2011-12-19 Rothstein Scott AM

IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR

BROWARD COUNTY, FLORIDA
Case No. 09-062943 (07)
_____________________________________________________
RAZORBACK FUNDING, LLC, et al.,
Plaintiffs,
vs.
SCOTT W. ROTHSTEIN, et al.,
Defendants.
____________________________________________________
DAY 6 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN:
TIME:
PLACE:
December 19, 2011

8:35 a.m. James Lawrence King Federal
Justice Building
99 N.E. Fourth Street
Courtroom 11-3
Miami, Florida 33128
Examination of the witness taken before:

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

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IN THE CIRCUIT COURT OF THE 17TH

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

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

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

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

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2
3
4
5
APPEARANCES FOR SCOTT ROTHSTEIN:

LAW OFFICE OF MARC S. NURIK
1 East Broward Boulevard
Suite 700
BY: MARC S. NURIK, ESQUIRE
APPEARANCES FOR THE CHAPTER 11 TRUSTEE,
HERBERT STETTIN:
6
7
8
BERGER SINGERMAN
350 East Las Olas Boulevard
Suite 1000
BY: CHARLES H. LICHTMAN,, ESQUIRE
9
APPEARANCES FOR THE TRUSTEE:
10
11
12
13
14
15
16
17
18
19
20
21
22
GENOVESE, JOBLOVE & BATTISTA, P.A.

100 S.E. 2nd Street
Suite 4400
By: JOHN. H. GENOVESE, ESQUIRE
DAVID C. CIMO, ESQUIRE
THERESA M.B. VAN VLIET, ESQUIRE
JESUS SUAREZ, ESQUIRE
APPEARANCES FOR RAZORBACK:
CONRAD & SCHERER, LLP
633 South Federal Highway
Eighth Floor
By: WILLIAM R. SCHERER, ESQUIRE
ERIC RAYMAN, ESQUIRE
IVAN J. KOPAS, ESQUIRE
and
KOZYAK, TROPIN & THROCKMORTON, P.A.
2525 Ponce de Leon Boulevard
Ninth Floor
Coral Gables, Florida 33134
By: HARLEY S. TROPIN, ESQUIRE
23
24
25
APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

CENTURION STRUCTURED GROWTH, LLC:
GOLDSTEIN, TANEN & TRENCH, P.A.
One Biscayne Tower, Suite 3700
One Biscayne Tower, Suite 3700

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2
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6
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Two South Biscayne Boulevard

By: SUSAN E. TRENCH, ESQUIRE
DONNA EVANS, ESQUIRE
APPEARANCES FOR LEVINSON'S JEWELERS:
KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL
200 SW 1st Ave
Suite 1200
BY: JAN ATLAS, ESQUIRE
APPEARANCES FOR THE COMMITTEE OF
UNSECURED CREDITORS:
8
9
10
AKERMAN, SENTERFITT
One Southeast Third Avenue
25th Floor
Miami, Florida 33131-1704
By: MICHAEL GOLDBERG, ESQUIRE
11
APPEARANCES FOR T.D. BANK:
12
13
14
15
GREENBERG TRAURIG, P.A.

401 E Las Olas Blvd Ste 2000
By: HOLLY SKOLNICK, ESQUIRE
APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,
COLUMBIA INC. & ZURICH INSURANCE:
16
17
18
CLAUSIN MILLER
One Chase Manhattan Plaza
39th Floor
New York, New York 10005
BY: SCOTT L. SCHMOOKLER, ESQUIRE
19
APPEARANCES FOR FEDERAL INSURANCE COMPANY:
20
21
22
ALEX HOFRICHTER, P.A

1430 South Dixie Highway
Suite 204
Coral Gables, Florida 331463127
By: ALEX HOFRICHTER, ESQUIRE
23
24
25
APPEARANCES FOR MORSE:

TRIPP SCOTT, P.A.
110 S.E. Sixth Street,15th Floor
By: GEORGE WALKER, ESQUIRE
By: GEORGE WALKER, ESQUIRE

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2
JOHN M. MULLIN, ESQUIRE

APPEARANCES FOR CAROL MORSE, TED MORSE & MORSE
OPERATIONS:
3
4
5
LAW OFFICES OF ROBERTA DEUTSCH

2499 Glades Road
Suite 110
Boca Raton, Floridan 33431
By: ROBERTA M. DEUTSCH, ESQUIRE
6
7
8
APPEARANCES FOR EMESS CAPITAL, LLC:

KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL
201 S Biscayne Blvd Fl 17
BY: CASEY H. CUSICK, ESQUIRE
9
APPEARANCES FOR ST. PAUL FIRE & MARINE:
10
11
12
MILLS PASKERT DIVERS P.A.

100 N Tampa St Ste 2010
Tampa, Florida 336025145
BY: JOHN A. BLACK, JR., ESQUIRE
13
APPEARANCES FOR ROSEANNE CARETSKY:
14
Billing Cochran Lyles

515 E Las Olas Blvd
Floor Six
By: DAN GELBER, ESQUIRE
APPEARANCES FOR PLATINUM & CENTURION:
HARVEY WERBLOWSKY, ESQUIRE
APPEARANCES FOR FEPICT, MS GROUP:
NYSTROM, BECKMAN & PARIS
One Marina Park Dr., 15th Flr.
Boston, MA 02210
By: JACK SEIGAL, ESQUIRE
15
16
17
18
19
20
21
22
23
APPEARANCES FOR MICHAEL SZANFRANKSI:

LYDECKER, DIAZ
1221 Brickell Avenue
Floor 19
BY: CHRISTOPHER G. BERGA, ESQUIRE
MIGUEL J. CHAMORRO, ESQUIRE
24
25
APPEARANCES FOR GIBRALTAR:

STEARNS WEAVER MILLER, et al.
150 W Flagler St Ste 2200

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2
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BY: MARY BARZEE-FLORES, ESQ.
MATTHEW DATES, ESQUIRE
APPEARANCES FOR FRANK PREVE:
PODHURST ORSEK
BY: RAMON A. RASCO, ESQUIRE
5
6
7
8
APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

WATCH U-WANT, INC.:
KOPELOWITZ OSTROW
200 SW 1st Ave Ste 1200
By: BART A. HOUSTON, ESQUIRE
9
APPEARANCES FOR THE US GOVERNMENT:
10
11
99 N.E. 4th Street

BY: LAWRENCE LAVECCHIO, ESQUIRE
12
13
14
15
16
17
APPEARANCES FOR FRANK SPINOSA:

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

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INDEX
CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN
3
4
DIRECT
1395
1470
Mr. Berga
Mr. Rasco
5
6
CERTIFICATE OF OATH
CETIFICATE OF REPORTER
1537
1538
7
8
9
10
11
SZAFRANSKI'S EXHIBIT INDEX

NO.
202
203
204
205
DESCRIPTION
April 15, 2008, Email
February 24, 2009, Email
August 7, 2009, Email
Document
PAGE NO
1426
1428
1431
1431
12
13
14
15
16
17
18
19
20
21
22
23
24
25

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Thereupon, the following proceedings were had:
MR. BERGA:
THE WITNESS:
Good morning?
Good morning.
Whereupon,
SCOTT W. ROTHSTEIN,
acknowledged having been duly sworn to tell the truth
and testified upon his oath as follows:
THE WITNESS:
9
10
I do.
DIRECT EXAMINATION (SCOTT W. ROTHSTEIN)

BY MR. BERGA:
11
Good morning, Scott.
12
Good morning.
13
My name is Chris Berga.
I'm with the law firm
14
of Lydecker Diaz and I'm here on behalf of Michael
15
Szafranski.
16
Good morning.
17
Obviously, we're going to continue on with our
18
allotment of time.
19
couple of times.
So I'll try to bounce around a

Just bear with me.
20
Okay.
21
When did you first meet Mr. Szafranski?
22
I don't know the time frame.
I believe it was
23
sometime in 2008 when the hedge funds asked him to be
24
the third-party verifier.
25
Who introduced you to Mike?

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The exact person, I don't recall,
specifically, at this moment; somebody from the hedge
funds.
And whose idea was it to get Szafranski
involved?
To my knowledge, it was the hedge funds.
And when you say "hedge funds," can you be
8
9
specific?
A
I'll refer to them as Centurion, Platinum and
10
Level 3, although I don't think Level 3 was involved at
11
that point in time.
12
13
Do you know who specifically from Centurion
Platinum requested Mr. Szafranski be involved?
14
I have a pretty good idea.
15
Can you tell me?
16
Sure.
Someone in the back room, meaning, to
17
my knowledge, Mr. Jedwab, had suggest we get a
18
third-party verifier.
19
20
Jack Simony subsequently came to Mr. Preve and

I and said, the guys want a third-party verifier.
21
22
23
Jack's initial statement to me was it could be

anybody.
Quickly thereafter -- and this should be clear
24
in the emails, quickly thereafter they said it can't be
25
anybody; this is who we want to use.

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And so that would have come to me, likely --
most likely, through Jack Simony, because he was the,
quote, unquote, hand-holder at that point in time.
He was the hand-holder on behalf of the fund?
To my knowledge, as far as I was concerned,
Do you recall the first time you actually met
Szafranski?
I do not.
10
Do you recall where you met Szafranski the
11
first time?
12
I do not.
13
When you found out about Szafranski and his
yes.
14
involvement at the request of the funds, what was it
15
that you did?
16
Initially, I freaked out.
17
Why?
18
Because I didn't want anyone doing any type of
19
verification if I didn't have to have anyone doing any
20
type of verification; and it seemed to me, okay, from
21
the landscape that I was dealing in, that more eyes --
22
the more eyes, the worse it is for what we were doing.
23
So I didn't want anyone else looking at it.
24
Okay.
25
Initially, yes, absolutely, I was.
So were you opposed to it?

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Did you voice your opposition to anybody?
I know I voiced my opposition to Frank.
recall a couple of conversations where I voiced my
opposition to Jack; but beyond that, no, not to my
knowledge.
recall Frank and Jack.
I may have dealt with someone else, but I
When you say "Frank"...
I can only give you approximate language.
9
10
11
12
13
can't tell you exactly because it was too long ago.

Q
Give me what the approximate language would
be; do you remember?

A
What the hell are they trying to do, this is
going to create problems for us, something around that.
14
What did you say to Jack?
15
I don't recall.
16
same lines.
It would have been along the
17
I would have pointed out -- if I did, in fact,
18
say something to Jack, I would have pointed out the fact
19
that he said, originally, we could use anybody and then
20
specifically brought somebody in; but I don't have a
21
specific recollection.
22
Now, when they brought Szafranksi in to do the
23
verifications, what was it that Szafranski was supposed
24
to do?
25
He was supposed to initially -- I seem to have

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a recollection of it changing over time, increasing, so
I could best give you what he was ultimately able to do.
Initially, I don't recall specifically.
have check the emails.
clean -- pretty clear to me.
You'd
It's out in there pretty
Who have been the individuals or entities that
would have established what Szafranski was required to
do?
It would have been what I was calling "the
10
Murray entities."
11
entities would have done it.
I don't know which one of the
12
13
mean to you?
14
Platinum, Centurion and Level 3.
15
Now, was Szafranski, was he required to verify
When you say "Murray entities," who does that
16
that the settlement agreement contained the signature
17
for both the plaintiff and the defendant?
18
He was.
19
When you say "ultimately," why do you make
20
21
Ultimately, he was, yes.
that distinction?
A
Because I seem to recall there being different
22
levels of due diligence before it got to what I would
23
consider the maximum due diligence by Szafranski.
24
wasn't that far in.
25
It
Ultimately, his job was to verify plaintiff's

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signature and defendant's signature.
2
3
When you say "far in," what do you mean by
"far in"?
I can't tell you.
Without seeing emails and
the like, it's impossible for me to place it in time
frame.
There was too much going on.

When you use the term "far in," are you
talking about timing?
Timing.
10
Now, that would have been timing of the entire
11
scheme or timing of Szafranski's involvement?
12
13
Timing of Szafranski's involvement.

It was like a polishing.
They had given him
14
an initial job to do; and I think, as they saw potential
15
loopholes, potential things they were missing, they were
16
cleaning it up as they went.
17
18
Okay.
When you say "they," you continue to
refer to the Murray entities?
19
I'm referring to whoever was calling the shots
20
back at the hedge funds.
21
you.
22
Specifically, I couldn't tell
But to the best of your belief, it would have
23
been Simony, or who would it have been, to the best of
24
your belief?
25
Who did I believe?
I believed it was Jedwab

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and Kalter; then Nordlicht and Glass, to a little bit of
a lesser extent.
You said Nordlicht?
Nordlicht and Glass, to a lesser extent.
So it's your testimony that they would have
been the ones calling the shots as to what the
verification process entailed?
to me to be.
10
11
12
It's my testimony that that's what it appeared
I have no idea what was actually going on

behind closed doors.
Q
Now, was Szafranski also required to verify
13
the daily transfer agreement, changes that contained a
14
signature for the plaintiff?
15
I would have to see the emails.
I would have
16
to see the emails exactly.
17
all of the documents to make sure that documents were
18
executed.
19
He was supposed to look at
Now, was he also required to verify that the
20
settlement amount had been wired to the purported
21
defendant's trust account?
22
Yes, he was.
23
Was he also required to verify that the
24
purported plaintiff had received the amount funded by
25
the investor?

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2
3
4
Yes.
The wire went out to the plaintiff;
that's correct.
Q
Was he also required to verify that the
balances were, in fact, in your firm's accounts?
He was.
You listed about four or five things.
7
8
9
Was he
required to verify any other piece of information?

A
At various points in time, he was advised by
the hedge funds to do follow-up.
He was -- at one point
10
in time, he was supposed to go in the court files, do
11
some kind of search to see if he could find any of the
12
plaintiffs' names or defendants.
13
There was one point in time when he was asked
14
to see if he could find a link between the plaintiffs
15
and defendants, and he made up some nonsensical story
16
that he told back to the hedge funds that he had, in
17
fact, found a link between several of the plaintiffs and
18
several of the defendants; which, of course, is
19
impossible because, at the very least, there were no
20
real plaintiffs.
21
22
23
He, additionally, at certain points in time -what else was he looking at?
He was supposed to try to get involved in one
24
of the negotiations.
25
That may have been, actually, for Damson.
I don't remember who this was for.

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But there was a point in time when he was
supposed to try to listen to some of what I was doing,
and he did, in fact, tell them that he did.
4
5
6
So that's all I remember at this moment.

Q
Okay.
When you say "negotiations," what
negotiations are you talking about?
Negotiations for the settlement?
Yes.
And that would have been with who?
10
11
Who would
you have been negotiating with.

A
12
I don't even know who it was.

I think, my recollection is -- from the emails
13
was, that it was a defense lawyer, that he was actually
14
supposed to be listening to the negotiations.
15
16
17
18
Now, did there ever come a point in time that
Szafranski went to your office to do the verifications?

A
He always came to my office to do the
verifications.
19
They were always done at your office?
20
When was he was really verifying, sure.
21
As opposed to when he wasn't verifying?
22
Well, there was a point in time when he was
23
really attempting to verify.
24
time when he was, what I'll call "psuedo-verifying": he
25
wasn't really verifying anything.
Then there was a point in

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Then there was a point in time when he stopped
showing up at the office.
he did show up and times when he didn't.
Okay.
I mean, there were times when
So let's go back to something you said.
There was a point in time when he was attempting to
verify, and there was a point in time when he was doing
psuedo-verification, as you call it.
Mhm-mhm.
So how do you distinguish between attempting
10
11
That's correct.
to verify and psuedo-verification?

A
The difference is depending upon what he knew
12
at that moment; the difference is, is whether he knew
13
there was a fraud going on or whether he didn't.
14
So when Frank was brought in to verify the
15
purported settlements by the hedge funds, did he know
16
that there was a fraud going on?
17
Initially, no, not to my knowledge.
18
Did you do anything to prevent Szafranski from
19
knowing that the settlements were fictitious?
20
In the beginning, sure.
21
What did you do?
22
I used a -- we had the same fake TD website
23
that we had created early on, took him to the bank, did
24
the show for him there.
25
You took him to the Weston branch?

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2
3
Yes.
Hang on.
I want to make sure there is nothing
else we did.
We also showed him documents, but I don't know
that that was -- I mean, that was attempting to go make
it look like there was nothing going on, but
unfortunately, we only had one or two signors.
8
9
10
So, ultimately, I did see a couple of

packages.
You can tell that the signatures are the
same.
11
But that's basically what we did.
12
And I, of course, discussed cases with him and
13
the like.
14
15
talk about?
16
Just the general nature of the case.
17
So from the moment you met Szafranski, did you
18
And when you discussed cases, what did you
ever provide him with any benefits?
19
From the moment?
20
Yes.
21
Early on I would have done the same thing with
22
him that I had done -- I did, in fact, do the same thing
23
with him that I had done with innocent investors.
24
is entertain them.
25
entertainment group, for lack of a better phrase.
That
So he was part of the -- I guess the

That,

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of course, escalated later; but early on, that's what it
was.
Did you ever give him any cash?
Early on, no.
Later on, though?
Later on -- the only time I recall giving him
cash was in a strip club.
payments to him, as I did with other individuals.
I didn't make any large cash
So --
10
Everything was done by check.
11
Did you give him cash in the strip club?
12
Yes.
13
What was that for?
14
A stripper.
15
Ever buy him any drinks?
16
Ever?
17
Yeah.
18
In the strip club or in general?
19
Anywhere.
20
Sure.
21
How many --
22
Frequently.
23
How many times?
24
How many times?
25
Yeah.
Generally.

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I would be guessing.
How about any meals?
Again, I would be guessing.
You ever take him to any sporting events,
games?
Sure.
How many?
You'd have to check the records.
9
10
you for certain.

Q
Over 100.
Dozens.
I can't tell
Over a dozen, I'm certain.
Now, was anybody else present with you when
11
you took him to these games or bought him these meals or
12
bought him these drinks?
13
Yes.
14
Who would have been present?
15
At the games, you'd have to look at the list.
16
The list exists at the -- in the firm's records as to
17
who was coming to the Dolphins games.
18
19
20
But you can't recall independently who would
have been at the games with you?

A
I can start.
My wife, Kimberly.
21
was at a lot of games when Mike was there.
22
was there when Mike was there.
23
when Mike was there.
24
were there when Mike was there.
25
Amy Howard
John Harris
Frank Spinosa was there
Various members of law enforcement
Can you name those?

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Ted Morse was there every -- every time, I
think, just about, that Mike was there.
Ron Pecou, from time to time.
And this would have been at Dolphin games?
Hang on.
I'm still going.
Yeah.
Ira Sochet was there on at least one occasion
when Mike was there.
Who else did we invite?
10
11
You know I invited -- Frank Adderley may have

been there when he was there.
12
13
These are Dolphins games.
You have to look at the pictures from the

game.
We frequently took pictures.
14
Amy Howard may have a better recollection than
15
I do, but there were lists that were circulated before
16
the game as to who we were taking.
17
16 tickets in our suite, and then we generally purchased
18
an additional four to six additional suite passes, so it
19
was a very large crowd.
20
Because you have got
There was a time when Gil Kalter came.
I'm
21
certain that Mr. Szafranski was there when Gil was
22
there.
23
24
25
How about any fundraisers or political events,
did you take him to any of those?

A
Yes.

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How many times?
I don't recall the specific number.
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
You'd
have to look.
Q
Is there anybody that would have been with you
when you took him to a political event?

A
Likely hundreds of people.
You have to look
at an event list.
Q
Well, I understand that, but people that he
took with him?

A
Most of the time I was throwing the event, so
you'd have to look at the event list.

Q
You can't recall any event in particular,
though?
A
I mean, we could be here all day if I do this.

The Alex Sink event he came to.
I remember
seeing the picture not that long ago.

Again, you look at the donor list and who was
there, that will tell you, instead of having me guess.
He was at one of the McCain events; again,
same thing.
21
The easiest way for you to track it would be
22
to take a look and see who he wrote checks to and then
23
look at the guest list.
24
that would be able to say they were there at the same
25
time he was there, but I do not want to guess.
You'll find plenty of people

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Well, I'm not asking to you guess.
Well, the problem is -- and I don't mean to
give you a hard time about this.
involved in dozens of these, and they all kind of meld
together after a while.
The problem is, I was
Which ones he was specifically at, the easiest
thing is to simply look at the attendance lists for each
event.
Now, Scott, can you identify for me, like, all
10
the people who testified Szafranski knew the settlements
11
were fictitious?
12
13
14
15
MR. LICHTMAN:
Can I hear the question
back?
BY MR. BERGA:
Q
16
Sure.
Can you identify all the people who would
17
testify that Szafranski knew the settlements were
18
fictitious?
19
All the people that I know knew?
20
Yes.
21
Myself.
22
This is assuming they're going to tell the
23
truth, right?
24
tell you that Frank Preve knew, but my understanding is
25
Frank has his own issues.
I mean, because I don't know -- I could
So I don't know what he is a

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going to say.
Anybody else?
Just give me a moment.
If these people told the truth, they would be
able to tell you that he was in, to some extent.
They
might not be able to tell you specific knowledge.
It
would be Preve, Ted Morse, David Boden, Irene Stay, Stu
Rosenfeldt.
9
10
11
That's all I recall at the moment.
There may
be more.
Q
So it's your testimony, sir, that each of
12
these individuals that you listed -- Preve, Morse,
13
Boden, Irene Stay, Stuart Rosenfeldt, each of these
14
individuals knew that Szafranski knew that the
15
settlements were fictitious?
16
No.
If you listen to my answer, I said, knew
17
that there was some kind of fraud going on; I don't know
18
the extent of their knowledge.
19
20
21
22
23
So they knew that Szafranski knew that there
was some kind of fraud going on?

A
They knew that Szafranski was involved in a
fraud with me.

Q
Did you -- let's take it -- for each of the
24
individuals that you listed, same question:
25
ever have any discussions with any of these individuals
Did you

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regarding what Szafranski purportedly knew?
With Boden, yes.
When did that happen?
Hang on a second.
Do you want the list or did
you want -- I don't know --
ahead.
Boden, Preve, Rosenfeldt, Morse.
But not with Irene?
10
Hang on.
11
I'm sorry.
You want to give me the list?
I'm thinking.
Hang on a second.
I had conversations with Irene that should
12
have indicated to her that he was involved.
13
I'll say Irene, also.
14
15
16
Go
So let's start with Preve.
So, yeah,
What did you
discuss with Preve regarding Szafranski's knowledge?

A
The only thing that I specifically recall
17
discussing with Frank is towards the middle to end of
18
2009, meaning middle of the year up until the time that
19
the Ponzi scheme exploded, at the end of October, Preve
20
and I had several conversations where we were discussing
21
whether or not we would have a problem with Szafranski
22
at any level if the thing did blow up.
23
Frank and I also used to joke around about the
24
fact that Szafranski was making a ridiculous amount of
25
money and sometimes we couldn't even get him to come to

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the office to do the, quote, unquote, verification.
Does that finish your answer?
My recollection is, is that there are some
emails that indicate that Szafranski was in the know,
also; but I would have to see those emails to tell you.
At this moment, that's all I recall.
I want to go back to something that you said
that you discussed with Preve regarding when he would be
a problem.
10
11
When you say "a problem," what did you mean?

A
Well, if you take a look at the email traffic
12
between Frank and I, there are at least semi-regular
13
discussions between Frank and I about particular problem
14
issues that would come up with regard to trust account
15
balances, auditors and the like.
16
conversations I had with Frank where we were discussing
17
who we could bring, for example, to meet with Larry
18
Rovin, the auditor for Bekkedam and for Ballamor.
19
And there were several
And Szafranski was considered to be a solid
20
proponent of what we were doing, that he would be able
21
to pull it off if he needed to meet with the auditors to
22
explain discrepancies and the like.
23
24
25
And this was at the middle to late '09 when
the scheme was blowing up?

A
The scheme was blowing up at the end of '09.

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It would have been maybe a little earlier; but, again, I
would be guessing.
Morse?
Okay.
What discussions did you have with
The discussions I had with Morse circled
around the amount of money I was paying Szafranski.
There were times when Mr. Szafranski was out
with Mr. Morse and I, whether it be a strip club or
dinner or something, and Ted used to joke around about
10
the fact:
11
tab?
You know, is he going to pick up the tab?
12
13
I said, I don't know.
I'm paying the guy
millions of dollars.
14
15
I mean, is Mike ever going to pick up the
And Ted would joke around with me:

one of your little henchmen?
16
Oh, is he
That type of stuff.
And there were also occasions where I told --
17
and where I told Ted not to worry about Mike when it
18
came to what he knew and didn't know, because Mike was
19
frequently sitting at the table with us when we were
20
having discussions of a -- at least a semi-private
21
nature.
22
Sitting at the table with you and Ted Morse?
23
Yes.
24
And you had discussions -- as Mike was
25
sitting, you'd be discussing parts of the fraud, parts

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2
3
4
of the scheme?
A
No.
I would be discussing other things that I
was doing on behalf of Morse.

Q
Such as?
Why would Morse be concerned that he was at
the table?
Morse would be concerned he was at the table
because, from time to time, Morse and I would discuss
things.
For example, there was some things going on
10
with his father, with Ted's dad, okay, and there were
11
times when these conversations came up when Szafranski
12
was at the table with us.
13
Szafranski -- whenever we came downstairs --
14
you have to understand, Szafranski had an office in my
15
office.
16
was heading down to Bova to go have my cocktails with
17
friends, me, Ted, for a cigar, Szafranski was with us.
18
So there came a point in time that whenever I
And I think Ted was getting a little bit
19
annoyed that Szafranski was with us constantly.
20
regularly had to tell Ted, don't worry about it,
21
Szafranski is a good guy.
22
23
24
25
And I
That type of stuff.
Other than that, I don't recall any

conversations, specifically.
Q
But Mike's office, he was in the same building
as yours or in your office?

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No.
Where was that located?
It was on another floor from me.
I gave him an office.
remember what floor it was.
on 22.
I was on 16.
I don't
He wasn't up
He may have been on 15.

What I had done was, I had given him -- as a
perk for his assistance, because he was bringing
investors in and the like, I gave him an office on one
of the other floors.
10
We set him up with a computer
there and a TV and the like.
11
12
Boden.
13
Same line of questioning with respect to Mr.
Boden, I specifically told him, I said, if you
14
need to do any of the those verifications for Ritchie's
15
people, Szafranski knows how it works, don't worry about
16
the signatures or anything.
17
extensive conversation with Boden.
18
19
It was a much more
Extensive in the sense that you discussed
Szafranski's knowledge?
20
Yes.
21
How many times did that happen?
22
Not more than half a dozen.
23
24
25
David wasn't the
kind of person you needed to repeat things to.

Q
Anybody else that would have been present
during your conversations with Boden when you were

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talking about Szafranski?
I don't recall, specifically.
How about Irene Stay?
There were times when I told Irene -- when she
thought she had to get certain information to Mike with
regard to the account balances and the like, that I
specifically told her, don't worry about it.
good.
You don't need to get him that type of stuff.
9
10
She would usually say things like:

sure?
It's fine.
Mike's fine.
Don't worry about
Mike.
13
14
Are you
Are you sure we don't need --
11
12
He's all
Did you discuss the fact that he actually knew
that the settlements were a fraud?
15
Here's what I think I need to square away for
16
you.
17
again, I don't know if you were present for my testimony
18
last week.
When we are talking about the fraud, okay --
19
When you're talking about the fraud, we don't
20
say, hey, let's go talk about the fraud.
21
Ponzi scheme going?
22
That's not what it is.
23
Hey, how's the
Does Mike know about the fraud?
Irene is asking me about -- this is a good
24
example.
25
that if Mike was representing -- was legitimately doing
Irene is asking me about a legitimate document

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third-party verification, he would have needed to see.
2
3
Irene says, I forgot.

document to -- to Mike.
4
5
Don't worry about Mike.
At that moment, you know that Mike is in the

know.
8
9
10
Mike doesn't need to
see that.
6
7
I have got to get this
David Boden says to me, We need a third party

to verify this.
What are we going to do?
Are we going
to bring somebody new in?
11
No, no, no.
12
knows what to do.
13
need.
Mike is with the program.
He
Just talk to Mike about what you
He'll handle.
14
It.
That would be the type of conversation.
15
There were no conversations that were in details saying,
16
okay, this is what we're going to do to perpetrate the
17
fraud.
18
That's not the way we spoke.

Okay.
When you say, "you know," you talked
19
about something that you know, not necessarily something
20
Irene Stay would know?
21
Well, Irene moved hundreds of millions of
22
dollars for me, illegally, over a several-year period of
23
time.
24
definite and specific knowledge about what was going on
25
in the law firm.
So I have a pretty good idea that Irene had

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We had an investment scheme going on where
there were payments supposed to be made out to
investors.
investor -- in this case, Mr. Preve -- to tell us what
needed to be paid, because we failed to keep detailed
track of it.
Okay.
She knew she had to wait for the
There were lots of more-than-significant
indications that what we were doing was a fraud, besides
the fact that Irene also knew that we were laundering
10
all kinds of campaign money through the firm, checks
11
sent out.
12
There was all kinds of things that tell you
13
what level a, quote, unquote, player each person is, as
14
we were using the term last week.
15
16
Rosenfeldt?
17
And the last person you mentioned was
Rosenfeldt came to me, May, June -- I'm not
18
going to remember the month; I don't want to guess --
19
but came to me after looking at our financials and
20
seeing millions of dollars in checks being written out
21
to Szafranski and wanted to know what the heck they were
22
for.
23
24
25
I said, are you happy with the amount of money

you're making?
He said, yeah.

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Well, that's what it's for.
to the money.
service.
It's all related
Szafranski is providing a very valuable
Leave it at that.
How many times did that conversation happen?
I don't believe it happened more than once.
don't think he ever asked me again.
Did you talk about anything else?
With Rosenfeldt?
Yes.
10
About the fraud?
11
With respect to Szafranski.
12
Ever?
13
I may have.
14
The best thing for you to do with regard to
I have got to think about it.
15
all these people would be if you have email traffic
16
between me and him regarding them -- between me and
17
those people regarding Szafranski, it would be good to
18
refresh my recollection so that I could give you
19
accurate information.
20
21
of people.
22
Sure.
23
Essentially the same question is going to be
Okay.
I would like to take you through a list
24
posed for each individual, and that question would be
25
whether or not you ever had any discussion with this

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particular individual that Szafranski knew the
settlements were fake or fraud.
Okay?
Sure.
Debra Villegas?
Specific conversation with Debra, no.
Marybeth Feiss?
I don't recall any.
8
9
You know, I may have had conversation with

Deb, but I really don't recall any.
10
Deb was so deeply involved with me that I
11
think it probably would have been obvious to her; I
12
didn't need to tell her anything.
13
But no specific discussions?
14
It's hard to say specific discussions, because
15
if you know how my office was set up, even when --
16
before I had that inner-sanctum thing going on, Deb's
17
office was always right outside my office, and we were
18
constantly interacting.
19
So if there would be -- it's possible, but I
20
don't -- I don't have a specific recollection as I sit
21
here today of a specific conversation, because there was
22
so much conversation.
23
Deb was the one person that I probably spoke
24
to more openly than anyone else about the nature of what
25
we had been doing.

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But as you sit here today, you don't have an
independent recollection of having a discussion with
her?
No.
If I recall anything else, I'll let you know.
How about -- you said no to Marybeth Feiss.
I don't recall any.
How about William Boockvor?
I wouldn't have talked to Bill about it.
10
So your answer is no?
11
My answer is I wouldn't have talked to Bill
12
13
14
about it.
Q
I didn't say no.
Other than that, I can't tell you.

So -- but the question is, did you have any
discussion with any of these individuals?
15
Well --
16
So it's either you had a conversation or you
17
18
didn't.
A
19
No.
No.
The problem is, is that I was dealing with a
20
lot of people.
21
a lot of conversations with a lot of people, some about
22
legitimate things, many about not-legitimate things.
23
24
25
Things were moving very fast, and I had
So it's possible that I had a conversation; I

just don't specifically recall one.
Q
How about Mr. Adler?

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No.
William Corte?
No.
Curtis Renie?
No.
Frank Preve?
Yeah.
George Levin?
No.
10
Jack Simony?
11
No.
12
Brian Jedwab?
13
No.
14
Gillad Kalter?
15
No.
16
Ari Glass?
17
No.
18
Ben Radinsky?
19
Who?
20
Ben Radinsky?
21
I don't recall who that was, so no.
22
Murray Huberfeld?
23
I never spoke to Murray.
24
So the answer is no?
25
The answer is no.
We covered him already.

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Mel Lifshitz?
No.
Mel Lifshitz?
There was some very odd emails going back and
forth between Lifshitz and Szafranski.
a look at those, but I didn't specifically have a
conversation with Mel about it.
7
8
9
You need to take
You never had any discussions with him
regarding what Szafranski's knowledge was?

A
I had discussions with Mel about Szafranski in
10
general, and I had several conversations with
11
Mr. Lifshitz where I was very concerned that he knew
12
what was going on.
13
there are emails back and forth between Mr. Lifshitz and
14
Michael Szafranski where the questioning is fairly
15
heated and where it appears that Mr. Lifshitz may
16
believe Mr. Szafranski is involved in something
17
inappropriate.
18
I don't have a specific recollection.
And my recollection is, is that
But you'd have to go read those emails.
19
Did you ever determine what Mr. Lifshitz knew?
20
Well, I wasn't concerned about Szafranski.
21
know what he knew.
22
So yes, Mr. Lifshitz.
23
How about Ira Sochet?
24
I don't think Ira ever knew, and I certainly
25
didn't have that conversation with him.

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Barry Damson?
No, sir.
Kathleen White?
No, sir.
Richard Pearson?
No.
I never had those conversations with
Richard.
A.J. Discala?
No, sir.
10
Jim Parrish.
11
I don't know who that is.
12
Oh, wait.
13
No, I never had any conversation with him
14
No, he worked for Canvass.
about Mr. Szafranski's knowledge.
15
How about Frank Spinosa?
16
No.
17
Rosanne Caretsky?
18
No.
19
Jennifer Kerstetter?
20
No.
21
Ricardo Mejia?
22
Oh, the bank guy, no.
23
Matthew Brennan?
24
Who is that?
25
Did you have any discussions with him?

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2
3
Matthew Brennan?
I think he was a friend of mine that tried to
sell me insurance.
No.
THE WITNESS:
MR. BERGA:
(Thereupon, the document was marked as
Do you want to mark this?

Yes.
Please.
Szafranski's Exhibit 202 for Identification.)
BY MR. BERGA:
Exhibit 202 for the record, it's an email
10
dated April 15th, 2008.
11
Barber and Jason Pinewski, and it's -- let me know when
12
you're done reviewing it.
13
I am.
14
Okay.
It's Gilad Kalter to Isaac
This April '08, would this have been
15
about the time that Szafranski became involved in the
16
verification process?
17
18
19
20
I don't remember specifically when he got
involved.
Q
It is your testimony that he became involved
through the funds, correct?
21
Correct.
22
And Gilad over at Centurion LOC would have
23
been one of the people involved in the fund?
24
Sorry.
25
Gilad Kalter, he was an individual involved
Say that again.

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with the funds, correct?
Centurion.
My understanding was he was an officer of
Now, Scott, I don't know if you remember:
think the first day of your depo you testified:
point in time -- and I'll read to you your testimony:
At some
"At some point in time, Szafranski -- it was
at the time that -- it actually was at the time, if I
remember correctly, when the hedge funds had basically
10
cut us off.
11
Mike said to me directly, if the hedge funds
12
aren't going to fund because I believe he had some kind
13
of prohibition about or he believed there was some kind
14
of conflict about bringing in investors while they were
15
still actively investing, although I do believe they
16
were still investing.
17
permission to bring in people, because he said to me,
18
dead out.
19
investors, I'll bring in my people.
But I guess he got their
20
If they're not going to be bringing in new
And my response to him was, I mean, Mike you
21
know there's no plaintiffs; you still want to bring
22
people in?
23
money.
24
25
He goes, yeah, everybody is making a lot of
I'll bring people in.
And he did."
Now, when did that conversation take place?

A
Tell me the day they cut me off?

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It would have been the date they cut you off?
No, not the day, it would have been around the
time that they either stopped or slowed their funding.
And when would that have been?
I don't recall specifically.
Sometime in '09?
Would it have been sometime in '08?
10
How about in '07?
11
It wasn't '07.
12
Did you ever tell anybody that you had that
13
conversation with Szafranski?
14
No.
15
Did Szafranski ever say anything else to you?
16
Actually, that's not true.
I did tell Frank
17
Preve that they were going to be getting money in from
18
people.
19
Szafranski knew nothing further than that.

You can tell when it was.
All you got to do
20
is look at the first S1 deal.
21
conversation within several weeks prior to that.
22
23
MR. BERGA:
Okay.
It would have been a
Give me one second.
I'll see if I can get that for you.
24
THE WITNESS:
25
(Thereupon, a document was marked as
Sure.

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Szafranski Exhibit 203 for Identification.)
MR. CHAMORRO:
record.
THE WITNESS:
MR. BERGA:
6
7
Oh, are we done with 202?

Yeah, we're done with 202.
Thanks.
BY MR. BERGA:
8
9
Exhibit 203 for the
So, for the record, this is Exhibit 202.
It's an email from you to Mike dated February 24th,
10
2009, and the subject matter you see there is S1.
11
that the document you're referring to?
12
Yes, sir.
13
Okay.
14
So this would have been the first deal,
as you mentioned?
15
16
Is
It looks like it is.
Yes, sir.
So this would
clarify the date.
17
The conversation that I had with Mike would
18
have occurred, let's say, a month or so prior -- maybe
19
not even that far back -- but right in this time frame.
20
21
Now, before having that conversation with you,
Szafranski knew the settlements were fictitious?
22
By that time, yes.
23
When you say "by that time," what time is
24
25
that?
A
By February 24th, 2009, Mr. Szafranski knew

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the settlements were fictitious.
Did you happen to have any specific
conversations with Szafranski discussing the fictitious
nature of the settlements?
5
6
A
for me.
7
8
I don't understand what you're asking me.

Yeah.
I mean, did you ever sit down and talk
with Mike and say, you know, this is what's going on?
9
10
You are going to have to clarify that question
I never had that conversation with anybody in
that nature:
11
Hey, this is what's going on.
There came a point in time when Mike realized
12
that there were -- funds were not in the accounts.
13
started asking me about the fact that all the signatures
14
looked the same.
15
16
He
That's when I knew that he knew what was going

on.
17
Okay.
18
That would have been back in '08 sometime,
19
20
21
based upon what you just showed me.

Q
And you're basing your testimony on the fact,
the date of the first deal?
22
23
When would that have been?
How do you know it was in '08?

A
Because it was well before Mike asked to bring
24
in investors.
25
knowledge, Mr. Szafranski did not know what was going
It was a point in time when, to my

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on.
idea.
knew, and then there was a point in time when he was
bringing in investors into something he knew didn't
exist.
7
8
9
There was a point in time when he had a pretty good

There was a point in time when he absolutely
Okay.
What would be the line of demarcation,
if you will, as to when he knew?

A
I'd have to go back through all the email
traffic between Szafranski, me and Preve to do that,
10
because you can tell -- at least I may be able to tell,
11
based upon the language of what was going on and
12
pinpoint the date a little better for you, but it was
13
sometime in '08.
14
Scott, were there instances where there was
15
unredacted deal documents used and then redacted deal
16
documents used?
17
18
Sure.
Yes.
MR. BERGA:
Just give me a second; I'll
19
give you some exhibits.
20
21
22
23
24
25
There were a lot of times when there were no
deal documents used.

(Thereupon, documents were marked as
Szafranksi Exhibits 204 and 205 for Identification.)
MR. CHAMORRO:
For the record, Exhibit
204 and 205.

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2
BY MR. BERGA:
Q
Okay.
So, Scott, for the record we have 0-4,
which is an email from Villegas to Szafranski.
dated August 7th, 2009.
subject matter, it says S105UN; and then, on the same
date, also an email from Villegas to Szafranski, copying
yourself, and the subject matter is S106.
8
9
It's
You were copied on it, and
Going back to Exhibit 0-4, does the "UN"

represent unredacted?
10
Yes.
11
What was the purpose of preparing unredacted
12
13
or redacted documents in the same deal doc?

A
Mike had to advise the people that he was
14
verifying for, that he saw unredacted documents and that
15
he was able to link these documents to names, numbers
16
and the like that were on wires and the like.
17
the purpose.
18
That was
Now, other than to between Villegas, yourself
19
and Mr. Szafranski, who else saw these unredacted
20
versions of the settlement documents?
21
22
23
The people that were photocopying them:
Amy
Howard, Marybeth Feiss.

David Boden saw his unredacted documents, the
24
ones for his deals.
25
don't know specifically.
He may have seen some of ours.

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But the only people who were seeing unredacted
documents were supposed to be my internal group in the
firm and Mike.
4
5
So Mike would have seen both the unredacted
and the redacted versions?
Yes.
Now, Scott, at some point in your deposition,
They both had specific purposes.
I believe it was Friday, you testified that you had lied
to a lot of people in carrying out the fraud, correct?
10
Yes, sir.
11
Was Mr. Szafranski one of the people that you
12
lied to?
13
Initially, yes.
14
What did you lie to him about?
15
I lied to him about the existence of the
16
deals.
17
What did you tell him exactly?
18
He had heard the initial -- the same pitch
19
that I had given to other people, so he had heard the
20
entire thing in detail.
21
When would he have heard that?
22
I don't recall the first time he heard it.
23
mean, he heard it in total likely dozens of the times,
24
but I don't recall the first time he heard it.
25
He would have heard it a dozen times before he

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2
began verifying or trying to get reference -A
No, no, no, not before.
My apology.
Once he was brought in -- it was my
understanding that at the time -- and this is only my
understanding from what I was told -- at the time that
he was brought in to do the verification, he had already
been explained the entire scenario by the hedge funds.
I was told that by Mr. Simony, and also by Mr.
Preve, that he knew what he was looking for, et cetera.
10
Subsequent to that, there were times when Mr.
11
Szafranski sat in on -- when I was making pitches.
12
he heard it then, as well.
13
14
So you lied to him about the settlement
documents being real.
15
16
Okay.
So
Anything else you lied to him about?

A
When you say "the settlement documents being
17
real," are you talking about everything pertinent to
18
that, like the balances, everything that goes with it?
19
Yeah, I'm trying to -- you said he heard it
20
about a dozen times; he would have heard everything that
21
were you lying about, right?
22
23
24
25
Well, let me make sure you have this in
context.
Before Mike knew there was anything going on,
he had heard me do the pitch.
So everything contained

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within that pitch that was a lie, he heard it, which is
the bulk of the pitch.
3
4
Okay.
And when were you making those pitches?
Who would have been present?
I don't specifically recall.
But your testimony is that that happened a
7
8
dozen or so times?
A
No, no.
A dozen or so times in total.
There were times when he was hearing the pitch
10
after he knew.
11
he knew what was going on.
12
and after, more frequently after, than before.
13
He had me give the pitch to people after

So he heard it both before
Understand that before he got involved and
14
knew what was going on, the only time he would have
15
heard it was when he was in my office to do
16
verifications and happened to be around.
17
Okay.
Other that the nature of the
18
settlements, is there anything else you lied to
19
Szafranski about?
20
I'm sure there is a lot of things that I lied
21
to him about.
22
and I can tell you what's true and what's not.
23
Okay.
I need to see email traffic and the like,
But without seeing the emails, what
24
would have been something else that you lied to him
25
about?

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Where I was at a particular point in time, if
he was looking for me; the fact that I was meeting with
a client who did not exist.
deal-pertinent items, whatever was necessary in order to
keep the fraud going.
It would have been
Anybody else present when you made these lies?
I don't specifically recall.
How about during the week that you fled to
Morocco, did you lie to Szafranski at that time?
10
Yes.
11
What did you lie to him about?
12
About the fact that I was trying to
13
resuscitate the deals, that I was trying to borrow the
14
money in order to pay off the investors.
15
16
Anybody else present when you were making
these lies to Mike?
17
No.
18
How about at the time that you -- immediately
19
20
I was alone in a room.
before you left for Morocco?

A
To tell you specifically, I would have to see
21
my email traffic with him.
22
that moment, I couldn't tell you off the top of my head.
23
24
25
I was so scatterbrained at
If you need to show -- if you show me the

email traffic, I would be able to tell you.
Q
Now, Scott, when did Debra Villegas first

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learn that the settlements were fake?
2
3
Hang on one second.
There's one more person
you need to add to the list early on.
Which list is that?
That I talked about when I was talking about
people that knew that Szafranski knew:
John had specifically asked me if BSA needed to talk to
someone about the deals who was, quote, unquote,
independent, if I had somebody.
10
11
John Harris.
And I said, yeah, we can trust Szafranski.

He'll handle it.
12
When did that conversation take place?
13
I don't specifically recall the time frame;
14
but if you look at the email traffic between John Harris
15
and I regarding BSA and the time when they're really
16
climbing all over me, it would have happened around that
17
time.
18
Is that --
19
Prior to that, John hadn't asked me about
20
anybody independent.
21
That was the one-time conversation?
22
You know, John asked me the same thing
23
repeatedly in so many different areas, I can't tell you
24
one way or the other.
25
occurred more than once.
With him, it's possible it

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2
Repeatedly regarding Szafranski or regarding
issues in general?
everything.
John asked me things repeatedly regarding
Okay.
Before you jump back to Harris, my
question was, when did Villegas first learn that
settlements were fake?
The first day we did one.
Which would have been?
10
Then you go -- now, you have got to look --
11
you have got to go back.
12
'07, possibly '06.
13
It's got to be '07 or early
I don't think -- when I was doing the -- what
14
we call the bridge loans, just the promissory notes
15
stuff, early on, I'm not sure whether Debra knew or not.
16
But for certain when we did the very first
17
deal, which would be, I believe, G1, by that date she
18
knew the entire scheme.
19
20
21
22
What did you tell her the purpose was in
preparing the fake settlement documents?

A
I didn't give her a purpose.
I just told her
to prepare them.
23
She didn't ask what they were for?
24
To my specific recollection, no, she did not.
25
Was it you that told Debra that, or would it

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have been somebody else?
Told Debra what?
That the settlements were fake.
No, no.
You could tell that they were fake
because I asked her to prepare documents and sign
someone's name to it.
7
8
But did you actually tell her that they were
fake, other than asking her to prepare these documents?
It's just like with everybody else:
Other
10
than hints that things were fake -- well, more than
11
hints, like saying to Szafranski, "well, you know
12
there's no plaintiffs, Mike, right?"
13
that.
14
15
I never said, Deb, here's some fake

settlements; can you sign them, please.
16
17
That's not the way we talk -- at least that's

not the way we talked.
18
Okay.
19
She would do it.
20
Statements like
This is what needs to be done.

Debra was a good soldier.
She did what I asked her to do.
21
Didn't question you as to what it was for?
22
Initially, no.
23
At some point in time did she?
24
At some point in time she expressed to me her
25
concern that we were going to get in a lot of trouble,

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and I tried, as best as I could, to keep her calm.
So from time to time, yeah, she expressed her
concern; but most of the time, in this kind of thing,
when people are getting involved in a fraud, they just
get involved.
time, but there is really very little specific
conversation about the overall -- in this case, the
overall Ponzi scheme, just specific illegal acts that
were going on at different points in time.
10
And they may ask questions from time to
Was there ever a point in time where you
11
discussed with her regarding the fictitious settlements,
12
that they weren't part of this scheme to launder mob
13
money.
14
Say that again.
15
Yeah.
Did you ever have a discussion with her
16
where she learned, and you told her, that the fake
17
settlements weren't part of scheme to launder mob money?
18
That they weren't part of it?
19
Yeah.
20
I don't know if I ever told her they weren't
21
part of it.
22
At one point in time she was in a real panic
23
over the -- just the entire -- I guess the size of what
24
we were involved in and our constant need for funds
25
coming in.
She could see that I was stressed out, and

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she asked me why I was so stressed.
conversations about it.
3
4
We had
And she also new about my connections to

organized-crime individuals.
And so I told her that we need to do this
because some of this money belongs to the mob -- is mob
money.
Prior to that, how did she learn about the
alleged organized-crime connection?
10
She saw them coming into my office.
11
And she knew who they were?
12
We would discuss it from time to time.
13
14
15
16
Certain of them were in Fort Lauderdale,

fairly well-known people.
Q
So she could tell just by looking at them that
they were allegedly organized-crime figures?
17
No.
18
How would she know that?
19
Certain of the individuals, certain things we
20
were handling for them, would lead you to the conclusion
21
that they were organized-crime figures.
22
23
24
25
Any other conversations that you had with her,
other than that one regarding laundering of mob money?

A
I don't recall specific conversations with
her, other than that; but there were, to my

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recollection, many conversations that I had with Debra,
just in general, about clients of ours that were
involved in organized crime.
MR. BERGA:
All right.
Take a
five-minute break.
MR. LEVECCHIO:
MR. BERGA:
(Thereupon, a recess was taken.)
Pardon me?
Take a five-minute break.
BY MR. BERGA:
10
Now, Scott, did you ever tell Szafranski that
11
you were sharing a piece of your attorney's fees with
12
anybody?
13
Okay.
14
fast.
15
Go ahead.
16
17
18
19
I'm sorry.
Say that again.
You're speaking a little
And I know I speak fast, also.
I don't listen fast; I only speak fast.

Did you ever tell Szafranski you were sharing
a piece of your attorney's fees with somebody else?

A
I believe I did, yes, because I told them I
was sharing them with him and with his clients.
20
How many times did that discussion take place?
21
Before he knew what was going on, maybe a few
22
times.
23
clientele into investing with us.
24
25
After, we used it as a kicker to entice his
Anybody else who would have been present when
you had those discussions with him?

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Not that I recall, no.
I tried very hard not
to have these conversations with a bunch of people
standing around listening.
regarding the attorney's fees should be laid out pretty
well in the email traffic.
But those conversations
Now, can you tell me -- can you give me a list
of people who received compensation for recruiting
investors into the scheme?
These are people that knew there was a fraud
10
that brought investors in, is that what you're asking
11
me?
12
13
didn't know?
14
15
Was there a difference as to people that
Well, there were people that I understand --
you're asking that I specifically compensated, right?
16
Right.
17
Okay.
Yes.
No.
The only people I would have
18
compensated were people that actually knew.
19
people -- let me break it down this way.
20
would have been the main person that I was giving large
21
dollars to for bringing people into the fraud.
22
The only
Szafranski
David Boden received perks, a ridiculously
23
large salary, the very low priced rental of a very
24
expensive home I owned off Las Olas.
25
that type of stuff, what we talked about, the rock-star
The travel, all

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lifestyle.
2
3
So Boden was compensated in that fashion for

bringing people in.
Preve was sort -- it's hard with Preve,
because Preve was bringing so many people.
were times when I didn't offer it to Preve but Preve
kind of took it.
8
9
Okay.
There
If you look at the email traffic, you'll see

where Preve is saying -- you know, he would send me a
10
bill.
11
between Frank and I and you'll see a bill from Frank to
12
me for consulting.
13
wasn't really consulting for us.
14
particular deal to the table.
There would be emails going back and forth
15
Well, that's what that was.
He
It was for bringing a
But really the bulk of the money went to
16
Szafranski because he was the main illegitimate feeder
17
during that 2009 time period.
18
And before Szafranski became involved, you
19
never paid compensation to anybody to bring investors
20
into the deals?
21
The bulk of the deals came in through Levin
22
and Banyan, so I didn't pay them.
23
have a specific recollection of doing that, no.
24
we tried to be very particular as to who was bringing
25
deals in.
Pay A.J.
I don't
Because

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And Szafranski, like I said, became my main
feeder fund once the hedge funds cut us off, and stayed
being one of the main feeder funds even through the time
of the Von Allmens, Discala, Clockwork people came in.
So in terms of the compensation that
Szafranski was receiving, as you just testified, did you
ever tell him to conceal those payments?
8
9
No.
I paid him by check.
I don't recall
telling him to conceal it.
10
And have all those checks been identified?
11
I'm sorry?
12
How were those checks identified, what were
13
they for?
14
15
I don't know what we called them.
We probably
called them some kind of consulting thing.
16
What would happen is -- you can identify the
17
checks.
18
because I would give him a string of post-dated checks.
19
So you'll have sequential case number -- excuse me, not
20
case numbers -- sequential check numbers with
21
non-sequential dates, to the tune of millions of dollars
22
not tied to anything specific, without any invoices to
23
us.
24
something that doesn't exist.
25
All you have to do is look at our ledgers,
So you can tell he's receiving remuneration for
Regarding the compensation that you were

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2
paying him for bringing in deals -A
He did tell me one time to make sure that I
never brought up the amount of money that he was making
with Damson and Sochet, those guys, the amount of money
that he was making with me, because he was very
concerned, because he was not supposed to -- and I knew
that as well -- he was not supposed to be taking money
from me, because he was supposed to be an independent
verifier.
And he was already receiving two different
10
types of payments from the people he was bringing in:
11
finder's fee, some type of commission-type thing, plus a
12
verification fee.
13
How many times did he tell you that?
14
It wouldn't have been more than a handful.
15
Anybody else present for that conversation
16
with you and him?
17
No.
18
And his instruction to you not to tell
19
anybody?
Uh-uh.
That was just to Damson.
Who else?
20
21
to meet Ira.
22
was meeting him for breakfast.
23
met Ira may have been at breakfast.
24
one of my breakfast meetings was Ira.
25
little diner he liked to go to.
No.
I recall it because I was getting ready

Okay.
We were going to have breakfast.
I think the first time I

But I was going to
We had this

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And I remember speaking to Mike some time
right before, and saying, Make sure you don't talk to
Ira about the money you're giving me because I'm not
supposed to be taking any money and I -- I'm sure I told
Mike don't worry about it.
to be taking that money.
business with him, with me.
8
9
I know you're not supposed

I won't discuss any of your
Let's switch topics then.
Talk about the
website, TD Bank website.
10
Sure.
11
Can you tell me all the people that would know
12
13
that the website was fake?

A
Me, Debra Villegas, Curtis Renie, Bill Corte,
14
David Boden, Bill Boockvor, Stuart Rosenfeldt, Richard
15
Pearson, Mike Szafranski, Frank Preve.
16
17
18
19
20
21
That's all I recall at this moment.
There may
be more.
Q
How did Mr. Szafranski come to learn the
website was fake?

A
I showed him how to work it so that he could
show it to his investor.
22
Where did you do that?
23
In my office.
24
25
It was at the time that Damson was

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investing -- it might have been with Sochet, actually.
It was either Socket or Damson.
office, whichever one it was, and Mike wanted to do --
Mike was giving them, for lack of a better word, a show
of his own, to show them what he did in his
verification.
believe that he was actually signing on to the specific
website and showing -- and looking at it.
And they were at my
He was leading a lot of the investors to
And there was an occasion with either Damson
10
or Socket where we were in my office, that person was
11
there, and Mike actually signed on to the website.
12
pretty sure it was Damson or Socket and not one of the
13
other -- now that I'm thinking about it, it could have
14
been with one of his other potential investors.
15
definitely signed on, because I showed him you can just
16
enter anything into the system.
17
Ishkabbible and it will still open up into the right
18
screen and the balances and the like would be on there.
19
20
21
22
23
I'm
But he
You can enter
And this all would have happened in your
office?
A
That's the only place it could happen.
It's
the only place the fake website existed.

You know, now that I'm thinking about it, it
24
wasn't Socket and Damson.
25
was some -- one of the other investors he had brought to
Because I remember him -- it

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my office for a show, okay, they were specifically
pushing on the whole -- they -- they wanted to have
access.
if you look at Mike Szafranski's emails with other
people, you'll see that he's creating all these little
other lie scenarios, that he's using to go sell the
product, where he's telling; for example, people that
he's the person that the Bar designated -- it was an
email I remember seeing where he told someone that the
If you look at Mike's emails to me -- actually,
10
Bar designated him as the only person that could see the
11
real settlement agreements.
12
13
He also told people that he actually had

access to this website.
14
15
And they wanted -- this particular investor

was giving us a hard time.
16
So, I went ahead and had Mike actually go
17
ahead and sign on with the investor so they could see
18
what he would, quote/unquote, be doing as part of his
19
third-party verification, which obviously was really
20
nothing.
21
22
23
And this would have all happened in your
office?
A
That's the only place that that could ever
24
occur, unless he had a -- his own little website that I
25
didn't know about.

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Who was the name of the investor?
I don't recall.
But the investor would have gone -- went to
your office actually at that instance?
There were several potential investors that
Mike actually brought to my office for the dog and pony
show.
How many times did that happen?
That he actually brought people?
10
Yeah.
11
No.
Was it just that one time or was it -It was half a dozen or less.
I mean, he
12
brought people from time to time to the office for the
13
show.
14
And were you always part of the show?
15
Yes.
16
Anybody else part of the show when it happened
17
18
in your office?
A
The only person that I recall being involved
19
from time to time and I actually remember seeing this in
20
some email traffic between Mike and Mel Lifshitz was Stu
21
Rosenfeldt.
22
discussions that I had with investors with Mike and
23
that's pinpointed in some of Mike's emails with
24
Mr. Lifshitz.
25
Stu was present during some of the
So the scenario would have been that the

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investors, the -- some of which -- you can't remember
any of the names of investors?
I met God knows how many people during the
course of this.
they weren't -- even some small investors, you'll recall
early on in my testimony, I had no idea that these
people were even investing.
large feeder fund, I wouldn't have remembered their
name.
10
11
Many people who did not invest.
If
So unless they were a very
And you didn't have any concerns with just
letting anybody into your office?
12
No, no, that's not the way it worked.
13
How did it work?
14
They would have had to have at least been, for
15
lack of a better word, prescreened, and I had my own
16
methodology of prescreening them when I met them.
17
Which was?
18
Start talking to them about the investment and
19
see the level of questions that they're asking; how much
20
they're pushing.
21
Some people are much more interested in what
22
I'll call the greed factor.
23
interested in the returns and don't really give a crap
24
what's behind the returns.
25
They're much more
Others are really looking for documentation,

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substantiation.
If you're talking about returning in excess of
100 percent, sometimes often in excess of 200 percent,
you get a lot of questions.
from some people, less from others.
prescreening process.
go with somebody based upon the way they're asking you
and whether they seem sufficiently pleased with the
initial answers you're giving them.
10
Some from -- some -- more

And so there's a
You can see how far you want to
So in terms of Szafranski and yourself
11
participating in this show, as you call it, this would
12
have happened at least a half a dozen times, you say?
13
Well, you've got to include in there that I
14
did -- you know, it's not the same thing as the bank
15
show.
16
it a show because it's obviously all fake.
All right?
It's a different thing.
17
Different kind of show?
18
Right.
19
I'm calling
I did it with Damson in my office.
With Mel
20
Klein in my office, I believe.
21
could swear I remember Socket being there, but I don't
22
specifically recall.
I don't recall -- I
23
People you mentioned in there was --
24
Kathleen White.
25
Not to cut you off, but was Szafranski present

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for all those times that you mentioned these people
before?
For some of the times.
He wasn't
necessarily -- every time Barry Damson came to my
office, I can't tell you one way or the other whether
Mike was there or not.
times.
8
9
There sometimes, not there other
But there were times when he brought in -- I

have specific recollection of sitting with him -- I had
10
a couch set up in my office -- sitting with him and
11
various investors, people asking questions.
12
13
14
And it would be Szafranski who would be
manning the computer?

A
No.
I said on one occasion I remember with an
15
investor who we thought was going to be interested but
16
was pushing the point of how Mike actually verified the
17
balances.
18
19
20
It was that -- that was the only time that
Szafranski logged on to the website?

A
I don't recall whether he did it other times
21
or not.
22
there but I have a specific recollection about someone
23
pushing the point.
24
he brought in, I might be able to recognize the name.
25
I may have allowed him to with someone else
If you have a list of everyone that
And it would have been one of his investors?

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Well, when you say "his investors," he was
being fed people, as I understand it, by the Turetski
family, some other families' names that I don't recall.
So, I don't know how you qualify them as his investors.
Someone that I put under the Szafranski umbrella of
investors, yes.
Now, can you put a time period on it as to
when Szafranski first learned that the TD Bank website
was fake?
10
You want to know what I think?
11
Well, I want to know what your testimony is,
12
your truthful testimony is, then you can tell me what
13
you think.
14
Well, I'm only giving truthful testimony.
15
Okay.
16
Okay.
As far as -- I can tell you what I
17
think he knew.
18
sometime and we were looking at the wires, and Debra or
19
whoever did the wire, she had made a mistake and the
20
wire amount was all off.
21
was crazy, I mean, the way that sheet was set up.
22
you look at those sheets, you'll see the way it was set
23
up.
24
25
We were -- we were -- it was in '08
There were zeros missing.
It
If
And there was a mistake on there.

And then as Mike was looking at it, he said,
"That can't be right."
He was looking at his deal

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sheet, whatever he got from Preve or from the -- from
the hedge funds.
looking at the thing, and he's saying, "That can't be
right."
numbers.
6
7
10
And then he starts to look at the actual wire
And Debra duplicated the exact same number

from page to page several times.
8
9
He's looking at the deal sheet, he's
And I was kind of dumbfounded, because all I

could say was it's got to be a bank error.
And I left
it at that.
11
At that moment I had -- I had a pretty good
12
idea that he knew something was amiss because those bank
13
websites, the wires are generally not incorrect.
14
matter of fact, all the time I was doing legitimate
15
business, I don't recall ever seeing a mistake on a wire
16
on the bank's website.
17
18
19
As a
So that's what you think, but tell us about
what you know.

A
At the time that he knew that there were no
20
plaintiffs when he brought his first deal in, at that
21
time I'm certain he knew the website was fake because he
22
knew there were no plaintiffs and no real money moving
23
in and out except from the investors.
24
25
Prior to that, I would be guessing.
He knew
sometime prior to that, because by the time he was

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bringing investors in, and I said, You know there's no
real plaintiffs, Mike and he said, Yeah, I know, but
everyone is making money. You know, we're doing good.
That's the kind of conversation we had.
If you spoke to Mike, you know, he doesn't say
a lot.
he's making money.
8
9
10
11
He's just kind of go-with-the-flow as long as
So it's your testimony that because he
allegedly knew that there were no plaintiffs, he knew

that the website was fake?
A
Oh, no, no.
Read the email traffic.
He knew
12
there were no plaintiffs.
13
and you look at the signatures, you don't have to be a
14
handwriting expert to see it's the same person.
15
he literally looked at hundreds of signatures signed by
16
the same person.
17
If you read the email traffic
I mean,
As good as Deb was, it doesn't take a
18
handwriting expert to tell you it's the same person
19
signing it.
20
And he would sit down, sir, sometimes,
21
sometimes look at ten and 20 deals at the same time, all
22
with the same basic signature pattern on them.
23
But I'm trying to get an understanding of what
24
your -- I mean, let's put aside reading the emails,
25
you're testifying that because he, as you say, didn't

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know there were any plaintiffs, that he automatically
knew -- made him know that the TD Bank website was fake?
Well, eventually he knew the TD Bank website
was fake because he knew that there were no plaintiffs.
Why would I be using -- how would I possibly -- if
there's no real plaintiffs and no real cases, how would
there possibly be a real website showing all that money
coming in and out from people that didn't exist.
makes no sense.
That
If he knows there's no plaintiffs, he
10
could not possibly believe that I was sending money out
11
to people that don't exist.
12
website.
That's what was on the
That makes no sense.
13
That's your testimony, right?
14
I'm sorry?
15
That's your testimony?
16
Yeah.
17
Did you ever ask Bill Corte or Curtis Renie to
18
update the balances before Szafranski arrived at the
19
office?
20
I asked him to update the balances before
21
Szafranski got there, while Szafranski was there, before
22
other investors got there, sure.
23
And when you asked him while Szafranski was
24
there, would Szafranski have been present while you
25
communicated that to Renie or Corte?

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He might have been but I did it usually by
getting on the computer and just sending an email to
Curtis or to Renie -- excuse me, to Renie or to Corte.
Now, did you ever have a conversation with
Szafranski about, I mean, your concern that you were
running short on cash to keep the scheme going?
Specifically like that, no.
What would it have been like if you did have
9
10
that conversation?
A
It would have been I need investors; nothing
11
more than that.
12
running low on cash on -- did not include Szafranski.
The only people that I ever said I'm
13
Who would that conversation take place with?
14
I said it to Boden a couple of times, I said
15
it to Irene Stay more than once, and I said it to Deb a
16
few times when we were running low on cash.
17
So those people you told them --
18
And I said it to Preve frequently.
19
Okay.
So those four people you told were
20
running low on cash, need cash to keep the scheme going,
21
as opposed to Szafranski when you told him --
22
No.
23
-- you need investors?
24
I never, ever said to anyone, "I need cash to
25
keep the scheme going."

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Okay.
I would say, Irene, let me know.
What did you tell them?
for money to come in.
are due.
Frank:
send me back that 2.7 million.
back that 3 million.
Send me back 2.7.
We've got payments that
I would write to Frank or I would talk to

Frank, we've got payments due.
9
10
Okay.
I'm waiting
You've got to
You've got to send me
I'm going to send you 3 million.
Boden, you've got to get Pearson's people to

pay, we've got other payments that are due.
11
So the way you tell someone, that is not --
12
we're running short on money for our scheme. What you
13
say is, we need deals to come in the door or we need
14
deals because payments are due. One of two things.
15
Okay.
But your conversations with Szafranski
16
weren't of that nature, it's your testimony.
17
testimony is that you told him that you needed more
18
investors?
19
Your
You have to look at the email traffic to see
20
exactly what I was telling him.
21
specific conversations with Mike telling him:
22
payments due, I need cash in the door. I don't recall
23
having that conversation.
24
I don't recall it.
25
I don't recall having

I have
It doesn't mean I didn't, but
But you do recall having conversations with

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him saying that you needed investors?
Yes.
Did you tell him why?
That's not -- that's not the way business was
5
6
7
8
9
done.
It's always discussed as little as possible.

Q
you mean?
A
I'm not sure I follow your answer.
What do
You told investors -You would have had to have been in the mix to
understand it completely.
10
I wasn't, so that's why I'm asking you.
11
I can't explain it.
When you're dealing with
12
someone -- when you have someone like Mike, for example,
13
who is taking millions of dollars in payments from me on
14
what would otherwise be nothing, if you're taking the
15
position that he had no idea what was going on, and he
16
was doing pretty good because he took, what, $13 million
17
from me to do nothing.
18
You have people who are involved.
You have
19
people that are taking bribes from you, in essence.
20
People that are getting things that they are not
21
otherwise entitled to, that are seeing things that they
22
know are not real.
23
in the know, being a player within the Ponzi scheme.
24
Not necessarily knowing, for example, that there's a
25
Ponzi scheme, but knowing that there's a major fraud
All of that adds up to someone being

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going on.
With those people, the conversations you have
are limited to what they need to know at that moment to
further the fraud.
Nothing further.
We never sat down -- I never sat down with
anyone, even Debra Villegas, and said, "Oh, my God.
Let's see what's going on in our fraud," and went into
detail about what was going on.
business was done.
10
11
That's just not the way
Now, you testified earlier that I think you --
you made some business to the bank with Szafranski?
12
Yes.
13
What was the purpose of that?
14
In the beginning, to make him think that the
15
balances were there.
16
17
And that would have been after he started
doing the verifications, around what time?
18
It would have been almost immediately after he
19
started doing verifications.
20
demanded that we start doing bank visits, it would have
21
been at that time.
22
Whenever the hedge funds
Take a look at the email traffic, it will tell
23
you.
24
rely on my attempt at remembering the specific date.
25
It's a lot easier to rely on that traffic than
So when you went to the bank to do the

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business with Szafranski, who else met you -- met with
you?
You mean was there another investor with me?
Anybody.
The only person who would have been at the
bank were the bank officials and Steve Caputi.
correctly.
with Szafranski?
10
Okay.
Maybe I didn't ask the question
Who would you have met with when you went
Early on, I would have -- I believe that
11
Szafranski -- I may be mistaken but I believe that
12
Szafranski was one of the people that was there when I
13
first used Caputi to pretend to be a bank official.
14
15
And he would have been there meeting with you
as well as Caputi?
16
Szafranski would have drove there with me.
17
How many visits did you take to the bank with
18
Szafranski?
19
In total, or with Caputi?
20
Let's start with in total.
21
Five or six.
22
How many with Caputi present?
23
Well, that's interesting because you've got to
Maybe less.
24
remember that it's the fact that Caputi is there that
25
ultimately leads one to understand that Mike clearly

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knew that there was a fraud going on.
Mike in the beginning, which I recall doing, Caputi was
playing Ricardo Mejia, a banker working for TD Bank.
Subsequently, Mike went to -- went to my night club with
me, Cafe Iguana at Pembroke Pines, where Steve Caputi
was the manager, and had drinks with Steve and I knowing
that the man's name was Steve Caputi.
8
9
Because if I took
Subsequently, Mike was at Bova on several

occasions with me with Steve Caputi drinking.
10
Mike went to Solid Gold on several occasions
11
with me and Steve Caputi.
12
relationship, used to be the money guy, Michael Peter,
13
who owned Solid Gold.
14
well when we went with Steve.
15
Caputi and Mr. Szafranski.
16
Steve had a very tight
So we used to get treated very

So we went there with
So it's clear that in the beginning, while
17
Caputi was playing Mr. Mejia, it became crystal clear to
18
Mike that he was Steve Caputi, not Mr. Mejia.
19
There were times, I believe, there may have
20
been times subsequent to Mike realizing Caputi is Caputi
21
and not Mejia, that we went back to the bank with one of
22
Mike's investors and Caputi was still playing the
23
banker.
24
know, I'd hate to go back to it but I would like to see
25
the email traffic because --
But I really need to see the -- again, you

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Mr. Rothstein, my question was who else was
present?
between Caputi and Szafranski.
little later.
had.
how many was Caputi present with --
I didn't ask you about the whole history

We can get to that a
I just want to know how many visits you
You said five or six, and of those five or six,
Maybe two, if he was present at all.
Now, of the five or six times that Szafranski
went to the bank with you, did anybody give him any
10
documents?
11
12
13
It may have been more than five or six.
Okay.
Well, my question still stands:
Did
anybody give him any documents?
16
17
It
may have been a few more than that.
14
15
No.
Either I -- no, it would have been me.
would have given him the fake bank statements.
18
Now, when --
19
Unless -- unless Caputi was there.
I would
20
usually have Caputi hand the fake bank statements to
21
them.
22
Now, when you gave him the bank statements
23
while you were at the branch, did you tell him that the
24
balances were fake?
25
No.

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2
3
Anybody else present when you handed the
documents to Mike?
A
You have to look at the bank films and see
where I handed it to him.
conference room, and Caputi was there, then it would
have been me, Szafranski, and Caputi.
him out in the middle of the bank floor, then whoever
handed me the documents would have seen me handing them
to him because that was part of the show.
10
If I handed it to him in the
If I handed it to
Documents come to -- from the banker to me --
11
it's like creating a chain of custody.
12
documents go from the banker to me, and from me to the
13
putative investor or verifier in this case.
14
The bank goes --
Other than yourself, did anybody else tell
15
Szafranski that the documents, the statements that he
16
was receiving at the business of the bank, that they
17
were not the actual balances in your firm's accounts?
18
Anybody other than yourself --
19
You're asking if someone told him that?
20
Yeah.
When they were handing him the
21
documents, did they tell him this is not the actual
22
balances?
23
No.
That was -- that was never said to
24
anybody we ever handed the documents to.
25
the documents to anyone and then say, "These are not the
We didn't hand

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actual balances."
that knew that they weren't the actual balances.
We didn't even say that to people
Let's talk about the lock letters.
Did you
ever tell Szafranski that there was in reality no TD
Bank lock letters?
Yes.
When we were first putting the lock letters
together, we got a request -- I believe it was actually
10
from one of his feeder fund clients.
11
Damson.
12
13
It might have been
Someone was requesting this lock.

It definitely wasn't Socket because Socket
asked for it later.
14
And Szafranski and I were sitting around
15
BS'ing in my office and the subject of the letter came
16
up.
17
creating real issues internally for me because -- the
18
locking mechanism doesn't exist.
19
Szafranski we want to use this as little as possible.
20
Don't -- I told him specifically, Don't offer this to
21
people because I don't know how many times I'm going to
22
be able to call on Spinosa to effectively get this put
23
in place, because there's nothing to lock.
24
25
We were talking about this, and I said this is
And so I told
And it was Mike, I think, who pointed out to

me the fact that I could go online and move the money

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anyway.
issue.
He was one of the people that raised that
When we are talking about locking the money,
all you have to do is go online and hit a wire button,
and you could take all the money out, assuming there was
any money in there to begin with.
with Mike?
Okay.
When did that conversation take place
It was early on with the lock letters.
We
10
were maybe one or two lock letters in, and that was a
11
face-to-face conversation.
12
Where did that take place?
13
It was either in my office or at Bova.
14
Anybody else present with you when you had
15
16
At your office?
that conversation?
A
17
I don't recall anyone being there.

As a matter of fact, I recall Szafranski
18
saying -- I don't know if he said -- he was really angry
19
with Damson at one point in time.
20
traffic going back and forth where Damson is breaking
21
his -- breaking his butt over some things that he was
22
either doing or not doing and he screwed up verification
23
where he had missed it by like -- like $22 million to
24
$27 million.
25
thing.
You'll see this email
It was a big mess-up that Mike had on his

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And Mike made a comment to me, he says, The
guy doesn't even understand how banking works.
he breaking my -- excuse my language -- breaking my
balls over this?
Why is
That's the type of conversation we were
having.
the fact that they -- these people are asking for
something that they know, because -- and it was Damson,
because Damson's partners, the Hahn brothers, owned the
10
And we were talking about the lock letters and
bank.
11
So here we were kind of getting a giggle out
12
of the fact that we had these bankers who were asking
13
for something that they know can't work.
14
know, because I don't know what they were actually being
15
told -- though Spinosa did a pretty fine job convincing
16
these people that it did, in fact, work.
Or should
17
Do you recognize the name Brad Edwards?
18
I do.
19
Who is that?
20
He worked for me.
21
Did he know that settlements you were offering
22
were fictitious?
23
No, sir.
24
Now, you testified at some point throughout
25
the last couple of weeks that you sent emails out

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falsely exculpating people, correct?
Yes.
Did you send any emails to Szafranski
exonerating him?
You'll have to show me the emails.
But as you remember them?
As I remember, I don't recall one way or the
other.
I would have to see emails.
I was sending them out because at that moment
10
I believed I was going to kill myself and I didn't want
11
to put anyone else through any further pain.
12
MR. BERGA:
13
THE WITNESS:
14
MR. BERGA:
15
THE WITNESS:
16
17
MR. RASCO:
18
19
Rasco.
Give me one second, Scott.

Sure.
I'm all set, Scott.
Thanks.
You're very welcome.
Good morning.
My name is Ray
I represent Frank Preve.
Let me get on the record before I start
20
that we have about two-and-a-half hours
21
allotted, pursuant to the amended protocol
22
ordered and the agreement on among defendants'
23
counsel.
24
25
I -- in light of the fact that there is

7,000 emails or more between you and Mr.

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Preve, we don't agree that that's sufficient
time to cross-examine, but we're going to do
the best we can in the time allotted.
4
5
6
DIRECT EXAMINATION
BY MR. RASCO:
Q
I want to start off with your testimony on
Friday, regarding a email from April 29, 2009, regarding
the -- it was -- the word "farce" was used.
9
10
Let me just -- it's not in the booklet that I

gave you.
11
Do you recall the email --
12
I do not.
13
-- from April 29, 2009; you discussed it on
14
Friday?
15
Could you show it to me?
16
I don't have it, but I -- you testified on
17
Friday that:
18
the Ponzi scheme, and he knew about the fact that the
19
Bar thing was something I had made up.
20
Do you recall that?
On April 29, 2009, Mr. Preve knew about
21
I recall saying something to that effect, yes.
22
Okay.
23
The email you described as -- usually,
you know, with a -- can you bear with me one second?
24
Sure.
25
You read it into the record, Page 1346, could

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you read into the record, the -- I'm sorry, it says:
"Give me a few.
with Adrian so I can continue this farce.
I am working on another Bar response

Love ya."
Do you recall that email?
I have a vague recollection of it, yes.
You indicated on Friday that that was an
indication that Mr. Preve knew that there was a Ponzi
scheme going on and that the Bar issue was fictitious?
I -- I don't recall testifying that that is an
10
indicator that Mr. Preve knew there was a Ponzi scheme
11
going on.
12
Well, what you said, specifically, was:
On
13
April 20th, 2009, Mr. Preve knew about the Ponzi scheme,
14
and he knew about the fact that the Bar thing was
15
something I had made up.
16
Yes, but I didn't say that that email is why
17
he knew there was a Ponzi scheme going on.
18
putting words in my mouth.
You are
19
Can you tell me the basis for that statement?
20
Everything that leads --
21
As --
22
-- me to believe that he knew there was a
23
Ponzi scheme?
24
On April 20th, 2009, at that time, yes.
25
How do I know that by that time he knew?

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Yes.
Unrelated to this email?
Unrelated to this email or related to this
email.
In no particular order, on multiple occasions
he knew that we had extremely low amounts of money in
our trust account.
Harris and Frank Spinosa, despite the fact that they
were supposed to be covering for me.
10
It was verified to him both by John
On --
11
Oh, well --
12
Let me finishing answering.
13
On at least a dozen occasions, maybe two or
14
three dozen occasions, Mr. Preve would send me, knowing
15
that we had no idea what was supposed to be in the bank
16
accounts and that there was no money in the bank
17
account, or very little, he would send me emails
18
instructing me what amounts needed to be in the bank
19
account.
20
There were multiple occasions where Frank was
21
taking investor money to pay Mr. Levin's personal bills,
22
clearly an indication that we know that this is a giant
23
fraud, because if it was a real investing -- investment
24
program, you don't generally take the client's money and
25
do what you want with it.

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There were multiple occasions where Frank
provided fake documents to me for use, for example, with
the auditors.
occasions and said to me, specifically told me,
listen -- We had discussions about the fact that Tracy
Weintraub of Berenfeld Spritzer was the auditor, as well
as my accountant.
pocket; and wherever he had problems with Tracy, he
would come to me and say, listen, you need to get this
10
He came to me on more than several
He knew I had Mr. Weintraub in my
straightened out.
11
There were multiple the conversations with Mr.
12
Preve where we discussed all the trust accounting
13
issues -- that is evidenced in a ton of emails -- and
14
specifically dealing with the accountants where Frank
15
said -- listen, he sent me, instead of me preparing
16
balance statements and the like for the accounts, where
17
he sent me the documents; tells me, for example, to
18
scribble on the document, to make it look like someone
19
actually worked on it; and then we sent that to the
20
accountants.
21
listed so far, all indicators that Frank was in on it.
22
That's one of the indicators that I have
He lied to Mr. Levin about things to cover his
23
tracks.
24
funds from Mr. Levin, going so far as to create a
25
pseudonym for himself, G. Steinbeck at whatever that
He did side deals with me, trying to hide the

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email address was.
He plotted with me on a regular basis as to
what stories to tell the hedge funds, what stories to
tell other investors.
Probably one of the most glaring things is --
and I think everyone knows this by now, if you have a
real investment program, you don't fund deals in a real
investment thing, in a real investment program, without
paperwork; and we funded in excess of $25 million in
10
deals with Mr. Scherer clients alone with being no
11
paper.
12
There are a ton of emails where Frank is
13
talking about, we're about to have an audit and we're
14
going to go down in a -- basically in a fiery ball of
15
flames.
16
had other phrases he used.
17
I don't think those were his exact words; he
He kept putting off audits.
18
lies to tell those auditors.
19
Do you want me to keep going?
20
We plotted about
I mean, there's a myriad.
That's -- I want to know -- I want to start
21
off with the first two, which are the John Harris and
22
Frank Spinosa emails, because you testified about that
23
last week, as well.
24
Okay.
25
Yeah, I have those emails, and if you look at
Did you have those emails?

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tab five in the binder -- I'm sorry, it's going to be
tab four in the binder I just handed you.
The first email is the December 4, 2007, email
from Frank to John Harris regarding a Banyan life
credit, and it's in that email that he indicates that
the Banyan account, which will be a source of repayment,
currently stands at over $21 million.
8
9
Yes, this is one -- yes, this is actually one
of the emails.
This is a good email because at this
10
points in time, I'm not certain what Frank knows; but
11
after this whole back and forth with Harris and what
12
went on, it became clear to me that, at the very least,
13
Frank was a player, because -- because he ignored a red
14
flag that looked like the Titanic sinking.
15
What red flag was Frank ignoring?
16
He writes to Harris and he talks about the
17
fact that the RRA trust Banyan account will be the
18
source of repayment and currently stands at over
19
$21 million.
20
Harris at that point in time indicates, based
21
upon his refusal to do a line of credit, refusal to
22
discuss it any further with Mr. Preve, that there's no
23
such thing in that bank account.
24
He indicates that to who?
25
To Mr. Preve.

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He does that in an email?
I don't believe it was in an email.
It was an
email back to Mr. Spinosa -- actually, it was in a
telephone call to Mr. Spinosa, confirmed later in an
email by Mr. Preve and Mr. Levin.
In this particular circumstance, it was the
back and forth between Banyan and the bank that
indicated to me, post this email, that Frank had a
pretty good idea of what was going on; because had they
10
really had control over $21 million, had that actually
11
really been the source of repayment, there is no reason
12
for Gibraltar Bank not to at least discuss giving them a
13
loan, but it was pushed off at every turn.
14
If you follow the email traffic, you will see
15
that it was pushed off at every turn because there was
16
not, in fact -- even if there was $21 million in that
17
account that day, and I don't believe there was, John
18
Harris knew -- which is the reason he wasn't going to do
19
any loans with Banyan, why they never did any loans with
20
them.
21
volatile, that one minute there could be $30 million in
22
the account; the next minute, there could be nothing.
23
John Harris knew that that money was highly
So Harris knew that it could never be a source
24
of repayment; and that, to me, should have sent major
25
flares up to Preve, but never did.

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2
3
So you're suggesting that that was a red flag,
the fact that the line of credit was not approved?

A
I don't believe they really got it off the
ground.
and months and months.
6
7
I think Harris kept pushing them off for months
Did Harris call you when this email was sent
to him regarding $21 million dollars to say --
Yes.
He called you and told you that there wasn't
10
that money in the account or that Frank was --
11
He asked me what the heck to do.
12
And what did you tell him?
13
Because they're saying -- I told him, don't
14
give him anymore information.
15
asking about my bank balances, use that as your block.
16
17
18
He's not supposed to be
Did you tell him not to approve the
line-of-credit request?
A
No.
I had asked him all along to try to get a
19
line of credit approved.
20
do it, just by that -- just by that statement alone,
21
okay, Harris knew, at that point in time, and ultimately
22
Preve, that there were problems with our trust
23
accounting.
24
25
He wasn't going to be able to
So as a result of the fact that this line of
credit was not approved, that there wasn't a lot of

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discussion about the line of credit in the following-up
email traffic, you're saying that it was a red flag, and
that's what led -- led you to believe that Mr. Preve was
a player from this time?
It was one of the things.
It was one of the things?
Let me put myself in their shoes.
8
9
If I'm investing hundreds of millions of

dollars in something or a hundred-million dollars or
10
even five-million dollars in something, and I get ahold
11
of the bank, okay, and tell them that we have got
12
$21 million in place for repayment; and they then give
13
me an indication that maybe those funds aren't then,
14
even a maybe those funds aren't there, I'm going to
15
start asking a lot of questions.
16
asked.
17
18
John Harris?
19
No questions were
Do you know that no questions were asked of
According what John told me, no further
20
questions were asked and certainly no questions were
21
asked of me.
22
23
Do you know that there is follow-up emails
between Frank and John Harris?
24
Let's take a look at them.
25
Well, there is one that follows it, but I'm
Are they in here?

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just asking you, generally, whether you knew that there
was any follow-up or Frank asking questions?
3
4
It wouldn't surprise me, but ultimately, he
can't substantiate that the money is there.
So if you point me to an email that says that
Frank should have been calmed down and as assuaged --
that is not the right word, is it?
"Assuaged" is fine.
Assuaged?
10
That's fine.
11
My vocabulary sometimes slows me down.
12
Is that good?
-- should have been assuaged by what John
13
Harris was telling him, that I would like to see.
14
Because my recollection is that -- in looking at the
15
emails, it looked to me like it would be a very large
16
red flag.
17
Are you aware that there was a meeting between
18
John Harris and George Levin and other people at
19
Gibraltar Bank?
20
Yes.
21
What was the purpose of the meeting?
22
They were trying to get a line of credit and
23
24
25
I was present at several of them.
establish a larger banking relationship.

Q
Was there several meetings, or do you recall
just one?

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2
I recall, off the top of my head, two.
There
may have been more that I was not present at.
Mhm-mhm.
But to my understanding, and from
conversations that I had with Mr. Preve, himself, and
with Mr. Harris, the bank kept putting them off as to
ultimately doing a line of credit.
8
9
Okay.
Going next to the email with Spinosa,
it's a little further in in that same tab.
It's FP Bate
10
number 112310.
11
chronological order -- a May 23rd, 2008, email.
It's May 23rd -- they're in
12
2008?
13
Yeah, 2008.
14
15
16
It's titled "Idiots."

A
I don't have May 23rd, 2008.
from --
17
MR. NURIK:
18
THE WITNESS:
19
MR. RASCO:
20
THE WITNESS:
21
MR. RASCO:
22
23
24
25
Mine jumps
What's the tab number?

Tab four?
I'm sorry.
Tab four?
It's at tab four.
Yeah.
If
you don't have it, I can show it to you.

THE WITNESS:
Hold on.
Let me see if
it's in here.
MS. TRENCH:
You said May, right?

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2
MR. RASCO:
May 23, 2008; it's titled
"Idiots."
THE WITNESS:
I remember that email.
MR. SCHERER:
About six from the back, in
that section.
6
7
THE WITNESS:
Thank you, Mr. Scherer.
BY MR. RASCO:
You're aware of that?
Give me one second.
10
Go ahead.
Go ahead.
11
MR. NURIK:
12
THE WITNESS:
13
14
15
Here it is.
Okay.
BY MR. RASCO:
Q
You're aware that there were several meetings
with Frank Spinosa and other people at TD Bank?
16
I do.
17
George Levin and Frank Preve were present?
18
I was under that impression, yes.
19
Were you part of any of those meetings?
20
I don't recall being, no, sir.
21
And do you recall that some of those meetings,
22
at least, were for the purpose of obtaining a line of
23
credit from TD Bank or Commerce Bank at the time?
24
I do recall that.
25
Okay.
And did you have any discussions with

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Frank Spinosa about the Banyan Group, let's call it,
trying to obtain a line of credit?
I did.
And what were those conversations?
Can you
describe them, please?
There was one, specifically, that occurred
around the time -- probably the day of, but right around
the time that this email went out, and I hadn't seen
this email at that time.
10
But the telephone call where you have this
11
whole thing, Spinosa contacts me and tells me he thinks
12
he may have screwed up because he thought that Frank was
13
attempting to confirm a bank balance using the whole
14
line-of-credit thing, attempting to confirm the bank
15
balance that I was holding and that they told him that
16
there wasn't that much in the account.
17
And then he said he panicked and lied to Preve
18
and told Preve, I can get you the bank balance but I
19
can't get it to you next week because I don't have
20
access to that information; only my girl has access to
21
it.
22
And at a subsequent point in time, I remember
23
speaking to Mr. Preve, and Preve is telling me that he
24
thinks that Spinosa is just basically off his rocker,
25
that he's -- his ability to lie and to keep stories

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straight is weak at best.
2
3
Preve is telling you that he is aware of the
fact that Spinosa is lying to him?
Yeah.
I mean, you can tell from this email
that he thinks he's lying to him.
section of the email.
7
8
9
I mean, read that
What section are you specifically referring
Let's see right here, second paragraph:
to?
And,
10
of course, after telling me that he did not have that
11
much in the RRA trust account -- I mean, at that point
12
in time, first of all, Preve, okay, gets this email and
13
doesn't know there is something going on.
14
think they would want an immediate audit of my trust
15
account, or at least ask some questions.
16
confirm to me, and after his return to the office, he
17
doesn't call me back.
18
19
You would
But he would
That is during the period of time that Frank

Spinosa is panicking.
20
I then called him, okay, and he told me that
21
he doesn't have personal access to the customer balance
22
system.
23
Okay.
That's -- as far as Frank's way of
24
looking at it and my way of looking at it, that's a
25
little bit of a crazy comment, because you would think

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that the regional vice president of a bank could find
out a customer balance if he needed to, especially when
we are talking about tens of millions of dollars that
are supposed to be sitting in an account.
And, ultimately, Frank just never responds in
full to these comments.
Frank -- excuse me, Frank Preve and Frank Spinosa; I had
better separate them out.
9
10
Right.
He just let's it go, as does
Frank Spinosa never fully responds to
these comments; is that what you're saying?
11
Not to my knowledge.
12
Well, are you --
13
And then -- hang on.
14
Mr. Preve's last comment -- and I think this
15
is probably more indicative than anything -- and during
16
all this idiocy, I have to remain nice and smiling just
17
in case we need him.
18
19
So instead of calling him on it, he just kind

of let's it float.
20
21
you to talk about this issue?
22
23
24
25
Do you know if Frank Preve followed up with
I just told you he did.
Yes, we spoke about
That's you and -- he indicated he knew that
it.
Spinosa was lying in that conversation?

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He told me that -- his comment was something
to the effect of -- and it was -- it was subsequent to
this, because it was involving other investors that
might have a reason to speak to Spinosa; and he told me
that we -- I needed to rein Spinosa in, that I needed to
be careful with him, don't rely on him to do too much
for me.
8
9
It was general terms like that, because he

tends to run at the mouth and not sound like he knows
10
what he's talking about, which is true about Frank.
11
That's one of the reasons I gave him that -- even for
12
that very simple conversation where I gave him a
13
script -- when I say "Frank," I mean Frank Spinosa.
14
15
16
And that's what you said, that -- I'm sorry.

I didn't catch the last part.
17
18
19
20
Thank you.
That's why you gave him a script?

A
That's one of the reasons I gave him a script,
yes, to try to stick to the script.

Q
Did you -- going to the first paragraph:
Are
21
those guys at Commerce the stupidest people you have
22
ever met?
23
upset you were with Tolomer for failing Scott -- telling
24
Scott about our conversation, and as soon as he leaves
25
my office, he calls Scott to ask about the conversation
I just got done talking to Frank Spinosa, how

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he just had with me.
2
3
4
Is there a reason that you didn't want Spinosa

talking to Frank about the trust account balances?
A
That's not what that is talking about.
is them not wanting Spinosa to talk to me.
me not wanting -- I'm not part of this.
Preve and Levin.
arrest.
9
10
11
This is not
This is between
I have never seen this until after my
You didn't see this email until after you
returned from Morocco?

A
12
13
This
That's correct.
And if you read that first paragraph, that is
Frank being angry -- Frank -- let me clarify.
14
That is Frank Preve being angry with Frank
15
Spinosa because he's telling Spinosa not to tell me
16
something, and then I'm getting on the phone calling
17
Preve and relying the exact conversation that Preve had
18
with Spinosa and Preve had with Tolomer -- and Levin had
19
with Tolomer.
20
It says:
I just got done talking with Frank
21
Spinosa, how upset you were you with Tolomer for telling
22
Scott about our conversation.
23
24
25
What did Tolomer tell you?

A
I don't remember the specifics; but, listen,
anytime anybody spoke about me or about this investment

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scheme with someone at the bank, okay, I was notified.
Okay?
By Tolomer or by Spinosa?
By Spinosa.
Okay.
Read the next sentence.
out:
And as soon as he leaves my office.
8
9
You can't leave that
Now, so this is what is in Preve's head,

because I am not having a conversation with him.
10
Preve, basically, dresses Spinosa down for
11
what Tolomer did in telling me about a conversation that
12
was had.
13
told me, okay?
14
At least he believes Tolomer is the one that
Right after that, after telling Spinosa how
15
mad he is about what happened with the Tolomer
16
conversation, as soon as Preve is done talking to
17
Spinosa, Spinosa picks up the phone and tells me about
18
that conversation.
19
all up in arms -- well, really Preve, because it's from
20
Preve.
21
And that is what has Preve and Levin
And you had a conversation with Preve; and in
22
that conversation, he indicated to you that he knew
23
Spinosa was lying.
24
25
Is that what you're saying?
That was on multiple occasions.
There were
multiple times when Frank and I chatted and he was

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telling me that I needed to be careful with Spinosa, as
to what I used him for.
Frank and I didn't get into much detail with
regard to other people.
job.
find out that someone was loose lips, that he thought
they couldn't be trusted, whatever it was, he would
bring that to my attention; and obviously, this is a --
you know, this is a glaring thing to think that you have
Frank had his job.
Other people had their jobs.
I had my
But when he would
10
tens of millions of dollars in a bank account and the
11
regional vice president tells you it's not there.
12
13
14
Do you know the specific amount that they were
discussing, first of all?

A
My recollection was that it was some
15
20-some-odd-million dollars, but I don't recall
16
specifically.
17
18
Your recollection was that Spinosa indicated
that there were 20-some-odd-million dollars?
19
No, that there wasn't.
20
Oh, that there --
21
In other words, whatever amount they were
22
looking for, Preve said, you have -- he's giving the
23
same sales pitch to Spinosa that he gave to Harris.
24
It's the same type of thing:
25
all this money -- and this happened on several
We have got control over

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occasions.
banks.
I don't know if it happened with other
But, basically, it was:
You guys have got
control over all this money.
to be the source of your repayment, and then the bank is
looking at it going, what are you talking about?
don't have this money?
8
9
10
Ultimately, this is going
We
And since both Harris and Spinosa are on my

payroll, both of them are like, well, what the heck do
we say to them?
11
Ultimately, I told Spinosa any time someone
12
asks you about anything having to do with me, invoke
13
bank secrecy.
14
anyone, even if the money comes from them to me.
15
my account.
16
You can't discuss my accounts with

It's
Did -- do you know if the decision not to
17
extend the line of credit to the Banyan Group by
18
TD Bank, or Commerce Bank at the time, was made by
19
Spinosa himself?
20
No.
21
And do you know anything specific about that
22
No.
It was made by a credit group.
decision?
23
No.
24
Okay.
25
I know that for many -- the only thing I know,
How about --

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specifically, is that for many months, it basically was
going nowhere.
year, because I remember emails between Levin and Preve
that Preve actually showed me where -- he may have
actually sent me copies of it, where he is saying,
George really wants this line of credit and I'm
basically running out of things to tell him, okay.
It might have been up to a period of
And he actually tells Spinosa put -- he either
told Spinosa or Harris -- I don't remember which lending
10
instance it was, but one of them tells -- Preve tells
11
one of them, listen, just at least go through the
12
motions just as a show for George so he thinks something
13
is going on, so he thinks something positive is
14
happening.
15
16
Do you know how long after this email was
sent, that that supposed email was written?
17
Well, do you have the email?
18
I don't have a copy of that email here.
19
It's in existence.
20
21
Then I can tell.
If I find it, while you're
here, I'll show it to you.

Q
Do you know if for about a year Frank was
22
following up with Spinosa about the issue of obtaining a
23
line of credit from TD Bank?
24
That wouldn't surprise me.
25
That wouldn't surprise you.

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And do you know that it was several weeks
after the meeting -- the email that we just discussed
between John Harris, that Preve sent several emails and
had discussions with John Harris and others at
Gibraltar?
That would not surprise me.
My understanding
was that the entire time, George wanted a line of
credit.
And Frank's concerns regarding -- not Frank
10
Spinosa, Preve's concerns regarding Spinosa, were those
11
relating to his ability or his competence, or were those
12
relating to the fact that he was concerned that he
13
wasn't going to keep his mouth shut about this?
14
You have got to remember that the people --
15
all the people, all the various tentacles of the Ponzi
16
scheme, I tried very hard not to let people talk to each
17
other, even within my office:
18
Deb that I was doing with Boden, things hidden from
19
Boden I was doing with Szafranski, things hidden from
20
Szafranski I was doing with Deb, all the way around.
21
It was the same thing in the Preve banking
I kept things hidden from
22
thing.
23
mind; I can tell you that Frank spoke to me the way he
24
normally would related to the illegal activity we were
25
doing.
I don't know, specifically, what was in Frank's

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And that is, be careful what you use Spinosa
for, he'll get you tripped up, be careful, he'll put you
in a trick box.
4
5
My question is, though:
Is that related to go
his competence or his ability to do his job?
As opposed to his involvement in the scheme?
Correct.
I think that his competence goes to his
ability to do the scheme.
You want bright people
10
involved in the fraud, so if -- it could have been a
11
comment as to his competence in the fraud.
12
all intertwined.
13
I think it's
Are there any emails between you and Frank,
14
specifically, indicating that he was -- that Frank was
15
aware that Spinosa was involved in the fraud?
16
17
18
19
20
A
anyone.
Q
I don't think I ever put that in any email to

I don't think I would have.
With respect to Preve or with respect to
Spinosa?
A
With respect to -- other than emails that you
21
can read and figure out that there is some fraud going
22
on -- probably more in emails between Levin and I than
23
any place; secondarily, emails between Frank Preve and
24
I -- I would never have put in an email, hey, be
25
careful, I know you told me to be careful of Spinosa

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because he knows about the fraud and we don't want him
to mess up our fraud.
speak.
Are you aware --
You use Ponzi-speak.
You're aware that after this email from May
That is just not the way we
23rd of 2008, and after the Harris email that we
discussed, that both Frank Preve and George Levin sought
independent verification of trust account balances on
10
several occasions, correct?
11
They did, yes.
12
Okay.
13
14
Through you and through other
independent sources, correct?

A
Well, "independent" is an interesting word
15
because at different points in time, even the banks
16
weren't independent, so --
17
Well --
18
-- yes, to your specific question, but --
19
Let me be --
20
-- as what it really means...
21
Let's talk about the independent third-party
22
verifier, Michael Szafranski.
23
Was Preve -- well, you indicated earlier this
24
morning that Preve was aware that Szafranski was a
25
player?

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At a certain point in time, yes.
Can you be more specific?
No.
4
5
6
7
Like I told the other gentleman this
morning, I don't know the time frame.

Q
Can you tell me how Frank Preve was aware that
Mr. Szafranski was a player, as you called him?

A
I can't pinpoint it for you.
It's the same
way -- everyone kind of eases into this type of fraud.
They start doing little bitty things that are illegal,
10
and eventually it grows into significant things.
11
Like with Szafranski, it starts out with him
12
realizing that the money is not there; me realizing that
13
he knows that the money is not there; ultimately to the
14
point where he is bringing in investors and it escalates
15
to the point where he is taking over $10 million from me
16
for his participation in the fraud.
17
So you're -- so Frank became aware -- beyond
18
these -- I'm sorry, beyond these two emails, you're
19
generally pointing to other emails that Frank Preve had
20
with you relating to trust account balances and
21
irregularities in trust account balances?
22
In order to get a full picture of my
23
relationship with Frank and to the extent of his
24
knowledge of the fraud, you can't look at this.
25
not even a thumbnail sketch of the email traffic.
This is

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I understand.
You need to really look at everything that's
going on, all the red flags, all the things that are
being ignored, the fraudulent things he's asking me to
do, the balance corrections; the one point in time when
he get a statement and glaring red flag, I sent him a --
Michael Szafranski sent him a balance statement and it's
completely wrong.
and Frank write back:
It's off by almost a billion dollars,

This is impossible.
10
Can you --
11
You would think at that point in time maybe he
12
would do something other than write back to me "this is
13
impossible."
14
15
that email?
16
I don't.
17
If you -- if --
18
I do remember it says, "did you find it?"
19
No, I didn't -- it's not -- it's not in this.
20
It's related to the 9146 account.
Can you tell me, do you recall the date of
I remember
21
him saying, "this can't be right.
22
because you're supposed to have almost a billion dollars
23
in the 9146 account, alone."
24
25
You need to fix this
Do you remember having a conversation with
Frank Preve about Irene Stay's ability to --

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Sorry, that would be inabilities.
That is my question.
What -- what was -- do
you recall that conversation with Frank Preve around
2007?
I'm sorry?
Do you recall that conversation with Frank
7
8
9
about Irene Stay's inabilities, as you call it?

A
We talked about the fact that Irene could be a
knuckle head, okay, when it came to her work.
We talked
10
about the fact that she didn't appear to have a solid
11
grasp of what she needed to do in her overall job
12
description; but, generally, when we spoke about those
13
things, we also had to remember the fact that she was an
14
instrumental part of what we were doing in the Ponzi
15
scheme and that she did properly effectuate hundreds of
16
million dollars of transfers for us on a daily basis
17
flowing in and out of trust accounts and the like.
18
had to balance her ineptitude with the fact that on the
19
things that really mattered to what we were doing in the
20
scam, she was quite effective.
21
22
So I
Was Frank aware of the fact that she was
involved in the scam?
23
24
frame.
25
Eventually, yes, but I don't know the time
Do you know the basis for that statement?

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Sure.
He's actually -- he actually sends -- I
mean, there's a bunch of red flags, but he's sending
balances to Irene.
So picture this:
This is supposed to be real
investment, and he's sending balances to the CFO, who is
supposed to really be sending the balances to him.
sending balances to her saying, send me these balances,
move the money around, this is how much you're supposed
to have in this account; this is how much you're
10
He's
supposed to have in that account.
11
It's not the way a -- at least not any
12
investment I had that was real, that's not how you do
13
it.
14
provides it to you, not the other way around.
15
16
Generally, you ask for a balance and the CFO
Did you consider Frank Preve to have more
financial and accounting expertise than Irene Stay?
17
Yeah, far more.
18
And in the conversations that you had in 2007
19
20
with Mr. Preve regarding Irene Stay's inability, did -A
Listen, do you have something specific this
21
conversation, because this is the first time I'm hearing
22
conversation in 2007.
23
Well --
24
We were talking generally before that.
25
-- are you talking about general conversations

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through 2007, '08 and '09 about her inability, or do you
recall that it was only in 2007?
No.
Throughout my relationship with
Mr. Preve, we had conversations on and off about Irene
and whether she was up to the challenges of everything
that was going on.
she fell down on it.
8
9
You know, there were things where
But overall, as I reminded him, usually over

cocktails, I remind him, listen, she has got a lot on
10
her plate.
11
of the law firm, plus she has got to do all my business;
12
and all the payments ultimately get to where they are
13
going.
14
She's got to run all the legitimate business
Until the Ponzi scheme exploded, every single
15
payment got to where it needed to go.
16
that was going to keep us all out of jail, she was doing
17
a good job.
18
So in the stuff
I understand that, but did Frank indicate to
19
you early on in 2007, when you first started doing
20
business with Levin, with the Banyan Group, did he
21
indicate to you that he was going to make sure that
22
everything was accounted for properly in order to make
23
sure that Irene was not missing anything?
24
25
He may have.
Do you have an email to show me that he says

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that?
2
3
I don't have a specific email, but I'm asking
for your recollection.
That he's going to make sure?

I assumed -- and this is an assumption on my
part.
track of the hundreds of millions of dollars we're
moving.
9
10
I assumed the entire time that Frank would keep
That's why I relied on him.

But as far as the balances, I think you may be
missing my point.
11
No matter what, the bank balances should have
12
nothing to do with Irene.
13
button -- if these are real balances, hit a button, look
14
at the screen, and then print that off and send it to
15
Frank.
16
Irene should be able to hit a
She shouldn't have to do any accounting to get
17
there.
18
"zzzscht," off we go.
It's a matter of pushing a button and print and
19
Can you put that on the record, "zzzcht"?
20
Okay.
21
What was really happening was, because Frank
Off we go.
22
knew this was happening, it is completely opposite:
23
Frank tells Irene, or me, or both, this is what needs to
24
be in the accounts.
25
and sends it off to him.
Okay.
And then, she fixes it up

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That's never the way it should work in a
legitimate investment deal, never.
calling my broker at Smith Barney and saying, I need to
know the balance, there's supposed to be $3 million in
there; can you make sure it says 3 million then send it
to me, please?
I can't imagine
Can you turn to tab two, the last email in tab
Yes.
10
If you read the first -- if you go to the
two?
11
bottom of that -- that string, it's an email from
12
October 1st, 2009, from Larry Lawrence King -- I'm
13
sorry, Larry King to Frank Preve.
14
Yes, I have it.
15
Yes, and it indicates that:
October 1st, 2009, at 8:45?
16
needs to hit this AM.
17
penalty box with a few of my investors.
Frank, my wire
18
If they don't, I will be in the

Thanks, Larry.
Frank then responds to you at 10:52 that
19
morning --
20
I'm sorry?
21
Frank then responds to you, if you go up to
22
the chain --
23
Yeah.
24
Okay --
25
Okay.
Let me go ahead and read that.

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-- Frank is saying, in the middle of that
paragraph -- let me just read the whole thing:
just doesn't smell right.
for three non-Florida-bar-related trust accounts: SFS,
LMB and BIF.
of entering a fourth relationship with AJ, and I am
concerned that we are going to find ourselves in the
same fix in a couple of months when we have $20 million
in payments due.
This
So far we have payment issues
The question is why?
We are on the verge
We must fix these three accounts so
10
that they never hear, smell or see any problems with
11
trust disbursements.
12
and without fail; and I need your assurances that I'm
13
not committing a gross stupidity by throwing good money
14
after bad by supporting the AJ program.
15
important to me personally and to our ongoing sanity.
16
Please.
They should be done automatically
This is
17
Okay.
18
And then you go and you -- the previous page,
19
you have your response, where you indicate to him:
20
are not being stupid, and LMB, according to cash
21
management, just went in new clients, more to follow and
22
close your nose.
Everything is fine.
You
Knock it off.
23
Why are you telling him on October 1st, 2009,
24
when this thing is unraveling, that he is -- that he is
25
correct, that his email below is correct?

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Why am I not telling him that?
Why are you telling him?
You are telling him
he's not being stupid.
two emails.
Okay.
Explain that it to me.
Okay.
We're talking about, now, you've got
these.
right, we're about to get in with.
You are missing all the Ponzi-speak in these
These are all notes to Mr Scherer's clients,
10
Correct?
11
We have BIF, which is Barry Bekkedam's and Mr.
12
Scherer's clients; there is money going through them.
13
What Frank is telling me here is that it
14
doesn't smell right.
15
up.
16
There are problems.
Clean them
He's not asking me, as someone would who
17
really didn't know what was going on, he's not asking me
18
anywhere in here:
19
bank statements.
20
you're sending me.
21
balances.
22
I need to see, for example, paper

I need to see something more than what
I'm concerned about all the
That he is asking me in this, when I read this
23
is, he's saying:
24
of what we're doing properly.
25
additional headaches.
Make sure you're handling you're part

I don't need these
It doesn't smell right.
We must

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fix these three accounts so I never hear, smell or see
any problems with trust disbursements.
We have been talking about that there are
dozens of emails like that, where we're not sending the
disbursements out on time because Irene doesn't know the
proper balances and doesn't know where the payments are
going.
8
9
One of the key things I tell him to do, if you

read my email is:
Close your nose.
Okay.
Which is my
10
indicator to him, don't worry, I've got -- you worry
11
about your side.
12
doing.
13
Don't worry about my smelling what I'm
I've got my side under control.

You have got to remember by this point in
14
time, sir, there is massive fraud going on.
15
funding tens of million dollars.
16
without a stitch of paper.
17
We are
Mr. Preve is funding
Now, Mr. Preve might have had momentary
18
lapses, okay; but you're talking about sending me in
19
excess, actually, of $25 million, in paper that you're
20
saying he didn't know was fraudulent with no paper, no
21
plaintiff, no defendant, no deal number, no assignment,
22
nothing, zero, just sending me the money because he
23
knows I have other payments to make.
24
25
It's glaring, so you can't take one email out

of the context.
You're taking one email out of the

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context of some seven-, eight-, ten-thousand, maybe
more, emails and trying to put a twist on it that really
isn't there.
It's all Ponzi-speak, especially by
October 1st.
forth and Frank sending more emails, it's crazy.
There is so much fraud flying back and
Isn't he indicating that the trust
disbursements should be done automatically and without
fail?
10
That was something we talked about early on:
11
They were supposed to be done -- quote, unquote, Irene
12
is supposed to get these things out.
13
What was happening over here, what he's
14
telling me is, you're sending up too many red flags.
15
are about to go into the business with AJ.
16
to take in a whole lot of money; we can't have this same
17
thing occurring.
18
We
We're about
One of the themes that Frank and I were
19
discussing regularly around the time that all of
20
Mr. Scherer's clients were coming in, was the fact that
21
these people aren't playing.
22
away with certain things and smoothed things over with
23
certain of the investors we had before, we don't have
24
that same kind of thing with these -- Von Allmen,
25
Clockwork.
Where we could have gotten

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These are serious people.
They're going to be
investing all kinds of serious money.
completely different level of investor.
to be asking a completely different level of questions,
and we need to tighten the strings on our -- on what
we're doing, pulling it all in, rein it in.
They are a
They are going
And that didn't occur, correct?
You weren't
able to rein it in when it came -- after October 2009
with the Von Allmen Group?
10
11
Well, we reined it in enough to convince them
to invest with us.
12
Ultimately, the whole thing exploded, but we
13
certainly reined all the deal packaging in and the sales
14
and the fraudulent documents, we reined that in enough
15
to convince them to invest a substantial amount of money
16
with us.
17
18
Do you recall testimony earlier last week
regarding the conference call with --
19
Actually, before we go there, you were talking
20
about the fact that there were deals being papered --
21
not being papered, towards the end, specifically, that
22
were -- were a very large quantity?
23
Do you know if Frank ever saw unredacted
24
documents?
25
I'm sorry?

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see --
Any unredacted deal documents, did he ever
Does that have anything to do with that
first -- I lost you because you started out that there
were deals that were not papered.
I'm asking the issue of -- well, first of all,
with the papering of deals, was Frank -- did Frank ever
see any -- any documents that were not redacted?
Yes.
10
When?
11
In my office on multiple occasions.
12
And Frank --
13
I may have sent some to him by email, but he
14
saw many of the deal packets in my office.
15
when we created some of them.
He was there
16
He saw you create deal packets?
17
Well, he was in -- at certain points in time,
18
it would be almost impossible, okay, not to see us
19
creating deal packets back there because we had some
20
days where we were creating five, ten, fifteen deal
21
packets, and that is all that was going on.
22
So if you were one of the people who was
23
allowed back into that area, yes, it's very possible
24
that you would have, and highly likely, I mean, that he
25
would have been there to see something going on.

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2
3
4
Who specifically did he see preparing deal
packets?
A
I don't recall specifically, but he did see
the deal packets.
Unredacted?
Unredacted, yes, sir.
In your office?
In my office.
Can you tell me who would have been present
10
when he did so?
11
Just me and Frank.
12
Okay.
13
As a matter of fact, I recall a specific
And --
14
occasion where he said, show me what you're showing
15
Szafranski.
16
Szafranski was looking at.
Okay.
He wanted to get an idea of what
17
What was your response to that?
18
Okay.
19
So you showed him what Szafranski was seeing;
20
you showed him deal files?
21
Yes.
22
Which were unredacted?
23
Yes.
24
Okay.
25
And you were the only one present at
that meeting?

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As I said earlier, I tried to limit who was
there whenever I was talking about or doing something
related to any of this, yes.
only person in there showing him the deal packets.
So I would have been the
Do you recall an approximate time frame?
I do not.
What did Frank say in response to that, if
anything?
He didn't say anything.
10
Did you ever tell Frank that --
11
To my knowledge.
12
make a comment like:
13
like fraud.
14
What are you doing; this looks
He didn't say anything like that.
He just looked at the deal packets, and that
15
was that.
16
at.
17
I mean, he certainly didn't
He wanted to see what Szafranski was looking
Did you ever tell Frank Preve or George Levin
18
that they could not look at, you know, redacted deal
19
documents because they were subject to confidentiality?
20
21
way through.
22
23
24
25
Early on, sure; and I told George that all the
And you did so in emails and verbally,
correct?
A
Absolutely.
And I probably wrote it to Frank
telling him, don't, you can't see this stuff.
But what

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I told Frank in emails and what Frank and I actually did
sometimes don't match.
Okay.
As evidenced by Frank's behavior, back.
When Brian Jedwab and Ari Glass came in
And --
December of 2008 to perform additional due diligence --
Yes.
-- did they look at deal files?
Yes.
10
Redacted?
11
My recollection is they were redacted, that
12
Ari and Brian looked at redacted files.
13
Did Frank speak to you at that time and ask if
14
he could join in on the due diligence and go and see the
15
files, as well?
16
I don't recall one way or the other.
If there
17
is some email traffic, it might help refresh my
18
recollection, but I don't recall one way or the other.
19
That's not sticking out.
That was a very
20
tense period of time for all of us involved in this
21
scam.
22
23
24
25
December of 2008, the time frame you're
talking about right now?

A
You're talking about the due diligence where
we're going to visit the other lawyers?

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Correct.
Around the time that they wanted to do that
enhanced due diligence and see the other lawyers, yes,
that was an extremely intense period of time for all of
us.
6
7
8
Did Frank want to be involved in that
diligence is my question.
A
I don't recall one way or the other.

I do recall that Frank -- either in an email
10
or in testimony -- said that he didn't know who we were
11
going to see, and that if he knew that we were going to
12
see Fla- -- excuse me, Bates Koppel and Rossi and
13
Herskowitz, that that would have set off a tremendous
14
red flag in his head.
15
or something --
16
17
That was -- I think his testimony
That -- are you talking about his deposition
testimony in the Razorback matter?
18
Could be, yeah.
19
Have you reviewed that deposition?
20
I saw pieces of it, yes.
21
You haven't read the whole thing; you've just
22
23
24
25
seen portions?
A
I don't think I've read the entire thing.
was looking for specific things.

But I do recall him saying that, and that --

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the only reason I am bringing that up is because that
reminds me that he was at least involved at some level,
because I remember reading that, saying, well, that's
nonsensical.
that I was going to be doing any due diligence on behalf
of the Banyan folks, which is really who I'm doing it on
behalf of because they're the borrower; and then Frank
is not going to be asking me every minute, what are you
doing.
10
There is no way, at this point in time,
What you're saying is nonsensical is Frank's
11
statement that he would have thought it was a red flag,
12
had he known the names of the attorneys?
13
14
of reasons.
Sure.
Because -- and I'll tell you a couple
15
One, there's a much earlier email between me
16
and Frank, maybe even George, where I'm discussing the
17
fact that I'm allegedly getting cases, okay, from Doug
18
Bates, all right, so he's heard the name before.
19
Then, when I'm going to do this due diligence,
20
generally, if you look at my cell phone records, for
21
example, and the like, email traffic, whenever I'm doing
22
anything for the hedge funds related to due diligence,
23
Frank wants regular updates.
24
So it is beyond believability, far beyond it,
25
to think that I would trot around with Brian Jedwab and

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Ari Glass to three different lawyers' offices and never
tell Frank what I was doing.
3
4
It's just not possible.
So you're saying you did tell Frank what you
were doing or you did not?
Sure.
So he knew you were conducting diligence, and
I absolutely did.
he knew you were meeting with these people?
Sure.
He knew their names?
10
Absolutely.
11
So he knew the individuals that you were
12
meeting with, Brian Jedwab and Ari Glass?
13
Yes, sir.
14
And through a conversation or through emails
15
16
17
18
19
20
you informed him?

A
Possible through both, I don't recall; but I
at least told him.

Q
Do you recall if it was personally or over the
phone or by email?
A
I recall either from -- Doug Bates's office
21
phone or from my cell phone, when I got done with one of
22
those meetings, with the Bates Koppel meeting, that I
23
called Frank to update him and let him know that
24
everything was going fine.
25
whether I called from their office phone or from my cell
I just don't remember

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phone.
3
4
5
You didn't give him anymore specifics than
that, did you?

A
Other than to let him know that we met with
the lawyers and they verified everything perfectly?
Right.
Just that.
Did you give him -- you gave him the names of
9
10
11
12
the lawyers, though?

A
He knew ahead of time who the lawyers were.
had told him that Russ Adler help me set them up.
Q
You had told him that Russ Adler helped you
13
set up these lawyers who were going to be putting on a
14
show for these investors in New York?
15
16
17
Yes.
Here's what happened.
You have got to
take it in order.
Initially, the hedge funds are sending us a
18
request for enhanced due diligence.
19
speak to some of our referring lawyers.
20
They just want to

Okay.
If you recall my testimony from last week, we
21
were just going to give him the names.
22
email out to the law firm, and we were just going to
23
give him some names of some people who would simply
24
verify, yes, they sent us labor and employment cases and
25
yes, they are pleased with us.
I sent that mass

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2
Then Brian Jedwab wanted to do more enhanced:

I want to be able to talk to these people at length.
That ultimately morphed, grew into a coming
down to all actually meet with lawyers.
in time, I needed to enlist the help of someone who knew
about the Ponzi scheme.
went to Adler, because Adler has been chomping at the
bit to get involved and to be able to make more capital
for himself.
10
At that point
So, as I testified last week, I
I have him go ahead and set up the meetings
11
with Rossi and Herskowitz, the people that I didn't
12
really know at that point in time and assist me in
13
setting up the Koppel Bates meeting.
14
And, yes, I kept Frank apprised as to what I
15
was doing because both Frank and I knew that any future
16
business with the hedge funds in New York would be
17
contingent upon passing this due diligence with flying
18
colors.
19
20
And was Jedwab convinced of the authenticity
of the investment strategy, let's call it?
21
He led me to believe he was, yes.
22
And do you believe he was?
23
At that time I believed he was, yes.
24
In hindsight?
25
MR. SCHERER:
Objection to the form.

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Well, yes, I believe Jedwab, up until the
time -- I believe Jedwab had suspicions; but as I
testified last week, I also believe that the second
Jedwab knew for certain that something was wrong, if he
ever did, he would have been screaming at the top of his
lungs for the police.
Do you know if Jedwab or Ari Glass provided
the results they -- they prepared a due-diligence
memorandum; do you recall that document?
10
11
12
I saw it subsequent to the Ponzi scheme
exploding, subsequent to October 2009.

Q
Do you know if Frank Preve, around that time,
13
in December, January -- December 2008, January 2009,
14
tried to obtain that due diligence report?
15
No.
My recollection is that they actually
16
gave that document -- if we're thinking about the same
17
document, I saw it before October of 2009, actually,
18
because that document actually came to Frank through
19
Jack Simony; but if you would show me the document, I
20
would be able to not go back and forth like that.
21
22
23
24
25
And that came -- that was provided to Frank by
Jack Simony by email?

A
Hang on a second.
Are we talking about the
Kroll due diligence report?

Q
We are talking about the due diligence

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memorandum written, by Brian Jedwab, that has as the
date on it, various dates.
Can you show it to me?
I don't have it.
5
6
But you don't know if that was provided to

Frank Preve one way or the other, do you?
8
9
I don't have it on me.
One of them -- I have to see it.

At least one, maybe both, were provided -- and
when I say both, I mean the Jedwab due diligence letter
10
and the Kroll report.
11
Preve by Jack Simony and showed to me.
12
13
14
15
16
17
One or both were provided to
But without seeing it, I can't tell you which

one.
Q
Okay.
The Kroll report, do you recall if that
was provided to Frank by Jack Simony in an email?

A
No, no, at least to my knowledge.
I don't
think he would be that stupid.
18
Okay.
19
I mean, that was an internal document.
20
don't think Jack would do that on an internal.
21
think he would deliver it to him.
22
I
I don't
Did you ever tell Frank Preve and George Levin
23
that you were spending a million dollars in marketing
24
per month to obtain --
25
It was some sum like that, yes.

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And that you were doing it through various
online advertisings and other methods, the million
dollars being spent; do you recall that?
At various points in time, I discussed with
both Mr. Preve and Mr. Levin as to what we were doing to
market, quote, unquote, the investments, quote, unquote.
At various times --
Different conversations between Preve and I
9
10
11
and Levin and I.

Q
Is it fair to say that they asked you several
questions about that over the course --
12
Give me a time frame.
13
2007 to 2008.
14
I'm sorry.
15
Let's say 2007.
16
Well, back before Preve knew what was going
Give me the time frame, again.
17
on, I definitely tried to sell him.
18
could easily picture him asking me that.
19
20
So I could -- I
Do I have a specific recollection of it, no;

but was it something that ultimately came up, yes.
21
But, again, there's difference in
22
conversations between myself and Preve and myself and
23
Levin.
24
25
When specifically did Preve know what was
going on?

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I can't tell you specifically.

Again, here's what you need to do:
If you
look at all the email traffic, you'll see -- with almost
everything that was involved, probably everybody that
was involved, you'll see that there's -- there's a
change-over.
People -- it's not like one day you wake up
and say, oh, okay, I'm going to tell Frank we're
committing fraud today.
10
That's not what happens.
People see little things, and then based upon
11
how they react, that's how you decide whether to open
12
the -- let's call the Ponzi door a little bit more.
13
Okay.
You open it a little bit more.
14
see a little bit more.
15
cash.
16
You start luring them in a little bit more.
17
that they are clearly players.
You see
Eventually they either do or don't get

involved in a much higher level.
20
21
You start feeding them money,
You start giving them the rock-star lifestyle.
18
19
That's what happens.
If there are people that I tried to get

involved that ultimately didn't get involved.
22
Did you ever lie to Frank Preve?
23
Yes.
24
Is it fair to say that you lied to him
25
They
throughout the course of your dealings with him and

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George?
About various things, yes.
Yes.
to Morocco?
Sure.
Including through the time that you went
When I went to Morocco, I told him I
was trying to fix this through London Bankers.
a complete lie.
8
9
10
11
That was
Why would you make up that story if Frank knew
what was going on?

A
I think I was simply desperate to try to put
everyone at ease while I decided what to do with myself.
12
Here's the thing, given Frank's level of
13
knowledge and the fact that this thing is exploding, at
14
that point in time, I was deeply concerned about what
15
Frank might do to attempt to save himself.
16
And until I decided what I was doing, I wanted
17
to hold everybody at bay and the only way I was going to
18
do that was to lead everyone, both people involved and
19
not involved, that I was going to be able to solve the
20
situation.
21
22
What did you think Frank might do to try to
save himself?
What were you concerned about?
23
Go to the police.
24
But you were already in Morocco; why would you
25
be concerned about that?

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doing.
4
5
6
Because I had not decided yet what I was
You weren't sure whether you were going to
return at that point?

A
I wasn't sure whether I was going to kill
myself, continue to flee, return.
But --
There were a whole myriad of things that were
going through my head at that point in time.
10
If you recall, early on, when I fled, I sent
11
emails to a bunch of people trying to figure what I
12
actually owed people to get their principal back.
13
suppose in some warped part of my mind, I was believing
14
that maybe I can get enough money together to make these
15
people whole so that this wouldn't be as bad as it
16
ultimately turned out to be.
17
Do you -- you indicated earlier in your
18
testimony that you had sent emails falsely exculpating
19
certain people, and that included Frank Preve, correct?
20
I believe I sent one to Frank.
If you have
21
it, it would be easier if I could just see it, but he
22
certainly -- I think I sent one to him and George
23
together, falsely ex- -- exculpating them.
24
25
Yeah, if you -- if you go through the tab one,
it's -- I believe it is -- it's -- I'm sorry.
It's

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October 31st, 2009, from you to George Levin, and it
says -- subject line is "me" --
Did you find it yet?
Do you have a time?
It's chronological in tab one.
Me.
It states, do not --
I'm just trying to help.
"Do not try to bail me out of this, save
Okay.
Yeah, I got it.
10
yourself.
11
am the liar.
12
either go to jail or die.
13
through watching me go to jail?
There you go.
You and Frank did nothing wrong.

I am the thief.
I did.
I am the scum bag.
I
I
Why should I put my family

Love forever, Scott."
14
Yes.
15
Are you indicating to me that that email is a
17
As to Frank it is.
18
It's not as to George, but it is as to Frank?
19
I can't -- even as I sit here today, I still
16
lie?
20
don't fully understand at what level George may have
21
been involved.
22
I just can't say one way or the other.
There are things that indicate to me, perhaps,
23
that he was in the know, to some extent; and there are
24
things that indicate to me that he absolutely believed
25
everything was accurate.
So I can't say one way or the

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other.
But, in any event, I had tremendously deep
feelings for George and Frank at this point in time.
And I was extremely emotional, and it -- it
was my decision, by the time I wrote this, that I was
going to kill myself.
anyone else to have to have problems with authorities
and the like after I was gone.
that?
10
And I saw no reason, at all, for
Why put them through
What -- what purpose would that serve?

Q
So your mental state at this time, when you're
11
sending this email, is that you're going to kill
12
yourself; that's right?
13
I think from the moment I got to -- to
14
Morocco, I had toyed with it; and there were
15
certainly -- and you can tell from email traffic, you
16
can tell where I'm more lucid than others.
17
depended upon what I was -- what pills I was taking,
18
what I was drinking at the time.
A lot of it
19
Okay.
20
I was more lucid than others; but you can
21
clearly tell there are times when I'm trying to fight my
22
way out of it, and there are times when I'm clearly
23
close to killing myself.
24
25
So...
But at this point you know that there are,
literally, thousands of emails between you and Frank

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that indicate that he knew something was up, right?
2
3
I mean, October 31st, 2009, you know -A
Right.
You're thinking that I went through
some kind of analysis while I was sitting there eating
Xanax and drinking vodka and thinking about killing
myself.
never attempted to kill yourself and been in this kind
of position, and you're under the strain that you're
under when this kind of crime is exploding, I can't -- I
10
I mean, you don't go through -- if you have
can't explain to you what my mind-set was.
11
I wasn't sitting there going, well, there's a
12
lot of emails that say Frank is clearly guilty, so let's
13
not try to exculpate him; let's just say George.
14
I mean, I was going to send emails to anyone
15
and everyone to try to save them.
16
reason -- I had already hurt enough people.
17
no reason to cause anymore pain.
18
There was no
There was
But you knew for a fact that you had all these
19
emails with Frank.
20
already today and last week, that you had thousands of
21
emails with Frank indicating that he knew something was
22
up, by October 31st, 2009; isn't that right?
23
24
25
I mean, you have testified about it
I don't understand why that has anything to do
with what I just testified to.

Q
Well, why would you falsely exculpate Frank if

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you know that you have thousands of emails with him that
show that he is part of it?
Okay.
Why would you falsely exculpate Frank if you
Say the question, again?
know that you have thousands of emails that clearly
indicate that he is part of it?
7
8
9
Because I intended to kill myself, and I
didn't want anyone else to have to go through this.

Q
And so you're -- you know you're going to kill
10
yourself or you're intending to go kill yourself and
11
you're purposely being dishonest at the moment that
12
you're about to kill yourself?
13
14
about, yes.
15
Yes.
I was trying to save people who I cared
If you go further down in that tab, there
16
are -- there is an exhibit, Exhibit A, at the bottom of
17
it, were emails of October 31st, 2009, between you and
18
Frank and you and George?
19
MR. SCHERER:
20
MR. RASCO:
Where are you, counsel?

It's just a few more pages
21
behind that October 31st email that we were
22
just discussing.
23
24
25
The subject is "sit tight."
THE WITNESS:
There was a lot of them
that say "sit tight"; which one of them?

MR. RASCO:
It's the one that says

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"Exhibit A" on the front of it.
UNIDENTIFIED SPEAKER:
Is there a Bates
number?
MR. RASCO:
It was produced by the
trustee.
B" has a Bates number on it, but I want to
talk about --
8
9
10
11
The following one that has "Exhibit
THE WITNESS:
Okay.
I have got one that
says Exhibit A.
BY MR. RASCO:
Q
If you go to -- it's a three-page exhibit.
12
you go to the last page of it, it begins with an email
13
from October 30th, 2009, 10:40 a.m.
14
you're in Morocco at this time, right?
If
You're with --
15
Yes.
16
And it's from you to Frank and to George; and
17
it says, on with my office and Adria.
18
Yes.
19
Why were you indicating to Frank and George
20
that you were on a call with Adria if they knew -- if
21
Frank knew, at least, as you testified last week, that
22
Adria, the Bar issue, was fictitious and that Adria did
23
not really exist?
24
25
I didn't want to talk to them about anything.
I was simply putting them off.

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Okay.
Frank responds that -- FYI BSA rumor
control is saying you skipped town, need to straighten
out -- straighten this out quickly.
You asked him where he heard that.
You said -- he says, your office.
You say, me too.
MR. SCHERER:
Broward Sheriff's Office?
9
10
That email says BSO,
MR. RASCO:
BSO, correct.
BY MR. RASCO:
11
And then Frank asks you:
Can you authorize
12
Deb to give me balances so we know what we are dealing
13
with.
14
that he has negotiating capacity when he has none?
I don't want George to suffer under the illusion
15
Yes.
16
He's asking you for trust balances, correct?
17
I believe he was asking me to see how much
18
money we really had so he could decide whether or not
19
George could bail this thing out or not.
20
21
So you -- so Frank on October 30th, doesn't
know what the trust balances are, correct?
22
What they really are?
23
Yes.
24
He knows they don't exist, but there is no way
25
Does he know that they don't exist?
for him to know -- he knows I am taking in money from a

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ton of other investors at this point in time.
doesn't know every deal.
spending, you know.
He
He doesn't know what I am
You're mixing apples and oranges.
So you're saying that he thinks that there is
some money in the trusts accounts, or you think he
doesn't think there is any money in the trust accounts?
I'm telling you he doesn't know what's in the
trust accounts.
wants to balances, because he doesn't want George to
If you read the email carefully, he
10
suffer under the illusion that he has negotiating
11
capacity where he has none.
12
13
He wants to see how much money is left in

there so he can tell George how to proceed.
14
Okay.
15
It has nothing to do with his level of
16
17
knowledge about anything else.

Q
Okay.
And he -- and he asked for
18
authorization for Deb to give him the balances, and you
19
indicate in the following email that you did give that
20
authorization?
21
Yes.
22
And then he indicates that Deb is saying she
23
doesn't have access, and then he asks about Irene.
24
You say, "Let me try."
25
And then he responds on October 30th, 2009:

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"Scott, as a friend, can you just tell me what we are
facing?
I need a little more substance so I can figure out how
long it will take to make anyone whole -- everyone
whole.
everyone else and thus mitigate everyone else's pain,
including your own, and your family's."
We understand it's a mess and a deep hole, but
I am asking for your help so we can help
Do you agree that it would have been -- it was
Frank's intention at that point to make everybody whole?
10
At that point in time?
11
Yes.
12
Yes.
I think he wanted to do the same thing
13
that I ultimately hoped we could do at various points in
14
time, and that is, pay everybody back so that they got
15
all their principal back.
16
Okay.
17
When a Ponzi scheme explodes, that's what
18
And your response --
everybody wants to do.
19
20
whole?
21
Yes.
22
And then you responded to him on October 31st,
23
So you both wanted to make everybody
"Much of my issue does not involve you."
24
25
Okay.
Do you see that?

A
Yes.

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What does that mean?
I have no idea.
You're not sure what that means?
I think it was more to the effect that
there -- I really don't know.
the life of me, I can't even tell you.
me just babbling on.
8
9
10
Okay.
As I'm sitting here, for

It sounds like
So you're not -- I mean, you're not
saying here that Frank was not involved with you, that
your issue doesn't -- this issue doesn't involve you?
11
No.
I'm saying that my issue, whatever my
12
issue was -- maybe the fact that I'm going to kill
13
myself, maybe the fact that I ran, maybe the fact that I
14
destroyed my family, it could have been anything at that
15
moment in time -- again, without being inside my head,
16
you can't understand what was going on at that time with
17
me.
18
19
So you're not sure what this email means:
"much of my issue does not involve you"?
20
At this moment, I don't recollect.
21
Okay.
The follow-up email from Frank,
22
October 31st, "We really need Irene to cooperate before
23
this thing goes public on Monday.
24
the shortage is now 300 million, which is still
25
manageable if we have your cooperation.
We understand that
Let me know."

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2
Do you know what Frank means there?

A
Okay.
Well, it's clear to me that he knows
that -- I mean, he's referring back to the fact that we
have this massive fraud going on.
this time, he thinks that this money is supposed to be
there.
email saying, what do you mean there's a problem?
was all this money, a billion dollars or so in all these
trust accounts, where is it?
Because at this point
10
As you will note, he never sends me a single

There
All he's trying to do is figure out, at this
11
point in time, how much money I had left in the account,
12
if any; because he wants to try to bail us all out.
13
mean, that is what he's trying to do.
14
But if you look -- if you read this email
15
chain and then think about what someone who didn't --
16
who wasn't in on it would have written to me at this
17
point in time, you'll see that they're night and day.
18
You're talking about a broad spectrum of potential
19
answers.
20
21
22
23
ALL PRESENT:
Objection.
BY MR. RASCO:
Q
Okay.
Do you know what he means by "the
shortage is still manageable"?
24
Yes.
25
What does it mean?

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2
I believe he thought that George could come up
with the money to bail these people out.
the money?
And how would George be able to come up with
George was -- to this day, I still couldn't
tell you how much money George really had.
points in time where I thought he was a billionaire;
there were points in time when I thought he was totally
cashed out and only had access to properties.
There were
10
But it was my impression, at least from what
11
Frank had told me and what George had told me and what
12
Sue Levin had, in fact, told me, was that George had
13
more than enough property and the like that he could
14
have leveraged and made these people whole.
15
that's what I was thinking at the time.
16
At least
So you're suggesting that George would -- was
17
willing, or that Frank thought George was willing to
18
sell off other unrelated assets, you know, unrelated to
19
this investment strategy, to manage that shortage?
20
21
22
It could have been any myriad of things.
don't want to guess what the thought process on it -Q
Do you know if Frank was under the impression
23
that there was over $300 million in the trust account at
24
this time?
25
I have no idea.
There should have been a lot

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more than that in the trust accounts.
I don't know.
Do you --
You know, George at that point in time, may
have believed -- again, and this goes to me really not
knowing the extent of George's involvement or lack of
involvement -- George certainly may have believed at
that point in time that there was plenty of money in the
trust accounts.
10
him.
11
were saying --
I don't know how much Frank was telling
So, again, I can't guess for you as to what they
12
Do you --
13
-- I can only tell you what my impression was
14
15
16
17
when I read it.

Q
Okay.
So certainly George had the impression
that there was more than that amount?

A
When you say "certainly," again, you're asking
18
me to get inside their heads.
19
am actually telling you now what I am thinking right at
20
this minute:
21
thought that George was just going to sell off whatever
22
it was; because I knew there was no money in the trust
23
account, so what else would I think?
24
25
I can only tell you -- I
At that point in time, I am certain that I
But you thought that George thought there was
money in the trust account at this time, right?

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I --
I mean, weren't there other sources of
verification that would have led George to believe that:
the screen shots, the independent verification from
Szafranski, the bank visits?
I have reason to believe that George believed
there was still a substantial amount of money in the
trust accounts.
sharing with him.
I do not know how much Frank was
10
11
Frank?
12
email or your recollection, that Frank thought there was
13
more than $300 million in the trust accounts?
14
Okay.
Do you have the same belief as to
In other words, do you think, based on this
As I sit here today, hindsight being 20/20, I
15
don't see how he would have possibly thought that; but I
16
certainly see, in retrospect, as this was all going on,
17
given the fact that he knew that I was getting
18
substantial amounts of money from other investors that
19
he was unaware of -- Sochet, Szafranski; he had no idea
20
how much money I was taking in -- he certainly could
21
have believed that there was billions of dollars still
22
floating around somewhere or that I had taken a billion
23
dollars with me.
24
25
He -- I don't know what was in his head.

You're asking me to guess over and over again, and I

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1
2
don't want to do that.

Q
So you respond:
"That is not the shortage.
That is the amount of money needed to give the investors
back their money.
It will make it easier for -- for everyone."
I really just need to end it, Frank.
Then Frank responds:
"Let's do the right
thing for everyone involved; and your, quote, unquote,
ending it, doesn't sound like the solution that is going
to do it.
Let's talk this through."
10
When you said "ending it" in that email, were
11
you talking about ending your life or ending your Ponzi
12
scheme?
13
Ending my life.
14
Afterwards, you respond to Frank saying:
15
"Tell me what to do?
16
surrender?
17
before I end it?"
18
19
I am at the end of my rope.
Do I end it?
Do I
Do you need me to do something
Did you -- were you honestly asking for

Frank's advice in that email?
20
Yes.
21
Okay.
22
I did.
23
And Frank's response to that email is:
Did you consider Frank a friend?
"I ran
24
once, but people smarter than me talked sense into me by
25
pointing that my absence would destroy the ones that I

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1
loved and was trying to protect.
face the shame of my actions, the vengeance of my
enemies and the nastiness of our criminal justice
system; but I also incurred renewed spirit by the love
of my family and the support of my friends.
will still have many who will support and love you.
will call in ten minutes."
By returning I had to
Yes, you
Do you recall that email?
I do.
10
What did that email mean to you?
11
It was a sincere email telling me that I
12
should turn myself in.
13
14
friendship?
15
At that moment?
16
At that moment, correct.
17
No.
18
Okay.
And you didn't -- you didn't doubt Frank's
You mentioned earlier that there was a
19
meeting that you had with Frank in your office where he
20
saw some unredacted settlement documents.
21
That's correct.
22
Do you know -- well, first of all, did Frank
23
have an office in your office?
24
Did Frank have a what?
25
Did Frank have an office in your -- in RRA?

(954) 525- 2221
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1
No, sir.
Did Frank ever have an office at RRA?
No, sir.
Okay.
And you testified recently that
Frank -- you would see Frank almost daily.
that was on Friday you indicated something to that
effect.
Yeah.
I believe
There were points in time where I saw
Frank everyday, whether we met for drinks or he came to
10
my office or I went to his office or we were going out,
11
yes.
12
13
Okay.
And do you recall how many times he
went to your office?
14
Dozens.
15
Dozens?
16
Dozens.
17
Can you be more specific than that, or you
18
19
20
21
22
23
don't recall?
A
I can't recall.
MR. RASCO:
Can we take ten minutes?
We
have been going for quite a while.

MR. LAVECCHIO:
Actually, instead of ten
minutes, why don't we take a lunch break.
24
MR. RASCO:
25
That's fine.

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Page 1537
1
C E R T I F I C A T E
2
3
THE STATE OF FLORIDA, )

COUNTY OF BROWARD.
)
4
5
I, Michele L. Savoy, Shorthand Reporter do
hereby certify that I was authorized to and did
report the foregoing proceedings and that the
transcript is a true record.
Dated this 19th day of December, 2011.
10
11
______________________________
12
Michele L. Savoy, RPR

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

(954) 525- 2221
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2
C E R T I F I C A T E
THE STATE OF FLORIDA, )
COUNTY OF BROWARD.
)
3
4
I, Michele L. Savoy, Shorthand Reporter,
do hereby certify that I was authorized to and did
report said deposition in stenotype; and that the
foregoing pages, numbered from 1388 to 1538,
inclusive, are a true and correct transcription of
my shorthand notes of said deposition.
10
I further certify that I am not an
11
attorney or counsel of any of the parties, nor am I
12
a relative or employee of any attorney or counsel or
13
party connected with the action, nor am I
14
financially interested in the action.
15
The foregoing certification of this
16
transcript does not apply to any reproduction of the
17
same by any means unless under the direct control
18
and/or direction of the certifying reporter.
19
Dated this 19th day of December, 2011.
20
21
22
23
24
___________________________________
Michele L. Savoy, RPR
Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
25

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09 (4)
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09062943 (1)
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1
1 (1)
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10 (3)
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1525:13
100 (4)
1390:11 1392:11
1407:1 1452:3
1000 (1)
1390:7
10005 (1)
1391:18
1003767rbr (1)
1389:19
1024110 (1)
1389:4
11 (1)
1390:5
110 (2)
1391:24 1392:4
1102368rbr (1)
1389:21
1103802rbr (1)
1389:20
112310 (1)
1480:10
113 (1)
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113173 (2)
1537:13 1538:24
11cv61688jic (1)
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1200 (2)
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1218 (1)
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1221 (1)
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13 (1)
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1346 (1)
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1431 (2)
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15 (2)
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150 (2)
1392:25,25
1537 (1)
1394:5
1538 (2)
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15th (3)
1391:24 1392:18
1426:10
16 (2)
1408:17 1416:4
17 (1)
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19 (3)
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1st (6)
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1500:12,14 1501:23
1504:5
2
2 (2)
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20 (4)
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1533:14,14
200 (3)
1391:4 1393:7 1452:3
2000 (1)
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2007 (9)
1475:3 1496:4
1497:18,22 1498:1
1498:2,19 1517:13
1517:15
2008 (13)
1394:9 1395:23
1426:10 1480:11,12
1480:13,15 1481:1
1493:7 1509:6,22
1515:13 1517:13
2009 (25)
1394:10,10 1412:18
1429:10,25 1432:4
1444:17 1470:7,13
1470:17 1471:13,24
1500:12,14 1501:23
1505:8 1515:11,13
1515:17 1521:1
1523:2,22 1524:17
1525:13 1527:25
201 (1)
1392:7
2010 (1)
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2011 (3)
1388:16 1537:9
1538:19
2015 (2)
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202 (6)
1394:9 1426:7,9
1429:4,5,8
203 (3)
1394:10 1429:1,2
204 (4)
1391:21 1394:10
1431:23,25
205 (3)
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20someoddmillion (2)
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20th (2)
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21 (6)
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3
3 (7)
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300 (3)
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(954) 525- 2221
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40 (1)
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45 (1)
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4th (1)
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515 (1)
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52 (1)
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6
6 (3)
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633 (1)
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7
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700 (2)
1390:3 1393:13
799 (2)
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7th (1)
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8
8 (2)
1388:16 1500:14
800 (1)
1393:3
9
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1495:20,23
954 (1)
1388:24
99 (2)
1388:18 1393:10

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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR

DAY 6 - MORNING SESSION

December 19, 2011

Examination of the witness taken before:

United Reporting, Inc.

IN THE CIRCUIT COURT OF THE 17TH

Case No. 10-24110 CACE (19)

EDWARD J. MORSE and CAROL A. MORSE,

SCOTT W. ROTHSTEIN, et al.,

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

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

United Reporting, Inc.

APPEARANCES FOR SCOTT ROTHSTEIN:

GENOVESE, JOBLOVE & BATTISTA, P.A.

APPEARANCES FOR PLATINUM PARTNERS VALUE ARBITRAGE

United Reporting, Inc.

Two South Biscayne Boulevard

GREENBERG TRAURIG, P.A.

ALEX HOFRICHTER, P.A

APPEARANCES FOR MORSE:

United Reporting, Inc.

JOHN M. MULLIN, ESQUIRE

LAW OFFICES OF ROBERTA DEUTSCH

APPEARANCES FOR EMESS CAPITAL, LLC:

MILLS PASKERT DIVERS P.A.

APPEARANCES FOR ROSEANNE CARETSKY:

Billing Cochran Lyles

APPEARANCES FOR MICHAEL SZANFRANKSI:

APPEARANCES FOR GIBRALTAR:

United Reporting, Inc.

Miami, Florida 331301545

APPEARANCES FOR LEVINSON PEARSON & ASSOCIATES,

99 N.E. 4th Street

APPEARANCES FOR FRANK SPINOSA:

United Reporting, Inc.

CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

SZAFRANSKI'S EXHIBIT INDEX

United Reporting, Inc.

Thereupon, the following proceedings were had:

acknowledged having been duly sworn to tell the truth

and testified upon his oath as follows:

DIRECT EXAMINATION (SCOTT W. ROTHSTEIN)

Good morning, Scott.

My name is Chris Berga.

I'm with the law firm

of Lydecker Diaz and I'm here on behalf of Michael

Obviously, we're going to continue on with our

So I'll try to bounce around a

When did you first meet Mr. Szafranski?

I don't know the time frame.

sometime in 2008 when the hedge funds asked him to be

the third-party verifier.

Who introduced you to Mike?

United Reporting, Inc.

The exact person, I don't recall,

specifically, at this moment; somebody from the hedge

And whose idea was it to get Szafranski

To my knowledge, it was the hedge funds.

And when you say "hedge funds," can you be

I'll refer to them as Centurion, Platinum and

Level 3, although I don't think Level 3 was involved at

that point in time.

Do you know who specifically from Centurion