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

1971
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
2
3
4 UNITED STATES OF AMERICA
*
*
*
*
*
5 VS.
6 ROBERT ALLEN STANFORD
7
09-CR-342
Houston, Texas
January 31, 2012
10:19 a.m.
JURY TRIAL
VOLUME 7
9
10
BEFORE THE HONORABLE DAVID HITTNER

UNITED STATES DISTRICT JUDGE
11
12 APPEARANCES:
13 FOR THE GOVERNMENT:

Gregg J. Costa
14 Assistant US Attorney
PO Box 61129
15 Houston, Texas 77208-1129
16 William Stellmach
Andrew Howard Warren
17 U.S. Department of Justice
1400 New York Avenue NW
18 Washington, DC 20005
19
20 FOR THE DEFENDANT:
Ali R. Fazel
21 Robert Scardino
Scardino & Fazel
22 1004 Congress Street
3rd Floor
23 Houston, Texas 77002
24
25
Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
1972
1 A P P E A R A N C E S: (Continued)
2 FOR THE DEFENDANT: (Continued)
John M. Parras
3 Attorney at Law
1018 Preston
4 Floor 2
Houston, Texas 77002
5
6 Kenneth W. McGuire
McGuire Law Firm
7 PO Box 79535
8
9
10 Court Reporter:
Johnny C. Sanchez, RPR, RMR, CRR
11 515 Rusk, #8016
12 713.250.5581
13 Proceedings recorded by mechanical stenography. Transcript
produced by computer-assisted transcription.
14
15
16
17
Court Reporter:
18 Johnny C. Sanchez, RPR, RMR, CRR
515 Rusk, #8016
19 Houston, Texas 77002
713.250.5581
20
Proceedings recorded by mechanical stenography. Transcript
21 produced by computer-assisted transcription.
22
23
24
25
1973
I N D E X
1
2
3 WITNESS
4
PAGE
MARIAN ALTHEA CRICK
5
6
CROSS-EXAMINATION BY MR. PARRAS................ 1983
7
8
REDIRECT EXAMINATION BY MR. WARREN............. 2062
9
10
RECROSS EXAMINATION BY MR. PARRAS.............. 2084
11
12
REDIRECT EXAMINATION BY MR. WARREN............. 2098
13
14
15
ARNOLD KNOCHE
16
17
DIRECT EXAMINATION BY MR. COSTA................ 2099
18
19
CROSS-EXAMINATION BY MR. SCARDINO.............. 2169
20
21
REDIRECT EXAMINATION BY MR. COSTA.............. 2233
22
23
RECROSS EXAMINATION BY MR. SCARDINO............ 2244
24
25
REDIRECT EXAMINATION BY MR. COSTA.............. 2251
1974
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
RECROSS EXAMINATION BY MR. SCARDINO............ 2255
1975
Direct-Crick/By Mr. Warren
(The following was held before the jury)
THE COURT: Thank you. Be seated. Good
3 morning. I can't say I've had a full day already, but I've
4 had full of something this morning already.
10:19:45
So we're ready to proceed. Counsel, go
6 right ahead.
7
MR. WARREN: Thank you, Your Honor.
DIRECT EXAMINATION
9 BY MR. WARREN:
10:19:50
10:20:00
10 Q.
Good morning, Ms. Crick?
11 A.
Good morning.
12 Q.
Are you familiar with Antiguan bank secrecy laws?
13 A.
Yes, I am.
14 Q.
Can you generally describe what those laws are?
15 A.
Those laws are contained in the International
16 Business Corporations Act, and it describes the conditions

17 under which information can be released to an individual
18 making a request.
19 Q.
10:20:19
And what types of information can be released and
20 what types of information can't be released, generally

21 speaking?
22 A.
Well, generally speaking, all information can be
23 released. It's a question of the conditions under which

24 they're released. For example, there are pieces of
10:20:33
25 information that are available to the public in general.

1976
1 For a fee, the public can see certain documents. There is

2 information that is shared with regulatory authorities
3 around the world under circumstances in which there is a
4 memorandum of understanding between the countries or
10:20:54
5 mutual legal assistance treaty with those countries. And

6 there are instances where if the information relates to
7 customer information, a bank -- court order is required.
10:21:17
8 Q.
What do you mean by "customer information"?
9 A.
Specifically in banking, information that would
10 outline a customer's business transactions with the bank.

11 Q.
By "customer," do you mean -- who's a customer in the
12 case of Stanford International Bank?

13 A.
In the case of Stanford International Bank, a
14 customer is one who either by way of deposit or loan

10:21:36
15 accesses the services of the bank.

16 Q.
Is there any prohibition against a bank like Stanford
17 International Bank disclosing its assets?

18
MR. PARRAS: Judge, object to the form of the
19 question.
10:21:49
20
THE COURT: Why?
21
MR. PARRAS: Best evidence would be the
22 statute? If it's to her knowledge, I -- to her

23 understanding, then I understand it. The question is?
24
10:21:56
THE COURT: State it again -- no, I want it
25 read back. Johnny, read it back, please.

1977
(Requested portion was read.)
THE COURT: Now, what's your problem?
MR. PARRAS: It's not qualified to indicate
4 that it's her understanding, and it seems -10:22:15
THE COURT: Hold it.
Ma'am, how long have you been in the
7 banking business?
10:22:23
THE WITNESS: For over 25 years.
THE COURT: On your country, you're familiar
10 with the laws?

11
THE WITNESS: Yes, I am.
12
THE COURT: Overrule the objection.
13 BY MR. WARREN:
10:22:30
14 Q.
Ms. Crick, do you recall the question?
15 A.
There is nothing that prevents a bank from revealing
16 its assets, no.

17 Q.
If Stanford International Bank wanted to tell its
18 customers or even the entire world about every single

19 asset in its investment portfolio, was it allowed to do
10:22:45
20 that?
21 A.
Yes, there's nothing in law that prevents the bank
22 from doing that.

23 Q.
Whose decision would that have been to disclose those
24 assets?
10:22:54
25 A.
The bank's decision.

1978
1 Q.
Can the FSRC tell the bank you're not allowed to do
2 that?
10:23:06
3 A.
No.
4 Q.
Are you familiar with a form called an IB5?
5 A.
Yes.
6 Q.
What's an IB5?
7 A.
An IB5 is a form which was designed by our
8 commission. It's information that the regulated entity is

9 required to submit to us on its investment portfolio on a
10:23:24
10 quarterly basis.
11 Q.
What kind of information is included in the IB5?
12 A.
The IB5 includes information -- the IB5 details a
13 bank's investment portfolio. It outlines the various

14 investment companies and the amounts invested, the
10:23:44
15 balances with those various investment houses.

16 Q.
Was Stanford International Bank an entity that
17 produced IB5s to the FSRC?
10:24:00
18 A.
Yes.
19 Q.
And please describe the information that would be
20 contained in those IB5s.

21 A.
The IB5 would contain --
22 Q.
I'm sorry. Particularly Stanford International
23 Bank's IB5s.
24 A.
10:24:17
It would contain a listing of all the investment
25 houses, the balances, the date at which those balances

1979
1 relate to. I can't remember all the details because it's

2 quite a compact schedule that is required, but those two
3 pieces of information would be essential.
10:24:38
4 Q.
The investment houses and?
5 A.
The balances with each of these investment houses.
6 Q.
What do you mean by "the investment houses"?
7 A.
The bank would at intervals within its own
8 decision-making process determine where it wants to invest

9 its resources with which investment company. So what that
10:25:07
10 schedule contain is a listing of all these institutions

11 with which the bank had, in fact, placed these
12 investments.
13 Q.
These would be other banks where Stanford
14 International Bank has its assets like a Credit Suisse or

10:25:20
15 a bank -16 A.
It could range anything from other banks to
17 institutions that specialize in investing portfolios. It

18 would be a wide range. It's a matter of their decision
19 with which organization to invest.
10:25:38
20 Q.
Is there any prohibition against Stanford
21 International Bank taking that IB5 that contains all its

22 investment houses and all the balances that it submits to
23 the commission and releasing that to its customers?
10:26:08
24 A.
There is nothing that prohibits that.
25 Q.
I'm showing you Government's Exhibit 218, which is

1980
1 already in evidence.
2
I'll represent to you that this is a
3 manual from Stanford International Bank?

4
10:26:17
THE COURT: When you say it's already in
5 evidence, it's all in evidence if it's been previously

6 referenced.
7
MR. WARREN: Yes, Your Honor, it's been
8 previously shown.
9
10:26:25
THE COURT: Here it is. I got it at the bottom
10 of that page. You can just say that, it's been previously
11 referencing, because it's all in evidence pursuant to my
12 initial ruling subject to defense objections.
13 BY MR. WARREN:
14 Q.
10:26:40
Ms. Crick, I'll represent to you that this is a
15 manual from Stanford International Bank that contains

16 questions and answers about the bank's operations and
17 portfolio.
18
MR. WARREN: If we could turn to Page 21.
19 BY MR. WARREN:
10:27:01
20 Q.
Ms. Crick, let me know if you're able to read that on
21 the screen in front of you; otherwise, I can give you a

22 hard copy.
10:27:21
23 A.
It's going to be a little difficult.
24 Q.
Sure. Ms. Crick, is that better?
25 A.
That's a lot better.

1981
1 Q.
You see the question: "Can a client see the
2 investments in the portfolio?"
10:27:37
3 A.
Yes, I do.
4 Q.
Can you please read the answer?
5 A.
"Bank regulators do not allow SIBL to discuss
6 specifics about the portfolio."

7 Q.
8
Let me stop you there.

Is that an accurate statement of what
9 Antiguan regulators allow or don't allow?

10:27:52
10 A.
That is not accurate.
11 Q.
Could you continue reading, please?
12 A.
"SIBL is also allowed" -- sorry -- "is only allowed
13 to discuss the portfolio from an investment philosophy

14 exercising the overall diversification parameters."
10:28:07
15 Q.
16
10:28:19
Let me stop you there, Ms. Crick.

Is that an accurate statement?
17 A.
No, it's not.
18 Q.
Could you continue reading, please?
19 A.
"If a bank were to drill down into the portfolio,
20 regulators would view this as the bank is representing

21 itself as a security or fund (sic) and would put the
22 banking license in jeopardy."
23 Q.
Ms. Crick, your reaction in answer to the question,
24 but is that a correct statement?

10:28:40
25 A.
That is not correct.

1982
1 Q.
And the last line, please.
2 A.
"Because SIBL is a bank and sells only bank products,
3 it must adhere to these guidelines."
10:28:54
4 Q.
5 A.
That is not accurate.
6 Q.
What about the next paragraph? The question is:
7 "What are the top positions in the portfolio?" Could you

8 please read what the manual says in response?
9 A.
10:29:11
"Unfortunately, SIBL is not allowed to disclose
10 individual positions because of banking regulations."

11 Q.
Let me stop you there.
12
10:29:21
13 A.
No, it's not.
14 Q.
Can you continue reading, please?
15 A.
"If it were to do so, it could be construed as
16 presenting itself as a security and/or fund which would

17 put the banking license in jeopardy."
10:29:38
18 Q.
19 A.
No, it's not.
20 Q.
Would any type of disclosure of the bank's assets or
21 where its accounts were held, where its money was held be
22 a violation of Antiguan law that would put its license in
23 jeopardy?
24 A.
10:29:50
25
No.
MR. WARREN: Court's indulgence.
1983
Cross-Crick/By Mr. Parras
10:30:14
10:30:25
THE COURT: All right.
MR. WARREN: Pass the witness, Your Honor.
MR. PARRAS: Can I ask before counsel sits down
5 what exhibit number this was?

6
THE COURT: 218.
MR. PARRAS: And the page?
MR. WARREN: 21.
MR. PARRAS: If I could have a few seconds.
10
THE COURT: You've got a few seconds. The
11 clock is running. So take as much time as you want. You

12 Ou might put those chess clocks up here and hit it when
13 counsel come up.
14
10:31:25
MR. PARRAS: If you could go back to the whole
15 page. Thank you.

16
CROSS-EXAMINATION
17 BY MR. PARRAS:
10:31:37
18 Q.
Good morning, Ms. Crick.
19 A.
Good morning.
20 Q.
My name is John Parras. We've never met before;
21 right?
22 A.
That's correct.
23 Q.
Actually, the first time that we talked --
24
10:31:49
THE COURT: Counsel, at least in front of the
25 microphone. If you want the lapel, that's fine.

1984
MR. PARRAS: I'll try this for a while, Judge.
THE COURT: Okay.
3 BY MR. PARRAS:
4 Q.
10:31:58
The first time that you and I met, we were -- I was
5 coming in from a break and you were sitting outside on the

6 bench; correct?
7 A.
That is correct.
8 Q.
I said, "Hello, are you Ms. Crick?" introduced
9 myself?
10:32:06
10 A.
That is correct.
11 Q.
And at the time you were standing with Mr. Gerber or
12 sitting with Mr. Gerber, correct, the agent that's right

13 here? He was right there with you?
10:32:18
14 A.
He was standing off to the side.
15 Q.
Right. And an FBI agent, Walter, was there with you,
16 too, right? The lady, the FBI agent, the lady, she was
17 there with you, too?
10:32:31
18 A.
She was standing to the side, yes.
19 Q.
We didn't talk about the case; right?
20 A.
No, we did not discuss the case.
21 Q.
Okay. And you and I -- you've never called my office
22 or any of the lawyers for Stanford to tell them that you

23 were going to come testify so that we could have a chance
24 to visit with you about what you might say here; right?
10:32:43
25 A.
No, I did not.

1985
1 Q.
You had another gentleman there with you that was
2 seated right next to you to your left, who was that

3 gentleman?
10:32:52
4 A.
That's Mr. Tom Baker.
5 Q.
Is he your lawyer?
6 A.
Yes, he is.
7 Q.
Are you afraid that you may be charged civilly or
8 criminally as a result of the FSRC's regulation of SIBL?

9 A.
10:33:06
No, I'm not.
10 Q.
What's the reason for having a lawyer here with you?
11 A.
It was simply a matter of giving me someone with whom
12 I could connect once I got here.
10:33:21
13 Q.
Is it a lawyer that you paid for?
14 A.
It's a lawyer that the commission paid for.
15 Q.
It's a U.S. lawyer?
16 A.
It's a U.S. lawyer, yes.
17
MR. PARRAS: I want to look up at Government's
18 Exhibit 218. We're looking at Page 21. And if you could

19 please for me, zoom in on the bottom left.
10:33:40
20
THE WITNESS: Could we have this enlarged as
21 well, please?
22
THE COURT: That's what he's going to do.
23
MR. PARRAS: Very, very bottom left under the
24 line.
10:33:46
25
THE COURT: Are you going to enlarge it?

1986
MR. PARRAS: Yes.
THE COURT: There we go.
How about that?
4
10:33:53
THE WITNESS: That's very good, yes.
5 BY MR. PARRAS:
6 Q.
Have you seen that before, ma'am? This is a document
7 that's not for distribution.
10:34:04
10:34:10
8 A.
I have not seen that, no.
9 Q.
Do you know whether this is a draft document or a
10 finalized version?
11 A.
I do not.
12 Q.
Do you know who created this document?
13 A.
I do not.
14 Q.
When is the first time you were shown this document?
15 A.
This morning.
16 Q.
Where were you shown this document?
17 A.
Here in court.
18 Q.
And do you know whether this document is drafted for
19 customers in the U.S. or outside the U.S.?

10:34:26
20 A.
I do not know.
21 Q.
If it were -- if it were created for customers of the
22 United States, there may be different laws that apply;

23 correct?
10:34:36
24 A.
I suppose that's possible.
25 Q.
For example, it may well be that if it were

1987
1 distributed to customers in the U.S., the information that

2 we talked about, where the investments are, that it could
3 be considered a security; correct?
4 A.
10:34:51
Given that I'm not familiar with U.S. laws, I really
5 can't answer that.

6 Q.
Well, you answered a number of questions for the
7 prosecutor -8
THE COURT: Hold it. I can't -- do you want
9 the lapel mike?

10:34:58
10
MR. PARRAS: I think so, Judge.
11
THE COURT: All right. Let's get the lapel
12 mike. Right here. I think you hold the budget until it

13 goes. I'll stop the clock. And you need to put it high on
14 the tie, please.
10:31:23
15
MR. PARRAS: If you could go back to the whole
16 page. Thank you.

17 BY MR. PARRAS:
18 Q.
So the first time you saw this document was this
19 morning in court, and yet you were shown pieces and

10:35:46
20 blown-up sections of it for this jury to convey what idea,

21 Ms. Crick?
22 A.
It was not to convey an idea, it was in response to
23 questions that was asked.

24
10:36:00
MR. PARRAS: I don't need that document
25 anymore. Thank you.

1988
May I have the ELMO, Judge?
Thank you.
3 BY MR. PARRAS:
4 Q.
10:36:40
I'm going to show you Government's Exhibit 511.
Do you remember being shown this document?
6 A.
Yes.
7 Q.
And being asked about whether or not it would be
8 important for you to know that the government of

9 Montserrat proposed to revoke the license of GIBL -10:36:54
10 A.
Yes.
11 Q.
-- back in 1990; do you remember that?
12 A.
Yes, I do.
13 Q.
You told this jury that the first time you saw that
14 document was the night before you testified; correct?

10:37:07
15 A.
That is correct.
16 Q.
You answered a number of questions about why it might
17 be important to know that information; correct?
10:37:24
18 A.
That is correct.
19 Q.
Were you also shown an opinion by Judge Redhead that
20 held that the license was not revoked and that, in fact,
21 help from Mr. Stanford and his directors that knew that it
22 had been revoked was improper?
10:37:43
23 A.
I have not seen such a document.
24 Q.
I'm going to show you what's been marked and admitted
25 into evidence as Defendant's Exhibit 2-14. And this is my

1989
1 copy.
2
3 A.
4
10:37:54
10:38:08
Do you see that?

Yes.
MR. PARRAS: I want to verify with the Court
5 that this is in evidence. I believe it is.

6
MR. WARREN: No objection.
THE COURT: Has it been referenced yet?
MR. WARREN: It has, Your Honor.
THE COURT: All right. 511 -- correct, 511?
10 What number is that?

11
MR. PARRAS: This is Defendant's Exhibit 2-14.
12
THE COURT: Okay. I'm sorry. Defendant's.
13 No. I don't have that. 2-14? I have the latest one, 7-4.
14
10:38:32
MR. PARRAS: It would have been marked with the
15 second witness. That's the significant of the two. That's

16 correct, Your Honor, it was introduced.
17
THE COURT: Ellen may have it. All right.
18 2-14.
10:38:47
19
MR. PARRAS: Yes, Your Honor.
20
THE COURT: Double-check during the break. I'm
21 pretty sure it's in now that I remember.

22
MR. PARRAS: Yes, sir.
23
THE COURT: All right. Go right ahead. What
24 is this or what is it.

25
1990
1 BY MR. PARRAS:
2 Q.
Let's look at the first page so that we can determine
3 what this is. Okay. You see at the top there, In the
4 High Court of Justice, Colony of Montserrat, 1994. Can
10:39:06
5 you read that, ma'am?

6 A.
Yes, I do.
7 BY MR. PARRAS:
8 Q.
Do you see the case is between James Stanford,
9 R. Allen Stanford, Don Caldwell, O.Y. Goswick, and the

10:39:21
10 attorney general of Montserrat. Do you see that?

11 A.
Yes, sir.
12 Q.
And you see that the case is before the Honorable
13 Justice Albert Redhead?
10:39:28
14 A.
Yes.
15 Q.
And then there's the names of the lawyers that
16 appeared for the parties. This was a case that was heard
17 on the 25th, 26th, 27th and 31st of August 1994, and this
18 is the judgment of the Court.
19
10:39:49
I'm going to turn to Page 20 and -- do you
20 know what this lawsuit was about, by the way?

21 A.
No, I've never seen the document, so I have no idea.
22 Q.
The government didn't show you this document when
23 they showed you the letter about the propose to revoke

24 GIBL language?
10:40:05
25 A.
I have not seen this document.

1991
1 Q.
All right. As a regulator who licenses corporations,
2 would it be important for you to know whether or not, in

3 fact, the license was revoked or not?
10:40:19
4 A.
Yes, it would be.
5 Q.
I'm going to go page by page, and eventually we will
6 skip a few.
7
You're a judge with the labor court;
8 court?
9 A.
10:40:55
I am a member of the court, yes.
10 Q.
You're not a judge?
11 A.
There's a reference to a judge. I sit on a panel,
12 yes, of three judges.
10:41:03
13 Q.
Are you trained in law?
14 A.
I'm not.
15
THE COURT: She's a CPA or the equivalent of
16 our CPA.
17 BY MR. PARRAS:
18 Q.
But you're not trained in law --
19
10:41:09
10:41:13
THE COURT: You never said you were an
20 attorney?
21
THE WITNESS: That's correct, sir.
22
THE COURT: Do you want to be an attorney?
23
THE WITNESS: Yes, sir.
24
THE COURT: You do?
25
THE WITNESS: Yes.

1992
THE COURT: Okay. Usually I get an absolutely
2 "no."
3
Okay. Go on.
4 BY MR. PARRAS:
10:41:21
5 Q.
Ma'am, this letter, this opinion is in evidence, and
6 if the jury so chooses, they can read it in its entirety.

7 I'm going to represent to you that this is a lawsuit
8 regarding the idea that Guardian's bank's license was
9 revoked. And in this lawsuit, which the exhibit will
10:41:42
10 speak for itself, the directors of Guardian are suing the

11 attorney general of Montserrat so that the directors of
12 Guardian could affirmatively say their license had not
13 been revoked, okay? Do you understand?
10:42:03
14 A.
I understand what you're saying, yes.
15 Q.
I want to go -- it's Bates marked A Stanford 0010763.
16 And I'm going to read and you follow, and if I mess up,
17 you tell me, okay?
10:42:18
18 A.
Uh-huh.
19 Q.
"Allen Stanford" --
20
MR. WARREN: I'm sorry, Counsel. Can you
21 repeat that page, please?

22 BY MR. PARRAS:
23 Q.
This is an opinion about the trial. "Allen Stanford
24 testified that at the very end of October 30th, 1990, the

10:42:39
25 government of Montserrat was informed of the bank's

1993
1 intention to leave and go to Antigua. This was before he

2 received the letter of 28th November 1990."
3
That's the Government's Exhibit 511, 28
4 November 1990.
10:42:57
The Judge goes on to say -- and these are
6 my markings. "Allen Stanford said on oath that on 30th

7 October 1990, he, James Stanford; Goswick; Judge Don
8 Caldwell, Jr., came to Montserrat, especially to inform
9 the government of Montserrat of the bank's intention. He
10:43:21
10 said they went to the governor's place of business and the

11 office of C.P. John and informed them.
12
"Allen Stanford said the chairman informed
13 Charles G. John of the bank's intention to move to Antigua.

14 Allen Stanford said that the chairman, James Stanford,
10:43:39
15 asked Charles John in his and in the presence of others if

16 there were any items that the bank needed to address prior
17 to its departure."
18
I want to stop right there. Does it sound
19 to you like the directors of Guardian International who are

10:43:56
20 about to leave Montserrat are going to the highest official

21 they can to make sure that things are okay?
22 A.
On that reading, it would appear that way.
23 Q.
It's the Judge's opinion? That's what he's saying;
24 right, that reading?

10:44:12
25 A.
I'm not sure what I have before me is the Judge's

1994
1 opinion.
2 Q.
Let's go to the front, then. Defendant's
3 Exhibit 214. Judgment in court. And if we go on the

4 back, who is it signed by?
10:44:34
5 A.
Judge Albert Redhead.
6 Q.
Do you have any doubt that this is an opinion by
7 Judge Redhead?
8 A.
The sections you quote to me were not the opinions of
9 the Judge.
10:44:51
10 Q.
Well, let's read further to be fair. "Stanford said
11 that he made a note of that conversation in that meeting.

12 Charles T. John denied that he ever told Allen Stanford
13 that Guardian International Bank had no problems in
14 Montserrat. He, however, testified that Allen Stanford
10:45:07
15 and the other members of the Guardian International Bank

16 visited his office on the 30th of October 1990."
17
So there's a dispute about what was said,
18 correct, from that reading?
10:45:28
19 A.
It would appear that way.
20 Q.
But there's no dispute that there was a meeting on
21 October 30th, correct, from this reading?

22 A.
From the reading, yes.
23 Q.
We'll read on to what the gentleman said. "The
24 purpose of the meeting according to my understanding was

10:45:43
25 that they were seeking a letter of good standing to

1995
1 certify that Guardian International Bank was in good

2 standing with us. I did not issue such a letter. At that
3 meeting, I cannot recall any of the directors informing me
4 that Guardian International Bank had taken the decision to
10:46:08
5 leave Montserrat. I did not issue a letter of good

6 standing, because in my view, there were some difficulties
7 which militate against me issuing such a letter:
8
"I told Mr. Stanford that there were
9 difficulties and I could not do it. I did not tell him

10:46:22
10 what the difficulties were, but I told him where he could

11 get the information. I did not at any time tell
12 Mr. Stanford that Guardian International Bank had no
13 problems in Montserrat."
14
10:46:39
That's the dispute, right, who said what;
15 correct?
16 A.
It would appear that way from the document.
17 Q.
Okay. "Charles T. Jordan, Charles T. John, said that
18 the Antiguan government did not ask for a letter of good

19 standing." That's another witness making another
10:46:56
20 statement. "I entertain no doubt" -- now we have the

21 Judge talking -- "whatever that the directors of Guardian
22 International Bank who were operating a bank in Montserrat
23 by the name of Guardian International Bank are the same
24 persons who are the directors of a bank in Antigua,
10:47:13
25 Guardian International Bank." Let's stop right there for

1996
1 a second.
2
It's clear to you from this judicial opinion
3 that the Judge is speaking about the same directors that

4 ended up moving to Antigua and later becoming regulated by
10:47:29
5 you; correct?
6 A.
It would appear from that, yes.
7 Q.
Okay. This is the Judge's finding here. "I
8 entertain no doubt either that prior to 30 October 1990,

9 the bank had consummated its plan to move to Antigua. If
10:47:51
10 the Antiguan government needed a letter of good standing

11 from the Montserrat government or if a letter of good
12 standing was a prerequisite, then in my view" -- Judge
13 speaking; correct -- "it would have been a simple and an
14 easy matter to obtain such a letter from a governmental
10:48:07
15 level. By this I mean it would have been an easy thing

16 for the government of Antigua to request such a letter
17 from the government of Montserrat."
18
As a regulator, ma'am, you could have
19 requested from Montserrat at any time that you were

10:48:27
20 director the files of Montserrat regarding Guardian

21 International Bank; correct?
22 A.
There is something I need to make clear in terms
23 of -24
10:48:38
THE COURT: In other words, you can't -- can
25 you answer the question yes or no. If you can't -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
1997
THE WITNESS: I can't answer it yes or no.
THE COURT: Okay.
3 BY MR. PARRAS:
4 Q.
10:48:50
You're the regulator now, right, of the FSRC in
5 Antigua?
6 A.
I am the Chairman of the Board, yes.
7 Q.
If you wanted to get information today about a bank
8 in Montserrat today, you could ask the government of

9 Montserrat for that information; correct?
10:49:02
10 A.
We could make the request, yes.
11 Q.
Let's keep reading, and I'll be done on the next
12 page. Down at the bottom. "Charles T. John having said

13 that he did not issue such a letter to Allen Stanford,
14 neither was one requested of him by the government of
10:49:27
15 Antigua. I must, therefore, conclude that such a letter

16 was not necessary so far as the government of Antigua was
17 concerned. If it was not necessary, then why would Allen
18 Stanford request one? I, therefore, accept Allen
19 Stanford's evidence in preference to Charles T. John's
10:49:52
20 evidence."
21
That's a finding; right?
22
THE COURT: That's a what, Counsel?
23
MR. PARRAS: A judicial finding, a fact
24 finding.
25
1998
1 BY MR. PARRAS:
2 Q.
This is the Judge saying that he gives more credit to
3 Allen Stanford's account than Charles John's account;

4 right?
10:50:08
5 A.
It would appear that way, yes.
6 Q.
"This is, he, Allen Stanford, did not request any
7 letter of good standing and that the purpose of the

8 meeting of 30 October 1990 was to inform Charles T. John
9 of the bank's intention to move to Antigua.
10:50:29
10
"Mr. Kenneth Allen and Allen Stanford
11 testified that they went to the chief minister's office on

12 21 December 1990."
13
We're talking about a different meeting
14 now; correct?
10:50:42
15 A.
16 Q.
"Mr. Allen said that at the chief minister's office,
17 he explained to the then chief minister, Mr. Osborne, that

18 the purpose of their meeting with him was to surrender the
19 A and B licenses of the time bank since we were about to
10:51:00
20 move to another jurisdiction and had seized business in

21 Montserrat and to thank him for the time we had operated
22 here.
23
"Mr. Allen said that he handed the chief
24 minister a large envelope which contained two original

10:51:15
25 licenses and later addressed to him -- and a letter

1999
1 addressed to him. He read the letter carefully, looked at

2 the two licenses, and then, according to Mr. Allen, said to
3 Allen Stanford, 'I'm sorry you're leaving because I've
4 always heard good news about your company.'"
10:51:31
5
6
That's what the opinion says; correct?

THE COURT: Counsel, that is a judicial
7 opinion?
10:51:38
MR. PARRAS: Yes, it is Judge.
THE COURT: Is that they write -- I guess they
10 write it in different jurisdictions different ways?

11
MR. PARRAS: Yes.
12
THE COURT: I mean, that --
13
MR. PARRAS: He probably was wearing a wig at
14 the time he wrote this.

10:51:48
15
THE COURT: Maybe they have it right. I don't
16 know.
17
MR. PARRAS: I always wanted to wear one of
18 those little legal wigs, especially now with this hair

19 going away, Judge.
10:52:03
20
THE COURT: They're hot. I've tried them on.
21 There is a wig store named -- what is it -- something in

22 Ravenscroft -- Ede & Ravenscroft in London, and I actually
23 went there to see what it was like and tried them on. I
24 don't need to wear it. It's hot. They're horse hair. And
10:52:24
25 the long -- the short ones are by the barristers and for
2000
1 judges when they try civil matters. When they try criminal
2 matters, they wear a red robe with a big long wig. I
3 learned all about that. I did not buy one.
4
10:52:46
MR. PARRAS: Going on to Page 25. And, again,
5 this is in evidence, the jury can ask for it. The jury can
6 read the entire thing. I'm going to go to Page 25, first
7 full paragraph.
8 BY MR. PARRAS:
9 Q.
10:52:58
"Neither Mr. Kenneth Allen nor Mr. Allen Stanford who
10 were present at the meeting can recall John Osborne

11 handing the license to the financial secretary."
12
It sounds like we're talking about the
13 same meeting where licenses were handed over.

14
10:53:11
"In my view" -- Judge speaking -- "it is
15 not of critical importance whether John Osborne handed the

16 license to Charles John or not. What is of importance is
17 whether Allen Stanford handed over the license to John
18 Osborne." Now the Judge speaking. "I have absolute no
19 doubt that on 21 December 1990 Allen Stanford handed over
10:53:30
20 the original A and B licenses to John Osborne at his

21 office.
22
And this opinion also alludes to some
23 differences of opinion that Mr. Stanford had with a

24 regulator named Roe. And I want to show you what the
10:54:05
25 Judge's findings are in that regard. Here's the Judge

2001
1 speaking. "From the evidence, I have no doubt that there

2 was bad blood again Allen Stanford and Roe."
3
4 A.
10:54:20
Do you know Mr. Roe?

No, I do not.
MR. PARRAS: Let me go to Page 38.
6 BY MR. PARRAS:
7 Q.
"The evidence is that Roe was a banking advisor. He
8 was not a lawyer."

9
10:54:39
Do you see that? Right there where the
10 pen is pointed.
11 A.
Okay. Yes, uh-huh.
12 Q.
It's true, ma'am, that there are times when in your
13 business, in your job as a regulator, you either don't

14 have the legal answers or you need to seek legal advice or
10:54:56
15 you need a legal opinion or you're frustrated that the law

16 doesn't allow you to do something you want to do; correct?
10:55:13
17 A.
I'll accept the last one.
18 Q.
Well, there are times --
19 A.
It's not been my experience.
20 Q.
So it's your experience that the IBC act of 1982 has
21 everything needed and you've never been frustrated by the

22 law in your pursuit of information or regulatory?
10:55:32
23 A.
I wouldn't use the word "frustrated," no.
24 Q.
Okay. Have you had occasion to think it should be
25 better, the law the should be better?

2002
1 A.
Laws can always be improved, and that's the case with
2 us as well.
3 Q.
And then just to close this out again, last page,
4 signed Judge Redhead. There are some -- I believe these

10:55:48
5 were admitted as well, these articles, and at the end a

6 judgment of the Court 20 December 1994. And I'm going to
7 read the judgment. It's only a page.
8
"This action having been tried before the
9 Honorable Mr. Justice Redhead, without a jury, and the

10:56:13
10 said Mr. Justice Redhead having on the 31st day of

11 August 1994 ordered that judgment as hereinafter provided
12 be entered for the plaintiff."
13
Let's go back to the front. We have here
14 the plaintiffs, James Stanford, Allen Stanford, Don

10:56:33
15 Caldwell, O.Y. Goswick.

16
"It is adjudged and declared as follows:
17 That Guardian International Bank, Limited, ceased to do

18 business on the 19th of December 1990."
10:56:50
19
I'm going to skip ahead.
20
"That the licenses granted to Guardian
21 International Bank on 9 January '86 and the 14th day of

22 November '88 could not be revoked."
10:57:03
23
I'm going to skip ahead.
24
"That the revocation referred to in a
25 letter dated -- I think that's 19th June, '91 -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2003
1 "purported to have been made on the 31st day of May 1991

2 is null and void and of no effect."
3
10:57:17
Do you see that, ma'am?
4 A.
Yes.
5 Q.
Okay. And this, you'll agree with me, was 1994;
6 correct?
7 A.
Yes.
8 Q.
Long before you had any occasion to regulate SIBL on
9 the island of Antigua; correct?

10:57:33
10 A.
Yes.
11 Q.
So if it was necessary for your duties to learn about
12 the history, in addition to this letter that the

13 government showed you, it would have been important for
14 you to have this exhibit that the defense has shown you,
10:57:50
10:58:00
15 wouldn't it?
16 A.
Yes.
17 Q.
And that would have cleared up the matter; right?
18 A.
Not necessarily.
19 Q.
Do you want to take that up with Judge Redhead?
20 A.
I don't have the benefit of having read the entire
21 document. I've been given sections of it. I don't know

22 how it all fits together cohesively.
23 Q.
24
10:58:24
Thank you.
We're talking about regulations. And it's
25 true that in 1998 and in 1999 when you -- so difficult to

2004
1 see with that screen, ma'am, sorry.

2
In 1998 and in 1999, there was an effort
3 in Montserrat to make the laws, the offshore banking laws,

4 the international business regulation laws better;
10:58:42
10:59:00
5 correct?
6 A.
In Montserrat?
7 Q.
I mean, in Antigua. I'm sorry. Thank you.
8 A.
Yes, uh-huh.
9 Q.
And it's true that in 1996 there was a law passed in
10 Antigua regarding money laundering; correct?

11 A.
That's correct.
12 Q.
At that time in the world, the drug war was raging
13 all over the Caribbean, South America, Central America and

14 North America; correct?
10:59:16
15 A.
I don't know that I have the expertise to answer
16 that.
17 Q.
Well, the money laundering laws were an effort to
18 impose tighter controls on banks and on financial

19 services -10:59:28
20 A.
Uh-huh.
21 Q.
-- in the Caribbean area and otherwise so that money
22 laundering could be shut down; correct?
10:59:40
23 A.
Money laundering, yes.
24 Q.
And that was 1996; right?
25 A.
Yes.
2005
1 Q.
And as time progressed into 1998 and 1999, what the
2 governments realized is that they had to also regulate the

3 financial services industry better; correct?
4 A.
11:00:02
There was that realization that the sector had to be
5 regulated better, yes.

6 Q.
And you were asked to join the Antiguan government in
7 an effort to make the bank, offshore bank, regulations

8 better; right?
9 A.
11:00:19
10 Q.
Yes, uh-huh.
You were asked to also join then Antiguan government
11 so that you could make offshore banking a business on the

12 Island of Antigua; correct?
11:00:40
13 A.
That's not correct.
14 Q.
You were asked to compare the Antiguan laws to other
15 Caribbean islands so that you could compete with places

16 like the Bahamas and the Cayman Islands for offshore
17 banking business; correct?
11:00:53
11:01:00
18 A.
That's not true.
19 Q.
Do you remember writing an International Financial
20 Sector operational plan -21 A.
Yes.
22 Q.
-- in November of 1998?
23 A.
Yes.
24 Q.
You authored it; correct?
25 A.
Yes.
2006
1 Q.
You authored it under the -- as the executive
2 director of the International Financial Sector Authority

3 correct?
11:01:08
4 A.
Yes.
5 Q.
And it was commissioned and intended to give the
6 commission a quick plan for hypergrowth; correct?
11:01:21
7 A.
Yes, uh-huh.
8 Q.
Of the offshore sector?
9 A.
Yes.
10 Q.
So the Government of Antigua was looking to expand
11 the offshore banking business; right?

12 A.
The international business. You see, you keep
13 focussing on banking sector. It's the international

14 business sector.
11:01:38
15 Q.
That's a great point because international business
16 and the AIBCI doesn't apply just to offshore bank;

17 correct?
11:01:47
18 A.
Exactly.
19 Q.
It applies to --
20 A.
A range of types of entities and services.
21 Q.
Internet gambling services?
22 A.
Internet gambling is not considered international
23 financial banking. International financial service, no.

24 Q.
11:02:02
So then, what are -- just give me an idea of what the
25 range is.
2007
1 A.
The range would include international insurance,
2 international trusts. We now regulate nonfinancial

3 business cooperatives. It's a wide range of regulatory
4 functions that we carry out.
11:02:23
5 Q.
And -- and you wrote a report and presented it to the
6 board. And that was late of 1998; correct?

7 A.
That sounds about right, yes, uh-huh.
8 Q.
And it's true that at that time there was a group
9 called the "Offshore Financial Sector Planning Committee";

11:02:42
10 right?
11 A.
Yes.
12 Q.
Okay. I'm going to call it the OFS for short. Is
13 that okay?
11:02:58
14 A.
The acronym doesn't quite fit, but yes.
15 Q.
The -- that committee was not a government entity;
16 correct?
17 A.
That is correct.
18 Q.
That committee was made up to help the government to
19 strengthen their financial laws and regulations, the same

11:03:10
20 kind of work that you were doing; correct?

21 A.
Yes.
22 Q.
And it's that committee that Mr. Stanford was a
23 chairman of; correct?
11:03:17
24 A.
Yes.
25 Q.
And you objected to that; right? You didn't think it

2008
1 was proper?
2 A.
No, I didn't object to that.
3 Q.
Okay. You didn't object? You never lodged a
4 complaint? You didn't file a report with anybody in the

11:03:32
5 government saying that you thought it was improper for

6 Mr. Stanford to be chairman of the OFSPC, did you?
11:03:48
7 A.
This was not a government body.
8 Q.
I understand.
9 A.
It's a civil body. Why would I object to a group of
10 business persons, in effect, to getting together to assist

11 the government.
11:03:57
12 Q.
It was a good thing?
13 A.
There's no need to object to that.
14 Q.
It was a good thing, wasn't it?
15 A.
I don't know that it was a good thing, but I know
16 there would be no need to object to it.

17 Q.
You found no -- let's just move on.
18
Let's -- you will agree that, on that
19 committee, was a former FBI agent named Lloyd Harold;

11:04:12
20 correct?
21 A.
I think -- I can't be sure that Harold was on that
22 committee. It's quite possible that he was.
11:04:31
23 Q.
A former DEA agent named Tom Cash?
24 A.
Yes. But --
25 Q.
A U.S. customs agent named Pat' O'Brien, former U.S.

2009
1 Customs agent. Same division that Mr. Gerber works with;

2 right?
11:04:46
11:05:04
3 A.
Uh-huh.
4 Q.
And a -- there were accountants from the big -- the
5 big accounting firm, BDO Seidman; correct?

6 A.
I don't recall that no.
7 Q.
There were lawyers from Greenberg, Traurig; correct?
8 A.
I know of a lawyer.
9 Q.
Was that Carlos Lumiere?
10 A.
The name that comes to mind is Patrick O'Brien.
11 Q.
And Patrick --
12 A.
That's not to say there wasn't. I just don't recall.
13 Q.
And that's a good point.
14
11:05:16
In addition to being a former customs
15 agent he was a lawyer too; right? Pat O'Brien?

16 A.
He was a lawyer, uh-huh.
17 Q.
There was a gentleman who had been the head of the
18 Puerto Rican financial regulatory agency named Mr. Diaz.

19
11:05:30
Was he on that committee?
20 A.
Mr. Ivan Diaz, yes.
21 Q.
And then there was a former East Caribbean Supreme
22 Court Judge named Kenneth Allen who was on that committee;

23 correct? If you remember.
11:05:52
24 A.
I can't recall that gentleman being on the committee.
25 Q.
It's true that that committee was helping you to

2010
1 establish a regulatory framework for international

2 corporations?
11:06:24
3 A.
This -- I cannot recall that committee doing that.
4 Q.
What do you recall that committee doing?
5 A.
In fact, the names that you mentioned, I know of them
6 as a team working on Operation Clean Slate.

7 Q.
Okay.
8 A.
The committee I was referring to when you asked me
9 early on was a committee I knew of as the Sectoral

11:06:48
10 Committee. This is why I said your acronym was not

11 correct, because you inserted the word "planning
12 committee," and I'm not familiar with the planning
13 committee. That's why I'm looking very confused because
14 the two things that I'm not -- that are not marrying at
11:07:03
15 all. They are two different things?

16 Q.
Maybe you can help me then.
17 A.
I would love to.
18 Q.
There was a committee of private individuals that
19 were helping the government regarding the regulations that

11:07:17
20 you were working on as the executive director of the IFSA;

21 correct?
22 A.
Among other things, yes. That was the Sectoral
23 Committee when I came on board.

24 Q.
11:07:30
Okay. And then you came on board and you and your
25 team developed a plan that we talked about started in

2011
1 November of '98 and resulted in a second report in

2 February of '99; correct?
11:07:48
3 A.
Yes. It's possible, yes.
4 Q.
And could you describe basically what your report was
5 about?
6 A.
This is so long ago. The report outlined what I saw
7 as the needs of the body to develop the sector to

8 strengthen the regulatory regime of the sector. That was
9 the broad theme of the report, if I recall correctly.
11:08:16
10 Q.
Is it true that at that time the United States and
11 places like UK had concerns about the banking industry

12 down in Antigua?
11:08:33
13 A.
It had concerns about operators in the sector, yes.
14 Q.
And you and this private group were trying to address
15 those concerns.
16
17 A.
That's fair, isn't it?

Not that group. I did not work with that group.
18 That's the point I want to make.

19 Q.
11:08:41
20
Okay. Let's just stick to you then, what you know.

You were working to address concerns of
21 the international community regarding the regulations of

22 international companies on Antigua?
23 A.
I was working as the person who was brought on board
24 to develop a regime that would make the jurisdiction

11:08:59
25 effective in respect to regulating the various

2012
1 international entities.
2 Q.
Okay.
3 A.
That was my task. It involved a number of things
4 that had to be done, from administrative to legislative.

11:09:14
5 It was a range of things that had to be put in place.

6
The team that you are describing is the
7 team I knew of Operating Clean Slate.

8 Q.
Okay. Then I will get there then; okay? Let's just
9 stick to what you did.

11:09:28
10
You turned in your reports to the board
11 and they replied back basically saying, you know, that's

12 good work, but we need you to do more quicker, and they
13 gave you a memo outlining the various things that they
14 wanted you to do, 29, 30 items, with a definitive time by
11:09:50
15 which you should get them done; correct?

16 A.
I remember that memo, yes.
17 Q.
Did that memo upset you?
18 A.
I was somewhat disturbed by the memo, yes. Some of
19 the timelines were unreasonable.

11:10:02
20 Q.
You thought they were asking you to do too much too
21 quickly; right?
22 A.
No.
23 Q.
What did you think then? Why were you disturbed by
24 the timeline?
11:10:11
25 A.
Because some of the things that were contained that I

2013
1 was being -- in that letter, that was being asked to do,

2 were things that could not reasonably be done in the
3 timeframe set.
4 Q.
11:10:26
Okay. Is it -- do you remember that memo coming out
5 approximately two months after your second report in April

6 of '99?
7 A.
That, I couldn't say for sure. It probably did.
8 Q.
Do you remember in April of '99 that the United
9 States and the United Kingdom sent a message out to the

11:10:41
10 world about doing business on the Island of Antigua?

11 A.
Yes.
12 Q.
What was the message that the United States and the
13 United Kingdom sent out to the world in April of '99?

14 A.
11:11:03
I don't recall exactly, but the gist of it was
15 essentially to -- alerting their constituents that there

16 were certain weaknesses within the regulatory regime in
17 Antigua and Barbuda. That's the general terms. I can't
18 remember the specifics.
19 Q.
11:11:22
And here's where we get to Operation Clean Slate.
20
Either in conjunction with or as a result
21 of that message, a group of individuals who you called

22 Operation Clean Slate undertook the job to scrub the
23 island of all its banks; correct? Basically?
24 A.
11:11:44
I never knew what was really the task of Operation
25 Clean Slate.
2014
1 Q.
Okay. Is this the group that was asking for your
2 files, or is that a different incident?

3 A.
It's the team, the Operation Clean Slate team, but
4 some of the names that you called are not familiar to me

11:11:59
5 as being part of the team. That's not to say they were

6 not.
7 Q.
Okay. Which ones do you remember being part of
8 Operation Clean Slate?

9 A.
11:12:11
I remember Lloyd Harold. I remember Pat O'Brien. I
10 remember Sandra Jeffrey. I remember Ivan Diaz and Cynthia

11 Roche.
12 Q.
And what you're telling us here today is that, as the
13 executive director of the regulatory agency on the Island

14 of Antigua, you don't know exactly what Operation Clean
11:12:34
15 Slate was doing?

16 A.
Sounds strange, doesn't it? But that was the case,
17 believe me.
18 Q.
Do you know that eventually Operation Clean Slate was
19 able to scrub the banks, get rid of some Russian banks and
11:12:48
20 drop a number of international offshore banks from 50 down

21 to 25 or less?
22 A.
Operation Clean Slate, its actions, what it did, what
23 the results were, were never revealed to me.
11:13:06
24 Q.
Okay.
25 A.
I don't have information leading to that. Anything

2015
1 that I had, any knowledge that I had, might have come

2 after; but certainly I don't know what they accomplished.
3 Q.
Okay. Let's talk about after this.
4
11:13:20
It's clear to you that, after Operation
5 Clean Slate, GIBL was still operating on the Island of

6 Antigua; right?
7 A.
I think so. If it was still Guardian. I'm not sure
8 when it changed to Stanford.

9 Q.
11:13:34
It's either Guardian or Stanford?
10 A.
Yes.
11 Q.
But bottom line is, Operation Clean Slate ended.
12 Guardian or SIBL is still in operation; correct?
11:13:47
11:14:00
13 A.
That is correct.
14 Q.
And you were successful in getting your regulatory
15 framework up and running, weren't you?

16 A.
As a result of Operation Clean Slate?
17 Q.
No. Just --
18 A.
Generally?
19 Q.
You eventually started examining banks; correct?
20 A.
In that regard, yes, uh-huh.
21 Q.
You started sending examiners to the different
22 international banks, having them go through the

23 accounting, go through the procedures, go through the
24 banks's processes, and reporting back to you; correct?
11:14:14
25 A.
I began that exercise, yes.

2016
1 Q.
As a side note, were you aware that Guardian
2 International Bank or SIBL in the spring of 1999 wrote

3 a 3 million-dollar check to the United States Marshals
4 Service pursuant to an investigation regarding money
11:14:40
5 laundering, an allegation that one of its customers had

6 improperly used the bank?
11:14:48
7 A.
I'm aware of that, yes.
8 Q.
And that's true. That happened; right?
9 A.
Yes. I'm aware of it, yes.
10 Q.
Guardian International Bank and Mr. Allen Stanford
11 cooperated with authorities in the investigation of money

12 laundering, didn't they?
11:15:10
13 A.
I don't know of that.
14 Q.
We talked briefly about the bank secrecy that was
15 raised this morning.

16
Is it good business or bad business to
17 give your customer information out to anybody that asks?
11:15:19
18 A.
Customer information?
19 Q.
Yes.
20 A.
No.
21 Q.
All right. Is it good business or bad business to
22 give your competitors information about how you're

23 investing money?
24 A.
11:15:35
That depends on the information and the nature of the
25 investment.
2017
1 Q.
It's true, isn't it, that depending on the
2 jurisdiction and the country that you're in, different

3 rules may apply?
11:15:46
4 A.
That is correct, yes.
5 Q.
I want to talk a little bit about your island; okay?
6 A.
Sure.
7 Q.
Let me show you what I think has been admitted as
8 Government's Exhibit 516.

9
11:16:16
MR. PARRAS: And if I can get verification on
10 that.
11
THE COURT: It's in. The question is: Has it
12 been identified?
13
It hasn't been identified since I've been
14 keeping the list. Has it been identified before?

11:16:27
15
MR. WARREN: Yes, Your Honor.
16
THE COURT: Okay.
17 BY MR. PARRAS:
18 Q.
11:16:35
I'm putting Government's Exhibit 5 -- 1516 --
19
THE COURT: Well, hold it. 1516?
20
MR. PARRAS: I thought it was five, Judge. I
21 misspoke. And I'm going to move this. Excuse me.

22 BY MR. PARRAS:
23 Q.
I'm going to point to the far right where it says
24 Barbuda and Antigua.

11:16:57
25
Do you see that?

2018
11:17:04
1 A.
Yes.
2 Q.
Is that where were born?
3 A.
I was born in Antigua, yes.
4 Q.
You lived there until you left for college in
5 Florida?
6 A.
Yes.
7 Q.
Was Florida the first place you visited outside of
8 Antigua?
9 A.
11:17:09
10 Q.
No.
What other places had you been to before you went to
11 Florida?
12 A.
Before I went to Florida, I had been to a number of
13 the other Caribbean islands, and basically that's the

14 extent of my travel, within the islands.
11:17:24
15 Q.
I haven't been out there. Whether we say the West
16 Indies, what are we talking about on this map?

17 A.
You're talking islands ranging anywhere from Trinidad
18 all the way up the chain to Anguilla.

19 Q.
11:17:49
Okay. And it's true that -- and this is way off
20 subject, but not way off subject. But it -- the one thing
21 that you nights all of those islands is cricket; right?
22 A.
You could say that, yes.
23 Q.
There's a saying that cricket is the glue that binds
24 the West Indies; correct?

11:18:02
25 A.
Not so much now, but there was a time, yes.

2019
1 Q.
And that's -- you're going exactly where I was
2 thinking.
3
There was a time -- there was a time when
4 the cricket players -- and cricket's a lot like baseball;

11:18:15
5 right? It's not a lot. It's kind of like baseball.

6 A.
It's not quite like baseball, no, but -- I wouldn't
7 say it's a lot like baseball, no.

8 Q.
There was a time in the '70s, I believe, and into the
9 '80s when the West Indies cricket team were the premier
11:18:34
11:18:47
11:18:57
10 team of the world for 15 years running; right?

11 A.
Yes.
12 Q.
They became known as the legend; right?
13 A.
Yes.
14 Q.
And it's true that the islands rise and fall with the
15 success of the cricket team -16 A.
Rise and fall.
17 Q.
-- of the West Indies?
18 A.
Rise and fall in what respect?
19 Q.
Well, heart and soul of the islands as a whole, as a
20 group, really come together behind the Westies; right?

21 A.
Yes. Uh-huh.
22 Q.
And during that time, the '70s and into the '80s, the
23 Westies, as they're called, traveled to?
11:19:14
24 A.
Indies.
25 Q.
The Indies -- West -- the Windies?

2020
1 A.
Indies.
2 Q.
Indies.
They traveled to places that had been
4 other colonial -- other colonies like Australia; right?

11:19:27
5 A.
(Answered affirmatively).
6 Q.
New Zealand, South Africa?
7 A.
8 Q.
And they absolutely whipped all of the countries in
9 cricket where they went to for 15 years; right?

11:19:38
10 A.
That's correct.
11 Q.
They went to London and did that in London, didn't
12 they, against the English team?

13 A.
14
11:19:51
All over.
THE COURT: All right, Counsel. Make the
15 point, please.
16 BY MR. PARRAS:
17 Q.
Cricket was something that Mr. Stanford attempted to
18 revive in the Indies in the five, ten years before SIBL

19 was taken over; correct?
11:20:12
20 A.
I don't know that that's the case, no.
21 Q.
I'm going to show you what's been marked as
22 Defendant's Exhibit 1530, it's a series of photos. I want

23 you to look through them see if you recognize them.
11:21:57
24
And when you're done, let me know; okay?
25
Do you recognize those places?

2021
1 A.
Not all of them.
2 Q.
Okay. If you -- let me walk up there, if you don't
3 mind, and I'll put a little note on the ones you

4 recognize.
11:22:07
Can you tell me which ones you recognize?
6 This first one?
11:22:15
11:22:24
11:22:35
11:22:57
7 A.
I don't recognize that.
8 Q.
Okay. Second one?
9 A.
Yes.
10 Q.
Third one?
11 A.
Yes.
12 Q.
Fourth one?
13 A.
Yes.
14 Q.
Fifth one?
15 A.
No.
16 Q.
Sixth one?
17 A.
Yes.
18 Q.
This one?
19 A.
Yes.
20 Q.
There may be a few of them. How about that one?
21 A.
Yes, sir.
22 Q.
Is that one?
23 A.
No.
24 Q.
That one?
25 A.
No.
2022
11:23:15
1 Q.
That one?
2 A.
Yes.
3 Q.
Is this one?
4 A.
No, that's not familiar.
5 Q.
This one?
6 A.
That looks like familiar. Yes, uh-huh.
7 Q.
Yes?
8 A.
I'm not familiar with that one. And, yes.
9
11:24:09
(Attorneys conferring)
10
MR. PARRAS: I should ask her.
11
MR. WARREN: That's fine.
12
MR. PARRAS: Judge, I move to admit

14
11:24:21
11:24:28
THE COURT: Has it -- it's already is, isn't
15 it?
16
MR. WARREN: I'm not making an objection.
17
THE COURT: Has it been identified?
18
MR. PARRAS: I can --
19
THE COURT: Hold it. Counsel, has it been
20 identified?
21
MR. WARREN: I don't believe so yet, Your
22 Honor. We have no objection.

23
THE COURT: All right. So it's already in, but
24 it's now identified.

25
2023
1 BY MR. PARRAS:
2 Q.
Just generally speaking, Ms. Crick, could you tell
3 the jury here what it is that you recognize in those

4 pictures?
11:24:52
5 A.
I recognized pictures of buildings that house
6 Mr. Stanford's -- some of Mr. Stanford's businesses.

7 Q.
Okay. Let me show you what is Bates Number 006.
8
9 A.
11:25:11
Do you recognize that building?

Yes.
10 Q.
Tell the jury what that building is?
11 A.
It's Stanford International Bank Services.
12 Q.
It's not a apartment in a strip club -- I mean a
13 strip mall, is it?
11:25:27
14 A.
No, it is not.
15 Q.
It's a big building for the Island of Antigua, isn't
16 it?
17 A.
You said for the Island of Antigua?
18 Q.
On the Island of Antigua, it's actually a nice
19 building?
11:25:38
20 A.
It's a building on the Island of Antigua.
21 Q.
Is it a nice one?
22 A.
You could say that, yes.
23 Q.
You indicated that you recognize this building.
24
11:26:02
Could you tell the jury what this building
25 is?
2024
1 A.
This is a hangar, aircraft hangar.
2 Q.
Who owns the hangar?
3 A.
As far as I'm aware, it's owned by Stanford, one of
4 Stanford's companies.
11:26:13
5 Q.
Is it still on the Island of Antigua?
6 A.
I think it is. I'm not absolutely sure.
7 Q.
When you fly in and out of Antigua, do you fly in and
8 out of the airport attached to this hangar?

9 A.
11:26:28
The airport attached to that hangar?
10 Q.
The airport where this hangar is located?
11 A.
In the general region, yes.
12 Q.
Do you have more than one airport on the Island of
13 Antigua?
11:26:40
14 A.
We have one airport, yes.
15 Q.
Okay. When you fly out, do you fly out of this
16 airport?
17 A.
Yes.
18 Q.
Okay. And this is in evidence, but you didn't
19 recognize this building; correct?

11:26:59
20 A.
No. I don't know. I'm not familiar with that
21 building.
22 Q.
You did say that you recognize this building. And
23 it's at Bates 000015.

24
11:27:14
25 A.
What is this building?

That's the building that houses Bank of Antigua.
2025
1 Q.
Now, Bank of Antigua is the bank that serves
2 Antiguans that Mr. Stanford or SIBL or -- and I don't know

3 exactly who right now, but that is part of the Stanford
4 entities; correct?
11:27:33
5 A.
Yes.
6 Q.
Okay. You told me you recognize this as an aerial
7 view of the cricket field?
11:27:55
8 A.
That's true yes.
9 Q.
And it's true that this cricket field is one of the
10 best cricket fields in the world; right? Do you know

11 that?
11:28:03
12 A.
I don't know that.
13 Q.
It's -- okay.
14 A.
I'm not a cricket field expert.
15 Q.
Have you been to a cricket match on this field?
16 A.
No.
17 Q.
All of the buildings that we just looked at to your
18 knowledge continue to exist on Antigua; correct?
11:28:24
19 A.
The buildings are there, yes.
20 Q.
Do you know whether there's an Antiguan receiver who
21 is in control or who has ownership of those buildings

22 right now?
23 A.
I know there is a liquidator. Whether the person has
24 control, to what extent, that, I'm not familiar with.

11:28:39
25 Q.
Have you seen any of the liquidators or attorneys for

2026
1 the liquidators in court here this week?

2 A.
No.
3 Q.
Okay. And you do know that there's another receiver,
4 a second receiver, in the United States who is in a legal

11:28:57
5 dispute with the Antiguan receiver about ownership of SIB

6 assets; correct?
7 A.
I know there's a dispute. I don't know the exact
8 details of the dispute.

9 Q.
11:29:35
On direct examination, you talked about a Mr. Hewlett
10 offering you a job to go and audit the Bank of Antigua;

11 correct?
12 A.
To partner with him in conducting the audit.
13 Q.
At the time -- do you remember what year he asked you
14 to do that?
11:29:44
15 A.
No, I don't recall. But I know it was in the --
16 maybe the late '80s, I think it might have been, or early

17 90s, somewhere around there.
18 Q.
Did Mr. Hewlett have a good reputation or a bad
19 reputation on the island?

11:30:01
20 A.
I don't know that he had a good -- in respect of
21 what?
22 Q.
Well, in respect to your decision to possibly partner
23 with him, did it concern you to concern to partner with

24 Mr. Hewlett?
11:30:18
25 A.
No, it did not cause me concern.

2027
1 Q.
In fact, as late of 2007, you and Mr. Hewlett were on
2 the same auditing organizations, island organizations;

3 correct?
11:30:31
4 A.
Yes. He's a certified accountant on the island.
5 Q.
And on direct, I believe you were asked about the
6 annual reports.
7
You know that Mr. Hewlett signed every
8 single one of these audits, these annual reports, that you

9 were asked about? Do you know that?
11:30:44
11:30:54
10 A.
The annual reports?
11 Q.
The SIBL or GIBL annual reports.
12 A.
The auditor's report?
13 Q.
Yes.
14 A.
He signed. He was the auditor, yes. He would have
15 signed them.
16 Q.
Let me show you what's been introduced as

18
MR. PARRAS: And I could -- I could use some
19 help here, PDF Page 27, please. Government's Exhibit 111.

11:31:12
20
MR. SCARDINO: Need to switch, Judge.
21
THE COURT: Okay.
22
MR. PARRAS: And if we could zoom in on the
23 signature and address at the bottom.

24 BY MR. PARRAS:
11:31:27
25 Q.
Is that the company and the address where from

2028
1 Mr. Hewlett worked?

2 A.
3
Yes.
MR. PARRAS: Okay. If we could go back out to
4 the full page. And if we can focus on the opinion at the

11:31:41
5 very end there.

6 BY MR. PARRAS:
7 Q.
And I'm going to read this out loud. If I mess it
8 up, please tell me.

9
11:31:49
"In our opinion, the financial statements
10 give a true and fair view of the state of affairs of the

11 bank as at 31 December 1998, and of the result of its
12 operation for the year then ended. The statements have
13 been prepared to comply with international accounting and
14 financial reporting standards and the companies law of
11:32:09
15 Antigua and Barbuda."

16
MR. PARRAS: This -- if we could can to the
17 first page of this exhibit to see what year it is. And if

18 we could zoom in there on annual report 1998.
19 BY MR. PARRAS:
11:32:23
20 Q.
Is this an annual report that at this time would have
21 been subject to a regulatory -- an Antiguan regulatory

22 body or agency for review?
23 A.
It would have been submitted, because it's a
24 requirement, yes.
11:32:38
25 Q.
Okay. And to your knowledge as the executive

2029
1 director of the regulatory body just a year later, was

2 there ever any complaint, professional complaint, about
3 Mr. Hewlett?
4 A.
11:32:53
Professional complaint, not that I can recall.
MR. PARRAS: Okay. Let's go to Government's
6 Exhibit 112, PDF 30 and let's start with the first page,
7 PDF 1, please. If we can go to the first page. I'm sorry.
8 BY MR. PARRAS:
9 Q.
11:33:09
What year is this, ma'am?
10 A.
1999.
11 Q.
Okay. At that time, you were head of the -- the
12 executive director of the regulatory agency on Antigua;

13 correct?
11:33:19
14 A.
Yes.
15 Q.
If you wanted to, you could have looked through a
16 comb of this report and asked the bank to go in and

17 examine their paperwork; correct?
18 A.
We could have, yes. I'm just trying to -- I'm
19 hesitating for a reason.

11:33:37
20
MR. PARRAS: Well, let's go to PDF Page 30.
21 And zoom in on the signature and address block at the

22 bottom.
23 BY MR. PARRAS:
24 Q.
11:33:56
That's Mr. Hewlett's signature and his working
25 address there on the island?

2030
1 A.
The address, yes. The signature appears to be his.
MR. PARRAS: Okay. Let's zoom back out.
3 BY MR. PARRAS:
4 Q.
11:34:09
And this one is harder to read, but let's try reading
5 the opinion again.

6
MR. PARRAS: That one -- yeah, we'll go to the
7 next year. Please pull up Government's Exhibit 113. Go to

8 the first page and show us what year this is in the bottom
9 left-hand section of the report.
11:34:25
10 BY MR. PARRAS:
11 Q.
You see that that's the 2000 annual report; right?
12 A.
Yes.
13 Q.
You were the executive director of the Antiguan
14 regulatory agency at that time; right?

11:34:38
15 A.
Yes.
16
MR. PARRAS: Let's go to PDF Page 37. And if
17 we could -- I'm going to read the whole thing this time.

18 If you could zoom in, please, on the first two paragraphs.
19 The whole thing, please, right above that.
11:35:01
20 BY MR. PARRAS:
21 Q.
Okay. The title says "Auditors' Report to the
22 Members," and then Mr. Hewlett's signature is under the

23 statement.
24
11:35:21
"We have audited the financial statements
25 on Pages 18 to 31."
2031
And then there's the heading, "Respective
2 Responsibilities of Directors and Auditors."

3
"As described on Page 34, the company's
4 management is responsible for the preparation of the

11:35:39
5 financial statements. It is our responsibility to form an

6 independent opinion based on our audit of those statements
7 and to report our opinion to you."
8
MR. PARRAS: Let's go to the next.
9 BY MR. PARRAS:
11:35:52
10 Q.
"Basis of opinion."
11
"We conducted our audit in accordance with
12 international auditing standards, which include

13 examination on a test basis of evidence relevant to the
14 amounts and disclosures in the financial statements. It
11:36:07
15 also includes an assessment of the significant estimates

16 and judgments made by the directors in the preparation of
17 the financial statements, and of whether the accounting
18 policies are appropriate to the bank's circumstances" -19
11:36:22
MR. PARRAS: Let's move that up, please.
20 BY MR. PARRAS:
21 Q.
-- "consistently applied and adequately disclosed.
22 We planned and performed our audit so as to obtain all the

23 information and explanations which we considered necessary
24 in order to provide us with sufficient evidence to give
11:36:38
25 reasonable assurance that the financial statements are

2032
1 free from material misstatement, whether caused by fraud

2 or other irregularity or error."
3
MR. PARRAS: If you can move that up, please.
4 BY MR. PARRAS:
11:36:51
5 Q.
"In forming our opinions, we also evaluated the
6 overall adequacy of the presentation of information in the

7 financial statements."
8
MR. PARRAS: Next paragraph please.
9 BY MR. PARRAS:
11:37:03
10 Q.
And before I go on, the auditor, Mr. Hewlett, his
11 signature, is telling people that he has reviewed

12 financial statements, that he has made an independent
13 judgment about the adequacy of the financial statements,
14 and is representing that they are free from material
11:37:25
15 misrepresentations, fraud or other irregularities;

16 correct?
17 A.
Uh-huh.
18 Q.
Okay. Let's go to his opinion.
19
11:37:37
"In our opinion, the financial statements
20 give a true and fair view of the state of the company's

21 affairs as at 31 December 2000, and of the results of its
22 operation for the year then ended. They have been
23 prepared to comply with international accounting and
24 financial reporting standards and the company's law of
11:37:54
25 Antigua and Barbuda."

2033
And then it's signed underneath by
2 Mr. Hewlett.
3
Have you had an occasion to go through all
4 of the annual reports available to you for the SIBL and

11:38:09
5 GIBL entities while they existed on Antigua?

6 A.
That would have been done, and I cannot recall if I'd
7 gone through all of the reports, which is your question.
11:38:35
8 Q.
Yes.
9 A.
But I know reviews were made of audited financial
10 statements prior to the examination which was first

11 conducted -- the first on-site examination which was
12 conducted in 2001, I think.
13 Q.
Okay. I think I'm going to break that down because I
14 think I know what you're saying and I want to be sure;

11:38:50
15 okay?
16 A.
Uh-huh.
17 Q.
That once your regulatory regime was set up, you
18 asked the -- whoever you asked, the SIBL or GIBL, whatever

19 it was at the time, you asked them to give you their
11:39:05
20 annual reports in preparation for your examination, for

21 your agency's examination?
22 A.
I think we would have been in possession of them. I
23 can't be sure. But I think we might have been in

24 possession. If not of all, of some of them.
11:39:18
25 Q.
Did you ask for other information as well?

2034
1 A.
There were other documents, pieces of information,
2 that we would have requested, yes.
11:39:35
3 Q.
And were you provided that information?
4 A.
I don't know. I can't be sure.
5 Q.
If you were not provided that information, would you
6 have correspondence about it?

7 A.
There ought to have been, yes.
8 Q.
Did you bring any correspondence with that regard
9 with you to the U.S. from Antigua?

11:39:49
10 A.
No.
11 Q.
Did you bring any records from the Island of Antigua
12 to the U.S. for your preparation and testimony here today?
11:40:05
13 A.
Any documents, no.
14 Q.
Did you bring any reports, notes, memos, exams,
15 anything in writing, that would help you to prepare for

16 your testimony here today?
11:40:19
17 A.
I do have a document that I made some notes on, yes.
18 Q.
Where is that document now?
19 A.
That's in my possession.
20
THE COURT: All right. Counsel, this may be a
21 time to take a break. We began about 10, 12 minutes,

22 15 minutes behind schedule, so some folks have been out
23 they're here for our hour and three-quarters.
24
11:40:36
MR. WARREN: Before we could take a break, I'm
25 not sure if counsel is coming back to those documents, but

2035
1 we would just ask for an instruction reminding the jury

2 that those annual reports have not been admitted for the
3 truth, but only as to what the investors were told.
4
11:40:52
THE COURT: That's so noted. That's so noted.
5 Let me get the screen up.

6
Okay. We'll see you back ready to resume
7 in 15 minutes. See you at that time.

8
9
12:00:05
(Recessed at 11:41 a.m.)
THE COURT: Tell the jury we'll be with them in
10 about a minute.
11
Have a seat. What have you got to bring
12 up?
13
MR. WARREN: Your Honor, Mr. Parras handed me
14 two documents, one he handed me at 10:00 o'clock this

12:00:16
15 morning, the other one he handed me after the court broke,

16 that he intends to use on cross-examination.
17
Just note for the Court these weren't
18 produced in a timely matter as with the Court's order from

19 last week. They've had more than a week's notice with
12:00:29
20 Ms. Crick. These are not surprise documents. This goes -21 one of them is part of her testimony. The other is
22 actually beyond the scope of direct in the first place.
23 But we would just note our objection to counsel using these
24 documents.
12:00:39
25
THE COURT: Wait a second. Not note your

2036
1 objection, do you object?

2
MR. WARREN: Yeah, we do object.
THE COURT: Okay. What's the first one, the
4 left hand, what's that?

12:00:47
MR. WARREN: This document is a letter from
6 November 29, 2000, regarding a certificate of good standing

7 that Ms. Crick issued regarding some of the directors of
8 the bank.
9
12:01:01
THE COURT: Okay. Have you ever seen those
10 before -- that before?

11
MR. WARREN: I've seen this document before,
12 Your Honor.
13
THE COURT: But you didn't know it was coming
14 here?
12:01:06
15
MR. WARREN: Did not.
16
THE COURT: What's the other one?
17
MR. WARREN: The other one I don't believe I've
18 ever seen before. It's from 1999. This was a document

19 just handed to me maybe ten minutes ago that has to do with
12:01:16
20 the growth of the international business corporations.

21 Mr. Parras went into that on cross-examination. It's
22 beyond the scope.
23
THE COURT: Aside from that, had you ever seen
24 it before?
12:01:30
25
MR. WARREN: No, Your Honor.

2037
THE COURT: What's your response?
MR. PARRAS: As to the first document, Judge,
3 it is a document that was produced to us by the government.

4 The reason that it is -12:01:36
THE COURT: First document objection is
6 overruled.
7
MR. PARRAS: The second one, Judge, we did talk
8 about it -9
12:01:43
THE COURT: Now, hold it. Let me make a note
10 on that.
11
And you've got a list, Ellen, and so do I.
12
That was -- that's defense document;
13 correct? Mr. Parras?
12:01:51
14
MR. PARRAS: Yes, Judge.
15
THE COURT: What number is it?
16
MR. PARRAS: I haven't given it a number. I
17 think we're on 10-1.

18
THE COURT: I don't know what you're on. You
19 got 17,000 documents. I don't know what number this is.

12:02:05
20
MR. PARRAS: Well, we're working to narrow it
21 down, so we've had to change our numbering system.
12:02:16
22
THE COURT: Well, you change it down to 100s?
23
MR. PARRAS: We started to do witnesses --
24
THE COURT: How many thousands do you have now?
25 Don't answer that question. I'm looking for hundreds, low

2038
1 hundreds. Hold it. Give it a number. Anybody.

2
MR. WARREN: 15,742, Your Honor.
THE COURT: That's a good number. Give me a
4 number eventually.
12:02:32
But, Ellen, I'm going to put a blank
6 there. That is admitted.

7
8
The other one?

MR. PARRAS: The second one, Judge, they're
9 correct, we have -- this is not from their production. It

12:02:43
10 is a letter that we talked about on cross-examination, and

11 it basically outlines the 30 points that the board,
12 regulatory board, was asking Ms. Crick to complete that she
13 talked as being lengthy and probably some of these not
14 being possible within the time given. I just want to get
12:03:04
15 it in to support the testimony.

16
THE COURT: Objection sustained as to that
17 second document.
18
All right. Are we ready to call the jury
19 in?
12:03:13
20
MR. WARREN: Nothing further from the
21 government, Your Honor.

22
23
24
12:04:06
THE COURT: All right. Let's go.

THE COURT: Before we get going, I've stopped
25 the clock. A 30-second story, a 30-second short note, the

2039
1 comment was about wearing wigs. There's a book that was

2 just recently published by former Supreme Court Justice
3 John Paul Stevens. He was on the court for 30 years. I
4 had met him on a number of occasions. Wonderful man.
12:04:25
It's entitled five chiefs, about the five
6 chief justices either he worked for or knew. And there was

7 a story that he told when Associate Justice William
8 Rehnquist became the chief justice. A couple of months
9 after he was chief, he showed up one time with a robe that
12:04:43
10 had four gold stripes sewn into the sleeves. And

11 apparently they were talking about it behind the scenes of
12 the Court. Of course, no one ever complained to the chief.
13 But it was a from a Gilbert -- the chief had seen it years
14 ago in a Gilbert & Sullivan production, and in that
12:05:01
15 production by that cast, there was a judge and he was

16 wearing a robe with four stripes. So for his tenure on the
17 Court, that's what he did.
18
And we've asked -- what is it -- Chief
19 Justice Roberts -- or at least Chief Justice Roberts does

12:05:19
20 not wear one. He became chief. He's now in plain black

21 robe.
22
So it's just a little story about what
23 goes on at the high 9. Fascinating book. It's a short

24 book, but it was most enjoyable.
12:05:33
25
With that, now that that is over and done

2040
1 with, defense time begins. Go on.

2
MR. PARRAS: Thank you, Judge.
3 BY MR. PARRAS:
4 Q.
12:05:46
Last year, Ms. Crick, okay? It's about your work as
5 a regulator on the island of Antigua, and I want to go a

6 little bit backwards to the spring of 1999.
7
If we remember correctly, in November you
8 wrote your first report, in February you wrote your second

9 report, and then sometime later, about April, there was a
12:06:08
10 response from the board with the 30 points, that you took
11 issue with some of them, but there's no doubt there were
12 approximately 30 points. And these were tasks that the
13 board felt you should complete so that the regulatory
14 agency could be set up and start working for the island;
12:06:26
15 correct?
16 A.
Basically, yes, uh-huh.
17 Q.
Each one of those tasks required money so that the
18 infrastructure and implementation could be put into place;

19 right.
12:06:44
20 A.
That's not true.
21 Q.
Well, let's talk about some of the tasks. You
22 certainly wanted to get an Internet system up for your

23 regulatory agency so that people could become licensed
24 over the Internet, that would be easier for people
12:07:02
25 offshore to become incorporated on the island; correct?

2041
1 A.
As a general requirement, yes, it's part of the task.
2 I don't recall that being in terms of a priority. Might

3 have been, but I don't recall it being a priority.
4 Q.
12:07:20
Would it help you or help you to remember if you were
5 to look at the memo itself?

6 A.
Yes, it would.
7 Q.
Okay. I'm going to hand you this, and I'm just going
8 to ask you to look at it, read it to yourself, and when

9 you're done, let me know, okay?
12:10:42
10 A.
(Reading document.)
11 Q.
Have you finished, ma'am?
12 A.
Yes, appears to.
13 Q.
Did it help you to remember some of the things that
14 the board -12:13:01
15 A.
Yes, it did. It did.
16 Q.
Go ahead and tell the jury the kinds of things that
17 the board wanted you to complete so that your agency could

18 start doing its work.
19 A.
12:13:28
Prepare, recruit staff, train staff, improve the --
20 as you mentioned before, the services that would be

21 provided by an Internet platform. Prepare budget to
22 support the overall development and, in fact, a budget for
23 each of the various items.
12:13:59
24 Q.
And --
25 A.
The other information on some various offshore

2042
1 sectors on the development of the sector, the industry in

2 the region. I did a quick read, so I'm really just trying
3 to -4 Q.
12:14:19
It's fair to say that there were a number of other
5 requests, but the bottom line was they wanted you to get a
6 regulatory agency in place and to hit the ground running;
7 correct?
12:14:35
8 A.
You could say that.
9 Q.
And you ended up doing that, didn't you?
10 A.
Putting -- to some extent, yes.
11 Q.
You hired staff?
12 A.
Yes, I did.
13 Q.
Staff that you felt were adequate to the task;
14 correct?
12:14:50
15 A.
Recommended, yes, uh-huh, but a staff -- interview
16 staff that I thought would have been -- had the skill

17 sets, yes.
18 Q.
And when do you think it was that you and your
19 regulatory agency started to examine the businesses under

12:15:07
20 your jurisdiction?
21 A.
It would have been sometime 2000, 2001.
22 Q.
Okay. I want to talk specifically now about SIBL.
23 You testified yesterday about the first examination, a

24 gentleman named Mr. Quelley and others were sent out
12:15:31
25 Mr. Quelley -- you got a call about Mr. Quelley, and the
2043
1 next thing you know -- the next thing you told us was that
2 you were on a tour of the Caribbean with Mr. Quelley,
3 yourself and a gentleman named Mr. Ferrance?
12:15:47
4 A.
Yes, uh-huh.
5 Q.
That was the first examination of Stanford
6 International Bank?
7 A.
That I can recall.
8 Q.
Do you remember approximately what time of the year
9 that was?
12:15:59
10 A.
It was sometime in August or September of 2001.
11 Q.
And did you do a subsequent examination -- August or
12 September, would that have been with Francis De Abreu?
12:16:22
13 A.
Yeah, De Abreu, yes.
14 Q.
And Peter Quelley was the junior examiner on that?
15 A.
Yes, uh-huh.
16 Q.
And Trevor Bailey was the senior examiner on that
17 team; correct?
12:16:36
18 A.
Not initially, no.
19 Q.
After Mr. Quelley taken off, then Mr. Trevor
20 Bailey became -21 A.
That's correct.
22 Q.
Before we get there, did you have occasion to examine
23 Stanford International Bank and its directors once you had

24 your regulatory agency up and running because they
12:16:52
25 requested a certificate of good standing?

2044
1 A.
To examine them, I don't recall that.
2 Q.
Do you think it would refresh your recollection to
3 see some correspondence?
12:17:04
4 A.
Sure.
5 Q.
Maybe we can do it this way. You can keep reading.
12:17:57
Do you recognize this document?
7 A.
Yes. I'm the author of the document.
8 Q.
It's something you -- it's your signature?
9 A.
Yes, uh-huh.
10 Q.
Do you remember writing it?
11 A.
Yes.
12
MR. PARRAS: Move to admit Defendant's
13 Exhibit -14
12:18:09
THE COURT: Is that the one we don't have a
15 number for yet?

16
MR. PARRAS: We're going to give this one -- it
17 is Judge. That's exactly the one. We're going to give it

18 10-1.
12:18:19
19
THE COURT: 10-1?
20
MR. PARRAS: Yes.
21
THE COURT: 10-1, we've already discussed it.
22 It's admitted.
23
MR. PARRAS: Let me put this on the board,
24 please, the ELMO.

12:18:26
25
MR. WARREN: Your Honor, we have an objection

2045
1 just to the copy we have as handwritten comments on it, I'm

2 not sure if those handwritten comments have been
3 authenticated. I don't know whose they are.
4
12:18:38
MR. PARRAS: I'll try to clear it up, Judge,
5 before I show it to the jury.

6
THE COURT: Okay.
7 BY MR. PARRAS:
8 Q.
Ms. Crick, do you recognize the handwriting there on
9 the left margin as yours?

12:18:46
10 A.
No.
11 Q.
Do you recognize it as someone in your agency?
12 A.
No, not that I can recall right off, no.
13
MR. PARRAS: Judge, I'll redact that portion
14 out.
12:18:54
15
THE COURT: Do you want to put a sticker over
16 it or something?
17
MR. PARRAS: I'm going to grab something from
18 my bag.
19
12:19:49
Okay. If I can have the ELMO, Judge.
20
21 BY MR. PARRAS:
22 Q.
Do you recognize that, Ms. Crick, as the letterhead
23 for the agency that you were the executive director of?
12:20:09
24 A.
Yes.
25 Q.
And I'm going to start reading -- this is addressed

2046
1 to Stanford International Bank; correct?

2 A.
Yes.
3 Q.
And I'm going to start reading there. "We knowledge
4 receipt of your request for a certificate of good standing

12:20:27
5 made on November 23, 2000. We wish to inform you,

6 however, that a letter requesting approval of Sir Courtney
7 Blackman and Mr. Robert Winter as directors should be
8 submitted to the authority. In accordance with Section 10
9 of the statutory instruments number 41 of 1998 of the
12:20:46
10 International Business Corporations Act Number 28 of" -11
THE COURT: Slow down a little bit.
12 BY MR. PARRAS:
13 Q.
-- "1982 as amended, which states: No licensed
14 institution shall make a change to its directors or the

12:21:00
15 director or indirect legal or beneficial owner of

16 5 percent or more of a class of shares in the institution
17 without the prior approval from the authority."
18
I'm going to stop right there, stop
19 reading.
12:21:15
20
What you were telling Stanford
21 International Bank is before you should issue a letter of

22 good standing, it had to comply with some statutory
23 requirements that you were now in charge of enforcing;
24 correct?
12:21:29
25 A.
That's correct, uh-huh.

2047
1 Q.
And specifically in this paragraph, they needed to
2 give you more information about Sir Courtney Blackman and

3 Mr. Robert Winter; correct?
4 A.
12:21:46
Not more information. They needed to obtain -- they
5 needed to request approval because they were coming on.

6 There was a change in directors, and they had not made
7 that request.
8 Q.
Okay. Next paragraph. "Additionally, the following
9 information is outstanding for Courtney Blackman: One

12:22:05
10 professional reference, and this is in addition to the one

11 on file, a statement whether Sir Blackman has ever been
12 formally charged or indicted with the commission of a
13 crime, criminal offense in any jurisdiction, and if so a
14 description of the offense charged and a statement of the
12:22:20
15 outcome of the charge. Three, a letter from Sir Blackman

16 accepting the position as the director of the bank."
17
These requirements -- I'm going to stop
18 there. Turn to Page 2 and ask you some questions.

19
12:22:41
These requirements were requests by you as
20 the regulator for more information; correct?

21 A.
Yes.
22 Q.
The application that a International Corporation has
23 to fill out only requires that you list the names and
24 addresses of the boards of directors; correct?
12:23:00
25 A.
The application for?

2048
1 Q.
Application for incorporation under the IBC Act. If
2 you know. If you don't know -3 A.
It only requires the name of the -- an address of the
4 directors.
12:23:12
5 Q.
Well, it actually has four or five statutory
6 requirements, but when it comes to the names of the

7 directors or the identity of the directors, the only thing
8 that's asked about the directors are their names and
9 addresses; correct?
12:23:28
10 A.
On the form itself, that's possible.
11 Q.
However --
12 A.
I can't recall the contents of the form immediately,
13 but --
12:23:34
14 Q.
Okay.
15 A.
-- that's possible.
16 Q.
Okay. If you wanted to ask for more information, you
17 have the power to do so; right?
12:23:46
18 A.
That is correct.
19 Q.
And what you're doing here in this letter is
20 exercising that power to a degree; correct?

21 A.
Yes.
22 Q.
It's not required anywhere on the application that
23 you say whether you've been in a discharged bankruptcy,

24 whether you have never been in bankruptcy, whether -12:24:03
25 that's something that's not asked on the form; correct?

2049
1 A.
It depends on which form you're referring to, because
2 there is the form you just described, but there is also,

3 if I remember correctly, a form that lists additional
4 details about the applicant.
12:24:27
5 Q.
Okay. What about the statute? The statute doesn't
6 require that you turn in that information when you file

7 your application; correct?
8 A.
It does not, but it does say that upon applying, the
9 supervisor can -- it makes provision, let me say, for the

12:24:50
10 supervisor to request any information.

11 Q.
And that's the point I'm trying to make. It makes
12 provision for the supervisor to request information. It

13 does not put the duty on the applicant to report the
14 information; correct?
12:25:05
12:25:19
15 A.
No, that's not correct.
16 Q.
Would it help you to look at the act itself?
17 A.
If I may be allowed to explain.
18 Q.
Would it help you to look at the act --
19 A.
I'm trying to assist you. If I could explain.
20
THE COURT: But that's up to the attorney.
21
Do you want to allow her to explain or are
22 you going to go on to the next question? Either way it's

23 okay. It's cross-examination. Go on.
24 BY MR. PARRAS:
12:25:28
25 Q.
If I could show you something, it may refresh your

2050
1 recollection, perhaps you could point me to what you're

2 talking about.
3 A.
Sure. Uh-huh.
4
12:26:43
5 Q.
Yes, I've read it.

Okay. It's true that within the application itself,
6 the statutory application, that information is not

7 required; correct?
12:27:10
8 A.
9 Q.
What subsection do you think applies --
10 A.
232.
11 Q.
And I'm getting there.
12
MR. PARRAS: Judge --
13 BY MR. PARRAS:
14 Q.
12:27:18
Do you recognize what's in front of you, ma'am, what
15 you're reading?
16 A.
It's a section from the International Business
17 Corporations Act.
18 Q.
Do you have any reason to believe that it's
19 inaccurate or not the actual language of the act itself?

12:27:32
20 A.
I'm not in a position to say that just looking at
21 this document, no.

22 Q.
Okay. What -- from your memory, okay, from your
23 memory, what is Section 231 titled?
12:27:57
24 A.
Section 231 is -- it's not even titled.
25 Q.
Is it titled Formalities?
2051
1 A.
I don't have this before me.
2 Q.
Let's go this way: Does Section 231 list five
3 requirements for the application?
12:28:17
4 A.
Along -- yes, along with Section 232.
5 Q.
And I'll get to 232. Let's just talk about 231.
6 A.
Okay. Fair enough. 231.
7 Q.
Among the five subsections, is there any requirement
8 that you indicate whether you've ever been in a

9 bankruptcy?
12:28:31
10 A.
No, it does not make an indication there.
11 Q.
And Section 232 is a section that applies to the
12 regulator on receipt of the application; correct?

13 A.
14
12:28:57
MR. PARRAS: Judge, I move to admit this as
15 Defendant's 10-2. I provided to the government early this

16 morning. It's something that I had not -17
THE COURT: Wait a second. Did I rule on that
18 already?
19
12:29:07
MR. WARREN: It's a different document, Your
20 Honor.
21
THE COURT: It's a different document. Okay.
22 Go on.
12:29:16
23
You move to admit 10-2. No.
24
What's the position of the government?
25
MR. WARREN: Objection, Your Honor.

2052
THE COURT: Why?
MR. WARREN: Well, for one, it was given to us
3 just earlier this morning in violation of the Court's prior

4 order.
12:29:25
Also, it hasn't been authenticated. It's
6 hearsay. The witness said she doesn't know whether it's

7 authentic.
8
THE COURT: Sustained.
9 BY MR. PARRAS:
12:29:33
10 Q.
Ma'am, you're the regulator for the Antiguan
11 government regarding the IBC Act; correct? As it applies

12 to international corporations?
12:29:47
13 A.
Yes.
14 Q.
Is it your testimony that Section 232 of the statutes
15 that you regulate does not apply upon receipt of an

16 application?
17 A.
Yes.
18 Q.
It's clear to you that, once an application is filed,
19 you have the power to ask for more information if you want
12:30:03
20 to; correct?
21 A.
That is correct.
22 Q.
Okay. Let's go back to this letter that is in
23 evidence.
24
12:30:17
Defendant's Exhibit 10-1, third paragraph,
25 second page.
2053
"The following information is needed for
2 Mr. Winter:
3
"A complete and up-to-date curriculum
4 vitae.
12:30:26
"Two references from well-established
6 banks stating the nature and extent of their knowledge of

7 and experience with him.
8
"A legible copy of Mr. Winter's passport
9 containing his photograph, as well as the passport numbers

12:30:40
10 and date and place of issue.

11
"One professional reference should be
12 submitted. Please note that this is in addition to the one

13 previously submitted.
14
12:30:52
"A letter from Mr. Winter accepting the
15 position as director of the bank.

16
"You are hereby requested to submit the
17 outstanding information as soon as possible so as to

18 complete the processing of the certificate of good
19 standing. Please be guided accordingly.
12:31:09
20
"Respectfully, M. Althea Crick, Executive
21 Director."
22
12:31:18
Did I read that correctly?
23 A.
That's correct.
24 Q.
You were asking for more information; correct?
25 A.
Yes.
2054
1 Q.
You didn't ask for information about Mr. Allen
2 Stanford, did you?
12:31:27
3 A.
No. This letter does not.
4 Q.
You could have asked for information about Mr. Allen
5 Stanford; right?
6 A.
I could have asked for information for him, yes, if
7 it was necessary.
8 Q.
If it was necessary.
9
12:31:37
So you didn't think it was necessary to
10 later on certify this -11
THE COURT: Look at the witness. Don't argue
12 it to the jury. They're listening.

13 BY MR. PARRAS:
14 Q.
12:31:47
You didn't think that it was necessary to ask for
15 more information beyond this letter so that you could

16 eventually issue a certificate of good standing; correct?
17 A.
Correct.
18 Q.
And eventually, you did issue a certificate of good
19 standing; correct?
12:32:02
20 A.
That is correct, in keeping with what it is that the
21 certificate of good standing actually states.

22 Q.
Okay. We talked about the first examination. And
23 it's true that, in addition to regulating the banks and

24 offshore companies on Antigua, you started to seek out
12:32:32
25 agreements with other jurisdictions on

2055
1 information-sharing; correct?
2 A.
That's one of the things we did, yes.
3 Q.
And what you did in July of 2001 is, you reached out
4 to the State of Texas and you entered into the first

12:32:46
5 agreement between Texas and a foreign entity to share

6 information; correct?
7 A.
That is correct.
8 Q.
You were proud of that? That was had a good thing,
9 wasn't it?
12:32:57
10 A.
Yes, it was a good thing.
11 Q.
I'm going to show you what's been marked as

13
And if you could look at it and let me
14 know if you recognize it, please.

12:33:37
15 A.
Yes, I'm familiar with the document.
16 Q.
Okay. While we're at it, let me show you what's been
17 marked as Government's Exhibit 615.

18
Also look through that and see if you
19 recognize it.
12:34:07
20 A.
Yes.
21 Q.
Speaking about Government's 666, is that something
22 that your agency produced?
12:34:16
23 A.
Yes.
24 Q.
Okay. And then and speaking about Government's
25 Exhibit 615, is that something that you received in your

2056
1 capacity as the executive director?

2 A.
Yes.
MR. PARRAS: Move to admit Government's
4 Exhibit -12:34:23
THE COURT: It's already in. All of the
6 Government's exhibits are in subject to the defense

7 specifically objecting to when it's referenced. So go
8 right ahead.
9
12:34:36
10 BY MR. PARRAS:
11 Q.
Let me show you the dates on both of these quickly so
12 that we could start with the first one.

13
Looking at Government's Exhibit 666. This
14 is -12:34:47
15
MR. PARRAS: Let's go to the top here.
16 BY MR. PARRAS:
17 Q.
-- a confidential report, violations and
18 recommendations for examination of Stanford International

19 Bank; correct?
12:34:57
20 A.
Yes.
21 Q.
And down here, it says "Examined by," and then it
22 lists the names and has dates; correct?
12:35:08
23 A.
That is correct.
24 Q.
And the dates are August through September 2001;
25 right?
2057
1 A.
Yes.
2 Q.
Do you recognize this as the first report of the
3 first exam of Stanford International Bank?
12:35:19
4 A.
I believe it is, yes.
5 Q.
Okay. And if we were to flip through Government's
6 Exhibit 666, what we would see -- let me back this up -7 is that you have, you and your agency have written a
8 number of points that you would like the bank, Stanford
9 International, to address; correct?
12:35:45
10 A.
That is correct.
11 Q.
Now, going to Government's Exhibit 615, dated
12 November 9, 2001, addressed to Ms. Althea Crick, and

13 signed by Frans Vingerhoedt.
14
12:36:05
Do you see that?
15 A.
Yes.
16 Q.
It's true that this letter is a response, a
17 point-by-point response, to your first exam inquiry;

18 correct?
19 A.
12:36:16
20
That is correct.
MR. PARRAS: And at this point, Judge, if I
21 could have the computer turned on back there. So I need

22 the help of the ladies. Thank you.
23 BY MR. PARRAS:
24 Q.
12:36:33
I want to go back through these two documents,
25 Government's Exhibit 666 on your left and Government's

2058
1 Exhibit 615 on your right. And I think that when they

2 come up, they're either going to be either side-by-side or
3 top and bottom, and we'll be able to -- I hope we'll be
4 able to tell which one is your report and which one is the
12:36:48
5 response.
6
MR. PARRAS: Next slide, please.
7 BY MR. PARRAS:
8 Q.
All right. Looking at Section 1.1. Do you recognize
9 the top portion as the -- coming from your report,

12:37:01
10 Government's Exhibit 666?

11
Do you recognize the top portion as coming
12 from your report, Ms. Crick?
12:37:38
13 A.
Yes.
14 Q.
And the bottom is coming from the response; correct?
15 A.
Yes.
16 Q.
And these are in evidence, so the jury will have them
17 to read.
18
But the complaint that you're telling SIB
19 about is that some of the loans did not have a purpose

12:37:53
20 identified on the paperwork; correct?

21 A.
It speaks to loan application forms having not been
22 seen in all the files examined.

23 Q.
And the second sentence says, "The examiners were
24 unable to establish the purpose of the loan in order to

12:38:22
25 verify compliance with the IBC Act; correct?

2059
1 A.
Yes.
2 Q.
And the response of the bank was -- is there at the
3 bottom, and I'll read it: "Loan portfolio

4 administration."
12:38:31
"Current loan request/application forms,
6 implemented in 1998 are mandatory for all new loans,

7 include a section for specification of the purpose of the
8 loan. Your recommendation is fully implemented."
9
12:38:47
Are they telling you that before 1998,
10 you're right, we have some problems and we're fixing them?

11 Is that basically what they're saying?
12 A.
It says that they have -- they have now complied with
13 our recommendation, yes.

14 Q.
12:39:31
And if we were to go through the letters together and
15 I'll just go through these slides -16
MR. PARRAS: Next slide, please. 2.1, 2.1,
17 next slide, please. 2.2, 2.2, next slide, please. And try
18 to line up the paragraphs here, same 2.2, next slide,
19 please, 2.3. Next slide. And if you could scroll through
12:39:51
20 the rest of the slide, please.

21
THE COURT: We don't have to. What's your
22 question? Let's assume she's scrolling through them. If

23 anybody wants to watch, you can scroll through them.
24
12:40:01
Just ask her the question.
25 BY MR. PARRAS:
2060
1 Q.
The process that you set up, everything that you were
2 trying to do, was finally working, wasn't it?
12:40:13
3 A.
I wouldn't say that.
4 Q.
Well, you were making queries of banks and they were
5 responding and you were going back and forth implementing

6 the regulations that finally came into existence; correct?
7 A.
We were conducting examinations, yes. We had started
8 the process.
9 Q.
12:40:29
Okay. And then you told this jury that, in 2002, you
10 left the -- you decided not to reapply under circumstances

11 that you've already described; correct?
12:40:40
12 A.
Not to apply, yes.
13 Q.
Your decision; right?
14 A.
That was my decision.
15 Q.
No one forced you to not apply; correct?
16 A.
No one forced me.
17 Q.
And you don't go back to the FSRC until April
18 of 2009; correct?
12:40:53
19 A.
That is correct.
20 Q.
And that's your current position: Executive director
21 of the FSRC; right?

22 A.
Current position is chairman of the board of
23 directors.
12:41:06
24 Q.
Do you have business outside of that position?
25 A.
Yes, I do.
2061
1 Q.
Do you have banks as clients?
2 A.
No, I don't, not currently. I have had banks as
3 clients, yes.
12:41:22
4 Q.
While you were the chairman of the board of the FSRC?
5 A.
No.
6 Q.
Okay. While you were chairman of the board of the
7 FSRC, do you do any work with people who are regulated by

8 your body?
9 A.
12:41:38
10 Q.
No.
If you could give me a minute, please, ma'am.
11
MR. PARRAS: Thank you, Ms. Crick.
12
I have no further questions.
13
THE COURT: Government is next, they keep going
14 back and forth until they have no more questions. You

12:42:15
15 can't get up and leave.

16
MR. PARRAS: He might ask you questions.
17
THE COURT: That's what I mean. The government
18 is next.
12:42:20
19
THE WITNESS: Oh, sorry.
20
THE COURT: We go back and forth or until they
21 have no more questions, or until I say that's all.

22
THE WITNESS: Okay.
23
THE COURT: Michelle can get it for you. Is it
24 the top button or the front button? Okay. Thank you.

12:42:57
25
All right, Counsel. Go on.

2062
Redirect-Crick/By Mr.Warren
REDIRECT EXAMINATION
3 BY MR. WARREN:
4 Q.
12:43:02
Ms. Crick, do you still have Government's Exhibit 615
5 in front of you?
6
MR. WARREN: If you would pull it up.
12:43:19
Your Honor, can you switch the --
THE COURT: Okay. To yours.
MR. WARREN: To the computer, please?
10
THE WITNESS: Yes, I do.
11 BY MR. WARREN:
12:43:31
12 Q.
Ms. Crick, what's the date of this letter?
13 A.
November 9, 2001.
14 Q.
And who sent it to you?
15 A.
Mr. Frans Fingervoedt.
16 Q.
And he was the president and CEO of the bank at the
17 time?
12:43:49
18 A.
Yes, he was.
19 Q.
And in Section 1, as Mr. Parras just asked you,
20 they're telling you that all the information about the

21 loans has been fully implemented, right, and now it's been
22 provided for the FSRC to roll up to speed about everything
23 on their loan portfolio?
24 A.
12:44:05
All they're saying is that we have now put this in
25 place. Thereby the applications are on file. That's the

2063
1 extent of what that is saying.

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

4
12:44:22
MR. WARREN: If there are no objections, Your
5 Honor, I'd ask that it be published.

6
THE COURT: Just keep going. On any of these,
7 just keep going unless we hear an objection.

8
9
12:44:35
That's 334; correct?

MR. WARREN: That top paragraph is fine. Thank
10 you.
11 BY MR. WARREN:
12:44:41
12 Q.
Ms. Crick, do you see the date of this document?
13 A.
Yes, I do.
14 Q.
What's the date of it?
15 A.
December 31, 2000.
16 Q.
And if you could please read that first paragraph
17 starting with the words "promissory note."

18 A.
"Promissory note. For value received, R. Allen
19 Stanford [hereinafter called 'Maker'] promises to pay to

12:45:04
20 the order of Stanford International Bank, Limited, at its

21 office located at 2000 Airport Boulevard, St. John's,
22 Antigua, West Indies [hereinafter called 'Payee'] the
23 principal sum of 59,500,000 no cents, U.S. dollars,"
24 59,500,000 in numbers, "[the 'Loan'] together with any
12:45:35
25 unpaid interest at the rate and on the terms set forth

2064
1 herein, as follows."
2 Q.
Ms. Crick, would you agree with me that this is a
3 promissory note from Mr. Stanford in the amount of

4 $59.5 million?
12:45:49
5 A.
It is.
6 Q.
Was this ever disclosed to the FSRC?
7 A.
Not to my knowledge.
8 Q.
Ms. Crick you were asked a series of questions about
9 the examination of the bank in 2001 and the report which

12:46:08
10 is Government's Exhibit 666 that resulted from that

11 examination.
12
12:46:17
Do you recall those questions?
13 A.
Yes.
14 Q.
Were you there throughout the end of the examination?
15 A.
No, I was not.
16 Q.
Can you remind the jury why you weren't there?
17 A.
Along with Mr. Queeley and Mr. Ferrance, I had been
18 asked to travel outside the island to visit several of the

19 islands in the region.
12:46:31
20 Q.
That was that hastily arranged trip?
21 A.
The hastily arranged trip. I was not present
22 throughout the course of that examination.

23 Q.
And you testified yesterday that Mr. Bailey replaced
24 you on the examination; correct?

12:46:42
25 A.
He replaced Mr. Queeley, yes.

2065
1 Q.
Do you know that Mr. Bailey went to work for
2 Mr. Stanford after he left the FSRC?
12:47:01
3 A.
I, in recent times, subsequently learned that, yes.
4 Q.
And he became the examiner after you and Mr. Queeley
5 were sent off island; correct?

6 A.
That is correct.
7 Q.
Do you recall Mr. Parras asking you about the IBC and
8 the statutes and what it requires the disclosure of?

9 A.
12:47:14
10 Q.
Yes.
Does the IBC -- is that the exhaustive statute
11 regulating the banking sector?

12 A.
The banking sector as a whole, no.
13 Q.
There are regulations that regulatory body can pass
14 in furtherance of its regulations, in furtherance of its

12:47:37
15 duties?
16 A.
There is.
17 Q.
And do you recall Section 231 that Mr. Parras showed
18 you?
12:47:44
19 A.
Yes.
20 Q.
Can you quote verbatim what Section 231 says? Off
21 your memory. I'm not asking you to read off the document.
22
MR. PARRAS: Judge, I have no objection to
23 admitting this into evidence.

24
12:48:02
MR. WARREN: I'm not offering it into evidence,
25 Your Honor.
2066
THE COURT: Okay.
2 BY MR. WARREN:
3 Q.
Ms. Crick, I'm handing you what you had seen before.
4 I direct your attention to Subparagraph (e) at

12:48:18
5 Section 231.
6 A.
Yes.
7 Q.
And look at that for a minute and I'll take it back
8 from you.
9 A.
12:48:30
10 Q.
Uh-huh.
Are you aware of any regulation that would require
11 the directors or owners of a bank to disclose other

12 relevant financial information for their application?
12:48:50
13 A.
Yes.
14 Q.
Would a prior bankruptcy be included in that
15 information that's required to be disclosed to the

16 regulatory body?
17 A.
If I recall correctly, yes.
18 Q.
Do you recall being asked some questions, a lot of
19 questions, about the judicial opinion from Montserrat?

12:49:14
20 A.
21
Yes.
MR. WARREN: If we could show Government's
22 Exhibit 511, please.

23 BY MR. WARREN:
24 Q.
12:49:37
Ms. Crick, what is the date of this document? This
25 is the one we looked at before about the notice of

2067
1 revocation.
2 A.
28 November 1990.
3 Q.
If we could please turn to Defense Exhibit -- and I
4 don't have the number offhand. It's the?

12:50:26
MR. COSTA: 2-14.
THE COURT: Thank you.
MR. WARREN: Could you use the overhead for
8 that, please.
9
12:50:38
Your Honor, if we could switch to the
10 easel -- I'm sorry. To the -- let's go to the last page.

11 BY MR. WARREN:
12 Q.
Ms. Crick, are you able to read -- this is the
13 government findings that Mr. Parras showed you.

14
12:51:02
Can you read that second paragraph to the
15 jury, please?
16 A.
That's Item 2?
17 Q.
Yes?
18 A.
"That the licenses granted to Guardian International
19 Bank Limited, on 9 January 1986, and the 14th day of

12:51:17
20 November 1988, could not be revoked by the government in

21 council since they did not exist."
22 Q.
And based on that document, on what date did Guardian
23 International Bank surrender its license, if you look at

24 the paragraph just above?
12:51:43
25 A.
It says it ceased to do business on the 19th of

2068
1 December 1990.
2 Q.
Ms. Crick, would you agree with me that they
3 surrendered their license after they had been notified of

4 the potential revocation?
12:52:04
5 A.
6 Q.
Have you ever heard the phrase, "You can't fire me, I
7 quit"?
12:52:35
8 A.
Yes. I'm familiar with the phrase.
9 Q.
There was some questioning on cross-examination about
10 the sector committee.

11
Do you recall that? That was the
12 nongovernment committee of people that -- private bankers,

13 et cetera?
12:52:49
14 A.
Yes.
15 Q.
And Mr. Parras asked you questions about you having a
16 problem with that committee or Mr. Stanford's involvement

17 in that committee.
18
That wasn't the committee you had a
19 problem with his involvement in; right?

12:53:00
20 A.
No, it was not.
21 Q.
You testified yesterday on direct that Mr. Stanford
22 was a part of what regulatory body when you joined in

23 1998?
24 A.
12:53:16
When I joined in '98, he was part of the -- the
25 Financial Services Sectoral Committee.

2069
1 Q.
And you had a problem with that; right?
2 A.
The sectoral committee?
3 Q.
No, not with the sectoral committee, with the -- I'm
4 sorry.
12:53:26
Was Mr. Stanford a part of the FSRC, a
6 member of the board of the FSRC when you joined?

7 A.
When I joined in '98, there was not yet a board.
8 Q.
And what was it that you had -- what position did
9 Mr. Stanford have that you testified about to yesterday

12:53:49
10 that you raised concerns about when you joined in 1998?

11 A.
There were -- there were two areas of concern. Prior
12 to 19 -- November 1998, my interaction was with the

13 sectoral committee.
12:54:13
14 Q.
Ms. Crick, I'm sorry. If I could just focus you.
15 A.
Okay.
16 Q.
What -- did Mr. Stanford have any position with any
17 government agency or regulatory body when you joined in

18 1998 that caused you concern?
12:54:31
19 A.
No.
20 Q.
We were discussing -- counsel asked you on
21 cross-examination about Operation Clean Slate.

22
12:54:52
Who bank-rolled Operation Clean Slate?
23 A.
Allen Stanford.
24 Q.
Did -- as part of Operation Clean Slate, was there
25 legislation passed regarding the banking sector and

2070
1 anti-money laundering in general in Antigua?

2 A.
As part of Operation Clean Slate, yes. There were
3 amendments to the --
12:55:06
THE COURT: Excuse me. Yes, sir.
MR. PARRAS: Judge, I object. Lack of personal
6 knowledge.
7
On my examination, she said she didn't
8 know what Operation Clean Slate meant.

9
12:55:17
10
THE COURT: Do you want to respond to that?

MR. WARREN: I'm sorry, Your Honor. What was
11 the basis for the objection?

12
THE COURT: He said that on his examination,
13 she said she didn't know about Clean Slate.
12:55:25
14
MR. PARRAS: About what it did.
15
THE COURT: What it did.
16 BY MR. WARREN:
17 Q.
I'm asking whether during that time period,
18 Ms. Crick, there was legislation passed regarding the

19 industry we've been discussing?
12:55:34
20 A.
21
That is correct.
MR. PARRAS: Object to the form of the
22 question. I believe he's tying Operation Clean Slate with

23 a -24
12:55:41
THE COURT: Again, I didn't hear an answer to
25 that question, but I'll sustain the objection as to the

2071
1 first question. He restated it. If you need to get back

2 into it, I'll consider it.
3 BY MR. WARREN:
12:55:54
4 Q.
Is that legislation still in effect?
5 A.
No, it's not.
6 Q.
What happened to it?
7 A.
It was repealed in its entirety.
8 Q.
Why?
9
12:56:18
THE COURT: The question is: Why was it
10 repealed; correct?
11
THE WITNESS: Yes. The legislation was
12 repealed for several reasons. Reason number one was

13 concerned about the author of the amendments.
12:56:37
14
THE COURT: Who was the author?
15
THE WITNESS: Mr. Patrick O'Brien.
16 BY MR. WARREN:
17 Q.
Who did Mr. O'Brien work for at the time, as you
18 understood?
12:56:44
19 A.
Allen Stanford.
20 Q.
What was reason number two?
21 A.
Reason number two was the thinking at the time that
22 the legislation might have in some respect weakened the

23 regulatory regime.
12:57:03
24 Q.
And what was reason number three?
25 A.
Reason number three was a general concern about the

2072
1 amendments that had been coming to the government from the

2 international community.
3 Q.
Ms. Crick, with regard to Operation Clean Slate, that
4 was when your files were taken from you; right?

12:57:25
5 A.
Yes.
6 Q.
Did it help or hinder your function as an Antiguan
7 regulator when Mr. Scardino took those files?
12:57:37
MR. PARRAS: Objection. Form of the question.
THE COURT: Sustained. Just rephrase it.
10 BY MR. WARREN:
11 Q.
Did it help or render your work whether those files
12 were taken?
12:57:46
13 A.
Hindered.
14 Q.
A moment ago we were talking about Mr. Stanford's
15 position when you came on to the commission, the

16 commission's predecessor in 1998, and I was asking you if
17 Mr. Stanford had any positions at that time.
18
Did Mr. Stanford have any positions with a
19 regulatory body on the board of a government department

12:58:03
20 before you came on?

21 A.
No.
22 Q.
You were asked questions about bank secrecy on
23 cross-examination. Do you recall that?
12:58:23
24 A.
Yes.
25 Q.
When Mr. Parras asked you whether it would be good or

2073
1 bad business, if you knew, to give the bank's competitors

2 information about where its assets were located, do you
3 recall that?
4 A.
12:58:35
Yes.
MR. WARREN: If we could look at Exhibit 218,
6 please.
7
Your Honor, if you could switch to the
8 computer, please.
9
12:58:59
10
THE COURT: Yes.

MR. WARREN: Page 21.
11
Can we focus again on the two paragraphs
12 we looked at before on the right-hand side of the page -13 I'm sorry -- the left-hand side of the page.
14
12:59:06
Thank you.
15 BY MR. WARREN:
16 Q.
Ms. Crick, I won't ask you to read these again out
17 loud, but do you see anything in there about the bank

18 saying it can't turn over its assets or its positions
19 because it would be bad to give that information to
12:59:22
20 competitors?
21 A.
No, I don't see that.
22 Q.
Instead, you see information that it says the bank
23 can't disclose that information because of Antiguan

24 regulations; isn't that correct?
12:59:33
25 A.
That is correct.
2074
1 Q.
And is that statement accurate?
2 A.
It is not.
3 Q.
Mr. Parras also suggested during cross-examination
4 that there were other jurisdictions that may have these

12:59:45
5 limitations. Where was the Stanford International Bank

6 located during this time?
7 A.
In Antigua.
8 Q.
Ms. Crick, you were asked some questions about
9 Mr. Hewlett on cross-examination. Do you recall that?

01:00:05
10 A.
Yes, I do.
11 Q.
And you were shown annual reports from the years
12 where you were at the commission where Mr. Hewlett had

13 certified to the statements. Do you recall that?
01:00:17
14 A.
Yes.
15 Q.
And Mr. Hewlett in his certification, as Mr. Parras
16 read, said that he formed an independent opinion as to the

17 accuracy of the financial statements?
01:00:32
18 A.
That is correct.
19 Q.
And Mr. Parras asked you about whether the FSRC could
20 have gone into the bank and asked for documents; right?
21 A.
Yes.
22 Q.
Did the FSRC have access to Mr. Hewlett's private
23 bank records?
01:00:42
24 A.
No.
25 Q.
To his personal bank account information?

2075
1 A.
No.
2 Q.
Did the FSRC have access to Mr. Stanford's Swiss bank
3 account?
4
01:00:52
MR. PARRAS: At this point object to
5 argumentative.
6
THE COURT: Overruled.
THE WITNESS: No, it did not.
8 BY MR. WARREN:
9 Q.
01:01:01
Did the commission know that Mr. Stanford had been
10 paying millions of dollars to Mr. Hewlett from its -- a

11 Swiss bank account to Mr. Hewlett's personal bank account?
01:01:16
12
MR. PARRAS: Objection, Judge --
13
THE WITNESS: No.
14
MR. PARRAS: -- argumentive and leading facts
15 that are not in evidence.

16
17 BY MR. WARREN:
18 Q.
Would information about payments from Mr. Stanford to
19 Mr. Hewlett have mattered to the commission?

01:01:28
20 A.
Certainly would have.
21 Q.
You were also asked a series of questions on
22 cross-examination about cricket. Do you remember that?
01:01:41
23 A.
Yes.
24 Q.
Most of which probably have nothing to do with what
25 we're here for, but -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2076
MR. PARRAS: Objection, Judge, to sidebar.
2 This jury is the one that's going to decide what it has to

3 do with why we're here.
4
01:01:48
THE COURT: Jury will decide.
5 BY MR. WARREN:
6 Q.
You were asked questions about Mr. Stanford trying to
7 revise the cricket industry. Do you recall that?

8 A.
Yes.
9
01:01:59
THE COURT: That it was the finest cricket
10 field in the world and you weren't sure; right? I

11 remember, too. Okay. Just like the jury does.
12 BY MR. WARREN:
13 Q.
Ms. Crick, was it ever disclosed to the FSRC or any
14 of its predecessors that Mr. Stanford was using investor

01:02:14
15 funds from the purchase of CDs to fund his promotion of

16 cricket?
17
MR. PARRAS: Objection, Judge, assumes facts
18 that are not in evidence and argumentative.

19
01:02:24
20
THE COURT: Hang on one second.

Let me hear the -- I listened, but I want
21 to hear it one more time.

22
Johnny, read that back, please.
23
(Requested portion was read.)
24
01:02:41
THE COURT: All right. For the purpose of this
25 witness, sustain the objection.

2077
1 BY MR. WARREN:
2 Q.
Were there any disclosure to the FSRC about how
3 Mr. Stanford was paying for his promotion of cricket?

4 A.
01:03:00
No, there was no disclosure.
MR. WARREN: If we turn to Government's

7
THE COURT: All right. After you get through
8 with this exhibit, we'll take a break.

9
01:03:06
10
THE COURT: Going up there. We'll talk about
11 this exhibit, if that's a good time.

12
MR. WARREN: That will be a good stopping
13 point, Your Honor.
01:03:15
14
THE COURT: Okay.
15
MR. WARREN: Turn to the next -- start with
16 that page.
17 BY MR. WARREN:
18 Q.
This is a picture of the Antigua Athletic Club;
19 right?
01:03:22
20 A.
Yes.
21 Q.
Was the FSRC ever told how this was paid for?
22 A.
No, it was not.
23 Q.
Was it ever told that -- I'm sorry.
24
01:03:31
Was the FSRC ever told that this building
25 was paid for through CD investor funds?

2078
1 A.
2
No, it was -MR. PARRAS: Objection, assumes facts not in
3 evidence, argumentative.
4
01:03:40
THE COURT: Counsel, how do you get around the
5 objection? You're making -- you're going into this area,

6 perhaps I'll allow it. You hear the objection, why don't
7 you tell me or you want to do it after lunch break?
01:03:50
MR. WARREN: No, Your Honor.
THE COURT: Why don't you do it right now.
10 Let's talk about it right now.

11
MR. WARREN: Of course. There's been testimony
12 about what the FSRC was told and wasn't told in regard to
13 its examination of the bank. I'm not assuming any facts.
14 I'm simply asking Ms. Crick if the FSRC was aware of this.
01:04:03
15 The requirement to ask that sort of a question is a good

16 faith basis.
17
Now, if Mr. Parras wants me to, I am happy
18 to put before the Court my good faith basis for asking

19 these questions.
01:04:13
20
21
THE COURT: Got it.

Your response? Isn't that basically the
22 rule?
23
MR. PARRAS: Judge, it is. My response is this
24 is purely argumentative. This witness is being used as a

01:04:24
25 ping-pong ball to make the arguments of prosecutors -- of

2079
1 the prosecution side.

2
THE COURT: All right. Let me ask you this:
3 Would this have been in this witness's ambit of

4 responsibility if that was known?
01:04:40
MR. WARREN: Yes. The answer is yes to that,
6 Your Honor.
7
And also in response to Mr. Parras's
8 point -9
01:04:47
MR. PARRAS: And I have not objected when the
10 question is asked in that manner.

11
THE COURT: All right. Let's see if you can
12 avoid objection. If you can't, then I'll rule, okay? I

13 may agree with you.
01:04:56
14
15
THE COURT: But, however, I agree on one thing
16 right now. It's almost five after 1:00, and that's our
17 outer limit. You remember there used to be a TV program,
18 The Outer Limits. So the first thing we do is raise the
19 screen, and the second thing we'll do is I'll see you back
01:05:11
20 at 2:15.
21
(Recessed at 1:05 p.m.)
22
23
THE COURT: All right, Counsel. Go right
24 ahead.
02:27:20
25

2080
1 BY MR. WARREN:
2 Q.
Ms. Crick, let's go back to Government's
3 Exhibit 1530, and we're looking at Page 11.

4
02:27:30
This was a photo that --
MR. WARREN: Your Honor, could you turn on the
6 overhead for the -7
THE COURT: Yes.
MR. WARREN: -- I'm sorry, the computer table.
9 Thank you.
02:27:34
10
THE COURT: Which one? The computer table?
11
MR. WARREN: Yes, sir.
12 BY MR. WARREN:
13 Q.
Ms. Crick, this was a photo that Mr. Parras showed
14 you on cross-examination.
02:27:44
15
Do you recall that?
16 A.
Yes.
17 Q.
Was it ever disclosed to the FSRC that this hangar
18 was paid for with CD money?

19
02:27:54
MR. PARRAS: Objection, Judge. Form of the
20 question. Assumes facts not in evidence. It's

21 argumentative.
22
THE COURT: I have concern it -- read it back
23 one time, Johnny.

24
02:28:13
25
(The requested portion was read.)
THE COURT: I'm going to take it question and

2081
1 answer. Sustained as to that question. I'm not saying you

2 can't go into this generally based upon what we talked
3 about after the jury left. I'll go question and answer on
4 it.
02:28:23
5 BY MR. WARREN:
6 Q.
Ms. Crick, was it ever disclosed to the FSRC how this
7 hangar was paid for?

8
MR. PARRAS: Judge, objection. If we could get
9 a timeframe, when she -- personal knowledge. And same

02:28:33
10 objections, also.
11
12
THE WITNESS: No, it was not.
13 BY MR. WARREN:
14 Q.
02:28:44
If we could turn to Page 9.
15
Do you recognize this?
16 A.
No, I do not.
17 Q.
Will you turn to Page 3.
18
02:28:56
Do you recognize the Sticky Wicket?
19 A.
Yes, I do.
20 Q.
What's the Sticky Wicket?
21 A.
The Sticky Wicket is a restaurant located at the
22 airport owned by Mr. Allen Stanford.

23
THE COURT: When they say "Sticky Wicket,"
24 that's kind of an idiomatic expression in the United

02:29:08
25 States. A wicket is those -- in effect, for want of a

2082
1 better, that sticks behind, what we call the catcher, isn't

2 it, or be in front of a catcher in a game of cricket;
3 right? Aren't the wickets the sticks in the ground?
02:29:26
THE WITNESS: A Sticky Wicket.
THE COURT: No. No. Not a stick wicket.
THE WITNESS: Uh-huh.
THE COURT: Okay. Now that's what a wicket is.
8
9
02:29:39
What is a sticky wicket.

THE WITNESS: Okay. The entire area between
10 the two sets of wickets is the area that's being referred

11 to, and if it is that area, the pitch as we speak, the
12 pitch between the two sets of three stumps that we call a
13 wicket, the two sets, the pitch between those two sets of
14 wickets --
02:29:58
15
THE COURT: You mean the dirt?
16
THE WITNESS: The dirt; right.
17
-- can prevent a problem if it is -- if
18 it's been raining, it's awkward to run on, and for the
19 bowlers to bowl. So if you're on a sticky wicket, you're
02:30:13
20 on a wicket -- in a situation that's very awkward, very -21
THE COURT: And a bowler is the pitcher; right?
22
THE WITNESS: The equivalent of, yes. Uh-huh.
23
THE COURT: All right. I never knew where it
24 came from. Thank you.

02:30:24
25
THE WITNESS: You're welcome.

2083
THE COURT: Go on. Stole a minute of the
2 government's time. It's a minute, but.

3
02:30:33
Thank you, Counsel.
MR. WARREN: Of course, Your Honor.
THE COURT: Go on.
6 BY MR. WARREN:
7 Q.
A sticky wicket refers to an awkward situation on the
8 pitch?
9 A.
02:30:39
10 Q.
Basically, yes.
How interesting.
11
Ms. Crick, was it ever disclosed to the
12 FSRC that the Sticky Wicket was paid for through CD

13 investor funds?
02:30:51
14
MR. PARRAS: Same objection, Judge.
15
THE WITNESS: No.
16
THE COURT: Hold it. I think the bottom
17 line -- I understand -- I think the jury will pick it up

18 either way. So I'm going to say overruled. The jury will
19 pick it up either way, even if you rephrase it.
02:31:03
20
But, Counsel, you're entitled to a ruling.
21 It's overruled.
22
MR. PARRAS: May I have a running objection to
23 that line of questioning?

24
02:31:12
THE COURT: No. By that, I mean a running
25 objection meaning every time the same subject came up, I

2084
Recross-Crick/By Mr. Parras
1 know he's got an objection. I'd rather do it question and

2 answer. Because if there's any slight deviation, I may
3 agree or disagree.
4
02:31:24
MR. WARREN: Can we have the question read back
5 from the record, please.

6
THE COURT: I think she answered it.
7
8
Go on, Johnny.
(The requested testimony was read)
9 BY MR. WARREN:
02:31:47
02:32:00
10 Q.
I'm sorry. That the Sticky Wicket --
11 A.
Sticky Wicket.
12 Q.
-- was paid for through CD investor funds?
13 A.
No, not to my knowledge, no.
14
15
MR. PARRAS: Hopefully briefly, Judge.
16
THE COURT: Sure.
17
RECROSS EXAMINATION
18 BY MR. PARRAS:
19 Q.
02:32:35
20
Let's start with that last few questions.

Between the years 2002, and the years
21 2009, you were not a part of the FSRC; correct?

22 A.
That is correct.
23 Q.
And as to those lines of questions about whether it
24 was ever disclosed, for that time period, if those

02:32:54
25 buildings, the hangar, the Sticky Wicket, if that was

2085
1 built after you left or towards the time -- beginning of

2 when you left, you wouldn't know whether or not it was
3 disclosed to the FSRC; correct?
4 A.
02:33:11
I would know, yes.
THE COURT: You would know?
THE WITNESS: I would know even though it's not
7 that time period.

8 BY MR. PARRAS:
9 Q.
02:33:19
Okay. And what you -- you would have to be the
10 accountant for SIBL to know how they disclosed their

11 investments, let's say, to the FSRC; for example, if they
12 were on this IB 5 to have put the Sticky Wicket or money
13 put into the Sticky Wicket into a broad category, you
14 wouldn't know that from the IB 5; correct?
02:33:41
15 A.
If it's part of an overall investment, I would not
16 know.
17 Q.
Okay. I want to go to the red head opinion, once
18 again. And again, this is in evidence so the jury will be

19 able to look at the entire thing if they'd like to.
02:33:58
20
21
I'd like to point out three places; okay?

MR. PARRAS: If I could have the overhead
22 projector, Judge.
23 BY MR. PARRAS:
24 Q.
02:34:12
First of all, the reason we're even talking about
25 this is because of Government's Exhibit 511.

2086
THE COURT: Just aim the mike at you. Just
2 turn it around. Okay. Thank you.

3
4 BY MR. PARRAS:
02:34:22
5 Q.
The reason we even discuss the Redhead opinion is
6 because of Government's Exhibit 511, the five reasons that

7 Montserrat at this time proposed to make an order under
8 the banking ordinance.
9
02:34:48
Now, going to Defendant's Exhibit 2-14,
10 the -- in the High Court of Justice, Colony of Montserrat,

11 if someone wanted to, they could go to A. Stanford,
12 0010774, and review the Judge's five grounds on which the
13 bank's license were purportedly revoked. Those would be
14 the Grounds 1 through 5, listed in Government's
02:35:15
15 Exhibit 511.
16
And I want to go to what the prosecutor
17 showed you. We are -- A. Stanford 001792.

18
Do you remember him asking you on redirect
19 to read this section ending in the fact that the licenses

02:35:46
20 granted to Guardian International Bank Limited on 9

21 January 1986, and the 14th day of November 1988, could not
22 be revoked by the government in council since they did not
23 exist.
24
02:36:02
25 A.
Do you remember that?

Yes, I do.
2087
1 Q.
They did not exist will at the time that the
2 government attempted to revoke them; correct?

3 A.
I need a refresh on the time the government intended
4 to revoke them.
02:36:15
5 Q.
Well, this isn't a statement that they never existed,
6 is it?
7 A.
That's what this statement indicates, yes.
8 Q.
Okay. Well, let's go to the Judge's opinion. This
9 is the last part. I told you I'd show you three places.
02:36:30
10
Judge's holding, A. Stanford 0010790.
11 Judge's holding, "I do hold, therefore, as from the 19th

12 of December 1990, when the bank surrendered its licenses
13 to the Ministry of Finance and accepted by the Minister of
14 Finance, the bank ceased to exist from that date."
02:36:56
15
You can't cease to exist without existing;
16 correct?
17 A.
I would think that, yes.
18 Q.
And then just -- I wasn't correct when I said three
19 places. One last page, front page, first sentence,

02:37:13
20 "Guardian International Bank Limited was granted a B

21 banking license on the 9th of January 1986, and an A
22 banking license on the 14th of November 1988, by the
23 government of Montserrat."
24
02:37:32
25 A.
That's a pretty clear sentence, isn't it?

Yes, it is.
2088
1 Q.
You weren't tempting to mislead this jury and making
2 them think that the licenses never exist, were you?

3 Existed, were you?
02:37:45
4 A.
Yes, the license existed.
5 Q.
Okay. As an accountant, do you know what tax
6 minimization is?
02:38:00
7 A.
Tax minimization?
8 Q.
Uh-huh.
9 A.
I'm familiar with the term, yes.
10 Q.
It's a concept, isn't it, by which companies or
11 people attempt to reduce their tax liability?

12
MR. WARREN: Your Honor, I'd object. It's
13 beyond the scope of the redirect.

14
02:38:12
15 BY MR. PARRAS:
16 Q.
Do you remember being shown Government's Exhibit 334
17 on redirect? This is the promissory note of December 31,

18 2000.
02:38:23
19 A.
Yes, I do.
20 Q.
Do you know whether this was an attempt by lawyers
21 and accountants for Mr. Stanford to set up a regulatory or

22 a reporting regime whereby tax minimization could take
23 place?
02:38:38
24 A.
I have no knowledge of that.
25 Q.
Okay. It's possible, isn't it?

2089
1 A.
I suppose anything is possible.
2 Q.
In response to the some of the question about the IBC
3 Act Section 231(e), your answer was, "If I recall

4 correctly"; right?
02:39:01
About subsection whether you could ask for
6 more information, you prefaced your answer with, "If I

7 could recall correctly."
8
9 A.
02:39:14

I might have, yes. I don't recall, but I might have,
10 yes.
11 Q.
The best thing to do would be to go to the act
12 itself, wouldn't it, to see what it says?

13 A.
Yes, uh-huh.
14
02:39:23
MR. PARRAS: Judge I move to introduce that
15 page -16
THE COURT: From what?
17
MR. PARRAS: -- of the exhibit.
18 BY MR. PARRAS:
19 Q.
02:40:15
02:40:26
That was Section 231; is that correct? And 232,
20 Ms. Crick?
21 A.
Yes, uh-huh.
22 Q.
Do you have that section up there with you?
23 A.
Yes, I do.
24 Q.
Does it look like a correct statement of the law?
25 A.
It appears to be.
2090
MR. PARRAS: Move to offer as Defendant's
2 Exhibit 10-2.
02:40:40
THE COURT: What?
MR. PARRAS: The Sections 231 and 232 of the
5 IBC Act.
6
THE COURT: Which act was it?
MR. PARRAS: International Business Act from
8 Antigua.
9
02:40:53
THE COURT: In other words, what year? Oh, is
10 it still in effect? Is that -- ma'am, is it still in

11 effect?
02:41:00
12
THE WITNESS: Yes, it's in effect.
13
THE COURT: Okay. Any objection?
14
MR. WARREN: We have no objection to those two
15 sections, Your Honor, if the witness can authenticate that

16 they're still in effect.
17
THE COURT: Okay. So it's -- again, that's
18 10-2; correct? And that's two sections of the law; is that

19 correct, Counsel?
02:41:13
20
MR. PARRAS: Yes, Judge.
21
MR. FAZEL: IBC Act.
22
THE COURT: Two sections. Okay. Got it.
23
MR. PARRAS: And Judge, I have a highlighted
24 copy. I'll mark one for the Court that's not highlighted
02:41:36
25 and use this one for now.

2091
THE COURT: Okay.
2 BY MR. PARRAS:
3 Q.
Let's look at Section 231, Ms. Crick. This is the
4 one you and I talked about.

02:41:43
And your answer under Subsection (e) is
6 that "Perhaps the issue of bankruptcy could be construed

7 to be called for by Subsection (e); "correct?
02:42:01
8 A.
That's not the statement I need made, no.
9 Q.
Tell me what you believe you were asked about
10 Subsection (e). What was the statement you made about

11 Subsection (e)?
12 A.
Subsection (e) clearly defines that any other
13 information can be requested.

14 Q.
02:42:15
And that's the part I want to focus on, the last part
15 of your sentence. "Can be requested"; correct?

16 A.
Yes.
17 Q.
If we go to subsections (a), (b), (c), (d),
18 there's -- those are things that the applicant must

19 provide; correct?
02:42:28
20 A.
Must provide once the request is made.
21 Q.
Okay. So the request has to be made before something
22 like some more information is required to be produced;

23 correct?
02:42:42
24 A.
That is correct.
25 Q.
And if we go to Subsection or Section 232, do you

2092
1 remember talking about on receipt of an application?

2 A.
Yes, uh-huh.
3 Q.
There is no -- you have the power to request more
4 information after you receive the initial application;

02:42:59
5 correct?
6 A.
7 Q.
Well, let's read 232.
"On receipt of an application for a
9 license under this part...."

02:43:19
10
What does that mean?
11
THE COURT: Okay, it's under that section. We
12 all understand. Keep going.

13 BY MR. PARRAS:
14 Q.
02:43:27
"...the appropriate official may cause such
15 investigations and inquiries to be made of the applicant

16 corporation, its directors and officers or proposed
17 directors and officers," et cetera, et cetera.
18
Maybe I'm wrong, tell me if I'm wrong,
19 that tells me that once an application is submitted, you

02:43:45
20 have the authority to then, if you want to, request more

21 information.
02:43:53
22 A.
That is not what that statement is indicating.
23 Q.
Okay.
24 A.
I disagree.
25 Q.
Okay. Do you remember talking to the -- talking

2093
1 about the files that were in your office, and you told
2 this jury that Mr. Stanford removed those files; correct?
02:44:17
3 A.
That is correct.
4 Q.
You also told this jury that you left work on Friday
5 and you returned Monday and they weren't there; correct?

6 A.
That is correct.
7 Q.
The reality, the truth, is you don't know who removed
8 your files; correct?

9 A.
02:44:28
10 Q.
Yes, I do.
Is it your belief that Mr. Stanford himself went to
11 your office and physically removed those files?

12 A.
That is my belief, yes.
13 Q.
That's not any personal knowledge that you have;
14 correct?
02:44:43
15 A.
It's -- well, I'm not sure how you define "personal
16 knowledge." I'm aware that that was what happened.

17 Q.
Well, did you see Mr. Stanford go into your office
18 and pull boxes of files out of your office?

19 A.
02:44:59
I did not see that. And it was not boxes of files.
20 The filing cabinets that were moved containing files.

21 Q.
Is there a video somewhere of Mr. Stanford removing
22 file cabinets of materials and files?
02:45:12
23 A.
No, there is not.
24 Q.
Are there pictures of Mr. Stanford going into your
25 office removing files and boxes of files?

2094
1 A.
No, there is not.
2 Q.
At that time, Lloyd Harold the former FBI agent, had
3 been made president, supervisor of banks; correct?
02:45:30
4 A.
Yes.
5 Q.
He was the person that took the files; correct?
6 A.
That is not correct. To my knowledge, that is not
7 correct.
8 Q.
Okay. Let's put aside -- what about Mr. Pat O'Brien
9 do you believe he took the files?

02:45:42
10 A.
I'm not sure if he was involved in the removement of
11 the files -- removal of the files.

12 Q.
Just to be clear, it's your belief that Mr. Stanford
13 himself physically picked up those files out of your

14 office?
02:45:58
15 A.
Mr. Stanford was present and conducted, or should I
16 say, supervised the removal of the filing cabinets from

17 the premises.
02:46:15
18 Q.
To your knowledge, who --
19 A.
To my knowledge.
20 Q.
To your knowledge, who did he supervise?
21 A.
A number of persons who were lifting and helping to
22 move the cabinets.
02:46:24
23 Q.
What are their names?
24 A.
I don't know their names.
25 Q.
Did you make a police report about that?

2095
1 A.
I believe I did, yes. I reported that the files are
2 missing.
3 Q.
What you did do was you asked for a legal opinion
4 from the solicitor general about whether it was

02:46:43
5 appropriate for the files to be removed, didn't you?

6 A.
That is incorrect.
7 Q.
You told this jury on direct examination that you
8 were being ordered to turn over the files and you sought a
9 legal opinion; correct?
02:46:53
10 A.
That was prior to the removal of the files.
11 Q.
Okay. And the result of that legal opinion was that
12 you should turn over the files; correct?

13 A.
That I should turn over the files to the supervisor
14 of international banks.
02:47:10
15 Q.
Okay. It was clear that they were going to leave
16 your office; correct?

17 A.
I don't understand the question.
18 Q.
I'll move on.
19
02:47:27
You told this jury that Pat O'Brien was an
20 employee of Mr. Stanford.

21
02:47:41
That's not true, is it?
22 A.
It is true.
23 Q.
Pat O'Brien was paid by the IFSA; correct?
24 A.
25 Q.
It would help, wouldn't it, for you to review

2096
1 correspondence regarding the payment of Pat O'Brien,

2 wouldn't it?
02:47:56
3 A.
Yes, it would.
4 Q.
Take your time to read this to yourself, and when
5 you're finished -6
THE COURT: How many pages?
7 BY MR. PARRAS:
8 Q.
9
02:48:02
-- let me know?
MR. PARRAS: Two pages and a paragraph on the
10 third, Judge. I apologize.

11
THE COURT: Counsel.
12
MR. PARRAS: It's on my time, Judge.
13
THE COURT: I know. I'm looking at the time.
14 It's clicking away.

02:48:33
15
While we're waiting, I will tell you what,
16 but we have a really nicer mindset like we did here. It's

17 not swearing in a new lawyer on -- what is it -- Friday?
18 It's one of the pleasures you get doing some things like
19 that. So I try to bring the jury into it. In fact, when I
02:52:07
20 have civil cases going on, like contract cases or civil

21 rights cases or whatever, I always bring those juries in to
22 see the criminal aspect of the case, of what we do here.
23 It's not just criminal work, all sorts of civil work. But
24 I may do the same thing. If I see I have a civil motion
02:52:25
25 some morning that may be of interest for you, we'll call

2097
1 you in to see what the civil aspects of this job is because

2 I've got civil cases stacked up both before and behind this
3 case. As soon as it's over, we'll be doing some one -- big
4 civil rights case, for instance, concerning matters that
02:52:42
5 allegedly occurred overseas that are suing a major U.S.

6 company about.
02:52:51
All right. Are we ready?
MR. PARRAS: I think so, Judge.
THE WITNESS: Yes, sir. Go right ahead,
10 Counsel.
11 BY MR. PARRAS:
12 Q.
Does that help to remind you that Mr. O'Brien was
13 being paid by the IFSA?
02:53:04
14 A.
It helps to confirm that that was not the case.
15 Q.
Is it because you believe that the Antiguan
16 government ended up meeting to get a loan from the Bank of

17 Antigua which is owned by Mr. Stanford? Is that why
18 you're saying --
02:53:19
19 A.
That is not why I am saying that.
20 Q.
Okay.
21
MR. PARRAS: No further questions.
22
THE COURT: Anything further?
23
MR. PARRAS: No, Judge. And I'll grab this
24 back.
02:53:25
25
THE COURT: Anything further, Counsel?

2098
MR. WARREN: Yes, Your Honor, very briefly.
3 BY MR. WARREN:
4 Q.
02:53:33
Ms. Crick, on the recross, Mr. Parras asked you again
5 about the Montserrat decision.

6
What was the date on which Guardian
7 International Bank surrendered its license?
02:53:47
8 A.
December 1999.
9 Q.
Is that before or after the notice of revocation came
10 in November of 1999?
11 A.
02:53:55
That is after the notice of revocation.
12
13
THE COURT: Anything further, Counsel.
14
MR. PARRAS: No, Judge.
15
THE COURT: All right. Thank you, ma'am.
16
Now you may step down. You're excused and
17 free to leave. I tell all witnesses this: If you'd like

18 to stick around and watch, you can. You're released from
19 that prior ruling as far as not being in the courtroom, but
02:54:09
02:54:18
20 you're certainly free to leave. Thank you.

21
THE WITNESS: Thank you, Your Honor.
22
THE COURT: Yes, ma'am.
23
All right. Call your next witness.
24
MR. COSTA: United States calls Arnold Knoche.
25
THE COURT: Sir, do you want to come around to

2099
Direct-Knoche/By Mr. Costa
1 your right.
2
Raise your right hand to be sworn.
Have a seat, please.
4
02:54:39
ARNOLD KNOCHE,
5 after having been first cautioned and duly sworn, testified

6 as follows:
7
DIRECT EXAMINATION
8 BY MR. COSTA:
02:54:44
9 Q.
Good afternoon.
10 A.
Good afternoon.
11 Q.
Would you please introduce yourself to the jury and
12 spell your last name for the court reporter?
02:54:58
02:55:07
13 A.
My name is Arnold Knoche, A-R-N-O-L-D, K-N-O-C-H-E.
14 Q.
And where do you live Mr. Knoche?
15 A.
I live in Ft. Bend County.
16 Q.
How long have you lived in the Houston area?
17 A.
Ever since I was six months old.
18 Q.
Got here as soon as you could?
19 A.
As soon as I could, yeah.
20 Q.
What do you do for a living these days?
21 A.
I'm semiretired. I'm still working a little bit,
22 just doing some bookkeeping work.
02:55:16
23 Q.
What is your profession?
24 A.
A CPA.
25 Q.
Tell the jury briefly about your educational

2100
1 background.
2 A.
Okay. I went to public schools in the Houston
3 Independent School District, and then to the University of

4 Houston. Got a bachelor's of administration with a major
02:55:27
5 in accounting.
6 Q.
And you said you're a CPA or a certified public
7 accountant?
02:55:34
8 A.
Yes.
9 Q.
How long have you held that title?
10 A.
For -- since I was 23 years old, so 45 years.
11 Q.
What's your current status as a CPA?
12 A.
In retired status for the last three years.
13 Q.
What did you do after graduating from the University
14 of Houston?
02:55:49
15 A.
I started out in public accounting, a national firm
16 called Peat, Marwick, Mitchell and then a local firm

17 called Milton & Milton.
18 Q.
Peat Marwick, was that one of the big international
19 accounting firms?
02:56:01
20 A.
Yes. It's called -- back then, it was called Big 8
21 accounting firms. They were the largest eight accounting

22 firms in the U.S.
23
THE COURT: What are they now down to? How
24 many big -02:56:10
25
THE WITNESS: I believe it's four now.

2101
1 BY MR. COSTA:
02:56:16
2 Q.
There have been some mergers?
3 A.
Yes, mergers.
4 Q.
Is Peat Marwick still around in any merged entity?
5 A.
Yes. I think its merged name is KPMG.
6 Q.
So you said you worked for Peat Marwick and then a
7 local accounting firm.

8
Did you at some point to into the real
9 estate industry?
02:56:27
10 A.
Well, I went first to the construction industry. I
11 worked for two subsidiaries of Austin Industries. They

12 were construction companies.
02:56:40
13 Q.
And then did you go to a homebuilder?
14 A.
Yes. A homebuilder named Monarch Homes. I was there
15 for 11 years, started as controller and then was executive

16 vice-president of finance.
17 Q.
What is a controller?
18 A.
That's responsible for the overall accounting
19 function and be sure the bills are paid, the payroll is

02:56:51
20 done, and then prepare the financial statements to be

21 presented to the president or the board of directors.
02:57:08
22 Q.
What year did you leave Monarch Homes?
23 A.
1987.
24 Q.
Why were you looking to leave Monarch Homes in 1987?
25 A.
The homebuilding business was very bad in Texas.

2102
1 That was back in the savings and loan crisis. And I was
2 going to have -- we were going to shut down in Texas, and
3 I was going to have to move to San Diego, California.
4 Q.
02:57:23
You didn't think the weather in San Diego would
5 measure up to Houston?
6 A.
No. It would have been beautiful, but our daughter
7 was in high school and we just didn't want to -- didn't

8 want to pull her out of high school if we could possibly
9 avoid it.
02:57:28
10 Q.
Did you start looking for jobs that would allow you
11 to stay here in the Houston area?
02:57:37
12 A.
That's correct.
13 Q.
And where did you end up going to work?
14 A.
A company -- it was Guardian International Investment
15 Services at that time.

16
THE COURT: What year was that? 1980 --
17
THE WITNESS: 1987.
18 BY MR. COSTA:
02:57:43
19 Q.
And who owned that company?
20 A.
Allen Stanford.
21 Q.
How did you first find out about that position with
22 Guardian International?
02:57:52
23 A.
I answered a newspaper ad.
24 Q.
Do you remember where the ad was placed?
25 A.
Probably The Houston Chronicle. It could have been

2103
1 the Wall Street Journal, but I believe it was The Houston

2 Chronicle.
3 Q.
And what do you recall the want ad requesting in
4 terms of background for the position?

02:58:04
5 A.
It advertised for a certified public accounting with
6 real estate experience.
02:58:15
02:58:24
7 Q.
Did you submit a resum?
8 A.
Yes. I sent a cover letter and a resum.
9 Q.
Were you invited for an interview?
10 A.
Yes.
11 Q.
With whom did you interview?
12 A.
I met with Allen Stanford.
13 Q.
Where was that meeting?
14 A.
It was on a Saturday morning at the 1100 Milam
15 Building. It's just a few blocks from here.

16 Q.
What did Mr. Stanford tell you about this position he
17 was interviewing for?

18 A.
Well, it was going to be a newly created part of the
19 organization that was going to seek out distressed real

02:58:36
02:58:46
20 estate and purchase it, operate it and sell it.

21 Q.
Do you see Mr. Stanford in the courtroom today?
22 A.
Yes. He's right there.
23 Q.
Can you point out what he's wearing?
24 A.
That's him.
25
THE COURT: He's standing up; correct?

2104
THE WITNESS: Correct. That's correct.
MR. COSTA: Ask that the record --
THE COURT: The record will reflect that he
4 identified Mr. Stanford.

02:58:53
5 BY MR. COSTA:
6 Q.
So Mr. Stanford told you this was a new entity he was
7 looking to hire someone for?
02:59:02
8 A.
That's correct.
9 Q.
Focused on distressed real estate?
10 A.
Yes.
11 Q.
Did he tell you at that initial interview about any
12 other businesses he had?
02:59:12
13 A.
Yes. He said he had a bank in Montserrat.
14 Q.
And what was the name of that bank?
15 A.
It was Guardian International Bank.
16 Q.
And this position you were interviewing for, was that
17 going to be with the bank?
02:59:22
18 A.
No, no.
19 Q.
It was going to be separate?
20 A.
Separate.
21 Q.
And focused on --
22 A.
Focused on real estate.
23 Q.
After that first interview with Mr. Stanford, what
24 happened?
02:59:29
25 A.
He called me back in a couple of days or somebody

2105
1 called me back and said they'd like me to go to Mexia,

2 Texas, to meet with the board of directors.
02:59:40
3 Q.
And did you go up to Mexia?
4 A.
Yes, I did.
5 Q.
Where is Mexia from Houston?
6 A.
It's up towards Dallas. Not quite all the way to
7 Dallas.
02:59:51
8 Q.
With whom did you meet in Mexia?
9 A.
That would have been James Stanford and Bill Goswick
10 and Don Caldwell.

11 Q.
Did you learn anything about Mr. Stanford's history
12 from that interview with those board members in Mexia?
03:00:06
13 A.
About his history?
14 Q.
Did anyone make a comment about what Mr. Allen
15 Stanford had done in the past?

16 A.
17
Oh, Bill Goswick, I think -MR. SCARDINO: We object to clarify who he's
18 referring to, who made the statement.

19
03:00:13
THE COURT: Okay.
20 BY MR. COSTA:
21 Q.
Who made a statement about what Mr. Allen Stanford
22 had done in the past?

23 A.
Oh, Bill Goswick made a comment about that Allen had
24 been in the -03:00:22
25
MR. SCARDINO: Object to the hearsay.

2106
THE COURT: How do you get around hearsay?
MR. COSTA: It's for the truth, it's just to
3 show what he understood about Mr. Stanford's business, but

4 I can move on. It's not -03:00:32
THE COURT: Sustain the objection.
6 BY MR. COSTA:
7 Q.
What did you learn from the board about this real
8 estate, distressed real estate project Mr. Stanford wanted

9 to hire you for?
03:00:40
10 A.
They basically said the same thing Mr. Stanford did;
11 that they thought this was a good opportunity to have

12 purchase of distressed real estate. There was a lot of it
13 around, and they thought we could do well.
03:00:53
14 Q.
Did you eventually get hired for the position?
15 A.
Yes.
16 Q.
And the entity that hired you was this Guardian
17 International Investment Services?
03:01:04
18 A.
That's correct.
19 Q.
Did anyone else work with you initially on the real
20 estate investments?
21 A.
Yes. When Mr. Stanford made me the offer, he said
22 that they had decided to hire two people, or they were

23 just going to hire one, but there was another applicant
24 that he hired at the same time. We were both -- both
03:01:15
25 executive vice-presidents reporting to him.

2107
03:01:25
1 Q.
Who was the other individual?
2 A.
Larry Slater.
3 Q.
And you both reported to Mr. Allen Stanford?
4 A.
That's correct.
5 Q.
We mentioned Mr. Stanford's father, but from now on
6 when I say "Mr. Stanford," do you understand I'm talking

7 about Mr. Allen Stanford?
03:01:33
8 A.
Yes.
9 Q.
Unless I specify?
10 A.
Yes.
11 Q.
You said Mr. Stanford already had a bank at this
12 time?
03:01:43
13 A.
That's correct.
14 Q.
So when was it that you started working at Guardian
15 International Investment Services?

16 A.
That would have been in the early part of 1987.
17 Q.
And did you learn about the bank after you went to
18 work even though you were working for this separate real
19 estate investment?
03:01:59
20 A.
Yes. It was a very small office in Houston, so that
21 I think there were three bank officers -- or they

22 weren't -- they weren't employees of the bank. They were
23 employees of Guardian International Investment Services,
24 another part of it. So it was a small office, and we had
03:02:13
25 meetings that would discuss some part -- early on, some

2108
1 parts about the bank.
03:02:23
2 Q.
And these were salespeople for the bank?
3 A.
These were salespeople for the bank.
4 Q.
What product were they selling for the bank
5 primarily?
6 A.
Primarily certificates of deposit.
7 Q.
Do you remember the names of some of those folks?
8 A.
I recall three of them. Sydney Adler. Michelle
9 Chambliess and Maria -- no. There's four. Maria

03:02:38
10 Promindon and Elsie Ethridge. And, actually, Michelle

11 came a little bit later, it was Sydney, Maria, and Elsie
12 first, and then Michelle came shortly thereafter.
03:02:51
13 Q.
You were there before Michelle?
14 A.
Yes.
15 Q.
In terms of Mr. Stanford's attention, from what you
16 saw, which part of his businesses did he devote most of

17 his time to in those first few years?
03:03:06
18 A.
The bank.
19 Q.
If you could put a percentage of his time that he was
20 focused on the bank, from what you saw, what would you
21 estimate?
22 A.
Oh, probably 90 percent.
23 Q.
And you said partly you learned about the bank just
24 because you were in the office with these other bankers,

03:03:21
25 the bankers who were actually selling the CD product?

2109
1 A.
That's correct.
2 Q.
Did you ever read promotional materials put out by
3 Guardian Bank?
03:03:28
4 A.
Yes.
5 Q.
Why?
6 A.
Oh, we were so small we were asked to. We would have
7 meetings to review the promotional material, in the early

8 days.
9 Q.
03:03:36
Who asked you to read the promotional materials?
10 A.
Mr. Stanford.
11 Q.
Who would be at these meetings where the promotional
12 materials were reviewed?

13 A.
That was the same people that I mentioned. And Larry
14 Slater and myself.

03:03:45
03:04:02
15 Q.
Would Mr. Stanford attend those meetings?
16 A.
Yes.
17 Q.
Did you also read the bank's annual reports?
18 A.
In the early years, yes.
19 Q.
Was that something Mr. Stanford required that you
20 read?
21 A.
Yes. He asked each of us to be totally familiar with
22 the bank's annual report.

23 Q.
And from the materials you read and from these
24 meetings you attended with Mr. Stanford, what did you

03:04:15
25 understand that the bank told the depositors it was doing

2110
1 with the CD money?

2
MR. SCARDINO: Objection to foundation and
3 hearsay.
03:04:25
THE COURT: Okay. Your response?
MR. COSTA: The foundation has been laid. He
6 said he read all the promotional materials. He was at

7 meetings with Mr. Stanford.
8
And for hearsay, it's not offered for the
9 truth. It's for what he understood what Mr. Stanford and

03:04:34
10 the materials told him the bank did with their money.
11
MR. SCARDINO: That's a different question than
12 asking him what materials they were asked to read.

13
THE COURT: Right. Okay. Ask the question.
14
03:04:46
Sir, don't answer it. See if there's an
15 objection, if we can around the objection; okay?

16 BY MR. COSTA:
17 Q.
Based on the materials you read, based on what
18 Mr. Stanford told you and others discussed in these

19 meetings, what did you understand that the bank was
03:04:56
20 telling its depositors it did with the money that was

21 deposited?
22
MR. SCARDINO: Again, I object to foundation,
23 the materials that he said he reviewed.
03:05:07
24
25
THE WITNESS: Would you repeat it then, please.

2111
1 BY MR. COSTA:
2 Q.
Sure. What did you understand, from what you read
3 and what you were told by Mr. Stanford, about what

4 Guardian Bank did with the money once it was deposited in
03:05:16
5 the bank?
6 A.
It was invested in conservative equities and bonds,
7 stocks and bonds.

8
MR. COSTA: And given Mr. Scardino's objection,
9 we'll show one of those. 103, please, which has already

03:05:29
10 been offered.
11
MR. SCARDINO: 103?
12
MR. COSTA: Yes.
13 BY MR. COSTA:
14 Q.
03:05:38
Do you recognize this as a Guardian Bank annual
15 report from 1990, Mr. Knoche?

16 A.
Yes.
17
MR. COSTA: If we could turn to Page 13,
18 please.
03:05:48
19
Thank you, Judge.
20
And there is a paragraph there, investment
21 portfolio, towards the beginning of the bottom half, if you

22 could highlight that.
23 BY MR. COSTA:
24 Q.
03:06:00
It says, "The investment portfolio is made up of
25 86.9 percent bonds, 9.4 percent equities, 2.6 percent

2112
1 commercial paper and 1.1 percent notes."

2
Is that consistent with what your memory
3 is of the type of investments the bank was saying it made?

4 A.
03:06:17
Yes.
MR. SCARDINO: Excuse me. I'll object. This
6 witness is not -- there's no foundation to establish this

7 witness had this knowledge personally. He's not being
8 asked to form an opinion as an expert, so I would object to
9 this line of questioning unless he plans to prove him up as
03:06:31
10 an expert.
11
THE COURT: Go on.
12
MR. COSTA: I asked him what he understood.
13 He's already said if there's no foundation, I -- he's been

14 at numerous meetings. He was required by Mr. Stanford to
03:06:39
15 read the bank's promotional materials. I'm happy to lay

16 more foundation, but I think it was -- it's clear he read
17 all the materials at the time he was required to, and
18 Mr. Stanford was in meetings telling him all that.
19
03:06:51
THE COURT: Now you're reading from something
20 already in evidence; correct?

21
MR. COSTA: Right.
22
MR. SCARDINO: Your Honor, I would respectfully
23 object, because the prosecutor -- Mr. Costa is actually

24 trying to have it both ways. He's trying to not make the
03:06:58
25 man an expert witness but still elicit an opinion from hi,

2113
1 and I would object.
03:07:05
MR. SCARDINO: I --
MR. COSTA: No, no, overruled. I'll keep an
5 eye out, though, Mr. Scardino. If you think you're getting

6 into pure expert witness testimony as a CPA, I'll jump in
7 or you jump in.
8 BY MR. COSTA:
9 Q.
03:07:19
Is that highlighted portion, Mr. Knoche, consistent
10 with what you heard from Mr. Stanford and from reading
11 materials that that's the nature of the bank's investment
12 portfolio?
03:07:34
13 A.
Yes, I agree.
14 Q.
You said you were told it was conservative, low-risk
15 investments. Do you think if it was in bonds and

16 9 percent equities, would that be conservative, in your
17 view?
18
MR. SCARDINO: Again, he's asking for an
19 opinion.
03:07:41
20
THE COURT: Overruled. Overruled.
21
THE WITNESS: Yes, certainly there is some
22 equities that are more risk than others, but basically

23 bonds, especially, that's conservative investment, yes.
24 BY MR. COSTA:
03:07:55
25 Q.
What did the bank say about whether it made loans

2114
1 like a commercial bank?

2 A.
It was my understanding there was no loans.
MR. COSTA: If we can go to 519, which has also
4 already been offered. If we can go to Page 5. On the

03:08:16
5 left-hand side, the second question and answer.

6 BY MR. COSTA:
7 Q.
It says, "Does the bank make loans?"
"Guardian International Bank limited has
9 never made and will never make loans or offer credit

03:08:28
10 instruments."
11
Is that consistent with the understanding
12 you had from working at Guardian Investment Services?

13
MR. SCARDINO: Again, object to foundation.
14 There's no basis to show that this man had knowledge of

03:08:41
15 loans or not.
16
17
MR. COSTA: I'm not asking whether he knew the
18 bank -19
03:08:44
THE COURT: I understand. I've overruled it.
20 Go on.
21 BY MR. COSTA:
22 Q.
Is that consistent with what you were told about the
23 bank?
03:08:48
24 A.
Yes.
25 Q.
Where did Mr. Stanford -- or did Mr. Stanford tell

2115
1 you who was making the investment decisions for the bank's
2 portfolio?
3 A.
Well, in the very early years, it would be himself,
4 and he -03:09:03
THE COURT: Hold it. The question is: Did he
6 tell you. Right? That was the question.

7 BY MR. COSTA:
8 Q.
Did Mr. Stanford tell you which individuals were
9 overseeing the bank's investment portfolio?

03:09:16
10 A.
I don't recall that he was -- specifically had
11 said that he would have answered that question. No, I

12 don't specifically remember that, but...
13 Q.
Did Mr. Stanford ever discuss money managers with
14 you?
03:09:26
15 A.
Yes, he said there were some money managers in
16 Switzerland.
17 Q.
And what were those Swiss money managers doing
18 according to Mr. Stanford?

19 A.
03:09:33
It would have been my understanding managing the
20 funds of the bank.

21 Q.
In these meetings you had with the bankers who were
22 selling the CDs that Mr. Stanford attended, did the topic
23 of insurance ever come up?
24 A.
03:09:49
Yes. They said that some of their clients had asked
25 if he had -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2116
MR. SCARDINO: Object to nonresponsive.
THE COURT: Sustained. The answer is -- it
3 will go a lot quicker if he asks for a narrative, then

4 visit with him. Otherwise, yes or no. If you can't answer
03:09:57
5 a question yes or no, let me know and I'll have him

6 rephrase it.
7
THE WITNESS: Yes, Your Honor.
8 BY MR. COSTA:
9 Q.
03:10:03
Did the topic of insurance come up?
10 A.
Yes.
11 Q.
Did the bankers, the people selling the CDs, ask
12 Mr. Stanford about the insurance issue?

13 A.
03:10:13
Yes.
14
MR. SCARDINO: Object to foundation.
15
16 BY MR. COSTA:
17 Q.
Were you in these meetings where the insurance issue
18 came up?
03:10:17
19 A.
Yes.
20 Q.
What did the banker say to Mr. Stanford about
21 insurance?
22 A.
That some of the clients had asked if there was -- if
23 their deposits were covered by FDIC insurance.
03:10:33
24 Q.
And what was the response?
25 A.
Response was no.

2117
1 Q.
So was there another insurance that Mr. Stanford said
2 applied to his bank?
03:10:47
3 A.
I think initially no, but then later yes.
4 Q.
Do you recall the name of that insurance that he said
5 applied to his bank?

6 A.
I remember two companies were mentioned. I don't
7 know what order. Lloyd's of London was mentioned, and a

8 British Insurance Fund was mentioned.
9
03:11:00
MR. COSTA: If we can go to 502, which has
10 already been offered and referenced, Your Honor.

11 BY MR. COSTA:
12 Q.
Do you see the name at the top there, Mr. Knoche,
13 British Insurance Fund, Limited?
03:11:18
14 A.
Yes.
15 Q.
Is that the insurance company you were just
16 referencing that Mr. Stanford talked about in these

17 meetings with the bankers?
03:11:27
18 A.
Yes.
19 Q.
In any of those meetings you attended where this
20 company was discussed, did Mr. Stanford ever say that it

21 was a captive insurance company that he owned?
22
MR. SCARDINO: Object to the form of the
23 question what did he ever say.

24
03:11:37
25 BY MR. COSTA:
2118
1 Q.
Did Mr. Stanford ever say that the British Insurance
2 Fund, Limited, was a captive insurance company that he

3 owned?
03:11:57
4 A.
No.
5 Q.
Was there ever in any of these brochures you were
6 required to review for the bank mentioned of an office in

7 Switzerland?
8 A.
Yes.
9
03:12:14
MR. COSTA: If we can go to 522, please. This
10 has already been offered and admitted. Page 19, please.

11 If you can highlight the bottom list of cities.
12 BY MR. COSTA:
13 Q.
List the number of offices and then it says,
14 "Affiliate offices."
03:12:30
15
16 A.
What's listed there?

It says Geneva, Switzerland.
17
MR. COSTA: If we can go to Page 3 of the same
18 Guardian brochure.
19 BY MR. COSTA:
03:12:39
20 Q.
If we go to the bottom, is that a list of offices as
21 well, Mr. Knoche?

22 A.
Yes.
23 Q.
And at the bottom, it says, "Affiliate office
24 Geneva"?
03:12:49
25 A.
Yes.
2119
1 Q.
Did you ever ask Mr. Stanford about whether there
2 was, in fact, an office of the bank in Geneva?

3 A.
In conjunction with reviewing one of the promotional
4 things, it had pictures of the other offices, Miami and

03:13:04
5 Aruba, but in Geneva, it just had a picture of a river.

6 And I said, "Wouldn't it be better if we had a picture of
7 the office?"
03:13:15
8 Q.
And what did Mr. Stanford say?
9 A.
He said, "Well, it's more like this, the
10 representative -- representation. There's not a formal

11 office as such."
12 Q.
I want to go on and talk about the real estate
13 investment group that you worked for.

14
03:13:32
Was -- were you told that that was the
15 bank -- the CD depositors' money that was going into those

16 real estate investments?
03:13:42
17 A.
No.
18 Q.
What did Mr. Stanford say about that?
19 A.
Well, the first ones we did were limited
20 partnerships. We raised money by -- can I elaborate?

21 Q.
22
I'll ask -THE COURT: Okay. Go on.
23 BY MR. COSTA:
24 Q.
03:13:54
Did you understand that the bank was separate from
25 these real estate partnerships?

2120
1 A.
Yes.
2 Q.
Now, was Mr. Stanford at first trying to target bank
3 customers to see if they would also be willing to invest

4 in the real estate partnerships?
03:14:05
5 A.
Yes.
6 Q.
And these real estate partnerships were focused on
7 what type of investments?
03:14:17
8 A.
Residential rental property.
9 Q.
In what area?
10 A.
In primarily Houston, Texas.
11 Q.
And what was going on in the economy here in Houston
12 when you were hired in 1987?

13 A.
It was -- in home building business and the real
14 estate business, it was very bad.

03:14:27
15 Q.
So what was the idea -- I think you used the term
16 "distressed real estate." What was the idea with

17 targeting distressed real estate?
18 A.
To purchase these properties that the current owners
19 were not able to spend money to keep them up on and

03:14:40
20 rehabilitate them and run them properly and then sell

21 them.
22 Q.
And was each project set up as a separate
23 partnership?
03:14:52
24 A.
Yes.
25 Q.
Where was the first partnership? What did that

2121
1 involve?
2 A.
It was a small apartment project in southwest Houston
3 called Takara So Apartments.
03:15:03
MR. SCARDINO: Spell that.
THE WITNESS: Yes, it was T-a-k-a-r-a S-o
6 Apartments.
7 BY MR. COSTA:
8 Q.
And did that partnership -- in that first
9 partnership, was Mr. Stanford's successful in getting some

03:15:19
10 of the bank's clients to also invest separately in the

11 real estate partnership?
12 A.
Yes.
13 Q.
What about -- was there a second real estate
14 partnership set up?

03:15:27
03:15:38
15 A.
Yes.
16 Q.
What did that partnership purchase?
17 A.
It was called the Jonathan Square One Apartments.
18 Q.
Where was that located?
19 A.
In southwest Houston.
20 Q.
For that second partnership that was set up, was
21 Mr. Stanford successful in getting the bank's clients to

22 invest separately in the real estate partnership?
03:15:53
23 A.
Not to the full extent.
24 Q.
It didn't fund the whole partnership?
25 A.
That's correct.
2122
1 Q.
Where -- were you told by Mr. Stanford where the rest
2 of the money came from to fund that second partnership?
03:16:09
03:16:16
3 A.
He said he had personal resources to take care of it.
4 Q.
Was there a third real estate partnership?
5 A.
Yes.
6 Q.
What did that purchase?
7 A.
It was called the Rock Springs Apartments.
8 Q.
In Houston?
9 A.
Southwest Houston.
10 Q.
Was Mr. Stanford successful in getting the bank
11 customers to invest separately in this third real estate

12 partnership?
13 A.
Yes, but not to the full extent, not to the full
14 need.
03:16:28
15 Q.
Who did Mr. Stanford say made up the difference?
16 A.
He said he had personal resources that would take
17 care of it.
03:16:40
18 Q.
Was there a fourth partnership set up?
19 A.
No, there was only three.
20 Q.
Was there -- were there also Austin investments?
21 A.
Yes, more properties were purchased, but they were
22 not limited partnerships.
03:16:52
23 Q.
How were those set up?
24 A.
They were -- these purchases -- by that time, the
25 name of the company had the changed to Guardian

2123
1 Development Corporation, and they were purchased by

2 Guardian Development Corporation.
3 Q.
How long did it take for Guardian Investment Services
4 that you started with in 1987 to become Guardian

03:17:05
5 Development Company?
6 A.
It was in the first two to three years.
7 Q.
And by this time when Guardian Development was
8 created, did you have a new title?

9 A.
03:17:21
10 Q.
Yes. I became president.

When Guardian Development was created, was
11 Mr. Stanford still trying to get bank customers to invest

12 separately in the real estate investments?
03:17:43
13 A.
No.
14 Q.
Did you learn why there were difficulties with
15 getting bank clients to invest in the real estate

16 partnerships?
17 A.
I heard from the bank officers some of the reasons.
18
MR. SCARDINO: Excuse me. Assuming facts that
19 are not in evidence, and he's leading the witness.

03:17:57
20
THE COURT: All right. Rephrase it.
21 BY MR. COSTA:
22 Q.
You mentioned that after the first real estate
23 partnership, the second and third were not fully funded by

24 the bank customers; correct?
03:18:08
25 A.
Yes.
2124
1 Q.
And then once Guardian Development started, the bank
2 clients weren't helping to fund that is your

3 understandings; right?
03:18:16
MR. SCARDINO: Object to leading.
THE WITNESS: Could you repeat it, please?
7 BY MR. COSTA:
8 Q.
Once Guardian Development started, was Mr. Stanford
9 still trying to get the bank clients to fund Guardian

03:18:29
10 Development?
11 A.
No.
12 Q.
Did you learn why he wasn't able to get enough bank
13 clients to fund, say, the second and third real estate

14 partnerships fully?
03:18:43
15
THE WITNESS: I would have to answer with some
16 narrative, Judge.
17 Q.
It's a narrative. It calls for a narrative.
18
THE COURT: Answer it yes or no.
19 BY MR. COSTA:
03:18:50
20 Q.
Did you learn why?
21 A.
Yes.
22
23 BY MR. COSTA:
24 Q.
03:18:59
What was different about investing in the bank CDs
25 as -- according to what the bank said it did with the

2125
1 money versus investing in these real estate partnerships?
03:19:11
2 A.
The real estate partnerships were not liquid.
3 Q.
What do you mean by that?
4 A.
Liquid means you can get your money if you decide --
MR. SCARDINO: Excuse me, Mr. Knoche.
He asking him to give an opinion about a
7 matter -- a financial transaction, and he's not qualified

8 to give an opinion about a financial transaction.
9
03:19:24
MR. COSTA: They've been asking all these
10 questions about international accounting standards, about

11 all types of stuff. I'm just asking what he understands -12 he was involved in the real estate companies.
13
14 BY MR. COSTA:
03:19:33
15 Q.
What do you mean when you say the real estate
16 partnerships were not liquid?

17 A.
If you want to get your money out, a real estate
18 partnership would not -- you would have to wait until the

19 property is sold.
03:19:46
20 Q.
What about -- we saw earlier the banks's annual
21 report talking about bonds and equities. How long does it

22 take to sell bonds and equities if they're traded on a
23 public market?
03:20:00
24 A.
Usually one to two days, I think.
25 Q.
These apartment complexes that you were working on on

2126
1 the real estate side of things, how long would it take to

2 sell those?
03:20:13
3 A.
It would take months.
4 Q.
What about the risk level? You mentioned the
5 liquidity difference. Is there also a difference in risk

6 level between what the bank was saying it did with its
7 investment portfolio versus these investments in
8 distressed real estate?
9 A.
03:20:25
10 Q.
Yes.
And what's the risk level of investments in
11 distressed real estate?

12 A.
Real estate would be considered to have some degree
13 of risk in it. The price of -- the value of the property

14 can go up or down.
03:20:37
15 Q.
Everything can go up or down; right?
16 A.
Yes.
17 Q.
What about the level of risk in a distressed real
18 estate investment versus the risk in a diversified

19 portfolio stocks and bonds?
03:20:49
20 A.
I would say it is more in the real estate.
21 Q.
You mentioned that Mr. Stanford was saying he
22 personally -- when the bank clients weren't interested in

23 funding these real estate partnerships, you said that he
24 told you it was his funds that were making up the
03:21:09
25 difference?
2127
1 A.
He had personal resources.
2 Q.
And what about when Guardian Development Company
3 started, where did Mr. Stanford tell you he was getting

4 the money for those acquisitions?
03:21:19
5 A.
Personal resources.
6 Q.
Were you actually able to see the bank records
7 showing the actual sources of those money?
03:21:40
8 A.
No.
9 Q.
At times did you ask Mr. Stanford where the money was
10 coming from?
11 A.
Maybe once or twice and then --
12 Q.
Why did you stop asking him?
13 A.
If he didn't want to answer a question, he wouldn't
14 answer it -- he wouldn't answer it.

03:21:50
15 Q.
So when you'd asked him those first couple of times,
16 did he give you a lot of information?

17 A.
No.
18
THE COURT: Move that mike away just a little
19 bit.
03:22:02
20
THE WITNESS: Okay. I'm sorry. Tell me if
21 this is going to be better.

22
THE COURT: Depends upon how close you get
23 again.
03:22:10
24
THE WITNESS: I'm sorry.
25
THE COURT: Right now it's fine.

2128
THE WITNESS: My fault.
2 BY MR. COSTA:
3 Q.
I'm sorry. You're saying if he didn't like to give
4 you more information?

03:22:20
5 A.
No.
6 Q.
Okay. In terms of working for Mr. Stanford, what was
7 the general atmosphere, in your view, about whether he

8 liked being questioned?
9 A.
03:22:31
10
He did not like to be questioned.

MR. SCARDINO: I object to the relevance of
11 whether he liked to be questioned.

12
13
By the way, you can sit back and pull that
14 microphone in if you want.

03:22:37
15
THE WITNESS: Okay.
16 BY MR. COSTA:
17 Q.
I'm sorry. There was an interruption. So could you
18 answer again what -- whether -- your understanding of

19 whether Mr. Stanford liked being questioned.
03:22:44
20 A.
My impression was he did not like to be questioned.
21 Q.
What do you base that impression on?
22 A.
Just the way he would respond if somebody asked him
23 about where monies came from.
03:22:55
24 Q.
How would he respond?
25 A.
If it was an employee, he would probably just not

2129
1 answer it, period. If it was somebody else, he might say,

2 "We'll talk about that later" or something like that.
3 Q.
Did Mr. Stanford ever tell you that he was taking
4 money from the bank, from its investment portfolio, to

03:23:13
5 invest in any of these real estate projects?

6 A.
No.
7 Q.
Would that have concerned you if he had told you
8 that?
03:23:20
9 A.
Yes.
10 Q.
Why?
11 A.
Well, because the bank's promotional material says
12 it's invested in other things.

13 Q.
You said you started with Mr. Stanford in 1987. And
14 I'm jumping ahead just a little bit. How long did you
03:23:37
03:23:44
15 work for Mr. Stanford?

16 A.
I worked there until 2003.
17 Q.
So that's about 16 years?
18 A.
Yes, 16 years.
19 Q.
Did there come a time when you learned that the bank
20 moved from Montserrat?

21 A.
Yes.
22 Q.
What -- did Mr. Stanford say about why the bank moved
23 from Montserrat?
24 A.
03:23:54
He said the bank had outgrown Montserrat, that he
25 needed to go to a larger venue such as Antigua.

2130
1 Q.
Did he ever tell you that Montserrat had sent a
2 letter notifying him they were planning to revoke his

3 banking license?
03:24:13
4 A.
No.
5 Q.
When you started working for Mr. Stanford in 1987,
6 was Jim Davis already working there?

7 A.
No.
8 Q.
Do you recall about how long after you got there that
9 Jim Davis came on board?

03:24:23
10 A.
Within the first year.
11 Q.
And what was Mr. Davis's position when he came on
12 board?
03:24:34
13 A.
Chief financial officer.
14 Q.
You already said you were a CPA; correct?
15 A.
Yes.
16 Q.
And you'd been a controller at one of those home
17 building companies?
03:24:42
18 A.
Yes.
19 Q.
Did Mr. Stanford ever ask you if you were interested
20 in that position of CFO that he gave to Jim Davis?

21 A.
No.
22 Q.
Had you heard that they were looking for that --
23 someone to fill that position?
03:24:51
24 A.
No.
25 Q.
Had there been an advertisement, a want ad, like the

2131
1 one for your position looking for a CFO?
03:25:02
2 A.
3 Q.
You said you were a CPA; correct?
4 A.
Yes.
5 Q.
Was Mr. Davis a CPA, to your knowledge?
6 A.
7 Q.
What was Mr. Stanford's relationship with Mr. Davis?
8 A.
He said they went way back. They were college
9 roommates.
03:25:15
10 Q.
And was there -- where was Mr. Davis's office in
11 relation to Mr. Stanford's once Mr. Davis came on board?

12 A.
In the same building, 1100 Milam Building.
13 Q.
Was Mr. Stanford's relationship with Mr. Davis
14 different than with his relationship with other employees

03:25:34
15 from what you saw?

16 A.
From what I saw, yes.
17 Q.
How was it different?
18 A.
They were friends. I mean, the rest of us were
19 employees, they were friends.

03:25:41
20 Q.
After Mr. Davis arrived, did it seem to you like
21 Mr. Davis was now in charge?
03:25:52
22 A.
No.
23 Q.
And you said you worked there through 2003?
24 A.
That's correct.
25 Q.
Through 2003, did it ever seem to you like Mr. Davis

2132
1 was in charge?
03:26:00
03:26:12
2 A.
No.
3 Q.
Did that thought ever even cross your mind?
4 A.
No.
5 Q.
Why not?
6 A.
It was Mr. Stanford's companies. There was no doubt.
7 Q.
Including the bank?
8 A.
Yes.
9 Q.
How would you describe Mr. Stanford's management
10 style in terms of his level of involvement?

11 A.
He was very involved. He knew what was going on.
12 Q.
Did there come a point when Mr. Davis actually helped
13 provide accounting services for your -- the company you

14 were president of, Stanford Development?
03:26:29
15 A.
Yes.
16 Q.
So Mr. Davis didn't just work for the bank; is that
17 right?
03:26:39
18 A.
That's correct.
19 Q.
Did Stanford Financial Group provide accounting and
20 other support services for a number of the companies?

21 A.
Yes.
22 Q.
So if it was said that Mr. Davis only had involvement
23 with the bank, you wouldn't agree with that?
03:26:51
24 A.
No.
25 Q.
Do you recall when it was that Mr. Davis started to

2133
1 help with the accounting for Stanford Development Company?

2 A.
Probably the early 1990s, early-to-mid-1990s.
3 Q.
And I should clarify one thing. You said -- you
4 started off you were hired for Guardian Investment

03:27:10
03:27:18
5 Services; right?
6 A.
Yes. Guardian International Investment Services.
7 Q.
And then you said it became Guardian Development?
8 A.
Yes.
9 Q.
And then did it change to something else?
10 A.
Yes.
11 Q.
What did it change to?
12 A.
Stanford Development Company -- Corporation.
13 Q.
And when Mr. Davis in the early '90s started to help
14 with the financial statements for Guardian Development

03:27:31
15 Company, did you just withdraw completely from having any

16 involvement in the financial aspects of your business?
03:27:47
17 A.
No.
18 Q.
Why not if he was CFO?
19 A.
Well, the president's responsible.
20 Q.
So you mentioned in the late '80s when you started,
21 the focus of these real estate investments was distressed

22 apartment complexes?
03:27:59
23 A.
Yes.
24 Q.
And the idea was to -- with these partnerships was to
25 sell those as an investment and eventually make a profit;

2134
1 right?
2 A.
Yes.
3 Q.
During the '90s, did the focus of the development
4 company begin to change?

03:28:11
5 A.
Yes.
6 Q.
Did the focus -- let's say in the mid-'90s, was the
7 focus still on buying distressed properties and then

8 trying to sell them a few years later?
9 A.
03:28:23
No.
10 Q.
What became the focus in the mid-'90s?
11 A.
Two things: We built some houses for sale, but
12 mainly we, I think, became like a construction department

13 for the other entities. We built things for the other
14 members of the group.
03:28:36
15 Q.
Let's take those one at a time. You mentioned some
16 houses that were built?
03:28:45
17 A.
Yes.
18 Q.
Tell the jury about those.
19 A.
We built one in Houston called Stanford Oaks. It was
20 16 townhomes, just off Kirby and San Felipe. And we built

21 one called Le Voisinage. It was about the same number of
22 units over off West Alabama.
03:29:00
23
MR. SCARDINO: Could you spell that?
24
THE WITNESS: Yes. It's a French word.
25 L-e V-o-i-s-a-n-g-e (sic), I believe.

2135
And then later, very late, we started the
2 loft project downtown, The Stanford over by Minute Maid

3 Park. It was about a four-story loft project.
4 BY MR. COSTA:
03:29:20
5 Q.
So, say, your last ten years with the company, say,
6 from '93 to '03, were those three projects you just

7 mentioned, were those the only investment-type projects --
03:29:32
8 A.
Yes.
9 Q.
-- that you recall?
10 A.
Oh. In Antigua, we built some houses, also. We
11 built a small subdivision in Antigua called Cedar Valley

12 Springs. Those were for sale.
13 Q.
And with any of those four projects that occurred
14 over your last decade or so, did Mr. Stanford ever tell
03:29:48
15 you that CD depositors' money was being used to fund

16 those?
17 A.
No.
18 Q.
Where did you understand the funding to come from for
19 those projects?
03:29:57
20 A.
They were coming from Stanford Financial Group or
21 Allen Stanford as an individual.

22 Q.
Now, you said most of the work during your last
23 decade became construction projects for other Stanford

24 businesses?
03:30:09
25 A.
Yes.
2136
1 Q.
And where were most of those construction projects
2 located?
3 A.
Well, some -- the offices for Stanford Group Company
4 were in the United States, and the others were in Antigua.

03:30:21
5 Q.
Did you end up spending a lot of time in Antigua?
6 A.
Yes. A great deal.
7 Q.
How often -- in your latter few years with the
8 company, how much time did you have to spend in Antigua?

9 A.
03:30:33
About half the time.
10
MR. COSTA: If we could go to 1530, please.
11 This we've already offered early this morning.

12 BY MR. COSTA:
03:30:50
03:31:01
13 Q.
Do you recognize that photo, Mr. Knoche?
14 A.
That was not completed when I left in 2003, but that
15 is the Antigua Athletic Club.

16 Q.
Who owned the Antigua Athletic Club?
17 A.
Stanford Development Company.
18 Q.
Like a health club?
19 A.
Yes.
20 Q.
With a swimming pool?
21 A.
Yes.
22
MR. COSTA: Let's go to Page 3, please. The
23 jury's already seen this.

24 BY MR. COSTA:
03:31:10
25 Q.
What's this photo?

2137
1 A.
That's the Sticky Wicket Restaurant and Bar.
2 Q.
And what entity built that?
3 A.
Stanford Development Company.
4
03:31:24
MR. COSTA: If we can go to Page 11.
5 BY MR. COSTA:
6 Q.
Do you recognize that?
7 A.
That's the airplane hangar in Antigua.
8 Q.
When you say airplane hangar, what airplanes were
9 allowed to use that hangar?

03:31:39
10 A.
The Stanford fleet or Stanford planes.
11 Q.
And who built -- which entity built that?
12 A.
Stanford Development Company did the construction.
13 There might have been a separate entity like Stanford

14 Aviation or something that might have been the ownership,
03:31:59
15 but Stanford Development Company built it.

16 Q.
You mentioned Stanford Aviation. That was another
17 company?
18 A.
That's my recollection -- that might not be exactly
19 the right terminology, but there was a separate entity

03:32:09
20 that had to do with aviation.

21 Q.
Now, when you say the aviation, what types of planes
22 are you talking about?
03:32:21
23 A.
That's strictly the private planes, Stanford planes.
24 Q.
Did there come a time when Mr. Stanford owned
25 commercial airline companies?

2138
03:32:36
1 A.
Yes. He started two commercial airline companies.
2 Q.
What were those called?
3 A.
Caribbean Star and Caribbean Sun.
4 Q.
But this hangar and the Stanford Aviation Company
5 related to the private jets?

6 A.
Yes.
MR. COSTA: Let's go to Page 13, please.
8 BY MR. COSTA:
9 Q.
03:32:46
10 A.

That was not built when I was there. I believe
11 that's out on a place called Barnacle Point, but that was

12 not even under construction when I left.
13
THE COURT: What is it? What is Barnacle
14 Point.
03:32:59
15
THE WITNESS: I believe it was going to be a
16 dock facility for the boat, his boat, or perhaps other

17 visitors' boats.
18 BY MR. COSTA:
19 Q.
03:33:11
20 you were aware for the planning for a boat dock?

21 A.
Yes.
22 Q.
And whose boat was going to dock there?
23 A.
Mr. Stanford's and I guess anybody else he invited.
24
03:33:23
So you weren't there to actually construct this, but
MR. COSTA: Let's go to Page 19, please.
25 BY MR. COSTA:
2139
1 Q.
2 A.
Yes. That's the cricket grounds.
3 Q.
Did Stanford Development build that when you were
4 president?
03:33:35
5 A.
Yes.
MR. COSTA: And finally number 23, please,
7 Page 23.
8 BY MR. COSTA:
9 Q.
03:33:45
It's an overview shot. Do you recognize that?
10 A.
Yes.
11 Q.
What is that showing?
12 A.
That's the overall -- some of the things we've
13 already seen. It shows the Sticky Wicket and the Athletic

14 Club. It also shows Stanford International Bank building.
03:33:58
15 Q.
Are these properties all in a certain area in
16 Antigua?
17 A.
Yes, they're all in approximately 20 acres adjacent
18 to the airport.
19 Q.
03:34:11
What were the years when this whole development
20 started construction?
21 A.
From the late 1990s through the early 2000s.
22 Q.
Was it expensive to build all these different
23 buildings?
03:34:27
24 A.
Yes, I mean, expensive relative, but, yes.
25 Q.
Was Mr. Stanford involved -- was he involved with you

2140
1 in the plans and the budgets?

2 A.
In the plans, very much so.
3 Q.
What about the budgets. Did Mr. Stanford -- did he
4 express a lot of concerns about cost?

03:34:43
5 A.
No.
6 Q.
Did you ever raise with him concerns about costs?
7 A.
Yes. And we tried to do budgets, but a lot of times
8 it was fast tracked and we weren't able to do a budget

9 because we already started construction before all the
03:34:54
10 bids were in and the construction documents were

11 completed.
03:35:03
12 Q.
And who wanted it fast tracked?
13 A.
Mr. Stanford.
14 Q.
What did he tell you about the time in which he
15 wanted these things built?

16 A.
They always needed to be built very quickly to show
17 that things could be done rapidly in the Caribbean.

18 Q.
What did Mr. Stanford say about the quality of this
19 construction?
03:35:13
20 A.
The quality had to be the best in the world.
21 Q.
Did he actually use the term about the standard of
22 quality he wanted to set?

23 A.
Yes, create a new standard of quality for the
24 Caribbean.
03:35:23
25 Q.
Is it difficult to get some of these materials used

2141
1 in these buildings down to Antigua?

2 A.
Yes. It's a small island, so there's very few
3 materials on the island. Almost everything has to be

4 brought in.
03:35:37
5 Q.
Can that be expensive to import all the materials?
6 A.
Yes. It adds to the cost, yes.
7 Q.
What types of materials did Mr. Stanford want
8 included that you had to import?

9 A.
03:35:52
The millwork, which is the wood paneling, granite and
10 marble finances.
11 Q.
Once the construction started, did Mr. Stanford stay
12 involved in monitoring the progress?
03:36:06
13 A.
Yes.
14 Q.
Was there ever an issue with some hardwood floors?
15 A.
Yes. We had hardwood floors in Stanford
16 International Bank. He thought we had a too light a shade

17 on them, and he wanted them change out.
03:36:19
18 Q.
Why did he want a different shade for the hardwoods?
19 A.
He wanted them to be the same as the other offices.
20 They end up being put in, in a lighter shade than the

21 other offices around the world. He wanted them all to be
22 the same.
23 Q.
And he noticed just that that shading was off in the
24 hardwood floors?
03:36:28
25 A.
Yes.
2142
03:36:36
1 Q.
What was his reaction when he saw that?
2 A.
He was very upset.
3 Q.
Did he talk to you about it?
4 A.
Yes.
5 Q.
What did he say?
6 A.
He said, "This shouldn't have happened."
7 Q.
What were you told from Mr. Stanford about the source
8 of funding for this Stanford world down in Antigua?

9 A.
03:36:58
10 Q.
Just he had his resources. He was doing it.

A few days ago, did I show you a video clip of
11 Mr. Stanford talking about these construction projects?
03:37:11
12 A.
Yes.
13 Q.
Did you recognize him as Mr. Stanford in that video?
14 A.
Yes.
15 Q.
Now, were you actually present at that particular
16 speech?
17 A.
No.
18 Q.
But was what Mr. Stanford said in that video, was it
19 consistent with what he was telling you over the years

03:37:22
20 about this Antiguan development?

21 A.
Yes.
22
MR. COSTA: Your Honor, at this time I'd offer
23 1535A.
24
03:37:39
25
(Attorneys conferring)
MR. SCARDINO: We have no objection.

2143
THE COURT: No objection, 1350 --
MR. COSTA: 1535A, Your Honor.
THE COURT: 1535A is now identified, and it's
4 in evidence.
03:38:04
Now, what is A? A is --
MR. COSTA: Let's go back.
THE COURT: What is --
MR. COSTA: A, Your Honor, is a clip. It's not
9 the entire -- the entire speech goes on. This is a clip of

03:38:14
03:38:23
10 a few minutes.
11
THE COURT: Video clip?
12
MR. COSTA: Video clip.
13
THE COURT: Thank you.
14
MR. COSTA: Can we get the lights maybe, Your
15 Honor?
16
THE COURT: Well, more lights.
17
MR. COSTA: Less.
18
(Whereupon, the tape was played)
19
03:38:46
MR. COSTA: Stop it right there.
20 BY MR. COSTA:
21 Q.
Who did he just say there? What pronoun did he use
22 when he was talking about who built it and who paid for
23 it?
03:38:56
24 A.
"I."
25 Q.
Is that consistent with your discussions with

2144
1 Mr. Stanford over the years?

2 A.
03:39:07
Yes.
MR. COSTA: Continue now.
THE COURT: A little louder.
6 BY MR. COSTA:
7 Q.
Did Mr. Stanford, again, say who was paying for the
8 development?
9 A.
03:41:39
10 Q.
He said "I."
What else did he say about the economics of the
11 development?
12 A.
On parts, that would make no economic sense.
13
MR. COSTA: Maybe we can just finish it up.
14
03:41:56
15 BY MR. COSTA:
16 Q.
Mr. Knoche, towards the end there, did Mr. Stanford
17 say where he was giving the speech?

18 A.
In the airport in Antigua. In the aircraft hangar in
19 Antigua.
03:43:09
20 Q.
That's the private hangar we just saw the picture of?
21 A.
Yes.
22 Q.
That wasn't part of the airport that any American
23 Airlines or any other plane could use; right?
03:43:19
24 A.
No. That's correct.
25 Q.
And when Mr. Stanford said in the video a couple of

2145
1 times, "I'm building this," that's consistent with what he

2 told you?
03:43:32
3 A.
Yes.
4 Q.
Did you ever inquire where he was getting all the
5 money?
6 A.
No. No.
7 Q.
Did he ever tell you -- mention his family money?
8 A.
On the early -- in the early, early days.
9
03:43:42
MR. SCARDINO: Excuse me. He asked him if he
10 ever inquired where he got the money, and he said no.

11
THE COURT: Okay.
12
MR. SCARDINO: Object to the form of the
13 question.
14
03:43:48
03:43:57
THE COURT: All right. Next question.
15 BY MR. COSTA:
16 Q.
Did he ever mention family money?
17 A.
Only in the early days.
18 Q.
What did he say in the early days?
19 A.
When -- where is the money coming from, he said, I
20 have fam -- personal resources, family resources.

21 Q.
And in later years, it was -- he just said it was
22 him?
03:44:06
23 A.
Yes.
24 Q.
Now despite Mr. Stanford telling you that, like he
25 said on the video, towards the end of your time with

2146
1 Mr. Stanford, did you start having concerns about whether,

2 in fact, all the money was coming from him?
3 A.
I just wondered where all the money was coming from
4 because it was a huge amount of money with the airlines

03:44:20
5 and all.
6 Q.
What do you mean when you say, "with the airlines and
7 all"?
8 A.
That was the biggest endeavor. To start two airlines
9 in the Caribbean was a huge endeavor.

03:44:28
10 Q.
That's the Caribbean Sun and Star you mentioned?
11 A.
Yes.
12 Q.
Was it also costing a lot for all these construction
13 projects --
03:44:35
14 A.
Yes.
15 Q.
-- in Antigua?
16
And if the money wasn't coming from
17 Mr. Stanford's personal wealth, did you have a suspicion

18 where it possibly could be coming from?
03:44:49
19
MR. SCARDINO: Assuming facts not in evidence.
20
21 BY MR. COSTA:
22 Q.
Did you know which other business of Mr. Stanford had
23 funds to support this type of construction and these two

24 airlines?
03:45:02
25 A.
I was not aware -- I was not aware of where it came

2147
1 from. I don't know.

2 Q.
You didn't know -- you didn't know where the money
3 came from?
03:45:10
4 A.
No.
5 Q.
You didn't see any financial records?
6 A.
No.
7 Q.
But did you have a concern -- if it wasn't coming
8 from Mr. Stanford, were you concerned about where it might

9 be coming from?
03:45:20
10 A.
Yes.
11
MR. SCARDINO: Too late.
12 BY MR. COSTA:
13 Q.
What was your concern about where it might be coming
14 from?
03:45:30
15
MR. SCARDINO: Objection to relevance as to
16 what his concern might have been.
03:45:36
17
18
MR. COSTA: Your Honor --
19
THE COURT: What?
20
MR. COSTA: It's -- I'm going to go ahead, but
21 it's part of the reason he -22
THE COURT: Well, thank you for going ahead,
23 but I appreciate that.

24
03:45:44
What else, though, Counsel? What else do
25 you want to say to get me to reverse that ruling? That's

2148
1 what I want to know.
03:45:50
MR. COSTA: Well, I just want to --
THE COURT: Put it that way.
MR. COSTA: I want to put it in context to make
5 it relevant as for his concerns when he left the company.

6
THE COURT: All right. He had concerns. See
7 if it's relevant.
8 BY MR. COSTA:
9 Q.
03:46:06
Let's go to Government 115, please, which is already
10 in evidence.
11
Do you recognize this as a Stanford
12 International Bank annual report?
03:46:23
13 A.
Yes. 2 -- I'm sorry. 2002.
14 Q.
That's towards the end of your time with
15 Mr. Stanford?
16 A.
Yes.
17 Q.
And in the 16 years you were with Mr. Stanford, did
18 he ever say that bank money was going to the development

19 corporation?
03:46:32
20 A.
No.
21 Q.
Did you ever see any bank documents that said that?
22 A.
No.
23
MR. COSTA: If we can turn to Page 50 of this
24 annual report. If we can highlight the top portion, that

03:46:47
25 first note.
2149
1 BY MR. COSTA:
2 Q.
This shows the bank's supposed investments for 2002.
Do you see it lists total assets in the
4 investment portfolio of 1.5 billion, Mr. Knoche?

03:47:03
03:47:22
5 A.
1.573 billion, yes.
6 Q.
And what does it say it has in equities?
7 A.
$720,900,000 -- $720,951.040.
8 Q.
And what about treasury bonds?
9 A.
$832,336,398.
10 Q.
It's actually 852. 852 million on treasury bonds?
11 A.
852 million on treasury bonds, yes.
12 Q.
Anywhere on there that you see it showing real estate
13 investments?
03:47:47
14 A.
No.
15 Q.
You were the president of the development company?
16 A.
Yes.
17 Q.
Did Mr. Stanford ever tell you he had received loans
18 from this Stanford International Bank to help fund the

19 development company?
03:47:58
20 A.
No.
21 Q.
I want to show you Government 336.
22
Do you recognize the signature on the
23 second page of this, Mr. Knoche?
03:48:28
24 A.
Yes, I do.
25 Q.
Whose signature is it?

2150
03:48:48
03:49:23
1 A.
R. Allen Stanford.
2 Q.
And what type of document is this?
3 A.
It is a promissory note.
MR. COSTA: Government offers 336.
MR. SCARDINO: Can I have just a second?
THE COURT: Sure.
MR. SCARDINO: No objection.
THE COURT: Okay. Keep in mind 336 --
MR. SCARDINO: Is it offered for the truth of
10 the matter?
11
MR. COSTA: It's just a contract, and it's
12 signed by the defendant as a party opponent.

13
THE COURT: All right. Keep in mind if you're
14 going to enter it -- if you're going offer it for other

03:49:30
15 than the standard reason, I think you just mentioned that

16 you would.
17
MR. COSTA: We're offering this for all
18 purposes. It's a document signed by Mr. Stanford. It's a

19 statement by party opponent.
03:49:39
20
THE COURT: Correct. What I'm about to say,
21 everything is already in evidence; okay. For -- what is

22 it -- just for the docket itself. I'm not going into the
23 exact determination.
24
03:49:57
So if you would, just say you're about to
25 discuss a certain exhibit and just put them on notice.

2151
And so it may go ahead with no objection.
2 But anyhow, 336 is in for all purposes.

3
MR. COSTA: Thank you, Your Honor.
4
03:50:10
If we can highlight the top portion,
5 including the first full paragraph. Perfect. Thank you.

6
THE COURT: Ladies and gentlemen, we'll take a
7 break in about five minutes.

8 BY MR. COSTA:
9 Q.
03:50:20
What's the date on this, Mr. Knoche?
10 A.
December 31, 2002.
11 Q.
I think you've said you left in 2003; is that
12 correct?
03:50:29
13 A.
That's correct.
14 Q.
So you were working for Mr. Stanford on that day?
15 A.
Yes.
16 Q.
And it's a promissory. It says Promissory Note.
17
03:50:43
What's a promissory note?
18 A.
That's a debt that -- it says -- it's a debt.
19 Q.
And do you see that it says, "For value received,
20 R. Allen Stanford promises to pay to the order of Stanford

21 International Bank," lists the address, "the principal sum
22 of $168 million, together with any unpaid interest at the
23 rate" -- "and on the terms set forth below."
24
03:51:01
25 A.
Do you see that?

Yes.
2152
1 Q.
At the top, it lists that amount again, $168 million?
2 A.
Yes.
3 Q.
Were you ever told about this when you worked for
4 Mr. Stanford?
03:51:09
5 A.
No.
6 Q.
Were you ever told that this loan was helping to fund
7 some of the development corporation projects that you were

8 in charge of?
9
03:51:19
MR. SCARDINO: Assuming facts that are not in
10 evidence. Object.
11
MR. COSTA: Just asking if Mr. Stanford told
12 him that.
13
THE COURT: Well, again, are you going for link
14 it up later?
03:51:24
15
MR. COSTA: The next witness is going to show
16 hundreds of millions of dollars going to that development

17 corporation.
18
MR. SCARDINO: Well, okay. If the next witness
19 does it that's fine, but this witness doesn't have

03:51:33
20 knowledge of it.
21
MR. COSTA: But all I need is a good faith
22 basis to ask the question.

23
THE COURT: I overrule the objection with that
24 caveat, with that proviso.

03:51:40
25 BY MR. COSTA:
2153
1 Q.
Did Mr. Stanford ever tell you that this $168 million
2 he was taking out of the bank, that some of that was being
3 used to fund the development corporation which you were
4 president of?
03:51:52
5 A.
No.
6 Q.
Would it have concerned you if you had seen this
7 promissory note and heard that some of this money was

8 going to the development corporation?
03:52:02
9 A.
Yes.
10 Q.
Why?
11 A.
That the depositors and the bank would not have --
12 were told that there were not loans being made.

13 Q.
03:53:45
I want to show 337.
14
MR. COSTA: Is it in, Your Honor?
15
THE COURT: Pardon me. They're still talking.
16
MR. COSTA: Give you a second.
17
THE COURT: But the clock is on them.
18
MR. SCARDINO: We don't have any objections to
19 this, Judge.
03:54:03
20
THE COURT: Okay. What exhibit then?
21
MR. COSTA: 337, Your Honor.
22
THE COURT: It's already been identified?
23
MR. COSTA: No. This is the first time it's
24 been discussed at trial.

03:54:09
25
THE COURT: Hang on a second. 337 is admitted.

2154
1 BY MR. COSTA:
03:54:24
2 Q.
When did you leave in 2003?
3 A.
At the end of June 2003.
4 Q.
About halfway through the year?
5 A.
Yes.
6 Q.
And this is dated the end of 2003; correct?
7 A.
Yes.
8 Q.
And does it look pretty much --
9
03:54:32
MR. COSTA: If you can go back to the full
10 document for a second, please. Please blow up -11 BY MR. COSTA:

12 Q.
Does that look similar to the prior promissory note
13 from 2002 I showed you?

14
03:54:58
And I can hand that to you, if you want.
15 Just generally, is it the same -16 A.
Yes.
17 Q.
-- type of document?
18
But it's just one year later,
19 December 2003?
03:55:04
20 A.
21
One year later, yes.

MR. COSTA: If we can go to the top portion
22 again, please.
23 BY MR. COSTA:
24 Q.
03:55:17
And what is the amount in December 31, 2003, that
25 Mr. Stanford now owes Stanford International Bank?

2155
1 A.
330 million.
2 Q.
And in 2003, there was still a lot of construction
3 being done on all these -- the Antiguan development we

4 looked at?
03:55:31
5 A.
6
Yes.
MR. COSTA: This is a good stopping point if
7 you want a break, Your Honor?

8
THE COURT: Ladies and gentlemen, it's now
9 3:55. We'll take our 20-minute break for the afternoon.

03:55:42
10 See you back ready to resume at 4:15.

11
12
04:22:06

(The following was held before the jury.)
13
THE COURT: Thank you. Be seated.
14
MR. COSTA: May I proceed, Your Honor?
15
THE COURT: Yes.
16
MR. COSTA: Thank you.
17 BY MR. COSTA:
18 Q.
Mr. Knoche, before the break, we were talking about
19 Government 337, which is this promissory note from the end

04:22:16
20 of December 2003 for $330 million.

21
And you said you were never told either in
22 2002 or 2003 that money from the bank was going to the
23 development corporation you were president of?
24 A.
04:22:32
25
That's correct.
MR. COSTA: If we can go to Page 2 and look at
2156
1 the signature. Blow up the signature portion.

2 BY MR. COSTA:
3 Q.
Do you recognize the signature on that promissory
4 note?
04:22:45
5 A.
Yes.
6 Q.
Whose signature is that?
7 A.
R. Allen Stanford.
8 Q.
During the break, did I hand you Government 115,
9 which is the 2002 annual report?

04:22:59
10 A.
Yes.
11 Q.
And to save time, did I ask you to look through it
12 during the break?
04:23:06
13 A.
Yes.
14 Q.
In 2002 --
15
MR. COSTA: If we can go back to 336 real
16 quick.
17 BY MR. COSTA:
18 Q.
2002, was that the year when there was the
19 168 million-dollar promissory note we saw?

04:23:18
20 A.
Yes.
21 Q.
Do you recall that? It's on the screen.
22 A.
Yes.
23 Q.
Anywhere in that 2002 annual report for the Stanford
24 International Bank did you see disclosure of this

04:23:31
25 168 million-dollar loan?

2157
1 A.
No.
MR. COSTA: If we can go to Government 111,
3 which has already been referenced Your Honor. Go to

4 Page 21. I'm sorry.
04:23:44
5 BY MR. COSTA:
6 Q.
Do you see that that's the Stanford International
7 Bank annual report? It's for 1998? It's hard to read,

8 but -9 A.
04:23:52
Yes.
10
MR. COSTA: And if we can go to Page 21.
11 BY MR. COSTA:
12 Q.
In this annual report, do you see disclosure of a
13 loan the bank extended to Robert Allen Stanford in the

14 blown-up portion?
04:24:13
15 A.
Yes.
16 Q.
It says on December 31st of '96, the bank extended to
17 Robert Allen Stanford, a director, a loan in the amount of

18 13 million and change for two years?
04:24:25
19 A.
Yes.
20 Q.
And it gives the balance of still 11.6 million --
21 A.
Yes.
22 Q.
-- at the end of '97?
23
And it gives more information about that
24 particular loan?
04:24:34
25 A.
Yes.
2158
1 Q.
So in 1998, there's discussion in the annual report
2 of a 13 million-dollar loan, but in the 2002 annual

3 report, you saw no discussion of 168 million-dollar loan?
04:24:47
4 A.
That's correct.
5 Q.
Is there a term you would use to describe the type of
6 loan being disclosed in this 1998 annual report?

7 A.
That would be a related party transaction.
8 Q.
Were you ever told when you worked for Mr. Stanford
9 that the bank or your company, Stanford -- the company you

04:25:09
10 were president of, Stanford Development, was using

11 international financial reporting standards?
12 A.
No.
13 Q.
Were you ever told that because of those
14 international financial reporting standards, that related

04:25:23
15 party transactions were not required to be disclosed?

16 A.
No.
17 Q.
And here in the '98 report, there is such a
18 disclosure; correct?
19 A.
04:25:34
20
That's correct.
MR. COSTA: If we can go back to the 2002
21 annual report, which is Government 115.

22 BY MR. COSTA:
23 Q.
Is that the one you looked through? It that
24 Government 115? There might be a sticker on it. Is that

04:25:49
25 the 2002 annual report -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2159
1 A.
Yes.
2 Q.
-- that you looked at during the break?
MR. COSTA: And if you can turn to the page --
4 BY MR. COSTA:
04:25:55
5 Q.
That's the one you said did not have the disclosure
6 of the 168 million-dollar loan?

7 A.
That's correct.
MR. COSTA: If we can go to Page 59 on the PDF.
9 BY MR. COSTA:
04:26:03
10 Q.
It might be different than the hard copy, Mr. Knoche.
11 If you can look on the screen.

12
MR. COSTA: If we can highlight the top couple
13 paragraphs.
14 BY MR. COSTA:
04:26:22
15 Q.
It says, "Independent auditors' report to the
16 members."
17
Are you familiar that the annual reports
18 for the bank typically had this independent auditor

19 report?
04:26:32
20 A.
Yes.
21 Q.
Who was the bank's independent auditor throughout the
22 whole time you worked for Mr. Stanford?

23 A.
24
04:26:44
It was Cas Hewlett.

MR. COSTA: And if we go to the bottom.
25 BY MR. COSTA:
2160
1 Q.
Is Mr. Hewlett signing off in this independent
2 auditor's report?
04:26:56
3 A.
Yes.
4 Q.
And generally what is an independent or outside
5 auditor? What's their job?

6 A.
Their job is to examine the books and records of the
7 client and give the necessary tests that they feel

8 necessary and then state an opinion as to the accuracy of
9 the financial statements.
04:27:10
10 Q.
Were you ever in meetings with the private banker and
11 Mr. Stanford where the banker raised issues about

12 Mr. Hewlett?
04:27:26
13 A.
Yes.
14 Q.
What did the banker tell Mr. Stanford about
15 Mr. Hewlett?
16 A.
That it was a very small firm.
17 Q.
And why was that a problem the bankers were bringing
18 to Mr. Stanford's Attention?

19 A.
04:27:37
They said that some of their clients did not
20 understand why the bank would not use a larger

21 international firm.
22 Q.
And you said you spent -- by the end of your time
23 with Mr. Stanford, you spent about half of your time down
24 on the island of Antigua?
04:27:47
25 A.
Yes.
2161
1 Q.
Was there a big international accounting firm with an
2 office in Antigua?
04:28:00
3 A.
Yes. Price Waterhouse had an office.
4 Q.
Did you understand what Mr. Stanford said about why
5 he wanted to hire Price Waterhouse like the clients were

6 requesting?
7 A.
I recall that he had met the general partner of that
8 firm and they didn't hit it off. He just didn't -9

04:28:13
MR. SCARDINO: Objection. If he has personal
10 knowledge of this -11
12
04:28:18
Mr. Stanford told you?
13
THE WITNESS: Yes.
14
THE COURT: Okay. Overruled.
15 BY MR. COSTA:
16 Q.
What was Mr. Stanford's explanation as to why he did
17 not want to use Price Waterhouse which had an office in

18 Antigua?
19 A.
04:28:30
He did not go into any detail. He just said he did
20 not care for that partner, and they didn't hit it off, and
21 he just did not want to use them.
22 Q.
In your last couple of years working for
23 Mr. Stanford, did he have a new business idea that he

24 asked you to get involved in?
04:28:42
25 A.
Yes. The Stanford Caribbean Investment Fund.

2162
1 Q.
So that was going to be separate from the development
2 corporation you worked for?
04:28:56
04:29:04
3 A.
Yes.
4 Q.
Was it also supposed to be separate from Stanford
5 International Bank?
6 A.
Yes.
7 Q.
A whole new business?
8 A.
Whole new business.
9 Q.
What was the idea behind the Stanford Caribbean
10 Investment Fund?
11 A.
He wanted to spread to many of the islands, probably
12 about a dozen of the other islands, and seek out

13 investment opportunities in those islands.
14 Q.
04:29:15
And what types of investment opportunities did he say
15 he wanted to seek out with this fund?

16 A.
He said anything was opened, but primarily he was
17 interested in resorts, and then he was interested in

18 improving the infrastructure of those islands that would
19 support the resorts.
04:29:29
20 Q.
Did this fund get off the ground by the time you left
21 in June 2003?
22 A.
It was in its very initial stage. We had hired
23 managers on each of, I think, eight islands, and he had

24 selected a board of directors from -- with directors from
04:29:41
25 the different islands.

2163
1 Q.
Do you know by that point in June 2003 if he had
2 actually got an outside investment money for the fund?
04:29:55
04:30:04
3 A.
I do not know.
4 Q.
You said it involved resorts and building
5 infrastructure on these islands?

6 A.
Yes.
7 Q.
What was your reaction to this business idea?
8 A.
Well, I thought it was very speculative.
9 Q.
Does that include the resorts?
10 A.
Yes.
11 Q.
Why did you think the idea of investing in resorts in
12 the Caribbean was speculative?

13 A.
I just always have thought it is. It's a very
14 fragile market. It's subject to hurricanes, subject to

04:30:18
15 public perception of that individual island, and it's the

16 difficulty of building things in the islands, difficulty
17 of staffing things in the islands.
18 Q.
The first thing you mentioned was hurricanes were a
19 risk with resorts in the Caribbean?

04:30:32
20 A.
That is a risk, yes.
21 Q.
That speaks for itself.
22
The second thing you mentioned was public
23 perception of the island. Could you explain why you say

24 that's a risk?
04:30:42
25 A.
Well, in any one given island, if there's a

2164
1 well-publicized crime of any sort against tourists and

2 that spreads all over the world -- it's not something that
3 happens every year, but if it does happen -- it's very
4 detrimental to the marketing.
04:30:56
5 Q.
Sort of like the Natalee Holloway that was in Aruba?
6 A.
That would be an example.
7 Q.
And, third, you mentioned the difficulty with
8 construction?
9 A.
04:31:09
Yes. All of the islands are small, and you have to
10 import everything. If something breaks, you have to

11 import the repair parts. There are some good people -12 workers, but there's not very many. So frequently you
13 have to import or relocate employees there.
14 Q.
04:31:28
What about infrastructure like plumbing and
15 electricity, is that ever a problem -16 A.
Oh, yes. Your --
17 Q.
-- in surrounding resorts?
18 A.
The resort is dependent to some extent on the
19 infrastructure of the island. You have to have the proper

04:31:38
20 roads to get to the resort.

21
Unless you produce your own electricity
22 and your own water, you're relying on the government

23 electricity and the government water, which in almost all
24 the islands is very undependable. It goes out frequently.
04:31:48
25 Q.
Did Mr. Stanford ever tell you as part of this

2165
1 discussion of resorts in the Caribbean about an idea he

2 had for a resort in Antigua?
04:32:03
3 A.
Yes.
4 Q.
What did he say? What was his idea for that Antiguan
5 resort?
6 A.
He wanted it to be a super high-end resort. It would
7 be the best of the best.
04:32:11
8 Q.
Catering to which type of folks?
9 A.
Extremely wealthy.
10 Q.
And when he's telling you that, it was part of this
11 idea for the Stanford Caribbean Investment Fund?

12 A.
No. Those were separate discussions.
13 Q.
Did he ever tell you the bank was going to put its
14 money into this super high-end resort he was thinking

04:32:28
15 about in Antigua?
16 A.
No.
17 Q.
In your view, would that type of investment had been
18 consistent with what you were told about the bank's

19 investment strategy?
04:32:37
20 A.
No.
21 Q.
Why wouldn't it be consistent with the bank's -- what
22 the bank said its investment strategy was?

23 A.
In my opinion, by any definition, that would be a
24 speculative investment, and the bank said it's in

04:32:50
25 conservative investments.
2166
1 Q.
Would an investment in a super fancy resort in
2 Antigua be a liquid investment?
04:32:55
3 A.
No.
4 Q.
Why not?
5 A.
There would be -- if you wanted to sell it, there
6 would be very, very, very few potential purchasers.

7 Q.
You've already told us you left Mr. Stanford's
8 company in 2003; is that right?

9 A.
04:33:07
10 Q.
That's correct.
By 2003, how were you -- what were your feelings
11 about the job with Mr. Stanford?

12 A.
Well, I was very concerned about the amount of travel
13 I was doing. I was away from home about half the time.
14 And the Stanford Caribbean Investment Fund, that was just
04:33:26
15 going to add to that.

16 Q.
And did you decide to resign?
17 A.
Yes.
18 Q.
Did you sit down with Mr. Stanford and tell him about
19 your decision?
04:33:35
20 A.
Well, I talked to my wife first. It was a hard
21 decision. And we sent an e-mail and a letter giving two

22 months' notice, and then he and I discussed it after that,
23 but I gave two months' notice.
24
04:33:49
THE COURT: Again, your specific reason for
25 resigning was?
2167
THE WITNESS: Travel.
2 BY MR. COSTA:
3 Q.
What did you tell Mr. Stanford when you sat down with
4 him after sending -- after sending the two months' notice?

04:33:56
5 A.
Just that, I was just away from home too much.
6 Q.
And was that the main reason you wanted to leave?
7 A.
Yes.
8 Q.
Was there also a concern you had, though, by that
9 time working for the development corporation in 2003?

04:34:09
10 A.
I was concerned about how much money was being spent,
11 invested.
12 Q.
In this -- all these construction projects in
13 Antigua?
04:34:19
14 A.
Yes.
15 Q.
If it's all Mr. Stanford's personal money, why be
16 concerned?
17 A.
Only that -- it seemed like there would be some limit
18 to how much money he had.

19 Q.
04:34:33
Did you have a job lined up when you sent that
20 two-month notice to Mr. Stanford?

21 A.
No.
22 Q.
How much were you making as president of the
23 development corporation?
04:34:42
24 A.
Approximately $300,000 a year including bonuses.
25 Q.
And how old were you when you decided to resign?

2168
04:34:55
1 A.
I would have been 60 years old.
2 Q.
Did you try looking for another job?
3 A.
Yes.
4 Q.
Did you find a job that paid about the same,
5 $300,000?
6 A.
No.
7 Q.
What did you end up doing?
8 A.
Went to work for the Society of St. Vincent de Paul.
9 It's a Catholic nonprofit organization that assists the

04:35:06
10 poor. And I made a salary of $60,000.

11 Q.
And what was your position?
12 A.
Director of finance.
13 Q.
So you took a 240,000-dollar pay cut after leaving
14 Mr. Stanford?
04:35:17
15 A.
Yes.
16 Q.
Did you regret that decision?
17 A.
No, no regrets.
18 Q.
You said at the beginning of your testimony that when
19 you -- the first couple of years you worked for

04:35:25
20 Mr. Stanford, he spent about 90 percent of his time

21 focused on the bank?
22 A.
Yes.
23 Q.
By the end of your time with Mr. Stanford in 2003,
24 from what you observed and what you understood, was the
04:35:38
25 bank still the primary business that he focused on?

2169
Cross-Knoche/By Mr. Scardino
1 A.
Yes.
2 Q.
Did he ever tell you about the importance of the bank
3 relative to all these other companies?
04:35:50
4 A.
Yes. He said it's what drives it all.
5 Q.
And that's Stanford International Bank?
6 A.
Stanford International Bank drives it all.
MR. COSTA: Pass the witness, Your Honor.
CROSS-EXAMINATION
9 BY MR. SCARDINO:
04:36:16
10 Q.
Good afternoon, Mr. Knoche. How are you?
11 A.
Very well. Thank you.
12 Q.
My name is Robert Scardino.
13
04:36:23
We have not met before, have we?
14 A.
No, sir.
15 Q.
How long did you work for Mr. Stanford?
16 A.
Sixteen years.
17 Q.
And what did you do before you came to work for
18 Mr. Stanford?
19 A.
04:36:33
I worked for Monarch Homes as the chief financial
20 officer.
21 Q.
Okay. And what was your approximate salary at that
22 time?
04:36:41
23 A.
Approximately $100,000.
24 Q.
So when you went to work for Mr. Stanford, you ended
25 up tripling your salary?

2170
1 A.
Well, in 16 years. When I went to work for
2 Mr. Stanford, I got the same salary. I started at about a

3 hundred thousand dollars.
4 Q.
04:36:51
And then you quit and took a job for considerably
5 less money?
6 A.
Yes, sir.
7 Q.
Now, you've talked a lot about what you observed
8 while you were working for Mr. Stanford about real estate
9 and how you were concerned about how maybe he got money to
04:37:03
04:37:15
10 invest in this real estate.

11 A.
Yes.
12 Q.
And you're a CPA?
13 A.
Yes.
14 Q.
When he hired you, it was for a specific purpose, was
15 it not?
16 A.
Yes.
17 Q.
And it was to develop real estate, find real estate
18 deals?
04:37:20
19 A.
That's correct.
20 Q.
And that was in the early '80s in Houston, or really
21 before that even, when he hired you?

22 A.
He hired me in 1987.
23 Q.
Okay. In '87 -- late '80s, I guess.
24
04:37:31
And that was a good time to invest in real
25 estate, wasn't it?

2171
1 A.
It was depressed. There was depressed real estate
2 out there, yes.
04:37:38
3 Q.
So it was a good time to invest in real estate?
4 A.
Yes.
5 Q.
And how many real estate deals did you invest in for
6 Mr. Stanford?
7 A.
We did four in Houston and two in Austin.
8 Q.
Is it possible you're wrong about that and that you
9 made many more investments other than just four?

04:37:51
10 A.
In Houston?
11 Q.
In Houston, right.
12 A.
Those were the four apartment -- there was only four
13 apartment projects.
04:38:01
14 Q.
Was there Stanford Lofts?
15 A.
That was one later, for-sale units. There was three
16 for-sale units, three for-sale projects.

17 Q.
Did you count that as one of the real estate deals?
18 A.
No. It was four rental and three for sale, total of
19 seven in Houston, Texas.

04:38:12
20 Q.
Okay. So there was a total of seven real estate
21 transactions?
04:38:20
22 A.
That's correct.
23 Q.
And were they all successful?
24 A.
They were all moderately successful.
25 Q.
They were all moderately successful.

2172
So it was a good idea to hire you to find
2 these real estate deals and invest in them?
04:38:29
3 A.
Yes.
4 Q.
Okay. And was what you were specifically hired to
5 do?
6 A.
Yes.
7 Q.
And you said there was another man that Mr. Stanford
8 interviewed with -- with you for this job?

9 A.
04:38:36
Yes.
10 Q.
Okay. And he hired you both?
11 A.
That's correct.
12 Q.
And didn't he tell you he couldn't decide who to hire
13 so he just hired you both?
04:38:43
14 A.
Yes.
15 Q.
Was that generous of him?
16 A.
I wouldn't -- I wouldn't call it generous. It was a
17 business decision. He made a business decision.

18 Q.
But it was the kind of guy he was. When he was
19 advertising for a job and two people interviewed for the

04:38:55
20 job, he didn't pick one of them. He picked both of them;

21 right?
22 A.
In my opinion, I still wouldn't call it generous. He
23 made a business decision.

24 Q.
04:39:04
Would it describe his personality where he was the
25 kind of guy that he thought, Well, instead of just picking

2173
1 one of you, I'll just bring both of you in and see what
2 that brings me? Wasn't maybe -- wasn't financially smart
3 necessarily, but he did it anyway, didn't he?
4 A.
04:39:19
04:39:25
04:39:31
I think he did it because he thought it was
5 financially smart, too.

6 Q.
Okay. Well, have you ever hired people --
7 A.
Yes.
8 Q.
-- personally?
9 A.
Yes.
10 Q.
Did you advertise for a position?
11 A.
Yes.
12 Q.
Say, I need to hire somebody?
13 A.
Yes.
14 Q.
Did you interview?
15 A.
Yes.
16 Q.
People come in and talk to them -- talk to you about
17 the position that you advertised?
04:39:39
18 A.
Yes.
19 Q.
And did you ever hire two people for the same
20 position?
21 A.
No.
22 Q.
Never did?
23
THE COURT: Slow down a little bit.
24
MR. SCARDINO: I'm sorry.
25
2174
1 BY MR. SCARDINO:
04:39:49
04:39:58
2 Q.
So that would be unusual?
3 A.
It was unusual, yes.
4 Q.
Okay. And your credentials, your background, was as
5 a CPA; right?
6 A.
Yes, sir.
7 Q.
But he didn't hire you as a CPA, did he?
8 A.
No.
9 Q.
He didn't hire you to look at his books, did he?
10 A.
No.
11 Q.
He didn't hire you to look at financial statements,
12 did he?
13 A.
Only in conjunction with the company I was going to
14 be working for.
04:40:06
04:40:16
15 Q.
Well, Stanford Development Company eventually; right?
16 A.
Yes.
17 Q.
You were the president of the company?
18 A.
That's correct.
19 Q.
And -- but you didn't -- you weren't C -- CFO of
20 Stanford Development Company, were you?

21 A.
No.
22 Q.
You weren't the controller of Stanford Development
23 Company, were you?
04:40:22
24 A.
No.
25 Q.
So you didn't create reports or books and records?

2175
1 Even though you had the background for it, that's not what
2 you were hired to do?
04:40:29
3 A.
That's correct.
4 Q.
So when you asked Mr. Stanford for information about
5 where did the money come from, that wasn't part of what
6 you were hired to determine, was it?
04:40:39
7 A.
No.
8 Q.
Okay. And he never bothered to tell you, did he?
9 A.
No.
10 Q.
And that was the kind of guy he was, wasn't he? You
11 asked him a question, and if he didn't want to answer it,

12 he didn't answer it.
04:40:49
13 A.
Yes, that's correct.
14 Q.
In fact, you weren't even in a position to ask that
15 question, were you, Mr. Knoche?

16 A.
You could say that.
17 Q.
You could say that. In fact, we will say that. You
18 were not in a position -- you weren't hired to make those

19 kind of determinations, were you?
04:40:59
20 A.
That's correct.
21 Q.
In fact, when you tell this jury you --
22
THE COURT: Slow down, Counsel. Slow down.
23
MR. SCARDINO: I'm sorry. I'm wound up a
24 little bit.
04:41:05
25
THE COURT: That's all right. I know all about

2176
1 being wound up. Go on. Go on.

2 BY MR. SCARDINO:
3 Q.
When you tell this jury that you were concerned about
4 where the money came from to make these real estate

04:41:18
5 developments, to make the deals work, that was none of

6 your concern, was it?
7 A.
That's correct.
8 Q.
Mr. Stanford never once in the 16 years you worked
9 for him asked you to be responsible for that kind of

04:41:31
10 information?
11 A.
That's correct.
12 Q.
In fact, knowing where the money came from wouldn't
13 have helped you perform your job for Mr. Stanford at all,
14 would it have?
04:41:40
15 A.
No.
16 Q.
And in your 16 years of working there, the concern
17 didn't rise to the level where you said, I'm going to quit
18 because I don't know where this money is coming from, did
19 it?
04:41:51
20 A.
No.
21 Q.
In fact, you quit because you were tired of the
22 traveling?
04:42:18
23 A.
Yes.
24 Q.
When you were interviewed by the FBI, do you remember
25 when that was?

2177
1 A.
It's been over a year ago, I believe.
2 Q.
It's actually been a lot longer than that.
You've been interviewed twice, haven't
4 you?
04:42:29
5 A.
Yes.
6 Q.
Do you remember the first date being May 18th of
7 2010?
04:42:39
8 A.
That could be right.
9 Q.
And do you remember who the FBI agents were that
10 interviewed you?
11 A.
No, I do not.
12 Q.
Have you had an opportunity to look at reports that
13 the FBI generates when they interview you?
04:42:48
14 A.
No.
15 Q.
Prosecution hadn't given those to you before you came
16 here to testify?
17 A.
No.
18 Q.
Did anybody -- did the FBI, when they created the
19 report, provide you a copy to look at to see if it was

04:42:57
20 accurate?
21 A.
No.
22 Q.
Nobody's gone back over the interviews to say, Did we
23 get it right or not, Mr. Knoche?
04:43:07
24 A.
No.
25 Q.
Well, I'll tell you that we get a copy of that as

2178
1 part of the process here, and I'd like to ask you some
2 questions about what you may or may not have told the FBI
3 during those interviews.
04:43:16
4 A.
Okay.
5 Q.
Back -- do you remember the first interview in
6 May 18, 2008, that took place in Richmond -- the interview

7 took place in Richmond, Texas?
04:43:33
8 A.
2008?
9 Q.
No. I'm sorry. 2010.
10 A.
Okay.
11 Q.
May 18, 2010.
12 A.
Okay.
13 Q.
Okay. Before you had that interview, were you
14 contacted by the FBI?

04:43:41
04:43:46
15 A.
Yes. They called.
16 Q.
And asked you if you would talk to them?
17 A.
Yes.
18 Q.
And did you agree to do that?
19 A.
Yes.
20 Q.
Okay. And did you hire a lawyer?
21 A.
No.
22 Q.
And did they come over to your place of residence or
23 home to interview you?
04:44:10
24 A.
My home.
25 Q.
And what time of day or night was that?

2179
04:44:23
1 A.
It was in the afternoon.
2 Q.
And how many FBI agents arrived?
3 A.
There were three.
4 Q.
Did it make you nervous?
5 A.
No.
6 Q.
Not in the least?
7 A.
Oh, I guess, yes, a little bit. It doesn't happen
8 every day, no.

9 Q.
04:44:33
But you had three FBI agents at your house at
10 night -11 A.
That's correct.
12 Q.
-- asking you about something that you know that at
13 that time Mr. Stanford had been charged with a crime at

14 that time?
04:44:42
15 A.
Yes.
16 Q.
Had been arrested at that time?
17 A.
Yes.
18 Q.
Okay. And had been charged with all kinds of
19 evildoing?
04:44:50
04:44:56
20 A.
Right.
21 Q.
You were familiar with that?
22 A.
I was familiar with that.
23 Q.
Watched -- watched it all on the news; right?
24 A.
Yes.
25 Q.
And, in fact, I think you told them you were

2180
1 surprised when you first heard about it. The word you
2 used was "shocked"?
04:45:04
3 A.
Yes.
4 Q.
And you were shocked because the 16 years that you
5 were there, you never say anything that you thought was
6 criminal, did you?
7 A.
No.
8 Q.
And did you tell them -- do you remember telling them
9 that, when they -- when they asked you if Mr. Stanford was
04:45:14
10 a hands-on or hands-off guy and in his management style?

11 A.
What's the question?
12 Q.
Well, I mean -- well, your report says you told them
13 he was a hands-off guy?

14
04:45:32
MR. COSTA: I'll object to reading from the
15 report. It's not in evidence. It's hearsay.

16
17 BY MR. SCARDINO:
18 Q.
Do you remember telling them that he was a hands-off
19 guy?
04:45:37
20 A.
No.
21 Q.
You don't remember that? No?
22
MR. SCARDINO: I'll have to ask him.
23 BY MR. SCARDINO:
24 Q.
04:45:48
Does it refresh your memory -- show you a report you
25 say you have not seen before, dated May 18, 2010,
2181
1 interview with you by these FBI agents.

2
MR. COSTA: I'd object. First of all, I don't
3 think it establishes it was the same FBI agents.

4
04:46:05
THE COURT: Overruled. You can take him later.
5 BY MR. SCARDINO:
6 Q.
Second page I've highlighted it, so it's easy to see.
7 And in reference to answering the question about whether

8 or not Stanford had a hands-on or a hands-off approach to
9 managing -- management style, do you remember what you
04:46:17
10 told them?
11 A.
Okay. To managing myself and Larry Slater, when we
12 first started, he was not in our offices every day or

13 anything. So yes, in that connotation, he would have been
14 hands-off. But he knew what was going on.
04:46:30
15 Q.
Of course, he knew what was going on. He owned
16 everything, didn't he?

17 A.
That's correct.
18 Q.
I mean, he owned a hundred percent of all of the
19 companies?
04:46:39
04:46:45
20 A.
That's correct.
21 Q.
Do you know how many companies he owned?
22 A.
No.
23 Q.
It was over a hundred, wasn't it?
24 A.
I would not know.
25 Q.
You had no idea? Because you weren't hired to know

2182
1 that sort of thing, were you?

2 A.
No.
3 Q.
And then, Mr. Knoche, in August of 2011, you were
4 visited by the FBI again, weren't you?

04:46:58
5 A.
That's correct.
6 Q.
Do you recognize the FBI agent that interviewed you
7 in the courtroom?
8 A.
I don't remember who was there, because I've talked
9 to them since here.

04:47:09
10 Q.
Male or female agents?
11 A.
Both.
12 Q.
Okay. And do you remember them asking you in that
13 interview whether or not he had a hands-on or hands-off

14 approach to handling his companies?
04:47:20
15 A.
I don't recall that question.
16 Q.
Now, this would have been over a year later; right?
17 A.
Yes.
18 Q.
And you got the second visit.
19
04:47:31
Was it at your home again?
20 A.
Yes.
21 Q.
Page 4, second paragraph. Do you remember what you
22 told them when they asked you if he was a hands-on guy or

23 not?
04:47:51
24 A.
It says right there he was hands-on.
25 Q.
Hands-on.
2183
So after they spend 13 months between
2 times when they interviewed you, your position changes

3 somewhat about his management style, does it not?
4 A.
04:48:09
From what I was quoted there, one time I said
5 hands-off; one time I said hands-on.

6 Q.
During the interview process, was it a circumstance
7 where they said, Mr. Knoche, just tell us everything you

8 know, and they wrote it down, or was it a process where
9 they asked you specific questions, and you gave them
04:48:27
10 specific answers?
11 A.
I would say some of each. They said they wanted to
12 get background information, and they asked some specific

13 questions.
04:48:39
04:48:53
14 Q.
Okay. So you volunteered some information?
15 A.
Yes.
16 Q.
Did you take notes?
17 A.
No, I did not.
18 Q.
Did you record the conversation?
19 A.
No, I did not.
20 Q.
When they were talking to you about background
21 information -- we've talked about this a little bit -22 Mr. Stanford asked you to find residential properties such
23 as apartment complexes, and he specifically wanted a
24 certain amount of return on the investment, didn't he? Do
04:49:07
25 you remember that?

2184
1 A.
I don't remember the amount, but yes, he wanted to
2 have a certain amount of return of investment for the

3 partners.
4 Q.
04:49:15
I think you even testified on direct examination that
5 he was looking for a 10 percent return.

6
7 A.

No, I don't remember saying a specific amount.
MR. COSTA: The question was what he testified
9 to under direct examination.

04:49:34
10
THE COURT: Pardon me?
11
MR. COSTA: The question was what he testified
12 to under direct examination.
04:49:41
13
MR. SCARDINO: Said he didn't recall.
14
THE COURT: Said he didn't recall.
15
MR. COSTA: He didn't say.
16
THE COURT: Pardon me? Go on.
17 BY MR. SCARDINO:
18 Q.
Does it refresh your memory to look at the report
19 that was created by that interview about what Mr. Stanford

04:49:49
20 had asked you to do and what kind of return he was looking

21 for? Page 2, first paragraph. I've highlighted it.
04:50:08
22 A.
That was the range, yes, 10 percent.
23 Q.
Okay.
24 A.
I don't recall saying that specific amount, but
25 that's not wrong.

2185
1 Q.
Well, I mean, you don't think the FBI wrote down
2 something other than what you said, do you?
04:50:19
04:50:23
04:50:33
04:50:39
3 A.
No.
4 Q.
So is it safe to assume that's what Stanford asked
5 you to provide for him?

6 A.
Yes.
7 Q.
Were you able to do that?
8 A.
Yes.
9 Q.
How about the other fellow that interviewed for the
10 job? Was he also on board doing that?

11 A.
He stayed there about one year.
12 Q.
Was he successful?
13 A.
Yes.
14 Q.
Did he find real estate deals for Mr. Stanford the
15 way did you?

16 A.
Yes.
17 Q.
Did they provide a 10 percent return the way you did?
18 A.
Yes.
19 Q.
But he moved on?
20 A.
He moved on.
21 Q.
Okay. And then you go on to talk about how he funded
22 these various projects, do you not, with the -- in the

23 interview?
24
04:50:49
25 A.
Oh, you haven't reviewed your reports yet.

(No audible answer).
2186
1 Q.
Do you remember talking to the FBI about talking to
2 Mr. Stanford about how he was going to fund these

3 projects?
04:50:59
4 A.
I'm sure that was part of the conversation, yes.
5 Q.
Okay. And what did you tell them, if you recall?
6 A.
He said he had clients of the bank that were
7 interested in real estate in Texas.
04:51:08
8 Q.
Did that raise any red flags for you?
9 A.
No.
10 Q.
Create any problems for you?
11 A.
No.
12 Q.
And when you brought him real estate deals, tell us
13 generally about what kind of -- like the first deal that

14 you were able to bring him. You referred to it as a small
04:51:20
15 project.
16 A.
Yes.
17 Q.
Tell us about it. What kind of project?
18 A.
It was approximately 70 units in Southwest Houston in
19 the Montrose area, near Southwest Houston.

04:51:30
20 Q.
You say 70 units. What does that mean?
21 A.
70 apartments.
22 Q.
And was it one apartment complex with 70 apartments
23 in it?
04:51:37
24 A.
That's correct.
25 Q.
Okay. And how did you acquire that? How did you
2187
1 find that?
2 A.
We looked at all -- every apartment we could find
3 that was of interest that was for sale. And that had a
4 good location, had been very stable. They had a manager
04:51:53
5 that had been there for 22 years. And it was just very
6 stable clientele, and it looked like a good opportunity.
7 Q.
Okay. Now, as part of what you were doing for
8 Mr. Stanford, how would you learn about there particular

9 project being available? What due diligence would you
04:52:06
10 have to do?
11 A.
We drove the streets and look at reports. There's a
12 lot of reports issued about what is -- what is for sale.
04:52:18
13 Q.
Okay. And this was the first deal that came up?
14 A.
It probably was not the first one. It was the first
15 one that looked like a good opportunity.

16 Q.
Okay. And you took it to Mr. Stanford?
17 A.
Yes.
18 Q.
And you explained to him that you thought it was a
19 good deal?
04:52:26
20 A.
Yes.
21 Q.
And who put together -- who closed the deal? Was it
22 you or Mr. Stanford? Who did the paperwork?
04:52:35
23 A.
I did.
24 Q.
You did? Okay.
25
And after it was acquired, what was the

2188
1 company that actually acquired this property?
04:52:47
2 A.
Guardian I Limited, Limited Partnership.
3 Q.
And who owned that?
4 A.
It was owned by -- the general partner was Guardian
5 International Investment Services, and then there were a

6 number of limited partners.
7 Q.
Okay. And it was funded by these limited partners;
8 right?
9 A.
04:52:59
10 Q.
That's correct.
And if you put a deal together that they couldn't get
11 all the money together to close it, Mr. Stanford came up

12 with the balance of the money?
04:53:10
13 A.
That's correct.
14 Q.
And you never knew where that money came from; right?
15 A.
That's correct.
16 Q.
And that wasn't part of what you were paid to know or
17 do, was it?
04:53:17
18 A.
That's correct.
19 Q.
Not in the 16 years that you worked there?
20 A.
No.
21 Q.
And you also talk about in your report to the FBI
22 that Mr. Stanford asked you to head up a construction

23 effort in Antigua?
04:53:31
24 A.
Yes.
25 Q.

2189
And what was the reason for that,
2 Mr. Knoche?
04:53:41
3 A.
He had projects he wanted to build there.
4 Q.
Okay. And was this after you had finished working on
5 developing the projects here, or were you doing it at the

6 same time?
04:53:49
04:53:54
7 A.
At the same time.
8 Q.
So you were traveling a lot, weren't you?
9 A.
Yes.
10 Q.
Married at the time?
11 A.
Yes.
12 Q.
Children?
13 A.
Yes.
14 Q.
Pretty tough duty, huh?
15 A.
Yeah, yes.
16 Q.
Working hard, but you were making good money; right?
17 A.
Yes.
18 Q.
And did you have a lot of interaction with
19 Mr. Stanford during all of this?

04:54:01
20 A.
Sure, yes.
21 Q.
I mean, you would come to him, you'd bring him deals,
22 and he would respond to them, y'all put it together. And

23 he was happy; you were happy?
04:54:09
24 A.
Yes.
25 Q.
And then he asked you to expand this, basically the

2190
1 same operation, into the Island of Antigua; right?

2 A.
That's correct.
3 Q.
And how long were you working for him when he asked
4 you to actually make that step, to go to this little

04:54:21
5 island out in the Atlantic?

6 A.
I started traveling to Antigua in the early 1990s, so
7 I had been there two, three years.

8 Q.
And how many people were working under you at the
9 time?
04:54:34
10 A.
In Texas, there would have only been, at the
11 apartments, maybe 15 total.

12 Q.
Okay. And how about when you went to Antigua. And
13 how many were working under you then?

14 A.
04:54:50
We eventually got up to where there was probably 250
15 employees of Stanford Development Company there.

16 Q.
And so, did he tell you why he wanted you to go to
17 Antigua? What was the general plan for you there?

18 A.
Well, he had confidence in me, and he wanted me to
19 head up the construction there.

04:55:01
20 Q.
21
And what were you to construct?

So you go from acquiring real estate to
22 getting into a construction business; right?

23 A.
Yes. Now, in Texas, we had also built things. We
24 had built the houses.

04:55:12
25 Q.
And you built the place over by the baseball park;

2191
1 right?
04:55:24
2 A.
Yes. That was much later, but yes.
3 Q.
Were all the real estate investments successful?
4 A.
Yes, moderately. Only one of them was very, very
5 successful. The others were moderately successful.

6 Q.
So it was smart of Mr. Stanford to get into real
7 estate at that time, and he got the right guy with you to
8 help him find the properties and acquire them?
9 A.
04:55:34
10 Q.
Yes.
Never a loss on any of the properties that you put
11 together?
12 A.
No.
13 Q.
Never a problem with funding of these properties with
14 Mr. Stanford?
04:55:40
15 A.
No.
16 Q.
Never a problem with somebody coming back and saying,
17 This was a bad deal, this was a fraud or this wasn't what
18 it was supposed to be?
04:55:48
19 A.
Nau-uh.
20 Q.
No misrepresentations that you know of in any of the
21 real estate transactions in the 16 years you worked for

22 Mr. Stanford?
04:55:59
23 A.
No.
24 Q.
Okay. Now, you got into some construction business,
25 and you built some projects while you were here. And he
2192
1 asked you to move to Antigua and build some projects there

2 and get into construction?
04:56:10
3 A.
That's correct.
4 Q.
Okay. Now, what kind of construction? What did he
5 want you to build there?

6 A.
The first thing we built was a new headquarters
7 building for the Bank of Antigua.

8 Q.
Okay. Now, the Bank of Antigua, was that a bank that
9 Mr. Stanford owned?

04:56:18
04:56:27
10 A.
Yes.
11 Q.
Was he the 100 percent shareholder that I would?
12 A.
As far as I know.
13 Q.
And you were asked to build a new facility?
14 A.
That's correct.
15 Q.
And did you have to acquire property to do that?
16 A.
I think he had already purchased the land. There was
17 about three acres of land at the airport, and he -- he had

18 purchased that from the government.
04:56:43
19 Q.
Why was he on the Island of Antigua, if you know?
20 A.
He wanted to move from Montserrat because he said it
21 was too small, and he just said he had looked at numerous,

22 and Antigua was one that he thought was the best
23 opportunity for him.
04:56:57
24 Q.
He had a plan, didn't he?
25 A.
Yes.
2193
1 Q.
I mean, he didn't just float by one day and say, This
2 looks like a good place to stop?
04:57:06
3 A.
No.
4 Q.
He had done some homework, hadn't he?
5 A.
Yes, he had.
6 Q.
In fact, he was a visionary in that regard, wasn't
7 he?
04:57:12
8 A.
Yes.
9 Q.
He was an entrepreneur, wasn't he?
10 A.
He was definitely an entrepreneur.
11 Q.
He started businesses, didn't he?
12 A.
Yes.
13 Q.
Okay. And he had guys like you helping him do it,
14 didn't he?
04:57:18
15 A.
Yes.
16 Q.
And his idea on Antigua was to build what? Not just
17 to build a bank, was it?
04:57:33
18 A.
No. Best in the world atmosphere.
19 Q.
Best in the world atmosphere.
20
Did he tell you that?
21 A.
Yes.
22 Q.
And what did that mean to you, "Best in the world"?
23 A.
Just what it -- just what it says. He wanted to she
24 better -- as good or better than anything anywhere else.

04:57:44
25 Q.
Why? Why not just okay? Why not just adequate?

2194
1 A.
That was his style.
2 Q.
And did he have a plan that the best in the world --
3 well, the best in the world would be expensive, wouldn't

4 it?
04:57:59
5 A.
Yes.
6 Q.
It would cost more money than just moderate, wouldn't
7 it?
04:58:03
8 A.
That's correct.
9 Q.
Or just average?
10 A.
Yes.
11 Q.
Did you understand there was a reason why
12 Mr. Stanford wanted the, quote-unquote, best in the world?
04:58:11
13 A.
Yes.
14 Q.
Was there a motive behind it?
15 A.
He wanted to show that that could be done in the
16 Caribbean.
17 Q.
And was that because it generally wasn't done in the
18 Caribbean?
04:58:19
19 A.
That would be fair to say, yes.
20 Q.
And why was it important to him, if you know, that it
21 be done from the Caribbean, the best in the world could be

22 accomplished there?
04:58:30
23 A.
That was just his vision.
24 Q.
Well, wasn't -- didn't he have an idea that he wanted
25 to develop that island in such a way to attract people to

2195
1 come there?
2 A.
Yes.
3 Q.
So it wasn't just building something for himself that
4 he could look at or take a picture of himself standing in

04:58:44
5 front of it.
6
04:58:50
He had another plan, didn't he?
7 A.
Yes.
8 Q.
Didn't he explain that to you?
9 A.
Yes.
10 Q.
Okay. What was the plan?
11 A.
That was -- that for the arriving clients of Stanford
12 International Bank, they would see something that they had

13 never seen something before their life, and they would be
14 so attracted to Antigua that they would tell all their
04:59:03
15 well-to-do friends, and everybody would have confidence in

16 Stanford International Bank on the Island of Antigua.
04:59:16
17 Q.
Well-to-do friends?
18 A.
Yes.
19 Q.
He wasn't catering to guys like you and me, was he?
20 A.
No.
21 Q.
"High net worth" was the terminology?
22 A.
"High net worth" was the terminology.
23 Q.
High net worth. So the high-net-worth people would
24 have been attracted to places where they could land their

04:59:25
25 private jet -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2196
1 A.
That's correct.
2 Q.
-- wouldn't they?
And what you were shown by the government
4 earlier -- and I don't remember which exhibit it was, but

04:59:35
5 it was the one where they were showing a hangar, and it

6 was -- it wasn't for public use; it was for private use?
04:59:44
7 A.
That's correct.
8 Q.
Did you build that?
9 A.
Yes.
10 Q.
Okay. And was that so that the high-net-worth people
11 would have a place to land their private jets?

12 A.
Land and be able to clear immigration and customs
13 right there. They didn't have to stand in line.
04:59:53
14 Q.
And did you build it?
15 A.
Yes.
16 Q.
So if someone would say not a brick was laid
17 regarding Mr. Stanford's grand plan, that's just not true,

18 is it? Bricks were laid; right?
05:00:04
19 A.
Yes.
20 Q.
Buildings were built, weren't they?
21 A.
Yes.
22 Q.
Built a fabulous marina that was with cost -- there
23 was no limit to the cost to that --
05:00:14
24 A.
I was gone when the marina was built.
25 Q.
When Barnacle Point was built? You saw a picture of

2197
1 it?
2 A.
I saw a picture of it.
3 Q.
I mean, do you have any question in your mind that it
4 wasn't built with the best of the best products and

05:00:26
5 finishes?
6 A.
I have -- I'm sure it was.
THE COURT: Pardon me?
THE WITNESS: I am sure it was built with the
9 best products.
05:00:31
10 BY MR. SCARDINO:
11 Q.
And you still had no idea where the money came from
12 to develop these projects, did you?
05:00:47
13 A.
No.
14 Q.
What are -- what other developments did you build?
15 What others projects did you have in Antigua besides the

16 airport and the bank? What else?
17 A.
Well, there were several specific ones at the
18 airport, and there's also a housing development called

19 Cedar Valley Springs.
05:01:00
20 Q.
Did you build that?
21 A.
Yes.
22 Q.
Describe that for the jury.
23 A.
That was a like a U.S.-style subdivision. It had an
24 entrance, one entrance, and it had a little water feature,

05:01:11
25 and it had individual lots, and we built houses on the

2198
1 individual lots.
2 Q.
Okay. And did you actually build houses?
3 A.
Built them -- when I left, we had built some of them,
4 not all of them.

05:01:21
5 Q.
How many did you build?
6 A.
Probably when I was there, 20.
7 Q.
And how many were left to be built in the development
8 plan?
9 A.
05:01:30
Probably about that same number. It was probably
10 about half built when I was -- when I left.

11 Q.
So about 40.
12
05:01:44
Do you know if it was completed or not?
13 A.
I do not know.
14 Q.
You told the jury that sometime during the time that
15 you were working for Mr. Stanford, he hired a guy named

16 Jim Davis or James Davis?
05:01:53
17 A.
That's correct.
18 Q.
Okay. And that they were old college chums?
19 A.
That's what I was told.
20 Q.
And they made -- Mr. Davis to be -- you said, the
21 CFO; right?
22 A.
That's my recollection. He was the chief financial
23 officer.
24 Q.
05:02:07
Okay. Can you tell the jury just briefly what a
25 chief financial officer does?

2199
1 A.
They're responsible for the overall accounting
2 function. They make -- be sure everything is paid, the

3 bills are paid, payroll is met. And then they're
4 responsible for the preparation the of financial
05:02:18
5 statements that are presented to the owner.

6 Q.
They're in control of the money; right?
7 A.
They, in conjunction with other management. They're
8 not -- they're not specifically in charge of the money.

9 Q.
05:02:33
Well, I mean, you have a treasurer, right, in most
10 companies?
11 A.
In most companies. In this one, there was not a
12 treasurer.
05:02:41
13 Q.
What's a controller?
14 A.
Controller would be usually right below the chief
15 financial officer, and they do more of the day-to-day

16 work. The chief financial officer is overseeing. The
17 controllers are the day-to-day.
18 Q.
And didn't you tell the FBI that when Mr. Stanford
19 hired Mr. Davis as -- I think you told them a controller

05:02:55
20 instead of a chief financial officer, but doesn't make

21 much difference one way or the other whether it was
22 controller or chief financial officer?
23 A.
Well, he replaced a controller. I think -- I think
24 when James Davis came in, his initial title was chief
05:03:07
25 financial officer, but I'm not positive of that.

2200
1 Q.
But were you put out that you weren't hired to be the
2 controller or chief financial officer?
05:03:16
3 A.
No.
4 Q.
I mean, you had previously been a controller; right?
5 A.
Yes, but I was not put out.
6 Q.
Okay. Why would that be an issue that the FBI would
7 ask you about then?

8 A.
They just asked the questions.
9
05:03:26
MR. COSTA: Object to the speculation, Your
10 Honor.
11
12 BY MR. SCARDINO:
13 Q.
You talked about -- in your interview with the FBI
14 about how much Mr. Stanford loved real estate development;

05:03:46
15 right?
16 A.
Yes. When he got involved in a project, he very much
17 enjoyed it.
05:03:56
18 Q.
Compulsive in what he did?
19 A.
I wouldn't use the word "compulsive. Extremely
20 interested in -- I'm not sure what word. I wouldn't say

21 "compulsive."
22 Q.
Well, I mean, he -- he wanted to make sure things
23 were done correctly; right?
05:04:05
24 A.
Yeah. Absolutely, yes.
25 Q.
Best of the best?

2201
1 A.
Yes.
2 Q.
And if it wasn't done to his specifications, like
3 with the way the floor was finished that you talked about,
4 he made sure that it was changed to his specifications?
05:04:15
5 A.
Yes.
6 Q.
Okay. So he was insistent that things be done in the
7 manner that he wanted it done?
05:04:23
05:04:30
8 A.
Yes.
9 Q.
And he could be difficult in that regard, couldn't
10 he?
11 A.
That's correct.
12 Q.
He demanded it to be the best of the best?
13 A.
He did.
14 Q.
Okay. And let's talk a little bit how you -- you
15 told the jury earlier that Mr. Stanford asked you to go to

16 Mexia, Texas -- and I've always pronounced it Mexia, I've
17 heard Mexia, but I mean, I'm from here --
05:04:44
18 A.
I understand it's Mexia.
19 Q.
I think it is Mexia. But whatever.
20
Did you go to Mexia?
21 A.
I did.
22 Q.
And about how long had you been working for him when
23 you went there?

24 A.
05:04:53
That was before I ever started. That was the
25 initial -- the second interview.

2202
1 Q.
Okay. So there was a reason why he asked you to go
2 there during the interviewing process, wasn't it?
05:05:01
3 A.
Yes.
4 Q.
And what was that reason?
5 A.
Well, these three gentlemen were the board of
6 directors.
05:05:10
7 Q.
He wanted you to meet the board of directors?
8 A.
Yes.
9 Q.
Before he hired you?
10 A.
Yes.
11 Q.
Okay. And how about the other fellow that was being
12 interviewed? Did he ask him to go also to Mexia?

13 A.
He must have. I was not there at the same time, but
14 he -- I'm sure he did.

05:05:20
05:05:32
15 Q.
And did you go meet these guys?
16 A.
Yes.
17 Q.
And tell us who they were again?
18 A.
James Stanford.
19 Q.
Let's stop there. Who was James Stanford?
20 A.
Allen Stanford's father.
21 Q.
And what kind of business was Mr. Stanford in; do you
22 know?
23 A.
He said he had been mayor of Mexia for many years,
24 and he was also in the insurance business.

05:05:41
25 Q.
Did he talk about his father at all?

2203
05:05:51
1 A.
Lotus Stanford.
2 Q.
And what did he tell you about his father?
3 A.
He just said he was --
MR. COSTA: Object to hearsay, Your Honor.
By the way, sometimes things can be
7 technically hearsay, something said, you know, by a third

8 party or out of the hearing of anyone here for the truth of
9 what was said. The judge in federal court has some
05:06:05
10 flexibility that even though technically it might be to

11 allow it in. I'm just electing to do so here.
12
Go on.
13 BY MR. SCARDINO:
14 Q.
05:06:14
You can answer. What did he tell you about his
15 father, Lotus?
16 A.
I don't recall him saying anything specific about
17 what business. He was a successful person, but I don't

18 know what -- how he --
05:06:22
19 Q.
Don't know what kind of business it was?
20 A.
No, I don't.
21 Q.
Don't know if it had any financial services attached
22 to it at all?
23 A.
I suspect it did, but, I mean, I don't know
24 specifically what type of financial services.

05:06:29
25 Q.
Okay. And who else on the board did you meet?

2204
05:06:37
1 A.
Bill Goswick.
2 Q.
Let's talk about him for a minute. You met him?
3 A.
Re.
4 Q.
Did you learn something about him?
5 A.
He was a car dealer. He owned a car dealership in
6 Mexia.
05:06:44
7 Q.
Anything else?
8 A.
Not that I recall.
9 Q.
And who else was on the board that you met?
10 A.
Don Caldwell.
11 Q.
Tell me who he was and what he did.
12 A.
They called him -- he was a judge. I do not know a
13 judge in what court, but he was a judge.
05:06:54
14 Q.
And so he was a lawyer?
15 A.
Must have been lawyer, yes.
16 Q.
And did you talk to him and find out anything about
17 his background in business or finance?
05:07:04
18 A.
No.
19 Q.
Wasn't there a British barrister also on the board?
20 A.
In later years.
21 Q.
Did you get to meet that person?
22 A.
That was Kenneth Allen. In later years I met him,
23 yes.
24 Q.
05:07:13
So the board consisted of Mr. Stanford, Allen
25 Stanford's father, a gentleman who was in business in a

2205
1 car dealership, a judge and a lawyer, and a British

2 barrister or a lawyer consisted of the board of directors?
05:07:28
3 A.
That's correct.
4 Q.
Was there anything, I think the word's been used,
5 untoward about any of that that you saw?

6 A.
No.
7 Q.
So you didn't just reel away and go, this doesn't
8 smell right to me. After you went to Mexia, it was

9 something that you said, okay, let's go with this?
05:07:40
10 A.
That's correct.
11 Q.
And you did?
12 A.
Yes.
13 Q.
Okay. When you were in the island of Antigua
14 working, did you ever have an opportunity to work with

05:08:06
15 Mr. Stanford on how he acquired some of the properties?

16 A.
Yes. He acquired almost everything from the
17 government.
05:08:16
18 Q.
From the government of Antigua?
19 A.
From the government of Antigua.
20 Q.
And that would have required him to do some
21 negotiating with the government; right?
05:08:23
22 A.
Yes.
23 Q.
And were you with him when he was doing that?
24 A.
Some of the times.
25 Q.
Mr. Knoche, when -- I'll find this in a minute.

2206
Did you find when you were dealing -- when
2 you were working with Mr. Stanford and he was dealing with
3 the government in trying to acquire these properties, was
4 there anything about that process that concerns you or
05:09:01
5 made you say, hey, I need to quit this business and leave
6 the island?
7 A.
No, these dealings with the government were very
8 normal.
9 Q.
05:09:12
And so, you would say they were arm's length
10 transactions?
11 A.
They were arm's length transactions.
12 Q.
And during that process, did it require him to
13 purchase some lands?
05:09:19
14 A.
Yes.
15 Q.
Did it require him to lease some lands?
16 A.
Yes.
17 Q.
Did it require him to get some sort of variances to
18 do what he wanted to do from the regulations?

19 A.
05:09:34
There were some building permit issues, if that's
20 what you're speaking of -21 Q.
Right.
22 A.
-- as far as variances. Yes, there were building
23 permit issues.
24 Q.
05:09:42
And so, did he negotiate that or did you negotiate
25 that or how did that process work?

2207
1 A.
The land sales and the land leases, he would have
2 been the primary one. He asked me to do certain things in

3 conjunction with it.
4
05:09:53
MR. SCARDINO: Your Honor, at this time I'd
5 offer Defense Exhibit Number 6-1. I provided the

6 government with a copy.
7
THE COURT: Any objection?
(Attorneys conferring.)
9
05:10:31
THE COURT: While they're talking, any problem
10 going through to 6:00 o'clock today? Anybody need to take

11 a break? Everybody okay?
12
All right. Let's go.
13
MR. COSTA: I don't have an objection, Your
14 Honor. Some of these were after Mr. Knoche worked for the
05:10:46
15 company.
16
THE COURT: 6-1 is admitted.
17
MR. SCARDINO: There we go. Can you make it
18 any clearer than that? Go to the next page, please. There

19 you go. Can you go to the top of the page, please, with
05:11:09
20 the seal. And highlight that for me.

21 BY MR. SCARDINO:
05:11:16
22 Q.
Can you see that, Mr. Knoche?
23 A.
Yes, I can.
24 Q.
Now, this was something that happened after you were
25 there; wasn't it?

2208
1 A.
Yes. I was gone in 2005.
2 Q.
Okay. Well, let's move on from that.
When was it -- you were there in 2003,
4 weren't you?
05:11:26
5 A.
6
I left at the end of June of 2003.

MR. SCARDINO: Okay. Let's go to the next
7 page, then. And at the very top of the page. If you'd

8 highlight that.
9 BY MR. SCARDINO:
05:11:38
10 Q.
Can you see what that is, Mr. Knoche?
11 A.
Yes. Executive cabinet decision in the cabinet of
12 Antigua and Barbuda.

13
MR. SCARDINO: And let's go down to the next
14 underlined portion.
05:11:49
05:11:56
15 BY MR. SCARDINO:
16 Q.
Purchase of government lands. Do you see that?
17 A.
Yes, I do.
18 Q.
Would you read that for us, please.
19 A.
"Purchases of government lands, conversion of
20 leaseholds to freeholds, purchase of a damaged warehouse,

21 the management and operation of the V.C. Bird
22 International Airport, airport development and
23 construction of a fixed base operation at the airport by
24 Stanford Development Company, Limited."
05:12:11
25 Q.
What is a fixed base operation?

2209
1 A.
That's the terminology for private hangars or private
2 planes land as opposed to commercial airlines.

3 Q.
And then the next paragraph, please, starting with
4 "Cabinet discussed." If you would read that for us,

05:12:30
5 please.
6 A.
"Cabinet discussed the enormous benefits brought to
7 the country by the airport project being developed by

8 Stanford Development Company, Limited. In this regard,
9 there are several matters pending that are essential for
05:12:41
10 the completion of the airport project. Thus, the cabinet

11 agrees and orders as follows."
12 Q.
Okay. And have you had an opportunity to look
13 through any of these types of notes that were generated by

14 the Antiguan government, Mr. Knoche?
05:12:58
15 A.
Yes, I'm familiar with those.
16 Q.
Okay. So there are numerous transactions between
17 Allen Stanford and Antiguan government to acquire

18 property, raw and improved land for Mr. Stanford's
19 development purposes, was there not?
05:13:15
20 A.
Primarily raw land. I don't recall any improved
21 land, but there may have been some minor improvements on

22 some of it.
05:13:25
23 Q.
Was there a hospital that they were building?
24 A.
They wanted to build a hospital.
25 Q.
Yes, sir. That was the intent; right?

2210
1 A.
That was the intent.
2 Q.
How about a desalination plant. Was that a part of
3 it, also?
4 A.
05:13:36
I don't recall being involved in a desalination
5 plant.
6 Q.
Never was part of any project in that regard?
7 A.
At the airport for the Stanford properties, we had a
8 waste treatment facility, but I don't recall that we had a

9 desalination plant.
05:13:50
10 Q.
And did these projects actually come to fruition?
11 Were they built? The Stanford -- how about the Antiguan

12 Bank, was that built?
05:14:04
05:14:13
13 A.
The Bank of Antiguan building was built.
14 Q.
Okay. What other buildings did you build for
15 Mr. Stanford on that island?

16 A.
The Stanford International Bank building.
17 Q.
That's separate from the Bank of Antigua?
18 A.
That's correct, it's two separate buildings.
19 Q.
In fact, Mr. Stanford took over the Bank of Antigua,
20 did he not? Was a bank there?

21 A.
He purchased the Bank of Antigua.
22 Q.
He purchased it.
23
And was -- do you know if it was failing
24 at the time he took it over?

05:14:21
25 A.
I think -- I don't know if it was specifically

2211
1 failing. It was in bad shape, I believe.

2 Q.
Did he put some capital in it to make it work?
3 A.
Yes, he must have. I wasn't in -- I never saw the
4 financial statements for Bank of Antigua, but he must

05:14:33
5 have, yes.
6 Q.
It was still there and up and running when you left,
7 wasn't it?
05:14:39
8 A.
Yes, it was.
9 Q.
As far as you know, it still is, isn't it?
10 A.
As far as I know, it still is.
11 Q.
What else did he build there?
12 A.
A building for Stanford Trust Company, the Sticky
13 Wicket Restaurant and Bar --
05:14:48
14 Q.
Okay.
15 A.
-- the cricket field. And when I left, there were
16 two projects under construction, the Pavilion Restaurant

17 was under construction and the Antigua Athletic Club was
18 under construction.
05:15:04
19 Q.
Were these projects inexpensive projects?
20 A.
No.
21 Q.
Were they very expensive projects?
22 A.
They were very expensive projects.
23 Q.
Would you say that hundreds of millions of dollars
24 were spent on developing projects on the island of Antigua

05:15:17
25 by Allen Stanford?
2212
1 A.
When I left, it would not have been in the hundreds
2 of millions, it would have been in the tens of millions,

3 but probably after that it became the hundreds of
4 millions.
05:15:26
5 Q.
And that was -- why would it have become hundreds of
6 millions?
7 A.
I assume they continued to build things. They
8 finished off the Pavilion. They built Barnacle Point.

9 I'm sure they built other things.
05:15:37
10 Q.
Plus you can book one thing as you buy it as book
11 value and then later as market value as you get licenses

12 and promote it; right?
05:15:47
13 A.
Say that question again.
14 Q.
Well, I mean, you buy a piece of property and you put
15 it on your books at book value, what you paid for it, and
16 then later after you get licenses and promote it and
17 develop it and get infrastructure there, you can list it
18 as market price; right?
19 A.
05:16:01
No, not to my knowledge. I don't think that's
20 correct.
21 Q.
But at any rate, what he built there was a benefit
22 for the island, wasn't it?
05:16:08
23 A.
Yes.
24 Q.
It provided jobs?
25 A.
Oh, yes.
2213
05:16:13
1 Q.
A lot of jobs?
2 A.
A lot of jobs.
3 Q.
And improved the island considerably; right?
4 A.
Yes.
5 Q.
You said that you built something called the Sticky
6 Wicket. And Mr. Costa, the prosecutor, talked to you

7 about that a little bit.
8
What was the purpose of the Sticky Wicket;
9 do you know?
05:16:27
10 A.
It was part of the big picture. It would be a place
11 where the clients would -- everybody. It was a fun place.

12 It was a sports bar type of place that featured cricket.
13 And cricket is the number one sport in Antigua.
05:16:44
05:16:51
14 Q.
Is cricket a sport all around the world, isn't it?
15 A.
Yes.
16 Q.
I mean, in fact, it's big in England and India?
17 A.
It is.
18 Q.
South America?
19 A.
It's extremely popular in some places.
20 Q.
Did you know whether or not they had a ticket --
21 ticket -- cricket team -- hard to say -- a cricket team on

22 the island?
23 A.
Well, there was little club teams, and they were part
24 of the West Indies team. The West Indies played as a

05:17:07
25 whole in the international competitions. When they played

2214
1 England, they would play as the West Indies, not as

2 Antigua.
05:17:13
3 Q.
And they were good, weren't they?
4 A.
Yes.
5 Q.
In fact, they beat teams around the word, didn't
6 they?
7 A.
In their early -- past decades, especially, they were
8 extremely strong.
05:17:23
9 Q.
And do you understand how cricket is played?
10 A.
I've watched the matches, but I can't say I
11 understand the sport that well, but it's -- I've watched

12 some.
13 Q.
They don't run around bases like we do, they run up
14 and down -05:17:34
15 A.
They run back and forth.
16 Q.
And a sticky wicket is a spot where -- a wicket
17 that's hard to hit or knock down?
05:17:41
18 A.
Yes.
19 Q.
Understand that?
20 A.
21 Q.
So Mr. Stanford built this facility, the sports
22 facility, called the Sticky Wicket, and he built a big

23 cricket field next to it. Have you seen pictures of it?
05:17:54
24 A.
I was there.
25 Q.
Did you build it?

2215
1 A.
Yes.
2 Q.
Okay. And next to it, he built a health club
3 facility; right?
05:18:02
4 A.
Yes. That was under construction when I left.
5 Q.
Was there -- did he change his philosophy when he was
6 building all this? Did he decide it shouldn't be the best

7 of the best?
05:18:09
8 A.
No.
9 Q.
Was the best of the best?
10 A.
Best of the best.
11 Q.
So did he tell you what his idea was in investing all
12 of these tens of millions of dollars in things like the

13 Sticky Wicket and the cricket field?
14 A.
05:18:19
It was all -- just like he explained in that talk he
15 gave, that's part of the big picture. It was to make it a

16 world-class destination.
05:18:28
17 Q.
Anything fraudulent about that, Mr. Knoche?
18 A.
No.
19 Q.
Do you have any problems with that? Did you run away
20 from the island when he told you what he was going to do

21 in that regard?
22 A.
No.
23 Q.
Did it seem like a good idea to you that a guy with
24 Mr. Stanford's vision and money that investing in a sports

05:18:38
25 franchise like that might pay off big later if it worked?

2216
1 A.
I'm not sure I ever thought it was going to pay off
2 big, no.
05:18:50
3 Q.
Did you ever hear of a guy named Tex Schramm?
4 A.
Yes.
5 Q.
He bought a sports franchise?
6 A.
Sports franchise. Yes, it's not possible -- not
7 impossible. Many sports franchises achieve.
05:19:00
8 Q.
Turned out pretty good, didn't it, for Mr. Schramm?
9 A.
Yes.
10 Q.
Okay. So would it be consistent or inconsistent with
11 what you knew about Mr. Stanford in the 16 years that you
12 worked for him that he would be the kind of guy that would
13 invest tens of millions of dollars in a sports franchise
14 that had the opportunity maybe to make him a whole a lot
05:19:13
15 of money later or maybe not make any money at all?

16 A.
Now, the involvement in cricket was after my time. I
17 mean, we built a cricket field. But I just read in the

18 newspapers what he did as far as having a cricket team and
19 all that. That was after my time.
05:19:25
20 Q.
You didn't know about the tournament he put on with
21 the prize money he put up of $20 million?

22 A.
That was after my time.
23 Q.
That was after.
24
05:19:32
25 A.
Did you follow that, though?

I read about it some in the newspaper.
2217
1 Q.
Okay. But you knew what he was up to when you were
2 reading about all that? He was promoting the sport on the

3 island, wasn't he?
05:19:41
4 A.
Yes.
5 Q.
And he actually changed it so that the game was
6 shorter, the whole idea was to -- because cricket matches

7 can last for days; right?
8 A.
I didn't -- there was two types -- there was always
9 two types of cricket, the full -- whatever they call it -05:19:53
10 match, and then they had some condensed ones that were -11 but I think that concept was always there.
12 Q.
So he -- when he had you build all these structures,
13 the whole idea was to promote cricket. And, actually,

14 were you there when he was negotiating with the sports
05:20:06
15 authorities for television rights and marketing rights for

16 the team?
05:20:13
17 A.
No.
18 Q.
You didn't have anything to do with any of that?
19 A.
Nothing to do with any of that.
20 Q.
You strictly were acquiring land and developing land?
21 A.
That happened -- those things you mentioned happened
22 after I left, yes.

23 Q.
And were you -- you were there when he was talking
24 about building the Island Club; right? He talked to you

05:20:28
25 about that?
2218
1 A.
What is the Island Club?
2 Q.
The Island Club. The development for the
3 billionaires to have a place to stay, a place to dock

4 their yachts and land their jets.
05:20:38
5 A.
I never heard it called that.
6 Q.
What did you hear it called?
7 A.
There was a marina at Barnacle Point that he was
8 going to build, but I never heard of the terminology

9 Island Club.
05:20:47
10 Q.
But you heard of the idea from Mr. Stanford that what
11 his idea was was to build a place for some of the richest
12 people in the world to come and do whatever they do?
05:20:58
13 A.
A resort, yes.
14 Q.
A resort?
15 A.
Yes, he always had a vision of --
16 Q.
You knew about that?
17 A.
I knew about his vision for a world-class resort.
18 Q.
And he was acquiring property on and near -- on the
19 islands near the island of Antigua to accomplish that,

05:21:08
20 wasn't he?
21 A.
When I left, he was negotiating, as I recall, for the
22 Guana Island area.

23 Q.
And did he ever acquire any of the islands for this
24 dream as a resort for billionaires? Did he acquire

05:21:24
25 property while you worked for him?

2219
1 A.
I don't -- I'm not sure. He was close probably, but
2 I don't remember if he acquired Guana Island and the land

3 around it before I left or not.
4 Q.
05:21:39
Mr. Knoche, how long did Allen Stanford talk to you
5 while you worked for him about this idea of a resort for
6 billionaires?
05:21:53
7 A.
The last few years.
8 Q.
So it wasn't just an overnight thing?
9 A.
No.
10 Q.
Did you have any idea of how he planned to structure
11 that, whether or not it was going to be something like a

12 club as opposed to a high-end place for people to come and
13 have their own home?
14 A.
05:22:07
I think he was looking at all possibilities where
15 people would buy into a club and people were -- and

16 another possibility where people -- it was strictly a
17 resort. They would come there and pay their money and
18 then leave.
19 Q.
05:22:17
While you were there, I mean, did he -- did you see
20 him spend tens of millions of dollars on architecture

21 plans, hiring architects to come in and help him design?
22 A.
Certainly millions and maybe tens of millions. But I
23 don't think tens of millions. I would say when I was

24 there millions of dollars, but then -05:22:31
25 Q.
On architecture plans?
2220
05:22:39
1 A.
On architecture plans.
2 Q.
For the wealthy people to come?
3 A.
Yes.
4 Q.
So it wasn't just a dream, was it?
5 A.
No. He was planning.
6 Q.
Spent a lot of money on it, didn't he?
7 A.
Yes.
8 Q.
How about people that come in and build a
9 infrastructure with information technology and things of

05:22:48
05:22:57
10 that nature there for this club for the rich people?
11 A.
I'm not familiar with that.
12 Q.
You didn't know anything about that?
13 A.
No.
14 Q.
But because of what you did, you were familiar with
15 some of the work that he had done regarding engaging the

16 services of architects?
17 A.
Yes.
18 Q.
Are you familiar with the firm he hired out of
19 New York for that purpose?

05:23:03
20 A.
Out of New York? No.
21 Q.
What firms are you familiar with that he used in that
22 regard?
23 A.
He used two from Houston, Watkins, Hamilton & Ross
24 and Jackson & Ryan, and then there was some firm in
05:23:18
25 Florida that I don't recall the name.

2221
1 Q.
And how far did they get when you were there that you
2 know of in helping him design plans for this club for the
3 rich people?
4 A.
05:23:30
I don't recall very far along at all when I was still
5 there.
6 Q.
But you know he had been talking about it and working
7 on it for years?
05:23:37
8 A.
Yes.
9 Q.
Let me shift gears on you for a minute.
10
Mr. Costa, the prosecutor, showed you some
11 information about -- from some of the annual reports that

12 Mr. Stanford had produced and information of that nature.
13
Are you familiar with IFRS? Do you know
14 what that is?

05:23:59
15 A.
It's international financial reporting system or
16 something like that.

17 Q.
Okay. I think that's close enough.
18
05:24:10
So you are somewhat familiar with it?
19 A.
Yes.
20 Q.
What is it that you understand?
21 A.
Well, the United States has its own what call GAAP,
22 accepted accounting principles. Great Britain has also

23 their GAAP. It's international. I never dealt with it.
24 But it's a body that oversees some of the other countries
05:24:27
25 or some of the other locations in the world besides the

2222
1 United States and Great Britain.

2 Q.
So you're not familiar with their reporting
3 requirements?
05:24:36
4 A.
No.
5 Q.
So when Mr. Costa asked you questions about whether
6 or not Mr. Stanford reported some loans to shareholders on

7 financial statements, you do know that they were working
8 under this IFRS rules instead of GAAP rules, right,
9 because they were on the island of Antigua?
05:24:50
10 A.
They were on the island of Antigua.
11 Q.
So they weren't using GAAP principles, were they?
12 A.
I would have thought they were using the British
13 GAAP, but it might not have been required.
05:25:00
14 Q.
So you just don't know, do you?
15 A.
I don't know.
16 Q.
And you don't know if these reporting requirements
17 required Mr. Stanford to list these from loans to

18 shareholder in the reports or not, do you?
05:25:10
19 A.
No.
20 Q.
You don't know whether it's okay or whether it's real
21 bad, do you?
22 A.
I don't know according to the standards if it's okay
23 or if it's real bad.

24 Q.
05:25:27
And the loans to shareholder, Mr. Stanford never
25 consulted with you about loans -- there's Government's

2223
1 Exhibit 337 that showed a 330 million-dollar loan to

2 shareholder. He showed that. Do you remember that
3 exhibited?
05:25:40
4 A.
I remember the exhibit, yes.
5 Q.
And, I mean, you're a CPA; right?
6 A.
Yes.
7 Q.
So you're familiar with sometimes a way to capitalize
8 a company is to take funds from another company if a

9 person owns both companies? Say, for example, I own
05:25:53
10 Company A and B, and I've got capital in A, and I want to

11 transfer it to B, and I want to avoid a taxable event, one
12 of the ways to do that is to borrow money, for me to
13 borrow money from A and loan it to B; right?
05:26:08
14 A.
Yes.
15 Q.
Anything wrong with that?
16 A.
No. I think it should be disclosed, but there's
17 nothing illegal about it.

18 Q.
Under GAAP rules, you think it should be disclosed,
19 but you don't know anything about the international

05:26:18
05:26:28
20 regulations disclosing it, do you?

21 A.
I do not.
22 Q.
So you don't know if it's wrong or not?
23 A.
Not according to those regulations.
24 Q.
So if I do that, that would be a way for me to put
25 capital if Company B needed it, that's a way for me to

2224
1 accomplish it?
05:26:34
2 A.
Yes, sir.
3 Q.
Disclosed or not; right?
4 A.
5 Q.
Perfectly legitimate; right?
6 A.
I don't know if it's perfectly legitimate or not. I
7 don't know --
05:26:45
8 Q.
Well, you're a CPA?
9 A.
I don't know under those regulations. You're telling
10 me that under those regulations disclosure is not

11 required.
12 Q.
Let's talk about one thing at a time. I own Company
13 A and then B through Z. A's got plenty of capital, B

14 through Z needs capital. They're start up. They're -05:27:00
15 hopefully they'll be successful, but not yet. So they

16 need capital.
17
So the way I transfer the money is I
18 borrow money from A, loan it to myself, and then loan it

19 to these companies. Now, I owe what I borrowed from A,
05:27:14
05:27:21
20 but B through Z owns me what I loaned to them; right?

21 A.
Right.
22 Q.
Nothing wrong with that, is there?
23 A.
No.
24 Q.
Now, you're talking about whether it should be
25 disclosed or how it should be disclosed?

2225
05:27:30
1 A.
Correct.
2 Q.
Separate issue, isn't it?
3 A.
Yes.
4 Q.
So if it was transferred in a way that -- if I did
5 something stupid like take money from A and call it a

6 constructive -- call it a dividend or income, I'm going to
7 pay taxes on that, aren't I?
05:27:41
8 A.
Yes.
9 Q.
And the way to avoid that is to call it a loan,
10 wouldn't it?
11 A.
Yes.
12 Q.
Now, are you familiar, Mr. Knoche, with the fact that
13 the Internal Revenue Service took issue with the way

14 Mr. Stanford was moving money from A, loaning it to
05:27:52
15 himself, and transferring it to B through Z, and the

16 Internal Revenue Service audited him from top to bottom
17 regarding those transactions. Do you know that?
05:28:07
18 A.
He told me he had been audited many times.
19 Q.
What he had told you, that the IRS kind of parked at
20 his door because he was -- one of these high net worth

21 guys; rights?
22 A.
He just -- he didn't tell me the reason. He just
23 said he had been audited many times and was having lots of
24 problems with the Internal Revenue Service.
05:28:18
25 Q.
So I guess is your answer you're not familiar with

2226
1 the lawsuit he had with the Internal Revenue Service?

2 A.
I don't know details of a specific lawsuit, no.
3 Q.
You don't know that the IRS declared that transfer,
4 that loan, decided it wasn't a loan but it was a

05:28:36
5 constructive dividend and wanted him to pay taxes on it?

6 A.
No, I did not know that.
7 Q.
He didn't talk to you about hiring a local law firm,
8 Chamberlain Hrdlicka, to help him fight the Internal

9 Revenue Service on that characterization of that transfer
05:28:48
05:28:52
10 of money?
11 A.
No.
12 Q.
You don't know anything about that?
13 A.
No.
14 Q.
And you're a CPA?
15 A.
No.
16 Q.
He didn't --
17 A.
Yes, I'm a CPA, yes.
18 Q.
Yeah.
19
05:28:55
He didn't feel like he needed to consult
20 with you or get your advice about how to deal with that
21 problem, did he?
05:29:03
22 A.
No.
23 Q.
Even though it created a huge tax liability for him?
24 A.
No.
25 Q.
No. Okay.
2227
MR. SCARDINO: Can I have just a moment, Your
2 Honor?
3
THE COURT: Yes, sir.
4 BY MR. SCARDINO:
05:29:33
5 Q.
In fact, Mr. Knoche, when Mr. Costa asked you
6 questions on direct examination, you told him that

7 Mr. Stanford actually told you that he had loans from the
8 bank; right?
9 A.
05:29:44
No.
10 Q.
Did not?
11 A.
No.
12 Q.
Did I write that down wrong? Mr. Stanford didn't
13 tell you he had loans from the bank?

14 A.
05:29:51
No, he did not tell me he had loans from the bank.
15
MR. FAZEL: One moment, Your Honor. I'm sorry.
16
THE COURT: Works both ways.
17
MR. SCARDINO: Can we have Government's
05:30:53
19
THE COURT: What's the number?
20
MR. SCARDINO: 115, Your Honor?
21
THE COURT: Has it been identified yet?
22
MR. SCARDINO: It's in evidence. The
23 government's identified it.
05:31:03
24
THE COURT: Has it been identified at any time?
25
MR. COSTA: Yes.

2228
THE COURT: It must have been on the clock
2 before I started making notes. 115.

3 BY MR. SCARDINO:
4 Q.
05:31:15
Mr. Knoche, I believe you testified on direct
5 examination that you had actually seen this exhibit, the

6 annual Stanford annual report?
7 A.
I know what you're speaking of now. He showed me two
8 financial statements, one back in the '90s that showed

9 there was like a 13 million-dollar loan to the
05:31:29
10 shareholder, and then he showed me the 2002 financials

11 that showed there was no loans.
12 Q.
13
Okay.
THE COURT: Just for the record, I'm looking
14 down here, the first notation I have when I started doing

05:31:42
15 this is 116 through 120. So 115 had been identified prior

16 to that group coming in?
17
MR. COSTA: The very first witness.
18
THE COURT: Okay. That listing I don't have up
19 here.
05:31:57
20 BY MR. SCARDINO:
21 Q.
Mr. Knoche, you did testify on direct examination
22 that you had read the -- this annual report; correct?

23 A.
I was shown the one from the 1990s that showed there
24 was a debt of about $13 million.

05:32:11
25 Q.
Mr. Costa asked you if you had reviewed -- was it the

2229
1 1990 annual report?

2 A.
The early years, 1990, I would -- very early years,
3 '87, '88, '89, '90, I'm sure I looked at all of those

4 financial statements. Mr. Stanford asked us all to. The
05:32:28
5 later years, I would not have read those unless I was

6 shown it in court today.
7 Q.
Well, I believe Mr. Costa did show you Stanford's
8 financial -- the annual report for 2002 and asked you if

9 it showed any loans that were disclosed.
05:32:43
10 A.
And I looked at it right now --
11 Q.
Yes, sir.
12 A.
-- and I did not see any loans disclosed.
13 Q.
And let me bring your attention to a page on that
14 report that you said you have reviewed.

05:32:54
15 A.
Well, I've reviewed it for about five minutes here in
16 court.
17 Q.
Review it for another five.
18 A.
Okay. If you can show me where.
19
05:33:04
MR. COSTA: Object. The question was the $168
20 loan to Mr. Stanford that was disclosed in that annual

21 report.
22
MR. SCARDINO: Actually, I'm going somewhere
23 completely different with this. If I can just get to the

24 exhibit. **
05:33:11
25

2230
MR. SCARDINO: Would you bring up, please,
2 Government's Exhibit 115, Page 59, and down to the Basis of

3 Opinion paragraph right there.
4 BY MR. SCARDINO:
05:33:25
5 Q.
Can you see that, Mr. Knoche?
6 A.
Yes.
7 Q.
Can you read that first sentence?
8 A.
"We conducted our audit in accordance with
9 international auditing standards."

05:33:33
10 Q.
That's not GAAP, is it?
11 A.
That's not GAAP.
12 Q.
So they're saying it right there in that annual
13 report of how they conduct their audits; right?
05:33:41
14 A.
Yes.
15 Q.
Any question in your mind now about the standards
16 that are applied?

17 A.
It says they conducted them in accordance with
18 international auditing standards.

19 Q.
05:34:56
I did leave out some things. I'm sorry, Mr. Knoche.
20 You talked about -- Mr. Costa asked you about whether or

21 not Mr. Stanford had any offices or connections in Geneva,
22 Switzerland?
05:35:12
23 A.
Yes.
24 Q.
And I think you said that he told you he didn't have
25 anything there except he had contacts there?

2231
1 A.
He said that there was no office to photograph when
2 the question came up about why did the other offices have
3 photographs, and he said there was nothing -- there was
4 not an appropriate -- or not an office to photograph.
05:35:26
5 Q.
So you don't know whether or not he had somebody
6 there, a manager there or somebody doing research there

7 for him or somebody investing money there for him or not?
8 A.
9
05:35:37
10
I do not.
MR. COSTA: Clarification on the timeframe.
THE COURT: Okay. Timeframe, please.
11 BY MR. SCARDINO:
12 Q.
Well, when -- the timeframe would have been when you
13 were aware of it, when you were there working with

14 Mr. Stanford?
05:35:45
15
THE COURT: Is that correct?
16
THE WITNESS: Yes.
17
THE COURT: Okay. Thank you.
18 BY MR. SCARDINO:
19 Q.
05:35:56
So again, you were asked a question about something
20 you really didn't know anything about; right?

21 A.
About whether there was an office in Geneva,
22 Switzerland? No.
23 Q.
Well, whether you know anything about Mr. Stanford's
24 business in Geneva, Switzerland or in South America or

05:36:09
25 anywhere else?
2232
1 A.
I know nothing of Geneva, Switzerland. I was at
2 the -- I helped with the South American offices, several

3 of those. I know nothing about Geneva, Switzerland.
4
05:36:24
MR. SCARDINO: If I can have just one minute,
5 Your Honor, and then I'm finished.

6 BY MR. SCARDINO:
7 Q.
When Mr. Davis came on board, did you monitor his
8 activities at all?
9 A.
05:36:41
10 Q.
No.
You didn't have anything to do with what Mr. Davis
11 did, did you?

12 A.
Nothing.
13 Q.
I mean, you don't know how far his power extended or
14 his influence extended through Stanford's empire, did you?

05:36:54
15 A.
I do not.
16 Q.
You did know that Mr. Stanford owned 100 percent of
17 everything, though; right?
05:37:02
18 A.
That's my understanding.
19 Q.
Okay. So you don't -- after you left, you have no
20 idea what kind of control, if any, Mr. Davis might have

21 been able to influence over Mr. Stanford's empire, do you?
22 A.
I have no idea.
23 Q.
Did you ever have any interaction with anybody in
24 Mr. Stanford's organization, particularly Stanford

05:37:19
25 International Bank? Did you have any interaction with the

2233
Redirect-Knoche/By Mr. Costa
1 people that worked in the bank or operated the bank?

2 A.
I knew some of the people. As we were building the
3 bank facility, we talked to them about their space needs

4 and things like that.
05:37:30
5 Q.
I mean, did you ever have any interaction with people
6 that sold any of the financial products?
05:37:42
7 A.
Just conversationally. I mean, that's all.
8 Q.
But you never sold any financial products?
9 A.
I never sold any financial -- no, I never sold any
10 financial products.
11 Q.
And you were never consulted by Mr. Stanford or
12 anybody else about how to run his business, how to market

13 his business, how for promote his business, were you?
14 A.
05:37:52
I was not.
15
MR. SCARDINO: Pass the witness.
16
17 BY MR. COSTA:
18 Q.
Mr. Knoche, do you remember at the beginning of your
19 cross-examination Mr. Scardino asked you about your prior

05:38:15
20 interviews with the FBI?

21 A.
Yes.
22 Q.
And he said the first interview, wasn't it true that
23 you said that Mr. Stanford wasn't all that hands-on with
24 you and the other individual who were running Guardian,
05:38:27
25 the real estate partnerships, at the beginning?

2234
05:38:33
1 A.
Yes.
2 Q.
3 A.
Yes.
4 Q.
And you said that's true with respect to what you
5 were doing at the earlier years; correct?

6 A.
Yes.
7 Q.
What was Mr. Stanford focused on and hands-on with
8 respect to in those early years?

9 A.
05:38:43
10 Q.
The bank.
And that continued throughout the time you left in
11 2003, from what you saw?

12 A.
Yes.
13 Q.
Mr. Scardino asked you a number of questions about
14 the developments down in Antigua, the airport development?

05:38:58
15 A.
Yes.
16 Q.
Do you recall those?
17
And he said Mr. Stanford wanted them to be
18 the best in the world?
05:39:04
19 A.
Yes.
20 Q.
Did Mr. Stanford ever tell you that these
21 best-in-the-world buildings were being funded by the CD

22 holders' deposits?
05:39:21
23 A.
No.
24 Q.
What did Mr. Stanford say on that video about the
25 profitability of these developments in Antigua?

2235
1 A.
He used the words, "I'm developing, I'm paying for
2 things that are -- would not otherwise be financially

3 feasible."
05:39:31
4 Q.
Makes no economic sense?
5 A.
Makes no economic sense.
6 Q.
And from what you've seen in the promotional
7 materials, what you understood hearing from Mr. Stanford,

8 were the CD depositors ever told that their money was
9 going to Antiguan real estate?
05:39:52
10 A.
No.
11 Q.
Mr. Scardino said, Did you ever see anything that you
12 thought was fraudulent when you worked at the development

13 company?
14
05:39:58
15 A.
That's correct.
16 Q.
If the CD depositors' money was going to fund the
17 development corporation and all these Antiguan real estate

18 deals, would that have been a problem for you?
05:40:12
19 A.
Yes, it would have been a problem.
20 Q.
Why?
21 A.
Because the depositors of the bank were not being
22 told of that.
05:40:19
23 Q.
Were you a depositor of the bank?
24 A.
No.
25 Q.
You never bought a CD?

2236
1 A.
No.
2 Q.
Mr. Scardino asked you -- I think when we were
3 looking at the airport pavilion, he said that was

4 constructed; right?
05:40:34
05:40:39
5 A.
The --
6 Q.
The airport pavilion?
7 A.
-- airport hangar.
8 Q.
The hangar was built?
9 A.
Yes, it was constructed.
10 Q.
The Pavilion was the restaurant?
11 A.
The Pavilion was the restaurant. That's right.
12 Q.
What did Mr. Stanford say about the Pavilion, the
13 restaurant? What was its purpose?

14 A.
05:40:48
It was going to be a super high-end restaurant, and
15 very expensive. I always pictured it was going to be

16 predominately for the clients of the bank, so they would
17 have a world class experience there.
18 Q.
Was there a big market in Antigua for a high-end
19 restaurant like that?

05:40:59
20 A.
No. There would have been a tiny number of people in
21 Antigua that could afford to eat there.

22 Q.
Was there a big market in Antigua for these types of
23 high-quality business offices and other buildings?
05:41:12
24 A.
No.
25 Q.
And he asked you if the airport hangar was built, and

2237
1 you said it was; right?
05:41:20
2 A.
Yes.
3 Q.
He asked about bricks being laid?
4 A.
5 Q.
Was a brick ever laid as far as you know on the super
6 fancy resort for billionaires?

7 A.
Not while I was there.
8 Q.
And when Mr. Stanford -- he asked you a number of
9 questions about Mr. Stanford talking for years about this

05:41:35
10 dream for the super fancy resort.

11
Did he ever say that was going to be
12 funded with CD depositors' money?
05:41:46
13 A.
No.
14 Q.
And would that be consistent with what the bank said
15 it did with the CD depositors' money?

16 A.
Well, if it was used, that would not be consistent.
17 Q.
Would putting the money into a super fancy, high-end
18 resort be what you consider a conservative, low-risk,

19 liquid investment?
05:41:59
20 A.
No.
21 Q.
Mr. Scardino talked about the number of jobs in
22 Antigua and things like that.
05:42:15
23 A.
Yes.
24 Q.
Do you recall that?
25 A.
Yes.
2238
1 Q.
Did Mr. Stanford, as far as you know, ever tell the
2 CD depositors that their money was going towards economic

3 development in Antigua?
05:42:27
4 A.
No.
5 Q.
Mr. Scardino towards the end asked you about
6 accounting standards.
7
05:42:35
Do you recall that?
8 A.
Yes.
9 Q.
And he asked you about this IFRS?
10 A.
Yes.
11 Q.
Your entire time working at Stanford, were you ever
12 told that IFRS, international accounting standards,

13 financial reporting standards, were these standards that
14 were being used?
05:42:47
15 A.
I don't recall ever being told that, no.
16 Q.
And Stanford Development Corporation had financial
17 statements; correct?
18 A.
Yes. And I just do not recall what the audit
19 report -- how it was worded. I do not recall if it was

05:42:59
20 under British GAAP or if it was under this intentionally.

21 I know we got a clean opinion, but I don't know what
22 standards.
23 Q.
And he asked you about related-party disclosures; do
24 you recall that?

05:43:08
25 A.
Yes.
2239
1 Q.
Now, regardless of whether loans should be disclosed,
2 is putting money into Antiguan real estate consistent with

3 what the bank said it was doing with its money?
05:43:21
4 A.
No.
5 Q.
And we saw those annual reports with stocks and bonds
6 and specified dollar amounts for those; correct?

7 A.
Yes.
8 Q.
And none of those that you've seen ever say Antiguan
9 real estate?
05:43:31
10 A.
I never saw Antiguan real estate listed.
11 Q.
Now, on this issue of related-party disclosures, did
12 I show you a few days ago an international accounting

13 standard concerning related-party disclosures?
05:43:49
14 A.
Yes, you did.
15 Q.
I'm going to hand it to you now.
16
Is that what you saw the other day?
17 A.
Yes.
18 Q.
And it's from this IFRS that Mr. Scardino asked
19 about?
05:44:00
20 A.
That's correct. International Financial Reporting
21 Standards.
22 Q.
And the entire subject of that accounting standard is
23 related-party disclosures?
24 A.
05:44:17
25
Related-party disclosures, yes.

MR. SCARDINO: Do we have the year?
2240
THE COURT: While they're looking, Mr. Costa,
2 the number of that is, Mr. Costa?

3
MR. COSTA: I'm sorry. I'm not going to offer
4 it, Your Honor.

05:44:34
THE COURT: Okay.
MR. COSTA: There's no exhibit number. Is that
7 the question?
05:44:43
THE COURT: No, you didn't hear the question.
MR. COSTA: You asked what number it was.
10
No? Did I miss it?
11
THE COURT: No, you didn't.
12
You may continue.
13 BY MR. COSTA:
14 Q.
05:44:52
In addition to related-party disclosures, are you
15 familiar with an accounting concept called "materiality"?

16 A.
Yes.
17 Q.
What does that mean, "materiality"?
18 A.
It means that the transaction --
19
05:45:02
MR. SCARDINO: Object. That's beyond the scope
20 of cross.
21
MR. COSTA: He asked about international
22 accounting standards repeatedly and related-party

23 disclosures, but we can't do the same?
24
05:45:13
THE COURT: Overruled. Give both sides
25 flexibility on the first go-round, which I've done on the

2241
1 first go-round.
2
This is his rebuttal. And then we have
3 recross, if we have it. Go on.

4 BY MR. COSTA:
05:45:20
5 Q.
What does the concept of "materiality" mean?
6 A.
If a transaction is being reviewed, it would depend
7 on the dollar amount of it. A ten-dollar transaction

8 would not be material. A million-dollar transaction,
9 probably in most cases, would be material.
05:45:34
10 Q.
That loan we saw to Mr. Stanford -- one was
11 $168 million; in 2003, it was $330 million -- are those

12 material amounts?
05:45:46
13 A.
In my opinion, certainly they're material.
14 Q.
Is it close to the line?
15 A.
I would not think so. I think they're easily
16 material.
17 Q.
And what does accounting standard of materiality --
18 is that a more general principle than particular

19 accounting standards on things like related-party
05:45:59
20 disclosures?
21 A.
Yes. It would just apply to almost any issue. He'd
22 just look at whether it was material in amount as to

23 whether it would be delved into or not.
24 Q.
05:46:12
And material -- someone -- a CD depositor, is that
25 the individual reading the bank's annual reports who would

2242
1 want to know -- would materiality be judged from their

2 perspective?
05:46:22
3 A.
Yes.
4 Q.
And if you were a CD depositor, would you want to
5 know if hundreds of millions of dollars had gone to the

6 sole shareholder, Mr. Allen Stanford?
7 A.
Yes, I would.
8 Q.
Mr. Scardino asked you about the real estate deals.
9 You said they were all profitable.

05:46:37
05:46:44
10
11 A.
Yes.
12 Q.
And you said most of them were moderately profitable?
13 A.
Yes.
14 Q.
There was one that was a good -- was highly
15 profitable?
16 A.
That's correct.
17 Q.
What about, though, these developments in Antigua?
18 Were they sold for a profit?
05:46:50
19 A.
No.
20 Q.
Was that even the goal?
21 A.
Only Cedar Valley Springs had an anticipation of
22 making some money.
05:46:58
23 Q.
But the airport hangar, was that --
24 A.
No.
25 Q.
-- the idea was to make it profit on that?

2243
1 A.
No. They were -- they were just built to be used by
2 the group of companies.
05:47:07
3 Q.
The Sticky Wicket?
4 A.
It had a chance of breaking even maybe.
5 Q.
And Mr. Stanford on the video said this would make no
6 economic sense; is that right?

7 A.
Yes.
MR. COSTA: Just one minute, Your Honor,
9 please.
05:47:42
10 BY MR. COSTA:
11 Q.
Mr. Scardino asked you whether it was your business
12 where the funding came from --
05:47:55
13 A.
Yes.
14 Q.
-- from these various projects.
15
Do you recall that?
16 A.
Yes.
17 Q.
Would CD depositors want to know what their money was
18 being spent on?

19 A.
05:48:04
In my opinion, they would definitely want to know
20 what CD money was being spent on.

21 Q.
And regardless of whether you were entitled to know,
22 when Mr. Stanford was asked where the money was coming
23 from for all these developments down in Antigua, what did
24 he say?
05:48:16
25 A.
Personal funds. Personal resources.

2244
Recross-Knoche/By Mr. Scardino
MR. SCARDINO: Just a few questions.
RECROSS EXAMINATION
4 BY MR. SCARDINO:
05:48:24
05:48:31
5 Q.
Mr. Costa asked you about certificates of deposits?
6 A.
Yes.
7 Q.
You know what those are, don't you?
8 A.
Yes, I do.
9 Q.
And that's when somebody goes to the bank and gives
10 the bank a sum of money, an agreement that the bank will

11 pay them back a percentage at a fixed time later; right?
12 A.
They'll pay them back the principal plus interest.
13 Q.
Traditionally, they're sold in 30-, 60-, 90-day,
14 one-year increments, five-year increments; right?

05:48:46
15 A.
Yes.
16 Q.
And they're not paying much right now, are they?
17 A.
No, paying very low right now.
18 Q.
Very little right now.
19
05:48:53
And when you -- the CD, when you purchase
20 it, is that the type of instrument where the person that

21 actually buys the CD, can they -- can they demand where
22 the bank invest that money?
05:49:05
23 A.
No.
24 Q.
They can't, can they?
25 A.
No.
2245
1 Q.
They don't have anything to say about how the bank
2 invests that money, do they?
05:49:13
3 A.
They cannot make the bank do something, no.
4 Q.
They cannot. And the bank -- the bank does this
5 because the bank makes money on that money, don't they?

6 A.
Yes.
7 Q.
And they deposit and invest it in various other
8 things to make money, don't they?

9 A.
05:49:22
That's correct.
10 Q.
And they invest it in stocks; right?
11 A.
Yes.
12 Q.
Bonds, notes, and sometimes real estate to make
13 money; right?
05:49:31
14 A.
That's correct.
15 Q.
Some make the bank money quicker. Some, it takes the
16 bank awhile for the bank to make money, doesn't it?

17 A.
Yes.
18 Q.
And sometimes the bank makes stupid decisions and
19 they go broke, don't they?

05:49:42
20 A.
Yes.
21 Q.
Banks like Bank of America?
22
MR. COSTA: Your Honor, I object.
23
MR. SCARDINO: Withdrawn. Withdrawn.
24
THE COURT: Withdrawn.
25
2246
1 BY MR. SCARDINO:
2 Q.
So a certificate of deposit is an instrument where
3 the person that owns it holds it, and the bank makes as
4 promise and the bank makes good on it if the bank is
05:50:00
5 successful?
6 A.
That's correct.
7 Q.
Okay. As opposed to where if you bought stock in the
8 bank, now you have something to say how the bank invests
9 that money; right?
05:50:07
10 A.
Right. If you buy stock, you're a partial owner.
11 Q.
Your own part of the bank.
12
So that distinguishes between the two;
13 right?
05:50:15
14 A.
Yes.
15 Q.
Okay. And what Mr. Costa was asking you about was a
16 CD that Stanford International Bank, Limited was selling.

17
And in their annual report, they do tell
18 people how they're investing money in some fashion, don't

19 they?
05:50:28
20
I mean, he just asked you about it,
21 Government's Exhibit 2002; right?

22 A.
Right.
23 Q.
I mean, I'm sorry, Government's Exhibit 115, the 2002
24 annual report.
05:50:35
25
Stanford didn't have to do that, did he?

2247
1 A.
I don't know the specific requirement if he had to or
2 not.
3 Q.
Well, you just told the jury that, if a person buys a
4 CD, they got nothing to say about how the bank invests the
05:50:50
5 money, do they?
6 A.
They have nothing to say about it. They would be
7 interested in knowing how the money was invested, but they

8 have no -- they'd have no rights. They can't tell the
9 bank what to do with it.
05:50:59
10 Q.
Right.
11
MR. SCARDINO: Would you please bring up
12 Government's 115 again and go to Page 50.

13
All right. Would you highlight the
14 investments and listed securities. Down one more. Right

05:51:17
15 there.
16 BY MR. SCARDINO:
17 Q.
Would you look at that, Mr. Knoche. It says
18 "Investments and listed securities"; right?
05:51:29
19 A.
Yes.
20 Q.
Read the rest of it for us.
21 A.
Equities, $720 million. Treasury bonds, notes,
22 corporate bonds, $852 million.
05:51:46
23 Q.
Treasury bonds; right? What's that?
24 A.
That's a debt of the government -- of governments,
25 usually.
2248
1 Q.
All right. And what's notes?
2 A.
Notes is a debt from somebody. It doesn't define
3 from whom.
05:51:56
4 Q.
A loan?
5 A.
A loan.
6 Q.
A loan.
So in the 2002 annual report, they do list
8 that part of what their investment is are in loans; right?

9 A.
05:52:12
10 Q.
The word "notes," yes.

Notes, a loan to somebody; right? They've invested.
11 Sometimes that's a good investment, isn't it?
05:52:24
12 A.
Could be.
13 Q.
Corporate America does it all the time, don't they?
14 A.
Corporate America borrows money all the time.
15 Q.
All the time. Okay. So they list -- they do list
16 that in the 2002 annual report, don't they?

17 A.
When there's a caption that says "notes," yes.
18 Q.
It doesn't go into detail of what it is or what it's
19 to, but -05:52:36
20 A.
No.
21 Q.
-- it does -- it does list that part of what they're
22 investing in is -- are in notes; right?
05:52:48
23 A.
That's correct.
24 Q.
Okay. Now, Mr. Costa asked you about that the people
25 that bought the CDs had a right to know or were somehow

2249
1 misled in where their money was being invested, and that

2 was a problem for you if it had been invested in either
3 real estate or that wasn't disclosed or loans to
4 shareholder that wasn't disclosed; right?
05:53:03
5 A.
Correct.
6 Q.
But you still don't know the standards, and you don't
7 understand the standards under which Mr. Stanford's

8 enterprise was being run. Mr. Costa showed you an
9 international financial regulatory commission standard
05:53:19
10 with no date on it; right? You don't know what year that
11 would have applied, do you?
12 A.
No.
13 Q.
And you talked about how -- in your opinion, whether
14 the Sticky Wicket was a profitable enterprise, and you

05:53:33
15 told Mr. Cost you thought it might break even?

16 A.
We did projections before it was built, and that was
17 the projections that we thought -- and including a

18 restaurant consultant. He thought it might break even.
05:53:46
19 Q.
Have you ever started a business?
20 A.
No, I have not.
21 Q.
Never have. I mean, have you ever helped people
22 start businesses in your capacity as a CPA?
05:53:56
23 A.
No, not as a CPA.
24 Q.
Well, in your business as a -- a business -- in your
25 CPA work, you know people start businesses, and sometimes

2250
1 they have to invest money and it doesn't operate at a

2 profit at first; right?
05:54:05
3 A.
Sure, yes.
4 Q.
And you know, sometimes when people start businesses
5 they spend money on things like airplane hangars that you

6 know is not going to be profitable, but you hope brings in
7 people that will produce a profit?
05:54:16
8 A.
Yes. That's the concept, yes.
9 Q.
So the hangar never was going to make money?
10 A.
Right.
11 Q.
Right?
12
But if it brought in all these
13 billionaires, it could have been very profitable; right?
05:54:22
14 A.
Right.
15 Q.
You didn't do any studies on that, though, did you?
16 A.
No.
17 Q.
Okay. And if the profits from the bank had been
18 invested in real estate and that had been -- turned out to

19 be fabulously successful, you wouldn't have had a problem
05:54:32
20 with that, would you?

21 A.
Well, I don't see it would have made any difference.
22 I mean -23 Q.
It wouldn't have been any different if the proceeds
24 from the bank had been invested in some sports enterprise

05:54:43
25 and it became fabulously successful, you wouldn't have had

2251
1 a problem with that, would you?

2 A.
No. I think it's the same principle. It still
3 wasn't -- nobody knew about it. Whether it made money or

4 did not make money, that wouldn't be the...
05:55:05
MR. SCARDINO: Thank you. Pass.
7 BY MR. COSTA:
8 Q.
Mr. Knoche, did -- in your 17 years working for
9 Mr. Stanford -05:55:13
10 A.
16.
11 Q.
16?
12
-- did he ever once tell you that since we
13 sell CDs, the bank can lie to the depositors?
05:55:24
14 A.
No.
15 Q.
What was the purpose of those promotional materials
16 and those annual reports by giving that information about

17 the investments being conservative, liquid, low risk?
18
Do you know why Mr. Stanford -- did he say
19 why he wanted to put out those promotional materials?

05:55:35
20 A.
Well --
21
MR. SCARDINO: Objection, asked and answered,
22 not relevant, and outside the scope of the knowledge of the

23 witness.
24
05:55:42
THE COURT: Well, somewhere in there sustained.
25 He had three different reasons.

2252
Move on, please.
2 BY MR. COSTA:
3 Q.
Do you know -- did Mr. Stanford say why he wanted put
4 all these promotional materials that he required you to

05:55:50
5 read?
6 A.
Well, to market the products, everybody has to have
7 marketing materials.
8 Q.
And were depositors relying on those marketing ing
9 materials?
05:55:59
10 A.
I would think so.
11 Q.
And you understand that when you represent -- make
12 representations about a product, the law requires you to

13 be truthful?
14 A.
05:56:09
15
Yes.
MR. COSTA: If we can go to 115, please.
16 Page 50, please.

17
Your Honor, we need to switch back, I
18 think, to our --
05:56:21
19
THE COURT: To where?
20
MR. COSTA: Our computer --
21
THE COURT: Okay.
22
MR. COSTA: -- please.
23
And if we can highlight the same thing
24 Mr. Scardino was just showing, but also the two lines
05:56:34
25 beneath the numbers.

2253
1 BY MR. COSTA:
2 Q.
And you talked about notes; right?
Corporate bonds and things like that can
4 also be called notes; correct?

05:56:49
5 A.
Yes.
6 Q.
Debt that Exxon or GM might issue is commonly called
7 notes as well; correct?
05:56:58
8 A.
Yes, uh-huh.
9 Q.
And beneath there, it says, "All listed securities of
10 or guaranteed by various governments, mature on fixed

11 dates up to 30 years. These investments are generally
12 listed on major international exchanges and are deemed
13 highly liquid."
14
05:57:14
Would a 330 million-dollar loan to
15 Mr. Stanford, do you think that was listed on a major

16 international exchange?
17 A.
No.
18 Q.
Why is listing on a public exchange relevant to
19 liquidity?
05:57:25
20 A.
That means you have a ready market for it. You just
21 call your stockbroker and say, I want to sell my shares on

22 IBM and you sell your shares in IBM.
05:57:35
23 Q.
And is that true for treasury bonds as well?
24 A.
Yes.
25
MR. COSTA: Your Honor, it's very hard to

2254
1 concentrate with all the --
05:57:45
MR. SCARDINO: I'm sorry.
MR. COSTA: -- talking.
MR. SCARDINO: I didn't mean to talk so loud.
THE COURT: Okay. Go on.
6 BY MR. COSTA:
05:57:51
7 Q.
Have you heard the term "marketable securities"?
8 A.
Yes.
9 Q.
What does that mean?
10 A.
That's the same thing, that they -- that there's a
11 market for them. If you want to sell them, there's people

12 ready to buy them.
13 Q.
And Mr. Scardino was saying, Well, maybe the 168
14 million to Mr. Stanford in 2002 was included in that one

05:58:05
15 line entry.
16
That concept of materiality you talked
17 about --
05:58:15
18 A.
Yes.
19 Q.
-- would it apply to noting that the sole shareholder
20 had a loan for $168 million, in your view?

21 A.
In my opinion, yes.
22
23
MR. SCARDINO: Just quickly. In fact, if we
24 can keep the exhibit. Same exhibit, please.

05:58:26
25
THE COURT: Okay.

2255
MR. SCARDINO: If you would highlight that --
2 that very last two lines, please.

3
RECROSS EXAMINATION
4 BY MR. SCARDINO:
05:58:37
5 Q.
Mr. Knoche, Mr. Costa just asked you about all listed
6 securities are guaranteed various government, mature on

7 fixed dates up to 30 years, that's referring to a
8 government bond, isn't it?
9 A.
05:58:51
It says "All listed securities." I don't know what
10 it refers to.
11 Q.
Well, I mean, that's what's being described there;
12 right? Government bonds?

13 A.
No. I think there could -- no. There's treasury
14 notes too. No. That easily be the same thing. Treasury

05:59:06
15 notes, treasury bonds.

16 Q.
Okay. Are you telling this jury that there's no way
17 you can invest in any real estate that's not liquid, not
18 ever, not ever an opportunity to have a real estate
19 investment that's -05:59:16
20 A.
No. If you know the facts, you're more than welcome
21 to invest in any kind of -- anything you want to, if you

22 know the facts.
23 Q.
In fact, you've been involved in a lot of real estate
24 transactions where there was closing at the same time

05:59:27
25 where the guy made money at the closing; right? At the

2256
1 closing?
2 A.
I -- I don't follow you.
3 Q.
Well, somebody buys a piece of real estate and then
4 sells it the -- to a third party right there in the same

05:59:39
5 transaction?
6 A.
Oh, flips it at the same time? I've not been
7 involved, but I know property are flipped like that, where

8 somebody buys and sells it the same day and makes money.
9 That is -- that's been done before.
05:59:47
10 Q.
Happened in Houston a lot in the '80s?
11 A.
Yes.
12 Q.
Would that be a liquid investment then, or liquid
13 transaction?
14 A.
05:59:55
Well, in that isolated instance, it happened to be
15 liquid because they already had it lined up. They would

16 have never bought the first property if they didn't know
17 they could sell it.
18 Q.
So you can just make a blanket statement that any
19 investment in real estate is not liquid, can you?

06:00:05
20 A.
Pretty close to it. I mean, you gave one exception.
21
MR. SCARDINO: Thank you. Pass.
22
MR. COSTA: Nothing further, Your Honor.
23
THE COURT: Thank you, sir. You may -- you're
24 excused. You may step down. You're free to leave.

06:00:18
25
THE WITNESS: Thank you, Your Honor.

2257
1
2
THE COURT: You're excused.

All right. Let's see. First thing to do,
3 let's get that screen up.

4
06:00:36
All right. That ends it for today. We'll
5 see you tomorrow, ready to resume at 10:00 a.m. Thank you

6 and good afternoon.
7
COURT REPORTER'S CERTIFICATE
9
10 I, Johnny C. Sanchez, certify that the foregoing is a
11 correct transcript from the record of proceedings in the
12 above-entitled matter.
13
14
/s/_________________________
Johnny C. Sanchez, CRR, RMR
15
16
17
18
19
20
21
22
23
24
25
2258
#
#8016 [2] - 1972:11, 1972:18
$
$100,000 [1] - 2169:23
$13 [1] - 2228:24
$168 [6] - 2151:22, 2152:1, 2153:1,
2229:19, 2241:11, 2254:20
$20 [1] - 2216:21
$300,000 [2] - 2167:24, 2168:5
$330 [2] - 2155:20, 2241:11
$60,000 [1] - 2168:10
$720 [1] - 2247:21
$720,900,000 [1] - 2149:7
$720,951.040 [1] - 2149:7
$832,336,398 [1] - 2149:9
$852 [1] - 2247:22
'
'03 [1] - 2135:6
'70s [2] - 2019:8, 2019:22
'80s [7] - 2019:9, 2019:22, 2026:16,
2133:20, 2170:20, 2170:23, 2256:10
'86 [1] - 2002:21
'87 [2] - 2170:23, 2229:3
'88 [2] - 2002:22, 2229:3
'89 [1] - 2229:3
'90 [1] - 2229:3
'90s [3] - 2133:13, 2134:3, 2228:8
'91 [1] - 2002:25
'93 [1] - 2135:6
'96 [1] - 2157:16
'97 [1] - 2157:22
'98 [4] - 2011:1, 2068:24, 2069:7,
2158:17
'99 [4] - 2011:2, 2013:6, 2013:8,
2013:13
'Loan' [1] - 2063:24
'Maker' [1] - 2063:19
'Payee' [1] - 2063:22
/
/s [1] - 2257:13
0
000015 [1] - 2024:23
0010763 [1] - 1992:15
0010774 [1] - 2086:12
0010790 [1] - 2087:10
001792 [1] - 2086:17
006 [1] - 2023:7
09-CR-342 [1] - 1971:4
Johnny
1986 [3] - 2067:19, 2086:21, 2087:21

1987 [9] - 2101:23, 2101:24, 2102:17,
2107:16, 2120:12, 2123:4, 2129:13,
2130:5, 2170:22
1988 [3] - 2067:20, 2086:21, 2087:22
1990 [17] - 1988:11, 1992:24, 1993:2,
1993:4, 1993:7, 1994:16, 1996:8,
1998:8, 1998:12, 2000:19, 2002:18,
2067:2, 2068:1, 2087:12, 2111:15,
2229:1, 2229:2
1990s [4] - 2133:2, 2139:21, 2190:6,
2228:23
1991 [1] - 2003:1
1994 [5] - 1990:4, 1990:17, 2002:6,
2002:11, 2003:5
1996 [2] - 2004:9, 2004:24
1998 [18] - 2003:25, 2004:2, 2005:1,
2005:22, 2007:6, 2028:11, 2028:18,
2046:9, 2059:6, 2059:9, 2068:23,
2069:10, 2069:12, 2069:18, 2072:16,
2157:7, 2158:1, 2158:6
1999 [9] - 2003:25, 2004:2, 2005:1,
2016:2, 2029:10, 2036:18, 2040:6,
2098:8, 2098:10
19th [4] - 2002:18, 2002:25, 2067:25,
2087:11
1:00 [1] - 2079:16
1:05 [1] - 2079:21
1 [3] - 2029:7, 2062:19, 2086:14

1.1 [2] - 2058:8, 2112:1
1.5 [1] - 2149:4
1.573 [1] - 2149:5
10 [5] - 2034:21, 2046:8, 2184:5,
2184:22, 2185:17
10-1 [5] - 2037:17, 2044:18, 2044:19,
2044:21, 2052:24
10-2 [4] - 2051:15, 2051:23, 2090:2,
2090:18
100 [2] - 2192:11, 2232:16
1004 [1] - 1971:22
100s [1] - 2037:22
1018 [1] - 1972:3
103 [2] - 2111:9, 2111:11
10:00 [2] - 2035:14, 2257:5
10:19 [1] - 1971:6
11 [3] - 2080:3, 2101:15, 2137:4
11.6 [1] - 2157:20
1100 [2] - 2103:14, 2131:12
111 [3] - 2027:17, 2027:19, 2157:2
112 [1] - 2029:6
113 [1] - 2030:7
115 [12] - 2148:9, 2156:8, 2158:21,
2158:24, 2227:18, 2227:20, 2228:2,
2228:15, 2230:2, 2246:23, 2247:12,
2252:15
2
116 [1] - 2228:15
11:41 [1] - 2035:8
2 [6] - 1972:4, 2047:18, 2067:16,
12 [1] - 2034:21
2148:13, 2155:25, 2184:21
120 [1] - 2228:15
2-14 [6] - 1988:25, 1989:11, 1989:13,
13 [6] - 2111:17, 2138:7, 2157:18,
1989:18, 2067:5, 2086:9
2158:2, 2183:1, 2228:9
2.1 [2] - 2059:16
1350 [1] - 2143:1
2.2 [3] - 2059:17, 2059:18
1400 [1] - 1971:17
2.3 [1] - 2059:19
14th [4] - 2002:21, 2067:19, 2086:21,
2.6 [1] - 2111:25
2087:22
20 [4] - 1990:19, 2002:6, 2139:17,
15 [5] - 2019:10, 2020:9, 2034:22,
2198:6
2035:7, 2190:11
20-minute [1] - 2155:9
15,742 [1] - 2038:2
2000 [8] - 2030:11, 2032:21, 2036:6,
1516 [2] - 2017:18, 2017:19
2042:21, 2046:5, 2063:15, 2063:21,
1530 [5] - 2020:22, 2022:13, 2077:6,
2088:18
2080:3, 2136:10
20005 [1] - 1971:18
1535A [3] - 2142:23, 2143:2, 2143:3
2000s [1] - 2139:21
16 [13] - 2129:17, 2129:18, 2134:20,
2001 [8] - 2033:12, 2042:21, 2043:10,
2148:17, 2170:1, 2176:8, 2176:16,
2055:3, 2056:24, 2057:12, 2062:13,
2180:4, 2188:19, 2191:21, 2216:11,
2064:9
2251:10, 2251:11
2002 [21] - 2060:9, 2084:20, 2148:13,
168 [5] - 2156:19, 2156:25, 2158:3,
2149:2, 2151:10, 2154:13, 2155:22,
2159:6, 2254:13
2156:9, 2156:14, 2156:18, 2156:23,
17 [1] - 2251:8
2158:2, 2158:20, 2158:25, 2228:10,
17,000 [1] - 2037:19
2229:8, 2246:21, 2246:23, 2248:7,
18 [4] - 2030:25, 2178:6, 2178:11,
2248:16, 2254:14
2180:25
2003 [23] - 2129:16, 2131:23, 2131:25,
18th [1] - 2177:6
2136:14, 2151:11, 2154:2, 2154:3,
19 [3] - 2069:12, 2118:10, 2138:24
2154:6, 2154:19, 2154:24, 2155:2,
1980 [1] - 2102:16
2155:20, 2155:22, 2162:21, 2163:1,
1982 [2] - 2001:20, 2046:13
2166:8, 2166:10, 2167:9, 2168:23,
1983 [1] - 1973:6
2208:3, 2208:5, 2234:11, 2241:11
C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2259
2005 [1] - 2208:1
2007 [1] - 2027:1
2008 [2] - 2178:6, 2178:8
2009 [2] - 2060:18, 2084:21
2010 [4] - 2177:7, 2178:9, 2178:11,
2180:25
2011 [1] - 2182:3
2012 [1] - 1971:5
2062 [1] - 1973:8
2084 [1] - 1973:10
2098 [1] - 1973:12
2099 [1] - 1973:17
21 [8] - 1980:18, 1983:8, 1985:18,
1998:12, 2000:19, 2073:10, 2157:4,
2157:10
214 [1] - 1994:3
2169 [1] - 1973:19
218 [4] - 1979:25, 1983:6, 1985:18,
2073:5
22 [1] - 2187:5
2233 [1] - 1973:21
2244 [1] - 1973:23
2251 [1] - 1973:25
2255 [1] - 1974:2
23 [4] - 2046:5, 2100:10, 2139:6,
2139:7
231 [11] - 2050:23, 2050:24, 2051:2,
2051:5, 2051:6, 2065:17, 2065:20,
2066:5, 2089:19, 2090:4, 2091:3
231(e [1] - 2089:3
232 [9] - 2050:10, 2051:4, 2051:5,
2051:11, 2052:14, 2089:19, 2090:4,
2091:25, 2092:7
240,000-dollar [1] - 2168:13
25 [4] - 1977:8, 2000:4, 2000:6,
2014:21
250 [1] - 2190:14
25th [1] - 1990:17
26th [1] - 1990:17
27 [1] - 2027:19
27th [1] - 1990:17
28 [3] - 1993:3, 2046:10, 2067:2
28th [1] - 1993:2
29 [2] - 2012:14, 2036:6
2:15 [1] - 2079:20
330 [3] - 2155:1, 2223:1, 2253:14

334 [3] - 2063:3, 2063:8, 2088:16
336 [5] - 2149:21, 2150:4, 2150:8,
2151:2, 2156:15
337 [5] - 2153:13, 2153:21, 2153:25,
2155:19, 2223:1
34 [1] - 2031:3
37 [1] - 2030:16
38 [1] - 2001:5
3:55 [1] - 2155:9
3:56 [1] - 2155:11
3rd [1] - 1971:22
4
4 [1] - 2182:21
40 [1] - 2198:11
41 [1] - 2046:9
45 [1] - 2100:10
4:15 [1] - 2155:10
77279 [1] - 1972:7

79535 [1] - 1972:7
8
8 [1] - 2100:20
852 [3] - 2149:10, 2149:11
86.9 [1] - 2111:25
9
9 [8] - 2002:21, 2039:23, 2057:12,
2062:13, 2067:19, 2081:14, 2086:20,
2113:16
9.4 [1] - 2111:25
90 [2] - 2108:22, 2168:20
90-day [1] - 2244:13
90s [1] - 2026:17
9th [1] - 2087:21
5
5 [6] - 2017:18, 2046:16, 2085:12,
2085:14, 2086:14, 2114:4
50 [4] - 2014:20, 2148:23, 2247:12,
2252:16
502 [1] - 2117:9
511 [8] - 1988:4, 1989:9, 1993:3,
2066:22, 2085:25, 2086:6, 2086:15
515 [2] - 1972:11, 1972:18
516 [1] - 2017:8
519 [1] - 2114:3
522 [1] - 2118:9
59 [2] - 2159:8, 2230:2
59,500,000 [2] - 2063:23, 2063:24
59.5 [1] - 2064:4
6
6-1 [2] - 2207:5, 2207:16
60 [2] - 2168:1, 2244:13
61129 [1] - 1971:14
615 [5] - 2055:17, 2055:25, 2057:11,
2058:1, 2062:4
666 [7] - 2055:12, 2055:21, 2056:13,
2057:6, 2057:25, 2058:10, 2064:10
6:00 [1] - 2207:10
6:01 [1] - 2257:7
A's [1] - 2224:13

a.m [3] - 1971:6, 2035:8, 2257:5
able [14] - 1980:20, 2014:19, 2058:3,
2058:4, 2067:12, 2085:19, 2120:19,
2124:12, 2127:6, 2140:8, 2185:7,
2186:14, 2196:12, 2232:21
above-entitled [1] - 2257:12
Abreu [2] - 2043:12, 2043:13
absolute [1] - 2000:18
absolutely [4] - 1992:1, 2020:8,
2024:6, 2200:24
accept [2] - 1997:18, 2001:17
accepted [2] - 2087:13, 2221:22
accepting [2] - 2047:16, 2053:14
access [2] - 2074:22, 2075:2
accesses [1] - 1976:15
accomplish [2] - 2218:19, 2224:1
accomplished [2] - 2015:2, 2194:22
accordance [4] - 2031:11, 2046:8,
2230:8, 2230:17
according [6] - 1994:24, 1999:2,
2115:18, 2124:25, 2222:22, 2223:23
accordingly [1] - 2053:19
account [6] - 1998:3, 2074:25, 2075:3,
2075:11
accountant [4] - 2027:4, 2085:10,
2088:5, 2100:7
accountants [2] - 2009:4, 2088:21
accounting [28] - 2009:5, 2015:23,
2028:13, 2031:17, 2032:23, 2100:5,
2100:15, 2100:19, 2100:21, 2101:7,
2101:18, 2103:5, 2125:10, 2132:13,
2132:19, 2133:1, 2161:1, 2199:1,
2221:22, 2238:6, 2238:12, 2239:12,
2239:22, 2240:15, 2240:22, 2241:17,
2241:19
accounts [1] - 1982:21
accuracy [2] - 2074:17, 2160:8
3 [4] - 2016:3, 2081:17, 2118:17,

2136:22
30 [12] - 1996:8, 1998:8, 2012:14,
2029:6, 2029:20, 2038:11, 2039:3,
7
2040:10, 2040:12, 2244:13, 2253:11,
2255:7
7 [1] - 1971:8
30-second [2] - 2038:25
7-4 [1] - 1989:13
30th [4] - 1992:24, 1993:6, 1994:16,
70 [4] - 2186:18, 2186:20, 2186:21,
1994:21
2186:22
31 [8] - 1971:5, 2028:11, 2030:25,
713.250.5581 [2] - 1972:12, 1972:19
2032:21, 2063:15, 2088:17, 2151:10,
77002 [4] - 1971:23, 1972:4, 1972:11,
2154:24
1972:19
31st [4] - 1990:17, 2002:10, 2003:1,
77208-1129 [1] - 1971:15
2157:16
2260
2102:20, 2103:12, 2105:14, 2105:21,
accurate [9] - 1981:8, 1981:10,
affirmatively [1] - 1992:12
2105:23, 2107:3, 2107:7, 2135:21,
1981:16, 1982:4, 1982:5, 1982:12,
affirmatively) [3] - 2020:5, 2020:7,
2150:1, 2156:7, 2157:13, 2157:17,
1982:18, 2074:1, 2177:20
2237:4
2204:22, 2204:24, 2209:17, 2211:25,
achieve [1] - 2216:7
afford [1] - 2236:21
2219:4, 2242:6
acquire [7] - 2186:25, 2191:8,
afraid [1] - 1985:7
allen [2] - 2151:20, 2202:20
2192:15, 2206:3, 2209:17, 2218:23,
Africa [1] - 2020:6
allow [8] - 1981:5, 1981:9, 2001:16,
2218:24
afternoon [6] - 2099:9, 2099:10,
2049:21, 2078:6, 2102:10, 2203:11
acquired [5] - 2187:25, 2188:1,
2155:9, 2169:10, 2179:1, 2257:6
allowed [7] - 1977:19, 1978:1,
2205:15, 2205:16, 2219:2
agency [16] - 2009:18, 2014:13,
1981:12, 1982:9, 2049:17, 2137:9
acquiring [3] - 2190:21, 2217:20,
2028:22, 2029:12, 2030:14, 2040:14,
alludes [1] - 2000:22
2218:18
2040:23, 2041:17, 2042:6, 2042:19,
almost [5] - 2079:16, 2141:3, 2164:23,
acquisitions [1] - 2127:4
2043:24, 2045:11, 2045:23, 2055:22,
2205:16, 2241:21
acres [2] - 2139:17, 2192:17
2057:7, 2069:17
Althea [2] - 2053:20, 2057:12
acronym [2] - 2007:14, 2010:10
agency's [1] - 2033:21
ALTHEA [1] - 1973:4
act [6] - 2001:20, 2049:16, 2049:18,
agent [10] - 1984:12, 1984:15,
ambit [1] - 2079:3
2050:19, 2089:11, 2090:6
1984:16, 2008:19, 2008:23, 2008:25,
amended [1] - 2046:13
2009:1, 2009:15, 2094:2, 2182:6
Act [10] - 1975:16, 2046:10, 2048:1,
agents [6] - 2177:9, 2179:2, 2179:9,
amendments [3] - 2070:3, 2071:13,
2050:17, 2052:11, 2058:25, 2089:3,
2090:5, 2090:7, 2090:21
2181:1, 2181:3, 2182:10
2072:1
action [1] - 2002:8
ago [7] - 2011:6, 2036:19, 2039:14,
America [8] - 2004:13, 2004:14,
2072:14, 2142:10, 2177:1, 2239:12
2213:18, 2231:24, 2245:21, 2248:13,
actions [1] - 2014:22
2248:14
agree [10] - 2003:5, 2008:18, 2064:2,
activities [1] - 2232:8
AMERICA [1] - 1971:4
2068:2, 2079:13, 2079:15, 2084:3,
actual [2] - 2050:19, 2127:7
2113:13, 2132:23, 2178:18
American [2] - 2144:22, 2232:2
ad [4] - 2102:23, 2102:24, 2103:3,
agreement [2] - 2055:5, 2244:10
amount [13] - 2064:3, 2146:4, 2152:1,
2130:25
agreements [1] - 2054:25
2154:24, 2157:17, 2166:12, 2183:24,
add [1] - 2166:15
2184:1, 2184:2, 2184:7, 2184:24,
agrees [1] - 2209:11
addition [6] - 2003:12, 2009:14,
2241:7, 2241:22
ahead [12] - 1975:6, 1989:23, 2002:19,
2047:10, 2053:12, 2054:23, 2240:14
amounts [4] - 1978:14, 2031:14,
2002:23, 2041:16, 2056:8, 2079:24,
additional [1] - 2049:3
2239:6, 2241:12
2097:9, 2129:14, 2147:20, 2147:22,
additionally [1] - 2047:8
Andrew [1] - 1971:16
2151:1
address [11] - 1993:16, 2011:14,
AIBCI [1] - 2006:16
Anguilla [1] - 2018:18
2011:20, 2027:23, 2027:25, 2029:21,
aim [1] - 2086:1
annual [42] - 2027:6, 2027:8, 2027:10,
2029:25, 2030:1, 2048:3, 2057:9,
2027:11, 2028:18, 2028:20, 2030:11,
aircraft [2] - 2024:1, 2144:18
2151:21
2033:4, 2033:20, 2035:2, 2074:11,
airline [2] - 2137:25, 2138:1
addressed [4] - 1998:25, 1999:1,
2109:17, 2109:22, 2111:14, 2125:20,
2045:25, 2057:12
Airlines [1] - 2144:23
2148:12, 2148:24, 2156:9, 2156:23,
addresses [2] - 2047:24, 2048:9
airlines [5] - 2146:4, 2146:6, 2146:8,
2157:7, 2157:12, 2158:1, 2158:2,
2146:24, 2209:2
adds [1] - 2141:6
2158:6, 2158:21, 2158:25, 2159:17,
airplane [3] - 2137:7, 2137:8, 2250:5
adequacy [2] - 2032:6, 2032:13
2221:11, 2228:6, 2228:22, 2229:1,
airplanes [1] - 2137:8
adequate [2] - 2042:13, 2193:25
2229:8, 2229:20, 2230:12, 2239:5,
Airport
[2]
2063:21,
2208:22
adequately [1] - 2031:21
2241:25, 2246:17, 2246:24, 2248:7,
airport [24] - 2024:8, 2024:9, 2024:10,
adhere [1] - 1982:3
2248:16, 2251:16
2024:12, 2024:14, 2024:16, 2081:22,
adjacent [1] - 2139:17
answer [30] - 1981:4, 1981:23, 1987:5,
2139:18, 2144:18, 2144:22, 2192:17,
adjudged [1] - 2002:16
1996:25, 1997:1, 2004:15, 2037:25,
2197:16, 2197:18, 2208:22, 2208:23,
Adler [1] - 2108:8
2070:24, 2079:5, 2081:1, 2081:3,
2209:7, 2209:10, 2210:7, 2234:14,
administration [2] - 2059:4, 2100:4
2084:2, 2089:3, 2089:6, 2091:5,
2236:3,
2236:6,
2236:7,
2236:25,
administrative [1] - 2012:4
2110:14, 2114:5, 2116:2, 2116:4,
2242:23
admit [5] - 2022:12, 2044:12, 2051:14,
2124:15, 2124:18, 2127:13, 2127:14,
Alabama [1] - 2134:22
2051:23, 2056:3
2128:18, 2129:1, 2175:11, 2175:12,
Albert [2] - 1990:13, 1994:5
admitted [9] - 1988:24, 2002:5,
2203:14, 2225:25
alerting
[1]
2013:15
2017:7, 2035:2, 2038:6, 2044:22,
answer) [1] - 2185:25
Ali [1] - 1971:20
2118:10, 2153:25, 2207:16
Answered [3] - 2020:5, 2020:7, 2237:4
allegation [1] - 2016:5
admitting [1] - 2065:23
answered [6] - 1987:6, 1988:16,
allegedly
[1]
2097:5
advertise [1] - 2173:10
2084:6, 2102:23, 2115:11, 2251:21
ALLEN [1] - 1971:6
advertised [2] - 2103:5, 2173:17
answering [1] - 2181:7
Allen [51] - 1990:9, 1992:19, 1992:23,
advertisement [1] - 2130:25
answers [3] - 1980:16, 2001:14,
1993:6, 1993:12, 1993:14, 1994:12,
advertising [1] - 2172:19
2183:10
1994:14,
1997:13,
1997:17,
1997:18,
advice [2] - 2001:14, 2226:20
anti [1] - 2070:1
1998:3, 1998:6, 1998:10, 1998:16,
advisor [1] - 2001:7
anti-money [1] - 2070:1
1998:23,
1999:2,
1999:3,
2000:9,
aerial [1] - 2025:6
anticipation [1] - 2242:21
2000:17,
2000:19,
2001:2,
2002:14,
affairs [2] - 2028:10, 2032:21
Antigua [109] - 1993:1, 1993:13,
2009:22,
2016:10,
2054:1,
2054:4,
Affiliate [2] - 2118:14, 2118:23
1995:24,
1996:4, 1996:9, 1996:16,
2063:18,
2069:23,
2071:19,
2081:22,
2261
1997:5, 1997:15, 1997:16, 1998:9,
2052:15, 2060:12, 2060:15, 2241:21,
attended [3] - 2109:24, 2115:22,
2003:9, 2004:7, 2004:10, 2005:12,
2254:19
2117:19
2006:10, 2011:12, 2011:22, 2013:10,
applying [1] - 2049:8
attention [4] - 2066:4, 2108:15,
2013:17, 2014:14, 2015:6, 2017:24,
appreciate [1] - 2147:23
2160:18, 2229:13
2018:3, 2018:8, 2023:15, 2023:17,
approach [2] - 2181:8, 2182:14
attorney [5] - 1990:10, 1991:20,
2023:18, 2023:20, 2024:5, 2024:7,
1991:22, 1992:11, 2049:20
appropriate [4] - 2031:18, 2092:14,
2024:13, 2024:25, 2025:1, 2025:18,
Attorney [2] - 1971:14, 1972:3
2095:5, 2231:4
2026:10, 2028:15, 2029:12, 2032:25,
approval [3] - 2046:6, 2046:17, 2047:5
attorneys [4] - 2022:9, 2025:25,
2033:5, 2034:9, 2034:11, 2040:5,
2142:24, 2207:8
approximate [1] - 2169:21
2054:24, 2063:22, 2070:1, 2074:7,
attract [1] - 2194:25
April [5] - 2013:5, 2013:8, 2013:13,
2077:18, 2090:8, 2097:17, 2129:25,
attracted [2] - 2195:14, 2195:24
2040:9, 2060:17
2135:10, 2135:11, 2136:4, 2136:5,
architects [2] - 2219:21, 2220:16
audible [1] - 2185:25
2136:8, 2136:15, 2136:16, 2137:7,
architecture [3] - 2219:20, 2219:25,
audit [7] - 2026:10, 2026:12, 2031:6,
2139:16, 2141:1, 2142:8, 2144:18,
2220:1
2031:11, 2031:22, 2230:8, 2238:18
2144:19, 2146:15, 2160:24, 2161:2,
area [11] - 2004:21, 2078:5, 2082:9,
audited [5] - 2030:24, 2033:9,
2161:18, 2165:2, 2165:15, 2166:2,
2082:10, 2082:11, 2099:16, 2102:11,
2225:16, 2225:18, 2225:23
2167:13, 2188:23, 2190:1, 2190:6,
2120:9, 2139:15, 2186:19, 2218:22
auditing [4] - 2027:2, 2031:12, 2230:9,
2190:12, 2190:17, 2192:1, 2192:7,
areas [1] - 2069:11
2230:18
2192:8, 2192:19, 2192:22, 2193:16,
argue [1] - 2054:11
auditor [5] - 2027:14, 2032:10,
2195:14, 2195:16, 2197:15, 2205:13,
2159:18, 2159:21, 2160:5
argumentative [5] - 2075:5, 2076:18,
2205:18, 2205:19, 2208:12, 2210:17,
2078:3, 2078:24, 2080:21
auditor's [2] - 2027:12, 2160:2
2210:19, 2210:21, 2211:4, 2211:17,
argumentive [1] - 2075:14
Auditors [1] - 2031:2
2211:24, 2213:13, 2214:2, 2218:19,
arguments [1] - 2078:25
auditors' [1] - 2159:15
2222:9, 2222:10, 2234:14, 2234:25,
arm's [2] - 2206:9, 2206:11
Auditors' [1] - 2030:21
2236:18, 2236:21, 2236:22, 2237:22,
Arnold [2] - 2098:24, 2099:13
audits [2] - 2027:8, 2230:13
2238:3, 2242:17, 2243:23
ARNOLD [3] - 1973:15, 2099:4,
August [6] - 1990:17, 2002:11,
Antiguan [28] - 1975:12, 1981:9,
2099:13
2043:10, 2043:11, 2056:24, 2182:3
1982:22, 1995:18, 1996:10, 2005:6,
arranged [2] - 2064:20, 2064:21
Austin [3] - 2101:11, 2122:20, 2171:7
2005:10, 2005:14, 2025:20, 2026:5,
arrested [1] - 2179:16
Australia [1] - 2020:4
2028:21, 2030:13, 2052:10, 2072:6,
arrived [2] - 2131:20, 2179:2
authentic [1] - 2052:7
2073:23, 2097:15, 2142:20, 2155:3,
arriving [1] - 2195:11
authenticate [1] - 2090:15
2165:4, 2209:14, 2209:17, 2210:11,
articles [1] - 2002:5
authenticated [2] - 2045:3, 2052:5
2210:13, 2235:9, 2235:17, 2239:2,
Aruba
[2] - 2119:5, 2164:5
author [3] - 2044:7, 2071:13, 2071:14
2239:8, 2239:10
aside
[2] - 2036:23, 2094:8
authored [2] - 2005:24, 2006:1
Antiguans [1] - 2025:2
aspect
[1] - 2096:22
authorities [3] - 1976:2, 2016:11,
anyhow [1] - 2151:2
2217:15
aspects [2] - 2097:1, 2133:16
anyway [1] - 2173:3
authority [3] - 2046:8, 2046:17,
assessment [1] - 2031:15
apartment [9] - 2023:12, 2121:2,
2092:20
asset
[1] - 1977:19
2125:25, 2133:22, 2171:12, 2171:13,
Authority [1] - 2006:2
assets [9] - 1976:17, 1977:16,
2183:23, 2186:22, 2187:2
available [3] - 1975:25, 2033:4, 2187:9
1977:24,
1979:14,
1982:20,
2026:6,
Apartments [4] - 2121:3, 2121:6,
Avenue [1] - 1971:17
2073:2,
2073:18,
2149:3
2121:17, 2122:7
assist [2] - 2008:10, 2049:19
average [1] - 2194:9
apartments [3] - 2186:21, 2186:22,
assistance [1] - 1976:5
Aviation [3] - 2137:14, 2137:16,
2190:11
2138:4
Assistant
[1] - 1971:14
apologize [1] - 2096:10
aviation [2] - 2137:20, 2137:21
assisted [2] - 1972:13, 1972:21
appear [7] - 1993:22, 1994:19,
avoid [4] - 2079:12, 2102:9, 2223:11,
assists [1] - 2168:9
1995:16, 1996:6, 1998:5, 1998:15,
2225:9
Associate
[1]
2039:7
2068:5
aware [11] - 2016:1, 2016:7, 2016:9,
assume [3] - 2059:22, 2185:4, 2212:7
APPEARANCES [1] - 1971:12
2024:3, 2066:10, 2078:14, 2093:16,
assumes [3] - 2076:17, 2078:2,
appeared [1] - 1990:16
2138:20, 2146:25, 2231:13
2080:20
applicant [5] - 2049:4, 2049:13,
awhile [1] - 2245:16
assuming
[4]
2078:13,
2123:18,
2091:18, 2092:15, 2106:23
awkward [3] - 2082:18, 2082:20,
2146:19, 2152:9
application [17] - 2047:22, 2047:25,
2083:7
assurance
[1]
2031:25
2048:1, 2048:22, 2049:7, 2050:5,
Athletic [5] - 2077:18, 2136:15,
2050:6, 2051:3, 2051:12, 2052:16,
2136:16, 2139:13, 2211:17
B
2052:18, 2058:21, 2066:12, 2092:1,
Atlantic [1] - 2190:5
2092:4, 2092:8, 2092:19
atmosphere [3] - 2128:7, 2193:18,
applications [1] - 2062:25
bachelor's [1] - 2100:4
2193:19
applied [5] - 2031:21, 2117:2, 2117:5,
background [7] - 2100:1, 2103:4,
attached [3] - 2024:8, 2024:9, 2203:21
2230:16, 2249:11
2174:4, 2175:1, 2183:12, 2183:20,
attempt [2] - 2088:11, 2088:20
applies [4] - 2006:19, 2050:9, 2051:11,
2204:17
attempted [2] - 2020:17, 2087:2
2052:11
backwards [1] - 2040:6
attend [1] - 2109:15
apply [8] - 1986:22, 2006:16, 2017:3,
bad [12] - 2001:2, 2016:16, 2016:21,
2262
2026:18, 2073:1, 2073:19, 2101:25,
2156:24, 2157:7, 2162:5, 2169:5,
began [2] - 2015:25, 2034:21
2120:14, 2191:17, 2211:1, 2222:21,
2169:6, 2192:7, 2192:8, 2195:12,
begin [1] - 2134:4
2222:23
2195:16, 2210:12, 2210:13, 2210:16,
beginning [5] - 2085:1, 2111:21,
2210:17, 2210:19, 2210:21, 2211:4,
bag [1] - 2045:18
2168:18, 2233:18, 2233:25
2232:25, 2245:21, 2246:16
Bahamas [1] - 2005:16
begins [1] - 2040:1
Bank's [1] - 1978:23
Bailey [4] - 2043:16, 2043:20, 2064:23,
behind [7] - 2019:20, 2034:22,
bank's [26] - 1977:25, 1978:13,
2065:1
2039:11, 2082:1, 2097:2, 2162:9,
1980:16, 1982:20, 1992:8, 1992:25,
Baker [1] - 1985:4
2194:14
1993:9, 1993:13, 1998:9, 2031:18,
balance [2] - 2157:20, 2188:12
belief [3] - 2093:10, 2093:12, 2094:12
2073:1, 2086:13, 2109:17, 2109:22,
balances [5] - 1978:15, 1978:25,
below [2] - 2151:23, 2199:14
2112:15, 2113:11, 2115:1, 2115:9,
1979:5, 1979:22
bench [1] - 1984:6
2121:10, 2121:21, 2129:11, 2149:2,
ball [1] - 2078:25
Bend [1] - 2099:15
2159:21, 2165:18, 2165:21, 2241:25
bank [160] - 1975:12, 1976:7, 1976:10,
beneath [2] - 2252:25, 2253:9
bank-rolled [1] - 2069:22
1976:15, 1976:16, 1977:15, 1977:21,
beneficial [1] - 2046:15
banker [4] - 2116:20, 2160:10,
1978:1, 1979:7, 1979:11, 1979:15,
benefit [2] - 2003:20, 2212:21
2160:11, 2160:14
1981:5, 1981:19, 1981:20, 1982:2,
benefits [1] - 2209:6
bankers [7] - 2068:12, 2108:24,
1993:16, 1995:22, 1995:24, 1996:9,
Best [1] - 2193:22
2108:25, 2115:21, 2116:11, 2117:17,
1997:7, 1998:19, 2005:7, 2006:16,
best [28] - 1976:21, 2025:10, 2089:11,
2160:17
2016:6, 2016:14, 2025:1, 2028:11,
2140:20, 2165:7, 2192:22, 2193:18,
banking [20] - 1976:9, 1977:7,
2029:16, 2036:8, 2047:16, 2053:15,
2193:19, 2194:2, 2194:3, 2194:12,
1981:22, 1982:10, 1982:17, 2001:7,
2057:8, 2059:2, 2062:16, 2064:9,
2194:21, 2197:4, 2197:9, 2200:25,
2004:3, 2005:11, 2005:17, 2006:11,
2066:11, 2069:22, 2072:22, 2073:17,
2201:12, 2215:6, 2215:7, 2215:9,
2006:13, 2006:23, 2011:11, 2065:11,
2073:22, 2074:20, 2074:23, 2074:25,
2215:10, 2234:18, 2234:21
2065:12, 2069:25, 2086:8, 2087:21,
2075:2, 2075:11, 2078:13, 2087:12,
best-in-the-world [1] - 2234:21
2087:22, 2130:3
2087:14, 2104:13, 2104:14, 2104:17,
better [13] - 1980:24, 1980:25,
bankruptcy [5] - 2048:23, 2048:24,
2107:11, 2107:17, 2107:21, 2107:22,
2001:25, 2004:4, 2005:3, 2005:5,
2051:9, 2066:14, 2091:6
2108:1, 2108:2, 2108:3, 2108:4,
2005:8, 2082:1, 2119:6, 2127:21,
banks [17] - 1979:13, 1979:16,
2108:18, 2108:20, 2108:23, 2109:25,
2193:24
2110:10, 2110:19, 2111:5, 2112:3,
2004:18, 2013:23, 2014:19, 2014:20,
between [11] - 1976:4, 1990:8, 2055:5,
2113:25, 2114:1, 2114:7, 2114:18,
2015:19, 2015:22, 2053:6, 2054:23,
2082:9, 2082:12, 2082:13, 2084:20,
2114:23, 2115:20, 2117:2, 2117:5,
2060:4, 2061:1, 2061:2, 2094:3,
2126:6, 2183:1, 2209:16, 2246:12
2118:6, 2119:2, 2119:15, 2119:24,
2095:14, 2245:21
beyond [5] - 2035:22, 2036:22,
2120:2, 2122:10, 2123:11, 2123:15,
banks's [2] - 2015:24, 2125:20
2054:15, 2088:13, 2240:19
2123:17, 2123:24, 2124:1, 2124:9,
bar [1] - 2213:12
bids [1] - 2140:10
2124:12, 2124:24, 2124:25, 2126:6,
Bar [2] - 2137:1, 2211:13
big [16] - 2000:2, 2009:4, 2009:5,
2126:22, 2127:6, 2129:4, 2129:19,
Barbuda [5] - 2013:17, 2017:24,
2023:15, 2097:3, 2100:18, 2100:24,
2129:22, 2129:24, 2132:7, 2132:16,
2028:15, 2032:25, 2208:12
2161:1, 2213:10, 2213:16, 2214:22,
2132:23, 2148:18, 2148:21, 2153:2,
Barnacle [5] - 2138:11, 2138:13,
2215:15, 2215:25, 2216:2, 2236:18,
2153:11, 2155:22, 2157:13, 2157:16,
2196:25, 2212:8, 2218:7
2236:22
2158:9, 2159:18, 2160:20, 2165:13,
barrister [2] - 2204:19, 2205:2
Big [1] - 2100:20
2165:22, 2165:24, 2168:21, 2168:25,
barristers [1] - 1999:25
biggest [1] - 2146:8
2169:2, 2186:6, 2192:8, 2193:17,
base [3] - 2128:21, 2208:23, 2208:25
Bill [3] - 2105:9, 2105:16, 2105:23
2197:16, 2210:20, 2227:8, 2227:13,
baseball [5] - 2019:4, 2019:5, 2019:6,
bill [1] - 2204:1
2227:14, 2233:1, 2233:3, 2234:9,
2019:7, 2190:25
billion [2] - 2149:4, 2149:5
2235:21, 2235:23, 2236:16, 2237:14,
based [5] - 2031:6, 2067:22, 2081:2,
billionaires [5] - 2218:3, 2218:24,
2239:3, 2244:9, 2244:10, 2244:22,
2110:17
2219:6, 2237:6, 2250:13
2245:1, 2245:3, 2245:4, 2245:5,
bases [1] - 2214:13
bills [2] - 2101:19, 2199:3
2245:15, 2245:16, 2245:18, 2246:3,
Basis [1] - 2230:2
binds [1] - 2018:23
2246:4, 2246:8, 2246:11, 2247:4,
basis [8] - 1978:10, 2031:10, 2031:13,
Bird [1] - 2208:21
2247:9, 2250:17, 2250:24, 2251:13
2070:11, 2078:16, 2078:18, 2114:14,
bit [13] - 2017:5, 2040:6, 2046:11,
Bank [70] - 1976:12, 1976:13, 1976:17,
2152:22
2099:21, 2108:11, 2127:19, 2129:14,
1977:17, 1978:16, 1979:14, 1979:21,
Bates [3] - 1992:15, 2023:7, 2024:23
2173:23, 2175:24, 2179:7, 2183:21,
1980:3, 1980:15, 1994:13, 1994:15,
BDO [1] - 2009:5
2201:14, 2213:7
1995:1, 1995:4, 1995:12, 1995:22,
beat [1] - 2214:5
black [1] - 2039:20
1995:23, 1995:25, 1996:21, 2002:17,
beautiful [1] - 2102:6
Blackman [5] - 2046:7, 2047:2,
2002:21, 2016:2, 2016:10, 2023:11,
became [12] - 2019:12, 2039:8,
2047:9,
2047:11, 2047:15
2024:25, 2025:1, 2026:10, 2043:6,
2039:20, 2043:20, 2065:4, 2123:9,
blank [1] - 2038:5
2043:23, 2046:1, 2046:21, 2056:19,
2133:7, 2134:10, 2134:12, 2135:23,
blanket [1] - 2256:18
2057:3, 2063:20, 2067:19, 2067:23,
2212:3, 2250:25
block [1] - 2029:21
2074:5, 2086:20, 2087:20, 2097:16,
become [4] - 2040:23, 2040:25,
blocks [1] - 2103:15
2098:7, 2104:15, 2109:3, 2111:4,
2123:4, 2212:5
blood [1] - 2001:2
2111:14, 2114:8, 2139:14, 2141:16,
becoming [1] - 1996:4
blow [2] - 2154:10, 2156:1
2148:12, 2149:18, 2151:21, 2154:25,
BEFORERMR,
[1] - 1971:10
Johnny C. Sanchez,
CRR - jcscourtreporter@aol.com
2263
2204:25, 2206:5, 2231:24, 2233:12,
blown [2] - 1987:20, 2157:14
bring [12] - 2034:8, 2034:11, 2034:14,
2233:13, 2236:23, 2243:11, 2249:19,
2035:11, 2096:19, 2096:21, 2173:1,
blown-up [2] - 1987:20, 2157:14
2249:24
2186:14, 2189:21, 2229:13, 2230:1,
board [35] - 2007:6, 2010:23, 2010:24,
businesses [9] - 2023:6, 2042:19,
2247:11
2011:23, 2012:10, 2038:11, 2038:12,
2104:12, 2108:16, 2135:24, 2193:11,
bringing [1] - 2160:17
2040:10, 2040:13, 2041:14, 2041:17,
2249:22, 2249:25, 2250:4
2044:23, 2060:22, 2061:4, 2061:6,
brings [2] - 2173:2, 2250:6
but.. [1] - 2115:12
2069:6, 2069:7, 2072:19, 2101:21,
Britain [2] - 2221:22, 2222:1
button [2] - 2061:24
2105:2, 2105:12, 2106:7, 2130:9,
British [7] - 2117:8, 2117:13, 2118:1,
2130:12, 2131:11, 2162:24, 2185:10,
buy [6] - 2000:3, 2212:10, 2212:14,
2204:19, 2205:1, 2222:12, 2238:20
2202:5, 2202:7, 2203:25, 2204:9,
2219:15, 2246:10, 2254:12
broad [2] - 2011:9, 2085:13
2204:19, 2204:24, 2205:2, 2232:7
buying [1] - 2134:7
brochure [1] - 2118:18
Board [1] - 1997:6
buys [4] - 2244:21, 2247:3, 2256:3,
brochures [1] - 2118:5
boards [1] - 2047:24
2256:8
broke [2] - 2035:15, 2245:19
boat [4] - 2138:16, 2138:20, 2138:22
BY [186] - 1973:6, 1973:8, 1973:10,
brought [5] - 2011:23, 2141:4,
boats [1] - 2138:17
1973:12, 1973:17, 1973:19, 1973:21,
2186:12, 2209:6, 2250:12
1973:23, 1973:25, 1974:2, 1975:9,
body [12] - 2008:7, 2008:9, 2011:7,
budget [4] - 1987:12, 2041:21,
1977:13, 1980:13, 1980:19, 1983:17,
2028:22, 2029:1, 2061:8, 2065:13,
2041:22, 2140:8
1984:3, 1986:5, 1987:17, 1988:3,
2066:16, 2068:22, 2069:17, 2072:19,
budgets [3] - 2140:1, 2140:3, 2140:7
1990:1, 1990:7, 1991:17, 1992:4,
2221:24
build [23] - 2139:3, 2139:22, 2189:3,
1992:22, 1997:3, 1998:1, 2000:8,
bond [1] - 2255:8
2192:1, 2192:5, 2192:13, 2193:16,
2001:6, 2017:17, 2017:22, 2020:16,
bonds [20] - 2111:6, 2111:7, 2111:25,
2193:17, 2196:8, 2196:14, 2197:14,
2023:1, 2027:24, 2028:6, 2028:19,
2113:15, 2113:23, 2125:21, 2125:22,
2197:20, 2198:2, 2198:5, 2209:24,
2029:8, 2029:23, 2030:3, 2030:10,
2126:19, 2149:8, 2149:10, 2149:11,
2210:14, 2211:11, 2212:7, 2214:25,
2030:20, 2031:9, 2031:20, 2032:4,
2239:5, 2245:12, 2247:21, 2247:22,
2217:12, 2218:8, 2218:11, 2220:8
2032:9, 2040:3, 2045:7, 2045:21,
2247:23, 2253:3, 2253:23, 2255:12,
Building [2] - 2103:15, 2131:12
2046:12, 2049:24, 2050:13, 2052:9,
2255:15
building [31] - 2023:8, 2023:10,
2054:13, 2056:10, 2056:16, 2057:23,
bonuses [1] - 2167:24
2023:15, 2023:19, 2023:20, 2023:23,
2058:7, 2059:25, 2062:3, 2062:11,
book [6] - 2039:1, 2039:23, 2039:24,
2023:24, 2024:19, 2024:21, 2024:22,
2063:11, 2066:2, 2066:23, 2067:11,
2212:10, 2212:15
2024:24, 2024:25, 2077:24, 2120:13,
2070:16, 2071:3, 2071:16, 2072:10,
bookkeeping [1] - 2099:22
2130:17, 2131:12, 2139:14, 2145:1,
2073:15, 2075:8, 2075:17, 2076:5,
books [4] - 2160:6, 2174:9, 2174:25,
2163:4, 2163:16, 2192:7, 2195:3,
2076:12, 2077:1, 2077:17, 2080:1,
2212:15
2206:19, 2206:22, 2209:23, 2210:13,
2080:12, 2081:5, 2081:13, 2083:6,
born [2] - 2018:2, 2018:3
2210:16, 2211:12, 2215:6, 2217:24,
2084:9, 2084:18, 2085:8, 2085:23,
2233:2
borrow [3] - 2223:12, 2223:13,
2086:4, 2088:15, 2089:18, 2091:2,
buildings [12] - 2023:5, 2025:17,
2224:18
2092:13, 2096:7, 2097:11, 2098:3,
2025:19, 2025:21, 2084:25, 2139:23,
borrowed [1] - 2224:19
2099:8, 2101:1, 2102:18, 2104:5,
2141:1, 2196:20, 2210:14, 2210:18,
borrows [1] - 2248:14
2105:20, 2106:6, 2110:16, 2111:1,
2234:21, 2236:23
bothered [1] - 2175:8
2111:13, 2111:23, 2113:8, 2113:24,
built [47] - 2085:1, 2134:11, 2134:13,
bottom [19] - 1980:9, 1985:19,
2114:6, 2114:21, 2115:7, 2116:8,
2134:16, 2134:19, 2134:20, 2135:10,
1985:23, 1997:12, 2015:11, 2027:23,
2116:16, 2117:11, 2117:25, 2118:12,
2135:11, 2137:2, 2137:11, 2137:15,
2029:22, 2030:8, 2042:5, 2058:3,
2118:19, 2119:23, 2121:7, 2123:21,
2138:10, 2140:15, 2140:16, 2143:22,
2058:14, 2059:3, 2083:16, 2111:21,
2124:7, 2124:19, 2124:23, 2125:14,
2190:23, 2190:24, 2190:25, 2191:25,
2118:11, 2118:20, 2118:23, 2159:24,
2128:2, 2128:16, 2135:4, 2136:12,
2192:6, 2196:20, 2196:22, 2196:24,
2225:16
2136:24, 2137:5, 2138:8, 2138:18,
2196:25,
2197:4,
2197:8,
2197:25,
bought [5] - 2216:5, 2235:25, 2246:7,
2138:25, 2139:8, 2143:20, 2144:6,
2198:3, 2198:7, 2198:10, 2210:11,
2248:25, 2256:16
2144:15, 2145:15, 2146:21, 2147:12,
2210:12, 2210:13, 2212:8, 2212:9,
Boulevard [1] - 2063:21
2148:8, 2149:1, 2151:8, 2152:25,
2212:21,
2213:5,
2214:21,
2214:22,
bowl [1] - 2082:19
2154:1, 2154:11, 2154:23, 2155:17,
2215:2,
2216:17,
2236:8,
2236:25,
bowler [1] - 2082:21
2156:2, 2156:17, 2157:5, 2157:11,
2243:1, 2249:16
bowlers [1] - 2082:19
2158:22, 2159:4, 2159:9, 2159:14,
Business
[4]
1975:16,
2046:10,
Box [2] - 1971:14, 1972:7
2159:25, 2161:15, 2167:2, 2169:9,
2050:16,
2090:7
boxes [3] - 2093:18, 2093:19, 2093:25
2174:1, 2176:2, 2180:17, 2180:23,
business [56] - 1976:10, 1977:7,
break [17] - 1984:5, 1989:20, 2033:13,
2181:5, 2184:17, 2197:10, 2200:12,
1993:10,
1998:20,
2001:13,
2002:18,
2034:21, 2034:24, 2077:8, 2078:7,
2203:13, 2207:21, 2208:9, 2208:15,
2004:4,
2005:11,
2005:17,
2006:11,
2151:7, 2155:7, 2155:9, 2155:18,
2227:4, 2228:3, 2228:20, 2230:4,
2006:12, 2006:14, 2006:15, 2007:3,
2156:8, 2156:12, 2159:2, 2207:11,
2231:11, 2231:18, 2232:6, 2233:17,
2008:10,
2013:10,
2016:16,
2016:21,
2249:15, 2249:18
2240:13, 2241:4, 2243:10, 2244:4,
2036:20,
2060:24,
2067:25,
2073:1,
breaking [1] - 2243:4
2246:1, 2247:16, 2251:7, 2252:2,
2101:25, 2106:3, 2120:13, 2120:14,
breaks [1] - 2164:10
2253:1, 2254:6, 2255:4
2133:16,
2146:22,
2161:23,
2162:7,
brick [2] - 2196:16, 2237:5
2162:8, 2163:7, 2168:25, 2172:17,
bricks [2] - 2196:18, 2237:3
2172:23, 2190:22, 2191:24, 2202:21,
briefly [5] - 2016:14, 2084:15, 2098:1,
2202:24, 2203:17, 2203:19, 2204:17,
2099:25, 2198:24
2264
certain [7] - 1976:1, 2013:16, 2139:15,
clarify [2] - 2105:17, 2133:3
2150:25, 2183:24, 2184:2, 2207:2
class [4] - 2046:16, 2215:16, 2218:17,
certainly [7] - 2015:2, 2040:22,
2236:17
C.P [1] - 1993:11
2075:20, 2098:20, 2113:21, 2219:22,
Clean [21] - 2010:6, 2012:7, 2013:19,
cabinet [4] - 2208:11, 2209:6, 2209:10
2241:13
2013:22, 2013:25, 2014:3, 2014:8,
Cabinet [1] - 2209:4
CERTIFICATE [1] - 2257:8
2014:14, 2014:18, 2014:22, 2015:5,
cabinets [4] - 2093:20, 2093:22,
2015:11, 2015:16, 2069:21, 2069:22,
certificate [8] - 2036:6, 2043:25,
2094:16, 2094:22
2069:24, 2070:2, 2070:8, 2070:13,
2046:4, 2053:18, 2054:16, 2054:18,
Caldwell [5] - 1990:9, 1993:8,
2070:22, 2072:3
2054:21, 2246:2
2002:15, 2105:10, 2204:10
clean [1] - 2238:21
certificates [2] - 2108:6, 2244:5
California [1] - 2102:3
clear [10] - 1996:2, 1996:22, 2015:4,
certification [1] - 2074:15
cannot [5] - 1995:3, 2010:3, 2033:6,
2045:4, 2052:18, 2087:24, 2094:12,
certified [4] - 2027:4, 2074:13, 2100:6,
2245:3, 2245:4
2095:15, 2112:16, 2196:12
2103:5
capacity [2] - 2056:1, 2249:22
cleared [1] - 2003:17
certify [3] - 1995:1, 2054:10, 2257:10
capital [6] - 2211:2, 2223:10, 2223:25,
clearer [1] - 2207:18
cetera [3] - 2068:13, 2092:17
2224:13, 2224:14, 2224:16
clearly [1] - 2091:12
CFO [5] - 2130:20, 2131:1, 2133:18,
capitalize [1] - 2223:7
clicking [1] - 2096:14
2174:19, 2198:21
caption [1] - 2248:17
client [2] - 1981:1, 2160:7
chain [1] - 2018:18
captive [2] - 2117:21, 2118:2
clientele [1] - 2187:6
Chairman [1] - 1997:6
car [3] - 2204:5, 2205:1
clients [17] - 2061:1, 2061:3, 2115:24,
chairman [7] - 1993:12, 1993:14,
care [3] - 2122:3, 2122:17, 2161:20
2116:22, 2121:10, 2121:21, 2123:15,
2007:23, 2008:6, 2060:22, 2061:4,
carefully [1] - 1999:1
2124:2, 2124:9, 2124:13, 2126:22,
2061:6
Caribbean [22] - 2004:13, 2004:21,
2160:19, 2161:5, 2186:6, 2195:11,
Chamberlain [1] - 2226:8
2005:15, 2009:21, 2018:13, 2043:2,
2213:11, 2236:16
Chambliess [1] - 2108:9
2138:3, 2140:17, 2140:24, 2146:9,
clip [5] - 2142:10, 2143:8, 2143:9,
chance [2] - 1984:23, 2243:4
2146:10, 2161:25, 2162:9, 2163:12,
2143:11, 2143:12
change [10] - 2037:21, 2037:22,
2163:19, 2165:1, 2165:11, 2166:14,
clock [5] - 1983:11, 1987:13, 2038:25,
2046:14, 2047:6, 2133:9, 2133:11,
2194:16, 2194:18, 2194:21
2153:17, 2228:1
2134:4, 2141:17, 2157:18, 2215:5
Carlos [1] - 2009:9
clocks [1] - 1983:12
changed [4] - 2015:8, 2122:25,
carry [1] - 2007:4
close [7] - 2002:3, 2127:22, 2188:11,
2201:4, 2217:5
Cas [1] - 2159:23
2219:1, 2221:17, 2241:14, 2256:20
changes [1] - 2183:2
case [14] - 1976:12, 1976:13, 1984:19,
closed [1] - 2187:21
characterization [1] - 2226:9
1984:20, 1990:8, 1990:12, 1990:16,
closing [3] - 2255:24, 2255:25, 2256:1
charge [6] - 2046:23, 2047:15,
2002:1, 2014:16, 2020:20, 2096:22,
club [8] - 2023:12, 2136:18, 2213:23,
2131:21, 2132:1, 2152:8, 2199:8
2097:3, 2097:4, 2097:14
2215:2, 2219:12, 2219:15, 2220:10,
charged [5] - 1985:7, 2047:12,
cases [5] - 2096:20, 2096:21, 2097:2,
2221:2
2047:14, 2179:13, 2179:18
2241:9
Club [9] - 2077:18, 2136:15, 2136:16,
Charles [10] - 1993:13, 1993:15,
Cash [1] - 2008:23
2139:14, 2211:17, 2217:24, 2218:1,
1994:12, 1995:17, 1997:12, 1997:19,
cast [1] - 2039:15
2218:2, 2218:9
1998:3, 1998:8, 2000:16
catcher [2] - 2082:1, 2082:2
cohesively [1] - 2003:22
check [2] - 1989:20, 2016:3
category [1] - 2085:13
college [3] - 2018:4, 2131:8, 2198:18
chess [1] - 1983:12
catering [2] - 2165:8, 2195:19
colonial [1] - 2020:4
chief [20] - 1998:11, 1998:16, 1998:17,
Catholic [1] - 2168:9
colonies [1] - 2020:4
1998:23, 2039:6, 2039:8, 2039:9,
caused [2] - 2032:1, 2069:18
Colony [2] - 1990:4, 2086:10
2039:12, 2039:13, 2039:20, 2130:13,
cautioned [1] - 2099:5
comb [1] - 2029:16
2169:19, 2198:22, 2198:25, 2199:14,
caveat [1] - 2152:24
2199:16, 2199:20, 2199:22, 2199:24,
coming [23] - 1984:5, 2013:4, 2034:25,
Cayman [1] - 2005:16
2200:2
2036:13, 2047:5, 2058:9, 2058:11,
CD [23] - 2077:25, 2080:18, 2083:12,
Chief [2] - 2039:18, 2039:19
2058:14, 2072:1, 2127:10, 2135:20,
2084:12, 2108:25, 2110:1, 2119:15,
2145:19, 2146:2, 2146:3, 2146:16,
chiefs [1] - 2039:5
2135:15, 2234:21, 2235:8, 2235:16,
2146:18, 2147:7, 2147:9, 2147:13,
children [1] - 2189:12
2235:25, 2237:12, 2237:15, 2238:2,
2176:18, 2191:16, 2228:16, 2243:22
chooses [1] - 1992:6
2241:24, 2242:4, 2243:17, 2243:20,
comment [3] - 2039:1, 2105:14,
Chronicle [2] - 2102:25, 2103:2
2244:19, 2244:21, 2246:16, 2247:4
2105:23
chums [1] - 2198:18
CDs [6] - 2076:15, 2115:22, 2116:11,
comments [2] - 2045:1, 2045:2
circumstance [1] - 2183:6
2124:24, 2248:25, 2251:13
commercial [5] - 2112:1, 2114:1,
circumstances [3] - 1976:3, 2031:18,
cease [1] - 2087:15
2137:25, 2138:1, 2209:2
2060:10
ceased [3] - 2002:17, 2067:25,
commission [10] - 1978:8, 1979:23,
cities [1] - 2118:11
2087:14
1985:14, 2006:6, 2047:12, 2072:15,
civil [9] - 2000:1, 2008:9, 2096:20,
Cedar [3] - 2135:11, 2197:19, 2242:21
2074:12, 2075:9, 2075:19, 2249:9
2096:23, 2096:24, 2097:1, 2097:2,
Central [1] - 2004:13
commission's [1] - 2072:16
2097:4
cents [1] - 2063:23
commissioned [1] - 2006:5
civilly [1] - 1985:7
CEO [1] - 2062:16
Committee [4] - 2007:9, 2010:10,
clarification [1] - 2231:9
2010:23, 2068:25
2265
2240:15, 2241:5, 2250:8, 2254:16
committee [24] - 2007:15, 2007:18,
contacts [1] - 2230:25
concern [13] - 2026:23, 2026:25,
2007:22, 2008:19, 2008:22, 2009:19,
contain [3] - 1978:21, 1978:24,
2009:22, 2009:24, 2009:25, 2010:3,
2069:11, 2069:18, 2071:25, 2080:22,
1979:10
2010:4, 2010:8, 2010:9, 2010:12,
2147:7, 2147:13, 2147:16, 2167:8,
contained [4] - 1975:15, 1978:20,
2010:13, 2010:18, 2068:10, 2068:12,
2176:6, 2176:16
1998:24, 2012:25
2068:16, 2068:17, 2068:18, 2069:2,
concerned [10] - 1997:17, 2071:13,
containing [2] - 2053:9, 2093:20
2069:3, 2069:13
2129:7, 2147:8, 2153:6, 2166:12,
contains [2] - 1979:21, 1980:15
commonly [1] - 2253:6
2167:10, 2167:16, 2170:9, 2176:3
contents [1] - 2048:12
community [2] - 2011:21, 2072:2
concerning [2] - 2097:4, 2239:13
context [1] - 2148:4
compact [1] - 1979:2
concerns [11] - 2011:11, 2011:13,
continue [6] - 1981:11, 1981:18,
2011:15, 2011:20, 2069:10, 2140:4,
companies [23] - 1978:14, 2011:22,
1982:14, 2025:18, 2144:3, 2240:12
2140:6, 2146:1, 2148:5, 2148:6, 2206:4
2024:4, 2028:14, 2054:24, 2088:10,
continued [2] - 2212:7, 2234:10
conclude [1] - 1997:15
2101:12, 2117:6, 2125:12, 2130:17,
Continued [2] - 1972:1, 1972:2
2132:6, 2132:20, 2137:25, 2138:1,
condensed [1] - 2217:10
contract [2] - 2096:20, 2150:11
2169:3, 2181:19, 2181:21, 2182:14,
conditions [2] - 1975:16, 1975:23
control [4] - 2025:21, 2025:24, 2199:6,
2199:10, 2199:11, 2223:9, 2224:19,
conduct [1] - 2230:13
2232:20
2243:2
conducted [6] - 2031:11, 2033:11,
controller [11] - 2101:15, 2101:17,
Company [21] - 2123:5, 2127:2,
2033:12, 2094:15, 2230:8, 2230:17
2130:16, 2174:22, 2199:13, 2199:14,
2133:1, 2133:12, 2133:15, 2136:3,
conducting [2] - 2026:12, 2060:7
2199:19, 2199:22, 2199:23, 2200:2,
2136:17, 2137:3, 2137:12, 2137:15,
conferring [3] - 2022:9, 2142:24,
2200:4
2138:4, 2174:15, 2174:20, 2174:23,
2207:8
controllers [1] - 2199:17
2190:15, 2208:24, 2209:8, 2211:12,
confidence [2] - 2190:18, 2195:15
controls [1] - 2004:18
2223:10, 2223:25, 2224:12
confidential [1] - 2056:17
conversation [3] - 1994:11, 2183:18,
company [29] - 1979:9, 1999:4,
confirm [1] - 2097:14
2186:4
2027:25, 2097:6, 2102:14, 2102:19,
confused [1] - 2010:13
conversationally [1] - 2233:7
2117:15, 2117:20, 2117:21, 2118:2,
Congress [1] - 1971:22
conversion [1] - 2208:19
2122:25, 2132:13, 2134:4, 2135:5,
conjunction [5] - 2013:20, 2119:3,
convey [2] - 1987:20, 1987:22
2136:8, 2137:17, 2148:5, 2149:15,
2174:13, 2199:7, 2207:3
cooperated [1] - 2016:11
2149:19, 2158:9, 2166:8, 2174:13,
connect [1] - 1985:12
cooperatives [1] - 2007:3
2174:17, 2188:1, 2207:15, 2223:8,
connections [1] - 2230:21
copy [9] - 1980:22, 1989:1, 2045:1,
2235:13
connotation [1] - 2181:13
2053:8, 2090:24, 2159:10, 2177:19,
company's [3] - 2031:3, 2032:20,
conservative [7] - 2111:6, 2113:14,
2177:25, 2207:6
2032:24
2113:16, 2113:23, 2165:25, 2237:18,
corporate [4] - 2247:22, 2248:13,
compare [1] - 2005:14
2251:17
2248:14, 2253:3
compete [1] - 2005:15
consider [2] - 2071:2, 2237:18
Corporation [5] - 2047:22, 2123:1,
competitions [1] - 2213:25
considerably [2] - 2170:4, 2213:3
2123:2, 2133:12, 2238:16
competitors [3] - 2016:22, 2073:1,
considered [4] - 1987:3, 2006:22,
corporation [11] - 2092:16, 2148:19,
2073:20
2031:23, 2126:12
2152:7, 2152:17, 2153:3, 2153:8,
complained [1] - 2039:12
consisted [2] - 2204:24, 2205:2
2155:23, 2162:2, 2167:9, 2167:23,
complaint [5] - 2008:4, 2029:2,
2235:17
consistent [13] - 2112:2, 2113:9,
2029:4, 2058:18
Corporations [3] - 1975:16, 2046:10,
2114:11, 2114:22, 2142:19, 2143:25,
complete [5] - 2038:12, 2040:13,
2145:1, 2165:18, 2165:21, 2216:10,
2050:17
2041:17, 2053:3, 2053:18
2237:14, 2237:16, 2239:2
corporations [4] - 1991:1, 2010:2,
completed [3] - 2136:14, 2140:11,
consistently [1] - 2031:21
2036:20, 2052:12
2198:12
constituents [1] - 2013:15
correct [242] - 1981:24, 1981:25,
completely [2] - 2133:15, 2229:23
1983:22, 1984:6, 1984:7, 1984:10,
construct [2] - 2138:19, 2190:20
completion [1] - 2209:10
1984:12, 1986:23, 1987:3, 1988:14,
constructed [2] - 2236:4, 2236:9
complex [1] - 2186:22
1988:15, 1988:17, 1988:18, 1989:9,
construction [29] - 2101:10, 2101:12,
complexes [3] - 2125:25, 2133:22,
1989:16, 1991:21, 1994:18, 1994:21,
2134:12, 2135:23, 2136:1, 2137:12,
2183:23
1995:15, 1996:5, 1996:13, 1996:21,
2138:12, 2139:20, 2140:9, 2140:10,
compliance [1] - 2058:25
1997:9, 1998:14, 1999:5, 2001:16,
2140:19, 2141:11, 2142:11, 2146:12,
complied [1] - 2059:12
2003:6, 2003:9, 2004:5, 2004:10,
2146:23, 2155:2, 2164:8, 2167:12,
comply [3] - 2028:13, 2032:23,
2004:11, 2004:14, 2004:22, 2005:3,
2188:22, 2190:19, 2190:22, 2191:24,
2046:22
2005:12, 2005:13, 2005:17, 2005:24,
2192:2, 2192:4, 2208:23, 2211:16,
compulsive [3] - 2200:18, 2200:19,
2006:3, 2006:6, 2006:17, 2007:6,
2211:17, 2211:18, 2215:4
2200:21
2007:16, 2007:17, 2007:20, 2007:23,
constructive [2] - 2225:6, 2226:5
computer [8] - 1972:13, 1972:21,
2008:20, 2009:5, 2009:7, 2009:23,
construed [2] - 1982:15, 2091:6
2057:21, 2062:9, 2073:8, 2080:8,
2010:11, 2010:21, 2011:2, 2012:15,
consult [1] - 2226:19
2080:10, 2252:20
2013:23, 2015:12, 2015:13, 2015:19,
consultant [1] - 2249:18
computer-assisted [2] - 1972:13,
2015:24, 2017:4, 2018:24, 2020:10,
consulted [2] - 2222:25, 2233:11
1972:21
2020:19, 2024:19, 2025:4, 2025:18,
consummated [1] - 1996:9
concentrate [1] - 2254:1
2026:6, 2026:11, 2027:3, 2029:13,
contacted [1] - 2178:14
concept [6] - 2088:10, 2217:11,
2029:17, 2032:16, 2037:13, 2038:9,
2266
2040:15, 2040:25, 2042:7, 2042:14,
2118:12, 2118:17, 2118:19, 2119:23,
1976:20, 1976:24, 1977:2, 1977:5,
2043:17, 2043:21, 2046:1, 2046:24,
2121:7, 2123:21, 2124:7, 2124:19,
1977:9, 1977:12, 1980:4, 1980:9,
2046:25, 2047:3, 2047:20, 2047:24,
2124:23, 2125:9, 2125:14, 2128:2,
1983:1, 1983:3, 1983:6, 1983:10,
2048:9, 2048:18, 2048:20, 2048:25,
2128:16, 2135:4, 2136:10, 2136:12,
1983:24, 1984:2, 1985:22, 1985:25,
2049:7, 2049:14, 2049:15, 2050:7,
2136:22, 2136:24, 2137:4, 2137:5,
1986:2, 1987:8, 1987:11, 1989:7,
2050:8, 2051:12, 2051:13, 2052:11,
2138:7, 2138:8, 2138:18, 2138:24,
1989:9, 1989:12, 1989:17, 1989:20,
2052:20, 2052:21, 2053:23, 2053:24,
2138:25, 2139:6, 2139:8, 2142:22,
1989:23, 1991:15, 1991:19, 1991:22,
2054:16, 2054:17, 2054:19, 2054:20,
2143:2, 2143:6, 2143:8, 2143:12,
1991:24, 1992:1, 1996:24, 1997:2,
2055:1, 2055:6, 2055:7, 2056:19,
2143:14, 2143:17, 2143:19, 2143:20,
1997:22, 1999:6, 1999:9, 1999:12,
2056:22, 2056:23, 2057:9, 2057:10,
2144:3, 2144:6, 2144:13, 2144:15,
1999:15, 1999:20, 2017:11, 2017:16,
2057:18, 2057:19, 2058:14, 2058:20,
2145:15, 2146:21, 2147:12, 2147:18,
2017:19, 2020:14, 2022:14, 2022:17,
2058:25, 2060:6, 2060:11, 2060:15,
2147:20, 2148:2, 2148:4, 2148:8,
2022:19, 2022:23, 2027:21, 2034:20,
2060:18, 2060:19, 2063:8, 2064:24,
2148:23, 2149:1, 2150:4, 2150:11,
2035:4, 2035:9, 2035:25, 2036:3,
2065:5, 2065:6, 2070:20, 2071:10,
2150:17, 2151:3, 2151:8, 2152:11,
2036:9, 2036:13, 2036:16, 2036:23,
2073:24, 2073:25, 2074:18, 2084:21,
2152:15, 2152:21, 2152:25, 2153:14,
2037:1, 2037:5, 2037:9, 2037:15,
2084:22, 2085:3, 2085:14, 2087:2,
2153:16, 2153:21, 2153:23, 2154:1,
2037:18, 2037:22, 2037:24, 2038:3,
2087:16, 2087:18, 2089:19, 2089:24,
2154:9, 2154:11, 2154:21, 2154:23,
2038:16, 2038:22, 2038:24, 2044:14,
2090:18, 2090:19, 2091:7, 2091:15,
2155:6, 2155:14, 2155:16, 2155:17,
2044:19, 2044:21, 2045:6, 2045:15,
2091:19, 2091:23, 2091:24, 2092:5,
2155:25, 2156:2, 2156:15, 2156:17,
2045:20, 2046:11, 2049:20, 2051:17,
2092:6, 2093:2, 2093:3, 2093:5,
2157:2, 2157:5, 2157:10, 2157:11,
2051:21, 2052:1, 2052:8, 2054:11,
2093:6, 2093:8, 2093:14, 2094:3,
2158:20, 2158:22, 2159:3, 2159:4,
2056:5, 2059:21, 2061:13, 2061:17,
2094:5, 2094:6, 2094:7, 2095:9,
2159:8, 2159:9, 2159:12, 2159:14,
2061:20, 2061:23, 2062:8, 2063:6,
2095:12, 2095:16, 2095:23, 2095:24,
2159:24, 2159:25, 2161:15, 2167:2,
2066:1, 2067:6, 2070:4, 2070:9,
2102:12, 2103:25, 2104:1, 2104:8,
2169:7, 2180:14, 2181:2, 2184:8,
2070:12, 2070:15, 2070:24, 2071:9,
2106:18, 2107:4, 2107:13, 2109:1,
2184:11, 2184:15, 2200:9, 2203:4,
2071:14, 2072:9, 2073:9, 2075:6,
2112:20, 2121:25, 2123:24, 2130:14,
2207:13, 2227:25, 2228:17, 2229:19,
2075:16, 2076:4, 2076:9, 2076:19,
2131:3, 2131:24, 2132:18, 2144:24,
2231:9, 2233:17, 2240:3, 2240:6,
2076:24, 2077:7, 2077:10, 2077:14,
2150:20, 2151:12, 2151:13, 2154:6,
2240:9, 2240:13, 2240:21, 2241:4,
2078:4, 2078:9, 2078:20, 2079:2,
2155:24, 2158:4, 2158:18, 2158:19,
2243:8, 2243:10, 2244:1, 2245:22,
2079:11, 2079:15, 2079:23, 2080:7,
2159:7, 2166:9, 2170:19, 2171:22,
2251:7, 2252:2, 2252:15, 2252:20,
2080:10, 2080:22, 2080:25, 2081:11,
2172:11, 2174:18, 2175:3, 2175:13,
2252:22, 2253:1, 2253:25, 2254:3,
2081:23, 2082:5, 2082:7, 2082:15,
2175:20, 2176:7, 2176:11, 2179:11,
2254:6, 2254:22, 2256:22
2082:21, 2082:23, 2083:1, 2083:5,
2181:17, 2181:20, 2182:5, 2186:24,
2083:16, 2083:24, 2084:6, 2084:16,
COSTA............. [2] - 1973:21, 1973:25
2188:9, 2188:13, 2188:15, 2188:18,
2085:5, 2086:1, 2088:14, 2089:16,
COSTA............... [1] - 1973:17
2190:2, 2192:3, 2192:14, 2194:8,
2090:3, 2090:6, 2090:9, 2090:13,
costing [1] - 2146:12
2196:1, 2196:7, 2198:17, 2201:11,
2090:17, 2090:22, 2091:1, 2092:11,
costs [1] - 2140:6
2205:3, 2205:10, 2210:18, 2212:20,
2096:6, 2096:11, 2096:13, 2097:22,
council [2] - 2067:21, 2086:22
2214:20, 2224:4, 2225:1, 2228:22,
2097:25, 2098:13, 2098:15, 2098:22,
counsel [11] - 1983:4, 1983:13,
2231:15, 2234:5, 2235:15, 2238:17,
2098:25, 2100:23, 2102:16, 2103:25,
1983:24, 1999:6, 2022:19, 2034:20,
2239:6, 2239:20, 2242:16, 2245:9,
2104:3, 2105:19, 2106:1, 2106:5,
2034:25, 2035:23, 2069:20, 2078:4,
2245:14, 2246:6, 2248:23, 2249:5,
2110:4, 2110:13, 2110:24, 2112:11,
2096:11
2253:4, 2253:7, 2257:11
2112:19, 2113:2, 2113:20, 2114:16,
Counsel [14] - 1975:5, 1992:20,
2114:19, 2115:5, 2116:2, 2116:15,
correctly [8] - 2011:9, 2040:7, 2049:3,
1997:22, 2020:14, 2061:25, 2079:23,
2117:24, 2119:22, 2123:20, 2124:5,
2053:22, 2066:17, 2089:4, 2089:7,
2083:3, 2083:20, 2090:19, 2097:10,
2124:18, 2124:22, 2125:13, 2127:18,
2200:23
2097:25, 2098:13, 2147:24, 2175:22
2127:22, 2127:25, 2128:12, 2138:13,
correspondence [4] - 2034:6, 2034:8,
count [1] - 2171:17
2143:1, 2143:3, 2143:7, 2143:11,
2044:3, 2096:1
countries [4] - 1976:4, 1976:5, 2020:8,
2143:13, 2143:16, 2144:4, 2145:11,
cost [6] - 2140:4, 2141:6, 2194:6,
2221:24
2145:14, 2146:20, 2147:17, 2147:19,
2196:22, 2196:23, 2249:15
country [3] - 1977:9, 2017:2, 2209:7
2147:22, 2148:3, 2148:6, 2150:6,
costa [9] - 2213:6, 2221:10, 2240:1,
County [1] - 2099:15
2150:8, 2150:13, 2150:20, 2151:6,
2240:2, 2244:5, 2246:15, 2248:24,
couple [7] - 2039:8, 2104:25, 2127:15,
2152:13, 2152:23, 2153:15, 2153:17,
2249:8, 2255:5
2144:25, 2159:12, 2161:22, 2168:19
2153:20, 2153:22, 2153:25, 2155:8,
Costa [7] - 1971:13, 2112:23, 2222:5,
course [5] - 2039:12, 2064:22,
2155:13, 2155:15, 2161:11, 2161:14,
2227:5, 2228:25, 2229:7, 2230:20
2078:11, 2083:4, 2181:15
2166:24, 2173:23, 2175:22, 2175:25,
COSTA [161] - 2067:5, 2098:24,
Court [14] - 1972:10, 1972:17, 1989:4,
2180:16, 2181:4, 2184:10, 2184:14,
2099:8, 2101:1, 2102:18, 2104:2,
1990:4, 1990:18, 2002:6, 2009:22,
2184:16, 2197:7, 2200:11, 2203:5,
2104:5, 2105:20, 2106:2, 2106:6,
2035:17, 2039:2, 2039:12, 2039:17,
2207:7, 2207:9, 2207:16, 2227:3,
2110:5, 2110:16, 2111:1, 2111:8,
2078:18, 2086:10, 2090:24
2227:16, 2227:19, 2227:21, 2227:24,
2111:12, 2111:13, 2111:17, 2111:23,
court [15] - 1976:7, 1986:17, 1987:19,
2228:1, 2228:13, 2228:18, 2229:25,
2112:12, 2112:21, 2113:4, 2113:8,
1991:7, 1991:8, 1991:9, 1994:3,
2231:10, 2231:15, 2231:17, 2240:1,
2113:24, 2114:3, 2114:6, 2114:17,
2026:1, 2035:15, 2039:3, 2099:12,
2240:5, 2240:8, 2240:11, 2240:24,
2114:21, 2115:7, 2116:8, 2116:16,
2203:9, 2204:13, 2229:6, 2229:16
2245:24, 2251:24, 2252:19, 2252:21,
2117:9, 2117:11, 2117:25, 2118:9,
COURT [259] - 1971:1, 1975:2,
2267
2254:5, 2254:25, 2256:23, 2257:1,
2098:8, 2151:10, 2154:19, 2154:24,
current [5] - 2059:5, 2060:20, 2060:22,
2257:8
2155:20, 2157:16
2100:11, 2120:18
Court's [3] - 1982:25, 2035:18, 2052:3
decide [6] - 2076:2, 2076:4, 2125:4,
curriculum [1] - 2053:3
2166:16, 2172:12, 2215:6
Courtney [3] - 2046:6, 2047:2, 2047:9
customer [7] - 1976:7, 1976:8,
decided [4] - 2060:10, 2106:22,
courtroom [3] - 2098:19, 2103:21,
1976:11, 1976:14, 2016:17, 2016:18
2167:25, 2226:4
2182:7
customer's [1] - 1976:10
decision [16] - 1977:23, 1977:25,
cover [1] - 2103:8
customers [10] - 1977:18, 1979:23,
1979:8, 1979:18, 1995:4, 2026:22,
covered [1] - 2116:23
1986:19, 1986:21, 1987:1, 2016:5,
2060:13, 2060:14, 2098:5, 2166:19,
2120:3, 2122:11, 2123:11, 2123:24
CPA [19] - 1991:15, 1991:16, 2099:24,
2166:21, 2168:16, 2172:17, 2172:23,
customs [3] - 2008:25, 2009:14,
2100:6, 2100:11, 2113:6, 2130:14,
2208:11
2131:3, 2131:5, 2170:12, 2174:5,
2196:12
decision-making [1] - 1979:8
2174:7, 2223:5, 2224:8, 2226:14,
Customs [1] - 2009:1
decisions [2] - 2115:1, 2245:18
2226:17, 2249:22, 2249:23, 2249:25
cut [1] - 2168:13
declared [2] - 2002:16, 2226:3
create [3] - 2140:23, 2174:25, 2186:10
Cynthia [1] - 2014:10
deemed [1] - 2253:12
created [8] - 1986:12, 1986:21,
DEFENDANT [2] - 1971:20, 1972:2
2103:18, 2123:8, 2123:10, 2177:18,
D
2184:19, 2226:23
defendant [1] - 2150:12
credentials [1] - 2174:4
Defendant's [9] - 1988:25, 1989:11,
Dallas [2] - 2105:6, 2105:7
credit [2] - 1998:2, 2114:9
1994:2, 2020:22, 2044:12, 2051:15,
damaged [1] - 2208:20
2052:24, 2086:9, 2090:1
Credit [1] - 1979:14
date [13] - 1978:25, 2053:3, 2053:10,
defendant's [1] - 1989:12
CRICK [1] - 1973:4
2062:12, 2063:12, 2063:14, 2066:24,
Defense [2] - 2067:3, 2207:5
crick [7] - 1975:10, 2045:8, 2045:22,
2067:22, 2087:14, 2098:6, 2151:9,
defense [5] - 1980:12, 2003:14,
2073:16, 2074:8, 2076:13, 2078:14
2177:6, 2249:10
2037:12, 2040:1, 2056:6
Crick [38] - 1977:14, 1980:14, 1980:20,
dated [4] - 2002:25, 2057:11, 2154:6,
define [2] - 2093:15, 2248:2
1980:24, 1981:15, 1981:23, 1983:18,
2180:25
1984:8, 1987:21, 2023:2, 2035:20,
defines [1] - 2091:12
dates [5] - 2056:11, 2056:22, 2056:24,
2036:7, 2038:12, 2040:4, 2053:20,
definitely [2] - 2193:10, 2243:19
2253:11, 2255:7
2057:12, 2058:12, 2061:11, 2062:4,
definition [1] - 2165:23
daughter [1] - 2102:6
2062:12, 2063:2, 2063:12, 2064:2,
definitive [1] - 2012:14
DAVID [1] - 1971:10
2064:8, 2066:3, 2066:24, 2067:12,
degree [2] - 2048:20, 2126:12
Davis [23] - 2130:6, 2130:9, 2130:20,
2068:2, 2069:14, 2070:18, 2072:3,
delved [1] - 2241:23
2131:5, 2131:7, 2131:11, 2131:13,
2080:2, 2080:13, 2081:6, 2083:11,
demand [1] - 2244:21
2131:20, 2131:21, 2131:25, 2132:12,
2089:20, 2091:3, 2098:4
demanded [1] - 2201:12
2132:16, 2132:22, 2132:25, 2133:13,
cricket [33] - 2018:21, 2018:23,
denied [1] - 1994:12
2198:16, 2198:20, 2199:19, 2199:24,
2019:4, 2019:9, 2019:15, 2020:9,
department [2] - 2072:19, 2134:12
2232:7, 2232:10, 2232:20
2025:7, 2025:9, 2025:10, 2025:14,
Department [1] - 1971:17
Davis's [2] - 2130:11, 2131:10
2025:15, 2075:22, 2076:7, 2076:9,
departure [1] - 1993:17
day-to-day [2] - 2199:15, 2199:17
2076:16, 2077:3, 2082:2, 2139:2,
dependent [1] - 2164:18
days [10] - 2099:20, 2104:25, 2109:8,
2211:15, 2213:12, 2213:13, 2213:14,
deposit [4] - 1976:14, 2108:6, 2245:7,
2125:24, 2142:10, 2145:8, 2145:17,
2213:21, 2214:9, 2214:23, 2215:13,
2246:2
2145:18, 2217:7, 2239:12
2216:16, 2216:17, 2216:18, 2217:6,
deposited [2] - 2110:21, 2111:4
DC [1] - 1971:18
2217:9, 2217:13
depositor [3] - 2235:23, 2241:24,
De [2] - 2043:12, 2043:13
Cricket [1] - 2020:17
2242:4
de [1] - 2168:8
cricket's [1] - 2019:4
depositors [9] - 2109:25, 2110:20,
DEA [1] - 2008:23
crime [3] - 2047:13, 2164:1, 2179:13
2153:11, 2235:8, 2235:21, 2238:2,
deal [8] - 2136:6, 2186:13, 2187:13,
criminal [5] - 2000:1, 2047:13,
2243:17, 2251:13, 2252:8
2187:19, 2187:21, 2188:10, 2191:17,
2096:22, 2096:23, 2180:6
depositors' [5] - 2119:15, 2135:15,
2226:20
criminally [1] - 1985:8
2235:16, 2237:12, 2237:15
dealer [1] - 2204:5
crisis [1] - 2102:1
deposits [3] - 2116:23, 2234:22,
dealership [2] - 2204:5, 2205:1
critical [1] - 2000:15
2244:5
dealing [2] - 2206:1, 2206:2
cross [14] - 2035:16, 2036:21,
depressed [2] - 2171:1
dealings [1] - 2206:7
2038:10, 2049:23, 2068:9, 2069:21,
desalination [3] - 2210:2, 2210:4,
deals [10] - 2170:18, 2171:5, 2171:17,
2072:23, 2074:3, 2074:9, 2075:22,
2210:9
2172:2, 2176:5, 2185:14, 2186:12,
2080:14, 2132:3, 2233:19, 2240:20
describe [7] - 1975:14, 1978:19,
2189:21, 2235:18, 2242:8
CROSS [4] - 1973:6, 1973:19,
2011:4, 2132:9, 2158:5, 2172:24,
dealt [1] - 2221:23
1983:16, 2169:8
2197:22
debt [6] - 2151:18, 2228:24, 2247:24,
cross-examination [12] - 2035:16,
described [4] - 2031:3, 2049:2,
2248:2, 2253:6
2036:21, 2038:10, 2049:23, 2068:9,
2060:11, 2255:11
decade [2] - 2135:14, 2135:23
2069:21, 2072:23, 2074:3, 2074:9,
describes [1] - 1975:16
decades [1] - 2214:7
2075:22, 2080:14, 2233:19
describing [1] - 2012:6
December [16] - 1998:12, 2000:19,
CROSS-EXAMINATION [4] - 1973:6,
description [1] - 2047:14
2002:6, 2002:18, 2028:11, 2032:21,
1973:19, 1983:16, 2169:8
design [2] - 2219:21, 2221:2
2063:15, 2068:1, 2087:12, 2088:17,
CRR [3] - 1972:10, 1972:18, 2257:14
2268
2036:5, 2036:11, 2036:18, 2037:2,
designed [1] - 1978:7
directors [30] - 1988:21, 1992:10,
2037:3, 2037:5, 2037:12, 2038:17,
1992:11, 1993:19, 1995:3, 1995:21,
despite [1] - 2145:24
2041:10, 2044:6, 2044:7, 2050:21,
1995:24, 1996:3, 2031:16, 2036:7,
destination [1] - 2215:16
2051:19, 2051:21, 2055:15, 2063:12,
2043:23, 2046:7, 2046:14, 2047:6,
detail [2] - 2161:19, 2248:18
2065:21, 2066:24, 2067:22, 2150:2,
2047:24, 2048:4, 2048:7, 2048:8,
details [5] - 1978:12, 1979:1, 2026:8,
2150:18, 2154:10, 2154:17
2060:23, 2066:11, 2092:16, 2092:17,
2049:4, 2226:2
documents [12] - 1976:1, 2034:1,
2101:21, 2105:2, 2162:24, 2202:6,
determination [1] - 2150:23
2202:7, 2205:2
2034:13, 2034:25, 2035:14, 2035:20,
determinations [1] - 2175:19
2035:24, 2037:19, 2057:24, 2074:20,
Directors [1] - 2031:2
determine [3] - 1979:8, 1990:2, 2175:6
2140:10, 2148:21
dirt [2] - 2082:15, 2082:16
detrimental [1] - 2164:4
dollar [13] - 2016:3, 2156:19, 2156:25,
disagree [2] - 2084:3, 2092:24
develop [6] - 2011:7, 2011:24,
2158:2, 2158:3, 2159:6, 2223:1,
discharged [1] - 2048:23
2170:17, 2194:25, 2197:12, 2212:17
2228:9, 2239:6, 2241:7, 2241:8,
disclose [4] - 1977:23, 1982:9,
developed [2] - 2010:25, 2209:7
2253:14
2066:11, 2073:23
developing [4] - 2189:5, 2211:24,
dollars [10] - 2063:23, 2075:10,
disclosed
[23]
2031:21,
2064:6,
2217:20, 2235:1
2152:16, 2170:3, 2211:23, 2215:12,
2066:15, 2076:13, 2080:17, 2081:6,
Development [27] - 2123:1, 2123:2,
2216:13, 2219:20, 2219:24, 2242:5
2083:11, 2084:24, 2085:3, 2085:10,
2123:5, 2123:7, 2123:10, 2124:1,
Don [5] - 1990:9, 1993:7, 2002:14,
2158:6,
2158:15,
2223:16,
2223:18,
2124:8, 2124:10, 2127:2, 2132:14,
2105:10, 2204:10
2224:3, 2224:25, 2229:9, 2229:12,
2133:1, 2133:7, 2133:12, 2133:14,
done [24] - 1997:11, 2012:4, 2012:15,
2229:20, 2239:1, 2249:3, 2249:4
2136:17, 2137:3, 2137:12, 2137:15,
2013:2,
2020:24, 2033:6, 2039:25,
disclosing
[2]
1976:17,
2223:20
2139:3, 2158:10, 2174:15, 2174:20,
2041:9, 2101:20, 2105:15, 2105:22,
disclosure [9] - 1982:20, 2065:8,
2174:22, 2190:15, 2208:24, 2209:8,
2140:17, 2155:3, 2193:4, 2194:15,
2077:2, 2077:4, 2156:24, 2157:12,
2238:16
2194:17, 2194:21, 2200:23, 2201:2,
2158:18,
2159:5,
2224:10
development [29] - 2041:22, 2042:1,
2201:6, 2201:7, 2220:15, 2240:25,
disclosures [9] - 2031:14, 2238:23,
2134:3, 2139:19, 2142:20, 2144:8,
2256:9
2239:11, 2239:13, 2239:23, 2239:24,
2144:11, 2148:18, 2149:15, 2149:19,
door [1] - 2225:20
2240:14,
2240:23,
2241:20
2152:7, 2152:16, 2153:3, 2153:8,
double [1] - 1989:20
discuss [7] - 1981:5, 1981:13,
2155:3, 2155:23, 2162:1, 2167:9,
double-check [1] - 1989:20
1984:20, 2086:5, 2107:25, 2115:13,
2167:23, 2197:18, 2198:7, 2200:14,
doubt [7] - 1994:6, 1995:20, 1996:8,
2150:25
2208:22, 2209:19, 2218:2, 2234:14,
2000:19, 2001:1, 2040:11, 2132:6
discussed [7] - 2044:21, 2110:18,
2235:12, 2235:17, 2238:3
down [36] - 1981:19, 1983:4, 1997:12,
2117:20, 2153:24, 2166:22, 2209:4,
developments [6] - 2176:5, 2197:14,
2004:22,
2011:12, 2014:20, 2033:13,
2209:6
2234:14, 2234:25, 2242:17, 2243:23
2037:21, 2037:22, 2046:11, 2056:21,
discussing [2] - 2069:20, 2070:19
deviation [1] - 2084:2
2098:16, 2100:23, 2102:2, 2126:14,
discussion [3] - 2158:1, 2158:3,
devote [1] - 2108:16
2126:15, 2141:1, 2142:8, 2160:23,
2165:1
Diaz [3] - 2009:18, 2009:20, 2014:10
2166:18, 2167:3, 2173:23, 2175:22,
discussions [2] - 2143:25, 2165:12
Diego [2] - 2102:3, 2102:4
2183:8, 2185:1, 2208:13, 2214:14,
dispute [6] - 1994:17, 1994:20,
difference [6] - 2122:15, 2126:5,
2214:17, 2227:12, 2228:14, 2230:2,
1995:14,
2026:5,
2026:7,
2026:8
2126:25, 2199:21, 2250:21
2234:14, 2243:23, 2247:14, 2256:24
distinguishes [1] - 2246:12
differences [1] - 2000:23
downtown [1] - 2135:2
distressed [11] - 2103:19, 2104:9,
different [21] - 1986:22, 1998:13,
dozen [1] - 2162:12
2106:8, 2106:12, 2120:16, 2120:17,
1999:10, 2010:15, 2014:2, 2015:21,
draft [1] - 1986:9
2126:8,
2126:11,
2126:17,
2133:21,
2017:2, 2051:19, 2051:21, 2110:11,
drafted [1] - 1986:18
2134:7
2124:24, 2131:14, 2131:17, 2139:22,
dream [3] - 2218:24, 2220:4, 2237:10
distributed [1] - 1987:1
2141:18, 2159:10, 2162:25, 2229:23,
drill [1] - 1981:19
distribution [1] - 1986:7
2250:23, 2251:25
drives [2] - 2169:4, 2169:6
DISTRICT [3] - 1971:1, 1971:1,
difficult [4] - 1980:23, 2003:25,
drop [1] - 2014:20
1971:10
2140:25, 2201:9
drove [1] - 2187:11
District
[1]
2100:3
difficulties [4] - 1995:6, 1995:9,
drug [1] - 2004:12
disturbed [2] - 2012:18, 2012:23
1995:10, 2123:14
due [1] - 2187:9
diversification [1] - 1981:14
difficulty [3] - 2163:16, 2164:7
duly [1] - 2099:5
diversified [1] - 2126:18
diligence [1] - 2187:9
during [16] - 1989:20, 2019:22,
dividend [2] - 2225:6, 2226:5
DIRECT [3] - 1973:17, 1975:8, 2099:7
2070:17, 2074:3, 2074:6, 2134:3,
division [1] - 2009:1
direct [12] - 2026:9, 2027:5, 2035:22,
2135:22, 2156:8, 2156:12, 2159:2,
DIVISION [1] - 1971:2
2066:4, 2068:21, 2095:7, 2184:4,
2178:3, 2183:6, 2189:19, 2198:14,
2184:9, 2184:12, 2227:6, 2228:4,
dock [4] - 2138:16, 2138:20, 2138:22,
2202:2, 2206:12
2228:21
2218:3
duties [2] - 2003:11, 2065:15
director [15] - 1996:20, 2006:2,
docket [1] - 2150:22
duty [2] - 2049:13, 2189:14
2010:20, 2014:13, 2029:1, 2029:12,
document [41] - 1986:6, 1986:9,
2030:13, 2045:23, 2046:15, 2047:16,
1986:12, 1986:14, 1986:16, 1986:18,
2053:15, 2056:1, 2060:20, 2157:17,
1987:18, 1987:24, 1988:5, 1988:14,
2168:12
1988:23, 1990:21, 1990:22, 1990:25,
Director [1] - 2053:21
1995:16, 2003:21,
2034:17,
2034:18,
Johnny C. Sanchez,
RMR, CRR
- jcscourtreporter@aol.com
2269
enjoyable [1] - 2039:24
eventually [10] - 1991:5, 2014:18,
2015:19, 2038:4, 2054:16, 2054:18,
enjoyed [1] - 2200:17
2106:14, 2133:25, 2174:15, 2190:14
enlarge [1] - 1985:25
e) [1] - 2091:10
evidence [34] - 1976:21, 1980:1,
enlarged [1] - 1985:20
e-mail [1] - 2166:21
1980:5, 1980:11, 1988:25, 1989:5,
enormous [1] - 2209:6
early [23] - 2010:9, 2026:16, 2051:15,
1992:5, 1997:19, 1997:20, 2000:5,
enter [1] - 2150:14
2107:16, 2107:25, 2109:7, 2109:18,
2001:1, 2001:7, 2024:18, 2031:13,
entered [2] - 2002:12, 2055:4
2115:3, 2133:2, 2133:13, 2136:11,
2031:24, 2052:23, 2058:16, 2065:23,
enterprise [3] - 2249:8, 2249:14,
2139:21, 2145:8, 2145:17, 2145:18,
2065:24, 2075:15, 2076:18, 2078:3,
2250:24
2170:20, 2190:6, 2214:7, 2229:2,
2080:20, 2085:18, 2112:20, 2123:19,
entertain [2] - 1995:20, 1996:8
2234:8
2143:4, 2146:19, 2148:10, 2150:21,
entire [9] - 1977:18, 2000:6, 2003:20,
early-to-mid-1990s [1] - 2133:2
2152:10, 2180:15, 2227:22
2082:9, 2085:19, 2143:9, 2238:11,
easel [1] - 2067:10
evildoing [1] - 2179:19
2239:22
easier [1] - 2040:24
exact [2] - 2026:7, 2150:23
entirety [2] - 1992:6, 2071:7
easily [2] - 2241:15, 2255:14
exactly [7] - 2006:18, 2013:14,
entities [5] - 2006:20, 2012:1, 2025:4,
East [1] - 2009:21
2014:14, 2019:1, 2025:3, 2044:17,
2033:5, 2134:13
easy [3] - 1996:14, 1996:15, 2181:6
2137:18
entitled [4] - 2039:5, 2083:20,
eat [1] - 2236:21
exam [2] - 2057:3, 2057:17
2243:21, 2257:12
economic [5] - 2144:12, 2235:4,
EXAMINATION [21] - 1973:6, 1973:8,
entity [11] - 1978:8, 1978:16, 2007:15,
2235:5, 2238:2, 2243:6
1973:10, 1973:12, 1973:17, 1973:19,
2055:5, 2101:4, 2104:6, 2106:16,
economics [1] - 2144:10
1973:21, 1973:23, 1973:25, 1974:2,
2137:2, 2137:11, 2137:13, 2137:19
economy [1] - 2120:11
1975:8, 1983:16, 2062:2, 2084:17,
entrance [2] - 2197:24
2098:2, 2099:7, 2169:8, 2233:16,
Ede [1] - 1999:22
entrepreneur [2] - 2193:9, 2193:10
2244:3, 2251:6, 2255:3
educational [1] - 2099:25
entry [1] - 2254:15
examination [38] - 2026:9, 2031:13,
effect [8] - 2003:2, 2008:10, 2071:4,
envelope [1] - 1998:24
2033:10, 2033:11, 2033:20, 2033:21,
2081:25, 2090:10, 2090:11, 2090:12,
equities [8] - 2111:6, 2111:25,
2035:16, 2036:21, 2038:10, 2042:23,
2090:16
2113:16, 2113:22, 2125:21, 2125:22,
2043:5, 2043:11, 2049:23, 2054:22,
effective [1] - 2011:25
2149:6, 2247:21
2056:18, 2064:9, 2064:11, 2064:14,
effort [4] - 2004:2, 2004:17, 2005:7,
equivalent [2] - 1991:15, 2082:22
2064:22, 2064:24, 2068:9, 2069:21,
2188:23
error [1] - 2032:2
2070:7, 2070:12, 2072:23, 2074:3,
eight [2] - 2100:21, 2162:23
especially [4] - 1993:8, 1999:18,
2074:9, 2075:22, 2078:13, 2080:14,
either [13] - 1976:14, 1996:8, 2001:13,
2113:23, 2214:7
2095:7, 2184:4, 2184:9, 2184:12,
2013:20, 2015:9, 2039:6, 2049:22,
essential [2] - 1979:3, 2209:9
2227:6, 2228:5, 2228:21, 2233:19
2058:2, 2083:18, 2083:19, 2155:21,
essentially [1] - 2013:15
examinations [1] - 2060:7
2249:2
establish [3] - 2010:1, 2058:24,
examine [5] - 2029:17, 2042:19,
elaborate [1] - 2119:20
2112:6
2043:22, 2044:1, 2160:6
electing [1] - 2203:11
established [1] - 2053:5
Examined [1] - 2056:21
electricity [3] - 2164:15, 2164:21,
establishes [1] - 2181:3
examined [1] - 2058:22
2164:23
estate [77] - 2101:9, 2103:6, 2103:20,
examiner [3] - 2043:14, 2043:16,
elicit [1] - 2112:25
2104:9, 2104:22, 2106:8, 2106:12,
2065:4
Ellen [3] - 1989:17, 2037:11, 2038:5
2106:20, 2107:19, 2119:12, 2119:16,
examiners [2] - 2015:21, 2058:23
ELMO [3] - 1988:1, 2044:24, 2045:19
2119:25, 2120:4, 2120:6, 2120:14,
examining [1] - 2015:19
Elsie [2] - 2108:10, 2108:11
2120:16, 2120:17, 2121:11, 2121:13,
example [5] - 1975:24, 1986:25,
empire [2] - 2232:14, 2232:21
2121:22, 2122:4, 2122:11, 2123:12,
2085:11, 2164:6, 2223:9
employee [2] - 2095:20, 2128:25
2123:15, 2123:22, 2124:13, 2125:1,
exams [1] - 2034:14
employees [6] - 2107:22, 2107:23,
2125:2, 2125:12, 2125:15, 2125:17,
except [1] - 2230:25
2131:14, 2131:19, 2164:13, 2190:15
2126:1, 2126:8, 2126:11, 2126:12,
exception [1] - 2256:20
end [25] - 1992:24, 2002:5, 2028:5,
2126:18, 2126:20, 2126:23, 2129:5,
exchange [2] - 2253:16, 2253:18
2064:14, 2102:13, 2136:5, 2141:20,
2133:21, 2149:12, 2170:8, 2170:10,
exchanges [1] - 2253:12
2144:16, 2145:25, 2148:14, 2154:3,
2170:17, 2170:25, 2171:1, 2171:3,
excuse [6] - 2017:21, 2070:4, 2112:5,
2154:6, 2155:19, 2157:22, 2160:22,
2171:5, 2171:17, 2171:20, 2172:2,
2123:18, 2125:5, 2145:9
2165:6, 2165:14, 2168:7, 2168:23,
2176:4, 2185:14, 2186:7, 2186:12,
excused [3] - 2098:16, 2256:24,
2208:5, 2219:12, 2236:14, 2236:18,
2190:21, 2191:3, 2191:7, 2191:21,
2257:1
2237:17, 2238:5
2200:14, 2233:25, 2235:9, 2235:17,
Executive [1] - 2053:20
endeavor [2] - 2146:8, 2146:9
2239:2, 2239:9, 2239:10, 2242:8,
executive [12] - 2006:1, 2010:20,
ended [7] - 1996:4, 2015:11, 2028:12,
2245:12, 2249:3, 2250:18, 2255:17,
2014:13, 2028:25, 2029:12, 2030:13,
2032:22, 2042:9, 2097:16, 2169:24
2255:18, 2255:23, 2256:3, 2256:19
2045:23, 2056:1, 2060:20, 2101:15,
ending [1] - 2086:19
estimate [1] - 2108:21
2106:25, 2208:11
ends [1] - 2257:4
estimates [1] - 2031:15
exercise [1] - 2015:25
enforcing [1] - 2046:23
et [3] - 2068:13, 2092:17
exercising [2] - 1981:14, 2048:20
engaging [1] - 2220:15
Ethridge [1] - 2108:10
exhaustive [1] - 2065:10
England [2] - 2213:16, 2214:1
evaluated [1] - 2032:5
Exhibit [47] - 1979:25, 1985:18,
English [1] - 2020:12
event
[1]
2223:11
2270
1988:4, 1988:25, 1989:11, 1993:3,
1994:3, 2017:8, 2017:18, 2020:22,
2022:13, 2027:17, 2027:19, 2029:6,
2030:7, 2044:13, 2052:24, 2055:12,
2055:17, 2055:25, 2056:4, 2056:13,
2057:6, 2057:11, 2057:25, 2058:1,
2058:10, 2062:4, 2063:3, 2064:10,
2066:22, 2067:3, 2073:5, 2077:6,
2080:3, 2085:25, 2086:6, 2086:9,
2086:15, 2088:16, 2090:2, 2207:5,
2223:1, 2227:18, 2230:2, 2246:21,
2246:23
exhibit [16] - 1983:5, 1992:9, 2003:14,
2028:17, 2077:8, 2077:11, 2089:17,
2150:25, 2153:20, 2196:4, 2223:4,
2228:5, 2229:24, 2240:6, 2254:24
exhibited [1] - 2223:3
exhibits [1] - 2056:6
exist [7] - 2025:18, 2067:21, 2086:23,
2087:1, 2087:14, 2087:15, 2088:2
existed [4] - 2033:5, 2087:5, 2088:3,
2088:4
existence [1] - 2060:6
existing [1] - 2087:15
expand [2] - 2006:10, 2189:25
expensive [7] - 2139:22, 2139:24,
2141:5, 2194:3, 2211:21, 2211:22,
2236:15
experience [5] - 2001:19, 2001:20,
2053:7, 2103:6, 2236:17
expert [5] - 2025:14, 2112:8, 2112:10,
2112:25, 2113:6
expertise [1] - 2004:15
explain [5] - 2049:17, 2049:19,
2049:21, 2163:23, 2195:8
explained [3] - 1998:17, 2187:18,
2215:14
explanation [1] - 2161:16
explanations [1] - 2031:23
express [1] - 2140:4
expression [1] - 2081:24
extended [4] - 2157:13, 2157:16,
2232:13, 2232:14
extent [8] - 2018:14, 2025:24,
2042:10, 2053:6, 2063:1, 2121:23,
2122:13, 2164:18
extremely [4] - 2165:9, 2200:19,
2213:19, 2214:8
Exxon [1] - 2253:6
eye [1] - 2113:5
2213:16, 2214:5, 2225:12, 2227:5,

2254:23, 2255:23
facts [10] - 2075:14, 2076:17, 2078:2,
2078:13, 2080:20, 2123:18, 2146:19,
2152:9, 2255:20, 2255:22
failing [2] - 2210:23, 2211:1
fair [7] - 1994:10, 2011:16, 2028:10,
2032:20, 2042:4, 2051:6, 2194:19
faith [3] - 2078:16, 2078:18, 2152:21
fall [3] - 2019:14, 2019:16, 2019:18
fam [1] - 2145:20
familiar [30] - 1975:12, 1977:9, 1978:4,
1987:4, 2010:12, 2014:4, 2022:4,
2022:6, 2022:8, 2024:20, 2025:24,
2055:15, 2068:8, 2088:9, 2109:21,
2159:17, 2179:21, 2179:22, 2209:15,
2220:11, 2220:14, 2220:18, 2220:21,
2221:13, 2221:18, 2222:2, 2223:7,
2225:12, 2225:25, 2240:15
family [3] - 2145:7, 2145:16, 2145:20
fancy [4] - 2166:1, 2237:6, 2237:10,
2237:17
far [14] - 1997:16, 2017:23, 2024:3,
2098:19, 2192:12, 2206:22, 2211:9,
2211:10, 2216:18, 2221:1, 2221:4,
2232:13, 2237:5, 2238:1
fascinating [1] - 2039:23
fashion [1] - 2246:18
fast [2] - 2140:8, 2140:12
father [6] - 2107:5, 2202:20, 2202:25,
2203:2, 2203:15, 2204:25
fault [1] - 2128:1
Fazel [2] - 1971:20, 1971:21
FAZEL [2] - 2090:21, 2227:15
FBI [23] - 1984:15, 1984:16, 2008:19,
2094:2, 2176:24, 2177:9, 2177:13,
2177:18, 2178:2, 2178:14, 2179:2,
2179:9, 2181:1, 2181:3, 2182:4,
2182:6, 2185:1, 2186:1, 2188:21,
2199:18, 2200:6, 2200:13, 2233:20
FDIC [1] - 2116:23
feasible [1] - 2235:3
feature [1] - 2197:24
featured [1] - 2213:12
February [2] - 2011:2, 2040:8
federal [1] - 2203:9
fee [1] - 1976:1
feelings [1] - 2166:10
Felipe [1] - 2134:20
fellow [2] - 2185:9, 2202:11
felt [2] - 2040:13, 2042:13
female [1] - 2182:10
Ferrance [2] - 2043:3, 2064:17
few [16] - 1983:9, 1983:10, 1991:6,
2021:20, 2084:19, 2103:15, 2108:17,
2134:8, 2136:7, 2141:2, 2142:10,
2143:10, 2166:6, 2219:7, 2239:12,
2244:2
field [9] - 2025:7, 2025:9, 2025:14,
2025:15, 2076:10, 2211:15, 2214:23,
2215:13, 2216:17
fields [1] - 2025:10
fifth [1] - 2021:14

fight [1] - 2226:8
file [5] - 2008:4, 2047:11, 2049:6,
2062:25, 2093:22
filed [1] - 2052:18
files [27] - 1996:20, 2014:2, 2058:22,
2072:4, 2072:7, 2072:11, 2093:1,
2093:2, 2093:8, 2093:11, 2093:18,
2093:19, 2093:20, 2093:22, 2093:25,
2094:5, 2094:9, 2094:11, 2094:13,
2095:1, 2095:5, 2095:8, 2095:10,
2095:12, 2095:13
filing [2] - 2093:20, 2094:16
fill [2] - 2047:23, 2130:23
finalized [1] - 1986:10
finally [3] - 2060:2, 2060:6, 2139:6
finance [3] - 2101:16, 2168:12,
2204:17
Finance [2] - 2087:13, 2087:14
finances [1] - 2141:10
Financial [7] - 2005:19, 2006:2,
2007:9, 2068:25, 2132:19, 2135:20,
2239:20
financial [58] - 2000:11, 2004:18,
2005:3, 2006:23, 2007:19, 2009:18,
2028:9, 2028:14, 2030:24, 2031:5,
2031:14, 2031:17, 2031:25, 2032:7,
2032:12, 2032:13, 2032:19, 2032:24,
2033:9, 2066:12, 2074:17, 2101:20,
2125:7, 2125:8, 2130:13, 2133:14,
2133:16, 2147:5, 2158:11, 2158:14,
2160:9, 2169:19, 2174:11, 2198:22,
2198:25, 2199:4, 2199:15, 2199:16,
2199:20, 2199:22, 2199:25, 2200:2,
2203:21, 2203:24, 2211:4, 2221:15,
2222:7, 2228:8, 2229:4, 2229:8,
2233:6, 2233:8, 2233:9, 2233:10,
2238:13, 2238:16, 2249:9
financially [3] - 2173:2, 2173:5,
2235:2
financials [1] - 2228:10
findings [2] - 2000:25, 2067:13
fine [5] - 1983:25, 2022:11, 2063:9,
2127:25, 2152:19
finest [1] - 2076:9
Fingervoedt [1] - 2062:15
finish [1] - 2144:13
finished [6] - 2041:11, 2096:5, 2189:4,
2201:3, 2212:8, 2232:5
finishes [1] - 2197:5
fire [1] - 2068:6
firm [11] - 2009:5, 2100:15, 2100:16,
F
2101:7, 2160:16, 2160:21, 2161:1,
2161:8, 2220:18, 2220:24, 2226:7
fabulous [1] - 2196:22
Firm [1] - 1972:6
fabulously [2] - 2250:19, 2250:25
firms [4] - 2100:19, 2100:21, 2100:22,
facility [7] - 2138:16, 2192:13, 2210:8,
2220:21
2214:21, 2214:22, 2215:3, 2233:3
first [74] - 1983:23, 1984:4, 1986:14,
fact [25] - 1979:11, 1988:20, 1991:3,
1987:18, 1988:13, 1990:2, 2000:6,
1997:23, 2010:5, 2027:1, 2041:22,
2018:7, 2021:6, 2028:17, 2029:6,
2086:19, 2096:19, 2119:2, 2146:2,
2029:7, 2030:8, 2030:18, 2033:10,
2175:14, 2175:17, 2175:21, 2176:12,
2033:11, 2035:22, 2036:3, 2037:2,
2176:21, 2179:25, 2193:6, 2210:19,
2037:5, 2040:8, 2042:23, 2043:5,
2271
2054:22, 2055:4, 2056:12, 2057:2,
2057:3, 2057:17, 2063:16, 2071:1,
2079:18, 2085:24, 2087:19, 2099:5,
2101:10, 2102:21, 2104:23, 2108:12,
2108:17, 2119:19, 2120:2, 2120:25,
2121:8, 2123:6, 2123:22, 2127:15,
2130:10, 2148:25, 2151:5, 2153:23,
2163:18, 2166:20, 2168:19, 2177:6,
2178:5, 2180:1, 2181:2, 2181:12,
2184:21, 2186:13, 2187:13, 2187:14,
2192:6, 2228:14, 2228:17, 2230:7,
2233:22, 2240:25, 2241:1, 2250:2,
2256:16, 2257:2
fit [1] - 2007:14
fits [1] - 2003:22
five [14] - 2017:20, 2020:18, 2039:5,
2048:5, 2051:2, 2051:7, 2079:16,
2086:6, 2086:12, 2151:7, 2229:15,
2229:17, 2244:14
five-year [1] - 2244:14
fixed [5] - 2208:23, 2208:25, 2244:11,
2253:10, 2255:7
fixing [1] - 2059:10
flags [1] - 2186:8
fleet [1] - 2137:10
flexibility [2] - 2203:10, 2240:25
flip [1] - 2057:5
flipped [1] - 2256:7
flips [1] - 2256:6
float [1] - 2193:1
Floor [2] - 1971:22, 1972:4
floor [1] - 2201:3
floors [3] - 2141:14, 2141:15, 2141:24
Florida [5] - 2018:5, 2018:7, 2018:11,
2018:12, 2220:25
fly [4] - 2024:7, 2024:15
focus [9] - 2028:4, 2069:14, 2073:11,
2091:14, 2133:21, 2134:3, 2134:6,
2134:7, 2134:10
focused [8] - 2104:9, 2104:21,
2104:22, 2108:20, 2120:6, 2168:21,
2168:25, 2234:7
focussing [1] - 2006:13
folks [3] - 2034:22, 2108:7, 2165:8
follow [3] - 1992:16, 2216:24, 2256:2
following [6] - 1975:1, 2038:23,
2047:8, 2053:1, 2079:22, 2155:12
follows [4] - 2002:16, 2064:1, 2099:6,
2209:11
FOR [3] - 1971:13, 1971:20, 1972:2
for-sale [3] - 2171:15, 2171:16
forced [2] - 2060:15, 2060:16
foregoing [1] - 2257:10
foreign [1] - 2055:5
Form [1] - 2072:8
form [15] - 1976:18, 1978:4, 1978:7,
2031:5, 2048:10, 2048:12, 2048:25,
2049:1, 2049:2, 2049:3, 2070:21,
2080:19, 2112:8, 2117:22, 2145:12
formal [1] - 2119:10
Formalities [1] - 2050:25
formally [1] - 2047:12
formed [1] - 2074:16

former [7] - 2008:19, 2008:23,
2008:25, 2009:14, 2009:21, 2039:2,
2094:2
forming [1] - 2032:5
forms [2] - 2058:21, 2059:5
forth [6] - 2060:5, 2061:14, 2061:20,
2063:25, 2151:23, 2214:15
foundation [8] - 2110:2, 2110:5,
2110:22, 2112:6, 2112:13, 2112:16,
2114:13, 2116:14
four [12] - 2039:10, 2039:16, 2048:5,
2100:25, 2108:9, 2135:3, 2135:13,
2171:7, 2171:9, 2171:12, 2171:18
four-story [1] - 2135:3
fourth [2] - 2021:12, 2122:18
fragile [1] - 2163:14
framework [2] - 2010:1, 2015:15
franchise [4] - 2215:25, 2216:5,
2216:6, 2216:13
franchises [1] - 2216:7
Francis [1] - 2043:12
Frans [2] - 2057:13, 2062:15
fraud [3] - 2032:1, 2032:15, 2191:17
fraudulent [2] - 2215:17, 2235:12
free [5] - 2032:1, 2032:14, 2098:17,
2098:20, 2256:24
freeholds [1] - 2208:20
French [1] - 2134:24
frequently [2] - 2164:12, 2164:24
Friday [2] - 2093:4, 2096:17
friends [4] - 2131:18, 2131:19,
2195:15, 2195:17
front [10] - 1980:21, 1983:24, 1994:2,
2002:13, 2050:14, 2061:24, 2062:5,
2082:2, 2087:19, 2195:5
fruition [1] - 2210:10
frustrated [3] - 2001:15, 2001:21,
2001:23
FSRC [27] - 1978:1, 1978:17, 1997:4,
2060:17, 2060:21, 2061:4, 2061:7,
2062:22, 2064:6, 2065:2, 2069:5,
2069:6, 2074:19, 2074:22, 2075:2,
2076:13, 2077:2, 2077:21, 2077:24,
2078:12, 2078:14, 2080:17, 2081:6,
2083:12, 2084:21, 2085:3, 2085:11
FSRC's [1] - 1985:8
Ft [1] - 2099:15
full [10] - 1975:3, 1975:4, 2000:7,
2028:4, 2121:23, 2122:13, 2151:5,
2154:9, 2217:9
fully [4] - 2059:8, 2062:21, 2123:23,
2124:14
fun [1] - 2213:11
function [3] - 2072:6, 2101:19, 2199:2
functions [1] - 2007:4
Fund [7] - 2117:8, 2117:13, 2118:2,
2161:25, 2162:10, 2165:11, 2166:14
fund [17] - 1981:21, 1982:16, 2076:15,
2121:24, 2122:2, 2124:2, 2124:9,
2124:13, 2135:15, 2149:18, 2152:6,
2153:3, 2162:15, 2162:20, 2163:2,
2186:2, 2235:16
funded [5] - 2123:23, 2185:21, 2188:7,
2234:21, 2237:12
funding [5] - 2126:23, 2135:18,
2142:8, 2191:13, 2243:12
funds [9] - 2076:15, 2077:25, 2083:13,
2084:12, 2115:20, 2126:24, 2146:23,
2223:8, 2243:25
furtherance [2] - 2065:14
GAAP [9] - 2221:21, 2221:23, 2222:8,

2222:11, 2222:13, 2223:18, 2230:10,
2230:11, 2238:20
gambling [2] - 2006:21, 2006:22
game [2] - 2082:2, 2217:5
gears [1] - 2221:9
general [14] - 1975:25, 1990:10,
1992:11, 2013:17, 2024:11, 2041:1,
2070:1, 2071:25, 2095:4, 2128:7,
2161:7, 2188:4, 2190:17, 2241:18
generally [11] - 1975:14, 1975:20,
1975:22, 2015:18, 2023:2, 2081:2,
2154:15, 2160:4, 2186:13, 2194:17,
2253:11
generated [1] - 2209:13
generates [1] - 2177:13
generous [3] - 2172:15, 2172:16,
2172:22
Geneva [9] - 2118:16, 2118:24,
2119:2, 2119:5, 2230:21, 2231:21,
2231:24, 2232:1, 2232:3
gentleman [8] - 1985:1, 1985:3,
1994:23, 2009:17, 2009:24, 2042:24,
2043:3, 2204:25
gentlemen [3] - 2151:6, 2155:8,
2202:5
gerber [3] - 1984:11, 1984:12, 2009:1
GIBL [6] - 1988:9, 1990:24, 2015:5,
2027:11, 2033:5, 2033:18
Gilbert [2] - 2039:13, 2039:14
gist [1] - 2013:14
given [8] - 1987:4, 2003:21, 2037:16,
2038:14, 2052:2, 2111:8, 2163:25,
2177:15
glue [1] - 2018:23
GM [1] - 2253:6
go-round [2] - 2240:25, 2241:1
goal [1] - 2242:20
gold [1] - 2039:10
Goswick [7] - 1990:9, 1993:7,
2002:15, 2105:9, 2105:16, 2105:23,
2204:1
Government [8] - 2006:10, 2148:9,
2149:21, 2155:19, 2156:8, 2157:2,
2158:21, 2158:24
GOVERNMENT [1] - 1971:13
government [58] - 1988:8, 1990:22,
1992:25, 1993:9, 1995:18, 1996:10,
1996:11, 1996:16, 1996:17, 1997:8,
1997:14, 1997:16, 2003:13, 2005:6,
2272
2005:10, 2007:15, 2007:18, 2008:5,
2240:8
guided [1] - 2053:19
2008:7, 2008:11, 2010:19, 2037:3,
heard [13] - 1990:16, 1999:4, 2068:6,
guidelines [1] - 1982:3
2038:21, 2051:15, 2051:24, 2052:11,
2113:10, 2123:17, 2130:22, 2153:7,
guy [13] - 2172:18, 2172:25, 2175:10,
2061:13, 2061:17, 2067:13, 2067:20,
2180:1, 2201:17, 2218:5, 2218:8,
2180:10, 2180:13, 2180:19, 2182:22,
2069:17, 2072:1, 2072:19, 2086:22,
2218:10, 2254:7
2191:7, 2198:15, 2215:23, 2216:3,
2087:2, 2087:3, 2087:23, 2097:16,
hearing [2] - 2203:8, 2235:7
2216:12, 2255:25
2150:4, 2164:22, 2164:23, 2192:18,
hearsay [8] - 2052:6, 2105:25, 2106:1,
guys [4] - 2193:13, 2195:19, 2202:15,
2196:3, 2205:17, 2205:18, 2205:19,
2110:3, 2110:8, 2180:15, 2203:4,
2225:21
2205:21, 2206:3, 2206:7, 2207:6,
2203:7
2208:16, 2208:19, 2209:14, 2209:17,
heart [1] - 2019:19
H
2247:24, 2255:6, 2255:8, 2255:12
held [8] - 1975:1, 1982:21, 1988:20,
government's [2] - 2083:2, 2227:23
2038:23, 2079:22, 2100:9, 2155:12
hair [2] - 1999:18, 1999:24
Government's [39] - 1979:25, 1985:17,
Hello [1] - 1984:8
half [5] - 2111:21, 2136:9, 2160:23,
1988:4, 1993:3, 2017:8, 2017:18,
help [21] - 1988:21, 2007:18, 2010:16,
2166:13, 2198:10
2022:13, 2027:17, 2027:19, 2029:5,
2027:19, 2034:15, 2041:4, 2041:13,
halfway [1] - 2154:4
2030:7, 2055:12, 2055:17, 2055:21,
2049:16, 2049:18, 2057:22, 2072:6,
Hamilton [1] - 2220:23
2055:24, 2056:3, 2056:6, 2056:13,
2072:11, 2095:25, 2097:12, 2133:1,
hand [10] - 2030:9, 2036:4, 2041:7,
2057:5, 2057:11, 2057:25, 2058:10,
2133:13, 2149:18, 2191:8, 2219:21,
2073:12, 2073:13, 2099:2, 2114:5,
2062:4, 2063:3, 2064:10, 2066:21,
2226:8
2154:14, 2156:8, 2239:15
2077:5, 2080:2, 2085:25, 2086:6,
helped [4] - 2132:12, 2176:13, 2232:2,
handed [9] - 1998:23, 2000:13,
2086:14, 2088:16, 2222:25, 2227:17,
2249:21
2000:15, 2000:17, 2000:19, 2035:13,
2230:2, 2246:21, 2246:23, 2247:12
helping [7] - 2009:25, 2010:19,
2035:14, 2035:15, 2036:19
governmental [1] - 1996:14
2094:21, 2124:2, 2152:6, 2193:13,
handing [3] - 2000:11, 2063:2, 2066:3
governments [3] - 2005:2, 2247:24,
2221:2
handling [1] - 2182:14
2253:10
helps [1] - 2097:14
hands [16] - 2180:10, 2180:13,
governor's [1] - 1993:10
hereby [1] - 2053:16
2180:18, 2181:8, 2181:14, 2182:13,
grab [2] - 2045:17, 2097:23
herein [1] - 2064:1
2182:22, 2182:24, 2182:25, 2183:5,
graduating [1] - 2100:13
hereinafter [3] - 2002:11, 2063:19,
2233:23, 2234:7
grand [1] - 2196:17
2063:22
hands-off [7] - 2180:10, 2180:13,
granite [1] - 2141:9
hesitating [1] - 2029:19
2180:18, 2181:8, 2181:14, 2182:13,
granted [4] - 2002:20, 2067:18,
Hewlett [18] - 2026:9, 2026:18,
2183:5
2086:20, 2087:20
2026:24, 2027:1, 2027:7, 2028:1,
hands-on [9] - 2180:10, 2181:8,
great [2] - 2006:15, 2136:6
2029:3, 2032:10, 2033:2, 2074:9,
2182:13, 2182:22, 2182:24, 2182:25,
Great [2] - 2221:22, 2222:1
2074:12, 2074:15, 2075:10, 2075:19,
2183:5, 2233:23, 2234:7
Greenberg [1] - 2009:7
2159:23, 2160:1, 2160:12, 2160:15
handwriting [1] - 2045:8
Gregg [1] - 1971:13
Hewlett's [4] - 2029:24, 2030:22,
handwritten [2] - 2045:1, 2045:2
ground [3] - 2042:6, 2082:3, 2162:20
2074:22, 2075:11
hang [2] - 2076:19, 2153:25
Grounds [1] - 2086:14
hi [1] - 2112:25
hangar [21] - 2024:1, 2024:2, 2024:8,
grounds [2] - 2086:12, 2139:2
high [17] - 1987:13, 2039:23, 2102:7,
2024:9, 2024:10, 2080:17, 2081:7,
Group [3] - 2132:19, 2135:20, 2136:3
2102:8, 2165:6, 2165:14, 2195:21,
2084:25, 2137:7, 2137:8, 2137:9,
2195:22, 2195:23, 2196:10, 2219:12,
group [12] - 2007:8, 2008:9, 2011:14,
2138:4, 2144:18, 2144:20, 2196:5,
2225:20, 2236:14, 2236:18, 2236:23,
2011:17, 2013:21, 2014:1, 2019:20,
2236:7, 2236:8, 2236:25, 2242:23,
2237:17
2119:13, 2134:14, 2228:16, 2243:2
2250:9
High [2] - 1990:4, 2086:10
growth [1] - 2036:20
hangars [2] - 2209:1, 2250:5
high-end [6] - 2165:6, 2165:14,
Guana [2] - 2218:22, 2219:2
happy [4] - 2078:17, 2112:15, 2189:23
2219:12, 2236:14, 2236:18, 2237:17
guaranteed [2] - 2253:10, 2255:6
hard [8] - 1980:22, 2157:7, 2159:10,
high-net-worth [2] - 2195:23, 2196:10
Guardian [53] - 1992:10, 1992:12,
2166:20,
2189:16, 2213:21, 2214:17,
high-quality [1] - 2236:23
1993:19, 1994:13, 1994:15, 1995:1,
2253:25
highest [1] - 1993:20
1995:4, 1995:12, 1995:21, 1995:23,
harder [1] - 2030:4
1995:25, 1996:20, 2002:17, 2002:20,
highlight [10] - 2111:22, 2118:11,
hardwood [3] - 2141:14, 2141:15,
2015:7, 2015:9, 2015:12, 2016:1,
2148:24, 2151:4, 2159:12, 2207:20,
2141:24
2016:10, 2067:18, 2067:22, 2086:20,
2208:8, 2247:13, 2252:23, 2255:1
hardwoods [1] - 2141:18
2087:20, 2098:6, 2102:14, 2102:22,
highlighted [5] - 2090:23, 2090:24,
Harold [4] - 2008:19, 2008:21, 2014:9,
2104:15, 2106:16, 2107:14, 2107:23,
2113:9, 2181:6, 2184:21
2094:2
2109:3, 2111:4, 2111:14, 2114:8,
highly [2] - 2242:14, 2253:13
hastily [2] - 2064:20, 2064:21
2114:12, 2118:18, 2122:25, 2123:2,
himself [6] - 2093:10, 2094:13,
head [5] - 2009:17, 2029:11, 2085:17,
2123:3, 2123:4, 2123:7, 2123:10,
2115:3, 2195:3, 2195:4, 2225:15
2188:22, 2190:19
2124:1, 2124:8, 2124:9, 2127:2,
hinder [1] - 2072:6
heading [1] - 2031:1
2133:4, 2133:6, 2133:7, 2133:14,
hindered [1] - 2072:13
headquarters [1] - 2192:6
2188:2, 2188:4, 2233:24
hire [13] - 2104:7, 2106:9, 2106:22,
health [2] - 2136:18, 2215:2
Guardian's [1] - 1992:8
2106:23, 2161:5, 2172:1, 2172:12,
hear [8] - 2063:7, 2070:24, 2076:20,
guess [5] - 1999:9, 2138:23, 2170:23,
2173:12, 2173:19, 2174:7, 2174:9,
2076:21, 2078:6, 2216:3, 2218:6,
2179:7, 2225:25
2174:11, 2178:20
2273
2100:14, 2102:5, 2102:11, 2102:25,
hired [23] - 2042:11, 2106:14, 2106:16,
improve [1] - 2041:19
2103:1, 2105:5, 2107:20, 2120:10,
2106:24, 2120:12, 2133:4, 2162:22,
improved [4] - 2002:1, 2209:18,
2120:11, 2121:2, 2121:19, 2122:8,
2170:14, 2170:21, 2170:22, 2172:4,
2209:20, 2213:3
2122:9, 2134:19, 2170:20, 2171:7,
2172:10, 2172:13, 2173:6, 2175:2,
improvements [1] - 2209:21
2171:10, 2171:11, 2171:19, 2186:18,
2175:6, 2175:18, 2181:25, 2198:15,
improving [1] - 2162:18
2186:19, 2220:23, 2256:10
2199:19, 2200:1, 2202:9, 2220:18
inaccurate [1] - 2050:19
Howard [1] - 1971:16
hiring [2] - 2219:21, 2226:7
incident [1] - 2014:2
Hrdlicka [1] - 2226:8
history [3] - 2003:12, 2105:11,
include [4] - 2007:1, 2031:12, 2059:7,
2105:13
huge [3] - 2146:4, 2146:9, 2226:23
2163:9
hit [5] - 1983:12, 2042:6, 2161:8,
hundred [3] - 2170:3, 2181:18,
included [4] - 1978:11, 2066:14,
2161:20, 2214:17
2181:23
2141:8, 2254:14
HITTNER [1] - 1971:10
hundreds [8] - 2037:25, 2038:1,
includes [2] - 1978:12, 2031:15
2152:16, 2211:23, 2212:1, 2212:3,
hold [10] - 1977:5, 1987:8, 1987:12,
including [4] - 2132:7, 2151:5,
2212:5, 2242:5
2017:19, 2022:19, 2037:9, 2038:1,
2167:24, 2249:17
hurricanes [2] - 2163:14, 2163:18
2083:16, 2087:11, 2115:5
income [1] - 2225:6
holders' [1] - 2234:22
hypergrowth [1] - 2006:6
inconsistent [1] - 2216:10
holding [2] - 2087:10, 2087:11
incorporated [1] - 2040:25
holds [1] - 2246:3
incorporation [1] - 2048:1
I
Holloway [1] - 2164:5
incorrect [1] - 2095:6
home [8] - 2120:13, 2130:16, 2166:13,
increments [2] - 2244:14
IB [2] - 2085:12, 2085:14
2167:5, 2178:23, 2178:24, 2182:19,
Independent [2] - 2100:3, 2159:15
IB5 [8] - 1978:4, 1978:6, 1978:7,
2219:13
independent [7] - 2031:6, 2032:12,
1978:11, 1978:12, 1978:21, 1979:21
homebuilder [2] - 2101:13, 2101:14
2074:16, 2159:18, 2159:21, 2160:1,
IB5s [3] - 1978:17, 1978:20, 1978:23
homebuilding [1] - 2101:25
2160:4
IBC [9] - 2001:20, 2048:1, 2052:11,
Homes [4] - 2101:14, 2101:22,
India [1] - 2213:16
2058:25, 2065:7, 2065:10, 2089:2,
2101:24, 2169:19
indicate [2] - 1977:3, 2051:8
2090:5, 2090:21
homework [1] - 2193:4
indicated [1] - 2023:23
IBM [2] - 2253:22
Honor [69] - 1975:7, 1980:7, 1983:2,
indicates [1] - 2087:7
idea [31] - 1987:20, 1987:22, 1990:21,
1989:8, 1989:16, 1989:19, 2017:15,
indicating [1] - 2092:22
1992:8, 2006:24, 2120:15, 2120:16,
2022:22, 2035:13, 2036:12, 2036:25,
indication [1] - 2051:10
2133:24, 2161:23, 2162:9, 2163:7,
2038:2, 2038:21, 2044:25, 2051:20,
indicted [1] - 2047:12
2163:11, 2165:1, 2165:4, 2165:11,
2051:25, 2062:1, 2062:7, 2063:5,
Indies [12] - 2018:16, 2018:24, 2019:9,
2172:1, 2181:25, 2193:16, 2194:24,
2065:25, 2067:9, 2070:10, 2073:7,
2019:17, 2019:25, 2020:1, 2020:2,
2197:11, 2215:11, 2215:23, 2217:6,
2077:9, 2077:13, 2078:8, 2079:6,
2020:18, 2063:22, 2213:24, 2214:1
2217:13, 2218:10, 2218:11, 2219:5,
2079:14, 2079:25, 2080:5, 2083:4,
indies [1] - 2019:24
2219:10, 2232:20, 2232:22, 2242:25
2084:14, 2088:12, 2090:15, 2098:1,
indirect [1] - 2046:15
identified [14] - 2017:12, 2017:13,
2098:12, 2098:21, 2112:22, 2116:7,
individual [9] - 1975:17, 1982:10,
2017:14, 2022:17, 2022:20, 2022:24,
2117:10, 2142:22, 2143:2, 2143:8,
2107:1, 2135:21, 2163:15, 2197:25,
2058:20, 2104:4, 2143:3, 2153:22,
2143:15, 2147:18, 2151:3, 2153:14,
2198:1, 2233:24, 2241:25
2227:21, 2227:23, 2227:24, 2228:15
2153:21, 2155:7, 2155:14, 2157:3,
individuals [3] - 2010:18, 2013:21,
identity [1] - 2048:7
2169:7, 2200:10, 2203:4, 2207:4,
2115:8
idiomatic [1] - 2081:24
2207:14, 2227:2, 2227:15, 2227:20,
indulgence [1] - 1982:25
IFRS [5] - 2221:13, 2222:8, 2238:9,
2232:5, 2240:4, 2243:8, 2244:1,
Industries [1] - 2101:11
2238:12,
2239:18
2245:22, 2252:17, 2253:25, 2254:22,
industry [7] - 2005:3, 2011:11, 2042:1,
IFSA [3] - 2010:20, 2095:23, 2097:13
2256:22, 2256:25
2070:19, 2076:7, 2101:9, 2101:10
illegal
[1]
2223:17
Honorable [2] - 1990:12, 2002:9
inexpensive [1] - 2211:19
immediately [1] - 2048:12
HONORABLE [1] - 1971:10
influence [2] - 2232:14, 2232:21
immigration [1] - 2196:12
hope [2] - 2058:3, 2250:6
inform [3] - 1993:8, 1998:8, 2046:5
implementation [1] - 2040:18
hopefully [2] - 2084:15, 2224:15
information [79] - 1975:17, 1975:19,
implemented
[3]
2059:6,
2059:8,
horse [1] - 1999:24
1975:20, 1975:22, 1975:25, 1976:2,
2062:21
hospital [2] - 2209:23, 2209:24
1976:6, 1976:7, 1976:8, 1976:9,
implementing [1] - 2060:5
hot [2] - 1999:20, 1999:24
1978:8, 1978:11, 1978:12, 1978:19,
import
[5] - 2141:5, 2141:8, 2164:10,
hour [1] - 2034:23
1979:3, 1987:1, 1988:17, 1995:11,
2164:11,
2164:13
house [2] - 2023:5, 2179:9
1997:7, 1997:9, 2001:22, 2014:25,
importance [3] - 2000:15, 2000:16,
houses [13] - 1978:15, 1978:25,
2016:17, 2016:18, 2016:22, 2016:24,
2169:2
1979:4, 1979:5, 1979:6, 1979:22,
2031:23, 2032:6, 2033:25, 2034:1,
important [5] - 1988:8, 1988:17,
2024:25, 2134:11, 2134:16, 2135:10,
2034:3, 2034:5, 2041:25, 2047:2,
1991:2, 2003:13, 2194:20
2190:24, 2197:25, 2198:2
2047:4, 2047:9, 2047:20, 2048:16,
impose
[1] - 2004:18
housing [1] - 2197:18
2049:6, 2049:10, 2049:12, 2049:14,
impossible [1] - 2216:7
HOUSTON [1] - 1971:2
2050:6, 2052:19, 2053:1, 2053:17,
impression [2] - 2128:20, 2128:21
Houston [33] - 1971:4, 1971:15,
2053:24, 2054:1, 2054:4, 2054:6,
improper [2] - 1988:22, 2008:5
1971:23, 1972:4, 1972:7, 1972:11,
2054:15, 2055:1, 2055:6, 2062:20,
improperly [1] - 2016:6
1972:19, 2099:16, 2100:2, 2100:4,
2274
2066:12, 2066:15, 2073:2, 2073:19,
2249:9, 2253:12, 2253:16
2165:24, 2166:1, 2166:2, 2183:24,
2073:22, 2073:23, 2074:25, 2075:18,
2184:2, 2237:19, 2248:8, 2248:11,
International [71] - 1975:15, 1976:12,
2089:6, 2091:13, 2091:22, 2092:4,
2255:19, 2256:12, 2256:19
1976:13, 1976:17, 1977:17, 1978:16,
2092:21, 2127:16, 2128:4, 2157:23,
Investment [13] - 2102:14, 2106:17,
1978:22, 1979:14, 1979:21, 1980:3,
2175:4, 2176:10, 2183:12, 2183:14,
1980:15, 1993:19, 1994:13, 1994:15,
2107:15, 2107:23, 2114:12, 2123:3,
2183:21, 2220:9, 2221:11, 2221:12,
1995:1, 1995:4, 1995:12, 1995:22,
2133:4, 2133:6, 2161:25, 2162:10,
2251:16
1995:23, 1995:25, 1996:21, 2002:17,
2165:11, 2166:14, 2188:5
information-sharing [1] - 2055:1
2002:21, 2005:19, 2006:2, 2016:2,
investment-type [1] - 2135:7
2016:10, 2023:11, 2043:6, 2043:23,
informed [3] - 1992:25, 1993:11,
investments [22] - 1979:12, 1981:2,
2046:1, 2046:10, 2046:21, 2047:22,
1993:12
1987:2, 2085:11, 2106:20, 2112:3,
2050:16, 2056:18, 2057:3, 2057:9,
informing [1] - 1995:3
2113:15, 2119:16, 2120:7, 2122:20,
2063:20, 2067:18, 2067:23, 2074:5,
2123:12, 2126:7, 2126:10, 2133:21,
infrastructure [7] - 2040:18, 2162:18,
2086:20, 2087:20, 2098:7, 2102:14,
2149:2, 2149:13, 2165:25, 2171:9,
2163:5, 2164:14, 2164:19, 2212:17,
2102:22, 2104:15, 2106:17, 2107:15,
2191:3, 2247:14, 2251:17, 2253:11
2220:9
2107:23, 2114:8, 2133:6, 2139:14,
Investments [1] - 2247:18
ing [1] - 2252:8
2141:16, 2148:12, 2149:18, 2151:21,
investor [4] - 2076:14, 2077:25,
initial [6] - 1980:12, 2092:4, 2104:11,
2154:25, 2156:24, 2157:6, 2162:5,
2083:13, 2084:12
2162:22, 2199:24, 2201:25
2169:5, 2169:6, 2188:5, 2195:12,
investors [1] - 2035:3
inquire [1] - 2145:4
2195:16, 2208:22, 2210:16, 2232:25,
invests [3] - 2245:2, 2246:8, 2247:4
inquired [1] - 2145:10
2246:16
invited [2] - 2103:9, 2138:23
inquiries [1] - 2092:15
Internet [5] - 2006:21, 2006:22,
involve [1] - 2121:1
inquiry [1] - 2057:17
2040:22, 2040:24, 2041:21
involved [13] - 2012:3, 2094:10,
inserted [1] - 2010:11
interruption [1] - 2128:17
2125:12, 2132:11, 2139:25, 2141:12,
insistent [1] - 2201:6
intervals [1] - 1979:7
2161:24, 2163:4, 2200:16, 2210:4,
instance [2] - 2097:4, 2256:14
interview [20] - 2042:15, 2103:9,
2255:23, 2256:7
instances [1] - 1976:6
2103:11, 2104:11, 2104:23, 2105:12,
involvement [6] - 2068:16, 2068:19,
instead [4] - 2073:22, 2172:25,
2173:14, 2177:13, 2178:5, 2178:6,
2132:10, 2132:22, 2133:16, 2216:16
2199:20, 2222:8
2178:13, 2178:23, 2181:1, 2182:13,
irregularities [1] - 2032:15
institution [2] - 2046:14, 2046:16
2183:6, 2184:19, 2185:23, 2200:13,
irregularity [1] - 2032:2
institutions [2] - 1979:10, 1979:17
2201:25, 2233:22
IRS [2] - 2225:19, 2226:3
instruction [1] - 2035:1
interviewed [9] - 2172:8, 2172:19,
island [33] - 2003:9, 2013:23, 2017:5,
instrument [2] - 2244:20, 2246:2
2176:24, 2177:3, 2177:10, 2182:6,
2026:19, 2027:2, 2027:4, 2029:25,
instruments [2] - 2046:9, 2114:10
2183:2, 2185:9, 2202:12
2040:5, 2040:14, 2040:25, 2064:18,
insurance [13] - 2007:1, 2115:23,
interviewing [3] - 2103:17, 2104:16,
2065:5, 2141:2, 2141:3, 2160:24,
2116:9, 2116:12, 2116:17, 2116:21,
2202:2
2163:15, 2163:23, 2163:25, 2164:19,
2116:23, 2117:1, 2117:4, 2117:15,
interviews [3] - 2177:22, 2178:3,
2190:5, 2194:25, 2205:13, 2206:6,
2117:21, 2118:2, 2202:24
2233:20
2210:15, 2211:24, 2212:22, 2213:3,
Insurance [3] - 2117:8, 2117:13,
introduce [2] - 2089:14, 2099:11
2213:22, 2215:20, 2217:3, 2218:19,
2118:1
introduced [3] - 1984:8, 1989:16,
2222:9, 2222:10
intended [2] - 2006:5, 2087:3
2027:16
Island [20] - 2005:12, 2013:10,
intends [1] - 2035:16
invest [21] - 1979:8, 1979:19, 2120:3,
2014:13, 2015:5, 2023:15, 2023:17,
intent [2] - 2209:25, 2210:1
2121:10, 2121:22, 2122:11, 2123:11,
2023:18, 2023:20, 2024:5, 2024:12,
intention [4] - 1993:1, 1993:9,
2123:15, 2129:5, 2170:10, 2170:24,
2034:11, 2190:1, 2192:19, 2195:16,
1993:13, 1998:9
2171:3, 2171:5, 2172:2, 2216:13,
2217:24, 2218:1, 2218:2, 2218:9,
intentionally [1] - 2238:20
2244:22, 2245:7, 2245:10, 2250:1,
2218:22, 2219:2
interaction [5] - 2069:12, 2189:18,
2255:17, 2255:21
islands [21] - 2005:15, 2018:13,
2232:23, 2232:25, 2233:5
invested [10] - 1978:14, 2111:6,
2018:14,
2018:17, 2018:21, 2019:14,
interest [5] - 2063:25, 2096:25,
2129:12, 2167:11, 2247:7, 2248:10,
2019:19, 2064:19, 2162:11, 2162:12,
2151:22, 2187:3, 2244:12
2249:1, 2249:2, 2250:18, 2250:24
2162:13, 2162:18, 2162:23, 2162:25,
interested [7] - 2126:22, 2130:19,
investigation [2] - 2016:4, 2016:11
2163:5, 2163:16, 2163:17, 2164:9,
2162:17, 2186:7, 2200:20, 2247:7
investigations [1] - 2092:15
2164:24, 2218:19, 2218:23
interesting [1] - 2083:10
investing [10] - 1979:17, 2016:23,
Islands [1] - 2005:16
Internal [5] - 2225:13, 2225:16,
2124:24, 2125:1, 2163:11, 2215:11,
isolated [1] - 2256:14
2225:24, 2226:1, 2226:8
2215:24, 2231:7, 2246:18, 2248:22
issue [18] - 1995:2, 1995:5, 1997:13,
international [41] - 2004:4, 2006:12,
investment [45] - 1977:19, 1978:9,
2040:11, 2046:21, 2053:10, 2054:16,
2006:13, 2006:15, 2006:22, 2006:23,
1978:13, 1978:14, 1978:15, 1978:24,
2054:18, 2091:6, 2116:12, 2116:17,
2007:1, 2007:2, 2010:1, 2011:21,
1979:4, 1979:5, 1979:6, 1979:9,
2141:14, 2200:6, 2225:2, 2225:13,
2011:22, 2012:1, 2014:20, 2015:22,
1979:22, 1981:13, 2016:25, 2085:15,
2239:11, 2241:21, 2253:6
2028:13, 2031:12, 2032:23, 2036:20,
2107:19, 2111:20, 2111:24, 2113:11,
issued [2] - 2036:7, 2187:12
2052:12, 2072:2, 2090:7, 2095:14,
2113:23, 2115:1, 2115:9, 2119:13,
issues [3] - 2160:11, 2206:19, 2206:23
2100:18, 2125:10, 2158:11, 2158:14,
2126:7, 2126:18, 2129:4, 2133:25,
issuing [1] - 1995:7
2160:21, 2161:1, 2213:25, 2221:15,
2135:7, 2149:4, 2162:13, 2162:14,
Item [1] - 2067:16
2221:23, 2223:19, 2230:9, 2230:18,
2163:2, 2165:17, 2165:19, 2165:22,
items [3] - 1993:16, 2012:14, 2041:23
2238:12, 2239:12, 2239:20, Johnny
2240:21, C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
2275
itself [11] - 1981:21, 1982:16, 1992:10,
2041:5, 2048:10, 2049:16, 2050:5,
2050:19, 2089:12, 2150:22, 2163:21
Ivan [2] - 2009:20, 2014:10
2124:16, 2153:19
Judge's [8] - 1993:23, 1993:25,
1996:7, 2000:25, 2086:12, 2087:8,
2087:10, 2087:11
judged [1] - 2242:1
judges [2] - 1991:12, 2000:1
judgment [6] - 1990:18, 1994:3,
2002:6, 2002:7, 2002:11, 2032:13
judgments [1] - 2031:16
judicial [4] - 1996:2, 1997:23, 1999:6,
2066:19
July [1] - 2055:3
jump [2] - 2113:6, 2113:7
jumping [1] - 2129:14
June [5] - 2002:25, 2154:3, 2162:21,
2163:1, 2208:5
junior [1] - 2043:14
juries [1] - 2096:21
jurisdiction [5] - 1998:20, 2011:24,
2017:2, 2042:20, 2047:13
jurisdictions [3] - 1999:10, 2054:25,
2074:4
jury [47] - 1975:1, 1987:20, 1988:13,
1992:6, 2000:5, 2002:9, 2023:3,
2023:10, 2023:24, 2035:1, 2035:9,
2038:18, 2038:23, 2041:16, 2045:5,
2054:12, 2058:16, 2060:9, 2064:16,
2067:15, 2076:2, 2076:4, 2076:11,
2079:22, 2081:3, 2083:17, 2083:18,
2085:18, 2088:1, 2093:2, 2093:4,
2095:7, 2095:19, 2096:19, 2099:11,
2099:25, 2134:18, 2155:12, 2175:21,
2176:3, 2197:22, 2198:14, 2198:24,
2201:15, 2247:3, 2255:16
JURY [1] - 1971:7
jury's [1] - 2136:23
Justice [9] - 1971:17, 1990:4, 1990:13,
2002:9, 2039:2, 2039:7, 2039:19,
2086:10
justice [2] - 2002:10, 2039:8
justices [1] - 2039:6
2118:21, 2125:5, 2136:13, 2144:16,

2149:4, 2149:23, 2151:9, 2155:18,
2159:10, 2169:10, 2175:15, 2177:23,
2182:3, 2183:7, 2189:2, 2205:25,
2207:14, 2207:22, 2208:10, 2209:14,
2215:17, 2219:4, 2225:12, 2227:5,
2228:4, 2228:21, 2230:5, 2230:19,
2233:18, 2247:17, 2251:8, 2255:5
KNOCHE [2] - 1973:15, 2099:4
knock [1] - 2214:17
knowing [2] - 2176:12, 2247:7
knowledge [26] - 1976:22, 2015:1,
2025:18, 2028:25, 2046:3, 2053:6,
2064:7, 2070:6, 2081:9, 2084:13,
2088:24, 2093:13, 2093:16, 2094:6,
2094:18, 2094:19, 2094:20, 2112:7,
2114:14, 2131:2, 2131:5, 2131:6,
2152:20, 2161:10, 2212:19, 2251:22
known [2] - 2019:12, 2079:4
KPMG [1] - 2101:5
Jackson [1] - 2220:24

James [9] - 1990:8, 1993:7, 1993:14,
2002:14, 2105:9, 2198:16, 2199:24,
2202:18, 2202:19
January [5] - 1971:5, 2002:21,
2067:19, 2086:21, 2087:21
Jeffrey [1] - 2014:10
jeopardy [3] - 1981:22, 1982:17,
1982:23
jet [1] - 2195:25
jets [3] - 2138:5, 2196:11, 2218:4
Jim [4] - 2130:6, 2130:9, 2130:20,
2198:16
job [16] - 2001:13, 2013:22, 2026:10,
L
2097:1, 2160:5, 2160:6, 2166:11,
2167:19, 2168:2, 2168:4, 2170:4,
labor [1] - 1991:7
2172:8, 2172:19, 2172:20, 2176:13,
lack [1] - 2070:5
2185:10
ladies [3] - 2057:22, 2151:6, 2155:8
jobs [5] - 2102:10, 2212:24, 2213:1,
lady [2] - 1984:16
2213:2, 2237:21
laid [5] - 2110:5, 2196:16, 2196:18,
John [15] - 1972:2, 1983:20, 1993:11,
2237:3, 2237:5
1993:13, 1993:15, 1994:12, 1995:17,
land [15] - 2192:16, 2192:17, 2195:24,
1997:12, 1998:8, 2000:10, 2000:15,
2196:11, 2196:12, 2207:1, 2209:2,
2000:16, 2000:17, 2000:20, 2039:3
2209:18, 2209:20, 2209:21, 2217:20,
John's [3] - 1997:19, 1998:3, 2063:21
2218:4, 2219:2
johnny [1] - 2076:22
lands [4] - 2206:13, 2206:15, 2208:16,
Johnny [7] - 1972:10, 1972:18,
2208:19
1976:25, 2080:23, 2084:7, 2257:10,
language [2] - 1990:24, 2050:19
2257:14
lapel [3] - 1983:25, 1987:9, 1987:11
join [2] - 2005:6, 2005:10
large [1] - 1998:24
joined [6] - 2068:22, 2068:24, 2069:6,
larger [2] - 2129:25, 2160:20
2069:7, 2069:10, 2069:17
largest [1] - 2100:21
Jonathan [1] - 2121:17
Larry [3] - 2107:2, 2109:13, 2181:11
Jordan [1] - 1995:17
last [19] - 1982:1, 2001:17, 2002:3,
Journal [1] - 2103:1
K
2035:19, 2040:4, 2067:10, 2084:19,
Jr [1] - 1993:8
2087:9, 2087:19, 2091:14, 2099:12,
judge [9] - 1991:7, 1991:10, 1991:11,
2100:12, 2135:5, 2135:14, 2135:22,
K-N-O-C-H-E [1] - 2099:13
2039:15, 2203:9, 2204:12, 2204:13,
2161:22, 2217:7, 2219:7, 2255:2
keep [12] - 1997:11, 2006:12, 2044:5,
2205:1
late [8] - 2007:6, 2026:16, 2027:1,
2061:13, 2063:6, 2063:7, 2092:12,
JUDGE [1] - 1971:10
2133:20, 2135:1, 2139:21, 2147:11,
2113:4, 2120:19, 2150:8, 2150:13,
Judge [61] - 1976:18, 1984:1, 1987:10,
2170:23
2254:24
1988:1, 1988:19, 1993:5, 1993:7,
latest [1] - 1989:13
keeping [2] - 2017:14, 2054:20
1994:5, 1994:7, 1994:9, 1995:21,
latter [1] - 2136:7
Kenneth [5] - 1972:6, 1998:10, 2000:9,
1996:3, 1996:12, 1998:2, 1999:8,
laundering [7] - 2004:10, 2004:17,
2009:22, 2204:22
1999:19, 2000:14, 2000:18, 2000:25,
2004:22, 2004:23, 2016:5, 2016:12,
kind [19] - 1978:11, 2007:20, 2019:5,
2002:4, 2003:19, 2009:22, 2017:20,
2070:1
2022:12, 2027:20, 2037:2, 2037:7,
2081:24, 2172:18, 2172:25, 2175:10,
2037:14, 2038:8, 2040:2, 2044:17,
2175:19, 2176:9, 2184:20, 2186:13,
Law [2] - 1972:3, 1972:6
2045:4, 2045:13, 2045:19, 2050:12,
2186:17, 2192:4, 2202:21, 2203:19,
law [14] - 1977:21, 1982:22, 1991:13,
2051:14, 2056:9, 2057:20, 2065:22,
2216:12, 2225:19, 2232:20, 2255:21
1991:18, 2001:15, 2001:22, 2001:25,
2070:5, 2075:12, 2076:1, 2076:17,
kinds [2] - 2041:16, 2179:18
2004:9, 2028:14, 2032:24, 2089:24,
2078:23, 2080:19, 2081:8, 2083:14,
2090:18, 2226:7, 2252:12
Kingdom [2] - 2013:9, 2013:13
2084:15, 2085:22, 2086:3, 2089:14,
laws [13] - 1975:12, 1975:14, 1975:15,
Kirby [1] - 2134:20
2090:20, 2090:23, 2096:10, 2096:12,
1977:10, 1986:22, 1987:4, 2002:1,
Knoche [38] - 2098:24, 2099:13,
2097:8, 2097:23, 2098:14, 2111:19,
2004:3, 2004:4, 2004:17, 2005:14,
2099:14, 2111:15, 2113:9, 2117:12,
2276
2007:19
2126:10, 2126:17, 2132:10, 2176:17
2158:3, 2158:6, 2159:6, 2223:1,
2223:13, 2224:18, 2225:9, 2226:4,
lawsuit [5] - 1990:20, 1992:7, 1992:9,
liability [2] - 2088:11, 2226:23
2228:9, 2229:20, 2241:10, 2248:4,
2226:1, 2226:2
license [20] - 1981:22, 1982:17,
2248:5, 2248:6, 2248:10, 2253:14,
lawyer [16] - 1985:5, 1985:10,
1982:22, 1988:9, 1988:20, 1991:3,
2254:20
1985:13, 1985:14, 1985:15, 1985:16,
1992:8, 1992:12, 2000:11, 2000:16,
loaned [1] - 2224:20
2001:8, 2009:8, 2009:15, 2009:16,
2000:17, 2067:23, 2068:3, 2086:13,
loaning [1] - 2225:14
2096:17, 2178:20, 2204:14, 2204:15,
2087:21, 2087:22, 2088:4, 2092:9,
2205:1, 2205:2
2098:7, 2130:3
loans [23] - 2058:19, 2059:6, 2062:21,
lawyers [4] - 1984:22, 1990:15,
licensed [2] - 2040:23, 2046:13
2113:25, 2114:2, 2114:7, 2114:9,
2009:7, 2088:20
2114:15, 2149:17, 2153:12, 2222:6,
licenses [13] - 1991:1, 1998:19,
2222:17, 2222:24, 2222:25, 2227:7,
lay [1] - 2112:15
1998:25, 1999:2, 2000:13, 2000:20,
2227:13, 2227:14, 2228:11, 2229:9,
2002:20, 2067:18, 2086:19, 2087:12,
Le [1] - 2134:21
2229:12, 2239:1, 2248:8, 2249:3
2088:2, 2212:11, 2212:16
LE [1] - 2134:25
local [3] - 2100:16, 2101:7, 2226:7
lie [1] - 2251:13
leading [4] - 2014:25, 2075:14,
located [7] - 2024:10, 2063:21,
life [1] - 2195:13
2123:19, 2124:4
2073:2, 2074:6, 2081:21, 2121:18,
lifting [1] - 2094:21
learn [9] - 2003:11, 2105:11, 2106:7,
2136:2
light [1] - 2141:16
2107:17, 2123:14, 2124:12, 2124:20,
location [1] - 2187:4
2187:8, 2204:4
lighter [1] - 2141:20
locations [1] - 2221:25
learned [4] - 2000:3, 2065:3, 2108:23,
lights [2] - 2143:14, 2143:16
lodged [1] - 2008:3
2129:19
limit [3] - 2079:17, 2167:17, 2196:23
loft [2] - 2135:2, 2135:3
lease [1] - 2206:15
limitations [1] - 2074:5
Lofts [1] - 2171:14
leaseholds [1] - 2208:20
Limited [12] - 2002:17, 2063:20,
London [4] - 1999:22, 2020:11, 2117:7
leases [1] - 2207:1
2067:19, 2086:20, 2087:20, 2117:13,
look [31] - 1985:17, 1990:2, 2020:23,
least [3] - 1983:24, 2039:19, 2179:6
2118:2, 2188:2, 2208:24, 2209:8,
2041:5, 2041:8, 2049:16, 2049:18,
2246:16
leave [15] - 1993:1, 1993:20, 1995:5,
2054:11, 2055:13, 2055:18, 2066:7,
limited [5] - 2114:8, 2119:19, 2122:22,
2061:15, 2095:15, 2098:17, 2098:20,
2067:23, 2073:5, 2085:19, 2089:24,
2101:22, 2101:24, 2154:2, 2167:6,
2188:6, 2188:7
2091:3, 2154:8, 2154:12, 2155:25,
2206:5, 2219:18, 2230:19, 2256:24
Limits [1] - 2079:18
2156:11, 2159:11, 2174:9, 2174:11,
leaving [2] - 1999:3, 2168:13
line [11] - 1982:1, 1985:24, 2015:11,
2177:12, 2177:19, 2184:18, 2187:11,
left [35] - 1985:2, 1985:19, 1985:23,
2042:5, 2059:18, 2083:17, 2083:23,
2195:4, 2209:12, 2241:22, 2247:17
2018:4, 2030:9, 2036:4, 2045:9,
2112:9, 2196:13, 2241:14, 2254:15
looked [14] - 1999:1, 2025:17,
2057:25, 2060:10, 2065:2, 2073:13,
lined [2] - 2167:19, 2256:15
2029:15, 2066:25, 2073:12, 2155:4,
2081:3, 2085:1, 2085:2, 2093:4,
lines [3] - 2084:23, 2252:24, 2255:2
2158:23, 2159:2, 2187:2, 2187:6,
2114:5, 2136:14, 2138:12, 2148:5,
link [1] - 2152:13
2187:15, 2192:21, 2229:3, 2229:10
2151:11, 2162:20, 2166:7, 2198:3,
liquid [12] - 2125:2, 2125:4, 2125:16,
looking [21] - 1985:18, 2006:10,
2198:7, 2198:10, 2208:5, 2211:6,
2166:2, 2237:19, 2251:17, 2253:13,
2010:13, 2037:25, 2050:20, 2056:13,
2211:15, 2212:1, 2215:4, 2217:22,
2255:17, 2256:12, 2256:15, 2256:19
2058:8, 2080:3, 2096:13, 2101:24,
2218:21, 2219:3, 2232:19, 2234:10
liquidator [1] - 2025:23
2102:10, 2104:7, 2130:22, 2131:1,
left-hand [3] - 2030:9, 2073:13, 2114:5
liquidators [2] - 2025:25, 2026:1
2168:2, 2184:5, 2184:20, 2219:14,
legal [10] - 1976:5, 1999:18, 2001:14,
liquidity [2] - 2126:5, 2253:19
2228:13, 2236:3, 2240:1
2001:15, 2026:4, 2046:15, 2095:3,
list [13] - 2017:14, 2037:11, 2047:23,
looks [2] - 2022:6, 2193:2
2095:9, 2095:11
2051:2, 2118:11, 2118:13, 2118:20,
loss [1] - 2191:10
legend [1] - 2019:12
2212:17, 2222:17, 2248:7, 2248:15,
Lotus [2] - 2203:1, 2203:15
legible [1] - 2053:8
2248:21
loud [3] - 2028:7, 2073:17, 2254:4
legislation [5] - 2069:25, 2070:18,
listed [10] - 2086:14, 2118:15,
louder [1] - 2144:4
2071:4, 2071:11, 2071:22
2239:10, 2247:14, 2247:18, 2253:9,
love [1] - 2010:17
legislative [1] - 2012:4
2253:12, 2253:15, 2255:5, 2255:9
loved [1] - 2200:14
legitimate [2] - 2224:5, 2224:6
listened [1] - 2076:20
low [5] - 2037:25, 2113:14, 2237:18,
length [2] - 2206:9, 2206:11
listening [1] - 2054:12
2244:17,
2251:17
lengthy [1] - 2038:13
listing [4] - 1978:24, 1979:10,
low-risk [2] - 2113:14, 2237:18
less [3] - 2014:21, 2143:17, 2170:5
2228:18, 2253:18
Lumiere [1] - 2009:9
letter [35] - 1990:23, 1992:5, 1993:2,
lists [5] - 2049:3, 2056:22, 2149:3,
lunch [1] - 2078:7
1994:25, 1995:2, 1995:5, 1995:7,
2151:21, 2152:1
1995:18, 1996:10, 1996:11, 1996:14,
live [2] - 2099:14, 2099:15
1996:16, 1997:13, 1997:15, 1998:7,
lived [2] - 2018:4, 2099:16
M
1998:25, 1999:1, 2002:25, 2003:12,
living [1] - 2099:20
2013:1, 2036:5, 2038:10, 2046:6,
Lloyd [3] - 2008:19, 2014:9, 2094:2
ma'am [16] - 1977:6, 1986:6, 1990:5,
2046:21, 2047:15, 2048:19, 2052:22,
Lloyd's [1] - 2117:7
1992:5, 1996:18, 2001:12, 2003:3,
2053:14, 2054:3, 2054:15, 2057:16,
loan [34] - 1976:14, 2058:21, 2058:24,
2004:1, 2029:9, 2041:11, 2050:14,
2062:12, 2103:8, 2130:2, 2166:21
2059:3, 2059:5, 2059:8, 2062:23,
2052:10, 2061:10, 2090:10, 2098:15,
letterhead [1] - 2045:22
2097:16, 2102:1, 2152:6, 2156:25,
2098:22
letters [1] - 2059:14
2157:13, 2157:17, 2157:24, 2158:2,
Maid [1] - 2135:2
level [7] - 1996:15, 2126:4, Johnny
2277
mail [1] - 2166:21
mature [2] - 2253:10, 2255:6
mid-'90s [2] - 2134:6, 2134:10
main [1] - 2167:6
mayor [1] - 2202:23
might [27] - 1983:12, 1984:24,
1988:16, 2015:1, 2026:16, 2033:23,
major [4] - 2097:5, 2100:4, 2253:12,
McGuire [2] - 1972:6, 1972:6
2041:2, 2061:16, 2071:22, 2089:9,
2253:15
mean [47] - 1976:8, 1976:11, 1979:6,
2129:1, 2137:13, 2137:14, 2137:18,
male [1] - 2182:10
1996:15, 1999:12, 2004:7, 2023:12,
2147:8, 2147:13, 2147:16, 2158:24,
2061:17, 2082:15, 2083:24, 2092:10,
mall [1] - 2023:13
2159:10, 2203:10, 2215:25, 2222:13,
2125:3, 2125:15, 2131:18, 2139:24,
man [4] - 2039:4, 2112:25, 2114:14,
2232:20, 2249:15, 2249:18, 2253:6
2146:6, 2180:12, 2181:18, 2185:1,
2172:7
mike [4] - 1987:9, 1987:12, 2086:1,
2186:20, 2189:21, 2193:1, 2193:22,
management [7] - 2031:4, 2132:9,
2127:18
2197:3, 2199:9, 2200:4, 2200:22,
2180:10, 2181:9, 2183:3, 2199:7,
Milam [2] - 2103:14, 2131:12
2201:17, 2203:23, 2212:14, 2213:16,
2208:21
2216:17, 2219:19, 2223:5, 2232:13,
militate [1] - 1995:7
manager [2] - 2187:4, 2231:6
2233:5, 2233:7, 2240:17, 2241:5,
million [28] - 2016:3, 2064:4, 2149:10,
managers [4] - 2115:13, 2115:15,
2246:20, 2246:23, 2249:21, 2250:22,
2149:11, 2151:22, 2152:1, 2153:1,
2115:17, 2162:23
2254:4, 2254:9, 2255:11, 2256:20
2155:1, 2155:20, 2156:19, 2156:25,
managing [3] - 2115:19, 2181:9,
meaning [1] - 2083:25
2157:18, 2157:20, 2158:2, 2158:3,
2181:11
means [3] - 2125:4, 2240:18, 2253:20
2159:6, 2216:21, 2223:1, 2228:9,
mandatory [1] - 2059:6
2228:24, 2241:8, 2241:11, 2247:21,
meant
[1]
2070:8
manner [2] - 2079:10, 2201:7
2247:22, 2253:14, 2254:14, 2254:20
measure [1] - 2102:5
manual [3] - 1980:3, 1980:15, 1982:8
million-dollar [10] - 2016:3, 2156:19,
mechanical [2] - 1972:13, 1972:20
map [1] - 2018:16
2156:25,
2158:2, 2158:3, 2159:6,
meet
[6]
2105:2,
2105:8,
2202:7,
marble [1] - 2141:10
2223:1, 2228:9, 2241:8, 2253:14
2202:15, 2203:25, 2204:21
margin [1] - 2045:9
millions [15] - 2075:10, 2152:16,
meeting [11] - 1994:11, 1994:20,
Maria [3] - 2108:9, 2108:11
2211:23,
2212:2, 2212:4, 2212:6,
1994:24,
1995:3,
1998:8,
1998:13,
MARIAN [1] - 1973:4
2215:12,
2216:13, 2219:20, 2219:22,
1998:18,
2000:10,
2000:13,
2097:16,
marina [3] - 2196:22, 2196:24, 2218:7
2219:23, 2219:24, 2242:5
2103:13
mark [1] - 2090:24
millwork [1] - 2141:9
meetings [14] - 2107:25, 2109:7,
marked [7] - 1988:24, 1989:14,
Milton [2] - 2100:17
2109:11,
2109:15,
2109:24,
2110:7,
1992:15, 2020:21, 2055:11, 2055:17,
mind [7] - 2009:10, 2021:3, 2132:3,
2110:19, 2112:14, 2112:18, 2115:21,
2063:2
2150:8, 2150:13, 2197:3, 2230:15
2116:17, 2117:17, 2117:19, 2160:10
market [10] - 2125:23, 2163:14,
mindset [1] - 2096:16
member [2] - 1991:9, 2069:6
2212:11, 2212:18, 2233:12, 2236:18,
minimization [3] - 2088:6, 2088:7,
members [4] - 1994:15, 2105:12,
2236:22, 2252:6, 2253:20, 2254:11
2088:22
2134:14, 2159:16
marketable [1] - 2254:7
minister [2] - 1998:17, 1998:24
Members [1] - 2030:22
marketing [4] - 2164:4, 2217:15,
Minister [1] - 2087:13
memo
[6]
2012:13,
2012:16,
2252:7, 2252:8
minister's [2] - 1998:11, 1998:16
2012:17, 2012:18, 2013:4, 2041:5
markings [1] - 1993:6
memorandum [1] - 1976:4
Ministry [1] - 2087:13
married [1] - 2189:10
memory
[6]
2050:22,
2050:23,
minor [1] - 2209:21
marrying [1] - 2010:14
2065:21, 2112:2, 2180:24, 2184:18
minute [10] - 2035:10, 2061:10,
Marshals [1] - 2016:3
memos [1] - 2034:14
2066:7, 2083:1, 2083:2, 2204:2,
Marwick [4] - 2100:16, 2100:18,
2205:25, 2221:9, 2232:4, 2243:8
mention [2] - 2145:7, 2145:16
2101:4, 2101:6
Minute [1] - 2135:2
mentioned [21] - 2010:5, 2041:20,
match [2] - 2025:15, 2217:10
minutes [7] - 2034:21, 2034:22,
2107:5, 2109:13, 2117:6, 2117:7,
matches [2] - 2214:10, 2217:6
2117:8,
2118:6,
2123:22,
2126:4,
2035:7,
2036:19, 2143:10, 2151:7,
material [11] - 2032:1, 2032:14,
2126:21,
2133:20,
2134:15,
2135:7,
2229:15
2109:7, 2129:11, 2241:8, 2241:9,
2137:16, 2146:10, 2150:15, 2163:18,
mislead [1] - 2088:1
2241:12, 2241:13, 2241:16, 2241:22,
2163:22,
2164:7,
2217:21
misled [1] - 2249:1
2241:24
merged
[2] - 2101:4, 2101:5
misrepresentations [2] - 2032:15,
materiality [6] - 2240:15, 2240:17,
mergers [2] - 2101:2, 2101:3
2191:20
2241:5, 2241:17, 2242:1, 2254:16
mess [2] - 1992:16, 2028:7
miss [1] - 2240:10
materials [23] - 2093:22, 2109:2,
message
[3]
2013:9,
2013:12,
missing [1] - 2095:2
2109:9, 2109:12, 2109:23, 2110:6,
2013:21
misspoke [1] - 2017:21
2110:10, 2110:12, 2110:17, 2110:23,
met [10] - 1983:20, 1984:4, 2039:4,
misstatement [1] - 2032:1
2112:15, 2112:17, 2113:11, 2140:25,
2103:12,
2161:7,
2169:13,
2199:3,
Mitchell [1] - 2100:16
2141:3, 2141:5, 2141:7, 2235:7,
2204:2, 2204:9, 2204:22
moderate [1] - 2194:6
2251:15, 2251:19, 2252:4, 2252:7,
Mexia [15] - 2105:1, 2105:3, 2105:5,
moderately [5] - 2171:24, 2171:25,
2252:9
2105:8, 2105:12, 2201:16, 2201:17,
2191:4, 2191:5, 2242:12
matter [8] - 1979:18, 1985:11,
2201:18, 2201:19, 2201:20, 2202:12,
moment [3] - 2072:14, 2227:1,
1996:14, 2003:17, 2035:18, 2125:7,
2202:23, 2204:6, 2205:8
2227:15
2150:10, 2257:12
Miami [1] - 2119:4
Monarch [4] - 2101:14, 2101:22,
mattered [1] - 2075:19
Michelle [5] - 2061:23, 2108:8,
2101:24, 2169:19
matters [4] - 2000:1, 2000:2, 2097:4,
2108:10, 2108:12, 2108:13
Monday [1] - 2093:5
2209:9
microphone
- 1983:25,
2128:14
Johnny C. Sanchez,
RMR,[2]CRR
2278
2092:13, 2096:7, 2096:9, 2096:12,
money [111] - 1982:21, 2004:10,
moved [5] - 2093:20, 2129:20,
2097:8, 2097:11, 2097:21, 2097:23,
2004:17, 2004:21, 2004:23, 2016:4,
2129:22, 2185:19, 2185:20
2098:1, 2098:3, 2098:12, 2098:14,
2016:11, 2016:23, 2040:17, 2070:1,
moving [2] - 1996:4, 2225:14
2098:24, 2099:8, 2101:1, 2102:18,
2080:18, 2085:12, 2110:1, 2110:10,
MR [497] - 1973:6, 1973:8, 1973:10,
2104:2, 2104:5, 2105:17, 2105:20,
2110:20, 2111:4, 2115:13, 2115:15,
1973:12, 1973:17, 1973:19, 1973:21,
2105:25, 2106:2, 2106:6, 2110:2,
2115:17, 2119:15, 2119:20, 2120:19,
1973:23, 1973:25, 1974:2, 1975:7,
2110:5, 2110:11, 2110:16, 2110:22,
2122:2, 2125:1, 2125:4, 2125:17,
1975:9, 1976:18, 1977:3, 1977:13,
2111:1, 2111:8, 2111:11, 2111:12,
2127:4, 2127:7, 2127:9, 2129:4,
1980:7, 1980:13, 1980:18, 1980:19,
2111:13, 2111:17, 2111:23, 2112:5,
2135:15, 2145:5, 2145:7, 2145:10,
1982:25, 1983:2, 1983:4, 1983:7,
2112:12, 2112:21, 2112:22, 2113:3,
2145:16, 2145:19, 2146:2, 2146:3,
1983:8, 1983:9, 1983:14, 1983:17,
2113:4, 2113:8, 2113:18, 2113:24,
2146:4, 2146:16, 2147:2, 2148:18,
1984:1, 1984:3, 1985:17, 1985:23,
2114:3, 2114:6, 2114:13, 2114:17,
2153:7, 2155:22, 2163:2, 2165:14,
1986:1, 1986:5, 1987:10, 1987:17,
2114:21, 2115:7, 2116:1, 2116:8,
2167:10, 2167:15, 2167:18, 2170:5,
1987:24, 1988:3, 1989:4, 1989:6,
2116:14, 2116:16, 2117:9, 2117:11,
2170:9, 2175:5, 2176:4, 2176:12,
1989:8, 1989:11, 1989:14, 1989:19,
2117:22, 2117:25, 2118:9, 2118:12,
2176:18, 2188:11, 2188:12, 2188:14,
1989:22, 1990:1, 1990:7, 1991:17,
2118:17, 2118:19, 2119:23, 2121:4,
2189:16, 2194:6, 2197:11, 2199:6,
1992:4, 1992:20, 1992:22, 1997:3,
2121:7, 2123:18, 2123:21, 2124:4,
2199:8, 2215:24, 2216:15, 2216:21,
1997:23, 1998:1, 1999:8, 1999:11,
2124:7, 2124:19, 2124:23, 2125:5,
2219:17, 2220:6, 2223:12, 2223:13,
1999:13, 1999:17, 2000:4, 2000:8,
2125:9, 2125:14, 2128:2, 2128:10,
2224:17, 2224:18, 2225:5, 2225:14,
2001:5, 2001:6, 2017:9, 2017:15,
2128:16, 2134:23, 2135:4, 2136:10,
2226:10, 2231:7, 2235:8, 2235:16,
2017:17, 2017:20, 2017:22, 2020:16,
2136:12, 2136:22, 2136:24, 2137:4,
2237:12, 2237:15, 2237:17, 2238:2,
2022:10, 2022:11, 2022:12, 2022:16,
2137:5, 2138:7, 2138:8, 2138:18,
2239:2, 2239:3, 2242:22, 2243:17,
2022:18, 2022:21, 2023:1, 2027:18,
2138:24, 2138:25, 2139:6, 2139:8,
2243:20, 2243:22, 2244:10, 2244:22,
2027:20, 2027:22, 2027:24, 2028:3,
2142:22, 2142:25, 2143:2, 2143:6,
2245:2, 2245:5, 2245:8, 2245:13,
2028:6, 2028:16, 2028:19, 2029:5,
2143:8, 2143:12, 2143:14, 2143:17,
2245:15, 2245:16, 2246:9, 2246:18,
2029:8, 2029:20, 2029:23, 2030:2,
2143:19, 2143:20, 2144:3, 2144:6,
2247:5, 2247:7, 2248:14, 2249:1,
2030:3, 2030:6, 2030:10, 2030:16,
2144:13, 2144:15, 2145:9, 2145:12,
2250:1, 2250:5, 2250:9, 2251:3,
2030:20, 2031:8, 2031:9, 2031:19,
2145:15, 2146:19, 2146:21, 2147:11,
2251:4, 2255:25, 2256:8
2031:20, 2032:3, 2032:4, 2032:8,
2147:12, 2147:15, 2147:18, 2147:20,
monies [1] - 2128:23
2032:9, 2034:24, 2035:13, 2036:2,
2148:2, 2148:4, 2148:8, 2148:23,
monitor [1] - 2232:7
2036:5, 2036:11, 2036:15, 2036:17,
2149:1, 2150:4, 2150:5, 2150:7,
2036:25, 2037:2, 2037:7, 2037:14,
monitoring [1] - 2141:12
2150:9, 2150:11, 2150:17, 2151:3,
2037:16, 2037:20, 2037:23, 2038:2,
month [1] - 2167:20
2151:8, 2152:9, 2152:11, 2152:15,
2038:8, 2038:20, 2040:2, 2040:3,
months [5] - 2013:5, 2039:8, 2099:17,
2152:18, 2152:21, 2152:25, 2153:14,
2044:12, 2044:16, 2044:20, 2044:23,
2126:3, 2183:1
2153:16, 2153:18, 2153:21, 2153:23,
2044:25, 2045:4, 2045:7, 2045:13,
months' [3] - 2166:22, 2166:23,
2154:1, 2154:9, 2154:11, 2154:21,
2045:17, 2045:21, 2046:12, 2049:24,
2167:4
2154:23, 2155:6, 2155:14, 2155:16,
2050:12,
2050:13,
2051:14,
2051:19,
Montrose [1] - 2186:19
2155:17, 2155:25, 2156:2, 2156:15,
2051:25, 2052:2, 2052:9, 2054:13,
Montserrat [32] - 1988:9, 1990:4,
2156:17, 2157:2, 2157:5, 2157:10,
2056:3, 2056:9, 2056:10, 2056:15,
1990:10, 1992:11, 1992:25, 1993:8,
2157:11, 2158:20, 2158:22, 2159:3,
2056:16,
2057:20,
2057:23,
2058:6,
1993:9, 1993:20, 1994:14, 1995:5,
2159:4, 2159:8, 2159:9, 2159:12,
2058:7, 2059:16, 2059:25, 2061:11,
1995:13, 1995:22, 1996:11, 1996:17,
2159:14, 2159:24, 2159:25, 2161:9,
2061:16, 2062:1, 2062:3, 2062:6,
1996:19, 1996:20, 1997:8, 1997:9,
2161:15, 2167:2, 2169:7, 2169:9,
2062:9,
2062:11,
2063:4,
2063:9,
1998:21, 2004:3, 2004:6, 2066:19,
2173:24, 2174:1, 2175:23, 2176:2,
2063:11, 2065:22, 2065:24, 2066:2,
2086:7, 2086:10, 2087:23, 2098:5,
2180:14, 2180:17, 2180:22, 2180:23,
2066:21, 2066:23, 2067:5, 2067:7,
2104:13, 2129:20, 2129:23, 2129:24,
2181:2, 2181:5, 2184:8, 2184:11,
2067:11,
2070:5,
2070:10,
2070:14,
2130:1, 2192:20
2184:13, 2184:15, 2184:17, 2197:10,
2070:16, 2070:21, 2071:3, 2071:16,
morning [15] - 1975:3, 1975:4,
2200:9, 2200:12, 2203:4, 2203:13,
2072:8, 2072:10, 2073:5, 2073:10,
1975:10, 1975:11, 1983:18, 1983:19,
2207:4, 2207:13, 2207:17, 2207:21,
2073:15,
2075:4,
2075:8,
2075:12,
1986:15, 1987:19, 2016:15, 2035:15,
2208:6, 2208:9, 2208:13, 2208:15,
2075:14, 2075:17, 2076:1, 2076:5,
2051:16, 2052:3, 2096:25, 2103:14,
2227:1, 2227:4, 2227:15, 2227:17,
2076:12,
2076:17,
2077:1,
2077:5,
2136:11
2227:20, 2227:22, 2227:25, 2228:3,
2077:9,
2077:12,
2077:15,
2077:17,
most [9] - 2039:24, 2075:24, 2108:16,
2228:17, 2228:20, 2229:19, 2229:22,
2078:2, 2078:8, 2078:11, 2078:23,
2135:22, 2136:1, 2199:9, 2199:11,
2230:1, 2230:4, 2231:9, 2231:11,
2079:5,
2079:9,
2079:14,
2079:25,
2241:9, 2242:12
2231:18, 2232:4, 2232:6, 2233:15,
2080:1,
2080:5,
2080:8,
2080:11,
motion [1] - 2096:24
2233:17, 2239:25, 2240:3, 2240:6,
2080:12, 2080:19, 2081:5, 2081:8,
motive [1] - 2194:14
2240:9, 2240:13, 2240:19, 2240:21,
2081:13,
2083:4,
2083:6,
2083:14,
move [24] - 1993:13, 1996:9, 1998:9,
2241:4, 2243:8, 2243:10, 2244:1,
2083:22,
2084:4,
2084:9,
2084:14,
1998:20, 2008:17, 2017:21, 2022:12,
2244:2, 2244:4, 2245:22, 2245:23,
2084:15, 2084:18, 2085:8, 2085:21,
2031:19, 2032:3, 2044:12, 2051:14,
2246:1, 2247:11, 2247:16, 2251:5,
2085:23,
2086:3,
2086:4,
2088:12,
2051:23, 2056:3, 2089:14, 2090:1,
2251:7, 2251:21, 2252:2, 2252:15,
2088:15,
2089:14,
2089:17,
2089:18,
2094:22, 2095:18, 2102:3, 2106:4,
2252:20, 2252:22, 2253:1, 2253:25,
2090:1, 2090:4, 2090:7, 2090:14,
2127:18, 2192:1, 2192:20, 2208:2,
2254:2, 2254:3, 2254:4, 2254:6,
2090:20,
2090:21,
2090:23,
2091:2,
2252:1
2279
2254:22, 2254:23, 2255:1, 2255:4,
2256:21, 2256:22
must [9] - 1982:3, 1997:15, 2091:18,
2091:20, 2202:13, 2204:15, 2211:3,
2211:4, 2228:1
mutual [1] - 1976:5
2123:8, 2140:23, 2161:23, 2162:7,

2018:12, 2037:15, 2037:16, 2037:19,
2162:8, 2192:6, 2192:13
2038:1, 2038:3, 2038:4, 2039:4,
2042:4, 2044:15, 2046:9, 2057:8,
New [4] - 1971:17, 2020:6, 2220:19,
2067:4, 2071:12, 2071:20, 2071:21,
2220:20
2071:24, 2071:25, 2094:21, 2118:13,
newly [1] - 2103:18
2132:20, 2134:21, 2139:6, 2188:6,
news [2] - 1999:4, 2179:23
2198:9, 2213:13, 2227:19, 2234:13,
newspaper [2] - 2102:23, 2216:25
2236:20, 2237:8, 2237:21, 2240:2,
newspapers
[1]
2216:18
N
2240:6, 2240:9
next [29] - 1982:6, 1985:2, 1997:11,
numbering [1] - 2037:21
2030:7, 2031:8, 2032:8, 2043:1,
name [13] - 1983:20, 1995:23,
numbers [3] - 2053:9, 2063:24,
2047:8, 2049:22, 2058:6, 2059:16,
2009:10, 2048:3, 2099:12, 2099:13,
2252:25
2059:17, 2059:18, 2059:19, 2061:13,
2101:5, 2104:14, 2117:4, 2117:12,
numerous [3] - 2112:14, 2192:21,
2061:18, 2077:15, 2098:23, 2145:14,
2122:25, 2169:12, 2220:25
2209:16
2152:15, 2152:18, 2207:18, 2208:6,
named [12] - 1999:21, 2000:24,
NW [1] - 1971:17
2208:13, 2209:3, 2214:23, 2215:2
2008:19, 2008:23, 2008:25, 2009:18,
nice [2] - 2023:18, 2023:21
2009:22, 2042:24, 2043:3, 2101:14,
nicer [1] - 2096:16
O
2198:15, 2216:3
night [3] - 1988:14, 2178:25, 2179:10
names [10] - 1990:15, 2010:5, 2014:4,
nights [1] - 2018:21
2047:23, 2048:6, 2048:8, 2056:22,
O'Brien [11] - 2008:25, 2009:10,
nobody [1] - 2251:3
2094:23, 2094:24, 2108:7
2009:15, 2014:9, 2071:15, 2071:17,
nobody's [1] - 2177:22
2094:8, 2095:19, 2095:23, 2096:1,
narrative [4] - 2116:3, 2124:16,
none [2] - 2176:5, 2239:8
2097:12
2124:17
nonfinancial [1] - 2007:2
o'clock [2] - 2035:14, 2207:10
narrow [1] - 2037:20
nongovernment [1] - 2068:12
O.Y [2] - 1990:9, 2002:15
Natalee [1] - 2164:5
nonprofit [1] - 2168:9
Oaks [1] - 2134:19
national [1] - 2100:15
nonresponsive [1] - 2116:1
oath [1] - 1993:6
nature [5] - 2016:24, 2053:6, 2113:11,
normal [1] - 2206:8
object [34] - 1976:18, 2008:2, 2008:3,
2220:10, 2221:12
North [1] - 2004:14
2008:9, 2008:13, 2008:16, 2036:1,
nau [1] - 2191:19
notation [1] - 2228:14
2036:2, 2070:5, 2070:21, 2075:4,
nau-uh [1] - 2191:19
Note [1] - 2151:16
2088:12, 2105:17, 2105:25, 2110:22,
near [3] - 2186:19, 2218:18, 2218:19
note [21] - 1994:11, 2016:1, 2021:3,
2112:5, 2112:8, 2112:23, 2113:1,
necessarily [2] - 2003:18, 2173:3
2035:17, 2035:23, 2035:25, 2037:9,
2114:13, 2116:1, 2116:14, 2117:22,
necessary [10] - 1997:16, 1997:17,
2038:25, 2053:12, 2063:17, 2063:18,
2124:4, 2128:10, 2145:12, 2152:10,
2003:11, 2031:23, 2054:7, 2054:8,
2064:3, 2088:17, 2148:25, 2150:3,
2180:14, 2181:2, 2200:9, 2203:4,
2054:9, 2054:14, 2160:7, 2160:8
2151:17, 2153:7, 2154:12, 2155:19,
2229:19, 2240:19, 2245:22
need [21] - 1987:13, 1987:24, 1996:22,
2156:4, 2156:19
objected [2] - 2007:25, 2079:9
1999:24, 2001:14, 2001:15, 2008:13,
noted [2] - 2035:4
objecting [1] - 2056:7
2008:16, 2012:12, 2027:20, 2057:21,
notes [19] - 2034:14, 2034:17, 2112:1,
objection [45] - 1977:12, 1989:6,
2071:1, 2087:3, 2091:8, 2122:14,
2183:16, 2209:13, 2228:2, 2245:12,
2022:16, 2022:22, 2035:23, 2036:1,
2152:21, 2173:12, 2206:5, 2207:10,
2247:21, 2248:1, 2248:2, 2248:9,
2037:5, 2038:16, 2044:25, 2051:25,
2224:16, 2252:17
2248:10, 2248:17, 2248:22, 2253:2,
2063:7, 2065:22, 2070:11, 2070:25,
needed [11] - 1993:16, 1996:10,
2253:4, 2253:7, 2255:14, 2255:15
2072:8, 2075:12, 2076:1, 2076:17,
2001:21, 2047:1, 2047:4, 2047:5,
nothing [15] - 1977:15, 1977:21,
2076:25, 2078:2, 2078:5, 2078:6,
2053:1, 2129:25, 2140:16, 2223:25,
1979:24, 2038:20, 2075:24, 2217:19,
2079:12, 2080:19, 2081:8, 2083:14,
2226:19
2223:17, 2224:22, 2231:3, 2232:1,
2083:22, 2083:25, 2084:1, 2090:13,
needs [3] - 2011:7, 2224:14, 2233:3
2232:3, 2232:12, 2247:4, 2247:6,
2090:14, 2106:5, 2110:2, 2110:15,
negotiate [2] - 2206:24
2256:22
2111:8, 2142:25, 2143:1, 2147:15,
negotiating [3] - 2205:21, 2217:14,
notice [9] - 2035:19, 2066:25, 2098:9,
2150:7, 2151:1, 2152:23, 2207:7,
2218:21
2098:11, 2150:25, 2166:22, 2166:23,
2207:13, 2251:21
nervous [1] - 2179:4
2167:4, 2167:20
Objection [1] - 2161:9
net [6] - 2195:21, 2195:22, 2195:23,
noticed [1] - 2141:23
objections [4] - 1980:12, 2063:4,
2196:10, 2225:20
notified [1] - 2068:3
2081:10, 2153:18
never [39] - 1983:20, 1984:21,
notifying [1] - 2130:2
observed [2] - 2168:24, 2170:7
1990:21, 1991:19, 2001:21, 2008:3,
noting [1] - 2254:19
obtain [3] - 1996:14, 2031:22, 2047:4
2013:24, 2014:23, 2048:24, 2082:23,
November [16] - 1993:2, 1993:4,
occasion [4] - 2001:24, 2003:8,
2087:5, 2088:2, 2114:9, 2155:21,
2002:22, 2005:22, 2011:1, 2036:6,
2033:3, 2043:22
2173:22, 2175:8, 2176:8, 2180:5,
2040:7, 2046:5, 2057:12, 2062:13,
occasions [1] - 2039:4
2188:14, 2191:10, 2191:13, 2191:16,
2067:2, 2067:20, 2069:12, 2086:21,
occurred [2] - 2097:5, 2135:13
2195:13, 2210:6, 2211:3, 2218:5,
2087:22, 2098:10
October [6] - 1992:24, 1993:7,
2218:8, 2221:23, 2222:24, 2233:8,
null [1] - 2003:2
1994:16, 1994:21, 1996:8, 1998:8
2233:9, 2233:11, 2235:25, 2239:10,
Number [3] - 2023:7, 2046:10, 2207:5
OF [2] - 1971:1, 1971:4
2249:21, 2250:9, 2256:16
number [40] - 1983:5, 1987:6,
offense [2] - 2047:13, 2047:14
new [10] - 2059:6, 2096:17, 2104:6,
1988:16, 1989:10,
2012:3,
2014:20,
Johnny C. Sanchez,
RMR, CRR
2280
2154:20, 2158:23, 2159:5, 2163:25,
offer [7] - 2090:1, 2106:21, 2114:9,
ought [1] - 2034:7
2171:15, 2171:17, 2172:20, 2173:1,
2142:22, 2150:14, 2207:5, 2240:3
outcome [1] - 2047:15
2183:4, 2183:5, 2185:11, 2186:22,
offered [7] - 2110:8, 2111:10, 2114:4,
outer [1] - 2079:17
2187:14, 2187:15, 2191:4, 2192:22,
2117:10, 2118:10, 2136:11, 2150:9
Outer [1] - 2079:18
2193:1, 2196:5, 2197:24, 2199:11,
offering [3] - 2026:10, 2065:24,
outgrown [1] - 2129:24
2199:21, 2207:2, 2212:10, 2213:13,
2150:17
outline [1] - 1976:10
2223:11, 2224:12, 2225:20, 2227:15,
offers [1] - 2150:4
outlined [1] - 2011:6
2228:8, 2228:23, 2232:4, 2241:10,
offhand [1] - 2067:4
outlines [2] - 1978:13, 2038:11
2242:14, 2243:8, 2244:14, 2247:14,
office [29] - 1984:21, 1993:11,
outlining [1] - 2012:13
2254:14, 2256:20
1994:16, 1998:11, 1998:16, 2000:21,
outside [8] - 1984:5, 1986:19, 2018:7,
one-year [1] - 2244:14
2063:21, 2093:1, 2093:11, 2093:17,
2060:24, 2064:18, 2160:4, 2163:2,
ones [7] - 1999:25, 2014:7, 2021:3,
2093:18, 2093:25, 2094:14, 2095:16,
2251:22
2021:5, 2119:19, 2197:17, 2217:10
2107:20, 2107:24, 2108:24, 2118:6,
outstanding [2] - 2047:9, 2053:17
opened [1] - 2162:16
2118:23, 2119:2, 2119:7, 2119:11,
overall [7] - 1981:14, 2032:6, 2041:22,
operate [2] - 2103:20, 2250:1
2131:10, 2161:2, 2161:3, 2161:17,
2085:15, 2101:18, 2139:12, 2199:1
operated [2] - 1998:21, 2233:1
2231:1, 2231:4, 2231:21
overhead [3] - 2067:7, 2080:6,
Operating [1] - 2012:7
officer [10] - 2130:13, 2169:20,
2085:21
2198:23, 2198:25, 2199:15, 2199:16,
operating [2] - 1995:22, 2015:5
overnight [1] - 2219:8
2199:20, 2199:22, 2199:25, 2200:2
Operation [18] - 2010:6, 2013:19,
overrule [2] - 1977:12, 2152:23
officers [4] - 2092:16, 2092:17,
2013:22, 2013:24, 2014:3, 2014:8,
overruled [21] - 2037:6, 2075:6,
2107:21, 2123:17
2014:14, 2014:18, 2015:4, 2015:11,
2081:11, 2083:18, 2083:21, 2110:24,
2015:16, 2069:21, 2069:22, 2069:24,
offices [12] - 2118:13, 2118:14,
2113:2, 2113:4, 2113:20, 2114:16,
2070:2, 2070:8, 2070:22, 2072:3
2118:20, 2119:4, 2136:3, 2141:19,
2114:19, 2117:24, 2124:5, 2125:13,
2141:21, 2181:12, 2230:21, 2231:2,
operation [8] - 2014:22, 2015:12,
2128:12, 2161:11, 2161:14, 2181:4,
2232:2, 2236:23
2028:12, 2032:22, 2190:1, 2208:21,
2203:5, 2240:24
2208:23, 2208:25
official [2] - 1993:20, 2092:14
overseas [1] - 2097:5
operational [1] - 2005:20
Offshore [1] - 2007:9
overseeing [2] - 2115:9, 2199:16
operations [1] - 1980:16
offshore [11] - 2004:3, 2005:7,
oversees [1] - 2221:24
operators [1] - 2011:13
2005:11, 2005:16, 2006:8, 2006:11,
overview [1] - 2139:9
2006:16, 2014:20, 2040:25, 2041:25,
Opinion [1] - 2230:3
owe [1] - 2224:19
2054:24
opinion [41] - 1988:19, 1992:5,
owes [1] - 2154:25
OFS [1] - 2007:12
1992:23, 1993:23, 1994:1, 1994:6,
own [8] - 1979:7, 2164:21, 2164:22,
OFSPC [1] - 2008:6
1996:2, 1999:5, 1999:7, 2000:22,
2219:13, 2221:21, 2223:9, 2224:12,
2000:23, 2001:15, 2028:4, 2028:9,
often [1] - 2136:7
2246:11
2030:5, 2031:6, 2031:7, 2031:10,
old [5] - 2099:17, 2100:10, 2167:25,
owned [16] - 2024:3, 2081:22,
2032:18, 2032:19, 2066:19, 2074:16,
2168:1, 2198:18
2097:17, 2102:19, 2117:21, 2118:3,
2085:17, 2086:5, 2087:8, 2095:3,
on-site [1] - 2033:11
2136:16, 2137:24, 2181:15, 2181:18,
2095:9, 2095:11, 2112:8, 2112:25,
once [15] - 1985:12, 2033:17, 2043:23,
2181:21, 2188:3, 2188:4, 2192:9,
2113:19, 2125:6, 2125:8, 2160:8,
2052:18, 2085:17, 2091:20, 2092:19,
2204:5, 2232:16
2165:23, 2172:22, 2238:21, 2241:13,
2111:4, 2124:1, 2124:8, 2127:11,
owner [3] - 2046:15, 2199:5, 2246:10
2243:19, 2249:13, 2254:21
2131:11, 2141:11, 2176:8, 2251:12
owners [2] - 2066:11, 2120:18
opinions [2] - 1994:8, 2032:5
One [1] - 2121:17
ownership [3] - 2025:21, 2026:5,
opponent [2] - 2150:12, 2150:19
one [122] - 1976:14, 1989:13, 1997:14,
2137:14
opportunities [2] - 2162:13, 2162:14
1997:18, 1999:17, 2000:3, 2001:17,
owns [4] - 2024:2, 2223:9, 2224:20,
opportunity [9] - 2106:11, 2177:12,
2016:5, 2018:20, 2021:6, 2021:8,
2246:3
2187:6, 2187:15, 2192:23, 2205:14,
2021:10, 2021:12, 2021:14, 2021:16,
2209:12, 2216:14, 2255:18
2021:18, 2021:20, 2021:22, 2021:24,
P
opposed [3] - 2209:2, 2219:12, 2246:7
2022:1, 2022:3, 2022:5, 2022:8,
order [9] - 1976:7, 2031:24, 2035:18,
2023:21, 2024:3, 2024:12, 2024:14,
p.m [3] - 2079:21, 2155:11, 2257:7
2025:9, 2027:8, 2030:4, 2030:6,
2052:4, 2058:24, 2063:20, 2086:7,
page [32] - 1980:10, 1983:7, 1983:15,
2035:14, 2035:15, 2035:21, 2036:3,
2117:7, 2151:20
1987:16, 1990:2, 1991:5, 1992:21,
2036:16, 2036:17, 2037:7, 2038:7,
ordered [2] - 2002:11, 2095:8
1997:12, 2002:3, 2002:7, 2028:4,
2038:8, 2039:9, 2039:12, 2039:20,
orders [1] - 2209:11
2028:17, 2029:6, 2029:7, 2030:8,
2040:17, 2044:14, 2044:16, 2044:17,
ordinance [1] - 2086:8
2052:25, 2067:10, 2073:12, 2073:13,
2047:9, 2047:10, 2052:2, 2053:11,
organization [4] - 1979:19, 2103:19,
2077:16, 2087:19, 2089:15, 2149:23,
2053:12, 2055:2, 2056:12, 2058:4,
2168:9, 2232:24
2159:3, 2181:6, 2207:18, 2207:19,
2060:15, 2060:16, 2066:25, 2071:12,
organizations [2] - 2027:2
2208:7, 2229:13
2076:2, 2076:19, 2076:21, 2079:15,
original [2] - 1998:24, 2000:20
PAGE [1] - 1973:3
2080:10, 2080:23, 2087:19, 2090:24,
Osborne [5] - 1998:17, 2000:10,
Page [34] - 1980:18, 1985:18, 1990:19,
2090:25, 2091:4, 2096:18, 2097:3,
2000:15, 2000:18, 2000:20
2100:18, 2106:23, 2111:9, 2119:3,
2000:4,
2000:6, 2001:5, 2027:19,
otherwise [4] - 1980:21, 2004:21,
2125:24, 2130:16, 2131:1, 2133:3,
2029:20, 2030:16, 2031:3, 2047:18,
2116:4, 2235:2
2134:15, 2134:19, 2134:21, 2154:18,
2073:10, 2080:3, 2081:14, 2081:17,
Ou [1] - 1983:12
Johnny C. Sanchez,
RMR, CRR - jcscourtreporter@aol.com
2281
2111:17, 2114:4, 2118:10, 2118:17,
2061:11, 2061:16, 2065:22, 2070:5,
Pavilion [5] - 2211:16, 2212:8,
2136:22, 2137:4, 2138:7, 2138:24,
2070:14, 2070:21, 2072:8, 2075:4,
2236:10, 2236:11, 2236:12
2139:7, 2148:23, 2155:25, 2157:4,
2075:12, 2075:14, 2076:1, 2076:17,
pay [10] - 2063:19, 2151:20, 2168:13,
2157:10, 2159:8, 2182:21, 2184:21,
2078:2, 2078:23, 2079:9, 2080:19,
2215:25, 2216:1, 2219:17, 2225:7,
2230:2, 2247:12, 2252:16
2081:8, 2083:14, 2083:22, 2084:15,
2226:5, 2244:11, 2244:12
2084:18, 2085:8, 2085:21, 2085:23,
Pages [1] - 2030:25
paying [6] - 2075:10, 2077:3, 2144:7,
2086:3, 2086:4, 2088:15, 2089:14,
pages [2] - 2096:6, 2096:9
2235:1, 2244:16, 2244:17
2089:17, 2089:18, 2090:1, 2090:4,
paid [17] - 1985:13, 1985:14, 2077:21,
payment [1] - 2096:1
2090:7, 2090:20, 2090:23, 2091:2,
2077:25, 2080:18, 2081:7, 2083:12,
payments [1] - 2075:18
2092:13, 2096:7, 2096:9, 2096:12,
2084:12, 2095:23, 2097:13, 2101:19,
payroll [2] - 2101:19, 2199:3
2097:8, 2097:11, 2097:21, 2097:23,
2143:22, 2168:4, 2188:16, 2199:2,
PDF [6] - 2027:19, 2029:6, 2029:7,
2098:14
2199:3, 2212:15
2029:20, 2030:16, 2159:8
Parras's [1] - 2079:7
panel [1] - 1991:11
Peat [4] - 2100:16, 2100:18, 2101:4,
PARRAS............. [1] - 1973:10
paneling [1] - 2141:9
2101:6
PARRAS............... [1] - 1973:6
paper [1] - 2112:1
pen [1] - 2001:10
part [37] - 2014:5, 2014:7, 2025:3,
paperwork [3] - 2029:17, 2058:20,
pending [1] - 2209:9
2035:21, 2041:1, 2068:22, 2068:24,
2187:22
people [38] - 2032:11, 2040:23,
2069:5, 2069:24, 2070:2, 2084:21,
paragraph [17] - 1982:6, 2000:7,
2040:24, 2061:7, 2068:12, 2088:11,
2085:15, 2087:9, 2091:14, 2103:18,
2032:8, 2047:1, 2047:8, 2052:24,
2106:22, 2109:13, 2116:11, 2164:11,
2107:16, 2107:24, 2107:25, 2108:16,
2063:9, 2063:16, 2067:14, 2067:24,
2172:19, 2173:6, 2173:16, 2173:19,
2144:22, 2147:21, 2164:25, 2165:10,
2096:9, 2111:20, 2151:5, 2182:21,
2190:8, 2194:25, 2195:23, 2196:10,
2175:5, 2178:1, 2186:4, 2187:7,
2184:21, 2209:3, 2230:3
2218:12, 2219:12, 2219:15, 2219:16,
2188:16, 2210:2, 2210:6, 2213:10,
paragraphs [4] - 2030:18, 2059:18,
2220:2, 2220:8, 2220:10, 2221:3,
2213:23, 2215:15, 2246:11, 2248:8,
2073:11, 2159:13
2233:1, 2233:2, 2233:5, 2236:20,
2248:21
parameters [1] - 1981:14
2246:18, 2248:24, 2249:21, 2249:25,
part... [1] - 2092:9
pardon [4] - 2153:15, 2184:10,
2250:4, 2250:7, 2254:11
partial [1] - 2246:10
2184:16, 2197:7
percent [14] - 2046:16, 2108:22,
particular [4] - 2142:15, 2157:24,
park [1] - 2190:25
2111:25, 2112:1, 2113:16, 2168:20,
2187:8, 2241:18
2181:18, 2184:5, 2184:22, 2185:17,
Park [1] - 2135:3
particularly [2] - 1978:22, 2232:24
2192:11, 2232:16
parked [1] - 2225:19
parties [1] - 1990:16
percentage [2] - 2108:19, 2244:11
Parras [17] - 1972:2, 1983:20,
partly [1] - 2108:23
perception [2] - 2163:15, 2163:23
2035:13, 2036:21, 2037:13, 2062:19,
partner [6] - 2026:12, 2026:22,
2065:7, 2065:17, 2067:13, 2068:15,
perfect [1] - 2151:5
2026:23, 2161:7, 2161:20, 2188:4
2072:25, 2074:3, 2074:15, 2074:19,
perfectly [2] - 2224:5, 2224:6
partners [3] - 2184:3, 2188:6, 2188:7
2078:17, 2080:13, 2098:4
perform [1] - 2176:13
Partnership [1] - 2188:2
PARRAS [155] - 1976:18, 1976:21,
performed [1] - 2031:22
partnership [16] - 2120:23, 2120:25,
1977:3, 1983:4, 1983:7, 1983:9,
Perhaps [1] - 2091:6
2121:8, 2121:9, 2121:11, 2121:14,
1983:14, 1983:17, 1984:1, 1984:3,
perhaps [3] - 2050:1, 2078:6, 2138:16
2121:16, 2121:20, 2121:22, 2121:24,
1985:17, 1985:23, 1986:1, 1986:5,
period [4] - 2070:17, 2084:24, 2085:7,
2122:2, 2122:4, 2122:12, 2122:18,
1987:10, 1987:15, 1987:17, 1987:24,
2129:1
2123:23, 2125:18
1988:3, 1989:4, 1989:11, 1989:14,
permit [2] - 2206:19, 2206:23
partnerships [13] - 2119:20, 2119:25,
1989:19, 1989:22, 1990:1, 1990:7,
person [9] - 2011:23, 2025:23, 2094:5,
2120:4, 2120:6, 2122:22, 2123:16,
1991:17, 1992:4, 1992:22, 1997:3,
2203:17, 2204:21, 2223:9, 2244:20,
2124:14, 2125:1, 2125:2, 2125:16,
1997:23, 1998:1, 1999:8, 1999:11,
2246:3, 2247:3
2126:23, 2133:24, 2233:25
1999:13, 1999:17, 2000:4, 2000:8,
personal [16] - 2070:5, 2074:25,
parts [3] - 2108:1, 2144:12, 2164:11
2001:5, 2001:6, 2017:9, 2017:17,
2075:11, 2081:9, 2093:13, 2093:15,
2017:20, 2017:22, 2020:16, 2022:10,
party [14] - 2150:12, 2150:19, 2158:7,
2122:3, 2122:16, 2127:1, 2127:5,
2022:12, 2022:18, 2023:1, 2027:18,
2158:15, 2203:8, 2238:23, 2239:11,
2145:20, 2146:17, 2161:9, 2167:15,
2027:22, 2027:24, 2028:3, 2028:6,
2239:13, 2239:23, 2239:24, 2240:14,
2243:25
2028:16, 2028:19, 2029:5, 2029:8,
2240:22, 2241:19, 2256:4
personality [1] - 2172:24
2029:20, 2029:23, 2030:2, 2030:3,
pass [10] - 1983:2, 2065:13, 2084:14,
personally [3] - 2112:7, 2126:22,
2030:6, 2030:10, 2030:16, 2030:20,
2098:12, 2169:7, 2233:15, 2244:1,
2173:8
2031:8, 2031:9, 2031:19, 2031:20,
2251:5, 2254:22, 2256:21
persons [3] - 1995:24, 2008:10,
2032:3, 2032:4, 2032:8, 2032:9,
passed [3] - 2004:9, 2069:25, 2070:18
2094:21
2037:2, 2037:7, 2037:14, 2037:16,
passport [2] - 2053:8, 2053:9
perspective [1] - 2242:2
2037:20, 2037:23, 2038:8, 2040:2,
past [3] - 2105:15, 2105:22, 2214:7
Peter [1] - 2043:14
2040:3, 2044:12, 2044:16, 2044:20,
Pat [6] - 2009:15, 2014:9, 2094:8,
philosophy [2] - 1981:13, 2215:5
2044:23, 2045:4, 2045:7, 2045:13,
2095:19, 2095:23, 2096:1
photo [4] - 2080:4, 2080:13, 2136:13,
2045:17, 2045:21, 2046:12, 2049:24,
Pat' [1] - 2008:25
2136:25
2050:12, 2050:13, 2051:14, 2052:9,
Patrick [3] - 2009:10, 2009:11,
photograph [3] - 2053:9, 2231:1,
2054:13, 2056:3, 2056:9, 2056:10,
2071:15
2231:4
2056:15, 2056:16, 2057:20, 2057:23,
Paul [2] - 2039:3, 2168:8
photographs [1] - 2231:3
2058:6, 2058:7, 2059:16, 2059:25,
pavilion [2] - 2236:3, 2236:6
photos [1] - 2020:22
2282
2199:5
phrase [2] - 2068:6, 2068:8
point-by-point [1] - 2057:17
presenting [1] - 1982:16
physically [2] - 2093:11, 2094:13
pointed [1] - 2001:10
president [13] - 2062:16, 2094:3,
pick [3] - 2083:17, 2083:19, 2172:20
points [4] - 2038:11, 2040:10,
2101:16, 2101:21, 2123:9, 2132:14,
2040:12, 2057:8
picked [2] - 2094:13, 2172:20
2139:4, 2149:15, 2153:4, 2155:23,
police [1] - 2094:25
picking [1] - 2172:25
2158:10, 2167:22, 2174:17
policies [1] - 2031:18
picture [9] - 2077:18, 2119:5, 2119:6,
president's [1] - 2133:19
pong [1] - 2078:25
2144:20, 2195:4, 2196:25, 2197:2,
presidents [1] - 2106:25
2213:10, 2215:15
pool [1] - 2136:20
Preston [1] - 1972:3
pictured [1] - 2236:15
poor [1] - 2168:10
pretty [6] - 1989:21, 2087:24, 2154:8,
pictures [5] - 2023:4, 2023:5, 2093:24,
popular [1] - 2213:19
2189:14, 2216:8, 2256:20
2119:4, 2214:23
portfolio [20] - 1977:19, 1978:9,
prevent [1] - 2082:17
piece [2] - 2212:14, 2256:3
1978:13, 1980:17, 1981:2, 1981:6,
prevents [2] - 1977:15, 1977:21
pieces [4] - 1975:24, 1979:3, 1987:19,
1981:13, 1981:19, 1982:7, 2059:3,
previously [5] - 1980:5, 1980:8,
2034:1
2062:23, 2111:21, 2111:24, 2113:12,
1980:10, 2053:13, 2200:4
2115:2, 2115:9, 2126:7, 2126:19,
ping [1] - 2078:25
Price [3] - 2161:3, 2161:5, 2161:17
2129:4, 2149:4
ping-pong [1] - 2078:25
portfolios [1] - 1979:17
price [2] - 2126:13, 2212:18
pitch [4] - 2082:11, 2082:12, 2082:13,
portion [13] - 1977:1, 2045:13, 2058:9,
primarily [5] - 2108:5, 2108:6,
2083:8
2058:11, 2076:23, 2080:24, 2113:9,
2120:10, 2162:16, 2209:20
pitcher [1] - 2082:21
2148:24, 2151:4, 2154:21, 2156:1,
primary [2] - 2168:25, 2207:2
place [23] - 1993:10, 2012:5, 2018:7,
2157:14, 2208:14
principal [3] - 2063:23, 2151:21,
2035:22, 2040:18, 2042:6, 2053:10,
position [26] - 2047:16, 2050:20,
2244:12
2062:25, 2088:23, 2138:11, 2178:6,
2051:24, 2053:15, 2060:20, 2060:22,
principle [2] - 2241:18, 2251:2
2178:7, 2178:22, 2190:25, 2193:2,
2060:24, 2069:8, 2069:16, 2072:15,
2196:11, 2213:10, 2213:11, 2213:12,
principles [2] - 2221:22, 2222:11
2102:21, 2103:4, 2103:16, 2104:16,
2218:3, 2218:11, 2219:12
priority [2] - 2041:2, 2041:3
2106:14, 2130:11, 2130:20, 2130:23,
placed [2] - 1979:11, 2102:24
private [13] - 2010:18, 2011:14,
2131:1, 2168:11, 2173:10, 2173:17,
places [10] - 2005:15, 2011:11,
2068:12, 2074:22, 2137:23, 2138:5,
2173:20, 2175:14, 2175:18, 2183:2
2018:10, 2020:3, 2020:25, 2085:20,
2144:20, 2160:10, 2195:25, 2196:6,
positions [5] - 1982:7, 1982:10,
2087:9, 2087:19, 2195:24, 2213:19
2196:11, 2209:1
2072:17, 2072:18, 2073:18
plain [1] - 2039:20
prize [1] - 2216:21
positive [1] - 2199:25
plaintiff [1] - 2002:12
problem [16] - 1977:2, 2068:16,
possession [3] - 2033:22, 2033:24,
plaintiffs [1] - 2002:14
2068:19, 2069:1, 2082:17, 2160:17,
2034:19
2164:15, 2191:13, 2191:16, 2207:9,
plan [11] - 1996:9, 2005:20, 2006:6,
possibilities [1] - 2219:14
2226:21, 2235:18, 2235:19, 2249:2,
2010:25, 2190:17, 2192:24, 2194:2,
possibility [1] - 2219:16
2250:19, 2251:1
2195:6, 2195:10, 2196:17, 2198:8
possible [11] - 1986:24, 2008:22,
problems [6] - 1994:13, 1995:13,
plane [1] - 2144:23
2011:3, 2038:14, 2048:10, 2048:15,
2059:10, 2186:10, 2215:19, 2225:24
planes [5] - 2137:10, 2137:21,
2053:17, 2088:25, 2089:1, 2171:8,
procedures [1] - 2015:23
2137:23, 2209:2
2216:6
proceed [2] - 1975:5, 2155:14
planned [2] - 2031:22, 2219:10
possibly [3] - 2026:22, 2102:8,
Proceedings [2] - 1972:13, 1972:20
Planning [1] - 2007:9
2146:18
proceedings [1] - 2257:11
planning [5] - 2010:11, 2010:12,
potential [2] - 2068:4, 2166:6
proceeds [1] - 2250:23
2130:2, 2138:20, 2220:5
power [5] - 2048:17, 2048:20,
plans [7] - 2112:9, 2140:1, 2140:2,
process [10] - 1979:8, 2060:1, 2060:8,
2052:19, 2092:3, 2232:13
2219:21, 2219:25, 2220:1, 2221:2
2178:1, 2183:6, 2183:8, 2202:2,
predecessor [1] - 2072:16
2206:4, 2206:12, 2206:25
plant [3] - 2210:2, 2210:5, 2210:9
predecessors [1] - 2076:14
processes [1] - 2015:24
platform [1] - 2041:21
predominately [1] - 2236:16
processing [1] - 2053:18
play [1] - 2214:1
prefaced [1] - 2089:6
produce [2] - 2164:21, 2250:7
played [6] - 2143:18, 2144:5, 2144:14,
preference [1] - 1997:19
produced [8] - 1972:13, 1972:21,
2213:24, 2213:25, 2214:9
premier [1] - 2019:9
1978:17, 2035:18, 2037:3, 2055:22,
players [1] - 2019:4
premises [1] - 2094:17
2091:22, 2221:12
pleasures [1] - 2096:18
preparation [5] - 2031:4, 2031:16,
product [3] - 2108:4, 2108:25, 2252:12
plenty [1] - 2224:13
2033:20, 2034:12, 2199:4
production [3] - 2038:9, 2039:14,
plumbing [1] - 2164:14
prepare [4] - 2034:15, 2041:19,
2039:15
plus [2] - 2212:10, 2244:12
2041:21, 2101:20
products [7] - 1982:2, 2197:4, 2197:9,
PO [2] - 1971:14, 1972:7
prepared [2] - 2028:13, 2032:23
2233:6, 2233:8, 2233:10, 2252:6
Point [5] - 2138:11, 2138:14, 2196:25,
prerequisite [1] - 1996:12
profession [1] - 2099:23
2212:8, 2218:7
presence [1] - 1993:15
professional [4] - 2029:2, 2029:4,
point [19] - 2006:15, 2009:13, 2011:18,
present [4] - 2000:10, 2064:21,
2047:10, 2053:11
2017:23, 2020:15, 2049:11, 2050:1,
2094:15, 2142:15
profit [5] - 2133:25, 2242:18, 2242:25,
2057:17, 2057:20, 2075:4, 2077:13,
presentation [1] - 2032:6
2250:2, 2250:7
2079:8, 2085:20, 2101:8, 2103:23,
presented [3] - 2007:5, 2101:21,
profitability [1] - 2234:25
2132:12, 2155:6, 2163:1
2283
profitable [6] - 2242:9, 2242:12,
2242:15, 2249:14, 2250:6, 2250:13
profits [1] - 2250:17
program [1] - 2079:17
progress [1] - 2141:12
progressed [1] - 2005:1
prohibition [2] - 1976:16, 1979:20
prohibits [1] - 1979:24
project [12] - 2106:8, 2120:22, 2121:2,
2135:2, 2135:3, 2186:15, 2186:17,
2187:9, 2200:16, 2209:7, 2209:10,
2210:6
projections [2] - 2249:16, 2249:17
projector [1] - 2085:22
projects [29] - 2129:5, 2135:6, 2135:7,
2135:13, 2135:19, 2135:23, 2136:1,
2142:11, 2146:13, 2152:7, 2167:12,
2171:13, 2171:16, 2185:22, 2186:3,
2189:3, 2189:5, 2191:25, 2192:1,
2197:12, 2197:15, 2210:10, 2211:16,
2211:19, 2211:21, 2211:22, 2211:24,
2243:14
Promindon [1] - 2108:10
promise [1] - 2246:4
promises [2] - 2063:19, 2151:20
Promissory [1] - 2151:16
promissory [12] - 2063:17, 2063:18,
2064:3, 2088:17, 2150:3, 2151:16,
2151:17, 2153:7, 2154:12, 2155:19,
2156:3, 2156:19
promote [4] - 2212:12, 2212:16,
2217:13, 2233:13
promoting [1] - 2217:2
promotion [2] - 2076:15, 2077:3
promotional [12] - 2109:2, 2109:7,
2109:9, 2109:11, 2110:6, 2112:15,
2119:3, 2129:11, 2235:6, 2251:15,
2251:19, 2252:4
pronoun [1] - 2143:21
pronounced [1] - 2201:16
proper [2] - 2008:1, 2164:19
properly [1] - 2120:20
properties [11] - 2120:18, 2122:21,
2134:7, 2139:15, 2183:22, 2191:8,
2191:10, 2191:13, 2205:15, 2206:3,
2210:7
property [11] - 2120:8, 2125:19,
2126:13, 2188:1, 2192:15, 2209:18,
2212:14, 2218:18, 2218:25, 2256:7,
2256:16
propose [1] - 1990:23
proposed [3] - 1988:9, 2086:7,
2092:16
prosecution [2] - 2079:1, 2177:15
prosecutor [5] - 1987:7, 2086:16,
2112:23, 2213:6, 2221:10
prosecutors [1] - 2078:25
proud [1] - 2055:8
prove [1] - 2112:9
provide [8] - 2031:24, 2091:19,
2091:20, 2132:13, 2132:19, 2177:19,
2185:5, 2185:17
provided [8] - 2002:11, 2034:3,

2034:5, 2041:21, 2051:15, 2062:22,
2207:5, 2212:24
provision [2] - 2049:9, 2049:12
proviso [1] - 2152:24
public [11] - 1975:25, 1976:1, 2100:2,
2100:6, 2100:15, 2103:5, 2125:23,
2163:15, 2163:22, 2196:6, 2253:18
publicized [1] - 2164:1
published [2] - 2039:2, 2063:5
Puerto [1] - 2009:18
pull [5] - 2030:7, 2062:6, 2093:18,
2102:8, 2128:13
purchase [10] - 2076:15, 2103:20,
2106:12, 2120:18, 2121:16, 2122:6,
2206:13, 2208:16, 2208:20, 2244:19
purchased [6] - 2122:21, 2123:1,
2192:16, 2192:18, 2210:21, 2210:22
purchasers [1] - 2166:6
purchases [2] - 2122:24, 2208:19
pure [1] - 2113:6
purely [1] - 2078:24
purported [1] - 2003:1
purportedly [1] - 2086:13
purpose [12] - 1994:24, 1998:7,
1998:18, 2058:19, 2058:24, 2059:7,
2076:24, 2170:14, 2213:8, 2220:19,
2236:13, 2251:15
purposes [3] - 2150:18, 2151:2,
2209:19
pursuant [2] - 1980:11, 2016:4
pursuit [1] - 2001:22
put [37] - 1981:21, 1982:17, 1982:22,
1983:12, 1987:13, 2012:5, 2021:3,
2038:5, 2040:18, 2044:23, 2045:15,
2049:13, 2062:24, 2078:18, 2085:12,
2085:13, 2094:8, 2108:19, 2109:2,
2141:20, 2148:3, 2148:4, 2150:25,
2165:13, 2187:21, 2188:10, 2189:22,
2191:10, 2200:1, 2200:5, 2211:2,
2212:14, 2216:20, 2216:21, 2223:24,
2251:19, 2252:3
putting [4] - 2017:18, 2042:10,
2237:17, 2239:2
1987:23, 1988:16, 2047:18, 2061:12,

2061:14, 2061:16, 2061:21, 2064:8,
2064:12, 2066:18, 2066:19, 2068:15,
2072:22, 2074:8, 2075:21, 2076:6,
2078:19, 2084:19, 2084:23, 2097:21,
2125:10, 2178:2, 2183:9, 2183:13,
2200:8, 2222:5, 2227:6, 2234:13,
2237:9, 2244:2
quick [3] - 2006:6, 2042:2, 2156:16
quicker [3] - 2012:12, 2116:3, 2245:15
quickly [4] - 2012:21, 2056:11,
2140:16, 2254:23
quit [5] - 2068:7, 2170:4, 2176:17,
2176:21, 2206:5
quite [5] - 1979:2, 2007:14, 2008:22,
2019:6, 2105:6
quote [3] - 1994:8, 2065:20, 2194:12
quote-unquote [1] - 2194:12
quoted [1] - 2183:4
raging [1] - 2004:12

raining [1] - 2082:18
raise [4] - 2079:18, 2099:2, 2140:6,
2186:8
raised [4] - 2016:15, 2069:10,
2119:20, 2160:11
range [8] - 1979:16, 1979:18, 2006:20,
2006:25, 2007:1, 2007:3, 2012:5,
2184:22
ranging [1] - 2018:17
rapidly [1] - 2140:17
rate [3] - 2063:25, 2151:23, 2212:21
rather [1] - 2084:1
Ravenscroft [2] - 1999:22
raw [2] - 2209:18, 2209:20
re [1] - 2204:3
reached [1] - 2055:3
reaction [3] - 1981:23, 2142:1, 2163:7
read [60] - 1976:25, 1977:1, 1980:20,
1981:4, 1982:8, 1990:5, 1992:6,
1992:16, 1994:10, 1994:23, 1999:1,
2000:6, 2002:7, 2003:20, 2028:7,
2030:4, 2030:17, 2041:8, 2042:2,
Q
2050:4, 2053:22, 2058:17, 2059:3,
2063:16, 2065:21, 2067:12, 2067:14,
qualified [2] - 1977:3, 2125:7
2073:16, 2074:16, 2076:22, 2076:23,
2080:22, 2080:24, 2084:4, 2084:8,
quality [5] - 2140:18, 2140:20,
2086:19, 2092:7, 2096:4, 2109:2,
2140:22, 2140:23, 2236:23
2109:9, 2109:17, 2109:20, 2109:23,
quarterly [1] - 1978:10
2110:6, 2110:12, 2110:17, 2111:2,
quarters [1] - 2034:23
2112:15, 2112:16, 2157:7, 2208:18,
Queeley [3] - 2064:17, 2064:25,
2209:4, 2216:17, 2216:25, 2228:22,
2065:4
2229:5, 2230:7, 2247:20, 2252:5
Quelley [6] - 2042:24, 2042:25,
reading [21] - 1981:11, 1981:18,
2043:2, 2043:14, 2043:19
1982:14, 1993:22, 1993:24, 1994:18,
queries [1] - 2060:4
1994:21, 1994:22, 1997:11, 2030:4,
questioned [5] - 2128:8, 2128:9,
2041:10, 2044:5, 2045:25, 2046:3,
2128:11, 2128:19, 2128:20
2046:19, 2050:15, 2112:19, 2113:10,
questioning [3] - 2068:9, 2083:23,
2180:14, 2217:2, 2241:25
2112:9
ready [8] - 1975:5, 2035:6, 2038:18,
questions [32] - 1980:16, 1987:6,
2284
2097:7, 2155:10, 2253:20, 2254:12,
2059:13
2005:7, 2007:19, 2010:19, 2011:21,
2257:5
2060:6, 2065:13, 2065:14, 2073:24,
recommendations [1] - 2056:18
2206:18, 2223:20, 2223:23, 2224:9,
real [80] - 2101:8, 2103:6, 2103:19,
recommended [1] - 2042:15
2224:10
2104:9, 2104:22, 2106:7, 2106:8,
record [6] - 2084:5, 2104:2, 2104:3,
regulator [10] - 1991:1, 1996:18,
2106:12, 2106:19, 2107:18, 2119:12,
2183:18, 2228:13, 2257:11
2119:16, 2119:25, 2120:4, 2120:6,
1997:4, 2000:24, 2001:13, 2040:5,
recorded [2] - 1972:13, 1972:20
2120:13, 2120:16, 2120:17, 2121:11,
2047:20, 2051:12, 2052:10, 2072:7
records [6] - 2034:11, 2074:23,
2121:13, 2121:22, 2122:4, 2122:11,
regulators [3] - 1981:5, 1981:9,
2127:6, 2147:5, 2160:6, 2174:25
2123:12, 2123:15, 2123:22, 2124:13,
1981:20
RECROSS [6] - 1973:10, 1973:23,
2125:1, 2125:2, 2125:12, 2125:15,
regulatory [29] - 1976:2, 2001:22,
1974:2, 2084:17, 2244:3, 2255:3
2125:17, 2126:1, 2126:8, 2126:11,
2007:3, 2009:18, 2010:1, 2011:8,
recross [2] - 2098:4, 2241:3
2126:12, 2126:17, 2126:20, 2126:23,
2013:16, 2014:13, 2015:14, 2028:21,
recruit [1] - 2041:19
2129:5, 2133:21, 2149:12, 2156:15,
2029:1, 2029:12, 2030:14, 2033:17,
red [3] - 2000:2, 2085:17, 2186:8
2170:8, 2170:10, 2170:17, 2170:24,
2038:12, 2040:13, 2040:23, 2042:6,
redact [1] - 2045:13
2171:1, 2171:3, 2171:5, 2171:17,
2042:19, 2043:24, 2065:13, 2066:16,
Redhead [9] - 1988:19, 1990:13,
2171:20, 2172:2, 2176:4, 2185:14,
2068:22, 2069:17, 2071:23, 2072:19,
1994:5, 1994:7, 2002:4, 2002:9,
2186:7, 2186:12, 2190:21, 2191:3,
2088:21, 2249:9
2002:10, 2003:19, 2086:5
2191:6, 2191:21, 2200:14, 2222:20,
rehabilitate [1] - 2120:20
redirect [3] - 2086:18, 2088:13,
2222:23, 2233:25, 2235:9, 2235:17,
Rehnquist [1] - 2039:8
2088:17
2239:2, 2239:9, 2239:10, 2242:8,
relate [1] - 1979:1
REDIRECT [8] - 1973:8, 1973:12,
2245:12, 2249:3, 2250:18, 2255:17,
related [11] - 2138:5, 2158:7, 2158:14,
1973:21, 1973:25, 2062:2, 2098:2,
2255:18, 2255:23, 2256:3, 2256:19
2238:23, 2239:11, 2239:13, 2239:23,
2233:16, 2251:6
reality [1] - 2093:7
2239:24, 2240:14, 2240:22, 2241:19
reduce [1] - 2088:11
realization [1] - 2005:4
related-party [8] - 2238:23, 2239:11,
reel [1] - 2205:7
realized [1] - 2005:2
2239:13, 2239:23, 2239:24, 2240:14,
reference [4] - 1991:11, 2047:10,
really [7] - 1987:4, 2013:24, 2019:20,
2240:22, 2241:19
2053:11, 2181:7
2042:2, 2096:16, 2170:20, 2231:20
relates [1] - 1976:6
referenced [5] - 1980:6, 1989:7,
reapply [1] - 2060:10
relation [1] - 2131:11
2056:7, 2117:10, 2157:3
reason [20] - 1985:10, 2029:19,
relationship [3] - 2131:7, 2131:13,
references [1] - 2053:5
2037:4, 2050:18, 2071:12, 2071:20,
2131:14
referencing [2] - 1980:11, 2117:16
2071:21, 2071:24, 2071:25, 2085:24,
relative [2] - 2139:24, 2169:3
referred [3] - 2002:24, 2082:10,
2086:5, 2147:21, 2150:15, 2166:24,
released [6] - 1975:17, 1975:19,
2186:14
2167:6, 2189:1, 2194:11, 2202:1,
1975:20, 1975:23, 1975:24, 2098:18
referring [4] - 2010:8, 2049:1,
2202:4, 2225:22
releasing [1] - 1979:23
2105:18, 2255:7
reasonable [1] - 2031:25
relevance [2] - 2128:10, 2147:15
refers [2] - 2083:7, 2255:10
reasonably [1] - 2013:2
relevant [6] - 2031:13, 2066:12,
reflect [1] - 2104:3
reasons [4] - 2071:12, 2086:6,
2148:5, 2148:7, 2251:22, 2253:18
refresh [5] - 2044:2, 2049:25, 2087:3,
2123:17, 2251:25
relocate [1] - 2164:13
2180:24, 2184:18
rebuttal [1] - 2241:2
relying [2] - 2164:22, 2252:8
regard [11] - 2000:25, 2015:20,
receipt [5] - 2046:4, 2051:12, 2052:15,
remember [60] - 1979:1, 1988:5,
2034:8, 2072:3, 2078:12, 2193:6,
2092:1, 2092:8
1988:11, 1989:21, 2005:19, 2009:23,
2201:9, 2209:8, 2210:6, 2215:21,
receive [1] - 2092:4
2012:16, 2013:4, 2013:8, 2013:18,
2220:22
received [5] - 1993:2, 2055:25,
2014:7, 2014:9, 2014:10, 2026:13,
regarding [15] - 1992:8, 1996:20,
2063:18, 2149:17, 2151:19
2040:7, 2041:4, 2041:13, 2043:8,
2004:10, 2010:19, 2011:21, 2016:4,
receiver [4] - 2025:20, 2026:3, 2026:4,
2044:10, 2049:3, 2075:22, 2076:11,
2036:6, 2036:7, 2052:11, 2069:25,
2026:5
2079:17, 2086:18, 2086:24, 2088:16,
2070:18, 2096:1, 2196:17, 2220:15,
recent [1] - 2065:3
2089:8, 2092:1, 2092:25, 2102:24,
2225:17
recently [1] - 2039:2
2108:7, 2115:12, 2117:6, 2176:24,
regardless [2] - 2239:1, 2243:21
Recessed [4] - 2035:8, 2079:21,
2177:6, 2177:9, 2178:5, 2180:8,
regime [6] - 2011:8, 2011:24, 2013:16,
2155:11, 2257:7
2180:18, 2180:21, 2181:9, 2182:8,
2033:17, 2071:23, 2088:22
recognize [34] - 2020:23, 2020:25,
2182:12, 2182:21, 2183:25, 2184:1,
region [3] - 2024:11, 2042:2, 2064:19
2021:4, 2021:5, 2021:7, 2023:3,
2184:6, 2184:7, 2186:1, 2188:25,
regret [1] - 2168:16
2023:8, 2023:23, 2024:19, 2024:22,
2196:4, 2219:2, 2223:2, 2223:4,
regrets [1] - 2168:17
2025:6, 2044:6, 2045:8, 2045:11,
2233:18, 2234:2, 2235:14, 2242:10
regulate [4] - 2003:8, 2005:2, 2007:2,
2045:22, 2050:14, 2055:14, 2055:19,
remind [2] - 2064:16, 2097:12
2052:15
2057:2, 2058:8, 2058:11, 2081:15,
reminding [1] - 2035:1
regulated [4] - 1978:8, 1996:4, 2005:5,
2081:18, 2111:14, 2136:13, 2137:6,
removal [3] - 2094:11, 2094:16,
2061:7
2138:9, 2139:1, 2139:9, 2142:13,
2095:10
regulating [3] - 2011:25, 2054:23,
2148:11, 2149:22, 2156:3, 2182:6
removed [4] - 2093:2, 2093:7,
2065:11
recognized [1] - 2023:5
2093:11,
2095:5
regulation [3] - 1985:8, 2004:4,
recollection [4] - 2044:2, 2050:1,
removement [1] - 2094:10
2066:10
2137:18, 2198:22
removing [2] - 2093:21, 2093:25
regulations [15] - 1982:10, 2003:24,
recommendation [2] - 2059:8,
render [1] - 2072:11
2285
2206:15, 2206:17
rental [2] - 2120:8, 2171:18
returned [1] - 2093:5
required [18] - 1976:7, 1978:9, 1979:2,
repair [1] - 2164:11
revealed [1] - 2014:23
2040:17, 2048:22, 2050:7, 2066:15,
repealed [3] - 2071:7, 2071:10,
revealing [1] - 1977:15
2091:22, 2109:19, 2112:14, 2112:17,
2071:12
Revenue [5] - 2225:13, 2225:16,
2118:6, 2158:15, 2205:20, 2222:13,
repeat [3] - 1992:21, 2110:25, 2124:6
2225:24, 2226:1, 2226:9
2222:17, 2224:11, 2252:4
repeatedly [1] - 2240:22
reverse [1] - 2147:25
requirement [5] - 2028:24, 2041:1,
rephrase [4] - 2072:9, 2083:19,
review [6] - 2028:22, 2086:12,
2051:7, 2078:15, 2247:1
2116:6, 2123:20
2095:25, 2109:7, 2118:6, 2229:17
requirements [7] - 2046:23, 2047:17,
replaced [3] - 2064:23, 2064:25,
reviewed [8] - 2032:11, 2109:12,
2047:19, 2048:6, 2051:3, 2222:3,
2199:23
2110:23, 2185:24, 2228:25, 2229:14,
2222:16
2229:15, 2241:6
replied [1] - 2012:11
requires [4] - 2047:23, 2048:3, 2065:8,
reviewing [1] - 2119:3
report [60] - 2007:5, 2008:4, 2011:1,
2252:12
reviews [1] - 2033:9
2011:4, 2011:6, 2011:9, 2013:5,
research [1] - 2231:6
2027:12, 2028:18, 2028:20, 2029:16,
revise [1] - 2076:7
residence [1] - 2178:22
2030:9, 2030:11, 2031:7, 2040:8,
revive [1] - 2020:18
residential [2] - 2120:8, 2183:22
2040:9, 2049:13, 2056:17, 2057:2,
revocation [5] - 2002:24, 2067:1,
resign [2] - 2166:16, 2167:25
2058:4, 2058:9, 2058:12, 2064:9,
2068:4, 2098:9, 2098:11
2094:25, 2109:22, 2111:15, 2125:21,
resigning [1] - 2166:25
revoke [5] - 1988:9, 1990:23, 2087:2,
2148:12, 2148:24, 2156:9, 2156:23,
resort [16] - 2164:18, 2164:20, 2165:2,
2087:4, 2130:2
2157:7, 2157:12, 2158:1, 2158:3,
2165:5, 2165:6, 2165:14, 2166:1,
revoked [9] - 1988:20, 1988:22,
2158:6, 2158:17, 2158:21, 2158:25,
2218:13, 2218:14, 2218:17, 2218:24,
1991:3, 1992:9, 1992:13, 2002:22,
2159:15, 2159:19, 2160:2, 2177:19,
2219:5, 2219:17, 2237:6, 2237:10,
2067:20, 2086:13, 2086:22
2180:12, 2180:15, 2180:24, 2184:18,
2237:18
Rican [1] - 2009:18
2188:21, 2228:6, 2228:22, 2229:1,
resorts [8] - 2162:17, 2162:19, 2163:4,
rich [2] - 2220:10, 2221:3
2229:8, 2229:14, 2229:21, 2230:13,
2163:9, 2163:11, 2163:19, 2164:17,
richest [1] - 2218:11
2238:19, 2246:17, 2246:24, 2248:7,
2165:1
Richmond [2] - 2178:6, 2178:7
2248:16
resources [9] - 1979:9, 2122:3,
rid [1] - 2014:19
Report [1] - 2030:21
2122:16, 2127:1, 2127:5, 2142:9,
right-hand [1] - 2073:12
reported [3] - 2095:1, 2107:3, 2222:6
2145:20, 2243:25
rights [6] - 2096:21, 2097:4, 2217:15,
Reporter [2] - 1972:10, 1972:17
respect [7] - 2011:25, 2019:18,
2225:21, 2247:8
reporter [1] - 2099:12
2026:20, 2026:22, 2071:22, 2234:4,
rise [4] - 2019:14, 2019:16, 2019:18,
2234:8
REPORTER'S [1] - 2257:8
2176:17
respectfully [2] - 2053:20, 2112:22
reporting [11] - 2015:24, 2028:14,
risk [13] - 2113:14, 2113:22, 2126:4,
Respective [1] - 2031:1
2032:24, 2088:22, 2106:25, 2158:11,
2126:5, 2126:10, 2126:13, 2126:17,
2158:14, 2221:15, 2222:2, 2222:16,
respond [4] - 2070:9, 2128:22,
2126:18, 2163:19, 2163:20, 2163:24,
2238:13
2128:24, 2189:22
2237:18, 2251:17
Reporting [1] - 2239:20
responding [1] - 2060:5
river [1] - 2119:5
reports [23] - 2012:10, 2027:6, 2027:8,
response [16] - 1982:8, 1987:22,
RMR [3] - 1972:10, 1972:18, 2257:14
2027:10, 2027:11, 2033:4, 2033:7,
2037:1, 2040:10, 2057:16, 2057:17,
roads [1] - 2164:20
2033:20, 2034:14, 2035:2, 2074:11,
2058:5, 2058:14, 2059:2, 2078:21,
robe [4] - 2000:2, 2039:9, 2039:16,
2109:17, 2159:17, 2174:25, 2177:12,
2078:23, 2079:7, 2089:2, 2110:4,
2039:21
2185:24, 2187:11, 2187:12, 2221:11,
2116:24, 2116:25
Robert [6] - 1971:21, 2046:7, 2047:3,
2222:18, 2239:5, 2241:25, 2251:16
Responsibilities [1] - 2031:2
2157:13, 2157:17, 2169:12
represent [4] - 1980:2, 1980:14,
responsibility [2] - 2031:5, 2079:4
ROBERT [1] - 1971:6
1992:7, 2252:11
responsible [6] - 2031:4, 2101:18,
Roberts [2] - 2039:19
representation [1] - 2119:10
2133:19, 2176:9, 2199:1, 2199:4
Roche [1] - 2014:11
representations [1] - 2252:12
rest [4] - 2059:20, 2122:1, 2131:18,
Rock [1] - 2122:7
representative [1] - 2119:10
2247:20
Roe [4] - 2000:24, 2001:2, 2001:3,
representing [2] - 1981:20, 2032:14
restated [1] - 2071:1
2001:7
reputation [2] - 2026:18, 2026:19
restaurant [7] - 2081:21, 2236:10,
roll [1] - 2062:22
request [14] - 1975:18, 1996:16,
2236:11, 2236:13, 2236:14, 2236:19,
rolled [1] - 2069:22
1997:10, 1997:18, 1998:6, 2046:4,
2249:18
roommates [1] - 2131:9
2047:5, 2047:7, 2049:10, 2049:12,
Restaurant [3] - 2137:1, 2211:13,
Ross [1] - 2220:23
2091:20, 2091:21, 2092:3, 2092:20
2211:16
round [2] - 2240:25, 2241:1
request/application [1] - 2059:5
result [5] - 1985:8, 2013:20, 2015:16,
RPR [2] - 1972:10, 1972:18
requested [9] - 1996:19, 1997:14,
2028:11, 2095:11
rule [3] - 2051:17, 2078:22, 2079:12
2034:2, 2043:25, 2053:16, 2080:24,
resulted [2] - 2011:1, 2064:10
rules [4] - 2017:3, 2222:8, 2223:18
2084:8, 2091:13, 2091:15
results [2] - 2014:23, 2032:21
ruling [4] - 1980:12, 2083:20, 2098:19,
Requested [2] - 1977:1, 2076:23
resume [3] - 2035:6, 2155:10, 2257:5
2147:25
requesting [3] - 2046:6, 2103:3,
resum [2] - 2103:7, 2103:8
run [8] - 2082:18, 2120:20, 2214:13,
2161:6
retired [1] - 2100:12
2214:15, 2215:19, 2233:12, 2249:8
requests [2] - 2042:5, 2047:19
return [5] - 2183:24, 2184:2, 2184:5,
running [9] - 1983:11, 2015:15,
require [5] - 2049:6, 2066:10,
2206:12,
2184:20, 2185:17
Johnny
C. Sanchez,
RMR, CRR - jcscourtreporter@aol.com
2286
2019:10, 2042:6, 2043:24, 2083:22,
2083:24, 2211:6, 2233:24
Rusk [2] - 1972:11, 1972:18
Russian [1] - 2014:19
Ryan [1] - 2220:24
2034:22
2149:12, 2151:19, 2151:24, 2155:10,
2156:24, 2157:6, 2157:12, 2173:1,
School [1] - 2100:3
2177:19, 2181:6, 2195:12, 2207:22,
school [2] - 2102:7, 2102:8
2208:10, 2208:16, 2219:19, 2229:12,
schools [1] - 2100:2
2230:5, 2235:11, 2250:21, 2257:2,
Schramm [2] - 2216:3, 2216:8
2257:5
scope [5] - 2035:22, 2036:22, 2088:13,
seek [5] - 2001:14, 2054:24, 2103:19,
2240:19, 2251:22
S
2162:12, 2162:15
screen [7] - 1980:21, 2004:1, 2035:5,
seeking [1] - 1994:25
2079:19, 2156:21, 2159:11, 2257:3
safe [1] - 2185:4
seem [3] - 2131:20, 2131:25, 2215:23
scroll [2] - 2059:19, 2059:23
salary [4] - 2168:10, 2169:21, 2169:25,
Seidman [1] - 2009:5
scrolling [1] - 2059:22
2170:2
seized [1] - 1998:20
scrub [2] - 2013:22, 2014:19
sale [8] - 2134:11, 2135:12, 2171:15,
selected [1] - 2162:24
seal [1] - 2207:20
2171:16, 2171:18, 2187:3, 2187:12
sell [12] - 2103:20, 2120:20, 2125:22,
seat [2] - 2035:11, 2099:3
sales [1] - 2207:1
2126:2, 2133:25, 2134:8, 2166:5,
seated [3] - 1975:2, 1985:2, 2155:13
salespeople [2] - 2108:2, 2108:3
2251:13, 2253:21, 2253:22, 2254:11,
second [33] - 1989:15, 1996:1, 2011:1,
San [3] - 2102:3, 2102:4, 2134:20
2256:17
2013:5, 2021:8, 2026:4, 2035:25,
Sanchez [4] - 1972:10, 1972:18,
selling [5] - 2108:4, 2108:25, 2115:22,
2037:7, 2038:8, 2038:17, 2040:8,
2257:10, 2257:14
2116:11, 2246:16
2051:17, 2052:25, 2058:23, 2067:14,
Sandra [1] - 2014:10
sells [3] - 1982:2, 2256:4, 2256:8
2076:19, 2079:19, 2114:5, 2121:13,
sat [1] - 2167:3
semiretired [1] - 2099:21
2121:20, 2122:2, 2123:23, 2124:13,
Saturday [1] - 2103:14
sending [3] - 2015:21, 2167:4
2149:23, 2150:5, 2153:16, 2153:25,
save [1] - 2156:11
senior [1] - 2043:16
2154:10, 2163:22, 2181:6, 2182:18,
savings [1] - 2102:1
2182:21, 2201:25
sense [4] - 2144:12, 2235:4, 2235:5,
saw [21] - 1987:18, 1988:13, 2011:6,
2243:6
seconds [2] - 1983:9, 1983:10
2108:16, 2108:20, 2125:20, 2131:15,
sent [9] - 2013:9, 2013:13, 2042:24,
secrecy [3] - 1975:12, 2016:14,
2131:16, 2142:1, 2144:20, 2156:19,
2062:14, 2065:5, 2103:8, 2130:1,
2072:22
2158:3, 2196:25, 2197:2, 2205:5,
2166:21, 2167:19
secretary [1] - 2000:11
2211:3, 2234:11, 2239:5, 2239:10,
sentence [5] - 2058:23, 2087:19,
Section [16] - 2046:8, 2050:23,
2239:16, 2241:10
2087:24, 2091:15, 2230:7
2050:24, 2051:2, 2051:4, 2051:11,
Scardino [16] - 1971:21, 1971:21,
separate [13] - 2104:19, 2104:20,
2052:14, 2058:8, 2062:19, 2065:17,
2072:7, 2113:5, 2169:12, 2233:19,
2107:18, 2119:24, 2120:22, 2137:13,
2065:20, 2066:5, 2089:3, 2089:19,
2234:13, 2235:11, 2236:2, 2237:21,
2137:19, 2162:1, 2162:4, 2165:12,
2091:3, 2091:25
2238:5, 2239:18, 2242:8, 2243:11,
2210:17, 2210:18, 2225:2
section [7] - 2030:9, 2050:16,
2252:24, 2254:13
separately [4] - 2121:10, 2121:22,
2051:11, 2059:7, 2086:19, 2089:22,
SCARDINO [86] - 2027:20, 2105:17,
2122:11, 2123:12
2092:11
2105:25, 2110:2, 2110:11, 2110:22,
September [3] - 2043:10, 2043:12,
Sections [1] - 2090:4
2111:11, 2112:5, 2112:22, 2113:3,
2056:24
sections [6] - 1987:20, 1994:8,
2113:18, 2114:13, 2116:1, 2116:14,
series [3] - 2020:22, 2064:8, 2075:21
2003:21, 2090:15, 2090:18, 2090:22
2117:22, 2121:4, 2123:18, 2124:4,
serves [1] - 2025:1
sector [12] - 2005:4, 2006:8, 2006:13,
2125:5, 2128:10, 2134:23, 2142:25,
Service [6] - 2016:4, 2225:13,
2006:14, 2011:7, 2011:8, 2011:13,
2145:9, 2145:12, 2146:19, 2147:11,
2042:1, 2065:11, 2065:12, 2068:10,
2225:16, 2225:24, 2226:1, 2226:9
2147:15, 2150:5, 2150:7, 2150:9,
2069:25
service [1] - 2006:23
2152:9, 2152:18, 2153:18, 2161:9,
Sector [3] - 2005:20, 2006:2, 2007:9
services [11] - 1976:15, 2004:19,
2169:9, 2173:24, 2174:1, 2175:23,
Sectoral [3] - 2010:9, 2010:22,
2005:3, 2006:20, 2006:21, 2041:20,
2176:2, 2180:17, 2180:22, 2180:23,
2068:25
2132:13, 2132:20, 2203:21, 2203:24,
2181:5, 2184:13, 2184:17, 2197:10,
2220:16
sectoral [3] - 2069:2, 2069:3, 2069:13
2200:12, 2203:13, 2207:4, 2207:17,
Services [11] - 2023:11, 2068:25,
sectors [1] - 2042:1
2207:21, 2208:6, 2208:9, 2208:13,
2102:15, 2106:17, 2107:15, 2107:23,
securities [6] - 2247:14, 2247:18,
2208:15, 2227:1, 2227:4, 2227:17,
2114:12, 2123:3, 2133:5, 2133:6,
2253:9, 2254:7, 2255:6, 2255:9
2227:20, 2227:22, 2228:3, 2228:20,
2188:5
security [3] - 1981:21, 1982:16,
2229:22, 2230:1, 2230:4, 2231:11,
set [13] - 2013:3, 2033:17, 2040:14,
1987:3
2231:18, 2232:4, 2232:6, 2233:15,
2060:1, 2063:25, 2088:21, 2120:22,
see [65] - 1976:1, 1981:1, 1989:2,
2239:25, 2240:19, 2244:2, 2244:4,
2121:14, 2121:20, 2122:18, 2122:23,
1990:3, 1990:8, 1990:10, 1990:12,
2245:23, 2246:1, 2247:11, 2247:16,
2140:22, 2151:23
1999:23, 2001:9, 2003:3, 2004:1,
2251:5, 2251:21, 2254:2, 2254:4,
sets [5] - 2042:17, 2082:10, 2082:12,
2006:12, 2017:25, 2020:23, 2028:17,
2254:23, 2255:1, 2255:4, 2256:21
2082:13
2030:11, 2035:6, 2035:7, 2044:3,
Scardino's [1] - 2111:8
seven [2] - 2171:19, 2171:20
2055:18, 2057:6, 2057:14, 2063:12,
SCARDINO........... [2] - 1973:23,
several [5] - 2064:18, 2071:12,
2073:17, 2073:21, 2073:22, 2079:11,
1974:2
2079:19, 2089:12, 2093:17, 2093:19,
2197:17, 2209:9, 2232:2
SCARDINO............. [1] - 1973:19
2096:22, 2096:24, 2097:1, 2103:21,
sewn [1] - 2039:10
scenes [1] - 2039:11
2110:14, 2117:12, 2120:3, 2127:6,
shade [3] - 2141:16, 2141:18, 2141:20
schedule [3] - 1979:2, 1979:10,
2147:5,
2148:6,
2148:21,
2149:3,
shading [1] - 2141:23
2287
shall [1] - 2046:14
shape [1] - 2211:1
share [1] - 2055:5
shared [1] - 1976:2
shareholder [8] - 2192:11, 2222:18,
2222:24, 2223:2, 2228:10, 2242:6,
2249:4, 2254:19
shareholders [1] - 2222:6
shares [3] - 2046:16, 2253:21, 2253:22
sharing [1] - 2055:1
shift [1] - 2221:9
shocked [2] - 2180:2, 2180:4
short [4] - 1999:25, 2007:12, 2038:25,
2039:23
shorter [1] - 2217:6
shortly [1] - 2108:12
shot [1] - 2139:9
show [29] - 1988:4, 1988:24, 1990:22,
2000:24, 2017:7, 2020:21, 2023:7,
2027:16, 2030:8, 2045:5, 2049:25,
2055:11, 2055:16, 2056:11, 2066:21,
2087:9, 2106:3, 2111:9, 2114:14,
2140:16, 2142:10, 2149:21, 2152:15,
2153:13, 2180:24, 2194:15, 2229:7,
2229:18, 2239:12
showed [18] - 1990:23, 2003:13,
2039:9, 2065:17, 2067:13, 2080:13,
2086:17, 2154:13, 2221:10, 2223:1,
2223:2, 2228:7, 2228:8, 2228:10,
2228:11, 2228:23, 2229:9, 2249:8
showing [6] - 1979:25, 2127:7,
2139:11, 2149:12, 2196:5, 2252:24
shown [12] - 1980:8, 1986:14,
1986:16, 1987:19, 1988:5, 1988:19,
2003:14, 2074:11, 2088:16, 2196:3,
2228:23, 2229:6
shows [3] - 2139:13, 2139:14, 2149:2
shut [2] - 2004:22, 2102:2
SIB [2] - 2026:5, 2058:18
SIBL [15] - 1981:5, 1981:12, 1982:2,
1982:9, 1985:8, 2003:8, 2015:12,
2016:2, 2020:18, 2025:2, 2027:11,
2033:4, 2033:18, 2042:22, 2085:10
sic [2] - 1981:21, 2134:25
side [10] - 1984:14, 1984:18, 2016:1,
2058:2, 2073:12, 2073:13, 2079:1,
2114:5, 2126:1
side-by-side [1] - 2058:2
sidebar [1] - 2076:1
sides [1] - 2240:24
signature [13] - 2027:23, 2029:21,
2029:24, 2030:1, 2030:22, 2032:11,
2044:8, 2149:22, 2149:25, 2156:1,
2156:3, 2156:6
signed [9] - 1994:4, 2002:4, 2027:7,
2027:14, 2027:15, 2033:1, 2057:13,
2150:12, 2150:18
significant [2] - 1989:15, 2031:15
signing [1] - 2160:1
similar [1] - 2154:12
simple [1] - 1996:13
simply [2] - 1985:11, 2078:14
single [2] - 1977:18, 2027:8

sound [1] - 1993:18
sit [3] - 1991:11, 2128:13, 2166:18
sounds [3] - 2000:12, 2007:7, 2014:16
site [1] - 2033:11
source [1] - 2142:7
sits [1] - 1983:4
sources [1] - 2127:7
sitting [2] - 1984:5, 1984:12
South [5] - 2004:13, 2020:6, 2213:18,
2231:24, 2232:2
situation [2] - 2082:20, 2083:7
SOUTHERN [1] - 1971:1
six [1] - 2099:17
southwest [3] - 2121:2, 2121:19,
sixteen [1] - 2169:16
2122:9
sixth [1] - 2021:16
Southwest [2] - 2186:18, 2186:19
skill [1] - 2042:16
space [1] - 2233:3
skip [3] - 1991:6, 2002:19, 2002:23
speaking [12] - 1975:21, 1975:22,
Slate [21] - 2010:6, 2012:7, 2013:19,
1996:3, 1996:13, 2000:14, 2000:18,
2013:22, 2013:25, 2014:3, 2014:8,
2001:1, 2023:2, 2055:21, 2055:24,
2014:15, 2014:18, 2014:22, 2015:5,
2206:20, 2228:7
2015:11, 2015:16, 2069:21, 2069:22,
speaks [2] - 2058:21, 2163:21
2069:24, 2070:2, 2070:8, 2070:13,
specialize [1] - 1979:17
2070:22, 2072:3
Slater [3] - 2107:2, 2109:14, 2181:11
specific [11] - 2166:24, 2170:14,
2183:9, 2183:10, 2183:12, 2184:7,
sleeves [1] - 2039:10
2184:24, 2197:17, 2203:16, 2226:2,
slide [7] - 2058:6, 2059:16, 2059:17,
2247:1
2059:18, 2059:19, 2059:20
specifically [11] - 1976:9, 2042:22,
slides [1] - 2059:15
2047:1, 2056:7, 2115:10, 2115:12,
slight [1] - 2084:2
2172:4, 2183:23, 2199:8, 2203:24,
slow [4] - 2046:11, 2173:23, 2175:22
2210:25
small [10] - 2107:20, 2107:24, 2109:6,
specification [1] - 2059:7
2121:2, 2135:11, 2141:2, 2160:16,
specifications [2] - 2201:2, 2201:4
2164:9, 2186:14, 2192:21
specifics [2] - 1981:6, 2013:18
smart [3] - 2173:2, 2173:5, 2191:6
specified [1] - 2239:6
smell [1] - 2205:8
specify [1] - 2107:9
SO [1] - 2121:5
speculation [1] - 2200:9
Society [1] - 2168:8
speculative [3] - 2163:8, 2163:12,
sold [7] - 2125:19, 2233:6, 2233:8,
2165:24
2233:9, 2242:18, 2244:13
speech [3] - 2142:16, 2143:9, 2144:17
sole [2] - 2242:6, 2254:19
speed [1] - 2062:22
solicitor [1] - 2095:4
spell [3] - 2099:12, 2121:4, 2134:23
someone [7] - 1985:11, 2045:11,
spend [5] - 2120:19, 2136:8, 2183:1,
2086:11, 2104:7, 2130:23, 2196:16,
2219:20, 2250:5
2241:24
spending [1] - 2136:5
sometime [4] - 2040:9, 2042:21,
spent [8] - 2160:22, 2160:23, 2167:10,
2043:10, 2198:14
2168:20, 2211:24, 2220:6, 2243:18,
sometimes [7] - 2203:6, 2223:7,
2243:20
2245:12, 2245:18, 2248:11, 2249:25,
sport [4] - 2213:13, 2213:14, 2214:11,
2250:4
2217:2
somewhat [3] - 2012:18, 2183:3,
sports [9] - 2213:12, 2214:21,
2221:18
2215:24, 2216:5, 2216:6, 2216:7,
somewhere [4] - 2026:17, 2093:21,
2216:13, 2217:14, 2250:24
2229:22, 2251:24
spot [1] - 2214:16
soon [4] - 2053:17, 2097:3, 2099:18,
spread [1] - 2162:11
2099:19
spreads [1] - 2164:2
sorry [31] - 1978:22, 1981:12, 1989:12,
1992:20, 1999:3, 2004:1, 2004:7,
spring [2] - 2016:2, 2040:6
2029:7, 2061:19, 2067:10, 2069:4,
Springs [4] - 2122:7, 2135:12,
2069:14, 2070:10, 2073:13, 2077:23,
2197:19, 2242:21
2080:8, 2084:10, 2127:20, 2127:24,
Square [1] - 2121:17
2128:3, 2128:17, 2148:13, 2157:4,
St [2] - 2063:21, 2168:8
2173:24, 2175:23, 2178:9, 2227:15,
stable [2] - 2187:4, 2187:6
2230:19, 2240:3, 2246:23, 2254:2
stacked [1] - 2097:2
sort [5] - 2078:15, 2164:1, 2164:5,
staff [6] - 2041:19, 2042:11, 2042:13,
2182:1, 2206:17
2042:15, 2042:16
sorts [1] - 2096:23
staffing [1] - 2163:17
sought [1] - 2095:8
stage [1] - 2162:22
soul [1] - 2019:19
stand [1] - 2196:13
2288
2147:8, 2148:11, 2148:15, 2148:17,
2160:8
standard [7] - 2140:21, 2140:23,
2149:17, 2149:18, 2150:1, 2150:18,
statement [21] - 1981:8, 1981:16,
2150:15, 2239:13, 2239:22, 2241:17,
2151:14, 2151:20, 2152:4, 2152:11,
2249:9
1981:24, 1982:4, 1982:12, 1982:18,
2153:1, 2154:25, 2156:7, 2156:23,
1995:20, 2030:23, 2047:11, 2047:14,
standards [19] - 2028:14, 2031:12,
2157:6, 2157:13, 2157:17, 2158:8,
2074:1, 2087:5, 2087:7, 2089:24,
2032:24, 2125:10, 2158:11, 2158:14,
2158:9, 2158:10, 2159:22, 2160:11,
2091:8, 2091:10, 2092:22, 2105:18,
2222:22, 2230:9, 2230:15, 2230:18,
2160:14, 2160:23, 2161:4, 2161:12,
2105:21, 2150:19, 2256:18
2238:6, 2238:12, 2238:13, 2238:22,
2161:23, 2161:25, 2162:4, 2162:9,
statements [25] - 2028:9, 2028:12,
2240:22, 2241:19, 2249:6, 2249:7
2164:25, 2165:11, 2166:11, 2166:14,
2030:24, 2031:5, 2031:6, 2031:14,
Standards [1] - 2239:21
2166:18, 2167:3, 2167:20, 2168:14,
2031:17, 2031:25, 2032:7, 2032:12,
standing [20] - 1984:11, 1984:14,
2168:20, 2168:23, 2169:5, 2169:6,
2032:13, 2032:19, 2033:10, 2074:13,
1984:18, 1994:25, 1995:2, 1995:6,
2169:15, 2169:18, 2169:24, 2170:2,
2074:17, 2101:20, 2133:14, 2160:9,
1995:19, 1996:10, 1996:12, 1998:7,
2170:8, 2171:6, 2171:14, 2172:7,
2174:11, 2199:5, 2211:4, 2222:7,
2036:6, 2043:25, 2046:4, 2046:22,
2174:15, 2174:20, 2174:22, 2175:4,
2228:8, 2229:4, 2238:17
2053:19, 2054:16, 2054:19, 2054:21,
2176:8, 2176:13, 2179:13, 2180:9,
STATES [3] - 1971:1, 1971:4, 1971:10
2103:25, 2195:4
2181:8, 2183:22, 2184:19, 2185:4,
states [2] - 2046:13, 2054:21
Stanford [339] - 1976:12, 1976:13,
2185:14, 2186:2, 2187:8, 2187:16,
States [11] - 1986:22, 2011:10, 2013:9,
1976:16, 1977:17, 1978:16, 1978:22,
2187:22, 2188:11, 2188:22, 2189:19,
1979:13, 1979:20, 1980:3, 1980:15,
2013:12, 2016:3, 2026:4, 2081:25,
2190:15, 2191:6, 2191:14, 2191:22,
1984:22, 1988:21, 1990:8, 1990:9,
2098:24, 2136:4, 2221:21, 2222:1
2192:9, 2194:12, 2195:11, 2195:16,
1992:15, 1992:19, 1992:23, 1993:6,
stating [1] - 2053:6
2198:15, 2199:18, 2200:14, 2201:15,
1993:7, 1993:12, 1993:14, 1994:10,
status [2] - 2100:11, 2100:12
2202:18, 2202:19, 2202:21, 2203:1,
1994:12, 1994:14, 1995:8, 1995:12,
statute [4] - 1976:22, 2049:5, 2065:10
2204:24, 2205:15, 2206:2, 2208:24,
1997:13, 1997:18, 1998:6, 1998:10,
statutes [2] - 2052:14, 2065:8
2209:8, 2209:17, 2210:7, 2210:11,
1999:3, 2000:9, 2000:17, 2000:19,
statutory [4] - 2046:9, 2046:22,
2210:15, 2210:16, 2210:19, 2211:12,
2000:23, 2001:2, 2002:14, 2007:22,
2048:5, 2050:6
2211:25, 2214:21, 2216:11, 2218:10,
2008:6, 2015:8, 2015:9, 2016:10,
stay [3] - 2102:11, 2141:11, 2218:3
2219:4, 2221:12, 2222:6, 2222:17,
2020:17, 2023:11, 2024:3, 2025:2,
stayed [1] - 2185:11
2222:24, 2225:14, 2227:7, 2227:12,
2025:3, 2043:5, 2043:23, 2046:1,
Stellmach [1] - 1971:16
2228:6, 2229:4, 2229:20, 2230:21,
2046:20, 2054:2, 2054:5, 2056:18,
stenography [2] - 1972:13, 1972:20
2231:14, 2232:16, 2232:24, 2233:11,
2057:3, 2057:8, 2063:19, 2063:20,
step [3] - 2098:16, 2190:4, 2256:24
2233:23, 2234:7, 2234:17, 2234:20,
2064:3, 2065:2, 2068:21, 2069:5,
Stevens [1] - 2039:3
2234:24, 2235:7, 2236:12, 2237:8,
2069:9, 2069:16, 2069:23, 2071:19,
stick [4] - 2011:19, 2012:9, 2082:5,
2237:9, 2238:1, 2238:11, 2238:16,
2072:17, 2072:18, 2074:5, 2075:9,
2098:18
2241:10, 2242:6, 2243:5, 2243:22,
2075:18, 2076:6, 2076:14, 2077:3,
sticker [2] - 2045:15, 2158:24
2246:16, 2246:25, 2251:9, 2251:18,
2081:22, 2086:11, 2086:17, 2087:10,
sticks [2] - 2082:1, 2082:3
2252:3, 2253:15, 2254:14
2088:21, 2093:2, 2093:10, 2093:17,
Sticky [19] - 2081:18, 2081:20,
STANFORD [1] - 1971:6
2093:21, 2093:24, 2094:12, 2094:15,
2081:21, 2081:23, 2082:4, 2083:12,
Stanford's [35] - 1997:19, 1998:3,
2095:20, 2097:17, 2102:20, 2103:12,
2084:10, 2084:25, 2085:12, 2085:13,
2023:6, 2024:4, 2068:16, 2072:14,
2103:16, 2103:21, 2104:4, 2104:6,
2137:1, 2139:13, 2211:12, 2213:5,
2075:2, 2105:11, 2106:3, 2107:5,
2104:23, 2105:9, 2105:15, 2105:21,
2213:8, 2214:22, 2215:13, 2243:3,
2108:15, 2121:9, 2131:7, 2131:11,
2106:8, 2106:10, 2106:21, 2107:3,
2249:14
2131:13, 2132:6, 2132:9, 2138:23,
2107:6, 2107:7, 2107:11, 2109:10,
sticky [5] - 2082:8, 2082:19, 2083:7,
2146:17, 2160:18, 2161:16, 2166:7,
2109:15, 2109:19, 2109:24, 2110:7,
2084:11, 2214:16
2167:15, 2196:17, 2202:20, 2204:25,
2110:9, 2110:18, 2111:3, 2112:14,
still [27] - 2015:5, 2015:7, 2015:12,
2209:18, 2215:24, 2229:7, 2231:23,
2112:18, 2113:10, 2114:25, 2115:8,
2024:5, 2062:4, 2071:4, 2090:10,
2232:14, 2232:21, 2232:24, 2249:7
2115:13, 2115:18, 2115:22, 2116:12,
2090:16, 2099:21, 2101:4, 2112:25,
Star [2] - 2138:3, 2146:10
2116:20, 2117:1, 2117:16, 2117:20,
2123:11, 2124:9, 2134:7, 2153:15,
start [15] - 2029:6, 2040:14, 2041:18,
2118:1, 2119:1, 2119:8, 2119:18,
2155:2, 2157:20, 2168:25, 2172:22,
2045:25, 2046:3, 2056:12, 2077:15,
2120:2, 2121:21, 2122:1, 2122:10,
2197:11, 2211:6, 2211:9, 2211:10,
2084:19, 2102:10, 2146:1, 2146:8,
2122:15, 2123:11, 2124:8, 2126:21,
2221:4, 2249:6, 2251:2
2224:14, 2249:22, 2249:25, 2250:4
2127:3, 2127:9, 2128:6, 2128:19,
stock [2] - 2246:7, 2246:10
started [33] - 2010:25, 2015:19,
2129:3, 2129:13, 2129:15, 2129:22,
stockbroker [1] - 2253:21
2130:5, 2130:19, 2132:14, 2132:19,
2015:21, 2037:23, 2042:19, 2054:24,
stocks [4] - 2111:7, 2126:19, 2239:5,
2133:1, 2133:12, 2134:19, 2135:2,
2060:7, 2100:15, 2101:15, 2107:14,
2245:10
2135:14, 2135:20, 2135:21, 2135:23,
2123:4, 2124:1, 2124:8, 2127:3,
stole [1] - 2083:1
2136:3, 2136:17, 2137:3, 2137:10,
2129:13, 2130:5, 2132:25, 2133:4,
stop [13] - 1981:7, 1981:15, 1982:11,
2137:12, 2137:13, 2137:15, 2137:16,
2133:13, 2133:20, 2135:1, 2138:1,
1987:13, 1993:18, 1995:25, 2046:18,
2137:23, 2137:24, 2138:4, 2139:3,
2139:20, 2140:9, 2141:11, 2170:2,
2047:17, 2127:12, 2143:19, 2193:2,
2139:14, 2139:25, 2140:3, 2140:13,
2181:12, 2190:6, 2193:11, 2201:24,
2202:19
2140:18, 2141:7, 2141:11, 2141:15,
2228:2, 2228:14, 2249:19
stopped [1] - 2038:24
2142:7, 2142:8, 2142:11, 2142:13,
starting [2] - 2063:17, 2209:3
stopping [2] - 2077:12, 2155:6
2142:18, 2144:1, 2144:7, 2144:16,
State [1] - 2055:4
store [1] - 1999:21
2144:25, 2145:24, 2146:1, 2146:22,
state [4] - 1976:24, 2028:10, 2032:20,
story [4] - 2038:25, 2039:7, 2039:22,
2289
2135:3
surrender [2] - 1998:18, 2067:23
testified [13] - 1988:14, 1992:24,
strange [1] - 2014:16
1994:14, 1998:11, 2042:23, 2064:23,
surrendered [3] - 2068:3, 2087:12,
2068:21, 2069:9, 2099:5, 2184:4,
strategy [2] - 2165:19, 2165:22
2098:7
2184:8, 2184:11, 2228:4
Street [2] - 1971:22, 2103:1
surrounding [1] - 2164:17
testify [3] - 1984:23, 2177:16, 2228:21
streets [1] - 2187:11
suspect [1] - 2203:23
testimony [9] - 2034:12, 2034:16,
strengthen [2] - 2007:19, 2011:8
suspicion [1] - 2146:17
2035:21, 2038:15, 2052:14, 2078:11,
strictly [3] - 2137:23, 2217:20,
sustain [3] - 2070:25, 2076:25, 2106:5
2084:8, 2113:6, 2168:18
2219:16
sustained [13] - 2038:16, 2052:8,
tests [1] - 2160:7
strip [2] - 2023:12, 2023:13
2072:9, 2075:16, 2081:1, 2088:14,
Tex [1] - 2216:3
2116:2, 2116:15, 2146:20, 2147:17,
stripes [2] - 2039:10, 2039:16
TEXAS [1] - 1971:1
2180:16, 2200:11, 2251:24
strong [1] - 2214:8
Texas [19] - 1971:4, 1971:15, 1971:23,
swearing [1] - 2096:17
structure [1] - 2219:10
1972:4, 1972:7, 1972:11, 1972:19,
swimming [1] - 2136:20
structures [1] - 2217:12
2055:4, 2055:5, 2101:25, 2102:2,
Swiss [3] - 2075:2, 2075:11, 2115:17
studies [1] - 2250:15
2105:2, 2120:10, 2171:19, 2178:7,
switch [5] - 2027:20, 2062:7, 2067:9,
stuff [1] - 2125:11
2186:7, 2190:10, 2190:23, 2201:16
2073:7, 2252:17
stumps [1] - 2082:12
THE [308] - 1971:10, 1971:13, 1971:20,
Switzerland [8] - 2115:16, 2118:7,
stupid [2] - 2225:5, 2245:18
1972:2, 1975:2, 1976:20, 1976:24,
2118:16, 2230:22, 2231:22, 2231:24,
style [5] - 2132:10, 2180:10, 2181:9,
1977:2, 1977:5, 1977:8, 1977:9,
2232:1, 2232:3
2183:3, 2194:1
1977:11, 1977:12, 1980:4, 1980:9,
sworn [2] - 2099:2, 2099:5
subdivision [2] - 2135:11, 2197:23
1983:1, 1983:3, 1983:6, 1983:10,
Sydney [2] - 2108:8, 2108:11
subject [9] - 1980:12, 2018:20,
1983:24, 1984:2, 1985:20, 1985:22,
system
[3]
2037:21,
2040:22,
2028:21, 2056:6, 2083:25, 2163:14,
1985:25, 1986:2, 1986:4, 1987:8,
2221:15
2239:22
1987:11, 1989:7, 1989:9, 1989:12,
submit [3] - 1978:9, 2053:16, 2103:7
1989:17, 1989:20, 1989:23, 1991:15,
submits [1] - 1979:22
T
1991:19, 1991:21, 1991:22, 1991:23,
submitted [5] - 2028:23, 2046:8,
1991:24, 1991:25, 1992:1, 1996:24,
2053:12, 2053:13, 2092:19
table [2] - 2080:8, 2080:10
1997:1, 1997:2, 1997:22, 1999:6,
Subparagraph [1] - 2066:4
Takara [1] - 2121:3
1999:9, 1999:12, 1999:15, 1999:20,
Subsection [6] - 2091:5, 2091:7,
TAKARA [1] - 2121:5
2017:11, 2017:16, 2017:19, 2020:14,
2091:10, 2091:11, 2091:12, 2091:25
tape [3] - 2143:18, 2144:5, 2144:14
2022:14, 2022:17, 2022:19, 2022:23,
subsection [2] - 2050:9, 2089:5
target [1] - 2120:2
2027:21, 2034:20, 2035:4, 2035:9,
subsections [2] - 2051:7, 2091:17
2035:25, 2036:3, 2036:9, 2036:13,
targeting [1] - 2120:17
subsequent [1] - 2043:11
2036:16, 2036:23, 2037:1, 2037:5,
task [4] - 2012:3, 2013:24, 2041:1,
subsequently [1] - 2065:3
2037:9, 2037:15, 2037:18, 2037:22,
2042:13
subsidiaries [1] - 2101:11
2037:24, 2038:3, 2038:16, 2038:22,
tasks [3] - 2040:12, 2040:17, 2040:21
success [1] - 2019:15
2038:24, 2044:14, 2044:19, 2044:21,
tax [5] - 2088:5, 2088:7, 2088:11,
successful [16] - 2015:14, 2121:9,
2045:6, 2045:15, 2045:20, 2046:11,
2088:22, 2226:23
2121:21, 2122:10, 2171:23, 2171:24,
2049:20, 2051:17, 2051:21, 2052:1,
taxable [1] - 2223:11
2171:25, 2185:12, 2191:3, 2191:5,
2052:8, 2054:11, 2056:5, 2059:21,
taxes [2] - 2225:7, 2226:5
2203:17, 2224:15, 2246:5, 2250:19,
2061:13, 2061:17, 2061:19, 2061:20,
team [17] - 2010:6, 2010:25, 2012:6,
2250:25
2061:22, 2061:23, 2062:8, 2062:10,
2012:7, 2014:3, 2014:5, 2019:9,
sufficient [1] - 2031:24
2063:6, 2066:1, 2067:6, 2070:4,
2019:10, 2019:15, 2020:12, 2043:17,
suggested [1] - 2074:3
2070:9, 2070:12, 2070:15, 2070:24,
2213:21, 2213:24, 2216:18, 2217:16
suing [2] - 1992:10, 2097:5
2071:9, 2071:11, 2071:14, 2071:15,
teams [2] - 2213:23, 2214:5
Suisse [1] - 1979:14
2072:9, 2073:9, 2075:6, 2075:7,
technically [2] - 2203:7, 2203:10
Sullivan [1] - 2039:14
2075:13, 2075:16, 2076:4, 2076:9,
technology [1] - 2220:9
sum [3] - 2063:23, 2151:21, 2244:10
2076:19, 2076:24, 2077:7, 2077:10,
television [1] - 2217:15
Sun [2] - 2138:3, 2146:10
2077:14, 2078:4, 2078:9, 2078:20,
tempting [1] - 2088:1
super [7] - 2165:6, 2165:14, 2166:1,
2079:2, 2079:11, 2079:15, 2079:23,
ten [4] - 2020:18, 2036:19, 2135:5,
2236:14, 2237:5, 2237:10, 2237:17
2080:7, 2080:10, 2080:22, 2080:25,
2241:7
supervise [1] - 2094:20
2081:11, 2081:12, 2081:23, 2082:4,
ten-dollar [1] - 2241:7
supervised [1] - 2094:16
2082:5, 2082:6, 2082:7, 2082:9,
tens [6] - 2212:2, 2215:12, 2216:13,
supervisor [5] - 2049:9, 2049:10,
2082:15, 2082:16, 2082:21, 2082:22,
2219:20, 2219:22, 2219:23
2049:12, 2094:3, 2095:13
2082:23, 2082:25, 2083:1, 2083:5,
tenure [1] - 2039:16
support [5] - 2038:15, 2041:22,
2083:15, 2083:16, 2083:24, 2084:6,
term [5] - 2088:9, 2120:15, 2140:21,
2132:20, 2146:23, 2162:19
2084:16, 2085:5, 2085:6, 2086:1,
2158:5, 2254:7
suppose [2] - 1986:24, 2089:1
2088:14, 2089:16, 2090:3, 2090:6,
terminology [5] - 2137:19, 2195:21,
supposed [3] - 2149:2, 2162:4,
2090:9, 2090:12, 2090:13, 2090:17,
2195:22, 2209:1, 2218:8
2090:22, 2091:1, 2092:11, 2096:6,
2191:18
terms [9] - 1996:22, 2013:17, 2041:2,
2096:11, 2096:13, 2097:9, 2097:22,
Supreme [2] - 2009:21, 2039:2
2063:25, 2103:4, 2108:15, 2128:6,
2097:25, 2098:13, 2098:15, 2098:21,
surprise [1] - 2035:20
2132:10, 2151:23
2098:22, 2098:25, 2100:23, 2100:25,
surprised [1] - 2180:1
test [1] - 2031:13
2290
2102:16, 2102:17, 2103:25, 2104:1,
tiny [1] - 2236:20
treatment [1] - 2210:8
2104:3, 2105:19, 2106:1, 2106:5,
tired [1] - 2176:21
treaty [1] - 1976:5
2110:4, 2110:13, 2110:24, 2110:25,
title [4] - 2030:21, 2100:9, 2123:8,
Trevor [2] - 2043:16, 2043:19
2112:11, 2112:19, 2113:2, 2113:20,
2199:24
trial [2] - 1992:23, 2153:24
2113:21, 2114:16, 2114:19, 2115:5,
titled [3] - 2050:23, 2050:24, 2050:25
TRIAL [1] - 1971:7
2116:2, 2116:7, 2116:15, 2117:24,
today [9] - 1997:7, 1997:8, 2014:12,
tried [4] - 1999:20, 1999:23, 2002:8,
2119:22, 2121:5, 2123:20, 2124:5,
2034:12, 2034:16, 2103:21, 2207:10,
2140:7
2124:6, 2124:15, 2124:18, 2124:22,
2229:6, 2257:4
Trinidad [1] - 2018:17
2125:13, 2127:18, 2127:20, 2127:22,
together [11] - 2003:22, 2008:10,
trip [2] - 2064:20, 2064:21
2127:24, 2127:25, 2128:1, 2128:12,
2019:20, 2059:14, 2063:24, 2151:22,
tripling [1] - 2169:25
2128:15, 2134:24, 2138:13, 2138:15,
2187:21, 2188:10, 2188:11, 2189:22,
true [25] - 2001:12, 2003:25, 2004:9,
2143:1, 2143:3, 2143:7, 2143:11,
2191:11
2005:18, 2007:8, 2009:25, 2011:10,
2143:13, 2143:16, 2144:4, 2145:11,
Tom [2] - 1985:4, 2008:23
2016:8, 2017:1, 2018:19, 2019:14,
2145:14, 2146:20, 2147:17, 2147:19,
tomorrow [1] - 2257:5
2025:8, 2025:9, 2028:10, 2032:20,
2147:22, 2148:3, 2148:6, 2150:6,
took [12] - 2040:10, 2072:7, 2094:5,
2040:20, 2050:5, 2054:23, 2057:16,
2150:8, 2150:13, 2150:20, 2151:6,
2094:9, 2168:13, 2170:4, 2178:6,
2095:21, 2095:22, 2196:17, 2233:22,
2152:13, 2152:23, 2153:15, 2153:17,
2178:7, 2187:16, 2210:19, 2210:24,
2234:4, 2253:23
2153:20, 2153:22, 2153:25, 2155:8,
2225:13
Trust [1] - 2211:12
2155:13, 2155:15, 2161:11, 2161:13,
top [17] - 1982:7, 1990:3, 2056:15,
trusts [1] - 2007:2
2161:14, 2166:24, 2167:1, 2173:23,
2058:3, 2058:9, 2058:11, 2061:24,
truth [6] - 2035:3, 2093:7, 2106:2,
2175:22, 2175:25, 2180:16, 2181:4,
2063:9, 2117:12, 2148:24, 2151:4,
2110:9, 2150:9, 2203:8
2184:10, 2184:14, 2184:16, 2197:7,
2152:1, 2154:21, 2159:12, 2207:19,
truthful [1] - 2252:13
2197:8, 2200:11, 2203:5, 2207:7,
2208:7, 2225:16
try [8] - 1984:1, 2000:1, 2030:4,
2207:9, 2207:16, 2227:3, 2227:16,
topic [2] - 2115:22, 2116:9
2045:4, 2059:17, 2096:19, 2168:2
2227:19, 2227:21, 2227:24, 2228:1,
total [4] - 2149:3, 2171:18, 2171:20,
trying [14] - 2011:14, 2029:18, 2042:2,
2228:13, 2228:18, 2229:25, 2231:10,
2190:11
2049:11, 2049:19, 2060:2, 2076:6,
2231:15, 2231:16, 2231:17, 2240:1,
totally [1] - 2109:21
2112:24, 2120:2, 2123:11, 2124:9,
2240:5, 2240:8, 2240:11, 2240:24,
tough [1] - 2189:14
2134:8, 2206:3
2245:24, 2251:24, 2252:19, 2252:21,
tour [1] - 2043:2
turn [18] - 1980:18, 1990:19, 2047:18,
2254:5, 2254:25, 2256:23, 2256:25,
tourists [1] - 2164:1
2049:6, 2067:3, 2073:18, 2077:5,
2257:1
tournament [1] - 2216:20
2077:15, 2080:5, 2081:14, 2081:17,
the.. [1] - 2251:4
2086:2, 2095:8, 2095:12, 2095:13,
towards [8] - 2085:1, 2105:6, 2111:21,
theme [1] - 2011:9
2111:17, 2148:23, 2159:3
2144:16, 2145:25, 2148:14, 2238:2,
thereafter [1] - 2108:12
turned [4] - 2012:10, 2057:21, 2216:8,
2238:5
thereby [1] - 2062:25
2250:18
townhomes [1] - 2134:20
therefore [3] - 1997:15, 1997:18,
TV [1] - 2079:17
tracked [2] - 2140:8, 2140:12
2087:11
twice [2] - 2127:11, 2177:3
traded [1] - 2125:22
they've [3] - 2035:19, 2125:9, 2248:10
two [50] - 1979:2, 1989:15, 1998:24,
traditionally [1] - 2244:13
thinking [3] - 2019:2, 2071:21,
1999:2, 2010:14, 2010:15, 2013:5,
train [1] - 2041:19
2165:14
2030:18, 2035:14, 2053:5, 2057:24,
trained [2] - 1991:13, 1991:18
third [10] - 2021:10, 2052:24, 2096:10,
2069:11, 2071:20, 2071:21, 2073:11,
transaction [9] - 2125:7, 2125:8,
2122:4, 2122:11, 2123:23, 2124:13,
2082:10, 2082:12, 2082:13, 2090:14,
2158:7, 2240:18, 2241:6, 2241:7,
2164:7, 2203:7, 2256:4
2090:18, 2090:22, 2096:9, 2101:11,
2241:8, 2256:5, 2256:13
thousand [1] - 2170:3
2106:22, 2117:6, 2123:6, 2125:24,
transactions [9] - 1976:10, 2158:15,
thousands [1] - 2037:24
2134:11, 2138:1, 2146:8, 2146:23,
2171:21, 2191:21, 2206:10, 2206:11,
three [24] - 1991:12, 2034:23, 2047:15,
2157:18, 2166:21, 2166:23, 2167:4,
2209:16, 2225:17, 2255:24
2071:24, 2071:25, 2082:12, 2085:20,
2167:20, 2171:7, 2172:19, 2173:19,
transcript [1] - 2257:11
2087:9, 2087:18, 2100:12, 2107:21,
2190:7, 2210:18, 2211:16, 2217:8,
Transcript [2] - 1972:13, 1972:20
2108:8, 2122:19, 2123:6, 2135:6,
2217:9, 2220:23, 2228:7, 2246:12,
transcription [2] - 1972:13, 1972:21
2171:15, 2171:16, 2171:18, 2179:3,
2252:24, 2255:2
transfer [4] - 2223:11, 2224:17,
2179:9, 2190:7, 2192:17, 2202:5,
two-month [1] - 2167:20
2226:3, 2226:9
2251:25
tying [1] - 2070:22
transferred [1] - 2225:4
three-quarters [1] - 2034:23
type [13] - 1982:20, 2112:3, 2120:7,
transferring [1] - 2225:15
throughout [4] - 2064:14, 2064:22,
2135:7,
2146:23, 2150:2, 2154:17,
Traurig [1] - 2009:7
2159:21, 2234:10
2158:5, 2165:8, 2165:17, 2203:24,
travel [4] - 2018:14, 2064:18, 2166:12,
ticket [2] - 2213:20, 2213:21
2213:12, 2244:20
2167:1
tie [1] - 1987:14
types [11] - 1975:19, 1975:20,
traveled [2] - 2019:23, 2020:3
tighter [1] - 2004:18
2006:20, 2125:11, 2137:21, 2141:7,
traveling [3] - 2176:22, 2189:8, 2190:6
timeframe [5] - 2013:3, 2081:9,
2162:14, 2209:13, 2217:8, 2217:9,
treasurer [2] - 2199:9, 2199:12
2231:9, 2231:10, 2231:12
2236:22
treasury [9] - 2149:8, 2149:10,
timeline [1] - 2012:24
typically [1] - 2159:18
2149:11, 2247:21, 2247:23, 2253:23,
timelines [1] - 2012:19
2255:13, 2255:14, 2255:15
timely [1] - 2035:18
2291
2217:1, 2224:14, 2228:18, 2230:1,
2231:2, 2247:11, 2253:11, 2255:7,
2256:15, 2257:3
up-to-date [1] - 2053:3
upset [2] - 2012:17, 2142:2
US [1] - 1971:14
warehouse [1] - 2208:20

Warren [1] - 1971:16
WARREN [85] - 1975:7, 1975:9,
U.S [14] - 1971:17, 1985:15, 1985:16,
1977:13, 1980:7, 1980:13, 1980:18,
1986:19, 1987:1, 1987:4, 2008:25,
1980:19, 1982:25, 1983:2, 1983:8,
2034:9, 2034:12, 2063:23, 2097:5,
1989:6, 1989:8, 1992:20, 2017:15,
2100:22
2022:11, 2022:16, 2022:21, 2034:24,
U.S.-style [1] - 2197:23
2035:13, 2036:2, 2036:5, 2036:11,
V
UK [1] - 2011:11
2036:15, 2036:17, 2036:25, 2038:2,
unable [1] - 2058:24
2038:20, 2044:25, 2051:19, 2051:25,
V.C [1] - 2208:21
undependable [1] - 2164:24
2052:2, 2062:1, 2062:3, 2062:6,
Valley [3] - 2135:11, 2197:19, 2242:21
under [29] - 1975:17, 1975:23, 1976:3,
2062:9, 2062:11, 2063:4, 2063:9,
value [6] - 2063:18, 2126:13, 2151:19,
1985:23, 2006:1, 2030:22, 2042:19,
2063:11, 2065:24, 2066:2, 2066:21,
2212:11, 2212:15
2048:1, 2060:10, 2086:7, 2091:5,
2066:23, 2067:7, 2067:11, 2070:10,
variances [2] - 2206:17, 2206:22
2092:9, 2092:11, 2138:12, 2184:9,
2070:16, 2071:3, 2071:16, 2072:10,
various [11] - 1978:13, 1978:15,
2184:12, 2190:8, 2190:13, 2211:16,
2073:5, 2073:10, 2073:15, 2075:8,
2011:25, 2012:13, 2041:23, 2041:25,
2211:17, 2211:18, 2215:4, 2222:8,
2075:17, 2076:5, 2076:12, 2077:1,
2185:22, 2243:14, 2245:7, 2253:10,
2223:18, 2224:9, 2224:10, 2238:20,
2077:5, 2077:9, 2077:12, 2077:15,
2255:6
2249:7
2077:17, 2078:8, 2078:11, 2079:5,
venue [1] - 2129:25
underlined [1] - 2208:14
2079:14, 2079:25, 2080:1, 2080:5,
verbatim [1] - 2065:20
underneath [1] - 2033:1
2080:8, 2080:11, 2080:12, 2081:5,
verification [1] - 2017:9
understandings [1] - 2124:3
2081:13, 2083:4, 2083:6, 2084:4,
verify [2] - 1989:4, 2058:25
2084:9, 2084:14, 2088:12, 2090:14,
understood [6] - 2071:18, 2106:3,
version [1] - 1986:10
2098:1, 2098:3, 2098:12
2110:9, 2112:12, 2168:24, 2235:7
versus [3] - 2125:1, 2126:7, 2126:18
WARREN............ [2] - 1973:8, 1973:12
undertook [1] - 2013:22
vice [2] - 2101:16, 2106:25
Washington [1] - 1971:18
unfortunately [1] - 1982:9
vice-president [1] - 2101:16
waste [1] - 2210:8
uNITED [1] - 1971:1
vice-presidents [1] - 2106:25
watch [2] - 2059:23, 2098:18
United [13] - 1986:22, 2011:10,
video [10] - 2093:21, 2142:10,
watched [4] - 2179:23, 2214:10,
2013:8, 2013:9, 2013:12, 2013:13,
2142:13, 2142:18, 2143:11, 2143:12,
2016:3, 2026:4, 2081:24, 2098:24,
2214:11
2144:25, 2145:25, 2234:24, 2243:5
2136:4, 2221:21, 2222:1
water [3] - 2164:22, 2164:23, 2197:24
view [11] - 1981:20, 1995:6, 1996:12,
UNITED [2] - 1971:4, 1971:10
Waterhouse [3] - 2161:3, 2161:5,
2000:14, 2025:7, 2028:10, 2032:20,
units [5] - 2134:22, 2171:15, 2171:16,
2161:17
2113:17, 2128:7, 2165:17, 2254:20
2186:18, 2186:20
Watkins [1] - 2220:23
Vincent [1] - 2168:8
University [2] - 2100:3, 2100:13
ways [4] - 1999:10, 2112:24, 2223:12,
Vingerhoedt [1] - 2057:13
unless [5] - 2063:7, 2107:9, 2112:9,
2227:16
violation [2] - 1982:22, 2052:3
2164:21, 2229:5
weakened [1] - 2071:22
violations [1] - 2056:17
unpaid [2] - 2063:25, 2151:22
weaknesses [1] - 2013:16
vision [4] - 2194:23, 2215:24, 2218:15,
unquote [1] - 2194:12
wealth [1] - 2146:17
2218:17
unreasonable [1] - 2012:19
wealthy [2] - 2165:9, 2220:2
visionary [1] - 2193:6
untoward [1] - 2205:5
wear [4] - 1999:17, 1999:24, 2000:2,
visit [4] - 1984:24, 2064:18, 2116:4,
unusual [2] - 2174:2, 2174:3
2039:20
2182:18
wearing [4] - 1999:13, 2039:1,
up [93] - 1983:12, 1983:13, 1985:17,
visited [3] - 1994:16, 2018:7, 2182:4
1987:20, 1992:16, 1996:4, 2003:17,
2039:16, 2103:23
visitors' [1] - 2138:17
2003:19, 2007:18, 2015:15, 2018:18,
weather [1] - 2102:4
vitae [1] - 2053:4
2021:2, 2028:8, 2030:7, 2031:19,
week [2] - 2026:1, 2035:19
void [1] - 2003:2
2032:3, 2033:17, 2035:5, 2035:12,
week's [1] - 2035:19
2039:9, 2040:14, 2040:22, 2042:9,
VOISANGE [1] - 2134:25
welcome [2] - 2082:25, 2255:20
2043:24, 2045:4, 2049:20, 2053:3,
Voisinage [1] - 2134:21
well-established [1] - 2053:5
2057:6, 2058:2, 2059:18, 2060:1,
VOLUME [1] - 1971:8
well-publicized [1] - 2164:1
2061:15, 2062:6, 2062:22, 2077:10,
volunteered [1] - 2183:14
well-to-do [1] - 2195:15
2083:17, 2083:19, 2083:25, 2088:21,
VS [1] - 1971:5
Well-to-do [1] - 2195:17
2089:22, 2094:13, 2097:2, 2097:16,
West [10] - 2018:15, 2018:24, 2019:9,
2102:5, 2102:13, 2103:25, 2105:3,
2019:17, 2019:25, 2063:22, 2134:22,
W
2105:6, 2111:24, 2112:9, 2115:23,
2213:24, 2214:1
2116:9, 2116:18, 2120:19, 2120:22,
Westies [2] - 2019:20, 2019:23
wait [3] - 2035:25, 2051:17, 2125:18
2121:14, 2121:20, 2122:15, 2122:18,
whereby [1] - 2088:22
waiting [1] - 2096:15
2122:23, 2126:14, 2126:15, 2126:24,
whipped [1] - 2020:8
walk [1] - 2021:2
2136:5, 2141:20, 2144:13, 2152:14,
whole [15] - 1983:14, 1987:15,
Wall [1] - 2103:1
2154:10, 2156:1, 2157:14, 2167:19,
2019:19, 2030:17, 2030:19, 2065:12,
Walter [1] - 1984:15
2168:7, 2169:25, 2175:23, 2176:1,
2121:24, 2139:19, 2159:22, 2162:7,
wants [3] - 1979:8, 2059:23, 2078:17
2187:13, 2188:11, 2188:22, 2190:14,
2162:8, 2213:25, 2216:14, 2217:6,
2190:19, 2211:6, 2214:13, 2216:21,
war [1] - 2004:12
2217:13
2292
2221:25, 2234:18, 2234:21, 2236:17
Wicket [20] - 2081:18, 2081:20,
world-class [2] - 2215:16, 2218:17
2081:21, 2081:23, 2082:4, 2083:12,
2084:10, 2084:11, 2084:25, 2085:12,
worth [6] - 2195:21, 2195:22, 2195:23,
2085:13, 2137:1, 2139:13, 2211:13,
2196:10, 2225:20
2213:6, 2213:8, 2214:22, 2215:13,
wound [2] - 2175:23, 2176:1
2243:3, 2249:14
write [3] - 1999:9, 1999:10, 2227:12
wicket [10] - 2081:25, 2082:5, 2082:7,
writing [3] - 2005:19, 2034:15,
2082:8, 2082:13, 2082:19, 2082:20,
2044:10
2083:7, 2214:16
written [1] - 2057:7
wickets [3] - 2082:3, 2082:10, 2082:14
wrote [7] - 1999:14, 2007:5, 2016:2,
wide [2] - 1979:18, 2007:3
2040:8, 2183:8, 2185:1
wife [1] - 2166:20
wig [3] - 1999:13, 1999:21, 2000:2
Y
wigs [2] - 1999:18, 2039:1
William [2] - 1971:16, 2039:7
y'all [1] - 2189:22
willing [1] - 2120:3
yachts [1] - 2218:4
Windies [1] - 2019:25
year [27] - 2026:13, 2028:12, 2028:17,
Winter [2] - 2046:7, 2047:3
2029:1,
2029:9, 2030:7, 2030:8,
winter [2] - 2053:2, 2053:14
2032:22, 2040:4, 2043:8, 2090:9,
winter's [1] - 2053:8
2101:22, 2102:16, 2130:10, 2154:4,
wish [1] - 2046:5
2154:18, 2154:20, 2156:18, 2164:3,
withdraw [1] - 2133:15
2167:24, 2177:1, 2182:16, 2185:11,
withdrawn [3] - 2245:23, 2245:24
2239:25, 2244:14, 2249:10
WITNESS [48] - 1973:3, 1977:8,
years [55] - 1977:8, 2019:10, 2020:9,
1977:11, 1985:20, 1986:4, 1991:21,
2020:18, 2039:3, 2039:13, 2074:11,
1991:23, 1991:25, 1997:1, 2061:19,
2084:20, 2100:10, 2100:12, 2101:15,
2061:22, 2062:10, 2071:11, 2071:15,
2108:17, 2109:18, 2115:3, 2123:6,
2075:7, 2075:13, 2081:12, 2082:4,
2129:17, 2129:18, 2134:8, 2135:5,
2082:6, 2082:9, 2082:16, 2082:22,
2136:7, 2139:19, 2142:19, 2144:1,
2082:25, 2083:15, 2085:6, 2090:12,
2145:21, 2148:17, 2157:18, 2161:22,
2097:9, 2098:21, 2100:25, 2102:17,
2168:1, 2168:19, 2169:16, 2170:1,
2104:1, 2110:25, 2113:21, 2116:7,
2176:8, 2176:16, 2180:4, 2187:5,
2121:5, 2124:6, 2124:15, 2127:20,
2188:19, 2190:7, 2191:21, 2202:23,
2127:24, 2128:1, 2128:15, 2134:24,
2204:20, 2204:22, 2216:11, 2219:7,
2138:15, 2161:13, 2167:1, 2197:8,
2221:7, 2229:2, 2229:5, 2234:5,
2231:16, 2256:25
2234:8, 2237:9, 2251:8, 2253:11,
witness [25] - 1983:2, 1989:15,
2255:7
1995:19, 2052:6, 2054:11, 2076:25,
yesterday [4] - 2042:23, 2064:23,
2078:24, 2084:14, 2090:15, 2098:12,
2068:21, 2069:9
2098:23, 2112:6, 2112:7, 2112:25,
York [3] - 1971:17, 2220:19, 2220:20
2113:6, 2123:19, 2152:15, 2152:18,
yourself [4] - 2041:8, 2043:3, 2096:4,
2152:19, 2169:7, 2228:17, 2233:15,
2099:11
2244:1, 2251:23, 2254:22
witness's [1] - 2079:3
Z
witnesses [2] - 2037:23, 2098:17
wondered [1] - 2146:3
wonderful [1] - 2039:4
Zealand [1] - 2020:6
wood [1] - 2141:9
zoom [6] - 1985:19, 2027:22, 2028:18,
word [8] - 2001:23, 2010:11, 2134:24,
2029:21, 2030:2, 2030:18
2180:1, 2200:19, 2200:20, 2214:5,
2248:9
word's [1] - 2205:4
worded [1] - 2238:19
words [4] - 1996:24, 2063:17, 2090:9,
2235:1
workers [1] - 2164:12
works [2] - 2009:1, 2227:16
world [27] - 1976:3, 1977:18, 2004:12,
2013:10, 2013:13, 2019:10, 2025:10,
2076:10, 2140:20, 2141:21, 2142:8,
2164:2, 2193:18, 2193:19, 2193:22,
2194:2, 2194:3, 2194:12, 2194:21,
2213:14, 2215:16, 2218:12, Johnny

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

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

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

Uploaded by

Copyright:

Available Formats

1971

UNITED STATES DISTRICT COURT

4 UNITED STATES OF AMERICA

BEFORE THE HONORABLE DAVID HITTNER

13 FOR THE GOVERNMENT:

MARIAN ALTHEA CRICK

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

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

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

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

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

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

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

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

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

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

(The following was held before the jury)

THE COURT: Thank you. Be seated. Good

So we're ready to proceed. Counsel, go

MR. WARREN: Thank you, Your Honor.

Good morning, Ms. Crick?

Are you familiar with Antiguan bank secrecy laws?

Can you generally describe what those laws are?

Those laws are contained in the International

16 Business Corporations Act, and it describes the conditions

And what types of information can be released and

20 what types of information can't be released, generally

Well, generally speaking, all information can be

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

25 information that are available to the public in general.

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

5 mutual legal assistance treaty with those countries. And

What do you mean by "customer information"?

Specifically in banking, information that would

10 outline a customer's business transactions with the bank.

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

12 case of Stanford International Bank?

In the case of Stanford International Bank, a

14 customer is one who either by way of deposit or loan

15 accesses the services of the bank.

Is there any prohibition against a bank like Stanford

17 International Bank disclosing its assets?

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

THE COURT: Why?

MR. PARRAS: Best evidence would be the

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

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

25 read back. Johnny, read it back, please.

(Requested portion was read.)

THE COURT: Now, what's your problem?

MR. PARRAS: It's not qualified to indicate

4 that it's her understanding, and it seems -10:22:15

THE COURT: Hold it.

Ma'am, how long have you been in the

THE WITNESS: For over 25 years.

THE COURT: On your country, you're familiar

10 with the laws?

THE WITNESS: Yes, I am.

THE COURT: Overrule the objection.

Ms. Crick, do you recall the question?

There is nothing that prevents a bank from revealing

16 its assets, no.

If Stanford International Bank wanted to tell its

18 customers or even the entire world about every single