Allen Stanford Criminal Trial Transcript Volume 7 Jan. 31, 2012

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

1971

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

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

VS. ** January 31, 2012

ROBERT ALLEN STANFORD * 10:19 a.m.

JURY TRIAL

VOLUME 7

BEFORE THE HONORABLE DAVID HITTNERUNITED STATES DISTRICT JUDGE

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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1972

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.

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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1973

I N D E X

WITNESS PAGE

MARIAN ALTHEA CRICK

CROSS-EXAMINATION BY MR. PARRAS................ 1983

REDIRECT EXAMINATION BY MR. WARREN............. 2062

RECROSS EXAMINATION BY MR. PARRAS.............. 2084

REDIRECT EXAMINATION BY MR. WARREN............. 2098

ARNOLD KNOCHE

DIRECT EXAMINATION BY MR. COSTA................ 2099

CROSS-EXAMINATION BY MR. SCARDINO.............. 2169

REDIRECT EXAMINATION BY MR. COSTA.............. 2233

RECROSS EXAMINATION BY MR. SCARDINO............ 2244

REDIRECT EXAMINATION BY MR. COSTA.............. 2251

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1974

RECROSS EXAMINATION BY MR. SCARDINO............ 2255

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Direct-Crick/By Mr. Warren


1975

(The following was held before the jury)

THE COURT: Thank you. Be seated. Good

morning. I can't say I've had a full day already, but I've

had full of something this morning already.

So we're ready to proceed. Counsel, go

right ahead.

MR. WARREN: Thank you, Your Honor.

DIRECT EXAMINATION

BY MR. WARREN:

Q. Good morning, Ms. Crick?

A. Good morning.

Q. Are you familiar with Antiguan bank secrecy laws?

A. Yes, I am.

Q. Can you generally describe what those laws are?

A. Those laws are contained in the International

Business Corporations Act, and it describes the conditions

under which information can be released to an individual

making a request.

Q. And what types of information can be released and

what types of information can't be released, generally

speaking?

A. Well, generally speaking, all information can be

released. It's a question of the conditions under which

they're released. For example, there are pieces of

information that are available to the public in general.

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1976

For a fee, the public can see certain documents. There is

information that is shared with regulatory authorities

around the world under circumstances in which there is a

memorandum of understanding between the countries or

mutual legal assistance treaty with those countries. And

there are instances where if the information relates to

customer information, a bank -- court order is required.

Q. What do you mean by "customer information"?

A. Specifically in banking, information that would

outline a customer's business transactions with the bank.

Q. By "customer," do you mean -- who's a customer in the

case of Stanford International Bank?

A. In the case of Stanford International Bank, a

customer is one who either by way of deposit or loan

accesses the services of the bank.

Q. Is there any prohibition against a bank like Stanford

International Bank disclosing its assets?

MR. PARRAS: Judge, object to the form of the

question.

THE COURT: Why?

MR. PARRAS: Best evidence would be the

statute? If it's to her knowledge, I -- to her

understanding, then I understand it. The question is?

THE COURT: State it again -- no, I want it

read back. Johnny, read it back, please.

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1977

(Requested portion was read.)

THE COURT: Now, what's your problem?

MR. PARRAS: It's not qualified to indicate

that it's her understanding, and it seems --

THE COURT: Hold it.

Ma'am, how long have you been in the

banking business?

THE WITNESS: For over 25 years.

THE COURT: On your country, you're familiar

with the laws?

THE WITNESS: Yes, I am.

THE COURT: Overrule the objection.

BY MR. WARREN:

Q. Ms. Crick, do you recall the question?

A. There is nothing that prevents a bank from revealing

its assets, no.

Q. If Stanford International Bank wanted to tell its

customers or even the entire world about every single

asset in its investment portfolio, was it allowed to do

that?

A. Yes, there's nothing in law that prevents the bank

from doing that.

Q. Whose decision would that have been to disclose those

assets?

A. The bank's decision.

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1978

Q. Can the FSRC tell the bank you're not allowed to do

that?

A. No.

Q. Are you familiar with a form called an IB5?

A. Yes.

Q. What's an IB5?

A. An IB5 is a form which was designed by our

commission. It's information that the regulated entity is

required to submit to us on its investment portfolio on a

quarterly basis.

Q. What kind of information is included in the IB5?

A. The IB5 includes information -- the IB5 details a

bank's investment portfolio. It outlines the various

investment companies and the amounts invested, the

balances with those various investment houses.

Q. Was Stanford International Bank an entity that

produced IB5s to the FSRC?

A. Yes.

Q. And please describe the information that would be

contained in those IB5s.

A. The IB5 would contain --

Q. I'm sorry. Particularly Stanford International

Bank's IB5s.

A. It would contain a listing of all the investment

houses, the balances, the date at which those balances

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1979

relate to. I can't remember all the details because it's

quite a compact schedule that is required, but those two

pieces of information would be essential.

Q. The investment houses and?

A. The balances with each of these investment houses.

Q. What do you mean by "the investment houses"?

A. The bank would at intervals within its own

decision-making process determine where it wants to invest

its resources with which investment company. So what that

schedule contain is a listing of all these institutions

with which the bank had, in fact, placed these

investments.

Q. These would be other banks where Stanford

International Bank has its assets like a Credit Suisse or

a bank --

A. It could range anything from other banks to

institutions that specialize in investing portfolios. It

would be a wide range. It's a matter of their decision

with which organization to invest.

Q. Is there any prohibition against Stanford

International Bank taking that IB5 that contains all its

investment houses and all the balances that it submits to

the commission and releasing that to its customers?

A. There is nothing that prohibits that.

Q. I'm showing you Government's Exhibit 218, which is

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1980

already in evidence.

I'll represent to you that this is a

manual from Stanford International Bank?

THE COURT: When you say it's already in

evidence, it's all in evidence if it's been previously

referenced.

MR. WARREN: Yes, Your Honor, it's been

previously shown.

THE COURT: Here it is. I got it at the bottom

of that page. You can just say that, it's been previously

referencing, because it's all in evidence pursuant to my

initial ruling subject to defense objections.

BY MR. WARREN:

Q. Ms. Crick, I'll represent to you that this is a

manual from Stanford International Bank that contains

questions and answers about the bank's operations and

portfolio.

MR. WARREN: If we could turn to Page 21.

BY MR. WARREN:

Q. Ms. Crick, let me know if you're able to read that on

the screen in front of you; otherwise, I can give you a

hard copy.

A. It's going to be a little difficult.

Q. Sure. Ms. Crick, is that better?

A. That's a lot better.

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1981

Q. You see the question: "Can a client see the

investments in the portfolio?"

A. Yes, I do.

Q. Can you please read the answer?

A. "Bank regulators do not allow SIBL to discuss

specifics about the portfolio."

Q. Let me stop you there.

Is that an accurate statement of what

Antiguan regulators allow or don't allow?

A. That is not accurate.

Q. Could you continue reading, please?

A. "SIBL is also allowed" -- sorry -- "is only allowed

to discuss the portfolio from an investment philosophy

exercising the overall diversification parameters."

Q. Let me stop you there, Ms. Crick.

Is that an accurate statement?

A. No, it's not.

Q. Could you continue reading, please?

A. "If a bank were to drill down into the portfolio,

regulators would view this as the bank is representing

itself as a security or fund (sic) and would put the

banking license in jeopardy."

Q. Ms. Crick, your reaction in answer to the question,

but is that a correct statement?

A. That is not correct.

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1982

Q. And the last line, please.

A. "Because SIBL is a bank and sells only bank products,

it must adhere to these guidelines."

Q. Is that an accurate statement?

A. That is not accurate.

Q. What about the next paragraph? The question is:

"What are the top positions in the portfolio?" Could you

please read what the manual says in response?

A. "Unfortunately, SIBL is not allowed to disclose

individual positions because of banking regulations."

Q. Let me stop you there.

Is that an accurate statement?

A. No, it's not.

Q. Can you continue reading, please?

A. "If it were to do so, it could be construed as

presenting itself as a security and/or fund which would

put the banking license in jeopardy."

Q. Is that an accurate statement?

A. No, it's not.

Q. Would any type of disclosure of the bank's assets or

where its accounts were held, where its money was held be

a violation of Antiguan law that would put its license in

jeopardy?

A. No.

MR. WARREN: Court's indulgence.

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Cross-Crick/By Mr. Parras


1983

THE COURT: All right.

MR. WARREN: Pass the witness, Your Honor.


MR. PARRAS: Can I ask before counsel sits down

what exhibit number this was?

THE COURT: 218.

MR. PARRAS: And the page?

MR. WARREN: 21.

MR. PARRAS: If I could have a few seconds.

THE COURT: You've got a few seconds. The

clock is running. So take as much time as you want. You

Ou might put those chess clocks up here and hit it when

counsel come up.

MR. PARRAS: If you could go back to the whole

page. Thank you.

CROSS-EXAMINATION

BY MR. PARRAS:

Q. Good morning, Ms. Crick.

A. Good morning.

Q. My name is John Parras. We've never met before;

right?

A. That's correct.

Q. Actually, the first time that we talked --

THE COURT: Counsel, at least in front of the

microphone. If you want the lapel, that's fine.

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1984

MR. PARRAS: I'll try this for a while, Judge.

THE COURT: Okay.

BY MR. PARRAS:

Q. The first time that you and I met, we were -- I was

coming in from a break and you were sitting outside on the

bench; correct?

A. That is correct.

Q. I said, "Hello, are you Ms. Crick?" introduced

myself?

A. That is correct.

Q. And at the time you were standing with Mr. Gerber or

sitting with Mr. Gerber, correct, the agent that's right

here? He was right there with you?

A. He was standing off to the side.

Q. Right. And an FBI agent, Walter, was there with you,

too, right? The lady, the FBI agent, the lady, she was

there with you, too?

A. She was standing to the side, yes.

Q. We didn't talk about the case; right?

A. No, we did not discuss the case.

Q. Okay. And you and I -- you've never called my office

or any of the lawyers for Stanford to tell them that you

were going to come testify so that we could have a chance

to visit with you about what you might say here; right?

A. No, I did not.

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1985

Q. You had another gentleman there with you that was

seated right next to you to your left, who was that

gentleman?

A. That's Mr. Tom Baker.

Q. Is he your lawyer?

A. Yes, he is.

Q. Are you afraid that you may be charged civilly or

criminally as a result of the FSRC's regulation of SIBL?

A. No, I'm not.

Q. What's the reason for having a lawyer here with you?

A. It was simply a matter of giving me someone with whom

I could connect once I got here.

Q. Is it a lawyer that you paid for?

A. It's a lawyer that the commission paid for.

Q. It's a U.S. lawyer?

A. It's a U.S. lawyer, yes.

MR. PARRAS: I want to look up at Government's

Exhibit 218. We're looking at Page 21. And if you could

please for me, zoom in on the bottom left.

THE WITNESS: Could we have this enlarged as

well, please?

THE COURT: That's what he's going to do.

MR. PARRAS: Very, very bottom left under the

line.

THE COURT: Are you going to enlarge it?

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1986

MR. PARRAS: Yes.

THE COURT: There we go.

How about that?

THE WITNESS: That's very good, yes.

BY MR. PARRAS:

Q. Have you seen that before, ma'am? This is a document

that's not for distribution.

A. I have not seen that, no.

Q. Do you know whether this is a draft document or a

finalized version?

A. I do not.

Q. Do you know who created this document?

A. I do not.

Q. When is the first time you were shown this document?

A. This morning.

Q. Where were you shown this document?

A. Here in court.

Q. And do you know whether this document is drafted for

customers in the U.S. or outside the U.S.?

A. I do not know.

Q. If it were -- if it were created for customers of the

United States, there may be different laws that apply;

correct?

A. I suppose that's possible.

Q. For example, it may well be that if it were

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1987

distributed to customers in the U.S., the information that

we talked about, where the investments are, that it could

be considered a security; correct?

A. Given that I'm not familiar with U.S. laws, I really

can't answer that.

Q. Well, you answered a number of questions for the

prosecutor --

THE COURT: Hold it. I can't -- do you want

the lapel mike?

MR. PARRAS: I think so, Judge.

THE COURT: All right. Let's get the lapel

mike. Right here. I think you hold the budget until it

goes. I'll stop the clock. And you need to put it high on

the tie, please.

MR. PARRAS: If you could go back to the whole

page. Thank you.

BY MR. PARRAS:

Q. So the first time you saw this document was this

morning in court, and yet you were shown pieces and

blown-up sections of it for this jury to convey what idea,

Ms. Crick?

A. It was not to convey an idea, it was in response to

questions that was asked.

MR. PARRAS: I don't need that document

anymore. Thank you.

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1988

May I have the ELMO, Judge?

Thank you.

BY MR. PARRAS:

Q. I'm going to show you Government's Exhibit 511.

Do you remember being shown this document?

A. Yes.

Q. And being asked about whether or not it would be

important for you to know that the government of

Montserrat proposed to revoke the license of GIBL --

A. Yes.

Q. -- back in 1990; do you remember that?

A. Yes, I do.

Q. You told this jury that the first time you saw that

document was the night before you testified; correct?

A. That is correct.

Q. You answered a number of questions about why it might

be important to know that information; correct?

A. That is correct.

Q. Were you also shown an opinion by Judge Redhead that

held that the license was not revoked and that, in fact,

help from Mr. Stanford and his directors that knew that it

had been revoked was improper?

A. I have not seen such a document.

Q. I'm going to show you what's been marked and admitted

into evidence as Defendant's Exhibit 2-14. And this is my

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1989

copy.

Do you see that?

A. Yes.

MR. PARRAS: I want to verify with the Court

that this is in evidence. I believe it is.

MR. WARREN: No objection.

THE COURT: Has it been referenced yet?

MR. WARREN: It has, Your Honor.

THE COURT: All right. 511 -- correct, 511?

What number is that?

MR. PARRAS: This is Defendant's Exhibit 2-14.

THE COURT: Okay. I'm sorry. Defendant's.

No. I don't have that. 2-14? I have the latest one, 7-4.

MR. PARRAS: It would have been marked with the

second witness. That's the significant of the two. That's

correct, Your Honor, it was introduced.

THE COURT: Ellen may have it. All right.

2-14.

MR. PARRAS: Yes, Your Honor.

THE COURT: Double-check during the break. I'm

pretty sure it's in now that I remember.

MR. PARRAS: Yes, sir.

THE COURT: All right. Go right ahead. What

is this or what is it.

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1990

BY MR. PARRAS:

Q. Let's look at the first page so that we can determine

what this is. Okay. You see at the top there, In the

High Court of Justice, Colony of Montserrat, 1994. Can

you read that, ma'am?

A. Yes, I do.

BY MR. PARRAS:

Q. Do you see the case is between James Stanford,

R. Allen Stanford, Don Caldwell, O.Y. Goswick, and the

attorney general of Montserrat. Do you see that?

A. Yes, sir.

Q. And you see that the case is before the Honorable

Justice Albert Redhead?

A. Yes.

Q. And then there's the names of the lawyers that

appeared for the parties. This was a case that was heard

on the 25th, 26th, 27th and 31st of August 1994, and this

is the judgment of the Court.

I'm going to turn to and -- do you

know what this lawsuit was about, by the way?

A. No, I've never seen the document, so I have no idea.

Q. The government didn't show you this document when

they showed you the letter about the propose to revoke

GIBL language?

A. I have not seen this document.

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1991

Q. All right. As a regulator who licenses corporations,

would it be important for you to know whether or not, in

fact, the license was revoked or not?

A. Yes, it would be.

Q. I'm going to go page by page, and eventually we will

skip a few.

You're a judge with the labor court;

court?

A. I am a member of the court, yes.

Q. You're not a judge?

A. There's a reference to a judge. I sit on a panel,

yes, of three judges.

Q. Are you trained in law?

A. I'm not.

THE COURT: She's a CPA or the equivalent of

our CPA.

BY MR. PARRAS:

Q. But you're not trained in law --

THE COURT: You never said you were an

attorney?

THE WITNESS: That's correct, sir.

THE COURT: Do you want to be an attorney?

THE WITNESS: Yes, sir.

THE COURT: You do?

THE WITNESS: Yes.

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1992

THE COURT: Okay. Usually I get an absolutely

"no."

Okay. Go on.

BY MR. PARRAS:

Q. Ma'am, this letter, this opinion is in evidence, and

if the jury so chooses, they can read it in its entirety.

I'm going to represent to you that this is a lawsuit

regarding the idea that Guardian's bank's license was

revoked. And in this lawsuit, which the exhibit will

speak for itself, the directors of Guardian are suing the

attorney general of Montserrat so that the directors of

Guardian could affirmatively say their license had not

been revoked, okay? Do you understand?

A. I understand what you're saying, yes.

Q. I want to go -- it's Bates marked A Stanford 0010763.

And I'm going to read and you follow, and if I mess up,

you tell me, okay?

A. Uh-huh.

Q. "Allen Stanford" --

MR. WARREN: I'm sorry, Counsel. Can you

repeat that page, please?

BY MR. PARRAS:

Q. This is an opinion about the trial. "Allen Stanford

testified that at the very end of October 30th, 1990, the

government of Montserrat was informed of the bank's

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1993

intention to leave and go to Antigua. This was before he

received the letter of 28th November 1990."

That's the Government's Exhibit 511, 28

November 1990.

The Judge goes on to say -- and these are

my markings. "Allen Stanford said on oath that on 30th

October 1990, he, James Stanford; Goswick; Judge Don

Caldwell, Jr., came to Montserrat, especially to inform

the government of Montserrat of the bank's intention. He

said they went to the governor's place of business and the

office of C.P. John and informed them.

"Allen Stanford said the chairman informed

Charles G. John of the bank's intention to move to Antigua.

Allen Stanford said that the chairman, James Stanford,

asked Charles John in his and in the presence of others if

there were any items that the bank needed to address prior

to its departure."

I want to stop right there. Does it sound

to you like the directors of Guardian International who are

about to leave Montserrat are going to the highest official

they can to make sure that things are okay?

A. On that reading, it would appear that way.

Q. It's the Judge's opinion? That's what he's saying;

right, that reading?

A. I'm not sure what I have before me is the Judge's

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1994

opinion.

Q. Let's go to the front, then. Defendant's

Exhibit 214. Judgment in court. And if we go on the

back, who is it signed by?

A. Judge Albert Redhead.

Q. Do you have any doubt that this is an opinion by

Judge Redhead?

A. The sections you quote to me were not the opinions of

the Judge.

Q. Well, let's read further to be fair. "Stanford said

that he made a note of that conversation in that meeting.

Charles T. John denied that he ever told Allen Stanford

that Guardian International Bank had no problems in

Montserrat. He, however, testified that Allen Stanford

and the other members of the Guardian International Bank

visited his office on the 30th of October 1990."

So there's a dispute about what was said,

correct, from that reading?

A. It would appear that way.

Q. But there's no dispute that there was a meeting on

October 30th, correct, from this reading?

A. From the reading, yes.

Q. We'll read on to what the gentleman said. "The

purpose of the meeting according to my understanding was

that they were seeking a letter of good standing to

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1995

certify that Guardian International Bank was in good

standing with us. I did not issue such a letter. At that

meeting, I cannot recall any of the directors informing me

that Guardian International Bank had taken the decision to

leave Montserrat. I did not issue a letter of good

standing, because in my view, there were some difficulties

which militate against me issuing such a letter:

"I told Mr. Stanford that there were

difficulties and I could not do it. I did not tell him

what the difficulties were, but I told him where he could

get the information. I did not at any time tell

Mr. Stanford that Guardian International Bank had no

problems in Montserrat."

That's the dispute, right, who said what;

correct?

A. It would appear that way from the document.

Q. Okay. "Charles T. Jordan, Charles T. John, said that

the Antiguan government did not ask for a letter of good

standing." That's another witness making another

statement. "I entertain no doubt" -- now we have the

Judge talking -- "whatever that the directors of Guardian

International Bank who were operating a bank in Montserrat

by the name of Guardian International Bank are the same

persons who are the directors of a bank in Antigua,

Guardian International Bank." Let's stop right there for

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1996

a second.

It's clear to you from this judicial opinion

that the Judge is speaking about the same directors that

ended up moving to Antigua and later becoming regulated by

you; correct?

A. It would appear from that, yes.

Q. Okay. This is the Judge's finding here. "I

entertain no doubt either that prior to 30 October 1990,

the bank had consummated its plan to move to Antigua. If

the Antiguan government needed a letter of good standing

from the Montserrat government or if a letter of good

standing was a prerequisite, then in my view" -- Judge

speaking; correct -- "it would have been a simple and an

easy matter to obtain such a letter from a governmental

level. By this I mean it would have been an easy thing

for the government of Antigua to request such a letter

from the government of Montserrat."

As a regulator, ma'am, you could have

requested from Montserrat at any time that you were

director the files of Montserrat regarding Guardian

International Bank; correct?

A. There is something I need to make clear in terms

of --

THE COURT: In other words, you can't -- can

you answer the question yes or no. If you can't --

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1997

THE WITNESS: I can't answer it yes or no.

THE COURT: Okay.

BY MR. PARRAS:

Q. You're the regulator now, right, of the FSRC in

Antigua?

A. I am the Chairman of the Board, yes.

Q. If you wanted to get information today about a bank

in Montserrat today, you could ask the government of

Montserrat for that information; correct?

A. We could make the request, yes.

Q. Let's keep reading, and I'll be done on the next

page. Down at the bottom. "Charles T. John having said

that he did not issue such a letter to Allen Stanford,

neither was one requested of him by the government of

Antigua. I must, therefore, conclude that such a letter

was not necessary so far as the government of Antigua was

concerned. If it was not necessary, then why would Allen

Stanford request one? I, therefore, accept Allen

Stanford's evidence in preference to Charles T. John's

evidence."

That's a finding; right?

THE COURT: That's a what, Counsel?

MR. PARRAS: A judicial finding, a fact

finding.

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1998

BY MR. PARRAS:

Q. This is the Judge saying that he gives more credit to

Allen Stanford's account than Charles John's account;

right?

A. It would appear that way, yes.

Q. "This is, he, Allen Stanford, did not request any

letter of good standing and that the purpose of the

meeting of 30 October 1990 was to inform Charles T. John

of the bank's intention to move to Antigua.

"Mr. Kenneth Allen and Allen Stanford

testified that they went to the chief minister's office on

21 December 1990."

We're talking about a different meeting

now; correct?


Q. "Mr. Allen said that at the chief minister's office,

he explained to the then chief minister, Mr. Osborne, that

the purpose of their meeting with him was to surrender the

A and B licenses of the time bank since we were about to

move to another jurisdiction and had seized business in

Montserrat and to thank him for the time we had operated

here.

"Mr. Allen said that he handed the chief

minister a large envelope which contained two original

licenses and later addressed to him -- and a letter

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1999

addressed to him. He read the letter carefully, looked at

the two licenses, and then, according to Mr. Allen, said to

Allen Stanford, 'I'm sorry you're leaving because I've

always heard good news about your company.'"

That's what the opinion says; correct?

THE COURT: Counsel, that is a judicial

opinion?

MR. PARRAS: Yes, it is Judge.

THE COURT: Is that they write -- I guess they

write it in different jurisdictions different ways?

MR. PARRAS: Yes.

THE COURT: I mean, that --

MR. PARRAS: He probably was wearing a wig at

the time he wrote this.

THE COURT: Maybe they have it right. I don't

know.

MR. PARRAS: I always wanted to wear one of

those little legal wigs, especially now with this hair

going away, Judge.

THE COURT: They're hot. I've tried them on.

There is a wig store named -- what is it -- something in

Ravenscroft -- Ede & Ravenscroft in London, and I actually

went there to see what it was like and tried them on. I

don't need to wear it. It's hot. They're horse hair. And

the long -- the short ones are by the barristers and for

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2000

judges when they try civil matters. When they try criminal

matters, they wear a red robe with a big long wig. I

learned all about that. I did not buy one.

MR. PARRAS: Going on to Page 25. And, again,

this is in evidence, the jury can ask for it. The jury can

read the entire thing. I'm going to go to Page 25, first

full paragraph.

BY MR. PARRAS:

Q. "Neither Mr. Kenneth Allen nor Mr. Allen Stanford who

were present at the meeting can recall John Osborne

handing the license to the financial secretary."

It sounds like we're talking about the

same meeting where licenses were handed over.

"In my view" -- Judge speaking -- "it is

not of critical importance whether John Osborne handed the

license to Charles John or not. What is of importance is

whether Allen Stanford handed over the license to John

Osborne." Now the Judge speaking. "I have absolute no

doubt that on 21 December 1990 Allen Stanford handed over

the original A and B licenses to John Osborne at his

office.

And this opinion also alludes to some

differences of opinion that Mr. Stanford had with a

regulator named Roe. And I want to show you what the

Judge's findings are in that regard. Here's the Judge

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2001

speaking. "From the evidence, I have no doubt that there

was bad blood again Allen Stanford and Roe."

Do you know Mr. Roe?

A. No, I do not.

MR. PARRAS: Let me go to Page 38.

BY MR. PARRAS:

Q. "The evidence is that Roe was a banking advisor. He

was not a lawyer."

Do you see that? Right there where the

pen is pointed.

A. Okay. Yes, uh-huh.

Q. It's true, ma'am, that there are times when in your

business, in your job as a regulator, you either don't

have the legal answers or you need to seek legal advice or

you need a legal opinion or you're frustrated that the law

doesn't allow you to do something you want to do; correct?

A. I'll accept the last one.

Q. Well, there are times --

A. It's not been my experience.

Q. So it's your experience that the IBC act of 1982 has

everything needed and you've never been frustrated by the

law in your pursuit of information or regulatory?

A. I wouldn't use the word "frustrated," no.

Q. Okay. Have you had occasion to think it should be

better, the law the should be better?

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A. Laws can always be improved, and that's the case with

us as well.

Q. And then just to close this out again, last page,

signed Judge Redhead. There are some -- I believe these

were admitted as well, these articles, and at the end a

judgment of the Court 20 December 1994. And I'm going to

read the judgment. It's only a page.

"This action having been tried before the

Honorable Mr. Justice Redhead, without a jury, and the

said Mr. Justice Redhead having on the 31st day of

August 1994 ordered that judgment as hereinafter provided

be entered for the plaintiff."

Let's go back to the front. We have here

the plaintiffs, James Stanford, Allen Stanford, Don

Caldwell, O.Y. Goswick.

"It is adjudged and declared as follows:

That Guardian International Bank, Limited, ceased to do

business on the 19th of December 1990."

I'm going to skip ahead.

"That the licenses granted to Guardian

International Bank on 9 January '86 and the 14th day of

November '88 could not be revoked."

I'm going to skip ahead.

"That the revocation referred to in a

letter dated -- I think that's 19th June, '91 --

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2003

"purported to have been made on the 31st day of May 1991

is null and void and of no effect."

Do you see that, ma'am?

A. Yes.

Q. Okay. And this, you'll agree with me, was 1994;

correct?

A. Yes.

Q. Long before you had any occasion to regulate SIBL on

the island of Antigua; correct?

A. Yes.

Q. So if it was necessary for your duties to learn about

the history, in addition to this letter that the

government showed you, it would have been important for

you to have this exhibit that the defense has shown you,

wouldn't it?

A. Yes.

Q. And that would have cleared up the matter; right?

A. Not necessarily.

Q. Do you want to take that up with Judge Redhead?

A. I don't have the benefit of having read the entire

document. I've been given sections of it. I don't know

how it all fits together cohesively.

Q. Thank you.

We're talking about regulations. And it's

true that in 1998 and in 1999 when you -- so difficult to

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see with that screen, ma'am, sorry.

In 1998 and in 1999, there was an effort

in Montserrat to make the laws, the offshore banking laws,

the international business regulation laws better;

correct?

A. In Montserrat?

Q. I mean, in Antigua. I'm sorry. Thank you.

A. Yes, uh-huh.

Q. And it's true that in 1996 there was a law passed in

Antigua regarding money laundering; correct?

A. That's correct.

Q. At that time in the world, the drug war was raging

all over the Caribbean, South America, Central America and

North America; correct?

A. I don't know that I have the expertise to answer

that.

Q. Well, the money laundering laws were an effort to

impose tighter controls on banks and on financial

services --

A. Uh-huh.

Q. -- in the Caribbean area and otherwise so that money

laundering could be shut down; correct?

A. Money laundering, yes.

Q. And that was 1996; right?

A. Yes.

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2005

Q. And as time progressed into 1998 and 1999, what the

governments realized is that they had to also regulate the

financial services industry better; correct?

A. There was that realization that the sector had to be

regulated better, yes.

Q. And you were asked to join the Antiguan government in

an effort to make the bank, offshore bank, regulations

better; right?

A. Yes, uh-huh.

Q. You were asked to also join then Antiguan government

so that you could make offshore banking a business on the

Island of Antigua; correct?

A. That's not correct.

Q. You were asked to compare the Antiguan laws to other

Caribbean islands so that you could compete with places

like the Bahamas and the Cayman Islands for offshore

banking business; correct?

A. That's not true.

Q. Do you remember writing an International Financial

Sector operational plan --

A. Yes.

Q. -- in November of 1998?

A. Yes.

Q. You authored it; correct?

A. Yes.

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Q. You authored it under the -- as the executive

director of the International Financial Sector Authority

correct?

A. Yes.

Q. And it was commissioned and intended to give the

commission a quick plan for hypergrowth; correct?

A. Yes, uh-huh.

Q. Of the offshore sector?

A. Yes.

Q. So the Government of Antigua was looking to expand

the offshore banking business; right?

A. The international business. You see, you keep

focussing on banking sector. It's the international

business sector.

Q. That's a great point because international business

and the AIBCI doesn't apply just to offshore bank;

correct?

A. Exactly.

Q. It applies to --

A. A range of types of entities and services.

Q. Internet gambling services?

A. Internet gambling is not considered international

financial banking. International financial service, no.

Q. So then, what are -- just give me an idea of what the

range is.

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A. The range would include international insurance,

international trusts. We now regulate nonfinancial

business cooperatives. It's a wide range of regulatory

functions that we carry out.

Q. And -- and you wrote a report and presented it to the

board. And that was late of 1998; correct?

A. That sounds about right, yes, uh-huh.

Q. And it's true that at that time there was a group

called the "Offshore Financial Sector Planning Committee";

right?

A. Yes.

Q. Okay. I'm going to call it the OFS for short. Is

that okay?

A. The acronym doesn't quite fit, but yes.

Q. The -- that committee was not a government entity;

correct?

A. That is correct.

Q. That committee was made up to help the government to

strengthen their financial laws and regulations, the same

kind of work that you were doing; correct?

A. Yes.

Q. And it's that committee that Mr. Stanford was a

chairman of; correct?

A. Yes.

Q. And you objected to that; right? You didn't think it

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2008

was proper?

A. No, I didn't object to that.

Q. Okay. You didn't object? You never lodged a

complaint? You didn't file a report with anybody in the

government saying that you thought it was improper for

Mr. Stanford to be chairman of the OFSPC, did you?

A. This was not a government body.

Q. I understand.

A. It's a civil body. Why would I object to a group of

business persons, in effect, to getting together to assist

the government.

Q. It was a good thing?

A. There's no need to object to that.

Q. It was a good thing, wasn't it?

A. I don't know that it was a good thing, but I know

there would be no need to object to it.

Q. You found no -- let's just move on.

Let's -- you will agree that, on that

committee, was a former FBI agent named Lloyd Harold;

correct?

A. I think -- I can't be sure that Harold was on that

committee. It's quite possible that he was.

Q. A former DEA agent named Tom Cash?

A. Yes. But --

Q. A U.S. customs agent named Pat' O'Brien, former U.S.

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Customs agent. Same division that Mr. Gerber works with;

right?

A. Uh-huh.

Q. And a -- there were accountants from the big -- the

big accounting firm, BDO Seidman; correct?

A. I don't recall that no.

Q. There were lawyers from Greenberg, Traurig; correct?

A. I know of a lawyer.

Q. Was that Carlos Lumiere?

A. The name that comes to mind is Patrick O'Brien.

Q. And Patrick --

A. That's not to say there wasn't. I just don't recall.

Q. And that's a good point.

In addition to being a former customs

agent he was a lawyer too; right? Pat O'Brien?

A. He was a lawyer, uh-huh.

Q. There was a gentleman who had been the head of the

Puerto Rican financial regulatory agency named Mr. Diaz.

Was he on that committee?

A. Mr. Ivan Diaz, yes.

Q. And then there was a former East Caribbean Supreme

Court Judge named Kenneth Allen who was on that committee;

correct? If you remember.

A. I can't recall that gentleman being on the committee.

Q. It's true that that committee was helping you to

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2010

establish a regulatory framework for international

corporations?

A. This -- I cannot recall that committee doing that.

Q. What do you recall that committee doing?

A. In fact, the names that you mentioned, I know of them

as a team working on Operation Clean Slate.

Q. Okay.

A. The committee I was referring to when you asked me

early on was a committee I knew of as the Sectoral

Committee. This is why I said your acronym was not

correct, because you inserted the word "planning

committee," and I'm not familiar with the planning

committee. That's why I'm looking very confused because

the two things that I'm not -- that are not marrying at

all. They are two different things?

Q. Maybe you can help me then.

A. I would love to.

Q. There was a committee of private individuals that

were helping the government regarding the regulations that

you were working on as the executive director of the IFSA;

correct?

A. Among other things, yes. That was the Sectoral

Committee when I came on board.

Q. Okay. And then you came on board and you and your

team developed a plan that we talked about started in

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November of '98 and resulted in a second report in

February of '99; correct?

A. Yes. It's possible, yes.

Q. And could you describe basically what your report was

about?

A. This is so long ago. The report outlined what I saw

as the needs of the body to develop the sector to

strengthen the regulatory regime of the sector. That was

the broad theme of the report, if I recall correctly.

Q. Is it true that at that time the United States and

places like UK had concerns about the banking industry

down in Antigua?

A. It had concerns about operators in the sector, yes.

Q. And you and this private group were trying to address

those concerns.

That's fair, isn't it?

A. Not that group. I did not work with that group.

That's the point I want to make.

Q. Okay. Let's just stick to you then, what you know.

You were working to address concerns of

the international community regarding the regulations of

international companies on Antigua?

A. I was working as the person who was brought on board

to develop a regime that would make the jurisdiction

effective in respect to regulating the various

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2012

international entities.

Q. Okay.

A. That was my task. It involved a number of things

that had to be done, from administrative to legislative.

It was a range of things that had to be put in place.

The team that you are describing is the

team I knew of Operating Clean Slate.

Q. Okay. Then I will get there then; okay? Let's just

stick to what you did.

You turned in your reports to the board

and they replied back basically saying, you know, that's

good work, but we need you to do more quicker, and they

gave you a memo outlining the various things that they

wanted you to do, 29, 30 items, with a definitive time by

which you should get them done; correct?

A. I remember that memo, yes.

Q. Did that memo upset you?

A. I was somewhat disturbed by the memo, yes. Some of

the timelines were unreasonable.

Q. You thought they were asking you to do too much too

quickly; right?

A. No.

Q. What did you think then? Why were you disturbed by

the timeline?

A. Because some of the things that were contained that I

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2013

was being -- in that letter, that was being asked to do,

were things that could not reasonably be done in the

timeframe set.

Q. Okay. Is it -- do you remember that memo coming out

approximately two months after your second report in April

of '99?

A. That, I couldn't say for sure. It probably did.

Q. Do you remember in April of '99 that the United

States and the United Kingdom sent a message out to the

world about doing business on the Island of Antigua?

A. Yes.

Q. What was the message that the United States and the

United Kingdom sent out to the world in April of '99?

A. I don't recall exactly, but the gist of it was

essentially to -- alerting their constituents that there

were certain weaknesses within the regulatory regime in

Antigua and Barbuda. That's the general terms. I can't

remember the specifics.

Q. And here's where we get to Operation Clean Slate.

Either in conjunction with or as a result

of that message, a group of individuals who you called

Operation Clean Slate undertook the job to scrub the

island of all its banks; correct? Basically?

A. I never knew what was really the task of Operation

Clean Slate.

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2014

Q. Okay. Is this the group that was asking for your

files, or is that a different incident?

A. It's the team, the Operation Clean Slate team, but

some of the names that you called are not familiar to me

as being part of the team. That's not to say they were

not.

Q. Okay. Which ones do you remember being part of

Operation Clean Slate?

A. I remember Lloyd Harold. I remember Pat O'Brien. I

remember Sandra Jeffrey. I remember Ivan Diaz and Cynthia

Roche.

Q. And what you're telling us here today is that, as the

executive director of the regulatory agency on the Island

of Antigua, you don't know exactly what Operation Clean

Slate was doing?

A. Sounds strange, doesn't it? But that was the case,

believe me.

Q. Do you know that eventually Operation Clean Slate was

able to scrub the banks, get rid of some Russian banks and

drop a number of international offshore banks from 50 down

to 25 or less?

A. Operation Clean Slate, its actions, what it did, what

the results were, were never revealed to me.

Q. Okay.

A. I don't have information leading to that. Anything

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2015

that I had, any knowledge that I had, might have come

after; but certainly I don't know what they accomplished.

Q. Okay. Let's talk about after this.

It's clear to you that, after Operation

Clean Slate, GIBL was still operating on the Island of

Antigua; right?

A. I think so. If it was still Guardian. I'm not sure

when it changed to Stanford.

Q. It's either Guardian or Stanford?

A. Yes.

Q. But bottom line is, Operation Clean Slate ended.

Guardian or SIBL is still in operation; correct?

A. That is correct.

Q. And you were successful in getting your regulatory

framework up and running, weren't you?

A. As a result of Operation Clean Slate?

Q. No. Just --

A. Generally?

Q. You eventually started examining banks; correct?

A. In that regard, yes, uh-huh.

Q. You started sending examiners to the different

international banks, having them go through the

accounting, go through the procedures, go through the

banks's processes, and reporting back to you; correct?

A. I began that exercise, yes.

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2016

Q. As a side note, were you aware that Guardian

International Bank or SIBL in the spring of 1999 wrote

a 3 million-dollar check to the United States Marshals

Service pursuant to an investigation regarding money

laundering, an allegation that one of its customers had

improperly used the bank?

A. I'm aware of that, yes.

Q. And that's true. That happened; right?

A. Yes. I'm aware of it, yes.

Q. Guardian International Bank and Mr. Allen Stanford

cooperated with authorities in the investigation of money

laundering, didn't they?

A. I don't know of that.

Q. We talked briefly about the bank secrecy that was

raised this morning.

Is it good business or bad business to

give your customer information out to anybody that asks?

A. Customer information?

Q. Yes.

A. No.

Q. All right. Is it good business or bad business to

give your competitors information about how you're

investing money?

A. That depends on the information and the nature of the

investment.

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2017

Q. It's true, isn't it, that depending on the

jurisdiction and the country that you're in, different

rules may apply?

A. That is correct, yes.

Q. I want to talk a little bit about your island; okay?

A. Sure.

Q. Let me show you what I think has been admitted as

Government's Exhibit 516.

MR. PARRAS: And if I can get verification on

that.

THE COURT: It's in. The question is: Has it

been identified?

It hasn't been identified since I've been

keeping the list. Has it been identified before?

MR. WARREN: Yes, Your Honor.

THE COURT: Okay.

BY MR. PARRAS:

Q. I'm putting Government's Exhibit 5 -- 1516 --

THE COURT: Well, hold it. 1516?

MR. PARRAS: I thought it was five, Judge. I

misspoke. And I'm going to move this. Excuse me.

BY MR. PARRAS:

Q. I'm going to point to the far right where it says

Barbuda and Antigua.

Do you see that?

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2018

A. Yes.

Q. Is that where were born?

A. I was born in Antigua, yes.

Q. You lived there until you left for college in

Florida?

A. Yes.

Q. Was Florida the first place you visited outside of

Antigua?

A. No.

Q. What other places had you been to before you went to

Florida?

A. Before I went to Florida, I had been to a number of

the other Caribbean islands, and basically that's the

extent of my travel, within the islands.

Q. I haven't been out there. Whether we say the West

Indies, what are we talking about on this map?

A. You're talking islands ranging anywhere from Trinidad

all the way up the chain to Anguilla.

Q. Okay. And it's true that -- and this is way off

subject, but not way off subject. But it -- the one thing

that you nights all of those islands is cricket; right?

A. You could say that, yes.

Q. There's a saying that cricket is the glue that binds

the West Indies; correct?

A. Not so much now, but there was a time, yes.

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2019

Q. And that's -- you're going exactly where I was

thinking.

There was a time -- there was a time when

the cricket players -- and cricket's a lot like baseball;

right? It's not a lot. It's kind of like baseball.

A. It's not quite like baseball, no, but -- I wouldn't

say it's a lot like baseball, no.

Q. There was a time in the '70s, I believe, and into the

'80s when the West Indies cricket team were the premier

team of the world for 15 years running; right?

A. Yes.

Q. They became known as the legend; right?

A. Yes.

Q. And it's true that the islands rise and fall with the

success of the cricket team --

A. Rise and fall.

Q. -- of the West Indies?

A. Rise and fall in what respect?

Q. Well, heart and soul of the islands as a whole, as a

group, really come together behind the Westies; right?

A. Yes. Uh-huh.

Q. And during that time, the '70s and into the '80s, the

Westies, as they're called, traveled to?

A. Indies.

Q. The Indies -- West -- the Windies?

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2020

A. Indies.

Q. Indies.

They traveled to places that had been

other colonial -- other colonies like Australia; right?

A. (Answered affirmatively).

Q. New Zealand, South Africa?


Q. And they absolutely whipped all of the countries in

cricket where they went to for 15 years; right?

A. That's correct.

Q. They went to London and did that in London, didn't

they, against the English team?

A. All over.

THE COURT: All right, Counsel. Make the

point, please.

BY MR. PARRAS:

Q. Cricket was something that Mr. Stanford attempted to

revive in the Indies in the five, ten years before SIBL

was taken over; correct?

A. I don't know that that's the case, no.

Q. I'm going to show you what's been marked as

Defendant's Exhibit 1530, it's a series of photos. I want

you to look through them see if you recognize them.

And when you're done, let me know; okay?

Do you recognize those places?

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2021

A. Not all of them.

Q. Okay. If you -- let me walk up there, if you don't

mind, and I'll put a little note on the ones you

recognize.

Can you tell me which ones you recognize?

This first one?

A. I don't recognize that.

Q. Okay. Second one?

A. Yes.

Q. Third one?

A. Yes.

Q. Fourth one?

A. Yes.

Q. Fifth one?

A. No.

Q. Sixth one?

A. Yes.

Q. This one?

A. Yes.

Q. There may be a few of them. How about that one?

A. Yes, sir.

Q. Is that one?

A. No.

Q. That one?

A. No.

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2022

Q. That one?

A. Yes.

Q. Is this one?

A. No, that's not familiar.

Q. This one?

A. That looks like familiar. Yes, uh-huh.

Q. Yes?

A. I'm not familiar with that one. And, yes.

(Attorneys conferring)

MR. PARRAS: I should ask her.

MR. WARREN: That's fine.

MR. PARRAS: Judge, I move to admit


THE COURT: Has it -- it's already is, isn't

it?

MR. WARREN: I'm not making an objection.

THE COURT: Has it been identified?

MR. PARRAS: I can --

THE COURT: Hold it. Counsel, has it been

identified?

MR. WARREN: I don't believe so yet, Your

Honor. We have no objection.

THE COURT: All right. So it's already in, but

it's now identified.

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2023

BY MR. PARRAS:

Q. Just generally speaking, Ms. Crick, could you tell

the jury here what it is that you recognize in those

pictures?

A. I recognized pictures of buildings that house

Mr. Stanford's -- some of Mr. Stanford's businesses.

Q. Okay. Let me show you what is Bates Number 006.

Do you recognize that building?

A. Yes.

Q. Tell the jury what that building is?

A. It's Stanford International Bank Services.

Q. It's not a apartment in a strip club -- I mean a

strip mall, is it?

A. No, it is not.

Q. It's a big building for the Island of Antigua, isn't

it?

A. You said for the Island of Antigua?

Q. On the Island of Antigua, it's actually a nice

building?

A. It's a building on the Island of Antigua.

Q. Is it a nice one?

A. You could say that, yes.

Q. You indicated that you recognize this building.

Could you tell the jury what this building

is?

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2024

A. This is a hangar, aircraft hangar.

Q. Who owns the hangar?

A. As far as I'm aware, it's owned by Stanford, one of

Stanford's companies.

Q. Is it still on the Island of Antigua?

A. I think it is. I'm not absolutely sure.

Q. When you fly in and out of Antigua, do you fly in and

out of the airport attached to this hangar?

A. The airport attached to that hangar?

Q. The airport where this hangar is located?

A. In the general region, yes.

Q. Do you have more than one airport on the Island of

Antigua?

A. We have one airport, yes.

Q. Okay. When you fly out, do you fly out of this

airport?

A. Yes.

Q. Okay. And this is in evidence, but you didn't

recognize this building; correct?

A. No. I don't know. I'm not familiar with that

building.

Q. You did say that you recognize this building. And

it's at Bates 000015.

What is this building?

A. That's the building that houses Bank of Antigua.

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2025

Q. Now, Bank of Antigua is the bank that serves

Antiguans that Mr. Stanford or SIBL or -- and I don't know

exactly who right now, but that is part of the Stanford

entities; correct?

A. Yes.

Q. Okay. You told me you recognize this as an aerial

view of the cricket field?

A. That's true yes.

Q. And it's true that this cricket field is one of the

best cricket fields in the world; right? Do you know

that?

A. I don't know that.

Q. It's -- okay.

A. I'm not a cricket field expert.

Q. Have you been to a cricket match on this field?

A. No.

Q. All of the buildings that we just looked at to your

knowledge continue to exist on Antigua; correct?

A. The buildings are there, yes.

Q. Do you know whether there's an Antiguan receiver who

is in control or who has ownership of those buildings

right now?

A. I know there is a liquidator. Whether the person has

control, to what extent, that, I'm not familiar with.

Q. Have you seen any of the liquidators or attorneys for

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2026

the liquidators in court here this week?

A. No.

Q. Okay. And you do know that there's another receiver,

a second receiver, in the United States who is in a legal

dispute with the Antiguan receiver about ownership of SIB

assets; correct?

A. I know there's a dispute. I don't know the exact

details of the dispute.

Q. On direct examination, you talked about a Mr. Hewlett

offering you a job to go and audit the Bank of Antigua;

correct?

A. To partner with him in conducting the audit.

Q. At the time -- do you remember what year he asked you

to do that?

A. No, I don't recall. But I know it was in the --

maybe the late '80s, I think it might have been, or early

90s, somewhere around there.

Q. Did Mr. Hewlett have a good reputation or a bad

reputation on the island?

A. I don't know that he had a good -- in respect of

what?

Q. Well, in respect to your decision to possibly partner

with him, did it concern you to concern to partner with

Mr. Hewlett?

A. No, it did not cause me concern.

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2027

Q. In fact, as late of 2007, you and Mr. Hewlett were on

the same auditing organizations, island organizations;

correct?

A. Yes. He's a certified accountant on the island.

Q. And on direct, I believe you were asked about the

annual reports.

You know that Mr. Hewlett signed every

single one of these audits, these annual reports, that you

were asked about? Do you know that?

A. The annual reports?

Q. The SIBL or GIBL annual reports.

A. The auditor's report?

Q. Yes.

A. He signed. He was the auditor, yes. He would have

signed them.

Q. Let me show you what's been introduced as


MR. PARRAS: And I could -- I could use some

help here, PDF Page 27, please. Government's Exhibit 111.

MR. SCARDINO: Need to switch, Judge.

THE COURT: Okay.

MR. PARRAS: And if we could zoom in on the

signature and address at the bottom.

BY MR. PARRAS:

Q. Is that the company and the address where from

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2028

Mr. Hewlett worked?

A. Yes.

MR. PARRAS: Okay. If we could go back out to

the full page. And if we can focus on the opinion at the

very end there.

BY MR. PARRAS:

Q. And I'm going to read this out loud. If I mess it

up, please tell me.

"In our opinion, the financial statements

give a true and fair view of the state of affairs of the

bank as at 31 December 1998, and of the result of its

operation for the year then ended. The statements have

been prepared to comply with international accounting and

financial reporting standards and the companies law of

Antigua and Barbuda."

MR. PARRAS: This -- if we could can to the

first page of this exhibit to see what year it is. And if

we could zoom in there on annual report 1998.

BY MR. PARRAS:

Q. Is this an annual report that at this time would have

been subject to a regulatory -- an Antiguan regulatory

body or agency for review?

A. It would have been submitted, because it's a

requirement, yes.

Q. Okay. And to your knowledge as the executive

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2029

director of the regulatory body just a year later, was

there ever any complaint, professional complaint, about

Mr. Hewlett?

A. Professional complaint, not that I can recall.

MR. PARRAS: Okay. Let's go to Government's

Exhibit 112, PDF 30 and let's start with the first page,

PDF 1, please. If we can go to the first page. I'm sorry.

BY MR. PARRAS:

Q. What year is this, ma'am?

A. 1999.

Q. Okay. At that time, you were head of the -- the

executive director of the regulatory agency on Antigua;

correct?

A. Yes.

Q. If you wanted to, you could have looked through a

comb of this report and asked the bank to go in and

examine their paperwork; correct?

A. We could have, yes. I'm just trying to -- I'm

hesitating for a reason.

MR. PARRAS: Well, let's go to PDF Page 30.

And zoom in on the signature and address block at the

bottom.

BY MR. PARRAS:

Q. That's Mr. Hewlett's signature and his working

address there on the island?

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2030

A. The address, yes. The signature appears to be his.

MR. PARRAS: Okay. Let's zoom back out.

BY MR. PARRAS:

Q. And this one is harder to read, but let's try reading

the opinion again.

MR. PARRAS: That one -- yeah, we'll go to the

next year. Please pull up Government's Exhibit 113. Go to

the first page and show us what year this is in the bottom

left-hand section of the report.

BY MR. PARRAS:

Q. You see that that's the 2000 annual report; right?

A. Yes.

Q. You were the executive director of the Antiguan

regulatory agency at that time; right?

A. Yes.

MR. PARRAS: Let's go to PDF Page 37. And if

we could -- I'm going to read the whole thing this time.

If you could zoom in, please, on the first two paragraphs.

The whole thing, please, right above that.

BY MR. PARRAS:

Q. Okay. The title says "Auditors' Report to the

Members," and then Mr. Hewlett's signature is under the

statement.

"We have audited the financial statements

on Pages 18 to 31."

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2031

And then there's the heading, "Respective

Responsibilities of Directors and Auditors."

"As described on Page 34, the company's

management is responsible for the preparation of the

financial statements. It is our responsibility to form an

independent opinion based on our audit of those statements

and to report our opinion to you."

MR. PARRAS: Let's go to the next.

BY MR. PARRAS:

Q. "Basis of opinion."

"We conducted our audit in accordance with

international auditing standards, which include

examination on a test basis of evidence relevant to the

amounts and disclosures in the financial statements. It

also includes an assessment of the significant estimates

and judgments made by the directors in the preparation of

the financial statements, and of whether the accounting

policies are appropriate to the bank's circumstances" --

MR. PARRAS: Let's move that up, please.

BY MR. PARRAS:

Q. -- "consistently applied and adequately disclosed.

We planned and performed our audit so as to obtain all the

information and explanations which we considered necessary

in order to provide us with sufficient evidence to give

reasonable assurance that the financial statements are

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2032

free from material misstatement, whether caused by fraud

or other irregularity or error."

MR. PARRAS: If you can move that up, please.

BY MR. PARRAS:

Q. "In forming our opinions, we also evaluated the

overall adequacy of the presentation of information in the

financial statements."

MR. PARRAS: Next paragraph please.

BY MR. PARRAS:

Q. And before I go on, the auditor, Mr. Hewlett, his

signature, is telling people that he has reviewed

financial statements, that he has made an independent

judgment about the adequacy of the financial statements,

and is representing that they are free from material

misrepresentations, fraud or other irregularities;

correct?

A. Uh-huh.

Q. Okay. Let's go to his opinion.

"In our opinion, the financial statements

give a true and fair view of the state of the company's

affairs as at 31 December 2000, and of the results of its

operation for the year then ended. They have been

prepared to comply with international accounting and

financial reporting standards and the company's law of

Antigua and Barbuda."

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2033

And then it's signed underneath by

Mr. Hewlett.

Have you had an occasion to go through all

of the annual reports available to you for the SIBL and

GIBL entities while they existed on Antigua?

A. That would have been done, and I cannot recall if I'd

gone through all of the reports, which is your question.

Q. Yes.

A. But I know reviews were made of audited financial

statements prior to the examination which was first

conducted -- the first on-site examination which was

conducted in 2001, I think.

Q. Okay. I think I'm going to break that down because I

think I know what you're saying and I want to be sure;

okay?

A. Uh-huh.

Q. That once your regulatory regime was set up, you

asked the -- whoever you asked, the SIBL or GIBL, whatever

it was at the time, you asked them to give you their

annual reports in preparation for your examination, for

your agency's examination?

A. I think we would have been in possession of them. I

can't be sure. But I think we might have been in

possession. If not of all, of some of them.

Q. Did you ask for other information as well?

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2034

A. There were other documents, pieces of information,

that we would have requested, yes.

Q. And were you provided that information?

A. I don't know. I can't be sure.

Q. If you were not provided that information, would you

have correspondence about it?

A. There ought to have been, yes.

Q. Did you bring any correspondence with that regard

with you to the U.S. from Antigua?

A. No.

Q. Did you bring any records from the Island of Antigua

to the U.S. for your preparation and testimony here today?

A. Any documents, no.

Q. Did you bring any reports, notes, memos, exams,

anything in writing, that would help you to prepare for

your testimony here today?

A. I do have a document that I made some notes on, yes.

Q. Where is that document now?

A. That's in my possession.

THE COURT: All right. Counsel, this may be a

time to take a break. We began about 10, 12 minutes,

15 minutes behind schedule, so some folks have been out

they're here for our hour and three-quarters.

MR. WARREN: Before we could take a break, I'm

not sure if counsel is coming back to those documents, but

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2035

we would just ask for an instruction reminding the jury

that those annual reports have not been admitted for the

truth, but only as to what the investors were told.

THE COURT: That's so noted. That's so noted.

Let me get the screen up.

Okay. We'll see you back ready to resume

in 15 minutes. See you at that time.

(Recessed at 11:41 a.m.)

THE COURT: Tell the jury we'll be with them in

about a minute.

Have a seat. What have you got to bring

up?

MR. WARREN: Your Honor, Mr. Parras handed me

two documents, one he handed me at 10:00 o'clock this

morning, the other one he handed me after the court broke,

that he intends to use on cross-examination.

Just note for the Court these weren't

produced in a timely matter as with the Court's order from

last week. They've had more than a week's notice with

Ms. Crick. These are not surprise documents. This goes --

one of them is part of her testimony. The other is

actually beyond the scope of direct in the first place.

But we would just note our objection to counsel using these

documents.

THE COURT: Wait a second. Not note your

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2036

objection, do you object?

MR. WARREN: Yeah, we do object.

THE COURT: Okay. What's the first one, the

left hand, what's that?

MR. WARREN: This document is a letter from

November 29, 2000, regarding a certificate of good standing

that Ms. Crick issued regarding some of the directors of

the bank.

THE COURT: Okay. Have you ever seen those

before -- that before?

MR. WARREN: I've seen this document before,

Your Honor.

THE COURT: But you didn't know it was coming

here?

MR. WARREN: Did not.

THE COURT: What's the other one?

MR. WARREN: The other one I don't believe I've

ever seen before. It's from 1999. This was a document

just handed to me maybe ten minutes ago that has to do with

the growth of the international business corporations.

Mr. Parras went into that on cross-examination. It's

beyond the scope.

THE COURT: Aside from that, had you ever seen

it before?

MR. WARREN: No, Your Honor.

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2037

THE COURT: What's your response?

MR. PARRAS: As to the first document, Judge,

it is a document that was produced to us by the government.

The reason that it is --

THE COURT: First document objection is

overruled.

MR. PARRAS: The second one, Judge, we did talk

about it --

THE COURT: Now, hold it. Let me make a note

on that.

And you've got a list, Ellen, and so do I.

That was -- that's defense document;

correct? Mr. Parras?

MR. PARRAS: Yes, Judge.

THE COURT: What number is it?

MR. PARRAS: I haven't given it a number. I

think we're on 10-1.

THE COURT: I don't know what you're on. You

got 17,000 documents. I don't know what number this is.

MR. PARRAS: Well, we're working to narrow it

down, so we've had to change our numbering system.

THE COURT: Well, you change it down to 100s?

MR. PARRAS: We started to do witnesses --

THE COURT: How many thousands do you have now?

Don't answer that question. I'm looking for hundreds, low

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2038

hundreds. Hold it. Give it a number. Anybody.

MR. WARREN: 15,742, Your Honor.

THE COURT: That's a good number. Give me a

number eventually.

But, Ellen, I'm going to put a blank

there. That is admitted.

The other one?

MR. PARRAS: The second one, Judge, they're

correct, we have -- this is not from their production. It

is a letter that we talked about on cross-examination, and

it basically outlines the 30 points that the board,

regulatory board, was asking Ms. Crick to complete that she

talked as being lengthy and probably some of these not

being possible within the time given. I just want to get

it in to support the testimony.

THE COURT: Objection sustained as to that

second document.

All right. Are we ready to call the jury

in?

MR. WARREN: Nothing further from the

government, Your Honor.

THE COURT: All right. Let's go.


THE COURT: Before we get going, I've stopped

the clock. A 30-second story, a 30-second short note, the

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2039

comment was about wearing wigs. There's a book that was

just recently published by former Supreme Court Justice

John Paul Stevens. He was on the court for 30 years. I

had met him on a number of occasions. Wonderful man.

It's entitled five chiefs, about the five

chief justices either he worked for or knew. And there was

a story that he told when Associate Justice William

Rehnquist became the chief justice. A couple of months

after he was chief, he showed up one time with a robe that

had four gold stripes sewn into the sleeves. And

apparently they were talking about it behind the scenes of

the Court. Of course, no one ever complained to the chief.

But it was a from a Gilbert -- the chief had seen it years

ago in a Gilbert & Sullivan production, and in that

production by that cast, there was a judge and he was

wearing a robe with four stripes. So for his tenure on the

Court, that's what he did.

And we've asked -- what is it -- Chief

Justice Roberts -- or at least Chief Justice Roberts does

not wear one. He became chief. He's now in plain black

robe.

So it's just a little story about what

goes on at the high 9. Fascinating book. It's a short

book, but it was most enjoyable.

With that, now that that is over and done

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2040

with, defense time begins. Go on.

MR. PARRAS: Thank you, Judge.

BY MR. PARRAS:

Q. Last year, Ms. Crick, okay? It's about your work as

a regulator on the island of Antigua, and I want to go a

little bit backwards to the spring of 1999.

If we remember correctly, in November you

wrote your first report, in February you wrote your second

report, and then sometime later, about April, there was a

response from the board with the 30 points, that you took

issue with some of them, but there's no doubt there were

approximately 30 points. And these were tasks that the

board felt you should complete so that the regulatory

agency could be set up and start working for the island;

correct?

A. Basically, yes, uh-huh.

Q. Each one of those tasks required money so that the

infrastructure and implementation could be put into place;

right.

A. That's not true.

Q. Well, let's talk about some of the tasks. You

certainly wanted to get an Internet system up for your

regulatory agency so that people could become licensed

over the Internet, that would be easier for people

offshore to become incorporated on the island; correct?

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2041

A. As a general requirement, yes, it's part of the task.

I don't recall that being in terms of a priority. Might

have been, but I don't recall it being a priority.

Q. Would it help you or help you to remember if you were

to look at the memo itself?

A. Yes, it would.

Q. Okay. I'm going to hand you this, and I'm just going

to ask you to look at it, read it to yourself, and when

you're done, let me know, okay?

A. (Reading document.)

Q. Have you finished, ma'am?

A. Yes, appears to.

Q. Did it help you to remember some of the things that

the board --

A. Yes, it did. It did.

Q. Go ahead and tell the jury the kinds of things that

the board wanted you to complete so that your agency could

start doing its work.

A. Prepare, recruit staff, train staff, improve the --

as you mentioned before, the services that would be

provided by an Internet platform. Prepare budget to

support the overall development and, in fact, a budget for

each of the various items.

Q. And --

A. The other information on some various offshore

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2042

sectors on the development of the sector, the industry in

the region. I did a quick read, so I'm really just trying

to --

Q. It's fair to say that there were a number of other

requests, but the bottom line was they wanted you to get a

regulatory agency in place and to hit the ground running;

correct?

A. You could say that.

Q. And you ended up doing that, didn't you?

A. Putting -- to some extent, yes.

Q. You hired staff?

A. Yes, I did.

Q. Staff that you felt were adequate to the task;

correct?

A. Recommended, yes, uh-huh, but a staff -- interview

staff that I thought would have been -- had the skill

sets, yes.

Q. And when do you think it was that you and your

regulatory agency started to examine the businesses under

your jurisdiction?

A. It would have been sometime 2000, 2001.

Q. Okay. I want to talk specifically now about SIBL.

You testified yesterday about the first examination, a

gentleman named Mr. Quelley and others were sent out

Mr. Quelley -- you got a call about Mr. Quelley, and the

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2043

next thing you know -- the next thing you told us was that

you were on a tour of the Caribbean with Mr. Quelley,

yourself and a gentleman named Mr. Ferrance?

A. Yes, uh-huh.

Q. That was the first examination of Stanford

International Bank?

A. That I can recall.

Q. Do you remember approximately what time of the year

that was?

A. It was sometime in August or September of 2001.

Q. And did you do a subsequent examination -- August or

September, would that have been with Francis De Abreu?

A. Yeah, De Abreu, yes.

Q. And Peter Quelley was the junior examiner on that?

A. Yes, uh-huh.

Q. And Trevor Bailey was the senior examiner on that

team; correct?

A. Not initially, no.

Q. After Mr. Quelley taken off, then Mr. Trevor

Bailey became --

A. That's correct.

Q. Before we get there, did you have occasion to examine

Stanford International Bank and its directors once you had

your regulatory agency up and running because they

requested a certificate of good standing?

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2044

A. To examine them, I don't recall that.

Q. Do you think it would refresh your recollection to

see some correspondence?

A. Sure.

Q. Maybe we can do it this way. You can keep reading.

Do you recognize this document?

A. Yes. I'm the author of the document.

Q. It's something you -- it's your signature?

A. Yes, uh-huh.

Q. Do you remember writing it?

A. Yes.

MR. PARRAS: Move to admit Defendant's

Exhibit --

THE COURT: Is that the one we don't have a

number for yet?

MR. PARRAS: We're going to give this one -- it

is Judge. That's exactly the one. We're going to give it

10-1.

THE COURT: 10-1?

MR. PARRAS: Yes.

THE COURT: 10-1, we've already discussed it.

It's admitted.

MR. PARRAS: Let me put this on the board,

please, the ELMO.

MR. WARREN: Your Honor, we have an objection

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2045

just to the copy we have as handwritten comments on it, I'm

not sure if those handwritten comments have been

authenticated. I don't know whose they are.

MR. PARRAS: I'll try to clear it up, Judge,

before I show it to the jury.

THE COURT: Okay.

BY MR. PARRAS:

Q. Ms. Crick, do you recognize the handwriting there on

the left margin as yours?

A. No.

Q. Do you recognize it as someone in your agency?

A. No, not that I can recall right off, no.

MR. PARRAS: Judge, I'll redact that portion

out.

THE COURT: Do you want to put a sticker over

it or something?

MR. PARRAS: I'm going to grab something from

my bag.

Okay. If I can have the ELMO, Judge.


BY MR. PARRAS:

Q. Do you recognize that, Ms. Crick, as the letterhead

for the agency that you were the executive director of?

A. Yes.

Q. And I'm going to start reading -- this is addressed

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2046

to Stanford International Bank; correct?

A. Yes.

Q. And I'm going to start reading there. "We knowledge

receipt of your request for a certificate of good standing

made on November 23, 2000. We wish to inform you,

however, that a letter requesting approval of Sir Courtney

Blackman and Mr. Robert Winter as directors should be

submitted to the authority. In accordance with Section 10

of the statutory instruments number 41 of 1998 of the

International Business Corporations Act Number 28 of" --

THE COURT: Slow down a little bit.

BY MR. PARRAS:

Q. -- "1982 as amended, which states: No licensed

institution shall make a change to its directors or the

director or indirect legal or beneficial owner of

5 percent or more of a class of shares in the institution

without the prior approval from the authority."

I'm going to stop right there, stop

reading.

What you were telling Stanford

International Bank is before you should issue a letter of

good standing, it had to comply with some statutory

requirements that you were now in charge of enforcing;

correct?

A. That's correct, uh-huh.

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2047

Q. And specifically in this paragraph, they needed to

give you more information about Sir Courtney Blackman and

Mr. Robert Winter; correct?

A. Not more information. They needed to obtain -- they

needed to request approval because they were coming on.

There was a change in directors, and they had not made

that request.

Q. Okay. Next paragraph. "Additionally, the following

information is outstanding for Courtney Blackman: One

professional reference, and this is in addition to the one

on file, a statement whether Sir Blackman has ever been

formally charged or indicted with the commission of a

crime, criminal offense in any jurisdiction, and if so a

description of the offense charged and a statement of the

outcome of the charge. Three, a letter from Sir Blackman

accepting the position as the director of the bank."

These requirements -- I'm going to stop

there. Turn to Page 2 and ask you some questions.

These requirements were requests by you as

the regulator for more information; correct?

A. Yes.

Q. The application that a International Corporation has

to fill out only requires that you list the names and

addresses of the boards of directors; correct?

A. The application for?

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2048

Q. Application for incorporation under the IBC Act. If

you know. If you don't know --

A. It only requires the name of the -- an address of the

directors.

Q. Well, it actually has four or five statutory

requirements, but when it comes to the names of the

directors or the identity of the directors, the only thing

that's asked about the directors are their names and

addresses; correct?

A. On the form itself, that's possible.

Q. However --

A. I can't recall the contents of the form immediately,

but --

Q. Okay.

A. -- that's possible.

Q. Okay. If you wanted to ask for more information, you

have the power to do so; right?

A. That is correct.

Q. And what you're doing here in this letter is

exercising that power to a degree; correct?

A. Yes.

Q. It's not required anywhere on the application that

you say whether you've been in a discharged bankruptcy,

whether you have never been in bankruptcy, whether --

that's something that's not asked on the form; correct?

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2049

A. It depends on which form you're referring to, because

there is the form you just described, but there is also,

if I remember correctly, a form that lists additional

details about the applicant.

Q. Okay. What about the statute? The statute doesn't

require that you turn in that information when you file

your application; correct?

A. It does not, but it does say that upon applying, the

supervisor can -- it makes provision, let me say, for the

supervisor to request any information.

Q. And that's the point I'm trying to make. It makes

provision for the supervisor to request information. It

does not put the duty on the applicant to report the

information; correct?

A. No, that's not correct.

Q. Would it help you to look at the act itself?

A. If I may be allowed to explain.

Q. Would it help you to look at the act --

A. I'm trying to assist you. If I could explain.

THE COURT: But that's up to the attorney.

Do you want to allow her to explain or are

you going to go on to the next question? Either way it's

okay. It's cross-examination. Go on.

BY MR. PARRAS:

Q. If I could show you something, it may refresh your

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2050

recollection, perhaps you could point me to what you're

talking about.

A. Sure. Uh-huh.

Yes, I've read it.

Q. Okay. It's true that within the application itself,

the statutory application, that information is not

required; correct?


Q. What subsection do you think applies --

A. 232.

Q. And I'm getting there.

MR. PARRAS: Judge --

BY MR. PARRAS:

Q. Do you recognize what's in front of you, ma'am, what

you're reading?

A. It's a section from the International Business

Corporations Act.

Q. Do you have any reason to believe that it's

inaccurate or not the actual language of the act itself?

A. I'm not in a position to say that just looking at

this document, no.

Q. Okay. What -- from your memory, okay, from your

memory, what is Section 231 titled?

A. Section 231 is -- it's not even titled.

Q. Is it titled Formalities?

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2051

A. I don't have this before me.

Q. Let's go this way: Does Section 231 list five

requirements for the application?

A. Along -- yes, along with Section 232.

Q. And I'll get to 232. Let's just talk about 231.

A. Okay. Fair enough. 231.

Q. Among the five subsections, is there any requirement

that you indicate whether you've ever been in a

bankruptcy?

A. No, it does not make an indication there.

Q. And Section 232 is a section that applies to the

regulator on receipt of the application; correct?


MR. PARRAS: Judge, I move to admit this as

Defendant's 10-2. I provided to the government early this

morning. It's something that I had not --

THE COURT: Wait a second. Did I rule on that

already?

MR. WARREN: It's a different document, Your

Honor.

THE COURT: It's a different document. Okay.

Go on.

You move to admit 10-2. No.

What's the position of the government?

MR. WARREN: Objection, Your Honor.

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2052

THE COURT: Why?

MR. WARREN: Well, for one, it was given to us

just earlier this morning in violation of the Court's prior

order.

Also, it hasn't been authenticated. It's

hearsay. The witness said she doesn't know whether it's

authentic.

THE COURT: Sustained.

BY MR. PARRAS:

Q. Ma'am, you're the regulator for the Antiguan

government regarding the IBC Act; correct? As it applies

to international corporations?

A. Yes.

Q. Is it your testimony that Section 232 of the statutes

that you regulate does not apply upon receipt of an

application?

A. Yes.

Q. It's clear to you that, once an application is filed,

you have the power to ask for more information if you want

to; correct?

A. That is correct.

Q. Okay. Let's go back to this letter that is in

evidence.

Defendant's Exhibit 10-1, third paragraph,

second page.

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2053

"The following information is needed for

Mr. Winter:

"A complete and up-to-date curriculum

vitae.

"Two references from well-established

banks stating the nature and extent of their knowledge of

and experience with him.

"A legible copy of Mr. Winter's passport

containing his photograph, as well as the passport numbers

and date and place of issue.

"One professional reference should be

submitted. Please note that this is in addition to the one

previously submitted.

"A letter from Mr. Winter accepting the

position as director of the bank.

"You are hereby requested to submit the

outstanding information as soon as possible so as to

complete the processing of the certificate of good

standing. Please be guided accordingly.

"Respectfully, M. Althea Crick, Executive

Director."

Did I read that correctly?

A. That's correct.

Q. You were asking for more information; correct?

A. Yes.

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Q. You didn't ask for information about Mr. Allen

Stanford, did you?

A. No. This letter does not.

Q. You could have asked for information about Mr. Allen

Stanford; right?

A. I could have asked for information for him, yes, if

it was necessary.

Q. If it was necessary.

So you didn't think it was necessary to

later on certify this --

THE COURT: Look at the witness. Don't argue

it to the jury. They're listening.

BY MR. PARRAS:

Q. You didn't think that it was necessary to ask for

more information beyond this letter so that you could

eventually issue a certificate of good standing; correct?

A. Correct.

Q. And eventually, you did issue a certificate of good

standing; correct?

A. That is correct, in keeping with what it is that the

certificate of good standing actually states.

Q. Okay. We talked about the first examination. And

it's true that, in addition to regulating the banks and

offshore companies on Antigua, you started to seek out

agreements with other jurisdictions on

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2055

information-sharing; correct?

A. That's one of the things we did, yes.

Q. And what you did in July of 2001 is, you reached out

to the State of Texas and you entered into the first

agreement between Texas and a foreign entity to share

information; correct?

A. That is correct.

Q. You were proud of that? That was had a good thing,

wasn't it?

A. Yes, it was a good thing.

Q. I'm going to show you what's been marked as


And if you could look at it and let me

know if you recognize it, please.

A. Yes, I'm familiar with the document.

Q. Okay. While we're at it, let me show you what's been

marked as Government's Exhibit 615.

Also look through that and see if you

recognize it.

A. Yes.

Q. Speaking about Government's 666, is that something

that your agency produced?

A. Yes.

Q. Okay. And then and speaking about Government's

Exhibit 615, is that something that you received in your

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2056

capacity as the executive director?

A. Yes.

MR. PARRAS: Move to admit Government's

Exhibit --

THE COURT: It's already in. All of the

Government's exhibits are in subject to the defense

specifically objecting to when it's referenced. So go

right ahead.


BY MR. PARRAS:

Q. Let me show you the dates on both of these quickly so

that we could start with the first one.

Looking at Government's Exhibit 666. This

is --

MR. PARRAS: Let's go to the top here.

BY MR. PARRAS:

Q. -- a confidential report, violations and

recommendations for examination of Stanford International

Bank; correct?

A. Yes.

Q. And down here, it says "Examined by," and then it

lists the names and has dates; correct?

A. That is correct.

Q. And the dates are August through September 2001;

right?

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2057

A. Yes.

Q. Do you recognize this as the first report of the

first exam of Stanford International Bank?

A. I believe it is, yes.

Q. Okay. And if we were to flip through Government's

Exhibit 666, what we would see -- let me back this up --

is that you have, you and your agency have written a

number of points that you would like the bank, Stanford

International, to address; correct?

A. That is correct.

Q. Now, going to Government's Exhibit 615, dated

November 9, 2001, addressed to Ms. Althea Crick, and

signed by Frans Vingerhoedt.

Do you see that?

A. Yes.

Q. It's true that this letter is a response, a

point-by-point response, to your first exam inquiry;

correct?

A. That is correct.

MR. PARRAS: And at this point, Judge, if I

could have the computer turned on back there. So I need

the help of the ladies. Thank you.

BY MR. PARRAS:

Q. I want to go back through these two documents,

Government's Exhibit 666 on your left and Government's

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2058

Exhibit 615 on your right. And I think that when they

come up, they're either going to be either side-by-side or

top and bottom, and we'll be able to -- I hope we'll be

able to tell which one is your report and which one is the

response.

MR. PARRAS: Next slide, please.

BY MR. PARRAS:

Q. All right. Looking at Section 1.1. Do you recognize

the top portion as the -- coming from your report,

Government's Exhibit 666?

Do you recognize the top portion as coming

from your report, Ms. Crick?

A. Yes.

Q. And the bottom is coming from the response; correct?

A. Yes.

Q. And these are in evidence, so the jury will have them

to read.

But the complaint that you're telling SIB

about is that some of the loans did not have a purpose

identified on the paperwork; correct?

A. It speaks to loan application forms having not been

seen in all the files examined.

Q. And the second sentence says, "The examiners were

unable to establish the purpose of the loan in order to

verify compliance with the IBC Act; correct?

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2059

A. Yes.

Q. And the response of the bank was -- is there at the

bottom, and I'll read it: "Loan portfolio

administration."

"Current loan request/application forms,

implemented in 1998 are mandatory for all new loans,

include a section for specification of the purpose of the

loan. Your recommendation is fully implemented."

Are they telling you that before 1998,

you're right, we have some problems and we're fixing them?

Is that basically what they're saying?

A. It says that they have -- they have now complied with

our recommendation, yes.

Q. And if we were to go through the letters together and

I'll just go through these slides --

MR. PARRAS: Next slide, please. 2.1, 2.1,

next slide, please. 2.2, 2.2, next slide, please. And try

to line up the paragraphs here, same 2.2, next slide,

please, 2.3. Next slide. And if you could scroll through

the rest of the slide, please.

THE COURT: We don't have to. What's your

question? Let's assume she's scrolling through them. If

anybody wants to watch, you can scroll through them.

Just ask her the question.

BY MR. PARRAS:

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2060

Q. The process that you set up, everything that you were

trying to do, was finally working, wasn't it?

A. I wouldn't say that.

Q. Well, you were making queries of banks and they were

responding and you were going back and forth implementing

the regulations that finally came into existence; correct?

A. We were conducting examinations, yes. We had started

the process.

Q. Okay. And then you told this jury that, in 2002, you

left the -- you decided not to reapply under circumstances

that you've already described; correct?

A. Not to apply, yes.

Q. Your decision; right?

A. That was my decision.

Q. No one forced you to not apply; correct?

A. No one forced me.

Q. And you don't go back to the FSRC until April

of 2009; correct?

A. That is correct.

Q. And that's your current position: Executive director

of the FSRC; right?

A. Current position is chairman of the board of

directors.

Q. Do you have business outside of that position?

A. Yes, I do.

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2061

Q. Do you have banks as clients?

A. No, I don't, not currently. I have had banks as

clients, yes.

Q. While you were the chairman of the board of the FSRC?

A. No.

Q. Okay. While you were chairman of the board of the

FSRC, do you do any work with people who are regulated by

your body?

A. No.

Q. If you could give me a minute, please, ma'am.

MR. PARRAS: Thank you, Ms. Crick.

I have no further questions.

THE COURT: Government is next, they keep going

back and forth until they have no more questions. You

can't get up and leave.

MR. PARRAS: He might ask you questions.

THE COURT: That's what I mean. The government

is next.

THE WITNESS: Oh, sorry.

THE COURT: We go back and forth or until they

have no more questions, or until I say that's all.

THE WITNESS: Okay.

THE COURT: Michelle can get it for you. Is it

the top button or the front button? Okay. Thank you.

All right, Counsel. Go on.

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Redirect-Crick/By Mr.Warren


2062


REDIRECT EXAMINATION

BY MR. WARREN:

Q. Ms. Crick, do you still have Government's Exhibit 615

in front of you?

MR. WARREN: If you would pull it up.

Your Honor, can you switch the --

THE COURT: Okay. To yours.

MR. WARREN: To the computer, please?

THE WITNESS: Yes, I do.

BY MR. WARREN:

Q. Ms. Crick, what's the date of this letter?

A. November 9, 2001.

Q. And who sent it to you?

A. Mr. Frans Fingervoedt.

Q. And he was the president and CEO of the bank at the

time?

A. Yes, he was.

Q. And in Section 1, as Mr. Parras just asked you,

they're telling you that all the information about the

loans has been fully implemented, right, and now it's been

provided for the FSRC to roll up to speed about everything

on their loan portfolio?

A. All they're saying is that we have now put this in

place. Thereby the applications are on file. That's the

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2063

extent of what that is saying.

Q. Ms. Crick, I'm handing you what's been marked as


MR. WARREN: If there are no objections, Your

Honor, I'd ask that it be published.

THE COURT: Just keep going. On any of these,

just keep going unless we hear an objection.

That's 334; correct?

MR. WARREN: That top paragraph is fine. Thank

you.

BY MR. WARREN:

Q. Ms. Crick, do you see the date of this document?

A. Yes, I do.

Q. What's the date of it?

A. December 31, 2000.

Q. And if you could please read that first paragraph

starting with the words "promissory note."

A. "Promissory note. For value received, R. Allen

Stanford [hereinafter called 'Maker'] promises to pay to

the order of Stanford International Bank, Limited, at its

office located at 2000 Airport Boulevard, St. John's,

Antigua, West Indies [hereinafter called 'Payee'] the

principal sum of 59,500,000 no cents, U.S. dollars,"

59,500,000 in numbers, "[the 'Loan'] together with any

unpaid interest at the rate and on the terms set forth

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2064

herein, as follows."

Q. Ms. Crick, would you agree with me that this is a

promissory note from Mr. Stanford in the amount of

$59.5 million?

A. It is.

Q. Was this ever disclosed to the FSRC?

A. Not to my knowledge.

Q. Ms. Crick you were asked a series of questions about

the examination of the bank in 2001 and the report which

is Government's Exhibit 666 that resulted from that

examination.

Do you recall those questions?

A. Yes.

Q. Were you there throughout the end of the examination?

A. No, I was not.

Q. Can you remind the jury why you weren't there?

A. Along with Mr. Queeley and Mr. Ferrance, I had been

asked to travel outside the island to visit several of the

islands in the region.

Q. That was that hastily arranged trip?

A. The hastily arranged trip. I was not present

throughout the course of that examination.

Q. And you testified yesterday that Mr. Bailey replaced

you on the examination; correct?

A. He replaced Mr. Queeley, yes.

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2065

Q. Do you know that Mr. Bailey went to work for

Mr. Stanford after he left the FSRC?

A. I, in recent times, subsequently learned that, yes.

Q. And he became the examiner after you and Mr. Queeley

were sent off island; correct?

A. That is correct.

Q. Do you recall Mr. Parras asking you about the IBC and

the statutes and what it requires the disclosure of?

A. Yes.

Q. Does the IBC -- is that the exhaustive statute

regulating the banking sector?

A. The banking sector as a whole, no.

Q. There are regulations that regulatory body can pass

in furtherance of its regulations, in furtherance of its

duties?

A. There is.

Q. And do you recall Section 231 that Mr. Parras showed

you?

A. Yes.

Q. Can you quote verbatim what Section 231 says? Off

your memory. I'm not asking you to read off the document.

MR. PARRAS: Judge, I have no objection to

admitting this into evidence.

MR. WARREN: I'm not offering it into evidence,

Your Honor.

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2066

THE COURT: Okay.

BY MR. WARREN:

Q. Ms. Crick, I'm handing you what you had seen before.

I direct your attention to Subparagraph (e) at

Section 231.

A. Yes.

Q. And look at that for a minute and I'll take it back

from you.

A. Uh-huh.

Q. Are you aware of any regulation that would require

the directors or owners of a bank to disclose other

relevant financial information for their application?

A. Yes.

Q. Would a prior bankruptcy be included in that

information that's required to be disclosed to the

regulatory body?

A. If I recall correctly, yes.

Q. Do you recall being asked some questions, a lot of

questions, about the judicial opinion from Montserrat?

A. Yes.

MR. WARREN: If we could show Government's

Exhibit 511, please.

BY MR. WARREN:

Q. Ms. Crick, what is the date of this document? This

is the one we looked at before about the notice of

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2067

revocation.

A. 28 November 1990.

Q. If we could please turn to Defense Exhibit -- and I

don't have the number offhand. It's the?

MR. COSTA: 2-14.

THE COURT: Thank you.

MR. WARREN: Could you use the overhead for

that, please.

Your Honor, if we could switch to the

easel -- I'm sorry. To the -- let's go to the last page.

BY MR. WARREN:

Q. Ms. Crick, are you able to read -- this is the

government findings that Mr. Parras showed you.

Can you read that second paragraph to the

jury, please?

A. That's Item 2?

Q. Yes?

A. "That the licenses granted to Guardian International

Bank Limited, on 9 January 1986, and the 14th day of

November 1988, could not be revoked by the government in

council since they did not exist."

Q. And based on that document, on what date did Guardian

International Bank surrender its license, if you look at

the paragraph just above?

A. It says it ceased to do business on the 19th of

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2068

December 1990.

Q. Ms. Crick, would you agree with me that they

surrendered their license after they had been notified of

the potential revocation?


Q. Have you ever heard the phrase, "You can't fire me, I

quit"?

A. Yes. I'm familiar with the phrase.

Q. There was some questioning on cross-examination about

the sector committee.

Do you recall that? That was the

nongovernment committee of people that -- private bankers,

et cetera?

A. Yes.

Q. And Mr. Parras asked you questions about you having a

problem with that committee or Mr. Stanford's involvement

in that committee.

That wasn't the committee you had a

problem with his involvement in; right?

A. No, it was not.

Q. You testified yesterday on direct that Mr. Stanford

was a part of what regulatory body when you joined in

1998?

A. When I joined in '98, he was part of the -- the

Financial Services Sectoral Committee.

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2069

Q. And you had a problem with that; right?

A. The sectoral committee?

Q. No, not with the sectoral committee, with the -- I'm

sorry.

Was Mr. Stanford a part of the FSRC, a

member of the board of the FSRC when you joined?

A. When I joined in '98, there was not yet a board.

Q. And what was it that you had -- what position did

Mr. Stanford have that you testified about to yesterday

that you raised concerns about when you joined in 1998?

A. There were -- there were two areas of concern. Prior

to 19 -- November 1998, my interaction was with the

sectoral committee.

Q. Ms. Crick, I'm sorry. If I could just focus you.

A. Okay.

Q. What -- did Mr. Stanford have any position with any

government agency or regulatory body when you joined in

1998 that caused you concern?

A. No.

Q. We were discussing -- counsel asked you on

cross-examination about Operation Clean Slate.

Who bank-rolled Operation Clean Slate?

A. Allen Stanford.

Q. Did -- as part of Operation Clean Slate, was there

legislation passed regarding the banking sector and

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2070

anti-money laundering in general in Antigua?

A. As part of Operation Clean Slate, yes. There were

amendments to the --

THE COURT: Excuse me. Yes, sir.

MR. PARRAS: Judge, I object. Lack of personal

knowledge.

On my examination, she said she didn't

know what Operation Clean Slate meant.

THE COURT: Do you want to respond to that?

MR. WARREN: I'm sorry, Your Honor. What was

the basis for the objection?

THE COURT: He said that on his examination,

she said she didn't know about Clean Slate.

MR. PARRAS: About what it did.

THE COURT: What it did.

BY MR. WARREN:

Q. I'm asking whether during that time period,

Ms. Crick, there was legislation passed regarding the

industry we've been discussing?

A. That is correct.

MR. PARRAS: Object to the form of the

question. I believe he's tying Operation Clean Slate with

a --

THE COURT: Again, I didn't hear an answer to

that question, but I'll sustain the objection as to the

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2071

first question. He restated it. If you need to get back

into it, I'll consider it.

BY MR. WARREN:

Q. Is that legislation still in effect?

A. No, it's not.

Q. What happened to it?

A. It was repealed in its entirety.

Q. Why?

THE COURT: The question is: Why was it

repealed; correct?

THE WITNESS: Yes. The legislation was

repealed for several reasons. Reason number one was

concerned about the author of the amendments.

THE COURT: Who was the author?

THE WITNESS: Mr. Patrick O'Brien.

BY MR. WARREN:

Q. Who did Mr. O'Brien work for at the time, as you

understood?

A. Allen Stanford.

Q. What was reason number two?

A. Reason number two was the thinking at the time that

the legislation might have in some respect weakened the

regulatory regime.

Q. And what was reason number three?

A. Reason number three was a general concern about the

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2072

amendments that had been coming to the government from the

international community.

Q. Ms. Crick, with regard to Operation Clean Slate, that

was when your files were taken from you; right?

A. Yes.

Q. Did it help or hinder your function as an Antiguan

regulator when Mr. Scardino took those files?

MR. PARRAS: Objection. Form of the question.

THE COURT: Sustained. Just rephrase it.

BY MR. WARREN:

Q. Did it help or render your work whether those files

were taken?

A. Hindered.

Q. A moment ago we were talking about Mr. Stanford's

position when you came on to the commission, the

commission's predecessor in 1998, and I was asking you if

Mr. Stanford had any positions at that time.

Did Mr. Stanford have any positions with a

regulatory body on the board of a government department

before you came on?

A. No.

Q. You were asked questions about bank secrecy on

cross-examination. Do you recall that?

A. Yes.

Q. When Mr. Parras asked you whether it would be good or

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2073

bad business, if you knew, to give the bank's competitors

information about where its assets were located, do you

recall that?

A. Yes.

MR. WARREN: If we could look at Exhibit 218,

please.

Your Honor, if you could switch to the

computer, please.

THE COURT: Yes.

MR. WARREN: Page 21.

Can we focus again on the two paragraphs

we looked at before on the right-hand side of the page --

I'm sorry -- the left-hand side of the page.

Thank you.

BY MR. WARREN:

Q. Ms. Crick, I won't ask you to read these again out

loud, but do you see anything in there about the bank

saying it can't turn over its assets or its positions

because it would be bad to give that information to

competitors?

A. No, I don't see that.

Q. Instead, you see information that it says the bank

can't disclose that information because of Antiguan

regulations; isn't that correct?

A. That is correct.

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2074

Q. And is that statement accurate?

A. It is not.

Q. Mr. Parras also suggested during cross-examination

that there were other jurisdictions that may have these

limitations. Where was the Stanford International Bank

located during this time?

A. In Antigua.

Q. Ms. Crick, you were asked some questions about

Mr. Hewlett on cross-examination. Do you recall that?

A. Yes, I do.

Q. And you were shown annual reports from the years

where you were at the commission where Mr. Hewlett had

certified to the statements. Do you recall that?

A. Yes.

Q. And Mr. Hewlett in his certification, as Mr. Parras

read, said that he formed an independent opinion as to the

accuracy of the financial statements?

A. That is correct.

Q. And Mr. Parras asked you about whether the FSRC could

have gone into the bank and asked for documents; right?

A. Yes.

Q. Did the FSRC have access to Mr. Hewlett's private

bank records?

A. No.

Q. To his personal bank account information?

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2075

A. No.

Q. Did the FSRC have access to Mr. Stanford's Swiss bank

account?

MR. PARRAS: At this point object to

argumentative.

THE COURT: Overruled.

THE WITNESS: No, it did not.

BY MR. WARREN:

Q. Did the commission know that Mr. Stanford had been

paying millions of dollars to Mr. Hewlett from its -- a

Swiss bank account to Mr. Hewlett's personal bank account?

MR. PARRAS: Objection, Judge --

THE WITNESS: No.

MR. PARRAS: -- argumentive and leading facts

that are not in evidence.


BY MR. WARREN:

Q. Would information about payments from Mr. Stanford to

Mr. Hewlett have mattered to the commission?

A. Certainly would have.

Q. You were also asked a series of questions on

cross-examination about cricket. Do you remember that?

A. Yes.

Q. Most of which probably have nothing to do with what

we're here for, but --

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2076

MR. PARRAS: Objection, Judge, to sidebar.

This jury is the one that's going to decide what it has to

do with why we're here.

THE COURT: Jury will decide.

BY MR. WARREN:

Q. You were asked questions about Mr. Stanford trying to

revise the cricket industry. Do you recall that?

A. Yes.

THE COURT: That it was the finest cricket

field in the world and you weren't sure; right? I

remember, too. Okay. Just like the jury does.

BY MR. WARREN:

Q. Ms. Crick, was it ever disclosed to the FSRC or any

of its predecessors that Mr. Stanford was using investor

funds from the purchase of CDs to fund his promotion of

cricket?

MR. PARRAS: Objection, Judge, assumes facts

that are not in evidence and argumentative.

THE COURT: Hang on one second.

Let me hear the -- I listened, but I want

to hear it one more time.

Johnny, read that back, please.

(Requested portion was read.)

THE COURT: All right. For the purpose of this

witness, sustain the objection.

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2077

BY MR. WARREN:

Q. Were there any disclosure to the FSRC about how

Mr. Stanford was paying for his promotion of cricket?

A. No, there was no disclosure.

MR. WARREN: If we turn to Government's


THE COURT: All right. After you get through

with this exhibit, we'll take a break.


THE COURT: Going up there. We'll talk about

this exhibit, if that's a good time.

MR. WARREN: That will be a good stopping

point, Your Honor.

THE COURT: Okay.

MR. WARREN: Turn to the next -- start with

that page.

BY MR. WARREN:

Q. This is a picture of the Antigua Athletic Club;

right?

A. Yes.

Q. Was the FSRC ever told how this was paid for?

A. No, it was not.

Q. Was it ever told that -- I'm sorry.

Was the FSRC ever told that this building

was paid for through CD investor funds?

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2078

A. No, it was --

MR. PARRAS: Objection, assumes facts not in

evidence, argumentative.

THE COURT: Counsel, how do you get around the

objection? You're making -- you're going into this area,

perhaps I'll allow it. You hear the objection, why don't

you tell me or you want to do it after lunch break?

MR. WARREN: No, Your Honor.

THE COURT: Why don't you do it right now.

Let's talk about it right now.

MR. WARREN: Of course. There's been testimony

about what the FSRC was told and wasn't told in regard to

its examination of the bank. I'm not assuming any facts.

I'm simply asking Ms. Crick if the FSRC was aware of this.

The requirement to ask that sort of a question is a good

faith basis.

Now, if Mr. Parras wants me to, I am happy

to put before the Court my good faith basis for asking

these questions.

THE COURT: Got it.

Your response? Isn't that basically the

rule?

MR. PARRAS: Judge, it is. My response is this

is purely argumentative. This witness is being used as a

ping-pong ball to make the arguments of prosecutors -- of

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2079

the prosecution side.

THE COURT: All right. Let me ask you this:

Would this have been in this witness's ambit of

responsibility if that was known?

MR. WARREN: Yes. The answer is yes to that,

Your Honor.

And also in response to Mr. Parras's

point --

MR. PARRAS: And I have not objected when the

question is asked in that manner.

THE COURT: All right. Let's see if you can

avoid objection. If you can't, then I'll rule, okay? I

may agree with you.


THE COURT: But, however, I agree on one thing

right now. It's almost five after 1:00, and that's our

outer limit. You remember there used to be a TV program,

The Outer Limits. So the first thing we do is raise the

screen, and the second thing we'll do is I'll see you back

at 2:15.

(Recessed at 1:05 p.m.)


THE COURT: All right, Counsel. Go right

ahead.


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2080

BY MR. WARREN:

Q. Ms. Crick, let's go back to Government's

Exhibit 1530, and we're looking at Page 11.

This was a photo that --

MR. WARREN: Your Honor, could you turn on the

overhead for the --

THE COURT: Yes.

MR. WARREN: -- I'm sorry, the computer table.

Thank you.

THE COURT: Which one? The computer table?

MR. WARREN: Yes, sir.

BY MR. WARREN:

Q. Ms. Crick, this was a photo that Mr. Parras showed

you on cross-examination.

Do you recall that?

A. Yes.

Q. Was it ever disclosed to the FSRC that this hangar

was paid for with CD money?

MR. PARRAS: Objection, Judge. Form of the

question. Assumes facts not in evidence. It's

argumentative.

THE COURT: I have concern it -- read it back

one time, Johnny.

(The requested portion was read.)

THE COURT: I'm going to take it question and

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2081

answer. Sustained as to that question. I'm not saying you

can't go into this generally based upon what we talked

about after the jury left. I'll go question and answer on

it.

BY MR. WARREN:

Q. Ms. Crick, was it ever disclosed to the FSRC how this

hangar was paid for?

MR. PARRAS: Judge, objection. If we could get

a timeframe, when she -- personal knowledge. And same

objections, also.


THE WITNESS: No, it was not.

BY MR. WARREN:

Q. If we could turn to Page 9.

Do you recognize this?

A. No, I do not.

Q. Will you turn to Page 3.

Do you recognize the Sticky Wicket?

A. Yes, I do.

Q. What's the Sticky Wicket?

A. The Sticky Wicket is a restaurant located at the

airport owned by Mr. Allen Stanford.

THE COURT: When they say "Sticky Wicket,"

that's kind of an idiomatic expression in the United

States. A wicket is those -- in effect, for want of a

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2082

better, that sticks behind, what we call the catcher, isn't

it, or be in front of a catcher in a game of cricket;

right? Aren't the wickets the sticks in the ground?

THE WITNESS: A Sticky Wicket.

THE COURT: No. No. Not a stick wicket.

THE WITNESS: Uh-huh.

THE COURT: Okay. Now that's what a wicket is.

What is a sticky wicket.

THE WITNESS: Okay. The entire area between

the two sets of wickets is the area that's being referred

to, and if it is that area, the pitch as we speak, the

pitch between the two sets of three stumps that we call a

wicket, the two sets, the pitch between those two sets of

wickets --

THE COURT: You mean the dirt?

THE WITNESS: The dirt; right.

-- can prevent a problem if it is -- if

it's been raining, it's awkward to run on, and for the

bowlers to bowl. So if you're on a sticky wicket, you're

on a wicket -- in a situation that's very awkward, very --

THE COURT: And a bowler is the pitcher; right?

THE WITNESS: The equivalent of, yes. Uh-huh.

THE COURT: All right. I never knew where it

came from. Thank you.

THE WITNESS: You're welcome.

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2083

THE COURT: Go on. Stole a minute of the

government's time. It's a minute, but.

Thank you, Counsel.

MR. WARREN: Of course, Your Honor.

THE COURT: Go on.

BY MR. WARREN:

Q. A sticky wicket refers to an awkward situation on the

pitch?

A. Basically, yes.

Q. How interesting.

Ms. Crick, was it ever disclosed to the

FSRC that the Sticky Wicket was paid for through CD

investor funds?

MR. PARRAS: Same objection, Judge.

THE WITNESS: No.

THE COURT: Hold it. I think the bottom

line -- I understand -- I think the jury will pick it up

either way. So I'm going to say overruled. The jury will

pick it up either way, even if you rephrase it.

But, Counsel, you're entitled to a ruling.

It's overruled.

MR. PARRAS: May I have a running objection to

that line of questioning?

THE COURT: No. By that, I mean a running

objection meaning every time the same subject came up, I

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Recross-Crick/By Mr. Parras


2084

know he's got an objection. I'd rather do it question and

answer. Because if there's any slight deviation, I may

agree or disagree.

MR. WARREN: Can we have the question read back

from the record, please.

THE COURT: I think she answered it.

Go on, Johnny.

(The requested testimony was read)

BY MR. WARREN:

Q. I'm sorry. That the Sticky Wicket --

A. Sticky Wicket.

Q. -- was paid for through CD investor funds?

A. No, not to my knowledge, no.


MR. PARRAS: Hopefully briefly, Judge.

THE COURT: Sure.

RECROSS EXAMINATION

BY MR. PARRAS:

Q. Let's start with that last few questions.

Between the years 2002, and the years

2009, you were not a part of the FSRC; correct?

A. That is correct.

Q. And as to those lines of questions about whether it

was ever disclosed, for that time period, if those

buildings, the hangar, the Sticky Wicket, if that was

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2085

built after you left or towards the time -- beginning of

when you left, you wouldn't know whether or not it was

disclosed to the FSRC; correct?

A. I would know, yes.

THE COURT: You would know?

THE WITNESS: I would know even though it's not

that time period.

BY MR. PARRAS:

Q. Okay. And what you -- you would have to be the

accountant for SIBL to know how they disclosed their

investments, let's say, to the FSRC; for example, if they

were on this IB 5 to have put the Sticky Wicket or money

put into the Sticky Wicket into a broad category, you

wouldn't know that from the IB 5; correct?

A. If it's part of an overall investment, I would not

know.

Q. Okay. I want to go to the red head opinion, once

again. And again, this is in evidence so the jury will be

able to look at the entire thing if they'd like to.

I'd like to point out three places; okay?

MR. PARRAS: If I could have the overhead

projector, Judge.

BY MR. PARRAS:

Q. First of all, the reason we're even talking about

this is because of Government's Exhibit 511.

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2086

THE COURT: Just aim the mike at you. Just

turn it around. Okay. Thank you.


BY MR. PARRAS:

Q. The reason we even discuss the Redhead opinion is

because of Government's Exhibit 511, the five reasons that

Montserrat at this time proposed to make an order under

the banking ordinance.

Now, going to Defendant's Exhibit 2-14,

the -- in the High Court of Justice, Colony of Montserrat,

if someone wanted to, they could go to A. Stanford,

0010774, and review the Judge's five grounds on which the

bank's license were purportedly revoked. Those would be

the Grounds 1 through 5, listed in Government's

Exhibit 511.

And I want to go to what the prosecutor

showed you. We are -- A. Stanford 001792.

Do you remember him asking you on redirect

to read this section ending in the fact that the licenses

granted to Guardian International Bank Limited on 9

January 1986, and the 14th day of November 1988, could not

be revoked by the government in council since they did not

exist.

Do you remember that?

A. Yes, I do.

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2087

Q. They did not exist will at the time that the

government attempted to revoke them; correct?

A. I need a refresh on the time the government intended

to revoke them.

Q. Well, this isn't a statement that they never existed,

is it?

A. That's what this statement indicates, yes.

Q. Okay. Well, let's go to the Judge's opinion. This

is the last part. I told you I'd show you three places.

Judge's holding, A. Stanford 0010790.

Judge's holding, "I do hold, therefore, as from the 19th

of December 1990, when the bank surrendered its licenses

to the Ministry of Finance and accepted by the Minister of

Finance, the bank ceased to exist from that date."

You can't cease to exist without existing;

correct?

A. I would think that, yes.

Q. And then just -- I wasn't correct when I said three

places. One last page, front page, first sentence,

"Guardian International Bank Limited was granted a B

banking license on the 9th of January 1986, and an A

banking license on the 14th of November 1988, by the

government of Montserrat."

That's a pretty clear sentence, isn't it?

A. Yes, it is.

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2088

Q. You weren't tempting to mislead this jury and making

them think that the licenses never exist, were you?

Existed, were you?

A. Yes, the license existed.

Q. Okay. As an accountant, do you know what tax

minimization is?

A. Tax minimization?

Q. Uh-huh.

A. I'm familiar with the term, yes.

Q. It's a concept, isn't it, by which companies or

people attempt to reduce their tax liability?

MR. WARREN: Your Honor, I'd object. It's

beyond the scope of the redirect.


BY MR. PARRAS:

Q. Do you remember being shown Government's Exhibit 334

on redirect? This is the promissory note of December 31,

2000.

A. Yes, I do.

Q. Do you know whether this was an attempt by lawyers

and accountants for Mr. Stanford to set up a regulatory or

a reporting regime whereby tax minimization could take

place?

A. I have no knowledge of that.

Q. Okay. It's possible, isn't it?

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2089

A. I suppose anything is possible.

Q. In response to the some of the question about the IBC

Act Section 231(e), your answer was, "If I recall

correctly"; right?

About subsection whether you could ask for

more information, you prefaced your answer with, "If I

could recall correctly."


A. I might have, yes. I don't recall, but I might have,

yes.

Q. The best thing to do would be to go to the act

itself, wouldn't it, to see what it says?

A. Yes, uh-huh.

MR. PARRAS: Judge I move to introduce that

page --

THE COURT: From what?

MR. PARRAS: -- of the exhibit.

BY MR. PARRAS:

Q. That was Section 231; is that correct? And 232,

Ms. Crick?

A. Yes, uh-huh.

Q. Do you have that section up there with you?

A. Yes, I do.

Q. Does it look like a correct statement of the law?

A. It appears to be.

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2090

MR. PARRAS: Move to offer as Defendant's

Exhibit 10-2.

THE COURT: What?

MR. PARRAS: The Sections 231 and 232 of the

IBC Act.

THE COURT: Which act was it?

MR. PARRAS: International Business Act from

Antigua.

THE COURT: In other words, what year? Oh, is

it still in effect? Is that -- ma'am, is it still in

effect?

THE WITNESS: Yes, it's in effect.

THE COURT: Okay. Any objection?

MR. WARREN: We have no objection to those two

sections, Your Honor, if the witness can authenticate that

they're still in effect.

THE COURT: Okay. So it's -- again, that's

10-2; correct? And that's two sections of the law; is that

correct, Counsel?

MR. PARRAS: Yes, Judge.

MR. FAZEL: IBC Act.

THE COURT: Two sections. Okay. Got it.

MR. PARRAS: And Judge, I have a highlighted

copy. I'll mark one for the Court that's not highlighted

and use this one for now.

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2091

THE COURT: Okay.

BY MR. PARRAS:

Q. Let's look at Section 231, Ms. Crick. This is the

one you and I talked about.

And your answer under Subsection (e) is

that "Perhaps the issue of bankruptcy could be construed

to be called for by Subsection (e); "correct?

A. That's not the statement I need made, no.

Q. Tell me what you believe you were asked about

Subsection (e). What was the statement you made about

Subsection (e)?

A. Subsection (e) clearly defines that any other

information can be requested.

Q. And that's the part I want to focus on, the last part

of your sentence. "Can be requested"; correct?

A. Yes.

Q. If we go to subsections (a), (b), (c), (d),

there's -- those are things that the applicant must

provide; correct?

A. Must provide once the request is made.

Q. Okay. So the request has to be made before something

like some more information is required to be produced;

correct?

A. That is correct.

Q. And if we go to Subsection or Section 232, do you

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2092

remember talking about on receipt of an application?

A. Yes, uh-huh.

Q. There is no -- you have the power to request more

information after you receive the initial application;

correct?


Q. Well, let's read 232.

"On receipt of an application for a

license under this part...."

What does that mean?

THE COURT: Okay, it's under that section. We

all understand. Keep going.

BY MR. PARRAS:

Q. "...the appropriate official may cause such

investigations and inquiries to be made of the applicant

corporation, its directors and officers or proposed

directors and officers," et cetera, et cetera.

Maybe I'm wrong, tell me if I'm wrong,

that tells me that once an application is submitted, you

have the authority to then, if you want to, request more

information.

A. That is not what that statement is indicating.

Q. Okay.

A. I disagree.

Q. Okay. Do you remember talking to the -- talking

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02:45:12



2093

about the files that were in your office, and you told

this jury that Mr. Stanford removed those files; correct?

A. That is correct.

Q. You also told this jury that you left work on Friday

and you returned Monday and they weren't there; correct?

A. That is correct.

Q. The reality, the truth, is you don't know who removed

your files; correct?

A. Yes, I do.

Q. Is it your belief that Mr. Stanford himself went to

your office and physically removed those files?

A. That is my belief, yes.

Q. That's not any personal knowledge that you have;

correct?

A. It's -- well, I'm not sure how you define "personal

knowledge." I'm aware that that was what happened.

Q. Well, did you see Mr. Stanford go into your office

and pull boxes of files out of your office?

A. I did not see that. And it was not boxes of files.

The filing cabinets that were moved containing files.

Q. Is there a video somewhere of Mr. Stanford removing

file cabinets of materials and files?

A. No, there is not.

Q. Are there pictures of Mr. Stanford going into your

office removing files and boxes of files?

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2094

A. No, there is not.

Q. At that time, Lloyd Harold the former FBI agent, had

been made president, supervisor of banks; correct?

A. Yes.

Q. He was the person that took the files; correct?

A. That is not correct. To my knowledge, that is not

correct.

Q. Okay. Let's put aside -- what about Mr. Pat O'Brien

do you believe he took the files?

A. I'm not sure if he was involved in the removement of

the files -- removal of the files.

Q. Just to be clear, it's your belief that Mr. Stanford

himself physically picked up those files out of your

office?

A. Mr. Stanford was present and conducted, or should I

say, supervised the removal of the filing cabinets from

the premises.

Q. To your knowledge, who --

A. To my knowledge.

Q. To your knowledge, who did he supervise?

A. A number of persons who were lifting and helping to

move the cabinets.

Q. What are their names?

A. I don't know their names.

Q. Did you make a police report about that?

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2095

A. I believe I did, yes. I reported that the files are

missing.

Q. What you did do was you asked for a legal opinion

from the solicitor general about whether it was

appropriate for the files to be removed, didn't you?

A. That is incorrect.

Q. You told this jury on direct examination that you

were being ordered to turn over the files and you sought a

legal opinion; correct?

A. That was prior to the removal of the files.

Q. Okay. And the result of that legal opinion was that

you should turn over the files; correct?

A. That I should turn over the files to the supervisor

of international banks.

Q. Okay. It was clear that they were going to leave

your office; correct?

A. I don't understand the question.

Q. I'll move on.

You told this jury that Pat O'Brien was an

employee of Mr. Stanford.

That's not true, is it?

A. It is true.

Q. Pat O'Brien was paid by the IFSA; correct?


Q. It would help, wouldn't it, for you to review

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2096

correspondence regarding the payment of Pat O'Brien,

wouldn't it?

A. Yes, it would.

Q. Take your time to read this to yourself, and when

you're finished --

THE COURT: How many pages?

BY MR. PARRAS:

Q. -- let me know?

MR. PARRAS: Two pages and a paragraph on the

third, Judge. I apologize.

THE COURT: Counsel.

MR. PARRAS: It's on my time, Judge.

THE COURT: I know. I'm looking at the time.

It's clicking away.

While we're waiting, I will tell you what,

but we have a really nicer mindset like we did here. It's

not swearing in a new lawyer on -- what is it -- Friday?

It's one of the pleasures you get doing some things like

that. So I try to bring the jury into it. In fact, when I

have civil cases going on, like contract cases or civil

rights cases or whatever, I always bring those juries in to

see the criminal aspect of the case, of what we do here.

It's not just criminal work, all sorts of civil work. But

I may do the same thing. If I see I have a civil motion

some morning that may be of interest for you, we'll call

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2097

you in to see what the civil aspects of this job is because

I've got civil cases stacked up both before and behind this

case. As soon as it's over, we'll be doing some one -- big

civil rights case, for instance, concerning matters that

allegedly occurred overseas that are suing a major U.S.

company about.

All right. Are we ready?

MR. PARRAS: I think so, Judge.

THE WITNESS: Yes, sir. Go right ahead,

Counsel.

BY MR. PARRAS:

Q. Does that help to remind you that Mr. O'Brien was

being paid by the IFSA?

A. It helps to confirm that that was not the case.

Q. Is it because you believe that the Antiguan

government ended up meeting to get a loan from the Bank of

Antigua which is owned by Mr. Stanford? Is that why

you're saying --

A. That is not why I am saying that.

Q. Okay.

MR. PARRAS: No further questions.

THE COURT: Anything further?

MR. PARRAS: No, Judge. And I'll grab this

back.

THE COURT: Anything further, Counsel?

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2098

MR. WARREN: Yes, Your Honor, very briefly.


BY MR. WARREN:

Q. Ms. Crick, on the recross, Mr. Parras asked you again

about the Montserrat decision.

What was the date on which Guardian

International Bank surrendered its license?

A. December 1999.

Q. Is that before or after the notice of revocation came

in November of 1999?

A. That is after the notice of revocation.


THE COURT: Anything further, Counsel.

MR. PARRAS: No, Judge.

THE COURT: All right. Thank you, ma'am.

Now you may step down. You're excused and

free to leave. I tell all witnesses this: If you'd like

to stick around and watch, you can. You're released from

that prior ruling as far as not being in the courtroom, but

you're certainly free to leave. Thank you.

THE WITNESS: Thank you, Your Honor.

THE COURT: Yes, ma'am.

All right. Call your next witness.

MR. COSTA: United States calls Arnold Knoche.

THE COURT: Sir, do you want to come around to

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Direct-Knoche/By Mr. Costa


2099

your right.

Raise your right hand to be sworn.

Have a seat, please.

ARNOLD KNOCHE,

after having been first cautioned and duly sworn, testified

as follows:

DIRECT EXAMINATION

BY MR. COSTA:

Q. Good afternoon.

A. Good afternoon.

Q. Would you please introduce yourself to the jury and

spell your last name for the court reporter?

A. My name is Arnold Knoche, A-R-N-O-L-D, K-N-O-C-H-E.

Q. And where do you live Mr. Knoche?

A. I live in Ft. Bend County.

Q. How long have you lived in the Houston area?

A. Ever since I was six months old.

Q. Got here as soon as you could?

A. As soon as I could, yeah.

Q. What do you do for a living these days?

A. I'm semiretired. I'm still working a little bit,

just doing some bookkeeping work.

Q. What is your profession?

A. A CPA.

Q. Tell the jury briefly about your educational

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2100

background.

A. Okay. I went to public schools in the Houston

Independent School District, and then to the University of

Houston. Got a bachelor's of administration with a major

in accounting.

Q. And you said you're a CPA or a certified public

accountant?

A. Yes.

Q. How long have you held that title?

A. For -- since I was 23 years old, so 45 years.

Q. What's your current status as a CPA?

A. In retired status for the last three years.

Q. What did you do after graduating from the University

of Houston?

A. I started out in public accounting, a national firm

called Peat, Marwick, Mitchell and then a local firm

called Milton & Milton.

Q. Peat Marwick, was that one of the big international

accounting firms?

A. Yes. It's called -- back then, it was called Big 8

accounting firms. They were the largest eight accounting

firms in the U.S.

THE COURT: What are they now down to? How

many big --

THE WITNESS: I believe it's four now.

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2101

BY MR. COSTA:

Q. There have been some mergers?

A. Yes, mergers.

Q. Is Peat Marwick still around in any merged entity?

A. Yes. I think its merged name is KPMG.

Q. So you said you worked for Peat Marwick and then a

local accounting firm.

Did you at some point to into the real

estate industry?

A. Well, I went first to the construction industry. I

worked for two subsidiaries of Austin Industries. They

were construction companies.

Q. And then did you go to a homebuilder?

A. Yes. A homebuilder named Monarch Homes. I was there

for 11 years, started as controller and then was executive

vice-president of finance.

Q. What is a controller?

A. That's responsible for the overall accounting

function and be sure the bills are paid, the payroll is

done, and then prepare the financial statements to be

presented to the president or the board of directors.

Q. What year did you leave Monarch Homes?

A. 1987.

Q. Why were you looking to leave Monarch Homes in 1987?

A. The homebuilding business was very bad in Texas.

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2102

That was back in the savings and loan crisis. And I was

going to have -- we were going to shut down in Texas, and

I was going to have to move to San Diego, California.

Q. You didn't think the weather in San Diego would

measure up to Houston?

A. No. It would have been beautiful, but our daughter

was in high school and we just didn't want to -- didn't

want to pull her out of high school if we could possibly

avoid it.

Q. Did you start looking for jobs that would allow you

to stay here in the Houston area?

A. That's correct.

Q. And where did you end up going to work?

A. A company -- it was Guardian International Investment

Services at that time.

THE COURT: What year was that? 1980 --

THE WITNESS: 1987.

BY MR. COSTA:

Q. And who owned that company?

A. Allen Stanford.

Q. How did you first find out about that position with

Guardian International?

A. I answered a newspaper ad.

Q. Do you remember where the ad was placed?

A. Probably The Houston Chronicle. It could have been

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2103

the Wall Street Journal, but I believe it was The Houston

Chronicle.

Q. And what do you recall the want ad requesting in

terms of background for the position?

A. It advertised for a certified public accounting with

real estate experience.

Q. Did you submit a resumé?

A. Yes. I sent a cover letter and a resumé.

Q. Were you invited for an interview?

A. Yes.

Q. With whom did you interview?

A. I met with Allen Stanford.

Q. Where was that meeting?

A. It was on a Saturday morning at the 1100 Milam

Building. It's just a few blocks from here.

Q. What did Mr. Stanford tell you about this position he

was interviewing for?

A. Well, it was going to be a newly created part of the

organization that was going to seek out distressed real

estate and purchase it, operate it and sell it.

Q. Do you see Mr. Stanford in the courtroom today?

A. Yes. He's right there.

Q. Can you point out what he's wearing?

A. That's him.

THE COURT: He's standing up; correct?

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2104

THE WITNESS: Correct. That's correct.

MR. COSTA: Ask that the record --

THE COURT: The record will reflect that he

identified Mr. Stanford.

BY MR. COSTA:

Q. So Mr. Stanford told you this was a new entity he was

looking to hire someone for?

A. That's correct.

Q. Focused on distressed real estate?

A. Yes.

Q. Did he tell you at that initial interview about any

other businesses he had?

A. Yes. He said he had a bank in Montserrat.

Q. And what was the name of that bank?

A. It was Guardian International Bank.

Q. And this position you were interviewing for, was that

going to be with the bank?

A. No, no.

Q. It was going to be separate?

A. Separate.

Q. And focused on --

A. Focused on real estate.

Q. After that first interview with Mr. Stanford, what

happened?

A. He called me back in a couple of days or somebody

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2105

called me back and said they'd like me to go to Mexia,

Texas, to meet with the board of directors.

Q. And did you go up to Mexia?

A. Yes, I did.

Q. Where is Mexia from Houston?

A. It's up towards Dallas. Not quite all the way to

Dallas.

Q. With whom did you meet in Mexia?

A. That would have been James Stanford and Bill Goswick

and Don Caldwell.

Q. Did you learn anything about Mr. Stanford's history

from that interview with those board members in Mexia?

A. About his history?

Q. Did anyone make a comment about what Mr. Allen

Stanford had done in the past?

A. Oh, Bill Goswick, I think --

MR. SCARDINO: We object to clarify who he's

referring to, who made the statement.

THE COURT: Okay.

BY MR. COSTA:

Q. Who made a statement about what Mr. Allen Stanford

had done in the past?

A. Oh, Bill Goswick made a comment about that Allen had

been in the --

MR. SCARDINO: Object to the hearsay.

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2106

THE COURT: How do you get around hearsay?

MR. COSTA: It's for the truth, it's just to

show what he understood about Mr. Stanford's business, but

I can move on. It's not --

THE COURT: Sustain the objection.

BY MR. COSTA:

Q. What did you learn from the board about this real

estate, distressed real estate project Mr. Stanford wanted

to hire you for?

A. They basically said the same thing Mr. Stanford did;

that they thought this was a good opportunity to have

purchase of distressed real estate. There was a lot of it

around, and they thought we could do well.

Q. Did you eventually get hired for the position?

A. Yes.

Q. And the entity that hired you was this Guardian

International Investment Services?

A. That's correct.

Q. Did anyone else work with you initially on the real

estate investments?

A. Yes. When Mr. Stanford made me the offer, he said

that they had decided to hire two people, or they were

just going to hire one, but there was another applicant

that he hired at the same time. We were both -- both

executive vice-presidents reporting to him.

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2107

Q. Who was the other individual?

A. Larry Slater.

Q. And you both reported to Mr. Allen Stanford?

A. That's correct.

Q. We mentioned Mr. Stanford's father, but from now on

when I say "Mr. Stanford," do you understand I'm talking

about Mr. Allen Stanford?

A. Yes.

Q. Unless I specify?

A. Yes.

Q. You said Mr. Stanford already had a bank at this

time?

A. That's correct.

Q. So when was it that you started working at Guardian

International Investment Services?

A. That would have been in the early part of 1987.

Q. And did you learn about the bank after you went to

work even though you were working for this separate real

estate investment?

A. Yes. It was a very small office in Houston, so that

I think there were three bank officers -- or they

weren't -- they weren't employees of the bank. They were

employees of Guardian International Investment Services,

another part of it. So it was a small office, and we had

meetings that would discuss some part -- early on, some

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2108

parts about the bank.

Q. And these were salespeople for the bank?

A. These were salespeople for the bank.

Q. What product were they selling for the bank

primarily?

A. Primarily certificates of deposit.

Q. Do you remember the names of some of those folks?

A. I recall three of them. Sydney Adler. Michelle

Chambliess and Maria -- no. There's four. Maria

Promindon and Elsie Ethridge. And, actually, Michelle

came a little bit later, it was Sydney, Maria, and Elsie

first, and then Michelle came shortly thereafter.

Q. You were there before Michelle?

A. Yes.

Q. In terms of Mr. Stanford's attention, from what you

saw, which part of his businesses did he devote most of

his time to in those first few years?

A. The bank.

Q. If you could put a percentage of his time that he was

focused on the bank, from what you saw, what would you

estimate?

A. Oh, probably 90 percent.

Q. And you said partly you learned about the bank just

because you were in the office with these other bankers,

the bankers who were actually selling the CD product?

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2109

A. That's correct.

Q. Did you ever read promotional materials put out by

Guardian Bank?

A. Yes.

Q. Why?

A. Oh, we were so small we were asked to. We would have

meetings to review the promotional material, in the early

days.

Q. Who asked you to read the promotional materials?

A. Mr. Stanford.

Q. Who would be at these meetings where the promotional

materials were reviewed?

A. That was the same people that I mentioned. And Larry

Slater and myself.

Q. Would Mr. Stanford attend those meetings?

A. Yes.

Q. Did you also read the bank's annual reports?

A. In the early years, yes.

Q. Was that something Mr. Stanford required that you

read?

A. Yes. He asked each of us to be totally familiar with

the bank's annual report.

Q. And from the materials you read and from these

meetings you attended with Mr. Stanford, what did you

understand that the bank told the depositors it was doing

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2110

with the CD money?

MR. SCARDINO: Objection to foundation and

hearsay.

THE COURT: Okay. Your response?

MR. COSTA: The foundation has been laid. He

said he read all the promotional materials. He was at

meetings with Mr. Stanford.

And for hearsay, it's not offered for the

truth. It's for what he understood what Mr. Stanford and

the materials told him the bank did with their money.

MR. SCARDINO: That's a different question than

asking him what materials they were asked to read.

THE COURT: Right. Okay. Ask the question.

Sir, don't answer it. See if there's an

objection, if we can around the objection; okay?

BY MR. COSTA:

Q. Based on the materials you read, based on what

Mr. Stanford told you and others discussed in these

meetings, what did you understand that the bank was

telling its depositors it did with the money that was

deposited?

MR. SCARDINO: Again, I object to foundation,

the materials that he said he reviewed.


THE WITNESS: Would you repeat it then, please.

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2111

BY MR. COSTA:

Q. Sure. What did you understand, from what you read

and what you were told by Mr. Stanford, about what

Guardian Bank did with the money once it was deposited in

the bank?

A. It was invested in conservative equities and bonds,

stocks and bonds.

MR. COSTA: And given Mr. Scardino's objection,

we'll show one of those. 103, please, which has already

been offered.

MR. SCARDINO: 103?

MR. COSTA: Yes.

BY MR. COSTA:

Q. Do you recognize this as a Guardian Bank annual

report from 1990, Mr. Knoche?

A. Yes.

MR. COSTA: If we could turn to Page 13,

please.

Thank you, Judge.

And there is a paragraph there, investment

portfolio, towards the beginning of the bottom half, if you

could highlight that.

BY MR. COSTA:

Q. It says, "The investment portfolio is made up of

86.9 percent bonds, 9.4 percent equities, 2.6 percent

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2112

commercial paper and 1.1 percent notes."

Is that consistent with what your memory

is of the type of investments the bank was saying it made?

A. Yes.

MR. SCARDINO: Excuse me. I'll object. This

witness is not -- there's no foundation to establish this

witness had this knowledge personally. He's not being

asked to form an opinion as an expert, so I would object to

this line of questioning unless he plans to prove him up as

an expert.

THE COURT: Go on.

MR. COSTA: I asked him what he understood.

He's already said if there's no foundation, I -- he's been

at numerous meetings. He was required by Mr. Stanford to

read the bank's promotional materials. I'm happy to lay

more foundation, but I think it was -- it's clear he read

all the materials at the time he was required to, and

Mr. Stanford was in meetings telling him all that.

THE COURT: Now you're reading from something

already in evidence; correct?

MR. COSTA: Right.

MR. SCARDINO: Your Honor, I would respectfully

object, because the prosecutor -- Mr. Costa is actually

trying to have it both ways. He's trying to not make the

man an expert witness but still elicit an opinion from hi,

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2113

and I would object.


MR. SCARDINO: I --

MR. COSTA: No, no, overruled. I'll keep an

eye out, though, Mr. Scardino. If you think you're getting

into pure expert witness testimony as a CPA, I'll jump in

or you jump in.

BY MR. COSTA:

Q. Is that highlighted portion, Mr. Knoche, consistent

with what you heard from Mr. Stanford and from reading

materials that that's the nature of the bank's investment

portfolio?

A. Yes, I agree.

Q. You said you were told it was conservative, low-risk

investments. Do you think if it was in bonds and

9 percent equities, would that be conservative, in your

view?

MR. SCARDINO: Again, he's asking for an

opinion.

THE COURT: Overruled. Overruled.

THE WITNESS: Yes, certainly there is some

equities that are more risk than others, but basically

bonds, especially, that's conservative investment, yes.

BY MR. COSTA:

Q. What did the bank say about whether it made loans

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2114

like a commercial bank?

A. It was my understanding there was no loans.

MR. COSTA: If we can go to 519, which has also

already been offered. If we can go to Page 5. On the

left-hand side, the second question and answer.

BY MR. COSTA:

Q. It says, "Does the bank make loans?"

"Guardian International Bank limited has

never made and will never make loans or offer credit

instruments."

Is that consistent with the understanding

you had from working at Guardian Investment Services?

MR. SCARDINO: Again, object to foundation.

There's no basis to show that this man had knowledge of

loans or not.


MR. COSTA: I'm not asking whether he knew the

bank --

THE COURT: I understand. I've overruled it.

Go on.

BY MR. COSTA:

Q. Is that consistent with what you were told about the

bank?

A. Yes.

Q. Where did Mr. Stanford -- or did Mr. Stanford tell

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2115

you who was making the investment decisions for the bank's

portfolio?

A. Well, in the very early years, it would be himself,

and he --

THE COURT: Hold it. The question is: Did he

tell you. Right? That was the question.

BY MR. COSTA:

Q. Did Mr. Stanford tell you which individuals were

overseeing the bank's investment portfolio?

A. I don't recall that he was -- specifically had

said that he would have answered that question. No, I

don't specifically remember that, but...

Q. Did Mr. Stanford ever discuss money managers with

you?

A. Yes, he said there were some money managers in

Switzerland.

Q. And what were those Swiss money managers doing

according to Mr. Stanford?

A. It would have been my understanding managing the

funds of the bank.

Q. In these meetings you had with the bankers who were

selling the CDs that Mr. Stanford attended, did the topic

of insurance ever come up?

A. Yes. They said that some of their clients had asked

if he had --

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MR. SCARDINO: Object to nonresponsive.

THE COURT: Sustained. The answer is -- it

will go a lot quicker if he asks for a narrative, then

visit with him. Otherwise, yes or no. If you can't answer

a question yes or no, let me know and I'll have him

rephrase it.

THE WITNESS: Yes, Your Honor.

BY MR. COSTA:

Q. Did the topic of insurance come up?

A. Yes.

Q. Did the bankers, the people selling the CDs, ask

Mr. Stanford about the insurance issue?

A. Yes.

MR. SCARDINO: Object to foundation.


BY MR. COSTA:

Q. Were you in these meetings where the insurance issue

came up?

A. Yes.

Q. What did the banker say to Mr. Stanford about

insurance?

A. That some of the clients had asked if there was -- if

their deposits were covered by FDIC insurance.

Q. And what was the response?

A. Response was no.

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2117

Q. So was there another insurance that Mr. Stanford said

applied to his bank?

A. I think initially no, but then later yes.

Q. Do you recall the name of that insurance that he said

applied to his bank?

A. I remember two companies were mentioned. I don't

know what order. Lloyd's of London was mentioned, and a

British Insurance Fund was mentioned.

MR. COSTA: If we can go to 502, which has

already been offered and referenced, Your Honor.

BY MR. COSTA:

Q. Do you see the name at the top there, Mr. Knoche,

British Insurance Fund, Limited?

A. Yes.

Q. Is that the insurance company you were just

referencing that Mr. Stanford talked about in these

meetings with the bankers?

A. Yes.

Q. In any of those meetings you attended where this

company was discussed, did Mr. Stanford ever say that it

was a captive insurance company that he owned?

MR. SCARDINO: Object to the form of the

question what did he ever say.


BY MR. COSTA:

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2118

Q. Did Mr. Stanford ever say that the British Insurance

Fund, Limited, was a captive insurance company that he

owned?

A. No.

Q. Was there ever in any of these brochures you were

required to review for the bank mentioned of an office in

Switzerland?

A. Yes.

MR. COSTA: If we can go to 522, please. This

has already been offered and admitted. Page 19, please.

If you can highlight the bottom list of cities.

BY MR. COSTA:

Q. List the number of offices and then it says,

"Affiliate offices."

What's listed there?

A. It says Geneva, Switzerland.

MR. COSTA: If we can go to Page 3 of the same

Guardian brochure.

BY MR. COSTA:

Q. If we go to the bottom, is that a list of offices as

well, Mr. Knoche?

A. Yes.

Q. And at the bottom, it says, "Affiliate office

Geneva"?

A. Yes.

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2119

Q. Did you ever ask Mr. Stanford about whether there

was, in fact, an office of the bank in Geneva?

A. In conjunction with reviewing one of the promotional

things, it had pictures of the other offices, Miami and

Aruba, but in Geneva, it just had a picture of a river.

And I said, "Wouldn't it be better if we had a picture of

the office?"

Q. And what did Mr. Stanford say?

A. He said, "Well, it's more like this, the

representative -- representation. There's not a formal

office as such."

Q. I want to go on and talk about the real estate

investment group that you worked for.

Was -- were you told that that was the

bank -- the CD depositors' money that was going into those

real estate investments?

A. No.

Q. What did Mr. Stanford say about that?

A. Well, the first ones we did were limited

partnerships. We raised money by -- can I elaborate?

Q. I'll ask --

THE COURT: Okay. Go on.

BY MR. COSTA:

Q. Did you understand that the bank was separate from

these real estate partnerships?

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2120

A. Yes.

Q. Now, was Mr. Stanford at first trying to target bank

customers to see if they would also be willing to invest

in the real estate partnerships?

A. Yes.

Q. And these real estate partnerships were focused on

what type of investments?

A. Residential rental property.

Q. In what area?

A. In primarily Houston, Texas.

Q. And what was going on in the economy here in Houston

when you were hired in 1987?

A. It was -- in home building business and the real

estate business, it was very bad.

Q. So what was the idea -- I think you used the term

"distressed real estate." What was the idea with

targeting distressed real estate?

A. To purchase these properties that the current owners

were not able to spend money to keep them up on and

rehabilitate them and run them properly and then sell

them.

Q. And was each project set up as a separate

partnership?

A. Yes.

Q. Where was the first partnership? What did that

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2121

involve?

A. It was a small apartment project in southwest Houston

called Takara So Apartments.

MR. SCARDINO: Spell that.

THE WITNESS: Yes, it was T-a-k-a-r-a S-o

Apartments.

BY MR. COSTA:

Q. And did that partnership -- in that first

partnership, was Mr. Stanford's successful in getting some

of the bank's clients to also invest separately in the

real estate partnership?

A. Yes.

Q. What about -- was there a second real estate

partnership set up?

A. Yes.

Q. What did that partnership purchase?

A. It was called the Jonathan Square One Apartments.

Q. Where was that located?

A. In southwest Houston.

Q. For that second partnership that was set up, was

Mr. Stanford successful in getting the bank's clients to

invest separately in the real estate partnership?

A. Not to the full extent.

Q. It didn't fund the whole partnership?

A. That's correct.

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2122

Q. Where -- were you told by Mr. Stanford where the rest

of the money came from to fund that second partnership?

A. He said he had personal resources to take care of it.

Q. Was there a third real estate partnership?

A. Yes.

Q. What did that purchase?

A. It was called the Rock Springs Apartments.

Q. In Houston?

A. Southwest Houston.

Q. Was Mr. Stanford successful in getting the bank

customers to invest separately in this third real estate

partnership?

A. Yes, but not to the full extent, not to the full

need.

Q. Who did Mr. Stanford say made up the difference?

A. He said he had personal resources that would take

care of it.

Q. Was there a fourth partnership set up?

A. No, there was only three.

Q. Was there -- were there also Austin investments?

A. Yes, more properties were purchased, but they were

not limited partnerships.

Q. How were those set up?

A. They were -- these purchases -- by that time, the

name of the company had the changed to Guardian

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2123

Development Corporation, and they were purchased by

Guardian Development Corporation.

Q. How long did it take for Guardian Investment Services

that you started with in 1987 to become Guardian

Development Company?

A. It was in the first two to three years.

Q. And by this time when Guardian Development was

created, did you have a new title?

A. Yes. I became president.

Q. When Guardian Development was created, was

Mr. Stanford still trying to get bank customers to invest

separately in the real estate investments?

A. No.

Q. Did you learn why there were difficulties with

getting bank clients to invest in the real estate

partnerships?

A. I heard from the bank officers some of the reasons.

MR. SCARDINO: Excuse me. Assuming facts that

are not in evidence, and he's leading the witness.

THE COURT: All right. Rephrase it.

BY MR. COSTA:

Q. You mentioned that after the first real estate

partnership, the second and third were not fully funded by

the bank customers; correct?

A. Yes.

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2124

Q. And then once Guardian Development started, the bank

clients weren't helping to fund that is your

understandings; right?

MR. SCARDINO: Object to leading.


THE WITNESS: Could you repeat it, please?

BY MR. COSTA:

Q. Once Guardian Development started, was Mr. Stanford

still trying to get the bank clients to fund Guardian

Development?

A. No.

Q. Did you learn why he wasn't able to get enough bank

clients to fund, say, the second and third real estate

partnerships fully?

THE WITNESS: I would have to answer with some

narrative, Judge.

Q. It's a narrative. It calls for a narrative.

THE COURT: Answer it yes or no.

BY MR. COSTA:

Q. Did you learn why?

A. Yes.


BY MR. COSTA:

Q. What was different about investing in the bank CDs

as -- according to what the bank said it did with the

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2125

money versus investing in these real estate partnerships?

A. The real estate partnerships were not liquid.

Q. What do you mean by that?

A. Liquid means you can get your money if you decide --

MR. SCARDINO: Excuse me, Mr. Knoche.

He asking him to give an opinion about a

matter -- a financial transaction, and he's not qualified

to give an opinion about a financial transaction.

MR. COSTA: They've been asking all these

questions about international accounting standards, about

all types of stuff. I'm just asking what he understands --

he was involved in the real estate companies.


BY MR. COSTA:

Q. What do you mean when you say the real estate

partnerships were not liquid?

A. If you want to get your money out, a real estate

partnership would not -- you would have to wait until the

property is sold.

Q. What about -- we saw earlier the banks's annual

report talking about bonds and equities. How long does it

take to sell bonds and equities if they're traded on a

public market?

A. Usually one to two days, I think.

Q. These apartment complexes that you were working on on

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2126

the real estate side of things, how long would it take to

sell those?

A. It would take months.

Q. What about the risk level? You mentioned the

liquidity difference. Is there also a difference in risk

level between what the bank was saying it did with its

investment portfolio versus these investments in

distressed real estate?

A. Yes.

Q. And what's the risk level of investments in

distressed real estate?

A. Real estate would be considered to have some degree

of risk in it. The price of -- the value of the property

can go up or down.

Q. Everything can go up or down; right?

A. Yes.

Q. What about the level of risk in a distressed real

estate investment versus the risk in a diversified

portfolio stocks and bonds?

A. I would say it is more in the real estate.

Q. You mentioned that Mr. Stanford was saying he

personally -- when the bank clients weren't interested in

funding these real estate partnerships, you said that he

told you it was his funds that were making up the

difference?

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2127

A. He had personal resources.

Q. And what about when Guardian Development Company

started, where did Mr. Stanford tell you he was getting

the money for those acquisitions?

A. Personal resources.

Q. Were you actually able to see the bank records

showing the actual sources of those money?

A. No.

Q. At times did you ask Mr. Stanford where the money was

coming from?

A. Maybe once or twice and then --

Q. Why did you stop asking him?

A. If he didn't want to answer a question, he wouldn't

answer it -- he wouldn't answer it.

Q. So when you'd asked him those first couple of times,

did he give you a lot of information?

A. No.

THE COURT: Move that mike away just a little

bit.

THE WITNESS: Okay. I'm sorry. Tell me if

this is going to be better.

THE COURT: Depends upon how close you get

again.

THE WITNESS: I'm sorry.

THE COURT: Right now it's fine.

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2128

THE WITNESS: My fault.

BY MR. COSTA:

Q. I'm sorry. You're saying if he didn't like to give

you more information?

A. No.

Q. Okay. In terms of working for Mr. Stanford, what was

the general atmosphere, in your view, about whether he

liked being questioned?

A. He did not like to be questioned.

MR. SCARDINO: I object to the relevance of

whether he liked to be questioned.


By the way, you can sit back and pull that

microphone in if you want.

THE WITNESS: Okay.

BY MR. COSTA:

Q. I'm sorry. There was an interruption. So could you

answer again what -- whether -- your understanding of

whether Mr. Stanford liked being questioned.

A. My impression was he did not like to be questioned.

Q. What do you base that impression on?

A. Just the way he would respond if somebody asked him

about where monies came from.

Q. How would he respond?

A. If it was an employee, he would probably just not

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2129

answer it, period. If it was somebody else, he might say,

"We'll talk about that later" or something like that.

Q. Did Mr. Stanford ever tell you that he was taking

money from the bank, from its investment portfolio, to

invest in any of these real estate projects?

A. No.

Q. Would that have concerned you if he had told you

that?

A. Yes.

Q. Why?

A. Well, because the bank's promotional material says

it's invested in other things.

Q. You said you started with Mr. Stanford in 1987. And

I'm jumping ahead just a little bit. How long did you

work for Mr. Stanford?

A. I worked there until 2003.

Q. So that's about 16 years?

A. Yes, 16 years.

Q. Did there come a time when you learned that the bank

moved from Montserrat?

A. Yes.

Q. What -- did Mr. Stanford say about why the bank moved

from Montserrat?

A. He said the bank had outgrown Montserrat, that he

needed to go to a larger venue such as Antigua.

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2130

Q. Did he ever tell you that Montserrat had sent a

letter notifying him they were planning to revoke his

banking license?

A. No.

Q. When you started working for Mr. Stanford in 1987,

was Jim Davis already working there?

A. No.

Q. Do you recall about how long after you got there that

Jim Davis came on board?

A. Within the first year.

Q. And what was Mr. Davis's position when he came on

board?

A. Chief financial officer.

Q. You already said you were a CPA; correct?

A. Yes.

Q. And you'd been a controller at one of those home

building companies?

A. Yes.

Q. Did Mr. Stanford ever ask you if you were interested

in that position of CFO that he gave to Jim Davis?

A. No.

Q. Had you heard that they were looking for that --

someone to fill that position?

A. No.

Q. Had there been an advertisement, a want ad, like the

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2131

one for your position looking for a CFO?


Q. You said you were a CPA; correct?

A. Yes.

Q. Was Mr. Davis a CPA, to your knowledge?


Q. What was Mr. Stanford's relationship with Mr. Davis?

A. He said they went way back. They were college

roommates.

Q. And was there -- where was Mr. Davis's office in

relation to Mr. Stanford's once Mr. Davis came on board?

A. In the same building, 1100 Milam Building.

Q. Was Mr. Stanford's relationship with Mr. Davis

different than with his relationship with other employees

from what you saw?

A. From what I saw, yes.

Q. How was it different?

A. They were friends. I mean, the rest of us were

employees, they were friends.

Q. After Mr. Davis arrived, did it seem to you like

Mr. Davis was now in charge?

A. No.

Q. And you said you worked there through 2003?

A. That's correct.

Q. Through 2003, did it ever seem to you like Mr. Davis

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2132

was in charge?

A. No.

Q. Did that thought ever even cross your mind?

A. No.

Q. Why not?

A. It was Mr. Stanford's companies. There was no doubt.

Q. Including the bank?

A. Yes.

Q. How would you describe Mr. Stanford's management

style in terms of his level of involvement?

A. He was very involved. He knew what was going on.

Q. Did there come a point when Mr. Davis actually helped

provide accounting services for your -- the company you

were president of, Stanford Development?

A. Yes.

Q. So Mr. Davis didn't just work for the bank; is that

right?

A. That's correct.

Q. Did Stanford Financial Group provide accounting and

other support services for a number of the companies?

A. Yes.

Q. So if it was said that Mr. Davis only had involvement

with the bank, you wouldn't agree with that?

A. No.

Q. Do you recall when it was that Mr. Davis started to

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2133

help with the accounting for Stanford Development Company?

A. Probably the early 1990s, early-to-mid-1990s.

Q. And I should clarify one thing. You said -- you

started off you were hired for Guardian Investment

Services; right?

A. Yes. Guardian International Investment Services.

Q. And then you said it became Guardian Development?

A. Yes.

Q. And then did it change to something else?

A. Yes.

Q. What did it change to?

A. Stanford Development Company -- Corporation.

Q. And when Mr. Davis in the early '90s started to help

with the financial statements for Guardian Development

Company, did you just withdraw completely from having any

involvement in the financial aspects of your business?

A. No.

Q. Why not if he was CFO?

A. Well, the president's responsible.

Q. So you mentioned in the late '80s when you started,

the focus of these real estate investments was distressed

apartment complexes?

A. Yes.

Q. And the idea was to -- with these partnerships was to

sell those as an investment and eventually make a profit;

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2134

right?

A. Yes.

Q. During the '90s, did the focus of the development

company begin to change?

A. Yes.

Q. Did the focus -- let's say in the mid-'90s, was the

focus still on buying distressed properties and then

trying to sell them a few years later?

A. No.

Q. What became the focus in the mid-'90s?

A. Two things: We built some houses for sale, but

mainly we, I think, became like a construction department

for the other entities. We built things for the other

members of the group.

Q. Let's take those one at a time. You mentioned some

houses that were built?

A. Yes.

Q. Tell the jury about those.

A. We built one in Houston called Stanford Oaks. It was

16 townhomes, just off Kirby and San Felipe. And we built

one called Le Voisinage. It was about the same number of

units over off West Alabama.

MR. SCARDINO: Could you spell that?

THE WITNESS: Yes. It's a French word.

L-e V-o-i-s-a-n-g-e (sic), I believe.

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2135

And then later, very late, we started the

loft project downtown, The Stanford over by Minute Maid

Park. It was about a four-story loft project.

BY MR. COSTA:

Q. So, say, your last ten years with the company, say,

from '93 to '03, were those three projects you just

mentioned, were those the only investment-type projects --

A. Yes.

Q. -- that you recall?

A. Oh. In Antigua, we built some houses, also. We

built a small subdivision in Antigua called Cedar Valley

Springs. Those were for sale.

Q. And with any of those four projects that occurred

over your last decade or so, did Mr. Stanford ever tell

you that CD depositors' money was being used to fund

those?

A. No.

Q. Where did you understand the funding to come from for

those projects?

A. They were coming from Stanford Financial Group or

Allen Stanford as an individual.

Q. Now, you said most of the work during your last

decade became construction projects for other Stanford

businesses?

A. Yes.

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2136

Q. And where were most of those construction projects

located?

A. Well, some -- the offices for Stanford Group Company

were in the United States, and the others were in Antigua.

Q. Did you end up spending a lot of time in Antigua?

A. Yes. A great deal.

Q. How often -- in your latter few years with the

company, how much time did you have to spend in Antigua?

A. About half the time.

MR. COSTA: If we could go to 1530, please.

This we've already offered early this morning.

BY MR. COSTA:

Q. Do you recognize that photo, Mr. Knoche?

A. That was not completed when I left in 2003, but that

is the Antigua Athletic Club.

Q. Who owned the Antigua Athletic Club?

A. Stanford Development Company.

Q. Like a health club?

A. Yes.

Q. With a swimming pool?

A. Yes.

MR. COSTA: Let's go to Page 3, please. The

jury's already seen this.

BY MR. COSTA:

Q. What's this photo?

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2137

A. That's the Sticky Wicket Restaurant and Bar.

Q. And what entity built that?

A. Stanford Development Company.

MR. COSTA: If we can go to Page 11.

BY MR. COSTA:

Q. Do you recognize that?

A. That's the airplane hangar in Antigua.

Q. When you say airplane hangar, what airplanes were

allowed to use that hangar?

A. The Stanford fleet or Stanford planes.

Q. And who built -- which entity built that?

A. Stanford Development Company did the construction.

There might have been a separate entity like Stanford

Aviation or something that might have been the ownership,

but Stanford Development Company built it.

Q. You mentioned Stanford Aviation. That was another

company?

A. That's my recollection -- that might not be exactly

the right terminology, but there was a separate entity

that had to do with aviation.

Q. Now, when you say the aviation, what types of planes

are you talking about?

A. That's strictly the private planes, Stanford planes.

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

commercial airline companies?

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2138

A. Yes. He started two commercial airline companies.

Q. What were those called?

A. Caribbean Star and Caribbean Sun.

Q. But this hangar and the Stanford Aviation Company

related to the private jets?

A. Yes.

MR. COSTA: Let's go to Page 13, please.

BY MR. COSTA:


A. That was not built when I was there. I believe

that's out on a place called Barnacle Point, but that was

not even under construction when I left.

THE COURT: What is it? What is Barnacle

Point.

THE WITNESS: I believe it was going to be a

dock facility for the boat, his boat, or perhaps other

visitors' boats.

BY MR. COSTA:

Q. So you weren't there to actually construct this, but

you were aware for the planning for a boat dock?

A. Yes.

Q. And whose boat was going to dock there?

A. Mr. Stanford's and I guess anybody else he invited.

MR. COSTA: Let's go to Page 19, please.

BY MR. COSTA:

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2139


A. Yes. That's the cricket grounds.

Q. Did Stanford Development build that when you were

president?

A. Yes.

MR. COSTA: And finally number 23, please,

Page 23.

BY MR. COSTA:

Q. It's an overview shot. Do you recognize that?

A. Yes.

Q. What is that showing?

A. That's the overall -- some of the things we've

already seen. It shows the Sticky Wicket and the Athletic

Club. It also shows Stanford International Bank building.

Q. Are these properties all in a certain area in

Antigua?

A. Yes, they're all in approximately 20 acres adjacent

to the airport.

Q. What were the years when this whole development

started construction?

A. From the late 1990s through the early 2000s.

Q. Was it expensive to build all these different

buildings?

A. Yes, I mean, expensive relative, but, yes.

Q. Was Mr. Stanford involved -- was he involved with you

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2140

in the plans and the budgets?

A. In the plans, very much so.

Q. What about the budgets. Did Mr. Stanford -- did he

express a lot of concerns about cost?

A. No.

Q. Did you ever raise with him concerns about costs?

A. Yes. And we tried to do budgets, but a lot of times

it was fast tracked and we weren't able to do a budget

because we already started construction before all the

bids were in and the construction documents were

completed.

Q. And who wanted it fast tracked?

A. Mr. Stanford.

Q. What did he tell you about the time in which he

wanted these things built?

A. They always needed to be built very quickly to show

that things could be done rapidly in the Caribbean.

Q. What did Mr. Stanford say about the quality of this

construction?

A. The quality had to be the best in the world.

Q. Did he actually use the term about the standard of

quality he wanted to set?

A. Yes, create a new standard of quality for the

Caribbean.

Q. Is it difficult to get some of these materials used

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2141

in these buildings down to Antigua?

A. Yes. It's a small island, so there's very few

materials on the island. Almost everything has to be

brought in.

Q. Can that be expensive to import all the materials?

A. Yes. It adds to the cost, yes.

Q. What types of materials did Mr. Stanford want

included that you had to import?

A. The millwork, which is the wood paneling, granite and

marble finances.

Q. Once the construction started, did Mr. Stanford stay

involved in monitoring the progress?

A. Yes.

Q. Was there ever an issue with some hardwood floors?

A. Yes. We had hardwood floors in Stanford

International Bank. He thought we had a too light a shade

on them, and he wanted them change out.

Q. Why did he want a different shade for the hardwoods?

A. He wanted them to be the same as the other offices.

They end up being put in, in a lighter shade than the

other offices around the world. He wanted them all to be

the same.

Q. And he noticed just that that shading was off in the

hardwood floors?

A. Yes.

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2142

Q. What was his reaction when he saw that?

A. He was very upset.

Q. Did he talk to you about it?

A. Yes.

Q. What did he say?

A. He said, "This shouldn't have happened."

Q. What were you told from Mr. Stanford about the source

of funding for this Stanford world down in Antigua?

A. Just he had his resources. He was doing it.

Q. A few days ago, did I show you a video clip of

Mr. Stanford talking about these construction projects?

A. Yes.

Q. Did you recognize him as Mr. Stanford in that video?

A. Yes.

Q. Now, were you actually present at that particular

speech?

A. No.

Q. But was what Mr. Stanford said in that video, was it

consistent with what he was telling you over the years

about this Antiguan development?

A. Yes.

MR. COSTA: Your Honor, at this time I'd offer

1535A.

(Attorneys conferring)

MR. SCARDINO: We have no objection.

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2143

THE COURT: No objection, 1350 --

MR. COSTA: 1535A, Your Honor.

THE COURT: 1535A is now identified, and it's

in evidence.

Now, what is A? A is --

MR. COSTA: Let's go back.

THE COURT: What is --

MR. COSTA: A, Your Honor, is a clip. It's not

the entire -- the entire speech goes on. This is a clip of

a few minutes.

THE COURT: Video clip?

MR. COSTA: Video clip.

THE COURT: Thank you.

MR. COSTA: Can we get the lights maybe, Your

Honor?

THE COURT: Well, more lights.

MR. COSTA: Less.

(Whereupon, the tape was played)

MR. COSTA: Stop it right there.

BY MR. COSTA:

Q. Who did he just say there? What pronoun did he use

when he was talking about who built it and who paid for

it?

A. "I."

Q. Is that consistent with your discussions with

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2144

Mr. Stanford over the years?

A. Yes.

MR. COSTA: Continue now.

THE COURT: A little louder.


BY MR. COSTA:

Q. Did Mr. Stanford, again, say who was paying for the

development?

A. He said "I."

Q. What else did he say about the economics of the

development?

A. On parts, that would make no economic sense.

MR. COSTA: Maybe we can just finish it up.


BY MR. COSTA:

Q. Mr. Knoche, towards the end there, did Mr. Stanford

say where he was giving the speech?

A. In the airport in Antigua. In the aircraft hangar in

Antigua.

Q. That's the private hangar we just saw the picture of?

A. Yes.

Q. That wasn't part of the airport that any American

Airlines or any other plane could use; right?

A. No. That's correct.

Q. And when Mr. Stanford said in the video a couple of

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2145

times, "I'm building this," that's consistent with what he

told you?

A. Yes.

Q. Did you ever inquire where he was getting all the

money?

A. No. No.

Q. Did he ever tell you -- mention his family money?

A. On the early -- in the early, early days.

MR. SCARDINO: Excuse me. He asked him if he

ever inquired where he got the money, and he said no.

THE COURT: Okay.

MR. SCARDINO: Object to the form of the

question.

THE COURT: All right. Next question.

BY MR. COSTA:

Q. Did he ever mention family money?

A. Only in the early days.

Q. What did he say in the early days?

A. When -- where is the money coming from, he said, I

have fam -- personal resources, family resources.

Q. And in later years, it was -- he just said it was

him?

A. Yes.

Q. Now despite Mr. Stanford telling you that, like he

said on the video, towards the end of your time with

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2146

Mr. Stanford, did you start having concerns about whether,

in fact, all the money was coming from him?

A. I just wondered where all the money was coming from

because it was a huge amount of money with the airlines

and all.

Q. What do you mean when you say, "with the airlines and

all"?

A. That was the biggest endeavor. To start two airlines

in the Caribbean was a huge endeavor.

Q. That's the Caribbean Sun and Star you mentioned?

A. Yes.

Q. Was it also costing a lot for all these construction

projects --

A. Yes.

Q. -- in Antigua?

And if the money wasn't coming from

Mr. Stanford's personal wealth, did you have a suspicion

where it possibly could be coming from?

MR. SCARDINO: Assuming facts not in evidence.


BY MR. COSTA:

Q. Did you know which other business of Mr. Stanford had

funds to support this type of construction and these two

airlines?

A. I was not aware -- I was not aware of where it came

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2147

from. I don't know.

Q. You didn't know -- you didn't know where the money

came from?

A. No.

Q. You didn't see any financial records?

A. No.

Q. But did you have a concern -- if it wasn't coming

from Mr. Stanford, were you concerned about where it might

be coming from?

A. Yes.

MR. SCARDINO: Too late.

BY MR. COSTA:

Q. What was your concern about where it might be coming

from?

MR. SCARDINO: Objection to relevance as to

what his concern might have been.


MR. COSTA: Your Honor --

THE COURT: What?

MR. COSTA: It's -- I'm going to go ahead, but

it's part of the reason he --

THE COURT: Well, thank you for going ahead,

but I appreciate that.

What else, though, Counsel? What else do

you want to say to get me to reverse that ruling? That's

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2148

what I want to know.

MR. COSTA: Well, I just want to --

THE COURT: Put it that way.

MR. COSTA: I want to put it in context to make

it relevant as for his concerns when he left the company.

THE COURT: All right. He had concerns. See

if it's relevant.

BY MR. COSTA:

Q. Let's go to Government 115, please, which is already

in evidence.

Do you recognize this as a Stanford

International Bank annual report?

A. Yes. 2 -- I'm sorry. 2002.

Q. That's towards the end of your time with

Mr. Stanford?

A. Yes.

Q. And in the 16 years you were with Mr. Stanford, did

he ever say that bank money was going to the development

corporation?

A. No.

Q. Did you ever see any bank documents that said that?

A. No.

MR. COSTA: If we can turn to Page 50 of this

annual report. If we can highlight the top portion, that

first note.

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2149

BY MR. COSTA:

Q. This shows the bank's supposed investments for 2002.

Do you see it lists total assets in the

investment portfolio of 1.5 billion, Mr. Knoche?

A. 1.573 billion, yes.

Q. And what does it say it has in equities?

A. $720,900,000 -- $720,951.040.

Q. And what about treasury bonds?

A. $832,336,398.

Q. It's actually 852. 852 million on treasury bonds?

A. 852 million on treasury bonds, yes.

Q. Anywhere on there that you see it showing real estate

investments?

A. No.

Q. You were the president of the development company?

A. Yes.

Q. Did Mr. Stanford ever tell you he had received loans

from this Stanford International Bank to help fund the

development company?

A. No.

Q. I want to show you Government 336.

Do you recognize the signature on the

second page of this, Mr. Knoche?

A. Yes, I do.

Q. Whose signature is it?

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2150

A. R. Allen Stanford.

Q. And what type of document is this?

A. It is a promissory note.

MR. COSTA: Government offers 336.

MR. SCARDINO: Can I have just a second?

THE COURT: Sure.

MR. SCARDINO: No objection.

THE COURT: Okay. Keep in mind 336 --

MR. SCARDINO: Is it offered for the truth of

the matter?

MR. COSTA: It's just a contract, and it's

signed by the defendant as a party opponent.

THE COURT: All right. Keep in mind if you're

going to enter it -- if you're going offer it for other

than the standard reason, I think you just mentioned that

you would.

MR. COSTA: We're offering this for all

purposes. It's a document signed by Mr. Stanford. It's a

statement by party opponent.

THE COURT: Correct. What I'm about to say,

everything is already in evidence; okay. For -- what is

it -- just for the docket itself. I'm not going into the

exact determination.

So if you would, just say you're about to

discuss a certain exhibit and just put them on notice.

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2151

And so it may go ahead with no objection.

But anyhow, 336 is in for all purposes.

MR. COSTA: Thank you, Your Honor.

If we can highlight the top portion,

including the first full paragraph. Perfect. Thank you.

THE COURT: Ladies and gentlemen, we'll take a

break in about five minutes.

BY MR. COSTA:

Q. What's the date on this, Mr. Knoche?

A. December 31, 2002.

Q. I think you've said you left in 2003; is that

correct?

A. That's correct.

Q. So you were working for Mr. Stanford on that day?

A. Yes.

Q. And it's a promissory. It says Promissory Note.

What's a promissory note?

A. That's a debt that -- it says -- it's a debt.

Q. And do you see that it says, "For value received,

R. Allen Stanford promises to pay to the order of Stanford

International Bank," lists the address, "the principal sum

of $168 million, together with any unpaid interest at the

rate" -- "and on the terms set forth below."

Do you see that?

A. Yes.

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2152

Q. At the top, it lists that amount again, $168 million?

A. Yes.

Q. Were you ever told about this when you worked for

Mr. Stanford?

A. No.

Q. Were you ever told that this loan was helping to fund

some of the development corporation projects that you were

in charge of?

MR. SCARDINO: Assuming facts that are not in

evidence. Object.

MR. COSTA: Just asking if Mr. Stanford told

him that.

THE COURT: Well, again, are you going for link

it up later?

MR. COSTA: The next witness is going to show

hundreds of millions of dollars going to that development

corporation.

MR. SCARDINO: Well, okay. If the next witness

does it that's fine, but this witness doesn't have

knowledge of it.

MR. COSTA: But all I need is a good faith

basis to ask the question.

THE COURT: I overrule the objection with that

caveat, with that proviso.

BY MR. COSTA:

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2153

Q. Did Mr. Stanford ever tell you that this $168 million

he was taking out of the bank, that some of that was being

used to fund the development corporation which you were

president of?

A. No.

Q. Would it have concerned you if you had seen this

promissory note and heard that some of this money was

going to the development corporation?

A. Yes.

Q. Why?

A. That the depositors and the bank would not have --

were told that there were not loans being made.

Q. I want to show 337.

MR. COSTA: Is it in, Your Honor?

THE COURT: Pardon me. They're still talking.

MR. COSTA: Give you a second.

THE COURT: But the clock is on them.

MR. SCARDINO: We don't have any objections to

this, Judge.

THE COURT: Okay. What exhibit then?

MR. COSTA: 337, Your Honor.

THE COURT: It's already been identified?

MR. COSTA: No. This is the first time it's

been discussed at trial.

THE COURT: Hang on a second. 337 is admitted.

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2154

BY MR. COSTA:

Q. When did you leave in 2003?

A. At the end of June 2003.

Q. About halfway through the year?

A. Yes.

Q. And this is dated the end of 2003; correct?

A. Yes.

Q. And does it look pretty much --

MR. COSTA: If you can go back to the full

document for a second, please. Please blow up --

BY MR. COSTA:

Q. Does that look similar to the prior promissory note

from 2002 I showed you?

And I can hand that to you, if you want.

Just generally, is it the same --

A. Yes.

Q. -- type of document?

But it's just one year later,

December 2003?

A. One year later, yes.

MR. COSTA: If we can go to the top portion

again, please.

BY MR. COSTA:

Q. And what is the amount in December 31, 2003, that

Mr. Stanford now owes Stanford International Bank?

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2155

A. 330 million.

Q. And in 2003, there was still a lot of construction

being done on all these -- the Antiguan development we

looked at?

A. Yes.

MR. COSTA: This is a good stopping point if

you want a break, Your Honor?

THE COURT: Ladies and gentlemen, it's now

3:55. We'll take our 20-minute break for the afternoon.

See you back ready to resume at 4:15.


(The following was held before the jury.)

THE COURT: Thank you. Be seated.

MR. COSTA: May I proceed, Your Honor?

THE COURT: Yes.

MR. COSTA: Thank you.

BY MR. COSTA:

Q. Mr. Knoche, before the break, we were talking about

Government 337, which is this promissory note from the end

of December 2003 for $330 million.

And you said you were never told either in

2002 or 2003 that money from the bank was going to the

development corporation you were president of?

A. That's correct.

MR. COSTA: If we can go to Page 2 and look at

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2156

the signature. Blow up the signature portion.

BY MR. COSTA:

Q. Do you recognize the signature on that promissory

note?

A. Yes.

Q. Whose signature is that?

A. R. Allen Stanford.

Q. During the break, did I hand you Government 115,

which is the 2002 annual report?

A. Yes.

Q. And to save time, did I ask you to look through it

during the break?

A. Yes.

Q. In 2002 --

MR. COSTA: If we can go back to 336 real

quick.

BY MR. COSTA:

Q. 2002, was that the year when there was the

168 million-dollar promissory note we saw?

A. Yes.

Q. Do you recall that? It's on the screen.

A. Yes.

Q. Anywhere in that 2002 annual report for the Stanford

International Bank did you see disclosure of this

168 million-dollar loan?

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2157

A. No.

MR. COSTA: If we can go to Government 111,

which has already been referenced Your Honor. Go to

Page 21. I'm sorry.

BY MR. COSTA:

Q. Do you see that that's the Stanford International

Bank annual report? It's for 1998? It's hard to read,

but --

A. Yes.

MR. COSTA: And if we can go to Page 21.

BY MR. COSTA:

Q. In this annual report, do you see disclosure of a

loan the bank extended to Robert Allen Stanford in the

blown-up portion?

A. Yes.

Q. It says on December 31st of '96, the bank extended to

Robert Allen Stanford, a director, a loan in the amount of

13 million and change for two years?

A. Yes.

Q. And it gives the balance of still 11.6 million --

A. Yes.

Q. -- at the end of '97?

And it gives more information about that

particular loan?

A. Yes.

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Q. So in 1998, there's discussion in the annual report

of a 13 million-dollar loan, but in the 2002 annual

report, you saw no discussion of 168 million-dollar loan?

A. That's correct.

Q. Is there a term you would use to describe the type of

loan being disclosed in this 1998 annual report?

A. That would be a related party transaction.

Q. Were you ever told when you worked for Mr. Stanford

that the bank or your company, Stanford -- the company you

were president of, Stanford Development, was using

international financial reporting standards?

A. No.

Q. Were you ever told that because of those

international financial reporting standards, that related

party transactions were not required to be disclosed?

A. No.

Q. And here in the '98 report, there is such a

disclosure; correct?

A. That's correct.

MR. COSTA: If we can go back to the 2002

annual report, which is Government 115.

BY MR. COSTA:

Q. Is that the one you looked through? It that

Government 115? There might be a sticker on it. Is that

the 2002 annual report --

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A. Yes.

Q. -- that you looked at during the break?

MR. COSTA: And if you can turn to the page --

BY MR. COSTA:

Q. That's the one you said did not have the disclosure

of the 168 million-dollar loan?

A. That's correct.

MR. COSTA: If we can go to Page 59 on the PDF.

BY MR. COSTA:

Q. It might be different than the hard copy, Mr. Knoche.

If you can look on the screen.

MR. COSTA: If we can highlight the top couple

paragraphs.

BY MR. COSTA:

Q. It says, "Independent auditors' report to the

members."

Are you familiar that the annual reports

for the bank typically had this independent auditor

report?

A. Yes.

Q. Who was the bank's independent auditor throughout the

whole time you worked for Mr. Stanford?

A. It was Cas Hewlett.

MR. COSTA: And if we go to the bottom.

BY MR. COSTA:

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2160

Q. Is Mr. Hewlett signing off in this independent

auditor's report?

A. Yes.

Q. And generally what is an independent or outside

auditor? What's their job?

A. Their job is to examine the books and records of the

client and give the necessary tests that they feel

necessary and then state an opinion as to the accuracy of

the financial statements.

Q. Were you ever in meetings with the private banker and

Mr. Stanford where the banker raised issues about

Mr. Hewlett?

A. Yes.

Q. What did the banker tell Mr. Stanford about

Mr. Hewlett?

A. That it was a very small firm.

Q. And why was that a problem the bankers were bringing

to Mr. Stanford's Attention?

A. They said that some of their clients did not

understand why the bank would not use a larger

international firm.

Q. And you said you spent -- by the end of your time

with Mr. Stanford, you spent about half of your time down

on the island of Antigua?

A. Yes.

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2161

Q. Was there a big international accounting firm with an

office in Antigua?

A. Yes. Price Waterhouse had an office.

Q. Did you understand what Mr. Stanford said about why

he wanted to hire Price Waterhouse like the clients were

requesting?

A. I recall that he had met the general partner of that

firm and they didn't hit it off. He just didn't --

MR. SCARDINO: Objection. If he has personal

knowledge of this --


Mr. Stanford told you?

THE WITNESS: Yes.

THE COURT: Okay. Overruled.

BY MR. COSTA:

Q. What was Mr. Stanford's explanation as to why he did

not want to use Price Waterhouse which had an office in

Antigua?

A. He did not go into any detail. He just said he did

not care for that partner, and they didn't hit it off, and

he just did not want to use them.

Q. In your last couple of years working for

Mr. Stanford, did he have a new business idea that he

asked you to get involved in?

A. Yes. The Stanford Caribbean Investment Fund.

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2162

Q. So that was going to be separate from the development

corporation you worked for?

A. Yes.

Q. Was it also supposed to be separate from Stanford

International Bank?

A. Yes.

Q. A whole new business?

A. Whole new business.

Q. What was the idea behind the Stanford Caribbean

Investment Fund?

A. He wanted to spread to many of the islands, probably

about a dozen of the other islands, and seek out

investment opportunities in those islands.

Q. And what types of investment opportunities did he say

he wanted to seek out with this fund?

A. He said anything was opened, but primarily he was

interested in resorts, and then he was interested in

improving the infrastructure of those islands that would

support the resorts.

Q. Did this fund get off the ground by the time you left

in June 2003?

A. It was in its very initial stage. We had hired

managers on each of, I think, eight islands, and he had

selected a board of directors from -- with directors from

the different islands.

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2163

Q. Do you know by that point in June 2003 if he had

actually got an outside investment money for the fund?

A. I do not know.

Q. You said it involved resorts and building

infrastructure on these islands?

A. Yes.

Q. What was your reaction to this business idea?

A. Well, I thought it was very speculative.

Q. Does that include the resorts?

A. Yes.

Q. Why did you think the idea of investing in resorts in

the Caribbean was speculative?

A. I just always have thought it is. It's a very

fragile market. It's subject to hurricanes, subject to

public perception of that individual island, and it's the

difficulty of building things in the islands, difficulty

of staffing things in the islands.

Q. The first thing you mentioned was hurricanes were a

risk with resorts in the Caribbean?

A. That is a risk, yes.

Q. That speaks for itself.

The second thing you mentioned was public

perception of the island. Could you explain why you say

that's a risk?

A. Well, in any one given island, if there's a

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2164

well-publicized crime of any sort against tourists and

that spreads all over the world -- it's not something that

happens every year, but if it does happen -- it's very

detrimental to the marketing.

Q. Sort of like the Natalee Holloway that was in Aruba?

A. That would be an example.

Q. And, third, you mentioned the difficulty with

construction?

A. Yes. All of the islands are small, and you have to

import everything. If something breaks, you have to

import the repair parts. There are some good people --

workers, but there's not very many. So frequently you

have to import or relocate employees there.

Q. What about infrastructure like plumbing and

electricity, is that ever a problem --

A. Oh, yes. Your --

Q. -- in surrounding resorts?

A. The resort is dependent to some extent on the

infrastructure of the island. You have to have the proper

roads to get to the resort.

Unless you produce your own electricity

and your own water, you're relying on the government

electricity and the government water, which in almost all

the islands is very undependable. It goes out frequently.

Q. Did Mr. Stanford ever tell you as part of this

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2165

discussion of resorts in the Caribbean about an idea he

had for a resort in Antigua?

A. Yes.

Q. What did he say? What was his idea for that Antiguan

resort?

A. He wanted it to be a super high-end resort. It would

be the best of the best.

Q. Catering to which type of folks?

A. Extremely wealthy.

Q. And when he's telling you that, it was part of this

idea for the Stanford Caribbean Investment Fund?

A. No. Those were separate discussions.

Q. Did he ever tell you the bank was going to put its

money into this super high-end resort he was thinking

about in Antigua?

A. No.

Q. In your view, would that type of investment had been

consistent with what you were told about the bank's

investment strategy?

A. No.

Q. Why wouldn't it be consistent with the bank's -- what

the bank said its investment strategy was?

A. In my opinion, by any definition, that would be a

speculative investment, and the bank said it's in

conservative investments.

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2166

Q. Would an investment in a super fancy resort in

Antigua be a liquid investment?

A. No.

Q. Why not?

A. There would be -- if you wanted to sell it, there

would be very, very, very few potential purchasers.

Q. You've already told us you left Mr. Stanford's

company in 2003; is that right?

A. That's correct.

Q. By 2003, how were you -- what were your feelings

about the job with Mr. Stanford?

A. Well, I was very concerned about the amount of travel

I was doing. I was away from home about half the time.

And the Stanford Caribbean Investment Fund, that was just

going to add to that.

Q. And did you decide to resign?

A. Yes.

Q. Did you sit down with Mr. Stanford and tell him about

your decision?

A. Well, I talked to my wife first. It was a hard

decision. And we sent an e-mail and a letter giving two

months' notice, and then he and I discussed it after that,

but I gave two months' notice.

THE COURT: Again, your specific reason for

resigning was?

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2167

THE WITNESS: Travel.

BY MR. COSTA:

Q. What did you tell Mr. Stanford when you sat down with

him after sending -- after sending the two months' notice?

A. Just that, I was just away from home too much.

Q. And was that the main reason you wanted to leave?

A. Yes.

Q. Was there also a concern you had, though, by that

time working for the development corporation in 2003?

A. I was concerned about how much money was being spent,

invested.

Q. In this -- all these construction projects in

Antigua?

A. Yes.

Q. If it's all Mr. Stanford's personal money, why be

concerned?

A. Only that -- it seemed like there would be some limit

to how much money he had.

Q. Did you have a job lined up when you sent that

two-month notice to Mr. Stanford?

A. No.

Q. How much were you making as president of the

development corporation?

A. Approximately $300,000 a year including bonuses.

Q. And how old were you when you decided to resign?

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2168

A. I would have been 60 years old.

Q. Did you try looking for another job?

A. Yes.

Q. Did you find a job that paid about the same,

$300,000?

A. No.

Q. What did you end up doing?

A. Went to work for the Society of St. Vincent de Paul.

It's a Catholic nonprofit organization that assists the

poor. And I made a salary of $60,000.

Q. And what was your position?

A. Director of finance.

Q. So you took a 240,000-dollar pay cut after leaving

Mr. Stanford?

A. Yes.

Q. Did you regret that decision?

A. No, no regrets.

Q. You said at the beginning of your testimony that when

you -- the first couple of years you worked for

Mr. Stanford, he spent about 90 percent of his time

focused on the bank?

A. Yes.

Q. By the end of your time with Mr. Stanford in 2003,

from what you observed and what you understood, was the

bank still the primary business that he focused on?

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Cross-Knoche/By Mr. Scardino


2169

A. Yes.

Q. Did he ever tell you about the importance of the bank

relative to all these other companies?

A. Yes. He said it's what drives it all.

Q. And that's Stanford International Bank?

A. Stanford International Bank drives it all.

MR. COSTA: Pass the witness, Your Honor.

CROSS-EXAMINATION

BY MR. SCARDINO:

Q. Good afternoon, Mr. Knoche. How are you?

A. Very well. Thank you.

Q. My name is Robert Scardino.

We have not met before, have we?

A. No, sir.

Q. How long did you work for Mr. Stanford?

A. Sixteen years.

Q. And what did you do before you came to work for

Mr. Stanford?

A. I worked for Monarch Homes as the chief financial

officer.

Q. Okay. And what was your approximate salary at that

time?

A. Approximately $100,000.

Q. So when you went to work for Mr. Stanford, you ended

up tripling your salary?

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2170

A. Well, in 16 years. When I went to work for

Mr. Stanford, I got the same salary. I started at about a

hundred thousand dollars.

Q. And then you quit and took a job for considerably

less money?

A. Yes, sir.

Q. Now, you've talked a lot about what you observed

while you were working for Mr. Stanford about real estate

and how you were concerned about how maybe he got money to

invest in this real estate.

A. Yes.

Q. And you're a CPA?

A. Yes.

Q. When he hired you, it was for a specific purpose, was

it not?

A. Yes.

Q. And it was to develop real estate, find real estate

deals?

A. That's correct.

Q. And that was in the early '80s in Houston, or really

before that even, when he hired you?

A. He hired me in 1987.

Q. Okay. In '87 -- late '80s, I guess.

And that was a good time to invest in real

estate, wasn't it?

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2171

A. It was depressed. There was depressed real estate

out there, yes.

Q. So it was a good time to invest in real estate?

A. Yes.

Q. And how many real estate deals did you invest in for

Mr. Stanford?

A. We did four in Houston and two in Austin.

Q. Is it possible you're wrong about that and that you

made many more investments other than just four?

A. In Houston?

Q. In Houston, right.

A. Those were the four apartment -- there was only four

apartment projects.

Q. Was there Stanford Lofts?

A. That was one later, for-sale units. There was three

for-sale units, three for-sale projects.

Q. Did you count that as one of the real estate deals?

A. No. It was four rental and three for sale, total of

seven in Houston, Texas.

Q. Okay. So there was a total of seven real estate

transactions?

A. That's correct.

Q. And were they all successful?

A. They were all moderately successful.

Q. They were all moderately successful.

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2172

So it was a good idea to hire you to find

these real estate deals and invest in them?

A. Yes.

Q. Okay. And was what you were specifically hired to

do?

A. Yes.

Q. And you said there was another man that Mr. Stanford

interviewed with -- with you for this job?

A. Yes.

Q. Okay. And he hired you both?

A. That's correct.

Q. And didn't he tell you he couldn't decide who to hire

so he just hired you both?

A. Yes.

Q. Was that generous of him?

A. I wouldn't -- I wouldn't call it generous. It was a

business decision. He made a business decision.

Q. But it was the kind of guy he was. When he was

advertising for a job and two people interviewed for the

job, he didn't pick one of them. He picked both of them;

right?

A. In my opinion, I still wouldn't call it generous. He

made a business decision.

Q. Would it describe his personality where he was the

kind of guy that he thought, Well, instead of just picking

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2173

one of you, I'll just bring both of you in and see what

that brings me? Wasn't maybe -- wasn't financially smart

necessarily, but he did it anyway, didn't he?

A. I think he did it because he thought it was

financially smart, too.

Q. Okay. Well, have you ever hired people --

A. Yes.

Q. -- personally?

A. Yes.

Q. Did you advertise for a position?

A. Yes.

Q. Say, I need to hire somebody?

A. Yes.

Q. Did you interview?

A. Yes.

Q. People come in and talk to them -- talk to you about

the position that you advertised?

A. Yes.

Q. And did you ever hire two people for the same

position?

A. No.

Q. Never did?

THE COURT: Slow down a little bit.

MR. SCARDINO: I'm sorry.

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2174

BY MR. SCARDINO:

Q. So that would be unusual?

A. It was unusual, yes.

Q. Okay. And your credentials, your background, was as

a CPA; right?

A. Yes, sir.

Q. But he didn't hire you as a CPA, did he?

A. No.

Q. He didn't hire you to look at his books, did he?

A. No.

Q. He didn't hire you to look at financial statements,

did he?

A. Only in conjunction with the company I was going to

be working for.

Q. Well, Stanford Development Company eventually; right?

A. Yes.

Q. You were the president of the company?

A. That's correct.

Q. And -- but you didn't -- you weren't C -- CFO of

Stanford Development Company, were you?

A. No.

Q. You weren't the controller of Stanford Development

Company, were you?

A. No.

Q. So you didn't create reports or books and records?

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2175

Even though you had the background for it, that's not what

you were hired to do?

A. That's correct.

Q. So when you asked Mr. Stanford for information about

where did the money come from, that wasn't part of what

you were hired to determine, was it?

A. No.

Q. Okay. And he never bothered to tell you, did he?

A. No.

Q. And that was the kind of guy he was, wasn't he? You

asked him a question, and if he didn't want to answer it,

he didn't answer it.

A. Yes, that's correct.

Q. In fact, you weren't even in a position to ask that

question, were you, Mr. Knoche?

A. You could say that.

Q. You could say that. In fact, we will say that. You

were not in a position -- you weren't hired to make those

kind of determinations, were you?

A. That's correct.

Q. In fact, when you tell this jury you --

THE COURT: Slow down, Counsel. Slow down.

MR. SCARDINO: I'm sorry. I'm wound up a

little bit.

THE COURT: That's all right. I know all about

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2176

being wound up. Go on. Go on.

BY MR. SCARDINO:

Q. When you tell this jury that you were concerned about

where the money came from to make these real estate

developments, to make the deals work, that was none of

your concern, was it?

A. That's correct.

Q. Mr. Stanford never once in the 16 years you worked

for him asked you to be responsible for that kind of

information?

A. That's correct.

Q. In fact, knowing where the money came from wouldn't

have helped you perform your job for Mr. Stanford at all,

would it have?

A. No.

Q. And in your 16 years of working there, the concern

didn't rise to the level where you said, I'm going to quit

because I don't know where this money is coming from, did

it?

A. No.

Q. In fact, you quit because you were tired of the

traveling?

A. Yes.

Q. When you were interviewed by the FBI, do you remember

when that was?

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2177

A. It's been over a year ago, I believe.

Q. It's actually been a lot longer than that.

You've been interviewed twice, haven't

you?

A. Yes.

Q. Do you remember the first date being May 18th of

2010?

A. That could be right.

Q. And do you remember who the FBI agents were that

interviewed you?

A. No, I do not.

Q. Have you had an opportunity to look at reports that

the FBI generates when they interview you?

A. No.

Q. Prosecution hadn't given those to you before you came

here to testify?

A. No.

Q. Did anybody -- did the FBI, when they created the

report, provide you a copy to look at to see if it was

accurate?

A. No.

Q. Nobody's gone back over the interviews to say, Did we

get it right or not, Mr. Knoche?

A. No.

Q. Well, I'll tell you that we get a copy of that as

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2178

part of the process here, and I'd like to ask you some

questions about what you may or may not have told the FBI

during those interviews.

A. Okay.

Q. Back -- do you remember the first interview in

May 18, 2008, that took place in Richmond -- the interview

took place in Richmond, Texas?

A. 2008?

Q. No. I'm sorry. 2010.

A. Okay.

Q. May 18, 2010.

A. Okay.

Q. Okay. Before you had that interview, were you

contacted by the FBI?

A. Yes. They called.

Q. And asked you if you would talk to them?

A. Yes.

Q. And did you agree to do that?

A. Yes.

Q. Okay. And did you hire a lawyer?

A. No.

Q. And did they come over to your place of residence or

home to interview you?

A. My home.

Q. And what time of day or night was that?

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A. It was in the afternoon.

Q. And how many FBI agents arrived?

A. There were three.

Q. Did it make you nervous?

A. No.

Q. Not in the least?

A. Oh, I guess, yes, a little bit. It doesn't happen

every day, no.

Q. But you had three FBI agents at your house at

night --

A. That's correct.

Q. -- asking you about something that you know that at

that time Mr. Stanford had been charged with a crime at

that time?

A. Yes.

Q. Had been arrested at that time?

A. Yes.

Q. Okay. And had been charged with all kinds of

evildoing?

A. Right.

Q. You were familiar with that?

A. I was familiar with that.

Q. Watched -- watched it all on the news; right?

A. Yes.

Q. And, in fact, I think you told them you were

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surprised when you first heard about it. The word you

used was "shocked"?

A. Yes.

Q. And you were shocked because the 16 years that you

were there, you never say anything that you thought was

criminal, did you?

A. No.

Q. And did you tell them -- do you remember telling them

that, when they -- when they asked you if Mr. Stanford was

a hands-on or hands-off guy and in his management style?

A. What's the question?

Q. Well, I mean -- well, your report says you told them

he was a hands-off guy?

MR. COSTA: I'll object to reading from the

report. It's not in evidence. It's hearsay.


BY MR. SCARDINO:

Q. Do you remember telling them that he was a hands-off

guy?

A. No.

Q. You don't remember that? No?

MR. SCARDINO: I'll have to ask him.

BY MR. SCARDINO:

Q. Does it refresh your memory -- show you a report you

say you have not seen before, dated May 18, 2010,

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interview with you by these FBI agents.

MR. COSTA: I'd object. First of all, I don't

think it establishes it was the same FBI agents.

THE COURT: Overruled. You can take him later.

BY MR. SCARDINO:

Q. Second page I've highlighted it, so it's easy to see.

And in reference to answering the question about whether

or not Stanford had a hands-on or a hands-off approach to

managing -- management style, do you remember what you

told them?

A. Okay. To managing myself and Larry Slater, when we

first started, he was not in our offices every day or

anything. So yes, in that connotation, he would have been

hands-off. But he knew what was going on.

Q. Of course, he knew what was going on. He owned

everything, didn't he?

A. That's correct.

Q. I mean, he owned a hundred percent of all of the

companies?

A. That's correct.

Q. Do you know how many companies he owned?

A. No.

Q. It was over a hundred, wasn't it?

A. I would not know.

Q. You had no idea? Because you weren't hired to know

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that sort of thing, were you?

A. No.

Q. And then, Mr. Knoche, in August of 2011, you were

visited by the FBI again, weren't you?

A. That's correct.

Q. Do you recognize the FBI agent that interviewed you

in the courtroom?

A. I don't remember who was there, because I've talked

to them since here.

Q. Male or female agents?

A. Both.

Q. Okay. And do you remember them asking you in that

interview whether or not he had a hands-on or hands-off

approach to handling his companies?

A. I don't recall that question.

Q. Now, this would have been over a year later; right?

A. Yes.

Q. And you got the second visit.

Was it at your home again?

A. Yes.

Q. Page 4, second paragraph. Do you remember what you

told them when they asked you if he was a hands-on guy or

not?

A. It says right there he was hands-on.

Q. Hands-on.

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2183

So after they spend 13 months between

times when they interviewed you, your position changes

somewhat about his management style, does it not?

A. From what I was quoted there, one time I said

hands-off; one time I said hands-on.

Q. During the interview process, was it a circumstance

where they said, Mr. Knoche, just tell us everything you

know, and they wrote it down, or was it a process where

they asked you specific questions, and you gave them

specific answers?

A. I would say some of each. They said they wanted to

get background information, and they asked some specific

questions.

Q. Okay. So you volunteered some information?

A. Yes.

Q. Did you take notes?

A. No, I did not.

Q. Did you record the conversation?

A. No, I did not.

Q. When they were talking to you about background

information -- we've talked about this a little bit --

Mr. Stanford asked you to find residential properties such

as apartment complexes, and he specifically wanted a

certain amount of return on the investment, didn't he? Do

you remember that?

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2184

A. I don't remember the amount, but yes, he wanted to

have a certain amount of return of investment for the

partners.

Q. I think you even testified on direct examination that

he was looking for a 10 percent return.


A. No, I don't remember saying a specific amount.

MR. COSTA: The question was what he testified

to under direct examination.

THE COURT: Pardon me?

MR. COSTA: The question was what he testified

to under direct examination.

MR. SCARDINO: Said he didn't recall.

THE COURT: Said he didn't recall.

MR. COSTA: He didn't say.

THE COURT: Pardon me? Go on.

BY MR. SCARDINO:

Q. Does it refresh your memory to look at the report

that was created by that interview about what Mr. Stanford

had asked you to do and what kind of return he was looking

for? Page 2, first paragraph. I've highlighted it.

A. That was the range, yes, 10 percent.

Q. Okay.

A. I don't recall saying that specific amount, but

that's not wrong.

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2185

Q. Well, I mean, you don't think the FBI wrote down

something other than what you said, do you?

A. No.

Q. So is it safe to assume that's what Stanford asked

you to provide for him?

A. Yes.

Q. Were you able to do that?

A. Yes.

Q. How about the other fellow that interviewed for the

job? Was he also on board doing that?

A. He stayed there about one year.

Q. Was he successful?

A. Yes.

Q. Did he find real estate deals for Mr. Stanford the

way did you?

A. Yes.

Q. Did they provide a 10 percent return the way you did?

A. Yes.

Q. But he moved on?

A. He moved on.

Q. Okay. And then you go on to talk about how he funded

these various projects, do you not, with the -- in the

interview?

Oh, you haven't reviewed your reports yet.

A. (No audible answer).

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Q. Do you remember talking to the FBI about talking to

Mr. Stanford about how he was going to fund these

projects?

A. I'm sure that was part of the conversation, yes.

Q. Okay. And what did you tell them, if you recall?

A. He said he had clients of the bank that were

interested in real estate in Texas.

Q. Did that raise any red flags for you?

A. No.

Q. Create any problems for you?

A. No.

Q. And when you brought him real estate deals, tell us

generally about what kind of -- like the first deal that

you were able to bring him. You referred to it as a small

project.

A. Yes.

Q. Tell us about it. What kind of project?

A. It was approximately 70 units in Southwest Houston in

the Montrose area, near Southwest Houston.

Q. You say 70 units. What does that mean?

A. 70 apartments.

Q. And was it one apartment complex with 70 apartments

in it?

A. That's correct.

Q. Okay. And how did you acquire that? How did you

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find that?

A. We looked at all -- every apartment we could find

that was of interest that was for sale. And that had a

good location, had been very stable. They had a manager

that had been there for 22 years. And it was just very

stable clientele, and it looked like a good opportunity.

Q. Okay. Now, as part of what you were doing for

Mr. Stanford, how would you learn about there particular

project being available? What due diligence would you

have to do?

A. We drove the streets and look at reports. There's a

lot of reports issued about what is -- what is for sale.

Q. Okay. And this was the first deal that came up?

A. It probably was not the first one. It was the first

one that looked like a good opportunity.

Q. Okay. And you took it to Mr. Stanford?

A. Yes.

Q. And you explained to him that you thought it was a

good deal?

A. Yes.

Q. And who put together -- who closed the deal? Was it

you or Mr. Stanford? Who did the paperwork?

A. I did.

Q. You did? Okay.

And after it was acquired, what was the

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2188

company that actually acquired this property?

A. Guardian I Limited, Limited Partnership.

Q. And who owned that?

A. It was owned by -- the general partner was Guardian

International Investment Services, and then there were a

number of limited partners.

Q. Okay. And it was funded by these limited partners;

right?

A. That's correct.

Q. And if you put a deal together that they couldn't get

all the money together to close it, Mr. Stanford came up

with the balance of the money?

A. That's correct.

Q. And you never knew where that money came from; right?

A. That's correct.

Q. And that wasn't part of what you were paid to know or

do, was it?

A. That's correct.

Q. Not in the 16 years that you worked there?

A. No.

Q. And you also talk about in your report to the FBI

that Mr. Stanford asked you to head up a construction

effort in Antigua?

A. Yes.

Q. Do you remember that?

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2189

And what was the reason for that,

Mr. Knoche?

A. He had projects he wanted to build there.

Q. Okay. And was this after you had finished working on

developing the projects here, or were you doing it at the

same time?

A. At the same time.

Q. So you were traveling a lot, weren't you?

A. Yes.

Q. Married at the time?

A. Yes.

Q. Children?

A. Yes.

Q. Pretty tough duty, huh?

A. Yeah, yes.

Q. Working hard, but you were making good money; right?

A. Yes.

Q. And did you have a lot of interaction with

Mr. Stanford during all of this?

A. Sure, yes.

Q. I mean, you would come to him, you'd bring him deals,

and he would respond to them, y'all put it together. And

he was happy; you were happy?

A. Yes.

Q. And then he asked you to expand this, basically the

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2190

same operation, into the Island of Antigua; right?

A. That's correct.

Q. And how long were you working for him when he asked

you to actually make that step, to go to this little

island out in the Atlantic?

A. I started traveling to Antigua in the early 1990s, so

I had been there two, three years.

Q. And how many people were working under you at the

time?

A. In Texas, there would have only been, at the

apartments, maybe 15 total.

Q. Okay. And how about when you went to Antigua. And

how many were working under you then?

A. We eventually got up to where there was probably 250

employees of Stanford Development Company there.

Q. And so, did he tell you why he wanted you to go to

Antigua? What was the general plan for you there?

A. Well, he had confidence in me, and he wanted me to

head up the construction there.

Q. And what were you to construct?

So you go from acquiring real estate to

getting into a construction business; right?

A. Yes. Now, in Texas, we had also built things. We

had built the houses.

Q. And you built the place over by the baseball park;

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2191

right?

A. Yes. That was much later, but yes.

Q. Were all the real estate investments successful?

A. Yes, moderately. Only one of them was very, very

successful. The others were moderately successful.

Q. So it was smart of Mr. Stanford to get into real

estate at that time, and he got the right guy with you to

help him find the properties and acquire them?

A. Yes.

Q. Never a loss on any of the properties that you put

together?

A. No.

Q. Never a problem with funding of these properties with

Mr. Stanford?

A. No.

Q. Never a problem with somebody coming back and saying,

This was a bad deal, this was a fraud or this wasn't what

it was supposed to be?

A. Nau-uh.

Q. No misrepresentations that you know of in any of the

real estate transactions in the 16 years you worked for

Mr. Stanford?

A. No.

Q. Okay. Now, you got into some construction business,

and you built some projects while you were here. And he

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2192

asked you to move to Antigua and build some projects there

and get into construction?

A. That's correct.

Q. Okay. Now, what kind of construction? What did he

want you to build there?

A. The first thing we built was a new headquarters

building for the Bank of Antigua.

Q. Okay. Now, the Bank of Antigua, was that a bank that

Mr. Stanford owned?

A. Yes.

Q. Was he the 100 percent shareholder that I would?

A. As far as I know.

Q. And you were asked to build a new facility?

A. That's correct.

Q. And did you have to acquire property to do that?

A. I think he had already purchased the land. There was

about three acres of land at the airport, and he -- he had

purchased that from the government.

Q. Why was he on the Island of Antigua, if you know?

A. He wanted to move from Montserrat because he said it

was too small, and he just said he had looked at numerous,

and Antigua was one that he thought was the best

opportunity for him.

Q. He had a plan, didn't he?

A. Yes.

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2193

Q. I mean, he didn't just float by one day and say, This

looks like a good place to stop?

A. No.

Q. He had done some homework, hadn't he?

A. Yes, he had.

Q. In fact, he was a visionary in that regard, wasn't

he?

A. Yes.

Q. He was an entrepreneur, wasn't he?

A. He was definitely an entrepreneur.

Q. He started businesses, didn't he?

A. Yes.

Q. Okay. And he had guys like you helping him do it,

didn't he?

A. Yes.

Q. And his idea on Antigua was to build what? Not just

to build a bank, was it?

A. No. Best in the world atmosphere.

Q. Best in the world atmosphere.

Did he tell you that?

A. Yes.

Q. And what did that mean to you, "Best in the world"?

A. Just what it -- just what it says. He wanted to she

better -- as good or better than anything anywhere else.

Q. Why? Why not just okay? Why not just adequate?

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2194

A. That was his style.

Q. And did he have a plan that the best in the world --

well, the best in the world would be expensive, wouldn't

it?

A. Yes.

Q. It would cost more money than just moderate, wouldn't

it?

A. That's correct.

Q. Or just average?

A. Yes.

Q. Did you understand there was a reason why

Mr. Stanford wanted the, quote-unquote, best in the world?

A. Yes.

Q. Was there a motive behind it?

A. He wanted to show that that could be done in the

Caribbean.

Q. And was that because it generally wasn't done in the

Caribbean?

A. That would be fair to say, yes.

Q. And why was it important to him, if you know, that it

be done from the Caribbean, the best in the world could be

accomplished there?

A. That was just his vision.

Q. Well, wasn't -- didn't he have an idea that he wanted

to develop that island in such a way to attract people to

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come there?

A. Yes.

Q. So it wasn't just building something for himself that

he could look at or take a picture of himself standing in

front of it.

He had another plan, didn't he?

A. Yes.

Q. Didn't he explain that to you?

A. Yes.

Q. Okay. What was the plan?

A. That was -- that for the arriving clients of Stanford

International Bank, they would see something that they had

never seen something before their life, and they would be

so attracted to Antigua that they would tell all their

well-to-do friends, and everybody would have confidence in

Stanford International Bank on the Island of Antigua.

Q. Well-to-do friends?

A. Yes.

Q. He wasn't catering to guys like you and me, was he?

A. No.

Q. "High net worth" was the terminology?

A. "High net worth" was the terminology.

Q. High net worth. So the high-net-worth people would

have been attracted to places where they could land their

private jet --

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2196

A. That's correct.

Q. -- wouldn't they?

And what you were shown by the government

earlier -- and I don't remember which exhibit it was, but

it was the one where they were showing a hangar, and it

was -- it wasn't for public use; it was for private use?

A. That's correct.

Q. Did you build that?

A. Yes.

Q. Okay. And was that so that the high-net-worth people

would have a place to land their private jets?

A. Land and be able to clear immigration and customs

right there. They didn't have to stand in line.

Q. And did you build it?

A. Yes.

Q. So if someone would say not a brick was laid

regarding Mr. Stanford's grand plan, that's just not true,

is it? Bricks were laid; right?

A. Yes.

Q. Buildings were built, weren't they?

A. Yes.

Q. Built a fabulous marina that was with cost -- there

was no limit to the cost to that --

A. I was gone when the marina was built.

Q. When Barnacle Point was built? You saw a picture of

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it?

A. I saw a picture of it.

Q. I mean, do you have any question in your mind that it

wasn't built with the best of the best products and

finishes?

A. I have -- I'm sure it was.

THE COURT: Pardon me?

THE WITNESS: I am sure it was built with the

best products.

BY MR. SCARDINO:

Q. And you still had no idea where the money came from

to develop these projects, did you?

A. No.

Q. What are -- what other developments did you build?

What others projects did you have in Antigua besides the

airport and the bank? What else?

A. Well, there were several specific ones at the

airport, and there's also a housing development called

Cedar Valley Springs.

Q. Did you build that?

A. Yes.

Q. Describe that for the jury.

A. That was a like a U.S.-style subdivision. It had an

entrance, one entrance, and it had a little water feature,

and it had individual lots, and we built houses on the

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individual lots.

Q. Okay. And did you actually build houses?

A. Built them -- when I left, we had built some of them,

not all of them.

Q. How many did you build?

A. Probably when I was there, 20.

Q. And how many were left to be built in the development

plan?

A. Probably about that same number. It was probably

about half built when I was -- when I left.

Q. So about 40.

Do you know if it was completed or not?

A. I do not know.

Q. You told the jury that sometime during the time that

you were working for Mr. Stanford, he hired a guy named

Jim Davis or James Davis?

A. That's correct.

Q. Okay. And that they were old college chums?

A. That's what I was told.

Q. And they made -- Mr. Davis to be -- you said, the

CFO; right?

A. That's my recollection. He was the chief financial

officer.

Q. Okay. Can you tell the jury just briefly what a

chief financial officer does?

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2199

A. They're responsible for the overall accounting

function. They make -- be sure everything is paid, the

bills are paid, payroll is met. And then they're

responsible for the preparation the of financial

statements that are presented to the owner.

Q. They're in control of the money; right?

A. They, in conjunction with other management. They're

not -- they're not specifically in charge of the money.

Q. Well, I mean, you have a treasurer, right, in most

companies?

A. In most companies. In this one, there was not a

treasurer.

Q. What's a controller?

A. Controller would be usually right below the chief

financial officer, and they do more of the day-to-day

work. The chief financial officer is overseeing. The

controllers are the day-to-day.

Q. And didn't you tell the FBI that when Mr. Stanford

hired Mr. Davis as -- I think you told them a controller

instead of a chief financial officer, but doesn't make

much difference one way or the other whether it was

controller or chief financial officer?

A. Well, he replaced a controller. I think -- I think

when James Davis came in, his initial title was chief

financial officer, but I'm not positive of that.

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2200

Q. But were you put out that you weren't hired to be the

controller or chief financial officer?

A. No.

Q. I mean, you had previously been a controller; right?

A. Yes, but I was not put out.

Q. Okay. Why would that be an issue that the FBI would

ask you about then?

A. They just asked the questions.

MR. COSTA: Object to the speculation, Your

Honor.


BY MR. SCARDINO:

Q. You talked about -- in your interview with the FBI

about how much Mr. Stanford loved real estate development;

right?

A. Yes. When he got involved in a project, he very much

enjoyed it.

Q. Compulsive in what he did?

A. I wouldn't use the word "compulsive. Extremely

interested in -- I'm not sure what word. I wouldn't say

"compulsive."

Q. Well, I mean, he -- he wanted to make sure things

were done correctly; right?

A. Yeah. Absolutely, yes.

Q. Best of the best?

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2201

A. Yes.

Q. And if it wasn't done to his specifications, like

with the way the floor was finished that you talked about,

he made sure that it was changed to his specifications?

A. Yes.

Q. Okay. So he was insistent that things be done in the

manner that he wanted it done?

A. Yes.

Q. And he could be difficult in that regard, couldn't

he?

A. That's correct.

Q. He demanded it to be the best of the best?

A. He did.

Q. Okay. And let's talk a little bit how you -- you

told the jury earlier that Mr. Stanford asked you to go to

Mexia, Texas -- and I've always pronounced it Mexia, I've

heard Mexia, but I mean, I'm from here --

A. I understand it's Mexia.

Q. I think it is Mexia. But whatever.

Did you go to Mexia?

A. I did.

Q. And about how long had you been working for him when

you went there?

A. That was before I ever started. That was the

initial -- the second interview.

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2202

Q. Okay. So there was a reason why he asked you to go

there during the interviewing process, wasn't it?

A. Yes.

Q. And what was that reason?

A. Well, these three gentlemen were the board of

directors.

Q. He wanted you to meet the board of directors?

A. Yes.

Q. Before he hired you?

A. Yes.

Q. Okay. And how about the other fellow that was being

interviewed? Did he ask him to go also to Mexia?

A. He must have. I was not there at the same time, but

he -- I'm sure he did.

Q. And did you go meet these guys?

A. Yes.

Q. And tell us who they were again?

A. James Stanford.

Q. Let's stop there. Who was James Stanford?

A. Allen Stanford's father.

Q. And what kind of business was Mr. Stanford in; do you

know?

A. He said he had been mayor of Mexia for many years,

and he was also in the insurance business.

Q. Did he talk about his father at all?

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2203

A. Lotus Stanford.

Q. And what did he tell you about his father?

A. He just said he was --

MR. COSTA: Object to hearsay, Your Honor.


By the way, sometimes things can be

technically hearsay, something said, you know, by a third

party or out of the hearing of anyone here for the truth of

what was said. The judge in federal court has some

flexibility that even though technically it might be to

allow it in. I'm just electing to do so here.

Go on.

BY MR. SCARDINO:

Q. You can answer. What did he tell you about his

father, Lotus?

A. I don't recall him saying anything specific about

what business. He was a successful person, but I don't

know what -- how he --

Q. Don't know what kind of business it was?

A. No, I don't.

Q. Don't know if it had any financial services attached

to it at all?

A. I suspect it did, but, I mean, I don't know

specifically what type of financial services.

Q. Okay. And who else on the board did you meet?

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2204

A. Bill Goswick.

Q. Let's talk about him for a minute. You met him?

A. Re.

Q. Did you learn something about him?

A. He was a car dealer. He owned a car dealership in

Mexia.

Q. Anything else?

A. Not that I recall.

Q. And who else was on the board that you met?

A. Don Caldwell.

Q. Tell me who he was and what he did.

A. They called him -- he was a judge. I do not know a

judge in what court, but he was a judge.

Q. And so he was a lawyer?

A. Must have been lawyer, yes.

Q. And did you talk to him and find out anything about

his background in business or finance?

A. No.

Q. Wasn't there a British barrister also on the board?

A. In later years.

Q. Did you get to meet that person?

A. That was Kenneth Allen. In later years I met him,

yes.

Q. So the board consisted of Mr. Stanford, Allen

Stanford's father, a gentleman who was in business in a

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2205

car dealership, a judge and a lawyer, and a British

barrister or a lawyer consisted of the board of directors?

A. That's correct.

Q. Was there anything, I think the word's been used,

untoward about any of that that you saw?

A. No.

Q. So you didn't just reel away and go, this doesn't

smell right to me. After you went to Mexia, it was

something that you said, okay, let's go with this?

A. That's correct.

Q. And you did?

A. Yes.

Q. Okay. When you were in the island of Antigua

working, did you ever have an opportunity to work with

Mr. Stanford on how he acquired some of the properties?

A. Yes. He acquired almost everything from the

government.

Q. From the government of Antigua?

A. From the government of Antigua.

Q. And that would have required him to do some

negotiating with the government; right?

A. Yes.

Q. And were you with him when he was doing that?

A. Some of the times.

Q. Mr. Knoche, when -- I'll find this in a minute.

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2206

Did you find when you were dealing -- when

you were working with Mr. Stanford and he was dealing with

the government in trying to acquire these properties, was

there anything about that process that concerns you or

made you say, hey, I need to quit this business and leave

the island?

A. No, these dealings with the government were very

normal.

Q. And so, you would say they were arm's length

transactions?

A. They were arm's length transactions.

Q. And during that process, did it require him to

purchase some lands?

A. Yes.

Q. Did it require him to lease some lands?

A. Yes.

Q. Did it require him to get some sort of variances to

do what he wanted to do from the regulations?

A. There were some building permit issues, if that's

what you're speaking of --

Q. Right.

A. -- as far as variances. Yes, there were building

permit issues.

Q. And so, did he negotiate that or did you negotiate

that or how did that process work?

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2207

A. The land sales and the land leases, he would have

been the primary one. He asked me to do certain things in

conjunction with it.

MR. SCARDINO: Your Honor, at this time I'd

offer Defense Exhibit Number 6-1. I provided the

government with a copy.

THE COURT: Any objection?

(Attorneys conferring.)

THE COURT: While they're talking, any problem

going through to 6:00 o'clock today? Anybody need to take

a break? Everybody okay?

All right. Let's go.

MR. COSTA: I don't have an objection, Your

Honor. Some of these were after Mr. Knoche worked for the

company.

THE COURT: 6-1 is admitted.

MR. SCARDINO: There we go. Can you make it

any clearer than that? Go to the next page, please. There

you go. Can you go to the top of the page, please, with

the seal. And highlight that for me.

BY MR. SCARDINO:

Q. Can you see that, Mr. Knoche?

A. Yes, I can.

Q. Now, this was something that happened after you were

there; wasn't it?

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2208

A. Yes. I was gone in 2005.

Q. Okay. Well, let's move on from that.

When was it -- you were there in 2003,

weren't you?

A. I left at the end of June of 2003.

MR. SCARDINO: Okay. Let's go to the next

page, then. And at the very top of the page. If you'd

highlight that.

BY MR. SCARDINO:

Q. Can you see what that is, Mr. Knoche?

A. Yes. Executive cabinet decision in the cabinet of

Antigua and Barbuda.

MR. SCARDINO: And let's go down to the next

underlined portion.

BY MR. SCARDINO:

Q. Purchase of government lands. Do you see that?

A. Yes, I do.

Q. Would you read that for us, please.

A. "Purchases of government lands, conversion of

leaseholds to freeholds, purchase of a damaged warehouse,

the management and operation of the V.C. Bird

International Airport, airport development and

construction of a fixed base operation at the airport by

Stanford Development Company, Limited."

Q. What is a fixed base operation?

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2209

A. That's the terminology for private hangars or private

planes land as opposed to commercial airlines.

Q. And then the next paragraph, please, starting with

"Cabinet discussed." If you would read that for us,

please.

A. "Cabinet discussed the enormous benefits brought to

the country by the airport project being developed by

Stanford Development Company, Limited. In this regard,

there are several matters pending that are essential for

the completion of the airport project. Thus, the cabinet

agrees and orders as follows."

Q. Okay. And have you had an opportunity to look

through any of these types of notes that were generated by

the Antiguan government, Mr. Knoche?

A. Yes, I'm familiar with those.

Q. Okay. So there are numerous transactions between

Allen Stanford and Antiguan government to acquire

property, raw and improved land for Mr. Stanford's

development purposes, was there not?

A. Primarily raw land. I don't recall any improved

land, but there may have been some minor improvements on

some of it.

Q. Was there a hospital that they were building?

A. They wanted to build a hospital.

Q. Yes, sir. That was the intent; right?

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2210

A. That was the intent.

Q. How about a desalination plant. Was that a part of

it, also?

A. I don't recall being involved in a desalination

plant.

Q. Never was part of any project in that regard?

A. At the airport for the Stanford properties, we had a

waste treatment facility, but I don't recall that we had a

desalination plant.

Q. And did these projects actually come to fruition?

Were they built? The Stanford -- how about the Antiguan

Bank, was that built?

A. The Bank of Antiguan building was built.

Q. Okay. What other buildings did you build for

Mr. Stanford on that island?

A. The Stanford International Bank building.

Q. That's separate from the Bank of Antigua?

A. That's correct, it's two separate buildings.

Q. In fact, Mr. Stanford took over the Bank of Antigua,

did he not? Was a bank there?

A. He purchased the Bank of Antigua.

Q. He purchased it.

And was -- do you know if it was failing

at the time he took it over?

A. I think -- I don't know if it was specifically

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2211

failing. It was in bad shape, I believe.

Q. Did he put some capital in it to make it work?

A. Yes, he must have. I wasn't in -- I never saw the

financial statements for Bank of Antigua, but he must

have, yes.

Q. It was still there and up and running when you left,

wasn't it?

A. Yes, it was.

Q. As far as you know, it still is, isn't it?

A. As far as I know, it still is.

Q. What else did he build there?

A. A building for Stanford Trust Company, the Sticky

Wicket Restaurant and Bar --

Q. Okay.

A. -- the cricket field. And when I left, there were

two projects under construction, the Pavilion Restaurant

was under construction and the Antigua Athletic Club was

under construction.

Q. Were these projects inexpensive projects?

A. No.

Q. Were they very expensive projects?

A. They were very expensive projects.

Q. Would you say that hundreds of millions of dollars

were spent on developing projects on the island of Antigua

by Allen Stanford?

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2212

A. When I left, it would not have been in the hundreds

of millions, it would have been in the tens of millions,

but probably after that it became the hundreds of

millions.

Q. And that was -- why would it have become hundreds of

millions?

A. I assume they continued to build things. They

finished off the Pavilion. They built Barnacle Point.

I'm sure they built other things.

Q. Plus you can book one thing as you buy it as book

value and then later as market value as you get licenses

and promote it; right?

A. Say that question again.

Q. Well, I mean, you buy a piece of property and you put

it on your books at book value, what you paid for it, and

then later after you get licenses and promote it and

develop it and get infrastructure there, you can list it

as market price; right?

A. No, not to my knowledge. I don't think that's

correct.

Q. But at any rate, what he built there was a benefit

for the island, wasn't it?

A. Yes.

Q. It provided jobs?

A. Oh, yes.

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2213

Q. A lot of jobs?

A. A lot of jobs.

Q. And improved the island considerably; right?

A. Yes.

Q. You said that you built something called the Sticky

Wicket. And Mr. Costa, the prosecutor, talked to you

about that a little bit.

What was the purpose of the Sticky Wicket;

do you know?

A. It was part of the big picture. It would be a place

where the clients would -- everybody. It was a fun place.

It was a sports bar type of place that featured cricket.

And cricket is the number one sport in Antigua.

Q. Is cricket a sport all around the world, isn't it?

A. Yes.

Q. I mean, in fact, it's big in England and India?

A. It is.

Q. South America?

A. It's extremely popular in some places.

Q. Did you know whether or not they had a ticket --

ticket -- cricket team -- hard to say -- a cricket team on

the island?

A. Well, there was little club teams, and they were part

of the West Indies team. The West Indies played as a

whole in the international competitions. When they played

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2214

England, they would play as the West Indies, not as

Antigua.

Q. And they were good, weren't they?

A. Yes.

Q. In fact, they beat teams around the word, didn't

they?

A. In their early -- past decades, especially, they were

extremely strong.

Q. And do you understand how cricket is played?

A. I've watched the matches, but I can't say I

understand the sport that well, but it's -- I've watched

some.

Q. They don't run around bases like we do, they run up

and down --

A. They run back and forth.

Q. And a sticky wicket is a spot where -- a wicket

that's hard to hit or knock down?

A. Yes.

Q. Understand that?


Q. So Mr. Stanford built this facility, the sports

facility, called the Sticky Wicket, and he built a big

cricket field next to it. Have you seen pictures of it?

A. I was there.

Q. Did you build it?

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2215

A. Yes.

Q. Okay. And next to it, he built a health club

facility; right?

A. Yes. That was under construction when I left.

Q. Was there -- did he change his philosophy when he was

building all this? Did he decide it shouldn't be the best

of the best?

A. No.

Q. Was the best of the best?

A. Best of the best.

Q. So did he tell you what his idea was in investing all

of these tens of millions of dollars in things like the

Sticky Wicket and the cricket field?

A. It was all -- just like he explained in that talk he

gave, that's part of the big picture. It was to make it a

world-class destination.

Q. Anything fraudulent about that, Mr. Knoche?

A. No.

Q. Do you have any problems with that? Did you run away

from the island when he told you what he was going to do

in that regard?

A. No.

Q. Did it seem like a good idea to you that a guy with

Mr. Stanford's vision and money that investing in a sports

franchise like that might pay off big later if it worked?

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2216

A. I'm not sure I ever thought it was going to pay off

big, no.

Q. Did you ever hear of a guy named Tex Schramm?

A. Yes.

Q. He bought a sports franchise?

A. Sports franchise. Yes, it's not possible -- not

impossible. Many sports franchises achieve.

Q. Turned out pretty good, didn't it, for Mr. Schramm?

A. Yes.

Q. Okay. So would it be consistent or inconsistent with

what you knew about Mr. Stanford in the 16 years that you

worked for him that he would be the kind of guy that would

invest tens of millions of dollars in a sports franchise

that had the opportunity maybe to make him a whole a lot

of money later or maybe not make any money at all?

A. Now, the involvement in cricket was after my time. I

mean, we built a cricket field. But I just read in the

newspapers what he did as far as having a cricket team and

all that. That was after my time.

Q. You didn't know about the tournament he put on with

the prize money he put up of $20 million?

A. That was after my time.

Q. That was after.

Did you follow that, though?

A. I read about it some in the newspaper.

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2217

Q. Okay. But you knew what he was up to when you were

reading about all that? He was promoting the sport on the

island, wasn't he?

A. Yes.

Q. And he actually changed it so that the game was

shorter, the whole idea was to -- because cricket matches

can last for days; right?

A. I didn't -- there was two types -- there was always

two types of cricket, the full -- whatever they call it --

match, and then they had some condensed ones that were --

but I think that concept was always there.

Q. So he -- when he had you build all these structures,

the whole idea was to promote cricket. And, actually,

were you there when he was negotiating with the sports

authorities for television rights and marketing rights for

the team?

A. No.

Q. You didn't have anything to do with any of that?

A. Nothing to do with any of that.

Q. You strictly were acquiring land and developing land?

A. That happened -- those things you mentioned happened

after I left, yes.

Q. And were you -- you were there when he was talking

about building the Island Club; right? He talked to you

about that?

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2218

A. What is the Island Club?

Q. The Island Club. The development for the

billionaires to have a place to stay, a place to dock

their yachts and land their jets.

A. I never heard it called that.

Q. What did you hear it called?

A. There was a marina at Barnacle Point that he was

going to build, but I never heard of the terminology

Island Club.

Q. But you heard of the idea from Mr. Stanford that what

his idea was was to build a place for some of the richest

people in the world to come and do whatever they do?

A. A resort, yes.

Q. A resort?

A. Yes, he always had a vision of --

Q. You knew about that?

A. I knew about his vision for a world-class resort.

Q. And he was acquiring property on and near -- on the

islands near the island of Antigua to accomplish that,

wasn't he?

A. When I left, he was negotiating, as I recall, for the

Guana Island area.

Q. And did he ever acquire any of the islands for this

dream as a resort for billionaires? Did he acquire

property while you worked for him?

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2219

A. I don't -- I'm not sure. He was close probably, but

I don't remember if he acquired Guana Island and the land

around it before I left or not.

Q. Mr. Knoche, how long did Allen Stanford talk to you

while you worked for him about this idea of a resort for

billionaires?

A. The last few years.

Q. So it wasn't just an overnight thing?

A. No.

Q. Did you have any idea of how he planned to structure

that, whether or not it was going to be something like a

club as opposed to a high-end place for people to come and

have their own home?

A. I think he was looking at all possibilities where

people would buy into a club and people were -- and

another possibility where people -- it was strictly a

resort. They would come there and pay their money and

then leave.

Q. While you were there, I mean, did he -- did you see

him spend tens of millions of dollars on architecture

plans, hiring architects to come in and help him design?

A. Certainly millions and maybe tens of millions. But I

don't think tens of millions. I would say when I was

there millions of dollars, but then --

Q. On architecture plans?

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2220

A. On architecture plans.

Q. For the wealthy people to come?

A. Yes.

Q. So it wasn't just a dream, was it?

A. No. He was planning.

Q. Spent a lot of money on it, didn't he?

A. Yes.

Q. How about people that come in and build a

infrastructure with information technology and things of

that nature there for this club for the rich people?

A. I'm not familiar with that.

Q. You didn't know anything about that?

A. No.

Q. But because of what you did, you were familiar with

some of the work that he had done regarding engaging the

services of architects?

A. Yes.

Q. Are you familiar with the firm he hired out of

New York for that purpose?

A. Out of New York? No.

Q. What firms are you familiar with that he used in that

regard?

A. He used two from Houston, Watkins, Hamilton & Ross

and Jackson & Ryan, and then there was some firm in

Florida that I don't recall the name.

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2221

Q. And how far did they get when you were there that you

know of in helping him design plans for this club for the

rich people?

A. I don't recall very far along at all when I was still

there.

Q. But you know he had been talking about it and working

on it for years?

A. Yes.

Q. Let me shift gears on you for a minute.

Mr. Costa, the prosecutor, showed you some

information about -- from some of the annual reports that

Mr. Stanford had produced and information of that nature.

Are you familiar with IFRS? Do you know

what that is?

A. It's international financial reporting system or

something like that.

Q. Okay. I think that's close enough.

So you are somewhat familiar with it?

A. Yes.

Q. What is it that you understand?

A. Well, the United States has its own what call GAAP,

accepted accounting principles. Great Britain has also

their GAAP. It's international. I never dealt with it.

But it's a body that oversees some of the other countries

or some of the other locations in the world besides the

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2222

United States and Great Britain.

Q. So you're not familiar with their reporting

requirements?

A. No.

Q. So when Mr. Costa asked you questions about whether

or not Mr. Stanford reported some loans to shareholders on

financial statements, you do know that they were working

under this IFRS rules instead of GAAP rules, right,

because they were on the island of Antigua?

A. They were on the island of Antigua.

Q. So they weren't using GAAP principles, were they?

A. I would have thought they were using the British

GAAP, but it might not have been required.

Q. So you just don't know, do you?

A. I don't know.

Q. And you don't know if these reporting requirements

required Mr. Stanford to list these from loans to

shareholder in the reports or not, do you?

A. No.

Q. You don't know whether it's okay or whether it's real

bad, do you?

A. I don't know according to the standards if it's okay

or if it's real bad.

Q. And the loans to shareholder, Mr. Stanford never

consulted with you about loans -- there's Government's

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2223

Exhibit 337 that showed a 330 million-dollar loan to

shareholder. He showed that. Do you remember that

exhibited?

A. I remember the exhibit, yes.

Q. And, I mean, you're a CPA; right?

A. Yes.

Q. So you're familiar with sometimes a way to capitalize

a company is to take funds from another company if a

person owns both companies? Say, for example, I own

Company A and B, and I've got capital in A, and I want to

transfer it to B, and I want to avoid a taxable event, one

of the ways to do that is to borrow money, for me to

borrow money from A and loan it to B; right?

A. Yes.

Q. Anything wrong with that?

A. No. I think it should be disclosed, but there's

nothing illegal about it.

Q. Under GAAP rules, you think it should be disclosed,

but you don't know anything about the international

regulations disclosing it, do you?

A. I do not.

Q. So you don't know if it's wrong or not?

A. Not according to those regulations.

Q. So if I do that, that would be a way for me to put

capital if Company B needed it, that's a way for me to

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2224

accomplish it?

A. Yes, sir.

Q. Disclosed or not; right?


Q. Perfectly legitimate; right?

A. I don't know if it's perfectly legitimate or not. I

don't know --

Q. Well, you're a CPA?

A. I don't know under those regulations. You're telling

me that under those regulations disclosure is not

required.

Q. Let's talk about one thing at a time. I own Company

A and then B through Z. A's got plenty of capital, B

through Z needs capital. They're start up. They're --

hopefully they'll be successful, but not yet. So they

need capital.

So the way I transfer the money is I

borrow money from A, loan it to myself, and then loan it

to these companies. Now, I owe what I borrowed from A,

but B through Z owns me what I loaned to them; right?

A. Right.

Q. Nothing wrong with that, is there?

A. No.

Q. Now, you're talking about whether it should be

disclosed or how it should be disclosed?

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2225

A. Correct.

Q. Separate issue, isn't it?

A. Yes.

Q. So if it was transferred in a way that -- if I did

something stupid like take money from A and call it a

constructive -- call it a dividend or income, I'm going to

pay taxes on that, aren't I?

A. Yes.

Q. And the way to avoid that is to call it a loan,

wouldn't it?

A. Yes.

Q. Now, are you familiar, Mr. Knoche, with the fact that

the Internal Revenue Service took issue with the way

Mr. Stanford was moving money from A, loaning it to

himself, and transferring it to B through Z, and the

Internal Revenue Service audited him from top to bottom

regarding those transactions. Do you know that?

A. He told me he had been audited many times.

Q. What he had told you, that the IRS kind of parked at

his door because he was -- one of these high net worth

guys; rights?

A. He just -- he didn't tell me the reason. He just

said he had been audited many times and was having lots of

problems with the Internal Revenue Service.

Q. So I guess is your answer you're not familiar with

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2226

the lawsuit he had with the Internal Revenue Service?

A. I don't know details of a specific lawsuit, no.

Q. You don't know that the IRS declared that transfer,

that loan, decided it wasn't a loan but it was a

constructive dividend and wanted him to pay taxes on it?

A. No, I did not know that.

Q. He didn't talk to you about hiring a local law firm,

Chamberlain Hrdlicka, to help him fight the Internal

Revenue Service on that characterization of that transfer

of money?

A. No.

Q. You don't know anything about that?

A. No.

Q. And you're a CPA?

A. No.

Q. He didn't --

A. Yes, I'm a CPA, yes.

Q. Yeah.

He didn't feel like he needed to consult

with you or get your advice about how to deal with that

problem, did he?

A. No.

Q. Even though it created a huge tax liability for him?

A. No.

Q. No. Okay.

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2227

MR. SCARDINO: Can I have just a moment, Your

Honor?

THE COURT: Yes, sir.

BY MR. SCARDINO:

Q. In fact, Mr. Knoche, when Mr. Costa asked you

questions on direct examination, you told him that

Mr. Stanford actually told you that he had loans from the

bank; right?

A. No.

Q. Did not?

A. No.

Q. Did I write that down wrong? Mr. Stanford didn't

tell you he had loans from the bank?

A. No, he did not tell me he had loans from the bank.

MR. FAZEL: One moment, Your Honor. I'm sorry.

THE COURT: Works both ways.

MR. SCARDINO: Can we have Government's


THE COURT: What's the number?

MR. SCARDINO: 115, Your Honor?

THE COURT: Has it been identified yet?

MR. SCARDINO: It's in evidence. The

government's identified it.

THE COURT: Has it been identified at any time?

MR. COSTA: Yes.

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2228

THE COURT: It must have been on the clock

before I started making notes. 115.

BY MR. SCARDINO:

Q. Mr. Knoche, I believe you testified on direct

examination that you had actually seen this exhibit, the

annual Stanford annual report?

A. I know what you're speaking of now. He showed me two

financial statements, one back in the '90s that showed

there was like a 13 million-dollar loan to the

shareholder, and then he showed me the 2002 financials

that showed there was no loans.

Q. Okay.

THE COURT: Just for the record, I'm looking

down here, the first notation I have when I started doing

this is 116 through 120. So 115 had been identified prior

to that group coming in?

MR. COSTA: The very first witness.

THE COURT: Okay. That listing I don't have up

here.

BY MR. SCARDINO:

Q. Mr. Knoche, you did testify on direct examination

that you had read the -- this annual report; correct?

A. I was shown the one from the 1990s that showed there

was a debt of about $13 million.

Q. Mr. Costa asked you if you had reviewed -- was it the

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2229

1990 annual report?

A. The early years, 1990, I would -- very early years,

'87, '88, '89, '90, I'm sure I looked at all of those

financial statements. Mr. Stanford asked us all to. The

later years, I would not have read those unless I was

shown it in court today.

Q. Well, I believe Mr. Costa did show you Stanford's

financial -- the annual report for 2002 and asked you if

it showed any loans that were disclosed.

A. And I looked at it right now --

Q. Yes, sir.

A. -- and I did not see any loans disclosed.

Q. And let me bring your attention to a page on that

report that you said you have reviewed.

A. Well, I've reviewed it for about five minutes here in

court.

Q. Review it for another five.

A. Okay. If you can show me where.

MR. COSTA: Object. The question was the $168

loan to Mr. Stanford that was disclosed in that annual

report.

MR. SCARDINO: Actually, I'm going somewhere

completely different with this. If I can just get to the

exhibit. **


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2230

MR. SCARDINO: Would you bring up, please,

Government's Exhibit 115, Page 59, and down to the Basis of

Opinion paragraph right there.

BY MR. SCARDINO:

Q. Can you see that, Mr. Knoche?

A. Yes.

Q. Can you read that first sentence?

A. "We conducted our audit in accordance with

international auditing standards."

Q. That's not GAAP, is it?

A. That's not GAAP.

Q. So they're saying it right there in that annual

report of how they conduct their audits; right?

A. Yes.

Q. Any question in your mind now about the standards

that are applied?

A. It says they conducted them in accordance with

international auditing standards.

Q. I did leave out some things. I'm sorry, Mr. Knoche.

You talked about -- Mr. Costa asked you about whether or

not Mr. Stanford had any offices or connections in Geneva,

Switzerland?

A. Yes.

Q. And I think you said that he told you he didn't have

anything there except he had contacts there?

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2231

A. He said that there was no office to photograph when

the question came up about why did the other offices have

photographs, and he said there was nothing -- there was

not an appropriate -- or not an office to photograph.

Q. So you don't know whether or not he had somebody

there, a manager there or somebody doing research there

for him or somebody investing money there for him or not?

A. I do not.

MR. COSTA: Clarification on the timeframe.

THE COURT: Okay. Timeframe, please.

BY MR. SCARDINO:

Q. Well, when -- the timeframe would have been when you

were aware of it, when you were there working with

Mr. Stanford?

THE COURT: Is that correct?

THE WITNESS: Yes.

THE COURT: Okay. Thank you.

BY MR. SCARDINO:

Q. So again, you were asked a question about something

you really didn't know anything about; right?

A. About whether there was an office in Geneva,

Switzerland? No.

Q. Well, whether you know anything about Mr. Stanford's

business in Geneva, Switzerland or in South America or

anywhere else?

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2232

A. I know nothing of Geneva, Switzerland. I was at

the -- I helped with the South American offices, several

of those. I know nothing about Geneva, Switzerland.

MR. SCARDINO: If I can have just one minute,

Your Honor, and then I'm finished.

BY MR. SCARDINO:

Q. When Mr. Davis came on board, did you monitor his

activities at all?

A. No.

Q. You didn't have anything to do with what Mr. Davis

did, did you?

A. Nothing.

Q. I mean, you don't know how far his power extended or

his influence extended through Stanford's empire, did you?

A. I do not.

Q. You did know that Mr. Stanford owned 100 percent of

everything, though; right?

A. That's my understanding.

Q. Okay. So you don't -- after you left, you have no

idea what kind of control, if any, Mr. Davis might have

been able to influence over Mr. Stanford's empire, do you?

A. I have no idea.

Q. Did you ever have any interaction with anybody in

Mr. Stanford's organization, particularly Stanford

International Bank? Did you have any interaction with the

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Redirect-Knoche/By Mr. Costa


2233

people that worked in the bank or operated the bank?

A. I knew some of the people. As we were building the

bank facility, we talked to them about their space needs

and things like that.

Q. I mean, did you ever have any interaction with people

that sold any of the financial products?

A. Just conversationally. I mean, that's all.

Q. But you never sold any financial products?

A. I never sold any financial -- no, I never sold any

financial products.

Q. And you were never consulted by Mr. Stanford or

anybody else about how to run his business, how to market

his business, how for promote his business, were you?

A. I was not.

MR. SCARDINO: Pass the witness.


BY MR. COSTA:

Q. Mr. Knoche, do you remember at the beginning of your

cross-examination Mr. Scardino asked you about your prior

interviews with the FBI?

A. Yes.

Q. And he said the first interview, wasn't it true that

you said that Mr. Stanford wasn't all that hands-on with

you and the other individual who were running Guardian,

the real estate partnerships, at the beginning?

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2234

A. Yes.

Q. Do you remember that?

A. Yes.

Q. And you said that's true with respect to what you

were doing at the earlier years; correct?

A. Yes.

Q. What was Mr. Stanford focused on and hands-on with

respect to in those early years?

A. The bank.

Q. And that continued throughout the time you left in

2003, from what you saw?

A. Yes.

Q. Mr. Scardino asked you a number of questions about

the developments down in Antigua, the airport development?

A. Yes.

Q. Do you recall those?

And he said Mr. Stanford wanted them to be

the best in the world?

A. Yes.

Q. Did Mr. Stanford ever tell you that these

best-in-the-world buildings were being funded by the CD

holders' deposits?

A. No.

Q. What did Mr. Stanford say on that video about the

profitability of these developments in Antigua?

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2235

A. He used the words, "I'm developing, I'm paying for

things that are -- would not otherwise be financially

feasible."

Q. Makes no economic sense?

A. Makes no economic sense.

Q. And from what you've seen in the promotional

materials, what you understood hearing from Mr. Stanford,

were the CD depositors ever told that their money was

going to Antiguan real estate?

A. No.

Q. Mr. Scardino said, Did you ever see anything that you

thought was fraudulent when you worked at the development

company?


A. That's correct.

Q. If the CD depositors' money was going to fund the

development corporation and all these Antiguan real estate

deals, would that have been a problem for you?

A. Yes, it would have been a problem.

Q. Why?

A. Because the depositors of the bank were not being

told of that.

Q. Were you a depositor of the bank?

A. No.

Q. You never bought a CD?

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2236

A. No.

Q. Mr. Scardino asked you -- I think when we were

looking at the airport pavilion, he said that was

constructed; right?

A. The --

Q. The airport pavilion?

A. -- airport hangar.

Q. The hangar was built?

A. Yes, it was constructed.

Q. The Pavilion was the restaurant?

A. The Pavilion was the restaurant. That's right.

Q. What did Mr. Stanford say about the Pavilion, the

restaurant? What was its purpose?

A. It was going to be a super high-end restaurant, and

very expensive. I always pictured it was going to be

predominately for the clients of the bank, so they would

have a world class experience there.

Q. Was there a big market in Antigua for a high-end

restaurant like that?

A. No. There would have been a tiny number of people in

Antigua that could afford to eat there.

Q. Was there a big market in Antigua for these types of

high-quality business offices and other buildings?

A. No.

Q. And he asked you if the airport hangar was built, and

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2237

you said it was; right?

A. Yes.

Q. He asked about bricks being laid?


Q. Was a brick ever laid as far as you know on the super

fancy resort for billionaires?

A. Not while I was there.

Q. And when Mr. Stanford -- he asked you a number of

questions about Mr. Stanford talking for years about this

dream for the super fancy resort.

Did he ever say that was going to be

funded with CD depositors' money?

A. No.

Q. And would that be consistent with what the bank said

it did with the CD depositors' money?

A. Well, if it was used, that would not be consistent.

Q. Would putting the money into a super fancy, high-end

resort be what you consider a conservative, low-risk,

liquid investment?

A. No.

Q. Mr. Scardino talked about the number of jobs in

Antigua and things like that.

A. Yes.

Q. Do you recall that?

A. Yes.

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2238

Q. Did Mr. Stanford, as far as you know, ever tell the

CD depositors that their money was going towards economic

development in Antigua?

A. No.

Q. Mr. Scardino towards the end asked you about

accounting standards.

Do you recall that?

A. Yes.

Q. And he asked you about this IFRS?

A. Yes.

Q. Your entire time working at Stanford, were you ever

told that IFRS, international accounting standards,

financial reporting standards, were these standards that

were being used?

A. I don't recall ever being told that, no.

Q. And Stanford Development Corporation had financial

statements; correct?

A. Yes. And I just do not recall what the audit

report -- how it was worded. I do not recall if it was

under British GAAP or if it was under this intentionally.

I know we got a clean opinion, but I don't know what

standards.

Q. And he asked you about related-party disclosures; do

you recall that?

A. Yes.

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2239

Q. Now, regardless of whether loans should be disclosed,

is putting money into Antiguan real estate consistent with

what the bank said it was doing with its money?

A. No.

Q. And we saw those annual reports with stocks and bonds

and specified dollar amounts for those; correct?

A. Yes.

Q. And none of those that you've seen ever say Antiguan

real estate?

A. I never saw Antiguan real estate listed.

Q. Now, on this issue of related-party disclosures, did

I show you a few days ago an international accounting

standard concerning related-party disclosures?

A. Yes, you did.

Q. I'm going to hand it to you now.

Is that what you saw the other day?

A. Yes.

Q. And it's from this IFRS that Mr. Scardino asked

about?

A. That's correct. International Financial Reporting

Standards.

Q. And the entire subject of that accounting standard is

related-party disclosures?

A. Related-party disclosures, yes.

MR. SCARDINO: Do we have the year?

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THE COURT: While they're looking, Mr. Costa,

the number of that is, Mr. Costa?

MR. COSTA: I'm sorry. I'm not going to offer

it, Your Honor.

THE COURT: Okay.

MR. COSTA: There's no exhibit number. Is that

the question?

THE COURT: No, you didn't hear the question.

MR. COSTA: You asked what number it was.

No? Did I miss it?

THE COURT: No, you didn't.

You may continue.

BY MR. COSTA:

Q. In addition to related-party disclosures, are you

familiar with an accounting concept called "materiality"?

A. Yes.

Q. What does that mean, "materiality"?

A. It means that the transaction --

MR. SCARDINO: Object. That's beyond the scope

of cross.

MR. COSTA: He asked about international

accounting standards repeatedly and related-party

disclosures, but we can't do the same?

THE COURT: Overruled. Give both sides

flexibility on the first go-round, which I've done on the

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first go-round.

This is his rebuttal. And then we have

recross, if we have it. Go on.

BY MR. COSTA:

Q. What does the concept of "materiality" mean?

A. If a transaction is being reviewed, it would depend

on the dollar amount of it. A ten-dollar transaction

would not be material. A million-dollar transaction,

probably in most cases, would be material.

Q. That loan we saw to Mr. Stanford -- one was

$168 million; in 2003, it was $330 million -- are those

material amounts?

A. In my opinion, certainly they're material.

Q. Is it close to the line?

A. I would not think so. I think they're easily

material.

Q. And what does accounting standard of materiality --

is that a more general principle than particular

accounting standards on things like related-party

disclosures?

A. Yes. It would just apply to almost any issue. He'd

just look at whether it was material in amount as to

whether it would be delved into or not.

Q. And material -- someone -- a CD depositor, is that

the individual reading the bank's annual reports who would

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want to know -- would materiality be judged from their

perspective?

A. Yes.

Q. And if you were a CD depositor, would you want to

know if hundreds of millions of dollars had gone to the

sole shareholder, Mr. Allen Stanford?

A. Yes, I would.

Q. Mr. Scardino asked you about the real estate deals.

You said they were all profitable.


A. Yes.

Q. And you said most of them were moderately profitable?

A. Yes.

Q. There was one that was a good -- was highly

profitable?

A. That's correct.

Q. What about, though, these developments in Antigua?

Were they sold for a profit?

A. No.

Q. Was that even the goal?

A. Only Cedar Valley Springs had an anticipation of

making some money.

Q. But the airport hangar, was that --

A. No.

Q. -- the idea was to make it profit on that?

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2243

A. No. They were -- they were just built to be used by

the group of companies.

Q. The Sticky Wicket?

A. It had a chance of breaking even maybe.

Q. And Mr. Stanford on the video said this would make no

economic sense; is that right?

A. Yes.

MR. COSTA: Just one minute, Your Honor,

please.

BY MR. COSTA:

Q. Mr. Scardino asked you whether it was your business

where the funding came from --

A. Yes.

Q. -- from these various projects.

Do you recall that?

A. Yes.

Q. Would CD depositors want to know what their money was

being spent on?

A. In my opinion, they would definitely want to know

what CD money was being spent on.

Q. And regardless of whether you were entitled to know,

when Mr. Stanford was asked where the money was coming

from for all these developments down in Antigua, what did

he say?

A. Personal funds. Personal resources.

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Recross-Knoche/By Mr. Scardino


2244


MR. SCARDINO: Just a few questions.

RECROSS EXAMINATION

BY MR. SCARDINO:

Q. Mr. Costa asked you about certificates of deposits?

A. Yes.

Q. You know what those are, don't you?

A. Yes, I do.

Q. And that's when somebody goes to the bank and gives

the bank a sum of money, an agreement that the bank will

pay them back a percentage at a fixed time later; right?

A. They'll pay them back the principal plus interest.

Q. Traditionally, they're sold in 30-, 60-, 90-day,

one-year increments, five-year increments; right?

A. Yes.

Q. And they're not paying much right now, are they?

A. No, paying very low right now.

Q. Very little right now.

And when you -- the CD, when you purchase

it, is that the type of instrument where the person that

actually buys the CD, can they -- can they demand where

the bank invest that money?

A. No.

Q. They can't, can they?

A. No.

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Q. They don't have anything to say about how the bank

invests that money, do they?

A. They cannot make the bank do something, no.

Q. They cannot. And the bank -- the bank does this

because the bank makes money on that money, don't they?

A. Yes.

Q. And they deposit and invest it in various other

things to make money, don't they?

A. That's correct.

Q. And they invest it in stocks; right?

A. Yes.

Q. Bonds, notes, and sometimes real estate to make

money; right?

A. That's correct.

Q. Some make the bank money quicker. Some, it takes the

bank awhile for the bank to make money, doesn't it?

A. Yes.

Q. And sometimes the bank makes stupid decisions and

they go broke, don't they?

A. Yes.

Q. Banks like Bank of America?

MR. COSTA: Your Honor, I object.

MR. SCARDINO: Withdrawn. Withdrawn.

THE COURT: Withdrawn.

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BY MR. SCARDINO:

Q. So a certificate of deposit is an instrument where

the person that owns it holds it, and the bank makes as

promise and the bank makes good on it if the bank is

successful?

A. That's correct.

Q. Okay. As opposed to where if you bought stock in the

bank, now you have something to say how the bank invests

that money; right?

A. Right. If you buy stock, you're a partial owner.

Q. Your own part of the bank.

So that distinguishes between the two;

right?

A. Yes.

Q. Okay. And what Mr. Costa was asking you about was a

CD that Stanford International Bank, Limited was selling.

And in their annual report, they do tell

people how they're investing money in some fashion, don't

they?

I mean, he just asked you about it,

Government's Exhibit 2002; right?

A. Right.

Q. I mean, I'm sorry, Government's Exhibit 115, the 2002

annual report.

Stanford didn't have to do that, did he?

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2247

A. I don't know the specific requirement if he had to or

not.

Q. Well, you just told the jury that, if a person buys a

CD, they got nothing to say about how the bank invests the

money, do they?

A. They have nothing to say about it. They would be

interested in knowing how the money was invested, but they

have no -- they'd have no rights. They can't tell the

bank what to do with it.

Q. Right.

MR. SCARDINO: Would you please bring up

Government's 115 again and go to Page 50.

All right. Would you highlight the

investments and listed securities. Down one more. Right

there.

BY MR. SCARDINO:

Q. Would you look at that, Mr. Knoche. It says

"Investments and listed securities"; right?

A. Yes.

Q. Read the rest of it for us.

A. Equities, $720 million. Treasury bonds, notes,

corporate bonds, $852 million.

Q. Treasury bonds; right? What's that?

A. That's a debt of the government -- of governments,

usually.

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2248

Q. All right. And what's notes?

A. Notes is a debt from somebody. It doesn't define

from whom.

Q. A loan?

A. A loan.

Q. A loan.

So in the 2002 annual report, they do list

that part of what their investment is are in loans; right?

A. The word "notes," yes.

Q. Notes, a loan to somebody; right? They've invested.

Sometimes that's a good investment, isn't it?

A. Could be.

Q. Corporate America does it all the time, don't they?

A. Corporate America borrows money all the time.

Q. All the time. Okay. So they list -- they do list

that in the 2002 annual report, don't they?

A. When there's a caption that says "notes," yes.

Q. It doesn't go into detail of what it is or what it's

to, but --

A. No.

Q. -- it does -- it does list that part of what they're

investing in is -- are in notes; right?

A. That's correct.

Q. Okay. Now, Mr. Costa asked you about that the people

that bought the CDs had a right to know or were somehow

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2249

misled in where their money was being invested, and that

was a problem for you if it had been invested in either

real estate or that wasn't disclosed or loans to

shareholder that wasn't disclosed; right?

A. Correct.

Q. But you still don't know the standards, and you don't

understand the standards under which Mr. Stanford's

enterprise was being run. Mr. Costa showed you an

international financial regulatory commission standard

with no date on it; right? You don't know what year that

would have applied, do you?

A. No.

Q. And you talked about how -- in your opinion, whether

the Sticky Wicket was a profitable enterprise, and you

told Mr. Cost you thought it might break even?

A. We did projections before it was built, and that was

the projections that we thought -- and including a

restaurant consultant. He thought it might break even.

Q. Have you ever started a business?

A. No, I have not.

Q. Never have. I mean, have you ever helped people

start businesses in your capacity as a CPA?

A. No, not as a CPA.

Q. Well, in your business as a -- a business -- in your

CPA work, you know people start businesses, and sometimes

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2250

they have to invest money and it doesn't operate at a

profit at first; right?

A. Sure, yes.

Q. And you know, sometimes when people start businesses

they spend money on things like airplane hangars that you

know is not going to be profitable, but you hope brings in

people that will produce a profit?

A. Yes. That's the concept, yes.

Q. So the hangar never was going to make money?

A. Right.

Q. Right?

But if it brought in all these

billionaires, it could have been very profitable; right?

A. Right.

Q. You didn't do any studies on that, though, did you?

A. No.

Q. Okay. And if the profits from the bank had been

invested in real estate and that had been -- turned out to

be fabulously successful, you wouldn't have had a problem

with that, would you?

A. Well, I don't see it would have made any difference.

I mean --

Q. It wouldn't have been any different if the proceeds

from the bank had been invested in some sports enterprise

and it became fabulously successful, you wouldn't have had

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2251

a problem with that, would you?

A. No. I think it's the same principle. It still

wasn't -- nobody knew about it. Whether it made money or

did not make money, that wouldn't be the...

MR. SCARDINO: Thank you. Pass.


BY MR. COSTA:

Q. Mr. Knoche, did -- in your 17 years working for

Mr. Stanford --

A. 16.

Q. 16?

-- did he ever once tell you that since we

sell CDs, the bank can lie to the depositors?

A. No.

Q. What was the purpose of those promotional materials

and those annual reports by giving that information about

the investments being conservative, liquid, low risk?

Do you know why Mr. Stanford -- did he say

why he wanted to put out those promotional materials?

A. Well --

MR. SCARDINO: Objection, asked and answered,

not relevant, and outside the scope of the knowledge of the

witness.

THE COURT: Well, somewhere in there sustained.

He had three different reasons.

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2252

Move on, please.

BY MR. COSTA:

Q. Do you know -- did Mr. Stanford say why he wanted put

all these promotional materials that he required you to

read?

A. Well, to market the products, everybody has to have

marketing materials.

Q. And were depositors relying on those marketing ing

materials?

A. I would think so.

Q. And you understand that when you represent -- make

representations about a product, the law requires you to

be truthful?

A. Yes.

MR. COSTA: If we can go to 115, please.

Page 50, please.

Your Honor, we need to switch back, I

think, to our --

THE COURT: To where?

MR. COSTA: Our computer --

THE COURT: Okay.

MR. COSTA: -- please.

And if we can highlight the same thing

Mr. Scardino was just showing, but also the two lines

beneath the numbers.

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2253

BY MR. COSTA:

Q. And you talked about notes; right?

Corporate bonds and things like that can

also be called notes; correct?

A. Yes.

Q. Debt that Exxon or GM might issue is commonly called

notes as well; correct?

A. Yes, uh-huh.

Q. And beneath there, it says, "All listed securities of

or guaranteed by various governments, mature on fixed

dates up to 30 years. These investments are generally

listed on major international exchanges and are deemed

highly liquid."

Would a 330 million-dollar loan to

Mr. Stanford, do you think that was listed on a major

international exchange?

A. No.

Q. Why is listing on a public exchange relevant to

liquidity?

A. That means you have a ready market for it. You just

call your stockbroker and say, I want to sell my shares on

IBM and you sell your shares in IBM.

Q. And is that true for treasury bonds as well?

A. Yes.

MR. COSTA: Your Honor, it's very hard to

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2254

concentrate with all the --

MR. SCARDINO: I'm sorry.

MR. COSTA: -- talking.

MR. SCARDINO: I didn't mean to talk so loud.

THE COURT: Okay. Go on.

BY MR. COSTA:

Q. Have you heard the term "marketable securities"?

A. Yes.

Q. What does that mean?

A. That's the same thing, that they -- that there's a

market for them. If you want to sell them, there's people

ready to buy them.

Q. And Mr. Scardino was saying, Well, maybe the 168

million to Mr. Stanford in 2002 was included in that one

line entry.

That concept of materiality you talked

about --

A. Yes.

Q. -- would it apply to noting that the sole shareholder

had a loan for $168 million, in your view?

A. In my opinion, yes.


MR. SCARDINO: Just quickly. In fact, if we

can keep the exhibit. Same exhibit, please.

THE COURT: Okay.

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2255

MR. SCARDINO: If you would highlight that --

that very last two lines, please.

RECROSS EXAMINATION

BY MR. SCARDINO:

Q. Mr. Knoche, Mr. Costa just asked you about all listed

securities are guaranteed various government, mature on

fixed dates up to 30 years, that's referring to a

government bond, isn't it?

A. It says "All listed securities." I don't know what

it refers to.

Q. Well, I mean, that's what's being described there;

right? Government bonds?

A. No. I think there could -- no. There's treasury

notes too. No. That easily be the same thing. Treasury

notes, treasury bonds.

Q. Okay. Are you telling this jury that there's no way

you can invest in any real estate that's not liquid, not

ever, not ever an opportunity to have a real estate

investment that's --

A. No. If you know the facts, you're more than welcome

to invest in any kind of -- anything you want to, if you

know the facts.

Q. In fact, you've been involved in a lot of real estate

transactions where there was closing at the same time

where the guy made money at the closing; right? At the

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2256

closing?

A. I -- I don't follow you.

Q. Well, somebody buys a piece of real estate and then

sells it the -- to a third party right there in the same

transaction?

A. Oh, flips it at the same time? I've not been

involved, but I know property are flipped like that, where

somebody buys and sells it the same day and makes money.

That is -- that's been done before.

Q. Happened in Houston a lot in the '80s?

A. Yes.

Q. Would that be a liquid investment then, or liquid

transaction?

A. Well, in that isolated instance, it happened to be

liquid because they already had it lined up. They would

have never bought the first property if they didn't know

they could sell it.

Q. So you can just make a blanket statement that any

investment in real estate is not liquid, can you?

A. Pretty close to it. I mean, you gave one exception.

MR. SCARDINO: Thank you. Pass.

MR. COSTA: Nothing further, Your Honor.

THE COURT: Thank you, sir. You may -- you're

excused. You may step down. You're free to leave.

THE WITNESS: Thank you, Your Honor.

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2257

THE COURT: You're excused.

All right. Let's see. First thing to do,

let's get that screen up.

All right. That ends it for today. We'll

see you tomorrow, ready to resume at 10:00 a.m. Thank you

and good afternoon.


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

#

#8016 [2] - 1972:11, 1972:18

$

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1350 [1] - 2143:1

1400 [1] - 1971:17

14th [4] - 2002:21, 2067:19, 2086:21,

2087:22

15 [5] - 2019:10, 2020:9, 2034:22,

2035:7, 2190:11

15,742 [1] - 2038:2

1516 [2] - 2017:18, 2017:19

1530 [5] - 2020:22, 2022:13, 2077:6,

2080:3, 2136:10

1535A [3] - 2142:23, 2143:2, 2143:3

16 [13] - 2129:17, 2129:18, 2134:20,

2148:17, 2170:1, 2176:8, 2176:16,

2180:4, 2188:19, 2191:21, 2216:11,

2251:10, 2251:11

168 [5] - 2156:19, 2156:25, 2158:3,

2159:6, 2254:13

17 [1] - 2251:8

17,000 [1] - 2037:19

18 [4] - 2030:25, 2178:6, 2178:11,

2180:25

18th [1] - 2177:6

19 [3] - 2069:12, 2118:10, 2138:24

1980 [1] - 2102:16

1982 [2] - 2001:20, 2046:13

1983 [1] - 1973:6


2258

1986 [3] - 2067:19, 2086:21, 2087:21

1987 [9] - 2101:23, 2101:24, 2102:17,

2107:16, 2120:12, 2123:4, 2129:13,

2130:5, 2170:22

1988 [3] - 2067:20, 2086:21, 2087:22

1990 [17] - 1988:11, 1992:24, 1993:2,

1993:4, 1993:7, 1994:16, 1996:8,

1998:8, 1998:12, 2000:19, 2002:18,

2067:2, 2068:1, 2087:12, 2111:15,

2229:1, 2229:2

1990s [4] - 2133:2, 2139:21, 2190:6,

2228:23

1991 [1] - 2003:1

1994 [5] - 1990:4, 1990:17, 2002:6,

2002:11, 2003:5

1996 [2] - 2004:9, 2004:24

1998 [18] - 2003:25, 2004:2, 2005:1,

2005:22, 2007:6, 2028:11, 2028:18,

2046:9, 2059:6, 2059:9, 2068:23,

2069:10, 2069:12, 2069:18, 2072:16,

2157:7, 2158:1, 2158:6

1999 [9] - 2003:25, 2004:2, 2005:1,

2016:2, 2029:10, 2036:18, 2040:6,

2098:8, 2098:10

19th [4] - 2002:18, 2002:25, 2067:25,

2087:11

1:00 [1] - 2079:16

1:05 [1] - 2079:21

2

2 [6] - 1972:4, 2047:18, 2067:16,

2148:13, 2155:25, 2184:21

2-14 [6] - 1988:25, 1989:11, 1989:13,

1989:18, 2067:5, 2086:9

2.1 [2] - 2059:16

2.2 [3] - 2059:17, 2059:18

2.3 [1] - 2059:19

2.6 [1] - 2111:25

20 [4] - 1990:19, 2002:6, 2139:17,

2198:6

20-minute [1] - 2155:9

2000 [8] - 2030:11, 2032:21, 2036:6,

2042:21, 2046:5, 2063:15, 2063:21,

2088:18

20005 [1] - 1971:18

2000s [1] - 2139:21

2001 [8] - 2033:12, 2042:21, 2043:10,

2055:3, 2056:24, 2057:12, 2062:13,

2064:9

2002 [21] - 2060:9, 2084:20, 2148:13,

2149:2, 2151:10, 2154:13, 2155:22,

2156:9, 2156:14, 2156:18, 2156:23,

2158:2, 2158:20, 2158:25, 2228:10,

2229:8, 2246:21, 2246:23, 2248:7,

2248:16, 2254:14

2003 [23] - 2129:16, 2131:23, 2131:25,

2136:14, 2151:11, 2154:2, 2154:3,

2154:6, 2154:19, 2154:24, 2155:2,

2155:20, 2155:22, 2162:21, 2163:1,

2166:8, 2166:10, 2167:9, 2168:23,

2208:3, 2208:5, 2234:11, 2241:11

2005 [1] - 2208:1

2007 [1] - 2027:1

2008 [2] - 2178:6, 2178:8

2009 [2] - 2060:18, 2084:21

2010 [4] - 2177:7, 2178:9, 2178:11,

2180:25

2011 [1] - 2182:3

2012 [1] - 1971:5

2062 [1] - 1973:8

2084 [1] - 1973:10

2098 [1] - 1973:12

2099 [1] - 1973:17

21 [8] - 1980:18, 1983:8, 1985:18,

1998:12, 2000:19, 2073:10, 2157:4,

2157:10

214 [1] - 1994:3

2169 [1] - 1973:19

218 [4] - 1979:25, 1983:6, 1985:18,

2073:5

22 [1] - 2187:5

2233 [1] - 1973:21

2244 [1] - 1973:23

2251 [1] - 1973:25

2255 [1] - 1974:2

23 [4] - 2046:5, 2100:10, 2139:6,

2139:7

231 [11] - 2050:23, 2050:24, 2051:2,

2051:5, 2051:6, 2065:17, 2065:20,

2066:5, 2089:19, 2090:4, 2091:3

231(e [1] - 2089:3

232 [9] - 2050:10, 2051:4, 2051:5,

2051:11, 2052:14, 2089:19, 2090:4,

2091:25, 2092:7

240,000-dollar [1] - 2168:13

25 [4] - 1977:8, 2000:4, 2000:6,

2014:21

250 [1] - 2190:14

25th [1] - 1990:17

26th [1] - 1990:17

27 [1] - 2027:19

27th [1] - 1990:17

28 [3] - 1993:3, 2046:10, 2067:2

28th [1] - 1993:2

29 [2] - 2012:14, 2036:6

2:15 [1] - 2079:20

3

3 [4] - 2016:3, 2081:17, 2118:17,

2136:22

30 [12] - 1996:8, 1998:8, 2012:14,

2029:6, 2029:20, 2038:11, 2039:3,

2040:10, 2040:12, 2244:13, 2253:11,

2255:7

30-second [2] - 2038:25

30th [4] - 1992:24, 1993:6, 1994:16,

1994:21

31 [8] - 1971:5, 2028:11, 2030:25,

2032:21, 2063:15, 2088:17, 2151:10,

2154:24

31st [4] - 1990:17, 2002:10, 2003:1,

2157:16

330 [3] - 2155:1, 2223:1, 2253:14

334 [3] - 2063:3, 2063:8, 2088:16

336 [5] - 2149:21, 2150:4, 2150:8,

2151:2, 2156:15

337 [5] - 2153:13, 2153:21, 2153:25,

2155:19, 2223:1

34 [1] - 2031:3

37 [1] - 2030:16

38 [1] - 2001:5

3:55 [1] - 2155:9

3:56 [1] - 2155:11

3rd [1] - 1971:22

4

4 [1] - 2182:21

40 [1] - 2198:11

41 [1] - 2046:9

45 [1] - 2100:10

4:15 [1] - 2155:10

5

5 [6] - 2017:18, 2046:16, 2085:12,

2085:14, 2086:14, 2114:4

50 [4] - 2014:20, 2148:23, 2247:12,

2252:16

502 [1] - 2117:9

511 [8] - 1988:4, 1989:9, 1993:3,

2066:22, 2085:25, 2086:6, 2086:15

515 [2] - 1972:11, 1972:18

516 [1] - 2017:8

519 [1] - 2114:3

522 [1] - 2118:9

59 [2] - 2159:8, 2230:2

59,500,000 [2] - 2063:23, 2063:24

59.5 [1] - 2064:4

6

6-1 [2] - 2207:5, 2207:16

60 [2] - 2168:1, 2244:13

61129 [1] - 1971:14

615 [5] - 2055:17, 2055:25, 2057:11,

2058:1, 2062:4

666 [7] - 2055:12, 2055:21, 2056:13,

2057:6, 2057:25, 2058:10, 2064:10

6:00 [1] - 2207:10

6:01 [1] - 2257:7

7

7 [1] - 1971:8

7-4 [1] - 1989:13

70 [4] - 2186:18, 2186:20, 2186:21,

2186:22

713.250.5581 [2] - 1972:12, 1972:19

77002 [4] - 1971:23, 1972:4, 1972:11,

1972:19

77208-1129 [1] - 1971:15Johnny C. Sanchez, RMR, CRR - [email protected]

2259

77279 [1] - 1972:7

79535 [1] - 1972:7

8

8 [1] - 2100:20

852 [3] - 2149:10, 2149:11

86.9 [1] - 2111:25

9

9 [8] - 2002:21, 2039:23, 2057:12,

2062:13, 2067:19, 2081:14, 2086:20,

2113:16

9.4 [1] - 2111:25

90 [2] - 2108:22, 2168:20

90-day [1] - 2244:13

90s [1] - 2026:17

9th [1] - 2087:21

A

A's [1] - 2224:13

a.m [3] - 1971:6, 2035:8, 2257:5

able [14] - 1980:20, 2014:19, 2058:3,

2058:4, 2067:12, 2085:19, 2120:19,

2124:12, 2127:6, 2140:8, 2185:7,

2186:14, 2196:12, 2232:21

above-entitled [1] - 2257:12

Abreu [2] - 2043:12, 2043:13

absolute [1] - 2000:18

absolutely [4] - 1992:1, 2020:8,

2024:6, 2200:24

accept [2] - 1997:18, 2001:17

accepted [2] - 2087:13, 2221:22

accepting [2] - 2047:16, 2053:14

access [2] - 2074:22, 2075:2

accesses [1] - 1976:15

accomplish [2] - 2218:19, 2224:1

accomplished [2] - 2015:2, 2194:22

accordance [4] - 2031:11, 2046:8,

2230:8, 2230:17

according [6] - 1994:24, 1999:2,

2115:18, 2124:25, 2222:22, 2223:23

accordingly [1] - 2053:19

account [6] - 1998:3, 2074:25, 2075:3,

2075:11

accountant [4] - 2027:4, 2085:10,

2088:5, 2100:7

accountants [2] - 2009:4, 2088:21

accounting [28] - 2009:5, 2015:23,

2028:13, 2031:17, 2032:23, 2100:5,

2100:15, 2100:19, 2100:21, 2101:7,

2101:18, 2103:5, 2125:10, 2132:13,

2132:19, 2133:1, 2161:1, 2199:1,

2221:22, 2238:6, 2238:12, 2239:12,

2239:22, 2240:15, 2240:22, 2241:17,

2241:19

accounts [1] - 1982:21

accuracy [2] - 2074:17, 2160:8

accurate [9] - 1981:8, 1981:10,

1981:16, 1982:4, 1982:5, 1982:12,

1982:18, 2074:1, 2177:20

achieve [1] - 2216:7

acquire [7] - 2186:25, 2191:8,

2192:15, 2206:3, 2209:17, 2218:23,

2218:24

acquired [5] - 2187:25, 2188:1,

2205:15, 2205:16, 2219:2

acquiring [3] - 2190:21, 2217:20,

2218:18

acquisitions [1] - 2127:4

acres [2] - 2139:17, 2192:17

acronym [2] - 2007:14, 2010:10

act [6] - 2001:20, 2049:16, 2049:18,

2050:19, 2089:11, 2090:6

Act [10] - 1975:16, 2046:10, 2048:1,

2050:17, 2052:11, 2058:25, 2089:3,

2090:5, 2090:7, 2090:21

action [1] - 2002:8

actions [1] - 2014:22

activities [1] - 2232:8

actual [2] - 2050:19, 2127:7

ad [4] - 2102:23, 2102:24, 2103:3,

2130:25

add [1] - 2166:15

addition [6] - 2003:12, 2009:14,

2047:10, 2053:12, 2054:23, 2240:14

additional [1] - 2049:3

additionally [1] - 2047:8

address [11] - 1993:16, 2011:14,

2011:20, 2027:23, 2027:25, 2029:21,

2029:25, 2030:1, 2048:3, 2057:9,

2151:21

addressed [4] - 1998:25, 1999:1,

2045:25, 2057:12

addresses [2] - 2047:24, 2048:9

adds [1] - 2141:6

adequacy [2] - 2032:6, 2032:13

adequate [2] - 2042:13, 2193:25

adequately [1] - 2031:21

adhere [1] - 1982:3

adjacent [1] - 2139:17

adjudged [1] - 2002:16

Adler [1] - 2108:8

administration [2] - 2059:4, 2100:4

administrative [1] - 2012:4

admit [5] - 2022:12, 2044:12, 2051:14,

2051:23, 2056:3

admitted [9] - 1988:24, 2002:5,

2017:7, 2035:2, 2038:6, 2044:22,

2118:10, 2153:25, 2207:16

admitting [1] - 2065:23

advertise [1] - 2173:10

advertised [2] - 2103:5, 2173:17

advertisement [1] - 2130:25

advertising [1] - 2172:19

advice [2] - 2001:14, 2226:20

advisor [1] - 2001:7

aerial [1] - 2025:6

affairs [2] - 2028:10, 2032:21

Affiliate [2] - 2118:14, 2118:23

affirmatively [1] - 1992:12

affirmatively) [3] - 2020:5, 2020:7,

2237:4

afford [1] - 2236:21

afraid [1] - 1985:7

Africa [1] - 2020:6

afternoon [6] - 2099:9, 2099:10,

2155:9, 2169:10, 2179:1, 2257:6

agency [16] - 2009:18, 2014:13,

2028:22, 2029:12, 2030:14, 2040:14,

2040:23, 2041:17, 2042:6, 2042:19,

2043:24, 2045:11, 2045:23, 2055:22,

2057:7, 2069:17

agency's [1] - 2033:21

agent [10] - 1984:12, 1984:15,

1984:16, 2008:19, 2008:23, 2008:25,

2009:1, 2009:15, 2094:2, 2182:6

agents [6] - 2177:9, 2179:2, 2179:9,

2181:1, 2181:3, 2182:10

ago [7] - 2011:6, 2036:19, 2039:14,

2072:14, 2142:10, 2177:1, 2239:12

agree [10] - 2003:5, 2008:18, 2064:2,

2068:2, 2079:13, 2079:15, 2084:3,

2113:13, 2132:23, 2178:18

agreement [2] - 2055:5, 2244:10

agreements [1] - 2054:25

agrees [1] - 2209:11

ahead [12] - 1975:6, 1989:23, 2002:19,

2002:23, 2041:16, 2056:8, 2079:24,

2097:9, 2129:14, 2147:20, 2147:22,

2151:1

AIBCI [1] - 2006:16

aim [1] - 2086:1

aircraft [2] - 2024:1, 2144:18

airline [2] - 2137:25, 2138:1

Airlines [1] - 2144:23

airlines [5] - 2146:4, 2146:6, 2146:8,

2146:24, 2209:2

airplane [3] - 2137:7, 2137:8, 2250:5

airplanes [1] - 2137:8

Airport [2] - 2063:21, 2208:22

airport [24] - 2024:8, 2024:9, 2024:10,

2024:12, 2024:14, 2024:16, 2081:22,

2139:18, 2144:18, 2144:22, 2192:17,

2197:16, 2197:18, 2208:22, 2208:23,

2209:7, 2209:10, 2210:7, 2234:14,

2236:3, 2236:6, 2236:7, 2236:25,

2242:23

Alabama [1] - 2134:22

Albert [2] - 1990:13, 1994:5

alerting [1] - 2013:15

Ali [1] - 1971:20

allegation [1] - 2016:5

allegedly [1] - 2097:5

ALLEN [1] - 1971:6

Allen [51] - 1990:9, 1992:19, 1992:23,

1993:6, 1993:12, 1993:14, 1994:12,

1994:14, 1997:13, 1997:17, 1997:18,

1998:3, 1998:6, 1998:10, 1998:16,

1998:23, 1999:2, 1999:3, 2000:9,

2000:17, 2000:19, 2001:2, 2002:14,

2009:22, 2016:10, 2054:1, 2054:4,

2063:18, 2069:23, 2071:19, 2081:22,Johnny C. Sanchez, RMR, CRR - [email protected]

2260

2102:20, 2103:12, 2105:14, 2105:21,

2105:23, 2107:3, 2107:7, 2135:21,

2150:1, 2156:7, 2157:13, 2157:17,

2204:22, 2204:24, 2209:17, 2211:25,

2219:4, 2242:6

allen [2] - 2151:20, 2202:20

allow [8] - 1981:5, 1981:9, 2001:16,

2049:21, 2078:6, 2102:10, 2203:11

allowed [7] - 1977:19, 1978:1,

1981:12, 1982:9, 2049:17, 2137:9

alludes [1] - 2000:22

almost [5] - 2079:16, 2141:3, 2164:23,

2205:16, 2241:21

Althea [2] - 2053:20, 2057:12

ALTHEA [1] - 1973:4

ambit [1] - 2079:3

amended [1] - 2046:13

amendments [3] - 2070:3, 2071:13,

2072:1

America [8] - 2004:13, 2004:14,

2213:18, 2231:24, 2245:21, 2248:13,

2248:14

AMERICA [1] - 1971:4

American [2] - 2144:22, 2232:2

amount [13] - 2064:3, 2146:4, 2152:1,

2154:24, 2157:17, 2166:12, 2183:24,

2184:1, 2184:2, 2184:7, 2184:24,

2241:7, 2241:22

amounts [4] - 1978:14, 2031:14,

2239:6, 2241:12

Andrew [1] - 1971:16

Anguilla [1] - 2018:18

annual [42] - 2027:6, 2027:8, 2027:10,

2027:11, 2028:18, 2028:20, 2030:11,

2033:4, 2033:20, 2035:2, 2074:11,

2109:17, 2109:22, 2111:14, 2125:20,

2148:12, 2148:24, 2156:9, 2156:23,

2157:7, 2157:12, 2158:1, 2158:2,

2158:6, 2158:21, 2158:25, 2159:17,

2221:11, 2228:6, 2228:22, 2229:1,

2229:8, 2229:20, 2230:12, 2239:5,

2241:25, 2246:17, 2246:24, 2248:7,

2248:16, 2251:16

answer [30] - 1981:4, 1981:23, 1987:5,

1996:25, 1997:1, 2004:15, 2037:25,

2070:24, 2079:5, 2081:1, 2081:3,

2084:2, 2089:3, 2089:6, 2091:5,

2110:14, 2114:5, 2116:2, 2116:4,

2124:15, 2124:18, 2127:13, 2127:14,

2128:18, 2129:1, 2175:11, 2175:12,

2203:14, 2225:25

answer) [1] - 2185:25

Answered [3] - 2020:5, 2020:7, 2237:4

answered [6] - 1987:6, 1988:16,

2084:6, 2102:23, 2115:11, 2251:21

answering [1] - 2181:7

answers [3] - 1980:16, 2001:14,

2183:10

anti [1] - 2070:1

anti-money [1] - 2070:1

anticipation [1] - 2242:21

Antigua [109] - 1993:1, 1993:13,

1995:24, 1996:4, 1996:9, 1996:16,

1997:5, 1997:15, 1997:16, 1998:9,

2003:9, 2004:7, 2004:10, 2005:12,

2006:10, 2011:12, 2011:22, 2013:10,

2013:17, 2014:14, 2015:6, 2017:24,

2018:3, 2018:8, 2023:15, 2023:17,

2023:18, 2023:20, 2024:5, 2024:7,

2024:13, 2024:25, 2025:1, 2025:18,

2026:10, 2028:15, 2029:12, 2032:25,

2033:5, 2034:9, 2034:11, 2040:5,

2054:24, 2063:22, 2070:1, 2074:7,

2077:18, 2090:8, 2097:17, 2129:25,

2135:10, 2135:11, 2136:4, 2136:5,

2136:8, 2136:15, 2136:16, 2137:7,

2139:16, 2141:1, 2142:8, 2144:18,

2144:19, 2146:15, 2160:24, 2161:2,

2161:18, 2165:2, 2165:15, 2166:2,

2167:13, 2188:23, 2190:1, 2190:6,

2190:12, 2190:17, 2192:1, 2192:7,

2192:8, 2192:19, 2192:22, 2193:16,

2195:14, 2195:16, 2197:15, 2205:13,

2205:18, 2205:19, 2208:12, 2210:17,

2210:19, 2210:21, 2211:4, 2211:17,

2211:24, 2213:13, 2214:2, 2218:19,

2222:9, 2222:10, 2234:14, 2234:25,

2236:18, 2236:21, 2236:22, 2237:22,

2238:3, 2242:17, 2243:23

Antiguan [28] - 1975:12, 1981:9,

1982:22, 1995:18, 1996:10, 2005:6,

2005:10, 2005:14, 2025:20, 2026:5,

2028:21, 2030:13, 2052:10, 2072:6,

2073:23, 2097:15, 2142:20, 2155:3,

2165:4, 2209:14, 2209:17, 2210:11,

2210:13, 2235:9, 2235:17, 2239:2,

2239:8, 2239:10

Antiguans [1] - 2025:2

anyhow [1] - 2151:2

anyway [1] - 2173:3

apartment [9] - 2023:12, 2121:2,

2125:25, 2133:22, 2171:12, 2171:13,

2183:23, 2186:22, 2187:2

Apartments [4] - 2121:3, 2121:6,

2121:17, 2122:7

apartments [3] - 2186:21, 2186:22,

2190:11

apologize [1] - 2096:10

appear [7] - 1993:22, 1994:19,

1995:16, 1996:6, 1998:5, 1998:15,

2068:5

APPEARANCES [1] - 1971:12

appeared [1] - 1990:16

applicant [5] - 2049:4, 2049:13,

2091:18, 2092:15, 2106:23

application [17] - 2047:22, 2047:25,

2048:1, 2048:22, 2049:7, 2050:5,

2050:6, 2051:3, 2051:12, 2052:16,

2052:18, 2058:21, 2066:12, 2092:1,

2092:4, 2092:8, 2092:19

applications [1] - 2062:25

applied [5] - 2031:21, 2117:2, 2117:5,

2230:16, 2249:11

applies [4] - 2006:19, 2050:9, 2051:11,

2052:11

apply [8] - 1986:22, 2006:16, 2017:3,

2052:15, 2060:12, 2060:15, 2241:21,

2254:19

applying [1] - 2049:8

appreciate [1] - 2147:23

approach [2] - 2181:8, 2182:14

appropriate [4] - 2031:18, 2092:14,

2095:5, 2231:4

approval [3] - 2046:6, 2046:17, 2047:5

approximate [1] - 2169:21

April [5] - 2013:5, 2013:8, 2013:13,

2040:9, 2060:17

architects [2] - 2219:21, 2220:16

architecture [3] - 2219:20, 2219:25,

2220:1

area [11] - 2004:21, 2078:5, 2082:9,

2082:10, 2082:11, 2099:16, 2102:11,

2120:9, 2139:15, 2186:19, 2218:22

areas [1] - 2069:11

argue [1] - 2054:11

argumentative [5] - 2075:5, 2076:18,

2078:3, 2078:24, 2080:21

argumentive [1] - 2075:14

arguments [1] - 2078:25

arm's [2] - 2206:9, 2206:11

Arnold [2] - 2098:24, 2099:13

ARNOLD [3] - 1973:15, 2099:4,

2099:13

arranged [2] - 2064:20, 2064:21

arrested [1] - 2179:16

arrived [2] - 2131:20, 2179:2

arriving [1] - 2195:11

articles [1] - 2002:5

Aruba [2] - 2119:5, 2164:5

aside [2] - 2036:23, 2094:8

aspect [1] - 2096:22

aspects [2] - 2097:1, 2133:16

assessment [1] - 2031:15

asset [1] - 1977:19

assets [9] - 1976:17, 1977:16,

1977:24, 1979:14, 1982:20, 2026:6,

2073:2, 2073:18, 2149:3

assist [2] - 2008:10, 2049:19

assistance [1] - 1976:5

Assistant [1] - 1971:14

assisted [2] - 1972:13, 1972:21

assists [1] - 2168:9

Associate [1] - 2039:7

assume [3] - 2059:22, 2185:4, 2212:7

assumes [3] - 2076:17, 2078:2,

2080:20

assuming [4] - 2078:13, 2123:18,

2146:19, 2152:9

assurance [1] - 2031:25

Athletic [5] - 2077:18, 2136:15,

2136:16, 2139:13, 2211:17

Atlantic [1] - 2190:5

atmosphere [3] - 2128:7, 2193:18,

2193:19

attached [3] - 2024:8, 2024:9, 2203:21

attempt [2] - 2088:11, 2088:20

attempted [2] - 2020:17, 2087:2

attend [1] - 2109:15Johnny C. Sanchez, RMR, CRR - [email protected]

2261

attended [3] - 2109:24, 2115:22,

2117:19

attention [4] - 2066:4, 2108:15,

2160:18, 2229:13

attorney [5] - 1990:10, 1991:20,

1991:22, 1992:11, 2049:20

Attorney [2] - 1971:14, 1972:3

attorneys [4] - 2022:9, 2025:25,

2142:24, 2207:8

attract [1] - 2194:25

attracted [2] - 2195:14, 2195:24

audible [1] - 2185:25

audit [7] - 2026:10, 2026:12, 2031:6,

2031:11, 2031:22, 2230:8, 2238:18

audited [5] - 2030:24, 2033:9,

2225:16, 2225:18, 2225:23

auditing [4] - 2027:2, 2031:12, 2230:9,

2230:18

auditor [5] - 2027:14, 2032:10,

2159:18, 2159:21, 2160:5

auditor's [2] - 2027:12, 2160:2

Auditors [1] - 2031:2

auditors' [1] - 2159:15

Auditors' [1] - 2030:21

audits [2] - 2027:8, 2230:13

August [6] - 1990:17, 2002:11,

2043:10, 2043:11, 2056:24, 2182:3

Austin [3] - 2101:11, 2122:20, 2171:7

Australia [1] - 2020:4

authentic [1] - 2052:7

authenticate [1] - 2090:15

authenticated [2] - 2045:3, 2052:5

author [3] - 2044:7, 2071:13, 2071:14

authored [2] - 2005:24, 2006:1

authorities [3] - 1976:2, 2016:11,

2217:15

authority [3] - 2046:8, 2046:17,

2092:20

Authority [1] - 2006:2

available [3] - 1975:25, 2033:4, 2187:9

Avenue [1] - 1971:17

average [1] - 2194:9

Aviation [3] - 2137:14, 2137:16,

2138:4

aviation [2] - 2137:20, 2137:21

avoid [4] - 2079:12, 2102:9, 2223:11,

2225:9

aware [11] - 2016:1, 2016:7, 2016:9,

2024:3, 2066:10, 2078:14, 2093:16,

2138:20, 2146:25, 2231:13

awhile [1] - 2245:16

awkward [3] - 2082:18, 2082:20,

2083:7

B

bachelor's [1] - 2100:4

background [7] - 2100:1, 2103:4,

2174:4, 2175:1, 2183:12, 2183:20,

2204:17

backwards [1] - 2040:6

bad [12] - 2001:2, 2016:16, 2016:21,

2026:18, 2073:1, 2073:19, 2101:25,

2120:14, 2191:17, 2211:1, 2222:21,

2222:23

bag [1] - 2045:18

Bahamas [1] - 2005:16

Bailey [4] - 2043:16, 2043:20, 2064:23,

2065:1

Baker [1] - 1985:4

balance [2] - 2157:20, 2188:12

balances [5] - 1978:15, 1978:25,

1979:5, 1979:22

ball [1] - 2078:25

bank [160] - 1975:12, 1976:7, 1976:10,

1976:15, 1976:16, 1977:15, 1977:21,

1978:1, 1979:7, 1979:11, 1979:15,

1981:5, 1981:19, 1981:20, 1982:2,

1993:16, 1995:22, 1995:24, 1996:9,

1997:7, 1998:19, 2005:7, 2006:16,

2016:6, 2016:14, 2025:1, 2028:11,

2029:16, 2036:8, 2047:16, 2053:15,

2057:8, 2059:2, 2062:16, 2064:9,

2066:11, 2069:22, 2072:22, 2073:17,

2073:22, 2074:20, 2074:23, 2074:25,

2075:2, 2075:11, 2078:13, 2087:12,

2087:14, 2104:13, 2104:14, 2104:17,

2107:11, 2107:17, 2107:21, 2107:22,

2108:1, 2108:2, 2108:3, 2108:4,

2108:18, 2108:20, 2108:23, 2109:25,

2110:10, 2110:19, 2111:5, 2112:3,

2113:25, 2114:1, 2114:7, 2114:18,

2114:23, 2115:20, 2117:2, 2117:5,

2118:6, 2119:2, 2119:15, 2119:24,

2120:2, 2122:10, 2123:11, 2123:15,

2123:17, 2123:24, 2124:1, 2124:9,

2124:12, 2124:24, 2124:25, 2126:6,

2126:22, 2127:6, 2129:4, 2129:19,

2129:22, 2129:24, 2132:7, 2132:16,

2132:23, 2148:18, 2148:21, 2153:2,

2153:11, 2155:22, 2157:13, 2157:16,

2158:9, 2159:18, 2160:20, 2165:13,

2165:22, 2165:24, 2168:21, 2168:25,

2169:2, 2186:6, 2192:8, 2193:17,

2197:16, 2210:20, 2227:8, 2227:13,

2227:14, 2233:1, 2233:3, 2234:9,

2235:21, 2235:23, 2236:16, 2237:14,

2239:3, 2244:9, 2244:10, 2244:22,

2245:1, 2245:3, 2245:4, 2245:5,

2245:15, 2245:16, 2245:18, 2246:3,

2246:4, 2246:8, 2246:11, 2247:4,

2247:9, 2250:17, 2250:24, 2251:13

Bank [70] - 1976:12, 1976:13, 1976:17,

1977:17, 1978:16, 1979:14, 1979:21,

1980:3, 1980:15, 1994:13, 1994:15,

1995:1, 1995:4, 1995:12, 1995:22,

1995:23, 1995:25, 1996:21, 2002:17,

2002:21, 2016:2, 2016:10, 2023:11,

2024:25, 2025:1, 2026:10, 2043:6,

2043:23, 2046:1, 2046:21, 2056:19,

2057:3, 2063:20, 2067:19, 2067:23,

2074:5, 2086:20, 2087:20, 2097:16,

2098:7, 2104:15, 2109:3, 2111:4,

2111:14, 2114:8, 2139:14, 2141:16,

2148:12, 2149:18, 2151:21, 2154:25,

2156:24, 2157:7, 2162:5, 2169:5,

2169:6, 2192:7, 2192:8, 2195:12,

2195:16, 2210:12, 2210:13, 2210:16,

2210:17, 2210:19, 2210:21, 2211:4,

2232:25, 2245:21, 2246:16

Bank's [1] - 1978:23

bank's [26] - 1977:25, 1978:13,

1980:16, 1982:20, 1992:8, 1992:25,

1993:9, 1993:13, 1998:9, 2031:18,

2073:1, 2086:13, 2109:17, 2109:22,

2112:15, 2113:11, 2115:1, 2115:9,

2121:10, 2121:21, 2129:11, 2149:2,

2159:21, 2165:18, 2165:21, 2241:25

bank-rolled [1] - 2069:22

banker [4] - 2116:20, 2160:10,

2160:11, 2160:14

bankers [7] - 2068:12, 2108:24,

2108:25, 2115:21, 2116:11, 2117:17,

2160:17

banking [20] - 1976:9, 1977:7,

1981:22, 1982:10, 1982:17, 2001:7,

2004:3, 2005:11, 2005:17, 2006:11,

2006:13, 2006:23, 2011:11, 2065:11,

2065:12, 2069:25, 2086:8, 2087:21,

2087:22, 2130:3

bankruptcy [5] - 2048:23, 2048:24,

2051:9, 2066:14, 2091:6

banks [17] - 1979:13, 1979:16,

2004:18, 2013:23, 2014:19, 2014:20,

2015:19, 2015:22, 2053:6, 2054:23,

2060:4, 2061:1, 2061:2, 2094:3,

2095:14, 2245:21

banks's [2] - 2015:24, 2125:20

bar [1] - 2213:12

Bar [2] - 2137:1, 2211:13

Barbuda [5] - 2013:17, 2017:24,

2028:15, 2032:25, 2208:12

Barnacle [5] - 2138:11, 2138:13,

2196:25, 2212:8, 2218:7

barrister [2] - 2204:19, 2205:2

barristers [1] - 1999:25

base [3] - 2128:21, 2208:23, 2208:25

baseball [5] - 2019:4, 2019:5, 2019:6,

2019:7, 2190:25

based [5] - 2031:6, 2067:22, 2081:2,

2110:17

bases [1] - 2214:13

Basis [1] - 2230:2

basis [8] - 1978:10, 2031:10, 2031:13,

2070:11, 2078:16, 2078:18, 2114:14,

2152:22

Bates [3] - 1992:15, 2023:7, 2024:23

BDO [1] - 2009:5

beat [1] - 2214:5

beautiful [1] - 2102:6

became [12] - 2019:12, 2039:8,

2039:20, 2043:20, 2065:4, 2123:9,

2133:7, 2134:10, 2134:12, 2135:23,

2212:3, 2250:25

become [4] - 2040:23, 2040:25,

2123:4, 2212:5

becoming [1] - 1996:4

BEFORE [1] - 1971:10Johnny C. Sanchez, RMR, CRR - [email protected]

2262

began [2] - 2015:25, 2034:21

begin [1] - 2134:4

beginning [5] - 2085:1, 2111:21,

2168:18, 2233:18, 2233:25

begins [1] - 2040:1

behind [7] - 2019:20, 2034:22,

2039:11, 2082:1, 2097:2, 2162:9,

2194:14

belief [3] - 2093:10, 2093:12, 2094:12

below [2] - 2151:23, 2199:14

bench [1] - 1984:6

Bend [1] - 2099:15

beneath [2] - 2252:25, 2253:9

beneficial [1] - 2046:15

benefit [2] - 2003:20, 2212:21

benefits [1] - 2209:6

Best [1] - 2193:22

best [28] - 1976:21, 2025:10, 2089:11,

2140:20, 2165:7, 2192:22, 2193:18,

2193:19, 2194:2, 2194:3, 2194:12,

2194:21, 2197:4, 2197:9, 2200:25,

2201:12, 2215:6, 2215:7, 2215:9,

2215:10, 2234:18, 2234:21

best-in-the-world [1] - 2234:21

better [13] - 1980:24, 1980:25,

2001:25, 2004:4, 2005:3, 2005:5,

2005:8, 2082:1, 2119:6, 2127:21,

2193:24

between [11] - 1976:4, 1990:8, 2055:5,

2082:9, 2082:12, 2082:13, 2084:20,

2126:6, 2183:1, 2209:16, 2246:12

beyond [5] - 2035:22, 2036:22,

2054:15, 2088:13, 2240:19

bids [1] - 2140:10

big [16] - 2000:2, 2009:4, 2009:5,

2023:15, 2097:3, 2100:18, 2100:24,

2161:1, 2213:10, 2213:16, 2214:22,

2215:15, 2215:25, 2216:2, 2236:18,

2236:22

Big [1] - 2100:20

biggest [1] - 2146:8

Bill [3] - 2105:9, 2105:16, 2105:23

bill [1] - 2204:1

billion [2] - 2149:4, 2149:5

billionaires [5] - 2218:3, 2218:24,

2219:6, 2237:6, 2250:13

bills [2] - 2101:19, 2199:3

binds [1] - 2018:23

Bird [1] - 2208:21

bit [13] - 2017:5, 2040:6, 2046:11,

2099:21, 2108:11, 2127:19, 2129:14,

2173:23, 2175:24, 2179:7, 2183:21,

2201:14, 2213:7

black [1] - 2039:20

Blackman [5] - 2046:7, 2047:2,

2047:9, 2047:11, 2047:15

blank [1] - 2038:5

blanket [1] - 2256:18

block [1] - 2029:21

blocks [1] - 2103:15

blood [1] - 2001:2

blow [2] - 2154:10, 2156:1

blown [2] - 1987:20, 2157:14

blown-up [2] - 1987:20, 2157:14

board [35] - 2007:6, 2010:23, 2010:24,

2011:23, 2012:10, 2038:11, 2038:12,

2040:10, 2040:13, 2041:14, 2041:17,

2044:23, 2060:22, 2061:4, 2061:6,

2069:6, 2069:7, 2072:19, 2101:21,

2105:2, 2105:12, 2106:7, 2130:9,

2130:12, 2131:11, 2162:24, 2185:10,

2202:5, 2202:7, 2203:25, 2204:9,

2204:19, 2204:24, 2205:2, 2232:7

Board [1] - 1997:6

boards [1] - 2047:24

boat [4] - 2138:16, 2138:20, 2138:22

boats [1] - 2138:17

body [12] - 2008:7, 2008:9, 2011:7,

2028:22, 2029:1, 2061:8, 2065:13,

2066:16, 2068:22, 2069:17, 2072:19,

2221:24

bond [1] - 2255:8

bonds [20] - 2111:6, 2111:7, 2111:25,

2113:15, 2113:23, 2125:21, 2125:22,

2126:19, 2149:8, 2149:10, 2149:11,

2239:5, 2245:12, 2247:21, 2247:22,

2247:23, 2253:3, 2253:23, 2255:12,

2255:15

bonuses [1] - 2167:24

book [6] - 2039:1, 2039:23, 2039:24,

2212:10, 2212:15

bookkeeping [1] - 2099:22

books [4] - 2160:6, 2174:9, 2174:25,

2212:15

born [2] - 2018:2, 2018:3

borrow [3] - 2223:12, 2223:13,

2224:18

borrowed [1] - 2224:19

borrows [1] - 2248:14

bothered [1] - 2175:8

bottom [19] - 1980:9, 1985:19,

1985:23, 1997:12, 2015:11, 2027:23,

2029:22, 2030:8, 2042:5, 2058:3,

2058:14, 2059:3, 2083:16, 2111:21,

2118:11, 2118:20, 2118:23, 2159:24,

2225:16

bought [5] - 2216:5, 2235:25, 2246:7,

2248:25, 2256:16

Boulevard [1] - 2063:21

bowl [1] - 2082:19

bowler [1] - 2082:21

bowlers [1] - 2082:19

Box [2] - 1971:14, 1972:7

boxes [3] - 2093:18, 2093:19, 2093:25

break [17] - 1984:5, 1989:20, 2033:13,

2034:21, 2034:24, 2077:8, 2078:7,

2151:7, 2155:7, 2155:9, 2155:18,

2156:8, 2156:12, 2159:2, 2207:11,

2249:15, 2249:18

breaking [1] - 2243:4

breaks [1] - 2164:10

brick [2] - 2196:16, 2237:5

bricks [2] - 2196:18, 2237:3

briefly [5] - 2016:14, 2084:15, 2098:1,

2099:25, 2198:24

bring [12] - 2034:8, 2034:11, 2034:14,

2035:11, 2096:19, 2096:21, 2173:1,

2186:14, 2189:21, 2229:13, 2230:1,

2247:11

bringing [1] - 2160:17

brings [2] - 2173:2, 2250:6

Britain [2] - 2221:22, 2222:1

British [7] - 2117:8, 2117:13, 2118:1,

2204:19, 2205:1, 2222:12, 2238:20

broad [2] - 2011:9, 2085:13

brochure [1] - 2118:18

brochures [1] - 2118:5

broke [2] - 2035:15, 2245:19

brought [5] - 2011:23, 2141:4,

2186:12, 2209:6, 2250:12

budget [4] - 1987:12, 2041:21,

2041:22, 2140:8

budgets [3] - 2140:1, 2140:3, 2140:7

build [23] - 2139:3, 2139:22, 2189:3,

2192:1, 2192:5, 2192:13, 2193:16,

2193:17, 2196:8, 2196:14, 2197:14,

2197:20, 2198:2, 2198:5, 2209:24,

2210:14, 2211:11, 2212:7, 2214:25,

2217:12, 2218:8, 2218:11, 2220:8

Building [2] - 2103:15, 2131:12

building [31] - 2023:8, 2023:10,

2023:15, 2023:19, 2023:20, 2023:23,

2023:24, 2024:19, 2024:21, 2024:22,

2024:24, 2024:25, 2077:24, 2120:13,

2130:17, 2131:12, 2139:14, 2145:1,

2163:4, 2163:16, 2192:7, 2195:3,

2206:19, 2206:22, 2209:23, 2210:13,

2210:16, 2211:12, 2215:6, 2217:24,

2233:2

buildings [12] - 2023:5, 2025:17,

2025:19, 2025:21, 2084:25, 2139:23,

2141:1, 2196:20, 2210:14, 2210:18,

2234:21, 2236:23

built [47] - 2085:1, 2134:11, 2134:13,

2134:16, 2134:19, 2134:20, 2135:10,

2135:11, 2137:2, 2137:11, 2137:15,

2138:10, 2140:15, 2140:16, 2143:22,

2190:23, 2190:24, 2190:25, 2191:25,

2192:6, 2196:20, 2196:22, 2196:24,

2196:25, 2197:4, 2197:8, 2197:25,

2198:3, 2198:7, 2198:10, 2210:11,

2210:12, 2210:13, 2212:8, 2212:9,

2212:21, 2213:5, 2214:21, 2214:22,

2215:2, 2216:17, 2236:8, 2236:25,

2243:1, 2249:16

Business [4] - 1975:16, 2046:10,

2050:16, 2090:7

business [56] - 1976:10, 1977:7,

1993:10, 1998:20, 2001:13, 2002:18,

2004:4, 2005:11, 2005:17, 2006:11,

2006:12, 2006:14, 2006:15, 2007:3,

2008:10, 2013:10, 2016:16, 2016:21,

2036:20, 2060:24, 2067:25, 2073:1,

2101:25, 2106:3, 2120:13, 2120:14,

2133:16, 2146:22, 2161:23, 2162:7,

2162:8, 2163:7, 2168:25, 2172:17,

2172:23, 2190:22, 2191:24, 2202:21,


2263

2204:25, 2206:5, 2231:24, 2233:12,

2233:13, 2236:23, 2243:11, 2249:19,

2249:24

businesses [9] - 2023:6, 2042:19,

2104:12, 2108:16, 2135:24, 2193:11,

2249:22, 2249:25, 2250:4

but.. [1] - 2115:12

button [2] - 2061:24

buy [6] - 2000:3, 2212:10, 2212:14,

2219:15, 2246:10, 2254:12

buying [1] - 2134:7

buys [4] - 2244:21, 2247:3, 2256:3,

2256:8

BY [186] - 1973:6, 1973:8, 1973:10,

1973:12, 1973:17, 1973:19, 1973:21,

1973:23, 1973:25, 1974:2, 1975:9,

1977:13, 1980:13, 1980:19, 1983:17,

1984:3, 1986:5, 1987:17, 1988:3,

1990:1, 1990:7, 1991:17, 1992:4,

1992:22, 1997:3, 1998:1, 2000:8,

2001:6, 2017:17, 2017:22, 2020:16,

2023:1, 2027:24, 2028:6, 2028:19,

2029:8, 2029:23, 2030:3, 2030:10,

2030:20, 2031:9, 2031:20, 2032:4,

2032:9, 2040:3, 2045:7, 2045:21,

2046:12, 2049:24, 2050:13, 2052:9,

2054:13, 2056:10, 2056:16, 2057:23,

2058:7, 2059:25, 2062:3, 2062:11,

2063:11, 2066:2, 2066:23, 2067:11,

2070:16, 2071:3, 2071:16, 2072:10,

2073:15, 2075:8, 2075:17, 2076:5,

2076:12, 2077:1, 2077:17, 2080:1,

2080:12, 2081:5, 2081:13, 2083:6,

2084:9, 2084:18, 2085:8, 2085:23,

2086:4, 2088:15, 2089:18, 2091:2,

2092:13, 2096:7, 2097:11, 2098:3,

2099:8, 2101:1, 2102:18, 2104:5,

2105:20, 2106:6, 2110:16, 2111:1,

2111:13, 2111:23, 2113:8, 2113:24,

2114:6, 2114:21, 2115:7, 2116:8,

2116:16, 2117:11, 2117:25, 2118:12,

2118:19, 2119:23, 2121:7, 2123:21,

2124:7, 2124:19, 2124:23, 2125:14,

2128:2, 2128:16, 2135:4, 2136:12,

2136:24, 2137:5, 2138:8, 2138:18,

2138:25, 2139:8, 2143:20, 2144:6,

2144:15, 2145:15, 2146:21, 2147:12,

2148:8, 2149:1, 2151:8, 2152:25,

2154:1, 2154:11, 2154:23, 2155:17,

2156:2, 2156:17, 2157:5, 2157:11,

2158:22, 2159:4, 2159:9, 2159:14,

2159:25, 2161:15, 2167:2, 2169:9,

2174:1, 2176:2, 2180:17, 2180:23,

2181:5, 2184:17, 2197:10, 2200:12,

2203:13, 2207:21, 2208:9, 2208:15,

2227:4, 2228:3, 2228:20, 2230:4,

2231:11, 2231:18, 2232:6, 2233:17,

2240:13, 2241:4, 2243:10, 2244:4,

2246:1, 2247:16, 2251:7, 2252:2,

2253:1, 2254:6, 2255:4

C

C.P [1] - 1993:11

cabinet [4] - 2208:11, 2209:6, 2209:10

Cabinet [1] - 2209:4

cabinets [4] - 2093:20, 2093:22,

2094:16, 2094:22

Caldwell [5] - 1990:9, 1993:8,

2002:15, 2105:10, 2204:10

California [1] - 2102:3

cannot [5] - 1995:3, 2010:3, 2033:6,

2245:3, 2245:4

capacity [2] - 2056:1, 2249:22

capital [6] - 2211:2, 2223:10, 2223:25,

2224:13, 2224:14, 2224:16

capitalize [1] - 2223:7

caption [1] - 2248:17

captive [2] - 2117:21, 2118:2

car [3] - 2204:5, 2205:1

care [3] - 2122:3, 2122:17, 2161:20

carefully [1] - 1999:1

Caribbean [22] - 2004:13, 2004:21,

2005:15, 2009:21, 2018:13, 2043:2,

2138:3, 2140:17, 2140:24, 2146:9,

2146:10, 2161:25, 2162:9, 2163:12,

2163:19, 2165:1, 2165:11, 2166:14,

2194:16, 2194:18, 2194:21

Carlos [1] - 2009:9

carry [1] - 2007:4

Cas [1] - 2159:23

case [14] - 1976:12, 1976:13, 1984:19,

1984:20, 1990:8, 1990:12, 1990:16,

2002:1, 2014:16, 2020:20, 2096:22,

2097:3, 2097:4, 2097:14

cases [5] - 2096:20, 2096:21, 2097:2,

2241:9

Cash [1] - 2008:23

cast [1] - 2039:15

catcher [2] - 2082:1, 2082:2

category [1] - 2085:13

catering [2] - 2165:8, 2195:19

Catholic [1] - 2168:9

caused [2] - 2032:1, 2069:18

cautioned [1] - 2099:5

caveat [1] - 2152:24

Cayman [1] - 2005:16

CD [23] - 2077:25, 2080:18, 2083:12,

2084:12, 2108:25, 2110:1, 2119:15,

2135:15, 2234:21, 2235:8, 2235:16,

2235:25, 2237:12, 2237:15, 2238:2,

2241:24, 2242:4, 2243:17, 2243:20,

2244:19, 2244:21, 2246:16, 2247:4

CDs [6] - 2076:15, 2115:22, 2116:11,

2124:24, 2248:25, 2251:13

cease [1] - 2087:15

ceased [3] - 2002:17, 2067:25,

2087:14

Cedar [3] - 2135:11, 2197:19, 2242:21

Central [1] - 2004:13

cents [1] - 2063:23

CEO [1] - 2062:16

certain [7] - 1976:1, 2013:16, 2139:15,

2150:25, 2183:24, 2184:2, 2207:2

certainly [7] - 2015:2, 2040:22,

2075:20, 2098:20, 2113:21, 2219:22,

2241:13

CERTIFICATE [1] - 2257:8

certificate [8] - 2036:6, 2043:25,

2046:4, 2053:18, 2054:16, 2054:18,

2054:21, 2246:2

certificates [2] - 2108:6, 2244:5

certification [1] - 2074:15

certified [4] - 2027:4, 2074:13, 2100:6,

2103:5

certify [3] - 1995:1, 2054:10, 2257:10

cetera [3] - 2068:13, 2092:17

CFO [5] - 2130:20, 2131:1, 2133:18,

2174:19, 2198:21

chain [1] - 2018:18

Chairman [1] - 1997:6

chairman [7] - 1993:12, 1993:14,

2007:23, 2008:6, 2060:22, 2061:4,

2061:6

Chamberlain [1] - 2226:8

Chambliess [1] - 2108:9

chance [2] - 1984:23, 2243:4

change [10] - 2037:21, 2037:22,

2046:14, 2047:6, 2133:9, 2133:11,

2134:4, 2141:17, 2157:18, 2215:5

changed [4] - 2015:8, 2122:25,

2201:4, 2217:5

changes [1] - 2183:2

characterization [1] - 2226:9

charge [6] - 2046:23, 2047:15,

2131:21, 2132:1, 2152:8, 2199:8

charged [5] - 1985:7, 2047:12,

2047:14, 2179:13, 2179:18

Charles [10] - 1993:13, 1993:15,

1994:12, 1995:17, 1997:12, 1997:19,

1998:3, 1998:8, 2000:16

check [2] - 1989:20, 2016:3

chess [1] - 1983:12

chief [20] - 1998:11, 1998:16, 1998:17,

1998:23, 2039:6, 2039:8, 2039:9,

2039:12, 2039:13, 2039:20, 2130:13,

2169:19, 2198:22, 2198:25, 2199:14,

2199:16, 2199:20, 2199:22, 2199:24,

2200:2

Chief [2] - 2039:18, 2039:19

chiefs [1] - 2039:5

children [1] - 2189:12

chooses [1] - 1992:6

Chronicle [2] - 2102:25, 2103:2

chums [1] - 2198:18

circumstance [1] - 2183:6

circumstances [3] - 1976:3, 2031:18,

2060:10

cities [1] - 2118:11

civil [9] - 2000:1, 2008:9, 2096:20,

2096:23, 2096:24, 2097:1, 2097:2,

2097:4

civilly [1] - 1985:7

clarification [1] - 2231:9


2264

clarify [2] - 2105:17, 2133:3

class [4] - 2046:16, 2215:16, 2218:17,

2236:17

Clean [21] - 2010:6, 2012:7, 2013:19,

2013:22, 2013:25, 2014:3, 2014:8,

2014:14, 2014:18, 2014:22, 2015:5,

2015:11, 2015:16, 2069:21, 2069:22,

2069:24, 2070:2, 2070:8, 2070:13,

2070:22, 2072:3

clean [1] - 2238:21

clear [10] - 1996:2, 1996:22, 2015:4,

2045:4, 2052:18, 2087:24, 2094:12,

2095:15, 2112:16, 2196:12

cleared [1] - 2003:17

clearer [1] - 2207:18

clearly [1] - 2091:12

clicking [1] - 2096:14

client [2] - 1981:1, 2160:7

clientele [1] - 2187:6

clients [17] - 2061:1, 2061:3, 2115:24,

2116:22, 2121:10, 2121:21, 2123:15,

2124:2, 2124:9, 2124:13, 2126:22,

2160:19, 2161:5, 2186:6, 2195:11,

2213:11, 2236:16

clip [5] - 2142:10, 2143:8, 2143:9,

2143:11, 2143:12

clock [5] - 1983:11, 1987:13, 2038:25,

2153:17, 2228:1

clocks [1] - 1983:12

close [7] - 2002:3, 2127:22, 2188:11,

2219:1, 2221:17, 2241:14, 2256:20

closed [1] - 2187:21

closing [3] - 2255:24, 2255:25, 2256:1

club [8] - 2023:12, 2136:18, 2213:23,

2215:2, 2219:12, 2219:15, 2220:10,

2221:2

Club [9] - 2077:18, 2136:15, 2136:16,

2139:14, 2211:17, 2217:24, 2218:1,

2218:2, 2218:9

cohesively [1] - 2003:22

college [3] - 2018:4, 2131:8, 2198:18

colonial [1] - 2020:4

colonies [1] - 2020:4

Colony [2] - 1990:4, 2086:10

comb [1] - 2029:16

coming [23] - 1984:5, 2013:4, 2034:25,

2036:13, 2047:5, 2058:9, 2058:11,

2058:14, 2072:1, 2127:10, 2135:20,

2145:19, 2146:2, 2146:3, 2146:16,

2146:18, 2147:7, 2147:9, 2147:13,

2176:18, 2191:16, 2228:16, 2243:22

comment [3] - 2039:1, 2105:14,

2105:23

comments [2] - 2045:1, 2045:2

commercial [5] - 2112:1, 2114:1,

2137:25, 2138:1, 2209:2

commission [10] - 1978:8, 1979:23,

1985:14, 2006:6, 2047:12, 2072:15,

2074:12, 2075:9, 2075:19, 2249:9

commission's [1] - 2072:16

commissioned [1] - 2006:5

Committee [4] - 2007:9, 2010:10,

2010:23, 2068:25

committee [24] - 2007:15, 2007:18,

2007:22, 2008:19, 2008:22, 2009:19,

2009:22, 2009:24, 2009:25, 2010:3,

2010:4, 2010:8, 2010:9, 2010:12,

2010:13, 2010:18, 2068:10, 2068:12,

2068:16, 2068:17, 2068:18, 2069:2,

2069:3, 2069:13

commonly [1] - 2253:6

community [2] - 2011:21, 2072:2

compact [1] - 1979:2

companies [23] - 1978:14, 2011:22,

2024:4, 2028:14, 2054:24, 2088:10,

2101:12, 2117:6, 2125:12, 2130:17,

2132:6, 2132:20, 2137:25, 2138:1,

2169:3, 2181:19, 2181:21, 2182:14,

2199:10, 2199:11, 2223:9, 2224:19,

2243:2

Company [21] - 2123:5, 2127:2,

2133:1, 2133:12, 2133:15, 2136:3,

2136:17, 2137:3, 2137:12, 2137:15,

2138:4, 2174:15, 2174:20, 2174:23,

2190:15, 2208:24, 2209:8, 2211:12,

2223:10, 2223:25, 2224:12

company [29] - 1979:9, 1999:4,

2027:25, 2097:6, 2102:14, 2102:19,

2117:15, 2117:20, 2117:21, 2118:2,

2122:25, 2132:13, 2134:4, 2135:5,

2136:8, 2137:17, 2148:5, 2149:15,

2149:19, 2158:9, 2166:8, 2174:13,

2174:17, 2188:1, 2207:15, 2223:8,

2235:13

company's [3] - 2031:3, 2032:20,

2032:24

compare [1] - 2005:14

compete [1] - 2005:15

competitions [1] - 2213:25

competitors [3] - 2016:22, 2073:1,

2073:20

complained [1] - 2039:12

complaint [5] - 2008:4, 2029:2,

2029:4, 2058:18

complete [5] - 2038:12, 2040:13,

2041:17, 2053:3, 2053:18

completed [3] - 2136:14, 2140:11,

2198:12

completely [2] - 2133:15, 2229:23

completion [1] - 2209:10

complex [1] - 2186:22

complexes [3] - 2125:25, 2133:22,

2183:23

compliance [1] - 2058:25

complied [1] - 2059:12

comply [3] - 2028:13, 2032:23,

2046:22

compulsive [3] - 2200:18, 2200:19,

2200:21

computer [8] - 1972:13, 1972:21,

2057:21, 2062:9, 2073:8, 2080:8,

2080:10, 2252:20

computer-assisted [2] - 1972:13,

1972:21

concentrate [1] - 2254:1

concept [6] - 2088:10, 2217:11,

2240:15, 2241:5, 2250:8, 2254:16

concern [13] - 2026:23, 2026:25,

2069:11, 2069:18, 2071:25, 2080:22,

2147:7, 2147:13, 2147:16, 2167:8,

2176:6, 2176:16

concerned [10] - 1997:17, 2071:13,

2129:7, 2147:8, 2153:6, 2166:12,

2167:10, 2167:16, 2170:9, 2176:3

concerning [2] - 2097:4, 2239:13

concerns [11] - 2011:11, 2011:13,

2011:15, 2011:20, 2069:10, 2140:4,

2140:6, 2146:1, 2148:5, 2148:6, 2206:4

conclude [1] - 1997:15

condensed [1] - 2217:10

conditions [2] - 1975:16, 1975:23

conduct [1] - 2230:13

conducted [6] - 2031:11, 2033:11,

2033:12, 2094:15, 2230:8, 2230:17

conducting [2] - 2026:12, 2060:7

conferring [3] - 2022:9, 2142:24,

2207:8

confidence [2] - 2190:18, 2195:15

confidential [1] - 2056:17

confirm [1] - 2097:14

confused [1] - 2010:13

Congress [1] - 1971:22

conjunction [5] - 2013:20, 2119:3,

2174:13, 2199:7, 2207:3

connect [1] - 1985:12

connections [1] - 2230:21

connotation [1] - 2181:13

conservative [7] - 2111:6, 2113:14,

2113:16, 2113:23, 2165:25, 2237:18,

2251:17

consider [2] - 2071:2, 2237:18

considerably [2] - 2170:4, 2213:3

considered [4] - 1987:3, 2006:22,

2031:23, 2126:12

consisted [2] - 2204:24, 2205:2

consistent [13] - 2112:2, 2113:9,

2114:11, 2114:22, 2142:19, 2143:25,

2145:1, 2165:18, 2165:21, 2216:10,

2237:14, 2237:16, 2239:2

consistently [1] - 2031:21

constituents [1] - 2013:15

construct [2] - 2138:19, 2190:20

constructed [2] - 2236:4, 2236:9

construction [29] - 2101:10, 2101:12,

2134:12, 2135:23, 2136:1, 2137:12,

2138:12, 2139:20, 2140:9, 2140:10,

2140:19, 2141:11, 2142:11, 2146:12,

2146:23, 2155:2, 2164:8, 2167:12,

2188:22, 2190:19, 2190:22, 2191:24,

2192:2, 2192:4, 2208:23, 2211:16,

2211:17, 2211:18, 2215:4

constructive [2] - 2225:6, 2226:5

construed [2] - 1982:15, 2091:6

consult [1] - 2226:19

consultant [1] - 2249:18

consulted [2] - 2222:25, 2233:11

consummated [1] - 1996:9

contacted [1] - 2178:14


2265

contacts [1] - 2230:25

contain [3] - 1978:21, 1978:24,

1979:10

contained [4] - 1975:15, 1978:20,

1998:24, 2012:25

containing [2] - 2053:9, 2093:20

contains [2] - 1979:21, 1980:15

contents [1] - 2048:12

context [1] - 2148:4

continue [6] - 1981:11, 1981:18,

1982:14, 2025:18, 2144:3, 2240:12

continued [2] - 2212:7, 2234:10

Continued [2] - 1972:1, 1972:2

contract [2] - 2096:20, 2150:11

control [4] - 2025:21, 2025:24, 2199:6,

2232:20

controller [11] - 2101:15, 2101:17,

2130:16, 2174:22, 2199:13, 2199:14,

2199:19, 2199:22, 2199:23, 2200:2,

2200:4

controllers [1] - 2199:17

controls [1] - 2004:18

conversation [3] - 1994:11, 2183:18,

2186:4

conversationally [1] - 2233:7

conversion [1] - 2208:19

convey [2] - 1987:20, 1987:22

cooperated [1] - 2016:11

cooperatives [1] - 2007:3

copy [9] - 1980:22, 1989:1, 2045:1,

2053:8, 2090:24, 2159:10, 2177:19,

2177:25, 2207:6

corporate [4] - 2247:22, 2248:13,

2248:14, 2253:3

Corporation [5] - 2047:22, 2123:1,

2123:2, 2133:12, 2238:16

corporation [11] - 2092:16, 2148:19,

2152:7, 2152:17, 2153:3, 2153:8,

2155:23, 2162:2, 2167:9, 2167:23,

2235:17

Corporations [3] - 1975:16, 2046:10,

2050:17

corporations [4] - 1991:1, 2010:2,

2036:20, 2052:12

correct [242] - 1981:24, 1981:25,

1983:22, 1984:6, 1984:7, 1984:10,

1984:12, 1986:23, 1987:3, 1988:14,

1988:15, 1988:17, 1988:18, 1989:9,

1989:16, 1991:21, 1994:18, 1994:21,

1995:15, 1996:5, 1996:13, 1996:21,

1997:9, 1998:14, 1999:5, 2001:16,

2003:6, 2003:9, 2004:5, 2004:10,

2004:11, 2004:14, 2004:22, 2005:3,

2005:12, 2005:13, 2005:17, 2005:24,

2006:3, 2006:6, 2006:17, 2007:6,

2007:16, 2007:17, 2007:20, 2007:23,

2008:20, 2009:5, 2009:7, 2009:23,

2010:11, 2010:21, 2011:2, 2012:15,

2013:23, 2015:12, 2015:13, 2015:19,

2015:24, 2017:4, 2018:24, 2020:10,

2020:19, 2024:19, 2025:4, 2025:18,

2026:6, 2026:11, 2027:3, 2029:13,

2029:17, 2032:16, 2037:13, 2038:9,

2040:15, 2040:25, 2042:7, 2042:14,

2043:17, 2043:21, 2046:1, 2046:24,

2046:25, 2047:3, 2047:20, 2047:24,

2048:9, 2048:18, 2048:20, 2048:25,

2049:7, 2049:14, 2049:15, 2050:7,

2050:8, 2051:12, 2051:13, 2052:11,

2052:20, 2052:21, 2053:23, 2053:24,

2054:16, 2054:17, 2054:19, 2054:20,

2055:1, 2055:6, 2055:7, 2056:19,

2056:22, 2056:23, 2057:9, 2057:10,

2057:18, 2057:19, 2058:14, 2058:20,

2058:25, 2060:6, 2060:11, 2060:15,

2060:18, 2060:19, 2063:8, 2064:24,

2065:5, 2065:6, 2070:20, 2071:10,

2073:24, 2073:25, 2074:18, 2084:21,

2084:22, 2085:3, 2085:14, 2087:2,

2087:16, 2087:18, 2089:19, 2089:24,

2090:18, 2090:19, 2091:7, 2091:15,

2091:19, 2091:23, 2091:24, 2092:5,

2092:6, 2093:2, 2093:3, 2093:5,

2093:6, 2093:8, 2093:14, 2094:3,

2094:5, 2094:6, 2094:7, 2095:9,

2095:12, 2095:16, 2095:23, 2095:24,

2102:12, 2103:25, 2104:1, 2104:8,

2106:18, 2107:4, 2107:13, 2109:1,

2112:20, 2121:25, 2123:24, 2130:14,

2131:3, 2131:24, 2132:18, 2144:24,

2150:20, 2151:12, 2151:13, 2154:6,

2155:24, 2158:4, 2158:18, 2158:19,

2159:7, 2166:9, 2170:19, 2171:22,

2172:11, 2174:18, 2175:3, 2175:13,

2175:20, 2176:7, 2176:11, 2179:11,

2181:17, 2181:20, 2182:5, 2186:24,

2188:9, 2188:13, 2188:15, 2188:18,

2190:2, 2192:3, 2192:14, 2194:8,

2196:1, 2196:7, 2198:17, 2201:11,

2205:3, 2205:10, 2210:18, 2212:20,

2214:20, 2224:4, 2225:1, 2228:22,

2231:15, 2234:5, 2235:15, 2238:17,

2239:6, 2239:20, 2242:16, 2245:9,

2245:14, 2246:6, 2248:23, 2249:5,

2253:4, 2253:7, 2257:11

correctly [8] - 2011:9, 2040:7, 2049:3,

2053:22, 2066:17, 2089:4, 2089:7,

2200:23

correspondence [4] - 2034:6, 2034:8,

2044:3, 2096:1

cost [6] - 2140:4, 2141:6, 2194:6,

2196:22, 2196:23, 2249:15

costa [9] - 2213:6, 2221:10, 2240:1,

2240:2, 2244:5, 2246:15, 2248:24,

2249:8, 2255:5

Costa [7] - 1971:13, 2112:23, 2222:5,

2227:5, 2228:25, 2229:7, 2230:20

COSTA [161] - 2067:5, 2098:24,

2099:8, 2101:1, 2102:18, 2104:2,

2104:5, 2105:20, 2106:2, 2106:6,

2110:5, 2110:16, 2111:1, 2111:8,

2111:12, 2111:13, 2111:17, 2111:23,

2112:12, 2112:21, 2113:4, 2113:8,

2113:24, 2114:3, 2114:6, 2114:17,

2114:21, 2115:7, 2116:8, 2116:16,

2117:9, 2117:11, 2117:25, 2118:9,

2118:12, 2118:17, 2118:19, 2119:23,

2121:7, 2123:21, 2124:7, 2124:19,

2124:23, 2125:9, 2125:14, 2128:2,

2128:16, 2135:4, 2136:10, 2136:12,

2136:22, 2136:24, 2137:4, 2137:5,

2138:7, 2138:8, 2138:18, 2138:24,

2138:25, 2139:6, 2139:8, 2142:22,

2143:2, 2143:6, 2143:8, 2143:12,

2143:14, 2143:17, 2143:19, 2143:20,

2144:3, 2144:6, 2144:13, 2144:15,

2145:15, 2146:21, 2147:12, 2147:18,

2147:20, 2148:2, 2148:4, 2148:8,

2148:23, 2149:1, 2150:4, 2150:11,

2150:17, 2151:3, 2151:8, 2152:11,

2152:15, 2152:21, 2152:25, 2153:14,

2153:16, 2153:21, 2153:23, 2154:1,

2154:9, 2154:11, 2154:21, 2154:23,

2155:6, 2155:14, 2155:16, 2155:17,

2155:25, 2156:2, 2156:15, 2156:17,

2157:2, 2157:5, 2157:10, 2157:11,

2158:20, 2158:22, 2159:3, 2159:4,

2159:8, 2159:9, 2159:12, 2159:14,

2159:24, 2159:25, 2161:15, 2167:2,

2169:7, 2180:14, 2181:2, 2184:8,

2184:11, 2184:15, 2200:9, 2203:4,

2207:13, 2227:25, 2228:17, 2229:19,

2231:9, 2233:17, 2240:3, 2240:6,

2240:9, 2240:13, 2240:21, 2241:4,

2243:8, 2243:10, 2244:1, 2245:22,

2251:7, 2252:2, 2252:15, 2252:20,

2252:22, 2253:1, 2253:25, 2254:3,

2254:6, 2254:22, 2256:22

COSTA............. [2] - 1973:21, 1973:25

COSTA............... [1] - 1973:17

costing [1] - 2146:12

costs [1] - 2140:6

council [2] - 2067:21, 2086:22

counsel [11] - 1983:4, 1983:13,

1983:24, 1999:6, 2022:19, 2034:20,

2034:25, 2035:23, 2069:20, 2078:4,

2096:11

Counsel [14] - 1975:5, 1992:20,

1997:22, 2020:14, 2061:25, 2079:23,

2083:3, 2083:20, 2090:19, 2097:10,

2097:25, 2098:13, 2147:24, 2175:22

count [1] - 2171:17

countries [4] - 1976:4, 1976:5, 2020:8,

2221:24

country [3] - 1977:9, 2017:2, 2209:7

County [1] - 2099:15

couple [7] - 2039:8, 2104:25, 2127:15,

2144:25, 2159:12, 2161:22, 2168:19

course [5] - 2039:12, 2064:22,

2078:11, 2083:4, 2181:15

Court [14] - 1972:10, 1972:17, 1989:4,

1990:4, 1990:18, 2002:6, 2009:22,

2035:17, 2039:2, 2039:12, 2039:17,

2078:18, 2086:10, 2090:24

court [15] - 1976:7, 1986:17, 1987:19,

1991:7, 1991:8, 1991:9, 1994:3,

2026:1, 2035:15, 2039:3, 2099:12,

2203:9, 2204:13, 2229:6, 2229:16

COURT [259] - 1971:1, 1975:2,Johnny C. Sanchez, RMR, CRR - [email protected]

2266

1976:20, 1976:24, 1977:2, 1977:5,

1977:9, 1977:12, 1980:4, 1980:9,

1983:1, 1983:3, 1983:6, 1983:10,

1983:24, 1984:2, 1985:22, 1985:25,

1986:2, 1987:8, 1987:11, 1989:7,

1989:9, 1989:12, 1989:17, 1989:20,

1989:23, 1991:15, 1991:19, 1991:22,

1991:24, 1992:1, 1996:24, 1997:2,

1997:22, 1999:6, 1999:9, 1999:12,

1999:15, 1999:20, 2017:11, 2017:16,

2017:19, 2020:14, 2022:14, 2022:17,

2022:19, 2022:23, 2027:21, 2034:20,

2035:4, 2035:9, 2035:25, 2036:3,

2036:9, 2036:13, 2036:16, 2036:23,

2037:1, 2037:5, 2037:9, 2037:15,

2037:18, 2037:22, 2037:24, 2038:3,

2038:16, 2038:22, 2038:24, 2044:14,

2044:19, 2044:21, 2045:6, 2045:15,

2045:20, 2046:11, 2049:20, 2051:17,

2051:21, 2052:1, 2052:8, 2054:11,

2056:5, 2059:21, 2061:13, 2061:17,

2061:20, 2061:23, 2062:8, 2063:6,

2066:1, 2067:6, 2070:4, 2070:9,

2070:12, 2070:15, 2070:24, 2071:9,

2071:14, 2072:9, 2073:9, 2075:6,

2075:16, 2076:4, 2076:9, 2076:19,

2076:24, 2077:7, 2077:10, 2077:14,

2078:4, 2078:9, 2078:20, 2079:2,

2079:11, 2079:15, 2079:23, 2080:7,

2080:10, 2080:22, 2080:25, 2081:11,

2081:23, 2082:5, 2082:7, 2082:15,

2082:21, 2082:23, 2083:1, 2083:5,

2083:16, 2083:24, 2084:6, 2084:16,

2085:5, 2086:1, 2088:14, 2089:16,

2090:3, 2090:6, 2090:9, 2090:13,

2090:17, 2090:22, 2091:1, 2092:11,

2096:6, 2096:11, 2096:13, 2097:22,

2097:25, 2098:13, 2098:15, 2098:22,

2098:25, 2100:23, 2102:16, 2103:25,

2104:3, 2105:19, 2106:1, 2106:5,

2110:4, 2110:13, 2110:24, 2112:11,

2112:19, 2113:2, 2113:20, 2114:16,

2114:19, 2115:5, 2116:2, 2116:15,

2117:24, 2119:22, 2123:20, 2124:5,

2124:18, 2124:22, 2125:13, 2127:18,

2127:22, 2127:25, 2128:12, 2138:13,

2143:1, 2143:3, 2143:7, 2143:11,

2143:13, 2143:16, 2144:4, 2145:11,

2145:14, 2146:20, 2147:17, 2147:19,

2147:22, 2148:3, 2148:6, 2150:6,

2150:8, 2150:13, 2150:20, 2151:6,

2152:13, 2152:23, 2153:15, 2153:17,

2153:20, 2153:22, 2153:25, 2155:8,

2155:13, 2155:15, 2161:11, 2161:14,

2166:24, 2173:23, 2175:22, 2175:25,

2180:16, 2181:4, 2184:10, 2184:14,

2184:16, 2197:7, 2200:11, 2203:5,

2207:7, 2207:9, 2207:16, 2227:3,

2227:16, 2227:19, 2227:21, 2227:24,

2228:1, 2228:13, 2228:18, 2229:25,

2231:10, 2231:15, 2231:17, 2240:1,

2240:5, 2240:8, 2240:11, 2240:24,

2245:24, 2251:24, 2252:19, 2252:21,

2254:5, 2254:25, 2256:23, 2257:1,

2257:8

Court's [3] - 1982:25, 2035:18, 2052:3

Courtney [3] - 2046:6, 2047:2, 2047:9

courtroom [3] - 2098:19, 2103:21,

2182:7

cover [1] - 2103:8

covered [1] - 2116:23

CPA [19] - 1991:15, 1991:16, 2099:24,

2100:6, 2100:11, 2113:6, 2130:14,

2131:3, 2131:5, 2170:12, 2174:5,

2174:7, 2223:5, 2224:8, 2226:14,

2226:17, 2249:22, 2249:23, 2249:25

create [3] - 2140:23, 2174:25, 2186:10

created [8] - 1986:12, 1986:21,

2103:18, 2123:8, 2123:10, 2177:18,

2184:19, 2226:23

credentials [1] - 2174:4

credit [2] - 1998:2, 2114:9

Credit [1] - 1979:14

CRICK [1] - 1973:4

crick [7] - 1975:10, 2045:8, 2045:22,

2073:16, 2074:8, 2076:13, 2078:14

Crick [38] - 1977:14, 1980:14, 1980:20,

1980:24, 1981:15, 1981:23, 1983:18,

1984:8, 1987:21, 2023:2, 2035:20,

2036:7, 2038:12, 2040:4, 2053:20,

2057:12, 2058:12, 2061:11, 2062:4,

2062:12, 2063:2, 2063:12, 2064:2,

2064:8, 2066:3, 2066:24, 2067:12,

2068:2, 2069:14, 2070:18, 2072:3,

2080:2, 2080:13, 2081:6, 2083:11,

2089:20, 2091:3, 2098:4

cricket [33] - 2018:21, 2018:23,

2019:4, 2019:9, 2019:15, 2020:9,

2025:7, 2025:9, 2025:10, 2025:14,

2025:15, 2075:22, 2076:7, 2076:9,

2076:16, 2077:3, 2082:2, 2139:2,

2211:15, 2213:12, 2213:13, 2213:14,

2213:21, 2214:9, 2214:23, 2215:13,

2216:16, 2216:17, 2216:18, 2217:6,

2217:9, 2217:13

Cricket [1] - 2020:17

cricket's [1] - 2019:4

crime [3] - 2047:13, 2164:1, 2179:13

criminal [5] - 2000:1, 2047:13,

2096:22, 2096:23, 2180:6

criminally [1] - 1985:8

crisis [1] - 2102:1

critical [1] - 2000:15

cross [14] - 2035:16, 2036:21,

2038:10, 2049:23, 2068:9, 2069:21,

2072:23, 2074:3, 2074:9, 2075:22,

2080:14, 2132:3, 2233:19, 2240:20

CROSS [4] - 1973:6, 1973:19,

1983:16, 2169:8

cross-examination [12] - 2035:16,

2036:21, 2038:10, 2049:23, 2068:9,

2069:21, 2072:23, 2074:3, 2074:9,

2075:22, 2080:14, 2233:19

CROSS-EXAMINATION [4] - 1973:6,

1973:19, 1983:16, 2169:8

CRR [3] - 1972:10, 1972:18, 2257:14

current [5] - 2059:5, 2060:20, 2060:22,

2100:11, 2120:18

curriculum [1] - 2053:3

customer [7] - 1976:7, 1976:8,

1976:11, 1976:14, 2016:17, 2016:18

customer's [1] - 1976:10

customers [10] - 1977:18, 1979:23,

1986:19, 1986:21, 1987:1, 2016:5,

2120:3, 2122:11, 2123:11, 2123:24

customs [3] - 2008:25, 2009:14,

2196:12

Customs [1] - 2009:1

cut [1] - 2168:13

Cynthia [1] - 2014:10

D

Dallas [2] - 2105:6, 2105:7

damaged [1] - 2208:20

date [13] - 1978:25, 2053:3, 2053:10,

2062:12, 2063:12, 2063:14, 2066:24,

2067:22, 2087:14, 2098:6, 2151:9,

2177:6, 2249:10

dated [4] - 2002:25, 2057:11, 2154:6,

2180:25

dates [5] - 2056:11, 2056:22, 2056:24,

2253:11, 2255:7

daughter [1] - 2102:6

DAVID [1] - 1971:10

Davis [23] - 2130:6, 2130:9, 2130:20,

2131:5, 2131:7, 2131:11, 2131:13,

2131:20, 2131:21, 2131:25, 2132:12,

2132:16, 2132:22, 2132:25, 2133:13,

2198:16, 2198:20, 2199:19, 2199:24,

2232:7, 2232:10, 2232:20

Davis's [2] - 2130:11, 2131:10

day-to-day [2] - 2199:15, 2199:17

days [10] - 2099:20, 2104:25, 2109:8,

2125:24, 2142:10, 2145:8, 2145:17,

2145:18, 2217:7, 2239:12

DC [1] - 1971:18

De [2] - 2043:12, 2043:13

de [1] - 2168:8

DEA [1] - 2008:23

deal [8] - 2136:6, 2186:13, 2187:13,

2187:19, 2187:21, 2188:10, 2191:17,

2226:20

dealer [1] - 2204:5

dealership [2] - 2204:5, 2205:1

dealing [2] - 2206:1, 2206:2

dealings [1] - 2206:7

deals [10] - 2170:18, 2171:5, 2171:17,

2172:2, 2176:5, 2185:14, 2186:12,

2189:21, 2235:18, 2242:8

dealt [1] - 2221:23

debt [6] - 2151:18, 2228:24, 2247:24,

2248:2, 2253:6

decade [2] - 2135:14, 2135:23

decades [1] - 2214:7

December [16] - 1998:12, 2000:19,

2002:6, 2002:18, 2028:11, 2032:21,


2267

2098:8, 2151:10, 2154:19, 2154:24,

2155:20, 2157:16

decide [6] - 2076:2, 2076:4, 2125:4,

2166:16, 2172:12, 2215:6

decided [4] - 2060:10, 2106:22,

2167:25, 2226:4

decision [16] - 1977:23, 1977:25,

1979:8, 1979:18, 1995:4, 2026:22,

2060:13, 2060:14, 2098:5, 2166:19,

2166:21, 2168:16, 2172:17, 2172:23,

2208:11

decision-making [1] - 1979:8

decisions [2] - 2115:1, 2245:18

declared [2] - 2002:16, 2226:3

deemed [1] - 2253:12

DEFENDANT [2] - 1971:20, 1972:2

defendant [1] - 2150:12

Defendant's [9] - 1988:25, 1989:11,

1994:2, 2020:22, 2044:12, 2051:15,

2052:24, 2086:9, 2090:1

defendant's [1] - 1989:12

Defense [2] - 2067:3, 2207:5

defense [5] - 1980:12, 2003:14,

2037:12, 2040:1, 2056:6

define [2] - 2093:15, 2248:2

defines [1] - 2091:12

definitely [2] - 2193:10, 2243:19

definition [1] - 2165:23

definitive [1] - 2012:14

degree [2] - 2048:20, 2126:12

delved [1] - 2241:23

demand [1] - 2244:21

demanded [1] - 2201:12

denied [1] - 1994:12

department [2] - 2072:19, 2134:12

Department [1] - 1971:17

departure [1] - 1993:17

dependent [1] - 2164:18

deposit [4] - 1976:14, 2108:6, 2245:7,

2246:2

deposited [2] - 2110:21, 2111:4

depositor [3] - 2235:23, 2241:24,

2242:4

depositors [9] - 2109:25, 2110:20,

2153:11, 2235:8, 2235:21, 2238:2,

2243:17, 2251:13, 2252:8

depositors' [5] - 2119:15, 2135:15,

2235:16, 2237:12, 2237:15

deposits [3] - 2116:23, 2234:22,

2244:5

depressed [2] - 2171:1

desalination [3] - 2210:2, 2210:4,

2210:9

describe [7] - 1975:14, 1978:19,

2011:4, 2132:9, 2158:5, 2172:24,

2197:22

described [4] - 2031:3, 2049:2,

2060:11, 2255:11

describes [1] - 1975:16

describing [1] - 2012:6

description [1] - 2047:14

design [2] - 2219:21, 2221:2

designed [1] - 1978:7

despite [1] - 2145:24

destination [1] - 2215:16

detail [2] - 2161:19, 2248:18

details [5] - 1978:12, 1979:1, 2026:8,

2049:4, 2226:2

determination [1] - 2150:23

determinations [1] - 2175:19

determine [3] - 1979:8, 1990:2, 2175:6

detrimental [1] - 2164:4

develop [6] - 2011:7, 2011:24,

2170:17, 2194:25, 2197:12, 2212:17

developed [2] - 2010:25, 2209:7

developing [4] - 2189:5, 2211:24,

2217:20, 2235:1

Development [27] - 2123:1, 2123:2,

2123:5, 2123:7, 2123:10, 2124:1,

2124:8, 2124:10, 2127:2, 2132:14,

2133:1, 2133:7, 2133:12, 2133:14,

2136:17, 2137:3, 2137:12, 2137:15,

2139:3, 2158:10, 2174:15, 2174:20,

2174:22, 2190:15, 2208:24, 2209:8,

2238:16

development [29] - 2041:22, 2042:1,

2134:3, 2139:19, 2142:20, 2144:8,

2144:11, 2148:18, 2149:15, 2149:19,

2152:7, 2152:16, 2153:3, 2153:8,

2155:3, 2155:23, 2162:1, 2167:9,

2167:23, 2197:18, 2198:7, 2200:14,

2208:22, 2209:19, 2218:2, 2234:14,

2235:12, 2235:17, 2238:3

developments [6] - 2176:5, 2197:14,

2234:14, 2234:25, 2242:17, 2243:23

deviation [1] - 2084:2

devote [1] - 2108:16

Diaz [3] - 2009:18, 2009:20, 2014:10

Diego [2] - 2102:3, 2102:4

difference [6] - 2122:15, 2126:5,

2126:25, 2199:21, 2250:21

differences [1] - 2000:23

different [21] - 1986:22, 1998:13,

1999:10, 2010:15, 2014:2, 2015:21,

2017:2, 2051:19, 2051:21, 2110:11,

2124:24, 2131:14, 2131:17, 2139:22,

2141:18, 2159:10, 2162:25, 2229:23,

2250:23, 2251:25

difficult [4] - 1980:23, 2003:25,

2140:25, 2201:9

difficulties [4] - 1995:6, 1995:9,

1995:10, 2123:14

difficulty [3] - 2163:16, 2164:7

diligence [1] - 2187:9

DIRECT [3] - 1973:17, 1975:8, 2099:7

direct [12] - 2026:9, 2027:5, 2035:22,

2066:4, 2068:21, 2095:7, 2184:4,

2184:9, 2184:12, 2227:6, 2228:4,

2228:21

director [15] - 1996:20, 2006:2,

2010:20, 2014:13, 2029:1, 2029:12,

2030:13, 2045:23, 2046:15, 2047:16,

2053:15, 2056:1, 2060:20, 2157:17,

2168:12

Director [1] - 2053:21

directors [30] - 1988:21, 1992:10,

1992:11, 1993:19, 1995:3, 1995:21,

1995:24, 1996:3, 2031:16, 2036:7,

2043:23, 2046:7, 2046:14, 2047:6,

2047:24, 2048:4, 2048:7, 2048:8,

2060:23, 2066:11, 2092:16, 2092:17,

2101:21, 2105:2, 2162:24, 2202:6,

2202:7, 2205:2

Directors [1] - 2031:2

dirt [2] - 2082:15, 2082:16

disagree [2] - 2084:3, 2092:24

discharged [1] - 2048:23

disclose [4] - 1977:23, 1982:9,

2066:11, 2073:23

disclosed [23] - 2031:21, 2064:6,

2066:15, 2076:13, 2080:17, 2081:6,

2083:11, 2084:24, 2085:3, 2085:10,

2158:6, 2158:15, 2223:16, 2223:18,

2224:3, 2224:25, 2229:9, 2229:12,

2229:20, 2239:1, 2249:3, 2249:4

disclosing [2] - 1976:17, 2223:20

disclosure [9] - 1982:20, 2065:8,

2077:2, 2077:4, 2156:24, 2157:12,

2158:18, 2159:5, 2224:10

disclosures [9] - 2031:14, 2238:23,

2239:11, 2239:13, 2239:23, 2239:24,

2240:14, 2240:23, 2241:20

discuss [7] - 1981:5, 1981:13,

1984:20, 2086:5, 2107:25, 2115:13,

2150:25

discussed [7] - 2044:21, 2110:18,

2117:20, 2153:24, 2166:22, 2209:4,

2209:6

discussing [2] - 2069:20, 2070:19

discussion [3] - 2158:1, 2158:3,

2165:1

discussions [2] - 2143:25, 2165:12

dispute [6] - 1994:17, 1994:20,

1995:14, 2026:5, 2026:7, 2026:8

distinguishes [1] - 2246:12

distressed [11] - 2103:19, 2104:9,

2106:8, 2106:12, 2120:16, 2120:17,

2126:8, 2126:11, 2126:17, 2133:21,

2134:7

distributed [1] - 1987:1

distribution [1] - 1986:7

DISTRICT [3] - 1971:1, 1971:1,

1971:10

District [1] - 2100:3

disturbed [2] - 2012:18, 2012:23

diversification [1] - 1981:14

diversified [1] - 2126:18

dividend [2] - 2225:6, 2226:5

division [1] - 2009:1

DIVISION [1] - 1971:2

dock [4] - 2138:16, 2138:20, 2138:22,

2218:3

docket [1] - 2150:22

document [41] - 1986:6, 1986:9,

1986:12, 1986:14, 1986:16, 1986:18,

1987:18, 1987:24, 1988:5, 1988:14,

1988:23, 1990:21, 1990:22, 1990:25,


2268

2036:5, 2036:11, 2036:18, 2037:2,

2037:3, 2037:5, 2037:12, 2038:17,

2041:10, 2044:6, 2044:7, 2050:21,

2051:19, 2051:21, 2055:15, 2063:12,

2065:21, 2066:24, 2067:22, 2150:2,

2150:18, 2154:10, 2154:17

documents [12] - 1976:1, 2034:1,

2034:13, 2034:25, 2035:14, 2035:20,

2035:24, 2037:19, 2057:24, 2074:20,

2140:10, 2148:21

dollar [13] - 2016:3, 2156:19, 2156:25,

2158:2, 2158:3, 2159:6, 2223:1,

2228:9, 2239:6, 2241:7, 2241:8,

2253:14

dollars [10] - 2063:23, 2075:10,

2152:16, 2170:3, 2211:23, 2215:12,

2216:13, 2219:20, 2219:24, 2242:5

Don [5] - 1990:9, 1993:7, 2002:14,

2105:10, 2204:10

done [24] - 1997:11, 2012:4, 2012:15,

2013:2, 2020:24, 2033:6, 2039:25,

2041:9, 2101:20, 2105:15, 2105:22,

2140:17, 2155:3, 2193:4, 2194:15,

2194:17, 2194:21, 2200:23, 2201:2,

2201:6, 2201:7, 2220:15, 2240:25,

2256:9

door [1] - 2225:20

double [1] - 1989:20

double-check [1] - 1989:20

doubt [7] - 1994:6, 1995:20, 1996:8,

2000:19, 2001:1, 2040:11, 2132:6

down [36] - 1981:19, 1983:4, 1997:12,

2004:22, 2011:12, 2014:20, 2033:13,

2037:21, 2037:22, 2046:11, 2056:21,

2098:16, 2100:23, 2102:2, 2126:14,

2126:15, 2141:1, 2142:8, 2160:23,

2166:18, 2167:3, 2173:23, 2175:22,

2183:8, 2185:1, 2208:13, 2214:14,

2214:17, 2227:12, 2228:14, 2230:2,

2234:14, 2243:23, 2247:14, 2256:24

downtown [1] - 2135:2

dozen [1] - 2162:12

draft [1] - 1986:9

drafted [1] - 1986:18

dream [3] - 2218:24, 2220:4, 2237:10

drill [1] - 1981:19

drives [2] - 2169:4, 2169:6

drop [1] - 2014:20

drove [1] - 2187:11

drug [1] - 2004:12

due [1] - 2187:9

duly [1] - 2099:5

during [16] - 1989:20, 2019:22,

2070:17, 2074:3, 2074:6, 2134:3,

2135:22, 2156:8, 2156:12, 2159:2,

2178:3, 2183:6, 2189:19, 2198:14,

2202:2, 2206:12

duties [2] - 2003:11, 2065:15

duty [2] - 2049:13, 2189:14

E

e) [1] - 2091:10

e-mail [1] - 2166:21

early [23] - 2010:9, 2026:16, 2051:15,

2107:16, 2107:25, 2109:7, 2109:18,

2115:3, 2133:2, 2133:13, 2136:11,

2139:21, 2145:8, 2145:17, 2145:18,

2170:20, 2190:6, 2214:7, 2229:2,

2234:8

early-to-mid-1990s [1] - 2133:2

easel [1] - 2067:10

easier [1] - 2040:24

easily [2] - 2241:15, 2255:14

East [1] - 2009:21

easy [3] - 1996:14, 1996:15, 2181:6

eat [1] - 2236:21

economic [5] - 2144:12, 2235:4,

2235:5, 2238:2, 2243:6

economics [1] - 2144:10

economy [1] - 2120:11

Ede [1] - 1999:22

educational [1] - 2099:25

effect [8] - 2003:2, 2008:10, 2071:4,

2081:25, 2090:10, 2090:11, 2090:12,

2090:16

effective [1] - 2011:25

effort [4] - 2004:2, 2004:17, 2005:7,

2188:23

eight [2] - 2100:21, 2162:23

either [13] - 1976:14, 1996:8, 2001:13,

2013:20, 2015:9, 2039:6, 2049:22,

2058:2, 2083:18, 2083:19, 2155:21,

2249:2

elaborate [1] - 2119:20

electing [1] - 2203:11

electricity [3] - 2164:15, 2164:21,

2164:23

elicit [1] - 2112:25

Ellen [3] - 1989:17, 2037:11, 2038:5

ELMO [3] - 1988:1, 2044:24, 2045:19

Elsie [2] - 2108:10, 2108:11

empire [2] - 2232:14, 2232:21

employee [2] - 2095:20, 2128:25

employees [6] - 2107:22, 2107:23,

2131:14, 2131:19, 2164:13, 2190:15

end [25] - 1992:24, 2002:5, 2028:5,

2064:14, 2102:13, 2136:5, 2141:20,

2144:16, 2145:25, 2148:14, 2154:3,

2154:6, 2155:19, 2157:22, 2160:22,

2165:6, 2165:14, 2168:7, 2168:23,

2208:5, 2219:12, 2236:14, 2236:18,

2237:17, 2238:5

endeavor [2] - 2146:8, 2146:9

ended [7] - 1996:4, 2015:11, 2028:12,

2032:22, 2042:9, 2097:16, 2169:24

ending [1] - 2086:19

ends [1] - 2257:4

enforcing [1] - 2046:23

engaging [1] - 2220:15

England [2] - 2213:16, 2214:1

English [1] - 2020:12

enjoyable [1] - 2039:24

enjoyed [1] - 2200:17

enlarge [1] - 1985:25

enlarged [1] - 1985:20

enormous [1] - 2209:6

enter [1] - 2150:14

entered [2] - 2002:12, 2055:4

enterprise [3] - 2249:8, 2249:14,

2250:24

entertain [2] - 1995:20, 1996:8

entire [9] - 1977:18, 2000:6, 2003:20,

2082:9, 2085:19, 2143:9, 2238:11,

2239:22

entirety [2] - 1992:6, 2071:7

entities [5] - 2006:20, 2012:1, 2025:4,

2033:5, 2134:13

entitled [4] - 2039:5, 2083:20,

2243:21, 2257:12

entity [11] - 1978:8, 1978:16, 2007:15,

2055:5, 2101:4, 2104:6, 2106:16,

2137:2, 2137:11, 2137:13, 2137:19

entrance [2] - 2197:24

entrepreneur [2] - 2193:9, 2193:10

entry [1] - 2254:15

envelope [1] - 1998:24

equities [8] - 2111:6, 2111:25,

2113:16, 2113:22, 2125:21, 2125:22,

2149:6, 2247:21

equivalent [2] - 1991:15, 2082:22

error [1] - 2032:2

especially [4] - 1993:8, 1999:18,

2113:23, 2214:7

essential [2] - 1979:3, 2209:9

essentially [1] - 2013:15

establish [3] - 2010:1, 2058:24,

2112:6

established [1] - 2053:5

establishes [1] - 2181:3

estate [77] - 2101:9, 2103:6, 2103:20,

2104:9, 2104:22, 2106:8, 2106:12,

2106:20, 2107:19, 2119:12, 2119:16,

2119:25, 2120:4, 2120:6, 2120:14,

2120:16, 2120:17, 2121:11, 2121:13,

2121:22, 2122:4, 2122:11, 2123:12,

2123:15, 2123:22, 2124:13, 2125:1,

2125:2, 2125:12, 2125:15, 2125:17,

2126:1, 2126:8, 2126:11, 2126:12,

2126:18, 2126:20, 2126:23, 2129:5,

2133:21, 2149:12, 2170:8, 2170:10,

2170:17, 2170:25, 2171:1, 2171:3,

2171:5, 2171:17, 2171:20, 2172:2,

2176:4, 2185:14, 2186:7, 2186:12,

2190:21, 2191:3, 2191:7, 2191:21,

2200:14, 2233:25, 2235:9, 2235:17,

2239:2, 2239:9, 2239:10, 2242:8,

2245:12, 2249:3, 2250:18, 2255:17,

2255:18, 2255:23, 2256:3, 2256:19

estimate [1] - 2108:21

estimates [1] - 2031:15

et [3] - 2068:13, 2092:17

Ethridge [1] - 2108:10

evaluated [1] - 2032:5

event [1] - 2223:11Johnny C. Sanchez, RMR, CRR - [email protected]

2269

eventually [10] - 1991:5, 2014:18,

2015:19, 2038:4, 2054:16, 2054:18,

2106:14, 2133:25, 2174:15, 2190:14

evidence [34] - 1976:21, 1980:1,

1980:5, 1980:11, 1988:25, 1989:5,

1992:5, 1997:19, 1997:20, 2000:5,

2001:1, 2001:7, 2024:18, 2031:13,

2031:24, 2052:23, 2058:16, 2065:23,

2065:24, 2075:15, 2076:18, 2078:3,

2080:20, 2085:18, 2112:20, 2123:19,

2143:4, 2146:19, 2148:10, 2150:21,

2152:10, 2180:15, 2227:22

evildoing [1] - 2179:19

exact [2] - 2026:7, 2150:23

exactly [7] - 2006:18, 2013:14,

2014:14, 2019:1, 2025:3, 2044:17,

2137:18

exam [2] - 2057:3, 2057:17

EXAMINATION [21] - 1973:6, 1973:8,

1973:10, 1973:12, 1973:17, 1973:19,

1973:21, 1973:23, 1973:25, 1974:2,

1975:8, 1983:16, 2062:2, 2084:17,

2098:2, 2099:7, 2169:8, 2233:16,

2244:3, 2251:6, 2255:3

examination [38] - 2026:9, 2031:13,

2033:10, 2033:11, 2033:20, 2033:21,

2035:16, 2036:21, 2038:10, 2042:23,

2043:5, 2043:11, 2049:23, 2054:22,

2056:18, 2064:9, 2064:11, 2064:14,

2064:22, 2064:24, 2068:9, 2069:21,

2070:7, 2070:12, 2072:23, 2074:3,

2074:9, 2075:22, 2078:13, 2080:14,

2095:7, 2184:4, 2184:9, 2184:12,

2227:6, 2228:5, 2228:21, 2233:19

examinations [1] - 2060:7

examine [5] - 2029:17, 2042:19,

2043:22, 2044:1, 2160:6

Examined [1] - 2056:21

examined [1] - 2058:22

examiner [3] - 2043:14, 2043:16,

2065:4

examiners [2] - 2015:21, 2058:23

examining [1] - 2015:19

example [5] - 1975:24, 1986:25,

2085:11, 2164:6, 2223:9

exams [1] - 2034:14

except [1] - 2230:25

exception [1] - 2256:20

exchange [2] - 2253:16, 2253:18

exchanges [1] - 2253:12

excuse [6] - 2017:21, 2070:4, 2112:5,

2123:18, 2125:5, 2145:9

excused [3] - 2098:16, 2256:24,

2257:1

Executive [1] - 2053:20

executive [12] - 2006:1, 2010:20,

2014:13, 2028:25, 2029:12, 2030:13,

2045:23, 2056:1, 2060:20, 2101:15,

2106:25, 2208:11

exercise [1] - 2015:25

exercising [2] - 1981:14, 2048:20

exhaustive [1] - 2065:10

Exhibit [47] - 1979:25, 1985:18,

1988:4, 1988:25, 1989:11, 1993:3,

1994:3, 2017:8, 2017:18, 2020:22,

2022:13, 2027:17, 2027:19, 2029:6,

2030:7, 2044:13, 2052:24, 2055:12,

2055:17, 2055:25, 2056:4, 2056:13,

2057:6, 2057:11, 2057:25, 2058:1,

2058:10, 2062:4, 2063:3, 2064:10,

2066:22, 2067:3, 2073:5, 2077:6,

2080:3, 2085:25, 2086:6, 2086:9,

2086:15, 2088:16, 2090:2, 2207:5,

2223:1, 2227:18, 2230:2, 2246:21,

2246:23

exhibit [16] - 1983:5, 1992:9, 2003:14,

2028:17, 2077:8, 2077:11, 2089:17,

2150:25, 2153:20, 2196:4, 2223:4,

2228:5, 2229:24, 2240:6, 2254:24

exhibited [1] - 2223:3

exhibits [1] - 2056:6

exist [7] - 2025:18, 2067:21, 2086:23,

2087:1, 2087:14, 2087:15, 2088:2

existed [4] - 2033:5, 2087:5, 2088:3,

2088:4

existence [1] - 2060:6

existing [1] - 2087:15

expand [2] - 2006:10, 2189:25

expensive [7] - 2139:22, 2139:24,

2141:5, 2194:3, 2211:21, 2211:22,

2236:15

experience [5] - 2001:19, 2001:20,

2053:7, 2103:6, 2236:17

expert [5] - 2025:14, 2112:8, 2112:10,

2112:25, 2113:6

expertise [1] - 2004:15

explain [5] - 2049:17, 2049:19,

2049:21, 2163:23, 2195:8

explained [3] - 1998:17, 2187:18,

2215:14

explanation [1] - 2161:16

explanations [1] - 2031:23

express [1] - 2140:4

expression [1] - 2081:24

extended [4] - 2157:13, 2157:16,

2232:13, 2232:14

extent [8] - 2018:14, 2025:24,

2042:10, 2053:6, 2063:1, 2121:23,

2122:13, 2164:18

extremely [4] - 2165:9, 2200:19,

2213:19, 2214:8

Exxon [1] - 2253:6

eye [1] - 2113:5

F

fabulous [1] - 2196:22

fabulously [2] - 2250:19, 2250:25

facility [7] - 2138:16, 2192:13, 2210:8,

2214:21, 2214:22, 2215:3, 2233:3

fact [25] - 1979:11, 1988:20, 1991:3,

1997:23, 2010:5, 2027:1, 2041:22,

2086:19, 2096:19, 2119:2, 2146:2,

2175:14, 2175:17, 2175:21, 2176:12,

2176:21, 2179:25, 2193:6, 2210:19,

2213:16, 2214:5, 2225:12, 2227:5,

2254:23, 2255:23

facts [10] - 2075:14, 2076:17, 2078:2,

2078:13, 2080:20, 2123:18, 2146:19,

2152:9, 2255:20, 2255:22

failing [2] - 2210:23, 2211:1

fair [7] - 1994:10, 2011:16, 2028:10,

2032:20, 2042:4, 2051:6, 2194:19

faith [3] - 2078:16, 2078:18, 2152:21

fall [3] - 2019:14, 2019:16, 2019:18

fam [1] - 2145:20

familiar [30] - 1975:12, 1977:9, 1978:4,

1987:4, 2010:12, 2014:4, 2022:4,

2022:6, 2022:8, 2024:20, 2025:24,

2055:15, 2068:8, 2088:9, 2109:21,

2159:17, 2179:21, 2179:22, 2209:15,

2220:11, 2220:14, 2220:18, 2220:21,

2221:13, 2221:18, 2222:2, 2223:7,

2225:12, 2225:25, 2240:15

family [3] - 2145:7, 2145:16, 2145:20

fancy [4] - 2166:1, 2237:6, 2237:10,

2237:17

far [14] - 1997:16, 2017:23, 2024:3,

2098:19, 2192:12, 2206:22, 2211:9,

2211:10, 2216:18, 2221:1, 2221:4,

2232:13, 2237:5, 2238:1

fascinating [1] - 2039:23

fashion [1] - 2246:18

fast [2] - 2140:8, 2140:12

father [6] - 2107:5, 2202:20, 2202:25,

2203:2, 2203:15, 2204:25

fault [1] - 2128:1

Fazel [2] - 1971:20, 1971:21

FAZEL [2] - 2090:21, 2227:15

FBI [23] - 1984:15, 1984:16, 2008:19,

2094:2, 2176:24, 2177:9, 2177:13,

2177:18, 2178:2, 2178:14, 2179:2,

2179:9, 2181:1, 2181:3, 2182:4,

2182:6, 2185:1, 2186:1, 2188:21,

2199:18, 2200:6, 2200:13, 2233:20

FDIC [1] - 2116:23

feasible [1] - 2235:3

feature [1] - 2197:24

featured [1] - 2213:12

February [2] - 2011:2, 2040:8

federal [1] - 2203:9

fee [1] - 1976:1

feelings [1] - 2166:10

Felipe [1] - 2134:20

fellow [2] - 2185:9, 2202:11

felt [2] - 2040:13, 2042:13

female [1] - 2182:10

Ferrance [2] - 2043:3, 2064:17

few [16] - 1983:9, 1983:10, 1991:6,

2021:20, 2084:19, 2103:15, 2108:17,

2134:8, 2136:7, 2141:2, 2142:10,

2143:10, 2166:6, 2219:7, 2239:12,

2244:2

field [9] - 2025:7, 2025:9, 2025:14,

2025:15, 2076:10, 2211:15, 2214:23,

2215:13, 2216:17

fields [1] - 2025:10


2270

fifth [1] - 2021:14

fight [1] - 2226:8

file [5] - 2008:4, 2047:11, 2049:6,

2062:25, 2093:22

filed [1] - 2052:18

files [27] - 1996:20, 2014:2, 2058:22,

2072:4, 2072:7, 2072:11, 2093:1,

2093:2, 2093:8, 2093:11, 2093:18,

2093:19, 2093:20, 2093:22, 2093:25,

2094:5, 2094:9, 2094:11, 2094:13,

2095:1, 2095:5, 2095:8, 2095:10,

2095:12, 2095:13

filing [2] - 2093:20, 2094:16

fill [2] - 2047:23, 2130:23

finalized [1] - 1986:10

finally [3] - 2060:2, 2060:6, 2139:6

finance [3] - 2101:16, 2168:12,

2204:17

Finance [2] - 2087:13, 2087:14

finances [1] - 2141:10

Financial [7] - 2005:19, 2006:2,

2007:9, 2068:25, 2132:19, 2135:20,

2239:20

financial [58] - 2000:11, 2004:18,

2005:3, 2006:23, 2007:19, 2009:18,

2028:9, 2028:14, 2030:24, 2031:5,

2031:14, 2031:17, 2031:25, 2032:7,

2032:12, 2032:13, 2032:19, 2032:24,

2033:9, 2066:12, 2074:17, 2101:20,

2125:7, 2125:8, 2130:13, 2133:14,

2133:16, 2147:5, 2158:11, 2158:14,

2160:9, 2169:19, 2174:11, 2198:22,

2198:25, 2199:4, 2199:15, 2199:16,

2199:20, 2199:22, 2199:25, 2200:2,

2203:21, 2203:24, 2211:4, 2221:15,

2222:7, 2228:8, 2229:4, 2229:8,

2233:6, 2233:8, 2233:9, 2233:10,

2238:13, 2238:16, 2249:9

financially [3] - 2173:2, 2173:5,

2235:2

financials [1] - 2228:10

findings [2] - 2000:25, 2067:13

fine [5] - 1983:25, 2022:11, 2063:9,

2127:25, 2152:19

finest [1] - 2076:9

Fingervoedt [1] - 2062:15

finish [1] - 2144:13

finished [6] - 2041:11, 2096:5, 2189:4,

2201:3, 2212:8, 2232:5

finishes [1] - 2197:5

fire [1] - 2068:6

firm [11] - 2009:5, 2100:15, 2100:16,

2101:7, 2160:16, 2160:21, 2161:1,

2161:8, 2220:18, 2220:24, 2226:7

Firm [1] - 1972:6

firms [4] - 2100:19, 2100:21, 2100:22,

2220:21

first [74] - 1983:23, 1984:4, 1986:14,

1987:18, 1988:13, 1990:2, 2000:6,

2018:7, 2021:6, 2028:17, 2029:6,

2029:7, 2030:8, 2030:18, 2033:10,

2033:11, 2035:22, 2036:3, 2037:2,

2037:5, 2040:8, 2042:23, 2043:5,

2054:22, 2055:4, 2056:12, 2057:2,

2057:3, 2057:17, 2063:16, 2071:1,

2079:18, 2085:24, 2087:19, 2099:5,

2101:10, 2102:21, 2104:23, 2108:12,

2108:17, 2119:19, 2120:2, 2120:25,

2121:8, 2123:6, 2123:22, 2127:15,

2130:10, 2148:25, 2151:5, 2153:23,

2163:18, 2166:20, 2168:19, 2177:6,

2178:5, 2180:1, 2181:2, 2181:12,

2184:21, 2186:13, 2187:13, 2187:14,

2192:6, 2228:14, 2228:17, 2230:7,

2233:22, 2240:25, 2241:1, 2250:2,

2256:16, 2257:2

fit [1] - 2007:14

fits [1] - 2003:22

five [14] - 2017:20, 2020:18, 2039:5,

2048:5, 2051:2, 2051:7, 2079:16,

2086:6, 2086:12, 2151:7, 2229:15,

2229:17, 2244:14

five-year [1] - 2244:14

fixed [5] - 2208:23, 2208:25, 2244:11,

2253:10, 2255:7

fixing [1] - 2059:10

flags [1] - 2186:8

fleet [1] - 2137:10

flexibility [2] - 2203:10, 2240:25

flip [1] - 2057:5

flipped [1] - 2256:7

flips [1] - 2256:6

float [1] - 2193:1

Floor [2] - 1971:22, 1972:4

floor [1] - 2201:3

floors [3] - 2141:14, 2141:15, 2141:24

Florida [5] - 2018:5, 2018:7, 2018:11,

2018:12, 2220:25

fly [4] - 2024:7, 2024:15

focus [9] - 2028:4, 2069:14, 2073:11,

2091:14, 2133:21, 2134:3, 2134:6,

2134:7, 2134:10

focused [8] - 2104:9, 2104:21,

2104:22, 2108:20, 2120:6, 2168:21,

2168:25, 2234:7

focussing [1] - 2006:13

folks [3] - 2034:22, 2108:7, 2165:8

follow [3] - 1992:16, 2216:24, 2256:2

following [6] - 1975:1, 2038:23,

2047:8, 2053:1, 2079:22, 2155:12

follows [4] - 2002:16, 2064:1, 2099:6,

2209:11

FOR [3] - 1971:13, 1971:20, 1972:2

for-sale [3] - 2171:15, 2171:16

forced [2] - 2060:15, 2060:16

foregoing [1] - 2257:10

foreign [1] - 2055:5

Form [1] - 2072:8

form [15] - 1976:18, 1978:4, 1978:7,

2031:5, 2048:10, 2048:12, 2048:25,

2049:1, 2049:2, 2049:3, 2070:21,

2080:19, 2112:8, 2117:22, 2145:12

formal [1] - 2119:10

Formalities [1] - 2050:25

formally [1] - 2047:12

formed [1] - 2074:16

former [7] - 2008:19, 2008:23,

2008:25, 2009:14, 2009:21, 2039:2,

2094:2

forming [1] - 2032:5

forms [2] - 2058:21, 2059:5

forth [6] - 2060:5, 2061:14, 2061:20,

2063:25, 2151:23, 2214:15

foundation [8] - 2110:2, 2110:5,

2110:22, 2112:6, 2112:13, 2112:16,

2114:13, 2116:14

four [12] - 2039:10, 2039:16, 2048:5,

2100:25, 2108:9, 2135:3, 2135:13,

2171:7, 2171:9, 2171:12, 2171:18

four-story [1] - 2135:3

fourth [2] - 2021:12, 2122:18

fragile [1] - 2163:14

framework [2] - 2010:1, 2015:15

franchise [4] - 2215:25, 2216:5,

2216:6, 2216:13

franchises [1] - 2216:7

Francis [1] - 2043:12

Frans [2] - 2057:13, 2062:15

fraud [3] - 2032:1, 2032:15, 2191:17

fraudulent [2] - 2215:17, 2235:12

free [5] - 2032:1, 2032:14, 2098:17,

2098:20, 2256:24

freeholds [1] - 2208:20

French [1] - 2134:24

frequently [2] - 2164:12, 2164:24

Friday [2] - 2093:4, 2096:17

friends [4] - 2131:18, 2131:19,

2195:15, 2195:17

front [10] - 1980:21, 1983:24, 1994:2,

2002:13, 2050:14, 2061:24, 2062:5,

2082:2, 2087:19, 2195:5

fruition [1] - 2210:10

frustrated [3] - 2001:15, 2001:21,

2001:23

FSRC [27] - 1978:1, 1978:17, 1997:4,

2060:17, 2060:21, 2061:4, 2061:7,

2062:22, 2064:6, 2065:2, 2069:5,

2069:6, 2074:19, 2074:22, 2075:2,

2076:13, 2077:2, 2077:21, 2077:24,

2078:12, 2078:14, 2080:17, 2081:6,

2083:12, 2084:21, 2085:3, 2085:11

FSRC's [1] - 1985:8

Ft [1] - 2099:15

full [10] - 1975:3, 1975:4, 2000:7,

2028:4, 2121:23, 2122:13, 2151:5,

2154:9, 2217:9

fully [4] - 2059:8, 2062:21, 2123:23,

2124:14

fun [1] - 2213:11

function [3] - 2072:6, 2101:19, 2199:2

functions [1] - 2007:4

Fund [7] - 2117:8, 2117:13, 2118:2,

2161:25, 2162:10, 2165:11, 2166:14

fund [17] - 1981:21, 1982:16, 2076:15,

2121:24, 2122:2, 2124:2, 2124:9,

2124:13, 2135:15, 2149:18, 2152:6,

2153:3, 2162:15, 2162:20, 2163:2,


2271

2186:2, 2235:16

funded [5] - 2123:23, 2185:21, 2188:7,

2234:21, 2237:12

funding [5] - 2126:23, 2135:18,

2142:8, 2191:13, 2243:12

funds [9] - 2076:15, 2077:25, 2083:13,

2084:12, 2115:20, 2126:24, 2146:23,

2223:8, 2243:25

furtherance [2] - 2065:14

G

GAAP [9] - 2221:21, 2221:23, 2222:8,

2222:11, 2222:13, 2223:18, 2230:10,

2230:11, 2238:20

gambling [2] - 2006:21, 2006:22

game [2] - 2082:2, 2217:5

gears [1] - 2221:9

general [14] - 1975:25, 1990:10,

1992:11, 2013:17, 2024:11, 2041:1,

2070:1, 2071:25, 2095:4, 2128:7,

2161:7, 2188:4, 2190:17, 2241:18

generally [11] - 1975:14, 1975:20,

1975:22, 2015:18, 2023:2, 2081:2,

2154:15, 2160:4, 2186:13, 2194:17,

2253:11

generated [1] - 2209:13

generates [1] - 2177:13

generous [3] - 2172:15, 2172:16,

2172:22

Geneva [9] - 2118:16, 2118:24,

2119:2, 2119:5, 2230:21, 2231:21,

2231:24, 2232:1, 2232:3

gentleman [8] - 1985:1, 1985:3,

1994:23, 2009:17, 2009:24, 2042:24,

2043:3, 2204:25

gentlemen [3] - 2151:6, 2155:8,

2202:5

gerber [3] - 1984:11, 1984:12, 2009:1

GIBL [6] - 1988:9, 1990:24, 2015:5,

2027:11, 2033:5, 2033:18

Gilbert [2] - 2039:13, 2039:14

gist [1] - 2013:14

given [8] - 1987:4, 2003:21, 2037:16,

2038:14, 2052:2, 2111:8, 2163:25,

2177:15

glue [1] - 2018:23

GM [1] - 2253:6

go-round [2] - 2240:25, 2241:1

goal [1] - 2242:20

gold [1] - 2039:10

Goswick [7] - 1990:9, 1993:7,

2002:15, 2105:9, 2105:16, 2105:23,

2204:1

Government [8] - 2006:10, 2148:9,

2149:21, 2155:19, 2156:8, 2157:2,

2158:21, 2158:24

GOVERNMENT [1] - 1971:13

government [58] - 1988:8, 1990:22,

1992:25, 1993:9, 1995:18, 1996:10,

1996:11, 1996:16, 1996:17, 1997:8,

1997:14, 1997:16, 2003:13, 2005:6,

2005:10, 2007:15, 2007:18, 2008:5,

2008:7, 2008:11, 2010:19, 2037:3,

2038:21, 2051:15, 2051:24, 2052:11,

2061:13, 2061:17, 2067:13, 2067:20,

2069:17, 2072:1, 2072:19, 2086:22,

2087:2, 2087:3, 2087:23, 2097:16,

2150:4, 2164:22, 2164:23, 2192:18,

2196:3, 2205:17, 2205:18, 2205:19,

2205:21, 2206:3, 2206:7, 2207:6,

2208:16, 2208:19, 2209:14, 2209:17,

2247:24, 2255:6, 2255:8, 2255:12

government's [2] - 2083:2, 2227:23

Government's [39] - 1979:25, 1985:17,

1988:4, 1993:3, 2017:8, 2017:18,

2022:13, 2027:17, 2027:19, 2029:5,

2030:7, 2055:12, 2055:17, 2055:21,

2055:24, 2056:3, 2056:6, 2056:13,

2057:5, 2057:11, 2057:25, 2058:10,

2062:4, 2063:3, 2064:10, 2066:21,

2077:5, 2080:2, 2085:25, 2086:6,

2086:14, 2088:16, 2222:25, 2227:17,

2230:2, 2246:21, 2246:23, 2247:12

governmental [1] - 1996:14

governments [3] - 2005:2, 2247:24,

2253:10

governor's [1] - 1993:10

grab [2] - 2045:17, 2097:23

graduating [1] - 2100:13

grand [1] - 2196:17

granite [1] - 2141:9

granted [4] - 2002:20, 2067:18,

2086:20, 2087:20

great [2] - 2006:15, 2136:6

Great [2] - 2221:22, 2222:1

Greenberg [1] - 2009:7

Gregg [1] - 1971:13

ground [3] - 2042:6, 2082:3, 2162:20

Grounds [1] - 2086:14

grounds [2] - 2086:12, 2139:2

Group [3] - 2132:19, 2135:20, 2136:3

group [12] - 2007:8, 2008:9, 2011:14,

2011:17, 2013:21, 2014:1, 2019:20,

2119:13, 2134:14, 2228:16, 2243:2

growth [1] - 2036:20

Guana [2] - 2218:22, 2219:2

guaranteed [2] - 2253:10, 2255:6

Guardian [53] - 1992:10, 1992:12,

1993:19, 1994:13, 1994:15, 1995:1,

1995:4, 1995:12, 1995:21, 1995:23,

1995:25, 1996:20, 2002:17, 2002:20,

2015:7, 2015:9, 2015:12, 2016:1,

2016:10, 2067:18, 2067:22, 2086:20,

2087:20, 2098:6, 2102:14, 2102:22,

2104:15, 2106:16, 2107:14, 2107:23,

2109:3, 2111:4, 2111:14, 2114:8,

2114:12, 2118:18, 2122:25, 2123:2,

2123:3, 2123:4, 2123:7, 2123:10,

2124:1, 2124:8, 2124:9, 2127:2,

2133:4, 2133:6, 2133:7, 2133:14,

2188:2, 2188:4, 2233:24

Guardian's [1] - 1992:8

guess [5] - 1999:9, 2138:23, 2170:23,

2179:7, 2225:25

guided [1] - 2053:19

guidelines [1] - 1982:3

guy [13] - 2172:18, 2172:25, 2175:10,

2180:10, 2180:13, 2180:19, 2182:22,

2191:7, 2198:15, 2215:23, 2216:3,

2216:12, 2255:25

guys [4] - 2193:13, 2195:19, 2202:15,

2225:21

H

hair [2] - 1999:18, 1999:24

half [5] - 2111:21, 2136:9, 2160:23,

2166:13, 2198:10

halfway [1] - 2154:4

Hamilton [1] - 2220:23

hand [10] - 2030:9, 2036:4, 2041:7,

2073:12, 2073:13, 2099:2, 2114:5,

2154:14, 2156:8, 2239:15

handed [9] - 1998:23, 2000:13,

2000:15, 2000:17, 2000:19, 2035:13,

2035:14, 2035:15, 2036:19

handing [3] - 2000:11, 2063:2, 2066:3

handling [1] - 2182:14

hands [16] - 2180:10, 2180:13,

2180:18, 2181:8, 2181:14, 2182:13,

2182:22, 2182:24, 2182:25, 2183:5,

2233:23, 2234:7

hands-off [7] - 2180:10, 2180:13,

2180:18, 2181:8, 2181:14, 2182:13,

2183:5

hands-on [9] - 2180:10, 2181:8,

2182:13, 2182:22, 2182:24, 2182:25,

2183:5, 2233:23, 2234:7

handwriting [1] - 2045:8

handwritten [2] - 2045:1, 2045:2

hang [2] - 2076:19, 2153:25

hangar [21] - 2024:1, 2024:2, 2024:8,

2024:9, 2024:10, 2080:17, 2081:7,

2084:25, 2137:7, 2137:8, 2137:9,

2138:4, 2144:18, 2144:20, 2196:5,

2236:7, 2236:8, 2236:25, 2242:23,

2250:9

hangars [2] - 2209:1, 2250:5

happy [4] - 2078:17, 2112:15, 2189:23

hard [8] - 1980:22, 2157:7, 2159:10,

2166:20, 2189:16, 2213:21, 2214:17,

2253:25

harder [1] - 2030:4

hardwood [3] - 2141:14, 2141:15,

2141:24

hardwoods [1] - 2141:18

Harold [4] - 2008:19, 2008:21, 2014:9,

2094:2

hastily [2] - 2064:20, 2064:21

head [5] - 2009:17, 2029:11, 2085:17,

2188:22, 2190:19

heading [1] - 2031:1

headquarters [1] - 2192:6

health [2] - 2136:18, 2215:2

hear [8] - 2063:7, 2070:24, 2076:20,


2272

2240:8

heard [13] - 1990:16, 1999:4, 2068:6,

2113:10, 2123:17, 2130:22, 2153:7,

2180:1, 2201:17, 2218:5, 2218:8,

2218:10, 2254:7

hearing [2] - 2203:8, 2235:7

hearsay [8] - 2052:6, 2105:25, 2106:1,

2110:3, 2110:8, 2180:15, 2203:4,

2203:7

heart [1] - 2019:19

held [8] - 1975:1, 1982:21, 1988:20,

2038:23, 2079:22, 2100:9, 2155:12

Hello [1] - 1984:8

help [21] - 1988:21, 2007:18, 2010:16,

2027:19, 2034:15, 2041:4, 2041:13,

2049:16, 2049:18, 2057:22, 2072:6,

2072:11, 2095:25, 2097:12, 2133:1,

2133:13, 2149:18, 2191:8, 2219:21,

2226:8

helped [4] - 2132:12, 2176:13, 2232:2,

2249:21

helping [7] - 2009:25, 2010:19,

2094:21, 2124:2, 2152:6, 2193:13,

2221:2

helps [1] - 2097:14

hereby [1] - 2053:16

herein [1] - 2064:1

hereinafter [3] - 2002:11, 2063:19,

2063:22

hesitating [1] - 2029:19

Hewlett [18] - 2026:9, 2026:18,

2026:24, 2027:1, 2027:7, 2028:1,

2029:3, 2032:10, 2033:2, 2074:9,

2074:12, 2074:15, 2075:10, 2075:19,

2159:23, 2160:1, 2160:12, 2160:15

Hewlett's [4] - 2029:24, 2030:22,

2074:22, 2075:11

hi [1] - 2112:25

high [17] - 1987:13, 2039:23, 2102:7,

2102:8, 2165:6, 2165:14, 2195:21,

2195:22, 2195:23, 2196:10, 2219:12,

2225:20, 2236:14, 2236:18, 2236:23,

2237:17

High [2] - 1990:4, 2086:10

high-end [6] - 2165:6, 2165:14,

2219:12, 2236:14, 2236:18, 2237:17

high-net-worth [2] - 2195:23, 2196:10

high-quality [1] - 2236:23

highest [1] - 1993:20

highlight [10] - 2111:22, 2118:11,

2148:24, 2151:4, 2159:12, 2207:20,

2208:8, 2247:13, 2252:23, 2255:1

highlighted [5] - 2090:23, 2090:24,

2113:9, 2181:6, 2184:21

highly [2] - 2242:14, 2253:13

himself [6] - 2093:10, 2094:13,

2115:3, 2195:3, 2195:4, 2225:15

hinder [1] - 2072:6

hindered [1] - 2072:13

hire [13] - 2104:7, 2106:9, 2106:22,

2106:23, 2161:5, 2172:1, 2172:12,

2173:12, 2173:19, 2174:7, 2174:9,

2174:11, 2178:20

hired [23] - 2042:11, 2106:14, 2106:16,

2106:24, 2120:12, 2133:4, 2162:22,

2170:14, 2170:21, 2170:22, 2172:4,

2172:10, 2172:13, 2173:6, 2175:2,

2175:6, 2175:18, 2181:25, 2198:15,

2199:19, 2200:1, 2202:9, 2220:18

hiring [2] - 2219:21, 2226:7

history [3] - 2003:12, 2105:11,

2105:13

hit [5] - 1983:12, 2042:6, 2161:8,

2161:20, 2214:17

HITTNER [1] - 1971:10

hold [10] - 1977:5, 1987:8, 1987:12,

2017:19, 2022:19, 2037:9, 2038:1,

2083:16, 2087:11, 2115:5

holders' [1] - 2234:22

holding [2] - 2087:10, 2087:11

holds [1] - 2246:3

Holloway [1] - 2164:5

home [8] - 2120:13, 2130:16, 2166:13,

2167:5, 2178:23, 2178:24, 2182:19,

2219:13

homebuilder [2] - 2101:13, 2101:14

homebuilding [1] - 2101:25

Homes [4] - 2101:14, 2101:22,

2101:24, 2169:19

homework [1] - 2193:4

Honor [69] - 1975:7, 1980:7, 1983:2,

1989:8, 1989:16, 1989:19, 2017:15,

2022:22, 2035:13, 2036:12, 2036:25,

2038:2, 2038:21, 2044:25, 2051:20,

2051:25, 2062:1, 2062:7, 2063:5,

2065:25, 2067:9, 2070:10, 2073:7,

2077:9, 2077:13, 2078:8, 2079:6,

2079:14, 2079:25, 2080:5, 2083:4,

2084:14, 2088:12, 2090:15, 2098:1,

2098:12, 2098:21, 2112:22, 2116:7,

2117:10, 2142:22, 2143:2, 2143:8,

2143:15, 2147:18, 2151:3, 2153:14,

2153:21, 2155:7, 2155:14, 2157:3,

2169:7, 2200:10, 2203:4, 2207:4,

2207:14, 2227:2, 2227:15, 2227:20,

2232:5, 2240:4, 2243:8, 2244:1,

2245:22, 2252:17, 2253:25, 2254:22,

2256:22, 2256:25

Honorable [2] - 1990:12, 2002:9

HONORABLE [1] - 1971:10

hope [2] - 2058:3, 2250:6

hopefully [2] - 2084:15, 2224:15

horse [1] - 1999:24

hospital [2] - 2209:23, 2209:24

hot [2] - 1999:20, 1999:24

hour [1] - 2034:23

house [2] - 2023:5, 2179:9

houses [13] - 1978:15, 1978:25,

1979:4, 1979:5, 1979:6, 1979:22,

2024:25, 2134:11, 2134:16, 2135:10,

2190:24, 2197:25, 2198:2

housing [1] - 2197:18

HOUSTON [1] - 1971:2

Houston [33] - 1971:4, 1971:15,

1971:23, 1972:4, 1972:7, 1972:11,

1972:19, 2099:16, 2100:2, 2100:4,

2100:14, 2102:5, 2102:11, 2102:25,

2103:1, 2105:5, 2107:20, 2120:10,

2120:11, 2121:2, 2121:19, 2122:8,

2122:9, 2134:19, 2170:20, 2171:7,

2171:10, 2171:11, 2171:19, 2186:18,

2186:19, 2220:23, 2256:10

Howard [1] - 1971:16

Hrdlicka [1] - 2226:8

huge [3] - 2146:4, 2146:9, 2226:23

hundred [3] - 2170:3, 2181:18,

2181:23

hundreds [8] - 2037:25, 2038:1,

2152:16, 2211:23, 2212:1, 2212:3,

2212:5, 2242:5

hurricanes [2] - 2163:14, 2163:18

hypergrowth [1] - 2006:6

I

IB [2] - 2085:12, 2085:14

IB5 [8] - 1978:4, 1978:6, 1978:7,

1978:11, 1978:12, 1978:21, 1979:21

IB5s [3] - 1978:17, 1978:20, 1978:23

IBC [9] - 2001:20, 2048:1, 2052:11,

2058:25, 2065:7, 2065:10, 2089:2,

2090:5, 2090:21

IBM [2] - 2253:22

idea [31] - 1987:20, 1987:22, 1990:21,

1992:8, 2006:24, 2120:15, 2120:16,

2133:24, 2161:23, 2162:9, 2163:7,

2163:11, 2165:1, 2165:4, 2165:11,

2172:1, 2181:25, 2193:16, 2194:24,

2197:11, 2215:11, 2215:23, 2217:6,

2217:13, 2218:10, 2218:11, 2219:5,

2219:10, 2232:20, 2232:22, 2242:25

identified [14] - 2017:12, 2017:13,

2017:14, 2022:17, 2022:20, 2022:24,

2058:20, 2104:4, 2143:3, 2153:22,

2227:21, 2227:23, 2227:24, 2228:15

identity [1] - 2048:7

idiomatic [1] - 2081:24

IFRS [5] - 2221:13, 2222:8, 2238:9,

2238:12, 2239:18

IFSA [3] - 2010:20, 2095:23, 2097:13

illegal [1] - 2223:17

immediately [1] - 2048:12

immigration [1] - 2196:12

implementation [1] - 2040:18

implemented [3] - 2059:6, 2059:8,

2062:21

implementing [1] - 2060:5

import [5] - 2141:5, 2141:8, 2164:10,

2164:11, 2164:13

importance [3] - 2000:15, 2000:16,

2169:2

important [5] - 1988:8, 1988:17,

1991:2, 2003:13, 2194:20

impose [1] - 2004:18

impossible [1] - 2216:7

impression [2] - 2128:20, 2128:21

improper [2] - 1988:22, 2008:5

improperly [1] - 2016:6Johnny C. Sanchez, RMR, CRR - [email protected]

2273

improve [1] - 2041:19

improved [4] - 2002:1, 2209:18,

2209:20, 2213:3

improvements [1] - 2209:21

improving [1] - 2162:18

inaccurate [1] - 2050:19

incident [1] - 2014:2

include [4] - 2007:1, 2031:12, 2059:7,

2163:9

included [4] - 1978:11, 2066:14,

2141:8, 2254:14

includes [2] - 1978:12, 2031:15

including [4] - 2132:7, 2151:5,

2167:24, 2249:17

income [1] - 2225:6

inconsistent [1] - 2216:10

incorporated [1] - 2040:25

incorporation [1] - 2048:1

incorrect [1] - 2095:6

increments [2] - 2244:14

Independent [2] - 2100:3, 2159:15

independent [7] - 2031:6, 2032:12,

2074:16, 2159:18, 2159:21, 2160:1,

2160:4

India [1] - 2213:16

indicate [2] - 1977:3, 2051:8

indicated [1] - 2023:23

indicates [1] - 2087:7

indicating [1] - 2092:22

indication [1] - 2051:10

indicted [1] - 2047:12

Indies [12] - 2018:16, 2018:24, 2019:9,

2019:17, 2019:25, 2020:1, 2020:2,

2020:18, 2063:22, 2213:24, 2214:1

indies [1] - 2019:24

indirect [1] - 2046:15

individual [9] - 1975:17, 1982:10,

2107:1, 2135:21, 2163:15, 2197:25,

2198:1, 2233:24, 2241:25

individuals [3] - 2010:18, 2013:21,

2115:8

indulgence [1] - 1982:25

Industries [1] - 2101:11

industry [7] - 2005:3, 2011:11, 2042:1,

2070:19, 2076:7, 2101:9, 2101:10

inexpensive [1] - 2211:19

influence [2] - 2232:14, 2232:21

inform [3] - 1993:8, 1998:8, 2046:5

information [79] - 1975:17, 1975:19,

1975:20, 1975:22, 1975:25, 1976:2,

1976:6, 1976:7, 1976:8, 1976:9,

1978:8, 1978:11, 1978:12, 1978:19,

1979:3, 1987:1, 1988:17, 1995:11,

1997:7, 1997:9, 2001:22, 2014:25,

2016:17, 2016:18, 2016:22, 2016:24,

2031:23, 2032:6, 2033:25, 2034:1,

2034:3, 2034:5, 2041:25, 2047:2,

2047:4, 2047:9, 2047:20, 2048:16,

2049:6, 2049:10, 2049:12, 2049:14,

2050:6, 2052:19, 2053:1, 2053:17,

2053:24, 2054:1, 2054:4, 2054:6,

2054:15, 2055:1, 2055:6, 2062:20,

2066:12, 2066:15, 2073:2, 2073:19,

2073:22, 2073:23, 2074:25, 2075:18,

2089:6, 2091:13, 2091:22, 2092:4,

2092:21, 2127:16, 2128:4, 2157:23,

2175:4, 2176:10, 2183:12, 2183:14,

2183:21, 2220:9, 2221:11, 2221:12,

2251:16

information-sharing [1] - 2055:1

informed [3] - 1992:25, 1993:11,

1993:12

informing [1] - 1995:3

infrastructure [7] - 2040:18, 2162:18,

2163:5, 2164:14, 2164:19, 2212:17,

2220:9

ing [1] - 2252:8

initial [6] - 1980:12, 2092:4, 2104:11,

2162:22, 2199:24, 2201:25

inquire [1] - 2145:4

inquired [1] - 2145:10

inquiries [1] - 2092:15

inquiry [1] - 2057:17

inserted [1] - 2010:11

insistent [1] - 2201:6

instance [2] - 2097:4, 2256:14

instances [1] - 1976:6

instead [4] - 2073:22, 2172:25,

2199:20, 2222:8

institution [2] - 2046:14, 2046:16

institutions [2] - 1979:10, 1979:17

instruction [1] - 2035:1

instrument [2] - 2244:20, 2246:2

instruments [2] - 2046:9, 2114:10

insurance [13] - 2007:1, 2115:23,

2116:9, 2116:12, 2116:17, 2116:21,

2116:23, 2117:1, 2117:4, 2117:15,

2117:21, 2118:2, 2202:24

Insurance [3] - 2117:8, 2117:13,

2118:1

intended [2] - 2006:5, 2087:3

intends [1] - 2035:16

intent [2] - 2209:25, 2210:1

intention [4] - 1993:1, 1993:9,

1993:13, 1998:9

intentionally [1] - 2238:20

interaction [5] - 2069:12, 2189:18,

2232:23, 2232:25, 2233:5

interest [5] - 2063:25, 2096:25,

2151:22, 2187:3, 2244:12

interested [7] - 2126:22, 2130:19,

2162:17, 2186:7, 2200:20, 2247:7

interesting [1] - 2083:10

Internal [5] - 2225:13, 2225:16,

2225:24, 2226:1, 2226:8

international [41] - 2004:4, 2006:12,

2006:13, 2006:15, 2006:22, 2006:23,

2007:1, 2007:2, 2010:1, 2011:21,

2011:22, 2012:1, 2014:20, 2015:22,

2028:13, 2031:12, 2032:23, 2036:20,

2052:12, 2072:2, 2090:7, 2095:14,

2100:18, 2125:10, 2158:11, 2158:14,

2160:21, 2161:1, 2213:25, 2221:15,

2221:23, 2223:19, 2230:9, 2230:18,

2238:12, 2239:12, 2239:20, 2240:21,

2249:9, 2253:12, 2253:16

International [71] - 1975:15, 1976:12,

1976:13, 1976:17, 1977:17, 1978:16,

1978:22, 1979:14, 1979:21, 1980:3,

1980:15, 1993:19, 1994:13, 1994:15,

1995:1, 1995:4, 1995:12, 1995:22,

1995:23, 1995:25, 1996:21, 2002:17,

2002:21, 2005:19, 2006:2, 2016:2,

2016:10, 2023:11, 2043:6, 2043:23,

2046:1, 2046:10, 2046:21, 2047:22,

2050:16, 2056:18, 2057:3, 2057:9,

2063:20, 2067:18, 2067:23, 2074:5,

2086:20, 2087:20, 2098:7, 2102:14,

2102:22, 2104:15, 2106:17, 2107:15,

2107:23, 2114:8, 2133:6, 2139:14,

2141:16, 2148:12, 2149:18, 2151:21,

2154:25, 2156:24, 2157:6, 2162:5,

2169:5, 2169:6, 2188:5, 2195:12,

2195:16, 2208:22, 2210:16, 2232:25,

2246:16

Internet [5] - 2006:21, 2006:22,

2040:22, 2040:24, 2041:21

interruption [1] - 2128:17

intervals [1] - 1979:7

interview [20] - 2042:15, 2103:9,

2103:11, 2104:11, 2104:23, 2105:12,

2173:14, 2177:13, 2178:5, 2178:6,

2178:13, 2178:23, 2181:1, 2182:13,

2183:6, 2184:19, 2185:23, 2200:13,

2201:25, 2233:22

interviewed [9] - 2172:8, 2172:19,

2176:24, 2177:3, 2177:10, 2182:6,

2183:2, 2185:9, 2202:12

interviewing [3] - 2103:17, 2104:16,

2202:2

interviews [3] - 2177:22, 2178:3,

2233:20

introduce [2] - 2089:14, 2099:11

introduced [3] - 1984:8, 1989:16,

2027:16

invest [21] - 1979:8, 1979:19, 2120:3,

2121:10, 2121:22, 2122:11, 2123:11,

2123:15, 2129:5, 2170:10, 2170:24,

2171:3, 2171:5, 2172:2, 2216:13,

2244:22, 2245:7, 2245:10, 2250:1,

2255:17, 2255:21

invested [10] - 1978:14, 2111:6,

2129:12, 2167:11, 2247:7, 2248:10,

2249:1, 2249:2, 2250:18, 2250:24

investigation [2] - 2016:4, 2016:11

investigations [1] - 2092:15

investing [10] - 1979:17, 2016:23,

2124:24, 2125:1, 2163:11, 2215:11,

2215:24, 2231:7, 2246:18, 2248:22

investment [45] - 1977:19, 1978:9,

1978:13, 1978:14, 1978:15, 1978:24,

1979:4, 1979:5, 1979:6, 1979:9,

1979:22, 1981:13, 2016:25, 2085:15,

2107:19, 2111:20, 2111:24, 2113:11,

2113:23, 2115:1, 2115:9, 2119:13,

2126:7, 2126:18, 2129:4, 2133:25,

2135:7, 2149:4, 2162:13, 2162:14,


2274

2165:24, 2166:1, 2166:2, 2183:24,

2184:2, 2237:19, 2248:8, 2248:11,

2255:19, 2256:12, 2256:19

Investment [13] - 2102:14, 2106:17,

2107:15, 2107:23, 2114:12, 2123:3,

2133:4, 2133:6, 2161:25, 2162:10,

2165:11, 2166:14, 2188:5

investment-type [1] - 2135:7

investments [22] - 1979:12, 1981:2,

1987:2, 2085:11, 2106:20, 2112:3,

2113:15, 2119:16, 2120:7, 2122:20,

2123:12, 2126:7, 2126:10, 2133:21,

2149:2, 2149:13, 2165:25, 2171:9,

2191:3, 2247:14, 2251:17, 2253:11

Investments [1] - 2247:18

investor [4] - 2076:14, 2077:25,

2083:13, 2084:12

investors [1] - 2035:3

invests [3] - 2245:2, 2246:8, 2247:4

invited [2] - 2103:9, 2138:23

involve [1] - 2121:1

involved [13] - 2012:3, 2094:10,

2125:12, 2132:11, 2139:25, 2141:12,

2161:24, 2163:4, 2200:16, 2210:4,

2255:23, 2256:7

involvement [6] - 2068:16, 2068:19,

2132:10, 2132:22, 2133:16, 2216:16

irregularities [1] - 2032:15

irregularity [1] - 2032:2

IRS [2] - 2225:19, 2226:3

island [33] - 2003:9, 2013:23, 2017:5,

2026:19, 2027:2, 2027:4, 2029:25,

2040:5, 2040:14, 2040:25, 2064:18,

2065:5, 2141:2, 2141:3, 2160:24,

2163:15, 2163:23, 2163:25, 2164:19,

2190:5, 2194:25, 2205:13, 2206:6,

2210:15, 2211:24, 2212:22, 2213:3,

2213:22, 2215:20, 2217:3, 2218:19,

2222:9, 2222:10

Island [20] - 2005:12, 2013:10,

2014:13, 2015:5, 2023:15, 2023:17,

2023:18, 2023:20, 2024:5, 2024:12,

2034:11, 2190:1, 2192:19, 2195:16,

2217:24, 2218:1, 2218:2, 2218:9,

2218:22, 2219:2

islands [21] - 2005:15, 2018:13,

2018:14, 2018:17, 2018:21, 2019:14,

2019:19, 2064:19, 2162:11, 2162:12,

2162:13, 2162:18, 2162:23, 2162:25,

2163:5, 2163:16, 2163:17, 2164:9,

2164:24, 2218:19, 2218:23

Islands [1] - 2005:16

isolated [1] - 2256:14

issue [18] - 1995:2, 1995:5, 1997:13,

2040:11, 2046:21, 2053:10, 2054:16,

2054:18, 2091:6, 2116:12, 2116:17,

2141:14, 2200:6, 2225:2, 2225:13,

2239:11, 2241:21, 2253:6

issued [2] - 2036:7, 2187:12

issues [3] - 2160:11, 2206:19, 2206:23

issuing [1] - 1995:7

Item [1] - 2067:16

items [3] - 1993:16, 2012:14, 2041:23

itself [11] - 1981:21, 1982:16, 1992:10,

2041:5, 2048:10, 2049:16, 2050:5,

2050:19, 2089:12, 2150:22, 2163:21

Ivan [2] - 2009:20, 2014:10

J

Jackson [1] - 2220:24

James [9] - 1990:8, 1993:7, 1993:14,

2002:14, 2105:9, 2198:16, 2199:24,

2202:18, 2202:19

January [5] - 1971:5, 2002:21,

2067:19, 2086:21, 2087:21

Jeffrey [1] - 2014:10

jeopardy [3] - 1981:22, 1982:17,

1982:23

jet [1] - 2195:25

jets [3] - 2138:5, 2196:11, 2218:4

Jim [4] - 2130:6, 2130:9, 2130:20,

2198:16

job [16] - 2001:13, 2013:22, 2026:10,

2097:1, 2160:5, 2160:6, 2166:11,

2167:19, 2168:2, 2168:4, 2170:4,

2172:8, 2172:19, 2172:20, 2176:13,

2185:10

jobs [5] - 2102:10, 2212:24, 2213:1,

2213:2, 2237:21

John [15] - 1972:2, 1983:20, 1993:11,

1993:13, 1993:15, 1994:12, 1995:17,

1997:12, 1998:8, 2000:10, 2000:15,

2000:16, 2000:17, 2000:20, 2039:3

John's [3] - 1997:19, 1998:3, 2063:21

johnny [1] - 2076:22

Johnny [7] - 1972:10, 1972:18,

1976:25, 2080:23, 2084:7, 2257:10,

2257:14

join [2] - 2005:6, 2005:10

joined [6] - 2068:22, 2068:24, 2069:6,

2069:7, 2069:10, 2069:17

Jonathan [1] - 2121:17

Jordan [1] - 1995:17

Journal [1] - 2103:1

Jr [1] - 1993:8

judge [9] - 1991:7, 1991:10, 1991:11,

2039:15, 2203:9, 2204:12, 2204:13,

2205:1

JUDGE [1] - 1971:10

Judge [61] - 1976:18, 1984:1, 1987:10,

1988:1, 1988:19, 1993:5, 1993:7,

1994:5, 1994:7, 1994:9, 1995:21,

1996:3, 1996:12, 1998:2, 1999:8,

1999:19, 2000:14, 2000:18, 2000:25,

2002:4, 2003:19, 2009:22, 2017:20,

2022:12, 2027:20, 2037:2, 2037:7,

2037:14, 2038:8, 2040:2, 2044:17,

2045:4, 2045:13, 2045:19, 2050:12,

2051:14, 2056:9, 2057:20, 2065:22,

2070:5, 2075:12, 2076:1, 2076:17,

2078:23, 2080:19, 2081:8, 2083:14,

2084:15, 2085:22, 2086:3, 2089:14,

2090:20, 2090:23, 2096:10, 2096:12,

2097:8, 2097:23, 2098:14, 2111:19,

2124:16, 2153:19

Judge's [8] - 1993:23, 1993:25,

1996:7, 2000:25, 2086:12, 2087:8,

2087:10, 2087:11

judged [1] - 2242:1

judges [2] - 1991:12, 2000:1

judgment [6] - 1990:18, 1994:3,

2002:6, 2002:7, 2002:11, 2032:13

judgments [1] - 2031:16

judicial [4] - 1996:2, 1997:23, 1999:6,

2066:19

July [1] - 2055:3

jump [2] - 2113:6, 2113:7

jumping [1] - 2129:14

June [5] - 2002:25, 2154:3, 2162:21,

2163:1, 2208:5

junior [1] - 2043:14

juries [1] - 2096:21

jurisdiction [5] - 1998:20, 2011:24,

2017:2, 2042:20, 2047:13

jurisdictions [3] - 1999:10, 2054:25,

2074:4

jury [47] - 1975:1, 1987:20, 1988:13,

1992:6, 2000:5, 2002:9, 2023:3,

2023:10, 2023:24, 2035:1, 2035:9,

2038:18, 2038:23, 2041:16, 2045:5,

2054:12, 2058:16, 2060:9, 2064:16,

2067:15, 2076:2, 2076:4, 2076:11,

2079:22, 2081:3, 2083:17, 2083:18,

2085:18, 2088:1, 2093:2, 2093:4,

2095:7, 2095:19, 2096:19, 2099:11,

2099:25, 2134:18, 2155:12, 2175:21,

2176:3, 2197:22, 2198:14, 2198:24,

2201:15, 2247:3, 2255:16

JURY [1] - 1971:7

jury's [1] - 2136:23

Justice [9] - 1971:17, 1990:4, 1990:13,

2002:9, 2039:2, 2039:7, 2039:19,

2086:10

justice [2] - 2002:10, 2039:8

justices [1] - 2039:6

K

K-N-O-C-H-E [1] - 2099:13

keep [12] - 1997:11, 2006:12, 2044:5,

2061:13, 2063:6, 2063:7, 2092:12,

2113:4, 2120:19, 2150:8, 2150:13,

2254:24

keeping [2] - 2017:14, 2054:20

Kenneth [5] - 1972:6, 1998:10, 2000:9,

2009:22, 2204:22

kind [19] - 1978:11, 2007:20, 2019:5,

2081:24, 2172:18, 2172:25, 2175:10,

2175:19, 2176:9, 2184:20, 2186:13,

2186:17, 2192:4, 2202:21, 2203:19,

2216:12, 2225:19, 2232:20, 2255:21

kinds [2] - 2041:16, 2179:18

Kingdom [2] - 2013:9, 2013:13

Kirby [1] - 2134:20

Knoche [38] - 2098:24, 2099:13,


2275

2118:21, 2125:5, 2136:13, 2144:16,

2149:4, 2149:23, 2151:9, 2155:18,

2159:10, 2169:10, 2175:15, 2177:23,

2182:3, 2183:7, 2189:2, 2205:25,

2207:14, 2207:22, 2208:10, 2209:14,

2215:17, 2219:4, 2225:12, 2227:5,

2228:4, 2228:21, 2230:5, 2230:19,

2233:18, 2247:17, 2251:8, 2255:5

KNOCHE [2] - 1973:15, 2099:4

knock [1] - 2214:17

knowing [2] - 2176:12, 2247:7

knowledge [26] - 1976:22, 2015:1,

2025:18, 2028:25, 2046:3, 2053:6,

2064:7, 2070:6, 2081:9, 2084:13,

2088:24, 2093:13, 2093:16, 2094:6,

2094:18, 2094:19, 2094:20, 2112:7,

2114:14, 2131:2, 2131:5, 2131:6,

2152:20, 2161:10, 2212:19, 2251:22

known [2] - 2019:12, 2079:4

KPMG [1] - 2101:5

L

labor [1] - 1991:7

lack [1] - 2070:5

ladies [3] - 2057:22, 2151:6, 2155:8

lady [2] - 1984:16

laid [5] - 2110:5, 2196:16, 2196:18,

2237:3, 2237:5

land [15] - 2192:16, 2192:17, 2195:24,

2196:11, 2196:12, 2207:1, 2209:2,

2209:18, 2209:20, 2209:21, 2217:20,

2218:4, 2219:2

lands [4] - 2206:13, 2206:15, 2208:16,

2208:19

language [2] - 1990:24, 2050:19

lapel [3] - 1983:25, 1987:9, 1987:11

large [1] - 1998:24

larger [2] - 2129:25, 2160:20

largest [1] - 2100:21

Larry [3] - 2107:2, 2109:13, 2181:11

last [19] - 1982:1, 2001:17, 2002:3,

2035:19, 2040:4, 2067:10, 2084:19,

2087:9, 2087:19, 2091:14, 2099:12,

2100:12, 2135:5, 2135:14, 2135:22,

2161:22, 2217:7, 2219:7, 2255:2

late [8] - 2007:6, 2026:16, 2027:1,

2133:20, 2135:1, 2139:21, 2147:11,

2170:23

latest [1] - 1989:13

latter [1] - 2136:7

laundering [7] - 2004:10, 2004:17,

2004:22, 2004:23, 2016:5, 2016:12,

2070:1

Law [2] - 1972:3, 1972:6

law [14] - 1977:21, 1982:22, 1991:13,

1991:18, 2001:15, 2001:22, 2001:25,

2004:9, 2028:14, 2032:24, 2089:24,

2090:18, 2226:7, 2252:12

laws [13] - 1975:12, 1975:14, 1975:15,

1977:10, 1986:22, 1987:4, 2002:1,

2004:3, 2004:4, 2004:17, 2005:14,

2007:19

lawsuit [5] - 1990:20, 1992:7, 1992:9,

2226:1, 2226:2

lawyer [16] - 1985:5, 1985:10,

1985:13, 1985:14, 1985:15, 1985:16,

2001:8, 2009:8, 2009:15, 2009:16,

2096:17, 2178:20, 2204:14, 2204:15,

2205:1, 2205:2

lawyers [4] - 1984:22, 1990:15,

2009:7, 2088:20

lay [1] - 2112:15

Le [1] - 2134:21

LE [1] - 2134:25

leading [4] - 2014:25, 2075:14,

2123:19, 2124:4

learn [9] - 2003:11, 2105:11, 2106:7,

2107:17, 2123:14, 2124:12, 2124:20,

2187:8, 2204:4

learned [4] - 2000:3, 2065:3, 2108:23,

2129:19

lease [1] - 2206:15

leaseholds [1] - 2208:20

leases [1] - 2207:1

least [3] - 1983:24, 2039:19, 2179:6

leave [15] - 1993:1, 1993:20, 1995:5,

2061:15, 2095:15, 2098:17, 2098:20,

2101:22, 2101:24, 2154:2, 2167:6,

2206:5, 2219:18, 2230:19, 2256:24

leaving [2] - 1999:3, 2168:13

left [35] - 1985:2, 1985:19, 1985:23,

2018:4, 2030:9, 2036:4, 2045:9,

2057:25, 2060:10, 2065:2, 2073:13,

2081:3, 2085:1, 2085:2, 2093:4,

2114:5, 2136:14, 2138:12, 2148:5,

2151:11, 2162:20, 2166:7, 2198:3,

2198:7, 2198:10, 2208:5, 2211:6,

2211:15, 2212:1, 2215:4, 2217:22,

2218:21, 2219:3, 2232:19, 2234:10

left-hand [3] - 2030:9, 2073:13, 2114:5

legal [10] - 1976:5, 1999:18, 2001:14,

2001:15, 2026:4, 2046:15, 2095:3,

2095:9, 2095:11

legend [1] - 2019:12

legible [1] - 2053:8

legislation [5] - 2069:25, 2070:18,

2071:4, 2071:11, 2071:22

legislative [1] - 2012:4

legitimate [2] - 2224:5, 2224:6

length [2] - 2206:9, 2206:11

lengthy [1] - 2038:13

less [3] - 2014:21, 2143:17, 2170:5

letter [35] - 1990:23, 1992:5, 1993:2,

1994:25, 1995:2, 1995:5, 1995:7,

1995:18, 1996:10, 1996:11, 1996:14,

1996:16, 1997:13, 1997:15, 1998:7,

1998:25, 1999:1, 2002:25, 2003:12,

2013:1, 2036:5, 2038:10, 2046:6,

2046:21, 2047:15, 2048:19, 2052:22,

2053:14, 2054:3, 2054:15, 2057:16,

2062:12, 2103:8, 2130:2, 2166:21

letterhead [1] - 2045:22

letters [1] - 2059:14

level [7] - 1996:15, 2126:4, 2126:6,

2126:10, 2126:17, 2132:10, 2176:17

liability [2] - 2088:11, 2226:23

license [20] - 1981:22, 1982:17,

1982:22, 1988:9, 1988:20, 1991:3,

1992:8, 1992:12, 2000:11, 2000:16,

2000:17, 2067:23, 2068:3, 2086:13,

2087:21, 2087:22, 2088:4, 2092:9,

2098:7, 2130:3

licensed [2] - 2040:23, 2046:13

licenses [13] - 1991:1, 1998:19,

1998:25, 1999:2, 2000:13, 2000:20,

2002:20, 2067:18, 2086:19, 2087:12,

2088:2, 2212:11, 2212:16

lie [1] - 2251:13

life [1] - 2195:13

lifting [1] - 2094:21

light [1] - 2141:16

lighter [1] - 2141:20

lights [2] - 2143:14, 2143:16

limit [3] - 2079:17, 2167:17, 2196:23

limitations [1] - 2074:5

Limited [12] - 2002:17, 2063:20,

2067:19, 2086:20, 2087:20, 2117:13,

2118:2, 2188:2, 2208:24, 2209:8,

2246:16

limited [5] - 2114:8, 2119:19, 2122:22,

2188:6, 2188:7

Limits [1] - 2079:18

line [11] - 1982:1, 1985:24, 2015:11,

2042:5, 2059:18, 2083:17, 2083:23,

2112:9, 2196:13, 2241:14, 2254:15

lined [2] - 2167:19, 2256:15

lines [3] - 2084:23, 2252:24, 2255:2

link [1] - 2152:13

liquid [12] - 2125:2, 2125:4, 2125:16,

2166:2, 2237:19, 2251:17, 2253:13,

2255:17, 2256:12, 2256:15, 2256:19

liquidator [1] - 2025:23

liquidators [2] - 2025:25, 2026:1

liquidity [2] - 2126:5, 2253:19

list [13] - 2017:14, 2037:11, 2047:23,

2051:2, 2118:11, 2118:13, 2118:20,

2212:17, 2222:17, 2248:7, 2248:15,

2248:21

listed [10] - 2086:14, 2118:15,

2239:10, 2247:14, 2247:18, 2253:9,

2253:12, 2253:15, 2255:5, 2255:9

listened [1] - 2076:20

listening [1] - 2054:12

listing [4] - 1978:24, 1979:10,

2228:18, 2253:18

lists [5] - 2049:3, 2056:22, 2149:3,

2151:21, 2152:1

live [2] - 2099:14, 2099:15

lived [2] - 2018:4, 2099:16

living [1] - 2099:20

Lloyd [3] - 2008:19, 2014:9, 2094:2

Lloyd's [1] - 2117:7

loan [34] - 1976:14, 2058:21, 2058:24,

2059:3, 2059:5, 2059:8, 2062:23,

2097:16, 2102:1, 2152:6, 2156:25,

2157:13, 2157:17, 2157:24, 2158:2,


2276

2158:3, 2158:6, 2159:6, 2223:1,

2223:13, 2224:18, 2225:9, 2226:4,

2228:9, 2229:20, 2241:10, 2248:4,

2248:5, 2248:6, 2248:10, 2253:14,

2254:20

loaned [1] - 2224:20

loaning [1] - 2225:14

loans [23] - 2058:19, 2059:6, 2062:21,

2113:25, 2114:2, 2114:7, 2114:9,

2114:15, 2149:17, 2153:12, 2222:6,

2222:17, 2222:24, 2222:25, 2227:7,

2227:13, 2227:14, 2228:11, 2229:9,

2229:12, 2239:1, 2248:8, 2249:3

local [3] - 2100:16, 2101:7, 2226:7

located [7] - 2024:10, 2063:21,

2073:2, 2074:6, 2081:21, 2121:18,

2136:2

location [1] - 2187:4

locations [1] - 2221:25

lodged [1] - 2008:3

loft [2] - 2135:2, 2135:3

Lofts [1] - 2171:14

London [4] - 1999:22, 2020:11, 2117:7

look [31] - 1985:17, 1990:2, 2020:23,

2041:5, 2041:8, 2049:16, 2049:18,

2054:11, 2055:13, 2055:18, 2066:7,

2067:23, 2073:5, 2085:19, 2089:24,

2091:3, 2154:8, 2154:12, 2155:25,

2156:11, 2159:11, 2174:9, 2174:11,

2177:12, 2177:19, 2184:18, 2187:11,

2195:4, 2209:12, 2241:22, 2247:17

looked [14] - 1999:1, 2025:17,

2029:15, 2066:25, 2073:12, 2155:4,

2158:23, 2159:2, 2187:2, 2187:6,

2187:15, 2192:21, 2229:3, 2229:10

looking [21] - 1985:18, 2006:10,

2010:13, 2037:25, 2050:20, 2056:13,

2058:8, 2080:3, 2096:13, 2101:24,

2102:10, 2104:7, 2130:22, 2131:1,

2168:2, 2184:5, 2184:20, 2219:14,

2228:13, 2236:3, 2240:1

looks [2] - 2022:6, 2193:2

loss [1] - 2191:10

Lotus [2] - 2203:1, 2203:15

loud [3] - 2028:7, 2073:17, 2254:4

louder [1] - 2144:4

love [1] - 2010:17

loved [1] - 2200:14

low [5] - 2037:25, 2113:14, 2237:18,

2244:17, 2251:17

low-risk [2] - 2113:14, 2237:18

Lumiere [1] - 2009:9

lunch [1] - 2078:7

M

ma'am [16] - 1977:6, 1986:6, 1990:5,

1992:5, 1996:18, 2001:12, 2003:3,

2004:1, 2029:9, 2041:11, 2050:14,

2052:10, 2061:10, 2090:10, 2098:15,

2098:22

Maid [1] - 2135:2

mail [1] - 2166:21

main [1] - 2167:6

major [4] - 2097:5, 2100:4, 2253:12,

2253:15

male [1] - 2182:10

mall [1] - 2023:13

man [4] - 2039:4, 2112:25, 2114:14,

2172:7

management [7] - 2031:4, 2132:9,

2180:10, 2181:9, 2183:3, 2199:7,

2208:21

manager [2] - 2187:4, 2231:6

managers [4] - 2115:13, 2115:15,

2115:17, 2162:23

managing [3] - 2115:19, 2181:9,

2181:11

mandatory [1] - 2059:6

manner [2] - 2079:10, 2201:7

manual [3] - 1980:3, 1980:15, 1982:8

map [1] - 2018:16

marble [1] - 2141:10

margin [1] - 2045:9

Maria [3] - 2108:9, 2108:11

MARIAN [1] - 1973:4

marina [3] - 2196:22, 2196:24, 2218:7

mark [1] - 2090:24

marked [7] - 1988:24, 1989:14,

1992:15, 2020:21, 2055:11, 2055:17,

2063:2

market [10] - 2125:23, 2163:14,

2212:11, 2212:18, 2233:12, 2236:18,

2236:22, 2252:6, 2253:20, 2254:11

marketable [1] - 2254:7

marketing [4] - 2164:4, 2217:15,

2252:7, 2252:8

markings [1] - 1993:6

married [1] - 2189:10

marrying [1] - 2010:14

Marshals [1] - 2016:3

Marwick [4] - 2100:16, 2100:18,

2101:4, 2101:6

match [2] - 2025:15, 2217:10

matches [2] - 2214:10, 2217:6

material [11] - 2032:1, 2032:14,

2109:7, 2129:11, 2241:8, 2241:9,

2241:12, 2241:13, 2241:16, 2241:22,

2241:24

materiality [6] - 2240:15, 2240:17,

2241:5, 2241:17, 2242:1, 2254:16

materials [23] - 2093:22, 2109:2,

2109:9, 2109:12, 2109:23, 2110:6,

2110:10, 2110:12, 2110:17, 2110:23,

2112:15, 2112:17, 2113:11, 2140:25,

2141:3, 2141:5, 2141:7, 2235:7,

2251:15, 2251:19, 2252:4, 2252:7,

2252:9

matter [8] - 1979:18, 1985:11,

1996:14, 2003:17, 2035:18, 2125:7,

2150:10, 2257:12

mattered [1] - 2075:19

matters [4] - 2000:1, 2000:2, 2097:4,

2209:9

mature [2] - 2253:10, 2255:6

mayor [1] - 2202:23

McGuire [2] - 1972:6, 1972:6

mean [47] - 1976:8, 1976:11, 1979:6,

1996:15, 1999:12, 2004:7, 2023:12,

2061:17, 2082:15, 2083:24, 2092:10,

2125:3, 2125:15, 2131:18, 2139:24,

2146:6, 2180:12, 2181:18, 2185:1,

2186:20, 2189:21, 2193:1, 2193:22,

2197:3, 2199:9, 2200:4, 2200:22,

2201:17, 2203:23, 2212:14, 2213:16,

2216:17, 2219:19, 2223:5, 2232:13,

2233:5, 2233:7, 2240:17, 2241:5,

2246:20, 2246:23, 2249:21, 2250:22,

2254:4, 2254:9, 2255:11, 2256:20

meaning [1] - 2083:25

means [3] - 2125:4, 2240:18, 2253:20

meant [1] - 2070:8

measure [1] - 2102:5

mechanical [2] - 1972:13, 1972:20

meet [6] - 2105:2, 2105:8, 2202:7,

2202:15, 2203:25, 2204:21

meeting [11] - 1994:11, 1994:20,

1994:24, 1995:3, 1998:8, 1998:13,

1998:18, 2000:10, 2000:13, 2097:16,

2103:13

meetings [14] - 2107:25, 2109:7,

2109:11, 2109:15, 2109:24, 2110:7,

2110:19, 2112:14, 2112:18, 2115:21,

2116:17, 2117:17, 2117:19, 2160:10

member [2] - 1991:9, 2069:6

members [4] - 1994:15, 2105:12,

2134:14, 2159:16

Members [1] - 2030:22

memo [6] - 2012:13, 2012:16,

2012:17, 2012:18, 2013:4, 2041:5

memorandum [1] - 1976:4

memory [6] - 2050:22, 2050:23,

2065:21, 2112:2, 2180:24, 2184:18

memos [1] - 2034:14

mention [2] - 2145:7, 2145:16

mentioned [21] - 2010:5, 2041:20,

2107:5, 2109:13, 2117:6, 2117:7,

2117:8, 2118:6, 2123:22, 2126:4,

2126:21, 2133:20, 2134:15, 2135:7,

2137:16, 2146:10, 2150:15, 2163:18,

2163:22, 2164:7, 2217:21

merged [2] - 2101:4, 2101:5

mergers [2] - 2101:2, 2101:3

mess [2] - 1992:16, 2028:7

message [3] - 2013:9, 2013:12,

2013:21

met [10] - 1983:20, 1984:4, 2039:4,

2103:12, 2161:7, 2169:13, 2199:3,

2204:2, 2204:9, 2204:22

Mexia [15] - 2105:1, 2105:3, 2105:5,

2105:8, 2105:12, 2201:16, 2201:17,

2201:18, 2201:19, 2201:20, 2202:12,

2202:23, 2204:6, 2205:8

Miami [1] - 2119:4

Michelle [5] - 2061:23, 2108:8,

2108:10, 2108:12, 2108:13

microphone [2] - 1983:25, 2128:14Johnny C. Sanchez, RMR, CRR - [email protected]

2277

mid-'90s [2] - 2134:6, 2134:10

might [27] - 1983:12, 1984:24,

1988:16, 2015:1, 2026:16, 2033:23,

2041:2, 2061:16, 2071:22, 2089:9,

2129:1, 2137:13, 2137:14, 2137:18,

2147:8, 2147:13, 2147:16, 2158:24,

2159:10, 2203:10, 2215:25, 2222:13,

2232:20, 2249:15, 2249:18, 2253:6

mike [4] - 1987:9, 1987:12, 2086:1,

2127:18

Milam [2] - 2103:14, 2131:12

militate [1] - 1995:7

million [28] - 2016:3, 2064:4, 2149:10,

2149:11, 2151:22, 2152:1, 2153:1,

2155:1, 2155:20, 2156:19, 2156:25,

2157:18, 2157:20, 2158:2, 2158:3,

2159:6, 2216:21, 2223:1, 2228:9,

2228:24, 2241:8, 2241:11, 2247:21,

2247:22, 2253:14, 2254:14, 2254:20

million-dollar [10] - 2016:3, 2156:19,

2156:25, 2158:2, 2158:3, 2159:6,

2223:1, 2228:9, 2241:8, 2253:14

millions [15] - 2075:10, 2152:16,

2211:23, 2212:2, 2212:4, 2212:6,

2215:12, 2216:13, 2219:20, 2219:22,

2219:23, 2219:24, 2242:5

millwork [1] - 2141:9

Milton [2] - 2100:17

mind [7] - 2009:10, 2021:3, 2132:3,

2150:8, 2150:13, 2197:3, 2230:15

mindset [1] - 2096:16

minimization [3] - 2088:6, 2088:7,

2088:22

minister [2] - 1998:17, 1998:24

Minister [1] - 2087:13

minister's [2] - 1998:11, 1998:16

Ministry [1] - 2087:13

minor [1] - 2209:21

minute [10] - 2035:10, 2061:10,

2066:7, 2083:1, 2083:2, 2204:2,

2205:25, 2221:9, 2232:4, 2243:8

Minute [1] - 2135:2

minutes [7] - 2034:21, 2034:22,

2035:7, 2036:19, 2143:10, 2151:7,

2229:15

mislead [1] - 2088:1

misled [1] - 2249:1

misrepresentations [2] - 2032:15,

2191:20

miss [1] - 2240:10

missing [1] - 2095:2

misspoke [1] - 2017:21

misstatement [1] - 2032:1

Mitchell [1] - 2100:16

moderate [1] - 2194:6

moderately [5] - 2171:24, 2171:25,

2191:4, 2191:5, 2242:12

moment [3] - 2072:14, 2227:1,

2227:15

Monarch [4] - 2101:14, 2101:22,

2101:24, 2169:19

Monday [1] - 2093:5

money [111] - 1982:21, 2004:10,

2004:17, 2004:21, 2004:23, 2016:4,

2016:11, 2016:23, 2040:17, 2070:1,

2080:18, 2085:12, 2110:1, 2110:10,

2110:20, 2111:4, 2115:13, 2115:15,

2115:17, 2119:15, 2119:20, 2120:19,

2122:2, 2125:1, 2125:4, 2125:17,

2127:4, 2127:7, 2127:9, 2129:4,

2135:15, 2145:5, 2145:7, 2145:10,

2145:16, 2145:19, 2146:2, 2146:3,

2146:4, 2146:16, 2147:2, 2148:18,

2153:7, 2155:22, 2163:2, 2165:14,

2167:10, 2167:15, 2167:18, 2170:5,

2170:9, 2175:5, 2176:4, 2176:12,

2176:18, 2188:11, 2188:12, 2188:14,

2189:16, 2194:6, 2197:11, 2199:6,

2199:8, 2215:24, 2216:15, 2216:21,

2219:17, 2220:6, 2223:12, 2223:13,

2224:17, 2224:18, 2225:5, 2225:14,

2226:10, 2231:7, 2235:8, 2235:16,

2237:12, 2237:15, 2237:17, 2238:2,

2239:2, 2239:3, 2242:22, 2243:17,

2243:20, 2243:22, 2244:10, 2244:22,

2245:2, 2245:5, 2245:8, 2245:13,

2245:15, 2245:16, 2246:9, 2246:18,

2247:5, 2247:7, 2248:14, 2249:1,

2250:1, 2250:5, 2250:9, 2251:3,

2251:4, 2255:25, 2256:8

monies [1] - 2128:23

monitor [1] - 2232:7

monitoring [1] - 2141:12

month [1] - 2167:20

months [5] - 2013:5, 2039:8, 2099:17,

2126:3, 2183:1

months' [3] - 2166:22, 2166:23,

2167:4

Montrose [1] - 2186:19

Montserrat [32] - 1988:9, 1990:4,

1990:10, 1992:11, 1992:25, 1993:8,

1993:9, 1993:20, 1994:14, 1995:5,

1995:13, 1995:22, 1996:11, 1996:17,

1996:19, 1996:20, 1997:8, 1997:9,

1998:21, 2004:3, 2004:6, 2066:19,

2086:7, 2086:10, 2087:23, 2098:5,

2104:13, 2129:20, 2129:23, 2129:24,

2130:1, 2192:20

morning [15] - 1975:3, 1975:4,

1975:10, 1975:11, 1983:18, 1983:19,

1986:15, 1987:19, 2016:15, 2035:15,

2051:16, 2052:3, 2096:25, 2103:14,

2136:11

most [9] - 2039:24, 2075:24, 2108:16,

2135:22, 2136:1, 2199:9, 2199:11,

2241:9, 2242:12

motion [1] - 2096:24

motive [1] - 2194:14

move [24] - 1993:13, 1996:9, 1998:9,

1998:20, 2008:17, 2017:21, 2022:12,

2031:19, 2032:3, 2044:12, 2051:14,

2051:23, 2056:3, 2089:14, 2090:1,

2094:22, 2095:18, 2102:3, 2106:4,

2127:18, 2192:1, 2192:20, 2208:2,

2252:1

moved [5] - 2093:20, 2129:20,

2129:22, 2185:19, 2185:20

moving [2] - 1996:4, 2225:14

MR [497] - 1973:6, 1973:8, 1973:10,

1973:12, 1973:17, 1973:19, 1973:21,

1973:23, 1973:25, 1974:2, 1975:7,

1975:9, 1976:18, 1977:3, 1977:13,

1980:7, 1980:13, 1980:18, 1980:19,

1982:25, 1983:2, 1983:4, 1983:7,

1983:8, 1983:9, 1983:14, 1983:17,

1984:1, 1984:3, 1985:17, 1985:23,

1986:1, 1986:5, 1987:10, 1987:17,

1987:24, 1988:3, 1989:4, 1989:6,

1989:8, 1989:11, 1989:14, 1989:19,

1989:22, 1990:1, 1990:7, 1991:17,

1992:4, 1992:20, 1992:22, 1997:3,

1997:23, 1998:1, 1999:8, 1999:11,

1999:13, 1999:17, 2000:4, 2000:8,

2001:5, 2001:6, 2017:9, 2017:15,

2017:17, 2017:20, 2017:22, 2020:16,

2022:10, 2022:11, 2022:12, 2022:16,

2022:18, 2022:21, 2023:1, 2027:18,

2027:20, 2027:22, 2027:24, 2028:3,

2028:6, 2028:16, 2028:19, 2029:5,

2029:8, 2029:20, 2029:23, 2030:2,

2030:3, 2030:6, 2030:10, 2030:16,

2030:20, 2031:8, 2031:9, 2031:19,

2031:20, 2032:3, 2032:4, 2032:8,

2032:9, 2034:24, 2035:13, 2036:2,

2036:5, 2036:11, 2036:15, 2036:17,

2036:25, 2037:2, 2037:7, 2037:14,

2037:16, 2037:20, 2037:23, 2038:2,

2038:8, 2038:20, 2040:2, 2040:3,

2044:12, 2044:16, 2044:20, 2044:23,

2044:25, 2045:4, 2045:7, 2045:13,

2045:17, 2045:21, 2046:12, 2049:24,

2050:12, 2050:13, 2051:14, 2051:19,

2051:25, 2052:2, 2052:9, 2054:13,

2056:3, 2056:9, 2056:10, 2056:15,

2056:16, 2057:20, 2057:23, 2058:6,

2058:7, 2059:16, 2059:25, 2061:11,

2061:16, 2062:1, 2062:3, 2062:6,

2062:9, 2062:11, 2063:4, 2063:9,

2063:11, 2065:22, 2065:24, 2066:2,

2066:21, 2066:23, 2067:5, 2067:7,

2067:11, 2070:5, 2070:10, 2070:14,

2070:16, 2070:21, 2071:3, 2071:16,

2072:8, 2072:10, 2073:5, 2073:10,

2073:15, 2075:4, 2075:8, 2075:12,

2075:14, 2075:17, 2076:1, 2076:5,

2076:12, 2076:17, 2077:1, 2077:5,

2077:9, 2077:12, 2077:15, 2077:17,

2078:2, 2078:8, 2078:11, 2078:23,

2079:5, 2079:9, 2079:14, 2079:25,

2080:1, 2080:5, 2080:8, 2080:11,

2080:12, 2080:19, 2081:5, 2081:8,

2081:13, 2083:4, 2083:6, 2083:14,

2083:22, 2084:4, 2084:9, 2084:14,

2084:15, 2084:18, 2085:8, 2085:21,

2085:23, 2086:3, 2086:4, 2088:12,

2088:15, 2089:14, 2089:17, 2089:18,

2090:1, 2090:4, 2090:7, 2090:14,

2090:20, 2090:21, 2090:23, 2091:2,


2278

2092:13, 2096:7, 2096:9, 2096:12,

2097:8, 2097:11, 2097:21, 2097:23,

2098:1, 2098:3, 2098:12, 2098:14,

2098:24, 2099:8, 2101:1, 2102:18,

2104:2, 2104:5, 2105:17, 2105:20,

2105:25, 2106:2, 2106:6, 2110:2,

2110:5, 2110:11, 2110:16, 2110:22,

2111:1, 2111:8, 2111:11, 2111:12,

2111:13, 2111:17, 2111:23, 2112:5,

2112:12, 2112:21, 2112:22, 2113:3,

2113:4, 2113:8, 2113:18, 2113:24,

2114:3, 2114:6, 2114:13, 2114:17,

2114:21, 2115:7, 2116:1, 2116:8,

2116:14, 2116:16, 2117:9, 2117:11,

2117:22, 2117:25, 2118:9, 2118:12,

2118:17, 2118:19, 2119:23, 2121:4,

2121:7, 2123:18, 2123:21, 2124:4,

2124:7, 2124:19, 2124:23, 2125:5,

2125:9, 2125:14, 2128:2, 2128:10,

2128:16, 2134:23, 2135:4, 2136:10,

2136:12, 2136:22, 2136:24, 2137:4,

2137:5, 2138:7, 2138:8, 2138:18,

2138:24, 2138:25, 2139:6, 2139:8,

2142:22, 2142:25, 2143:2, 2143:6,

2143:8, 2143:12, 2143:14, 2143:17,

2143:19, 2143:20, 2144:3, 2144:6,

2144:13, 2144:15, 2145:9, 2145:12,

2145:15, 2146:19, 2146:21, 2147:11,

2147:12, 2147:15, 2147:18, 2147:20,

2148:2, 2148:4, 2148:8, 2148:23,

2149:1, 2150:4, 2150:5, 2150:7,

2150:9, 2150:11, 2150:17, 2151:3,

2151:8, 2152:9, 2152:11, 2152:15,

2152:18, 2152:21, 2152:25, 2153:14,

2153:16, 2153:18, 2153:21, 2153:23,

2154:1, 2154:9, 2154:11, 2154:21,

2154:23, 2155:6, 2155:14, 2155:16,

2155:17, 2155:25, 2156:2, 2156:15,

2156:17, 2157:2, 2157:5, 2157:10,

2157:11, 2158:20, 2158:22, 2159:3,

2159:4, 2159:8, 2159:9, 2159:12,

2159:14, 2159:24, 2159:25, 2161:9,

2161:15, 2167:2, 2169:7, 2169:9,

2173:24, 2174:1, 2175:23, 2176:2,

2180:14, 2180:17, 2180:22, 2180:23,

2181:2, 2181:5, 2184:8, 2184:11,

2184:13, 2184:15, 2184:17, 2197:10,

2200:9, 2200:12, 2203:4, 2203:13,

2207:4, 2207:13, 2207:17, 2207:21,

2208:6, 2208:9, 2208:13, 2208:15,

2227:1, 2227:4, 2227:15, 2227:17,

2227:20, 2227:22, 2227:25, 2228:3,

2228:17, 2228:20, 2229:19, 2229:22,

2230:1, 2230:4, 2231:9, 2231:11,

2231:18, 2232:4, 2232:6, 2233:15,

2233:17, 2239:25, 2240:3, 2240:6,

2240:9, 2240:13, 2240:19, 2240:21,

2241:4, 2243:8, 2243:10, 2244:1,

2244:2, 2244:4, 2245:22, 2245:23,

2246:1, 2247:11, 2247:16, 2251:5,

2251:7, 2251:21, 2252:2, 2252:15,

2252:20, 2252:22, 2253:1, 2253:25,

2254:2, 2254:3, 2254:4, 2254:6,

2254:22, 2254:23, 2255:1, 2255:4,

2256:21, 2256:22

must [9] - 1982:3, 1997:15, 2091:18,

2091:20, 2202:13, 2204:15, 2211:3,

2211:4, 2228:1

mutual [1] - 1976:5

N

name [13] - 1983:20, 1995:23,

2009:10, 2048:3, 2099:12, 2099:13,

2101:5, 2104:14, 2117:4, 2117:12,

2122:25, 2169:12, 2220:25

named [12] - 1999:21, 2000:24,

2008:19, 2008:23, 2008:25, 2009:18,

2009:22, 2042:24, 2043:3, 2101:14,

2198:15, 2216:3

names [10] - 1990:15, 2010:5, 2014:4,

2047:23, 2048:6, 2048:8, 2056:22,

2094:23, 2094:24, 2108:7

narrative [4] - 2116:3, 2124:16,

2124:17

narrow [1] - 2037:20

Natalee [1] - 2164:5

national [1] - 2100:15

nature [5] - 2016:24, 2053:6, 2113:11,

2220:10, 2221:12

nau [1] - 2191:19

nau-uh [1] - 2191:19

near [3] - 2186:19, 2218:18, 2218:19

necessarily [2] - 2003:18, 2173:3

necessary [10] - 1997:16, 1997:17,

2003:11, 2031:23, 2054:7, 2054:8,

2054:9, 2054:14, 2160:7, 2160:8

need [21] - 1987:13, 1987:24, 1996:22,

1999:24, 2001:14, 2001:15, 2008:13,

2008:16, 2012:12, 2027:20, 2057:21,

2071:1, 2087:3, 2091:8, 2122:14,

2152:21, 2173:12, 2206:5, 2207:10,

2224:16, 2252:17

needed [11] - 1993:16, 1996:10,

2001:21, 2047:1, 2047:4, 2047:5,

2053:1, 2129:25, 2140:16, 2223:25,

2226:19

needs [3] - 2011:7, 2224:14, 2233:3

negotiate [2] - 2206:24

negotiating [3] - 2205:21, 2217:14,

2218:21

nervous [1] - 2179:4

net [6] - 2195:21, 2195:22, 2195:23,

2196:10, 2225:20

never [39] - 1983:20, 1984:21,

1990:21, 1991:19, 2001:21, 2008:3,

2013:24, 2014:23, 2048:24, 2082:23,

2087:5, 2088:2, 2114:9, 2155:21,

2173:22, 2175:8, 2176:8, 2180:5,

2188:14, 2191:10, 2191:13, 2191:16,

2195:13, 2210:6, 2211:3, 2218:5,

2218:8, 2221:23, 2222:24, 2233:8,

2233:9, 2233:11, 2235:25, 2239:10,

2249:21, 2250:9, 2256:16

new [10] - 2059:6, 2096:17, 2104:6,

2123:8, 2140:23, 2161:23, 2162:7,

2162:8, 2192:6, 2192:13

New [4] - 1971:17, 2020:6, 2220:19,

2220:20

newly [1] - 2103:18

news [2] - 1999:4, 2179:23

newspaper [2] - 2102:23, 2216:25

newspapers [1] - 2216:18

next [29] - 1982:6, 1985:2, 1997:11,

2030:7, 2031:8, 2032:8, 2043:1,

2047:8, 2049:22, 2058:6, 2059:16,

2059:17, 2059:18, 2059:19, 2061:13,

2061:18, 2077:15, 2098:23, 2145:14,

2152:15, 2152:18, 2207:18, 2208:6,

2208:13, 2209:3, 2214:23, 2215:2

nice [2] - 2023:18, 2023:21

nicer [1] - 2096:16

night [3] - 1988:14, 2178:25, 2179:10

nights [1] - 2018:21

nobody [1] - 2251:3

nobody's [1] - 2177:22

none [2] - 2176:5, 2239:8

nonfinancial [1] - 2007:2

nongovernment [1] - 2068:12

nonprofit [1] - 2168:9

nonresponsive [1] - 2116:1

normal [1] - 2206:8

North [1] - 2004:14

notation [1] - 2228:14

Note [1] - 2151:16

note [21] - 1994:11, 2016:1, 2021:3,

2035:17, 2035:23, 2035:25, 2037:9,

2038:25, 2053:12, 2063:17, 2063:18,

2064:3, 2088:17, 2148:25, 2150:3,

2151:17, 2153:7, 2154:12, 2155:19,

2156:4, 2156:19

noted [2] - 2035:4

notes [19] - 2034:14, 2034:17, 2112:1,

2183:16, 2209:13, 2228:2, 2245:12,

2247:21, 2248:1, 2248:2, 2248:9,

2248:10, 2248:17, 2248:22, 2253:2,

2253:4, 2253:7, 2255:14, 2255:15

nothing [15] - 1977:15, 1977:21,

1979:24, 2038:20, 2075:24, 2217:19,

2223:17, 2224:22, 2231:3, 2232:1,

2232:3, 2232:12, 2247:4, 2247:6,

2256:22

notice [9] - 2035:19, 2066:25, 2098:9,

2098:11, 2150:25, 2166:22, 2166:23,

2167:4, 2167:20

noticed [1] - 2141:23

notified [1] - 2068:3

notifying [1] - 2130:2

noting [1] - 2254:19

November [16] - 1993:2, 1993:4,

2002:22, 2005:22, 2011:1, 2036:6,

2040:7, 2046:5, 2057:12, 2062:13,

2067:2, 2067:20, 2069:12, 2086:21,

2087:22, 2098:10

null [1] - 2003:2

Number [3] - 2023:7, 2046:10, 2207:5

number [40] - 1983:5, 1987:6,


2279

2018:12, 2037:15, 2037:16, 2037:19,

2038:1, 2038:3, 2038:4, 2039:4,

2042:4, 2044:15, 2046:9, 2057:8,

2067:4, 2071:12, 2071:20, 2071:21,

2071:24, 2071:25, 2094:21, 2118:13,

2132:20, 2134:21, 2139:6, 2188:6,

2198:9, 2213:13, 2227:19, 2234:13,

2236:20, 2237:8, 2237:21, 2240:2,

2240:6, 2240:9

numbering [1] - 2037:21

numbers [3] - 2053:9, 2063:24,

2252:25

numerous [3] - 2112:14, 2192:21,

2209:16

NW [1] - 1971:17

O

O'Brien [11] - 2008:25, 2009:10,

2009:15, 2014:9, 2071:15, 2071:17,

2094:8, 2095:19, 2095:23, 2096:1,

2097:12

o'clock [2] - 2035:14, 2207:10

O.Y [2] - 1990:9, 2002:15

Oaks [1] - 2134:19

oath [1] - 1993:6

object [34] - 1976:18, 2008:2, 2008:3,

2008:9, 2008:13, 2008:16, 2036:1,

2036:2, 2070:5, 2070:21, 2075:4,

2088:12, 2105:17, 2105:25, 2110:22,

2112:5, 2112:8, 2112:23, 2113:1,

2114:13, 2116:1, 2116:14, 2117:22,

2124:4, 2128:10, 2145:12, 2152:10,

2180:14, 2181:2, 2200:9, 2203:4,

2229:19, 2240:19, 2245:22

objected [2] - 2007:25, 2079:9

objecting [1] - 2056:7

objection [45] - 1977:12, 1989:6,

2022:16, 2022:22, 2035:23, 2036:1,

2037:5, 2038:16, 2044:25, 2051:25,

2063:7, 2065:22, 2070:11, 2070:25,

2072:8, 2075:12, 2076:1, 2076:17,

2076:25, 2078:2, 2078:5, 2078:6,

2079:12, 2080:19, 2081:8, 2083:14,

2083:22, 2083:25, 2084:1, 2090:13,

2090:14, 2106:5, 2110:2, 2110:15,

2111:8, 2142:25, 2143:1, 2147:15,

2150:7, 2151:1, 2152:23, 2207:7,

2207:13, 2251:21

Objection [1] - 2161:9

objections [4] - 1980:12, 2063:4,

2081:10, 2153:18

observed [2] - 2168:24, 2170:7

obtain [3] - 1996:14, 2031:22, 2047:4

occasion [4] - 2001:24, 2003:8,

2033:3, 2043:22

occasions [1] - 2039:4

occurred [2] - 2097:5, 2135:13

October [6] - 1992:24, 1993:7,

1994:16, 1994:21, 1996:8, 1998:8

OF [2] - 1971:1, 1971:4

offense [2] - 2047:13, 2047:14

offer [7] - 2090:1, 2106:21, 2114:9,

2142:22, 2150:14, 2207:5, 2240:3

offered [7] - 2110:8, 2111:10, 2114:4,

2117:10, 2118:10, 2136:11, 2150:9

offering [3] - 2026:10, 2065:24,

2150:17

offers [1] - 2150:4

offhand [1] - 2067:4

office [29] - 1984:21, 1993:11,

1994:16, 1998:11, 1998:16, 2000:21,

2063:21, 2093:1, 2093:11, 2093:17,

2093:18, 2093:25, 2094:14, 2095:16,

2107:20, 2107:24, 2108:24, 2118:6,

2118:23, 2119:2, 2119:7, 2119:11,

2131:10, 2161:2, 2161:3, 2161:17,

2231:1, 2231:4, 2231:21

officer [10] - 2130:13, 2169:20,

2198:23, 2198:25, 2199:15, 2199:16,

2199:20, 2199:22, 2199:25, 2200:2

officers [4] - 2092:16, 2092:17,

2107:21, 2123:17

offices [12] - 2118:13, 2118:14,

2118:20, 2119:4, 2136:3, 2141:19,

2141:21, 2181:12, 2230:21, 2231:2,

2232:2, 2236:23

official [2] - 1993:20, 2092:14

Offshore [1] - 2007:9

offshore [11] - 2004:3, 2005:7,

2005:11, 2005:16, 2006:8, 2006:11,

2006:16, 2014:20, 2040:25, 2041:25,

2054:24

OFS [1] - 2007:12

OFSPC [1] - 2008:6

often [1] - 2136:7

old [5] - 2099:17, 2100:10, 2167:25,

2168:1, 2198:18

on-site [1] - 2033:11

once [15] - 1985:12, 2033:17, 2043:23,

2052:18, 2085:17, 2091:20, 2092:19,

2111:4, 2124:1, 2124:8, 2127:11,

2131:11, 2141:11, 2176:8, 2251:12

One [1] - 2121:17

one [122] - 1976:14, 1989:13, 1997:14,

1997:18, 1999:17, 2000:3, 2001:17,

2016:5, 2018:20, 2021:6, 2021:8,

2021:10, 2021:12, 2021:14, 2021:16,

2021:18, 2021:20, 2021:22, 2021:24,

2022:1, 2022:3, 2022:5, 2022:8,

2023:21, 2024:3, 2024:12, 2024:14,

2025:9, 2027:8, 2030:4, 2030:6,

2035:14, 2035:15, 2035:21, 2036:3,

2036:16, 2036:17, 2037:7, 2038:7,

2038:8, 2039:9, 2039:12, 2039:20,

2040:17, 2044:14, 2044:16, 2044:17,

2047:9, 2047:10, 2052:2, 2053:11,

2053:12, 2055:2, 2056:12, 2058:4,

2060:15, 2060:16, 2066:25, 2071:12,

2076:2, 2076:19, 2076:21, 2079:15,

2080:10, 2080:23, 2087:19, 2090:24,

2090:25, 2091:4, 2096:18, 2097:3,

2100:18, 2106:23, 2111:9, 2119:3,

2125:24, 2130:16, 2131:1, 2133:3,

2134:15, 2134:19, 2134:21, 2154:18,

2154:20, 2158:23, 2159:5, 2163:25,

2171:15, 2171:17, 2172:20, 2173:1,

2183:4, 2183:5, 2185:11, 2186:22,

2187:14, 2187:15, 2191:4, 2192:22,

2193:1, 2196:5, 2197:24, 2199:11,

2199:21, 2207:2, 2212:10, 2213:13,

2223:11, 2224:12, 2225:20, 2227:15,

2228:8, 2228:23, 2232:4, 2241:10,

2242:14, 2243:8, 2244:14, 2247:14,

2254:14, 2256:20

one-year [1] - 2244:14

ones [7] - 1999:25, 2014:7, 2021:3,

2021:5, 2119:19, 2197:17, 2217:10

opened [1] - 2162:16

operate [2] - 2103:20, 2250:1

operated [2] - 1998:21, 2233:1

Operating [1] - 2012:7

operating [2] - 1995:22, 2015:5

Operation [18] - 2010:6, 2013:19,

2013:22, 2013:24, 2014:3, 2014:8,

2014:14, 2014:18, 2015:4, 2015:11,

2015:16, 2069:21, 2069:22, 2069:24,

2070:2, 2070:8, 2070:22, 2072:3

operation [8] - 2014:22, 2015:12,

2028:12, 2032:22, 2190:1, 2208:21,

2208:23, 2208:25

operational [1] - 2005:20

operations [1] - 1980:16

operators [1] - 2011:13

Opinion [1] - 2230:3

opinion [41] - 1988:19, 1992:5,

1992:23, 1993:23, 1994:1, 1994:6,

1996:2, 1999:5, 1999:7, 2000:22,

2000:23, 2001:15, 2028:4, 2028:9,

2030:5, 2031:6, 2031:7, 2031:10,

2032:18, 2032:19, 2066:19, 2074:16,

2085:17, 2086:5, 2087:8, 2095:3,

2095:9, 2095:11, 2112:8, 2112:25,

2113:19, 2125:6, 2125:8, 2160:8,

2165:23, 2172:22, 2238:21, 2241:13,

2243:19, 2249:13, 2254:21

opinions [2] - 1994:8, 2032:5

opponent [2] - 2150:12, 2150:19

opportunities [2] - 2162:13, 2162:14

opportunity [9] - 2106:11, 2177:12,

2187:6, 2187:15, 2192:23, 2205:14,

2209:12, 2216:14, 2255:18

opposed [3] - 2209:2, 2219:12, 2246:7

order [9] - 1976:7, 2031:24, 2035:18,

2052:4, 2058:24, 2063:20, 2086:7,

2117:7, 2151:20

ordered [2] - 2002:11, 2095:8

orders [1] - 2209:11

ordinance [1] - 2086:8

organization [4] - 1979:19, 2103:19,

2168:9, 2232:24

organizations [2] - 2027:2

original [2] - 1998:24, 2000:20

Osborne [5] - 1998:17, 2000:10,

2000:15, 2000:18, 2000:20

otherwise [4] - 1980:21, 2004:21,

2116:4, 2235:2

Ou [1] - 1983:12Johnny C. Sanchez, RMR, CRR - [email protected]

2280

ought [1] - 2034:7

outcome [1] - 2047:15

outer [1] - 2079:17

Outer [1] - 2079:18

outgrown [1] - 2129:24

outline [1] - 1976:10

outlined [1] - 2011:6

outlines [2] - 1978:13, 2038:11

outlining [1] - 2012:13

outside [8] - 1984:5, 1986:19, 2018:7,

2060:24, 2064:18, 2160:4, 2163:2,

2251:22

outstanding [2] - 2047:9, 2053:17

overall [7] - 1981:14, 2032:6, 2041:22,

2085:15, 2101:18, 2139:12, 2199:1

overhead [3] - 2067:7, 2080:6,

2085:21

overnight [1] - 2219:8

overrule [2] - 1977:12, 2152:23

overruled [21] - 2037:6, 2075:6,

2081:11, 2083:18, 2083:21, 2110:24,

2113:2, 2113:4, 2113:20, 2114:16,

2114:19, 2117:24, 2124:5, 2125:13,

2128:12, 2161:11, 2161:14, 2181:4,

2203:5, 2240:24

overseas [1] - 2097:5

overseeing [2] - 2115:9, 2199:16

oversees [1] - 2221:24

overview [1] - 2139:9

owe [1] - 2224:19

owes [1] - 2154:25

own [8] - 1979:7, 2164:21, 2164:22,

2219:13, 2221:21, 2223:9, 2224:12,

2246:11

owned [16] - 2024:3, 2081:22,

2097:17, 2102:19, 2117:21, 2118:3,

2136:16, 2137:24, 2181:15, 2181:18,

2181:21, 2188:3, 2188:4, 2192:9,

2204:5, 2232:16

owner [3] - 2046:15, 2199:5, 2246:10

owners [2] - 2066:11, 2120:18

ownership [3] - 2025:21, 2026:5,

2137:14

owns [4] - 2024:2, 2223:9, 2224:20,

2246:3

P

p.m [3] - 2079:21, 2155:11, 2257:7

page [32] - 1980:10, 1983:7, 1983:15,

1987:16, 1990:2, 1991:5, 1992:21,

1997:12, 2002:3, 2002:7, 2028:4,

2028:17, 2029:6, 2029:7, 2030:8,

2052:25, 2067:10, 2073:12, 2073:13,

2077:16, 2087:19, 2089:15, 2149:23,

2159:3, 2181:6, 2207:18, 2207:19,

2208:7, 2229:13

PAGE [1] - 1973:3

Page [34] - 1980:18, 1985:18, 1990:19,

2000:4, 2000:6, 2001:5, 2027:19,

2029:20, 2030:16, 2031:3, 2047:18,

2073:10, 2080:3, 2081:14, 2081:17,

2111:17, 2114:4, 2118:10, 2118:17,

2136:22, 2137:4, 2138:7, 2138:24,

2139:7, 2148:23, 2155:25, 2157:4,

2157:10, 2159:8, 2182:21, 2184:21,

2230:2, 2247:12, 2252:16

Pages [1] - 2030:25

pages [2] - 2096:6, 2096:9

paid [17] - 1985:13, 1985:14, 2077:21,

2077:25, 2080:18, 2081:7, 2083:12,

2084:12, 2095:23, 2097:13, 2101:19,

2143:22, 2168:4, 2188:16, 2199:2,

2199:3, 2212:15

panel [1] - 1991:11

paneling [1] - 2141:9

paper [1] - 2112:1

paperwork [3] - 2029:17, 2058:20,

2187:22

paragraph [17] - 1982:6, 2000:7,

2032:8, 2047:1, 2047:8, 2052:24,

2063:9, 2063:16, 2067:14, 2067:24,

2096:9, 2111:20, 2151:5, 2182:21,

2184:21, 2209:3, 2230:3

paragraphs [4] - 2030:18, 2059:18,

2073:11, 2159:13

parameters [1] - 1981:14

pardon [4] - 2153:15, 2184:10,

2184:16, 2197:7

park [1] - 2190:25

Park [1] - 2135:3

parked [1] - 2225:19

Parras [17] - 1972:2, 1983:20,

2035:13, 2036:21, 2037:13, 2062:19,

2065:7, 2065:17, 2067:13, 2068:15,

2072:25, 2074:3, 2074:15, 2074:19,

2078:17, 2080:13, 2098:4

PARRAS [155] - 1976:18, 1976:21,

1977:3, 1983:4, 1983:7, 1983:9,

1983:14, 1983:17, 1984:1, 1984:3,

1985:17, 1985:23, 1986:1, 1986:5,

1987:10, 1987:15, 1987:17, 1987:24,

1988:3, 1989:4, 1989:11, 1989:14,

1989:19, 1989:22, 1990:1, 1990:7,

1991:17, 1992:4, 1992:22, 1997:3,

1997:23, 1998:1, 1999:8, 1999:11,

1999:13, 1999:17, 2000:4, 2000:8,

2001:5, 2001:6, 2017:9, 2017:17,

2017:20, 2017:22, 2020:16, 2022:10,

2022:12, 2022:18, 2023:1, 2027:18,

2027:22, 2027:24, 2028:3, 2028:6,

2028:16, 2028:19, 2029:5, 2029:8,

2029:20, 2029:23, 2030:2, 2030:3,

2030:6, 2030:10, 2030:16, 2030:20,

2031:8, 2031:9, 2031:19, 2031:20,

2032:3, 2032:4, 2032:8, 2032:9,

2037:2, 2037:7, 2037:14, 2037:16,

2037:20, 2037:23, 2038:8, 2040:2,

2040:3, 2044:12, 2044:16, 2044:20,

2044:23, 2045:4, 2045:7, 2045:13,

2045:17, 2045:21, 2046:12, 2049:24,

2050:12, 2050:13, 2051:14, 2052:9,

2054:13, 2056:3, 2056:9, 2056:10,

2056:15, 2056:16, 2057:20, 2057:23,

2058:6, 2058:7, 2059:16, 2059:25,

2061:11, 2061:16, 2065:22, 2070:5,

2070:14, 2070:21, 2072:8, 2075:4,

2075:12, 2075:14, 2076:1, 2076:17,

2078:2, 2078:23, 2079:9, 2080:19,

2081:8, 2083:14, 2083:22, 2084:15,

2084:18, 2085:8, 2085:21, 2085:23,

2086:3, 2086:4, 2088:15, 2089:14,

2089:17, 2089:18, 2090:1, 2090:4,

2090:7, 2090:20, 2090:23, 2091:2,

2092:13, 2096:7, 2096:9, 2096:12,

2097:8, 2097:11, 2097:21, 2097:23,

2098:14

Parras's [1] - 2079:7

PARRAS............. [1] - 1973:10

PARRAS............... [1] - 1973:6

part [37] - 2014:5, 2014:7, 2025:3,

2035:21, 2041:1, 2068:22, 2068:24,

2069:5, 2069:24, 2070:2, 2084:21,

2085:15, 2087:9, 2091:14, 2103:18,

2107:16, 2107:24, 2107:25, 2108:16,

2144:22, 2147:21, 2164:25, 2165:10,

2175:5, 2178:1, 2186:4, 2187:7,

2188:16, 2210:2, 2210:6, 2213:10,

2213:23, 2215:15, 2246:11, 2248:8,

2248:21

part... [1] - 2092:9

partial [1] - 2246:10

particular [4] - 2142:15, 2157:24,

2187:8, 2241:18

particularly [2] - 1978:22, 2232:24

parties [1] - 1990:16

partly [1] - 2108:23

partner [6] - 2026:12, 2026:22,

2026:23, 2161:7, 2161:20, 2188:4

partners [3] - 2184:3, 2188:6, 2188:7

Partnership [1] - 2188:2

partnership [16] - 2120:23, 2120:25,

2121:8, 2121:9, 2121:11, 2121:14,

2121:16, 2121:20, 2121:22, 2121:24,

2122:2, 2122:4, 2122:12, 2122:18,

2123:23, 2125:18

partnerships [13] - 2119:20, 2119:25,

2120:4, 2120:6, 2122:22, 2123:16,

2124:14, 2125:1, 2125:2, 2125:16,

2126:23, 2133:24, 2233:25

parts [3] - 2108:1, 2144:12, 2164:11

party [14] - 2150:12, 2150:19, 2158:7,

2158:15, 2203:8, 2238:23, 2239:11,

2239:13, 2239:23, 2239:24, 2240:14,

2240:22, 2241:19, 2256:4

pass [10] - 1983:2, 2065:13, 2084:14,

2098:12, 2169:7, 2233:15, 2244:1,

2251:5, 2254:22, 2256:21

passed [3] - 2004:9, 2069:25, 2070:18

passport [2] - 2053:8, 2053:9

past [3] - 2105:15, 2105:22, 2214:7

Pat [6] - 2009:15, 2014:9, 2094:8,

2095:19, 2095:23, 2096:1

Pat' [1] - 2008:25

Patrick [3] - 2009:10, 2009:11,

2071:15

Paul [2] - 2039:3, 2168:8

pavilion [2] - 2236:3, 2236:6Johnny C. Sanchez, RMR, CRR - [email protected]

2281

Pavilion [5] - 2211:16, 2212:8,

2236:10, 2236:11, 2236:12

pay [10] - 2063:19, 2151:20, 2168:13,

2215:25, 2216:1, 2219:17, 2225:7,

2226:5, 2244:11, 2244:12

paying [6] - 2075:10, 2077:3, 2144:7,

2235:1, 2244:16, 2244:17

payment [1] - 2096:1

payments [1] - 2075:18

payroll [2] - 2101:19, 2199:3

PDF [6] - 2027:19, 2029:6, 2029:7,

2029:20, 2030:16, 2159:8

Peat [4] - 2100:16, 2100:18, 2101:4,

2101:6

pen [1] - 2001:10

pending [1] - 2209:9

people [38] - 2032:11, 2040:23,

2040:24, 2061:7, 2068:12, 2088:11,

2106:22, 2109:13, 2116:11, 2164:11,

2172:19, 2173:6, 2173:16, 2173:19,

2190:8, 2194:25, 2195:23, 2196:10,

2218:12, 2219:12, 2219:15, 2219:16,

2220:2, 2220:8, 2220:10, 2221:3,

2233:1, 2233:2, 2233:5, 2236:20,

2246:18, 2248:24, 2249:21, 2249:25,

2250:4, 2250:7, 2254:11

percent [14] - 2046:16, 2108:22,

2111:25, 2112:1, 2113:16, 2168:20,

2181:18, 2184:5, 2184:22, 2185:17,

2192:11, 2232:16

percentage [2] - 2108:19, 2244:11

perception [2] - 2163:15, 2163:23

perfect [1] - 2151:5

perfectly [2] - 2224:5, 2224:6

perform [1] - 2176:13

performed [1] - 2031:22

Perhaps [1] - 2091:6

perhaps [3] - 2050:1, 2078:6, 2138:16

period [4] - 2070:17, 2084:24, 2085:7,

2129:1

permit [2] - 2206:19, 2206:23

person [9] - 2011:23, 2025:23, 2094:5,

2203:17, 2204:21, 2223:9, 2244:20,

2246:3, 2247:3

personal [16] - 2070:5, 2074:25,

2075:11, 2081:9, 2093:13, 2093:15,

2122:3, 2122:16, 2127:1, 2127:5,

2145:20, 2146:17, 2161:9, 2167:15,

2243:25

personality [1] - 2172:24

personally [3] - 2112:7, 2126:22,

2173:8

persons [3] - 1995:24, 2008:10,

2094:21

perspective [1] - 2242:2

Peter [1] - 2043:14

philosophy [2] - 1981:13, 2215:5

photo [4] - 2080:4, 2080:13, 2136:13,

2136:25

photograph [3] - 2053:9, 2231:1,

2231:4

photographs [1] - 2231:3

photos [1] - 2020:22

phrase [2] - 2068:6, 2068:8

physically [2] - 2093:11, 2094:13

pick [3] - 2083:17, 2083:19, 2172:20

picked [2] - 2094:13, 2172:20

picking [1] - 2172:25

picture [9] - 2077:18, 2119:5, 2119:6,

2144:20, 2195:4, 2196:25, 2197:2,

2213:10, 2215:15

pictured [1] - 2236:15

pictures [5] - 2023:4, 2023:5, 2093:24,

2119:4, 2214:23

piece [2] - 2212:14, 2256:3

pieces [4] - 1975:24, 1979:3, 1987:19,

2034:1

ping [1] - 2078:25

ping-pong [1] - 2078:25

pitch [4] - 2082:11, 2082:12, 2082:13,

2083:8

pitcher [1] - 2082:21

place [23] - 1993:10, 2012:5, 2018:7,

2035:22, 2040:18, 2042:6, 2053:10,

2062:25, 2088:23, 2138:11, 2178:6,

2178:7, 2178:22, 2190:25, 2193:2,

2196:11, 2213:10, 2213:11, 2213:12,

2218:3, 2218:11, 2219:12

placed [2] - 1979:11, 2102:24

places [10] - 2005:15, 2011:11,

2018:10, 2020:3, 2020:25, 2085:20,

2087:9, 2087:19, 2195:24, 2213:19

plain [1] - 2039:20

plaintiff [1] - 2002:12

plaintiffs [1] - 2002:14

plan [11] - 1996:9, 2005:20, 2006:6,

2010:25, 2190:17, 2192:24, 2194:2,

2195:6, 2195:10, 2196:17, 2198:8

plane [1] - 2144:23

planes [5] - 2137:10, 2137:21,

2137:23, 2209:2

planned [2] - 2031:22, 2219:10

Planning [1] - 2007:9

planning [5] - 2010:11, 2010:12,

2130:2, 2138:20, 2220:5

plans [7] - 2112:9, 2140:1, 2140:2,

2219:21, 2219:25, 2220:1, 2221:2

plant [3] - 2210:2, 2210:5, 2210:9

platform [1] - 2041:21

play [1] - 2214:1

played [6] - 2143:18, 2144:5, 2144:14,

2213:24, 2213:25, 2214:9

players [1] - 2019:4

pleasures [1] - 2096:18

plenty [1] - 2224:13

plumbing [1] - 2164:14

plus [2] - 2212:10, 2244:12

PO [2] - 1971:14, 1972:7

Point [5] - 2138:11, 2138:14, 2196:25,

2212:8, 2218:7

point [19] - 2006:15, 2009:13, 2011:18,

2017:23, 2020:15, 2049:11, 2050:1,

2057:17, 2057:20, 2075:4, 2077:13,

2079:8, 2085:20, 2101:8, 2103:23,

2132:12, 2155:6, 2163:1

point-by-point [1] - 2057:17

pointed [1] - 2001:10

points [4] - 2038:11, 2040:10,

2040:12, 2057:8

police [1] - 2094:25

policies [1] - 2031:18

pong [1] - 2078:25

pool [1] - 2136:20

poor [1] - 2168:10

popular [1] - 2213:19

portfolio [20] - 1977:19, 1978:9,

1978:13, 1980:17, 1981:2, 1981:6,

1981:13, 1981:19, 1982:7, 2059:3,

2062:23, 2111:21, 2111:24, 2113:12,

2115:2, 2115:9, 2126:7, 2126:19,

2129:4, 2149:4

portfolios [1] - 1979:17

portion [13] - 1977:1, 2045:13, 2058:9,

2058:11, 2076:23, 2080:24, 2113:9,

2148:24, 2151:4, 2154:21, 2156:1,

2157:14, 2208:14

position [26] - 2047:16, 2050:20,

2051:24, 2053:15, 2060:20, 2060:22,

2060:24, 2069:8, 2069:16, 2072:15,

2102:21, 2103:4, 2103:16, 2104:16,

2106:14, 2130:11, 2130:20, 2130:23,

2131:1, 2168:11, 2173:10, 2173:17,

2173:20, 2175:14, 2175:18, 2183:2

positions [5] - 1982:7, 1982:10,

2072:17, 2072:18, 2073:18

positive [1] - 2199:25

possession [3] - 2033:22, 2033:24,

2034:19

possibilities [1] - 2219:14

possibility [1] - 2219:16

possible [11] - 1986:24, 2008:22,

2011:3, 2038:14, 2048:10, 2048:15,

2053:17, 2088:25, 2089:1, 2171:8,

2216:6

possibly [3] - 2026:22, 2102:8,

2146:18

potential [2] - 2068:4, 2166:6

power [5] - 2048:17, 2048:20,

2052:19, 2092:3, 2232:13

predecessor [1] - 2072:16

predecessors [1] - 2076:14

predominately [1] - 2236:16

prefaced [1] - 2089:6

preference [1] - 1997:19

premier [1] - 2019:9

premises [1] - 2094:17

preparation [5] - 2031:4, 2031:16,

2033:20, 2034:12, 2199:4

prepare [4] - 2034:15, 2041:19,

2041:21, 2101:20

prepared [2] - 2028:13, 2032:23

prerequisite [1] - 1996:12

presence [1] - 1993:15

present [4] - 2000:10, 2064:21,

2094:15, 2142:15

presentation [1] - 2032:6

presented [3] - 2007:5, 2101:21,


2282

2199:5

presenting [1] - 1982:16

president [13] - 2062:16, 2094:3,

2101:16, 2101:21, 2123:9, 2132:14,

2139:4, 2149:15, 2153:4, 2155:23,

2158:10, 2167:22, 2174:17

president's [1] - 2133:19

presidents [1] - 2106:25

Preston [1] - 1972:3

pretty [6] - 1989:21, 2087:24, 2154:8,

2189:14, 2216:8, 2256:20

prevent [1] - 2082:17

prevents [2] - 1977:15, 1977:21

previously [5] - 1980:5, 1980:8,

1980:10, 2053:13, 2200:4

Price [3] - 2161:3, 2161:5, 2161:17

price [2] - 2126:13, 2212:18

primarily [5] - 2108:5, 2108:6,

2120:10, 2162:16, 2209:20

primary [2] - 2168:25, 2207:2

principal [3] - 2063:23, 2151:21,

2244:12

principle [2] - 2241:18, 2251:2

principles [2] - 2221:22, 2222:11

priority [2] - 2041:2, 2041:3

private [13] - 2010:18, 2011:14,

2068:12, 2074:22, 2137:23, 2138:5,

2144:20, 2160:10, 2195:25, 2196:6,

2196:11, 2209:1

prize [1] - 2216:21

problem [16] - 1977:2, 2068:16,

2068:19, 2069:1, 2082:17, 2160:17,

2164:15, 2191:13, 2191:16, 2207:9,

2226:21, 2235:18, 2235:19, 2249:2,

2250:19, 2251:1

problems [6] - 1994:13, 1995:13,

2059:10, 2186:10, 2215:19, 2225:24

procedures [1] - 2015:23

proceed [2] - 1975:5, 2155:14

Proceedings [2] - 1972:13, 1972:20

proceedings [1] - 2257:11

proceeds [1] - 2250:23

process [10] - 1979:8, 2060:1, 2060:8,

2178:1, 2183:6, 2183:8, 2202:2,

2206:4, 2206:12, 2206:25

processes [1] - 2015:24

processing [1] - 2053:18

produce [2] - 2164:21, 2250:7

produced [8] - 1972:13, 1972:21,

1978:17, 2035:18, 2037:3, 2055:22,

2091:22, 2221:12

product [3] - 2108:4, 2108:25, 2252:12

production [3] - 2038:9, 2039:14,

2039:15

products [7] - 1982:2, 2197:4, 2197:9,

2233:6, 2233:8, 2233:10, 2252:6

profession [1] - 2099:23

professional [4] - 2029:2, 2029:4,

2047:10, 2053:11

profit [5] - 2133:25, 2242:18, 2242:25,

2250:2, 2250:7

profitability [1] - 2234:25

profitable [6] - 2242:9, 2242:12,

2242:15, 2249:14, 2250:6, 2250:13

profits [1] - 2250:17

program [1] - 2079:17

progress [1] - 2141:12

progressed [1] - 2005:1

prohibition [2] - 1976:16, 1979:20

prohibits [1] - 1979:24

project [12] - 2106:8, 2120:22, 2121:2,

2135:2, 2135:3, 2186:15, 2186:17,

2187:9, 2200:16, 2209:7, 2209:10,

2210:6

projections [2] - 2249:16, 2249:17

projector [1] - 2085:22

projects [29] - 2129:5, 2135:6, 2135:7,

2135:13, 2135:19, 2135:23, 2136:1,

2142:11, 2146:13, 2152:7, 2167:12,

2171:13, 2171:16, 2185:22, 2186:3,

2189:3, 2189:5, 2191:25, 2192:1,

2197:12, 2197:15, 2210:10, 2211:16,

2211:19, 2211:21, 2211:22, 2211:24,

2243:14

Promindon [1] - 2108:10

promise [1] - 2246:4

promises [2] - 2063:19, 2151:20

Promissory [1] - 2151:16

promissory [12] - 2063:17, 2063:18,

2064:3, 2088:17, 2150:3, 2151:16,

2151:17, 2153:7, 2154:12, 2155:19,

2156:3, 2156:19

promote [4] - 2212:12, 2212:16,

2217:13, 2233:13

promoting [1] - 2217:2

promotion [2] - 2076:15, 2077:3

promotional [12] - 2109:2, 2109:7,

2109:9, 2109:11, 2110:6, 2112:15,

2119:3, 2129:11, 2235:6, 2251:15,

2251:19, 2252:4

pronoun [1] - 2143:21

pronounced [1] - 2201:16

proper [2] - 2008:1, 2164:19

properly [1] - 2120:20

properties [11] - 2120:18, 2122:21,

2134:7, 2139:15, 2183:22, 2191:8,

2191:10, 2191:13, 2205:15, 2206:3,

2210:7

property [11] - 2120:8, 2125:19,

2126:13, 2188:1, 2192:15, 2209:18,

2212:14, 2218:18, 2218:25, 2256:7,

2256:16

propose [1] - 1990:23

proposed [3] - 1988:9, 2086:7,

2092:16

prosecution [2] - 2079:1, 2177:15

prosecutor [5] - 1987:7, 2086:16,

2112:23, 2213:6, 2221:10

prosecutors [1] - 2078:25

proud [1] - 2055:8

prove [1] - 2112:9

provide [8] - 2031:24, 2091:19,

2091:20, 2132:13, 2132:19, 2177:19,

2185:5, 2185:17

provided [8] - 2002:11, 2034:3,

2034:5, 2041:21, 2051:15, 2062:22,

2207:5, 2212:24

provision [2] - 2049:9, 2049:12

proviso [1] - 2152:24

public [11] - 1975:25, 1976:1, 2100:2,

2100:6, 2100:15, 2103:5, 2125:23,

2163:15, 2163:22, 2196:6, 2253:18

publicized [1] - 2164:1

published [2] - 2039:2, 2063:5

Puerto [1] - 2009:18

pull [5] - 2030:7, 2062:6, 2093:18,

2102:8, 2128:13

purchase [10] - 2076:15, 2103:20,

2106:12, 2120:18, 2121:16, 2122:6,

2206:13, 2208:16, 2208:20, 2244:19

purchased [6] - 2122:21, 2123:1,

2192:16, 2192:18, 2210:21, 2210:22

purchasers [1] - 2166:6

purchases [2] - 2122:24, 2208:19

pure [1] - 2113:6

purely [1] - 2078:24

purported [1] - 2003:1

purportedly [1] - 2086:13

purpose [12] - 1994:24, 1998:7,

1998:18, 2058:19, 2058:24, 2059:7,

2076:24, 2170:14, 2213:8, 2220:19,

2236:13, 2251:15

purposes [3] - 2150:18, 2151:2,

2209:19

pursuant [2] - 1980:11, 2016:4

pursuit [1] - 2001:22

put [37] - 1981:21, 1982:17, 1982:22,

1983:12, 1987:13, 2012:5, 2021:3,

2038:5, 2040:18, 2044:23, 2045:15,

2049:13, 2062:24, 2078:18, 2085:12,

2085:13, 2094:8, 2108:19, 2109:2,

2141:20, 2148:3, 2148:4, 2150:25,

2165:13, 2187:21, 2188:10, 2189:22,

2191:10, 2200:1, 2200:5, 2211:2,

2212:14, 2216:20, 2216:21, 2223:24,

2251:19, 2252:3

putting [4] - 2017:18, 2042:10,

2237:17, 2239:2

Q

qualified [2] - 1977:3, 2125:7

quality [5] - 2140:18, 2140:20,

2140:22, 2140:23, 2236:23

quarterly [1] - 1978:10

quarters [1] - 2034:23

Queeley [3] - 2064:17, 2064:25,

2065:4

Quelley [6] - 2042:24, 2042:25,

2043:2, 2043:14, 2043:19

queries [1] - 2060:4

questioned [5] - 2128:8, 2128:9,

2128:11, 2128:19, 2128:20

questioning [3] - 2068:9, 2083:23,

2112:9

questions [32] - 1980:16, 1987:6,Johnny C. Sanchez, RMR, CRR - [email protected]

2283

1987:23, 1988:16, 2047:18, 2061:12,

2061:14, 2061:16, 2061:21, 2064:8,

2064:12, 2066:18, 2066:19, 2068:15,

2072:22, 2074:8, 2075:21, 2076:6,

2078:19, 2084:19, 2084:23, 2097:21,

2125:10, 2178:2, 2183:9, 2183:13,

2200:8, 2222:5, 2227:6, 2234:13,

2237:9, 2244:2

quick [3] - 2006:6, 2042:2, 2156:16

quicker [3] - 2012:12, 2116:3, 2245:15

quickly [4] - 2012:21, 2056:11,

2140:16, 2254:23

quit [5] - 2068:7, 2170:4, 2176:17,

2176:21, 2206:5

quite [5] - 1979:2, 2007:14, 2008:22,

2019:6, 2105:6

quote [3] - 1994:8, 2065:20, 2194:12

quote-unquote [1] - 2194:12

quoted [1] - 2183:4

R

raging [1] - 2004:12

raining [1] - 2082:18

raise [4] - 2079:18, 2099:2, 2140:6,

2186:8

raised [4] - 2016:15, 2069:10,

2119:20, 2160:11

range [8] - 1979:16, 1979:18, 2006:20,

2006:25, 2007:1, 2007:3, 2012:5,

2184:22

ranging [1] - 2018:17

rapidly [1] - 2140:17

rate [3] - 2063:25, 2151:23, 2212:21

rather [1] - 2084:1

Ravenscroft [2] - 1999:22

raw [2] - 2209:18, 2209:20

re [1] - 2204:3

reached [1] - 2055:3

reaction [3] - 1981:23, 2142:1, 2163:7

read [60] - 1976:25, 1977:1, 1980:20,

1981:4, 1982:8, 1990:5, 1992:6,

1992:16, 1994:10, 1994:23, 1999:1,

2000:6, 2002:7, 2003:20, 2028:7,

2030:4, 2030:17, 2041:8, 2042:2,

2050:4, 2053:22, 2058:17, 2059:3,

2063:16, 2065:21, 2067:12, 2067:14,

2073:16, 2074:16, 2076:22, 2076:23,

2080:22, 2080:24, 2084:4, 2084:8,

2086:19, 2092:7, 2096:4, 2109:2,

2109:9, 2109:17, 2109:20, 2109:23,

2110:6, 2110:12, 2110:17, 2111:2,

2112:15, 2112:16, 2157:7, 2208:18,

2209:4, 2216:17, 2216:25, 2228:22,

2229:5, 2230:7, 2247:20, 2252:5

reading [21] - 1981:11, 1981:18,

1982:14, 1993:22, 1993:24, 1994:18,

1994:21, 1994:22, 1997:11, 2030:4,

2041:10, 2044:5, 2045:25, 2046:3,

2046:19, 2050:15, 2112:19, 2113:10,

2180:14, 2217:2, 2241:25

ready [8] - 1975:5, 2035:6, 2038:18,

2097:7, 2155:10, 2253:20, 2254:12,

2257:5

real [80] - 2101:8, 2103:6, 2103:19,

2104:9, 2104:22, 2106:7, 2106:8,

2106:12, 2106:19, 2107:18, 2119:12,

2119:16, 2119:25, 2120:4, 2120:6,

2120:13, 2120:16, 2120:17, 2121:11,

2121:13, 2121:22, 2122:4, 2122:11,

2123:12, 2123:15, 2123:22, 2124:13,

2125:1, 2125:2, 2125:12, 2125:15,

2125:17, 2126:1, 2126:8, 2126:11,

2126:12, 2126:17, 2126:20, 2126:23,

2129:5, 2133:21, 2149:12, 2156:15,

2170:8, 2170:10, 2170:17, 2170:24,

2171:1, 2171:3, 2171:5, 2171:17,

2171:20, 2172:2, 2176:4, 2185:14,

2186:7, 2186:12, 2190:21, 2191:3,

2191:6, 2191:21, 2200:14, 2222:20,

2222:23, 2233:25, 2235:9, 2235:17,

2239:2, 2239:9, 2239:10, 2242:8,

2245:12, 2249:3, 2250:18, 2255:17,

2255:18, 2255:23, 2256:3, 2256:19

reality [1] - 2093:7

realization [1] - 2005:4

realized [1] - 2005:2

really [7] - 1987:4, 2013:24, 2019:20,

2042:2, 2096:16, 2170:20, 2231:20

reapply [1] - 2060:10

reason [20] - 1985:10, 2029:19,

2037:4, 2050:18, 2071:12, 2071:20,

2071:21, 2071:24, 2071:25, 2085:24,

2086:5, 2147:21, 2150:15, 2166:24,

2167:6, 2189:1, 2194:11, 2202:1,

2202:4, 2225:22

reasonable [1] - 2031:25

reasonably [1] - 2013:2

reasons [4] - 2071:12, 2086:6,

2123:17, 2251:25

rebuttal [1] - 2241:2

receipt [5] - 2046:4, 2051:12, 2052:15,

2092:1, 2092:8

receive [1] - 2092:4

received [5] - 1993:2, 2055:25,

2063:18, 2149:17, 2151:19

receiver [4] - 2025:20, 2026:3, 2026:4,

2026:5

recent [1] - 2065:3

recently [1] - 2039:2

Recessed [4] - 2035:8, 2079:21,

2155:11, 2257:7

recognize [34] - 2020:23, 2020:25,

2021:4, 2021:5, 2021:7, 2023:3,

2023:8, 2023:23, 2024:19, 2024:22,

2025:6, 2044:6, 2045:8, 2045:11,

2045:22, 2050:14, 2055:14, 2055:19,

2057:2, 2058:8, 2058:11, 2081:15,

2081:18, 2111:14, 2136:13, 2137:6,

2138:9, 2139:1, 2139:9, 2142:13,

2148:11, 2149:22, 2156:3, 2182:6

recognized [1] - 2023:5

recollection [4] - 2044:2, 2050:1,

2137:18, 2198:22

recommendation [2] - 2059:8,

2059:13

recommendations [1] - 2056:18

recommended [1] - 2042:15

record [6] - 2084:5, 2104:2, 2104:3,

2183:18, 2228:13, 2257:11

recorded [2] - 1972:13, 1972:20

records [6] - 2034:11, 2074:23,

2127:6, 2147:5, 2160:6, 2174:25

RECROSS [6] - 1973:10, 1973:23,

1974:2, 2084:17, 2244:3, 2255:3

recross [2] - 2098:4, 2241:3

recruit [1] - 2041:19

red [3] - 2000:2, 2085:17, 2186:8

redact [1] - 2045:13

Redhead [9] - 1988:19, 1990:13,

1994:5, 1994:7, 2002:4, 2002:9,

2002:10, 2003:19, 2086:5

redirect [3] - 2086:18, 2088:13,

2088:17

REDIRECT [8] - 1973:8, 1973:12,

1973:21, 1973:25, 2062:2, 2098:2,

2233:16, 2251:6

reduce [1] - 2088:11

reel [1] - 2205:7

reference [4] - 1991:11, 2047:10,

2053:11, 2181:7

referenced [5] - 1980:6, 1989:7,

2056:7, 2117:10, 2157:3

references [1] - 2053:5

referencing [2] - 1980:11, 2117:16

referred [3] - 2002:24, 2082:10,

2186:14

referring [4] - 2010:8, 2049:1,

2105:18, 2255:7

refers [2] - 2083:7, 2255:10

reflect [1] - 2104:3

refresh [5] - 2044:2, 2049:25, 2087:3,

2180:24, 2184:18

regard [11] - 2000:25, 2015:20,

2034:8, 2072:3, 2078:12, 2193:6,

2201:9, 2209:8, 2210:6, 2215:21,

2220:22

regarding [15] - 1992:8, 1996:20,

2004:10, 2010:19, 2011:21, 2016:4,

2036:6, 2036:7, 2052:11, 2069:25,

2070:18, 2096:1, 2196:17, 2220:15,

2225:17

regardless [2] - 2239:1, 2243:21

regime [6] - 2011:8, 2011:24, 2013:16,

2033:17, 2071:23, 2088:22

region [3] - 2024:11, 2042:2, 2064:19

regret [1] - 2168:16

regrets [1] - 2168:17

regulate [4] - 2003:8, 2005:2, 2007:2,

2052:15

regulated [4] - 1978:8, 1996:4, 2005:5,

2061:7

regulating [3] - 2011:25, 2054:23,

2065:11

regulation [3] - 1985:8, 2004:4,

2066:10

regulations [15] - 1982:10, 2003:24,


2284

2005:7, 2007:19, 2010:19, 2011:21,

2060:6, 2065:13, 2065:14, 2073:24,

2206:18, 2223:20, 2223:23, 2224:9,

2224:10

regulator [10] - 1991:1, 1996:18,

1997:4, 2000:24, 2001:13, 2040:5,

2047:20, 2051:12, 2052:10, 2072:7

regulators [3] - 1981:5, 1981:9,

1981:20

regulatory [29] - 1976:2, 2001:22,

2007:3, 2009:18, 2010:1, 2011:8,

2013:16, 2014:13, 2015:14, 2028:21,

2029:1, 2029:12, 2030:14, 2033:17,

2038:12, 2040:13, 2040:23, 2042:6,

2042:19, 2043:24, 2065:13, 2066:16,

2068:22, 2069:17, 2071:23, 2072:19,

2088:21, 2249:9

rehabilitate [1] - 2120:20

Rehnquist [1] - 2039:8

relate [1] - 1979:1

related [11] - 2138:5, 2158:7, 2158:14,

2238:23, 2239:11, 2239:13, 2239:23,

2239:24, 2240:14, 2240:22, 2241:19

related-party [8] - 2238:23, 2239:11,

2239:13, 2239:23, 2239:24, 2240:14,

2240:22, 2241:19

relates [1] - 1976:6

relation [1] - 2131:11

relationship [3] - 2131:7, 2131:13,

2131:14

relative [2] - 2139:24, 2169:3

released [6] - 1975:17, 1975:19,

1975:20, 1975:23, 1975:24, 2098:18

releasing [1] - 1979:23

relevance [2] - 2128:10, 2147:15

relevant [6] - 2031:13, 2066:12,

2148:5, 2148:7, 2251:22, 2253:18

relocate [1] - 2164:13

relying [2] - 2164:22, 2252:8

remember [60] - 1979:1, 1988:5,

1988:11, 1989:21, 2005:19, 2009:23,

2012:16, 2013:4, 2013:8, 2013:18,

2014:7, 2014:9, 2014:10, 2026:13,

2040:7, 2041:4, 2041:13, 2043:8,

2044:10, 2049:3, 2075:22, 2076:11,

2079:17, 2086:18, 2086:24, 2088:16,

2089:8, 2092:1, 2092:25, 2102:24,

2108:7, 2115:12, 2117:6, 2176:24,

2177:6, 2177:9, 2178:5, 2180:8,

2180:18, 2180:21, 2181:9, 2182:8,

2182:12, 2182:21, 2183:25, 2184:1,

2184:6, 2184:7, 2186:1, 2188:25,

2196:4, 2219:2, 2223:2, 2223:4,

2233:18, 2234:2, 2235:14, 2242:10

remind [2] - 2064:16, 2097:12

reminding [1] - 2035:1

removal [3] - 2094:11, 2094:16,

2095:10

removed [4] - 2093:2, 2093:7,

2093:11, 2095:5

removement [1] - 2094:10

removing [2] - 2093:21, 2093:25

render [1] - 2072:11

rental [2] - 2120:8, 2171:18

repair [1] - 2164:11

repealed [3] - 2071:7, 2071:10,

2071:12

repeat [3] - 1992:21, 2110:25, 2124:6

repeatedly [1] - 2240:22

rephrase [4] - 2072:9, 2083:19,

2116:6, 2123:20

replaced [3] - 2064:23, 2064:25,

2199:23

replied [1] - 2012:11

report [60] - 2007:5, 2008:4, 2011:1,

2011:4, 2011:6, 2011:9, 2013:5,

2027:12, 2028:18, 2028:20, 2029:16,

2030:9, 2030:11, 2031:7, 2040:8,

2040:9, 2049:13, 2056:17, 2057:2,

2058:4, 2058:9, 2058:12, 2064:9,

2094:25, 2109:22, 2111:15, 2125:21,

2148:12, 2148:24, 2156:9, 2156:23,

2157:7, 2157:12, 2158:1, 2158:3,

2158:6, 2158:17, 2158:21, 2158:25,

2159:15, 2159:19, 2160:2, 2177:19,

2180:12, 2180:15, 2180:24, 2184:18,

2188:21, 2228:6, 2228:22, 2229:1,

2229:8, 2229:14, 2229:21, 2230:13,

2238:19, 2246:17, 2246:24, 2248:7,

2248:16

Report [1] - 2030:21

reported [3] - 2095:1, 2107:3, 2222:6

Reporter [2] - 1972:10, 1972:17

reporter [1] - 2099:12

REPORTER'S [1] - 2257:8

reporting [11] - 2015:24, 2028:14,

2032:24, 2088:22, 2106:25, 2158:11,

2158:14, 2221:15, 2222:2, 2222:16,

2238:13

Reporting [1] - 2239:20

reports [23] - 2012:10, 2027:6, 2027:8,

2027:10, 2027:11, 2033:4, 2033:7,

2033:20, 2034:14, 2035:2, 2074:11,

2109:17, 2159:17, 2174:25, 2177:12,

2185:24, 2187:11, 2187:12, 2221:11,

2222:18, 2239:5, 2241:25, 2251:16

represent [4] - 1980:2, 1980:14,

1992:7, 2252:11

representation [1] - 2119:10

representations [1] - 2252:12

representative [1] - 2119:10

representing [2] - 1981:20, 2032:14

reputation [2] - 2026:18, 2026:19

request [14] - 1975:18, 1996:16,

1997:10, 1997:18, 1998:6, 2046:4,

2047:5, 2047:7, 2049:10, 2049:12,

2091:20, 2091:21, 2092:3, 2092:20

request/application [1] - 2059:5

requested [9] - 1996:19, 1997:14,

2034:2, 2043:25, 2053:16, 2080:24,

2084:8, 2091:13, 2091:15

Requested [2] - 1977:1, 2076:23

requesting [3] - 2046:6, 2103:3,

2161:6

requests [2] - 2042:5, 2047:19

require [5] - 2049:6, 2066:10, 2206:12,

2206:15, 2206:17

required [18] - 1976:7, 1978:9, 1979:2,

2040:17, 2048:22, 2050:7, 2066:15,

2091:22, 2109:19, 2112:14, 2112:17,

2118:6, 2158:15, 2205:20, 2222:13,

2222:17, 2224:11, 2252:4

requirement [5] - 2028:24, 2041:1,

2051:7, 2078:15, 2247:1

requirements [7] - 2046:23, 2047:17,

2047:19, 2048:6, 2051:3, 2222:3,

2222:16

requires [4] - 2047:23, 2048:3, 2065:8,

2252:12

research [1] - 2231:6

residence [1] - 2178:22

residential [2] - 2120:8, 2183:22

resign [2] - 2166:16, 2167:25

resigning [1] - 2166:25

resort [16] - 2164:18, 2164:20, 2165:2,

2165:5, 2165:6, 2165:14, 2166:1,

2218:13, 2218:14, 2218:17, 2218:24,

2219:5, 2219:17, 2237:6, 2237:10,

2237:18

resorts [8] - 2162:17, 2162:19, 2163:4,

2163:9, 2163:11, 2163:19, 2164:17,

2165:1

resources [9] - 1979:9, 2122:3,

2122:16, 2127:1, 2127:5, 2142:9,

2145:20, 2243:25

respect [7] - 2011:25, 2019:18,

2026:20, 2026:22, 2071:22, 2234:4,

2234:8

respectfully [2] - 2053:20, 2112:22

Respective [1] - 2031:1

respond [4] - 2070:9, 2128:22,

2128:24, 2189:22

responding [1] - 2060:5

response [16] - 1982:8, 1987:22,

2037:1, 2040:10, 2057:16, 2057:17,

2058:5, 2058:14, 2059:2, 2078:21,

2078:23, 2079:7, 2089:2, 2110:4,

2116:24, 2116:25

Responsibilities [1] - 2031:2

responsibility [2] - 2031:5, 2079:4

responsible [6] - 2031:4, 2101:18,

2133:19, 2176:9, 2199:1, 2199:4

rest [4] - 2059:20, 2122:1, 2131:18,

2247:20

restated [1] - 2071:1

restaurant [7] - 2081:21, 2236:10,

2236:11, 2236:13, 2236:14, 2236:19,

2249:18

Restaurant [3] - 2137:1, 2211:13,

2211:16

result [5] - 1985:8, 2013:20, 2015:16,

2028:11, 2095:11

resulted [2] - 2011:1, 2064:10

results [2] - 2014:23, 2032:21

resume [3] - 2035:6, 2155:10, 2257:5

resumé [2] - 2103:7, 2103:8

retired [1] - 2100:12

return [5] - 2183:24, 2184:2, 2184:5,

2184:20, 2185:17Johnny C. Sanchez, RMR, CRR - [email protected]

2285

returned [1] - 2093:5

revealed [1] - 2014:23

revealing [1] - 1977:15

Revenue [5] - 2225:13, 2225:16,

2225:24, 2226:1, 2226:9

reverse [1] - 2147:25

review [6] - 2028:22, 2086:12,

2095:25, 2109:7, 2118:6, 2229:17

reviewed [8] - 2032:11, 2109:12,

2110:23, 2185:24, 2228:25, 2229:14,

2229:15, 2241:6

reviewing [1] - 2119:3

reviews [1] - 2033:9

revise [1] - 2076:7

revive [1] - 2020:18

revocation [5] - 2002:24, 2067:1,

2068:4, 2098:9, 2098:11

revoke [5] - 1988:9, 1990:23, 2087:2,

2087:4, 2130:2

revoked [9] - 1988:20, 1988:22,

1991:3, 1992:9, 1992:13, 2002:22,

2067:20, 2086:13, 2086:22

Rican [1] - 2009:18

rich [2] - 2220:10, 2221:3

richest [1] - 2218:11

Richmond [2] - 2178:6, 2178:7

rid [1] - 2014:19

right-hand [1] - 2073:12

rights [6] - 2096:21, 2097:4, 2217:15,

2225:21, 2247:8

rise [4] - 2019:14, 2019:16, 2019:18,

2176:17

risk [13] - 2113:14, 2113:22, 2126:4,

2126:5, 2126:10, 2126:13, 2126:17,

2126:18, 2163:19, 2163:20, 2163:24,

2237:18, 2251:17

river [1] - 2119:5

RMR [3] - 1972:10, 1972:18, 2257:14

roads [1] - 2164:20

robe [4] - 2000:2, 2039:9, 2039:16,

2039:21

Robert [6] - 1971:21, 2046:7, 2047:3,

2157:13, 2157:17, 2169:12

ROBERT [1] - 1971:6

Roberts [2] - 2039:19

Roche [1] - 2014:11

Rock [1] - 2122:7

Roe [4] - 2000:24, 2001:2, 2001:3,

2001:7

roll [1] - 2062:22

rolled [1] - 2069:22

roommates [1] - 2131:9

Ross [1] - 2220:23

round [2] - 2240:25, 2241:1

RPR [2] - 1972:10, 1972:18

rule [3] - 2051:17, 2078:22, 2079:12

rules [4] - 2017:3, 2222:8, 2223:18

ruling [4] - 1980:12, 2083:20, 2098:19,

2147:25

run [8] - 2082:18, 2120:20, 2214:13,

2214:15, 2215:19, 2233:12, 2249:8

running [9] - 1983:11, 2015:15,

2019:10, 2042:6, 2043:24, 2083:22,

2083:24, 2211:6, 2233:24

Rusk [2] - 1972:11, 1972:18

Russian [1] - 2014:19

Ryan [1] - 2220:24

S

safe [1] - 2185:4

salary [4] - 2168:10, 2169:21, 2169:25,

2170:2

sale [8] - 2134:11, 2135:12, 2171:15,

2171:16, 2171:18, 2187:3, 2187:12

sales [1] - 2207:1

salespeople [2] - 2108:2, 2108:3

San [3] - 2102:3, 2102:4, 2134:20

Sanchez [4] - 1972:10, 1972:18,

2257:10, 2257:14

Sandra [1] - 2014:10

sat [1] - 2167:3

Saturday [1] - 2103:14

save [1] - 2156:11

savings [1] - 2102:1

saw [21] - 1987:18, 1988:13, 2011:6,

2108:16, 2108:20, 2125:20, 2131:15,

2131:16, 2142:1, 2144:20, 2156:19,

2158:3, 2196:25, 2197:2, 2205:5,

2211:3, 2234:11, 2239:5, 2239:10,

2239:16, 2241:10

Scardino [16] - 1971:21, 1971:21,

2072:7, 2113:5, 2169:12, 2233:19,

2234:13, 2235:11, 2236:2, 2237:21,

2238:5, 2239:18, 2242:8, 2243:11,

2252:24, 2254:13

SCARDINO [86] - 2027:20, 2105:17,

2105:25, 2110:2, 2110:11, 2110:22,

2111:11, 2112:5, 2112:22, 2113:3,

2113:18, 2114:13, 2116:1, 2116:14,

2117:22, 2121:4, 2123:18, 2124:4,

2125:5, 2128:10, 2134:23, 2142:25,

2145:9, 2145:12, 2146:19, 2147:11,

2147:15, 2150:5, 2150:7, 2150:9,

2152:9, 2152:18, 2153:18, 2161:9,

2169:9, 2173:24, 2174:1, 2175:23,

2176:2, 2180:17, 2180:22, 2180:23,

2181:5, 2184:13, 2184:17, 2197:10,

2200:12, 2203:13, 2207:4, 2207:17,

2207:21, 2208:6, 2208:9, 2208:13,

2208:15, 2227:1, 2227:4, 2227:17,

2227:20, 2227:22, 2228:3, 2228:20,

2229:22, 2230:1, 2230:4, 2231:11,

2231:18, 2232:4, 2232:6, 2233:15,

2239:25, 2240:19, 2244:2, 2244:4,

2245:23, 2246:1, 2247:11, 2247:16,

2251:5, 2251:21, 2254:2, 2254:4,

2254:23, 2255:1, 2255:4, 2256:21

Scardino's [1] - 2111:8

SCARDINO........... [2] - 1973:23,

1974:2

SCARDINO............. [1] - 1973:19

scenes [1] - 2039:11

schedule [3] - 1979:2, 1979:10,

2034:22

School [1] - 2100:3

school [2] - 2102:7, 2102:8

schools [1] - 2100:2

Schramm [2] - 2216:3, 2216:8

scope [5] - 2035:22, 2036:22, 2088:13,

2240:19, 2251:22

screen [7] - 1980:21, 2004:1, 2035:5,

2079:19, 2156:21, 2159:11, 2257:3

scroll [2] - 2059:19, 2059:23

scrolling [1] - 2059:22

scrub [2] - 2013:22, 2014:19

seal [1] - 2207:20

seat [2] - 2035:11, 2099:3

seated [3] - 1975:2, 1985:2, 2155:13

second [33] - 1989:15, 1996:1, 2011:1,

2013:5, 2021:8, 2026:4, 2035:25,

2037:7, 2038:8, 2038:17, 2040:8,

2051:17, 2052:25, 2058:23, 2067:14,

2076:19, 2079:19, 2114:5, 2121:13,

2121:20, 2122:2, 2123:23, 2124:13,

2149:23, 2150:5, 2153:16, 2153:25,

2154:10, 2163:22, 2181:6, 2182:18,

2182:21, 2201:25

seconds [2] - 1983:9, 1983:10

secrecy [3] - 1975:12, 2016:14,

2072:22

secretary [1] - 2000:11

Section [16] - 2046:8, 2050:23,

2050:24, 2051:2, 2051:4, 2051:11,

2052:14, 2058:8, 2062:19, 2065:17,

2065:20, 2066:5, 2089:3, 2089:19,

2091:3, 2091:25

section [7] - 2030:9, 2050:16,

2051:11, 2059:7, 2086:19, 2089:22,

2092:11

Sections [1] - 2090:4

sections [6] - 1987:20, 1994:8,

2003:21, 2090:15, 2090:18, 2090:22

sector [12] - 2005:4, 2006:8, 2006:13,

2006:14, 2011:7, 2011:8, 2011:13,

2042:1, 2065:11, 2065:12, 2068:10,

2069:25

Sector [3] - 2005:20, 2006:2, 2007:9

Sectoral [3] - 2010:9, 2010:22,

2068:25

sectoral [3] - 2069:2, 2069:3, 2069:13

sectors [1] - 2042:1

securities [6] - 2247:14, 2247:18,

2253:9, 2254:7, 2255:6, 2255:9

security [3] - 1981:21, 1982:16,

1987:3

see [65] - 1976:1, 1981:1, 1989:2,

1990:3, 1990:8, 1990:10, 1990:12,

1999:23, 2001:9, 2003:3, 2004:1,

2006:12, 2017:25, 2020:23, 2028:17,

2030:11, 2035:6, 2035:7, 2044:3,

2055:18, 2057:6, 2057:14, 2063:12,

2073:17, 2073:21, 2073:22, 2079:11,

2079:19, 2089:12, 2093:17, 2093:19,

2096:22, 2096:24, 2097:1, 2103:21,

2110:14, 2117:12, 2120:3, 2127:6,


2286

2149:12, 2151:19, 2151:24, 2155:10,

2156:24, 2157:6, 2157:12, 2173:1,

2177:19, 2181:6, 2195:12, 2207:22,

2208:10, 2208:16, 2219:19, 2229:12,

2230:5, 2235:11, 2250:21, 2257:2,

2257:5

seek [5] - 2001:14, 2054:24, 2103:19,

2162:12, 2162:15

seeking [1] - 1994:25

seem [3] - 2131:20, 2131:25, 2215:23

Seidman [1] - 2009:5

seized [1] - 1998:20

selected [1] - 2162:24

sell [12] - 2103:20, 2120:20, 2125:22,

2126:2, 2133:25, 2134:8, 2166:5,

2251:13, 2253:21, 2253:22, 2254:11,

2256:17

selling [5] - 2108:4, 2108:25, 2115:22,

2116:11, 2246:16

sells [3] - 1982:2, 2256:4, 2256:8

semiretired [1] - 2099:21

sending [3] - 2015:21, 2167:4

senior [1] - 2043:16

sense [4] - 2144:12, 2235:4, 2235:5,

2243:6

sent [9] - 2013:9, 2013:13, 2042:24,

2062:14, 2065:5, 2103:8, 2130:1,

2166:21, 2167:19

sentence [5] - 2058:23, 2087:19,

2087:24, 2091:15, 2230:7

separate [13] - 2104:19, 2104:20,

2107:18, 2119:24, 2120:22, 2137:13,

2137:19, 2162:1, 2162:4, 2165:12,

2210:17, 2210:18, 2225:2

separately [4] - 2121:10, 2121:22,

2122:11, 2123:12

September [3] - 2043:10, 2043:12,

2056:24

series [3] - 2020:22, 2064:8, 2075:21

serves [1] - 2025:1

Service [6] - 2016:4, 2225:13,

2225:16, 2225:24, 2226:1, 2226:9

service [1] - 2006:23

services [11] - 1976:15, 2004:19,

2005:3, 2006:20, 2006:21, 2041:20,

2132:13, 2132:20, 2203:21, 2203:24,

2220:16

Services [11] - 2023:11, 2068:25,

2102:15, 2106:17, 2107:15, 2107:23,

2114:12, 2123:3, 2133:5, 2133:6,

2188:5

set [13] - 2013:3, 2033:17, 2040:14,

2060:1, 2063:25, 2088:21, 2120:22,

2121:14, 2121:20, 2122:18, 2122:23,

2140:22, 2151:23

sets [5] - 2042:17, 2082:10, 2082:12,

2082:13

seven [2] - 2171:19, 2171:20

several [5] - 2064:18, 2071:12,

2197:17, 2209:9, 2232:2

sewn [1] - 2039:10

shade [3] - 2141:16, 2141:18, 2141:20

shading [1] - 2141:23

shall [1] - 2046:14

shape [1] - 2211:1

share [1] - 2055:5

shared [1] - 1976:2

shareholder [8] - 2192:11, 2222:18,

2222:24, 2223:2, 2228:10, 2242:6,

2249:4, 2254:19

shareholders [1] - 2222:6

shares [3] - 2046:16, 2253:21, 2253:22

sharing [1] - 2055:1

shift [1] - 2221:9

shocked [2] - 2180:2, 2180:4

short [4] - 1999:25, 2007:12, 2038:25,

2039:23

shorter [1] - 2217:6

shortly [1] - 2108:12

shot [1] - 2139:9

show [29] - 1988:4, 1988:24, 1990:22,

2000:24, 2017:7, 2020:21, 2023:7,

2027:16, 2030:8, 2045:5, 2049:25,

2055:11, 2055:16, 2056:11, 2066:21,

2087:9, 2106:3, 2111:9, 2114:14,

2140:16, 2142:10, 2149:21, 2152:15,

2153:13, 2180:24, 2194:15, 2229:7,

2229:18, 2239:12

showed [18] - 1990:23, 2003:13,

2039:9, 2065:17, 2067:13, 2080:13,

2086:17, 2154:13, 2221:10, 2223:1,

2223:2, 2228:7, 2228:8, 2228:10,

2228:11, 2228:23, 2229:9, 2249:8

showing [6] - 1979:25, 2127:7,

2139:11, 2149:12, 2196:5, 2252:24

shown [12] - 1980:8, 1986:14,

1986:16, 1987:19, 1988:5, 1988:19,

2003:14, 2074:11, 2088:16, 2196:3,

2228:23, 2229:6

shows [3] - 2139:13, 2139:14, 2149:2

shut [2] - 2004:22, 2102:2

SIB [2] - 2026:5, 2058:18

SIBL [15] - 1981:5, 1981:12, 1982:2,

1982:9, 1985:8, 2003:8, 2015:12,

2016:2, 2020:18, 2025:2, 2027:11,

2033:4, 2033:18, 2042:22, 2085:10

sic [2] - 1981:21, 2134:25

side [10] - 1984:14, 1984:18, 2016:1,

2058:2, 2073:12, 2073:13, 2079:1,

2114:5, 2126:1

side-by-side [1] - 2058:2

sidebar [1] - 2076:1

sides [1] - 2240:24

signature [13] - 2027:23, 2029:21,

2029:24, 2030:1, 2030:22, 2032:11,

2044:8, 2149:22, 2149:25, 2156:1,

2156:3, 2156:6

signed [9] - 1994:4, 2002:4, 2027:7,

2027:14, 2027:15, 2033:1, 2057:13,

2150:12, 2150:18

significant [2] - 1989:15, 2031:15

signing [1] - 2160:1

similar [1] - 2154:12

simple [1] - 1996:13

simply [2] - 1985:11, 2078:14

single [2] - 1977:18, 2027:8

sit [3] - 1991:11, 2128:13, 2166:18

site [1] - 2033:11

sits [1] - 1983:4

sitting [2] - 1984:5, 1984:12

situation [2] - 2082:20, 2083:7

six [1] - 2099:17

sixteen [1] - 2169:16

sixth [1] - 2021:16

skill [1] - 2042:16

skip [3] - 1991:6, 2002:19, 2002:23

Slate [21] - 2010:6, 2012:7, 2013:19,

2013:22, 2013:25, 2014:3, 2014:8,

2014:15, 2014:18, 2014:22, 2015:5,

2015:11, 2015:16, 2069:21, 2069:22,

2069:24, 2070:2, 2070:8, 2070:13,

2070:22, 2072:3

Slater [3] - 2107:2, 2109:14, 2181:11

sleeves [1] - 2039:10

slide [7] - 2058:6, 2059:16, 2059:17,

2059:18, 2059:19, 2059:20

slides [1] - 2059:15

slight [1] - 2084:2

slow [4] - 2046:11, 2173:23, 2175:22

small [10] - 2107:20, 2107:24, 2109:6,

2121:2, 2135:11, 2141:2, 2160:16,

2164:9, 2186:14, 2192:21

smart [3] - 2173:2, 2173:5, 2191:6

smell [1] - 2205:8

SO [1] - 2121:5

Society [1] - 2168:8

sold [7] - 2125:19, 2233:6, 2233:8,

2233:9, 2242:18, 2244:13

sole [2] - 2242:6, 2254:19

solicitor [1] - 2095:4

someone [7] - 1985:11, 2045:11,

2086:11, 2104:7, 2130:23, 2196:16,

2241:24

sometime [4] - 2040:9, 2042:21,

2043:10, 2198:14

sometimes [7] - 2203:6, 2223:7,

2245:12, 2245:18, 2248:11, 2249:25,

2250:4

somewhat [3] - 2012:18, 2183:3,

2221:18

somewhere [4] - 2026:17, 2093:21,

2229:22, 2251:24

soon [4] - 2053:17, 2097:3, 2099:18,

2099:19

sorry [31] - 1978:22, 1981:12, 1989:12,

1992:20, 1999:3, 2004:1, 2004:7,

2029:7, 2061:19, 2067:10, 2069:4,

2069:14, 2070:10, 2073:13, 2077:23,

2080:8, 2084:10, 2127:20, 2127:24,

2128:3, 2128:17, 2148:13, 2157:4,

2173:24, 2175:23, 2178:9, 2227:15,

2230:19, 2240:3, 2246:23, 2254:2

sort [5] - 2078:15, 2164:1, 2164:5,

2182:1, 2206:17

sorts [1] - 2096:23

sought [1] - 2095:8

soul [1] - 2019:19


2287

sound [1] - 1993:18

sounds [3] - 2000:12, 2007:7, 2014:16

source [1] - 2142:7

sources [1] - 2127:7

South [5] - 2004:13, 2020:6, 2213:18,

2231:24, 2232:2

SOUTHERN [1] - 1971:1

southwest [3] - 2121:2, 2121:19,

2122:9

Southwest [2] - 2186:18, 2186:19

space [1] - 2233:3

speaking [12] - 1975:21, 1975:22,

1996:3, 1996:13, 2000:14, 2000:18,

2001:1, 2023:2, 2055:21, 2055:24,

2206:20, 2228:7

speaks [2] - 2058:21, 2163:21

specialize [1] - 1979:17

specific [11] - 2166:24, 2170:14,

2183:9, 2183:10, 2183:12, 2184:7,

2184:24, 2197:17, 2203:16, 2226:2,

2247:1

specifically [11] - 1976:9, 2042:22,

2047:1, 2056:7, 2115:10, 2115:12,

2172:4, 2183:23, 2199:8, 2203:24,

2210:25

specification [1] - 2059:7

specifications [2] - 2201:2, 2201:4

specifics [2] - 1981:6, 2013:18

specified [1] - 2239:6

specify [1] - 2107:9

speculation [1] - 2200:9

speculative [3] - 2163:8, 2163:12,

2165:24

speech [3] - 2142:16, 2143:9, 2144:17

speed [1] - 2062:22

spell [3] - 2099:12, 2121:4, 2134:23

spend [5] - 2120:19, 2136:8, 2183:1,

2219:20, 2250:5

spending [1] - 2136:5

spent [8] - 2160:22, 2160:23, 2167:10,

2168:20, 2211:24, 2220:6, 2243:18,

2243:20

sport [4] - 2213:13, 2213:14, 2214:11,

2217:2

sports [9] - 2213:12, 2214:21,

2215:24, 2216:5, 2216:6, 2216:7,

2216:13, 2217:14, 2250:24

spot [1] - 2214:16

spread [1] - 2162:11

spreads [1] - 2164:2

spring [2] - 2016:2, 2040:6

Springs [4] - 2122:7, 2135:12,

2197:19, 2242:21

Square [1] - 2121:17

St [2] - 2063:21, 2168:8

stable [2] - 2187:4, 2187:6

stacked [1] - 2097:2

staff [6] - 2041:19, 2042:11, 2042:13,

2042:15, 2042:16

staffing [1] - 2163:17

stage [1] - 2162:22

stand [1] - 2196:13

standard [7] - 2140:21, 2140:23,

2150:15, 2239:13, 2239:22, 2241:17,

2249:9

standards [19] - 2028:14, 2031:12,

2032:24, 2125:10, 2158:11, 2158:14,

2222:22, 2230:9, 2230:15, 2230:18,

2238:6, 2238:12, 2238:13, 2238:22,

2240:22, 2241:19, 2249:6, 2249:7

Standards [1] - 2239:21

standing [20] - 1984:11, 1984:14,

1984:18, 1994:25, 1995:2, 1995:6,

1995:19, 1996:10, 1996:12, 1998:7,

2036:6, 2043:25, 2046:4, 2046:22,

2053:19, 2054:16, 2054:19, 2054:21,

2103:25, 2195:4

Stanford [339] - 1976:12, 1976:13,

1976:16, 1977:17, 1978:16, 1978:22,

1979:13, 1979:20, 1980:3, 1980:15,

1984:22, 1988:21, 1990:8, 1990:9,

1992:15, 1992:19, 1992:23, 1993:6,

1993:7, 1993:12, 1993:14, 1994:10,

1994:12, 1994:14, 1995:8, 1995:12,

1997:13, 1997:18, 1998:6, 1998:10,

1999:3, 2000:9, 2000:17, 2000:19,

2000:23, 2001:2, 2002:14, 2007:22,

2008:6, 2015:8, 2015:9, 2016:10,

2020:17, 2023:11, 2024:3, 2025:2,

2025:3, 2043:5, 2043:23, 2046:1,

2046:20, 2054:2, 2054:5, 2056:18,

2057:3, 2057:8, 2063:19, 2063:20,

2064:3, 2065:2, 2068:21, 2069:5,

2069:9, 2069:16, 2069:23, 2071:19,

2072:17, 2072:18, 2074:5, 2075:9,

2075:18, 2076:6, 2076:14, 2077:3,

2081:22, 2086:11, 2086:17, 2087:10,

2088:21, 2093:2, 2093:10, 2093:17,

2093:21, 2093:24, 2094:12, 2094:15,

2095:20, 2097:17, 2102:20, 2103:12,

2103:16, 2103:21, 2104:4, 2104:6,

2104:23, 2105:9, 2105:15, 2105:21,

2106:8, 2106:10, 2106:21, 2107:3,

2107:6, 2107:7, 2107:11, 2109:10,

2109:15, 2109:19, 2109:24, 2110:7,

2110:9, 2110:18, 2111:3, 2112:14,

2112:18, 2113:10, 2114:25, 2115:8,

2115:13, 2115:18, 2115:22, 2116:12,

2116:20, 2117:1, 2117:16, 2117:20,

2118:1, 2119:1, 2119:8, 2119:18,

2120:2, 2121:21, 2122:1, 2122:10,

2122:15, 2123:11, 2124:8, 2126:21,

2127:3, 2127:9, 2128:6, 2128:19,

2129:3, 2129:13, 2129:15, 2129:22,

2130:5, 2130:19, 2132:14, 2132:19,

2133:1, 2133:12, 2134:19, 2135:2,

2135:14, 2135:20, 2135:21, 2135:23,

2136:3, 2136:17, 2137:3, 2137:10,

2137:12, 2137:13, 2137:15, 2137:16,

2137:23, 2137:24, 2138:4, 2139:3,

2139:14, 2139:25, 2140:3, 2140:13,

2140:18, 2141:7, 2141:11, 2141:15,

2142:7, 2142:8, 2142:11, 2142:13,

2142:18, 2144:1, 2144:7, 2144:16,

2144:25, 2145:24, 2146:1, 2146:22,

2147:8, 2148:11, 2148:15, 2148:17,

2149:17, 2149:18, 2150:1, 2150:18,

2151:14, 2151:20, 2152:4, 2152:11,

2153:1, 2154:25, 2156:7, 2156:23,

2157:6, 2157:13, 2157:17, 2158:8,

2158:9, 2158:10, 2159:22, 2160:11,

2160:14, 2160:23, 2161:4, 2161:12,

2161:23, 2161:25, 2162:4, 2162:9,

2164:25, 2165:11, 2166:11, 2166:14,

2166:18, 2167:3, 2167:20, 2168:14,

2168:20, 2168:23, 2169:5, 2169:6,

2169:15, 2169:18, 2169:24, 2170:2,

2170:8, 2171:6, 2171:14, 2172:7,

2174:15, 2174:20, 2174:22, 2175:4,

2176:8, 2176:13, 2179:13, 2180:9,

2181:8, 2183:22, 2184:19, 2185:4,

2185:14, 2186:2, 2187:8, 2187:16,

2187:22, 2188:11, 2188:22, 2189:19,

2190:15, 2191:6, 2191:14, 2191:22,

2192:9, 2194:12, 2195:11, 2195:16,

2198:15, 2199:18, 2200:14, 2201:15,

2202:18, 2202:19, 2202:21, 2203:1,

2204:24, 2205:15, 2206:2, 2208:24,

2209:8, 2209:17, 2210:7, 2210:11,

2210:15, 2210:16, 2210:19, 2211:12,

2211:25, 2214:21, 2216:11, 2218:10,

2219:4, 2221:12, 2222:6, 2222:17,

2222:24, 2225:14, 2227:7, 2227:12,

2228:6, 2229:4, 2229:20, 2230:21,

2231:14, 2232:16, 2232:24, 2233:11,

2233:23, 2234:7, 2234:17, 2234:20,

2234:24, 2235:7, 2236:12, 2237:8,

2237:9, 2238:1, 2238:11, 2238:16,

2241:10, 2242:6, 2243:5, 2243:22,

2246:16, 2246:25, 2251:9, 2251:18,

2252:3, 2253:15, 2254:14

STANFORD [1] - 1971:6

Stanford's [35] - 1997:19, 1998:3,

2023:6, 2024:4, 2068:16, 2072:14,

2075:2, 2105:11, 2106:3, 2107:5,

2108:15, 2121:9, 2131:7, 2131:11,

2131:13, 2132:6, 2132:9, 2138:23,

2146:17, 2160:18, 2161:16, 2166:7,

2167:15, 2196:17, 2202:20, 2204:25,

2209:18, 2215:24, 2229:7, 2231:23,

2232:14, 2232:21, 2232:24, 2249:7

Star [2] - 2138:3, 2146:10

start [15] - 2029:6, 2040:14, 2041:18,

2045:25, 2046:3, 2056:12, 2077:15,

2084:19, 2102:10, 2146:1, 2146:8,

2224:14, 2249:22, 2249:25, 2250:4

started [33] - 2010:25, 2015:19,

2015:21, 2037:23, 2042:19, 2054:24,

2060:7, 2100:15, 2101:15, 2107:14,

2123:4, 2124:1, 2124:8, 2127:3,

2129:13, 2130:5, 2132:25, 2133:4,

2133:13, 2133:20, 2135:1, 2138:1,

2139:20, 2140:9, 2141:11, 2170:2,

2181:12, 2190:6, 2193:11, 2201:24,

2228:2, 2228:14, 2249:19

starting [2] - 2063:17, 2209:3

State [1] - 2055:4

state [4] - 1976:24, 2028:10, 2032:20,


2288

2160:8

statement [21] - 1981:8, 1981:16,

1981:24, 1982:4, 1982:12, 1982:18,

1995:20, 2030:23, 2047:11, 2047:14,

2074:1, 2087:5, 2087:7, 2089:24,

2091:8, 2091:10, 2092:22, 2105:18,

2105:21, 2150:19, 2256:18

statements [25] - 2028:9, 2028:12,

2030:24, 2031:5, 2031:6, 2031:14,

2031:17, 2031:25, 2032:7, 2032:12,

2032:13, 2032:19, 2033:10, 2074:13,

2074:17, 2101:20, 2133:14, 2160:9,

2174:11, 2199:5, 2211:4, 2222:7,

2228:8, 2229:4, 2238:17

STATES [3] - 1971:1, 1971:4, 1971:10

states [2] - 2046:13, 2054:21

States [11] - 1986:22, 2011:10, 2013:9,

2013:12, 2016:3, 2026:4, 2081:25,

2098:24, 2136:4, 2221:21, 2222:1

stating [1] - 2053:6

status [2] - 2100:11, 2100:12

statute [4] - 1976:22, 2049:5, 2065:10

statutes [2] - 2052:14, 2065:8

statutory [4] - 2046:9, 2046:22,

2048:5, 2050:6

stay [3] - 2102:11, 2141:11, 2218:3

stayed [1] - 2185:11

Stellmach [1] - 1971:16

stenography [2] - 1972:13, 1972:20

step [3] - 2098:16, 2190:4, 2256:24

Stevens [1] - 2039:3

stick [4] - 2011:19, 2012:9, 2082:5,

2098:18

sticker [2] - 2045:15, 2158:24

sticks [2] - 2082:1, 2082:3

Sticky [19] - 2081:18, 2081:20,

2081:21, 2081:23, 2082:4, 2083:12,

2084:10, 2084:25, 2085:12, 2085:13,

2137:1, 2139:13, 2211:12, 2213:5,

2213:8, 2214:22, 2215:13, 2243:3,

2249:14

sticky [5] - 2082:8, 2082:19, 2083:7,

2084:11, 2214:16

still [27] - 2015:5, 2015:7, 2015:12,

2024:5, 2062:4, 2071:4, 2090:10,

2090:16, 2099:21, 2101:4, 2112:25,

2123:11, 2124:9, 2134:7, 2153:15,

2155:2, 2157:20, 2168:25, 2172:22,

2197:11, 2211:6, 2211:9, 2211:10,

2221:4, 2249:6, 2251:2

stock [2] - 2246:7, 2246:10

stockbroker [1] - 2253:21

stocks [4] - 2111:7, 2126:19, 2239:5,

2245:10

stole [1] - 2083:1

stop [13] - 1981:7, 1981:15, 1982:11,

1987:13, 1993:18, 1995:25, 2046:18,

2047:17, 2127:12, 2143:19, 2193:2,

2202:19

stopped [1] - 2038:24

stopping [2] - 2077:12, 2155:6

store [1] - 1999:21

story [4] - 2038:25, 2039:7, 2039:22,

2135:3

strange [1] - 2014:16

strategy [2] - 2165:19, 2165:22

Street [2] - 1971:22, 2103:1

streets [1] - 2187:11

strengthen [2] - 2007:19, 2011:8

strictly [3] - 2137:23, 2217:20,

2219:16

strip [2] - 2023:12, 2023:13

stripes [2] - 2039:10, 2039:16

strong [1] - 2214:8

structure [1] - 2219:10

structures [1] - 2217:12

studies [1] - 2250:15

stuff [1] - 2125:11

stumps [1] - 2082:12

stupid [2] - 2225:5, 2245:18

style [5] - 2132:10, 2180:10, 2181:9,

2183:3, 2194:1

subdivision [2] - 2135:11, 2197:23

subject [9] - 1980:12, 2018:20,

2028:21, 2056:6, 2083:25, 2163:14,

2239:22

submit [3] - 1978:9, 2053:16, 2103:7

submits [1] - 1979:22

submitted [5] - 2028:23, 2046:8,

2053:12, 2053:13, 2092:19

Subparagraph [1] - 2066:4

Subsection [6] - 2091:5, 2091:7,

2091:10, 2091:11, 2091:12, 2091:25

subsection [2] - 2050:9, 2089:5

subsections [2] - 2051:7, 2091:17

subsequent [1] - 2043:11

subsequently [1] - 2065:3

subsidiaries [1] - 2101:11

success [1] - 2019:15

successful [16] - 2015:14, 2121:9,

2121:21, 2122:10, 2171:23, 2171:24,

2171:25, 2185:12, 2191:3, 2191:5,

2203:17, 2224:15, 2246:5, 2250:19,

2250:25

sufficient [1] - 2031:24

suggested [1] - 2074:3

suing [2] - 1992:10, 2097:5

Suisse [1] - 1979:14

Sullivan [1] - 2039:14

sum [3] - 2063:23, 2151:21, 2244:10

Sun [2] - 2138:3, 2146:10

super [7] - 2165:6, 2165:14, 2166:1,

2236:14, 2237:5, 2237:10, 2237:17

supervise [1] - 2094:20

supervised [1] - 2094:16

supervisor [5] - 2049:9, 2049:10,

2049:12, 2094:3, 2095:13

support [5] - 2038:15, 2041:22,

2132:20, 2146:23, 2162:19

suppose [2] - 1986:24, 2089:1

supposed [3] - 2149:2, 2162:4,

2191:18

Supreme [2] - 2009:21, 2039:2

surprise [1] - 2035:20

surprised [1] - 2180:1

surrender [2] - 1998:18, 2067:23

surrendered [3] - 2068:3, 2087:12,

2098:7

surrounding [1] - 2164:17

suspect [1] - 2203:23

suspicion [1] - 2146:17

sustain [3] - 2070:25, 2076:25, 2106:5

sustained [13] - 2038:16, 2052:8,

2072:9, 2075:16, 2081:1, 2088:14,

2116:2, 2116:15, 2146:20, 2147:17,

2180:16, 2200:11, 2251:24

swearing [1] - 2096:17

swimming [1] - 2136:20

Swiss [3] - 2075:2, 2075:11, 2115:17

switch [5] - 2027:20, 2062:7, 2067:9,

2073:7, 2252:17

Switzerland [8] - 2115:16, 2118:7,

2118:16, 2230:22, 2231:22, 2231:24,

2232:1, 2232:3

sworn [2] - 2099:2, 2099:5

Sydney [2] - 2108:8, 2108:11

system [3] - 2037:21, 2040:22,

2221:15

T

table [2] - 2080:8, 2080:10

Takara [1] - 2121:3

TAKARA [1] - 2121:5

tape [3] - 2143:18, 2144:5, 2144:14

target [1] - 2120:2

targeting [1] - 2120:17

task [4] - 2012:3, 2013:24, 2041:1,

2042:13

tasks [3] - 2040:12, 2040:17, 2040:21

tax [5] - 2088:5, 2088:7, 2088:11,

2088:22, 2226:23

taxable [1] - 2223:11

taxes [2] - 2225:7, 2226:5

team [17] - 2010:6, 2010:25, 2012:6,

2012:7, 2014:3, 2014:5, 2019:9,

2019:10, 2019:15, 2020:12, 2043:17,

2213:21, 2213:24, 2216:18, 2217:16

teams [2] - 2213:23, 2214:5

technically [2] - 2203:7, 2203:10

technology [1] - 2220:9

television [1] - 2217:15

tempting [1] - 2088:1

ten [4] - 2020:18, 2036:19, 2135:5,

2241:7

ten-dollar [1] - 2241:7

tens [6] - 2212:2, 2215:12, 2216:13,

2219:20, 2219:22, 2219:23

tenure [1] - 2039:16

term [5] - 2088:9, 2120:15, 2140:21,

2158:5, 2254:7

terminology [5] - 2137:19, 2195:21,

2195:22, 2209:1, 2218:8

terms [9] - 1996:22, 2013:17, 2041:2,

2063:25, 2103:4, 2108:15, 2128:6,

2132:10, 2151:23

test [1] - 2031:13Johnny C. Sanchez, RMR, CRR - [email protected]

2289

testified [13] - 1988:14, 1992:24,

1994:14, 1998:11, 2042:23, 2064:23,

2068:21, 2069:9, 2099:5, 2184:4,

2184:8, 2184:11, 2228:4

testify [3] - 1984:23, 2177:16, 2228:21

testimony [9] - 2034:12, 2034:16,

2035:21, 2038:15, 2052:14, 2078:11,

2084:8, 2113:6, 2168:18

tests [1] - 2160:7

Tex [1] - 2216:3

TEXAS [1] - 1971:1

Texas [19] - 1971:4, 1971:15, 1971:23,

1972:4, 1972:7, 1972:11, 1972:19,

2055:4, 2055:5, 2101:25, 2102:2,

2105:2, 2120:10, 2171:19, 2178:7,

2186:7, 2190:10, 2190:23, 2201:16

THE [308] - 1971:10, 1971:13, 1971:20,

1972:2, 1975:2, 1976:20, 1976:24,

1977:2, 1977:5, 1977:8, 1977:9,

1977:11, 1977:12, 1980:4, 1980:9,

1983:1, 1983:3, 1983:6, 1983:10,

1983:24, 1984:2, 1985:20, 1985:22,

1985:25, 1986:2, 1986:4, 1987:8,

1987:11, 1989:7, 1989:9, 1989:12,

1989:17, 1989:20, 1989:23, 1991:15,

1991:19, 1991:21, 1991:22, 1991:23,

1991:24, 1991:25, 1992:1, 1996:24,

1997:1, 1997:2, 1997:22, 1999:6,

1999:9, 1999:12, 1999:15, 1999:20,

2017:11, 2017:16, 2017:19, 2020:14,

2022:14, 2022:17, 2022:19, 2022:23,

2027:21, 2034:20, 2035:4, 2035:9,

2035:25, 2036:3, 2036:9, 2036:13,

2036:16, 2036:23, 2037:1, 2037:5,

2037:9, 2037:15, 2037:18, 2037:22,

2037:24, 2038:3, 2038:16, 2038:22,

2038:24, 2044:14, 2044:19, 2044:21,

2045:6, 2045:15, 2045:20, 2046:11,

2049:20, 2051:17, 2051:21, 2052:1,

2052:8, 2054:11, 2056:5, 2059:21,

2061:13, 2061:17, 2061:19, 2061:20,

2061:22, 2061:23, 2062:8, 2062:10,

2063:6, 2066:1, 2067:6, 2070:4,

2070:9, 2070:12, 2070:15, 2070:24,

2071:9, 2071:11, 2071:14, 2071:15,

2072:9, 2073:9, 2075:6, 2075:7,

2075:13, 2075:16, 2076:4, 2076:9,

2076:19, 2076:24, 2077:7, 2077:10,

2077:14, 2078:4, 2078:9, 2078:20,

2079:2, 2079:11, 2079:15, 2079:23,

2080:7, 2080:10, 2080:22, 2080:25,

2081:11, 2081:12, 2081:23, 2082:4,

2082:5, 2082:6, 2082:7, 2082:9,

2082:15, 2082:16, 2082:21, 2082:22,

2082:23, 2082:25, 2083:1, 2083:5,

2083:15, 2083:16, 2083:24, 2084:6,

2084:16, 2085:5, 2085:6, 2086:1,

2088:14, 2089:16, 2090:3, 2090:6,

2090:9, 2090:12, 2090:13, 2090:17,

2090:22, 2091:1, 2092:11, 2096:6,

2096:11, 2096:13, 2097:9, 2097:22,

2097:25, 2098:13, 2098:15, 2098:21,

2098:22, 2098:25, 2100:23, 2100:25,

2102:16, 2102:17, 2103:25, 2104:1,

2104:3, 2105:19, 2106:1, 2106:5,

2110:4, 2110:13, 2110:24, 2110:25,

2112:11, 2112:19, 2113:2, 2113:20,

2113:21, 2114:16, 2114:19, 2115:5,

2116:2, 2116:7, 2116:15, 2117:24,

2119:22, 2121:5, 2123:20, 2124:5,

2124:6, 2124:15, 2124:18, 2124:22,

2125:13, 2127:18, 2127:20, 2127:22,

2127:24, 2127:25, 2128:1, 2128:12,

2128:15, 2134:24, 2138:13, 2138:15,

2143:1, 2143:3, 2143:7, 2143:11,

2143:13, 2143:16, 2144:4, 2145:11,

2145:14, 2146:20, 2147:17, 2147:19,

2147:22, 2148:3, 2148:6, 2150:6,

2150:8, 2150:13, 2150:20, 2151:6,

2152:13, 2152:23, 2153:15, 2153:17,

2153:20, 2153:22, 2153:25, 2155:8,

2155:13, 2155:15, 2161:11, 2161:13,

2161:14, 2166:24, 2167:1, 2173:23,

2175:22, 2175:25, 2180:16, 2181:4,

2184:10, 2184:14, 2184:16, 2197:7,

2197:8, 2200:11, 2203:5, 2207:7,

2207:9, 2207:16, 2227:3, 2227:16,

2227:19, 2227:21, 2227:24, 2228:1,

2228:13, 2228:18, 2229:25, 2231:10,

2231:15, 2231:16, 2231:17, 2240:1,

2240:5, 2240:8, 2240:11, 2240:24,

2245:24, 2251:24, 2252:19, 2252:21,

2254:5, 2254:25, 2256:23, 2256:25,

2257:1

the.. [1] - 2251:4

theme [1] - 2011:9

thereafter [1] - 2108:12

thereby [1] - 2062:25

therefore [3] - 1997:15, 1997:18,

2087:11

they've [3] - 2035:19, 2125:9, 2248:10

thinking [3] - 2019:2, 2071:21,

2165:14

third [10] - 2021:10, 2052:24, 2096:10,

2122:4, 2122:11, 2123:23, 2124:13,

2164:7, 2203:7, 2256:4

thousand [1] - 2170:3

thousands [1] - 2037:24

three [24] - 1991:12, 2034:23, 2047:15,

2071:24, 2071:25, 2082:12, 2085:20,

2087:9, 2087:18, 2100:12, 2107:21,

2108:8, 2122:19, 2123:6, 2135:6,

2171:15, 2171:16, 2171:18, 2179:3,

2179:9, 2190:7, 2192:17, 2202:5,

2251:25

three-quarters [1] - 2034:23

throughout [4] - 2064:14, 2064:22,

2159:21, 2234:10

ticket [2] - 2213:20, 2213:21

tie [1] - 1987:14

tighter [1] - 2004:18

timeframe [5] - 2013:3, 2081:9,

2231:9, 2231:10, 2231:12

timeline [1] - 2012:24

timelines [1] - 2012:19

timely [1] - 2035:18

tiny [1] - 2236:20

tired [1] - 2176:21

title [4] - 2030:21, 2100:9, 2123:8,

2199:24

titled [3] - 2050:23, 2050:24, 2050:25

today [9] - 1997:7, 1997:8, 2014:12,

2034:12, 2034:16, 2103:21, 2207:10,

2229:6, 2257:4

together [11] - 2003:22, 2008:10,

2019:20, 2059:14, 2063:24, 2151:22,

2187:21, 2188:10, 2188:11, 2189:22,

2191:11

Tom [2] - 1985:4, 2008:23

tomorrow [1] - 2257:5

took [12] - 2040:10, 2072:7, 2094:5,

2094:9, 2168:13, 2170:4, 2178:6,

2178:7, 2187:16, 2210:19, 2210:24,

2225:13

top [17] - 1982:7, 1990:3, 2056:15,

2058:3, 2058:9, 2058:11, 2061:24,

2063:9, 2117:12, 2148:24, 2151:4,

2152:1, 2154:21, 2159:12, 2207:19,

2208:7, 2225:16

topic [2] - 2115:22, 2116:9

total [4] - 2149:3, 2171:18, 2171:20,

2190:11

totally [1] - 2109:21

tough [1] - 2189:14

tour [1] - 2043:2

tourists [1] - 2164:1

tournament [1] - 2216:20

towards [8] - 2085:1, 2105:6, 2111:21,

2144:16, 2145:25, 2148:14, 2238:2,

2238:5

townhomes [1] - 2134:20

tracked [2] - 2140:8, 2140:12

traded [1] - 2125:22

traditionally [1] - 2244:13

train [1] - 2041:19

trained [2] - 1991:13, 1991:18

transaction [9] - 2125:7, 2125:8,

2158:7, 2240:18, 2241:6, 2241:7,

2241:8, 2256:5, 2256:13

transactions [9] - 1976:10, 2158:15,

2171:21, 2191:21, 2206:10, 2206:11,

2209:16, 2225:17, 2255:24

transcript [1] - 2257:11

Transcript [2] - 1972:13, 1972:20

transcription [2] - 1972:13, 1972:21

transfer [4] - 2223:11, 2224:17,

2226:3, 2226:9

transferred [1] - 2225:4

transferring [1] - 2225:15

Traurig [1] - 2009:7

travel [4] - 2018:14, 2064:18, 2166:12,

2167:1

traveled [2] - 2019:23, 2020:3

traveling [3] - 2176:22, 2189:8, 2190:6

treasurer [2] - 2199:9, 2199:12

treasury [9] - 2149:8, 2149:10,

2149:11, 2247:21, 2247:23, 2253:23,

2255:13, 2255:14, 2255:15


2290

treatment [1] - 2210:8

treaty [1] - 1976:5

Trevor [2] - 2043:16, 2043:19

trial [2] - 1992:23, 2153:24

TRIAL [1] - 1971:7

tried [4] - 1999:20, 1999:23, 2002:8,

2140:7

Trinidad [1] - 2018:17

trip [2] - 2064:20, 2064:21

tripling [1] - 2169:25

true [25] - 2001:12, 2003:25, 2004:9,

2005:18, 2007:8, 2009:25, 2011:10,

2016:8, 2017:1, 2018:19, 2019:14,

2025:8, 2025:9, 2028:10, 2032:20,

2040:20, 2050:5, 2054:23, 2057:16,

2095:21, 2095:22, 2196:17, 2233:22,

2234:4, 2253:23

Trust [1] - 2211:12

trusts [1] - 2007:2

truth [6] - 2035:3, 2093:7, 2106:2,

2110:9, 2150:9, 2203:8

truthful [1] - 2252:13

try [8] - 1984:1, 2000:1, 2030:4,

2045:4, 2059:17, 2096:19, 2168:2

trying [14] - 2011:14, 2029:18, 2042:2,

2049:11, 2049:19, 2060:2, 2076:6,

2112:24, 2120:2, 2123:11, 2124:9,

2134:8, 2206:3

turn [18] - 1980:18, 1990:19, 2047:18,

2049:6, 2067:3, 2073:18, 2077:5,

2077:15, 2080:5, 2081:14, 2081:17,

2086:2, 2095:8, 2095:12, 2095:13,

2111:17, 2148:23, 2159:3

turned [4] - 2012:10, 2057:21, 2216:8,

2250:18

TV [1] - 2079:17

twice [2] - 2127:11, 2177:3

two [50] - 1979:2, 1989:15, 1998:24,

1999:2, 2010:14, 2010:15, 2013:5,

2030:18, 2035:14, 2053:5, 2057:24,

2069:11, 2071:20, 2071:21, 2073:11,

2082:10, 2082:12, 2082:13, 2090:14,

2090:18, 2090:22, 2096:9, 2101:11,

2106:22, 2117:6, 2123:6, 2125:24,

2134:11, 2138:1, 2146:8, 2146:23,

2157:18, 2166:21, 2166:23, 2167:4,

2167:20, 2171:7, 2172:19, 2173:19,

2190:7, 2210:18, 2211:16, 2217:8,

2217:9, 2220:23, 2228:7, 2246:12,

2252:24, 2255:2

two-month [1] - 2167:20

tying [1] - 2070:22

type [13] - 1982:20, 2112:3, 2120:7,

2135:7, 2146:23, 2150:2, 2154:17,

2158:5, 2165:8, 2165:17, 2203:24,

2213:12, 2244:20

types [11] - 1975:19, 1975:20,

2006:20, 2125:11, 2137:21, 2141:7,

2162:14, 2209:13, 2217:8, 2217:9,

2236:22

typically [1] - 2159:18

U

U.S [14] - 1971:17, 1985:15, 1985:16,

1986:19, 1987:1, 1987:4, 2008:25,

2034:9, 2034:12, 2063:23, 2097:5,

2100:22

U.S.-style [1] - 2197:23

UK [1] - 2011:11

unable [1] - 2058:24

undependable [1] - 2164:24

under [29] - 1975:17, 1975:23, 1976:3,

1985:23, 2006:1, 2030:22, 2042:19,

2048:1, 2060:10, 2086:7, 2091:5,

2092:9, 2092:11, 2138:12, 2184:9,

2184:12, 2190:8, 2190:13, 2211:16,

2211:17, 2211:18, 2215:4, 2222:8,

2223:18, 2224:9, 2224:10, 2238:20,

2249:7

underlined [1] - 2208:14

underneath [1] - 2033:1

understandings [1] - 2124:3

understood [6] - 2071:18, 2106:3,

2110:9, 2112:12, 2168:24, 2235:7

undertook [1] - 2013:22

unfortunately [1] - 1982:9

uNITED [1] - 1971:1

United [13] - 1986:22, 2011:10,

2013:8, 2013:9, 2013:12, 2013:13,

2016:3, 2026:4, 2081:24, 2098:24,

2136:4, 2221:21, 2222:1

UNITED [2] - 1971:4, 1971:10

units [5] - 2134:22, 2171:15, 2171:16,

2186:18, 2186:20

University [2] - 2100:3, 2100:13

unless [5] - 2063:7, 2107:9, 2112:9,

2164:21, 2229:5

unpaid [2] - 2063:25, 2151:22

unquote [1] - 2194:12

unreasonable [1] - 2012:19

untoward [1] - 2205:5

unusual [2] - 2174:2, 2174:3

up [93] - 1983:12, 1983:13, 1985:17,

1987:20, 1992:16, 1996:4, 2003:17,

2003:19, 2007:18, 2015:15, 2018:18,

2021:2, 2028:8, 2030:7, 2031:19,

2032:3, 2033:17, 2035:5, 2035:12,

2039:9, 2040:14, 2040:22, 2042:9,

2043:24, 2045:4, 2049:20, 2053:3,

2057:6, 2058:2, 2059:18, 2060:1,

2061:15, 2062:6, 2062:22, 2077:10,

2083:17, 2083:19, 2083:25, 2088:21,

2089:22, 2094:13, 2097:2, 2097:16,

2102:5, 2102:13, 2103:25, 2105:3,

2105:6, 2111:24, 2112:9, 2115:23,

2116:9, 2116:18, 2120:19, 2120:22,

2121:14, 2121:20, 2122:15, 2122:18,

2122:23, 2126:14, 2126:15, 2126:24,

2136:5, 2141:20, 2144:13, 2152:14,

2154:10, 2156:1, 2157:14, 2167:19,

2168:7, 2169:25, 2175:23, 2176:1,

2187:13, 2188:11, 2188:22, 2190:14,

2190:19, 2211:6, 2214:13, 2216:21,

2217:1, 2224:14, 2228:18, 2230:1,

2231:2, 2247:11, 2253:11, 2255:7,

2256:15, 2257:3

up-to-date [1] - 2053:3

upset [2] - 2012:17, 2142:2

US [1] - 1971:14

V

V.C [1] - 2208:21

Valley [3] - 2135:11, 2197:19, 2242:21

value [6] - 2063:18, 2126:13, 2151:19,

2212:11, 2212:15

variances [2] - 2206:17, 2206:22

various [11] - 1978:13, 1978:15,

2011:25, 2012:13, 2041:23, 2041:25,

2185:22, 2243:14, 2245:7, 2253:10,

2255:6

venue [1] - 2129:25

verbatim [1] - 2065:20

verification [1] - 2017:9

verify [2] - 1989:4, 2058:25

version [1] - 1986:10

versus [3] - 2125:1, 2126:7, 2126:18

vice [2] - 2101:16, 2106:25

vice-president [1] - 2101:16

vice-presidents [1] - 2106:25

video [10] - 2093:21, 2142:10,

2142:13, 2142:18, 2143:11, 2143:12,

2144:25, 2145:25, 2234:24, 2243:5

view [11] - 1981:20, 1995:6, 1996:12,

2000:14, 2025:7, 2028:10, 2032:20,

2113:17, 2128:7, 2165:17, 2254:20

Vincent [1] - 2168:8

Vingerhoedt [1] - 2057:13

violation [2] - 1982:22, 2052:3

violations [1] - 2056:17

vision [4] - 2194:23, 2215:24, 2218:15,

2218:17

visionary [1] - 2193:6

visit [4] - 1984:24, 2064:18, 2116:4,

2182:18

visited [3] - 1994:16, 2018:7, 2182:4

visitors' [1] - 2138:17

vitae [1] - 2053:4

void [1] - 2003:2

VOISANGE [1] - 2134:25

Voisinage [1] - 2134:21

VOLUME [1] - 1971:8

volunteered [1] - 2183:14

VS [1] - 1971:5

W

wait [3] - 2035:25, 2051:17, 2125:18

waiting [1] - 2096:15

walk [1] - 2021:2

Wall [1] - 2103:1

Walter [1] - 1984:15

wants [3] - 1979:8, 2059:23, 2078:17

war [1] - 2004:12Johnny C. Sanchez, RMR, CRR - [email protected]

2291

warehouse [1] - 2208:20

Warren [1] - 1971:16

WARREN [85] - 1975:7, 1975:9,

1977:13, 1980:7, 1980:13, 1980:18,

1980:19, 1982:25, 1983:2, 1983:8,

1989:6, 1989:8, 1992:20, 2017:15,

2022:11, 2022:16, 2022:21, 2034:24,

2035:13, 2036:2, 2036:5, 2036:11,

2036:15, 2036:17, 2036:25, 2038:2,

2038:20, 2044:25, 2051:19, 2051:25,

2052:2, 2062:1, 2062:3, 2062:6,

2062:9, 2062:11, 2063:4, 2063:9,

2063:11, 2065:24, 2066:2, 2066:21,

2066:23, 2067:7, 2067:11, 2070:10,

2070:16, 2071:3, 2071:16, 2072:10,

2073:5, 2073:10, 2073:15, 2075:8,

2075:17, 2076:5, 2076:12, 2077:1,

2077:5, 2077:9, 2077:12, 2077:15,

2077:17, 2078:8, 2078:11, 2079:5,

2079:14, 2079:25, 2080:1, 2080:5,

2080:8, 2080:11, 2080:12, 2081:5,

2081:13, 2083:4, 2083:6, 2084:4,

2084:9, 2084:14, 2088:12, 2090:14,

2098:1, 2098:3, 2098:12

WARREN............ [2] - 1973:8, 1973:12

Washington [1] - 1971:18

waste [1] - 2210:8

watch [2] - 2059:23, 2098:18

watched [4] - 2179:23, 2214:10,

2214:11

water [3] - 2164:22, 2164:23, 2197:24

Waterhouse [3] - 2161:3, 2161:5,

2161:17

Watkins [1] - 2220:23

ways [4] - 1999:10, 2112:24, 2223:12,

2227:16

weakened [1] - 2071:22

weaknesses [1] - 2013:16

wealth [1] - 2146:17

wealthy [2] - 2165:9, 2220:2

wear [4] - 1999:17, 1999:24, 2000:2,

2039:20

wearing [4] - 1999:13, 2039:1,

2039:16, 2103:23

weather [1] - 2102:4

week [2] - 2026:1, 2035:19

week's [1] - 2035:19

welcome [2] - 2082:25, 2255:20

well-established [1] - 2053:5

well-publicized [1] - 2164:1

well-to-do [1] - 2195:15

Well-to-do [1] - 2195:17

West [10] - 2018:15, 2018:24, 2019:9,

2019:17, 2019:25, 2063:22, 2134:22,

2213:24, 2214:1

Westies [2] - 2019:20, 2019:23

whereby [1] - 2088:22

whipped [1] - 2020:8

whole [15] - 1983:14, 1987:15,

2019:19, 2030:17, 2030:19, 2065:12,

2121:24, 2139:19, 2159:22, 2162:7,

2162:8, 2213:25, 2216:14, 2217:6,

2217:13

Wicket [20] - 2081:18, 2081:20,

2081:21, 2081:23, 2082:4, 2083:12,

2084:10, 2084:11, 2084:25, 2085:12,

2085:13, 2137:1, 2139:13, 2211:13,

2213:6, 2213:8, 2214:22, 2215:13,

2243:3, 2249:14

wicket [10] - 2081:25, 2082:5, 2082:7,

2082:8, 2082:13, 2082:19, 2082:20,

2083:7, 2214:16

wickets [3] - 2082:3, 2082:10, 2082:14

wide [2] - 1979:18, 2007:3

wife [1] - 2166:20

wig [3] - 1999:13, 1999:21, 2000:2

wigs [2] - 1999:18, 2039:1

William [2] - 1971:16, 2039:7

willing [1] - 2120:3

Windies [1] - 2019:25

Winter [2] - 2046:7, 2047:3

winter [2] - 2053:2, 2053:14

winter's [1] - 2053:8

wish [1] - 2046:5

withdraw [1] - 2133:15

withdrawn [3] - 2245:23, 2245:24

WITNESS [48] - 1973:3, 1977:8,

1977:11, 1985:20, 1986:4, 1991:21,

1991:23, 1991:25, 1997:1, 2061:19,

2061:22, 2062:10, 2071:11, 2071:15,

2075:7, 2075:13, 2081:12, 2082:4,

2082:6, 2082:9, 2082:16, 2082:22,

2082:25, 2083:15, 2085:6, 2090:12,

2097:9, 2098:21, 2100:25, 2102:17,

2104:1, 2110:25, 2113:21, 2116:7,

2121:5, 2124:6, 2124:15, 2127:20,

2127:24, 2128:1, 2128:15, 2134:24,

2138:15, 2161:13, 2167:1, 2197:8,

2231:16, 2256:25

witness [25] - 1983:2, 1989:15,

1995:19, 2052:6, 2054:11, 2076:25,

2078:24, 2084:14, 2090:15, 2098:12,

2098:23, 2112:6, 2112:7, 2112:25,

2113:6, 2123:19, 2152:15, 2152:18,

2152:19, 2169:7, 2228:17, 2233:15,

2244:1, 2251:23, 2254:22

witness's [1] - 2079:3

witnesses [2] - 2037:23, 2098:17

wondered [1] - 2146:3

wonderful [1] - 2039:4

wood [1] - 2141:9

word [8] - 2001:23, 2010:11, 2134:24,

2180:1, 2200:19, 2200:20, 2214:5,

2248:9

word's [1] - 2205:4

worded [1] - 2238:19

words [4] - 1996:24, 2063:17, 2090:9,

2235:1

workers [1] - 2164:12

works [2] - 2009:1, 2227:16

world [27] - 1976:3, 1977:18, 2004:12,

2013:10, 2013:13, 2019:10, 2025:10,

2076:10, 2140:20, 2141:21, 2142:8,

2164:2, 2193:18, 2193:19, 2193:22,

2194:2, 2194:3, 2194:12, 2194:21,


2292

2221:25, 2234:18, 2234:21, 2236:17

world-class [2] - 2215:16, 2218:17

worth [6] - 2195:21, 2195:22, 2195:23,

2196:10, 2225:20

wound [2] - 2175:23, 2176:1

write [3] - 1999:9, 1999:10, 2227:12

writing [3] - 2005:19, 2034:15,

2044:10

written [1] - 2057:7

wrote [7] - 1999:14, 2007:5, 2016:2,

2040:8, 2183:8, 2185:1

Y

y'all [1] - 2189:22

yachts [1] - 2218:4

year [27] - 2026:13, 2028:12, 2028:17,

2029:1, 2029:9, 2030:7, 2030:8,

2032:22, 2040:4, 2043:8, 2090:9,

2101:22, 2102:16, 2130:10, 2154:4,

2154:18, 2154:20, 2156:18, 2164:3,

2167:24, 2177:1, 2182:16, 2185:11,

2239:25, 2244:14, 2249:10

years [55] - 1977:8, 2019:10, 2020:9,

2020:18, 2039:3, 2039:13, 2074:11,

2084:20, 2100:10, 2100:12, 2101:15,

2108:17, 2109:18, 2115:3, 2123:6,

2129:17, 2129:18, 2134:8, 2135:5,

2136:7, 2139:19, 2142:19, 2144:1,

2145:21, 2148:17, 2157:18, 2161:22,

2168:1, 2168:19, 2169:16, 2170:1,

2176:8, 2176:16, 2180:4, 2187:5,

2188:19, 2190:7, 2191:21, 2202:23,

2204:20, 2204:22, 2216:11, 2219:7,

2221:7, 2229:2, 2229:5, 2234:5,

2234:8, 2237:9, 2251:8, 2253:11,

2255:7

yesterday [4] - 2042:23, 2064:23,

2068:21, 2069:9

York [3] - 1971:17, 2220:19, 2220:20

yourself [4] - 2041:8, 2043:3, 2096:4,

2099:11

Z

Zealand [1] - 2020:6

zoom [6] - 1985:19, 2027:22, 2028:18,

2029:21, 2030:2, 2030:18

Allen Stanford Criminal Trial Transcript Volume 7 Jan. 31, 2012

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Transcript of Allen Stanford Criminal Trial Transcript Volume 7 Jan. 31, 2012