2011-12-16 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 5 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN:
TIME:
PLACE:
December 16, 2011

8:36 a.m. - 10:54 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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APPEARANCES FOR SCOTT ROTHSTEIN:
LAW OFFICE OF MARC S. NURIK

1 East Broward Boulevard
Suite 700
BY: MARC S. NURIK, ESQUIRE
APPEARANCES FOR THE TRUSTEE:
BERGER SINGERMAN
350 East Las Olas Boulevard
Suite 1000
BY: CHARLES H. LICHTMAN,, ESQUIRE
APPEARANCES FOR THE TRUSTEE:
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
APPEARANCES FOR RAZORBACK:
CONRAD & SCHERER, LLP
633 South Federal Highway
Eighth Floor
By: WILLIAM R. SCHERER, ESQUIRE
REID A. COCALIS, ESQUIRE
IVAN J. KOPAS, ESQUIRE
APPEARANCES FOR RAZORBACK:
KOZYAK, TROPIN & THROCKMORTON, P.A.
2525 Ponce de Leon Boulevard
Ninth Floor
Coral Gables, Florida 33134
By: ADAM MOSKOWITZ, ESQUIRE
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
ON BEHALF OF PLATINUM PARTNERS VALUE ARBITRAGE

Centurion Structured Growth, LLC
GOLDSTEIN, TANEN & TRENCH, P.A.
One Biscayne Tower, Suite 3700
Two South Biscayne Boulevard
By: SUSAN E. TRENCH, ESQUIRE
24
25

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2
3
4
5
6
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:
AKERMAN, SENTERFITT
One Southeast Third Avenue
25th Floor
Miami, Florida 33131-1704
By: MICHAEL GOLDBERG, ESQUIRE
7
8
9
10
APPEARANCES FOR T.D. BANK:

GREENBERG TRAURIG, P.A.
401 E Las Olas Blvd Ste 2000
By: DONNA EVANS, ESQUIRE
11
12
13
14
15
APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

COLUMBIA INC. & ZURICH INSURANCE:
CLAUSIN MILLER
One Chase Manhattan Plaza
39th Floor
New York, New York 10005
BY: SCOTT L. SCHMOOKLER, ESQUIRE
16
APPEARANCES FOR FEDERAL INSURANCE COMPANY:
17
ALEX HOFRICHTER, P.A

1430 South Dixie Highway
Suite 204
Coral Gables, Florida 331463127
By: ALEX HOFRICHTER, ESQUIRE
18
19
20
21
22
23
APPEARANCES FOR MORSE:

TRIPP SCOTT, P.A.
110 S.E. Sixth Street,15th Floor
By: GEORGE WALKER, ESQUIRE
JOHN M. MULLIN, ESQUIRE
24
25

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2
3
APPEARANCES FOR EMESS CAPITAL, LLC:

KLUGER KAPLAN SILVERMAN, KATZEN & LEVINE, PL
201 S Biscayne Blvd Fl 17
BY: CASEY H. CUSICK, ESQUIRE
4
5
6
APPEARANCES FOR ST. PAUL FIRE & MARINE:

MILLS PASKERT DIVERS P.A.
100 N Tampa St Ste 2010
Tampa, Florida 336025145
JOHN A. BLACK, JR., ESQUIRE
7
8
9
10
11
12
APPEARANCES FOR THE DEFENDANT:

ROSEANNE CARETSKY
Billing Cochran Lyles
515 E Las Olas Blvd
Floor Six
By: W. TUCKER CRAIG, ESQUIRE
APPEARANCES FOR THE DEFENDANT:
FRANK SPINOSA
13
14
15
SCHLESINGER AND COTZEN, P.L.

799 Brickell Plz Ste 700
BY: MICHAEL J. SCHLESINGER, ESQUIRE
16
17
18
19
20
21
22
23
24
25

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INDEX
CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN
3
DIRECT
4
5
6
Mr. Scherer
Mr. Lichtman
Mr. Rabin
FURTHER DIRECT
1133
1222
1224
CERTIFICATE OF OATH
CETIFICATE OF REPORTER
1250
1251
7
8
9
10
11
PLAINTIFF'S EXHIBITS INDEX

NO.
168
169
170
171
DESCRIPTION
Metadata and Email Trail
Emails and Deal Documents
Exhibit to the Complaint
Multiple Emails
NO.
172
DEFENDANT'S EXHIBITS INDEX

DESCRIPTION
PAGE NO
October 31, 2009, Email
1236
12
13
PAGE NO
1147
1159
1168
1217
14
15
16
17
18
19
20
21
22
23
24
25

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Thereupon, the following proceedings were had:
2
3
FURTHER DIRECT EXAMINATION

BY MR. SCHERER:
Good morning, Mr. Rothstein.
Good morning.
I'm continuing on with my direct examination.
We bring it up here because of the way we have tried to
divide our time.
I'm going to try to be efficient.
I have got some time this morning, and

It's going to be sort
10
of in the nature of a redirect, a little bit, because I
11
don't know --
12
Okay.
13
-- I don't know if I have any time to redirect
14
next week, and that is also just a little bit of direct
15
examination.
16
17
If you don't mind -- well, we might as well go

through the drill:
18
I do.
19
All right.
You know you're still under oath?
And I would like this to kind of
20
be a lightning round.
21
answers as brief as possible, consistent with you
22
telling the truth, of course.
I would like you to keep your
23
Okay.
24
Obviously, if you want to explain, you can
25
explain, but these questions are kind of like follow-up

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questions.
have been covered before or multiple times before.
I'm going to try not to re-cover things that
Okay.
You know, I don't know if you have a TV where
you are.
they do the lightning round?
7
8
9
Do they let you watch FOX news, you know, how
I actually have a group of dancers in there --
please don't put that on the record.

Q
I was going to say, if you watch FOX news --
10
Lichtman doesn't watch it, so he wouldn't know what I'm
11
talking about, but I am going to get you the question
12
and you get the answer back so we get a lot of
13
information out.
14
15
16
17
20
21
I have got that.
I watch one of the sports
channels, so I'm good to go.

Q
Unlike MSNBC where Lichtman watches, they kind
of go a little slow and move along.
18
19
Okay?
MR. KOPAS:
They get caught up on the
truth there.
BY MR. SCHERER:
Q
By the way, from time to time, you know, we
22
have kidded around, like right now, and it looks like
23
each and every time --
24
MR. LICHTMAN:
25
MR. SCHERER:
You weren't serious?

Right.

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2
BY MR. SCHERER:
Q
Each and every time, you appear to have
laughed, and did you take offense at any of the little
small chit-chat that has gone on here?
Not at all.
Okay.
And did any of it in any way interfere
with you telling it the way you remember it?
Not at all, Mr. Scherer.
All right.
10
11
Thanks.
So, and it hasn't affected your testimony in

any way, I don't think?
12
Not in the least, not at all.
13
You were questioned by Ms. Morse's counsel
14
about my motion to get the court -- a bankruptcy court
15
to pay Mr. Nurik for his work in this deposition as a
16
court cost.
17
18
19
Do you remember her questions -- I started to

say her testimony -- but her questioning you about that?
A
20
21
22
23
Yes, sir.
MR. NURIK:
It was almost testimonial.
BY MR. SCHERER:
Q
Is the fact that I filed that, is that
influencing your testimony here --
24
Not at all.
25
-- in favor of my clients?

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Not at all.
Why not?
Because I'm not bargaining my life with
anything.
would be here.
the truth.
anything and I have not been promised anything in
exchange for that, at all.
Okay?
I have a -- promised the government I

I promised the government I would tell
I promised the government I would not hide
So you wouldn't risk a Rule 35 situation that
10
may be in the cards for you by trying to help my clients
11
recover?
12
No, not -- not at all.
There is no reason to.
13
The people that did bad things, did bad things, and
14
that's what they did.
15
One last thing on getting Mr. Nurik paid, if
16
that ultimately happens -- and I asked you this, but I
17
would like to reiterate it again -- by the way,
18
Mr. Nurik has been with you from the beginning, as I
19
recall?
20
From before my return from Morocco, yes.
21
And he had something to do with you coming
22
back, I think?
23
Yes.
24
I mean, you obviously made the decision, but
25
he helped you --

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But he was --
-- make that?
He was instrumental in counselling me and
4
5
guiding me through a very, very tough period of time.

Q
And he has continued to be with you when you
have been questioned and when you have been involved in
this process for the last two years?
Yes.
Knows a lot about the case?
10
Yes.
11
You talk to him frequently?
12
Yes.
13
If he wasn't here, would you be testifying?
14
No, sir.
15
Thanks.
16
MR. SCHLESINGER:
Just note my objection
17
to that question.
18
testified with Mr. Nurik not here.
19
20
Mr. Rothstein already
BY MR. SCHERER:
Q
Well, there was a time yesterday when
21
Mr. Nurik was in court on another matter, and you did
22
testify for the Trustee's questions for a few hours,
23
correct?
24
That's correct.
25
Would you have given a -- this deposition to

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me, and to the other people here who want to know your
story, if Mr. Nurik was not available?
I have known some of the lawyers in this room
for two decades, okay, but I don't care about how long
I've known them; the only reason I testified for
Mr. Lichtman, answering his questions when Mr. Nurik was
not here, is that I had already spent three full days
with him at another undisclosed location, okay, being
debriefed pursuant to court order; and I was extremely
10
comfortable that they were not going to attempt to take
11
advantage of me during that time period, that they were
12
going to be fair.
13
I don't know everybody who is going to be
14
questioning me.
15
intention is.
16
other people, unless Mr. Nurik is with me, just to
17
protect myself -- not even you, Mr. Scherer, and I have
18
known you a long time.
19
20
21
22
I don't know what anyone's actual

I'm not going to answer questions of
All right, sir.
Thank you.
We're going to take your testimony here then.

Thanks.
I would like to have you focus a little bit on
23
the order that -- the fake order, as we have called
24
it -- and you have talked about it, and you testified
25
about it -- that was entered that you -- you forged

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Judge Marra's signature on this order that you concocted
or drafted.
Okay.
The Marra order.
The Marra order, yes.
And in that order, essentially, you ruled that
the Morses are entitled to $23 million, I think:
21 million, punitive damages, and a million dollars,
compensatory; or maybe 2 million compensatory and
21 million punitive?
10
I believe that's correct, sir, yes.
11
And you also discussed that there was
12
$10 million that you had -- your firm had found through
13
investigators in various bank accounts for Jan Jones in
14
the United States, in South Florida; is that right?
15
That sounds correct, yes.
16
And $20 million in the Cayman Islands, I
17
18
19
20
think, was in that order?

A
There was money referenced about us finding
money in the Cayman Islands, yes, sir.

Q
And was there a -- did you have any telephone
21
call hearings, fake telephone call hearings with --
22
allegedly with Judge Marra leading up to the entry of
23
that order?
24
25
Yes, sir.
MR. MULLINS:
Can I just raise -- I don't

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want to interrupt you too often, Mr. Scherer;
but I just want to make sure that I am
asserting a standing, continuing objection to
questions that you're asking about the Morses,
about Ted Morse.
You do not have a pending case that has
been noticed in this deposition in which you
have a protocol order allowing to you take
that deposition; and the fact that I asked
10
questions of the depo that I properly got
11
permission for, I don't think gives you an
12
opportunity to redirect on the Morses.
13
So, I don't want to interrupt you all
14
day, but I want it to be clear that we have a
15
continuing objection to this line of
16
questioning; and we're going to move to strike
17
it, and we're going to certainly oppose it
18
being used in any new case that you have not
19
been given permission to question the witness
20
on.
21
22
23
MR. SCHERER:
Thank you.
BY MR. SCHERER:
Q
I believe counsel for Morse testified --
24
examined you yesterday about that -- about that Judge
25
Marra order.

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You remember that?
Yes, two different attorneys did.
I don't think they asked you about whether or
Yes.
not there were any fake hearings, telephone hearings,
that preceded the entry of that fake order that -- the
drafting of that fake order.
7
8
9
MR. MULLINS:
A
Object to the form.
I don't know that they asked me, but somebody
questioning me yesterday at the hearings did come up,
10
briefly, at some point in time.
11
it did.
12
BY MR. SCHERER:
13
14
15
At some point in time
And the hearings where they -- tell us about
the hearings.
A
Okay.
At various points in time during the --
16
what's called the "fake proceedings," leading up to and
17
probably subsequent to those orders, there were multiple
18
telephone hearings where Ed Morse, Ted Morse, myself,
19
and someone playing the Judge Marra was on the telephone
20
pretending to conduct a hearing, actually questioning
21
Mr. Ed Morse with Mr. Ted Morse on the phone, with me on
22
the phone, me actually making argument, and the fake
23
Judge Marra actually ruling.
24
25
And who was -- was there an actual person that
played like Judge Marra?

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Yes, sir.
And who was that?
An attorney with my firm, Scott Goldstein.
And did anybody on the phone on the Morse side
know that Mr. Goldstein was acting, pretending to be
Judge Marra?
8
9
10
MR. MULLINS:
And who was that?

MR. SCHERER:
MR. MULLINS:
14
other people knew.
15
speculation.
17
Well, excuse me, what's the
objectionable about that?
13
16
Object to the form.
BY MR. SCHERER:
11
12
Yes.
You're asking him what

You're calling for
BY MR. SCHERER:
Q
Okay.
Do you have any information that
18
anybody on the phone -- I mean, obviously Mr. Goldstein
19
knew he wasn't Judge Marra, right?
20
Yes.
21
Okay.
22
right?
23
Yes.
24
You set it up?
25
I did.
And you knew it was a fake hearing,

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calls?
He was.
And do you know whether Ted knew that it was a
And you said Ted Morse was on each of those
fake hearing?
I do know.
All right.
Okay.
reasons.
And how do you know that?
Ted knew it was fake for several
10
One, I told him what was going to go on.

Number two -- and I had a specific reason for
11
telling him what was going on, because Ted -- anyone who
12
does business with Ted knows, he is a bulldog.
13
really needs information about something, thinks
14
something is going sideways that could affect him or his
15
family, he is a bulldog, and I needed to make sure he
16
laid back.
17
When he
The second thing was -- and more than one
18
person saw this -- Ted knew Scott Goldstein.
19
spoken to him many times before.
20
down from time to time and sit outside with us outside
21
Bova and smoke cigars with us.
22
He had
Scott used to come
On more than several occasions, as Scott
23
Goldstein was approaching us, Ted would take his cigar
24
out of his mouth and say, oh, here comes the judge now.
25
Here comes Judge Goldstein -- I mean, Judge Marra.

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I would like to talk to you about the 11th
Circuit Court of Appeals order, fraudulent, that was
entered and drafted by you; and there seemed to be some
confusion yesterday about that, about that order.
5
6
7
8
Mr. Scherer, one other important point on the
fake hearings -Q
Sure.
Do you have another important point on
the fake hearing?
I do.
10
Okay.
11
12
13
14
MR. MULLINS:
17
What is it?
Objection to form.
BY MR. SCHERER:
Q
Wait a minute.
He's objected to form.
Let me
start off again.
15
16
I would like to hear it.
Did we cover everything that was important on

the fake hearings or on Judge Marra?
A
No.
There was another hearing or two where
18
Mr. Goldstein also pretended to be a circuit court judge
19
in the actual case filed in circuit court on behalf of
20
the Morses.
21
clear.
22
I just wanted to make sure the record is
And I think you might have said, and I may
23
have missed it, that there were some other people that
24
were aware of this fake hearing, phone hearing, other
25
than the people that we mentioned?

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Well, the people who were sitting around with
us at the time, I'm sure, would have heard Ted saying
that, because he wasn't bashful about it.
4
5
6
Do you have any recollection of any people
that were around you that may have overheard that?

A
No.
I have to think about who was actually
there during that time period.
regular group of friends that I mentioned earlier.
9
10
11
12
13
14
15
Okay.
It would have been our
Do you recall how many of these fake
telephone hearings were conducted?

A
I would say between four and seven, eight,
something to that effect.

Q
And would they have all been before the date
of the Marra order?

A
Most likely, but I can't be certain that we
16
didn't have some afterwards.
17
one was before the Marra order because it was before I
18
allegedly have the case elevated to federal court.
19
I know the circuit court
And then you had the case elevated to the
20
court of appeal, and there was some testimony about that
21
yesterday?
22
Yes, sir.
23
There seemed to be a little bit of confusion
24
about when that fake Judge Black order was prepared.
25
you recall the confusion?
Do

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Yes.
As I understand -- and it's in the document
there -- that the document bore a date of August
something?
Correct.
And there was some email forwarding it to the
Morses in October?
Correct.
And you said you didn't know exactly when you
10
11
12
13
did that order, couldn't remember?

A
I don't, without seeing the email traffic and
the metadata, I have no way of remembering that.

Q
14
Let's see if we can't show you the metadata.

Well, let me ask this:
Would it refresh your
15
recollection to remind you that perhaps you drafted that
16
order on the eighth of September, the same day you did
17
the Seltzer order?
18
19
20
21
22
MR. MULLINS:
A
That certainly is possible.
BY MR. SCHERER:
Q
I mean, were you in the fake-order-drafting
mode on the 8th, correct?
23
24
Objection, form.
MR. MULLINS:
A
Objection.
Yes, I was.
25

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2
3
BY MR. SCHERER:
Q
According your testimony, you were drawing the
Seltzer order on the 8th?
Correct.
Okay.
on that already.
7
8
And there is quite a bit in the record
Let me show you the -- what the metadata looks

like, and we'll mark that as our next --
MR. KOPAS:
Plaintiff's 168 is the
10
printout of the metadata from the fake 11th
11
Circuit court order.
12
stamped number on that.
13
exhibit, also with an email trail from
14
September 8th, 2009, Bates labeled Rothstein
15
1180 to 1182.
There is no Bates
It's a composite
16
And I have copies for counsel.
17
(Thereupon, the document was marked as
18
Plaintiff's Exhibit No. 168 for Identification.)
19
BY MR. SCHERER:
20
21
22
23
24
25
Have you ever seen what the metadata looks
like from your computer before?

A
No.
The only time I saw it was the other day
in here when somebody showed me some.

Q
Yeah.
Okay.
You can see the document that's got the 11th

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Circuit order data on it, and you have got the related
dates, and it shows when it was last modified, when it
was created, last printed.
Do you see that?
I do.
And go ahead and tell us when was it created
and when was it modified and when it was printed?
8
9
A
2009.
It was created at 8:21 a.m. on September 8th,

It was modified on September 8th, 2009, and 10:13
10
a.m.; and it was last printed on September 18, 2009 at
11
10:13 a.m., right after the modification, apparently.
12
Okay.
And the -- do you know when -- can you
13
recall when Ted Morse came into your office that
14
morning?
15
Yeah, it was around 10:00 or so.
Ted was
16
always on time for everything, so I -- someone sent me
17
an email saying he's here.
18
19
Yeah, there was an email that said Ted's here.
I think we put that in the record, at 10:00.
20
Do you have a recollection of whether Ted --
21
whether you shared the Judge Black recently-created
22
order with Ted when he was in your office?
23
24
25
It looks like you printed it after he was

there, 10:13; he arrived at 10:00.
A
My recollection, Mr. Scherer, is that I gave

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it to him while we were sitting in my office just to
read.
Now, there was a little questioning -- there
was some questioning yesterday concerning when you
started drawing the Judge Seltzer order and the exact
order of what you did that day.
Yes.
But let me -- before I ask that, was this
Judge Black court of appeals, 11th Circuit Court of
10
Appeals order that you forged on the 8th, the same day
11
that you forged the Seltzer order in response to Carol's
12
email, Carol Morse's email to you of a couple of days
13
before, that asked for the orders in a threatening tone?
14
15
16
17
18
19
Yes.
MR. MULLINS:
Object to the form.
BY MR. SCHERER:
Q
What was this order -- why was this court of
appeals order done on the 8th of September?

A
Because I was in a panic over Carol creeping
20
around, looking to try to figure out what I was actually
21
doing.
22
Yeah, and I think you testified, but I'll ask
23
you again, you received that email from her, and you got
24
the impression that she don't draw -- write that thing
25
by herself, correct?

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That's correct.
I already knew that she had
been talking to her sister-in-law extensively about
this.
involvement, and it appeared to me to be a lawyer.
5
6
7
8
9
So it was clear to me that someone else had
Well, it was kind of drafted like a lawyer
would draft an order?

A
It had language in it that I hadn't
particularly seen in Mrs. Morse's prior emails.

Q
From her behavior from that point, on, did you
10
have the belief, at that time, that she had a legal
11
counsel that was advising her?
12
13
14
15
16
I did.
MR. MULLINS:
Objection.
Asked and
answered.
BY MR. SCHERER:
Q
Okay.
Did you ever discuss that with Ted
17
during that period of time from September the 6th, when
18
you received her threatening email, to the crash at the
19
end of October, that you thought Carol might have a
20
lawyer?
21
Yes.
22
And would you describe your concern about her
23
24
25
having a lawyer?
A
Yes.
I told -- I called Ted immediately after
getting the email.
I asked him -- I'll save you the

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language.
said, she is all over me.
stop this.
quell the situation.
going to blow this whole thing up, and we're all going
down over it.
I asked him what the "F" was going on.
We need to do something to
You need to talk to your dad.
You need to
I can't function like this.
She's
So would that have been one of those mutual
destruction talks that you talked about here in the
last --
10
11
Yes.
Ted knew what that was, the
doctrine of mutually assured destruction.
12
13
14
DOMAD.
DOMAD.
All right.
So, you had one of those kind of talks with

Ted?
15
Yes.
16
Do you recall telling Ted that you thought she
17
had a lawyer?
18
Yes.
19
Okay.
No.
20
21
Did you ask him who that lawyer might
be?
He told me -- he said she probably does.
22
He kept telling me, she's driving my father crazy.
23
is going to end up killing him.
24
getting out of hand.
25
getting out of control.
She
This whole thing is
I'll see what I can do.
She's
Even Ed can't control her

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2
anymore.
Q
Well, did you have any discussions with Ted
about what it would take to prevent Carol and her lawyer
from blowing the whistle on your Ponzi scheme?
there any discussion about that?
MR. LAVECCHIO:
Was
I have to assert an
objection -- Larry LaVecchio on behalf of the
government.
investigator privilege at this point.
I have to assert a government
10
MR. SCHERER:
11
Let me see if I can -- I'll honor the
All right.
Okay.
12
privilege, certainly, but let me see if I can
13
get around it a little bit.
14
15
MR. LAVECCHIO:
question-by-question issue.
16
17
18
It's a
MR. SCHERER:
it works.
Yes, sir.
I understand how
It's not my first rodeo.
BY MR. SCHERER:
19
Mr. Rothstein?
20
Yes, sir.
21
If Carol Morse had blown the whistle on you at
22
that point, do you think the Ponzi scheme could have
23
continued?
24
25
MR. MULLINS:
A
Objection.
Absolutely not.

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BY MR. SCHERER:
And why do you say that?
Because she was one of the lynch pins based
upon the fake court orders, the sheer amount of money
that I had stolen from Ed and Carol, the amount of
focused fraud I had levied in their direction, it just
would have -- the whole entire thing would have come
tumbling down; and I knew it and so did Ted.
9
10
Well, obviously it didn't come tumbling down
until the end of October, correct?
11
Correct.
12
My clients put maybe $100 million into the
13
Ponzi scheme between September 6th and the end of
14
October.
15
That's correct.
16
And --
17
They did.
18
And the financial records show -- well, let me
19
ask this:
20
the Morse operation and Ed and Carol on the phony bond
21
repayment during that last two months or so before the
22
crash of the Ponzi.
23
24
25
Do you know how much the Morses received --
I believe I gave them just shy of half their
money back, $25 million.

Q
That's okay.
That's right.

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And they had an expectation of the phony
bond -- of the phony judgment recovery, plus the
interest on the bonds, plus some profit on the deals, of
about another 25 to 30 million; is that your
recollection?
7
8
9
10
Yes, sir.
MR. MULLINS:
Objection, form.
BY MR. SCHERER:
Q
What is your recollection of what their
expectation was in addition to getting their money back?
11
12
Correct.
MR. MULLINS:
A
Objection.
Ed and Carol had an expectation, as did Ted,
13
that I would repay all of the bond money back; and Ted
14
expected me to be able to not only repay the bond money
15
back, but to repay all the deals with interest.
16
BY MR. SCHERER:
17
Okay.
18
And because of my relationship with Ted, I
19
will tell you that it was absolutely my goal at that
20
point in time to do everything I could to make sure
21
that, at the least, Ed and Carol were made completely
22
whole and hopefully I would be able to get Ted all his
23
interest.
24
25
Q
judgment.
Well, then he had a $23 million phony

Was it your intention to pay him that, if you

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had the money?
Absolutely.
So that his expectation would have been some
25 to 30 million more from September to the end of
October?
6
7
MR. MULLINS:
A
Object to the form.
At that stage of the Ponzi scheme, in order to
keep it from blowing up, I would have had to continue to
make all the payments to everybody.
10
As you know, from reviewing the history, as it
11
got closer and closer to blowing up, I focused the
12
payments towards the people that I wanted to make sure
13
were made whole.
14
BY MR. SCHERER:
15
16
And were the Morses in that group of people
you wanted to make whole?
17
They were at the top of the list.
18
And Mr. Von Allmen, my client was at the
19
bottom?
20
That's correct, Mr. Scherer.
21
Any reason that he was at the bottom?
22
He was not anywhere near my best friend.
He
23
was to me, an acquaintance, who was certainly becoming a
24
friend; but he was an acquaintance, and I viewed him as
25
someone who was extremely wealthy who could withstand

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2
the loss.
Q
I would ask during that time frame, from
September the 6th, when Carol Morse wrote you that
disturbing email, until the crash, did she continue to
press you for repayment?
You know, I don't have an independent
recollection.
every -- during that period of time, I can tell you I
was getting continuing pressure from the Morses to get
10
You'd have to show me emails.
as much money to them as possible.
11
And you were doing that?
12
I was.
13
14
I mean,
I believe I was sending them money
right up to the last minute.

Q
So, their silence in not blowing the whistle
15
on the Ponzi scheme benefited them in the money that
16
they got back between September the 6th and the end
17
of -- and the crash, correct?
18
19
MR. MULLINS:
A
Objection to form.
Of course it did.
20
MR. SCHERER:
What's wrong with the form?
21
MR. MULLINS:
You're assuming that the
22
Morses all knew about the Ponzi scheme and
23
kept silent about it.
24
evidence.
25
Assumes facts not in
BY MR. SCHERER:

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2
3
Well, did the Morses know about the Ponzi
scheme?
A
Ted did, and Carol certainly suspected it -- I
don't know that she suspected it was a Ponzi scheme, but
she certainly suspected that I was stealing her money
and committing fraud.
7
8
And, so, rather than blow the whistle on what
she suspected, what did she do?
She continued to receive money from me.
10
Now, you know that my clients, Razorback and
11
D3, put approximately 50 million in the Ponzi Scheme in
12
October.
13
14
15
16
Those are the dates of Razorback and D3?

Right.
They were at the very end of the Ponzi
scheme, correct.
Q
Right.
50 million in and Mr. Sochet was
putting money in at the same time; do you recall that?
17
He was, sir.
18
So, the 100 million that I represent that my
19
clients had invested in your Ponzi scheme from September
20
to the end of the crash, I said it was about one-hundred
21
million, plus or minus, you know, millions, I don't
22
know, but a lot of money?
23
Yes, sir.
24
Was any of that money used to repay the Morses
25
back the 20 or 25 million that you paid them back

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between September 6th and the crash at the end of
October?
Yes, sir.
Now, I asked you whether Ted Morse knew the
settlements were fake, and there was some discussion of
that; and I'm asking you again, did Ted Morse know at
some point in time that these settlements that you were
doing or your settlement business was a fraud?
10
11
12
13
Yes.
MR. MULLINS:
Objection, asked and
answered.
BY MR. SCHERER:
Q
I'm going to show you some paperwork, I don't
14
think I did that.
15
about the two deals that Mr. Morse invested in, 700 cash
16
with 300 back and then 700 cash and 300 back by two of
17
the deals twice; do you remember that?
Do you remember when I examined you
18
Yes, I recall that.
19
And then you recall that when you did the
20
Ponzi paper, as I called it, the settlement paper, that
21
you didn't do two $1 million deals; you did one
22
$2 million deal.
23
Do you remember questions about that?
24
I do, sir.
25
Let me show you those documents and just put

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those in the record.
MR. KOPAS:
All right.
Plaintiff's 169
is a composite exhibit, four emails relative
to four deals in March of 2008, and then deal
documents for what are RRA M1 and RRA M2, two
deals, no Bates numbers, but these actually
were produced before.
Plaintiff's Exhibit No. 169 for Identification.)
10
11
BY MR. SCHERER:
Q
Mr. Rothstein, take a look at that.
I think
12
those are the documents on the two $700,000 money-in
13
deals with punitive payments of -- no, they weren't
14
punitive they were actual payments of $300,000 profit?
15
Correct.
16
You see that, paid in ten weeks?
17
I do, sir.
18
Okay.
And that's on the email traffic back
19
and forth, the email dated Tuesday, March 18th, 2008,
20
right?
21
Yes, sir.
22
Now, I would like you to go -- look at the --
23
what I call the Ponzi paper there or the deal documents
24
that are attached in that composite.
25
That would be RRA M1; I guess that's Morse 1?
Do you see those?

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Yes.
Okay.
Morse 1 and Morse 2.

Did you combine the two of those
settlements into one set of papers?
Yes.
And that's what these documents represent?
Yes.
Neither Ted, nor I, nor Debra was
creating -- could have cared less as to what the paper
looked like, as long as it passed muster with the
auditors.
10
11
this was all fake?
12
13
Plus Ted knew there were no settlements and
MR. MULLINS:
A
Yes.
absolutely, yes.
15
BY MR. SCHERER:
Ted asked me to create the paperwork, so
14
16
Objection to the form.
But knowing that there was no settlement, that
17
there were no -- or accepting that there were no
18
punitive funds held in trust, you know, the whole spiel,
19
he knew it was a fraud?
20
Of course.
I mean this paperwork was created
21
after he had already started receiving his money, so it
22
must be fake.
23
24
25
Got it.
Thank you.
You testified on my direct examination a few

days ago that Ted knew that Doug was in -- Doug Von

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Allmen was an investor and vice versa; do you remember
that testimony?
I do.
You testified yesterday, or you were
questioned yesterday, about whether Ted talked to any of
the investors; and you said, yes, Razorback.
counsel went on to another subject.
8
9
Then
Let me see if we can explore that a little

more.
10
Okay.
11
The question is, did Ted ever talk to any of
12
the Ponzi investors, and your answer is?
13
Yes.
14
And who did he speak with, that you know of,
15
regarding the Ponzi investors?
16
Of all the Ponzi investors?
17
Yes?
18
Oh, lord, okay.
19
Let's start with my clients first and then
20
we'll -- well, let's talk about the Razorback first,
21
because you talked about that yesterday and then didn't
22
follow up on it.
23
Okay.
Ted spoke to Doug Von Allmen.
24
and spoke with A.J. Discala.
25
Bekkedam.
He met
He spoke with Barry
He spoke with Dean Kretschmar.
He spoke with

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Mike Szafranski.
Ira Sochet.
spoke with Barry Damson.
of times.
He spoke with -- he didn't speak with
I don't think he ever met Ira -- oh, he

That happened at Bova a couple
He met with -- he spoke with -- at various
points in time all of the hedge fund guys, I think,
except for Gil Kalter; and let me see if I can name them
so the record is clear for you.
He definitely, as I said, spoke with Mike
10
Szfranski.
11
with Jack Simony.
12
spoke with Mr. Nordlicht.
He definitely spoke on multiple occasions

He spoke with -- I don't believe he
13
Ari Glass?
14
I don't recall him speaking with Mr. Glass.
15
He only actually did speak with Gil Kalter
16
because Gil was a voracious Miami Dolphins fan.
17
fact, he came from New York -- and Ted is a big Dolphins
18
fan -- and I remember we were all together.
19
actually at one of the games that I brought Gil to.
20
Who else?
In
It was
There are -- two of the other
21
investors that are -- were also in the know on the
22
thing.
23
early and late investors.
24
25
Gary Lipsitz and Domenick Tonacchio, who were

He knew them very well.
And by knowing them, did he know they were
investing in the fraud?
Did Ted know that the people

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that you just identified were investors in the Ponzi
scheme?
about, yes.
All of the ones that I mentioned, Ted knew
Did you overhear their discussions?
Did they
talk about the Ponzi at all or the investments or the
settlement investments?
Okay.
I understand that.
We never discussed the Ponzi scheme.

That was a bad question.
10
You have already told us that a bunch, and I'll try not
11
to do that.
12
13
14
15
Did he talk about the structured -- the

settlement, confidential settlement program?
A
Let me clarify my statement so this is not
misconstrued.
16
When I say we never talked about the Ponzi
17
scheme, I mean that when we are sitting around in a
18
group, like a meeting with me, Domenick and Barry, we
19
didn't say, how is the Ponzi going.
20
Right.
21
Okay.
We certainly, individually, frequently
22
talked about the fraud and things that were going on;
23
but that out-loud group thing, that did not occur.
24
25
So, your question now is?

Q
Well, my question now is, what -- did Ted also

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talk with investors in the confidential settlement
program that did not know they were investing in a
fraud?
Sure.
Like some of my clients?
Sure.
Ted would say to various people, I told
you it was -- it was one of his favorite comments:
Scott is -- especially during the downturn of the car
business:
Scott is our most-profitable car dealership.
10
We're going to give him a sign, you know, the Scott
11
Rothstein -- I'm going to get the award for the
12
most-profitable car dealership.
13
Do you have a recollection of him making
14
comments like that, or similar to that, to A.J. Discala
15
and Dean Kretschmar, Doug Von Allmen?
16
17
that nature.
18
best of my recollection, with Doug Von Allmen were very,
19
very simple as to how the investment is going, nothing
20
more complicated than that.
21
The comments to Doug Von Allmen were not of

The comments -- the conversations, to the
Doug is not the -- there was not that kind of
22
jovial thing back and forth between Doug and I and Ted
23
and I.
24
25
How did Ted say the investment was going to
Mr. Von Allmen or to my clients, to your knowledge?

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I believe he said that he was very satisfied
with it.
a very business-like answer.
you know:
of thing.
6
7
It was a very -- I recall, only because it was

It wasn't Ted's normal,
He's our most profitable car dealership kind
It wouldn't be a flamboyant answer; it would
have been a business answer?
It would have been a business answer.
Because Mr. Von Allmen is more of a
10
business-type man?
11
Yes.
12
He is extremely?
13
14
He's extremely proper.
MR. LAVECCHIO:
A
Proper.
15
He's extremely proper.

In fact, he once wrote me an email, before we
16
were getting ready to talk to some investors on the
17
phone reminding me there was a lady on the phone.
18
19
I actually wrote him back something to the

effect of:
Got it, language to be adjusted properly.
20
He doesn't use swear words, does he?
21
No, he doesn't, not -- I have never heard him
22
23
24
25
curse before, no.

Q
I'm going to get back to the September 6th
date, '09, Seltzer order in a minute.

A
Is that the 6th or the 8th?

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2
I'm sorry, the 8th, precipitated by the email
of the 6th, the --
Yes.
-- order on the 8th.
Thank you.
But we're trying to get some documents.
Do we have them?
Just give me a second here.
Yes, sir.
All right.
10
now so we can keep this all in context.
11
12
Let me go ahead and try to do this
On the 8th of September, Mr. Morse is in your

office at 10:00 a.m.?
13
Correct.
14
There's an email that says to you, Morse is in
15
reception?
16
Correct.
17
And then you and Mr. Morse -- what did you do
18
when he first got there?
19
what you did before you went to judge -- well, let me
20
see if I can get the broad strokes first and then I'll
21
fill in.
Do you have a recollection of
22
Okay.
23
After he arrived at 10:00 a.m., thereafter,
24
you have testified that you went to Judge Seltzer, the
25
two of you, and then you went to Weston to get the

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bank -- the phony bank balance.
your office.
Then you came back to
You then talked to Ed on the telephone and
said, send me authorization for Ted to testify.
then he sent you authorization for Ted to testify.
And
Then you, at 4:30 in the afternoon, sent Ed
and Carol the Seltzer order and there was a phone call
at that time where Ted told them about the order and
read parts of that to them.
10
11
Is that a correct restatement of your

testimony?
12
To the best of my recollection, yes, sir.
13
Okay.
What I want to do is, I want to show
14
you some composite exhibits, and we'll put those in as
15
our next exhibit so that you can refer to them and we
16
can maybe shorten the times, although we don't need to
17
shorten them much.
18
19
Okay.
MR. KOPAS:
Plaintiff's 170 is a
20
composite exhibit, and these are the exhibits
21
to the complaint we filed against the Morses
22
on Tuesday.
23
MR. MULLINS:
24
and asked and answered.
25
Objection, move to strike,

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Plaintiff's Composite Exhibit No. 170 for
Identification.)
BY MR. SCHERER:
Well, I don't mean to -- if it's been asked
and answered, Mr. Rothstein, you just say that, and I'll
accept it.
it.
8
9
But I think we need a little more clarity on
No.
I can tell you that, based upon the
series of questions I have been asked so far, it
10
definitely requires clarity.
11
jumping all over the place with this.
12
13
People have been kind of
Now, between ten -- and you see that -- you
see a picture of you and Ted at the bank there.
14
What is the date of that?
15
It's September 8th, 2009, at 12:45.
16
So we know at 12:45 you're in Weston getting
17
the phony bank balance?
18
Correct.
19
Now, and we know that Ted was in your office
20
at 10:00?
21
Yes.
22
Now, between 10:00 and 12:45, what did you do?
23
Okay.
Ted gets to the office at 10:00.
I go
24
get Ted immediately, because as anyone that that's done
25
business with Ted knows:
You don't leave him waiting.

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So I went -- even as my best friend, I don't
want to hear it.
to the office.
So I went and got him.
We went back
At that point in time -- you should have the
metadata somewhere -- but we are messing around with the
order, initially.
created.
That's when it's initially being
And is he helping you?
He's helping me to the extent that I'm asking
10
him -- you know, we talked about his -- what his role
11
was going to be --
12
Okay.
13
-- and how much of that I was going to put in
14
the order, because I was not going to put him in a
15
position where he had to say something to his father
16
that he himself was not comfortable saying.
17
So we went ahead, and I finished up the order.
18
Following finishing up the order, I gave the
19
order to Deb.
20
Ted.
21
pastes Judge Seltzer's signature on to the order, puts
22
it in an envelope for me and gives me the order.
Deb and -- this part is unbeknownst to
I give that to Deb.
Deb goes ahead and cuts and
23
Ted and I leave to go to Judge Seltzer's.
24
We arrived at Judge Seltzer's.
25
When I get to
Judge Seltzer's chambers, after his secretary announces

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me, I go in with Ted.
I introduce Judge Seltzer to Ted.
The remainder of the time that Ted is in there
with me, we are simply talking -- Judge Seltzer had
upcoming nuptials; we were talking about that.
Seltzer and I generally talk about skiing, we talk about
some sports, and then I excused Ted.
Judge
At that moment, I wanted Ted, for my own
purposes, to believe that I had Judge Seltzer in my
pocket; and Ted, having known that I had a lot of
10
politicians, law enforcement people and the like in my
11
pocket, it was not very difficult to believe because he
12
had used those people before.
13
So I went ahead and had Ted step out.
I then,
14
while Ted is obviously thinking I'm getting Judge
15
Seltzer to sign the order, I talk to Judge Seltzer about
16
his upcoming potential eventual nomination to the
17
federal bench by the president, and we are just
18
kibitzing about general stuff, talking about general
19
stuff.
20
I then take the order.
I then take the order.
21
Judge Seltzer had given me -- I asked him for a notebook
22
of all his, you know, resumes, his CV, all of his
23
accomplishments, because I wanted to send that off for
24
him to people regarding the federal judgeship.
25
I took the order and placed it inside the

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inside sleeve of the notebook.
Ted.
I then went out with
I took Ted, said good bye the judge.
We left.
As we were walking over there, I pulled the
order out, at some point in time.
whether it was while walking over there or later; but at
some point in time I take the order out of there and
give it to Ted.
8
9
10
I don't remember
Now, did you discuss with Ted the purpose of
going to Judge Seltzer?
I mean, why did you do that if
he was going to go along with the farce anyway?
11
For whatever reason, at that point in time, I
12
wanted Ted to believe that I had a member of the federal
13
judiciary in my pocket.
14
Okay.
15
Which I obviously did not.
16
You know the order referred to Ted testifying.
17
Did --
Did you attempt to give Ted some kind of alibi
18
that he thought what you did with Judge Seltzer was a
19
hearing?
20
21
22
No.
Please allow me to explain what occurred while
we were in there.
23
Ted, during the course of this, barely said
24
anything at all.
25
Ted.
It was the quietest I had ever heard
He was actually the most demure I had ever seen

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him during my entire friendship with him.
said anything, which was really not like him.
He barely
But there was no way in the world that Ted
thought a hearing was occurring, okay, nothing of the
sort, nothing to lead him to believe it.
even any discussion about Ted being involved in any type
of litigation.
There wasn't
Nothing of that nature happened.
What Ted believed was that I went in there
privately and somehow got Judge Seltzer to sign that
10
order.
11
12
Now, I'd like you to look at the next document
in that composite.
You've got the --
13
Let me just --
14
Go ahead.
15
Which, by the way --
16
Have you finished?
17
No.
18
Which, by the way, is consistent with Ted's
19
understanding of my influence in the community in
20
general.
21
level of influence over and above what it actually was,
22
because I did not have any federal judges in my pocket,
23
certainly not Judge Seltzer or anybody else involved.
24
25
It would have elevated what was my actual
Okay.
I'd like you to look at the -- you've
got the bank visit, and I think we have already talked

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about that; but the document shows you in the bank, and
I'm interested in the timing.
Yes.
And it's 12:45?
Correct.
Then look at the next couple of documents,
those -- that is the phony statement and the Caretsky
cover letter.
Yes.
10
And then there's the metadata.
I would like
11
you to look at that.
12
more drafting of that order.
13
metadata up at the top, the -- go back to the -- may I
14
show you the -- let me do this.
15
haven't walked over.
16
17
MR. SCHERER:
20
21
22
If you can see the
I haven't done this.
May I, Marshal, go over
MR. NURIK:
You can come around.
You can
come around.
BY MR. SCHERER:
Q
This appears to be a -- a drafting and then a
printing of the final, so it looks like --
23
Okay.
24
And then you have the metadata that actually
25
here close?
18
19
It looks to me like you did some
shows the date of the final printing of the order.

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Do you see that?
I do.
Now, after you -- apparently more drafting on
that order took place after you returned from the bank.
5
6
7
Do you recall that?

A
I have a vague recollection of me making
certain corrections to the order.
Okay.
I don't know exactly what they were.
10
You can pretty much tell by looking at those
11
successive copies there.
12
thing, it looks like, only one was in regular form and
13
one was in final form.
14
line, you had to cut and paste judge's signature?
15
Yes.
It's pretty much the same
And then somewhere along the
What -- at some point in time, okay,
16
prior to me giving -- it looks like Pam was working on
17
it, which makes sense because --
18
Pam?
19
Pam Dominicis.
20
Right.
21
It looks like she was working on it at some
22
point in time.
23
At what time?
24
At 1:54 p.m.
25
Okay.

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And then this -- it says "last modified," it
looks like some kind of modification was made actually
after it was last printed.
That's correct, because it says September 8,
2009, 2:24 p.m. last printed; it says last modified two
minutes after that, which may have just been the
methodology that Pam was using to notate it for later
purposes to be able to access it.
anything the way that works.
10
11
It could have been
It's at 2:25 p.m., correct, or around that
time, around 2:30?
12
Yes.
13
And Ted is still with you, correct?
14
Yes.
15
And then do you see an email from Ed
16
authorizing Ted to testify?
17
right?
18
Yes.
19
Okay.
20
Mr. Scherer, bear with me one second.
21
What time was that?

I just
want to make sure that we got this from the right order.
22
Right.
23
No.
24
25
I think that's in there,
Okay.
Q
Can I help you?
We're in the right order.
All right.
And what time does Ed email you

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back that it's okay for Ted to testify in the hearing
before Judge Seltzer that you -- you know, that you
already had the visit for?
2:25 p.m.
And Ted is still there at that point, right?
Yes.
Ted and then you, apparently, waited a few
Ted was with me the entire day, yes.
hours before you emailed Judge Seltzer's order; do you
see that?
10
Do you see the date or the time of the email
or the order?
11
I do.
12
What time was that?
13
I emailed the order at 4:11 p.m.
14
And was there a phone call between you and Ed,
15
you and Ted and Ed and Carol at that time that you
16
emailed the phony order to them?
Do you recall that?
17
A telephone call, sure, there was, yes.
18
And do you recall what happened on that phone
19
call, what you said, what Ted said to Ed and Carol?
20
I do.
21
What was that, please?
22
I called up Ed on the phone.
23
sitting with me.
24
conference room table at my office.
25
phone on.
I had Ted
We were actually sitting at the

I had the speaker
I told Ed Ted was with me.

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We did a conference call.
We dialed -- I
don't know if we dialed Carol in or not, actually.
have to look at her telephone records.
4
5
But in any event, I know Ed was on the phone

with Ted.
I told Ed we won.
I explained the basis of
it.
said, because without Ted's sworn testimony, there was
no way that the judge was ruling in our favor, that he
I told him that he should be very proud of Ted, I
10
really was the star of the order and the hearing and not
11
me.
12
I said -- told him -- I think I actually wrote
13
it in a subsequent email, something about that I would
14
love to take the credit for this but I can't; it really
15
all goes to his son, to Ted, for his testimony.
16
Ed then spoke to Ted while we were there and
17
asked Ted some very specific and pointed questions about
18
the hearing, specifically what the judge asked him and
19
the like.
20
his father, and we wrapped up the call.
21
a copy of the order to take with him, and I also emailed
22
the copy to Ed and Carol.
23
Ted answered all the questions by lying to

And I gave Ted
There were some more emails in the days that
24
followed between you and Ed and Carol, and you -- where
25
you, again, invited the father to talk to his son, if he

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didn't believe you about the hearing and Ted's
testimony.
You do recall that?

Yes.
It was more directed to Carol.
repeatedly told Carol, because she -- she sent me that
very terse email back at one point in time saying, well,
that's amazing how you got this whole thing handled, the
IRS and the hearing, you know, the bond funds in eight
hours, isn't that amazing.
Something to that effect.
Right.
10
So I wrote her a strong email back, and I
11
invited her, in that email and on multiple other
12
occasions, if you don't believe me as to what happened,
13
ask Ted --
14
Did --
15
-- Ted was there.
Do you know whether they actually spoke about
16
19
20
21
22
23
Talk to
him.
17
18
Ted testified.
it?
Did she ask Ted?

A
Ted hated Carol.
He probably avoided her, so
I don't know; but I know Ted spoke to his father.

Q
Okay.
And what do you know about that
conversation?
A
I know that Ted told him repeatedly about his
24
testimony.
25
his father's eyes.
He was using it to bolster his own worth in

I mean, it was clear that was going

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2
on during the course of the initial conversation.

Q
And during those conversations, Ted would lie
to his father that he testified at a hearing before
Judge Seltzer when you guys visited Seltzer that day on
the 8th, correct?
That's absolutely correct.
All right.
I mean, the order is clear that -- it says Ted
testified.
It says, under oath, that he testified under
10
oath; and I believe the word -- either "at length" or
11
"extensively."
12
Who was keeping track of the mathematics, the
13
accounting on the -- all of the payments that were due
14
under the bonds, under the deals, and the interest, et
15
cetera, for Morse operation and Ed and Carol under the
16
bonds?
17
Dennis McGinnis and Michael Kelly; and
18
internally, my office, either Irene or Deb.
19
know which one.
20
I don't
I'm not sure we're doing lightning rounds,
21
but -- it's going fast for me, but they tell me I'm
22
going slow.
23
move it along because others need an opportunity.
24
25
So I would like to kind of see if I can't
Let me direct -- I have a few questions to TD

Bank that's more in the nature of redirect, I think.

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Okay.
The -- on the cover letters that Caretsky, and
on a few occasions Kerstetter, did to accompany, the
fake statements, and I believe that you have testified
pretty completely about that whole process, correct?
Yes, sir.
And I asked you this, but I don't think it was
100 percent clear, that every time that they did a cover
letter, the cover letter was original; you never faked
10
11
12
13
any cover letters?

A
letter.
To my recollection, we never faked a cover
We didn't need to.

Yeah.
And is your understanding that every
14
time they gave you a fake cover letter, they asked the
15
bank's -- they made a -- printed a screen shot from the
16
bank of the actual balance to go along with the cover
17
letter?
18
Yes, sir.
19
So they would have some deniability?
20
Yes.
21
At one point in time I asked Ms. Caretsky, I
22
said, you know, I don't need these, just stick them in
23
the file.
24
25
She said, no, I need to show that they were

printed at the time that I wrote this letter so we have

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2
a complete record.
Q
And, of course, those printed, actual bank
statements nowhere near matched the fraudulent
statements that you were providing for the switch,
correct?
No, sir.
Now, with Mr. Spinosa, I know that he met with
some investors to talk to them about your business and
to vouch for you and to vouch for the authenticity of
10
the lock letters, correct?
11
Yes, sir.
12
And I know that he also had meetings with some
13
investors that you talked about:
14
Kathleen White for Coquina, where Mr. Spinosa actually
15
affirmed false balances in the falsely locked account,
16
correct?
17
18
19
20
MR. SCHLESINGER:
A
Barry Damson and
Objection to form.
Correct.
BY MR. SCHERER:
Q
What did Mr. Spinosa tell Barry Damson and
21
Kathleen White on Coquina when they visited his office
22
in Cypress Creek with you concerning the bank balances?
23
He told them that we had -- it was in
24
excess -- I don't remember what amount we were looking
25
at the time, but whatever the amount was, several tens

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of millions of dollars, he verified to them that we had
in excess of that amount in the account.
And that was a lie, of course?
Yes, sir.
Now, do you have a recollection of Mr. Spinosa
6
7
8
meeting with Ira Sochet?

A
He may have.
I don't have a specific
recollection of it.
Now -- okay.
10
He may have had a telephone call with
11
Mr. Sochet.
12
Ira Sochet, nice man?
13
Yes.
14
In his 80s?
15
Yes, sir.
16
Did you take advantage of him?
17
I did, sir.
18
Well, would you describe how you took
I don't recall whether Ira did or not.
Wonderful man.
19
advantage -- let me ask this:
20
also, of his age in any regard?
Did you take advantage,
21
I did, sir.
22
How?
23
He was in a stage in his life where he was --
24
from what I understand from Mr. Szfranski, who had known
25
him a lot longer than I had, he had mellowed, and he was

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very trusting; very sharp but very trusting, and I took
advantage of that.
fraud?
He did not, sir.
In your mind?
No, sir.
Same question for Mr. Von Allmen, did he know?
No, sir.
10
Now, would you describe your relationship at
Did he know that you were running a scam or a
11
TD Bank as atypical, as an atypical banking
12
relationship?
13
That's one word, "atypical," not; "a typical."
14
No, no, no.
Was it atypical.
15
one word, A-T-Y-P-I-C-A-L.
16
relationship?
That would be
Was it an atypical
17
Yes, it was an extremely unusual relationship.
18
Unusual or atypical?
19
Yes.
20
Would you say that TD provided you with
21
special accommodations --
22
23
24
25
MR. SCHLESINGER:
Objection.
BY MR. SCHERER:
Q
-- in the way they handled your accounts and
you as a customers?

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Yes, sir.
Without TD Bank's help and Mr. Spinosa's help
and TD Bank, in general, could your Ponzi scheme have
survived?
5
6
ALL PRESENT:
several times.
7
8
MR. SCHERER:
It's been asked and
answered?
MR. RABIN:
10
11
Object, asked and answered
Several times.
MR. SCHERER:
A
Fine.
It couldn't have.
12
MR. RABIN:
13
MR. SCHERER:
14
move to strike.
15
to form.
Move to strike.
Well, you don't need to
All you need to do is object
16
MR. RABIN:
17
MR. SCHERER:
18
I did it anyway.
That's all you have got to
do.
19
MR. RABIN:
20
MR. SCHERER:
21
22
23
Thank you.
I don't think you're going
to coach this guy.

BY MR. SCHERER:
Q
Would you describe your relationship with
24
Gibraltar Bank as an atypical banking relationship?
25
That would one word, "atypical."

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Yes.
And did they provide you with special
accommodations?
Gibraltar.
I'm talking about the people at
Yes, sir.
Let me talk to you about your testimony the
other day that I should have followed up on and didn't,
concerning A.J. Discala of Clockwork and my clients and
your dinner with him in Bova where you guys were excited
10
and even toasted some drink to some event.
11
Do you recall that testimony?
12
Yes, sir.
13
Would you tell me about that a little bit, and
14
15
16
17
then I'll ask you some follow-up questions.

A
Can you give me the time frame again?
Who was
with me?
Q
Yes.
It was before the Razorback investment
18
while Clockwork was doing its due diligence, and that
19
would be sometime in, probably, September or maybe the
20
summer, June, July, August, September, somewhere in that
21
line, when they were doing their due diligence about
22
investing in your fund.
23
precise than that because it's your memory.
24
25
Yes.
Is that -- I can't get more
I recall -- the problem is that I recall
having dinner with them on several occasions there.

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also recall a time when we were sitting off to the side
tables, closer to the bar, where, actually, Thane
Ritchie was there and some of the other guys, and we
were sitting there having drinks, toasting.
What I'm interested in is A.J.'s statements to
you about his due diligence and investigation of the
performance of the New York hedge funds and their past
performance with your investment scene.
10
11
Okay.
MS. TRENCH:
12
Object to form.
I remember what you're talking about now.

MR. SCHERER:
I have an objection there.
13
If it's from Susan, it's probably pretty good
14
and I'll change the question.
15
What is it?
16
MS. TRENCH:
It's testifying.
It's
17
asking him to speculate, talking about what
18
other people knew.
19
20
BY MR. SCHERER:
Q
Well, okay.
I'm asking you if you were
21
present when A.J., when there were discussions
22
concerning his diligence.
23
Yes, I was.
24
And tell -- and by the way, did you have
25
similar conversations with either Mr. Simony or

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Mr. Nordlicht from the funds about --
Yes, sir.
-- their positive references to Mr. Discala
4
5
and the Clockwork people?

A
6
7
Yes, sir.
MS. TRENCH:
Object to form.
BY MR. SCHERER:
Tell us about those discussion, please.
You want me to start with the A.J.
10
discussions?
11
12
13
Yeah.
Start with A.J., and then we will go
onto the others.

A
At the -- at one of the dinners we were
14
having, we were toasting the fact that their due
15
diligence people, whoever was making the call -- I don't
16
know who it was, someone on behalf of the Clockwork, Von
17
Allmen, that whole group -- had spoke to the folks in
18
New York at the New York hedge funds, and they had given
19
us a sterling recommendation, both with regard to
20
consistency of payment and the type of investment
21
strategy we were representing.
22
There were also conversations prior to that
23
where I spoke to Jack Simony and I spoke once or twice
24
to Mr. Nordlicht about the fact that they were looking
25
forward to getting their money because they had done

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what they were supposed to do in giving me a positive
reference to our new investors.
3
4
And that "new investors" would have been the
Clockwork people?
Yes, sir, among them, yes.
And did you have any conversations with Simony
or Nordlicht about A.J., in particular, or anybody else
in my client group --
I did.
10
-- that you recall?
11
I did.
12
All right.
13
I remember -- the conversation with Discala
And tell us about that, please.
14
sticks out because he was at one point in time married
15
to Meadow Soprano -- I forget her name.
16
real name?
17
Jamie Sigler.
18
Right.
19
What is her
Jamie Sigler.
So somehow it had come up in the conversation
20
with the hedge funds, because Simony -- I don't remember
21
whether Nordlicht asked me, but Simony was asking me, he
22
said, I didn't know he was married to her.
23
why it sticks out.
24
25
So that's
Other than that, that's all I can tell you.

Q
Do you think that conversation occurred prior

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to the time of the Razorback investment in your
investment -- settlement investment scheme?
I was told both by Doug Von Allmen and by A.J.
Discala, specifically, that without the blessing of our
large -- largest investors, they were not going to be
able to invest.
That was key.
Well, let me ask you this:
Who, in doing due
diligence, would ever invest without the positive
reference of a fund that was primarily funding the
10
investment for 18 months?
11
critical to any kind of diligence?
12
13
MS. TRENCH:
A
Yes.
Wouldn't that be absolutely
Object to form.
Based on my experience in running a
14
Ponzi scheme for four or five years, the only people
15
that ever invested without doing that type of due
16
diligence were people who were in the know about the
17
fact that we were committing a fraud.
18
BY MR. SCHERER:
19
Do any of my clients, A.J. -- and A.J. Discala
20
and Parrish or any of those other fellows have a -- how
21
did you rephrase that -- how did you phrase that?
22
they have an escort issue?
23
to any of my clients?
Did
Did you ever provide escorts
24
No, sir.
25
And you can't say the same thing about some of

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those fellows at Platinum, though, can you?
2
3
4
5
MS. TRENCH:
A
No.
Object to form.
No, sir.
BY MR. SCHERER:
Q
As inducements to Simony, Nordlicht and Glass,
did you provide them tickets to concerts, Super Bowl,
BCS, political events, dinners, charter flights, the
things that you have been talking about?
10
11
I did.
ALL PRESENT:
Object to form.
BY MR. SCHERER:
12
And escorts, same thing?
13
Some them, yes, sir.
14
15
16
MS. TRENCH:
Objection.
BY MR. SCHERER:
Q
And how often would you provide -- would they
17
partake in your rock-star lifestyle that you have been
18
talking about here for a few days?
19
20
MS. TRENCH:
A
Same objection.
I would say it was on a regular basis.
21
Certainly whenever they were in Florida, they were; and
22
whenever I traveled to New York, they were; and whenever
23
we traveled together, they were.
24
25
Okay.
Did you do that to induce them into
treating you more favorably, or why did you do that?

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I did that because that is the way I took care
of people that were involved -- I -- I don't really know
how to put this.
hedge funds -- there's two methodologies of rewards.
You were rewarding guys that were in on it; but at the
hedge funds, I was really just trying to make them
comfortable with me so they would invest.
right?
10
11
I mean, you do -- the guys at the
Well, and some of them were in on it, though,
MS. TRENCH:
Object to form.
BY MR. SCHERER:
12
Like Simony?
13
I believe -- here's the way you have got to
14
break this down, Mr. Scherer.
15
Simony had some knowledge of the fraud.
16
opinion.
17
Okay.
I believe that Jack

That is my
I do not know it for a fact.
On the other side, Brian Jedwab, I believe had
18
no knowledge -- thought about it, and had he found out,
19
he would have shut us down in a second.
20
As I said, he would have gone running down the
21
hall, calling the police on the way.
22
Simony would have done that.
I don't think
23
And Nordlicht?
24
That is based on my dealings with him.
25
my opinion.
That's

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Okay.
I believe at some point in time Nordlicht
Nordlicht?
knew.
fraud in the works.
It's my opinion that he knew that there was a
right?
Well, and some of them were in on it, though,
MS. TRENCH:
Object to form.
I don't --
Like Simony?
10
I believe -- here's the way you've got to
11
break this down, Mr. Scherer, okay.
12
Simony had some knowledge of the fraud.
13
opinion.
Okay.
I believe that Jack

That is my
I do not know it for a fact.
14
On the other side, Brian Jedwab I believe had
15
no knowledge, thought about it, and had he found out he
16
would have shut us down in a second.
17
would have gone running down the hall calling the police
18
on the way.
19
As I said, he
I don't think Simony would have done that.
20
And Nordlicht --
21
That's based on my dealings with them.
22
my opinion.
23
Okay.
24
I believe at some point in time Nordlicht
25
knew.
That's
Nordlicht?
It's my opinion that he knew that there was a

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fraud in the works.
2
3
Well, and then -- let's see -- why do you say
that?
4
5
Yeah.
And then I'm going to ask you about
what they got out of their actions thereafter.
Well, it's based on a conversation -MS. TRENCH:
Object to form.
-- that I had with him in my office.
You have talked about that.
10
That I went through.
So, you know, listen, as
11
you're going through this thing, there are people that
12
you know are involved because they're involved.
13
actually -- like Szafranski, bringing in investors to
14
something he knows doesn't exist.
15
David Boden, creating paperwork.
16
people you know.
17
between that and my opinion.
18
They're
Those are
I want to clearly differentiate
Then there are people that you think know.
19
Okay.
20
for me.
21
Okay.
I know Mr. Spinosa knowed (sic) because he lied

I know Harris knowed because he lied for me.
22
I know Ted Morse knowed.
23
I don't know whether or not Simony or
24
Nordlicht knew.
25
looked the other way because they wanted to get their
It was my opinion that he knew and

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money out.
Okay.
They were making a lot of money and then they
were almost making no money and they wanted to get all
their money out.
They had a hundred million dollars in it
approximately, in April.
they started slow paying or ramping down the payment,
they had about $180 million.
10
11
that.
14
I would like you to assume
I think that's pretty accurate.

A
I believe that's accurate, sir.
12
13
They had, in December, when
MS. TRENCH:
Object to form.
BY MR. SCHERER:
Q
And the positive references that Platinum and
15
Centurion and their -- Simony, Nordlicht, Glass,
16
provided -- and anybody else there, provided to our
17
investors -- enabled your scheme to continue on through
18
the end of October, correct?
19
MS. TRENCH:
20
MR. SCHERER:
21
24
25
What is wrong with the
form?
22
23
Object to form.
MS. TRENCH:
It assumes facts not in
evidence.
BY MR. SCHERER:
Q
Okay.
Well, we -- that's all deposit

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information, so that is in evidence or will be in
evidence.
3
4
5
6
I want you to assume that they had about

$100 million outstanding in April.
A
I don't need to assume it.
They did have
approximately that amount of money.
Okay.
Yes.
And at the end of the crash, they got it all
10
11
12
13
You remember that?
back except about $18 million?

A
Yes, I believe -- my recollection is, is they
were just $18 million shy.

Q
Okay.
So they made about $80 million back for
14
their fund and that -- between April and the end of
15
October, correct?
16
17
18
19
Yes, sir.
MS. TRENCH:
BY MR. SCHERER:
Q
And what did they do to get that back other
20
than remain silent?
21
didn't they?
22
23
24
25
Object to form.
They did more than remain silent,
Yes.
MS. TRENCH:
Object to form.
They looked the other way and they gave us a
positive credit reference to our new investors.

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2
BY MR. SCHERER:
Q
All right.
Now, did Nordlicht partake in the
inducements also:
charter flights, hotels, food, drink?
6
7
Tickets, concerts, escorts, flights,
Not -MS. TRENCH:
Object to form.
Food and drink, yeah, but not so much.
Nordlicht was more of a family guy.
BY MR. SCHERER:
10
Okay.
11
Did his thing on the side.
12
Simony and Glass more so?
13
Yes.
Very much Simony and, you know, Glass
14
was a little squeamish about it from time to time but he
15
got over it.
16
17
Okay.
How about how many -- how many -- what
are we talking about?
How many times?
Multiple times?
18
For a --
19
For both of those guys.
20
Simony liked the escorts and Glass liked more
21
to go to strip clubs and then get --
22
Serviced?
23
Serviced.
24
strip clubs.
25
reason.
Extra special treatment at the
He felt secure in the strip clubs for some

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And did he ever pay for it or did you pay for
No.
And where did you get the money to pay for it?
Ponzi scheme.
Now, you flew Glass to the islands, to the
it?
I always paid.
Bahamas in order to -- for him to do some due diligence
and approve some settlements offshore because some other
business was offshore, correct?
10
11
MS. TRENCH:
A
That is why I thought we were going there,
12
yes, sir.
13
BY MR. SCHERER:
14
Object to the form.
But what did you do when you were there?
15
didn't do any business, did he?
16
MS. TRENCH:
17
No.
Object to the form.
business.
19
BY MR. SCHERER:
We did monkey business.
18
We did no real
20
And monkey business meaning?
21
We drank and we had women at our disposal
22
there.
23
Okay.
He
And do you think that the requirement
24
to do business offshore was satisfied by the monkey
25
business that you guys engaged in when you were in the

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Bahamas?
2
3
MS. TRENCH:
A
No.
Object to the form.
One thing had nothing -- one thing had
nothing to do with other.
BY MR. SCHERER:
The deals that you were actually -- or that he
was actually looking at there were being really looked
at back in New York, right?
Yes.
Because when we got there, Mr. Scherer,
10
I said, "Okay, what do we have to do?"
11
do you mean we have to do?"
12
already been approved."
13
on we'll get a call.
14
that everything's -- that I've reviewed all the
15
documents and it's been approved.
16
Later
I'll go upstairs and just type in
We had no way to receive the documents.

had no documents with us.
18
and bathing suits.
20
He said, "Everything's
Go downstairs and drink.
17
19
He said, "What
Okay.
We had his laptop.
We
Wallets
We were good to go.
Let me talk to you about the bar
grievance procedure.
21
Okay.
22
You actually had a -- had the Platinum guys
23
come in, and you used this contrivance that you had a
24
Bar problem tying up your trust accounts, and therefore,
25
you were slow paying them or no paying them because

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ostensibly the Bar had tied up your trust accounts,
right?
Correct.
4
5
6
7
MS. TRENCH:
Object to form.
BY MR. SCHERER:
Q
And is there anything incorrect about that
predicate statement?
No, sir.
Okay.
And at one point you got somebody from
10
your office on the phone who played like a lawyer for
11
the Bar?
12
Yes, sir.
13
Okay.
14
A female at the office.
And I guess -- what, did you use a
speakerphone or something like that?
15
Yes.
16
And who was in the office to witness this
17
18
spectacle?
A
19
20
21
22
23
I don't remember, Mr. Scherer.

MS. TRENCH:
Object to form.
BY MR. SCHERER:
Q
Simony?
A
Okay.
Who was in the office to -- was it
Was he there; do you recall?

I really don't recall.
I recall there being
24
somebody there from the hedge funds and someone on the
25
call also that had been conferenced in.
But I don't

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2
recall who was there.

Q
So you -- I mean, you put on this charade
about the Bar grievance to justify withholding money
that was due to the funds, correct?
Yes.
I -- it was twofold.
I wanted to
pressure them into potentially settling -- not
settling -- I wanted to pressure them into potentially
funding more cases, and I needed to have a -- at least
semi viable reason why I was not paying them.
10
The Bar grievance ruse was for the funds, not
11
anybody else?
12
that were -- that you used this Bar -- this fictional
13
Bar problem with?
14
15
16
17
No.
I mean, were there any other investors
It was utilized for the purpose of
controlling the New York hedge funds.

Q
Did you have a concern that they would pick up
the telephone and call the Florida Bar?
18
Terrified.
19
They didn't do that, though, obviously.
20
Not to my knowledge.
21
22
23
24
25
MS. TRENCH:
Object to form on that one.
BY MR. SCHERER:
Q
Did the person that was on the phone acting
like a Bar lawyer use a Bar lawyer's name?

A
Yes.

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Adrianna something?
Adria Quintela.
Adria Quintela.
4
5
6
7
8
Who is actually a lawyer for
the Bar?
A
Yeah.
She actually ran the Fort Lauderdale
office.
Q
So were you fearful that somebody from the
fund would call Adria and say, is this true?
Terrified.
10
Didn't happen, though, did it?
11
No, sir.
12
13
14
15
MS. TRENCH:
Object to form.
BY MR. SCHERER:
Q
Now, when the funds did their due diligence in
December at Steve Rossi's office --
16
Yes.
17
Doesn't Mr. Rossi have a relatively modest
18
office?
19
20
21
22
MS. TRENCH:
A
Object to form.
Extremely modest.
Yes.
BY MR. SCHERER:
Q
Were you concerned that whoever was doing the
23
due diligence in talking to Mr. Rossi would look around
24
the office and have a little bit of a problem believing
25
that he could send you hundreds of cases a month?

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before, yes.
around about it later but we made it through it.
When I arrived there, having never been there

I was very concerned.
I actually joked
Well, yeah, you did.

Were you concerned that Mr. Glass and
Mr. Jedwab would do the Plaintiff/Defendant Index at
Broward and Palm Beach and Dade County and find out that
Mr. Rossi has only but a handful of cases?
9
10
11
MS. TRENCH:
A
Object to form.
Yes, sir.
BY MR. SCHERER:
12
That didn't happen either, though, did it?
13
To my knowledge, no.
14
Now, Mr. Herskowitz -- is that how you
15
16
17
pronounce it?
A
It's either Herskovitz (phonetic) or
Herskowitz (phonetic).
18
Okay.
19
Yes.
20
And same question.
His office is modest as well, isn't it?

Comparatively so, yes.
Were you concerned that
21
they would look around that office and say, how did this
22
guy -- how can this guy send hundreds of cases worth
23
hundreds of thousands of dollars?
24
Yes.
25
And I don't know Doug Bates.
What does his

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office look like?
Same.
Same concern?
Yes, sir.
Did you have the same concern that they would
Modest.
run the Plaintiff/Defendant Index to see if those
fellows had any cases?
I did, sir.
Because you knew they didn't have very many
10
cases, right?
11
That's correct, sir.
12
They have very modest practices?
13
Yeah.
If you ran Bates, you would know; you
14
would find a bunch of personal injury cases and a lot of
15
workers' comp cases.
16
17
MR. SCHLESINGER:
one minute left in the plaintiff's time.
18
19
MR. SCHERER:
that.
20
21
Mr. Scherer, there's
I'm going to take more than
I'm going to finish.

MR. SCHLESINGER:
That wasn't stipulated
to.
22
MR. SCHERER:
23
I'm taking -- I'm going to finish this.
24
25
Read the court order.
I'll be done in a few minutes.

BY MR. SCHERER:

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Let me ask you about Mr. Levin.
Okay.
Was he a player as you've defined "player" in
this deposition this week?
Mr. Levin I considered to be a player, yes,
Do you think he was in on the fraud?
I do.
sir.
However, I have to qualify it.
I never
had direct conversations with George Levin about the
10
fraud.
11
for you.
12
Frank's emails.
But there were -- let me break it down this way

Okay.
I knew he had the ability to monitor

Frank and I had discussed that.
13
Right.
14
He would read Frank's emails.
15
tell you.
16
there's a fraud going on.
I'm sure you read them all.
I don't need to
It's clear that
17
Right.
18
That's one.
19
I agree.
20
Two, there was with a key moment in time in
21
'08, key moment, there's an email -- I think it was May
22
of '08 -- where Frank Preve has called -- where Frank
23
Preve has called TD Bank, and he has discussed the trust
24
balance, okay, with Frank Spinosa.
25
bobbles the ball and says we don't have as much in the
And Frank Spinosa,

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trust account and then rushes and excuses himself and
gets off the phone.
Now, how do I know that happened?
Mr. Preve confirmed all that in an email to Mr. Levin.
I think the email title is "Idiots" and it's Frank
writing to George Levin and he says, "I was -- are these
people at Commerce Bank idiots?
time.
they're telling me about telephone calls he had with
Because
It was Commerce at the
He's going through the -- what he did, that
10
them.
11
Frank's referencing him.
12
tell him not to tell Scott something and he picks up the
13
phone and tells Scott immediately, because Scott's
14
telling me about the conversations he had with Spinosa.
15
The second paragraph of the email is the key.
It's clear I've got Spinosa in my pocket because

In the email he's saying -- I
16
In that particular paragraph, he says during the
17
conversation, Spinosa tells him that Rothstein doesn't
18
have that much money in the trust account.
19
basically panics and hangs up and says, "I'll have to
20
get back to you."
21
Then
Never gets back to him.
When Preve tries to follow up with him to try
22
to figure out how much money I have, he -- Frank,
23
unfortunately -- and I had never seen these emails until
24
I came back and in reviewing emails you see that Frank
25
bobbled the ball again.
He says, "I don't have access

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to customer balances.
back on Tuesday, something to that effect.
I got to wait until my girl gets
Frank Spinosa?
Frank Spinosa.
So at that moment, it's -- now looking at
these emails, it's crystal clear to me what was going on
because Preve had relayed this to me earlier on.
Preve and I were speaking -- you'll see emails back and
forth where Preve is talking to me about what an idiot
10
Once,
Spinosa is and I need to watch him.
11
It's clear from that email and from the
12
behavior that George, to my knowledge, knew what was
13
going on.
14
business -- okay, George and I became very close.
15
way George did his business was Frank was his Chinese
16
wall.
17
from liability, that is clear in everything he did.
18
back to the classic motor cars thing; it's the exact
19
same thing.
20
It's the, I don't know, someone else takes care of it.
But George, the way he always did his

The
Frank -- he used Frank to try to insulate him
21
Go
It's the way he does his banking business.
The exact same thing, by the way, if you look
22
through the email traffic, happened with John Harris and
23
Gibraltar, where Frank made a call over and said -- he
24
was trying to get --
25
Frank Preve?

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Frank Preve was trying to get a line of credit
with Gibraltar for the Banyon people.
well -- and in the email he mentions, he says, "Well,
you've got $21 million in the trust account."
Harris follows the ball, okay, and says, uh, yeah, okay,
something -- and you can tell by the email Frank knows
the money is not there and he's writing -- and George is
copied on the email.
money is not there.
And he said,
And now
You can see that they know the

Okay.
10
And the way John Harris recovers, you see, is
11
he continues to attempt to put through Levin's Banyon's
12
request for a line of credit.
13
Preve keeps pushing him.
Keeps pushing
14
Spinosa and Levin -- excuse me, Spinosa and Harris to
15
try to get these lines in place.
16
the emails that everyone knew that the trust account
17
balances were not there.
18
19
When you -MR. RABIN:
20
moment.
21
five after ten.
22
23
But you can see from
Mr. Scherer, just -- for a
I want to put on the record, it's now
Although you say you don't care about

whatever --
24
MR. SCHERER:
25
SPEAKER?:
Let me finish.
Let me just put this on the

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record, please.
MR. SCHERER:
MR. RABIN:
Sure.
There was an agreement
reached by all counsel.
actually coordinated the agreement, that the
plaintiffs would stop today at 10:00, because
this was going to be a shortened day, and in
order to be assured that we would get all of
our time in that was guaranteed by the court
I think Mr. Lichtman
10
order that you referred to, that you would
11
stop by 10:00 so that we could start.
12
13
14
It's now five past 10:00.
You've now
violated the agreement.

So I'm not sure if it's the court order
15
that you're going by or ignoring the agreement
16
that all the lawyers in this case reached, but
17
I think you should be a man of your word and
18
abide by the agreement that all the lawyers
19
reached.
20
MR. SCHERER:
21
MR. RABIN:
22
MR. SCHERER:
23
I'm about finished, so -Okay.

-- just give me a few more
minutes.
24
MR. RABIN:
25
MR. SCHERER:
All right.
Okay?
And the court order

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gives me the right to take all morning if I
want.
MR. RABIN:
The problem with that, of
course, is that the court order didn't take
into account --
MR. SCHERER:
MR. RABIN:
MR. SCHERER:
MR. LICHTMAN:
15
16
Rather than fight about
it --
13
14
Well, that change of
schedule will be the same next Friday.
11
12
I understand the court didn't
take into account the change of schedule.
9
10
Don't take --
MR. SCHERER:
We don't need a referee.
Let's go.
BY MR. SCHERER:
Q
Do you recall receiving emails, correspondence
17
from Mr. Levin late in the game, let's say as your Ponzi
18
scheme was crumbling in the fall of 2009, that made you
19
think that he still felt there was money in -- actual
20
money in trust accounts?
21
I do.
22
And actual defendant's money in trust accounts
23
that were held up by the Bar?
24
25
lines.
Yes.
I recall receiving something along those

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2
Did that make you concerned that maybe this
guy doesn't know?
I couldn't decide because it was like a civil
thing.
There were things that were discussed that made
me think one way and then I would receive something like
that that would make me think the other way.
7
8
9
When you got back from the Ponzi scheme,
initially you weren't sure, were you?

A
No.
No, I wasn't.
I'm still not sure as I
10
sit here.
11
tremendous hindsight and there were clearly things that
12
say this man knows that something was wrong or at the
13
very least just wants to look the other way.
14
to this day I have no way of knowing for certain.
15
my opinion.
16
I mean, looking back on reading emails I have
But I -It's
Do you recall a fatherly email that he wrote
17
you late in October where he said, Take a deep breath --
18
something.
19
this situation where you promise plaintiffs you'll
20
settle the case until we get the money in-house.
Take a deep breath.
Don't get yourself into
21
Yes.
22
And then you've got the defendants' money
23
in-house, and we'll be all right?
24
Yes, sir.
25
You remember that?

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I do.
Well, when you got that, did you think, well,
he still thinks this Ponzi scheme is real?
To some extent, sure.
Defendants' money in-house locked up,
plaintiffs' money coming in, plaintiffs' money promised,
investor money coming in --
Yes.
-- he said, Scott, don't promise the
10
plaintiffs anymore until you get the investor money
11
in-hand?
12
Sure.
13
Remember that?
14
Sure.
15
And we've got all that defendants' money, it's
Absolutely.
16
already in there, we can wait and get the periodic
17
payments?
18
Yes, sir.
19
I mean, he wrote you that in October?
20
Yes, sir.
21
Did you think when he wrote you that, that he
22
was just covering up for the record or that he actually
23
believed it?
24
25
At that point in time I really didn't know one
way or the other.

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Again, the problem always was that I couldn't
tell.
couldn't tell.
He kept himself so isolated for everything I
4
5
For all I knew, he wasn't; and for all I knew,

he was.
You know, just -- I guess the emails that I
saw him writing me said he wasn't aware.
was aware, it was to a limited extent.
At least if he
The email traffic between him and Mr. Preve
10
and the conversations Preve is telling me he's having,
11
speak to the other side of the coin, that he was aware.
12
So it's very difficult for me to tell.
13
Well, and aren't there some emails between you
14
and Preve that "we're going to keep the old man in the
15
dark" and Preve said he's going back to the islands and,
16
I'm going to put my feet up on his desk and think about
17
how to screw him and -- remember that --
18
Yes.
19
-- email?
20
Yes, sir.
21
And that was late in the game?
22
It was, sir.
23
I mean, that email would make you think that
24
25
maybe Mr. Levin isn't -- didn't know.

MS. TRENCH:
Objection.
Form.

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Yes, but I have to tell you, Mr. Scherer, as I
sit here today, what I'm telling you is merely my
opinion.
not Mr. Levin knew there was a Ponzi scheme going on.
just do not know.
that's floating around in my brain over the last couple
of years is contradictory.
BY MR. SCHERER:
Okay.
I do not know for certain whether or
The emails and all the evidence
Let me show you this -- I'm going to -- I've
10
got one more email and I'll be done in just a minute,
11
fellows.
12
BY MR. SCHERER:
13
Your testimony about the other tentacles to
14
your fraud operation, that involved more than just the
15
confidential settlements?
16
fraud?
17
Correct.
18
But your fraud had other branches?
19
Correct.
20
You had the -- as you discussed, Ron Picou and
That was one branch of your
21
his grout company that you were using to get money and
22
give him money fraudulently -- or Ponzi scheme money and
23
putting his money into the Ponzi scheme?
24
25
He wasn't involved in the Ponzi scheme but I
was using funds from him to fund the Ponzi scheme, while

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at the same time laundering money for him for the things
he needed money for and to help him hide money from
his -- at that point in time soon-to-be ex-wife.
And -- well, you know, I thought in the
beginning you might have said that the Ponzi was bigger
than just the settlement because all of the money came
in from all of these multi-faceted frauds --
I did say that.
-- and then was paid out on a multi -- out of
10
Ponzi money or fraudulent money, without regard to who
11
was owed what on the basis of some contract or illegal
12
contract or agreement?
13
14
Yes.
Let me make sure you understand that I
15
believe -- actually I'm confident as I sit here today
16
that every one of the tentacles of the criminal
17
enterprise that I was running, all flowed back in some
18
way to benefit the Ponzi.
19
any phase, judiciary, law enforcement, banking.
20
it was laundering money for organized crime and all the
21
myriad of things that occurred in between.
22
all involved at some way ultimately funding or assisting
23
the Ponzi scheme.
24
25
Whether it was power -- in

Whether
They were
Was Mel and Barry Lifshitz involved with you
early on?

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Mel Taylor?
No, no, Mel -- is it -- is there a Mel
3
4
5
Lifshitz also.
A
Mely?
You're getting them -- Mely -- there's Mel
Taylor --
Okay.
Or Thaler, who's Barry Lipsitz -- excuse me,
Barry Lipsitz's --
Lipsitz's.
10
-- partner in Flashdancers in New York and in
11
some other businesses.
12
Okay.
13
Then there's Menachem, Mely, Lifshitz, who
14
is -- who is an investor through Szafranski.
15
Okay.
16
That wasn't easy.
17
All right.
All right.
That's okay.
So those are -- the Barry Lipsitz
18
was not a settlement Ponzi investor?
19
Taylor, the Flashdance guys, did they --
20
Barry and Mel
To my knowledge, Mel wasn't involved in it.
21
Mel was involved in some kind of money laundering thing
22
with Barry to get cash to build a home in Fort
23
Lauderdale -- actually to redo a home in Fort
24
Lauderdale.
25
Barry was an investor, just like Tanachio, in

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2
3
the -- just the promissory notes, like Morse.

Q
Right.
The -- Mely or Menachem was in the
structured settlement --
everything.
That would be the Emess Group?
The Emess Group, yes.
All right.
The full-blown deals, full-blown -- you know,

Through Szafranski.
Thank you.
Is that Emess?
Thank you.
Now, did the Tanachio frauds, as you have
10
discussed, and Ronnie Picou's fraud that you discussed
11
and the Peters Silversea, was that also during the time
12
of the Ponzi -- the settlement Ponzi business?
13
Yes.
14
Let me show you some emails.
15
16
I'm going to do
it as a composite.
MR. RABIN:
For the record, it's 10:15,
17
Mr. Scherer.
18
wrapping up since about five after when you
19
made the first --
20
MR. SCHERER:
21
MR. RABIN:
You have now said you would be
Pretty soon.
I understand but pretty
22
soon -- you're violating the order the
23
lawyers, the agreements of the lawyers --
24
25
MR. SCHERER:
take all next week.
Look, you're not going to

You'll have plenty of

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time.
Just hold your horses.

MR. RABIN:
me.
take time, so --
There's a lot of lawyers that want to
5
6
MR. SCHERER:
You'll have time all next
week.
7
8
Unfortunately, it's not just
MR. RABIN:
You're cutting into that
time.
(Multiple conversation.)
10
MR. SCHERER:
Well, I'm sure I won't.
So
11
I'm going to do this right now because I may
12
not get to see this man again.
13
MR. KOPAS:
All right.
Plaintiff's
14
Composite Exhibit 171.
15
email that was Exhibit 28 to Nordlicht's
16
deposition.
17
another email TCL 60572; another email begins
18
FP -- Bates number FP 156116/1; another email,
19
FP Bates-labeled ends 167761/1.
20
First thing is an
Bates Stamp FP ends in 167641/1;
(Thereupon, the documents were marked as
21
Plaintiff's Composite Exhibit No. 171 for
22
Identification?)
23
24
25
Thank you, sir.
BY MR. SCHERER:
Q
Look at that first email.
It says, "Jack

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asked you to send something to the other two funds to
keep them quiet."
May 6th.
You see that?
Yes, sir.
And was this part of your DOMAD, doctrine of
mutually -- mutually assured destruction?
Yes, sir.
And --
10
11
12
13
14
MS. TRENCH:
Object to form.
BY MR. SCHERER:
Q
Okay.
Why were you sending something to the
other funds to keep them quiet?

A
Because Preve and Mr. Simony and I had a
15
concern that if I didn't get money over to all the
16
various parts of the New York hedge funds, that one of
17
them might explode and blow the whistle on us.
18
Okay.
I would like you to look at that next
19
email, October 15th.
20
Morocco you met with Simony.
21
22
A couple of weeks before you go to
You see that?
Take a look at that email,
October 15th email.
23
I see that.
24
And when we took his deposition, he couldn't
25
remember anything you discussed at that late, late

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meeting in October, but in the email, you see where it
says "please email me the docs we spoke about"?
MS. TRENCH:
4
5
Yes.
BY MR. SCHERER:
7
8
Object to form.
You see that?

And then he also says, "Please let me know
wire sent and I will shred."
You see that?
10
Yes.
11
Do you remember what that was all about?
12
I don't remember what the documents were but I
13
had given him a check to hold for an amount that I was
14
promising to send them.
15
if I sent the wire, he was going to shred the check.
And if I was going to send --
16
Do you know whether --
17
He wanted to know whether to deposit it or
19
Did you send the wire?
20
I don't recall one way or the other.
21
Okay.
18
22
not.
And then look at the March 20th, '09,
email, please.
23
Yes, sir.
24
And what was the -- you see the reference to
25
Murray's trust there --

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Yes.
-- on that email?
Yes.
Do you know what Murray's trust referred to?
I do not.
You know who the Murray is, right?
Yes.
8
9
10
It's Murray Huberfeld.
MS. TRENCH:
Form.
BY MR. SCHERER:
Q
And you know that Murray's had some kind of a
11
trust that was owning the Regent's or part of the
12
Regent's deal?
13
14
I'm not familiar with that backroom information.
15
16
17
18
I don't know if that's what was associated.
MS. TRENCH:
Objection to form.
BY MR. SCHERER:
Q
The Regent's money came into you, 11 million,
paid out 22 million.
19
Do you remember that?
20
I do.
21
That money came in in January of '09.
22
Was that money important in maintaining and
23
continuing the Ponzi scheme at that period of time,
24
January '09?
25
Absolutely it was, sir.

(954) 525- 2221
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Page 1221
1
2
3
4
5
MS. TRENCH:
Form.
BY MR. SCHERER:
Q
Without that $11 million infusion, do you know
what would have happened?

A
Yeah.
I believe if you look at the finances,
financial records and ledgers at the time, the Ponzi
would have exploded and I wouldn't have been able to
make payments to other investors.
9
10
Okay.
Would you look at that last email,
May 6th, and then these guys can have the floor?
11
Yes, sir.
12
And these amounts that you are discussing in
13
this email, you can see that with -- this was to
14
Mr. Nordlicht, right?
15
Yes, sir.
16
Did you fund these amounts of money in order
17
18
to keep the hedge funds quiet?

A
All of the money that I sent them was to keep
19
the hedge funds quite, yes, sir.
20
MS. TRENCH:
21
22
23
24
25
Object to form.
BY MR. SCHERER:
Q
Why did you send them the money that you
referenced in that email on May 6th, '09?

A
I didn't want anyone exploding and blowing the
whistle and blowing up the Ponzi scheme.

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MR. SCHERER:
Okay.
further questions.
MR. LICHTMAN:
Thank you.
No
Sam, while they're
switching tables, I'm going to ask five very
quick questions that make clear the Magistrate
Seltzer had no complicity in the fraud.
7
8
So do that, and by the time you get here,

I'll be done.
MR. RABIN:
10
11
MR. LICHTMAN:
14
15
I'm going to ask the
questions.
12
13
I think that's clear.
FURTHER EXAMINATION
BY MR. LICHTMAN:
Q
Scott, you weren't on the Federal JNC,
correct?
16
No, sir.
17
You had zero ability to play any role in
18
assisting Magistrate Seltzer in reaching aspirations of
19
becoming a federal judge; is that correct?
20
THE REPORTER:
Hold on a second.
21
having trouble hearing you with all the
22
shuffling.
23
way.
I'm
24
25
Maybe you want to come over this
BY MR. LICHTMAN:
Q
You had zero ability to play any role in

(954) 525- 2221
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assisting Magistrate Seltzer in becoming a federal
judge, correct?
I really don't know the answer to that
question.
Washington ran, but I can tell you that Judge Seltzer
wasn't expecting anything illegal from me.
7
8
I don't know how deep my influence in
In 2008 and 2009, there was a democratic
president, correct?
Yes.
10
Okay.
When you went in to see Magistrate
11
Seltzer with Ted Morse, you were playing Judge Seltzer
12
that day, correct?
13
I --
14
You were manipulating Judge Seltzer?
15
I was manipulating Judge Seltzer, yes.
16
And Judge Seltzer had no idea he was being
17
manipulated, correct?
18
Absolutely.
19
Would you agree that your knowledge of
He had no idea.
20
Magistrate Seltzer is that he's a judge of the highest
21
character and integrity?
22
Say that again.
23
Would you agree that Magistrate Seltzer, from
I'm sorry.
24
your knowledge of him, is a judge of the highest
25
character and integrity?

(954) 525- 2221
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Page 1224
1
Absolutely.
So no one should draw the slightest inference
by his use of the name in this thing with Ted Morse,
that he knew of or participated in any wrongdoing,
right?
Judge Seltzer knew nothing about anything that
was going on --
All right.
-- and I took advantage of him, yes.
10
11
And I'm not sure that a democrat was in office

when you're saying that, just so we're clear.
12
2008?
13
Yeah, 2009.
14
15
Oh, 2009.
MR. LICHTMAN:
THE WITNESS:
17
MR. RABIN:
I think you're wrong.

We have to take a ten-minute
(Thereupon, a recess was taken.)
20
DIRECT EXAMINATION
BY MR. RABIN:
22
All right.
23
Good morning, Mr. Rabin.
24
All right.
25
Thank
break.
19
21
All right.
you.
16
18
Okay.
Good morning, Mr. Rothstein.
You and I, although you know my
name and we spoke briefly at the beginning of or during

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this deposition, we never met before, correct?
Not to my knowledge, no, sir.
You have never represented me in any matters?
No, sir.
I have not participated in your rock-star
lifestyle?
No, sir.
Okay.
First of all I want to dispel this myth
that seems to have been created that you wouldn't be
10
testifying without Mr. Nurik here.
11
first of all, that you're here pursuant to court order,
12
don't you?
You understand,
13
Yes, sir.
14
And a subpoena?
15
I've never seen a subpoena, but I know the
16
17
judge ordered me to be here, yes, sir.

Q
And you know that this is -- also, that the
18
government expects you to cooperate in any and all
19
proceedings that you're required to be at, right?
20
Yes, sir.
21
Okay.
So you're not saying that you would
22
risk your Rule 35?
23
violate a court order and be held in contempt by
24
refusing to go testify if Mark Nurik weren't sitting
25
next to you, are you?
You're not saying that you would

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I believe that I have a right to have counsel
at all times that I'm testifying regarding any of these
matters, so I don't believe a judge would order me to be
here without counsel.
You're asking me to guess about something that is not
going to happen.
7
8
All right.
So I can't answer your question.
Well, you have access to Lexis,
don't you?
Yes, sir.
10
Take a look, when you get back, do one of your
11
searches on your right to counsel post-sentencing; you
12
may find that you don't have a right to counsel.
13
let's go on from there.
14
But
I want to ask you some questions about your
15
conditions of confinement; and in asking you these
16
questions, I want to make it clear from the beginning,
17
so there is no objections from the government and
18
marshals, I do not want to know anything about your
19
location.
20
Do you understand that?
21
I do.
22
I have noticed that you come to court every
23
day in street clothes and new outfits every day; is that
24
correct?
25
That's not correct.

(954) 525- 2221
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Okay.
Yes.
Okay.
Well, fresh shirts?
And when you leave here, do you change
into prison garb?
MR. LAVECCHIO:
MR. RABIN:
MR. LAVECCHIO:
Yes, sir.
BY MR. RABIN:
10
11
Lexis?
12
Yes, sir.
13
Okay.
14
As to whether he changes into
prison garb?
8
9
Objection, privilege.
All right.
You indicated you have access to
And I assume that that's unlimited
access?
15
There's actually a time frame that you can go
16
on.
17
then it shuts me off so someone else can use it.
18
it's not unlimited, but I have access.
19
have our prison library.
20
21
22
I can do research for a certain number of time and
All right.
So
It's the way we
It's instead of books.
And is there any restrictions on
the types of searches that you can do on Lexis?

A
I don't believe so, but I don't know.
I never
23
had it stop me from searching; but then again, I was
24
only searching me.
25
In addition, have you -- do you also have a

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television?
2
3
4
5
MR. LAVECCHIO:
BY MR. RABIN:
Q
I mean, it's a simple question:
You either
have a television or you don't.
Yes.
Okay.
8
9
You can answer.
MR. NURIK:
Let the record reflect that
the time that he spent to pause was not for
10
any other reason than to determine whether or
11
not the government was going to interpose a
12
privilege objection.
13
MS. TRENCH:
14
trouble hearing.
15
MR. NURIK:
I'm sorry.
I'm having
The time he spent to pause is
16
for no other reason than for him to determine
17
whether or not the government was going to
18
interpose a privilege objection.
19
20
21
BY MR. RABIN:
Q
Do you also have access to some exercise
equipment?
22
Yes.
23
Okay.
24
25
And I notice that you seem to have lost
some weight, right?

A
Yes.

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Okay.
Thirty-five.
Okay.
You've cut your hair, and you have
grown a little facial hair, correct?
Yes.
Okay.
About how many pounds have you lost?
Other than that, your appearance has
been the same?
Yes, sir.
Okay.
Now, the lawyers that have questioned
10
you earlier in this week, you met with Mr. Lichtman, who
11
you call "Chuck," for approximately three days, you
12
said, much earlier in the year, I guess?
13
Yeah.
I spent two or three days with Mark,
14
prepping, and Mr. Nurik, prepping; and then I met with
15
Mr. Lichtman and his people for three days.
16
17
Okay.
And then since that time, have you met
with him additional times?
18
No, sir.
19
Okay.
20
Yes, sir.
21
And before the deposition, how many times did
So a total of three days?
22
you have the opportunity to meet with Mr. Scherer or
23
anybody that works with him?
24
25
The very first time that I spoke with
Mr. Scherer was when he started questioning me here.

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2
haven't spoken with him or met with him.

Q
But you did speak with him through Mr. Nurik,
who you spoke to and authorized Mr. Nurik to speak with
Mr. Scherer on your behalf, correct?
It's too many questions in one question.
Fair enough.
7
8
Let me break it down.
You did authorize Mr. Nurik to speak to Mr.

Scherer on your behalf, correct?
Yes, I did.
10
Okay.
And there was essentially a dialogue
11
that was going on where Mr. Scherer would want to know
12
things, and those things were, essentially, asked of you
13
by Mr. Nurik and then answered back to Mr. Scherer by
14
Mr. Nurik, correct?
15
16
No, sir.
To the best of my recollection that
is exactly not the way it was occurring.
17
Well, tell us how it occurred then.
18
As part and parcel of my review of things that
19
are part of my cooperation, I would provide information
20
to Mr. Nurik and I gave him authorization that, as he
21
saw fit, he could share it with Mr. Scherer.
22
Okay.
Let's talk -- that brings us right into
23
what you were reviewing.
24
reviewed hundreds of thousands of documents, correct?
25
You said earlier that you
I have never stopped to count them, but I have

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been literally reviewing documents since the day I set
foot back on US soil.
3
4
And the documents that you have reviewed
include emails from you, correct?
Yes.
And so that gives you benefit of refreshing
your recollection as to certain events, right?
Yes.
And the documents you have reviewed include
10
emails that you weren't even a party to, correct?
11
Correct.
12
And that gives you the benefit of not only
13
refreshing your recollection of events, but learning
14
about what other people were saying and doing, correct?
15
Sure.
16
Okay.
And did you ever review the Coquina
17
complaint that was filed in one of the cases that
18
revolves around you?
19
I don't recall one way or the other whether I
21
Have you --
22
After having reviewed so many documents, I
20
did.
23
don't remember specifically.
24
my mind.
25
Certain ones stick out in
That one is not sicking out.

Have you reviewed any depositions or trial

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transcripts as part of the documents you were reviewing?
Depositions?
Depositions or trial transcripts.
No trial transcripts.
Okay.
Deposition transcripts, yes.
Okay.
Approximately, how many deposition
transcripts have you had the opportunity to review?
I don't recall.
10
Okay.
Let's talk about before you left for
11
Morocco.
12
deceived everyone you knew?
Would it be fair to say that you lied and
13
At least to some extent, yeah, sure, I did.
14
You lied to your law partners?
15
Yes, sir.
16
You lied to investors?
17
Yes, sir.
18
You lied to your friends?
19
Yes, sir.
20
You lied to your family members?
21
I did.
22
You lied to professionals that you employed,
23
including bankers?
24
The ones that weren't involved, yes, sir.
25
Well, you -- you didn't tell any banker what

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you were doing, did you?
Well, you're assuming that they asked me.
Well, I am asking you, did you tell any banker
4
5
6
7
8
9
what you were doing?

A
To a limited extent, to the extent that they
needed to know, yes; and otherwise, no.

Q
Otherwise you kept them in the dark about what
you were doing, correct?

A
I didn't tell them anything that I didn't
10
think they needed to know in order to fulfill their
11
obligations to me.
12
13
Accountants, same thing, you didn't tell them
what you were doing?
14
I told one accountant a lot; everything, no.
15
And as part of your lies --
16
And I also told one banker a lot, also, and a
17
18
few lies, but a lot of -- a lot of detailed information.

Q
As part of your lies, you used the court --
19
essentially incorporated the court in your lies and in
20
your deception, correct?
21
I did.
22
All levels of federal court, starting at the
23
magistrate level, district court level, into the circuit
24
court level, right?
25
I did.

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2
Okay.
And not only forging court orders but
having people pretend to be judges?
Yes.
And even incorporating Judge Seltzer, as -- he
was unaware, but incorporating him into your scheme, so
actually visiting him and incorporating him into your
scheme?
Yes, sir.
And you did all this for one purpose, right?
10
Multiple purposes.
11
Well, the one singular purpose, though, was to
12
make money, right?
13
Multiple purposes.
14
Did you use charities in a way to give
15
yourself the air of legitimacy?
16
No.
17
You never used charities to give yourself
18
legitimacy?
19
20
21
22
day.
I discussed this in my testimony the other

I --
I understand that, but you understand I can
ask you questions about your testimony, don't you?
23
Yes.
24
So I am asking you, did you use the charities
25
in order to give yourself legitimacy?

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It turns out that it did give me legitimacy,
but this is one of those times that I'm going to differ
with you on it, okay.
lot of things that's I spent money on and a lot of
things that I did, I intended to create a specific air
around me.
It was not my intention.
With a
When I was giving money to the charities, like
Joe DiMaggio Children's Hospital, I was actually trying
to help the children there -- with stolen money, but I
10
was trying to help them.
11
Well, certainly you deceived the charities by
12
not letting them know it was stolen money; and more
13
importantly, it did have the effect of giving the air of
14
legitimacy, correct?
15
16
19
20
Let me answer both of
them.
17
18
That's two questions.
Yes, I deceived charities; and yes, it

absolutely added to the air of legitimacy.
Q
You used the political process in order to
further your scheme, correct?
21
That I absolutely did, yes, sir.
22
And there were times when you either falsely
23
24
25
exculpated people, didn't you?

A
I falsely exculpated people?
Yes, I tried to
save a bunch of my co-conspirators from jail, I did.

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2
You falsely created the persona that you were
a successful lawyer when you were not, correct?
That's correct.
You pretended to have a successful law firm,
when you didn't?
That's correct.
You pretended to be a legitimate lawyer,
correct?
That's correct.
10
And a legitimate investor?
11
That's correct.
12
And, in fact, you really were, to quote you --
13
let me show you an exhibit...
14
15
Defendant's Exhibit No. 172 for Identification.)
16
MR. RABIN:
I am showing what is marked
17
as Plaintiff's -- or Defendant's Exhibit -- we
18
are going in order, 172.
19
Rothstein, October 31st, 2009, to George
20
Levin?
21
22
THE WITNESS:
It's an email, Scott
Give me one second.
can't see.
23
MR. RABIN:
24
UNIDENTIFIED SPEAKER:
25
Take your time.

What page is that
email?

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MR. RABIN:
Mr. Rothstein -- it's from
Scott Rothstein to George Levin dated
October 31, 2009, at 3:33.
BY MR. RABIN:
Why don't you read it out loud, Mr. Rothstein.
Sure.
It's from me to George, subject, me:
try to bail me out of this.
Frank did nothing wrong.
10
the thief.
11
die.
12
to jail.
13
14
I did.
I am the scum bag.
I am the liar.
I am
I either go to jail or
Love forever, Scott.

So, the way you describe yourself was as a
scum bag, correct?

A
I absolutely was.
16
Okay.
Now, let's move forward to your --
let's move forward to your sentencing.
18
19
You and
Why should I put my family through watching me go
15
17
Save yourself.
Do not
At your sentencing, you -- you made some

promises, didn't you?
20
I believe I did, yes, sir.
21
You promised to help people recover money,
22
your investors recover money?
23
Innocent investors, yes, sir.
24
Okay.
25
You pledged to help Mr. Scherer, didn't
you?

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I -- I don't -- I haven't seen the transcript
from it, but if you're saying I did, if you can show me
something where I said that; but Mr. Scherer, since I
now know him to be representing a group of innocent
investors, if I didn't pledge to do that, I would have,
absolutely.
Do you remember Mr. Nurik at your sentencing
hearing, talking about, pointing out the fact that Mr.
Scherer was in the audience and that he was here and
10
that was somewhat remarkable because he was one of your
11
major protagonists prior to that?
12
13
A
behalf?
So you're saying Mr. Nurik said it on my

That, I believe, is correct, yes.
14
Okay.
15
Hang on.
16
17
Well.
Through --
Through Mr. Nurik, I did pledge to help

certain people, yes.
18
And, in fact, Mr. Scherer even was benevolent
19
enough to write a letter on your behalf to the
20
sentencing judge?
21
Yes, he was very kind in doing that.
22
And you previously -- your relationship with
23
Mr. Scherer is, in fact, he was your client once, wasn't
24
he?
25
He was a client of the law firm at some point

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in time.
Did you represent him?
I don't remember whether it was me,
specifically me, in conjunction with other lawyers.
5
6
7
If you have a document that you can show me,

it may refresh my recollection.
Q
And, now, in helping your legitimate
investors, as you put it, and your former client, Bill
Scherer, have you identified who the deepest pocket is
10
in all this litigation?
11
No, sir.
12
Yeah, well, you know that, don't you?
13
I could tell you who I think the deepest
14
pockets are.
15
Who do you think it is?
16
TD Bank.
17
Oh, okay.
18
cooperation.
19
for that, but I understand that the subject of a Rule 35
20
came up, and I would like to pursue that a little bit.
21
Now let's talk about your
I wasn't here yesterday in the afternoon
You understand what a Rule 35 is, correct?
22
I do, sir.
23
You understand that there is only one person
24
or group of people that can file that motion on your
25
behalf, correct?

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I do, sir.
And Mark Nurik can't file that motion for you?
Right.
4
5
The only person that can file it is
the government.
Q
And you understand that the government -- in
order for the government to file that motion, first of
all, if they file it, and they, of course, will never
promise you that they will file it, right?
They have never promised me.
10
They won't promise you; they will never make
11
that promise, correct?
12
13
promised me.
14
the future.
15
I don't know what they'll do.
They have not
I don't know what they are going to do in
So, but in order for the government to
16
consider filing that motion, they have to be convinced
17
that your testimony is complete and truthful, correct?
18
Yes.
19
And you understand --
20
No truth, no Rule 35.
21
And you understand that there are components
22
of the cooperation that involve you helping them to
23
recover money, correct?
24
25
To the extent that they would be forfeiting
people's property, as I understand the United States

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government, yes, to that extent, yes.
is all the civil lawyers.
government.
This other stuff
It has nothing to do with the
You also understand you would have to testify
in any court proceedings in which you could be a
potential witness?
Yes, sir.
And as often -- as often as needed, you would
9
10
11
12
13
have to testify against as many people as they wanted

you to, where you had -- where you had information?
A
My understanding, yes, on the criminal side
I've got to testify every time they want me to, yes.

Q
And you also you understand that if you do
14
additional things, that that is an added arrow in your
15
quiver of cooperation?
16
something that is looked upon as favorable, correct?
17
18
19
Like working undercover, that is
I am assuming that it's looked upon as
favorable if they asked me to work undercover, yes, sir.

Q
And likewise, if you were to put your life in
20
danger, that would also be a factor that would be
21
considered, right?
22
Yes, sir.
23
And all of these -- all of these combined
24
together -- in the event the government files a Rule 35,
25
all of these combined together to give you the potential

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for a sentence reduction, right?
Yes, sir.
Okay.
Now, we already know that you
essentially lied in every aspects of your life in order
to get money; but of course, you would never lie in
order to get a Rule 35, right?
No, sir, I absolutely would not.
And --
If I lie and get caught lying, even an little
10
11
bit, I will die in prison.

Q
Well, that's really the key, isn't it?
You
12
could really lie, as long as you didn't get caught,
13
right?
14
Apparently you don't know Mr. LaVecchio and
15
his co-AUSA's.
16
did not come back from a non-extradition country, where
17
I was sitting with more money than I would spend in ten
18
lifetimes, okay, to come back here and lie again.
19
was not the purpose.
20
I wouldn't even venture an attempt.
That
That's a lie right there because, in fact, you
21
only had how much money, 15 million, 16 million?
22
spent 200 million in the two years of your Ponzi scheme,
23
so you could easily spend that in much less than a
24
lifetime, couldn't you?
25
You
Apparently you have never been in Morocco.

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could have lived in Morocco with $15 million at least --
at least 100 years, very well.
I had priced it all out.
Did you --
I could live as I was living in Fort
5
6
7
8
9
10
11
12
Lauderdale for $10,000 a month with a full staff.

Q
check it out?
A
15
16
17
Yeah.
On and on top of that, by the way, I
also had a watch collection with me and some jewelry

that was worth several million dollars.
Q
Well, we're going to get to what you took on
the plane.
13
14
Did you go to Morocco before you fled there to
MR. RABIN:
Thank you, Mr. Nurik, for
pointing that out to him.

BY MR. RABIN:
Q
Did you go to -- did you go to Morocco before
you fled there in order to check it out?
18
No, sir.
19
Okay.
Now, you talked about drug use.
What
20
drugs did you use during the time that you were running
21
around committing your crimes?
22
During the time of the Ponzi scheme, I -- the
23
only drug I used was I smoked pot, and I took
24
prescription medication.
25
All right.
So you're saying when you talked

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about drug use, I think as part of the rock-star
lifestyle, in fact, as I think one of Mr. Scherer's
PowerPoints, sex and drugs, the only drug you're talking
about that you used was marijuana?
Mr. Scherer's PowerPoint regarding drug use as
part of the rock-star lifestyle was incorrect.
pot on the weekends with my wife.
MR. LICHTMAN:
9
10
13
14
Sam, if you don't mind.
know that the other court reporter just showed

up and I don't know --
11
12
I smoked
MR. SCHLESINGER:
They asked us to stop
at one, so thank you, Chuck.

BY MR. RABIN:
Q
All right.
So you said the only drugs you
15
used were marijuana with your wife.
16
you didn't -- that wasn't incorporated in the rock-star
17
lifestyle, using drugs with any of your investors or
18
co-conspirators?
19
20
Is she the only --
No, actually, never.

Actually, I had a lot of opportunities to
21
because there was a lot of marijuana smoking going on in
22
my office, but it wasn't something -- I prefer to drink
23
vodka.
24
Actually in the office it was going on?
25
In the office, in the garage, outside the

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office, I had some partners that couldn't come to work
without smoking pot.
Okay.
I also found out they were actually dealing
drugs in the office.
that.
I actually tried to put a stop to
That was one crime you wouldn't tolerated?
No, no, it's not that.
attention.
I didn't want to draw
You don't want to have marijuana dealing
10
from the middle of your law office because I was running
11
a giant Ponzi scheme out of there.
12
13
Did you ever have any of the escorts visit the
office?
14
Yeah.
15
You had had prostitutes in the office, but you
16
17
Sure.
wouldn't have pot?

A
You're missing the point.
The police also
18
were sleeping with my escorts.
19
listen, Broward Sheriff's Office, Fort Lauderdale Police
20
Department weren't going to bother me, okay, I could
21
have had all the escorts I wanted.
22
You, obviously --
Pot, not a great idea in the office, I don't
23
know why, specifically, it bothered me; but it troubled
24
me, probably because they were actually dealing the pot
25
out of the office while I was in the middled of running

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2
a several-hundred-million-dollar Ponzi scheme.

Q
Okay.
You -- you indicated that you had plans
to kill yourself, I guess, on more than one occasion,
right?
Twice.
Twice, once with the .357 in the shower; is
that one of them?
Yes, sir.
Okay.
10
Yes, sir.
11
Was it registered?
12
What do you mean "registered"?
13
I mean --
14
I had a concealed weapons permit.
15
16
17
18
Was that gun loaded, by the way?
It was a
legal weapon, yes.

Q
I'm asking where did you get the gun, is
basically what I was asking.

A
You don't register weapons in Florida.
You
19
just purchase them, and they send off the information.
20
I didn't have to register it.
21
purchased it.
22
23
24
25
It was registered when I
Actually, thank you for that tip, but you can
register guns in the State of Florida.

A
with you.
I said you don't have to.
Okay?
I am not arguing
I just did whatever was legally necessary to

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1
2
3
4
5
6
purchase the weapons.

Q
And that was one of only two times you
attempted to kill yourself, correct?

A
Actually, attempted to kill myself, yes, there
was two -- two occasions.

Q
One was with putting the gun to your head in
the shower while were you dressed in a suit, and the
other one was pills in Morocco?
Pills and vodka, yes.
10
Okay.
11
And did you -- you didn't actually take
any of the pills, though, right?
12
I had started to take the pills but --
13
Now --
14
-- I didn't finish.
15
What kind of pills were they?
16
Xanax and blood pressure medication.
17
That blood pressure medicine will get you.
18
19
Have you ever been treated by a doctor for

mental illness?
20
I have been treated for anxiety disorder.
21
Has a doctor ever told you that you have you a
22
mental illness?
23
No.
24
Okay.
25
So when you say mental -- what anxiety
disorder?

(954) 525- 2221
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Yeah.
I was diagnosed with -- I think it's
called -- it wasn't -- the word wasn't severe anxiety
disorder.
It was some -- it was some --
Acute anxiety?
Acute.
And that was when you came back, right?
Oh, no, sir.
It was before?
Let me finish, please.
10
11
12
13
There we go.
Acute anxiety disorder.
I was --
I was diagnosed with acute anxiety disorder

going all the way back to the time I was in college.
Q
Okay.
So back starting in college, you're
talking, what year would that have been?
14
I was in college from 1980 to 1984.
15
So -- and you have had, I guess, multiple
16
doctors diagnose you -- diagnose you with this acute
17
anxiety disorder?
18
Yeah, when I was the University of -- it was
19
either when I was in the University of Florida or when I
20
was in law school and I started to have very severe
21
panic attacks.
22
gastroenterologist diagnosed me.
I was diagnosed, actually by -- my
23
Okay.
24
At the time, Steven Sackel.
25
And who was the last doctor that treated you
What was his name?

(954) 525- 2221
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1
for your acute anxiety disorder?
Lauderdale.
5
6
Dr. Fernando Mata, a psychiatrist in Fort
Are you presently taking any medication for
depression or anxiety?
A
I'm taking sertraline -- that's the generic
name; I don't know what the actual drug is.
few milligrams of that every day for the anxiety
disorder.
10
Okay.
I take a
Let's turn now --
11
Before I start that, we'll take a break.
12
(Thereupon, at 10:54, a recess was had.)
13
14
15
16
17
18
19
20
21
22
23
24
25

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

COUNTY OF BROWARD.
)
4
5
I, Michele L. Savoy, Shorthand Reporter do
hereby certify that I was authorized to and did
report the foregoing proceedings and that the
transcript is a true record.
Dated this 16th 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 1127 to
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 16th day of December, 2011.
20
21
22
23
___________________________________
Michele L. Savoy, RPR
Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
24
25

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abide 1208:18
ability 1204:11
1222:17,25
able 1154:14,22
1175:8 1189:6
1221:7
absolutely 1152:25
1154:19 1155:2
1160:14 1179:6
1189:10 1211:14
1220:25 1223:18
1224:1 1235:18
1235:21 1237:15
1238:6 1242:7
accept 1168:6
accepting 1160:17
access 1175:8
1205:25 1226:7
1227:10,14,18
1228:20
accommodations
1183:21 1185:3
accompany 1180:3
accomplishments
1170:23
account 1181:15
1182:2 1205:1,18
1207:4,16 1209:5
1209:8
accountant
1233:14
accountants
1233:12
accounting
1179:13
accounts 1139:13
1183:24 1198:24
1199:1 1209:20
1209:22
accurate 1194:10
1194:11
acquaintance
1155:23,24
acting 1142:5
1200:23
action 1251:13,14
actions 1193:5
actual 1138:14
1141:24 1144:19
1159:14 1172:20
1180:16 1181:2
1209:19,22
1249:7
acute 1248:4,5,5,10
1248:16 1249:1
adam 1129:18
adams 1128:13
added 1235:18
1241:14
addition 1154:10
1227:25
additional 1229:17
1241:14
adjusted 1165:19
adria 1201:2,3,8
adrianna 1201:1
advantage 1138:11
1182:16,19,19
1183:2 1224:9
advising 1150:11
affect 1143:14
affirmed 1181:15
afternoon 1167:6
1239:18
age 1182:20
ago 1160:25
agree 1204:19
1223:19,23
agreement 1208:3
1208:5,13,15,18
1214:12
agreements
1216:23
ahead 1148:6
1166:9 1169:17
1169:20 1170:13
1172:14
air 1234:15 1235:5
1235:13,18
akerman 1130:4
al 1127:5,8 1128:9
1128:13
alex 1130:17,19
alibi 1171:17
allegedly 1139:22
1145:18
allmen 1155:18
1161:1,23
1164:15,16,18,25
1165:9 1183:8
1187:17 1189:3
allow 1171:21
allowing 1140:8
amazing 1178:6,8
amount 1153:4,5
1181:24,25
1182:2 1195:6
1219:13
amounts 1221:12
1221:16
amy 1128:13
announces 1169:25
answer 1134:12
1138:15 1161:12
1165:3,6,7,8
1223:3 1226:4
1228:2 1235:15
answered 1150:14
1158:11 1167:24
1168:5 1177:19
1184:5,8 1230:13
answering 1138:6
answers 1133:21
anxiety 1247:20,24
1248:2,4,5,10,17
1249:1,5,8
anybody 1142:4,18
1172:23 1188:7
1194:16 1200:11
1229:23
anymore 1152:1
1211:10
anyones 1138:14
anyway 1171:10
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apparently
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appeal 1145:20
appeals 1144:2
1149:9,10,18
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appearance 1229:6
appearances
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1130:1,4,8,11,16
1130:20 1131:1,4
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apply 1251:16
approaching
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approve 1197:8
approved 1198:12
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april 1194:7 1195:4
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arbitrage 1129:19
arent 1212:13
arguing 1246:24
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ari 1162:13
arrived 1148:24
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arrow 1241:14
asked 1136:16
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1180:7,14,21
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asking 1140:4
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aspirations
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assert 1152:6,8
asserting 1140:3
assisting 1214:22
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associated 1220:13
assume 1194:9
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assumes 1156:23
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assured 1151:11
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atlas 1130:3
attached 1159:24
attacks 1248:21
attempt 1138:10
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attention 1245:9
attorney 1142:3
1251:11,12
attorneys 1141:2
atypical 1183:11
1183:11,13,14,15
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audience 1238:9
auditors 1160:9
august 1146:3
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authorization
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B
b 1129:11
back 1134:12
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backroom 1220:14
bad 1136:13,13
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bag 1237:10,14
bahamas 1197:7
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bail 1237:8
balance 1167:1
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balances 1181:15
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ball 1204:25
1205:25 1207:5
bank 1128:16,16
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1167:1,1 1168:13
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banker 1232:25
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bankruptcy
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banks 1180:15
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banyon 1207:2
banyons 1207:11
bar 1186:2 1198:19
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1200:24,24
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barely 1171:23
1172:1
bargaining 1136:3
barry 1161:24
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based 1153:3
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basis 1177:6
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bates 1147:11,14
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bateslabeled
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bathing 1198:18
battista 1129:8
bcs 1190:7
beach 1202:7
bear 1175:20
becoming 1155:23
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beginning 1136:18
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begins 1217:17
behalf 1129:19
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behavior 1150:9
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bekkedam 1161:25
belief 1150:10
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believed 1172:8
1211:23
believing 1201:24
bench 1170:17
benefit 1214:18
1231:6,12
benefited 1156:15
benevolent 1238:18
berger 1129:5
best 1155:22
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1169:1 1230:15
big 1162:17
bigger 1214:5
bill 1239:8
billing 1131:9
biscayne 1129:21
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bit 1133:10,14
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black 1131:6
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blessing 1189:4
blood 1247:16,17
blow 1151:5 1157:7
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blowing 1152:4
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blown 1152:21
blvd 1130:9 1131:2
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bobbled 1205:25
bobbles 1204:25
boden 1193:15
bolster 1178:24
bond 1153:20
1154:2,13,14
1178:7
bonds 1154:3
1179:14,16
books 1227:19
bore 1146:3
bother 1245:20
bothered 1245:23
bottom 1155:19,21
boulevard 1129:2,5
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(954) 525- 2221
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bowl 1190:6
brain 1213:6
branch 1213:15
branches 1213:18
break 1191:14
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1224:18 1230:6
1249:11
breath 1210:17,18
brian 1191:17
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brickell 1131:14
brief 1133:21
briefly 1141:10
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bring 1133:7
bringing 1193:13
brings 1230:22
broad 1166:20
brought 1162:19
broward 1127:2
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build 1215:22
building 1127:17
bulldog 1143:12,15
bunch 1163:10
1203:14 1235:25
business 1143:12
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1206:15,19
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businesses 1215:11
businesslike 1165:3
businesstype
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bye 1171:2
C
c 1129:10 1250:1,1
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call 1139:21,21
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called 1138:23
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calling 1142:14
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calls 1143:2 1205:9
cant 1145:15
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capital 1131:1
car 1164:8,9,12
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cards 1136:10
care 1138:4 1191:1
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cared 1160:7
caretsky 1131:8
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carol 1128:5
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carols 1149:11
cars 1206:18
case 1127:3 1128:4
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cases 1200:8
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1203:10,14,15
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casey 1131:3
cash 1158:15,16
1215:22
caught 1134:18
1242:9,12
cayman 1139:16,19
centurion 1129:20
1194:15
certain 1145:15
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1231:7,23
1238:17
certainly 1140:17
1146:19 1152:12
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1190:21 1235:11
certificate 1132:6
certification
1251:15
certify 1250:6
1251:5,10
certifying 1251:18
cetera 1179:15
cetificate 1132:6
chambers 1169:25
change 1186:14
1209:8,9 1227:3
changes 1227:6
channels 1134:15
character 1223:21
1223:25
charade 1200:2
charities 1234:14
1234:17,24
1235:7,11,17
charles 1129:7
charter 1190:7
1196:4
chase 1130:13
check 1219:13,15
1243:7,17
children 1235:9
childrens 1235:8
chinese 1206:15
chitchat 1135:4
chuck 1229:11
1244:12
cigar 1143:23
cigars 1143:21
cimo 1129:10
circuit 1127:1,1
1128:1,1 1144:2
1144:18,19
1145:16 1147:11
1148:1 1149:9
1233:23
civil 1210:3 1241:2
clarify 1163:14
clarity 1168:6,10
classic 1206:18
clausin 1130:13
clear 1140:14
1144:21 1150:3
1162:8 1178:25
1179:8 1180:8
1204:15 1205:10
1206:6,11,17
1222:5,9 1224:11
1226:16
clearly 1193:16
1210:11
client 1155:18
1188:8 1238:23
1238:25 1239:8
clients 1135:25
1136:10 1153:12
1157:10,19
1161:19 1164:5
1164:25 1185:8
1189:19,23
clockwork 1185:8
1185:18 1187:4
1187:16 1188:4
close 1173:17
1206:14
closer 1155:11,11
1186:2
clothes 1226:23
clubs 1196:21,24
1196:24
coach 1184:21
coausas 1242:15
cocalis 1129:14
cochran 1131:9
coconspirators
1235:25 1244:18
coin 1212:11
collection 1243:9
college 1248:11,12
1248:14
columbia 1130:12
combine 1160:2
combined 1241:23
1241:25
come 1141:9
1143:19 1153:7,9
1173:18,19
1188:19 1198:23
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1245:1
comes 1143:24,25
comfortable
1138:10 1169:16
1191:7
coming 1136:21
1211:6,7
comments 1164:7
1164:14,16,17
commerce 1205:7
1205:7
commission
1250:13 1251:23
committee 1130:4
committing 1157:6
1189:17 1243:21
community
1172:19
comp 1203:15

(954) 525- 2221
company 1128:16
1130:11,16
1213:21
comparatively
1202:19
compensatory
1139:8,8
complaint 1132:10
1167:21 1231:17
complete 1181:1
1240:17
completely 1154:21
1180:5
complicated
1164:20
complicity 1222:6
components
1240:21
composite 1147:12
1159:3,24
1167:14,20
1168:1 1172:12
1216:15 1217:14
1217:21
computer 1147:21
concealed 1246:14
concern 1150:22
1200:16 1203:3,5
1218:15
concerned 1201:22
1202:2,5,20
1210:1
concerning 1149:4
1181:22 1185:8
1186:22
concerts 1190:6
1196:3
concocted 1139:1
conditions 1226:15
conduct 1141:20
conducted 1145:10
conference 1176:24
1177:1
conferenced
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confident 1214:15
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confusion 1144:4
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conjunction 1239:4
connected 1251:13
conrad 1129:12
consider 1240:16
considered 1204:5
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consistency
1187:20
consistent 1133:21
1172:18
contempt 1225:23
context 1166:10
continue 1155:8
1156:4 1194:17
continued 1132:2
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continues 1207:11
continuing 1133:6
1140:3,15 1156:9
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contract 1214:11
1214:12
contradictory
1213:7
contrivance
1198:23
control 1151:25,25
1251:17
controlling
1200:15
conversation
1178:22 1179:1
1188:13,19,25
1193:6 1205:17
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conversations
1164:17 1179:2
1186:25 1187:22
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1205:14 1212:10
convinced 1240:16
cooperate 1225:18
cooperation
1230:19 1239:18
1240:22 1241:15
coordinated 1208:5
copied 1207:8
copies 1147:16
1174:11
copy 1177:21,22
coquina 1181:14
1181:21 1231:16
coral 1129:17
1130:18
correct 1137:23,24
1139:10,15
1146:5,8,22
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1175:4,10,13
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1181:5,10,16,18
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1222:15,19
1223:2,8,12,17
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1230:4,8,14,24
1231:4,10,11,14
1233:8,20
1235:14,20
1236:2,3,6,8,9,11
1237:14 1238:13
1239:21,25
1240:11,17,23
1241:16 1247:3
1251:8
corrections 1174:7
correspondence
1209:16
cost 1135:16
cotzen 1131:13
couldnt 1146:10
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1212:1,3 1218:24
1242:24 1245:1
counsel 1135:13
1140:23 1147:16
1150:11 1161:7
1208:4 1226:1,4
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1251:11,12
counselling 1137:3
count 1230:25
country 1242:16
county 1127:2
1128:2 1202:7
1250:3 1251:2
couple 1149:12
1162:3 1173:6
1213:6 1218:19
course 1133:22
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court 1127:1
1128:1 1135:14
1135:14,16
1137:21 1138:9
1144:2,18,19
1145:16,18,20
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1203:22 1208:9
1208:14,25
1209:4,7 1225:11
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1233:18,19,22,23
1233:24 1234:1
1241:5 1244:9
courtroom 1127:18
cover 1144:15
1173:8 1180:2,8,9
1180:10,11,14,16
covered 1134:2
covering 1211:22
craig 1131:11
crash 1150:18
1153:22 1156:4
1156:17 1157:20
1158:1 1195:9
crazy 1151:22
create 1160:13
1235:5
created 1148:3,6,8
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1225:9 1236:1
creating 1160:7
1193:15
credit 1177:14
1195:25 1207:1
1207:12
creek 1181:22
creeping 1149:19
crime 1214:20
1245:7
crimes 1243:21
criminal 1214:16
1241:11
critical 1189:11
crumbling 1209:18
crystal 1206:6
curse 1165:22
cusick 1131:3
customer 1206:1
customers 1183:25
cut 1174:14 1229:3
cuts 1169:20
cutting 1217:7
cv 1170:22
cypress 1181:22
D
d 1130:8
d3 1157:11,12
dad 1151:3
dade 1202:7
damages 1139:7
damson 1162:3

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dancers 1134:7
danger 1241:20
dark 1212:15
1233:7
data 1148:1
date 1127:16
1145:13 1146:3
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1173:25 1176:9
dated 1159:19
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dates 1148:2
1157:12
david 1129:10
1193:15
day 1127:12
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1250:9 1251:19
days 1138:7
1149:12 1160:25
1177:23 1190:18
1229:11,13,15,19
de 1129:16
deal 1132:10
1158:22 1159:4
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dealership 1164:9
1164:12 1165:4
dealing 1245:4,9,24
dealings 1191:24
1192:21
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deception 1233:20
decide 1210:3
decision 1136:24
deep 1210:17,18
1223:4
deepest 1239:9,13
defendant 1131:7
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defendants 1127:9
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definitely 1162:9
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democrat 1224:10
democratic 1223:7
demure 1171:25
deniability 1180:19
dennis 1179:17
department
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depo 1140:10
deposit 1194:25
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depression 1249:5
describe 1150:22
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description 1132:9
1132:12
desk 1212:16
destruction 1151:8
1151:11 1218:7
detailed 1233:17
determine 1228:10
1228:16
diagnose 1248:16
1248:16
diagnosed 1248:1
1248:10,21,22
dialed 1177:1,2
dialogue 1230:10
didnt 1145:16
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1162:1 1163:19
1178:1 1180:12
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1221:24 1232:25
1233:9,9,12
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differ 1235:2
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diligence 1185:18
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dimaggio 1235:8
dinner 1185:9,25
dinners 1187:13
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direct 1132:3,3
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direction 1153:6
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discala 1161:24
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discuss 1150:16
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discussed 1139:11
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discussing 1221:12
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discussions 1152:2
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disorder 1247:20
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1248:10,17
1249:1,9
dispel 1225:8
disposal 1197:21
district 1233:23
disturbing 1156:4
divers 1131:5
divide 1133:8
dixie 1130:17
docs 1219:2
doctor 1247:18,21
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doctors 1248:16
doctrine 1151:11
1218:6
document 1146:2,3
1147:17,25
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documents 1132:10
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1198:16,17
1217:20 1219:12
1230:24 1231:1,3
1231:9,22 1232:1
doesnt 1134:10
1165:20,21
1193:14 1201:17
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M
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1222:18 1223:1,5
1223:11,11,14,15
1223:16,20,23
1224:6 1234:4
seltzers 1169:21,23
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sentencing 1237:17
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shirts 1227:1
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shot 1180:15
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1192:16
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sic 1193:19
sicking 1231:24
side 1142:4 1186:1
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sideways 1143:14
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silence 1156:14
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silverman 1131:2
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sisterinlaw 1150:2
sit 1143:20 1210:10
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sitting 1145:1
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situation 1136:9
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six 1131:10
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soil 1231:2
somebody 1141:8
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somewhat 1238:10
son 1177:15,25
soon 1216:20,22
soontobe 1214:3
soprano 1188:15
sorry 1166:1
1223:22 1228:13
sort 1133:9 1172:5
sounds 1139:15
south 1129:12,22
1130:17 1139:14
southeast 1130:5
speak 1161:14
1162:1,15
1212:11 1230:2,3
1230:7
speaker 1176:24
1207:25 1236:24
speakerphone
1199:14
speaking 1162:14
1206:8
special 1183:21
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specific 1143:10
1177:17 1182:7
1235:5
specifically
1177:18 1189:4
1231:23 1239:4
1245:23
spectacle 1199:17
speculate 1186:17
speculation
1142:15
spend 1242:17,23
spent 1138:7
1228:9,15
1229:13 1235:4
1242:22
spiel 1160:18
spinosa 1131:12

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spinosas 1184:2
spoke 1161:23,24
1161:24,25,25
1162:1,3,5,9,10
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1177:16 1178:17
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spoken 1143:19
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sports 1134:14
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squeamish 1196:14
st 1131:4,5
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stage 1155:7
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star 1177:10
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street 1127:18
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strip 1196:21,24,24
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stuff 1170:18,19
1241:1
subject 1161:7
1237:7 1239:19
subpoena 1225:14
1225:15
subsequent
1141:17 1177:13
successful 1236:2,4
successive 1174:11
suit 1247:7
suite 1129:3,6,9,21
1130:2,18
suits 1198:18
summer 1185:20
super 1190:6
supposed 1188:1
sure 1140:2
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1211:4,12,14
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1224:10 1231:15
1232:13 1237:6
1245:14
survived 1184:4
susan 1129:23
1186:13
suspected 1157:3,4
1157:5,8
sw 1130:2
swear 1165:20
switch 1181:4
switching 1222:4
sworn 1177:8
szafranski 1162:1
1193:13 1215:14
1216:5
szfranski 1162:10
1182:24
T
t 1130:8 1250:1,1
1251:1,1
table 1176:24
tables 1186:2
1222:4
take 1135:3
1138:10,20
1140:8 1143:23
1152:3 1159:11
1170:20,20
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1182:19 1203:18
1209:1,4,6,8
1210:17,18
1216:25 1217:4
1218:21 1224:17
1226:10 1236:23
1247:10,12
1249:7,11
taken 1127:16,22
1224:19
takes 1206:20
talk 1137:11
1144:1 1151:3
1161:11,20
1163:6,12 1164:1
1165:16 1170:5,5
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1230:22 1232:10
1239:17
talked 1138:24
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1163:16,22
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1172:25 1181:13
1193:9 1243:19
1243:25
talking 1134:11
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1170:18 1185:3
1186:11,17
1190:8,18
1196:17 1201:23
1206:9 1238:8
1244:3 1248:13
talks 1151:8,13
tampa 1131:5,6
tanachio 1215:25
1216:9
tanen 1129:21
taylor 1215:1,5,19
tcl 1217:17
td 1128:16,21
1179:24 1183:11
1183:20 1184:2,3
1204:23 1239:16
ted 1140:5 1141:18
1141:21 1143:1,4
1143:8,11,12,18
1143:23 1145:2
1148:13,15,20,22
1150:16,24
1151:10,14,16
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1154:12,13,18,22
1157:3 1158:4,6
1160:6,10,13,25
1161:5,11,23
1162:17,25
1163:3,25 1164:6
1164:22,24
1167:4,5,8
1168:13,19,23,24
1168:25 1169:20
1169:23 1170:1,1
1170:2,6,7,9,13
1170:14 1171:2,2
1171:7,8,12,16,17
1171:23,25
1172:3,6,8
1175:13,16
1176:1,5,6,7,15
1176:19,22,25
1177:5,7,15,16,17
1177:19,20
1178:13,15,15,18
1178:19,20,23
1179:2,8 1193:22
1223:11 1224:3
teds 1148:18
1165:3 1172:18
1177:8 1178:1
telephone 1139:20
1139:21 1141:4
1141:18,19
1145:10 1167:3
1176:17 1177:3
1182:10 1200:17
1205:9
television 1228:1,5
tell 1136:5 1141:13
1148:6 1154:19
1156:8 1168:8
1174:10 1179:21

(954) 525- 2221
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1188:12,24
1204:15 1205:12
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1212:2,3,12
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1230:17 1232:25
1233:3,9,12
1239:13
telling 1133:22
1135:7 1143:11
1151:16,22
1205:9,14
1212:10 1213:2
tells 1205:13,17
ten 1159:16
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tenminute 1224:17
tens 1181:25
tentacles 1213:13
1214:16
terrified 1200:18
1201:9
terse 1178:5
testified 1137:18
1138:5,24
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testify 1137:22
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1241:4,9,12
testifying 1137:13
1171:16 1186:16
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testimonial
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testimony 1135:10
1135:18,23
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1167:11 1177:8
1177:15 1178:2
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thanks 1135:9
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thats 1136:14
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1194:11,25
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theres 1166:14
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1203:16 1204:16
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1215:13 1217:3
1227:15
theresa 1129:11
theyll 1240:12
theyre 1193:12,12
1205:9 1222:3
thief 1237:10
thing 1136:15
1143:17 1149:24
1151:5,23 1153:7
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1174:12 1178:6
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1193:11 1196:11
1198:3,3 1206:18
1206:19,21
1210:4 1215:21
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1233:12
things 1134:1
1136:13,13
1163:22 1190:8
1210:4,11 1214:1
1214:21 1230:12
1230:12,18
1235:4,5 1241:14
think 1135:11
1136:22 1139:6
1139:17 1140:11
1141:3 1144:22
1145:6 1148:19
1149:22 1152:22
1158:14 1159:11
1162:2,6 1168:6
1172:25 1175:16
1177:12 1179:25
1180:7 1184:20
1188:25 1191:21
1192:19 1193:18
1194:10 1197:23
1204:7,21 1205:5
1208:4,17
1209:19 1210:5,6
1211:2,21
1212:16,23
1222:9 1224:16
1233:10 1239:13
1239:15 1244:1,2
1248:1
thinking 1170:14
thinks 1143:13
1211:3
third 1127:23
1130:5
thirtyfive 1229:2
thought 1150:19
1151:16 1171:18
1172:4 1191:18
1192:15 1197:11
1214:4
thousands 1202:23
1230:24
threatening
1149:13 1150:18
three 1138:7
1229:11,13,15,19
throckmorton
1129:16
tickets 1190:6
1196:3
tied 1199:1
time 1127:16
1133:8,8,13
1134:21,21,23
1135:2 1137:4,20
1138:11,18
1141:10,10,15
1143:20,20
1145:2,7 1147:22
1148:16 1150:10
1150:17 1154:20
1156:2,8 1157:16
1158:7 1162:6
1167:8 1169:4
1170:2 1171:4,6
1171:11 1174:15
1174:22,23
1175:11,19,25
1176:9,12,15
1178:5 1180:8,14
1180:21,25
1181:25 1185:15
1186:1 1188:14
1189:1 1192:2,24
1196:14,14
1203:17 1204:20
1205:8 1208:9
1211:24 1214:1,3
1216:11 1217:1,4
1217:5,8 1220:23
1221:6 1222:7
1227:15,16
1228:9,15
1229:16,24
1236:23 1239:1
1241:12 1243:20
1243:22 1248:11
1248:24
times 1134:2
1143:19 1162:4
1167:16 1184:6,9
1196:17,17
1226:2 1229:17
1229:21 1235:2
1235:22 1247:2
timing 1173:2
tip 1246:22
title 1205:5
toasted 1185:10
toasting 1186:4
1187:14
today 1208:6
1213:2 1214:15
told 1143:9
1150:24 1151:21
1163:10 1164:6
1167:8 1176:25
1177:6,7,12
1178:4,23
1181:23 1189:3
1233:14,16
1247:21
tolerated 1245:7
tonacchio 1162:22
tone 1149:13
top 1155:17
1173:13 1243:8
total 1229:19
tough 1137:4
tower 1129:21
track 1179:12
traffic 1146:11
1159:18 1206:22
1212:9
trail 1132:9
1147:13

(954) 525- 2221
transcript 1238:1
1250:8 1251:16
transcription
1251:8
transcripts 1232:1
1232:3,4,6,8
traurig 1130:9
traveled 1190:22
1190:23
treated 1247:18,20
1248:25
treating 1190:25
treatment 1196:23
tremendous
1210:11
trench 1129:21,23
1186:10,16
1187:6 1189:12
1190:2,14,19
1191:10 1192:7
1193:7 1194:12
1194:19,22
1195:17,23
1196:6 1197:10
1197:16 1198:2
1199:4,19
1200:21 1201:12
1201:19 1202:9
1212:25 1218:10
1219:3 1220:8,15
1221:1,20
1228:13
trial 1231:25
1232:3,4
tried 1133:7
1235:24 1245:5
tries 1205:21
tripp 1130:21
tropin 1129:16
trouble 1222:21
1228:14
troubled 1245:23
true 1201:8 1250:8
1251:8
trust 1128:16,19
1160:18 1198:24
1199:1 1204:23
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1220:4,11
trustee 1129:4,7
trustees 1137:22
trusting 1183:1,1
truth 1133:22
1134:19 1136:6
1240:20
truthful 1240:17
try 1133:9 1134:1
1149:20 1163:10
1166:9 1205:21
1206:16 1207:15
1237:8
trying 1136:10
1166:5 1191:6
1206:24 1207:1
1235:8,10
tucker 1131:11
tuesday 1159:19
1167:22 1206:2
tumbling 1153:8,9
turn 1249:10
turns 1235:1
tv 1134:4
twice 1158:17
1187:23 1246:5,6
two 1129:22 1137:7
1138:4 1141:2
1143:10 1144:17
1153:21 1158:15
1158:16,21
1159:5,12 1160:2
1162:20 1166:25
1175:5 1191:4
1204:20 1218:1
1229:13 1235:15
1242:22 1247:2,5
1247:5
twofold 1200:5
tying 1198:24
type 1172:6
1187:20 1189:15
1198:13
types 1227:21
typical 1183:13
U
uh 1207:5
ultimately 1136:16
1214:22
unaware 1234:5
unbeknownst
1169:19
undercover
1241:15,18
understand 1146:2
1152:16 1163:9
1182:24 1209:7
1214:14 1216:21
1225:10 1226:20
1234:21,21
1239:19,21,23
1240:5,19,21,25
1241:4,13
understanding
1172:19 1180:13
1241:11
undisclosed 1138:8
unfortunately
1205:23 1217:2
unidentified
1236:24
united 1127:23
1139:14 1240:25
university 1248:18
1248:19
unlimited 1227:13
1227:18
unsecured 1130:4
unusual 1183:17
1183:18
upcoming 1170:4
1170:16
upstairs 1198:13
use 1165:20
1199:13 1200:24
1224:3 1227:17
1234:14,24
1243:19,20
1244:1,5
utilized 1200:14
wallets 1198:17
want 1133:24
1138:1 1140:1,2
1140:13,14
1167:13,13
1169:2 1175:21
1187:9 1193:16
1195:3 1207:20
1209:2 1217:3
1221:24 1222:22
1225:8 1226:14
1226:16,18
1230:11 1241:12
1245:8,9
wanted 1144:20
1155:12,16
1170:7,23
1171:12 1193:25
1194:4 1200:5,7
1219:17 1241:9
1245:21
wants 1210:13
washington 1223:5
wasnt 1137:13
1142:19 1145:3
1165:3 1172:5
1203:20 1210:9
1212:4,7 1213:24
1215:16,20
1223:6 1238:23
1239:18 1244:16
1244:22 1248:2,2
watch 1134:5,9,10
1134:14 1206:10
1243:9
W
watches 1134:16
w 1127:8,13 1128:9 watching 1237:11
1128:16 1131:11 way 1133:7
1134:21 1135:6,7
1132:2
1135:11 1136:17
wait 1144:13
1146:12 1172:3
1206:1 1211:16
1172:15,18
waited 1176:7
1175:9 1177:9
waiting 1168:25
1183:24 1186:24
walked 1173:15
1191:1,13,21
walker 1130:22
1192:10,18
walking 1171:3,5
1193:25 1195:24
wall 1206:16
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value 1129:19
van 1129:11
various 1139:13
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venture 1242:15
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versa 1161:1
viable 1200:9
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visiting 1234:6
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(954) 525- 2221
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(954) 525- 2221
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1980 1248:14
1984 1248:14
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2008 1159:4,19
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2009 1132:13
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2015 1250:13
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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR

DAY 5 - MORNING SESSION

December 16, 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:

LAW OFFICE OF MARC S. NURIK

ON BEHALF OF PLATINUM PARTNERS VALUE ARBITRAGE

United Reporting, Inc.

APPEARANCES FOR LEVINSON'S JEWELERS:

APPEARANCES FOR T.D. BANK:

APPEARANCES FOR RLI ZURICH INSURANCE COMPANY,

APPEARANCES FOR FEDERAL INSURANCE COMPANY:

ALEX HOFRICHTER, P.A

APPEARANCES FOR MORSE:

United Reporting, Inc.

APPEARANCES FOR EMESS CAPITAL, LLC:

APPEARANCES FOR ST. PAUL FIRE & MARINE:

APPEARANCES FOR THE DEFENDANT:

SCHLESINGER AND COTZEN, P.L.

United Reporting, Inc.

CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

PLAINTIFF'S EXHIBITS INDEX

DEFENDANT'S EXHIBITS INDEX

United Reporting, Inc.

Thereupon, the following proceedings were had:

FURTHER DIRECT EXAMINATION

Good morning, Mr. Rothstein.

I'm continuing on with my direct examination.

We bring it up here because of the way we have tried to

divide our time.

I'm going to try to be efficient.

I have got some time this morning, and

of in the nature of a redirect, a little bit, because I

-- I don't know if I have any time to redirect

next week, and that is also just a little bit of direct

If you don't mind -- well, we might as well go

You know you're still under oath?

And I would like this to kind of

answers as brief as possible, consistent with you

telling the truth, of course.

I would like you to keep your

Obviously, if you want to explain, you can

explain, but these questions are kind of like follow-up

United Reporting, Inc.

have been covered before or multiple times before.

I'm going to try not to re-cover things that

You know, I don't know if you have a TV where

they do the lightning round?

Do they let you watch FOX news, you know, how

I actually have a group of dancers in there --

please don't put that on the record.

I was going to say, if you watch FOX news --

Lichtman doesn't watch it, so he wouldn't know what I'm

talking about, but I am going to get you the question

and you get the answer back so we get a lot of