [2] - 3143:5, 3390:6

6.3 [11] - 3248:7, 3249:25, 3252:1,

3252:20, 3253:22, 3255:11, 3255:20,

3258:10, 3259:2, 3259:6, 3264:10

6.6 [1] - 3180:3

60th [2] - 3203:20, 3203:21

61129 [1] - 3143:14

63 [2] - 3216:17, 3373:9

63-1/2 [6] - 3215:12, 3215:23, 3216:24,

3217:11, 3223:2, 3252:10

63.5 [2] - 3214:25, 3218:6

641 [1] - 3224:11

668 [2] - 3154:13, 3154:18

6:00 [2] - 3331:6, 3421:14

6:05 [1] - 3390:24

6:12 [1] - 3424:2

6th [1] - 3394:16

7

7 [2] - 3252:19, 3388:14

70 [1] - 3363:4

700 [1] - 3225:19

713.250.5581 [1] - 3144:13

726 [1] - 3236:13

733 [1] - 3225:10

741 [1] - 3224:22

75 [1] - 3281:5

77002 [3] - 3143:23, 3144:4, 3144:12

77208-1129 [1] - 3143:15

77279 [1] - 3144:7

79535 [1] - 3144:7


3426

8

8 [1] - 3359:6

801(D)(2)(d) [1] - 3229:20

81,603,329 [1] - 3381:5

85 [3] - 3151:12, 3185:20, 3186:18

88.2 [1] - 3195:24

880 [3] - 3328:10, 3330:20, 3372:14

880,000 [1] - 3293:18

8th [2] - 3394:16, 3394:17

9

9 [2] - 3154:15, 3359:6

900 [1] - 3330:20

900,000 [2] - 3358:14, 3358:16

990 [4] - 3370:14, 3370:15, 3372:19,

3372:21

9:00 [1] - 3247:14

9:30 [1] - 3420:14

A

a.m [5] - 3143:6, 3162:6, 3206:2,

3410:2, 3420:25

ability [1] - 3147:20

able [20] - 3148:3, 3148:14, 3182:17,

3182:22, 3203:10, 3242:1, 3245:5,

3246:25, 3247:3, 3288:15, 3290:11,

3294:5, 3310:9, 3317:5, 3321:24,

3322:12, 3327:4, 3327:23, 3337:18,

3423:1

above-entitled [1] - 3424:7

absolute [1] - 3300:9

Absolutely [1] - 3177:24

absolutely [6] - 3155:23, 3209:9,

3244:20, 3258:1, 3400:24, 3419:11

abstract [1] - 3155:21

abundance [2] - 3272:2, 3272:3

acceptable [2] - 3157:17, 3416:24

access [11] - 3174:4, 3176:20,

3211:10, 3327:4, 3356:21, 3356:23,

3357:15, 3357:21, 3360:8, 3374:23,

3395:12

accessed [2] - 3335:5, 3370:5

accordance [1] - 3324:13

according [10] - 3155:25, 3166:3,

3167:9, 3191:2, 3203:2, 3216:16,

3250:20, 3251:25, 3279:4, 3295:11

account [30] - 3186:3, 3186:5, 3186:7,

3186:9, 3194:10, 3212:18, 3322:23,

3323:7, 3326:21, 3327:24, 3335:23,

3355:7, 3362:24, 3363:5, 3363:13,

3363:16, 3363:24, 3363:25, 3364:2,

3364:15, 3365:9, 3365:12, 3366:20,

3368:18, 3369:3, 3369:5, 3369:8,

3370:11, 3372:5

accountant [2] - 3275:21, 3279:19

accountants [3] - 3176:11, 3176:19,

3197:16

accounting [29] - 3159:4, 3175:21,

3175:25, 3176:3, 3200:7, 3204:4,

3206:23, 3208:1, 3209:18, 3217:23,

3218:15, 3222:3, 3223:19, 3263:16,

3263:23, 3271:5, 3275:17, 3279:20,

3283:8, 3356:10, 3356:11, 3356:22,

3364:1, 3374:20, 3374:21, 3381:21,

3382:1, 3385:11

accounting-wise [1] - 3223:19

accountings [1] - 3187:18

accounts [19] - 3184:17, 3191:18,

3194:14, 3294:11, 3295:6, 3322:16,

3322:20, 3323:5, 3323:9, 3323:10,

3323:21, 3327:8, 3327:17, 3348:19,

3363:7, 3363:20, 3363:22, 3364:4,

3364:10

accurate [12] - 3253:12, 3254:10,

3274:15, 3276:10, 3276:11, 3276:25,

3277:7, 3281:16, 3281:17, 3288:25,

3289:7, 3342:12

accurately [2] - 3224:4, 3276:15

acquired [2] - 3210:24, 3216:23

acre [2] - 3217:4, 3223:7

acreages [2] - 3218:7, 3223:6

acres [10] - 3217:25, 3218:1, 3218:4,

3218:25, 3219:21, 3222:17, 3222:18,

3223:3, 3223:9, 3388:14

act [1] - 3347:21

acted [1] - 3347:19

acting [1] - 3270:5

action [8] - 3273:6, 3273:22, 3274:6,

3274:16, 3274:17, 3274:18, 3275:14,

3347:23

activities [1] - 3174:15

activity [1] - 3172:23

actual [10] - 3164:4, 3204:16, 3205:14,

3217:21, 3253:23, 3257:6, 3262:13,

3266:23, 3347:16, 3415:22

acute [1] - 3162:2

add [1] - 3203:6

added [1] - 3253:17

adding [1] - 3201:19

addition [6] - 3165:7, 3184:9, 3237:18,

3245:1, 3358:17, 3393:23

additional [7] - 3172:23, 3175:20,

3180:21, 3242:17, 3242:19, 3243:4,

3243:5

address [4] - 3165:24, 3277:20,

3286:12, 3323:7

addressed [1] - 3236:25

adjacent [2] - 3266:4, 3287:25

adjourn [1] - 3409:23

adjourned [2] - 3423:25, 3424:1

administrative [2] - 3189:14, 3363:25

admissibility [1] - 3213:6

admissible [2] - 3213:1, 3373:19

admitted [5] - 3155:24, 3180:7,

3286:18, 3362:15, 3368:13

admonish [1] - 3410:24

adultery [1] - 3409:11

advance [3] - 3198:19, 3334:6, 3417:7

Advertising [1] - 3169:16

advertising [1] - 3271:4

advisor [4] - 3164:6, 3168:14, 3169:6,

3242:15

advisors [13] - 3150:6, 3150:13,

3158:5, 3158:11, 3158:17, 3158:24,

3163:21, 3165:9, 3192:15, 3226:5,

3241:22, 3241:25, 3260:1

affair [1] - 3344:1

affairs [10] - 3293:1, 3340:9, 3340:12,

3340:16, 3340:18, 3341:4, 3341:12,

3343:1, 3343:4, 3410:19

affect [1] - 3401:8

affiliated [1] - 3271:6

affirmatively [2] - 3304:1, 3316:4

aforementioned [1] - 3343:12

afoul [1] - 3420:2

afraid [2] - 3201:14, 3201:16

afternoon [3] - 3262:19, 3410:3,

3418:23

age [4] - 3377:25, 3378:1, 3397:18,

3401:7

aged [1] - 3377:23

agency [1] - 3375:4

agenda [1] - 3165:1

agent [4] - 3229:19, 3271:18, 3271:22,

3273:15

agents [2] - 3212:21, 3304:11

ago [2] - 3315:25, 3316:13

agree [9] - 3269:17, 3298:18, 3322:3,

3355:24, 3411:9, 3412:8, 3413:3,

3417:9, 3423:6

agreed [3] - 3323:1, 3323:2, 3394:20

agreement [19] - 3311:22, 3315:6,

3315:7, 3321:24, 3322:4, 3322:13,

3323:2, 3323:6, 3323:11, 3324:13,

3324:19, 3326:17, 3327:25, 3328:3,

3346:8, 3346:9, 3395:20, 3395:22,

3420:11

Agreement [1] - 3324:9

agrees [1] - 3323:7

ahead [18] - 3146:5, 3176:7, 3190:8,

3206:5, 3213:22, 3232:23, 3239:21,

3241:11, 3257:23, 3274:20, 3286:2,

3300:25, 3330:17, 3351:25, 3374:4,

3397:16, 3400:14

ahold [1] - 3338:24

aids [3] - 3350:13, 3350:24, 3373:6

air [1] - 3414:14

aircraft [1] - 3174:16

airline [1] - 3174:18

airlines [13] - 3171:11, 3187:22,

3188:2, 3188:8, 3188:13, 3188:15,

3188:18, 3188:23, 3189:7, 3189:12,

3189:19, 3189:21, 3189:25

airplane [1] - 3189:16

Airport [1] - 3233:13

Al [1] - 3148:9

alarmed [1] - 3162:5

Ali [1] - 3143:20

all-time [1] - 3174:6

alleging [1] - 3271:11

Allen [14] - 3149:11, 3292:19, 3318:16,


3427

3319:20, 3338:24, 3365:20, 3375:13,

3375:20, 3376:8, 3376:18, 3376:22,

3378:4, 3378:6, 3379:11

ALLEN [1] - 3143:6

allow [2] - 3208:20, 3286:21

allowed [3] - 3155:19, 3239:21,

3263:17

allowing [1] - 3274:19

almost [8] - 3314:14, 3339:2, 3344:23,

3348:23, 3349:7, 3355:1, 3385:6,

3397:17

alone [3] - 3154:10, 3174:17, 3343:15

alternatives [1] - 3351:13

aluminum [1] - 3388:18

Alvarado [22] - 3212:8, 3228:3,

3228:11, 3228:19, 3228:22, 3229:3,

3229:9, 3229:16, 3229:23, 3230:21,

3231:2, 3231:10, 3232:18, 3232:19,

3233:15, 3233:16, 3244:2, 3244:3,

3244:16, 3267:18, 3267:19, 3281:23

America [2] - 3160:11, 3176:1

AMERICA [1] - 3143:4

amount [27] - 3152:14, 3153:11,

3156:11, 3157:14, 3157:21, 3161:11,

3180:9, 3180:12, 3186:22, 3194:13,

3196:11, 3197:2, 3197:3, 3217:4,

3217:5, 3225:12, 3246:7, 3254:17,

3275:2, 3293:18, 3334:5, 3334:24,

3371:18, 3372:17, 3377:21, 3415:16,

3421:9

amounts [1] - 3191:3

amplification [1] - 3351:17

analysis [1] - 3223:18

analyst [2] - 3177:18, 3178:7

analysts [1] - 3173:4

Andrew [1] - 3143:16

announce [6] - 3198:13, 3201:19,

3203:10, 3204:1, 3207:16, 3419:20

announced [4] - 3204:12, 3204:19,

3224:11, 3224:15

announcement [10] - 3200:21, 3203:7,

3204:3, 3205:2, 3205:12, 3205:16,

3206:10, 3221:21, 3226:2, 3226:4

announcements [1] - 3421:1

announcing [1] - 3199:17

annual [10] - 3166:4, 3289:10,

3374:11, 3374:13, 3374:14, 3374:15,

3374:19, 3379:15, 3380:4, 3382:10

answer [29] - 3183:18, 3183:23,

3204:7, 3213:16, 3221:6, 3221:7,

3245:11, 3245:12, 3252:22, 3261:3,

3272:24, 3304:19, 3304:22, 3305:1,

3311:7, 3319:24, 3325:19, 3325:20,

3325:25, 3326:3, 3326:8, 3326:12,

3349:25, 3383:12, 3383:22, 3383:23,

3384:5, 3403:16

Answered [2] - 3304:1, 3316:4

answered [8] - 3307:11, 3307:14,

3385:21, 3399:7, 3406:6, 3407:17,

3407:18, 3408:19

answering [3] - 3305:18, 3305:24,

3306:6

anticipate [4] - 3413:4, 3414:10,

3414:22, 3415:4

Antigua [14] - 3162:4, 3170:18,

3171:1, 3172:16, 3172:18, 3173:17,

3208:9, 3210:6, 3210:19, 3211:17,

3240:25, 3252:5, 3363:18, 3395:4

anytime [1] - 3147:4

anyway [1] - 3176:15

apartment [1] - 3162:23

apologize [2] - 3384:10, 3400:14

appeal [1] - 3211:5

appear [1] - 3398:9

APPEARANCES [2] - 3143:12

appeared [1] - 3204:19

appellate [1] - 3419:23

applicable [1] - 3408:14

appointed [2] - 3160:9, 3327:11

appraisal [1] - 3218:18

appreciate [1] - 3397:11

appreciates [1] - 3220:14

approach [5] - 3297:15, 3410:18,

3412:20, 3412:24, 3420:1

approached [1] - 3183:7

appropriate [3] - 3276:4, 3412:21,

3419:21

approval [2] - 3188:5, 3372:7

approve [1] - 3293:13

Approved [1] - 3386:19

approved [7] - 3293:15, 3313:24,

3367:11, 3367:12, 3372:1, 3372:7,

3381:22

area [5] - 3160:1, 3161:7, 3173:7,

3174:16, 3266:3

areas [2] - 3209:1, 3421:1

arenas [1] - 3165:4

argue [1] - 3419:1

argument [2] - 3230:15, 3419:23

Arizona [1] - 3241:24

arm [1] - 3152:11

arms [1] - 3268:7

arrive [2] - 3218:11, 3249:9

arrived [12] - 3244:6, 3244:23, 3245:3,

3245:5, 3249:1, 3249:11, 3262:18,

3262:19, 3262:21, 3265:13, 3287:24,

3310:12

arrow [1] - 3215:23

art [3] - 3284:22, 3341:22, 3341:24

artfully [2] - 3218:8, 3396:13

articles [1] - 3354:10

aside [2] - 3295:1, 3301:15

aspect [2] - 3412:19, 3413:18

ass [1] - 3247:6

assert [1] - 3298:5

asset [5] - 3217:2, 3237:16, 3248:8,

3250:1, 3253:11

assets [59] - 3149:25, 3150:10,

3150:11, 3150:13, 3150:14, 3150:19,

3150:22, 3151:2, 3151:6, 3151:13,

3151:18, 3152:1, 3157:2, 3166:10,

3182:16, 3184:11, 3184:15, 3200:3,

3202:22, 3204:16, 3205:14, 3208:7,

3208:9, 3226:3, 3231:8, 3231:9,

3234:15, 3235:19, 3238:21, 3239:8,

3239:9, 3251:7, 3255:1, 3255:9,

3255:18, 3255:19, 3256:18, 3259:6,

3259:9, 3259:25, 3262:14, 3263:18,

3263:25, 3264:10, 3264:12, 3265:9,

3289:6, 3320:18, 3322:16, 3326:20,

3327:14, 3328:19, 3329:7, 3345:14,

3345:15, 3348:22, 3361:17, 3361:19

assigned [1] - 3252:20

Assistant [2] - 3143:14, 3352:11

assistant [2] - 3170:2, 3408:22

assisted [1] - 3144:14

assume [1] - 3419:10

assuming [6] - 3168:19, 3192:6,

3204:24, 3205:4, 3211:24, 3213:1

asterisks [1] - 3185:17

AT [1] - 3331:12

attached [3] - 3188:5, 3206:16, 3226:9

attachment [6] - 3187:23, 3222:8,

3226:25, 3237:5, 3237:9, 3237:10

attack [5] - 3162:4, 3162:8, 3162:9,

3162:10, 3411:9

attacked [1] - 3286:9

attacks [1] - 3162:5

attempt [2] - 3162:12, 3162:15

attempted [1] - 3337:15

attend [4] - 3164:2, 3164:6, 3164:12,

3282:8

attendance [1] - 3245:2

attended [2] - 3193:1, 3233:14

attendees [4] - 3165:5, 3247:13,

3248:23, 3273:9

attending [3] - 3254:1, 3258:15,

3259:23

attention [3] - 3413:23, 3414:17,

3417:7

Attorney [2] - 3143:14, 3144:3

attorney [10] - 3288:15, 3297:9,

3299:16, 3300:17, 3300:18, 3301:6,

3303:1, 3304:23, 3378:10, 3384:6

attorney-client [3] - 3299:16, 3300:17,

3300:18

attorneys [6] - 3288:7, 3306:14,

3309:15, 3329:15, 3421:6, 3423:25

Attorneys [1] - 3352:12

audacious [1] - 3411:9

audible [1] - 3319:24

audit [4] - 3279:14, 3280:2, 3280:3,

3280:18

auditor [2] - 3146:13, 3146:17

auditors [1] - 3279:22

authorities [1] - 3287:1

authority [2] - 3349:13, 3349:14

automobile [1] - 3377:7

automobiles [1] - 3377:10

available [2] - 3162:25, 3191:24

Avenue [1] - 3143:17

average [1] - 3167:7

Aviation [3] - 3171:13, 3174:17,

3233:13

avoid [2] - 3214:17, 3329:13

aware [5] - 3153:9, 3153:16, 3170:17,

3170:21, 3341:12


3428

Aztec [1] - 3165:15

B

baby [1] - 3419:12

babysitter [5] - 3404:18, 3404:21,

3404:23, 3405:4, 3405:20

backed [1] - 3255:23

background [1] - 3377:9

backing [1] - 3278:22

backup [1] - 3423:3

backwards [1] - 3275:2

bad [6] - 3232:13, 3316:3, 3361:7,

3361:10, 3361:24, 3366:23

bag [2] - 3333:6, 3336:15

balance [10] - 3196:1, 3198:14,

3200:22, 3225:14, 3255:14, 3276:20,

3364:17, 3364:22, 3364:25, 3369:9

balances [4] - 3194:5, 3194:7,

3194:10, 3194:21

Baldwyn [24] - 3292:25, 3293:24,

3339:13, 3339:14, 3339:18, 3340:21,

3340:23, 3340:24, 3341:13, 3341:15,

3341:18, 3342:25, 3343:4, 3343:15,

3344:5, 3344:10, 3355:10, 3360:22,

3361:9, 3364:2, 3366:3, 3371:2,

3401:12, 3402:16

ballpark [1] - 3422:13

bank [192] - 3146:13, 3146:19, 3149:5,

3149:8, 3151:7, 3151:20, 3157:22,

3161:17, 3166:4, 3166:8, 3166:22,

3167:14, 3168:17, 3171:1, 3171:7,

3171:9, 3172:9, 3172:18, 3172:19,

3172:23, 3180:2, 3180:15, 3181:24,

3182:15, 3182:22, 3183:7, 3183:13,

3183:24, 3184:20, 3184:23, 3186:2,

3186:7, 3190:25, 3192:3, 3192:16,

3193:10, 3193:14, 3193:18, 3193:22,

3196:2, 3196:7, 3197:2, 3198:14,

3199:13, 3199:15, 3199:17, 3200:6,

3200:16, 3200:22, 3201:21, 3202:24,

3203:24, 3204:13, 3204:16, 3205:1,

3205:16, 3206:11, 3209:17, 3209:20,

3209:21, 3209:23, 3211:21, 3212:1,

3212:3, 3212:14, 3213:9, 3213:12,

3214:1, 3214:22, 3214:24, 3215:7,

3215:9, 3216:3, 3216:6, 3216:12,

3216:13, 3216:18, 3216:23, 3217:2,

3217:17, 3217:18, 3219:21, 3220:4,

3220:5, 3221:13, 3221:14, 3221:21,

3224:3, 3224:8, 3224:19, 3224:20,

3225:5, 3225:25, 3226:2, 3226:4,

3229:4, 3229:17, 3230:7, 3230:8,

3230:11, 3232:23, 3233:1, 3233:17,

3234:15, 3234:23, 3235:25, 3236:13,

3238:7, 3238:20, 3239:5, 3244:1,

3251:13, 3251:20, 3253:5, 3253:8,

3253:11, 3259:14, 3259:17, 3263:25,

3264:15, 3264:18, 3264:23, 3273:25,

3275:15, 3276:9, 3276:18, 3276:19,

3278:11, 3283:7, 3288:22, 3289:4,

3289:10, 3289:17, 3290:10, 3290:20,

3290:23, 3291:1, 3291:4, 3293:16,

3294:11, 3315:8, 3318:15, 3326:21,

3327:8, 3327:17, 3328:15, 3328:20,

3329:19, 3330:4, 3330:9, 3330:18,

3335:18, 3335:23, 3347:1, 3347:7,

3347:25, 3348:1, 3348:13, 3348:18,

3348:19, 3348:21, 3348:22, 3348:23,

3348:25, 3349:1, 3349:6, 3349:8,

3349:10, 3349:11, 3352:21, 3352:22,

3356:16, 3356:17, 3356:24, 3358:7,

3363:7, 3363:13, 3363:16, 3363:20,

3363:22, 3363:24, 3364:15, 3366:14,

3366:19, 3368:18, 3370:9

Bank [27] - 3170:4, 3186:4, 3186:8,

3186:16, 3194:14, 3201:22, 3202:13,

3210:3, 3214:3, 3231:8, 3235:19,

3236:25, 3246:6, 3250:6, 3255:15,

3279:17, 3348:4, 3348:5, 3348:15,

3356:20, 3362:24, 3363:14, 3363:17,

3368:17, 3370:11, 3374:11, 3375:22

bank's [18] - 3149:20, 3167:5,

3171:21, 3172:4, 3184:11, 3194:16,

3202:16, 3202:18, 3202:19, 3204:1,

3207:16, 3208:3, 3238:21, 3255:1,

3255:9, 3263:18, 3264:23, 3288:24

banked [1] - 3368:19

banking [4] - 3191:18, 3191:21,

3200:18, 3363:5

bankruptcy [1] - 3147:24

banks [6] - 3166:6, 3330:9, 3330:11,

3330:13, 3363:20, 3368:21

Baptist [2] - 3402:17, 3402:18

bar [2] - 3266:3, 3267:2

Barbuda [3] - 3208:9, 3210:6, 3252:5

bare [1] - 3415:24

bargain [3] - 3310:12, 3337:14

barrister [2] - 3378:6, 3378:8

bars [1] - 3319:3

base [1] - 3290:22

based [18] - 3148:23, 3167:19,

3167:22, 3168:3, 3168:4, 3172:13,

3172:14, 3226:23, 3233:3, 3234:9,

3253:5, 3273:6, 3273:11, 3273:22,

3273:23, 3274:7, 3278:21, 3416:25

basic [1] - 3275:17

basis [9] - 3148:16, 3152:23, 3172:18,

3180:24, 3183:14, 3195:16, 3269:12,

3271:7, 3299:1

Baton [1] - 3148:24

batting [1] - 3359:21

Bay [1] - 3243:24

Bazel [1] - 3202:24

became [2] - 3150:11, 3376:1

become [2] - 3161:24, 3169:6

becoming [1] - 3197:10

BEFORE [1] - 3143:10

beforehand [1] - 3420:14

began [5] - 3181:23, 3198:4, 3247:14,

3268:3, 3411:11

begin [1] - 3262:5

beginning [6] - 3155:8, 3165:3,

3202:9, 3314:15, 3383:5

behalf [1] - 3386:19

behavior [1] - 3406:17

behind [2] - 3173:13, 3268:7

bell [1] - 3412:17

below [4] - 3186:21, 3225:2, 3237:7,

3357:20

bench [5] - 3297:15, 3297:17, 3410:5,

3412:21, 3412:24

BENCH [1] - 3331:12

beneath [2] - 3186:10, 3237:3

best [4] - 3150:15, 3274:3, 3300:10,

3416:19

betray [2] - 3407:4, 3407:6

betrayal [1] - 3407:8

betrayed [4] - 3407:23, 3407:25,

3408:3, 3409:9

better [10] - 3148:16, 3187:10, 3291:7,

3291:8, 3332:5, 3333:17, 3346:15,

3350:25, 3410:23, 3417:8

Betty [2] - 3352:2, 3352:5

between [17] - 3165:8, 3176:4,

3177:20, 3180:13, 3184:12, 3215:5,

3240:10, 3240:20, 3242:13, 3255:7,

3255:13, 3303:14, 3319:10, 3336:24,

3380:24, 3394:20

beyond [5] - 3157:2, 3214:19, 3264:7,

3386:10, 3421:14

Bible [5] - 3401:13, 3401:14, 3401:16,

3401:18, 3402:15

big [9] - 3180:4, 3191:19, 3209:1,

3321:11, 3321:15, 3330:13, 3388:13,

3389:16, 3390:20

Bill [2] - 3375:13, 3377:21

bill [1] - 3376:23

billed [1] - 3338:6

billion [55] - 3150:17, 3150:18,

3160:12, 3180:1, 3180:3, 3180:5,

3180:14, 3181:9, 3193:10, 3193:14,

3203:3, 3203:8, 3204:2, 3207:6,

3207:17, 3207:19, 3216:12, 3216:18,

3217:1, 3217:6, 3217:20, 3218:5,

3218:11, 3221:22, 3223:4, 3224:4,

3224:14, 3224:18, 3224:25, 3225:3,

3226:6, 3248:7, 3249:25, 3252:1,

3252:10, 3252:20, 3253:7, 3253:22,

3255:11, 3255:20, 3258:10, 3259:2,

3259:6, 3261:8, 3264:10, 3295:11,

3295:16, 3322:3, 3322:19, 3323:2,

3323:8, 3323:18, 3326:4, 3328:3

billion-dollar [1] - 3255:11

billionaires [1] - 3211:17

billions [1] - 3322:9

bills [1] - 3347:12

birthday [4] - 3203:20, 3203:21,

3207:15

Biscayne [1] - 3243:24

bit [7] - 3186:21, 3187:9, 3350:19,

3387:18, 3389:16, 3401:8, 3408:15

biz [1] - 3339:13

block [1] - 3389:1

blocked [1] - 3209:2

blurted [1] - 3410:20

board [28] - 3198:1, 3202:18, 3208:22,

3209:1, 3209:6, 3375:3, 3375:6,Johnny C. Sanchez, RMR, CRR - [email protected]

3429

3375:10, 3375:12, 3375:21, 3375:24,

3376:5, 3376:6, 3376:7, 3376:9,

3377:4, 3377:12, 3377:19, 3378:3,

3378:15, 3379:8, 3379:16, 3379:18,

3379:24, 3380:3, 3380:5, 3384:13,

3386:19

boat [4] - 3211:17, 3388:2, 3388:17,

3388:18

Boca [1] - 3330:23

body [1] - 3286:14

Bogar [12] - 3160:3, 3160:6, 3160:14,

3160:21, 3160:23, 3233:18, 3244:4,

3261:23, 3267:20, 3268:1, 3268:5,

3268:7

bogar [2] - 3160:4, 3160:5

Bogar's [2] - 3160:8, 3268:8

BOH [1] - 3186:15

bolster [2] - 3199:14, 3200:22

bonds [1] - 3150:8

bonus [3] - 3158:13, 3290:17, 3290:22

bonuses [10] - 3158:10, 3292:24,

3295:2, 3313:18, 3313:20, 3313:21,

3314:18, 3325:1, 3338:19, 3358:16

book [1] - 3271:10

bookkeeping [13] - 3159:5, 3204:15,

3205:9, 3205:11, 3206:8, 3206:12,

3206:25, 3208:8, 3216:1, 3224:9,

3224:14, 3225:18, 3250:24

books [8] - 3177:24, 3178:2, 3224:20,

3250:5, 3250:23, 3329:24, 3330:1,

3330:3

borrow [1] - 3372:16

borrowed [2] - 3180:19, 3301:22

borrowing [3] - 3161:16, 3335:1,

3345:20

bother [1] - 3335:17

bottom [19] - 3185:19, 3186:17,

3190:16, 3190:17, 3194:1, 3194:9,

3194:11, 3195:20, 3207:5, 3207:6,

3279:15, 3317:25, 3319:18, 3324:3,

3324:5, 3366:24, 3381:13, 3381:24,

3386:17

bought [2] - 3171:19, 3333:18

bounds [1] - 3156:5

Box [2] - 3143:14, 3144:7

box [3] - 3237:3, 3363:3, 3389:13

boys [3] - 3404:4, 3404:6, 3404:7

branches [1] - 3149:1

break [19] - 3205:20, 3205:23,

3205:25, 3206:9, 3212:23, 3213:7,

3217:7, 3244:22, 3257:18, 3265:21,

3266:20, 3307:4, 3308:25, 3329:16,

3331:4, 3342:21, 3420:23, 3421:4

breakdown [4] - 3188:3, 3224:6,

3224:18, 3231:8

breakdowns [1] - 3223:15

breaking [2] - 3189:14, 3214:17

breaks [1] - 3227:8

brick [2] - 3189:15, 3264:11

brief [3] - 3295:22, 3302:21, 3391:1

briefs [1] - 3419:15

bright [1] - 3232:10

bring [7] - 3328:5, 3331:5, 3333:9,

3336:15, 3373:13, 3373:18, 3413:25

bringing [1] - 3413:22

brings [1] - 3202:20

British [5] - 3194:25, 3227:5, 3378:13,

3378:14, 3379:25

broke [5] - 3262:5, 3268:3, 3330:13,

3371:24, 3405:10

broken [1] - 3251:7

broker [6] - 3150:5, 3150:11, 3150:12,

3151:16, 3153:4, 3154:3

brokerage [51] - 3147:12, 3147:16,

3147:20, 3148:4, 3148:6, 3148:11,

3148:15, 3148:21, 3148:23, 3148:25,

3149:6, 3149:8, 3149:10, 3149:14,

3149:20, 3150:4, 3150:10, 3150:15,

3150:18, 3150:23, 3151:1, 3151:4,

3151:8, 3151:19, 3152:1, 3152:11,

3152:15, 3152:24, 3153:11, 3156:11,

3156:19, 3157:1, 3157:6, 3157:14,

3157:18, 3157:19, 3157:21, 3158:5,

3159:15, 3159:24, 3160:9, 3160:16,

3160:18, 3160:24, 3165:9, 3232:23,

3233:18, 3244:4, 3261:24, 3268:1,

3269:8

brought [4] - 3173:13, 3218:19,

3234:1, 3417:6

budget [1] - 3175:10

budgetary [2] - 3175:9

building [1] - 3211:4

buildings [1] - 3219:22

built [2] - 3211:24, 3212:4

bunch [1] - 3185:25

business [38] - 3148:16, 3166:25,

3242:18, 3242:19, 3279:18, 3339:23,

3339:25, 3340:1, 3340:15, 3340:22,

3340:25, 3341:1, 3341:12, 3341:15,

3343:1, 3343:4, 3343:20, 3344:3,

3344:6, 3344:13, 3364:4, 3364:6,

3371:2, 3374:18, 3377:6, 3377:7,

3392:12, 3392:25, 3393:1, 3393:8,

3393:9, 3393:10, 3394:1, 3394:2,

3394:3, 3394:22, 3404:7

businesses [22] - 3292:25, 3293:23,

3293:25, 3294:1, 3294:5, 3327:12,

3327:15, 3327:18, 3339:15, 3339:18,

3339:20, 3339:22, 3340:21, 3341:18,

3342:2, 3342:4, 3342:7, 3343:12,

3343:14, 3343:17, 3355:9, 3364:2

businessman [1] - 3376:25

buy [3] - 3211:6, 3214:24, 3341:1

buy-sell [1] - 3341:1

buying [1] - 3214:8

BY [204] - 3145:4, 3145:5, 3146:9,

3147:1, 3151:23, 3152:22, 3153:22,

3154:12, 3155:3, 3156:7, 3156:17,

3157:12, 3158:4, 3161:23, 3166:14,

3167:3, 3168:12, 3169:4, 3170:16,

3171:17, 3172:3, 3175:5, 3176:9,

3177:6, 3178:6, 3179:7, 3179:17,

3180:8, 3180:11, 3181:7, 3182:13,

3184:3, 3185:5, 3185:21, 3187:12,

3189:4, 3190:7, 3190:13, 3190:22,

3191:14, 3192:12, 3193:2, 3193:8,

3195:22, 3196:19, 3199:1, 3200:12,

3201:5, 3201:18, 3202:4, 3204:9,

3205:6, 3206:7, 3206:19, 3207:12,

3209:10, 3209:14, 3210:22, 3211:15,

3213:8, 3214:7, 3214:14, 3215:18,

3216:21, 3217:10, 3219:16, 3220:24,

3221:5, 3221:9, 3222:6, 3222:16,

3222:22, 3223:14, 3226:22, 3227:13,

3228:2, 3228:9, 3228:16, 3229:2,

3229:8, 3230:20, 3232:1, 3234:12,

3235:16, 3236:4, 3236:12, 3236:24,

3237:12, 3238:18, 3239:2, 3239:22,

3240:18, 3244:7, 3244:24, 3245:13,

3245:25, 3247:24, 3249:13, 3249:16,

3249:21, 3250:17, 3252:16, 3254:25,

3257:3, 3258:2, 3258:3, 3258:25,

3260:14, 3261:1, 3261:5, 3261:16,

3262:2, 3266:13, 3268:14, 3269:2,

3269:18, 3270:19, 3270:20, 3274:21,

3274:22, 3275:12, 3276:7, 3277:19,

3278:6, 3279:10, 3279:25, 3281:10,

3282:7, 3285:22, 3286:23, 3287:10,

3287:23, 3289:13, 3289:14, 3290:14,

3291:9, 3291:10, 3292:9, 3296:3,

3296:24, 3301:1, 3303:5, 3305:4,

3305:13, 3306:3, 3307:3, 3308:5,

3309:1, 3309:5, 3309:19, 3311:13,

3313:6, 3315:24, 3316:11, 3321:5,

3322:25, 3324:11, 3325:18, 3326:2,

3326:15, 3328:6, 3329:18, 3331:12,

3331:21, 3332:7, 3334:14, 3342:1,

3350:6, 3350:17, 3350:21, 3351:23,

3353:4, 3356:1, 3361:6, 3362:19,

3367:3, 3368:14, 3369:4, 3369:23,

3370:25, 3371:8, 3372:12, 3373:14,

3374:5, 3380:13, 3383:17, 3384:12,

3385:5, 3386:18, 3387:3, 3389:14,

3389:24, 3390:4, 3391:3, 3397:21,

3398:4, 3399:10, 3399:24, 3405:18,

3406:9, 3407:2, 3407:22, 3408:16,

3409:2

C

calculated [1] - 3294:18

calculation [5] - 3217:6, 3217:22,

3217:23, 3220:14, 3223:5

Caldwell [6] - 3377:13, 3377:14,

3377:15, 3377:17, 3377:18, 3377:22

calendar [1] - 3374:16

California [1] - 3253:15

calm [1] - 3351:7

Canada [1] - 3186:4

Canadian [1] - 3194:25

cannot [2] - 3304:22, 3415:5

capability [1] - 3240:6

capable [1] - 3170:6

Capital [14] - 3251:16, 3345:8,

3345:12, 3346:16, 3348:14, 3348:22,

3353:9, 3353:14, 3353:16, 3353:22,

3355:14, 3369:22, 3370:3, 3370:9


3430

capital [22] - 3202:19, 3202:22,

3202:23, 3202:24, 3204:1, 3206:11,

3207:16, 3208:4, 3208:5, 3221:21,

3223:22, 3224:12, 3224:15, 3224:23,

3225:13, 3226:6, 3253:2, 3293:1,

3293:2, 3343:10, 3345:11, 3348:13

capital-to-assets [1] - 3202:22

capital-to-deposits [1] - 3202:23

capitalize [1] - 3328:20

captured [1] - 3159:7

captures [1] - 3380:22

car [1] - 3284:23

care [3] - 3237:1, 3292:4, 3423:13

career [1] - 3401:13

Caribbean [2] - 3188:8, 3188:9

case [17] - 3273:14, 3294:4, 3302:4,

3302:6, 3302:18, 3321:16, 3349:3,

3349:4, 3365:21, 3366:22, 3373:17,

3383:24, 3384:2, 3384:4, 3408:14,

3415:22, 3416:21

CASE [1] - 3331:24

cases [3] - 3253:16, 3419:8, 3419:15

cash [42] - 3161:14, 3162:25, 3163:2,

3179:24, 3182:24, 3183:4, 3183:5,

3183:6, 3184:17, 3185:14, 3188:16,

3188:18, 3191:24, 3192:4, 3192:5,

3193:15, 3193:20, 3194:5, 3194:7,

3194:11, 3194:13, 3194:16, 3194:21,

3195:6, 3195:15, 3196:1, 3196:3,

3196:9, 3196:12, 3197:2, 3197:3,

3198:1, 3200:2, 3203:23, 3204:16,

3204:19, 3205:14, 3238:22, 3326:23,

3364:1

catch [1] - 3351:5

cattle [2] - 3377:8, 3377:10

caused [2] - 3165:25, 3367:9

caution [2] - 3272:2, 3272:4

Cd [1] - 3325:15

CD [65] - 3146:19, 3147:6, 3147:9,

3148:8, 3149:4, 3149:23, 3150:24,

3151:15, 3152:2, 3154:10, 3155:9,

3156:11, 3157:2, 3157:6, 3157:14,

3157:15, 3157:21, 3159:1, 3159:4,

3159:8, 3159:12, 3159:15, 3160:1,

3161:3, 3161:10, 3161:11, 3161:13,

3163:18, 3163:19, 3164:9, 3164:20,

3165:21, 3166:4, 3171:2, 3171:4,

3171:6, 3171:19, 3179:11, 3180:2,

3181:9, 3181:19, 3182:1, 3182:23,

3189:20, 3190:24, 3192:1, 3196:5,

3198:16, 3199:3, 3201:23, 3242:8,

3253:5, 3255:5, 3277:3, 3277:5,

3280:8, 3280:10, 3281:4, 3287:17,

3295:11, 3325:6, 3342:8, 3342:9,

3348:8, 3372:2

CDs [34] - 3147:6, 3149:15, 3149:20,

3151:4, 3151:7, 3151:20, 3152:15,

3153:11, 3154:4, 3158:6, 3158:11,

3158:16, 3161:9, 3163:22, 3165:10,

3165:25, 3166:5, 3170:18, 3181:10,

3182:1, 3182:19, 3183:7, 3198:23,

3199:3, 3200:25, 3242:23, 3277:13,

3277:24, 3280:12, 3280:22, 3288:22,

3289:5, 3290:11, 3328:16

ceased [1] - 3280:10

celebration [1] - 3203:21

cell [5] - 3291:22, 3328:8, 3332:8,

3332:12, 3332:18

cellphone [12] - 3312:25, 3313:3,

3314:13, 3314:22, 3316:1, 3317:8,

3317:9, 3317:11, 3317:12, 3317:20,

3319:19

center [1] - 3191:3

central [1] - 3389:9

Central [1] - 3376:25

cents [1] - 3151:9

CEO [1] - 3195:13

certain [6] - 3154:22, 3164:7, 3164:8,

3352:18, 3354:2, 3355:3

certainly [7] - 3157:24, 3199:4,

3262:1, 3292:2, 3300:14, 3344:17,

3398:9

CERTIFICATE [1] - 3424:3

certificates [2] - 3242:21, 3278:1

certify [1] - 3424:5

cetera [5] - 3189:16, 3253:1, 3285:25,

3351:5, 3354:10

CFO [22] - 3178:21, 3179:9, 3237:1,

3322:17, 3326:3, 3345:16, 3348:16,

3349:13, 3355:17, 3356:4, 3356:8,

3356:9, 3356:17, 3356:19, 3357:1,

3357:19, 3358:4, 3358:9, 3360:3,

3370:13, 3380:2

chain [1] - 3357:1

chair [1] - 3232:22

chairman [9] - 3149:21, 3195:13,

3198:1, 3375:25, 3376:1, 3376:6,

3376:8, 3376:17, 3380:2

chance [1] - 3297:4

change [6] - 3252:1, 3253:7, 3342:16,

3372:20, 3422:25, 3423:2

changed [5] - 3217:16, 3224:13,

3276:21, 3276:23, 3299:2

changing [2] - 3324:24, 3351:4

characterize [3] - 3275:21, 3338:16,

3357:14

characterized [1] - 3315:3

charge [5] - 3185:13, 3356:9, 3356:10,

3358:5

charged [4] - 3395:21, 3395:23,

3395:25, 3399:16

charities [1] - 3294:22

Charles [1] - 3168:13

chart [21] - 3248:3, 3248:5, 3249:24,

3251:19, 3251:21, 3251:25, 3252:4,

3253:25, 3254:3, 3258:4, 3259:21,

3260:3, 3261:14, 3262:7, 3262:10,

3262:25, 3263:12, 3264:8, 3264:13,

3265:8, 3266:6

charts [1] - 3305:6

check [7] - 3313:2, 3331:4, 3366:12,

3367:5, 3367:24, 3368:2, 3369:16

checked [1] - 3237:2

checking [4] - 3186:9, 3194:14,

3323:18, 3369:3

checks [3] - 3366:8, 3370:20, 3371:18

chief [12] - 3169:1, 3233:20, 3238:7,

3245:2, 3267:17, 3269:8, 3289:24,

3322:6, 3356:9, 3358:5, 3386:24,

3401:4

children [3] - 3404:2, 3404:11,

3406:14

China [3] - 3421:20, 3422:1, 3423:9

Chinese [2] - 3413:18, 3413:20

choice [1] - 3423:10

Church [2] - 3402:17, 3402:18

church [15] - 3294:25, 3295:2,

3305:22, 3312:23, 3313:2, 3313:14,

3401:24, 3402:2, 3402:4, 3402:6,

3402:8, 3402:10, 3402:12, 3402:16

churches [1] - 3294:21

CIO [1] - 3267:16

circle [2] - 3209:25, 3210:2

circular [1] - 3329:2

circumstances [1] - 3177:25

claim [4] - 3319:19, 3321:25, 3324:20,

3338:24

claims [2] - 3328:15, 3328:21

clarified [2] - 3342:13, 3342:20

clarify [2] - 3161:19, 3305:11

class [7] - 3401:13, 3401:14, 3401:16,

3401:18, 3402:15, 3402:19, 3403:1

classes [2] - 3248:8, 3250:1

clean [2] - 3260:10, 3321:10

clear [9] - 3213:19, 3232:11, 3242:22,

3302:23, 3322:15, 3323:10, 3327:9,

3365:11, 3370:6

cleared [1] - 3209:1

clearer [1] - 3362:18

clearly [4] - 3313:8, 3397:12, 3397:14,

3412:9

client [7] - 3194:22, 3246:5, 3297:21,

3299:16, 3300:3, 3300:17, 3300:18

clients [12] - 3150:7, 3150:10,

3150:19, 3150:21, 3150:23, 3153:12,

3170:25, 3242:16, 3285:4, 3287:17

clip [3] - 3192:9, 3192:18, 3193:10

clock [6] - 3176:5, 3295:21, 3390:23,

3409:24, 3419:2, 3421:9

close [4] - 3196:13, 3216:22, 3293:23,

3419:7

closed [3] - 3165:4, 3182:10, 3294:1

closely [1] - 3152:7

closer [2] - 3332:3, 3411:2

closing [2] - 3250:5, 3250:23

clothes [1] - 3197:22

club [5] - 3211:18, 3211:23, 3211:24,

3212:2, 3212:3

Club [8] - 3163:11, 3163:12, 3163:13,

3163:20, 3165:7, 3211:1, 3211:2,

3241:18

clubs [1] - 3148:1

co [3] - 3148:12, 3271:12, 3273:14

co-conspirator [1] - 3271:12

co-defendant [1] - 3273:14

co-presidents [1] - 3148:12

cobwebs [1] - 3390:25


3431

coffee [1] - 3423:16

college [1] - 3401:12

column [3] - 3186:2, 3191:7, 3222:25

Comaeux [5] - 3148:9, 3148:10,

3148:19, 3153:5, 3159:19

Comerica [1] - 3194:24

comfort [1] - 3415:16

comfortable [6] - 3151:14, 3235:11,

3299:22, 3419:11, 3419:18, 3420:21

coming [17] - 3146:4, 3161:13,

3173:20, 3182:1, 3182:14, 3188:1,

3197:1, 3199:6, 3199:23, 3200:25,

3285:4, 3287:18, 3287:20, 3357:5,

3418:12, 3422:21

commence [1] - 3276:4

comment [2] - 3410:22, 3411:1

comments [1] - 3172:17

commercial [5] - 3171:11, 3174:18,

3187:22, 3188:8, 3369:3

Commission [3] - 3236:16, 3237:6,

3327:11

commissions [1] - 3158:10

commit [1] - 3310:6

commitment [1] - 3232:14

commitments [1] - 3189:15

committed [5] - 3325:4, 3328:2,

3329:21, 3345:25, 3409:11

committing [1] - 3378:21

communicate [1] - 3197:24

communicated [2] - 3208:21, 3296:13

communicating [5] - 3183:11,

3183:12, 3183:14, 3191:23, 3195:14

communication [5] - 3156:2, 3296:17,

3314:2, 3338:15, 3396:25

communications [1] - 3393:10

companies [27] - 3180:22, 3180:23,

3180:25, 3181:5, 3182:19, 3187:21,

3214:16, 3241:23, 3269:7, 3269:10,

3270:9, 3270:10, 3271:6, 3286:1,

3308:1, 3342:10, 3352:2, 3354:3,

3356:13, 3356:18, 3357:9, 3361:1,

3361:8, 3361:24, 3368:4

company [56] - 3160:10, 3160:13,

3175:15, 3175:22, 3205:15, 3214:11,

3225:3, 3251:15, 3251:16, 3269:6,

3269:19, 3269:21, 3269:22, 3269:24,

3270:5, 3270:13, 3270:21, 3270:24,

3271:23, 3292:23, 3294:1, 3316:2,

3328:14, 3336:7, 3341:25, 3345:12,

3345:13, 3348:13, 3349:8, 3353:8,

3353:10, 3353:23, 3353:24, 3354:1,

3354:2, 3354:6, 3354:8, 3354:9,

3354:10, 3354:14, 3354:15, 3354:16,

3354:17, 3354:19, 3354:25, 3355:1,

3355:4, 3355:20, 3356:11, 3361:18,

3364:1, 3372:5, 3374:16, 3404:16,

3404:24

Company [14] - 3147:12, 3150:4,

3150:5, 3223:16, 3223:17, 3224:10,

3224:11, 3224:25, 3225:10, 3251:18,

3270:7, 3270:23

comparable [4] - 3218:9, 3218:13,

3218:22, 3219:25

compare [3] - 3166:5, 3218:24,

3385:16

compared [1] - 3147:4

comparison [1] - 3218:14

competed [1] - 3165:12

competition [1] - 3165:21

competitions [1] - 3165:8

competitive [1] - 3148:22

complete [2] - 3231:7, 3241:15

completed [6] - 3221:11, 3221:16,

3222:1, 3224:9, 3252:11, 3294:16

completes [1] - 3409:25

compliance [12] - 3152:6, 3153:3,

3233:19, 3244:1, 3267:17, 3267:24,

3268:19, 3269:3, 3269:8, 3270:6,

3270:13, 3271:4

complicated [2] - 3223:18, 3310:20

component [3] - 3175:11, 3175:13,

3175:14

composition [1] - 3261:20

compound [1] - 3308:17

computer [27] - 3144:14, 3248:16,

3285:20, 3352:10, 3385:13, 3387:5,

3387:9, 3387:12, 3387:15, 3387:16,

3387:17, 3388:19, 3388:20, 3389:6,

3391:4, 3391:8, 3392:7, 3392:8,

3392:10, 3396:15, 3396:17, 3396:18,

3396:25, 3397:4, 3398:6, 3398:17

computer-assisted [1] - 3144:14

computers [11] - 3285:7, 3285:9,

3285:12, 3285:15, 3286:4, 3286:14,

3287:7, 3387:14, 3393:13, 3398:13,

3399:13

concern [9] - 3152:14, 3154:1,

3156:12, 3161:24, 3161:25, 3162:1,

3162:24, 3271:25, 3300:9

concerned [8] - 3152:25, 3178:20,

3179:18, 3197:9, 3197:10, 3197:12,

3197:14

concerning [3] - 3268:16, 3273:2,

3273:3

concerns [11] - 3153:2, 3153:6,

3153:9, 3153:10, 3157:20, 3162:16,

3168:7, 3175:6, 3179:8, 3197:7, 3240:2

concierge's [1] - 3266:3

conclusions [1] - 3412:16

concurred [1] - 3278:15

conditions [1] - 3227:23

conducting [1] - 3379:12

conduit [1] - 3357:12

confer [1] - 3329:13

conference [2] - 3169:2, 3233:24

conferences [1] - 3309:14

conferring [1] - 3329:15

confess [1] - 3334:15

confidence [4] - 3200:22, 3201:11,

3201:13, 3201:21

confidential [2] - 3154:14, 3156:2

configure [1] - 3266:16

configuring [1] - 3266:19

confirms [1] - 3264:4

conflict [1] - 3417:24

confront [1] - 3314:11

confronted [3] - 3317:4, 3400:6,

3400:9

confused [2] - 3382:9, 3393:3

confusing [2] - 3373:21, 3373:22

Congress [1] - 3143:22

connection [1] - 3242:13

connotation [1] - 3354:5

consider [1] - 3360:15

considerably [1] - 3403:4

considered [1] - 3164:11

consisted [1] - 3255:1

consistent [2] - 3166:15, 3166:22

consistently [2] - 3166:22, 3167:15

consolidation [2] - 3328:23, 3329:1

conspirator [1] - 3271:12

Constitution [1] - 3300:19

constructed [1] - 3210:16

Consultant [3] - 3413:5, 3413:8,

3413:10

consultant [3] - 3288:14, 3409:17,

3413:15

consulting [1] - 3417:15

consultive [2] - 3233:16, 3244:3

consummated [1] - 3326:18

contact [2] - 3246:20, 3317:5

contained [4] - 3276:14, 3285:19,

3285:20, 3285:24

content [3] - 3256:5, 3256:7, 3259:11

contention [2] - 3176:3, 3176:12

contents [2] - 3239:25, 3266:23

context [2] - 3222:15, 3412:22

continue [9] - 3157:18, 3171:22,

3177:23, 3178:4, 3202:25, 3287:3,

3391:2, 3410:12, 3421:15

CONTINUED [1] - 3146:8

continued [4] - 3192:6, 3277:24,

3280:8, 3280:10

Continued [2] - 3144:1, 3144:2

continuing [1] - 3277:13

contracts [1] - 3189:15

contradict [2] - 3265:4, 3265:10

contribution [5] - 3202:20, 3208:3,

3208:5, 3224:14, 3225:13

contributions [1] - 3223:22

controlled [1] - 3295:7

controller [5] - 3218:16, 3218:17,

3226:14, 3356:23, 3358:3

convened [2] - 3245:3, 3245:8

conventional [4] - 3292:23, 3334:22,

3334:23, 3336:7

conversation [26] - 3153:19, 3153:24,

3162:20, 3163:4, 3175:8, 3177:16,

3177:18, 3177:22, 3178:10, 3184:8,

3184:9, 3203:12, 3205:7, 3207:14,

3231:10, 3231:18, 3235:7, 3235:10,

3240:8, 3242:6, 3247:1, 3266:1,

3283:19, 3318:12, 3339:4, 3339:7

conversations [8] - 3153:8, 3153:23,

3156:18, 3159:13, 3189:1, 3198:6,

3242:12, 3285:1

conveyed [1] - 3315:8Johnny C. Sanchez, RMR, CRR - [email protected]

3432

convince [2] - 3310:15, 3341:10

cook [2] - 3177:24, 3178:2

cooked [5] - 3304:6, 3329:24, 3330:1,

3330:3, 3385:16

cooperate [1] - 3286:3

cooperated [1] - 3395:25

cooperating [2] - 3286:17, 3306:25

copied [1] - 3394:24

copies [2] - 3297:3, 3394:24

copy [3] - 3291:11, 3317:20, 3362:7

corner [1] - 3202:9

corporate [4] - 3374:14, 3387:16,

3391:18, 3393:2

correct [77] - 3151:3, 3155:18,

3161:15, 3161:20, 3161:22, 3171:20,

3194:17, 3198:23, 3201:1, 3202:2,

3212:25, 3213:3, 3217:12, 3222:5,

3224:24, 3226:1, 3227:3, 3235:13,

3235:14, 3236:16, 3237:22, 3237:25,

3247:15, 3251:6, 3251:24, 3252:2,

3252:12, 3255:10, 3255:25, 3259:3,

3264:21, 3265:3, 3271:17, 3271:20,

3272:20, 3274:10, 3278:20, 3278:23,

3278:24, 3307:13, 3309:3, 3309:4,

3313:11, 3314:23, 3323:3, 3327:7,

3327:12, 3327:15, 3327:19, 3327:23,

3330:6, 3348:1, 3348:6, 3353:6,

3367:21, 3367:22, 3367:24, 3368:11,

3368:22, 3369:19, 3374:25, 3376:7,

3381:1, 3381:5, 3381:8, 3381:11,

3382:13, 3384:23, 3390:21, 3393:24,

3394:6, 3396:22, 3402:9, 3406:10,

3406:14, 3414:18, 3424:6

corrected [1] - 3277:14

correspondence [2] - 3394:25, 3395:7

correspondent [2] - 3186:3, 3186:5

cost [8] - 3161:12, 3215:25, 3216:5,

3218:6, 3223:2, 3253:13, 3253:21,

3254:5

COSTA [17] - 3156:6, 3411:8, 3411:14,

3412:8, 3412:17, 3416:20, 3417:11,

3417:14, 3417:22, 3420:13, 3420:17,

3421:18, 3421:20, 3421:25, 3422:6,

3422:22, 3422:24

Costa [7] - 3143:13, 3305:9, 3410:20,

3410:23, 3411:2, 3411:7, 3414:19

costing [1] - 3180:25

costs [1] - 3189:13

Counsel [3] - 3229:15, 3286:7,

3407:21

counsel [21] - 3146:5, 3179:6, 3212:7,

3212:17, 3227:20, 3229:3, 3229:17,

3229:24, 3230:8, 3232:19, 3233:15,

3233:16, 3234:21, 3235:13, 3244:2,

3244:3, 3254:21, 3267:17, 3281:24,

3289:25, 3329:13

counsel's [1] - 3281:24

countries [1] - 3241:22

country [6] - 3158:21, 3175:15,

3210:18, 3227:1, 3280:22, 3344:11

counts [2] - 3395:23, 3411:11

couple [13] - 3147:11, 3151:5,

3195:18, 3203:6, 3243:14, 3302:21,

3310:13, 3324:8, 3374:2, 3394:10,

3404:22, 3416:3, 3422:17

course [4] - 3163:23, 3244:10,

3297:21, 3300:18

COURT [421] - 3143:1, 3146:2,

3146:25, 3151:22, 3152:20, 3153:15,

3153:20, 3154:7, 3154:11, 3154:17,

3154:19, 3154:23, 3155:2, 3155:16,

3155:21, 3155:24, 3156:4, 3156:14,

3156:16, 3157:9, 3157:11, 3158:3,

3161:20, 3166:12, 3167:2, 3167:25,

3168:10, 3168:20, 3170:13, 3170:15,

3171:10, 3171:14, 3171:16, 3171:24,

3172:1, 3174:18, 3174:21, 3174:24,

3175:1, 3175:4, 3176:5, 3177:3,

3177:5, 3178:1, 3178:5, 3178:24,

3179:2, 3179:5, 3179:16, 3181:2,

3181:6, 3182:6, 3182:8, 3182:10,

3182:12, 3183:17, 3184:1, 3187:6,

3187:9, 3189:3, 3190:4, 3193:6,

3196:15, 3196:18, 3198:18, 3198:22,

3200:9, 3200:15, 3200:24, 3201:2,

3201:4, 3201:7, 3201:15, 3201:17,

3201:25, 3204:6, 3204:8, 3204:18,

3204:22, 3205:5, 3205:20, 3206:4,

3207:11, 3208:16, 3208:23, 3209:9,

3209:12, 3210:10, 3210:13, 3210:15,

3210:18, 3210:21, 3211:10, 3211:14,

3212:22, 3213:1, 3213:3, 3213:5,

3213:18, 3213:22, 3214:13, 3215:15,

3216:16, 3216:20, 3217:7, 3219:6,

3219:10, 3219:12, 3220:18, 3220:23,

3221:1, 3221:4, 3221:7, 3222:2,

3222:19, 3222:21, 3226:15, 3226:20,

3227:4, 3227:8, 3227:12, 3227:21,

3228:1, 3228:7, 3228:13, 3228:15,

3228:24, 3229:1, 3229:6, 3229:14,

3229:18, 3230:1, 3230:4, 3230:13,

3230:16, 3230:19, 3231:24, 3234:2,

3234:5, 3234:11, 3234:16, 3234:18,

3234:21, 3234:24, 3235:1, 3235:12,

3235:15, 3236:6, 3236:10, 3236:15,

3236:19, 3236:21, 3238:10, 3238:13,

3238:15, 3238:25, 3239:14, 3239:17,

3239:20, 3240:14, 3243:21, 3244:20,

3245:12, 3245:22, 3247:15, 3247:17,

3247:20, 3248:10, 3248:14, 3248:16,

3248:19, 3248:25, 3249:3, 3249:6,

3249:8, 3249:11, 3249:19, 3250:9,

3250:15, 3252:15, 3254:7, 3254:10,

3254:13, 3254:19, 3254:21, 3254:23,

3256:11, 3256:16, 3256:20, 3256:22,

3257:8, 3257:10, 3257:12, 3257:15,

3257:22, 3258:1, 3258:16, 3258:20,

3258:24, 3260:11, 3260:21, 3260:24,

3261:3, 3261:9, 3261:25, 3266:12,

3268:11, 3268:13, 3269:1, 3269:17,

3270:3, 3270:7, 3270:16, 3270:18,

3271:9, 3271:14, 3271:17, 3271:21,

3271:25, 3272:7, 3272:10, 3272:17,

3272:20, 3272:22, 3272:24, 3273:2,

3273:5, 3273:10, 3273:16, 3273:21,

3274:1, 3274:6, 3274:10, 3274:13,

3275:5, 3275:8, 3275:11, 3275:20,

3275:24, 3277:18, 3278:3, 3278:14,

3278:18, 3279:1, 3279:3, 3279:9,

3279:18, 3280:21, 3281:3, 3281:5,

3281:8, 3282:3, 3285:14, 3285:17,

3286:7, 3286:13, 3286:21, 3287:6,

3287:9, 3287:20, 3291:21, 3292:1,

3292:7, 3295:20, 3295:23, 3296:1,

3296:20, 3297:15, 3297:18, 3297:25,

3298:3, 3298:6, 3298:11, 3298:14,

3299:4, 3299:12, 3299:15, 3299:25,

3300:16, 3300:25, 3303:4, 3304:16,

3304:18, 3304:21, 3305:3, 3306:2,

3307:2, 3308:16, 3308:21, 3308:25,

3309:3, 3309:13, 3311:6, 3311:12,

3316:7, 3316:10, 3322:18, 3323:11,

3324:1, 3324:5, 3324:10, 3325:17,

3325:25, 3326:10, 3326:14, 3329:8,

3329:14, 3329:16, 3331:2, 3331:12,

3331:16, 3331:19, 3331:23, 3331:25,

3332:3, 3332:5, 3341:21, 3341:23,

3350:1, 3350:5, 3350:14, 3350:20,

3351:1, 3351:7, 3351:10, 3351:15,

3351:22, 3353:1, 3355:23, 3361:5,

3362:11, 3362:15, 3368:10, 3368:13,

3371:6, 3373:23, 3374:1, 3380:10,

3383:8, 3383:11, 3383:16, 3383:21,

3384:1, 3384:11, 3385:2, 3386:14,

3388:24, 3389:1, 3389:3, 3389:6,

3389:9, 3389:11, 3390:18, 3390:20,

3390:22, 3391:2, 3397:14, 3397:16,

3397:23, 3399:5, 3399:8, 3399:20,

3399:22, 3405:14, 3405:17, 3406:8,

3406:20, 3406:22, 3407:10, 3407:13,

3407:16, 3407:18, 3408:9, 3408:12,

3408:21, 3408:25, 3409:23, 3410:7,

3410:12, 3411:3, 3411:7, 3411:13,

3411:21, 3412:2, 3412:5, 3412:11,

3412:15, 3412:19, 3413:18, 3413:20,

3414:16, 3414:20, 3415:5, 3415:25,

3416:2, 3416:6, 3416:10, 3416:22,

3417:13, 3417:21, 3418:5, 3418:12,

3418:15, 3418:24, 3420:3, 3420:7,

3420:15, 3420:19, 3421:19, 3421:24,

3422:4, 3422:8, 3422:11, 3422:17,

3422:19, 3422:23, 3423:5, 3423:11,

3423:20, 3423:23, 3424:3

court [4] - 3331:15, 3333:10, 3414:2,

3419:2

Court [14] - 3144:11, 3178:25,

3183:22, 3235:2, 3316:8, 3383:9,

3410:24, 3411:6, 3412:9, 3414:5,

3415:1, 3416:12, 3416:15, 3420:11

Court's [2] - 3218:3, 3420:2

courtroom [4] - 3301:7, 3386:11,

3402:22, 3415:11

cousin [2] - 3409:6, 3409:7

cover [10] - 3163:2, 3182:18, 3184:23,

3186:24, 3196:5, 3198:1, 3255:5,

3255:18, 3366:20, 3374:12

covered [2] - 3183:1, 3360:23

covering [1] - 3182:22

coward [3] - 3306:21, 3400:19,Johnny C. Sanchez, RMR, CRR - [email protected]

3433

3400:25

CPAs [1] - 3175:23

CPU [2] - 3388:24, 3389:8

create [2] - 3336:23, 3338:16

created [2] - 3188:21, 3413:16

creative [3] - 3165:2, 3169:15, 3169:18

credibility [2] - 3286:8, 3286:10

credit [3] - 3208:1, 3208:2, 3225:20

credited [1] - 3251:20

cried [1] - 3261:22

crime [1] - 3399:16

crimes [1] - 3328:2

criminal [1] - 3304:12

crisis [1] - 3166:18

Croix [5] - 3176:1, 3226:13, 3227:4,

3231:14, 3269:21

crook [9] - 3306:17, 3309:8, 3309:11,

3309:18, 3321:15, 3379:8, 3379:20,

3379:22, 3379:25

crooks [1] - 3380:5

cross [5] - 3410:19, 3414:24, 3415:17,

3420:1, 3422:5

CROSS [2] - 3145:5, 3296:2

cross-examination [4] - 3410:19,

3414:24, 3415:17, 3420:1

CROSS-EXAMINATION [2] - 3145:5,

3296:2

CRR [2] - 3144:11, 3424:9

cry [1] - 3261:21

cup [1] - 3423:16

currency [2] - 3347:10, 3347:17

current [6] - 3200:23, 3250:25,

3403:20, 3405:15, 3405:19, 3414:10

curtailing [1] - 3174:15

curve [1] - 3412:18

cushion [1] - 3202:17

customer [1] - 3191:9

customers [11] - 3150:11, 3151:19,

3152:15, 3155:9, 3171:7, 3173:12,

3173:15, 3173:18, 3181:25, 3201:23,

3246:5

D

D.C [1] - 3234:10

daily [3] - 3180:24, 3183:14, 3195:16

danger [1] - 3421:17

Danny [3] - 3160:3, 3233:18, 3244:4

data [5] - 3187:23, 3188:11, 3304:5,

3393:23, 3395:13

date [18] - 3188:24, 3189:5, 3191:8,

3191:25, 3192:20, 3194:15, 3203:16,

3237:6, 3250:4, 3250:5, 3250:14,

3250:22, 3282:18, 3314:6, 3332:11,

3332:14, 3364:20, 3364:23

dated [3] - 3154:14, 3191:13, 3202:6

dates [3] - 3191:3, 3191:7, 3208:22

DAVID [1] - 3143:10

Davis [106] - 3146:10, 3155:5, 3156:9,

3167:20, 3168:8, 3176:10, 3177:17,

3179:21, 3184:4, 3185:22, 3187:13,

3192:14, 3202:11, 3206:8, 3206:20,

3208:11, 3209:4, 3211:9, 3213:14,

3213:19, 3222:7, 3223:23, 3234:13,

3236:5, 3236:18, 3247:25, 3252:17,

3258:4, 3268:23, 3273:13, 3290:2,

3291:11, 3292:10, 3296:4, 3302:24,

3304:11, 3304:18, 3307:15, 3310:14,

3311:14, 3311:16, 3312:9, 3313:7,

3314:6, 3316:12, 3317:6, 3319:17,

3320:21, 3324:15, 3325:2, 3327:9,

3330:6, 3330:16, 3331:22, 3332:8,

3334:15, 3340:3, 3341:14, 3342:22,

3343:11, 3346:11, 3351:24, 3352:14,

3353:12, 3360:19, 3361:7, 3362:5,

3362:20, 3362:24, 3363:1, 3364:1,

3365:13, 3365:23, 3367:13, 3368:7,

3368:15, 3368:23, 3368:25, 3370:2,

3370:13, 3371:1, 3371:10, 3372:23,

3373:10, 3373:15, 3374:6, 3380:14,

3381:20, 3382:9, 3384:22, 3385:10,

3385:24, 3391:5, 3393:3, 3398:6,

3399:1, 3399:14, 3400:13, 3401:20,

3403:20, 3407:3, 3409:20, 3410:20,

3421:25, 3422:2, 3422:3

DAVIS [2] - 3145:3, 3146:7

davis [1] - 3359:16

Davis's [1] - 3408:20

day-to-day [2] - 3159:6, 3159:8

days [14] - 3151:8, 3151:12, 3182:14,

3191:18, 3191:21, 3193:20, 3374:3,

3415:23, 3415:25, 3416:4, 3416:6,

3416:7, 3417:7, 3421:10

DC [1] - 3143:18

deadline [1] - 3415:19

deal [14] - 3215:10, 3232:20, 3258:22,

3301:10, 3306:10, 3306:24, 3308:7,

3310:1, 3310:10, 3320:24, 3321:8,

3321:14, 3337:13, 3423:2

dealer [5] - 3150:5, 3150:11, 3151:16,

3153:4, 3154:3

dealing [2] - 3174:14, 3311:11

debit [2] - 3208:1, 3367:25

deceive [2] - 3344:16, 3407:4

deceived [1] - 3406:2

December [12] - 3195:18, 3196:2,

3202:6, 3221:20, 3228:17, 3228:18,

3291:2, 3291:16, 3314:2, 3314:3,

3335:3, 3380:19

decide [5] - 3312:14, 3318:4, 3330:22,

3417:16, 3417:22

decided [12] - 3163:25, 3208:7,

3218:13, 3244:22, 3281:25, 3282:4,

3286:2, 3306:9, 3311:1, 3312:4,

3318:16, 3386:7

decides [1] - 3373:19

deciding [2] - 3158:13, 3164:11

decision [21] - 3149:19, 3149:22,

3159:23, 3160:21, 3175:20, 3202:18,

3213:11, 3238:4, 3238:6, 3238:10,

3238:11, 3268:15, 3273:10, 3281:11,

3281:18, 3281:21, 3300:5, 3318:3,

3347:19, 3384:3

decisions [4] - 3174:6, 3174:10,

3174:11, 3273:7

declare [1] - 3337:6

deeds [1] - 3222:2

defendant [3] - 3272:18, 3273:14,

3362:15

DEFENDANT [2] - 3143:20, 3144:2

defense [10] - 3154:21, 3295:23,

3413:24, 3414:12, 3415:17, 3416:24,

3417:7, 3417:19, 3419:17, 3423:20

Defense [2] - 3362:6, 3368:9

definitely [1] - 3410:9

definitions [1] - 3237:11

degree [1] - 3261:19

dehydration [1] - 3162:10

deliberations [1] - 3276:5

delineate [1] - 3239:9

demanded [1] - 3379:17

demands [1] - 3197:4

DeMaria [3] - 3170:2, 3170:6, 3170:11

demonstrate [1] - 3349:6

demonstration [1] - 3208:19

denied [2] - 3321:20, 3412:5

depart [1] - 3178:16

department [4] - 3169:16, 3175:15,

3381:21, 3404:16

Department [2] - 3143:17, 3413:13

depicted [1] - 3264:12

deposit [3] - 3148:8, 3149:4, 3278:1

deposited [1] - 3368:4

depositor [3] - 3197:4, 3202:15,

3290:1

depositors [22] - 3150:24, 3161:11,

3161:14, 3164:20, 3170:17, 3171:4,

3171:6, 3173:11, 3180:2, 3182:23,

3189:20, 3191:1, 3198:15, 3199:6,

3226:5, 3253:6, 3259:25, 3263:17,

3263:24, 3277:3, 3277:5, 3289:6

deposits [2] - 3202:23, 3242:21

Depression [1] - 3220:11

describe [3] - 3209:15, 3235:18,

3283:4

described [3] - 3165:22, 3179:10,

3400:19

describing [1] - 3221:24

design [1] - 3341:25

designated [1] - 3210:7

designed [1] - 3391:21

desire [4] - 3173:21, 3231:6, 3231:7,

3355:25

desired [2] - 3207:5, 3207:19

desirous [1] - 3151:15

desk [2] - 3389:4, 3390:8

desktop [6] - 3387:11, 3391:4, 3392:7,

3392:20, 3393:4, 3393:18

desktops [1] - 3388:20

destroy [1] - 3286:5

destroyed [3] - 3285:13, 3395:17,

3396:4

destroying [1] - 3395:21

detail [4] - 3234:14, 3235:18, 3235:20

details [3] - 3232:24, 3356:24, 3413:6

detecting [1] - 3279:23

determine [2] - 3397:9, 3411:3Johnny C. Sanchez, RMR, CRR - [email protected]

3434

determined [1] - 3289:24

developed [5] - 3219:4, 3219:5,

3219:24, 3223:8, 3414:14

development [2] - 3174:15, 3227:11

device [2] - 3393:12, 3393:14

devices [1] - 3350:22

diagram [4] - 3208:14, 3216:17,

3224:1, 3224:2

dialogue [1] - 3302:21

died [2] - 3146:13, 3146:17

difference [4] - 3241:2, 3255:7,

3255:13, 3380:24

different [13] - 3165:8, 3166:18,

3212:20, 3239:18, 3251:9, 3259:6,

3259:24, 3263:24, 3279:20, 3330:25,

3339:21, 3343:3, 3373:21

difficult [3] - 3147:22, 3147:23,

3291:12

dilemma [2] - 3203:23

diligently [1] - 3415:9

diminished [1] - 3181:14

diminishing [1] - 3181:14

direct [12] - 3154:16, 3174:5, 3328:14,

3328:18, 3335:22, 3353:11, 3387:4,

3393:11, 3395:16, 3401:2, 3401:9,

3422:6

DIRECT [2] - 3145:4, 3146:8

directed [2] - 3241:24, 3383:5

direction [6] - 3194:8, 3330:10,

3382:19, 3382:25, 3383:20, 3384:19

directly [5] - 3177:13, 3237:3, 3247:3,

3247:4, 3293:8

director [3] - 3169:15, 3178:17,

3386:24

directors [6] - 3202:18, 3375:3,

3375:6, 3378:15, 3379:16, 3380:3

disagree [2] - 3329:4, 3355:24

disbelief [1] - 3169:7

disbursed [1] - 3186:22

disclose [2] - 3266:23, 3286:3

disclosed [2] - 3268:17, 3273:4

disclosure [8] - 3163:18, 3289:12,

3289:16, 3289:19, 3289:23, 3290:3,

3290:6, 3290:7

discontinue [1] - 3179:1

discuss [10] - 3154:6, 3215:6,

3231:11, 3235:10, 3284:7, 3288:4,

3302:6, 3385:19, 3418:2, 3421:4

discussed [13] - 3147:15, 3157:7,

3175:6, 3188:17, 3203:14, 3206:24,

3242:4, 3288:5, 3288:6, 3302:6,

3302:19, 3325:1, 3386:11

discussing [13] - 3146:12, 3157:3,

3197:15, 3197:18, 3228:8, 3228:10,

3285:2, 3285:3, 3285:4, 3285:21,

3287:15, 3289:20, 3417:1

discussion [9] - 3147:18, 3152:3,

3231:13, 3238:1, 3238:19, 3239:3,

3242:7, 3277:12, 3298:13

displayed [2] - 3248:22, 3319:14

disregard [4] - 3183:22, 3316:9,

3383:10, 3383:11

distributed [2] - 3248:19, 3248:21

distribution [1] - 3214:4

DISTRICT [3] - 3143:1, 3143:1,

3143:10

divided [1] - 3218:6

DIVISION [1] - 3143:2

divorce [8] - 3212:9, 3212:11,

3212:14, 3213:11, 3214:3, 3214:5,

3214:17, 3214:22

document [24] - 3154:22, 3155:20,

3155:22, 3203:2, 3206:18, 3207:4,

3208:12, 3223:12, 3247:25, 3315:10,

3316:21, 3316:24, 3317:1, 3317:2,

3317:6, 3324:6, 3345:20, 3346:7,

3352:1, 3352:8, 3352:10, 3373:15,

3373:16, 3374:6

documentation [1] - 3349:18

documents [38] - 3221:16, 3231:20,

3236:5, 3237:13, 3237:18, 3305:5,

3316:15, 3318:21, 3325:23, 3326:24,

3326:25, 3327:14, 3335:8, 3335:10,

3335:13, 3335:17, 3336:11, 3336:22,

3340:2, 3340:4, 3341:8, 3346:5,

3349:5, 3349:10, 3349:14, 3352:13,

3366:4, 3372:15, 3372:20, 3372:21,

3384:22, 3385:24, 3386:6, 3386:8,

3386:10, 3386:12, 3395:9

doings [1] - 3352:24

dollar [6] - 3160:12, 3223:20, 3255:11,

3347:12, 3360:3, 3367:5

dollar-wise [1] - 3223:20

dollars [42] - 3151:9, 3182:4, 3184:6,

3191:8, 3201:20, 3203:3, 3203:8,

3204:2, 3206:11, 3221:22, 3224:13,

3226:6, 3246:7, 3295:16, 3314:15,

3316:1, 3316:5, 3318:17, 3322:3,

3322:9, 3322:20, 3323:3, 3323:8,

3324:20, 3326:4, 3326:23, 3330:17,

3330:19, 3339:2, 3341:5, 3348:23,

3349:8, 3355:1, 3359:24, 3361:25,

3362:1, 3365:7, 3365:23, 3366:11,

3370:17, 3380:20

domestically [3] - 3278:2, 3278:3,

3280:10

Dominion [1] - 3186:3

Don [1] - 3377:13

donated [1] - 3313:13

donation [3] - 3294:25, 3295:2,

3312:23

donations [1] - 3294:21

done [29] - 3175:25, 3176:13, 3203:10,

3207:23, 3208:24, 3214:6, 3217:23,

3218:19, 3220:3, 3222:3, 3223:5,

3226:18, 3249:11, 3267:7, 3274:24,

3276:17, 3277:23, 3279:13, 3304:13,

3311:24, 3338:18, 3347:5, 3370:8,

3396:6, 3414:3, 3415:12, 3417:8,

3418:7, 3422:2

door [1] - 3338:13

doors [2] - 3165:4, 3165:6

doubt [2] - 3176:22, 3411:19

down [70] - 3146:4, 3146:25, 3157:6,

3157:14, 3157:16, 3157:21, 3161:3,

3170:18, 3170:25, 3171:3, 3171:8,

3171:10, 3171:18, 3171:24, 3172:16,

3173:13, 3173:17, 3174:13, 3181:19,

3188:13, 3188:15, 3188:23, 3189:7,

3189:12, 3189:18, 3189:22, 3189:25,

3190:1, 3194:25, 3198:16, 3199:3,

3202:1, 3208:13, 3212:24, 3213:7,

3217:8, 3227:22, 3227:24, 3251:7,

3262:4, 3262:5, 3262:23, 3263:11,

3268:3, 3290:13, 3292:3, 3294:1,

3307:4, 3307:8, 3308:25, 3309:20,

3317:20, 3357:1, 3362:4, 3366:6,

3366:24, 3367:4, 3367:23, 3369:21,

3370:22, 3380:25, 3383:19, 3387:2,

3389:15, 3397:6, 3415:6, 3419:4,

3420:24, 3421:17

downfall [1] - 3302:18

downstairs [1] - 3423:16

downtown [1] - 3341:17

downturn [2] - 3198:19, 3220:11

drafted [1] - 3396:13

drafts [1] - 3285:24

drain [2] - 3188:16, 3195:15

draw [12] - 3194:24, 3201:23, 3291:15,

3292:22, 3312:13, 3315:6, 3334:19,

3334:20, 3334:21, 3334:24, 3336:11,

3353:19

drawn [5] - 3305:6, 3315:7, 3315:9,

3316:16, 3318:21

draws [1] - 3208:25

drew [8] - 3224:1, 3224:2, 3232:9,

3248:16, 3312:2, 3353:12, 3353:20,

3353:21

drive [11] - 3285:10, 3318:5, 3387:5,

3393:15, 3393:25, 3394:25, 3395:6,

3395:11, 3396:20, 3399:14

drives [4] - 3285:10, 3285:15, 3286:5,

3286:14

dropping [1] - 3255:4

drove [2] - 3284:21, 3284:22

due [1] - 3326:8

dumb [3] - 3411:17, 3412:7, 3412:10

dummy [1] - 3386:7

dummy-up [1] - 3386:7

during [14] - 3233:25, 3234:13,

3238:16, 3267:3, 3268:15, 3274:23,

3276:9, 3281:18, 3283:13, 3294:19,

3310:21, 3382:2, 3382:6, 3410:18

E

e-mail [32] - 3173:25, 3177:14,

3184:10, 3185:3, 3185:6, 3185:17,

3186:17, 3187:13, 3187:24, 3187:25,

3190:9, 3190:14, 3191:2, 3191:4,

3191:12, 3191:15, 3192:22, 3193:17,

3193:22, 3193:25, 3194:1, 3194:10,

3194:18, 3195:9, 3195:18, 3196:23,

3226:8, 3226:25, 3293:5, 3338:23,

3396:18

e-mails [5] - 3197:1, 3329:6, 3394:24,

3395:7, 3395:8Johnny C. Sanchez, RMR, CRR - [email protected]

3435

Eagles [1] - 3165:15

early [12] - 3146:20, 3147:3, 3151:8,

3151:12, 3151:25, 3169:20, 3177:11,

3215:5, 3231:17, 3414:11, 3414:22,

3418:22

earn [1] - 3167:14

earned [1] - 3294:18

earning [1] - 3182:16

earnings [1] - 3202:12

ears [1] - 3350:11

easel [1] - 3305:7

easier [5] - 3208:11, 3209:8, 3304:19,

3364:3, 3420:22

East [1] - 3233:4

easy [1] - 3365:19

eats [2] - 3292:24, 3337:1

economic [4] - 3198:3, 3198:18,

3203:23, 3227:11

economy [3] - 3220:9, 3316:3, 3330:8

effect [9] - 3208:20, 3272:12, 3275:6,

3284:8, 3298:16, 3347:14, 3349:19,

3382:14, 3420:21

effective [1] - 3171:1

effectively [1] - 3176:18

effort [6] - 3254:16, 3328:19, 3340:6,

3352:12, 3385:17, 3396:11

efforts [4] - 3169:18, 3243:3, 3396:9,

3396:11

eight [2] - 3403:9, 3403:10

either [11] - 3170:6, 3180:21, 3234:18,

3242:1, 3270:22, 3274:16, 3310:20,

3323:14, 3396:18, 3417:22, 3421:16

elder [4] - 3402:4, 3402:6, 3402:12,

3402:14

elderly [1] - 3377:24

electrified [1] - 3351:15

elevate [1] - 3148:17

elicit [1] - 3272:4

elicited [1] - 3239:18

eliminate [2] - 3163:5, 3223:21

eliminating [1] - 3225:4

elongated [1] - 3421:4

elsewhere [1] - 3149:1

elusive [1] - 3338:24

emergency [1] - 3162:6

emeritus [2] - 3376:1, 3376:8

emotional [1] - 3197:13

emperor [1] - 3197:21

empire [1] - 3401:3

employ [1] - 3148:13

employee [3] - 3194:8, 3269:10,

3270:4

employees [13] - 3167:12, 3167:24,

3168:6, 3172:16, 3173:7, 3173:12,

3173:16, 3189:14, 3354:20, 3355:14,

3355:19, 3356:2, 3391:22

enable [1] - 3149:19

enabling [1] - 3239:7

encountering [1] - 3165:23

end [28] - 3146:20, 3147:2, 3147:14,

3150:14, 3163:4, 3167:4, 3169:10,

3177:25, 3178:19, 3179:22, 3179:24,

3181:8, 3181:13, 3181:16, 3183:18,

3211:4, 3263:7, 3265:20, 3301:18,

3314:15, 3316:18, 3324:7, 3358:16,

3371:24, 3372:2, 3374:15, 3374:16,

3415:21

ended [5] - 3146:12, 3179:25, 3335:1,

3380:19, 3406:10

engaged [1] - 3230:24

enlarge [5] - 3185:4, 3185:17,

3191:11, 3206:17, 3223:13

enlarged [2] - 3207:4, 3222:14

entered [2] - 3326:17, 3391:18

entertainment [3] - 3211:7, 3251:10,

3253:1

entire [6] - 3167:21, 3185:18, 3239:4,

3269:24, 3271:6, 3407:11

entities [2] - 3161:12, 3364:8

entitled [3] - 3286:12, 3416:25, 3424:7

entity [1] - 3364:7

entries [5] - 3209:18, 3221:24,

3224:17, 3224:22, 3225:18

entry [13] - 3200:7, 3200:10, 3200:13,

3200:17, 3204:15, 3205:9, 3205:11,

3206:8, 3206:13, 3206:25, 3207:25,

3208:6, 3208:8

epiphany [2] - 3310:23

equal [3] - 3186:18, 3224:25, 3290:22

equity [21] - 3184:19, 3184:22,

3198:13, 3199:10, 3199:12, 3199:13,

3202:21, 3203:1, 3203:7, 3204:1,

3204:12, 3208:2, 3248:7, 3249:25,

3251:11, 3252:18, 3252:22, 3252:25,

3253:10, 3259:16, 3261:17

equivalent [1] - 3378:9

erase [1] - 3334:2

es [1] - 3325:24

especially [1] - 3181:20

essence [4] - 3260:21, 3260:23,

3260:24, 3261:9

essentially [1] - 3262:18

establish [3] - 3180:21, 3268:24,

3397:7

established [3] - 3152:18, 3229:22,

3230:10

estate [55] - 3174:14, 3184:19,

3184:22, 3208:10, 3209:17, 3209:21,

3210:3, 3210:4, 3210:7, 3211:20,

3212:3, 3212:15, 3213:10, 3215:21,

3216:11, 3217:3, 3217:20, 3218:10,

3218:13, 3218:14, 3220:13, 3223:1,

3223:20, 3224:2, 3225:6, 3225:11,

3225:24, 3251:23, 3252:3, 3252:6,

3252:9, 3253:19, 3259:14, 3261:15,

3292:25, 3340:13, 3340:14, 3340:15,

3340:22, 3340:24, 3340:25, 3341:1,

3341:2, 3341:3, 3341:9, 3341:17,

3341:19, 3343:1, 3343:4, 3358:12,

3361:11, 3361:13, 3361:18, 3361:20

estates [1] - 3340:18

estimate [1] - 3421:10

et [5] - 3189:16, 3253:1, 3285:24,

3351:4, 3354:10

Europe [1] - 3242:14

evening [2] - 3162:7, 3283:23

event [5] - 3162:25, 3310:17, 3310:21,

3311:14, 3423:2

events [4] - 3163:20, 3164:22,

3166:18, 3166:21

eventually [7] - 3249:8, 3249:10,

3268:9, 3276:3, 3282:11, 3282:19,

3288:8

Evidence [1] - 3303:22

evidence [15] - 3155:16, 3168:19,

3192:10, 3192:25, 3204:25, 3205:4,

3271:10, 3285:7, 3329:6, 3373:20,

3395:18, 3395:21, 3396:4, 3399:17,

3400:17

evidenced [1] - 3222:3

ex [3] - 3410:8, 3410:10, 3415:1

exact [3] - 3228:7, 3261:10, 3359:15

exactly [9] - 3214:10, 3272:19,

3272:25, 3298:6, 3312:15, 3335:9,

3338:22, 3342:12, 3418:19

exam [1] - 3157:18

examination [12] - 3328:14, 3328:18,

3335:23, 3353:11, 3387:4, 3393:11,

3401:2, 3401:10, 3410:19, 3414:24,

3415:17, 3420:1

EXAMINATION [4] - 3145:4, 3145:5,

3146:8, 3296:2

example [5] - 3176:20, 3259:13,

3266:21, 3322:19, 3402:13

exceed [1] - 3202:24

excellent [1] - 3202:1

except [2] - 3156:1, 3278:19

exception [2] - 3270:15, 3271:8

Exception [1] - 3273:15

excess [7] - 3188:20, 3358:20,

3358:21, 3359:10, 3359:11, 3359:14,

3359:16

Exchange [3] - 3236:16, 3237:6,

3327:10

excited [1] - 3163:17

excitement [1] - 3164:17

excluded [1] - 3155:24

excuse [18] - 3146:22, 3157:8, 3158:3,

3167:20, 3185:14, 3204:6, 3204:23,

3211:10, 3236:20, 3260:8, 3279:16,

3282:3, 3284:13, 3308:16, 3322:5,

3326:10, 3412:8, 3419:22

excused [1] - 3423:24

executive [1] - 3160:10

executives [6] - 3233:7, 3256:5,

3258:6, 3259:23, 3266:6, 3283:7

exempt [1] - 3214:4

Exhibit [18] - 3154:13, 3180:7, 3185:3,

3195:17, 3202:5, 3206:15, 3221:20,

3222:9, 3222:12, 3247:22, 3285:23,

3289:9, 3291:7, 3312:25, 3319:15,

3362:7, 3368:9, 3373:13

exhibit [12] - 3155:14, 3196:22,

3222:10, 3319:5, 3332:19, 3333:24,

3334:7, 3334:12, 3367:15, 3373:15,

3374:6, 3380:8

exhibits [4] - 3414:13, 3415:17,

3415:22, 3416:14Johnny C. Sanchez, RMR, CRR - [email protected]

3436

Exhibits [1] - 3236:3

exist [2] - 3340:4, 3366:5

existed [1] - 3258:21

existence [3] - 3171:21, 3259:19,

3385:3

exists [3] - 3155:8, 3345:22, 3349:21

expand [1] - 3157:1

expansion [1] - 3174:13

expectations [1] - 3202:13

expected [1] - 3217:1

expecting [2] - 3191:10, 3256:17

expense [2] - 3175:22, 3175:24

expenses [6] - 3175:6, 3225:20,

3360:19, 3360:21, 3380:22, 3380:24

experience [3] - 3160:8, 3160:15,

3305:25

expert [6] - 3218:19, 3413:9, 3417:12,

3417:14, 3417:17, 3417:19

experts [4] - 3413:3, 3413:7, 3413:8,

3413:15

explain [20] - 3147:23, 3150:3,

3152:13, 3157:5, 3161:8, 3176:13,

3183:1, 3191:6, 3199:11, 3209:4,

3212:1, 3223:15, 3234:14, 3248:5,

3254:3, 3275:13, 3346:24, 3353:25,

3356:8, 3366:13

explained [5] - 3212:13, 3214:21,

3259:4, 3262:25, 3276:9

explaining [1] - 3303:22

explains [2] - 3208:25, 3209:2

explanation [1] - 3328:22

exposed [2] - 3178:21, 3179:10

express [7] - 3157:20, 3169:7,

3173:21, 3197:7, 3240:2, 3240:5,

3260:15

expressed [1] - 3380:20

expression [2] - 3197:21, 3247:9

extent [3] - 3151:10, 3292:20, 3355:23

extra [2] - 3205:21, 3351:17

extravaganza [1] - 3164:16

extreme [1] - 3197:13

extremely [1] - 3181:14

eyesight [1] - 3380:11

F

face [1] - 3203:22

facilitate [1] - 3354:6

facilities [1] - 3170:19

facing [1] - 3411:24

fact [39] - 3148:3, 3151:18, 3154:13,

3163:7, 3171:2, 3176:10, 3184:5,

3188:18, 3193:17, 3203:5, 3226:3,

3230:2, 3264:6, 3265:7, 3265:11,

3272:5, 3280:11, 3286:4, 3289:9,

3296:7, 3318:20, 3320:24, 3321:14,

3335:13, 3335:18, 3341:8, 3353:12,

3356:7, 3361:16, 3366:23, 3369:15,

3371:9, 3371:23, 3402:1, 3403:23,

3404:6, 3412:15, 3414:3, 3415:10

facts [5] - 3168:19, 3204:24, 3205:4,

3230:3, 3275:22

failed [2] - 3148:1, 3171:2

Failing [1] - 3212:18

fair [2] - 3237:15, 3398:5

Fair [1] - 3214:20

fairly [2] - 3148:20, 3167:15

fake [1] - 3354:1

fall [7] - 3161:2, 3161:5, 3161:7,

3165:23, 3177:11, 3198:5, 3216:15

false [1] - 3290:8

falsely [1] - 3232:16

familiar [9] - 3149:25, 3200:18,

3206:20, 3218:22, 3310:23, 3333:19,

3347:8, 3388:6, 3404:24

family [1] - 3344:14

family's [1] - 3391:9

far [6] - 3165:17, 3211:12, 3232:11,

3300:19, 3327:20, 3409:10

farm [2] - 3294:16, 3320:12

farmers [1] - 3368:17

Farmers [2] - 3362:23, 3370:11

fast [1] - 3415:19

father [3] - 3214:2, 3375:20, 3376:12

fault [1] - 3263:15

Fazel [3] - 3143:20, 3143:21, 3413:12

FAZEL [19] - 3192:24, 3298:9,

3410:15, 3410:17, 3411:5, 3412:4,

3412:6, 3413:1, 3413:24, 3414:18,

3414:21, 3415:8, 3416:1, 3417:25,

3418:10, 3418:13, 3422:10, 3422:18,

3423:22

FBI [10] - 3304:11, 3307:5, 3307:8,

3307:16, 3309:15, 3385:23, 3396:8,

3396:9, 3397:6, 3397:8

February [20] - 3143:5, 3171:25,

3172:2, 3182:11, 3240:11, 3240:23,

3241:9, 3241:14, 3243:7, 3250:3,

3250:21, 3255:20, 3258:7, 3282:13,

3287:13, 3288:19, 3394:9, 3394:17

fed [1] - 3174:8

feelings [1] - 3177:14

fees [2] - 3211:6, 3211:7

feet [4] - 3162:14, 3351:21, 3389:21,

3390:6

fell [1] - 3256:14

felt [1] - 3260:9

few [4] - 3172:10, 3172:11, 3245:5,

3302:10

fiancee [1] - 3246:25

fictitious [2] - 3224:15, 3241:1

field [1] - 3176:3

fiend [1] - 3297:22

figure [1] - 3359:8

figures [3] - 3188:5, 3222:4, 3381:25

file [7] - 3337:9, 3337:11, 3337:14,

3337:15, 3337:18, 3374:1, 3393:10

filed [4] - 3338:8, 3375:2, 3418:13,

3418:14

files [1] - 3393:9

filing [1] - 3338:13

fill [1] - 3227:4

final [1] - 3182:14

finalize [1] - 3232:24

finally [4] - 3188:23, 3254:8, 3254:14,

3262:18

finance [2] - 3356:10, 3356:11

financed [1] - 3270:11

finances [2] - 3358:6, 3358:8

financial [52] - 3150:6, 3150:12,

3158:5, 3158:6, 3158:11, 3158:17,

3158:23, 3159:7, 3159:15, 3163:21,

3163:25, 3164:6, 3164:10, 3165:9,

3167:5, 3168:14, 3168:17, 3169:6,

3170:5, 3184:11, 3186:11, 3192:15,

3226:5, 3235:22, 3237:16, 3241:1,

3241:21, 3241:24, 3242:14, 3253:1,

3260:1, 3264:15, 3275:1, 3275:15,

3276:8, 3276:13, 3276:17, 3276:19,

3276:24, 3276:25, 3277:6, 3277:7,

3277:25, 3279:17, 3288:24, 3289:6,

3304:5, 3322:7, 3356:9, 3358:5,

3374:17, 3386:24

Financial [16] - 3178:16, 3179:9,

3238:8, 3251:17, 3269:20, 3270:22,

3270:23, 3270:25, 3271:2, 3279:16,

3290:15, 3355:7, 3356:19, 3358:7,

3381:21, 3398:3

financials [5] - 3264:21, 3264:22,

3264:23, 3265:3

findings [2] - 3412:12, 3412:15

fine [7] - 3193:7, 3275:22, 3331:2,

3407:21, 3418:5, 3421:7, 3423:15

finish [3] - 3243:15, 3350:1, 3350:2

fired [4] - 3169:12, 3169:23, 3169:25,

3170:12

firm [44] - 3147:12, 3147:16, 3147:20,

3148:4, 3148:6, 3148:15, 3148:21,

3148:23, 3148:25, 3149:6, 3149:8,

3149:10, 3149:14, 3149:20, 3150:4,

3150:15, 3150:18, 3150:24, 3151:1,

3151:4, 3151:19, 3152:1, 3152:15,

3152:24, 3153:11, 3156:11, 3156:20,

3157:6, 3157:14, 3157:21, 3158:5,

3159:15, 3159:24, 3160:9, 3160:16,

3160:18, 3160:24, 3234:2, 3234:7,

3261:24, 3268:1, 3270:17, 3417:15,

3417:20

Firm [1] - 3144:6

firms [1] - 3165:9

first [57] - 3151:4, 3151:5, 3153:21,

3173:24, 3181:13, 3181:16, 3181:17,

3191:17, 3194:19, 3199:11, 3209:25,

3210:2, 3224:22, 3228:18, 3240:11,

3240:22, 3241:8, 3241:14, 3243:7,

3243:20, 3244:11, 3244:13, 3250:3,

3257:15, 3258:7, 3266:6, 3277:18,

3282:12, 3286:25, 3290:3, 3290:16,

3292:1, 3293:1, 3306:13, 3307:5,

3307:16, 3308:6, 3309:17, 3329:5,

3333:22, 3342:19, 3343:10, 3374:2,

3382:10, 3394:8, 3400:20, 3402:17,

3402:18, 3403:21, 3407:6, 3410:15,

3411:3, 3416:3, 3417:3, 3417:6, 3419:7

firstly [1] - 3240:13

fiscal [1] - 3374:15

fiscally [1] - 3202:14Johnny C. Sanchez, RMR, CRR - [email protected]

3437

fishbowl [2] - 3173:3, 3173:7

fishing [1] - 3388:18

five [14] - 3147:7, 3149:18, 3180:13,

3205:21, 3268:20, 3278:16, 3329:16,

3361:2, 3367:5, 3418:6, 3419:6,

3421:11

flagged [1] - 3152:7

flash [5] - 3285:9, 3393:14, 3394:25,

3395:6, 3395:11

fleet [1] - 3174:21

flew [2] - 3162:15, 3284:21

flights [1] - 3423:3

flip [6] - 3209:12, 3209:13, 3209:15,

3215:20, 3252:7, 3252:11

FLIP [1] - 3209:12

flips [1] - 3329:2

Floor [2] - 3143:22, 3144:4

floor [4] - 3263:11, 3388:22, 3388:23,

3389:1

Florida [2] - 3175:23, 3243:10

flow [2] - 3195:15, 3364:1

flowed [1] - 3364:7

flowing [1] - 3204:20

fly [3] - 3171:18, 3211:17, 3247:7

flying [1] - 3288:6

Flynn [1] - 3307:9

focus [6] - 3161:1, 3163:5, 3187:10,

3231:6, 3376:13

focused [5] - 3147:9, 3147:10, 3159:9,

3159:14, 3159:17

focussed [1] - 3155:6

focussing [3] - 3185:3, 3229:12,

3231:3

folded [1] - 3290:21

folks [4] - 3254:14, 3256:17, 3278:19,

3351:16

follow [6] - 3243:13, 3339:4, 3379:2,

3383:13, 3383:14, 3384:7

follow-up [3] - 3243:13, 3339:4,

3383:13

following [16] - 3146:1, 3206:3,

3250:16, 3254:19, 3256:23, 3257:21,

3267:11, 3287:4, 3288:18, 3297:17,

3300:24, 3331:9, 3331:15, 3331:18,

3375:25, 3410:4

footnote [1] - 3290:9

footnotes [1] - 3276:21

FOR [3] - 3143:13, 3143:20, 3144:2

forces [1] - 3163:17

foregoing [1] - 3424:5

foreign [2] - 3154:4, 3241:21

forensic [5] - 3279:14, 3279:19,

3280:3, 3280:18

forfeit [4] - 3322:3, 3323:2, 3323:7,

3328:1

forfeited [1] - 3301:14

forfeiture [3] - 3322:13, 3323:17,

3324:7

Forfeiture [1] - 3324:9

forfeitures [1] - 3324:2

forgo [1] - 3421:6

forgot [2] - 3360:7, 3422:12

form [8] - 3146:22, 3155:21, 3224:17,

3256:9, 3258:12, 3311:12, 3322:14,

3407:15

formally [1] - 3204:12

format [2] - 3164:14, 3164:16

former [1] - 3256:19

forms [1] - 3175:24

Fort [6] - 3231:7, 3243:16, 3243:18,

3282:17, 3284:16, 3284:17

forth [4] - 3195:14, 3359:21, 3381:7

forward [4] - 3181:13, 3281:11,

3281:22, 3286:17

foundation [2] - 3155:14, 3268:25

founded [1] - 3300:19

four [9] - 3149:17, 3216:25, 3220:4,

3377:5, 3392:8, 3392:18, 3411:10,

3411:11

fourth [3] - 3181:14, 3199:24, 3247:17

fraud [21] - 3174:3, 3178:8, 3178:21,

3178:22, 3275:17, 3275:25, 3276:2,

3279:23, 3283:8, 3310:5, 3310:6,

3325:4, 3329:21, 3345:25, 3354:6,

3376:2, 3378:18, 3378:22, 3379:11,

3379:12, 3379:20

fraudster [11] - 3306:19, 3306:20,

3308:8, 3308:23, 3308:24, 3309:6,

3309:20, 3310:3, 3310:16, 3311:1,

3311:16

free [2] - 3232:11, 3304:25

frequently [3] - 3158:20, 3159:11,

3184:12

Friday [14] - 3146:12, 3166:18,

3191:20, 3265:22, 3265:23, 3267:13,

3267:14, 3268:12, 3281:18, 3282:12,

3283:23, 3284:18, 3288:7

front [15] - 3235:11, 3285:10, 3301:5,

3305:5, 3313:9, 3323:12, 3323:13,

3330:16, 3386:3, 3388:9, 3388:10,

3388:11, 3410:20, 3410:23, 3411:19

fruit [2] - 3294:16, 3320:12

frustrating [2] - 3175:19, 3384:4

full [2] - 3155:7, 3202:7

fully [3] - 3235:18, 3289:16, 3290:6

function [1] - 3175:25

fund [4] - 3176:21, 3188:6, 3358:11,

3361:23

fundamental [1] - 3359:2

funding [4] - 3188:1, 3188:3, 3189:9,

3355:9

funds [18] - 3150:9, 3161:16, 3187:19,

3191:18, 3191:22, 3192:3, 3194:23,

3196:14, 3199:14, 3285:3, 3301:12,

3325:13, 3337:23, 3337:25, 3354:3,

3370:10, 3411:14, 3412:20

funnel [1] - 3368:6

future [6] - 3177:10, 3225:17, 3225:20,

3232:10, 3232:21

FYI [1] - 3195:9

G

gallery [1] - 3341:24

gather [1] - 3274:17

gathered [1] - 3188:25

gears [1] - 3409:20

general [15] - 3155:21, 3212:7,

3212:17, 3227:20, 3229:3, 3229:16,

3229:23, 3230:8, 3233:15, 3237:14,

3244:2, 3256:12, 3256:13, 3262:12,

3281:24

generally [12] - 3208:23, 3261:10,

3280:23, 3321:21, 3321:22, 3356:10,

3357:11, 3361:14, 3361:15, 3361:20,

3397:1, 3408:25

generate [1] - 3345:20

generated [6] - 3346:7, 3347:10,

3380:23, 3382:1, 3395:9, 3397:3

generation [1] - 3333:22

generic [1] - 3256:10

gentlemen [4] - 3257:17, 3274:13,

3331:3, 3409:25

gift [2] - 3214:2, 3214:3

gifts [1] - 3295:4

Gill [1] - 3381:22

gill [1] - 3381:25

girlfriend [2] - 3405:16, 3408:7

girlfriends [1] - 3410:21

given [15] - 3158:6, 3163:21, 3163:24,

3167:15, 3256:13, 3274:3, 3283:6,

3325:22, 3349:7, 3399:25, 3414:2,

3414:14, 3414:23, 3415:16, 3422:1

glad [1] - 3421:6

glass [2] - 3173:2, 3173:13

global [10] - 3176:1, 3226:13, 3233:19,

3244:1, 3267:17, 3267:24, 3269:7,

3358:1, 3358:3

Global [4] - 3178:18, 3269:20,

3270:22, 3358:9

globe [1] - 3181:5

goal [1] - 3416:14

goals [1] - 3165:16

goodness [1] - 3400:2

Goswick [6] - 3375:14, 3376:23,

3376:24, 3377:6, 3377:21, 3377:22

GOVERNMENT [1] - 3143:13

Government [1] - 3330:24

government [59] - 3178:23, 3242:9,

3242:12, 3286:3, 3286:17, 3301:10,

3301:25, 3302:9, 3303:8, 3303:13,

3305:23, 3306:11, 3306:13, 3307:16,

3308:15, 3308:20, 3309:14, 3309:25,

3310:10, 3310:22, 3311:11, 3312:1,

3314:4, 3315:25, 3316:12, 3316:15,

3316:20, 3320:25, 3321:9, 3321:14,

3321:23, 3322:12, 3324:12, 3324:18,

3325:12, 3325:13, 3326:5, 3326:17,

3328:1, 3335:11, 3336:21, 3337:13,

3337:24, 3338:12, 3373:17, 3373:24,

3383:14, 3385:14, 3386:2, 3395:17,

3396:6, 3400:1, 3410:18, 3413:2,

3413:24, 3418:13, 3419:9, 3419:19,

3423:18

government's [7] - 3297:1, 3315:14,

3335:4, 3384:2, 3384:6, 3417:15,

3418:1Johnny C. Sanchez, RMR, CRR - [email protected]

3438

Government's [23] - 3154:13, 3180:6,

3185:3, 3195:17, 3202:5, 3206:15,

3221:19, 3222:8, 3222:12, 3236:3,

3236:6, 3247:22, 3285:23, 3289:9,

3291:7, 3312:24, 3313:4, 3319:15,

3323:15, 3328:4, 3328:7, 3372:11,

3373:13

grand [2] - 3190:17, 3320:20

granted [3] - 3244:20, 3354:9, 3366:14

grave [1] - 3162:1

gray [1] - 3419:9

great [4] - 3161:25, 3170:7, 3215:10,

3235:8

Great [1] - 3220:11

Green [1] - 3193:1

Gregg [1] - 3143:13

gross [1] - 3421:9

ground [1] - 3389:21

grounds [2] - 3211:7, 3407:10

group [8] - 3176:19, 3192:15, 3233:17,

3245:20, 3253:2, 3253:16, 3269:7,

3271:6

Group [17] - 3147:12, 3150:4, 3150:5,

3178:16, 3179:9, 3238:8, 3244:5,

3251:17, 3269:20, 3270:22, 3270:23,

3270:25, 3271:2, 3290:16, 3356:19,

3358:7, 3381:21

grow [1] - 3202:25

growing [1] - 3184:5

growth [3] - 3159:12, 3159:25,

3202:16

Guardian [1] - 3363:14

guess [10] - 3227:23, 3291:24,

3313:14, 3319:8, 3333:11, 3333:17,

3346:14, 3364:9, 3407:3, 3418:21

guilty [3] - 3295:13, 3300:2, 3309:22

guts [2] - 3389:11, 3389:12

guy [7] - 3338:23, 3358:4, 3365:6,

3366:11, 3382:22, 3383:18, 3417:23

guys [3] - 3377:22, 3400:7, 3420:9

H

half [20] - 3251:22, 3293:3, 3302:8,

3345:9, 3346:3, 3346:6, 3346:7,

3359:24, 3361:25, 3362:1, 3365:6,

3365:22, 3366:11, 3416:9, 3420:23,

3421:12, 3423:15

half-hour [2] - 3420:23, 3423:15

halls [1] - 3165:4

hallway [1] - 3173:2

halt [2] - 3267:18, 3267:19

hand [11] - 3185:24, 3186:2, 3197:3,

3202:9, 3207:3, 3222:13, 3251:8,

3259:20, 3283:2, 3283:3, 3383:18

handed [1] - 3324:6

handle [2] - 3280:23, 3423:5

handled [1] - 3169:17

hands [4] - 3224:13, 3268:8, 3316:25,

3352:9

hang [4] - 3176:5, 3234:16, 3271:9,

3409:24

hangar [8] - 3233:13, 3239:24,

3240:11, 3240:21, 3240:22, 3241:10,

3241:13, 3243:14

haphazard [1] - 3420:1

happy [1] - 3323:16

hard [7] - 3291:11, 3310:6, 3334:15,

3338:24, 3342:22, 3380:9, 3415:19

Harry [1] - 3212:18

haslett [1] - 3169:12

hate [1] - 3420:9

Hazlett [6] - 3168:13, 3168:14,

3168:16, 3169:1, 3169:6, 3169:11

head [5] - 3160:9, 3160:15, 3160:23,

3247:6, 3300:11

heading [2] - 3316:3, 3330:9

headquartered [1] - 3244:5

headquarters [6] - 3172:4, 3172:5,

3172:8, 3172:9, 3226:13, 3226:15

heads [1] - 3159:24

health [2] - 3147:25, 3162:2

healthcare [1] - 3251:10

hear [11] - 3167:25, 3193:6, 3193:9,

3350:12, 3373:4, 3397:11, 3397:14,

3411:1, 3411:20, 3412:23, 3420:21

heard [6] - 3193:6, 3193:12, 3193:21,

3212:24, 3220:20, 3408:13

hearing [6] - 3350:12, 3350:22,

3350:24, 3351:16, 3373:6, 3418:2

HEARING [1] - 3331:12

hearings [1] - 3420:13

hearsay [18] - 3153:14, 3153:15,

3155:15, 3167:22, 3168:4, 3183:15,

3212:19, 3228:5, 3229:1, 3229:6,

3229:13, 3229:20, 3234:17, 3260:20,

3268:21, 3269:16, 3270:15, 3272:8

heart [2] - 3162:4, 3162:8

heated [1] - 3227:17

Heather [2] - 3408:17, 3409:3

HELD [1] - 3331:12

held [19] - 3146:1, 3194:13, 3206:3,

3233:9, 3233:10, 3235:22, 3239:10,

3241:20, 3241:21, 3248:20, 3248:21,

3257:21, 3297:17, 3300:24, 3331:9,

3331:15, 3331:18, 3370:9, 3410:4

help [8] - 3323:24, 3343:14, 3350:14,

3350:15, 3351:13, 3355:9, 3361:23,

3401:7

helped [1] - 3325:13

helping [4] - 3184:7, 3337:21, 3338:4,

3415:12

herself [1] - 3283:3

Hewlett [1] - 3146:13

hide [9] - 3396:10, 3396:22, 3397:9,

3398:13, 3399:17, 3400:3, 3400:4,

3400:8, 3400:16

high [7] - 3147:4, 3152:5, 3154:5,

3211:4, 3215:12, 3225:2, 3390:5

high-end [1] - 3211:4

higher [2] - 3166:7, 3253:16

highlight [5] - 3185:18, 3190:11,

3190:19, 3195:21, 3345:4

highlighted [2] - 3190:17, 3224:17

highly [1] - 3167:10

himself [3] - 3204:13, 3213:11,

3275:21

hire [7] - 3160:21, 3175:20, 3301:15,

3301:17, 3301:19, 3301:23, 3302:13

hired [9] - 3148:11, 3177:2, 3177:7,

3273:24, 3278:10, 3301:12, 3301:17,

3403:12, 3403:13

hires [2] - 3148:11, 3413:14

history [1] - 3147:5

hit [1] - 3207:23

HITTNER [1] - 3143:10

hold [12] - 3167:25, 3201:7, 3214:22,

3220:18, 3252:15, 3304:16, 3311:6,

3331:23, 3350:1, 3351:1, 3399:5

holders [10] - 3149:4, 3183:7, 3190:24,

3281:4, 3325:6, 3325:15, 3342:9,

3348:8, 3372:2

holding [2] - 3353:23, 3353:24

holdings [3] - 3235:19, 3241:1,

3261:15

Holdings [4] - 3251:16, 3362:25,

3364:1, 3368:23

holds [2] - 3148:8, 3354:2

hole [6] - 3180:4, 3180:13, 3181:9,

3184:5, 3254:18, 3255:20

Hollywood [1] - 3164:16

Holt [31] - 3169:2, 3169:7, 3233:19,

3237:24, 3238:7, 3238:19, 3245:3,

3281:15, 3282:2, 3282:5, 3282:11,

3282:16, 3283:12, 3284:2, 3284:14,

3284:16, 3343:24, 3344:1, 3344:6,

3344:15, 3360:24, 3360:25, 3399:18,

3400:2, 3401:4, 3401:5, 3402:24,

3406:24, 3407:25, 3408:3, 3408:6

Holt's [1] - 3409:6

home [14] - 3203:17, 3284:23, 3285:6,

3285:8, 3287:21, 3294:8, 3320:16,

3320:20, 3344:13, 3349:23, 3388:6,

3388:8, 3406:3

honestly [1] - 3179:12

honor [6] - 3183:6, 3196:14, 3246:7,

3285:3, 3287:16, 3324:19

Honor [111] - 3146:6, 3152:17,

3153:13, 3154:9, 3155:14, 3171:12,

3174:23, 3176:8, 3178:3, 3180:10,

3182:7, 3183:20, 3187:4, 3187:7,

3187:8, 3190:3, 3190:5, 3200:11,

3201:3, 3201:12, 3204:21, 3205:18,

3206:6, 3208:18, 3209:13, 3210:12,

3210:17, 3210:20, 3211:12, 3213:21,

3217:9, 3220:16, 3222:5, 3222:20,

3226:18, 3227:25, 3231:25, 3234:4,

3234:9, 3235:8, 3236:7, 3236:9,

3238:17, 3247:16, 3247:23, 3248:15,

3248:22, 3249:15, 3254:16, 3254:24,

3256:2, 3256:19, 3257:14, 3257:24,

3258:11, 3258:23, 3260:19, 3268:12,

3268:25, 3269:12, 3271:7, 3271:13,

3272:4, 3272:21, 3273:12, 3273:20,

3274:5, 3275:7, 3278:5, 3279:7,

3279:22, 3280:25, 3291:20, 3295:19,


3439

3298:20, 3298:23, 3305:2, 3307:1,

3311:3, 3315:19, 3316:6, 3324:4,

3325:24, 3331:20, 3351:19, 3361:4,

3362:13, 3368:11, 3368:12, 3373:25,

3384:10, 3389:7, 3406:18, 3407:7,

3408:8, 3409:21, 3412:6, 3413:1,

3413:19, 3414:9, 3417:11, 3417:25,

3418:1, 3419:25, 3421:18, 3422:18,

3423:19

HONORABLE [1] - 3143:10

honored [1] - 3182:24

hook [2] - 3254:17

hope [1] - 3397:13

hopefully [2] - 3380:24, 3422:1

hoping [2] - 3306:24

hospital [1] - 3162:6

hot [4] - 3366:8, 3366:12, 3367:5,

3371:18

Hotel [1] - 3287:25

hotel [3] - 3266:2, 3266:3, 3267:2

hour [6] - 3420:23, 3421:7, 3422:6,

3422:13, 3422:14, 3423:15

hours [10] - 3296:25, 3297:2, 3303:24,

3304:2, 3304:6, 3305:8, 3305:17,

3421:12, 3422:17, 3422:20

house [12] - 3235:21, 3285:11, 3321:1,

3321:4, 3321:6, 3321:7, 3388:9,

3388:10, 3388:11, 3390:9, 3390:10,

3404:20

housekeeping [1] - 3414:8

housing [1] - 3219:8

HOUSTON [1] - 3143:2

Houston [18] - 3143:4, 3143:15,

3143:23, 3144:4, 3144:7, 3144:12,

3170:14, 3170:15, 3176:2, 3186:16,

3226:16, 3226:24, 3227:2, 3244:5,

3333:7, 3336:14, 3336:16, 3346:20

Howard [1] - 3143:16

HR [1] - 3178:17

HSBC [1] - 3186:13

huge [1] - 3149:23

hugging [1] - 3265:18

human [2] - 3177:13, 3178:11

hundred [5] - 3164:5, 3203:6, 3206:11,

3349:9, 3419:19

hundreds [3] - 3150:6, 3166:1,

3201:20

hypocrite [1] - 3409:11

I

IB5 [1] - 3395:1

Idea [1] - 3169:16

idea [6] - 3158:9, 3200:21, 3211:18,

3328:24, 3392:1, 3392:4

ideas [2] - 3198:10, 3273:8

identified [3] - 3191:3, 3252:3,

3281:15

identify [4] - 3232:25, 3266:20,

3327:18, 3416:14

identifying [2] - 3156:2, 3416:13

ignored [1] - 3177:9

II [1] - 3202:24

illicit [1] - 3403:7

illiquid [1] - 3185:1

immediately [3] - 3317:24, 3347:21,

3412:21

impact [1] - 3213:11

impacted [1] - 3275:2

impacting [1] - 3162:2

impairment [1] - 3351:16

important [2] - 3324:18, 3346:18

importantly [3] - 3163:23, 3183:13,

3277:2

impression [4] - 3165:11, 3201:12,

3256:12, 3256:13

improve [1] - 3380:10

improved [2] - 3219:2, 3219:4

improvements [1] - 3217:14

inaccuracies [1] - 3264:16

inaccurate [2] - 3276:14, 3277:7

Inc [1] - 3238:8

incentives [5] - 3158:6, 3158:9,

3163:21, 3163:24, 3163:25

incentivize [1] - 3163:18

inches [5] - 3389:22, 3389:25, 3390:1,

3390:6

incident [2] - 3169:1, 3169:5

include [4] - 3175:1, 3272:13,

3358:23, 3358:24

included [1] - 3278:23

includes [2] - 3358:25, 3359:1

including [4] - 3186:13, 3351:16,

3356:11, 3421:5

income [4] - 3337:6, 3359:23, 3381:1,

3381:5

incoming [2] - 3192:1

increase [4] - 3181:23, 3198:16,

3202:19, 3290:18

increased [1] - 3151:15

incredible [3] - 3174:7, 3174:9,

3174:12

incrimination [1] - 3300:15

indeed [1] - 3296:14

indicate [1] - 3352:1

indicated [3] - 3181:23, 3212:8,

3354:4

indicates [3] - 3191:9, 3343:2, 3358:4

indicating [4] - 3215:21, 3216:11,

3389:19, 3389:20

indicative [1] - 3261:15

Indies [2] - 3378:7

individual [10] - 3158:16, 3158:22,

3158:23, 3168:9, 3169:19, 3223:1,

3223:5, 3223:22, 3252:25, 3413:17

individuals [6] - 3167:17, 3172:24,

3244:14, 3245:1, 3260:18, 3267:16

industry [2] - 3152:12, 3160:15

inflated [12] - 3223:20, 3223:21,

3252:9, 3252:13, 3253:13, 3253:14,

3253:20, 3254:5, 3254:12, 3254:14,

3255:12, 3262:10

inflating [2] - 3255:23, 3259:5

inflection [1] - 3351:4

inform [1] - 3395:16

information [61] - 3159:4, 3168:4,

3176:20, 3184:10, 3194:6, 3234:15,

3235:3, 3235:24, 3250:12, 3250:19,

3268:16, 3273:3, 3274:24, 3275:13,

3276:14, 3277:13, 3283:7, 3285:12,

3285:19, 3285:20, 3285:25, 3286:4,

3288:23, 3289:5, 3303:11, 3304:2,

3304:3, 3304:4, 3306:9, 3309:21,

3311:21, 3314:10, 3317:1, 3327:4,

3341:5, 3352:16, 3356:22, 3357:12,

3357:16, 3374:23, 3379:15, 3380:4,

3390:11, 3392:6, 3392:9, 3392:22,

3393:17, 3393:22, 3393:25, 3394:1,

3394:2, 3394:22, 3395:5, 3396:10,

3396:16, 3396:21, 3397:3, 3397:8,

3398:5, 3398:7, 3399:25

informed [3] - 3302:24, 3303:1, 3303:6

infrastructure [1] - 3219:11

infused [1] - 3205:1

infusion [8] - 3198:1, 3198:13,

3199:10, 3199:12, 3200:21, 3204:13,

3208:2, 3224:23

infusions [2] - 3224:12, 3224:16

initial [1] - 3148:10

initials [1] - 3185:25

injected [1] - 3206:10

inquiry [2] - 3157:22, 3407:12

insecurity [1] - 3198:15

insisting [1] - 3265:11

installation [1] - 3391:25

instead [1] - 3226:16

institutes [1] - 3174:5

institution [3] - 3201:11, 3235:22,

3241:2

institutions [1] - 3186:11

instruct [6] - 3178:25, 3183:22,

3299:20, 3316:8, 3347:25, 3383:9

instructed [9] - 3184:1, 3274:14,

3299:19, 3316:10, 3348:22, 3348:25,

3352:21, 3352:22, 3370:10

instruction [3] - 3276:4, 3348:2,

3353:6

instructions [3] - 3188:12, 3370:8,

3418:16

intact [1] - 3382:5

intend [1] - 3269:13

intended [1] - 3313:24

intention [2] - 3225:15, 3234:6

Intercontinental [2] - 3266:4, 3287:25

interest [5] - 3149:5, 3154:7, 3156:19,

3201:25, 3381:5

interior [2] - 3341:20, 3341:25

internal [2] - 3280:2

Internal [1] - 3338:7

international [2] - 3263:16, 3263:23

International [18] - 3170:4, 3186:8,

3194:14, 3201:22, 3202:13, 3210:2,

3214:3, 3231:8, 3235:19, 3236:25,

3246:5, 3250:6, 3255:15, 3279:17,

3356:20, 3363:17, 3374:11, 3375:21

internationally [2] - 3280:12, 3287:18


3440

interview [3] - 3296:11, 3302:24,

3303:7

interviewing [1] - 3296:25

interviews [1] - 3398:9

intimately [1] - 3158:18

introduced [1] - 3163:20

invested [1] - 3371:2

investigation [12] - 3227:15, 3227:17,

3228:4, 3228:10, 3228:12, 3228:21,

3229:10, 3229:11, 3229:12, 3230:22,

3231:2, 3231:11

investigators [5] - 3297:1, 3297:8,

3304:12, 3309:24, 3310:22

investing [1] - 3167:10

investment [20] - 3150:8, 3166:9,

3167:8, 3167:15, 3167:19, 3169:2,

3172:24, 3231:9, 3233:20, 3235:21,

3237:16, 3237:17, 3238:7, 3239:10,

3245:2, 3284:10, 3361:8, 3361:10,

3401:4

investments [15] - 3150:7, 3150:8,

3150:9, 3167:6, 3182:16, 3184:19,

3208:6, 3235:22, 3251:9, 3251:11,

3252:18, 3259:14, 3259:17, 3357:3,

3366:3

investors [3] - 3200:23, 3277:1,

3277:3

investors' [1] - 3200:23

invitation [1] - 3227:22

invite [1] - 3164:11

invited [1] - 3270:12

invitees [1] - 3270:15

involve [1] - 3209:16

involved [12] - 3153:7, 3158:13,

3164:21, 3165:18, 3167:10, 3169:5,

3206:12, 3211:4, 3223:16, 3329:5,

3401:3, 3404:6

involves [1] - 3407:8

involving [4] - 3167:8, 3233:7, 3252:7,

3327:18

iPhone [11] - 3292:15, 3293:22,

3318:25, 3319:10, 3332:23, 3332:24,

3333:1, 3333:14, 3333:20, 3334:2,

3367:17

iPhones [1] - 3333:22

irate [1] - 3169:7

irony [1] - 3320:9

IRS [2] - 3304:12, 3338:12

Island [2] - 3170:25, 3363:17

island [5] - 3171:3, 3171:8, 3219:15,

3219:17, 3220:1

islands [5] - 3210:11, 3210:13,

3211:11, 3219:13, 3227:24

Islands [9] - 3211:1, 3211:2, 3226:16,

3227:5, 3227:6, 3227:9, 3231:15,

3245:7

issue [10] - 3159:12, 3212:9, 3218:24,

3230:6, 3230:12, 3276:2, 3286:11,

3417:12, 3421:18, 3422:1

issued [8] - 3151:7, 3151:20, 3155:9,

3235:24, 3264:15, 3276:8, 3276:13,

3374:15

issues [5] - 3192:14, 3212:8, 3232:12,

3410:17, 3414:14

IT [3] - 3391:19, 3393:2, 3398:3

item [4] - 3175:17, 3175:18, 3237:14,

3389:16

itemize [1] - 3239:9

itemized [1] - 3237:15

items [5] - 3175:19, 3252:25, 3253:17,

3278:23, 3380:25

itself [4] - 3157:22, 3211:21, 3213:13,

3214:2

J

James [9] - 3363:1, 3368:25, 3375:13,

3375:17, 3376:6, 3376:12, 3376:22,

3379:8, 3379:20

JAMES [2] - 3145:3, 3146:7

January [16] - 3146:14, 3171:23,

3228:18, 3231:17, 3233:11, 3241:17,

3250:21, 3255:20, 3291:2, 3293:3,

3335:3, 3345:9, 3346:3, 3369:25,

3394:8

Jay [2] - 3148:9, 3153:4

jets [3] - 3171:14, 3171:18, 3174:21

Jim [4] - 3176:15, 3230:23, 3263:12,

3267:6

Joan [1] - 3178:17

job [6] - 3160:15, 3169:20, 3170:7,

3176:15, 3176:16, 3185:12

John [1] - 3144:2

Johnny [3] - 3144:11, 3424:5, 3424:9

joining [1] - 3414:1

JPW [1] - 3367:18

Juan [7] - 3233:17, 3238:6, 3243:25,

3245:17, 3245:24, 3264:17, 3282:5

judge [3] - 3327:11, 3377:16, 3379:22

Judge [10] - 3260:25, 3298:9, 3350:22,

3351:21, 3373:19, 3377:14, 3377:17,

3377:18, 3416:19, 3423:10

JUDGE [1] - 3143:10

Judge's [1] - 3221:6

judicial [1] - 3412:11

juggle [1] - 3421:21

jump [7] - 3190:8, 3192:9, 3193:25,

3194:9, 3286:2, 3332:8, 3376:5

jumping [1] - 3351:3

June [5] - 3154:15, 3250:1, 3250:4,

3250:19, 3250:22

juries [1] - 3385:15

JUROR [1] - 3336:3

jury [79] - 3146:1, 3183:22, 3184:1,

3206:3, 3208:19, 3208:21, 3235:11,

3257:21, 3274:14, 3276:1, 3286:19,

3297:12, 3298:14, 3299:20, 3300:6,

3300:22, 3300:24, 3301:5, 3301:14,

3302:7, 3304:4, 3305:6, 3305:7,

3305:19, 3306:5, 3309:17, 3310:11,

3310:14, 3312:7, 3312:14, 3312:20,

3313:9, 3313:16, 3315:2, 3316:9,

3316:10, 3322:11, 3330:16, 3331:9,

3331:16, 3331:18, 3333:24, 3342:11,

3346:25, 3350:10, 3352:9, 3352:20,

3353:3, 3353:21, 3354:1, 3354:4,

3354:16, 3356:8, 3357:10, 3372:15,

3373:18, 3373:19, 3375:19, 3376:2,

3377:17, 3383:10, 3384:3, 3386:4,

3401:9, 3405:9, 3406:16, 3408:13,

3410:4, 3410:21, 3410:24, 3411:19,

3411:24, 3411:25, 3418:6, 3419:1,

3419:4, 3419:22, 3420:18

JURY [1] - 3143:7

justice [1] - 3395:22

Justice [2] - 3143:17, 3413:13

K

keep [16] - 3294:5, 3301:14, 3356:25,

3357:2, 3357:5, 3359:21, 3360:4,

3360:6, 3366:8, 3366:19, 3391:22,

3412:23, 3420:23, 3421:2, 3423:6

keeping [2] - 3315:18, 3410:13

keeps [1] - 3366:7

Kenneth [2] - 3144:6, 3378:4

kept [4] - 3161:10, 3322:9, 3326:4,

3390:7

key [2] - 3390:15, 3390:18

killing [1] - 3174:4

kind [15] - 3186:23, 3310:5, 3310:10,

3354:5, 3360:21, 3364:6, 3373:22,

3377:6, 3387:11, 3388:19, 3388:21,

3392:9, 3392:22, 3394:22, 3414:19

King [1] - 3154:15

king [3] - 3156:13, 3157:24, 3227:23

kitty [1] - 3225:19

knock [1] - 3414:10

knocking [1] - 3338:13

knowing [2] - 3240:17, 3310:9

knowledge [17] - 3149:12, 3152:19,

3152:21, 3164:13, 3171:12, 3173:6,

3200:3, 3217:19, 3218:18, 3219:23,

3221:14, 3222:1, 3243:6, 3248:11,

3296:9, 3358:9, 3379:21

known [7] - 3150:9, 3150:13, 3158:1,

3227:10, 3377:3, 3377:20, 3377:21

knows [9] - 3235:9, 3286:19, 3315:22,

3323:20, 3399:19, 3399:21, 3410:16,

3410:23, 3415:1

Kuhrt [17] - 3197:16, 3197:19,

3206:24, 3217:24, 3218:15, 3218:21,

3220:15, 3226:9, 3226:11, 3227:1,

3252:24, 3357:17, 3357:25, 3384:18,

3399:17, 3400:6

L

lack [1] - 3203:23

lacking [1] - 3278:25

ladies [4] - 3257:17, 3274:13, 3331:3,

3409:25

lady [2] - 3302:12, 3343:25

lag [1] - 3251:3

lake [15] - 3285:10, 3286:5, 3386:9,

3387:6, 3387:24, 3388:11, 3388:13,


3441

3388:15, 3393:12, 3394:5, 3394:7,

3394:11, 3398:13, 3399:14, 3400:18

land [21] - 3210:23, 3214:8, 3214:18,

3214:22, 3214:24, 3215:1, 3215:7,

3215:25, 3216:2, 3216:6, 3216:9,

3216:23, 3217:11, 3217:16, 3217:25,

3218:19, 3218:21, 3218:22, 3218:24,

3219:5, 3221:13

landscaping [1] - 3219:8

lapel [1] - 3208:17

laptop [14] - 3190:3, 3387:11, 3387:13,

3387:15, 3387:19, 3391:15, 3392:16,

3393:7, 3393:19, 3393:20, 3393:21,

3394:23, 3395:6, 3396:20

large [3] - 3163:1, 3164:4, 3285:20

larger [1] - 3265:11

last [31] - 3180:13, 3193:7, 3250:5,

3250:8, 3250:23, 3256:1, 3288:17,

3292:17, 3296:7, 3302:7, 3303:6,

3303:24, 3304:9, 3305:10, 3305:11,

3311:24, 3312:18, 3312:21, 3313:3,

3314:8, 3314:9, 3321:8, 3324:8,

3348:11, 3364:17, 3364:22, 3369:9,

3370:24, 3411:16

late [11] - 3165:3, 3171:21, 3177:11,

3199:22, 3232:14, 3244:16, 3292:5,

3377:25, 3378:1, 3418:22

latest [1] - 3188:10

laura [1] - 3282:5

LAURA [1] - 3405:16

Laura [12] - 3169:2, 3233:19, 3238:7,

3245:3, 3282:2, 3284:13, 3343:24,

3401:4, 3401:5, 3405:14, 3406:24,

3409:6

Laura's [1] - 3409:6

law [4] - 3300:20, 3301:22, 3412:7,

3412:16

Law [2] - 3144:3, 3144:6

law's [1] - 3301:21

lawyer [32] - 3232:25, 3233:25,

3244:19, 3273:24, 3278:10, 3296:10,

3297:21, 3298:16, 3298:21, 3298:22,

3299:10, 3300:3, 3300:7, 3301:2,

3301:4, 3301:9, 3301:15, 3301:23,

3302:3, 3302:5, 3302:8, 3302:13,

3303:10, 3307:8, 3311:7, 3336:11,

3336:23, 3346:6, 3373:17, 3378:13,

3379:25, 3386:2

lawyer-client [1] - 3300:3

lawyers [9] - 3154:1, 3307:17,

3308:15, 3308:20, 3309:24, 3310:10,

3310:22, 3373:16, 3413:25

lead [3] - 3157:22, 3247:8, 3247:10

leadership [2] - 3206:23, 3232:22

leading [9] - 3151:21, 3161:18,

3214:12, 3215:14, 3215:17, 3220:17,

3238:23, 3239:13, 3239:20

learn [1] - 3153:1

learned [3] - 3204:3, 3263:13, 3364:9

learning [1] - 3282:9

leases [1] - 3189:16

least [6] - 3201:2, 3204:19, 3261:14,

3265:9, 3416:6, 3422:14

leave [9] - 3148:14, 3148:20, 3208:11,

3254:21, 3257:10, 3257:12, 3292:4,

3410:5, 3417:5

leaving [2] - 3179:18, 3191:20

led [5] - 3164:25, 3258:9, 3258:12,

3259:1, 3259:9

leeway [1] - 3299:13

left [14] - 3178:20, 3179:8, 3185:24,

3186:2, 3191:7, 3192:3, 3193:18,

3193:20, 3196:3, 3207:3, 3222:13,

3225:12, 3225:19, 3251:8

left-hand [5] - 3185:24, 3186:2,

3207:3, 3222:13, 3251:8

legal [5] - 3189:14, 3209:18, 3224:9,

3271:4, 3354:9

legally [2] - 3221:16, 3354:9

legitimate [2] - 3316:17, 3341:11

Lena [3] - 3233:18, 3244:1, 3268:18

lengthier [1] - 3414:24

lengthy [1] - 3409:22

Leo [2] - 3169:19, 3169:20

Leroy [1] - 3154:15

less [5] - 3359:18, 3359:19, 3380:22,

3416:8

lesser [1] - 3261:19

letter [5] - 3154:14, 3155:1, 3156:12,

3157:24

letters [4] - 3185:25, 3186:10,

3285:24, 3393:9

letting [1] - 3419:11

level [9] - 3162:24, 3164:7, 3164:8,

3207:5, 3207:8, 3207:16, 3207:17,

3207:19, 3397:11

levels [1] - 3197:13

liar [13] - 3306:15, 3306:16, 3306:19,

3307:18, 3307:21, 3307:23, 3307:24,

3308:8, 3308:23, 3308:24, 3309:2,

3309:18, 3311:17

Libya [3] - 3242:8, 3242:13, 3242:17

Libyan [2] - 3242:8, 3242:11

lie [17] - 3232:4, 3232:8, 3232:10,

3253:24, 3254:4, 3254:12, 3256:6,

3283:10, 3310:6, 3381:8, 3381:11,

3381:12, 3382:4, 3382:12, 3382:15

lied [9] - 3310:4, 3310:5, 3312:13,

3325:4, 3342:14, 3344:24, 3406:5,

3409:12

lies [1] - 3283:11

lieu [2] - 3292:24, 3338:19

life [1] - 3312:4

light [1] - 3274:24

likely [2] - 3194:24, 3414:21

limine [3] - 3411:12, 3418:9, 3418:10

Limited [13] - 3186:8, 3194:14,

3202:13, 3210:3, 3214:4, 3235:20,

3238:8, 3246:6, 3250:6, 3255:15,

3279:17, 3363:17, 3374:11

limited [3] - 3274:2, 3274:19, 3406:25

Limited's [1] - 3170:4

Lindenberg [1] - 3409:13

line [25] - 3167:21, 3186:20, 3207:4,

3209:3, 3223:6, 3232:9, 3246:5,

3296:21, 3312:2, 3312:13, 3336:1,

3339:11, 3345:2, 3364:22, 3366:6,

3366:9, 3367:4, 3367:6, 3367:10,

3369:2, 3369:21, 3380:17, 3381:13,

3407:11

liquid [5] - 3167:10, 3167:15, 3182:16,

3193:22, 3200:3

liquidity [3] - 3162:25, 3199:15,

3203:24

list [5] - 3190:15, 3237:15, 3381:3,

3415:4, 3415:20

listened [1] - 3297:9

listing [4] - 3194:10, 3237:15, 3253:2,

3253:15

lists [1] - 3241:1

literate [1] - 3387:17

live [10] - 3293:23, 3294:13, 3302:22,

3321:4, 3321:6, 3344:5, 3344:8,

3344:9, 3344:13, 3360:17

lived [4] - 3294:8, 3320:20, 3320:25,

3321:7

LLC [1] - 3368:23

loan [35] - 3224:25, 3225:3, 3225:13,

3289:16, 3292:23, 3293:13, 3313:22,

3313:23, 3315:4, 3315:6, 3315:7,

3316:2, 3316:15, 3316:20, 3316:24,

3317:6, 3318:20, 3325:1, 3332:9,

3332:13, 3334:22, 3334:23, 3336:7,

3336:11, 3336:22, 3345:12, 3346:5,

3346:8, 3346:9, 3349:14, 3358:10,

3372:15, 3372:20, 3372:21, 3394:20

loaned [2] - 3180:12, 3302:12

loans [12] - 3225:4, 3225:7, 3253:8,

3259:19, 3260:7, 3266:20, 3290:10,

3290:23, 3290:24, 3291:1, 3295:3,

3339:24

lobby [3] - 3266:2, 3266:3, 3267:2

local [2] - 3218:17, 3356:23

located [9] - 3162:22, 3210:4,

3219:12, 3219:14, 3241:25, 3304:14,

3336:17, 3341:18, 3363:17

locating [1] - 3162:17

look [17] - 3154:13, 3271:9, 3290:9,

3298:17, 3314:13, 3314:21, 3335:5,

3335:16, 3345:19, 3345:21, 3346:18,

3364:15, 3368:15, 3370:19, 3380:17,

3396:21, 3422:12

looked [6] - 3152:7, 3154:3, 3252:7,

3267:9, 3335:23, 3396:7

looking [15] - 3152:8, 3152:24, 3207:3,

3222:13, 3222:19, 3234:14, 3251:8,

3271:15, 3273:16, 3273:17, 3276:1,

3324:1, 3386:7, 3419:9, 3422:19

looks [3] - 3334:25, 3387:22, 3419:7

Lopez [15] - 3197:16, 3197:19,

3206:24, 3217:24, 3226:10, 3226:23,

3227:1, 3252:24, 3357:24, 3357:25,

3381:22, 3381:25, 3384:16, 3399:18,

3400:6

Lori [11] - 3404:12, 3404:14, 3404:25,

3405:13, 3405:14, 3405:15, 3405:19,

3406:5, 3406:12, 3407:23, 3408:6

LORI [1] - 3405:15Johnny C. Sanchez, RMR, CRR - [email protected]

3442

losing [3] - 3189:8, 3329:19, 3330:4

loss [4] - 3276:20, 3380:19, 3380:21,

3382:15

lost [3] - 3188:20, 3201:10, 3201:13

Louisiana [1] - 3148:24

low [2] - 3162:24, 3174:6

lower [3] - 3147:7, 3157:3, 3251:22

lucky [1] - 3146:18

lunch [3] - 3257:17, 3421:4, 3421:6

lying [4] - 3232:6, 3232:7, 3307:25,

3312:5

Lynch [3] - 3148:12, 3148:15, 3148:20

M

Machine [1] - 3165:13

machine [3] - 3317:17, 3317:18,

3317:20

mail [32] - 3173:25, 3177:14, 3184:10,

3185:3, 3185:6, 3185:17, 3186:17,

3187:13, 3187:24, 3187:25, 3190:9,

3190:14, 3191:2, 3191:4, 3191:12,

3191:15, 3192:22, 3193:17, 3193:22,

3193:25, 3194:1, 3194:10, 3194:18,

3195:9, 3195:18, 3196:23, 3226:8,

3226:25, 3293:5, 3338:23, 3396:18

mails [5] - 3197:1, 3329:6, 3394:24,

3395:7, 3395:8

mainland [2] - 3219:12, 3227:9

maintain [4] - 3152:5, 3180:21,

3180:23, 3180:25

maintaining [1] - 3181:4

maintenance [1] - 3211:7

major [1] - 3212:9

Maldonado [21] - 3185:9, 3185:11,

3185:13, 3187:14, 3187:24, 3190:9,

3190:15, 3194:5, 3194:8, 3194:20,

3195:2, 3195:8, 3197:1, 3348:2,

3349:16, 3349:19, 3352:3, 3352:4,

3352:5, 3352:6, 3352:22

Maldonado's [1] - 3186:17

man [2] - 3230:17, 3373:10

Man [1] - 3362:17

managed [1] - 3150:12

management [9] - 3150:1, 3150:13,

3150:15, 3150:23, 3151:2, 3151:6,

3151:13, 3152:1, 3157:2

manager [3] - 3185:10, 3185:12,

3348:3

MANAGER [1] - 3331:24

manager/member [2] - 3363:1,

3368:25

managing [2] - 3150:19, 3174:5

manner [2] - 3319:4, 3370:7

manufacturing [1] - 3251:11

March [11] - 3181:17, 3182:21, 3187:3,

3187:13, 3188:23, 3189:17, 3196:6,

3198:4, 3301:6, 3307:6, 3312:1

marching [1] - 3237:14

margin [1] - 3185:24

Maricio [1] - 3212:8

Mark [1] - 3218:15

market [6] - 3149:23, 3202:17, 3223:4,

3225:10, 3254:6, 3366:20

marketable [5] - 3179:25, 3182:17,

3183:3, 3196:20, 3238:22

marketing [3] - 3166:3, 3167:9,

3288:23

markets [5] - 3166:20, 3220:10,

3220:13, 3253:2, 3253:16

markup [1] - 3220:6

marriage [4] - 3212:9, 3405:10,

3406:10, 3406:16

married [10] - 3160:5, 3403:23,

3404:1, 3404:12, 3404:15, 3405:7,

3405:8, 3405:20, 3406:12, 3408:6

massive [1] - 3198:2

master [1] - 3364:9

materials [5] - 3166:3, 3167:9,

3169:17, 3170:5, 3288:23

matter [14] - 3213:25, 3234:6, 3274:9,

3289:3, 3298:18, 3309:12, 3342:16,

3410:6, 3413:1, 3413:3, 3414:8,

3415:1, 3415:10, 3424:7

maturities [2] - 3191:3, 3191:6

Mauricio [4] - 3232:18, 3233:15,

3244:2, 3281:23

max [1] - 3421:13

maximum [1] - 3149:18

McGuire [3] - 3144:6, 3144:6, 3415:11

mean [47] - 3154:7, 3172:22, 3175:13,

3183:4, 3186:6, 3186:19, 3238:13,

3250:15, 3254:8, 3270:10, 3270:16,

3273:14, 3275:5, 3275:11, 3276:16,

3277:3, 3277:5, 3315:21, 3319:12,

3322:5, 3333:17, 3334:20, 3334:21,

3339:9, 3347:10, 3347:11, 3348:18,

3356:16, 3359:7, 3359:12, 3360:1,

3360:15, 3360:19, 3360:21, 3364:6,

3387:11, 3388:1, 3388:5, 3388:24,

3390:18, 3391:10, 3391:12, 3413:20,

3415:23, 3417:13, 3418:25, 3421:5

meaning [8] - 3171:5, 3181:17,

3186:22, 3198:16, 3199:20, 3264:22,

3278:3, 3374:16

means [5] - 3183:2, 3199:12, 3199:13,

3359:14, 3369:12

meant [6] - 3150:3, 3212:14, 3275:14,

3288:23, 3334:22

mechanical [1] - 3144:14

media [4] - 3285:10, 3385:13, 3393:14,

3400:12

meet [9] - 3197:3, 3202:12, 3241:13,

3266:2, 3283:23, 3288:2, 3288:14,

3401:11, 3420:10

meeting [90] - 3164:12, 3165:2,

3165:4, 3165:20, 3192:15, 3192:17,

3192:18, 3193:3, 3230:25, 3231:22,

3232:21, 3232:23, 3232:24, 3233:6,

3233:9, 3233:10, 3233:12, 3233:25,

3234:13, 3238:1, 3238:17, 3239:11,

3239:24, 3240:2, 3240:10, 3240:21,

3240:22, 3241:7, 3241:10, 3241:12,

3241:15, 3242:4, 3242:5, 3243:13,

3243:15, 3243:20, 3244:23, 3245:3,

3247:7, 3247:13, 3248:23, 3254:1,

3255:8, 3255:19, 3256:4, 3257:5,

3258:5, 3258:8, 3258:9, 3258:15,

3259:1, 3259:8, 3259:13, 3259:23,

3260:6, 3260:15, 3262:5, 3262:9,

3262:22, 3264:2, 3265:14, 3265:20,

3265:21, 3265:23, 3266:15, 3266:18,

3267:11, 3267:12, 3267:14, 3267:15,

3267:25, 3268:9, 3268:15, 3269:14,

3270:1, 3270:12, 3273:4, 3274:23,

3275:16, 3276:10, 3281:18, 3282:4,

3282:15, 3286:25, 3288:7, 3288:13,

3307:16

meeting's [1] - 3245:8

meetings [10] - 3163:15, 3163:16,

3164:2, 3164:15, 3165:1, 3165:3,

3165:8, 3241:18, 3242:2, 3242:6

Mejia [2] - 3169:20

melted [2] - 3267:4, 3267:6

member [4] - 3384:13, 3401:24,

3402:1, 3402:3

memorialize [3] - 3318:2, 3318:18,

3318:19

memorialized [1] - 3318:12

memory [1] - 3401:8

Memphis [5] - 3172:14, 3172:16,

3173:13, 3177:18, 3178:8

men [3] - 3377:23, 3377:24

mens [1] - 3418:16

mental [1] - 3197:13

mention [1] - 3283:18

mentioned [8] - 3161:2, 3203:5,

3207:8, 3226:21, 3243:13, 3245:1,

3247:14, 3340:21

Merchant [2] - 3362:23, 3362:24

Merchants [2] - 3368:17, 3370:11

merely [2] - 3272:5, 3274:11

Merrill [3] - 3148:12, 3148:15, 3148:20

message [7] - 3296:19, 3319:9,

3319:19, 3332:17, 3334:1, 3334:3,

3406:22

messages [1] - 3184:12

met [14] - 3284:21, 3296:5, 3303:24,

3308:7, 3377:18, 3401:10, 3401:12,

3402:24, 3403:7, 3403:14, 3404:12,

3404:25, 3405:19, 3405:21

metals [1] - 3150:9

Miami [30] - 3162:15, 3162:18,

3162:22, 3162:23, 3165:13, 3168:15,

3169:2, 3169:3, 3233:13, 3239:24,

3241:14, 3241:21, 3242:5, 3243:10,

3243:12, 3243:22, 3243:23, 3244:9,

3247:7, 3248:3, 3254:1, 3258:5,

3259:24, 3282:15, 3284:18, 3285:5,

3287:19, 3287:24, 3289:3

Michigan [1] - 3294:14

microphone [1] - 3208:17

mid [1] - 3231:17

middle [10] - 3190:9, 3194:19,

3198:20, 3215:4, 3233:11, 3252:20,

3262:20, 3377:23, 3377:25, 3378:1

middle-aged [1] - 3377:23

midmorning [2] - 3244:16, 3245:4Johnny C. Sanchez, RMR, CRR - [email protected]

3443

midnight [1] - 3162:6

might [14] - 3208:11, 3240:3, 3266:10,

3279:23, 3291:7, 3304:14, 3312:16,

3318:14, 3351:13, 3395:9, 3414:24,

3419:3, 3421:21, 3423:1

mike [2] - 3208:17, 3371:6

mill [1] - 3215:23

million [82] - 3151:9, 3180:16,

3180:19, 3181:1, 3181:2, 3182:4,

3184:6, 3185:20, 3186:18, 3188:3,

3188:4, 3188:20, 3189:10, 3189:12,

3190:20, 3191:1, 3191:20, 3194:11,

3194:24, 3195:24, 3196:3, 3199:19,

3200:2, 3200:6, 3202:19, 3203:6,

3206:11, 3214:25, 3215:12, 3216:17,

3216:24, 3217:11, 3218:6, 3223:2,

3223:6, 3224:11, 3224:22, 3225:10,

3225:19, 3252:10, 3289:17, 3294:20,

3295:18, 3314:15, 3316:1, 3316:5,

3318:17, 3321:25, 3330:17, 3330:19,

3339:2, 3341:5, 3348:23, 3349:8,

3355:1, 3358:20, 3358:21, 3359:9,

3359:10, 3359:11, 3359:13, 3359:16,

3359:17, 3359:24, 3360:12, 3361:25,

3362:1, 3365:6, 3365:22, 3366:11,

3370:17, 3371:17, 3371:19, 3371:23,

3381:15, 3381:17, 3381:18, 3383:6

millions [4] - 3191:8, 3201:20,

3324:20, 3325:22

Millions [1] - 3325:21

mind [12] - 3272:1, 3272:13, 3272:15,

3272:18, 3299:2, 3311:10, 3323:23,

3370:2, 3370:4, 3389:15, 3389:18,

3410:13

mine [2] - 3387:10, 3388:16

minimum [1] - 3415:24

minus [1] - 3365:9

minute [11] - 3198:24, 3298:15,

3309:23, 3314:21, 3322:24, 3332:9,

3361:3, 3374:13, 3376:5, 3390:23

minutes [7] - 3205:21, 3205:25,

3206:1, 3329:17, 3342:17, 3418:6,

3419:6

misappropriated [1] - 3295:12

misappropriations [1] - 3179:10

mischaracterization [1] - 3412:13

mischaracterizes [2] - 3328:25,

3355:22

miscommunication [1] - 3329:13

misconduct [1] - 3240:6

misrepresent [1] - 3416:12

Mississippi [12] - 3203:18, 3284:23,

3284:25, 3285:6, 3287:21, 3293:24,

3294:9, 3343:15, 3344:5, 3344:10,

3355:10, 3401:12

misstatements [1] - 3279:15

mistaken [1] - 3413:12

mistrial [3] - 3410:25, 3412:3, 3412:5

mix [1] - 3280:21

model [2] - 3167:19, 3284:10

modulate [1] - 3351:10

moment [7] - 3155:11, 3176:6,

3223:24, 3248:13, 3276:9, 3329:12,

3403:17

Monday [5] - 3146:2, 3244:6, 3267:11,

3287:4

monetary [1] - 3163:24

Money [1] - 3165:13

money [161] - 3148:6, 3149:3, 3149:4,

3161:11, 3161:13, 3171:6, 3171:7,

3171:9, 3171:19, 3179:11, 3180:12,

3181:24, 3182:18, 3189:8, 3189:17,

3193:18, 3196:8, 3199:2, 3199:6,

3199:13, 3201:8, 3201:10, 3201:20,

3201:22, 3205:1, 3205:2, 3205:3,

3217:5, 3225:16, 3246:10, 3287:16,

3290:1, 3291:4, 3291:15, 3293:16,

3293:21, 3294:18, 3295:1, 3295:3,

3295:6, 3295:12, 3301:15, 3301:19,

3301:20, 3301:21, 3301:22, 3302:13,

3304:14, 3312:22, 3313:12, 3313:17,

3314:3, 3315:2, 3316:17, 3316:22,

3318:15, 3320:18, 3321:23, 3321:24,

3322:11, 3322:23, 3323:1, 3324:12,

3324:21, 3324:25, 3325:3, 3325:9,

3325:11, 3326:5, 3326:7, 3326:11,

3326:18, 3327:6, 3327:21, 3328:2,

3328:15, 3329:19, 3330:4, 3334:5,

3334:7, 3335:6, 3335:14, 3335:15,

3335:16, 3335:19, 3335:24, 3337:4,

3338:17, 3339:3, 3339:18, 3339:24,

3340:14, 3341:9, 3341:11, 3342:6,

3342:11, 3342:24, 3343:3, 3343:8,

3343:13, 3345:16, 3345:18, 3345:20,

3345:22, 3346:6, 3346:11, 3346:15,

3346:19, 3347:3, 3348:1, 3348:5,

3348:8, 3348:9, 3348:12, 3348:17,

3349:1, 3355:3, 3355:4, 3355:5,

3355:6, 3355:8, 3355:9, 3356:25,

3357:2, 3358:11, 3358:19, 3358:23,

3358:24, 3359:1, 3359:7, 3360:4,

3360:15, 3361:23, 3364:3, 3364:7,

3364:16, 3365:17, 3365:19, 3366:19,

3368:3, 3368:6, 3368:7, 3370:2,

3370:5, 3370:20, 3371:1, 3371:4,

3371:9, 3371:11, 3371:17, 3371:21,

3371:25, 3372:3, 3379:2

monies [4] - 3253:5, 3289:25,

3314:17, 3360:22

monitor [1] - 3175:24

monitoring [1] - 3195:15

month [7] - 3187:2, 3192:3, 3250:10,

3251:3, 3370:8, 3382:2, 3382:6

monthly [2] - 3202:6, 3221:20

months [6] - 3208:10, 3216:25,

3220:4, 3293:1, 3310:13, 3343:10

Montserrat [1] - 3363:14

morning [19] - 3146:2, 3146:3,

3146:10, 3146:11, 3249:20, 3249:22,

3262:4, 3262:25, 3265:22, 3267:14,

3415:18, 3417:3, 3417:6, 3418:22,

3419:21, 3420:10, 3420:20, 3421:23,

3423:12

mortar [2] - 3189:16, 3264:12

most [15] - 3159:13, 3163:23, 3164:3,

3165:1, 3165:3, 3172:10, 3194:24,

3250:25, 3253:16, 3277:1, 3308:3,

3356:24, 3375:3, 3393:1, 3414:21

mostly [1] - 3175:23

mother [2] - 3301:21, 3301:22

mother-in-law [1] - 3301:22

mother-in-law's [1] - 3301:21

motion [6] - 3411:12, 3412:5, 3418:8,

3418:10, 3418:13, 3418:14

motive [2] - 3318:1, 3371:22

mouths [1] - 3256:14

move [5] - 3150:10, 3370:23, 3387:1,

3407:21, 3408:15

moved [1] - 3215:22

moving [10] - 3161:21, 3178:10,

3181:8, 3181:11, 3182:21, 3194:23,

3209:17, 3227:14, 3329:7, 3413:9

MR [579] - 3145:4, 3145:5, 3146:6,

3146:9, 3146:22, 3147:1, 3151:21,

3151:23, 3152:17, 3152:22, 3153:13,

3153:16, 3153:18, 3153:22, 3154:12,

3154:18, 3154:20, 3154:25, 3155:3,

3155:13, 3155:18, 3155:23, 3156:1,

3156:6, 3156:7, 3156:17, 3157:8,

3157:10, 3157:12, 3158:2, 3158:4,

3161:18, 3161:19, 3161:23, 3166:14,

3166:24, 3167:1, 3167:3, 3167:20,

3167:24, 3168:1, 3168:5, 3168:12,

3168:18, 3169:4, 3170:16, 3171:17,

3171:25, 3172:2, 3172:3, 3175:5,

3176:8, 3176:9, 3177:1, 3177:4,

3177:6, 3178:6, 3178:22, 3178:25,

3179:3, 3179:7, 3179:14, 3179:17,

3180:6, 3180:8, 3180:10, 3180:11,

3181:7, 3182:7, 3182:9, 3182:11,

3182:13, 3183:15, 3183:20, 3183:21,

3183:25, 3184:3, 3185:2, 3185:5,

3185:16, 3185:21, 3187:4, 3187:7,

3187:12, 3189:2, 3189:4, 3190:2,

3190:5, 3190:7, 3190:11, 3190:13,

3190:19, 3190:22, 3191:11, 3191:14,

3192:9, 3192:12, 3192:20, 3192:21,

3192:23, 3192:24, 3192:25, 3193:2,

3193:8, 3195:20, 3195:22, 3196:19,

3199:1, 3200:12, 3201:5, 3201:18,

3202:4, 3204:5, 3204:7, 3204:9,

3204:23, 3205:6, 3205:18, 3206:6,

3206:7, 3206:17, 3206:19, 3207:10,

3207:12, 3208:18, 3209:7, 3209:10,

3209:13, 3209:14, 3210:22, 3211:15,

3212:19, 3212:21, 3212:25, 3213:2,

3213:4, 3213:8, 3213:14, 3214:7,

3214:12, 3214:14, 3215:14, 3215:18,

3216:21, 3217:9, 3217:10, 3219:7,

3219:16, 3220:16, 3220:24, 3221:3,

3221:5, 3221:9, 3222:6, 3222:10,

3222:12, 3222:16, 3222:20, 3222:22,

3223:11, 3223:14, 3226:22, 3227:13,

3228:2, 3228:5, 3228:6, 3228:9,

3228:14, 3228:16, 3229:2, 3229:8,

3229:13, 3229:16, 3229:19, 3229:21,

3229:23, 3230:2, 3230:5, 3230:7,

3230:10, 3230:14, 3230:18, 3230:20,


3444

3234:8, 3234:12, 3234:17, 3234:22,

3234:25, 3235:2, 3235:6, 3235:14,

3235:16, 3236:2, 3236:4, 3236:7,

3236:9, 3236:11, 3236:12, 3236:18,

3236:24, 3237:8, 3237:12, 3238:18,

3238:23, 3239:2, 3239:13, 3239:19,

3239:22, 3240:18, 3243:22, 3244:7,

3244:18, 3244:24, 3245:10, 3245:13,

3245:25, 3247:21, 3247:24, 3249:13,

3249:16, 3249:21, 3250:12, 3250:17,

3252:13, 3252:14, 3252:16, 3254:24,

3254:25, 3256:1, 3256:3, 3256:9,

3257:3, 3257:14, 3257:24, 3258:3,

3258:11, 3258:14, 3258:18, 3258:25,

3260:8, 3260:10, 3260:14, 3260:19,

3260:22, 3260:25, 3261:1, 3261:5,

3261:16, 3262:2, 3266:11, 3266:13,

3268:14, 3268:21, 3268:22, 3268:24,

3269:2, 3269:12, 3269:15, 3269:18,

3270:2, 3270:4, 3270:9, 3270:14,

3270:17, 3270:20, 3271:7, 3271:13,

3271:16, 3271:20, 3271:23, 3272:3,

3272:8, 3272:12, 3272:15, 3272:19,

3272:21, 3272:23, 3273:1, 3273:3,

3273:7, 3273:12, 3273:13, 3273:19,

3273:23, 3274:5, 3274:8, 3274:11,

3274:22, 3275:7, 3275:10, 3275:12,

3275:19, 3275:23, 3276:7, 3277:17,

3277:19, 3278:6, 3278:12, 3279:10,

3279:25, 3281:10, 3282:1, 3282:7,

3285:22, 3286:6, 3286:8, 3286:10,

3286:11, 3286:16, 3286:19, 3286:23,

3287:10, 3287:23, 3289:11, 3289:14,

3290:13, 3290:14, 3291:6, 3291:10,

3291:17, 3291:19, 3291:22, 3291:24,

3292:2, 3292:4, 3292:8, 3292:9,

3295:19, 3295:25, 3296:3, 3296:15,

3296:18, 3296:24, 3297:14, 3297:23,

3298:2, 3298:4, 3298:7, 3298:9,

3298:12, 3298:20, 3298:23, 3299:2,

3299:6, 3299:9, 3299:14, 3299:22,

3299:24, 3300:13, 3301:1, 3303:3,

3303:5, 3304:15, 3304:17, 3305:4,

3305:10, 3305:13, 3306:1, 3306:3,

3307:3, 3308:4, 3308:5, 3308:12,

3308:14, 3308:15, 3308:17, 3308:18,

3308:24, 3309:1, 3309:5, 3309:16,

3309:19, 3311:3, 3311:9, 3311:13,

3313:4, 3313:6, 3315:19, 3315:21,

3315:24, 3316:6, 3316:8, 3316:11,

3321:2, 3321:5, 3322:14, 3322:19,

3322:22, 3322:25, 3323:4, 3323:6,

3323:9, 3323:13, 3323:15, 3323:17,

3323:18, 3323:20, 3323:22, 3323:24,

3323:25, 3324:3, 3324:6, 3324:11,

3325:14, 3325:16, 3325:18, 3326:2,

3326:15, 3328:5, 3328:6, 3328:25,

3329:4, 3329:12, 3329:18, 3330:24,

3331:20, 3331:21, 3332:2, 3332:4,

3332:6, 3332:7, 3334:12, 3334:14,

3342:1, 3350:6, 3350:9, 3350:17,

3350:21, 3351:20, 3351:23, 3352:25,

3353:4, 3355:21, 3356:1, 3361:3,

3361:6, 3362:6, 3362:9, 3362:10,

3362:12, 3362:13, 3362:16, 3362:19,

3367:1, 3367:3, 3368:9, 3368:11,

3368:12, 3368:14, 3369:2, 3369:4,

3369:20, 3369:23, 3370:22, 3370:25,

3371:8, 3372:10, 3372:12, 3373:12,

3373:14, 3373:25, 3374:5, 3380:7,

3380:11, 3380:13, 3383:7, 3383:9,

3383:17, 3384:12, 3385:5, 3386:13,

3386:16, 3386:18, 3387:1, 3387:3,

3389:8, 3389:14, 3389:22, 3389:24,

3390:2, 3390:4, 3390:21, 3391:3,

3397:21, 3397:24, 3398:4, 3399:2,

3399:4, 3399:6, 3399:7, 3399:10,

3399:19, 3399:21, 3399:24, 3405:15,

3405:18, 3406:6, 3406:9, 3406:18,

3406:21, 3406:23, 3406:25, 3407:2,

3407:9, 3407:11, 3407:15, 3407:17,

3407:22, 3408:8, 3408:10, 3408:16,

3408:19, 3408:22, 3409:2, 3409:21,

3410:5, 3410:8, 3410:9, 3410:11,

3410:15, 3410:16, 3410:17, 3411:1,

3411:5, 3411:8, 3411:14, 3411:25,

3412:4, 3412:6, 3412:8, 3412:10,

3412:13, 3412:17, 3413:1, 3413:11,

3413:19, 3413:24, 3414:7, 3414:17,

3414:18, 3414:21, 3415:8, 3415:15,

3416:1, 3416:3, 3416:8, 3416:11,

3416:20, 3417:11, 3417:14, 3417:22,

3417:25, 3418:8, 3418:10, 3418:11,

3418:13, 3418:21, 3419:25, 3420:4,

3420:8, 3420:13, 3420:17, 3421:18,

3421:20, 3421:25, 3422:5, 3422:6,

3422:10, 3422:15, 3422:18, 3422:22,

3422:24, 3423:10, 3423:19, 3423:22

multibillion [1] - 3360:3

multibillion-dollar [1] - 3360:3

multiple [3] - 3160:12, 3218:4,

3411:18

multitude [1] - 3232:11

mumble [1] - 3411:8

mushrooming [1] - 3165:25

must [3] - 3237:3, 3237:4, 3397:18

N

naive [1] - 3267:4

name [12] - 3163:9, 3163:10, 3186:8,

3190:12, 3190:17, 3210:25, 3214:9,

3214:11, 3242:15, 3269:21, 3296:4,

3402:16

named [2] - 3401:4, 3403:23

names [2] - 3208:22, 3373:21

narrative [1] - 3304:24

narrow [6] - 3146:23, 3146:25,

3166:24, 3258:13, 3258:14, 3362:4

narrowed [1] - 3258:16

NASD [6] - 3152:9, 3152:10, 3152:14,

3152:24, 3152:25, 3154:2

NASD's [1] - 3153:2

Nashville [1] - 3284:21

nature [1] - 3229:10

Navigant [7] - 3413:5, 3413:7, 3413:9,

3413:12, 3413:14, 3413:16, 3414:1

Navy [1] - 3350:12

near [4] - 3197:13, 3302:22, 3388:5,

3388:8

necessary [6] - 3179:13, 3189:18,

3221:15, 3383:14, 3412:22, 3421:2

necessity [1] - 3417:4

necks [1] - 3265:18

need [27] - 3213:19, 3246:6, 3273:21,

3277:18, 3298:12, 3307:18, 3323:25,

3331:23, 3341:11, 3343:2, 3343:8,

3361:23, 3383:13, 3384:3, 3384:5,

3384:7, 3397:19, 3407:20, 3410:17,

3411:3, 3412:20, 3412:22, 3415:3,

3418:8, 3419:18, 3419:22, 3422:14

needed [18] - 3157:1, 3201:8, 3201:9,

3203:22, 3207:23, 3276:17, 3277:23,

3278:8, 3279:12, 3340:14, 3341:9,

3365:16, 3371:4, 3371:9, 3371:11,

3371:13, 3371:17, 3372:13

needle [1] - 3284:22

needs [7] - 3197:2, 3212:23, 3371:11,

3417:16, 3417:17, 3417:23, 3421:5

negative [16] - 3257:11, 3261:12,

3261:13, 3354:5, 3354:17, 3365:1,

3365:2, 3365:12, 3365:16, 3366:7,

3366:23, 3366:25, 3367:5, 3367:6,

3369:15, 3369:17

negatively [1] - 3261:20

negotiate [1] - 3310:10

negotiated [1] - 3301:9

neighborhood [7] - 3150:17, 3199:18,

3255:21, 3255:22, 3259:2, 3261:7,

3281:1

nervous [1] - 3332:6

net [4] - 3191:19, 3199:14, 3199:15

net-net [1] - 3191:19

netted [1] - 3192:1

never [15] - 3168:22, 3222:1, 3224:12,

3225:24, 3232:12, 3232:13, 3235:6,

3252:11, 3267:7, 3283:23, 3284:1,

3296:13, 3311:19, 3385:24

New [7] - 3143:17, 3233:5, 3234:3,

3234:9, 3234:10, 3422:25, 3423:7

new [17] - 3147:6, 3148:11, 3148:15,

3161:13, 3165:23, 3171:2, 3181:10,

3181:19, 3182:1, 3198:16, 3199:3,

3201:23, 3276:24, 3277:7, 3277:24,

3413:14, 3413:17

newspaper [1] - 3330:12

newspapers [3] - 3302:16, 3302:17,

3302:19

next [40] - 3162:14, 3181:21, 3194:25,

3195:17, 3195:21, 3209:2, 3215:19,

3215:20, 3223:2, 3237:10, 3239:3,

3244:25, 3247:12, 3262:4, 3262:16,

3262:17, 3267:11, 3267:13, 3268:16,

3278:8, 3283:13, 3292:24, 3299:5,

3306:2, 3336:1, 3338:19, 3339:11,

3345:2, 3366:9, 3367:1, 3367:9,

3384:9, 3386:16, 3409:21, 3412:23,

3414:11, 3414:22, 3414:23, 3416:14Johnny C. Sanchez, RMR, CRR - [email protected]

3445

nice [9] - 3320:22, 3320:23, 3320:25,

3321:4, 3321:6, 3321:7, 3321:10,

3321:11, 3321:13

niece [1] - 3160:5

night [3] - 3267:1, 3282:24, 3415:18

nobody [16] - 3176:16, 3235:9,

3239:11, 3303:11, 3349:22, 3385:23,

3386:2, 3395:24, 3398:12, 3398:16,

3398:21, 3398:24, 3399:16, 3400:1,

3414:4

nobody's [3] - 3399:25, 3400:2,

3400:6

noise [1] - 3300:12

non [1] - 3325:24

non-es [1] - 3325:24

none [5] - 3205:17, 3225:23, 3298:16,

3299:18, 3326:6

noninterest [1] - 3381:5

Nonresponsive [1] - 3352:25

nonresponsive [24] - 3157:10, 3158:2,

3177:1, 3177:4, 3183:16, 3183:23,

3189:2, 3204:5, 3204:7, 3207:10,

3231:23, 3266:11, 3275:19, 3282:1,

3303:3, 3304:15, 3304:17, 3306:1,

3308:4, 3308:12, 3316:6, 3325:14,

3325:16, 3386:13

nonresponsiveness [1] - 3179:14

normal [2] - 3159:5, 3351:3

North [2] - 3160:11, 3176:1

north [2] - 3203:7, 3204:2

Northeast [2] - 3284:23, 3287:21

note [4] - 3261:6, 3290:6, 3339:13,

3342:25

notes [9] - 3155:25, 3253:3, 3253:4,

3253:7, 3261:12, 3292:24, 3374:2,

3384:7

nothing [8] - 3177:9, 3217:16, 3220:3,

3302:16, 3311:22, 3327:25, 3391:24,

3423:19

notifying [1] - 3195:11

November [10] - 3193:25, 3194:16,

3202:20, 3291:18, 3292:17, 3314:2,

3332:16, 3364:24, 3366:6

nowhere [1] - 3302:2

number [46] - 3154:17, 3156:24,

3166:18, 3174:3, 3190:19, 3190:23,

3194:12, 3195:23, 3202:15, 3203:1,

3203:4, 3207:5, 3207:7, 3218:4,

3218:5, 3222:23, 3222:25, 3223:2,

3223:4, 3224:23, 3232:9, 3246:9,

3251:7, 3255:4, 3255:11, 3255:13,

3255:23, 3259:5, 3270:10, 3280:1,

3288:5, 3305:17, 3324:15, 3324:16,

3324:17, 3326:22, 3359:15, 3382:16,

3382:17, 3382:22, 3383:19, 3384:20,

3384:23, 3401:21, 3423:5

Number [2] - 3362:7, 3368:2

numbers [18] - 3190:16, 3191:6,

3191:8, 3191:9, 3250:25, 3254:4,

3254:7, 3256:6, 3276:20, 3360:2,

3381:4, 3381:14, 3381:25, 3382:3,

3382:5, 3382:11, 3382:13

numerous [1] - 3214:16

NW [1] - 3143:17

O

o'clock [2] - 3247:14, 3421:14

oath [2] - 3232:8, 3232:10

object [45] - 3151:21, 3152:17,

3153:13, 3158:2, 3161:18, 3167:21,

3168:3, 3177:1, 3178:22, 3179:14,

3183:15, 3189:2, 3204:5, 3204:24,

3205:3, 3207:10, 3208:18, 3208:20,

3212:19, 3213:15, 3214:12, 3215:14,

3220:16, 3228:5, 3230:11, 3231:23,

3235:13, 3238:23, 3239:13, 3252:13,

3256:9, 3258:11, 3260:8, 3260:19,

3266:11, 3268:21, 3275:19, 3277:17,

3282:1, 3286:6, 3308:19, 3383:7,

3386:13, 3407:9, 3410:22

objecting [2] - 3308:19, 3308:20

objection [38] - 3154:21, 3155:14,

3168:10, 3179:6, 3208:24, 3213:5,

3244:19, 3244:21, 3269:16, 3269:17,

3270:2, 3274:2, 3278:13, 3296:15,

3296:22, 3297:14, 3306:1, 3308:18,

3311:3, 3311:9, 3315:19, 3322:14,

3323:4, 3328:25, 3329:8, 3352:25,

3355:21, 3362:9, 3362:10, 3362:11,

3362:14, 3368:12, 3399:2, 3399:19,

3406:6, 3406:18, 3408:8, 3414:4

objections [1] - 3407:14

obligated [1] - 3190:25

observing [1] - 3175:9

obstruction [1] - 3395:21

obtain [5] - 3200:5, 3243:3, 3291:3,

3327:23, 3352:13

obtained [3] - 3243:5, 3413:4, 3413:9

obtaining [2] - 3242:8, 3415:2

obviously [2] - 3252:18, 3299:7

occurred [1] - 3349:18

October [14] - 3190:8, 3190:14,

3190:25, 3191:13, 3192:14, 3192:17,

3192:21, 3193:4, 3193:17, 3199:25,

3203:14, 3204:11, 3207:14, 3303:7

odd [1] - 3326:22

OF [2] - 3143:1, 3143:4

offer [3] - 3236:9, 3362:6, 3368:9

offered [1] - 3274:8

offering [1] - 3272:9

office [10] - 3168:15, 3169:3, 3173:14,

3231:7, 3242:14, 3266:4, 3287:3,

3287:11, 3346:20, 3363:3

officer [20] - 3153:3, 3169:2, 3233:19,

3233:20, 3238:7, 3244:1, 3245:2,

3267:17, 3267:24, 3268:19, 3269:4,

3269:9, 3270:6, 3270:13, 3322:7,

3356:9, 3358:5, 3386:24, 3401:4,

3411:5

officers [2] - 3237:5, 3237:19

offices [9] - 3149:1, 3162:23, 3176:1,

3176:2, 3189:15, 3231:14, 3234:10,

3243:23, 3288:1

officially [1] - 3424:1

officing [2] - 3172:25, 3173:1

offset [3] - 3182:17, 3224:15, 3225:1

offsetting [1] - 3208:6

offshore [2] - 3210:6, 3210:10

often [2] - 3208:25, 3300:11

old [11] - 3373:8, 3388:21, 3392:8,

3403:2, 3403:12, 3404:24, 3405:23,

3411:17, 3412:7, 3412:10, 3419:4

oldest [1] - 3404:8

on-the-record [1] - 3417:17

once [12] - 3160:23, 3216:9, 3223:21,

3224:7, 3224:9, 3224:19, 3265:13,

3276:23, 3279:11, 3294:1, 3369:17,

3419:17

one [80] - 3146:18, 3152:9, 3162:6,

3171:18, 3175:17, 3175:19, 3176:5,

3179:5, 3202:15, 3208:24, 3212:9,

3214:15, 3215:16, 3232:9, 3234:16,

3235:4, 3239:15, 3241:21, 3241:23,

3241:24, 3243:13, 3245:17, 3252:8,

3256:1, 3256:14, 3260:4, 3263:6,

3263:17, 3270:9, 3271:9, 3275:24,

3277:1, 3283:2, 3285:3, 3289:12,

3307:4, 3308:10, 3315:8, 3331:7,

3335:3, 3338:5, 3343:19, 3345:3,

3347:7, 3348:16, 3348:20, 3358:14,

3360:25, 3361:16, 3361:19, 3362:1,

3364:7, 3364:13, 3366:8, 3368:4,

3368:21, 3375:15, 3380:25, 3384:20,

3385:16, 3387:22, 3388:20, 3394:14,

3395:23, 3397:19, 3400:16, 3401:2,

3409:24, 3410:16, 3410:17, 3411:21,

3413:2, 3413:3, 3413:14, 3413:15,

3414:8, 3418:18, 3421:16, 3421:18

ones [4] - 3244:6, 3278:20, 3360:24,

3397:2

ongoing [4] - 3152:4, 3157:19, 3175:8,

3176:24

open [7] - 3147:20, 3148:3, 3148:6,

3148:25, 3165:6, 3256:14, 3331:15

opened [2] - 3148:23, 3294:6

opening [4] - 3147:16, 3164:25,

3286:9, 3411:15

opens [1] - 3149:14

opera [2] - 3406:21, 3413:7

operate [1] - 3211:23

operating [2] - 3381:1, 3381:14

operation [1] - 3360:3

opinion [1] - 3240:5

opportunity [5] - 3148:16, 3148:17,

3155:4, 3156:8, 3202:2

opposed [5] - 3212:15, 3213:10,

3214:8, 3308:19, 3312:18

opposite [1] - 3283:10

Oracle [5] - 3285:25, 3391:19,

3391:21, 3392:4, 3393:2

order [6] - 3148:20, 3196:5, 3207:23,

3255:5, 3347:1, 3423:8

ORDERED [1] - 3331:12

orders [1] - 3412:9

organization [7] - 3173:9, 3233:8,

3237:20, 3256:5, 3271:3, 3357:13,

3358:1Johnny C. Sanchez, RMR, CRR - [email protected]

3446

organizational [1] - 3160:19

organizer [1] - 3164:23

organizing [1] - 3164:21

original [4] - 3305:11, 3362:8, 3372:4,

3421:10

originally [4] - 3210:24, 3375:25,

3382:14, 3403:24

Orlando [1] - 3175:24

otherwise [5] - 3292:23, 3337:1,

3351:6, 3374:16, 3407:21

ought [2] - 3299:19, 3417:8

ourselves [1] - 3423:2

outgoing [1] - 3192:2

outgoings [1] - 3194:23

outlying [3] - 3219:13, 3219:14,

3219:17

outside [13] - 3218:18, 3227:1,

3232:18, 3280:15, 3280:22, 3281:5,

3281:24, 3290:1, 3344:11, 3397:4,

3409:17, 3413:15, 3415:11

overall [2] - 3151:10, 3382:13

overdraft [2] - 3366:14, 3366:18

overdrafts [1] - 3366:20

overhead [4] - 3187:5, 3187:6,

3248:23, 3291:19

overpaid [1] - 3215:10

overrule [4] - 3274:1, 3296:20,

3296:22, 3329:8

overruled [18] - 3161:20, 3168:20,

3205:5, 3215:15, 3220:19, 3228:7,

3230:13, 3234:18, 3235:15, 3238:25,

3239:14, 3252:15, 3256:11, 3282:3,

3296:20, 3308:21, 3386:14

oversaw [1] - 3160:11

oversight [1] - 3375:4

owed [2] - 3180:2, 3225:5

own [8] - 3151:2, 3201:20, 3211:23,

3212:2, 3214:9, 3339:19, 3342:2,

3343:17

owned [24] - 3147:25, 3149:10,

3150:19, 3150:20, 3150:21, 3150:23,

3151:1, 3184:22, 3187:22, 3205:16,

3209:17, 3215:22, 3230:11, 3251:13,

3251:15, 3251:17, 3269:22, 3271:6,

3339:23, 3340:24, 3360:24, 3360:25,

3372:5

owner [2] - 3290:10, 3343:22

ownership [3] - 3149:5, 3209:18,

3215:22

owning [1] - 3214:9

owns [3] - 3271:24, 3317:9, 3349:8

P

p.m [3] - 3257:20, 3331:8, 3424:2

pace [2] - 3161:10, 3330:6

pad [2] - 3390:15, 3390:18

page [17] - 3154:16, 3155:7, 3190:10,

3194:2, 3194:9, 3194:19, 3195:7,

3195:21, 3202:8, 3237:10, 3324:1,

3367:1, 3370:23, 3370:24, 3383:19,

3386:16, 3386:17

Page [4] - 3237:10, 3367:2, 3380:7,

3381:19

PAGE [1] - 3145:2

pages [2] - 3324:8

paid [15] - 3158:10, 3164:19, 3171:3,

3215:7, 3216:7, 3223:3, 3225:13,

3290:12, 3290:15, 3328:21, 3337:25,

3338:2, 3342:25, 3371:16, 3371:17

pains [1] - 3235:8

panic [3] - 3162:5, 3162:9, 3162:10

panicked [1] - 3400:18

paper [7] - 3200:9, 3200:10, 3200:13,

3200:17, 3347:14, 3347:16, 3348:9

paperwork [1] - 3221:15

paragraph [7] - 3155:6, 3155:8,

3155:12, 3156:8, 3202:7, 3202:8,

3202:10

parcel [2] - 3215:21, 3219:20

parcels [7] - 3208:10, 3211:6,

3214:25, 3215:25, 3219:1, 3223:1,

3223:19

PARRAS [2] - 3416:11, 3418:11

Parras [2] - 3144:2, 3415:12

part [24] - 3183:22, 3204:25, 3205:3,

3210:18, 3224:13, 3266:16, 3319:4,

3319:18, 3322:4, 3324:7, 3324:19,

3326:16, 3327:8, 3327:16, 3337:13,

3346:7, 3361:17, 3379:18, 3379:19,

3379:20, 3382:13, 3395:20, 3395:22,

3413:8

parte [3] - 3410:8, 3410:10, 3415:1

participate [1] - 3233:23

participated [1] - 3153:19

participating [3] - 3153:24, 3174:4,

3239:24

particular [5] - 3184:15, 3219:20,

3285:5, 3334:7, 3355:4

particularly [2] - 3356:14, 3356:16

parties [2] - 3271:18

partner [2] - 3343:23, 3412:7

parts [1] - 3173:9

party [5] - 3270:8, 3271:19, 3272:22,

3273:13, 3273:15

parté [1] - 3410:11

pass [4] - 3295:19, 3354:14, 3354:15,

3418:21

pass-through [2] - 3354:14, 3354:15

passed [1] - 3349:16

passes [1] - 3354:3

passing [2] - 3173:2, 3285:1

password [4] - 3391:10, 3391:14,

3391:17, 3391:18

past [5] - 3147:7, 3173:20, 3242:16,

3373:24, 3412:17

Patlan [2] - 3194:3, 3194:7

Patricia [6] - 3185:9, 3348:2, 3349:16,

3352:4, 3352:5, 3352:6

pause [1] - 3403:16

pay [16] - 3148:22, 3161:14, 3171:7,

3171:9, 3182:23, 3191:1, 3197:2,

3199:6, 3200:16, 3211:6, 3225:7,

3225:20, 3290:22, 3325:12, 3328:15,

3337:4

paying [9] - 3148:19, 3161:12, 3166:5,

3166:6, 3181:25, 3216:2, 3318:15,

3337:23, 3371:13

payments [4] - 3292:25, 3339:13,

3340:15, 3342:25

payroll [3] - 3292:22, 3336:4, 3336:5

Pendergest [2] - 3401:5, 3406:24

pending [1] - 3321:16

pension [1] - 3294:17

people [59] - 3152:6, 3164:4, 3168:2,

3168:5, 3168:7, 3172:7, 3172:17,

3173:3, 3173:15, 3174:16, 3174:24,

3176:2, 3176:17, 3177:2, 3192:15,

3198:22, 3199:2, 3200:16, 3201:8,

3201:9, 3201:21, 3212:20, 3239:12,

3239:23, 3244:6, 3254:1, 3255:7,

3255:19, 3256:4, 3256:8, 3257:4,

3257:5, 3258:8, 3258:12, 3258:15,

3258:21, 3259:8, 3259:13, 3260:3,

3260:5, 3260:15, 3260:17, 3261:22,

3262:8, 3262:9, 3262:17, 3263:5,

3272:13, 3272:16, 3279:3, 3280:13,

3281:15, 3342:10, 3374:20, 3374:21,

3374:23, 3380:5, 3403:1, 3407:4

per [6] - 3166:1, 3181:1, 3181:2,

3217:4, 3223:6, 3241:1

percent [20] - 3151:12, 3166:12,

3166:13, 3166:23, 3167:7, 3202:22,

3202:23, 3220:6, 3220:14, 3230:11,

3251:23, 3252:19, 3253:21, 3255:2,

3261:14, 3281:1, 3281:2, 3281:5,

3349:9, 3419:20

percentage [13] - 3151:10, 3152:3,

3152:5, 3154:4, 3154:7, 3154:10,

3157:3, 3157:4, 3157:6, 3157:16,

3166:7, 3280:21

percentage-wise [1] - 3166:7

percentages [1] - 3280:24

perform [1] - 3165:22

performance [1] - 3289:6

Performers [1] - 3163:11

performing [2] - 3181:9, 3181:12

perhaps [1] - 3412:21

period [5] - 3192:22, 3305:17,

3310:25, 3343:4, 3394:12

perjure [1] - 3283:3

permanent [1] - 3173:16

permanently [1] - 3172:9

permission [2] - 3291:4, 3349:7

perpetuating [1] - 3379:11

person [9] - 3162:21, 3183:12,

3256:10, 3273:17, 3273:19, 3337:21,

3338:1, 3408:5, 3414:1

personal [20] - 3285:24, 3302:3,

3322:16, 3323:9, 3323:18, 3326:7,

3326:11, 3327:24, 3340:19, 3340:20,

3344:2, 3387:15, 3391:8, 3392:10,

3392:14, 3392:23, 3393:5, 3393:7,

3393:25, 3408:22

personally [4] - 3212:16, 3214:8,

3349:21, 3366:5

personnel [1] - 3392:24Johnny C. Sanchez, RMR, CRR - [email protected]

3447

persons [1] - 3401:3

perspective [2] - 3170:25, 3174:8

persuade [1] - 3148:14

pertaining [1] - 3188:2

pertains [1] - 3225:3

Peter [1] - 3242:15

Phoenix [1] - 3242:5

phone [19] - 3162:21, 3195:14,

3238:13, 3238:14, 3238:16, 3239:25,

3245:5, 3291:23, 3293:7, 3302:22,

3318:24, 3328:8, 3332:8, 3332:12,

3332:18, 3332:20, 3332:22, 3333:23,

3333:25

phonied [3] - 3382:16, 3382:17,

3382:22

phony [4] - 3304:6, 3383:19, 3384:20,

3385:16

photo [1] - 3332:18

photocopy [2] - 3317:17, 3317:18

photograph [2] - 3317:16, 3332:12

photographed [1] - 3333:15

photos [1] - 3321:3

phrase [1] - 3221:8

phrased [1] - 3269:16

physically [2] - 3233:21, 3239:12

pick [1] - 3257:13

picked [1] - 3196:7

picture [10] - 3291:22, 3292:14,

3314:14, 3314:22, 3314:25, 3316:1,

3317:8, 3317:13, 3328:8

pictures [1] - 3321:2

pie [9] - 3249:24, 3253:25, 3254:3,

3258:4, 3260:3, 3262:7, 3262:10,

3265:8, 3266:6

piece [4] - 3218:9, 3253:3, 3261:17,

3395:1

pieces [6] - 3207:25, 3252:22, 3335:2,

3341:17, 3395:6, 3396:25

pilots [1] - 3175:2

place [37] - 3153:24, 3160:23,

3166:19, 3171:22, 3177:19, 3184:13,

3196:12, 3196:14, 3211:8, 3216:14,

3216:23, 3221:25, 3231:13, 3231:14,

3231:16, 3232:21, 3233:7, 3235:7,

3235:8, 3237:6, 3240:8, 3240:9,

3240:16, 3241:8, 3243:17, 3262:21,

3274:19, 3275:4, 3279:15, 3279:24,

3280:19, 3282:15, 3290:3, 3295:21,

3347:23, 3388:5, 3391:22

placed [2] - 3151:19, 3252:17

places [1] - 3202:23

plan [7] - 3178:15, 3204:3, 3204:10,

3225:9, 3225:16, 3244:8, 3281:17

plane [1] - 3423:9

planes [1] - 3171:13

plans [2] - 3188:8, 3188:10

platoon [1] - 3176:2

play [3] - 3192:19, 3239:7, 3375:24

played [3] - 3193:1, 3193:5, 3411:16

plea [12] - 3310:12, 3322:4, 3323:2,

3323:6, 3323:11, 3324:19, 3324:24,

3328:3, 3337:13, 3395:20, 3395:22

pleaded [1] - 3309:22

pled [3] - 3179:4, 3295:13, 3300:2

plenty [1] - 3379:3

plug [1] - 3255:17

plugs [1] - 3393:17

plummeting [2] - 3220:12, 3220:13

plus [2] - 3254:18, 3290:17

PO [2] - 3143:14, 3144:7

pocket [2] - 3347:11, 3368:7

point [48] - 3157:25, 3160:19, 3161:9,

3161:25, 3174:10, 3176:3, 3176:12,

3181:22, 3181:24, 3184:23, 3188:7,

3188:11, 3189:17, 3192:19, 3193:13,

3193:22, 3195:16, 3196:13, 3199:18,

3199:20, 3205:19, 3210:25, 3218:14,

3227:16, 3235:4, 3235:23, 3239:12,

3247:2, 3262:8, 3265:7, 3272:1,

3277:21, 3288:20, 3289:2, 3297:20,

3298:18, 3299:19, 3311:14, 3312:4,

3312:16, 3319:8, 3358:14, 3371:15,

3371:16, 3407:3, 3411:18, 3419:24

pointed [1] - 3312:24

points [3] - 3278:16, 3280:6, 3280:7

portfolio [6] - 3166:9, 3196:17,

3196:20, 3237:17, 3239:5, 3266:24

portion [6] - 3185:4, 3191:12, 3206:18,

3207:3, 3222:14

portions [2] - 3154:22, 3156:1

portrayed [1] - 3208:19

position [10] - 3148:17, 3169:7,

3174:14, 3202:24, 3278:18, 3278:21,

3298:15, 3366:18, 3413:4, 3418:1

positions [3] - 3179:13, 3194:22,

3194:25

positive [1] - 3257:8

possibility [1] - 3147:16

possible [8] - 3167:14, 3167:19,

3169:8, 3319:17, 3319:20, 3403:4,

3420:8, 3422:3

possibly [6] - 3150:9, 3198:15,

3201:23, 3291:18, 3348:15, 3364:5

post [1] - 3363:3

poster [1] - 3209:1

potential [5] - 3170:17, 3171:7,

3173:11, 3173:15

pound [1] - 3194:25

power [1] - 3352:12

practice [2] - 3170:20, 3170:21

prayer [1] - 3268:8

precise [2] - 3168:9, 3168:11

prejudiced [1] - 3417:19

preparation [2] - 3241:15, 3243:15

prepare [4] - 3303:18, 3305:8,

3337:21, 3346:6

prepared [9] - 3248:3, 3250:2,

3250:20, 3316:21, 3359:3, 3372:15,

3375:2, 3379:17, 3381:19

preparer [1] - 3338:1

prepares [1] - 3374:19

preparing [6] - 3284:17, 3305:15,

3305:19, 3305:22, 3335:12, 3386:3

presence [4] - 3300:24, 3331:9,

3350:10, 3410:4

present [21] - 3153:17, 3153:18,

3153:23, 3170:25, 3180:22, 3180:23,

3191:19, 3191:22, 3191:25, 3193:19,

3239:12, 3239:23, 3244:11, 3263:3,

3266:7, 3266:18, 3272:13, 3272:16,

3272:18, 3278:19

presentation [7] - 3243:16, 3262:16,

3263:2, 3263:7, 3264:3, 3265:7,

3266:17

presenters [1] - 3266:17

preserve [3] - 3317:14, 3318:1,

3318:10

president [13] - 3153:4, 3183:13,

3183:24, 3233:17, 3233:18, 3238:6,

3238:20, 3243:25, 3244:4, 3261:23,

3264:18, 3264:24, 3268:1

presidents [1] - 3148:12

Preston [1] - 3144:3

presume [2] - 3315:17, 3317:2

pretty [8] - 3174:7, 3174:8, 3174:9,

3195:16, 3320:25, 3365:11, 3371:21,

3395:19

previous [3] - 3148:13, 3246:24,

3283:5

previously [6] - 3177:14, 3180:7,

3238:9, 3281:14, 3290:7, 3369:5

price [7] - 3215:6, 3215:10, 3215:12,

3216:4, 3216:6, 3223:3, 3252:10

primarily [4] - 3147:24, 3155:8,

3160:1, 3184:17

primary [2] - 3273:17, 3273:19

printing [1] - 3169:17

priority [1] - 3202:16

private [16] - 3171:14, 3171:18,

3174:15, 3174:21, 3184:19, 3184:22,

3248:7, 3249:25, 3251:11, 3252:17,

3252:22, 3252:25, 3253:10, 3259:16,

3261:17, 3301:12

privately [1] - 3265:24

privilege [16] - 3230:5, 3230:9,

3230:12, 3234:17, 3234:21, 3234:23,

3234:24, 3296:15, 3298:5, 3298:13,

3299:16, 3300:3, 3300:13, 3300:15,

3300:17, 3300:18

privileged [2] - 3154:14, 3296:16

probability [1] - 3279:8

problem [15] - 3161:4, 3161:6, 3161:8,

3163:6, 3165:22, 3198:7, 3214:17,

3254:15, 3260:12, 3275:24, 3299:23,

3338:16, 3411:10, 3415:25, 3416:10

problems [2] - 3161:3, 3361:16

procedure [1] - 3303:23

proceed [4] - 3146:3, 3213:25,

3295:25, 3331:20

proceedings [1] - 3424:6

Proceedings [1] - 3144:14

process [8] - 3157:18, 3178:18,

3211:3, 3232:20, 3252:11, 3252:23,

3277:10, 3415:2

processes [1] - 3159:5

processing [1] - 3389:9

produce [4] - 3171:2, 3237:3, 3237:4,Johnny C. Sanchez, RMR, CRR - [email protected]

3448

3336:21

produced [3] - 3144:14, 3164:7,

3164:8

Producer [3] - 3163:12, 3163:20,

3165:7

producer [1] - 3164:2

Producers [2] - 3163:13, 3241:18

product [2] - 3163:18, 3163:19

production [1] - 3287:17

products [4] - 3155:9, 3158:7,

3159:15, 3164:10

profit [8] - 3166:22, 3276:20, 3380:19,

3380:21, 3380:23, 3381:14, 3382:14,

3382:15

program [10] - 3152:2, 3163:5, 3163:7,

3163:9, 3163:10, 3165:24, 3171:1,

3232:19, 3277:4, 3277:5

project [8] - 3191:17, 3210:8, 3210:23,

3210:25, 3211:3, 3293:24, 3328:24,

3329:2

projects [2] - 3174:14, 3360:22

promised [1] - 3283:23

promoted [1] - 3172:19

promotion [1] - 3271:5

promotional [4] - 3169:17, 3170:5,

3170:7, 3170:8

proof [2] - 3318:17, 3318:18

properly [1] - 3338:18

property [2] - 3219:25, 3223:8

proposal [1] - 3280:17

proposals [2] - 3280:1, 3280:5

propose [5] - 3273:1, 3274:23,

3276:12, 3278:11, 3279:12

proposed [11] - 3198:12, 3198:13,

3199:16, 3200:5, 3220:25, 3221:2,

3221:10, 3225:23, 3274:12, 3275:1,

3280:2

prosecution [1] - 3235:3

prosecutor [2] - 3306:10, 3311:11

prosecutors [18] - 3301:10, 3301:25,

3302:9, 3303:13, 3304:10, 3305:16,

3306:7, 3310:15, 3311:2, 3311:5,

3327:3, 3328:1, 3335:4, 3335:11,

3336:21, 3338:12, 3385:14, 3400:1

Proskauer [1] - 3234:8

prospective [1] - 3200:23

PROSPECTIVE [1] - 3336:2

protect [1] - 3298:15

prove [3] - 3291:25, 3292:1, 3292:6

provide [8] - 3202:17, 3231:19,

3271:4, 3276:3, 3349:9, 3349:11,

3413:13, 3415:3

provided [1] - 3289:5

providing [2] - 3196:23, 3416:5

provision [2] - 3366:14, 3366:18

public [1] - 3290:11

publicly [1] - 3204:19

published [3] - 3250:8, 3250:9,

3379:17

pull [7] - 3187:9, 3187:10, 3201:22,

3247:21, 3331:25, 3332:3, 3371:6

pulled [2] - 3253:5, 3418:15

pulling [2] - 3201:10, 3347:12

purchase [5] - 3212:15, 3213:10,

3215:6, 3215:10, 3252:10

purchased [13] - 3152:15, 3208:10,

3209:21, 3211:20, 3212:3, 3215:1,

3217:11, 3217:17, 3218:7, 3219:21,

3220:4, 3341:2, 3341:18

purchases [1] - 3170:18

purpose [15] - 3163:15, 3163:17,

3180:20, 3203:19, 3243:11, 3256:24,

3272:10, 3274:2, 3274:19, 3288:13,

3334:8, 3355:8, 3355:11, 3407:1

purposes [3] - 3251:19, 3251:21,

3407:1

put [40] - 3151:7, 3153:12, 3163:5,

3163:7, 3179:12, 3199:17, 3217:20,

3217:21, 3245:20, 3249:9, 3249:24,

3251:5, 3262:25, 3268:7, 3269:7,

3286:11, 3293:22, 3316:21, 3317:19,

3319:18, 3329:6, 3359:5, 3360:22,

3364:3, 3364:16, 3365:17, 3365:19,

3374:24, 3383:18, 3383:19, 3391:21,

3396:17, 3412:12, 3412:15, 3413:25,

3414:5, 3415:6, 3416:13, 3417:2

puts [1] - 3369:16

putting [4] - 3286:14, 3308:11, 3416:4,

3423:11

pyramid [1] - 3176:24

Q

quadrant [2] - 3251:9, 3259:20

qualified [2] - 3160:18, 3176:2

quarter [8] - 3166:2, 3181:13, 3181:15,

3181:16, 3181:17, 3199:22, 3199:24,

3215:5

quarterly [2] - 3163:10, 3163:16

questioned [1] - 3311:20

questioning [5] - 3167:22, 3168:17,

3170:3, 3170:9

questions [17] - 3155:19, 3184:15,

3264:14, 3299:17, 3305:18, 3305:24,

3306:6, 3307:11, 3307:14, 3308:20,

3323:22, 3362:3, 3383:12, 3385:21,

3398:15, 3400:11, 3422:16

queue [1] - 3246:4

quick [1] - 3226:9

quicker [1] - 3304:25

quickly [1] - 3415:14

quit [5] - 3173:21, 3174:2, 3177:8,

3178:13, 3312:4

quite [5] - 3162:5, 3169:6, 3400:15,

3411:9, 3415:15

quote [1] - 3230:23

R

raise [7] - 3177:10, 3177:12, 3203:7,

3205:25, 3277:21, 3297:21, 3299:18

raised [4] - 3152:14, 3157:25,

3177:13, 3221:22

raising [1] - 3226:6

ran [1] - 3317:20

ranching [1] - 3377:8

range [4] - 3150:8, 3166:15, 3166:23,

3167:4

rapid [1] - 3330:6

rate [20] - 3147:2, 3147:4, 3147:7,

3147:9, 3154:8, 3159:8, 3159:12,

3166:4, 3166:5, 3182:19, 3191:19,

3191:22, 3191:25, 3192:1, 3192:6,

3193:19, 3199:4, 3414:10, 3415:16

rates [1] - 3202:1

rather [5] - 3155:21, 3174:13, 3213:15,

3223:18, 3320:20

ratio [2] - 3202:22, 3202:23

RE [2] - 3340:9, 3340:12

rea [1] - 3418:17

reach [3] - 3246:20, 3290:20, 3420:11

reaching [1] - 3347:11

react [2] - 3256:8, 3262:3

reacted [2] - 3261:24, 3262:4

reaction [6] - 3256:16, 3256:25,

3257:2, 3260:4, 3262:17, 3280:4

read [20] - 3155:11, 3155:22, 3187:25,

3191:15, 3194:19, 3202:10, 3237:2,

3248:6, 3291:12, 3292:20, 3292:21,

3334:16, 3334:18, 3339:12, 3345:5,

3368:16, 3380:9, 3397:23, 3397:25,

3412:23

reading [9] - 3155:13, 3187:23,

3194:5, 3207:5, 3224:4, 3237:3,

3248:5, 3271:10, 3334:16

reads [8] - 3185:20, 3186:18, 3187:18,

3189:9, 3190:16, 3194:11, 3225:10,

3249:25

ready [14] - 3146:3, 3146:4, 3165:6,

3235:12, 3247:7, 3257:18, 3262:5,

3304:7, 3379:7, 3391:2, 3410:1,

3417:3, 3419:3, 3419:24

real [72] - 3174:14, 3176:3, 3184:19,

3184:22, 3208:9, 3209:17, 3209:21,

3210:4, 3210:7, 3211:20, 3212:3,

3212:15, 3213:10, 3215:21, 3216:11,

3217:3, 3217:20, 3218:10, 3218:13,

3218:14, 3220:13, 3223:1, 3223:20,

3224:2, 3225:6, 3225:11, 3225:24,

3251:23, 3252:3, 3252:6, 3252:9,

3253:19, 3254:15, 3254:17, 3254:18,

3259:14, 3261:15, 3264:11, 3264:12,

3278:22, 3292:25, 3320:5, 3340:13,

3340:14, 3340:15, 3340:18, 3340:22,

3340:24, 3340:25, 3341:1, 3341:2,

3341:3, 3341:9, 3341:17, 3341:19,

3343:1, 3343:4, 3354:2, 3354:8,

3358:12, 3361:11, 3361:13, 3361:18,

3361:20, 3365:19, 3385:15, 3385:24,

3386:6, 3386:8, 3386:10, 3386:12

reality [1] - 3263:19

really [10] - 3176:17, 3176:22,

3176:25, 3179:12, 3198:3, 3224:12,

3357:8, 3378:13, 3421:5

rearraignment [1] - 3420:19

reason [11] - 3188:25, 3189:6,Johnny C. Sanchez, RMR, CRR - [email protected]

3449

3212:14, 3214:5, 3226:17, 3239:20,

3270:12, 3318:10, 3343:7, 3355:12

reasons [4] - 3174:3, 3226:19,

3235:10, 3343:3

recap [1] - 3284:8

recapitalize [1] - 3328:20

receivable [3] - 3253:3, 3261:6,

3261:12

receive [5] - 3191:10, 3293:5, 3295:3,

3318:24, 3319:9

received [8] - 3185:6, 3185:7, 3237:22,

3314:18, 3324:23, 3324:25, 3397:5,

3398:15

receiver [19] - 3230:9, 3234:23,

3234:25, 3235:1, 3294:4, 3315:15,

3315:20, 3316:25, 3317:3, 3317:5,

3326:20, 3327:1, 3327:7, 3327:11,

3327:14, 3327:23, 3340:7, 3352:9,

3413:8

receiver's [5] - 3315:16, 3315:22,

3337:19, 3349:23, 3360:7

reception [1] - 3266:3

recess [2] - 3295:22, 3391:1

Recessed [4] - 3206:2, 3257:20,

3331:8, 3424:2

recognition [1] - 3163:23

recognize [5] - 3206:22, 3236:5,

3247:25, 3292:10, 3292:12

recollection [3] - 3150:16, 3155:17,

3356:3

recommend [1] - 3160:6

recommendation [1] - 3281:24

reconstruct [1] - 3396:9

reconstructed [1] - 3396:16

record [9] - 3236:17, 3236:22, 3292:5,

3412:6, 3413:25, 3414:5, 3417:17,

3418:3, 3424:6

recorded [1] - 3144:14

recordkeeping [1] - 3374:3

records [13] - 3200:8, 3328:11,

3335:18, 3337:16, 3337:17, 3337:19,

3352:10, 3360:6, 3360:7, 3360:8,

3373:23, 3385:11, 3385:15

recreate [1] - 3398:16

rectangle [1] - 3389:1

redeemed [1] - 3182:19

redeeming [1] - 3182:1

redemptions [10] - 3146:20, 3146:21,

3147:2, 3184:23, 3196:5, 3196:7,

3196:11, 3196:13, 3255:5, 3328:16

redirect [1] - 3384:8

reestablish [1] - 3397:7

refer [3] - 3288:15, 3373:12, 3373:20

reference [2] - 3167:2, 3353:13

referenced [2] - 3154:19, 3154:20

referred [4] - 3354:25, 3369:6,

3373:24, 3381:1

referring [12] - 3210:11, 3222:11,

3242:20, 3256:10, 3309:13, 3309:16,

3327:6, 3327:21, 3327:22, 3340:18,

3341:16, 3422:8

refers [2] - 3273:15, 3334:7

reflect [4] - 3224:6, 3276:21, 3372:20,

3372:21

reflected [2] - 3259:20, 3261:7

refreshing [1] - 3155:17

regarding [21] - 3152:14, 3177:22,

3183:23, 3191:17, 3192:16, 3234:15,

3235:25, 3242:17, 3261:6, 3276:12,

3277:16, 3277:24, 3278:7, 3278:8,

3280:8, 3280:17, 3285:7, 3294:8,

3301:4, 3398:8, 3410:19

regardless [4] - 3329:21, 3329:24,

3330:3, 3372:4

region [2] - 3158:21, 3175:16

regional [1] - 3160:10

regions [2] - 3151:16, 3160:12

registered [1] - 3347:16

regular [3] - 3170:20, 3279:20,

3279:22

regulating [1] - 3152:11

regulator [2] - 3153:7, 3153:11

regulators [7] - 3152:7, 3152:8,

3157:16, 3240:25, 3277:1, 3395:2,

3395:10

regulatory [1] - 3156:19

relate [1] - 3168:23

related [6] - 3152:6, 3159:4, 3206:25,

3271:5, 3327:15, 3340:21

relates [1] - 3181:2

relating [1] - 3168:3

relation [1] - 3160:4

relationship [21] - 3181:20, 3199:4,

3252:6, 3310:21, 3310:25, 3343:25,

3344:2, 3344:3, 3344:12, 3344:15,

3344:16, 3403:8, 3405:5, 3405:12,

3405:25, 3406:24, 3408:5, 3408:24,

3409:3, 3409:10, 3409:18

relationships [2] - 3408:20, 3409:1

relative [4] - 3276:2, 3278:22, 3412:20,

3415:6

relaxed [1] - 3351:25

relayed [2] - 3154:1, 3296:18

relaying [1] - 3168:7

relevance [7] - 3286:6, 3286:7,

3406:19, 3407:11, 3407:14, 3408:10,

3408:23

relevant [2] - 3272:16, 3408:12

relief [2] - 3195:1, 3195:3

relieved [1] - 3256:18

remain [2] - 3178:18, 3423:23

remaining [3] - 3191:18, 3191:22,

3225:11

remark [2] - 3240:9, 3348:11

remember [33] - 3157:23, 3159:21,

3215:3, 3230:14, 3260:17, 3261:23,

3261:25, 3264:14, 3270:14, 3309:10,

3313:1, 3313:2, 3318:9, 3332:10,

3332:15, 3332:19, 3334:9, 3335:21,

3335:22, 3335:25, 3348:18, 3348:19,

3353:10, 3353:11, 3358:14, 3374:2,

3374:8, 3376:17, 3387:6, 3398:8,

3399:12, 3400:5, 3400:21

remind [9] - 3146:16, 3147:13,

3177:21, 3185:12, 3187:21, 3220:8,

3226:11, 3243:11, 3278:12

reminded [1] - 3411:17

remorse [2] - 3265:16, 3265:17

remuneration [2] - 3148:16, 3148:18

renew [1] - 3270:2

renovation [1] - 3293:24

repaid [2] - 3289:16, 3290:7

repay [2] - 3149:8, 3150:24

repeat [5] - 3155:6, 3173:10, 3189:23,

3289:1, 3351:6

rephrase [6] - 3183:18, 3183:25,

3184:2, 3231:24, 3304:23, 3305:14

replace [3] - 3159:24, 3257:24, 3334:2

replaced [4] - 3159:18, 3160:2,

3169:19, 3276:24

replicate [2] - 3318:23, 3319:2

replied [1] - 3177:24

reply [1] - 3167:18

report [22] - 3160:24, 3166:4, 3202:6,

3221:20, 3240:25, 3250:8, 3250:11,

3289:10, 3374:12, 3374:13, 3374:14,

3374:15, 3374:19, 3374:24, 3379:15,

3380:4, 3381:19, 3382:10, 3386:7,

3395:1, 3396:7, 3414:4

reported [16] - 3167:5, 3170:4, 3203:2,

3254:17, 3255:9, 3255:14, 3255:18,

3262:24, 3264:8, 3283:9, 3330:11,

3357:20, 3357:22, 3357:24, 3357:25

Reporter [1] - 3144:11

REPORTER [1] - 3291:18

REPORTER'S [1] - 3424:3

reporting [8] - 3166:9, 3166:22,

3185:13, 3197:2, 3226:14, 3275:3,

3275:18, 3356:12

reports [5] - 3175:22, 3297:3, 3297:5,

3302:2, 3304:5

represent [13] - 3186:1, 3190:23,

3194:12, 3195:25, 3207:7, 3207:20,

3215:24, 3222:23, 3233:1, 3235:5,

3255:12, 3298:17

represented [3] - 3150:6, 3234:22,

3250:23

represents [4] - 3186:3, 3210:2,

3230:6, 3230:7

request [11] - 3183:21, 3187:19,

3188:3, 3189:9, 3196:14, 3199:5,

3245:10, 3285:4, 3291:15, 3313:14,

3420:4

requested [1] - 3397:25

requesting [1] - 3246:6

requests [2] - 3190:24, 3287:16

require [5] - 3375:3, 3375:4, 3375:6,

3379:19, 3415:5

required [3] - 3375:1, 3415:7, 3418:17

requirement [1] - 3189:12

requirements [1] - 3202:25

research [6] - 3172:17, 3172:24,

3172:25, 3173:4, 3177:18, 3178:7

resolution [1] - 3420:5

resolving [1] - 3192:13

resort [1] - 3211:4

resources [2] - 3177:13, 3178:11


3450

respect [4] - 3253:10, 3307:20,

3326:8, 3413:11

respectfully [2] - 3183:21, 3229:21

respects [1] - 3378:9

respond [2] - 3228:6, 3338:10

responded [1] - 3264:25

responding [1] - 3319:11

response [10] - 3156:20, 3213:18,

3231:20, 3240:24, 3293:5, 3319:4,

3319:10, 3366:15, 3366:16, 3386:15

responsibility [2] - 3357:1, 3357:4

responsible [1] - 3263:14

responsive [2] - 3179:16, 3383:7

rest [6] - 3414:11, 3414:22, 3415:3,

3416:1, 3416:2, 3416:15

restate [2] - 3276:15, 3276:16

restated [3] - 3275:2, 3275:10,

3275:11

restatement [1] - 3277:10

restaurant [1] - 3343:21

restraints [2] - 3175:9, 3175:10

restrictions [1] - 3321:18

result [4] - 3228:8, 3228:10, 3295:12,

3380:23

resume [3] - 3257:18, 3410:2, 3422:3

resumed [2] - 3265:22, 3265:23

retails [1] - 3251:8

retained [3] - 3413:12, 3413:16,

3414:1

retire [1] - 3178:19

retrieve [1] - 3396:12

retrieved [2] - 3287:7, 3396:15

retrofitted [1] - 3275:6

return [8] - 3166:23, 3337:7, 3337:9,

3337:11, 3338:8, 3338:13, 3338:17,

3359:3

returned [2] - 3280:11, 3284:1

returning [1] - 3209:19

returns [13] - 3166:8, 3166:9, 3167:5,

3167:6, 3167:14, 3167:18, 3168:17,

3169:8, 3170:3, 3170:9, 3182:15,

3337:14, 3337:18

revealed [2] - 3311:19, 3396:8

Revenue [1] - 3338:7

revenue [2] - 3154:10, 3380:24

revenues [1] - 3380:22

review [5] - 3155:4, 3156:8, 3175:22,

3297:4, 3335:12

reviewed [2] - 3305:5, 3380:4

rich [1] - 3211:6

rid [1] - 3169:10

right-hand [2] - 3202:9, 3259:20

rights [1] - 3298:17

River [1] - 3162:23

RMR [2] - 3144:11, 3424:9

roads [3] - 3219:9, 3219:17, 3219:24

robbed [1] - 3215:11

ROBERT [1] - 3143:6

Robert [2] - 3143:21, 3296:4

Rodriguez [13] - 3233:17, 3238:6,

3238:20, 3243:25, 3245:18, 3246:9,

3264:17, 3264:20, 3265:2, 3267:19,

3281:14, 3282:5, 3282:8

rodriguez [1] - 3246:1

ROI [1] - 3168:2

role [6] - 3239:7, 3239:9, 3270:5,

3270:13, 3271:2, 3375:24

rolled [1] - 3270:10

Ron [1] - 3169:14

room [3] - 3169:2, 3263:5, 3423:1

Rose [1] - 3234:8

Rossi [8] - 3169:14, 3169:15, 3169:23,

3170:1, 3170:6, 3170:11, 3422:10,

3422:16

Rossi's [1] - 3170:2

rotating [1] - 3172:18

Rouge [1] - 3148:24

routing [1] - 3185:14

RPR [1] - 3144:11

Rule [1] - 3274:3

rule [6] - 3235:12, 3319:3, 3319:14,

3417:2, 3417:5, 3417:9

Rules [1] - 3303:22

ruling [5] - 3156:4, 3213:5, 3416:23,

3420:2

run [10] - 3160:18, 3191:19, 3192:6,

3193:19, 3331:5, 3358:1, 3366:6,

3379:16, 3403:19, 3420:2

running [10] - 3161:12, 3244:18,

3244:21, 3278:12, 3378:18, 3419:2,

3420:22, 3421:9, 3421:15, 3421:16

Rusk [1] - 3144:12

rustic [2] - 3321:11, 3321:13

Ruth [14] - 3403:23, 3404:1, 3404:11,

3404:12, 3404:15, 3405:7, 3405:10,

3405:12, 3405:20, 3406:5, 3406:10,

3406:17, 3407:6

S

safe [1] - 3202:14

safely [1] - 3283:1

safety [1] - 3202:15

salaries [5] - 3313:18, 3313:19,

3314:18, 3324:25, 3342:8

salary [2] - 3290:18, 3295:2

sales [52] - 3147:6, 3147:9, 3149:23,

3151:15, 3154:10, 3156:11, 3157:2,

3157:6, 3157:14, 3157:15, 3157:21,

3158:21, 3158:23, 3159:1, 3159:4,

3159:8, 3159:12, 3159:14, 3159:16,

3160:1, 3160:19, 3161:3, 3161:10,

3161:14, 3163:10, 3163:17, 3164:9,

3164:10, 3165:16, 3165:18, 3165:20,

3165:22, 3165:25, 3171:2, 3181:9,

3181:10, 3181:19, 3182:1, 3192:1,

3198:17, 3199:3, 3242:8, 3242:21,

3243:4, 3243:5, 3277:24, 3280:9,

3280:10, 3377:7, 3380:22, 3380:23,

3391:22

salespeople [1] - 3163:19

Sanchez [3] - 3144:11, 3424:5, 3424:9

sand [1] - 3232:9

sat [4] - 3262:23, 3263:11, 3307:8,

3309:20

satisfy [1] - 3271:8

saturation [1] - 3312:4

save [2] - 3293:9, 3361:25

saved [1] - 3395:8

saw [11] - 3166:17, 3167:9, 3173:7,

3173:12, 3192:22, 3193:17, 3221:19,

3256:7, 3288:17, 3298:1

scam [2] - 3176:23, 3176:24

Scardino [10] - 3143:21, 3143:21,

3261:13, 3286:9, 3296:4, 3296:21,

3298:24, 3299:1, 3299:11, 3411:10

SCARDINO [226] - 3146:22, 3151:21,

3152:17, 3153:13, 3153:16, 3155:13,

3157:8, 3157:10, 3158:2, 3161:18,

3166:24, 3167:20, 3168:1, 3168:18,

3177:1, 3177:4, 3178:22, 3178:25,

3179:14, 3183:15, 3183:21, 3189:2,

3192:20, 3192:23, 3204:5, 3204:7,

3204:23, 3207:10, 3208:18, 3212:19,

3212:25, 3213:2, 3213:4, 3213:14,

3214:12, 3215:14, 3220:16, 3222:10,

3228:5, 3229:13, 3229:21, 3230:2,

3230:5, 3230:10, 3231:23, 3234:17,

3235:2, 3235:14, 3238:23, 3239:13,

3244:18, 3245:10, 3252:13, 3256:9,

3258:11, 3260:8, 3260:19, 3266:11,

3268:21, 3269:15, 3270:2, 3270:14,

3272:15, 3273:13, 3274:5, 3274:8,

3275:19, 3277:17, 3278:12, 3282:1,

3286:6, 3286:10, 3286:19, 3291:24,

3292:4, 3295:25, 3296:3, 3296:18,

3296:24, 3298:20, 3299:2, 3299:6,

3299:22, 3300:13, 3301:1, 3303:3,

3303:5, 3304:15, 3304:17, 3305:4,

3305:13, 3306:1, 3306:3, 3307:3,

3308:4, 3308:5, 3308:12, 3308:15,

3308:18, 3308:24, 3309:1, 3309:5,

3309:16, 3309:19, 3311:13, 3313:4,

3313:6, 3315:21, 3315:24, 3316:6,

3316:8, 3316:11, 3321:2, 3321:5,

3322:22, 3322:25, 3323:6, 3323:15,

3323:18, 3323:22, 3323:25, 3324:3,

3324:6, 3324:11, 3325:14, 3325:16,

3325:18, 3326:2, 3326:15, 3328:5,

3328:6, 3329:4, 3329:18, 3330:24,

3331:20, 3331:21, 3332:2, 3332:4,

3332:6, 3332:7, 3334:12, 3334:14,

3342:1, 3350:6, 3350:9, 3350:17,

3350:21, 3351:20, 3351:23, 3352:25,

3353:4, 3356:1, 3361:3, 3361:6,

3362:6, 3362:10, 3362:12, 3362:16,

3362:19, 3367:1, 3367:3, 3368:9,

3368:11, 3368:14, 3369:2, 3369:4,

3369:20, 3369:23, 3370:22, 3370:25,

3371:8, 3372:10, 3372:12, 3373:12,

3373:14, 3374:5, 3380:7, 3380:11,

3380:13, 3383:7, 3383:9, 3383:17,

3384:12, 3385:5, 3386:13, 3386:16,

3386:18, 3387:1, 3387:3, 3389:8,

3389:14, 3389:24, 3390:4, 3390:21,

3391:3, 3397:21, 3397:24, 3398:4,


3451

3399:24, 3405:15, 3405:18, 3406:9,

3406:23, 3407:2, 3407:22, 3408:16,

3409:2, 3409:21, 3410:5, 3410:9,

3410:11, 3410:16, 3412:10, 3412:13,

3414:17, 3418:8, 3418:21, 3419:25,

3420:4, 3420:8, 3422:15, 3423:10

Scardino's [1] - 3410:19

SCARDINO............. [1] - 3145:5

scenic [1] - 3321:11

schedule [2] - 3414:12, 3421:21

scheduled [3] - 3282:16, 3420:14,

3422:24

scheme [2] - 3200:21, 3295:12

Schoblum [3] - 3267:20, 3268:6,

3273:24

scope [3] - 3146:23, 3166:24, 3270:5

scorekeeping [1] - 3356:12

scrambling [1] - 3328:15

screen [11] - 3146:3, 3206:1, 3248:23,

3248:24, 3257:16, 3257:24, 3262:25,

3389:3, 3389:12, 3390:13, 3390:20

screened [1] - 3413:17

scroll [2] - 3369:20, 3370:22

scrutiny [2] - 3157:16, 3157:17

SEALED [1] - 3331:12

seated [6] - 3206:4, 3257:22, 3295:23,

3331:19, 3414:20, 3423:24

SEC [38] - 3152:9, 3154:15, 3156:3,

3156:12, 3157:24, 3171:24, 3227:15,

3227:21, 3228:10, 3231:6, 3232:4,

3232:8, 3232:17, 3232:24, 3233:1,

3234:14, 3235:17, 3235:24, 3236:15,

3237:13, 3237:18, 3238:2, 3239:5,

3240:3, 3240:6, 3240:12, 3241:16,

3243:16, 3266:18, 3281:12, 3281:19,

3282:9, 3282:11, 3282:17, 3283:6,

3284:3, 3284:7, 3284:14

SEC's [2] - 3228:20, 3230:21

second [26] - 3154:16, 3155:7, 3161:1,

3176:5, 3185:19, 3186:18, 3194:9,

3195:1, 3195:3, 3195:21, 3202:7,

3202:8, 3212:22, 3221:1, 3234:16,

3258:20, 3271:9, 3287:13, 3331:7,

3358:10, 3367:4, 3367:6, 3372:11,

3388:19, 3409:24

secret [1] - 3315:18

section [5] - 3199:14, 3239:10,

3239:15, 3263:1

sectors [2] - 3248:7, 3249:25

securities [12] - 3160:14, 3167:10,

3179:25, 3182:17, 3182:24, 3183:3,

3183:5, 3184:17, 3195:5, 3196:16,

3196:20, 3238:22

Securities [3] - 3236:15, 3237:6,

3327:10

Security [1] - 3294:17

see [56] - 3154:24, 3155:10, 3171:8,

3173:4, 3180:6, 3185:22, 3194:21,

3203:1, 3206:1, 3213:7, 3231:7,

3251:22, 3254:23, 3257:18, 3261:3,

3272:1, 3283:1, 3299:16, 3299:17,

3299:25, 3300:4, 3300:6, 3301:8,

3301:22, 3311:6, 3313:7, 3313:8,

3318:9, 3319:5, 3335:5, 3335:10,

3335:13, 3335:18, 3337:18, 3341:23,

3346:19, 3351:10, 3353:14, 3353:16,

3362:17, 3362:20, 3364:18, 3370:19,

3380:14, 3381:24, 3388:20, 3388:21,

3394:13, 3396:10, 3396:21, 3397:8,

3410:1, 3410:13, 3419:10, 3420:10

seeing [3] - 3173:16, 3198:2, 3270:14

seeking [3] - 3237:13, 3237:18,

3237:19

seem [1] - 3415:24

seize [1] - 3321:24

seized [14] - 3294:4, 3294:10, 3294:12,

3315:13, 3315:23, 3320:16, 3320:18,

3326:20, 3326:25, 3327:8, 3327:14,

3337:16, 3337:24, 3340:5

selection [1] - 3391:25

self [2] - 3152:11, 3300:15

self-incrimination [1] - 3300:15

self-regulating [1] - 3152:11

sell [12] - 3147:6, 3149:20, 3154:4,

3155:8, 3158:6, 3158:11, 3163:19,

3163:21, 3165:9, 3277:13, 3290:11,

3341:1

selling [4] - 3149:15, 3151:4, 3288:22,

3289:5

send [5] - 3209:22, 3292:18, 3319:9,

3347:3, 3364:16

sending [2] - 3319:11, 3370:8

senior [1] - 3258:5

sense [2] - 3237:9, 3365:18

sent [10] - 3173:25, 3190:15, 3191:16,

3194:18, 3195:8, 3227:1, 3293:4,

3319:20, 3330:20, 3338:23

sentence [1] - 3418:18

separate [3] - 3172:25, 3210:13,

3390:17

separated [2] - 3405:8, 3406:7

sequestered [2] - 3175:21, 3420:23

series [1] - 3163:1

serious [3] - 3228:22, 3229:9, 3230:23

seriously [1] - 3176:23

seriousness [2] - 3228:11, 3228:20

servant [1] - 3271:18

Service [1] - 3338:7

service [5] - 3169:18, 3292:25,

3339:13, 3342:25, 3343:3

services [4] - 3165:2, 3169:15, 3271:5,

3340:15

set [12] - 3154:3, 3164:25, 3165:16,

3176:11, 3186:7, 3208:15, 3214:11,

3214:16, 3219:24, 3364:6, 3364:10,

3364:13

setting [2] - 3165:18, 3175:10

settled [1] - 3153:21

settlement [2] - 3214:3, 3214:5

seven [1] - 3363:10

seventh [1] - 3251:3

seventh-month [1] - 3251:3

several [10] - 3165:12, 3184:8,

3187:18, 3206:10, 3261:22, 3341:17,

3367:15, 3373:7, 3391:6, 3391:7

SGC [1] - 3155:8

shades [1] - 3419:8

shake [1] - 3390:24

shall [1] - 3295:21

shape [3] - 3316:3, 3361:24, 3366:23

share [2] - 3241:5, 3306:9

shared [15] - 3153:6, 3162:24,

3177:14, 3204:10, 3235:4, 3263:1,

3263:12, 3267:16, 3268:18, 3274:25,

3275:14, 3278:16, 3284:14, 3288:6,

3303:11

shareholder [4] - 3198:13, 3202:21,

3203:1, 3260:7

sharing [1] - 3400:7

sheet [4] - 3198:14, 3200:22, 3255:14,

3276:20

shell [14] - 3214:11, 3214:15, 3214:16,

3251:16, 3353:23, 3353:24, 3354:1,

3354:6, 3354:8, 3354:15, 3354:17,

3354:19, 3354:25, 3355:20

Shepherd [3] - 3408:17, 3408:21,

3409:4

shift [2] - 3372:23, 3409:20

shit [1] - 3230:23

shock [4] - 3256:14, 3257:8, 3260:4,

3260:15

shocked [2] - 3260:5, 3262:8

shore [3] - 3388:1, 3388:3, 3388:4

short [2] - 3416:18, 3419:23

shortly [3] - 3149:15, 3286:16,

3332:16

shoulder [1] - 3268:8

show [23] - 3154:22, 3215:19, 3224:2,

3235:23, 3246:18, 3257:4, 3257:5,

3262:7, 3268:9, 3274:18, 3284:22,

3291:6, 3318:2, 3318:14, 3319:2,

3323:16, 3335:8, 3335:24, 3336:15,

3349:18, 3367:23, 3373:18

showed [15] - 3172:18, 3172:21,

3172:23, 3243:20, 3244:13, 3254:3,

3254:5, 3256:4, 3258:5, 3260:3,

3266:5, 3283:24, 3314:19, 3332:12,

3341:10

showing [12] - 3155:1, 3206:15,

3215:23, 3236:2, 3251:9, 3253:22,

3253:25, 3254:8, 3265:8, 3265:17,

3290:10, 3390:5

shown [11] - 3194:6, 3206:23,

3244:14, 3249:17, 3249:23, 3253:11,

3256:24, 3259:6, 3317:4, 3367:15

shows [8] - 3179:21, 3180:9, 3208:14,

3314:14, 3364:17, 3367:4, 3369:8,

3381:4

shut [8] - 3171:24, 3188:12, 3189:7,

3189:12, 3189:18, 3189:21, 3189:24,

3190:1

shutdown [3] - 3187:23, 3188:2,

3188:11

shutting [2] - 3188:15, 3188:23

SIBL [7] - 3171:6, 3186:2, 3186:21,

3194:5, 3194:21, 3215:21, 3237:17

SIBL's [1] - 3264:23

side [7] - 3185:24, 3223:12, 3250:24,Johnny C. Sanchez, RMR, CRR - [email protected]

3452

3253:3, 3268:6, 3421:9, 3421:17

sidebar [1] - 3410:22

sides [1] - 3421:8

siding [1] - 3421:17

signatory [1] - 3322:16

signature [1] - 3386:22

signed [2] - 3324:14, 3325:23

significant [1] - 3196:11

significantly [1] - 3166:7

silently [1] - 3155:11

similar [4] - 3161:4, 3186:8, 3225:18,

3316:4

similarly [1] - 3248:22

simple [1] - 3299:8

single [1] - 3237:14

sink [1] - 3200:6

Siragna [1] - 3242:15

sit [2] - 3397:6, 3421:4

site [1] - 3172:8

sites [1] - 3172:5

sitting [8] - 3193:14, 3219:6, 3262:4,

3388:20, 3388:21, 3388:23, 3411:2,

3411:23

situation [8] - 3179:22, 3183:8,

3184:5, 3195:12, 3195:15, 3197:8,

3197:15, 3421:22

six [10] - 3147:8, 3171:18, 3174:21,

3250:10, 3251:3, 3293:1, 3343:10,

3351:21, 3362:3, 3363:10

six-feet [1] - 3351:21

six-month [1] - 3250:10

sizzle [1] - 3164:17

Sjoblom [20] - 3233:2, 3233:3,

3233:16, 3233:25, 3234:9, 3234:13,

3234:22, 3235:4, 3235:17, 3235:23,

3244:2, 3244:16, 3278:7, 3278:10,

3278:15, 3279:12, 3279:14, 3280:2,

3280:18, 3281:23

skim [1] - 3295:6

skimming [1] - 3316:2

skirt [2] - 3299:17, 3300:21

skits [1] - 3164:17

slow [1] - 3198:16

slower [2] - 3350:15, 3350:18

slowing [1] - 3174:13

slush [1] - 3176:21

small [2] - 3294:17, 3321:13

smaller [2] - 3217:3, 3219:1

smart [2] - 3241:3, 3241:5

snack [1] - 3420:24

so-called [5] - 3182:25, 3239:10,

3254:6, 3254:17, 3395:1

so.. [1] - 3151:16

soap [2] - 3406:21, 3413:7

sobbed [1] - 3268:2

sobbing [1] - 3268:5

sobs [1] - 3262:6

SocGen [2] - 3322:20, 3322:23

Social [1] - 3294:17

sold [5] - 3183:5, 3184:23, 3195:5,

3278:1, 3280:12

solicitor [2] - 3378:6, 3378:8

solve [1] - 3198:6

some-odd [1] - 3326:22

someone [4] - 3179:13, 3179:19,

3209:2, 3300:22

sometime [3] - 3312:2, 3414:11,

3414:22

sometimes [4] - 3302:22, 3373:21,

3394:24, 3401:7

somewhat [1] - 3218:23

somewhere [8] - 3251:17, 3256:18,

3318:5, 3318:6, 3345:21, 3349:23,

3353:12, 3397:5

son [5] - 3177:17, 3177:22, 3177:23,

3178:7, 3404:8

sons [3] - 3302:15, 3302:17, 3302:20

soon [5] - 3286:2, 3369:15, 3395:19,

3415:3, 3415:13

sooner [1] - 3420:6

sorry [32] - 3153:1, 3168:18, 3183:2,

3185:19, 3194:2, 3202:7, 3204:22,

3213:14, 3218:8, 3221:4, 3222:20,

3226:20, 3228:14, 3237:11, 3241:11,

3245:23, 3249:22, 3263:15, 3267:13,

3268:23, 3275:8, 3279:11, 3285:14,

3290:2, 3324:7, 3352:5, 3352:6,

3354:13, 3362:13, 3400:14, 3414:17,

3414:20

sort [4] - 3152:20, 3166:8, 3173:3,

3418:16

sound [1] - 3202:14

source [6] - 3355:5, 3372:4, 3396:20,

3397:3, 3397:7, 3398:2

sources [3] - 3153:2, 3153:3, 3398:2

South [1] - 3160:11

south [1] - 3316:3

SOUTHERN [1] - 3143:1

sowed [1] - 3258:6

space [1] - 3173:14

spacing [1] - 3319:14

speakerphone [1] - 3245:20

speakers [1] - 3164:18

speaking [10] - 3152:4, 3152:16,

3197:4, 3228:19, 3246:16, 3267:1,

3284:24, 3287:12, 3288:20, 3289:2

special [1] - 3164:17

specific [6] - 3160:14, 3188:24,

3200:14, 3203:14, 3210:8, 3279:23

specifically [11] - 3156:21, 3157:23,

3159:25, 3181:3, 3203:16, 3213:16,

3231:9, 3235:20, 3237:9, 3260:17,

3266:22

specified [2] - 3237:4, 3237:7

speculate [1] - 3311:10

spend [2] - 3303:18, 3305:15

spending [1] - 3182:3

spent [13] - 3214:24, 3289:25,

3296:25, 3297:2, 3303:22, 3304:9,

3304:11, 3305:17, 3305:23, 3365:22,

3371:2, 3371:3, 3371:24

spite [3] - 3311:19, 3318:20, 3330:15

split [5] - 3224:19, 3293:2, 3345:8,

3346:1, 3419:12

spreadsheet [5] - 3206:16, 3206:20,

3222:13, 3223:12, 3285:23

St [5] - 3176:1, 3226:13, 3227:4,

3231:14, 3269:21

st [1] - 3228:18

Stack [1] - 3178:17

staff [3] - 3165:2, 3175:21, 3175:23

stage [1] - 3228:13

stall [1] - 3198:15

stand [8] - 3186:15, 3222:7, 3300:14,

3303:14, 3303:15, 3309:17, 3390:23,

3400:20

standard [1] - 3351:5

Standard [1] - 3370:3

standards [2] - 3263:17, 3263:23

standing [3] - 3388:1, 3388:3, 3388:4

standpoint [1] - 3160:19

STANFORD [1] - 3143:6

Stanford [398] - 3146:16, 3147:9,

3147:12, 3147:15, 3147:19, 3148:3,

3148:14, 3148:18, 3149:11, 3149:21,

3149:22, 3150:4, 3150:5, 3150:20,

3150:22, 3151:1, 3151:14, 3151:15,

3151:17, 3151:24, 3153:7, 3153:9,

3153:16, 3153:23, 3154:2, 3154:6,

3156:19, 3157:5, 3157:13, 3157:20,

3158:12, 3158:16, 3159:11, 3159:14,

3159:18, 3159:23, 3160:6, 3160:22,

3160:25, 3161:12, 3161:16, 3162:13,

3162:15, 3162:17, 3162:22, 3163:3,

3163:14, 3164:1, 3164:21, 3165:17,

3166:20, 3167:12, 3167:19, 3168:6,

3168:8, 3168:16, 3168:25, 3169:5,

3169:9, 3169:25, 3170:4, 3170:19,

3170:21, 3171:13, 3171:19, 3172:15,

3173:22, 3174:5, 3174:7, 3174:11,

3174:17, 3175:7, 3176:10, 3176:13,

3177:8, 3177:12, 3177:17, 3177:23,

3178:16, 3179:8, 3179:12, 3179:19,

3180:12, 3180:19, 3180:22, 3180:23,

3181:4, 3182:3, 3182:18, 3183:8,

3184:4, 3184:10, 3184:14, 3184:18,

3185:7, 3186:8, 3187:16, 3187:22,

3187:24, 3188:7, 3188:14, 3188:17,

3188:22, 3189:1, 3189:6, 3189:22,

3189:24, 3191:12, 3191:16, 3192:14,

3193:3, 3193:9, 3193:13, 3194:14,

3195:9, 3195:11, 3196:23, 3196:24,

3197:4, 3198:6, 3198:9, 3198:12,

3199:9, 3199:16, 3200:2, 3201:19,

3201:21, 3202:13, 3203:4, 3203:17,

3203:25, 3204:10, 3205:8, 3205:15,

3206:10, 3207:9, 3207:13, 3208:3,

3208:5, 3209:19, 3209:22, 3210:2,

3211:3, 3211:25, 3212:1, 3212:6,

3212:7, 3212:12, 3212:13, 3212:17,

3213:9, 3213:12, 3213:17, 3213:20,

3213:24, 3214:1, 3214:3, 3214:8,

3214:15, 3215:6, 3215:22, 3216:2,

3216:10, 3216:12, 3216:13, 3217:18,

3217:21, 3221:14, 3224:3, 3225:4,

3225:7, 3225:21, 3226:3, 3226:14,


3453

3231:1, 3231:8, 3231:11, 3231:18,

3231:21, 3232:2, 3232:15, 3232:22,

3232:25, 3233:7, 3233:8, 3233:13,

3233:21, 3235:5, 3235:19, 3236:25,

3238:8, 3238:12, 3240:1, 3240:2,

3240:12, 3240:15, 3240:16, 3240:19,

3241:13, 3241:23, 3242:1, 3242:7,

3242:11, 3242:20, 3242:25, 3243:23,

3244:3, 3244:4, 3244:8, 3244:14,

3244:17, 3244:23, 3245:4, 3245:6,

3245:14, 3245:23, 3246:5, 3246:8,

3246:12, 3246:18, 3247:3, 3247:5,

3248:11, 3248:25, 3249:8, 3249:17,

3249:22, 3250:6, 3251:16, 3251:17,

3253:4, 3255:15, 3258:6, 3259:19,

3261:6, 3262:18, 3262:21, 3263:3,

3263:7, 3263:11, 3263:21, 3264:2,

3264:9, 3265:4, 3265:10, 3265:13,

3265:18, 3265:24, 3266:5, 3266:14,

3267:1, 3267:8, 3267:20, 3268:9,

3269:20, 3269:23, 3270:22, 3270:23,

3270:24, 3271:2, 3271:3, 3271:6,

3271:19, 3272:14, 3273:17, 3278:20,

3279:16, 3280:4, 3283:18, 3284:10,

3284:15, 3284:24, 3285:2, 3287:12,

3288:2, 3288:12, 3288:15, 3288:17,

3288:21, 3289:3, 3289:16, 3289:20,

3289:22, 3290:5, 3290:15, 3291:15,

3292:19, 3293:4, 3293:5, 3293:7,

3293:13, 3293:15, 3294:19, 3294:21,

3295:4, 3295:10, 3295:18, 3302:18,

3305:20, 3305:24, 3308:1, 3312:22,

3313:13, 3313:25, 3315:3, 3316:5,

3317:24, 3318:3, 3318:16, 3319:20,

3322:1, 3327:12, 3327:15, 3327:18,

3330:9, 3330:16, 3332:13, 3334:6,

3336:24, 3338:25, 3339:5, 3339:7,

3341:4, 3341:10, 3341:12, 3342:24,

3343:13, 3345:13, 3346:16, 3347:18,

3348:14, 3348:21, 3348:25, 3349:7,

3349:15, 3352:2, 3353:8, 3353:13,

3353:16, 3353:21, 3355:7, 3355:8,

3355:14, 3356:16, 3356:19, 3356:20,

3358:1, 3358:7, 3358:9, 3361:16,

3363:16, 3364:7, 3364:10, 3365:20,

3367:11, 3367:13, 3367:18, 3369:21,

3370:9, 3371:13, 3372:1, 3372:3,

3374:11, 3375:6, 3375:13, 3375:17,

3375:21, 3376:6, 3376:8, 3376:12,

3376:18, 3376:22, 3378:15, 3378:23,

3379:8, 3379:11, 3379:20, 3379:23,

3380:2, 3381:21, 3381:23, 3394:19,

3394:21, 3398:3, 3401:3, 3415:6,

3417:16, 3417:18, 3418:3

stanford [1] - 3214:21

Stanford's [17] - 3151:7, 3175:20,

3200:20, 3212:18, 3231:14, 3269:10,

3270:5, 3291:3, 3348:12, 3349:13,

3356:13, 3368:7, 3375:20, 3382:19,

3382:25, 3383:20, 3410:21

Stanford-owned [1] - 3271:6

Star [2] - 3188:4, 3188:8

Star/Sun [1] - 3187:19

start [12] - 3147:11, 3148:15, 3148:21,

3149:15, 3190:9, 3194:1, 3342:4,

3342:6, 3344:12, 3403:7, 3405:5,

3420:12

start-up [1] - 3147:11

started [16] - 3151:4, 3165:20,

3165:21, 3230:19, 3286:16, 3290:16,

3306:13, 3307:5, 3307:17, 3343:14,

3344:6, 3361:8, 3370:20, 3374:3,

3382:10, 3405:25

starting [5] - 3196:6, 3197:10, 3198:4,

3202:1, 3224:10

state [9] - 3168:21, 3168:22, 3213:23,

3219:2, 3219:4, 3241:12, 3272:12,

3272:15, 3272:17

statement [13] - 3163:18, 3274:18,

3276:20, 3355:24, 3362:23, 3364:17,

3364:18, 3364:22, 3369:9, 3380:19,

3380:21, 3382:15, 3411:15

statements [16] - 3159:7, 3264:15,

3275:1, 3275:15, 3276:8, 3276:10,

3276:13, 3276:18, 3276:19, 3276:24,

3276:25, 3277:6, 3277:8, 3277:25,

3279:17, 3288:24

STATES [3] - 3143:1, 3143:4, 3143:10

States [16] - 3147:17, 3148:4, 3149:1,

3149:16, 3149:24, 3151:5, 3233:4,

3241:25, 3278:4, 3280:15, 3280:22,

3281:6, 3306:14, 3352:12, 3363:11,

3378:12

states [1] - 3223:19

stationed [4] - 3170:13, 3172:9,

3173:8, 3175:23

status [1] - 3184:18

stay [2] - 3419:1, 3423:14

stayed [1] - 3366:23

staying [1] - 3232:11

steady [2] - 3161:10, 3351:9

steal [8] - 3301:20, 3324:21, 3325:3,

3325:9, 3342:11, 3342:14, 3342:19,

3371:21

stealing [3] - 3316:17, 3325:5, 3325:6

stellmach [5] - 3204:23, 3305:8,

3329:4, 3335:22, 3353:11

Stellmach [7] - 3143:16, 3192:20,

3222:10, 3323:23, 3374:7, 3387:5,

3395:15

STELLMACH [312] - 3146:6, 3146:9,

3147:1, 3151:23, 3152:22, 3153:18,

3153:22, 3154:12, 3154:18, 3154:20,

3154:25, 3155:3, 3155:18, 3155:23,

3156:1, 3156:7, 3156:17, 3157:12,

3158:4, 3161:19, 3161:23, 3166:14,

3167:1, 3167:3, 3167:24, 3168:5,

3168:12, 3169:4, 3170:16, 3171:17,

3171:25, 3172:2, 3172:3, 3175:5,

3176:8, 3176:9, 3177:6, 3178:6,

3179:3, 3179:7, 3179:17, 3180:6,

3180:8, 3180:10, 3180:11, 3181:7,

3182:7, 3182:9, 3182:11, 3182:13,

3183:20, 3183:25, 3184:3, 3185:2,

3185:5, 3185:16, 3185:21, 3187:4,

3187:7, 3187:12, 3189:4, 3190:2,

3190:5, 3190:7, 3190:11, 3190:13,

3190:19, 3190:22, 3191:11, 3191:14,

3192:9, 3192:12, 3192:21, 3192:25,

3193:2, 3193:8, 3195:20, 3195:22,

3196:19, 3199:1, 3200:12, 3201:5,

3201:18, 3202:4, 3204:9, 3205:6,

3205:18, 3206:6, 3206:7, 3206:17,

3206:19, 3207:12, 3209:7, 3209:10,

3209:13, 3209:14, 3210:22, 3211:15,

3212:21, 3213:8, 3214:7, 3214:14,

3215:18, 3216:21, 3217:9, 3217:10,

3219:7, 3219:16, 3220:24, 3221:3,

3221:5, 3221:9, 3222:6, 3222:12,

3222:16, 3222:20, 3222:22, 3223:11,

3223:14, 3226:22, 3227:13, 3228:2,

3228:6, 3228:9, 3228:14, 3228:16,

3229:2, 3229:8, 3229:16, 3229:19,

3229:23, 3230:7, 3230:14, 3230:18,

3230:20, 3231:25, 3232:1, 3234:4,

3234:8, 3234:12, 3234:22, 3234:25,

3235:6, 3235:16, 3236:2, 3236:4,

3236:7, 3236:9, 3236:11, 3236:12,

3236:18, 3236:24, 3237:8, 3237:12,

3238:18, 3239:2, 3239:19, 3239:22,

3240:18, 3243:22, 3244:7, 3244:24,

3245:13, 3245:25, 3247:21, 3247:24,

3249:13, 3249:16, 3249:21, 3250:12,

3250:17, 3252:14, 3252:16, 3254:24,

3254:25, 3256:1, 3256:3, 3257:3,

3257:14, 3257:24, 3258:3, 3258:14,

3258:18, 3258:25, 3260:10, 3260:14,

3260:22, 3260:25, 3261:1, 3261:5,

3261:16, 3262:2, 3266:13, 3268:14,

3268:22, 3268:24, 3269:2, 3269:12,

3269:18, 3270:4, 3270:9, 3270:17,

3270:20, 3271:7, 3271:13, 3271:16,

3271:20, 3271:23, 3272:3, 3272:8,

3272:12, 3272:19, 3272:21, 3272:23,

3273:1, 3273:3, 3273:7, 3273:12,

3273:19, 3273:23, 3274:11, 3274:22,

3275:7, 3275:10, 3275:12, 3275:23,

3276:7, 3277:19, 3278:6, 3279:10,

3279:25, 3281:10, 3282:7, 3285:22,

3286:8, 3286:11, 3286:16, 3286:23,

3287:10, 3287:23, 3289:11, 3289:14,

3290:13, 3290:14, 3291:6, 3291:10,

3291:17, 3291:19, 3291:22, 3292:2,

3292:8, 3292:9, 3295:19, 3296:15,

3297:14, 3297:23, 3298:2, 3298:4,

3298:7, 3298:12, 3298:23, 3299:9,

3299:14, 3299:24, 3305:10, 3308:14,

3308:17, 3311:3, 3311:9, 3315:19,

3322:14, 3322:19, 3323:4, 3323:9,

3323:13, 3323:17, 3323:20, 3323:24,

3328:25, 3329:12, 3355:21, 3362:9,

3362:13, 3368:12, 3373:25, 3389:22,

3390:2, 3399:2, 3399:7, 3399:19,

3406:6, 3406:18, 3406:21, 3406:25,

3407:9, 3407:11, 3407:15, 3407:17,

3408:8, 3408:10, 3408:19, 3408:22,

3410:8, 3411:1, 3411:25, 3413:11,

3413:19, 3414:7, 3415:15, 3416:3,

3416:8, 3423:19


3454

STELLMACH........... [1] - 3145:4

stenography [1] - 3144:14

step [5] - 3161:1, 3208:13, 3208:24,

3416:14, 3420:6

stepped [1] - 3327:11

stepping [1] - 3389:15

steps [5] - 3239:3, 3268:16, 3268:18,

3278:8, 3279:22

sticking [1] - 3175:10

still [21] - 3181:11, 3245:4, 3245:6,

3249:17, 3263:5, 3280:12, 3281:19,

3287:12, 3293:11, 3300:3, 3310:9,

3320:25, 3333:1, 3371:17, 3395:12,

3397:18, 3400:23, 3405:7, 3417:16,

3417:23, 3421:25

Stinson [19] - 3233:19, 3244:1,

3267:22, 3268:18, 3268:23, 3269:3,

3269:13, 3269:19, 3270:1, 3270:21,

3273:1, 3274:23, 3276:12, 3277:20,

3277:22, 3277:23, 3278:16, 3278:17,

3280:1

stinson [2] - 3267:23, 3272:5

stocks [1] - 3150:8

stole [8] - 3301:18, 3324:20, 3325:11,

3342:14, 3358:23, 3358:24, 3359:1

stood [1] - 3262:23

stop [12] - 3176:5, 3200:24, 3223:23,

3295:21, 3334:20, 3375:15, 3382:7,

3382:18, 3382:20, 3390:22, 3409:24

stopped [2] - 3178:21, 3179:9

store [5] - 3392:9, 3392:22, 3393:17,

3393:25, 3394:22

stored [6] - 3390:11, 3393:2, 3393:22,

3393:23, 3395:5, 3396:19

storing [1] - 3392:6

story [5] - 3304:24, 3306:4, 3310:16,

3310:17, 3316:22

straight [1] - 3393:4

strain [1] - 3188:19

strategy [2] - 3167:8, 3167:15

stream [1] - 3198:2

Street [1] - 3143:22

strengthen [1] - 3198:14

stress [1] - 3197:13

stretch [1] - 3295:20

strictly [1] - 3211:11

strips [1] - 3209:2

strong [3] - 3181:11, 3202:14, 3202:17

structure [1] - 3158:14

stuck [1] - 3230:3

studio [3] - 3341:19, 3341:21, 3341:22

stuff [1] - 3393:7

styled [3] - 3259:11, 3324:8, 3362:24

Suarez [1] - 3289:25

subject [7] - 3154:21, 3158:20,

3173:25, 3194:21, 3210:3, 3330:25,

3356:7

subjects [1] - 3288:5

submit [3] - 3229:21, 3235:2, 3415:21

submitted [1] - 3349:6

subpoena [8] - 3231:19, 3231:20,

3236:14, 3236:16, 3237:5, 3237:22,

3335:17, 3352:12

subpoenaed [4] - 3230:25, 3237:24,

3303:1

subpoenas [2] - 3232:20, 3235:23

subsequently [1] - 3293:16

successful [1] - 3162:17

sudden [1] - 3312:17

sufficient [1] - 3229:25

suggested [1] - 3355:5

suggestion [2] - 3273:6, 3280:17

suggestions [2] - 3278:8, 3279:4

suit [1] - 3270:8

summary [1] - 3302:21

summary-type [1] - 3302:21

summer [5] - 3177:11, 3182:21,

3197:11, 3198:5, 3215:5

sums [1] - 3374:17

Sun [2] - 3188:4, 3188:9

superimposed [1] - 3319:19

Superstars [1] - 3165:13

support [9] - 3188:4, 3202:16,

3205:11, 3208:8, 3224:23, 3226:4,

3266:17, 3294:15, 3413:13

supportive [1] - 3280:6

suppose [1] - 3265:18

supposed [3] - 3312:9, 3337:23,

3415:21

sustain [5] - 3168:10, 3179:6,

3183:18, 3269:17, 3407:13

sustained [27] - 3151:22, 3157:11,

3158:3, 3177:5, 3178:24, 3179:16,

3189:3, 3204:8, 3207:11, 3209:3,

3213:6, 3213:18, 3214:13, 3260:11,

3260:21, 3266:12, 3275:20, 3303:4,

3306:2, 3311:12, 3316:7, 3325:17,

3353:1, 3355:23, 3383:8, 3406:8,

3406:20

swear [1] - 3423:6

Swiss [1] - 3363:22

Switzerland [1] - 3176:21

system [9] - 3201:13, 3201:15, 3286:1,

3378:14, 3391:19, 3391:20, 3391:21,

3393:2, 3398:3

systems [1] - 3200:19

T

table [5] - 3235:9, 3236:1, 3268:4,

3268:6, 3268:7

talks [1] - 3381:14

tall [1] - 3351:21

Tamarin [1] - 3409:13

tape [1] - 3193:5

target [3] - 3207:8, 3207:21, 3207:24

targets [2] - 3165:16, 3165:18

TARP [2] - 3411:14, 3412:20

Tarrie [3] - 3194:2, 3194:22

tax [15] - 3212:18, 3226:19, 3227:8,

3292:23, 3337:7, 3337:9, 3337:11,

3337:14, 3337:18, 3337:21, 3338:1,

3338:8, 3338:13, 3338:17, 3359:3

Tax [1] - 3337:1

taxi [1] - 3211:11

TCP [1] - 3164:12

TD [2] - 3186:2, 3191:5

teaching [4] - 3401:17, 3401:18,

3402:15, 3402:19

team [2] - 3158:21, 3217:23

teams [5] - 3165:9, 3165:12, 3165:13,

3165:14, 3165:16

tears [3] - 3262:6, 3265:15, 3265:19

technical [1] - 3192:13

technically [2] - 3161:20, 3346:21

technology [2] - 3251:10, 3252:19

telephone [1] - 3233:24

telephonics [1] - 3347:5

tend [2] - 3316:16, 3336:23

Tennessee [1] - 3172:14

term [8] - 3149:25, 3178:1, 3178:2,

3178:22, 3179:1, 3179:2, 3199:12,

3252:13

termination [1] - 3189:14

terms [22] - 3146:19, 3148:17, 3150:4,

3151:9, 3157:1, 3159:8, 3178:1,

3178:15, 3183:2, 3195:3, 3199:9,

3199:20, 3207:16, 3216:1, 3220:9,

3237:14, 3239:23, 3262:12, 3290:10,

3346:20, 3354:9, 3373:16

territorial [1] - 3210:19

testified [30] - 3177:15, 3177:16,

3204:14, 3205:8, 3206:9, 3220:3,

3227:14, 3229:24, 3238:9, 3253:19,

3262:8, 3281:14, 3282:21, 3289:15,

3290:7, 3301:5, 3305:12, 3312:3,

3314:22, 3322:6, 3328:18, 3329:2,

3329:5, 3336:10, 3344:4, 3355:19,

3358:13, 3370:3, 3387:4, 3401:2

testify [21] - 3231:19, 3232:3, 3232:16,

3238:2, 3238:5, 3238:20, 3239:4,

3239:8, 3281:16, 3281:19, 3281:22,

3282:11, 3282:16, 3282:19, 3284:2,

3284:17, 3310:11, 3328:23, 3329:1,

3386:3, 3421:22

testifying [4] - 3207:1, 3220:17,

3320:4, 3413:4

testimony [36] - 3207:9, 3220:21,

3235:24, 3237:19, 3239:17, 3243:17,

3250:21, 3252:23, 3253:20, 3278:21,

3279:5, 3281:12, 3283:13, 3283:25,

3295:11, 3299:10, 3303:19, 3305:16,

3307:15, 3309:10, 3313:9, 3325:2,

3328:13, 3329:1, 3329:10, 3330:15,

3333:23, 3335:12, 3342:16, 3355:22,

3380:3, 3381:11, 3381:12, 3410:1,

3412:14, 3420:12

TEXAS [1] - 3143:1

Texas [10] - 3143:4, 3143:15, 3143:23,

3144:4, 3144:7, 3144:12, 3170:14,

3226:24, 3243:16, 3376:25

text [14] - 3184:12, 3185:16, 3185:18,

3191:15, 3291:23, 3293:4, 3293:7,

3293:8, 3293:9, 3293:22, 3318:12,

3330:19, 3330:20, 3332:16

texted [2] - 3184:14, 3317:24

texting [1] - 3195:13Johnny C. Sanchez, RMR, CRR - [email protected]

3455

texts [2] - 3285:1

thankless [1] - 3176:15

THE [567] - 3143:10, 3143:13, 3143:20,

3144:2, 3146:2, 3146:25, 3151:22,

3152:20, 3153:15, 3153:20, 3154:7,

3154:9, 3154:11, 3154:17, 3154:19,

3154:23, 3155:2, 3155:16, 3155:21,

3155:24, 3156:4, 3156:14, 3156:15,

3156:16, 3157:9, 3157:11, 3158:3,

3161:20, 3161:22, 3166:12, 3166:13,

3167:2, 3167:25, 3168:10, 3168:20,

3168:25, 3170:13, 3170:14, 3170:15,

3171:10, 3171:12, 3171:14, 3171:15,

3171:16, 3171:24, 3172:1, 3174:18,

3174:20, 3174:21, 3174:23, 3174:24,

3174:25, 3175:1, 3175:3, 3175:4,

3176:5, 3177:2, 3177:3, 3177:5,

3178:1, 3178:3, 3178:5, 3178:24,

3179:2, 3179:5, 3179:16, 3181:2,

3181:4, 3181:6, 3182:6, 3182:8,

3182:10, 3182:12, 3183:17, 3184:1,

3187:6, 3187:9, 3189:3, 3190:4,

3190:21, 3193:6, 3196:15, 3196:16,

3196:18, 3198:18, 3198:20, 3198:22,

3198:24, 3200:9, 3200:10, 3200:15,

3200:20, 3200:24, 3201:1, 3201:2,

3201:3, 3201:4, 3201:7, 3201:12,

3201:15, 3201:16, 3201:17, 3201:25,

3202:3, 3204:6, 3204:8, 3204:18,

3204:21, 3204:22, 3205:5, 3205:20,

3206:4, 3207:11, 3208:16, 3208:23,

3209:9, 3209:12, 3210:10, 3210:12,

3210:13, 3210:14, 3210:15, 3210:17,

3210:18, 3210:20, 3210:21, 3211:10,

3211:12, 3211:14, 3212:22, 3213:1,

3213:3, 3213:5, 3213:18, 3213:21,

3213:22, 3214:1, 3214:13, 3215:15,

3216:16, 3216:19, 3216:20, 3217:7,

3219:6, 3219:8, 3219:10, 3219:11,

3219:12, 3219:14, 3220:18, 3220:22,

3220:23, 3221:1, 3221:4, 3221:7,

3222:2, 3222:5, 3222:19, 3222:21,

3226:15, 3226:18, 3226:20, 3227:4,

3227:7, 3227:8, 3227:10, 3227:12,

3227:21, 3227:25, 3228:1, 3228:7,

3228:13, 3228:15, 3228:24, 3228:25,

3229:1, 3229:6, 3229:14, 3229:18,

3230:1, 3230:4, 3230:13, 3230:16,

3230:19, 3231:24, 3234:2, 3234:5,

3234:11, 3234:16, 3234:18, 3234:20,

3234:21, 3234:24, 3235:1, 3235:12,

3235:15, 3236:6, 3236:8, 3236:10,

3236:15, 3236:19, 3236:20, 3236:21,

3238:10, 3238:11, 3238:13, 3238:14,

3238:15, 3238:16, 3238:25, 3239:1,

3239:14, 3239:15, 3239:17, 3239:20,

3240:14, 3240:15, 3243:21, 3243:23,

3244:20, 3244:22, 3245:12, 3245:22,

3245:23, 3247:15, 3247:16, 3247:17,

3247:19, 3247:20, 3248:10, 3248:13,

3248:14, 3248:15, 3248:16, 3248:18,

3248:19, 3248:21, 3248:25, 3249:2,

3249:3, 3249:5, 3249:6, 3249:7,

3249:8, 3249:10, 3249:11, 3249:15,

3249:19, 3249:20, 3250:9, 3250:10,

3250:13, 3250:15, 3252:15, 3254:7,

3254:9, 3254:10, 3254:11, 3254:13,

3254:16, 3254:19, 3254:20, 3254:21,

3254:22, 3254:23, 3256:11, 3256:13,

3256:16, 3256:19, 3256:20, 3256:21,

3256:22, 3257:1, 3257:8, 3257:9,

3257:10, 3257:11, 3257:12, 3257:15,

3257:22, 3258:1, 3258:16, 3258:17,

3258:20, 3258:23, 3258:24, 3260:11,

3260:21, 3260:24, 3261:3, 3261:9,

3261:11, 3261:25, 3262:1, 3266:12,

3268:11, 3268:12, 3268:13, 3269:1,

3269:17, 3270:3, 3270:7, 3270:16,

3270:18, 3271:9, 3271:14, 3271:17,

3271:21, 3271:25, 3272:7, 3272:10,

3272:17, 3272:20, 3272:22, 3272:24,

3273:2, 3273:5, 3273:10, 3273:16,

3273:21, 3274:1, 3274:6, 3274:10,

3274:13, 3275:5, 3275:8, 3275:11,

3275:20, 3275:24, 3277:18, 3278:3,

3278:5, 3278:14, 3278:15, 3278:18,

3278:25, 3279:1, 3279:2, 3279:3,

3279:7, 3279:9, 3279:18, 3279:21,

3280:21, 3280:25, 3281:3, 3281:4,

3281:5, 3281:7, 3281:8, 3281:9,

3282:2, 3282:3, 3282:4, 3285:14,

3285:16, 3285:17, 3285:18, 3286:7,

3286:13, 3286:21, 3287:6, 3287:8,

3287:9, 3287:20, 3287:21, 3291:18,

3291:21, 3292:1, 3292:7, 3295:20,

3295:23, 3296:1, 3296:20, 3297:15,

3297:18, 3297:25, 3298:3, 3298:6,

3298:11, 3298:14, 3299:4, 3299:12,

3299:15, 3299:25, 3300:16, 3300:25,

3303:4, 3304:16, 3304:18, 3304:20,

3304:21, 3305:2, 3305:3, 3306:2,

3307:1, 3307:2, 3308:13, 3308:16,

3308:21, 3308:25, 3309:3, 3309:4,

3309:13, 3311:4, 3311:6, 3311:12,

3315:23, 3316:7, 3316:10, 3321:4,

3322:18, 3323:11, 3324:1, 3324:5,

3324:10, 3325:15, 3325:17, 3325:24,

3325:25, 3326:10, 3326:12, 3326:14,

3329:8, 3329:14, 3329:16, 3331:2,

3331:12, 3331:16, 3331:19, 3331:23,

3331:25, 3332:3, 3332:5, 3341:21,

3341:22, 3341:23, 3341:24, 3350:1,

3350:3, 3350:5, 3350:11, 3350:14,

3350:15, 3350:20, 3351:1, 3351:3,

3351:7, 3351:9, 3351:10, 3351:14,

3351:15, 3351:19, 3351:22, 3353:1,

3353:2, 3355:23, 3361:5, 3362:11,

3362:15, 3368:10, 3368:13, 3371:6,

3373:23, 3374:1, 3380:10, 3383:8,

3383:11, 3383:15, 3383:16, 3383:21,

3383:25, 3384:1, 3384:10, 3384:11,

3385:2, 3385:4, 3386:14, 3388:24,

3388:25, 3389:1, 3389:2, 3389:3,

3389:5, 3389:6, 3389:7, 3389:9,

3389:10, 3389:11, 3389:23, 3390:3,

3390:18, 3390:19, 3390:20, 3390:22,

3391:2, 3397:14, 3397:15, 3397:16,

3397:17, 3397:23, 3398:1, 3399:3,

3399:5, 3399:8, 3399:20, 3399:22,

3399:23, 3405:14, 3405:17, 3406:8,

3406:20, 3406:22, 3407:7, 3407:10,

3407:13, 3407:16, 3407:18, 3408:9,

3408:12, 3408:21, 3408:25, 3409:23,

3410:7, 3410:12, 3411:3, 3411:7,

3411:13, 3411:21, 3412:2, 3412:5,

3412:11, 3412:15, 3412:19, 3413:18,

3413:20, 3414:16, 3414:20, 3415:5,

3415:25, 3416:2, 3416:6, 3416:10,

3416:22, 3417:13, 3417:21, 3418:5,

3418:12, 3418:15, 3418:24, 3420:3,

3420:7, 3420:15, 3420:19, 3421:19,

3421:24, 3422:4, 3422:8, 3422:11,

3422:17, 3422:19, 3422:23, 3423:5,

3423:11, 3423:20, 3423:23

theft [1] - 3179:11

themselves [1] - 3148:17

theories [1] - 3419:16

theory [4] - 3201:2, 3383:24, 3384:2,

3413:20

therefore [3] - 3214:2, 3229:18,

3274:18

they've [5] - 3300:8, 3352:17, 3413:15,

3414:14, 3422:7

thinks [1] - 3408:14

third [4] - 3199:22, 3215:5, 3253:3,

3370:22

thousand [2] - 3326:22, 3367:5

thousand-dollar [1] - 3367:5

thousands [2] - 3166:1

three [35] - 3149:17, 3206:24, 3212:19,

3231:22, 3253:17, 3303:20, 3303:24,

3304:2, 3304:6, 3304:9, 3305:8,

3305:23, 3306:4, 3306:6, 3306:8,

3306:11, 3308:11, 3321:8, 3338:5,

3344:22, 3359:18, 3359:19, 3359:20,

3377:5, 3385:21, 3390:17, 3392:8,

3399:13, 3415:23, 3415:25, 3416:4,

3416:6, 3416:7, 3416:21, 3422:20

three-week [1] - 3416:21

threw [9] - 3286:4, 3387:6, 3387:24,

3393:12, 3394:5, 3394:15, 3398:13,

3399:13, 3400:18

throughout [4] - 3166:19, 3166:21,

3196:5, 3255:4

throw [4] - 3285:14, 3386:8, 3394:7,

3394:10

thrust [2] - 3308:6, 3309:17

thumb [8] - 3285:10, 3285:15, 3286:5,

3286:14, 3387:5, 3393:25, 3396:19,

3399:14

Thunderbirds [1] - 3165:15

Thursday [9] - 3247:12, 3247:15,

3247:17, 3249:19, 3249:20, 3249:22,

3258:6, 3262:7, 3283:5

tied [1] - 3286:1

Tier [68] - 3182:17, 3183:2, 3183:4,

3183:5, 3184:16, 3184:18, 3185:14,

3185:15, 3185:19, 3187:1, 3191:24,


3456

3196:9, 3196:10, 3196:12, 3196:13,

3196:15, 3239:10, 3239:25, 3240:17,

3248:7, 3248:11, 3249:4, 3249:25,

3253:23, 3254:8, 3254:18, 3255:1,

3255:12, 3255:13, 3255:14, 3256:5,

3257:6, 3258:10, 3258:21, 3259:10,

3259:12, 3259:25, 3261:14, 3261:18,

3261:20, 3262:13, 3262:14, 3264:10,

3265:9, 3266:16, 3266:19, 3266:23,

3274:25, 3275:3, 3275:14, 3282:10,

3283:4, 3283:15, 3283:16, 3284:12,

3284:15, 3386:11

tier [6] - 3185:20, 3186:18, 3191:17,

3195:1, 3195:3, 3249:4

Tiers [5] - 3179:24, 3182:25, 3238:21,

3255:8

time-wise [1] - 3421:8

timeframe [1] - 3414:2

timing [1] - 3161:7

title [5] - 3214:22, 3248:5, 3248:6,

3357:16, 3358:4

titled [2] - 3269:21, 3368:23

today [11] - 3194:22, 3298:2, 3303:16,

3303:19, 3314:7, 3410:1, 3411:15,

3414:19, 3414:21, 3415:10, 3417:5

together [13] - 3163:5, 3163:7, 3180:1,

3192:1, 3241:14, 3249:24, 3251:5,

3286:1, 3306:4, 3306:8, 3310:5,

3359:5, 3415:10

Tom [5] - 3233:2, 3233:3, 3233:16,

3244:2, 3281:23

tomorrow [16] - 3194:23, 3194:24,

3246:10, 3246:11, 3333:9, 3336:15,

3410:1, 3417:3, 3418:4, 3418:22,

3419:20, 3420:10, 3420:19, 3420:25,

3423:12

tone [3] - 3351:3, 3351:11, 3373:1

tonight [3] - 3418:2, 3423:18, 3423:21

took [23] - 3153:24, 3166:19, 3231:14,

3253:16, 3262:21, 3263:11, 3274:19,

3295:3, 3304:6, 3305:8, 3314:25,

3317:8, 3317:13, 3327:17, 3332:12,

3332:18, 3347:23, 3372:3, 3372:6,

3383:5, 3387:24, 3394:10, 3400:20

Top [6] - 3163:10, 3163:12, 3163:13,

3163:20, 3165:7, 3241:18

top [15] - 3164:2, 3185:4, 3186:20,

3191:13, 3195:7, 3196:22, 3209:11,

3224:10, 3252:24, 3300:11, 3319:3,

3364:22, 3368:15, 3369:2, 3380:17

topic [4] - 3188:17, 3387:2, 3409:21,

3414:13

topics [2] - 3372:23, 3381:3

Toronto [1] - 3186:3

tossed [1] - 3285:9

total [21] - 3175:11, 3188:2, 3189:9,

3190:18, 3194:11, 3195:21, 3195:24,

3202:20, 3203:1, 3203:7, 3214:25,

3222:17, 3222:24, 3222:25, 3223:1,

3251:25, 3254:17, 3255:9, 3255:14,

3259:5, 3359:8

totaling [1] - 3224:22

touch [3] - 3245:6, 3283:24, 3338:7

tough [3] - 3198:3, 3201:7, 3416:19

tour [2] - 3170:18, 3171:1

toward [8] - 3147:14, 3167:4, 3172:24,

3190:9, 3195:7, 3196:6, 3241:24,

3411:24

towards [1] - 3324:7

tower [1] - 3387:13

town [1] - 3293:23

TPC [5] - 3163:13, 3165:7, 3165:20,

3192:17, 3193:3

track [11] - 3158:16, 3159:1, 3322:9,

3326:4, 3356:25, 3357:2, 3357:5,

3360:4, 3360:6, 3391:22

tracked [1] - 3159:5

tranches [4] - 3293:3, 3335:2, 3345:9,

3346:10

transaction [11] - 3208:14, 3220:25,

3221:10, 3316:17, 3318:19, 3341:9,

3347:8, 3347:14, 3347:15, 3349:15,

3349:17

transactional [1] - 3221:15

transactions [9] - 3217:3, 3217:5,

3329:3, 3346:3, 3348:14, 3374:17,

3382:2, 3382:5

transcript [1] - 3424:6

Transcript [1] - 3144:14

transcription [1] - 3144:14

transfer [10] - 3215:24, 3216:13,

3216:22, 3328:19, 3346:23, 3346:24,

3346:25, 3347:16, 3352:23, 3353:6

transferred [17] - 3195:6, 3205:15,

3209:22, 3216:10, 3216:11, 3216:18,

3217:18, 3220:5, 3224:3, 3224:7,

3225:24, 3226:3, 3322:23, 3346:14,

3346:22, 3348:9, 3396:19

transfers [6] - 3185:18, 3186:18,

3186:23, 3186:25, 3205:14, 3221:13

travel [8] - 3175:24, 3243:8, 3251:10,

3252:25, 3321:20, 3333:6, 3336:14,

3422:1

traveled [1] - 3321:15

treasurer [2] - 3349:19, 3352:2

treasury [3] - 3185:9, 3185:12, 3348:3

treated [2] - 3224:20, 3251:19

TRIAL [1] - 3143:7

trial [5] - 3303:21, 3407:1, 3411:11,

3414:2, 3414:15

tried [15] - 3296:7, 3296:10, 3318:23,

3319:2, 3319:5, 3334:1, 3334:3,

3336:19, 3352:17, 3396:14, 3398:12,

3398:16, 3398:24, 3399:17, 3400:16

trip [3] - 3171:2, 3242:17, 3243:1

trips [1] - 3171:3

true [5] - 3265:5, 3274:15, 3339:16,

3344:4, 3400:23

Truellenque [4] - 3148:9, 3148:10,

3148:19, 3159:19

Trustmark [1] - 3348:15

truth [25] - 3232:5, 3232:13, 3264:6,

3272:5, 3272:9, 3274:9, 3276:22,

3311:22, 3311:23, 3311:25, 3312:6,

3312:8, 3312:9, 3312:12, 3312:17,

3312:18, 3312:19, 3312:20, 3339:10,

3367:14, 3383:2, 3383:3

truthful [1] - 3313:10

try [14] - 3246:20, 3260:25, 3291:19,

3302:23, 3314:6, 3341:10, 3351:18,

3351:22, 3385:15, 3385:17, 3393:4,

3397:6, 3397:7, 3420:5

trying [22] - 3161:19, 3197:24,

3230:14, 3256:17, 3257:4, 3257:5,

3283:24, 3299:6, 3299:7, 3303:7,

3318:10, 3323:24, 3345:19, 3358:14,

3396:10, 3396:22, 3397:8, 3398:13,

3400:3, 3400:4, 3421:21, 3422:25

Tuesday [4] - 3246:16, 3246:17,

3282:18, 3414:23

turmoil [1] - 3166:20

turn [13] - 3202:5, 3202:7, 3202:8,

3206:8, 3223:11, 3236:13, 3237:8,

3289:11, 3322:12, 3324:12, 3324:19,

3395:16, 3414:12

turned [4] - 3183:5, 3195:6, 3326:18,

3414:3

turning [2] - 3187:2, 3243:7

twice [1] - 3411:16

two [44] - 3176:4, 3184:12, 3185:17,

3188:2, 3188:18, 3207:25, 3214:25,

3224:11, 3224:15, 3224:22, 3232:9,

3241:13, 3248:15, 3253:17, 3265:24,

3293:2, 3294:16, 3298:15, 3308:11,

3333:20, 3335:2, 3337:20, 3343:3,

3345:9, 3346:1, 3346:10, 3359:19,

3359:24, 3361:25, 3365:6, 3365:22,

3366:11, 3380:5, 3387:13, 3387:14,

3393:13, 3401:23, 3404:1, 3404:4,

3404:11, 3406:14, 3410:17, 3416:16

type [7] - 3275:3, 3302:21, 3318:24,

3332:20, 3332:22, 3348:10, 3357:16

types [5] - 3165:14, 3167:14, 3184:15,

3259:9, 3265:9

U

U.S [11] - 3143:17, 3149:20, 3166:5,

3227:5, 3227:7, 3231:15, 3245:6,

3281:4, 3361:20, 3363:20, 3380:20

ultimate [1] - 3276:1

ultimately [8] - 3189:21, 3189:24,

3212:2, 3280:8, 3284:2, 3290:20,

3293:21, 3342:8

ultra [2] - 3211:5

uncomfortable [3] - 3151:18, 3151:25,

3351:24

uncover [1] - 3240:3

uncovered [1] - 3176:23

uncovering [2] - 3240:6, 3279:23

under [19] - 3149:25, 3150:13,

3150:14, 3150:22, 3151:2, 3151:6,

3151:13, 3152:1, 3157:2, 3194:8,

3215:22, 3217:23, 3222:17, 3223:2,

3227:22, 3232:8, 3232:10, 3369:3,

3381:22

understood [6] - 3155:19, 3180:16,

3200:20, 3211:5, 3211:19, 3212:10Johnny C. Sanchez, RMR, CRR - [email protected]

3457

underway [1] - 3423:13

undeveloped [1] - 3223:9

unencumbered [1] - 3199:14

unfortunately [1] - 3311:25

unit [5] - 3175:25, 3176:11, 3217:5,

3389:9, 3390:20

uNITED [1] - 3143:1

United [16] - 3147:17, 3148:4, 3149:1,

3149:16, 3149:24, 3151:5, 3233:4,

3241:25, 3278:4, 3280:15, 3280:22,

3281:6, 3306:14, 3352:12, 3363:11,

3378:12

UNITED [2] - 3143:4, 3143:10

units [1] - 3175:22

unless [2] - 3310:6, 3419:12

unmute [1] - 3331:23

unreasonable [1] - 3417:21

up [112] - 3147:11, 3148:15, 3148:21,

3154:3, 3158:9, 3159:12, 3173:24,

3174:8, 3175:10, 3176:11, 3179:25,

3182:14, 3186:7, 3191:24, 3195:7,

3196:7, 3205:16, 3206:9, 3208:15,

3214:11, 3214:17, 3217:6, 3219:24,

3224:19, 3227:17, 3227:22, 3243:13,

3243:20, 3244:13, 3244:14, 3244:22,

3246:18, 3247:6, 3247:21, 3248:16,

3249:18, 3249:23, 3252:21, 3257:13,

3257:16, 3258:6, 3262:23, 3262:25,

3266:5, 3268:6, 3268:9, 3270:17,

3271:10, 3275:25, 3276:9, 3278:22,

3278:24, 3279:3, 3283:24, 3287:15,

3291:25, 3292:1, 3292:4, 3292:6,

3292:7, 3292:8, 3292:24, 3295:24,

3298:17, 3300:12, 3300:22, 3302:23,

3304:6, 3305:7, 3311:7, 3312:14,

3313:4, 3315:6, 3315:7, 3316:16,

3317:20, 3318:21, 3319:18, 3326:24,

3327:9, 3328:5, 3331:6, 3334:12,

3335:1, 3336:11, 3337:2, 3339:4,

3341:8, 3351:24, 3364:6, 3364:10,

3364:13, 3373:13, 3374:17, 3378:18,

3382:16, 3382:17, 3382:22, 3383:13,

3383:14, 3384:7, 3384:20, 3385:16,

3386:7, 3390:23, 3402:12, 3405:10,

3410:6, 3414:14, 3418:12, 3420:24

upcoming [3] - 3232:20, 3232:24,

3241:15

update [2] - 3194:22, 3196:24

updates [1] - 3184:10

upper [5] - 3202:8, 3206:18, 3207:3,

3222:13, 3251:8

upset [2] - 3405:12, 3406:17

US [1] - 3143:14

usage [1] - 3211:7

USD [1] - 3191:5

uses [1] - 3179:5

utilities [3] - 3219:9, 3219:17, 3219:24

V

validity [1] - 3316:22

valuation [6] - 3218:11, 3252:23,

3252:24, 3418:11, 3418:20, 3419:18

valuations [1] - 3252:21

value [28] - 3199:15, 3217:1, 3217:20,

3217:21, 3218:10, 3218:14, 3218:19,

3223:8, 3223:9, 3223:20, 3224:7,

3224:25, 3225:11, 3237:16, 3251:22,

3252:20, 3253:22, 3253:23, 3257:6,

3258:10, 3259:25, 3262:13, 3264:7,

3264:10, 3265:11, 3279:2, 3348:9

values [11] - 3223:21, 3250:18,

3252:17, 3253:11, 3253:16, 3254:4,

3255:24, 3259:5, 3262:9, 3278:22,

3278:24

various [1] - 3150:12

Velcro [1] - 3209:2

Venture [15] - 3251:16, 3345:8,

3345:12, 3346:16, 3348:14, 3348:21,

3353:8, 3353:13, 3353:16, 3353:22,

3355:14, 3367:18, 3369:21, 3370:3,

3370:9

venture [3] - 3293:2, 3345:11, 3348:12

verbal [2] - 3339:4, 3339:6

verbatim [1] - 3247:11

verify [7] - 3316:16, 3316:21, 3336:23,

3340:2, 3352:8, 3366:4, 3398:24

version [3] - 3304:12, 3305:19,

3310:16

versus [2] - 3227:9, 3389:3

vestibule [1] - 3165:5

vicinity [1] - 3217:4

video [1] - 3192:10

videos [1] - 3164:17

view [1] - 3321:13

violated [1] - 3411:11

violates [1] - 3412:9

Virgin [6] - 3227:4, 3227:5, 3227:9,

3231:15, 3245:7

Virgins [1] - 3226:16

virtue [1] - 3322:17

visible [2] - 3173:1, 3173:2

visit [2] - 3203:19, 3227:23

visited [2] - 3173:12, 3203:17

visitors [2] - 3172:19, 3173:6

visits [5] - 3171:21, 3172:4, 3303:20,

3304:10, 3305:23

visual [1] - 3173:5

voice [2] - 3351:4, 3373:1

volatility [1] - 3202:18

VOLUME [1] - 3143:8

volunteer [1] - 3314:10

VS [1] - 3143:5

W

wages [2] - 3324:25, 3342:8

wait [7] - 3212:22, 3221:1, 3258:20,

3299:24, 3299:25, 3331:7, 3347:21

waited [1] - 3165:5

waiting [2] - 3245:8, 3245:15

waive [2] - 3300:16, 3417:24

waived [6] - 3230:8, 3234:23, 3234:24,

3300:13, 3300:14, 3300:17

waiver [1] - 3417:18

walk [5] - 3173:3, 3208:14, 3209:7,

3210:1, 3387:18

walked [1] - 3268:7

walking [1] - 3265:8

wall [3] - 3173:13, 3199:8, 3413:16

Wall [2] - 3413:18, 3413:21

wants [4] - 3176:17, 3300:7, 3417:16,

3423:7

warning [1] - 3300:10

warnings [1] - 3411:18

WARREN [1] - 3422:5

Warren [2] - 3143:16, 3305:9

Washington [6] - 3143:18, 3233:4,

3234:3, 3288:7, 3288:9, 3288:14

watch [3] - 3299:15, 3331:4, 3412:23

water [3] - 3211:11, 3253:1, 3286:15

waters [1] - 3210:19

ways [3] - 3239:18, 3419:8, 3423:5

wearing [1] - 3373:6

Wednesday [9] - 3246:15, 3246:17,

3247:2, 3249:17, 3287:19, 3288:18,

3414:23, 3421:22, 3422:25

week [31] - 3146:3, 3159:6, 3188:6,

3203:20, 3228:18, 3240:11, 3240:22,

3241:8, 3241:14, 3243:7, 3246:14,

3248:4, 3250:3, 3258:7, 3282:12,

3285:5, 3287:13, 3287:19, 3288:18,

3303:24, 3305:10, 3305:11, 3394:8,

3411:16, 3414:11, 3414:22, 3414:23,

3416:21

week-to-week [1] - 3159:6

weekend [4] - 3284:20, 3284:25,

3285:6, 3287:2

weekends [1] - 3394:14

weeks [9] - 3195:19, 3241:14,

3243:14, 3296:25, 3310:13, 3347:23,

3347:24, 3394:10, 3416:16

weight [1] - 3408:14

welcome [1] - 3373:3

West [1] - 3378:7

Western [1] - 3378:6

who'd [1] - 3234:1

whole [6] - 3155:22, 3168:3, 3281:4,

3383:2, 3383:3, 3421:6

wholly [1] - 3271:24

wide [3] - 3389:21, 3389:25, 3390:5

wife [18] - 3212:12, 3214:4, 3284:21,

3302:10, 3302:11, 3343:21, 3344:8,

3344:9, 3344:16, 3344:24, 3402:21,

3403:20, 3403:21, 3405:16, 3405:19,

3406:2, 3406:3, 3407:6

wife's [1] - 3388:16

wiggle [1] - 3423:1

wilderness [2] - 3247:8, 3247:10

William [1] - 3143:16

willing [5] - 3297:7, 3298:22, 3407:3,

3407:6, 3420:14

windows [1] - 3173:2

windup [1] - 3189:13

wire [14] - 3346:23, 3346:24, 3346:25,

3347:5, 3347:15, 3347:25, 3348:22,


3458

3349:1, 3352:21, 3352:23, 3353:6,

3367:18, 3370:8, 3370:10

Wire [1] - 3369:21

wired [2] - 3348:4, 3348:6

wireless [5] - 3160:10, 3160:13,

3251:9, 3252:19, 3253:1

wise [5] - 3166:7, 3223:19, 3223:20,

3412:18, 3421:8

withdraw [3] - 3191:20, 3286:20,

3293:16

withdrawal [10] - 3190:24, 3191:10,

3191:19, 3191:22, 3191:25, 3196:14,

3198:2, 3199:4, 3285:4, 3287:16

withdrawals [12] - 3163:1, 3181:20,

3181:21, 3181:23, 3182:24, 3183:6,

3186:22, 3198:16, 3200:24, 3225:21,

3246:6, 3246:7

withdrawn [5] - 3303:10, 3314:3,

3399:4, 3399:6, 3399:8

witness [28] - 3155:19, 3168:22,

3208:21, 3229:24, 3236:2, 3252:14,

3269:13, 3272:14, 3291:6, 3295:19,

3298:7, 3298:10, 3298:24, 3300:14,

3303:14, 3303:15, 3308:19, 3309:17,

3311:10, 3397:9, 3400:20, 3406:7,

3415:4, 3415:20, 3416:7, 3421:20,

3422:4

WITNESS [143] - 3145:2, 3154:9,

3156:15, 3161:22, 3166:13, 3168:25,

3170:14, 3171:12, 3171:15, 3174:20,

3174:23, 3174:25, 3175:3, 3177:2,

3178:3, 3181:4, 3190:21, 3196:16,

3198:20, 3198:24, 3200:10, 3200:20,

3201:1, 3201:3, 3201:12, 3201:16,

3202:3, 3204:21, 3210:12, 3210:14,

3210:17, 3210:20, 3211:12, 3213:21,

3214:1, 3216:19, 3219:8, 3219:11,

3219:14, 3220:22, 3222:5, 3226:18,

3227:7, 3227:10, 3227:25, 3228:25,

3234:20, 3236:8, 3236:20, 3238:11,

3238:14, 3238:16, 3239:1, 3239:15,

3240:15, 3243:23, 3244:22, 3245:23,

3247:16, 3247:19, 3248:13, 3248:15,

3248:18, 3248:21, 3249:2, 3249:5,

3249:7, 3249:10, 3249:15, 3249:20,

3250:10, 3250:13, 3254:9, 3254:11,

3254:16, 3254:20, 3254:22, 3256:13,

3256:19, 3256:21, 3257:1, 3257:9,

3257:11, 3258:17, 3258:23, 3261:11,

3262:1, 3268:12, 3278:5, 3278:15,

3278:25, 3279:2, 3279:7, 3279:21,

3280:25, 3281:4, 3281:7, 3281:9,

3282:2, 3282:4, 3285:16, 3285:18,

3287:8, 3287:21, 3304:20, 3305:2,

3307:1, 3308:13, 3309:4, 3311:4,

3315:23, 3321:4, 3325:15, 3325:24,

3326:12, 3341:22, 3341:24, 3350:3,

3350:11, 3350:15, 3351:3, 3351:9,

3351:14, 3351:19, 3353:2, 3383:15,

3383:25, 3384:10, 3385:4, 3388:25,

3389:2, 3389:5, 3389:7, 3389:10,

3389:23, 3390:3, 3390:19, 3397:15,

3397:17, 3398:1, 3399:3, 3399:23,

3407:7

witness's [2] - 3298:5, 3322:15

witnesses [2] - 3416:4, 3417:8

woman [6] - 3271:11, 3273:22,

3344:12, 3401:4, 3401:10, 3403:23

wondering [1] - 3414:12

wood [1] - 3414:11

word [14] - 3156:22, 3267:5, 3275:9,

3275:24, 3312:10, 3319:23, 3320:5,

3320:7, 3320:10, 3340:3, 3352:14,

3372:8, 3399:1

word-for-word [1] - 3156:22

words [21] - 3157:7, 3171:14, 3182:22,

3200:17, 3209:4, 3222:2, 3228:7,

3246:4, 3249:3, 3256:23, 3260:11,

3261:10, 3274:14, 3276:1, 3318:23,

3351:1, 3351:8, 3386:1, 3389:12,

3412:20, 3421:11

works [1] - 3351:1

worksheet [1] - 3216:4

world [6] - 3201:13, 3201:15, 3211:6,

3220:9, 3226:15, 3374:14

worldwide [1] - 3160:12

worn [1] - 3350:12

worry [2] - 3421:8, 3421:15

worse [2] - 3198:21, 3220:11

worth [3] - 3264:12, 3279:5, 3279:6

Worth [6] - 3231:7, 3243:16, 3243:18,

3282:17, 3284:16, 3284:17

wow [3] - 3353:14, 3380:9, 3388:13

wrap [1] - 3331:5

write [5] - 3209:5, 3292:16, 3367:24,

3369:16, 3419:4

writes [2] - 3207:18, 3366:12

writing [5] - 3199:8, 3208:21, 3366:8,

3370:20, 3371:18

written [2] - 3207:6, 3207:18

wrote [9] - 3191:21, 3194:20, 3195:4,

3195:8, 3195:9, 3209:11, 3292:13,

3366:8, 3367:5

Y

y'all [1] - 3359:5

year [26] - 3147:13, 3166:15, 3182:6,

3196:6, 3215:4, 3290:17, 3290:22,

3296:8, 3314:8, 3314:9, 3315:25,

3316:13, 3332:15, 3333:14, 3333:17,

3333:18, 3358:16, 3365:7, 3366:11,

3374:15, 3374:16, 3380:19, 3403:13,

3416:20

years [52] - 3147:8, 3147:11, 3149:17,

3151:5, 3151:25, 3156:24, 3166:19,

3166:25, 3169:21, 3175:9, 3180:13,

3232:7, 3264:16, 3275:2, 3294:16,

3294:20, 3303:20, 3304:9, 3305:20,

3305:23, 3306:4, 3306:6, 3306:8,

3306:11, 3308:1, 3311:24, 3312:13,

3312:18, 3321:8, 3330:7, 3337:20,

3338:5, 3342:15, 3344:22, 3371:19,

3373:7, 3376:1, 3377:5, 3385:21,


3459

3399:13, 3401:21, 3401:22, 3403:9,

3403:10, 3405:6, 3406:1

yes-no [1] - 3407:8

yesterday [3] - 3303:15, 3309:10,

3314:6

Yolanda [1] - 3289:25

York [7] - 3143:17, 3233:5, 3234:3,

3234:9, 3234:10, 3422:25, 3423:7

you-all [1] - 3227:22

young [2] - 3373:10, 3377:23

younger [2] - 3403:4, 3403:14

yourself [8] - 3155:12, 3187:16,

3248:17, 3294:15, 3371:24, 3376:21,

3400:19

Z

Zach [1] - 3404:9

Zack [2] - 3177:17, 3177:23

zone [2] - 3227:11, 3421:17

zoom [1] - 3187:10

Allen Stanford Criminal Trial Transcript Volume 11 Feb. 6, 2012

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Transcript of Allen Stanford Criminal Trial Transcript Volume 11 Feb. 6, 2012