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

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
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4 UNITED STATES OF AMERICA
5 VS.
6 ROBERT ALLEN STANFORD
7
February 6, 2012
10:07 a.m.
VOLUME 11
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09-CR-342
Houston, Texas
JURY TRIAL
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BEFORE THE HONORABLE DAVID HITTNER

UNITED STATES DISTRICT JUDGE
12 APPEARANCES: 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
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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
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11 Court Reporter:
Johnny C. Sanchez, RPR, RMR, CRR
12 515 Rusk, #8016
13 713.250.5581
14 Proceedings recorded by mechanical stenography. Transcript
produced by computer-assisted transcription.
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I N D E X
1
2 WITNESS
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JAMES DAVIS
DIRECT EXAMINATION BY MR. STELLMACH............ 3146
CROSS-EXAMINATION BY MR. SCARDINO.............. 3296
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Direct-Davis/By Mr. Stellmach
1
2
(The following was held before the jury)
THE COURT: Good morning everybody. Monday
3 morning, another week. We're ready to proceed. Screen is

4 coming down, so we're all ready to go.
10:07:27
5
6
Counsel, go right ahead.

MR. STELLMACH: Thank you, Your Honor.
JAMES DAVIS
CONTINUED DIRECT EXAMINATION
9 BY MR. STELLMACH:
10:07:29
10 Q.
Good morning, Mr. Davis.
11 A.
Good morning.
12 Q.
When we ended on Friday, you were discussing
13 Mr. Hewlett, the auditor of the bank, who died on

14 January 1, 2009?
10:07:40
15 A.
Yes, sir.
16 Q.
And when you called Mr. Stanford, could you remind us
17 what he said when you told him that the auditor had died?
10:07:58
18 A.
He said, "He's the lucky one."
19 Q.
What was going on at the bank in terms of CD
20 redemptions at that time, end of 2008, early 2009?

21 A.
22
The redemptions were -MR. SCARDINO: Excuse me. Form of the
23 question. Ask that it be more narrow in scope as to what

24 was going on.
10:08:09
25
THE COURT: All right. Narrow it down, please.

3147
1 BY MR. STELLMACH:
2 Q.
What was the rate of redemptions by the end of 2008
3 and in to early 2009?

4 A.
10:08:23
At a very, very high rate compared to anytime in
5 history.
6 Q.
And what about CD sales, sell of new CDs?
7 A.
They were at a lower rate than much of the past five
8 years, six years.

9 Q.
10:08:39
How focused was Mr. Stanford on the rate of CD sales?
10 A.
I would say very focused.
11 Q.
And going back a couple of years to the start-up of
12 the brokerage firm, Stanford Group Company, could you tell

13 us -- can you remind us what year that happened?
10:08:58
14 A.
1995, toward the end.
15 Q.
And prior to 1995, had Mr. Stanford ever discussed
16 with you the possibility of opening a brokerage firm here

17 in the United States?
10:09:13
18 A.
Yes. We had that discussion.
19 Q.
And before 1995 what had Mr. Stanford told you about
20 his ability to open a brokerage firm?

21 A.
Among other things, he said that it would probably be
22 very difficult.
10:09:31
23 Q.
Did he explain why he thought it would be difficult?
24 A.
Primarily because of his bankruptcy.
25 Q.
From the time in the '80s when he owned those health

3148
1 clubs that failed?

2 A.
Yes, sir.
3 Q.
But Mr. Stanford in 1995 was, in fact, able to open a
4 brokerage firm here in the United States?

10:09:45
5 A.
Yes, sir.
6 Q.
Where did the money to open the brokerage firm come
7 from?
10:09:57
8 A.
CD deposit holds.
9 Q.
Who were Jay Comaeux and Al Truellenque?
10 A.
Mr. Comaeux and Mr. Truellenque were the initial
11 hires for the new brokerage. They were hired as

12 co-presidents, and they came from Merrill Lynch in their
13 previous employ.
14 Q.
10:10:20
How was Mr. Stanford able to persuade them to leave
15 Merrill Lynch and come to start up a new brokerage firm?

16 A.
Better business opportunity, on a remuneration basis,
17 opportunity to elevate themselves in terms of position.

18 Q.
And by "remuneration," did Mr. Stanford tell you
19 whether he was paying Mr. Truellenque and Mr. Comaeux

10:10:48
20 fairly well in order to leave Merrill Lynch and come to

21 start up the brokerage firm?
10:11:03
22 A.
Yes, sir. Their pay was very competitive.
23 Q.
Where were they based when the brokerage firm opened?
24 A.
Baton Rouge, Louisiana.
25 Q.
And over time did the brokerage firm open other

3149
1 branches and offices elsewhere in the United States?
10:11:17
2 A.
Yes, sir.
3 Q.
Where did the money come to do that?
4 A.
The money came from CD deposit holders.
5 Q.
Did the bank have any ownership interest in the
6 brokerage firm?
10:11:28
10:11:47
7 A.
No, sir.
8 Q.
Did the brokerage firm repay the bank?
9 A.
No, sir.
10 Q.
Who owned the brokerage firm?
11 A.
Mr. Allen Stanford.
12 Q.
All of it, to your knowledge?
13 A.
Yes, sir.
14 Q.
And, so, the brokerage firm opens 1995, 1996. How
15 shortly after that does it start selling CDs here in the

16 United States?
17 A.
I would say four years, three to four years, maybe
18 five, maximum.
19 Q.
10:12:04
Who made that decision, the decision to enable the
20 brokerage firm to sell the bank's CDs here in the U.S.?

21 A.
Mr. Stanford. He was the chairman.
22 Q.
What did Mr. Stanford tell you about that decision?
23 A.
Well, that would be a huge market for the CD sales in
24 the United States.

10:12:29
25 Q.
Are you familiar with the term "assets under

3150
1 management"?
2 A.
Yes, sir.
3 Q.
Could you explain what that meant or what that meant
4 in terms of Stanford Group Company, the brokerage firm?

10:12:42
5 A.
Stanford Group Company was a broker dealer and as
6 such had financial advisors that represented hundreds of

7 clients. Those clients had investments. And those
8 investments would range from stocks, bonds, investment
9 funds, possibly metals. And those investments known as
10:13:14
10 assets would move to the brokerage when these clients

11 became customers of the broker dealer, and those assets,
12 after broker being managed by the various financial
13 advisors, would be known as assets under management.
14 Q.
10:13:45
So by the end of 2008, 2009, how much in assets under
15 management did the brokerage firm have, to the best of

16 your recollection?
17 A.
In the neighborhood of $40 billion.
18 Q.
And some of that $40 billion that the brokerage firm
19 was managing, were those assets owned by the clients or

10:14:01
20 were they owned by Mr. Stanford?

21 A.
They would be owned by the clients.
22 Q.
So could Mr. Stanford take any of the assets under
23 management that were owned by the clients at the brokerage

24 firm and use them to repay CD depositors?
10:14:16
25 A.
No, sir.
3151
1 Q.
Mr. Stanford owned the brokerage firm, but he didn't
2 own all the assets under management?
10:14:29
3 A.
That's correct.
4 Q.
And when the brokerage firm first started selling CDs
5 here in the United States in those first couple of years,

6 approximately how much of the assets under management had
7 been put into CDs issued by Mr. Stanford's bank?
8 A.
In the early days of the brokerage, there were
9 probably, in terms of dollars and cents, 20, $25 million.

10:14:52
10 Q.
And overall as a percentage, to the extent you can
11 recall?
12 A.
In the early days, as much as 85 percent of the
13 assets under management.
10:15:06
14 Q.
Was Mr. Stanford comfortable with that?
15 A.
Mr. Stanford was desirous of increased CD sales by
16 the broker dealer and other regions, so...

17 Q.
And, initially, did Mr. Stanford say that he was
18 uncomfortable with the fact that so many of the assets of

19 the customers at the brokerage firm had been placed into
10:15:33
20 CDs issued by his bank?

21
MR. SCARDINO: Object to the leading question.
22
THE COURT: Sustained.
23 BY MR. STELLMACH:
24 Q.
10:15:41
What, if anything, did Mr. Stanford tell you in the
25 early years about whether he was uncomfortable with having

3152
1 so many assets under management at the brokerage firm in

2 the CD program?
3 A.
We had the discussion about the percentage that
4 you're speaking of and that it would not be an ongoing

10:15:58
5 percentage to maintain. The percentage being so high, as

6 related to both of us by our compliance people, was being
7 flagged, looked at very, very closely by the regulators.
10:16:22
8 Q.
Who were the regulators that were looking at this?
9 A.
The NASD for one, SEC.
10 Q.
What's the NASD?
11 A.
That is a self-regulating arm of the brokerage
12 industry.
13 Q.
And what was -- could you just explain for us what
14 was the concern raised by the NASD regarding this amount

10:16:44
15 of CDs that customers at the brokerage firm had purchased?

16 A.
17
As I understand it from speaking -MR. SCARDINO: Your Honor, I would object.
18 He's asking him a question that is not established within

19 the knowledge of the -10:16:53
20
THE COURT: Just find out what sort of
21 knowledge he has.
23 Q.
What was the basis for your understanding about what
24 the NASD was looking into at the brokerage firm?

10:17:03
25 A.
My understanding was that the NASD was concerned -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3153
1 Q.
I'm sorry. I'm just asking: How did you learn about
2 the NASD's concerns? Who were your sources?

3 A.
Yes, sir. My sources were the compliance officer of
4 the broker dealer as well as the president, Mr. Jay

10:17:29
5 Comaeux.
6 Q.
And when they shared these concerns from the
7 regulator with you, was Mr. Stanford also involved in

8 those conversations?
10:17:38
9 A.
Yes, sir, Mr. Stanford was aware of those concerns.
10 Q.
And so what were you told about the concerns by the
11 regulator about the amount of CDs that the brokerage firm

12 had put clients into?
13
MR. SCARDINO: Your Honor, object to the
14 hearsay.
10:17:47
15
THE COURT: Well, hearsay or --
16
MR. SCARDINO: Mr. Stanford was aware of it.
17 He didn't say he was present.

18
MR. STELLMACH: He did say he was present and
19 participated in the conversation.

10:17:55
20
THE COURT: Okay. He said he wasn't, you say
21 he was. Let's get that settled first.

23 Q.
Was Mr. Stanford present when these conversations
24 took place or participating in the conversation?

10:18:04
25 A.
Yes, sir.
3154
1 Q.
So what was the concern that the lawyers relayed to
2 Mr. Stanford from the NASD?

3 A.
That it looked like the broker dealer was set up just
4 to sell foreign CDs because of the percentage being so

10:18:21
5 high.
6 Q.
Did Mr. Stanford discuss --
THE COURT: Percentage -- you mean the interest
8 rate?
9
10:18:27
THE WITNESS: No, sir. Your Honor, the
10 percentage of revenue that came from CD sales alone.

11
THE COURT: Okay.
13 Q.
And, in fact, if we look at Government's Exhibit 668,
14 this is the confidential and privileged letter dated

10:18:40
15 June 9, 2005, from the SEC to Mr. Leroy King. If I could

16 direct you to the second page?
10:18:56
17
THE COURT: Again, what number is that?
18
MR. STELLMACH: This is 668. I believe --
19
THE COURT: We've already referenced that?
20
MR. STELLMACH: It has been referenced, but
21 it's subject to, I think, an objection by the defense. We

22 can only show certain portions of the document.
23
THE COURT: Oh, that's right. Here it is.
24 Yes, I see.
10:19:04
25
MR. STELLMACH: I was just asking a question

3155
1 about something in the letter, not showing the letter.

2
THE COURT: Okay.
3 BY MR. STELLMACH:
4 Q.
10:19:13
Have you had an opportunity to review that,
5 Mr. Davis?
6 A.
Would you repeat the focussed paragraph?
7 Q.
Sure. It's on the second page, the second full
8 paragraph beginning, "SGC primarily exists to sell its

9 customers the CD products issued."
10:19:26
10 A.
Yes, sir, I see that.
11 Q.
Could you just take a moment to silently read that
12 paragraph to yourself.
13
MR. SCARDINO: While he's reading it, Your
14 Honor, I think our objection to this exhibit was foundation

10:19:53
15 and hearsay.
16
THE COURT: Well, it's not in evidence. It's
17 just for what he's doing, refreshing some recollection.

18
MR. STELLMACH: That is correct. And as I
19 understood it, I was allowed to ask the witness questions

10:20:06
20 about the document -21
THE COURT: In general abstract form rather
22 than read it in, and the whole document has --
10:20:12
23
MR. STELLMACH: Absolutely.
24
THE COURT: -- been excluded, not admitted,
25 according to my notes.
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MR. STELLMACH: Except for those portions
2 identifying it as a confidential communication from the

3 SEC.
4
10:20:19
THE COURT: We made that ruling. I think
5 you're well within the bounds. Everybody understands?

6
MR. COSTA: All right.
7 BY MR. STELLMACH:
8 Q.
Have you had an opportunity to review that paragraph,
9 Mr. Davis?
10:20:29
10 A.
Yes, sir, I have.
11 Q.
So was the amount of CD sales by the brokerage firm
12 also a concern from the -- by the SEC in its letter to

13 Mr. King back in 2005?
10:20:43
14
THE COURT: Yes or no.
15
THE WITNESS: Yes, sir.
16
THE COURT: Okay.
17 BY BY MR. STELLMACH:
18 Q.
And, so, when you had these conversations with are
19 Mr. Stanford about regulatory interest in the brokerage

10:20:51
10:21:08
20 firm, could you tell us what he said in response?

21 A.
Not specifically.
22 Q.
Well, you can't recall word-for-word.
23 A.
Yes, sir.
24 Q.
It's been a number of years, but could you tell us
25 what he said?
3157
1 A.
That the brokerage needed to expand in terms of
2 assets under management beyond the CD sales so that that

3 percentage that we're discussing would be a lower
4 percentage.
10:21:26
5 Q.
And did Mr. Stanford explain why he wanted to get the
6 percentage of CD sales down at the brokerage firm?

7 A.
10:21:42
In so many words, it was discussed.
MR. SCARDINO: Excuse me.
THE COURT: Yes, sir.
10
MR. SCARDINO: Nonresponsive.
11
13 Q.
What did Mr. Stanford say about why he wanted to get
14 the amount of CD sales down at the brokerage firm?

10:21:53
15 A.
He wanted -- he said he wanted the CD sales
16 percentage down so that the scrutiny of the regulators

17 would be -- it would be an acceptable scrutiny any and
18 exam process so that the brokerage could continue to be an
19 ongoing brokerage.
10:22:23
20 Q.
Did Mr. Stanford express any concerns that if the
21 amount of CD sales by his brokerage firm didn't go down

22 that could lead into an inquiry into the bank itself?
10:22:39
23 A.
I don't remember that specifically.
24 Q.
But in the SEC letter to Mr. King, that was certainly
25 a point that will they raised, wasn't it?

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1 A.
Yes, it was. And by that, he would have known.
MR. SCARDINO: Object to nonresponsive.
THE COURT: Excuse me. Sustained.
4 BY MR. STELLMACH:
10:22:52
5 Q.
Were the financial advisors at the brokerage firm
6 given incentives to sell the CDs over other financial

7 products?
10:23:03
8 A.
Yes, sir, they were.
9 Q.
Who came up with the idea of the incentives and the
10 bonuses and the commissions that would be paid to the

11 financial advisors to sell the CDs?
12 A.
Mr. Stanford.
13 Q.
Were you involved in deciding what the bonus
14 structure should be?

10:23:13
15 A.
No, sir.
16 Q.
Did Mr. Stanford track CDs by the individual
17 financial advisors?
10:23:24
18 A.
Yes, sir, intimately.
19 Q.
How do you know that?
20 A.
He spoke to me very frequently on the subject, how
21 the sales were going by region, by country, by team, by

22 individual.
23 Q.
Did he know about sales by individual financial
24 advisors?
10:23:42
25 A.
Yes, sir.
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10:23:57
1 Q.
Did you track CD sales?
2 A.
No, sir.
3 Q.
Why not?
4 A.
The accounting information related to CD sales would
5 have been tracked by the normal bookkeeping processes that

6 happened day-to-day, week-to-week. It would have been
7 captured in the financial statements.
8 Q.
So in terms of the day-to-day rate of CD sales, was
9 that something you were focused on?

10:24:12
10 A.
No, sir.
11 Q.
How frequently when you spoke with Mr. Stanford did
12 the issue of CD sales and the rate of growth come up?
10:24:30
13 A.
Most of the time, we had conversations.
14 Q.
Was Mr. Stanford focused on the sales of any other
15 financial products by the brokerage firm other than the CD

16 sales?
17 A.
No, sir, he was not focused on those.
18 Q.
Did there come a time when Mr. Stanford replaced
19 Mr. Comaeux and Mr. Truellenque?

10:24:45
20 A.
Yes, sir.
21 Q.
Do you remember approximately when that happened?
22 A.
2004, 2005.
23 Q.
What did Mr. Stanford tell you about his decision to
24 replace them as heads of the brokerage firm?

10:25:02
25 A.
He s that the growth wasn't happening specifically in

3160
1 the CD area of sales and primarily --
10:25:28
2 Q.
Who replaced them?
3 A.
Mr. Danny Bogar.
4 Q.
Who was Mr. Bogar in relation to you?
5 A.
Mr. Bogar was married to my niece.
6 Q.
Did you recommend Mr. Bogar to Mr. Stanford?
7 A.
Yes, I did.
8 Q.
What was Mr. Bogar's prior experience before he was
9 appointed as head of the brokerage firm?

10:25:41
10 A.
He was a regional executive in a wireless company,
11 and I believe he oversaw the North and South America

12 regions. It was a multiple billion dollar worldwide
13 wireless company.
14 Q.
10:26:02
But Mr. Bogar didn't have any specific securities
15 industry experience before getting that job as head of the

16 brokerage firm?
10:26:14
17 A.
No, sir.
18 Q.
So was he qualified to run the brokerage firm?
19 A.
From the sales point and organizational standpoint,
20 yes, sir.
21 Q.
Who made the decision to actually hire Mr. Bogar?
22 A.
Mr. Stanford.
23 Q.
And once Mr. Bogar was in place as head of the
24 brokerage firm, who did he report to?

10:26:26
25 A.
Mr. Stanford.
3161
1 Q.
I want to step back for just a second and focus on
2 the fall of 2000. You've mentioned that by 2008 into

3 2009, there were problems with CD sales. They were down.
4
10:26:45
Had there been a similar problem like that
5 back in the fall of 2000?

6 A.
Yes, sir, there was. I believe it was a problem
7 area. Timing was in the fall of -- yes, sir, it was 2000.

8 Q.
Could you explain to us what the problem was with the
9 CDs at that point?

10:27:09
10 A.
The CD sales, while steady, had not kept pace with
11 the amount of money being taken from the CD depositors in

12 paying the cost of running the other Stanford entities.
13 Q.
So there wasn't enough money coming in from new CD
14 sales to pay off depositors who wanted to cash out?

10:27:37
15 A.
I believe that's correct, yes.
16 Q.
As well as whatever funds Mr. Stanford was borrowing
17 from the bank?
10:27:50
18
19
MR. STELLMACH: I'm just trying to clarify.
20
THE COURT: Technically correct, but overruled.
21 Let's get it moving. Go on.

22
THE WITNESS: Yes, sir, that's correct.
10:28:00
24 Q.
How much of a concern did that become for you?
25 A.
It was at that point in time a very great concern.

3162
10:28:30
1 Q.
How grave a concern was it for you?
2 A.
It was impacting my health in an acute way.
3 Q.
In what way?
4 A.
I thought I had a heart attack. I was in Antigua at
5 the time. And I was quite alarmed, panic attacks and went
6 to the hospital emergency one midnight, 2:00 a.m.,
7 evening.
8 Q.
And after you had -- was it a heart attack or was it
9 a panic attack?
10:28:51
10 A.
Actually, it was a dehydration panic attack, yes,
11 sir.
12 Q.
After that happened, did you make any attempt to
13 speak with Mr. Stanford?

14 A.
10:29:07
Yes, sir. After I got back on my feet the next day,
15 I flew to Miami to attempt to find Mr. Stanford and speak

16 with him about my concerns.
17 Q.
Were you successful in locating Mr. Stanford in
18 Miami?
10:29:19
19 A.
Yes, sir, I was.
20 Q.
Could you tell us what happened in that conversation.
21
22 A.
Was it in person or was it over the phone?

No, sir. I located Mr. Stanford in Miami at his
23 apartment, across the Miami River from our offices, and I

24 shared with him my concern about the low level of
10:29:43
25 liquidity or cash available, in the event there was a

3163
1 large series of withdrawals, that there would not be

2 enough cash to cover them.
10:30:07
3 Q.
What did Mr. Stanford say when you told him that?
4 A.
Well, at the end of the conversation, he said that he
5 would focus on it and put a program together to eliminate

6 that problem.
10:30:18
7 Q.
Did he, in fact, put together a program?
8 A.
Yes, sir.
9 Q.
What was the name of the program?
10 A.
It was a quarterly sales program by the name of "Top
11 Performers Club."
10:30:37
12 Q.
Could it have been Top Producer Club or --
13 A.
Yes, sir, TPC, Top Producers Club.
14 Q.
Could you tell us -- what did Mr. Stanford tell you
15 was the purpose of that -- of these meetings, these

16 quarterly meetings?
17 A.
The purpose was to get the sales forces excited about
18 the CD disclosure statement product and incentivize the

19 salespeople to sell the CD product.
10:30:57
20 Q.
After the Top Producer Club events were introduced,
21 what incentives were the financial advisors given to sell

22 CDs?
23 A.
Of course, recognition; but most importantly, they
24 were given monetary incentives.

10:31:18
25 Q.
Who decided what those financial incentives would be?

3164
10:31:34
10:31:44
1 A.
Mr. Stanford.
2 Q.
Did you attend these top producer meetings?
3 A.
Most of them I did, yes, sir.
4 Q.
How large were they? How many actual people came?
5 A.
Say, around hundred.
6 Q.
Could any financial advisor attend?
7 A.
Yes, sir. They did if they produced a certain level.
8 Q.
If they produced a certain level of what?
9 A.
Of CD sales.
10 Q.
Were the sales of any other financial products
11 considered in deciding whether to invite somebody to

12 attend a TCP meeting?
10:31:58
13 A.
Not to my knowledge.
14 Q.
Could you just tell us what the format of these
15 meetings was like?

16 A.
It was an extravaganza format, Hollywood, a lot of
17 sizzle, excitement. There were skits, videos, special

18 speakers.
10:32:22
19 Q.
Who paid for all of this?
20 A.
CD depositors.
21 Q.
Was Mr. Stanford involved at all in organizing these
22 events?
10:32:31
23 A.
Yes, he was. He was the organizer.
24 Q.
Why do you say that?
25 A.
Well, I knew he was. He led the opening. He set the

3165
1 agenda. Most of the times we had meetings, he would work

2 with his creative services staff prior to the meeting
3 beginning. Most of the meetings were late beginning. He
4 had the doors in the meeting arenas and halls closed, and
10:33:07
5 the attendees waited out in the vestibule until he was

6 ready to open the doors.
7 Q.
In addition to these TPC or Top Producer Club
8 meetings, were there also competitions between different

9 teams of financial advisors at the brokerage firms to sell
10:33:25
10 the CDs?
11 A.
Yes, sir. That was my impression, yes, sir. There
12 were several teams that competed.

13 Q.
Teams like the Superstars or the Miami Money Machine,
14 those types of teams?

10:33:37
10:33:53
15 A.
Yes, sir. And the Aztec Eagles, the Thunderbirds.
16 Q.
Who set the goals for the teams, the sales targets?
17 A.
As far as I know, Mr. Stanford.
18 Q.
Were you involved in setting those sales targets?
19 A.
No, sir.
20 Q.
And after the TPC meeting started and the sales
21 competition started, how did things -- how did the CD

22 sales perform? You had described a problem that you were
23 encountering in the fall of 2000. How did this new
24 program address it?
10:34:11
25 A.
It caused a mushrooming of the sales of CDs. They

3166
1 went from maybe thousands to hundreds of thousands per

2 quarter.
3 Q.
Now, according to the marketing materials in the
4 annual report, how did the CD -- the rate that the bank
10:34:38
5 was paying on its CDs compare with the rate that U.S.
6 banks were paying?
7 A.
It was percentage-wise significantly higher.
8 Q.
And to do that, what sort of returns was the bank
9 reporting on its portfolio, its investment returns on its

10:34:59
10 assets?
11 A.
13, 13 1/2.
12
THE COURT: Percent?
13
THE WITNESS: Percent.
10:35:04
15 Q.
Was that consistent year after year, in that range?
16 A.
Yes, sir.
17 Q.
And we saw -- I won't go back to it, but we saw on
18 Friday there were a number of different crisis and events

19 that took place throughout the 20 years you worked for
10:35:19
20 Mr. Stanford, a lot of turmoil in the markets.

21
Throughout all of those events, was the
22 bank reporting a consistently -- a consistent profit or

23 return in the range of 12, 13 percent?
24
10:35:33
MR. SCARDINO: Can we narrow the scope of the
25 question? They were in business for 22 years.

3167
MR. STELLMACH: I'm just saying --
THE COURT: Get a time reference.
3 BY MR. STELLMACH:
4 Q.
10:35:45
Toward the end, after 2000, in what range were the
5 bank's reported financial returns?

6 A.
The returns on the investments would have been in the
7 12.7 to 14 percent on average.

8 Q.
And that was on -- involving an investment strategy,
9 according to the marketing materials that we saw, that

10:36:08
10 involved investing in highly liquid securities?

11 A.
Yes, sir.
12 Q.
Did any of the employees that worked for Mr. Stanford
13 in the time you worked for him ever question how that was
14 a possible, how could the bank earn those types of returns
10:36:22
15 consistently given a fairly liquid investment strategy?

16 A.
Yes, sir.
17 Q.
What would happen to those individuals?
18 A.
Well, the reply would be made as to why those returns
19 were possible based on the Stanford investment model.

10:36:43
20
21
MR. SCARDINO: Excuse me, Mr. Davis.

I'll object to this entire line of
22 questioning. It is based on hearsay, what somebody else

23 said.
10:36:50
24
MR. STELLMACH: These are other employees --
25
THE COURT: Hold it. Let me hear him. Go on.

3168
MR. SCARDINO: He asked him a question, What
2 did other people say about the ROI, and he's actually
3 relating now. And I would object as based on -- whole
4 information is based on hearsay.
10:37:02
MR. STELLMACH: These aren't other people.
6 These are other employees of Mr. Stanford. These are

7 people who work for him were relaying these concerns to
8 Mr. Davis and Mr. Stanford. I can be -- I'll be more
9 precise. I can ask him individual.
10:37:12
10
THE COURT: All right. Sustain the objection.
11 You may be a little more precise.

10:37:21
13 Q.
Who is Charles Hazlett?
14 A.
Mr. Hazlett was a financial advisor working in the
15 Miami office.
16 Q.
What did you tell Mr. Stanford about Mr. Hazlett in
17 his questioning of the financial returns of the bank?

18
MR. SCARDINO: Well, I'm sorry for this, but
19 he's assuming facts not in evidence.

10:37:32
20
THE COURT: Overruled.
21
Again, if he didn't state that, the
22 witness will so state he never said it; but if he said it,

23 he can relate it.
24
10:37:43
25
Go on.
THE WITNESS: I called Mr. Stanford and let him
3169
1 know that Mr. Hazlett had had an incident with our chief
2 investment officer, Laura Holt, in a Miami conference room
3 in the Miami office.
4 BY MR. STELLMACH:
10:37:56
5 Q.
What did you tell Mr. Stanford the incident involved?
6 A.
Mr. Hazlett, the financial advisor, had become quite
7 irate in his position to express his disbelief to Ms. Holt

8 that those returns were possible.
9 Q.
10:38:18
10 A.
What did Mr. Stanford say when you told him that?
At the end of the day, he said we'd have to get rid
11 of Mr. Hazlett.
10:38:30
12 Q.
Was Mr. Haslett fired?
13 A.
Yes, sir.
14 Q.
Who is Ron Rossi?
15 A.
Mr. Rossi was the director of creative services,
16 which was the department that came after Idea Advertising

17 handled the promotional materials, printing of those,
18 other creative service efforts.
19 Q.
10:39:01
So this was an individual who would have replaced Leo
20 Mejia, the job that Leo Mejia he was doing in the early
21 years?
10:39:07
22 A.
Yes, sir.
23 Q.
Was Mr. Rossi fired?
24 A.
Yes, sir.
25 Q.
What did Mr. Stanford tell you about why he fired

3170
1 Mr. Rossi?
2 A.
Said that he and Mr. DeMaria, Mr. Rossi's assistant,
3 were questioning -- again, questioning the returns that

4 were reported on Stanford International Bank Limited's
10:39:32
5 financial and promotional materials. He also said that

6 Mr. Rossi, Mr. DeMaria weren't very capable either, that
7 they didn't do that great a job in their promotional work.
8 Q.
So he didn't like their promotional work and
9 questioning the returns?

10:39:55
10:40:06
10 A.
Yes, sir.
11 Q.
What happened to Mr. Rossi and Mr. DeMaria?
12 A.
They were fired.
13
THE COURT: Where were they stationed?
14
THE WITNESS: Houston, Texas.
15
THE COURT: Houston.
17 Q.
Were you aware of potential depositors -- potential
18 purchases of CDs being taken down to Antigua on a tour of

19 the Stanford facilities?
10:40:22
10:40:40
20 A.
Yes, sir. This was a regular practice.
21 Q.
Was Mr. Stanford aware of that practice?
22 A.
Yes, sir, he was.
23 Q.
24 A.
Among other things that he said, he said that taking
25 perspective clients and present clients down to the Island

3171
1 of Antigua to tour the bank was a very effective program.

2 In fact, no trip made had failed to produce new CD sales.
10:41:05
3 Q.
Who paid for these trips down to the island?
4 A.
CD depositors.
5 Q.
Meaning?
6 A.
The money came from the SIBL CD depositors.
7 Q.
So bank money was used to pay for potential customers
8 to come down and see the island?

9 A.
10:41:22
10
Bank money was used to pay for everything.

THE COURT: How did they get down there? Was
11 it on commercial airlines?
12
THE WITNESS: Not to my knowledge, Your Honor.
13 It was on Stanford Aviation planes.
10:41:36
14
THE COURT: In other words, the private jets.
15
16
THE COURT: Okay.
18 Q.
So they'd fly down in any one of the six private jets
19 Mr. Stanford bought with CD money?

10:41:43
20 A.
That's correct.
21 Q.
How late into the bank's existence did these visits
22 continue to take place?

23 A.
10:42:05
I believe January of 2009.
24
THE COURT: When was it the SEC shut it down?
25
MR. STELLMACH: February.

3172
THE COURT: Of 2009?
MR. STELLMACH: February 2009.
3 BY MR. STELLMACH:
4 Q.
10:42:17
When visits were taken to the bank's headquarters,
5 were they taken to the headquarters, among other sites?

6 A.
Yes, sir.
7 Q.
When they were taken there, were all of the people
8 who were on the site working in the headquarters of the

9 bank actually permanently stationed at those headquarters?
10:42:33
10 A.
Most of them were; some few were not.
11 Q.
I wanted to ask about the few who were not.
12
Where did -- do you know where they were
13 based?
10:42:48
14 A.
Yes, sir. They were based in Memphis, Tennessee.
15 Q.
What did Mr. Stanford tell you about, if anything,
16 about why Memphis employees were down in Antigua?

17 A.
His comments were that the research people working in
18 the bank on a rotating basis there in Antigua showed well

19 and promoted the bank well to the visitors that would
10:43:15
20 come.
21 Q.
You say "showed well." What did you understand that
22 to mean?
23 A.
Well, it showed activity in the bank with additional
24 individuals who were working toward investment research,

10:43:33
25 and they had a separate research officing, and that

3173
1 officing was very visible in that it had -- in that it had

2 glass windows, very visible from the hallway passing by.
3 Q.
Sort of like a fishbowl that people could walk by and
4 see the research analysts in?

10:43:56
5 A.
You had the same -- same visual, yes, sir.
6 Q.
To your knowledge, were the visitors ever told that
7 the employees they saw working in that fishbowl area

8 weren't actually stationed there all the time, that they
9 worked in other parts of the organization?
10:44:12
10 A.
Repeat that question, please.
11 Q.
Do you know whether the depositors or potential
12 customers who visited and saw the employees who had been
13 brought down from Memphis to work behind that glass wall,
14 those -- that was in that office space, whether those
10:44:28
15 potential customers were ever told that the people they

16 were seeing weren't actually permanent employees working
17 down -- working down in Antigua?
18 A.
I don't know what they were told as the customers
19 came by.
10:44:44
20 Q.
Coming into -- we're now past 2000, coming into 2006,
21 2007, did you ever express any desire to quit to

22 Mr. Stanford?
10:45:01
23 A.
Yes, sir, I did.
24 Q.
When did that first come up?
25 A.
Sent him an e-mail to that subject, I believe, in

3174
1 2006. Could have been 2007. I believe it was '06.

2 Q.
Why did you want to quit?
3 A.
I was very -- a number of reasons. The fraud that I
4 was participating in was killing me. The access to

10:45:25
5 Mr. Stanford and direct time in managing these institutes

6 was at a all-time low. There had been some decisions by
7 Mr. Stanford that were pretty incredible, I thought, from
8 my perspective, and I was just pretty fed up.
9 Q.
10:45:56
You say there had been some pretty incredible
10 decisions by this point in 2006.

11
What were those decisions by Mr. Stanford
12 that you found incredible?

13 A.
Well, rather than slowing down the expansion of
14 projects dealing with the real estate, my position in

10:46:14
15 development, and curtailing some activities in the private

16 aircraft area, there were by then probably 42 people in
17 Stanford Aviation alone.
18
THE COURT: That wasn't the commercial airline
19 or was it?
10:46:32
20
THE WITNESS: No, sir, it was not.
21
THE COURT: The private fleet of the six jets,
22 is that what you're talking about?
10:46:41
23
THE WITNESS: Yes, sir, Your Honor.
24
THE COURT: 42 people?
25

3175
THE COURT: All right. Does that include the
2 pilots?
10:46:47
THE COURT: All right.
5 BY MR. STELLMACH:
6 Q.
Had you discussed any concerns about expenses with
7 Mr. Stanford prior to this?

8 A.
Yes, sir. It had been a ongoing conversation for
9 years about budgetary restraints, observing budgetary

10:47:04
10 restraints, setting up a budget and actually sticking to

11 it by component and in total.
12
13 Q.
Also, there was -When you say "component," what do you mean by
14 "component"?
10:47:16
15 A.
By department within company, within country, within
16 region.
17
10:47:32
There was also one other item.
18 Q.
What was that other item?
19 A.
One of the frustrating items at the time as well was
20 that Mr. Stanford's decision to hire an additional, I

21 would say, sequestered staff from the other accounting
22 units within the company to review expense reports. There
23 was a staff of 11, mostly CPAs, stationed in Florida, I
24 believe Orlando, to monitor travel expense forms, which
10:48:08
25 was a function already being done in the accounting unit

3176
1 and global, St. Croix offices as well as North America

2 Houston offices, by a platoon of qualified people in the
3 accounting field, and it was real point of contention
4 between the two of us.
10:48:34
THE COURT: Hang on one second. Stop the clock
6 for just a moment.

7
Go right ahead.
MR. STELLMACH: Yes, Your Honor.
9 BY MR. STELLMACH:
10:49:17
10 Q.
Mr. Davis, you were saying the fact that Mr. Stanford
11 had set up a unit of 11 or so other accountants was a

12 point of contention.
13
Did Mr. Stanford explain why he had done
14 that?
10:49:29
15 A.
He told me that, Jim, it's a thankless job anyway.
16 You don't want to do that job. It's something that nobody

17 really wants to do, and your people can use their time
18 more effectively doing other things.
19 Q.
10:49:50
So this other group of accountants, were they going
20 to have access to information, for example, about the

21 slush fund in Switzerland?
22 A.
I really didn't know. I doubt it very, very
23 seriously. That would have uncovered the scam, this

24 ongoing 21-year pyramid scam, and I don't think so. I'm
10:50:15
25 really not sure why -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3177
10:50:20
MR. SCARDINO: Object to the nonresponsive.
THE WITNESS: Those people were hired.
THE COURT: Sir?
MR. SCARDINO: It's nonresponsive.
6 BY MR. STELLMACH:
7 Q.
So you weren't sure why they were hired, but what did
8 Mr. Stanford say when you told him you wanted to quit?
9 A.
10:50:35
Nothing. Just ignored it.
10 Q.
Did you ever raise this again in the future?
11 A.
In the late summer, early fall 2008, I did.
12 Q.
What -- did you raise it with Mr. Stanford?
13 A.
I raised it directly with human resources having
14 already shared my feelings by e-mail previously, as I

10:51:00
15 testified.
16 Q.
You had testified earlier about a conversation you
17 had with Mr. Stanford about your son, Zack Davis, who was
18 a research analyst in Memphis. When did that conversation
19 take place?
10:51:12
20 A.
I would say between '07, '08.
21 Q.
And could you remind us what happened in that
22 conversation regarding your son?

23 A.
Mr. Stanford asked me if my son, Zack, would continue
24 to cook the books. And I replied, "Absolutely not, no

10:51:36
25 circumstances." And that was the end of it.

3178
THE COURT: Did he use those terms -- the term
2 "cook the books" or some other term?

3
THE WITNESS: Your Honor, I believe it was
4 would he continue to do what I was doing.

10:51:53
THE COURT: Okay.
6 BY MR. STELLMACH:
7 Q.
And your son was working as a research analyst in
8 Memphis. Did he know about the fraud?

9 A.
10:52:03
10 Q.
No, sir.
After that conversation and moving into 2008, you
11 said you spoke to human resources?
10:52:15
12 A.
Yes, sir.
13 Q.
Did you tell them that you wanted to quit?
14 A.
Yes, sir.
15 Q.
So what was your plan in terms of when you were
16 actually going to depart Stanford Financial Group?

17 A.
I spoke to Ms. Joan Stack, who was HR director for
18 Global, and a process was worked out where I would remain

19 to the end of 2009 and then retire.
10:52:43
20 Q.
Were you concerned at all that if you left and
21 stopped being CFO, that the fraud could be exposed?

22
MR. SCARDINO: Object to the term of "fraud" by
23 the government.
10:52:54
24
25
MR. SCARDINO: Ask the Court to instruct to

3179
1 discontinue using the term.

2
THE COURT: Let's not use that term.
MR. STELLMACH: I was only using it because
4 he's pled.
10:53:03
THE COURT: Well, if he uses it, that's one
6 thing, but I sustain the objection as to counsel.

7 BY MR. STELLMACH:
8 Q.
Did you have any concerns that if you left Stanford
9 Financial Group and stopped being the CFO, that the

10:53:17
10 misappropriations that you've described would be exposed,

11 the theft of CD money?
12 A.
Honestly, I really didn't. Mr. Stanford always put
13 someone in the necessary positions.

14
10:53:38
MR. SCARDINO: Object to nonresponsiveness to
15 the question.
16
THE COURT: Sustained. Not responsive.
10:53:49
18 Q.
Why weren't you concerned about leaving?
19 A.
Because I knew Mr. Stanford would find someone else
20 to do what I was doing.

21 Q.
Now, we've seen this before. It shows, Mr. Davis,
22 what the situation was at the end of '07?
10:54:26
23 A.
Yes, sir.
24 Q.
And by the end of '07, Tiers 1 and 2, the cash and
25 marketable securities, ended up to how much?

3180
10:54:40
1 A.
Together about 1.5 billion.
2 Q.
And the bank owed CD depositors how much?
3 A.
6.6 billion.
4 Q.
And the hole was there for how big?
5 A.
5 billion.
MR. STELLMACH: And if I could see Government's
7 Exhibit 1603, which has been previously admitted.

8 BY MR. STELLMACH:
9 Q.
10:55:04
This shows the amount of --
10
12 Q.
-- the amount of money loaned to Mr. Stanford over
13 the last five years. Between 2007, when the hole was
14 about 5.1 billion, to 2008, how much more was taken out of
10:55:19
15 the bank?
16 A.
400 million from '07 to '08, if I understood your
17 question.
18 Q.
19
10:55:36
That was my question.

So 400 million borrowed by Mr. Stanford
20 for what purpose?

21 A.
To either establish additional or to maintain the
22 present Stanford companies among other things.

23 Q.
When you say maintain the present Stanford companies,
24 by 2008, on a daily basis, approximately how much was it

10:55:57
25 costing to maintain those companies?

3181
1 A.
$1 million per day.
THE COURT: The 1 million per day relates to
3 what specifically again?

4
10:56:16
THE WITNESS: Maintaining the Stanford
5 companies across the globe.

6
THE COURT: Okay.
7 BY MR. STELLMACH:
8 Q.
And moving into 2008, from the end of 2007 when the
9 hole was 5.1 billion, how were CD sales performing, the

10:56:31
10 sales of new CDs?

11 A.
Moving from '07 to '08, they were still strong.
12 Q.
And then going into '08, how were they performing?
13 A.
From the end of the first quarter forward in a
14 diminishing way, extremely diminished by the fourth

10:56:52
15 quarter.
16 Q.
So when you say the first quarter, by the end of the
17 first quarter meaning March or so?
10:57:02
18 A.
Yes, sir.
19 Q.
So new CD sales were down?
20 A.
Yes, sir. Especially in relationship to withdrawals.
21 Q.
And that was my next question. How were withdrawals
22 at this point?
10:57:23
23 A.
As I indicated, the withdrawals began to increase.
24 Q.
Did there come a point when the bank had more money
25 going out that it was paying for customers who were

3182
1 redeeming CDs than it had coming in from new CD sales?

2 A.
Yes, sir.
3 Q.
And while that happens, Mr. Stanford is also spending
4 another million dollars a day?

10:57:37
10:57:46
5 A.
Yes, sir.
THE COURT: What year are we talking about now?
MR. STELLMACH: This is all 2008, Your Honor.
THE COURT: 2008.
MR. STELLMACH: 2008.
10
THE COURT: And it was closed in 2009?
11
MR. STELLMACH: February of '09.
12
THE COURT: Okay.
14 Q.
10:57:53
So we're coming up into the final days.
15
So were the returns that the bank was
16 earning on its investments in the liquid assets, the

17 marketable securities in Tier 2, were those able to offset
18 the money Mr. Stanford was taking out to cover his
19 companies or the rate of CDs being redeemed?
10:58:15
20 A.
No, sir.
21 Q.
So moving into 2008, into March, into the summer, how
22 was the bank covering, in other words, how was it able to

23 pay, CD depositors?
24 A.
10:58:36
Withdrawals were honored by the securities and cash
25 and the so-called Tiers 1 and Tiers 2.

3183
1 Q.
When you say covered, could you explain what that
2 means in terms of Tier 1, which is -- I'm sorry -- Tier 2,

3 which is marketable securities?
4 A.
10:58:58
It would mean that if there was no cash in Tier 1,
5 Tier 2 securities would be sold and turned into cash, and

6 then that cash would be used to honor the withdrawals the
7 CDs holders approached the bank with.
8 Q.
Was this situation something Mr. Stanford was told
9 about?
10:59:10
10 A.
Oh, yes, sir.
11 Q.
How were you communicating it to him?
12 A.
Well, I was communicating in person, but more
13 importantly, the president of the bank would have been

14 communicating this, I would think, on a daily basis.
10:59:31
15
MR. SCARDINO: Object to hearsay and
16 nonresponsive.
17
THE COURT: Well, he said "I would think" at
18 the end. I sustain as to that answer. And please rephrase

19 the question.
10:59:42
20
21
MR. SCARDINO: We respectfully request the
22 Court to instruct the jury to disregard the part of the

23 answer that was nonresponsive regarding what he thought the
24 president of the bank -10:59:48
25
MR. STELLMACH: I'll go back and rephrase.

3184
THE COURT: The jury is so instructed and are
2 going to rephrase it.

3 BY MR. STELLMACH:
4 Q.
10:59:56
So, Mr. Davis, were you telling Mr. Stanford about
5 this situation, the fact that the hole was growing in 2008
6 and he was taking a million dollars a day and that wasn't
7 helping things?
11:00:10
8 A.
Yes, sir. We had that conversation several times.
9 Q.
In addition to having the conversation, did you ever
10 e-mail Mr. Stanford any updates or information about the

11 bank's financial assets?
12 A.
Very frequently. Text messages between the two of us
13 would take place.

14 Q.
11:00:28
When you texted Mr. Stanford, were there -- was he
15 asking any questions about any particular types of assets?

16 A.
Yes, sir. He would ask about Tier 1, Tier 2, which
17 were the cash and the primarily securities accounts.

18 Q.
Was Mr. Stanford asking about the status of Tier 3,
19 the real estate and private equity investments of the

11:00:47
20 bank?
21 A.
No, sir.
22 Q.
Was the real estate or private equity owned by the
23 bank being sold at this point to cover redemptions?
11:00:56
24 A.
No, sir.
25 Q.
Why not?
3185
1 A.
Illiquid.
MR. STELLMACH: And if we could go to
3 Government's Exhibit 1524. Focussing on the e-mail. If we

4 could just enlarge the top portion.
10:53:07
11:01:37
5 BY MR. STELLMACH:
6 Q.
Who received this e-mail?
7 A.
It was received by Mr. Stanford and myself.
8 Q.
And who was it from?
9 A.
It was from Patricia Maldonado, who was the treasury
10 manager that -11 Q.
We talked about Ms. Maldonado before, but could you
12 just remind us what her job was as the treasury manager?

13 A.
Ms. Maldonado was in charge of reporting for and
14 routing the cash that was in Tier 2 -- Tier 1, excuse me,

11:01:57
15 in Tier 1.
16
MR. STELLMACH: And if we go to the text of her
17 e-mail where there are two asterisks. We'll enlarge the

18 entire text, and if we could just highlight transfers to
19 Tier 1, it's at the very bottom -- I'm sorry, to second
11:02:15
20 tier. It reads: "85 million."

11:02:27
22 Q.
Do you see that, Mr. Davis?
23 A.
Yes, sir, I do.
24 Q.
So, on the side, on the left-hand margin, there are a
25 bunch of initials and letters. Could you tell us what

3186
1 those represent?
2 A.
Yes, sir. The left-hand column is SIBL, the bank; TD
3 represents our correspondent account at Toronto Dominion

4 Bank in Canada.
11:02:46
5 Q.
Where you say correspondent account, what do you
6 mean?
7 A.
That's an -- that is a bank account set up in the
8 name of Stanford International Bank, Limited, similar to a

9 checking account.
11:02:57
10 Q.
Okay. And then the other letters beneath that, are
11 those also other financial institutions?
11:03:10
12 A.
Yes, sir.
13 Q.
Including HSBC?
14 A.
Yes, sir.
15 Q.
And BOH, what does that stand for?
16 A.
Bank of Houston.
17 Q.
And, so, at the bottom of Ms. Maldonado's e-mail, it
18 reads: "Transfers to second tier equal 85 million."

19
11:03:26
20 A.
What did you understand that to mean?

My understanding was that in the top line to the
21 right of -- a little bit below and to the right of SIBL,

22 there is an amount disbursed, meaning withdrawals, and my
23 understanding would be that transfers are kind of going to
24 come in to cover that.
11:03:57
25 Q.
Transfers are going to come in from where?

3187
1 A.
They would have to be from Tier 2.
2 Q.
Turning to 1525, which is about a month later,
3 March 4th of 2008.

4
11:04:34
5 overhead.
6
THE COURT: Overhead?
Thank you, Your Honor.
9
11:04:49
MR. STELLMACH: Your Honor, if I could have the
THE COURT: Pull that out a little bit. It may
10 focus it better. Pull out the focus -- the zoom, in or

11 out.
13 Q.
And, so, Mr. Davis, this is a March 4, 2008 e-mail
14 from Ms. Maldonado?

11:05:04
15 A.
Yes, sir.
16 Q.
To yourself and to Mr. Stanford?
17 A.
Yes, sir.
18 Q.
As well as several other accountings. It reads:
19 "Funds request for Star/Sun"?

11:05:19
20 A.
Yes, sir.
21 Q.
Could you remind us what companies those were?
22 A.
Commercial airlines owned by Mr. Stanford.
23 Q.
And there's an attachment reading: "Shutdown data,"
24 and then an e-mail for Mr. Stanford from Ms. Maldonado.

11:05:35
25 Could you read the e-mail for us?

3188
1 A.
Yes, sir. "We are coming to you for funding
2 pertaining to the shutdown of the two airlines. Total

3 funding request is for $5 million. Breakdown is
4 1.7 million for Sun, and 3.1 million for Star. Support
11:05:58
5 for these figures is attached. May we have your approval

6 to fund this week?"
7 Q.
At this point what had Mr. Stanford told you about
8 his plans for the commercial airlines, Caribbean Star and

9 Caribbean Sun?
11:06:15
10 A.
The latest plans, sir?
11 Q.
As of this point, yes, the shutdown data.
12 A.
His instructions, as I recall, were to shut the
13 airlines down.
14 Q.
11:06:31
What did Mr. Stanford tell you about why he was
15 shutting down the airlines?

16 A.
Cash drain.
17 Q.
Was this a topic you had discussed with Mr. Stanford
18 before, the fact that these two airlines were a cash

19 strain?
11:06:43
20 A.
Yes, sir, they had lost in excess of $500 million
21 since they were created.

22 Q.
What did Mr. Stanford tell you about why he was
23 finally shutting down the airlines in March of 2008?

24 A.
11:07:05
I don't recall as to a specific -- on this date a
25 reason, but the reason, I gathered from earlier

3189
1 conversations with Mr. Stanford, was -2
4 BY MR. STELLMACH:
11:07:13
5 Q.
Prior to this date, what, if anything, had
6 Mr. Stanford told you about the reason why he wanted to

7 shut down the airlines?
11:07:31
8 A.
That they were losing too much money.
9 Q.
And, so, it reads: "Total funding request is for
10 $5 million."
11
Why -- was there -- why is -- was there a
12 requirement for $5 million to shut down the airlines?

13 A.
It's my understanding that there were windup costs,
14 legal, administrative, termination of employees, breaking

11:07:47
15 contracts for offices and other commitments of brick and

16 mortar, airplane leases, et cetera.
17 Q.
At this point in March of '08, where would the money
18 have come from that was necessary to shut down the

19 airlines?
11:07:59
20 A.
From the CD depositors.
21 Q.
Do you know whether the airlines were ultimately shut
22 down by Mr. Stanford?
11:08:14
23 A.
Please repeat that.
24 Q.
Do you know whether Mr. Stanford ultimately did shut
25 down the airlines?

3190
1 A.
Yes, sir, they were shut down.
MR. STELLMACH: I was going to go back to the
3 laptop, Your Honor.
11:08:29
THE COURT: Okay.
Go to 1526.
7 BY MR. STELLMACH:
8 Q.
I want to jump ahead now to October of 2008. We'll
9 start with the e-mail from Ms. Maldonado toward the middle
11:08:47
10 of the page.
11
MR. STELLMACH: If we could just highlight her
12 name.
14 Q.
11:09:01
It's on October 22nd of 2008. And it was an e-mail
15 sent to you by Ms. Maldonado, and there's a long list of

16 numbers. And at the very bottom, it reads, right above
17 where her name is highlighted at the bottom, "grand
18 total."
19
11:09:15
MR. STELLMACH: Could we highlight that number,
20 406.8 million.
21
11:09:30
23 Q.
What did you understand that number to represent?
24 A.
Those were withdrawal requests from the CD holders.
25 Q.
So as of October of '08, the bank was obligated to

3191
1 pay over $400 million to depositors?

2 A.
Yes, sir. According to this e-mail and the
3 identified amounts and dates of maturities in the center

4 of the e-mail.
11:09:49
5 Q.
Okay. So if we go to TD USD, right here, these
6 maturities -- could you just explain what the numbers in

7 the left column are and the dates?
8 A.
The numbers are millions of dollars, and the date to
9 the right of those numbers indicates when the customer is

11:10:20
10 expecting to receive their withdrawal.

11
MR. STELLMACH: And if we could enlarge the
12 portion of the e-mail -- your e-mail to Mr. Stanford at the

13 very top, dated October 23rd of '08.
11:10:37
15 Q.
And could you read for us the text, the e-mail you
16 sent to Mr. Stanford?

17 A.
Yes, sir. "Regarding first tier, I project that we
18 have 35 to 45 banking days of funds remaining in accounts

19 at the present net-net withdrawal run rate. Another big
11:11:01
20 withdraw leaving Friday of 44 million."

21 Q.
So when you wrote "we have 35 to 45 banking days of
22 funds remaining at the present withdrawal rate," what were

23 you communicating?
24 A.
11:11:25
That the cash available in Tier 1 would be used up by
25 that date at the present withdrawal rate and the present

3192
1 incoming CD sales rate netted out together incoming

2 against outgoing.
3 Q.
So the bank had about another month of funds left in
4 cash?
11:11:39
5 A.
In cash, yes, sir.
6 Q.
Assuming the run rate continued at the rate it had
7 been going?
8 A.
9
11:11:49
Yes, sir.
MR. STELLMACH: If we could jump to a clip from
10 a video that's already in evidence, 1532-C. This is -- I

11 think -- 1532-C.
13 Q.
Do you recall -- while we're resolving some technical
14 issues, Mr. Davis, do you recall in October Mr. Stanford

11:12:28
15 had a meeting with a group of people of financial advisors

16 regarding the bank?
17 A.
Yes, sir. Probably the TPC meeting of October.
18 Q.
And we have a clip from that meeting we're going to
19 play at this point.

11:12:50
20
MR. SCARDINO: Mr. Stellmach, what's the date?
21
MR. STELLMACH: It's October 2008, the same
22 time period as the e-mail we just saw.
11:13:05
23
MR. SCARDINO: Thank you.
24
MR. FAZEL: We have seen it?
25
MR. STELLMACH: It is in evidence. We have

3193
1 played it with Mr. Green. He attended it.

2 BY MR. STELLMACH:
3 Q.
Do you recall why Mr. Stanford had a TPC meeting in
4 October of 2008?
11:13:30
(Whereupon, the tape was played)
THE COURT: Again, we can't hear it. We heard
7 it fine the last time.

8 BY MR. STELLMACH:
9 Q.
11:13:57
Did you recall -- did you just hear Mr. Stanford in
10 that clip say that the bank had 5.5 -- $5.5 billion too
11 much?
12 A.
Yes, sir, I believe that's what I heard.
13 Q.
And had you ever told Mr. Stanford at any point prior
14 to this that the bank was sitting on $5.5 billion too much
11:14:12
15 in cash?
16 A.
No, sir.
17 Q.
In fact, in the October e-mail we just saw, what had
18 you told him about how much money the bank had left?
19 A.
11:14:29
Told him that present run rate, we had about 30 to 45
20 days left of cash.

21 Q.
And had you ever told him, as we just heard in the
22 e-mail, that the bank was too liquid at this point in

23 time?
11:14:42
24 A.
No, sir.
25 Q.
I want to jump to 1527 an e-mail from November 11,

3194
1 2008. And we'll start with the e-mail at the bottom of

2 the page from Ms. -- I'm sorry -- is it Tarrie -- Tarrie
3 Patlan?
11:15:02
4 A.
Yes, sir.
5 Q.
To Ms. Maldonado, reading "SIBL cash balances."
6
7 A.
What information is shown there?

These are Tier 1 cash balances. Ms. Patlan was an
8 employee under the direction of Ms. Maldonado.

9 Q.
11:15:26
And if we jump to the bottom of the second page of
10 the e-mail, which goes on just listing account balances,

11 at the bottom, it reads: "Total cash 173.6 million."
12
13 A.
So what does that number represent?

This is the amount of Tier 1 cash held in the
14 Stanford International Bank, Limited, checking accounts as

11:15:53
15 it were at that date.

16 Q.
All of the bank's cash as of November 11th of '08?
17 A.
That's correct.
18 Q.
And if we go to the e-mail that was then sent to you
19 in the middle of the first page, could you read for us

11:16:12
20 what Ms. Maldonado wrote to you about?

21 A.
Yes. "Subject: SIBL cash balances. Please see
22 positions today. Tarrie will update me on client

23 outgoings for tomorrow. We are moving funds from
24 Comerica, 10 million, tomorrow and will most likely draw
11:16:38
25 down on Canadian and British pound positions next. When

3195
1 can we get some relief from the second tier?"

2 Q.
What do you understand Ms. Maldonado to be asking in
3 terms of relief from the second tier, the question she

4 wrote to you?
11:16:58
5 A.
She's asking that the Tier 2 securities be sold and
6 turned into cash and that cash be transferred to Tier 1.

7 Q.
And then if we go up toward the top of the page, you
8 wrote "working on it" to Ms. Maldonado and then sent an

9 e-mail to Mr. Stanford and you wrote "FYI"?
11:17:26
10 A.
Yes, sir.
11 Q.
Why were you notifying Mr. Stanford about the
12 situation?
13 A.
Because he was a chairman and CEO and was texting
14 back and forth and communicating by phone back and forth

11:17:43
15 monitoring the cash flow, cash drain situation, on a -16 pretty much a daily basis at that point.
17 Q.
And if we go to Government's Exhibit 1528, the next
18 e-mail. This is from December 1, 2008, just a couple of

19 weeks later.
11:18:00
20
MR. STELLMACH: Again, at the very bottom, I
21 think it's the second page, if we highlight next to total.

11:18:19
23 Q.
What's the number there?
24 A.
Total of $88.2 million.
25 Q.
And what does that represent?

3196
1 A.
I believe it is the balance of cash.
2 Q.
So by December of 2008, the bank had about
3 $88 million left in cash?
11:18:33
4 A.
Yes, sir.
5 Q.
And in order to cover CD redemptions throughout the
6 year, starting, you know, toward March when you said

7 redemptions picked up, where had the bank been getting the
8 money to do that?
9 A.
11:18:48
From Tier 1 cash.
10 Q.
And what about Tier 2?
11 A.
At this time not a significant amount of redemptions
12 in Tier 2 into cash had taken place, but this is getting

13 close to that point where redemptions in Tier 2 was the
14 only place to get the funds to honor withdrawal request.
11:19:15
15
THE COURT: Tier 2, you're saying?
16
THE WITNESS: Yes, sir. The securities
17 portfolio.
18
11:19:20
20 Q.
The marketable securities portfolio?
21 A.
Yes, sir.
22 Q.
And if we go to the top of this exhibit, just your
23 e-mail to Mr. Stanford, again, you were providing an

24 update to Mr. Stanford?
11:19:35
25 A.
Yes, sir, I am. I did.

3197
1 Q.
As these e-mails are coming in from Ms. Maldonado
2 reporting on the amount of cash that the bank needs to pay

3 out the amount of cash it has actually on hand to meet
4 depositor demands, were you speaking with Mr. Stanford as
11:19:52
5 well?
6 A.
Yes, sir.
7 Q.
Did he express any concerns to you about the
8 situation?
9 A.
11:19:59
10 Q.
Yes, sir, we were both concerned.

How concerned were you becoming starting in the
11 summer of '08?
12 A.
I was concerned. I was very concerned. Probably
13 near emotional and mental -- extreme stress levels

14 concerned.
11:20:22
15 Q.
Were you discussing the situation with the
16 accountants who worked for Mr. Lopez and Mr. Kuhrt?

17 A.
Yes, sir.
18 Q.
And you were discussing it with them as well,
19 Mr. Kuhrt and Mr. Lopez?

11:20:36
20 A.
Yes, sir.
21 Q.
Do you recall ever using the expression "the emperor
22 has no clothes"?
11:20:47
23 A.
Yes, sir, I did say that.
24 Q.
And what were you trying to communicate?
25 A.
That among other things, there wasn't going to be any

3198
1 cash infusion from the chairman of the board to cover this

2 massive withdrawal stream that we were seeing in these
3 really -- really tough economic times.
4 Q.
11:21:21
In 2008 as this began, starting in March going into
5 the summer, into the fall, were you having any

6 conversations with Mr. Stanford about how to solve the
7 problem?
11:21:34
8 A.
Yes, sir.
9 Q.
What did -- did Mr. Stanford tell you he had any
10 ideas on how to do that?

11 A.
Yes, sir.
12 Q.
What did Mr. Stanford tell you he proposed to do?
13 A.
He proposed to announce a shareholder equity infusion
14 into the bank which would strengthen the balance sheet and
11:21:58
15 very possibly for stall the insecurity of the depositors,

16 meaning slow down the withdrawals, and increase new CD
17 sales.
18
THE COURT: Well, times -- was the economic
19 downturn about that time, or was this in advance of it.

11:22:17
20
THE WITNESS: We were right in the middle of
21 it, and it was getting worse.

22
THE COURT: So people were making calls on
23 their CDs. Is that correct?

24
THE WITNESS: Minute by minute. Yes, sir.
25
3199
1 BY MR. STELLMACH:
2 Q.
So people are making calls, they want their money out
3 of the CDs, and new CD sales are down?

4 A.
11:22:43
In relationship, certainly, to the rate of withdrawal
5 request, yes, sir.

6 Q.
Not enough money coming in to pay the depositors who
7 wanted out?
11:22:55
8 A.
The writing was on the wall, yes, sir.
9 Q.
Yes, sir. So what did Mr. Stanford tell you in terms
10 of this equity infusion?

11
First of all, could you explain what the
12 term "equity infusion" means?

13 A.
It means that money would come into the bank equity
14 section; that is, unencumbered funds to bolster the net

11:23:18
15 value, net liquidity value of the bank.

16 Q.
Did Mr. Stanford tell you how much he proposed
17 announcing he had put into the bank?

18 A.
At that point, I believe it was in the neighborhood
19 of $600 million.
11:23:34
20 Q.
"At that point," meaning where are we in terms of
21 2008?
11:23:43
22 A.
Late third quarter.
23 Q.
So coming into --
24 A.
Fourth quarter.
25 Q.
-- October?
3200
1 A.
Yes, sir.
2 Q.
Did Mr. Stanford actually have $600 million in cash
3 or liquid assets, to your knowledge?
11:23:57
4 A.
No, sir.
5 Q.
Did he tell you how he proposed to obtain
6 $600 million to sink into the bank?

7 A.
Told me just make an entry into the accounting
8 records that it had been made.

9
11:24:13
THE COURT: So just on paper?
10
THE WITNESS: Paper entry, yes, sir, Your
11 Honor.
13 Q.
And we'll come to the paper entry.
14
11:24:19
15
But do you recall any specific -THE COURT: Well, let me ask you this: How you
16 would that pay off people making call on the bank? In

17 other words, it was just a paper entry.
18
Again, I'm not familiar with the banking
19 systems.
11:24:31
20
THE WITNESS: As I understood, Mr. Stanford's
21 scheme or idea was that an announcement of an infusion into

22 the balance sheet of the bank would bolster confidence
23 among investors', prospective as well as current investors.
24
11:24:53
THE COURT: So they'd stop the withdrawals, and
25 then, you'd get more CDs coming in?

3201
11:24:57
THE WITNESS: Yes, sir, that's correct.
THE COURT: At least the theory?
THE WITNESS: Yes, Your Honor.
THE COURT: Okay.
5 BY MR. STELLMACH:
6 Q.
7
These -THE COURT: Hold it. Times were tough at that
8 time; right? People needed the money out, and wasn't that
9 what's all is happening at that time? People needed the
11:25:10
10 money? Or were they just pulling it out because they lost

11 confidence in the institution, if you know?
12
THE WITNESS: My impression, Your Honor, was
13 that they had lost confidence in the world system and they
14 were afraid.
11:25:23
15
THE COURT: The world system.
16
THE WITNESS: They were afraid.
17
THE COURT: Okay.
19 Q.
11:25:31
So Mr. Stanford was going to announce he was adding
20 hundreds of millions of dollars of his own money to the

21 bank so that people would have confidence in Stanford
22 International Bank and not pull out their money and
23 possibly even draw in new CD customers?
24 A.
11:25:43
25
Yes, sir, that was my understanding.

THE COURT: Because at that time, the interest
3202
1 rates are starting to go down, and it was an excellent

2 opportunity. Is that correct?
3
4 BY MR. STELLMACH:
11:25:53
5 Q.
And if we could turn to Government's Exhibit 138.
6 This is a monthly report dated December 2008. And if we

7 turn to the second full paragraph -- I'm sorry. If we
8 turn to the second page and the paragraph in the upper
9 right-hand corner beginning "Although."
11:26:24
10
And if you could just read that paragraph
11 to us, Mr. Davis?

12 A.
Yes, sir. "Although our earnings will not meet
13 expectations in 2008, Stanford International Bank, Limited

14 is strong, safe and fiscally sound. We have always
11:26:40
15 believed that the depositor safety was our number one

16 priority. To further support the bank's growth and
17 provide a strong cushion for any further market
18 volatility, the bank's board of directors made a decision
19 to increase the bank's capital by 541 million on
11:27:01
20 November 28, 2008. This contribution brings total

21 shareholder equity to $1,020,029,802 with a
22 capital-to-assets ratio of 11.87 percent and a
23 capital-to-deposits ratio of 13.48 percent. This places
24 our bank in a position to well exceed Bazel II capital
11:27:30
25 requirements as we continue to grow in 2009."

3203
1 Q.
The number we see there, the total shareholder equity
2 is now, according to this document, being reported

3 although over a billion dollars.
4
11:27:46
Was that a number Mr. Stanford had ever
5 mentioned to you, before the fact that it's not enough

6 just to add a couple hundred million and make an
7 announcement, but to raise the total equity north of a
8 billion dollars?
9 A.
11:27:56
Yes.
10 Q.
Or to be able to announce that that had been done?
11 A.
Yes.
12 Q.
When do you recall him having that conversation with
13 you?
14 A.
11:28:13
A specific time that was discussed was October 18,
15 2008.
16 Q.
How do you recall that are date so specifically?
17 A.
Mr. Stanford had visited me in my home in
18 Mississippi.
11:28:24
19 Q.
What was the purpose for the visit?
20 A.
Well, I had just had a 60th birthday the week before,
21 and there was a little celebration for that 60th birthday;

22 but also that we needed some face time because of the
23 economic dilemma and the dilemma we had with lack of cash
24 and liquidity at the bank.
11:28:51
25 Q.
And, so, that's when -- is that Mr. Stanford tells

3204
1 you, "I want to announce the bank's capital or the equity

2 is now north of a billion dollars"?
3 A.
It was a plan. Actually, the announcement I learned
4 from, I believe it was, the accounting.

11:29:05
THE COURT: Excuse me?
MR. SCARDINO: Nonresponsive answer.
9 BY MR. STELLMACH:
11:29:08
10 Q.
So what was the plan that Mr. Stanford shared with
11 you in October?
12 A.
That there would be a formally announced equity
13 infusion by himself into the bank.

14 Q.
11:29:27
And I think you said earlier -- you testified earlier
15 that that was just going to be a bookkeeping entry, no

16 actual cash or assets were going to go to the bank?
17 A.
Yes, sir.
18
THE COURT: Even though it was going to be
19 announced publicly that at least it appeared that cash was

11:29:38
20 flowing in?
21
22
THE COURT: All right. I'm sorry. Yes, sir.
23
MR. SCARDINO: Excuse me, Mr. Stellmach.
24
11:29:48
I'll object to the question assuming facts
25 that are not in evidence, the part of the question where he

3205
1 says, but no money would be infused into the bank. He said

2 just the announcement would be made, but no money would be.
3 And I would object to the "no money would be" part of the
4 question, assuming facts not in evidence.
11:30:02
6 BY MR. STELLMACH:
7 Q.
And, so, after you had that conversation with
8 Mr. Stanford, I think you testified you were told a

9 bookkeeping entry had to be made?
11:30:13
10 A.
Yes, sir.
11 Q.
Was a bookkeeping entry made to support that
12 announcement?
11:30:25
13 A.
Yes, sir.
14 Q.
But were there any actual cash transfers or assets
15 actually transferred from Mr. Stanford or a company he

16 owned into the bank to back up that announcement?
17 A.
No, sir, there was none.
18
MR. STELLMACH: Your Honor, we're at a good
19 point.
11:30:38
20
THE COURT: Take a break. Good break time.
21 We'll take about an extra five minutes. I've got some work
22 to do back there, and I don't want to have for take a
23 longer break later.
24
11:30:51
So it's now 11:30. We'll take a 20-minute
25 break, get back in 10 minutes to 12:00. I'll raise the

3206
1 screen and see you back in 20 minutes.

2
(Recessed at 11:30 a.m.)
4
11:56:03
THE COURT: Thank you. Be seated.
Go right ahead.
7 BY MR. STELLMACH:
8 Q.
Mr. Davis, I wanted to turn to the bookkeeping entry
9 that you testified before the break to back up the

11:56:12
10 announcement that Mr. Stanford had injected several

11 hundred million dollars into the bank in capital.
12
Were you involved in that bookkeeping
13 entry?
11:56:25
14 A.
Yes, sir.
15 Q.
And I'm showing you Government's Exhibit 5. And if
16 you could go to the spreadsheet that's attached.

17
MR. STELLMACH: And if we could just enlarge
18 the upper portion of the document.

11:57:04
20 Q.
Are you familiar with this spreadsheet, Mr. Davis?
21 A.
Yes, sir.
22 Q.
How do you recognize it?
23 A.
This was shown to me by our accounting leadership,
24 Mr. Lopez, Mr. Kuhrt, and the three of us discussed it.

11:57:24
25 Q.
Is this related at all to the bookkeeping entry that

3207
1 you've been testifying about?

2 A.
Yes, sir.
3 Q.
And looking at the upper left-hand portion of the
4 document, which is enlarged right now, there's a line at

11:57:39
5 the very bottom reading "desired level," and the number

6 "1 billion" is written at the bottom.
7
8 A.
What did that number represent?

This was the target level, I mentioned earlier
9 testimony, that Mr. Stanford was -11:58:00
10
11
13 Q.
What did Mr. Stanford tell you in the earlier
14 conversation you had with him in October right before your

11:58:09
15 birthday or around your birthday about what he wanted to

16 announce in terms of the level of the bank's capital?
17 A.
The level he wanted was $1 billion.
18 Q.
And, so, here it writes -- here's it's written,
19 "desired level 1 billion."

11:58:24
20
What did that represent? You said it was
21 a target?
22 A.
Yes, sir.
23 Q.
And what needed to be done in order to hit that
24 target?
11:58:35
25 A.
An entry would have to be made in two pieces. In

3208
1 accounting there's a debit and there's a credit, and the

2 credit would go into the equity as an infusion.
3 Q.
As a contribution by Mr. Stanford into the bank's
4 capital?
11:58:55
5 A.
As a contribution by Mr. Stanford into the capital.
6 The offsetting entry would go into investments.

7 Q.
How was it decided to do that? What assets would be
8 used to support the bookkeeping entry?

9 A.
11:59:22
The assets in and around Antigua, Barbuda were real
10 estate parcels that had been purchased just months before.

11 Q.
It might be easier, I think, Mr. Davis, if we leave
12 the document for now. We'll come back to it.

13
But if I could ask you to step down and
14 walk us through a diagram that shows how the transaction

11:59:43
15 was set up.

16
THE COURT: Sir, do you want to take the
17 microphone, please, the lapel mike.

18
MR. SCARDINO: Your Honor, I will object to the
19 demonstration as it is being portrayed before the jury

12:00:48
20 because it in effect does not allow me to object to what is

21 communicated to the jury by the witness when he's writing
22 dates and names on the board.
23
THE COURT: All right. That's generally how
24 it's done with an objection like that, you do one step at a

12:01:05
25 time. He explains it as he draws it out. Very often, if

3209
1 it's even a big poster board, you have areas cleared -2 blocked by Velcro strips, and as someone explains the next
3 line, then he can take that off. So that's sustained.
4
12:01:27
Mr. Davis, if you would explain in words
5 as to what you're doing every time you write something on

6 the board.
7
MR. STELLMACH: And if I could just walk --
8 maybe it would be easier if I -9

12:01:35
THE COURT: Sure. Okay. Absolutely. Sure.
11 Q.
At the top you wrote: "2008 'flip.'"
12
THE COURT: Flip, f-l-i-p?
13
MR. STELLMACH: Flip, yes, Your Honor.
12:01:46
15 Q.
What was the flip that you're about to describe?
16 What did it involve?

17 A.
In real estate that the bank already owned and moving
18 it by legal and accounting entries into the ownership of

19 Mr. Stanford and then returning it back from Mr. Stanford
12:02:11
20 to the bank.
21 Q.
So the bank had purchased real estate. It was going
22 to be transferred to Mr. Stanford so he could send it back

23 to the bank?
12:02:22
24 A.
Yes, sir.
25 Q.
All right. And, so, the first circle, if you could

3210
1 just walk us through that.

2 A.
The first circle represents Stanford International
3 Bank, Limited. Subject here is estate.

4 Q.
12:02:34
And where was the real estate located that you're
5 talking about?
6 A.
Just offshore to Antigua, Barbuda.
7 Q.
And had this real estate been designated for a
8 specific project?
9 A.
12:02:44
10
Yes, sir.
THE COURT: When you say offshore, are these
11 the islands you were referring to or what?
12:02:52
12
13
THE COURT: The separate little islands --
14
15
THE COURT: -- that something was going to be
16 constructed upon?
17
18
THE COURT: Was that a part of the country of
19 Antigua, also within their territorial waters?

12:03:03
20
21
THE COURT: Okay.
23 Q.
And, so, what was the project that the land had been
24 acquired for originally?

12:03:10
25 A.
I believe the name of the project at this point was

3211
1 Islands Club.
2 Q.
What was the Islands Club?
3 A.
This was a project and process of Mr. Stanford, and
4 it involved building out a high-end resort, as I

12:03:33
5 understood it, that would appeal only to the ultra, ultra

6 rich of the world. They would buy parcels, pay fees, and
7 maintenance of grounds and entertainment and usage fees to
8 take place there.
9 Q.
12:03:55
10
Mr. Davis -THE COURT: Excuse me. How do you access those
11 islands, strictly by water taxi or something like that?

12
THE WITNESS: Yes, Your Honor, as far as I
13 understand it.
14
12:04:03
16 Q.
Actually, I do have a question about that. So the
17 billionaires would fly into Antigua and then take a boat

18 out to the club? Was that the idea?
12:04:15
19 A.
That's as I understood it, yes, sir.
20 Q.
All right. The real estate, though, was purchased by
21 the bank itself?

22 A.
Yes, sir, it was.
23 Q.
But who was going to own the club and operate the
24 club, assuming it was ever built?

12:04:31
25 A.
My understanding, Mr. Stanford.

3212
1 Q.
But why did the bank -- did Mr. Stanford ever explain
2 to you if he ultimately was going to own the club, why the

3 bank had purchased the real estate that the club was going
4 to be built on?
12:04:46
5 A.
Yes, sir.
6 Q.
What did Mr. Stanford tell you about that?
7 A.
As I recall, Mr. Stanford and the general counsel as
8 well, Maricio Alvarado, indicated there were other issues,

9 the major one being a marriage and divorce issue. And as
12:05:13
10 I understood it -11 Q.
Whose divorce?
12 A.
Mr. Stanford and his wife.
13 Q.
And, so, as it was explained to you by Mr. Stanford,
14 what was the reason why his divorce meant that the bank
12:05:27
15 had to purchase the real estate as opposed to him

16 personally?
17 A.
As I was told by Mr. Stanford and the general counsel
18 and Harry Failing, Mr. Stanford's tax account.

19
12:05:43
MR. SCARDINO: Object to hearsay, three
20 different people.
21
MR. STELLMACH: Well, these are all agents.
22
THE COURT: Wait a second.
23
So what are you saying, he needs to break
24 down what he heard from each?

12:05:49
25
MR. SCARDINO: That is correct.

3213
12:05:54
THE COURT: Assuming they're all admissible?
MR. SCARDINO: Right.
THE COURT: Correct?
MR. SCARDINO: Yes.
THE COURT: I'm not ruling on your objection to
6 admissibility. All right. Sustained as to that question.

7 See if we can break it down.
8 BY MR. STELLMACH:
9 Q.
12:06:08
What did Mr. Stanford tell you about why the bank had
10 to purchase the real estate as opposed to why he couldn't

11 do it himself? How did his divorce impact that decision?
12 A.
As I understand it from Mr. Stanford, the bank
13 itself -14
12:06:20
MR. SCARDINO: I'm sorry, Mr. Davis.
15
I'll object to what he understands, rather
16 than if he specifically can answer the question asked by

17 Mr. Stanford.
18
THE COURT: Sustained as to the response. I
19 think you can clear -- Mr. Davis, we need to know what you
12:06:30
20 were told by Mr. Stanford, okay?

21
22
THE COURT: Go right ahead. Now you -- is
23 that -- state it that way. What did -- I'll ask the

24 question. What did Mr. Stanford tell you about this
12:06:42
25 matter? Now you may proceed.

3214
THE WITNESS: Mr. Stanford said that the bank
2 itself was a gift from his father, and, therefore, in a

3 divorce settlement, the gift, Stanford International Bank,
4 Limited, would be exempt from distribution to his wife in a
12:07:07
5 divorce settlement. That's the reason he told me that it

6 was done that way.
7 BY MR. STELLMACH:
8 Q.
As opposed to Mr. Stanford buying the land personally
9 and owning it in his own name?

12:07:20
10 A.
Exactly.
11 Q.
Or in the name of a shell company he had set up?
12
13
12:07:27
15 Q.
Could Mr. Stanford have used any one of his shell
16 companies, his numerous shell companies that he had set

17 up, to avoid the problem with the divorce in breaking up
18 the land?
12:07:38
19 A.
That's beyond my understanding, sir.
20 Q.
Fair enough.
21
But Mr. Stanford explained because of his
22 divorce, the bank had to hold title to the land?
12:07:55
23 A.
Yes, sir.
24 Q.
Okay. How much had the bank spent to buy the land?
25 A.
Two parcels, a total of $63.5 million.

3215
1 Q.
When was the land purchased?
2 A.
2008.
3 Q.
Do you remember approximately? Was it earlier in the
4 year, middle of the year?

12:08:08
5 A.
Between early summer and third quarter.
6 Q.
Did Mr. Stanford ever discuss the purchase price that
7 the bank had paid for the land with you?
12:08:22
12:08:44
8 A.
Yes, sir, he did.
9 Q.
Did he tell you whether he thought the bank had
10 overpaid or gotten a great deal on the purchase price?

11 A.
He said that it was too much, that he was robbed.
12 Q.
$63-1/2 million was too high a price?
13 A.
Yes, sir.
14
15
THE COURT: Well, overruled as to that
16 question. We'll go one question at a time, although it was

17 leading. Go on.
19 Q.
12:08:53
And then could you show us what happened next or what
20 was going to happen next in this flip?

21 A.
(Indicating) the parcel of real estate that SIBL
22 owned would be moved under the ownership of Mr. Stanford.

23 Q.
And why is there an arrow, 63-1/2 mill, showing that
24 transfer? What does that represent?

12:09:37
25 A.
That was the cost of the parcels of land.

3216
1 Q.
So how much on the -- in terms of bookkeeping was
2 Mr. Stanford going to be paying for that land to get it

3 from the bank?
4 A.
12:09:58
As I understand the worksheet, the same price, same
5 cost.
6 Q.
So he would get land at the same price the bank had
7 paid?
12:10:07
8 A.
Yes, sir.
9 Q.
And then what was going to happen once the land had
10 been transferred to Mr. Stanford?

11 A.
(Indicating.) The real estate would be transferred
12 from Mr. Stanford back to the bank at $3.2 billion.

13 Q.
When was the transfer from Mr. Stanford to the bank
14 going to take place?

12:10:40
15 A.
16
The fall of 2008.

THE COURT: So it was going to him, according
17 to your diagram, the 63 million, and then it was going to

18 be transferred back to the bank at 3.2 billion?
12:10:57
19
20
THE COURT: Okay.
22 Q.
And how close in time was that transfer going to take
23 place from the time when the bank acquired the land at
24 63-1/2 million?
12:11:08
25 A.
Approximately four months.

3217
1 Q.
Where did the value of 3.2 billion for this expected
2 bank asset come from?

3 A.
There were some smaller real estate transactions in
4 the vicinity, and the amount per acre of those

12:11:43
5 transactions was the unit amount of money that was used in

6 the calculation to come up with the 3.2 billion.
7
THE COURT: I don't understand that. Break it
8 down, please.
9
12:12:00
11 Q.
So the land had been purchased for $63-1/2 million;
12 is that correct?
12:12:06
13 A.
Yes, sir.
14 Q.
Had any improvements been made to it?
15 A.
No, sir.
16 Q.
So nothing had been changed in the land from the time
17 it was purchased by the bank to the time it was going to

18 be transferred to Mr. Stanford and then back to the bank?
12:12:26
19 A.
20 Q.
Who put a value of 3.2 billion on that real estate?
21 A.
The value was put by Mr. Stanford, the actual --
22 Q.
Who did the calculation?
23 A.
The calculation was done by the accounting team under
24 Mr. Kuhrt and Mr. Lopez.

12:12:54
25 Q.
So the land that -- was about 1,500 acres,

3218
1 1,600 acres?
2 A.
I believe 1,532, maybe.
3 Q.
And to go back to the Court's question, how was the
4 number used to multiple that 1,500 or so acres to get to

12:13:12
5 3.2 billion? Where did that number come from?

6 A.
Basically the cost of $63.5 million divided by the
7 acreages that were purchased.

8 Q.
I'm sorry. I'm not asking the question artfully.
9
12:13:29
Was there a comparable, another piece of
10 real estate, that was used to value this real estate and
11 arrive at a 3.2 billion valuation?
12 A.
Yes, sir. That's my understanding, yes, sir.
13 Q.
Who decided which real estate to use as a comparable,
14 as a comparison point, to value this real estate?

12:13:44
15 A.
Mr. Kuhrt, Mr. Mark Kuhrt, in accounting.
16 Q.
He was the controller?
17 A.
Local controller, yes, sir.
18 Q.
To your knowledge, was there any outside appraisal
19 done or expert who was brought in to value the land?

12:14:03
20 A.
No, sir.
21 Q.
And, so, the land that Mr. Kuhrt used as a
22 comparable, were you familiar with that land?
12:14:20
23 A.
Somewhat, yes, sir.
24 Q.
How did it compare to the land at issue here, the
25 1,500 or so acres that we're talking about?

3219
1 A.
Well, it was of smaller parcels, and it was in an
2 improved state.
3 Q.
Well, that's the question I had. When you say it was
4 in an improved state, was it developed?

12:14:35
5 A.
It was developed land, yes, sir.
THE COURT: Like, what was sitting on it?
MR. STELLMACH: Right.
THE WITNESS: Housing and landscaping and
9 utilities to it, roads -12:14:51
10
THE COURT: Was that --
11
THE WITNESS: -- infrastructure.
12
THE COURT: Was that located on the mainland or
13 also on some outlying islands?

14
12:15:00
THE WITNESS: It was located on an outlying
15 island.
17 Q.
But this outlying island had roads and utilities on
18 it?
12:15:06
19 A.
Yes, sir.
20 Q.
And this particular parcel that we're talking about,
21 the 1,500 acres that the bank had purchased, did it have
22 buildings on it?
12:15:21
23 A.
24 Q.
Was it set up for utilities and roads and developed
25 in the same way that the comparable property on the other

3220
1 island had been?

2 A.
No, sir.
3 Q.
And nothing had been done, as you've testified, in
4 the four months from when the bank purchased it to when it

12:15:32
5 was going to be transferred back to the bank at a

6 5,000 percent markup?
7 A.
No, sir.
8 Q.
And, again, this was 2008. Can you remind us in
9 terms of the world economy what was happening to the

12:15:46
10 markets?
11 A.
It was the worse downturn since the Great Depression.
12 They were plummeting.

13 Q.
And when the markets are plummeting, this real estate
14 appreciates 5,000 percent through this calculation that

12:16:02
15 Mr. Kuhrt did?

16
MR. SCARDINO: Your Honor, I'll object to the
17 leading question. He's testifying -18
THE COURT: Hold it. I understand the
19 question. Overruled.
12:16:11
20
Is that what we've heard? Sir? From your
21 testimony?
22
23
THE COURT: Okay.
12:16:23
25 Q.
And this transaction that was proposed -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3221
THE COURT: It was -- wait a second. Was it
2 proposed or did it actually go through?
12:16:33
MR. STELLMACH: That was my question.
THE COURT: I'm sorry. I'll back off.
5 BY MR. STELLMACH:
6 Q.
Could you answer the Judge's question?
THE COURT: No, answer your question. You
8 phrase it the way you want to, please.

9 BY MR. STELLMACH:
12:16:43
10 Q.
Was this transaction that was actually proposed
11 actually completed?
12 A.
No, sir, it was not.
13 Q.
So these transfers of the land from the bank to
14 Mr. Stanford and back to the bank, to your knowledge, was

12:16:57
15 the paperwork and all the necessary transactional

16 documents, were those completed to make that legally
17 happen?
12:17:10
18 A.
No, sir.
19 Q.
That didn't happen, but we saw in Government's
20 Exhibit 138, the December 2008 monthly report, that there

21 was an announcement that the capital of the bank had been
22 raised to over a billion dollars?
12:17:24
23 A.
Yes, sir.
24 Q.
So even this -- these entries that you're describing,
25 did they ever take place?

3222
1 A.
They were never completed, to my knowledge.
THE COURT: In other words, there were no deeds
3 or anything else done, it was evidenced by accounting

4 figures?
12:17:37
THE WITNESS: That's correct, Your Honor.
6 BY MR. STELLMACH:
7 Q.
And I think, Mr. Davis, if you could take the stand.
8 And I wanted to go back to the attachment to Government's

9 Exhibit 5.
12:18:00
10
MR. SCARDINO: Mr. Stellmach, what exhibit are
11 you referring to?

12
MR. STELLMACH: Government's Exhibit 5, the
13 spreadsheet we had just been looking at, upper left-hand

14 portion, the same portion we had seen enlarged before. I
12:18:12
15 know we have a little more context for it.

17 Q.
So under "acres," there's a total of 1,500 or so
18 acres?
12:18:26
19
THE COURT: Where are we looking at?
20
MR. STELLMACH: I'm sorry, Your Honor.
21
THE COURT: Oh, there it is. Okay.
23 Q.
What did that number represent? What was that a
24 total of?
12:18:32
25 A.
A total of the column above that number. It's a

3223
1 total of the individual real estate parcels.
12:18:57
2 Q.
And the number next to it under cost, 63-1/2 million?
3 A.
It was the price actually paid for those acres.
4 Q.
And then the 3.173 billion market number?
5 A.
That was a calculation done of the individual
6 acreages line by line basically times the $2 million per

7 acre.
8 Q.
Using the value for this other developed property to
9 value the 1,500 undeveloped acres here?

12:19:19
10 A.
Yes, sir.
11
MR. STELLMACH: And if we turn to the right
12 side of this document of the spreadsheet, if we could -13 yes, just enlarge that.
12:19:35
15 Q.
Could you explain to us what these breakdowns are
16 involved? It says Company A, Company B, Company C,

17 Company D.
18 A.
Yes, sir. It's a rather complicated analysis
19 accounting-wise, but it basically states that the parcels

12:19:55
20 of real estate were, dollar-wise, inflated in value. And

21 those values, once inflated, were used to eliminate
22 individual capital contributions in A and B.
23 Q.
Could I ask you to stop there, Mr. Davis, for a
24 moment?
12:20:23
25 A.
Yes, sir.
3224
1 Q.
And going back to the diagram you drew. So in the
2 diagram you drew, you show the real estate being

3 transferred back from Mr. Stanford to the bank at 3.2 -4 $3.1 billion. Am I reading that accurately?
12:20:38
5 A.
Yes, sir.
6 Q.
And then the breakdown here, what does this reflect
7 was going to happen once that value had been transferred

8 back to the bank?
9 A.
12:20:56
Once the bookkeeping and legal was completed,
10 starting from the top, where it says "Company A, 200

11 million; Company B, 641 million," those were two announced
12 capital infusions that never really actually happened. No
13 dollars ever changed hands. And, so, part of the
14 3.2 billion bookkeeping contribution was going to be used
12:21:21
15 to offset those two announced fictitious capital

16 infusions.
17 Q.
So the highlighted entries on this form, are those --
18 are those a breakdown of how the 3.2 billion was going to

19 be split up, once it went back to the bank, how it was
12:21:38
20 going to be treated on the books of the bank?

21 A.
Yes, sir.
22 Q.
And, so, the first two entries totaling 741 million,
23 those were going to support the capital infusion number?
12:21:49
24 A.
That's correct.
25 Q.
And then Company C, value equal to 1.7 billion loan

3225
1 offset?
2 A.
Yes, sir. Just below that high -- okay. Yes, sir.
Company C, the 1.7 billion loan pertains
4 to eliminating the loans that Mr. Stanford had taken out

12:22:11
5 and owed to the bank.

6 Q.
So this was also going to be used, this real estate,
7 to pay off all of the loans that Mr. Stanford had taken
8 out?
9 A.
12:22:24
10 Q.
Yes, sir. That was the plan.

And then Company D, it reads, "733 million market
11 value remaining of real estate."

12
Was that the amount left over after the
13 capital contribution and the loan had been paid off?
12:22:42
14 A.
Yes, sir. That would be a balance.
15 Q.
And what was the intention of how to use that -- what
16 was the plan on how to use that money?

17 A.
As I recall, it was there to use for future
18 bookkeeping entries similar to these.

19 Q.
12:23:05
So another 700 million left in the kitty, so to
20 speak, to pay any future expenses or credit for future

21 withdrawals by Mr. Stanford?
22 A.
Yes, sir.
23 Q.
And, again, this was all proposed. None of it ever
24 actually happened? That real estate was never transferred

12:23:19
25 from the bank?

3226
1 A.
That's correct.
2 Q.
Was there ever any announcement by the bank or by
3 Mr. Stanford that no assets had, in fact, been transferred

4 to the bank to support the announcement that had been made
12:23:31
5 to the financial advisors and to the depositors about him

6 raising the capital to over a billion dollars?
7 A.
No, sir.
8 Q.
If we could just go back to the e-mail that this was
9 attached to, very quick question. It goes from Mr. Kuhrt

12:23:50
10 to Mr. Lopez.
11
Could you just remind us where Mr. Kuhrt
12 was working at the time this was all happening?

13 A.
Working in global headquarters in St. Croix as global
14 controller reporting to Mr. Stanford.

12:24:06
15
THE COURT: How come the world headquarters was
16 in the Virgins Islands instead of Houston? Was there a

17 reason for that?
18
THE WITNESS: Yes, Your Honor. It was done for
19 tax reasons.
12:24:17
20
THE COURT: Okay. That's right. I'm sorry.
21 You mentioned that before. Okay.

12:24:27
23 Q.
And then Mr. Lopez, where was he based?
24 A.
In Houston, Texas.
25 Q.
So this e-mail with this attachment would have been

3227
1 sent by Mr. Kuhrt from outside the country to Mr. Lopez

2 here in Houston?
3 A.
That's correct.
4
12:24:43
THE COURT: Just to fill in, St. Croix, Virgin
5 Islands, is that British Virgin Islands or the U.S. Virgin

6 Islands?
7
THE WITNESS: U.S.
THE COURT: And they do have tax breaks on the
9 Virgin Islands versus the mainland?

12:24:53
10
THE WITNESS: Yes, sir. It's known as an
11 economic development zone.

12
14 Q.
12:25:08
And moving into 2008, we've -- you've testified
15 before about an SEC investigation back in 2005 and 2006.

16
Did there come a point in 2008 when that
17 investigation heated up again?
12:25:25
18 A.
Yes, sir.
19 Q.
How did you find out about that?
20 A.
From -- I found out from our general counsel.
21
THE COURT: By the way, did the SEC ever take
22 you-all up on the invitation to come down under those

23 conditions, I guess, to visit with Mr. King, and did they
24 ever come down to the islands to do that?
12:25:42
25
THE WITNESS: No, Your Honor.

3228
THE COURT: Okay.
2 BY MR. STELLMACH:
3 Q.
And what did Mr. Alvarado tell you about the
4 investigation?
12:25:50
MR. SCARDINO: Object to the hearsay.
MR. STELLMACH: May I respond?
THE COURT: Overruled. Not the exact words.
8 As a result of discussing with him, do it that way, please.

9 BY MR. STELLMACH:
12:26:01
10 Q.
As a result of discussing the SEC investigation with
11 Mr. Alvarado, what do you understand about the seriousness

12 of that investigation?
12:26:13
13
THE COURT: At what stage?
14
MR. STELLMACH: This was -- I'm sorry.
15
THE COURT: 2008?
12:26:27
17 Q.
It's 2008, and I think it was December?
18 A.
December -- first st week in January of 2009.
19 Q.
Okay. After speaking with Mr. Alvarado, what did you
20 understand about the seriousness of the SEC's

21 investigation?
22 A.
That it was very serious to Mr. Alvarado, for sure.
23 He said --
12:26:38
24
THE COURT: No, can't say what he said.
25

3229
THE COURT: That's hearsay.
2 BY MR. STELLMACH:
3 Q.
Although Mr. Alvarado was the general counsel of the
4 bank?
12:26:43
5 A.
6
Yes, sir.
THE COURT: What he's saying is hearsay. You
7 can get around that.

8 BY MR. STELLMACH:
9 Q.
12:26:56
When Mr. Alvarado told you that it was serious, what
10 did he tell you about the nature of the investigation,

11 what the investigation -- what did you understand the
12 investigation was focussing on?
12:27:04
13
MR. SCARDINO: That's hearsay.
14
THE COURT: All right. How do you get around
15 it, Counsel?
16
MR. STELLMACH: Mr. Alvarado is the general
17 counsel of the bank.
12:27:11
18
THE COURT: And therefore?
19
MR. STELLMACH: An agent of Mr. Stanford. It's
20 not hearsay. It's in 801(D)(2)(d).

21
MR. SCARDINO: I'll respectfully submit that's
22 not been established.

23
MR. STELLMACH: That Alvarado is the general
24 counsel? I think the witness has testified about that.

12:27:22
25 That's sufficient.
3230
MR. SCARDINO: If, in fact, if that is -- I got
3 stuck. Too many facts in there.
12:27:33
THE COURT: Yes.
MR. SCARDINO: Then there would be a privilege
6 issue if he represents Mr. Stanford.

7
MR. STELLMACH: He represents the bank. He's
8 the general counsel of the bank, and the bank has waived
9 all privilege. They're the receiver.
12:27:44
10
MR. SCARDINO: It's been established that
11 Mr. Stanford owned the bank 100 percent. We would object

12 on the privilege issue.
12:27:55
13
14
MR. STELLMACH: So -- I'm trying to remember
15 why we even got into this argument.

16
THE COURT: No. No. You can ask him what the
17 man said.
12:28:02
18
MR. STELLMACH: Right.
19
THE COURT: That's where we started.
21 Q.
What did Mr. Alvarado tell you about the SEC's
22 investigation?
23 A.
He said, quote, "Jim, this is serious shit. You've
24 got to get Mr. Stanford engaged. We have to have a

12:28:18
25 meeting. They have subpoenaed you -- subpoenaed you and

3231
1 Mr. Stanford."
2 Q.
Did Mr. Alvarado tell you what the investigation was
3 focussing on?
12:28:31
4 A.
Yes, sir.
5 Q.
And what did he tell you about that?
6 A.
Said the focus was on their desire at the SEC in
7 Fort Worth office, their desire to see a complete

8 breakdown of the assets of Stanford International Bank,
9 specifically the investment assets.
12:28:52
10 Q.
After that conversation with Mr. Alvarado, did you
11 discuss the investigation with Mr. Stanford?
12:29:09
12 A.
Yes.
13 Q.
Where did that discussion take place?
14 A.
It took place in Mr. Stanford's offices in St. Croix,
15 U.S. Virgin Islands.

16 Q.
And approximately when did it take place?
17 A.
Early to mid January 2009.
18 Q.
What did Mr. Stanford say in that conversation about
19 whether he would subpoena -- he would testify or provide

12:29:30
20 documents in response to a subpoena?

21 A.
I don't recall what Mr. Stanford said, but at the
22 meeting the three of us --
12:29:49
23
MR. SCARDINO: I'll object to nonresponsive.
24
THE COURT: Rephrase it. Thank you.
25

3232
1 BY MR. STELLMACH:
2 Q.
What did you tell Mr. Stanford about whether you
3 would testify?
4 A.
12:30:01
12:30:28
I told him that I wasn't going to lie to the SEC. If
5 I went, I was going to tell the truth.

6 Q.
Even though you had been lying since 1991, 1992?
7 A.
Even though I had been lying for 16, 17 years.
8 Q.
Why not lie under oath to the SEC?
9 A.
Number one, I drew a line in the sand. Number two,
10 if you lie under oath, the future is not very bright, as

11 far as things staying free and clear of a multitude of
12 issues. There's never -- I thought to myself, there's
13 never a time -- a bad time to tell the truth. It's never
14 too late. So that was my commitment then.
12:30:52
15 Q.
What did Mr. Stanford say when you told him you
16 wouldn't testify falsely if you actually went in to speak

17 with the SEC?
18 A.
Basically that Mr. Mauricio Alvarado and outside
19 counsel to Mr. Alvarado were working the program, the

12:31:13
20 process out, to deal with the subpoenas and the upcoming

21 meeting and that a future meeting would take place that
22 Mr. Stanford would chair and have the leadership of the
23 brokerage and the bank at that meeting and go ahead and
24 finalize the details of the upcoming SEC meeting.
12:31:38
25 Q.
Did Mr. Stanford identify who this other lawyer was

3233
1 who was going to represent the bank with the SEC?
12:31:56
2 A.
Yes, sir. Mr. Tom Sjoblom.
3 Q.
Where was Mr. Tom Sjoblom based?
4 A.
United States, in the East. I believe in Washington.
5 Not sure, could have been New York.

6 Q.
Did there come a time when a meeting actually did
7 take place involving Mr. Stanford and other executives at

8 the Stanford organization?
9 A.
12:32:11
12:32:28
Yes, sir, there was a meeting held.
10 Q.
When was that meeting held approximately?
11 A.
Middle of January 2009.
12 Q.
Where was the meeting?
13 A.
At a Stanford Aviation hangar in Miami Airport.
14 Q.
Who attended?
15 A.
Myself; Mr. Mauricio Alvarado, general counsel;
16 Mr. Tom Sjoblom, consultive counsel to Mr. Alvarado and

17 the group; Juan Rodriguez, the president of the bank;
18 Mr. Danny Bogar, president of the brokerage; Ms. Lena
19 Stinson, global compliance officer; and Ms. Laura Holt,
12:33:02
12:33:11
20 the chief investment officer.

21 Q.
What about Mr. Stanford? Was he there physically?
22 A.
No, sir.
23 Q.
Did he participate?
24 A.
Yes, sir. He called in by telephone conference.
25 Q.
And during that meeting, did Mr. Sjoblom, the lawyer

3234
1 who'd been brought -2
THE COURT: Is he -- with a was there's a firm
3 in New York or Washington?
12:33:24
MR. STELLMACH: Yes, he is, Your Honor.
THE COURT: I'm just going to ask you. It's a
6 matter of I don't think intention.

7
8
What firm was he with?

MR. STELLMACH: It was Proskauer Rose, Your
9 Honor, in New York. I think Mr. Sjoblom is based in the

12:33:33
10 New York and D.C. offices.

11
THE COURT: Okay.
13 Q.
So, Mr. Davis, during that meeting, did Mr. Sjoblom
14 explain in any more detail what the SEC was looking for by
12:33:46
15 way of information regarding the bank and its assets?

16
THE COURT: Hang on one second.
17
MR. SCARDINO: Hearsay and privilege.
18
THE COURT: Overruled. It's either a "yes" or
19 "no."
12:33:55
20
21
THE COURT: Counsel, why isn't it privilege?
22
MR. STELLMACH: Mr. Sjoblom represented the
23 bank, and the privilege has been waived by the receiver.
12:34:07
24
THE COURT: Privilege has been waived by who?
25
MR. STELLMACH: The receiver.

3235
THE COURT: By the receiver. Okay.
MR. SCARDINO: I would submit to the Court that
3 there is also information that is -- that the prosecution

4 has shared with us, and Mr. Sjoblom at one point in time
12:34:16
5 did actually represent Mr. Stanford.

6
MR. STELLMACH: Well, that never actually
7 happened. There's a conversation that takes place much

8 place later, and we've taken great pains, Your Honor, to
9 making nobody at this table knows what happened at that
12:34:27
10 conversation for reasons I don't know if we want to discuss

11 in front of the jury, but I'm comfortable.
12
THE COURT: Okay. I'm ready to rule.
13
12:34:35
Counsel, you object. Is that correct?
14
MR. SCARDINO: That is correct.
15
17 Q.
What did Mr. Sjoblom tell you the SEC wanted to know?
18 A.
Wanted to know the detail that would fully describe
19 the holdings of assets for Stanford International Bank,

12:35:00
20 Limited, specifically the detail of each and every detail

21 of the investment and the investment house or the
22 financial institution, where those investments were held.
23 Q.
Did Mr. Sjoblom at any point also show you subpoenas
24 that the SEC had issued for your testimony and information
12:35:23
25 regarding the bank?

3236
1 A.
They were on the table, sir.
MR. STELLMACH: I'm showing the witness
3 Government's Exhibits 26A, B and C.

4 BY MR. STELLMACH:
12:35:34
12:35:48
5 Q.
Do you recognize those documents, Mr. Davis?
THE COURT: Government's 26A B and C?
THE WITNESS: Yes, sir, I've seen this.
MR. STELLMACH: Your Honor, we offer those.
10
THE COURT: They're in.
11
MR. STELLMACH: They're in.
13 Q.
We'll turn to 726 C, which I think is the bank
14 subpoena.
12:36:01
15
THE COURT: This is an SEC -- a Securities and
16 Exchange Commission subpoena. Is that correct? Just for

17 the record.
12:36:09
18
MR. STELLMACH: Mr. Davis -- yes, it is.
19
THE COURT: It is.
20
THE WITNESS: Excuse me. Yes, sir.
21
THE COURT: I just want to get it in for the
22 record.
23
Go on.
12:36:12
25 Q.
And it's addressed to Stanford International Bank,

3237
1 care of you as the CFO.

2
And could you read what it -- the checked
3 box directly beneath it, reading, "You must produce."

4 A.
12:36:29
Yes, sir. "You must produce everything specified in
5 the attachment to the subpoena to officers of the

6 Securities and Exchange Commission, at the place, date and
7 time specified below."
8
MR. STELLMACH: And could we just turn to the
9 attachment to get a sense of what it was. Specifically

12:36:45
10 Page 2 of the attachment, the next page. Those are all

11 definitions. I'm sorry.
13 Q.
What were the documents that the SEC was seeking? In
14 general terms, not marching through every single item.

12:37:02
15 A.
They wanted a listing, an itemized list, of the fair
16 value of each and every investment or financial asset in

17 the SIBL investment portfolio.
18 Q.
And in addition to seeking documents, was the SEC
19 also seeking testimony from any officers of the

12:37:28
12:37:40
20 organization?
21 A.
Yes, sir.
22 Q.
You received a subpoena. Is that correct?
23 A.
Yes, sir.
24 Q.
And Ms. Holt was also subpoenaed?
25 A.
Yes, sir, that's correct.

3238
1 Q.
Was there any discussion in this meeting about who
2 should testify before the SEC?
12:37:56
3 A.
Yes, sir, there was.
4 Q.
What was the decision made about who should actually
5 go in and testify?
6 A.
Decision was made that Juan Rodriguez, the president
7 of the bank, and Laura Holt, the chief investment officer

8 of Stanford Financial Group Limited, and Inc.
9 Q.
12:38:14
Now you've testified previously that --
10
THE COURT: Who made that decision?
11
THE WITNESS: That decision was made by
12 Mr. Stanford.
12:38:23
13
THE COURT: You mean, on the phone?
14
THE WITNESS: On the phone.
15
THE COURT: Okay. Thank you.
16
THE WITNESS: He was on the phone during that
17 meeting, Your Honor.

19 Q.
12:38:31
Was there any discussion about how Ms. Holt or
20 Mr. Rodriguez, the bank president, could testify about all

21 of the bank's assets when all they knew about was Tiers 1
22 and 2, the cash and the marketable securities?
23
MR. SCARDINO: I'll object to the leading
24 question.
12:38:42
25

3239
THE WITNESS: Yes, there was.
2 BY MR. STELLMACH:
3 Q.
Was there a discussion about the next steps that
4 would be taken so that they could testify about the entire

12:38:55
5 portfolio of the bank before the SEC?

6 A.
7 Q.
And what role were you going to play in enabling them
8 to testify about all the assets?

9 A.
12:39:13
My role was to delineate or itemize the assets that
10 were held in the so-called Tier 3 investment section.

11 Q.
Which nobody else at the meeting had seen at that
12 point, the people who were physically present had seen?
12:39:31
13
MR. SCARDINO: Object to leading.
14
15
THE WITNESS: That's the section that no one
16 else at that time had seen, yes, sir.

17
THE COURT: That testimony has already been
18 elicited many different ways already.
12:39:40
19
MR. STELLMACH: Yes.
20
THE COURT: The reason why it was a leading
21 question, but I allowed you to go ahead. Go on.

23 Q.
So in terms of the people who were present at this
24 meeting in the Miami hangar and who were participating by

12:39:52
25 phone, who actually knew of the contents of Tier 3 were?

3240
1 A.
Mr. Stanford and myself.
2 Q.
Did Mr. Stanford express any concerns in this meeting
3 about the SEC and what they might uncover?
12:40:10
4 A.
No, sir.
5 Q.
Did he ever express any opinion to you about the
6 capability of the SEC in uncovering any misconduct?

7 A.
Yes, he did.
8 Q.
When did he -- when did that conversation take place
9 or that remark take place?

12:40:28
10 A.
Between -- at a time between this meeting at the
11 hangar and the first week of February.
12:41:05
12 Q.
What did Mr. Stanford say about the SEC?
13 A.
Firstly, if I may, I asked the question of how --
14
THE COURT: You asked a question of who, sir?
15
THE WITNESS: Mr. Stanford. I asked the
16 question of Mr. Stanford, how this was going to take place

17 knowing that there is no Tier 3?
12:41:14
19 Q.
When did you ask that question of Mr. Stanford?
20 A.
Between --
21 Q.
After the hangar meeting?
22 A.
After the hangar meeting, prior to the first week in
23 February.
24
12:41:23
His response was, "Just give them the same
25 report that you give to the regulators in Antigua which

3241
1 lists all of the fictitious holdings per financial

2 institution, so they won't know the difference. They're
3 not that smart."
4
12:41:44
And, so, I said, "Well, they are that
5 smart, and they will know, and I'm not going to share that
6 with them."
7 Q.
And then you said that there was another meeting that
8 takes place later after this in the first week of

9 February?
12:42:02
10 A.
Yes. At the meeting at the hangar.
11 Q.
Well, I'm sorry. Go ahead.
12 A.
I was just going to state at the meeting at the
13 hangar, Mr. Stanford said, "Well, let's meet again in two

14 weeks, first week of February in Miami together, and we
12:42:22
15 will complete preparation for this upcoming meeting with

16 the SEC."
17 Q.
And, so, also in January, were there any other
18 meetings of the Top Producers Club?
12:42:37
19 A.
Yes, sir.
20 Q.
Where were those held?
21 A.
One was held in Miami with the foreign financial
22 advisors; that is, those in other countries working for

23 other Stanford companies. And there was one also in
24 Arizona, and that one was a directed toward the financial
12:43:00
25 advisors who were located in the United States.

3242
1 Q.
Were you able to speak with Mr. Stanford at either of
2 these meetings?
12:43:20
3 A.
Yes, sir.
4 Q.
What was discussed? Which meeting did you speak with
5 him, at the Miami or Phoenix meeting?

6 A.
We had conversation at both meetings.
7 Q.
Do you recall discussion with Mr. Stanford about
8 obtaining more CD sales from Libya, from the Libyan

9 government?
12:43:33
10 A.
Yes, sir.
11 Q.
What did Mr. Stanford tell you about the Libyan
12 government in those conversations?

13 A.
Well, he said that there was connection between Libya
14 and the Europe office with -- through our financial

12:43:51
15 advisor by the name of Peter Siragna and that they had

16 been clients in the past, and that he was going to take a
17 trip to Libya and speak with them regarding additional
18 business.
19 Q.
12:44:10
By "additional business," what do you understand
20 Mr. Stanford to be referring to?

21 A.
Sales of certificates of deposits.
22 Q.
Was he clear about that, that he was talking about
23 CDs?
12:44:20
24 A.
Yes, sir.
25 Q.
Did Mr. Stanford ever tell you later whether he

3243
1 actually made that trip?

2 A.
Yes, sir.
3 Q.
And what did he tell you about his efforts to obtain
4 additional sales?
12:44:30
5 A.
That no additional sales were obtained, to my
6 knowledge. That's what he said.

7 Q.
So we're now turning to the first week of February.
Where did you go? Where did you travel
9 to?
12:44:49
10 A.
Miami, Florida.
11 Q.
And remind us, what was the purpose of going to
12 Miami?
13 A.
It was a follow-up meeting to the one mentioned
14 earlier at the hangar a couple of weeks before. This

12:45:03
15 meeting was called to finish preparation for a

16 presentation to be made to the SEC in Fort Worth, Texas.
17 Q.
Was that where the testimony was going to take place,
18 in Fort Worth?
12:45:22
19 A.
Yes, sir.
20 Q.
Who showed up at the meeting the first day?
21
THE COURT: Where?
22
MR. STELLMACH: In Miami.
23
THE WITNESS: The Miami Stanford offices,
24 Biscayne Bay.
12:45:36
25
Mr. Juan Rodriguez, the president of the

3244
1 bank; myself; Ms. Lena Stinson, global compliance officer;

2 Mr. Mauricio Alvarado; general counsel; Mr. Tom Sjoblom,
3 consultive counsel to Mr. Alvarado and to Stanford;
4 Mr. Danny Bogar, president of the brokerage, Stanford
12:46:07
5 Group, headquartered in Houston. I believe -- believe that

6 was the ones on Monday, the people that arrived on Monday.
7 BY MR. STELLMACH:
8 Q.
Was Mr. Stanford -- was the plan that Mr. Stanford
9 would also be there in Miami?

12:46:27
10 A.
Yes, sir, of course.
11 Q.
On the first day, though, was he present?
12 A.
No, sir.
13 Q.
So what happened the first day that you showed up
14 with these individuals and Mr. Stanford hadn't shown up

12:46:39
15 yet?
16 A.
Late midmorning, Mr. Alvarado and Mr. Sjoblom said
17 that since Mr. Stanford is not there -18
MR. SCARDINO: If I can have a running
19 objection as to what the lawyer said.

12:46:54
20
THE COURT: Absolutely. You are granted a
21 running objection.
22
THE WITNESS: It was decided to break up the
23 meeting since Mr. Stanford had not yet arrived.

12:47:07
25 Q.
What happened the next day?

3245
1 A.
In addition to the individuals that I just mentioned
2 that were in attendance, the chief investment officer,

3 Laura Holt, arrived, the meeting was convened. And about
4 midmorning, 10:00 or 10:30 Mr. Stanford had still not
12:47:35
5 arrived. And after a few phone calls, I was able to get

6 in touch with Mr. Stanford, who was still in the U.S.
7 Virgin Islands. And he asked what was going on, and I
8 said that "Well, the meeting's convened. We're waiting on
9 you."
12:47:55
10
MR. SCARDINO: Request it be question and
11 answer.
12
THE COURT: Okay. Question and answer.
14 Q.
12:48:01
And what did Mr. Stanford say when you told him
15 everyone was waiting on him?

16 A.
He asked what was going on.
17
And I said, "Well, for one thing, Mr. Juan
18 Rodriguez has a question for you."
12:48:17
19 Q.
Did you tell him what the question was?
20 A.
I put him on speakerphone to the group, and he
21 said -22
THE COURT: Who is "he"?
23
THE WITNESS: I'm sorry. That Mr. Stanford
24 said, "What is it, Juan?"

12:48:26
3246
12:48:37
1 Q.
And what did Mr. -- did Mr. Rodriguez say anything?
2 A.
He did.
3 Q.
What did he say?
4 A.
He said, "There is a queue" -- in other words, a
5 line -- "of client customers of Stanford International

6 Bank, Limited requesting withdrawals. And we need X
7 amount of dollars to honor those withdrawals."
12:49:03
8 Q.
And what did Mr. Stanford say?
9 A.
After Mr. Rodriguez gave him the number, he said,
10 "Okay. I'll be there tomorrow. I've got your money and

11 I'll be there tomorrow."
12:49:22
12 Q.
Did you speak with Mr. Stanford later that day or no?
13 A.
No, sir.
14 Q.
And what day of the week are we at now? Is this
15 Wednesday?
16 A.
We were speaking of Tuesday.
17 Q.
Tuesday. What happened on Wednesday? Did
18 Mr. Stanford show up?
12:49:35
19 A.
No, sir.
20 Q.
Did you do anything to try to reach him or contact
21 him?
12:49:46
22 A.
Yes, sir.
23 Q.
What did you do?
24 A.
I called again, as I did the previous day. I was
25 able to speak with his, I believe, fiancee at the time.

3247
1 Q.
And we're not going to get into that conversation,
2 but did there come a point later on Wednesday when you

3 were able to speak with Mr. Stanford directly?
12:49:59
4 A.
Directly, yes, sir.
5 Q.
And what did Mr. Stanford say to you?
6 A.
He said that he had had his head up his ass and that
7 he was now ready to come to the meeting, fly to Miami, and

8 lead us out of the wilderness.
9 Q.
12:50:27
Was that an expression that you recall him using, "To
10 lead you out of the wilderness"?

11 A.
Verbatim.
12 Q.
And on -- what happened the next day, Thursday?
13 A.
Well, the meeting with the attendees to the meeting
14 as mentioned earlier began about 9:00 o'clock.

12:50:45
15
THE COURT: So this is on Thursday; correct?
16
17
THE COURT: Thursday, the fourth day that
18 you've been there?
12:50:50
19
20
21
MR. STELLMACH: And if we could pull up
22 Government's Exhibit 332.

23
Thank you, Your Honor.
12:50:59
25 Q.
Do you recognize this document, Mr. Davis?

3248
1 A.
Yes, sir, I do.
2 Q.
And what was it -- or what is it?
3 A.
This is a chart that I prepared while in Miami that
4 week.
12:51:13
5 Q.
And reading the title of the chart, can you explain
6 to us -- or just read that title for us?

7 A.
"Tier 3, 6.3 billion, private equity sectors and
8 asset classes."
9 Q.
12:51:33
Okay. And so --
10
THE COURT: Since it was -- who actually had
11 knowledge of Tier 3? It was you and Mr. Stanford and

12 anyone else?
12:51:43
13
THE WITNESS: Prior to this moment?
14
15
THE WITNESS: The two of us, Your Honor.
16
THE COURT: So you drew this up on the computer
17 yourself?
12:51:51
18
THE WITNESS: I did.
19
THE COURT: All right. Was it distributed to
20 everybody or you just held on to it?

21
THE WITNESS: It was not distributed. I held
22 on to it, Your Honor, until it was similarly displayed

23 before the attendees at this meeting on a screen, overhead
24 screen.
12:52:09
25
THE COURT: Was that after Mr. Stanford

3249
1 arrived?
2
THE WITNESS: No, sir.
THE COURT: In other words, you let them know
4 what tier -- that there was a Tier 3?

12:52:16
THE WITNESS: Yes, sir --
THE COURT: Okay.
THE WITNESS: -- I did.
THE COURT: Now, did Mr. Stanford eventually
9 arrive, let's put it that way?

12:52:22
10
THE WITNESS: Yes, sir, he eventually came.
11
THE COURT: So this was done before he arrived
12 there?
14 Q.
12:52:27
And, so, we're --
15
17 Q.
We're still on Wednesday. Mr. Stanford hasn't shown
18 up yet.
12:52:33
19
THE COURT: I thought we were on Thursday.
20
THE WITNESS: Thursday morning.
22 Q.
I'm sorry. Thursday morning. Mr. Stanford hasn't
23 shown up yet.
24
12:52:43
And you put together this pie chart. It
25 reads: "6.3 billion in Tier 3, private equity sectors and

3250
1 asset classes, 30 June 2008."

2
12:53:04
This was prepared when?
3 A.
February -- first week in February of 2009.
4 Q.
Why were you using June 30th of 2008 as the date?
5 A.
This was the date of the last closing of the books
6 for Stanford International Bank, Limited -7 Q.
And --
8 A.
-- and the last published report.
9
12:53:15
THE COURT: Was that published?
10
THE WITNESS: It was, sir. The six-month
11 report.
12
MR. STELLMACH: Of the information.
13
THE WITNESS: Not this, but he asked me about
14 the date.
12:53:22
15
THE COURT: That's what I mean, so I'm not
16 following that.
18 Q.
All right. And, so, why do you have the values and
19 the information in here as of June 30th of 2008 even

12:53:32
20 though it wasn't prepared, according to your prior

21 testimony, until February -- January, February of '09?
22 Why date it as of June of '08?
23 A.
That was the last closing of the books represented in
24 the bookkeeping side.

12:53:48
25 Q.
Were those the most current numbers you had to work

3251
1 with?
12:53:57
2 A.
Yes, sir.
3 Q.
So that's why there's a six- or seventh-month lag --
4 A.
Right.
5 Q.
-- from when you put it together?
6 A.
Yes, sir, correct.
7 Q.
And there are a number of -- of assets broken down
8 here. Retails -- I'm looking at the upper left-hand

9 quadrant showing different investments, wireless
12:54:13
10 technology, travel, entertainment, healthcare,

11 manufacturing. Were these private equity investments?
12:54:26
12 A.
Yes, sir, they were.
13 Q.
Owned by the bank?
14 A.
No, sir.
15 Q.
Well, owned by which company?
16 A.
Stanford Venture Capital Holdings as shell company
17 and also somewhere owned by Stanford Financial Group

18 Company.
19 Q.
12:54:41
But treated -- but for purposes of this chart, they
20 were credited to the bank?

21 A.
For the purposes of this chart, yes, sir.
22 Q.
And the value we see in the lower half is about --
23 50.7 percent is in real estate?
12:54:57
24 A.
25 Q.
So that according to the chart, the total is

3252
1 6.3 billion. That's about 3.1 billion and change?

2 A.
3 Q.
What was the real estate being identified in the
4 chart?
12:55:11
5 A.
In Antigua, Barbuda.
6 Q.
Did it have any relationship to the real estate we
7 just looked at involving the flip?
12:55:26
8 A.
The one and the same.
9 Q.
So it's the same real estate that had been inflated
10 from 63-1/2 million at its purchase price to 3.2 billion

11 through the flip process that was never completed?
12 A.
12:55:36
Correct.
13
MR. SCARDINO: Object to the term "inflated."
14
MR. STELLMACH: That was the witness.
15
THE COURT: Hold it. Overruled.
17 Q.
So, Mr. Davis, there are values placed on the private
18 equity investments that are seen here. Obviously if

19 something is 7 percent like the wireless technology in the
12:55:51
20 middle of 6.3 billion, there's been a value assigned to

21 them. Who came up with those valuations?
22 A.
The answer is in pieces. The private equity came
23 from our earlier testimony, the valuation process that

24 came from Mr. Kuhrt, Mr. Lopez. And valuation of the top
12:56:22
25 private equity individual items such as travel,

3253
1 entertainment, water, wireless, financial, et cetera, came

2 from a listing from the capital markets group. And the
3 third piece over on the right side notes receivable.
4 Those notes were the notes Mr. Stanford had made with the
12:56:46
5 bank based on the monies that he had pulled from the CD

6 depositors.
7 Q.
So that's the 2 billion and change in notes he had
8 taken out of the bank or loans he had taken?

9 A.
12:56:57
10 Q.
Yes, sir.
But with respect to the private equity that was here
11 being shown as a bank asset, were the values shown

12 accurate or not?
12:57:09
13 A.
They were inflated above cost.
14 Q.
Who inflated them?
15 A.
I did. They came from a listing from California
16 markets group, and I took the higher values on most cases

17 that they gave me and added some on two or three items
18 myself.
19 Q.
12:57:32
And the real estate you've testified about before,
20 was it your testimony that that was also inflated?

21 A.
Yes, sir. Above cost, approximately 5,000 percent.
22 Q.
So the 6.3 billion value that you were showing in
23 Tier 3, was that an actual value?
12:57:50
24 A.
It's a lie.
25 Q.
But this was the pie chart you were showing the
3254
1 people attending that meeting in Miami?

2 A.
Yes, sir.
3 Q.
When you showed them the pie chart, did you explain
4 to them that the numbers in it, the values, are a lie?

12:58:06
5 A.
I showed them that they were inflated over cost at
6 so-called a market.
7
THE COURT: Where did you get those numbers
8 from? I mean, now that you're finally showing Tier 3 -9

12:58:25
10
THE COURT: -- were those accurate?
11
THE WITNESS: No, sir. As I said, they were
12 inflated. They were a lie. It was a lie.

13
THE COURT: Let me ask you this: Why was it
14 inflated for these folks who were finally finding out that
12:58:38
15 there's a real problem?

16
THE WITNESS: It was, Your Honor, in an effort
17 to hook -- hook to the total amount reported so-called real

18 Tier 1, real Tier 2, plus the hole.
12:58:58
12:59:04
19
THE COURT: I'm not following.
20
THE WITNESS: Okay. It was --
21
THE COURT: No, no, I'll leave it to counsel.
22
23
THE COURT: Do you see what I'm saying?
24
MR. STELLMACH: I do, Your Honor.
3255
1 Q.
So the bank's assets consisted of Tier 1 and Tier 2,
2 that was about 25 percent?
12:59:14
3 A.
Yes, sir.
4 Q.
That number had been dropping throughout 2008 in
5 order to cover CD redemptions?

6 A.
Yes, sir.
7 Q.
So there was now a difference between what the people
8 at the meeting knew, because they knew about Tiers 1 and 2

9 and the bank's total reported assets?
12:59:27
10 A.
That is correct.
11 Q.
And what did that 6.3 billion-dollar number that you
12 inflated to represent Tier 3 represent?

13 A.
The number -- the difference between Tier 1 and
14 Tier 2 total in what was reported in the balance sheet of

12:59:46
15 Stanford International Bank, Limited.

16 Q.
So --
17 A.
It was a plug.
18 Q.
So to cover the assets that were being reported, and
19 the assets that the people at the meeting actually knew,

12:59:55
20 that hole was about 6.3 billion as of January, February of

21 '09, in that neighborhood?
22 A.
Yes, sir, in that neighborhood.
23 Q.
So you backed into that number by inflating the
24 values?
01:00:08
25 A.
That's correct.
3256
MR. STELLMACH: One last question on this, Your
2 Honor.
3 BY MR. STELLMACH:
4 Q.
01:00:14
When you showed the people at the meeting, these
5 executives in the organization, what the content of Tier 3

6 was without telling them that the numbers were a lie like
7 you just told us, just when they saw the content, how did
8 people react?
9
01:00:29
MR. SCARDINO: I'll object to form of the
10 question. It's generic. Which person is he referring to?

11
12
13

General impression.
THE WITNESS: The general impression given to
14 me was one of shock, mouths fell open. They were taken

01:00:47
15 back.
16
THE COURT: Well, was that a reaction you were
17 expecting or were you trying to get these folks just to be

18 relieved that there was some other assets somewhere around?
01:01:01
19
THE WITNESS: I think the former, Your Honor.
20
THE COURT: What?
21
THE WITNESS: That this is what is there.
22
THE COURT: Well, was it there or was it not
23 there? That's what I'm not following. In other words, it

24 was shown to them for a purpose. Was the purpose that you
01:01:17
25 thought you'd get, was that the reaction?

3257
THE WITNESS: I thought that I would get that
2 reaction.
3 BY MR. STELLMACH:
4 Q.
01:01:29
But you were trying to show the people -- were you
5 trying to show the people at the meeting that there was

6 actual value in Tier 3?
7 A.
01:01:40
I believe so, yes, sir.
THE COURT: So was it a positive shock?
10
THE COURT: Okay. Let's leave it.
11
THE WITNESS: Negative.
12
THE COURT: Let's leave it right there. We can
13 pick up that later.
01:01:46
14
15
THE COURT: First thing to do, let me get the
16 screen up.
17
Ladies and gentlemen, we'll take our lunch
18 break. Please be back ready to resume at 2:15. We'll see

19 you at that time.
02:14:09
20
(Recessed at 1:01 p.m.)
21
22
23
24
02:21:02

Go right ahead.
MR. STELLMACH: Your Honor, replace the screen,
25 please?
3258
THE COURT: Oh, absolutely. On its way.
2 BY:
3 BY MR. STELLMACH:
4 Q.
02:21:14
Mr. Davis, I want to go back to this pie chart which
5 you showed at the Miami meeting to the other senior

6 executives before Mr. Stanford sowed up Thursday that
7 first week in February of '09?
8
Prior to that meeting, had people at that
9 meeting been led to think that there was about

02:21:31
10 $6.3 billion in value in Tier 3?

11
12 form of the question, had people been led to believe, and

13 ask you to narrow -14
02:21:42
MR. STELLMACH: I think I did narrow it to the
15 people who were attending the meeting.

16
THE COURT: Okay. It's narrowed. Thank you.
17
19 Q.
02:21:49
20
And you then -THE COURT: So -- wait a second. So these
21 people knew a Tier 3 existed, but they didn't know what was
22 in it, is that the deal?
02:21:58
23
24
3259
1 Q.
But they had been led prior to the meeting to think
2 it was in the neighborhood of $6.3 billion?
02:22:07
3 A.
Correct.
4 Q.
And you -- I think you had explained that you then
5 used that total number when inflating the values of the

6 different assets shown here to back into the 6.3 billion?
7 A.
Yes, sir.
8 Q.
Prior to the meeting, though, what had people been
9 led to believe about the types of assets that were in

02:22:22
10 Tier 3?
11 A.
That they were the same styled and content of what
12 was in Tier 2.
13 Q.
So, for example, had people at the meeting been told
14 about any real estate investments by the bank?

02:22:39
15 A.
No, sir.
16 Q.
Had they been told about any private equity
17 investments by the bank?
02:22:50
18 A.
No, sir.
19 Q.
Or the existence of any loans to Mr. Stanford
20 Reflected in the right-hand quadrant of the -- of that

21 chart?
22 A.
No, sir.
23 Q.
So the executives who were attending this meeting in
24 Miami, had they been told anything different about the

02:23:03
25 assets and the value of Tier 3 than what the depositors

3260
1 had been told or the financial advisors?

2 A.
No, sir.
3 Q.
So when you showed people this pie chart and you said
4 that the reaction was one of shock, what was your

02:23:19
5 understanding about what people were shocked by at the

6 meeting?
7 A.
There was shareholder loans --
MR. SCARDINO: Excuse me. I would object to
9 him asking a question about what somebody else felt.

02:23:30
10
MR. STELLMACH: I'll clean it.
11
THE COURT: Okay. Sustained. In other words,
12 how does he know that that's why there was a problem, if

13 they were.
02:23:39
15 Q.
Did people express shock at the meeting?
16 A.
They did.
17 Q.
What specifically did people say, if you can remember
18 the individuals?
19
02:23:50
20 hearsay.
21
THE COURT: Sustained. You can say in essence.
23 Q.
02:23:58
In essence what did they say?
24
THE COURT: Well, no. In essence --
25
MR. STELLMACH: I had to try, Judge.

3261
1 BY MR. STELLMACH:
2 Q.
Let me ask it this way --
THE COURT: Let's see now, don't answer, sir.
4
02:24:06
Go on.
5 BY MR. STELLMACH:
6 Q.
Regarding the note receivable to Mr. Stanford, which
7 is reflected here in the neighborhood of 1.7 to

8 $2 billion, that was -9
02:24:24
THE COURT: What was the essence of what they
10 said, not in their exact words, but just generally.

11
THE WITNESS: They were taken back in a
12 negative way that there were notes receivable from

13 Mr. Scardino. They were taken back in a negative way that
14 there were 51 percent of the Tier 3 at least on this chart
02:24:45
15 indicative of real estate holdings.

17 Q.
And what about the private equity, the other piece of
18 Tier 3?
19 A.
02:24:57
In a lesser degree, yes, they were taken back
20 negatively about the composition of Tier 3.

21 Q.
Did anyone cry?
22 A.
Several people cried, yes.
23 Q.
Do you remember if Mr. Bogar, the president of the
24 brokerage firm, how he reacted?

02:25:12
25
THE COURT: Do you remember?

3262
THE WITNESS: I certainly do.
2 BY MR. STELLMACH:
02:25:23
3 Q.
How did he react?
4 A.
The very next morning he reacted by sitting down
5 getting ready the meeting to begin and he broke down in

6 sobs, in tears.
7 Q.
So on Thursday you show the pie chart, and you
8 testified people were shocked. At this point, did you

9 tell the people at that meeting that the values in this
02:25:43
10 pie chart were inflated?

11 A.
I don't believe so, no, sir.
12 Q.
So you were telling them in general terms what was in
13 Tier 3, but were you telling them the actual value of the
14 assets in Tier 3?
02:25:58
15 A.
No, sir.
16 Q.
After you had this presentation, what happened next?
17 When people had that reaction, what happened next?
02:26:22
18 A.
Essentially Mr. Stanford finally arrived after that.
19 Q.
He arrived that afternoon?
20 A.
Middle of the day.
21 Q.
And when Mr. Stanford arrived, what took place in the
22 meeting?
23 A.
I believe he sat down with the others. I stood up
24 and said, "This is what was reported by myself this

02:26:37
25 morning." Put this chart up on the screen, and explained

3263
1 section by section what had been shared.

2 Q.
So you went through your presentation again with
3 Mr. Stanford present?
02:26:54
4 A.
I did.
5 Q.
Were the other people in the room still there?
6 A.
Every one of them, yes, sir.
7 Q.
At the end of your presentation, did Mr. Stanford say
8 anything?
9 A.
02:27:02
Yes, he did.
10 Q.
What did he say?
11 A.
Mr. Stanford took the floor, I sat down, and he said,
12 "It's just as Jim has shared in this chart."
02:27:25
13 Q.
Did he say, "I just learned about this myself"?
14 A.
No, sir. He said that he was responsible for this,
15 it's his fault, and he's very sorry.

16 Q.
Did he say that there were international accounting
17 standards that allowed him to tell the depositors one

18 thing about the bank's assets and to do another in
19 reality?
02:27:39
20 A.
I don't recall that.
21 Q.
Do you recall Mr. Stanford every saying that in the
22 time you worked for him, that because of some

23 international accounting standards, he could tell
24 depositors something different than what he was doing with
02:27:53
25 the assets of the bank?

3264
1 A.
I don't recall him saying that.
2 Q.
And, so, does Mr. Stanford at this meeting say
3 anything else, after this presentation has happened, and

4 he says -- he confirms what you've told them, do you
02:28:04
5 recall anything else that he said?

6 A.
Yes, sir. He said that that is, in fact, the truth
7 and that beyond that, there's actually much more value

8 that is reported in that chart.
9 Q.
02:28:31
So Mr. Stanford said he believed there was more than
10 even 6.3 billion in value in the Tier 3 assets?

11 A.
Yes, sir. He said that they had real brick and
12 mortar assets, real assets worth more than depicted in

13 this chart, yes.
14 Q.
02:28:49
Do you remember anyone asking any questions about the
15 financial statements of the bank which had been issued for

16 years, whether there were any inaccuracies in them?
02:29:03
17 A.
Mr. Juan Rodriguez.
18 Q.
He was the president of the bank?
19 A.
Yes, sir.
20 Q.
What did Mr. Rodriguez say?
21 A.
He asked if his financials were correct.
22 Q.
His financials meaning what financials?
23 A.
The bank's SIBL's financials, the bank that he was
24 president of.
02:29:17
25 Q.
And who responded to that question?

3265
02:29:36
1 A.
I believe I did.
2 Q.
And what did you tell Mr. Rodriguez?
3 A.
I told him that financials were not correct.
4 Q.
Did Mr. Stanford contradict you and say that's not
5 true?
6 A.
No, sir.
7 Q.
In fact, at any point in the presentation you made
8 when you were walking through this pie chart and showing
9 the types of assets, at least, that were in Tier 3, did
02:29:50
10 Mr. Stanford ever contradict anything you said other than

11 insisting the value was, in fact, larger?
12 A.
No, sir.
13 Q.
Once Mr. Stanford arrived, what happened in the
14 meeting?
02:30:03
15 A.
Well, there was a -- there were a lot of tears, a lot
16 of remorse.
17 Q.
Who was showing remorse?
18 A.
I suppose Mr. Stanford was. He was hugging necks,
19 and there were tears.

02:30:31
20 Q.
What happened? Did the meeting then end?
21 A.
I believe a meeting did break for the day, and it
22 resumed again on Friday morning.

23 Q.
Before the meeting resumed on Friday, did you speak
24 at all with Mr. Stanford privately, just the two of you?

02:30:53
25 A.
I did.
3266
1 Q.
Where did you have that conversation?
2 A.
Well, I know we did meet in the lobby of the hotel in
3 the lobby bar reception, concierge's area of the hotel,

4 Intercontinental, which was adjacent to the office.
02:31:11
5 Q.
Now, before Mr. Stanford showed up and you had gone
6 through this pie chart first with the executives and then
7 again with him present, had you told him this is what you
8 were going to do?
9 A.
02:31:29
I don't believe I told him that this is what I was
10 going to do. I told him -- we had made a -- if I might -11
12
14 Q.
02:31:40
What had you told Mr. Stanford you would do at the
15 meeting?
16 A.
Configure what was in Tier 3 as part of the
17 presentation to support the presenters that were going to

18 present at the SEC meeting.
19 Q.
02:31:56
But in configuring what was in Tier 3, did you tell
20 him you were going to break out and identify the loans,
21 for example, that he had taken?
22 A.
Not specifically, no.
23 Q.
Or disclose the actual contents of the Tier 3
24 portfolio?
02:32:09
25 A.
No, I did not.

3267
1 Q.
So that night, when you're speaking with Mr. Stanford
2 in the lobby bar of the hotel, what -- did he say anything

3 to you about what had happened during the day?
02:32:30
4 A.
Yes, he said I was naive and that I had melted.
5 Q.
Was that the word he used?
6 A.
He said, "Jim, you melted. If I had been there, I
7 would have never let you have done that."
02:32:48
8 Q.
What did you say to Mr. Stanford?
9 A.
I looked at him and said, "You weren't here."
10 Q.
And then you speak with -- then there's another
11 meeting the following day, the next Monday?
02:32:59
12 A.
No, sir. There was a meeting --
13 Q.
I'm sorry. The next Friday?
14 A.
-- Friday. Friday morning we had a meeting.
15 Q.
Who was at that meeting?
16 A.
The individuals that I shared with you before. CIO,
17 the global compliance officer, the chief counsel.
02:33:24
02:33:34
18 Q.
So Ms. Halt, Mr. Alvarado?
19 A.
Yes, Ms. Halt, Mr. Alvarado, Mr. Rodriguez,
20 Mr. Bogar, Mr. Schoblum, Mr. Stanford, and myself.

21 Q.
And --
22 A.
Ms. Stinson as well.
23 Q.
Who is Ms. Stinson?
24 A.
Global compliance officer.
25 Q.
And I think you had said this was the meeting at

3268
1 which Mr. Bogar, the president of the brokerage firm,

2 sobbed?
3 A.
Yes. Just before it began, he broke down at the
4 table.
02:33:45
5 Q.
What happened when Mr. Bogar was sobbing?
6 A.
Mr. Schoblum, at the other side of the table, got up,
7 walked around the table behind Mr. Bogar, put his arms -8 hands on Mr. Bogar's shoulder and said a prayer.
9 Q.
02:34:11
10 A.
Did Mr. Stanford eventually show up at this meeting?

He was there, yes.
11
THE COURT: What day now are we talking about?
12
THE WITNESS: Friday, Your Honor.
13
THE COURT: Okay.
02:34:19
15 Q.
During the meeting, was there any decision made about
16 the next steps to take concerning the information that had

17 been disclosed?
18 A.
There were some steps shared by Ms. Lena Stinson,
19 yes, the compliance officer. She stated that there had to

02:34:35
20 be a five -- I believe it was five -21
MR. SCARDINO: Object to the hearsay.
23 Q.
24
02:34:43
Ms. Stinson was the -- I'm sorry, Mr. Davis.

MR. STELLMACH: I'll just establish the
25 foundation, Your Honor.

3269
THE COURT: Go on.
2 BY MR. STELLMACH:
3 Q.
Who was Ms. Stinson, again? She was the compliance
4 officer?
02:34:48
5 A.
Yes.
6 Q.
For what company?
7 A.
The global group of companies, which would have put
8 her over the brokerage as well as chief compliance

9 officer.
02:34:59
10 Q.
So an employee of Mr. Stanford's companies?
11 A.
Yes.
12
MR. STELLMACH: So on that basis, Your Honor, I
13 intend to ask the witness: What did Ms. Stinson say at the
14 meeting?
02:35:09
15
MR. SCARDINO: I don't think there's an
16 objection to hearsay the way it's phrased.

17
THE COURT: I agree. Sustain the objection.
02:35:18
19 Q.
Which company did Ms. Stinson work for?
20 A.
Stanford Financial Group Global, I believe, was the
21 titled name, a St. Croix company.
02:35:31
22 Q.
And who owned that company?
23 A.
Mr. Stanford.
24 Q.
The entire company?
25 A.
Yes, sir.
3270
1 Q.
02:35:43
What did Ms. Stinson say at the meeting?
MR. SCARDINO: Renew my objection.
THE COURT: How do you get around it?
MR. STELLMACH: She is an employee of
5 Mr. Stanford's company, acting within the scope of her role

6 as compliance officer.
7
THE COURT: But is the -- is the Company A
8 party to this suit?

9
02:35:53
MR. STELLMACH: Well, it's one of the companies
10 that's rolled into -- I mean, a number of the companies are

11 because of the way they were being financed, but she was
12 invited to this meeting for the reason of -- because of her
13 role as compliance officer of that company.
14
02:36:07
MR. SCARDINO: I don't remember seeing where
15 invitees are an exception to the hearsay.

16
THE COURT: That's what I mean.
17
MR. STELLMACH: I'll firm it up.
18
19 BY:
02:36:11
21 Q.
What was the company Ms. Stinson worked at?
22 A.
It was either Stanford Financial Group Global or
23 Stanford Financial Group Company or both.

24 Q.
02:36:31
And which company -- you worked for Stanford
25 Financial Group?
3271
1 A.
Yes, sir.
2 Q.
And what was the role of Stanford Financial Group in
3 the Stanford organization?

4 A.
02:36:41
It was to provide legal compliance advertising,
5 promotion, accounting and other related services to the

6 entire affiliated group of Stanford-owned companies.
7
MR. STELLMACH: Your Honor, on that basis, I
8 think we satisfy the exception.

9
02:36:54
THE COURT: Hang on one second. Let me look it
10 up. I'm reading from the evidence book.

11
Now, are you alleging that this woman was a
12 co-conspirator?
02:37:18
13
MR. STELLMACH: No, Your Honor.
14
THE COURT: All right. So E is out. So
15 looking at D -16
MR. STELLMACH: That's right.
17
THE COURT: -- correct?
18
Parties, agent or servant, the parties.
19 The party is Mr. Stanford?

02:37:30
20
MR. STELLMACH: That's correct.
21
THE COURT: All right. Is she her -- is she
22 his agent?
23
MR. STELLMACH: She is through the company that
24 he wholly owns.
02:37:37
25
THE COURT: That's the concern I've got. I

3272
1 don't mind telling you. Okay. So you see the point that
2 I'm making out of an abundance of caution?
3
MR. STELLMACH: And out of abundance of
4 caution, Your Honor, we could also elicit it not for the

02:37:50
5 truth but merely for the fact that this is what Ms. Stinson
6 said -7
THE COURT: And then what?
MR. STELLMACH: Then it's not hearsay. We're
9 not offering it for the truth.

02:37:55
10
THE COURT: I know. But for what purpose are
11 you -12
MR. STELLMACH: For the effect on the state of
13 mind of the people who were present who include

14 Mr. Stanford as well as this witness.
02:38:02
15
MR. SCARDINO: Well, the state of the mind of
16 the people present is not relevant.

17
THE COURT: No, you're talking about state of
18 mind he was present, he's a defendant --
02:38:11
02:38:19
19
MR. STELLMACH: Exactly.
20
THE COURT: -- correct?
21
MR. STELLMACH: That's right, Your Honor.
22
THE COURT: Or party?
23
MR. STELLMACH: Yes.
24
THE COURT: Don't answer, sir. What was the
25 question exactly? What did -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3273
MR. STELLMACH: What did Ms. Stinson propose?
THE COURT: Concerning?
MR. STELLMACH: Concerning the information that
4 had just been disclosed at the meeting.

02:38:27
THE COURT: And now, what happened after that?
6 Was some action taken based upon what her suggestion was?
7
MR. STELLMACH: There were some decisions made.
8 I think she had some ideas, as well as some of the other

9 attendees.
02:38:35
10
THE COURT: I'm just saying was some decision
11 made based upon what she said?

12
MR. STELLMACH: I believe so, Your Honor.
13
MR. SCARDINO: Well, Mr. Davis isn't a party to
14 this case. I mean, he is a co-defendant, but that

02:38:45
15 Exception D refers to a party or an agent.

16
THE COURT: I understand. I'm looking at
17 the -- I'm looking at Mr. Stanford being the primary person

18 here.
19
02:38:58
MR. STELLMACH: He is the primary person, Your
20 Honor.
21
THE COURT: No, no. You just need to tell me
22 was some action taken based upon what this woman said?
23
MR. STELLMACH: Based upon what she said as
24 well as Mr. Schoblum, the lawyer, who had been hired for
02:39:09
25 the bank.
3274
THE COURT: All right. I think -- overrule the
2 objection for that limited purpose. I understand that I've

3 given it the best I can, and I think it's within the Rule
4 that way -02:39:19
MR. SCARDINO: Your Honor --
THE COURT: -- because some action was taken
7 based upon what she said.

8
MR. SCARDINO: So it's offered not for the
9 truth of the matter, then?

02:39:25
10
THE COURT: That's correct.
11
MR. STELLMACH: Merely for this is what she
12 proposed?
13
THE COURT: All right. Ladies and gentlemen of
14 the jury, you're so instructed. In other words, not

02:39:31
15 getting into whether it's true or accurate as to what she

16 said, but because of what she said, some action was either
17 taken or not taken. I gather some action was taken. So
18 just to show a statement was made and, therefore, an action
19 took place, I'm allowing it in for that limited purpose.
02:39:48
20
Go right ahead.
21 BY:
23 Q.
During the meeting, what did Ms. Stinson propose
24 should be done in light of the information that had been

02:39:55
25 shared about Tier 3?

3275
1 A.
She proposed that the financial statements would have
2 to be restated backwards, the years impacted by the amount

3 of time that this type of reporting in Tier 3 had taken
4 place.
02:40:16
THE COURT: You mean -- I didn't understand
6 by -- retrofitted, in effect?
7
THE COURT: What does that -- I'm sorry.
9 That's not the word he used. Have to be -02:40:26
10
MR. STELLMACH: Restated.
11
THE COURT: Restated. What does that mean?
13 Q.
Could you explain why the information that you had
14 shared about Tier 3 meant that any action had to be taken

02:40:35
15 with the financial statements of the bank going back

16 before this meeting?
17 A.
Yes, sir. This is a basic accounting fraud
18 reporting --
02:40:48
19
20
THE COURT: Sustained. We'll get -- if you
21 want him to characterize it as an accountant himself later

22 on, fine. Let's get to the facts and then --
02:41:05
23
MR. STELLMACH: If I could, I'll just --
24
THE COURT: The problem is that one word -- by
25 the way, fraud, if any, it's going to be up to you. And

3276
1 I'm looking at the jury, in other words. So the ultimate

2 issue is relative to what is or what is not fraud.
3 Eventually I'll provide you that -- what is it -- the
4 appropriate instruction before you commence your
02:41:23
5 deliberations.
6
Go on.
7 BY MR. STELLMACH:
8 Q.
The financial statements that have been issued by the
9 bank up until this moment, had you explained during that

02:41:33
10 meeting whether those statements were accurate or not?

11 A.
Yes, I did. I said that they were not accurate.
12 Q.
And what did Ms. Stinson propose to do regarding
13 these prior financial statements that had been issued

14 which contained inaccurate information?
02:41:49
15 A.
Restate them accurately.
16 Q.
And when you say restate them, what does that mean?
17 What needed to be done with the earlier financial

18 statements for the bank?
19 A.
02:42:05
The earlier financial statements of the bank, the
20 numbers in the balance sheet and profit and loss statement

21 and the footnotes would have to be changed to reflect the
22 truth.
23 Q.
And once they were changed, who then had to be told
24 that the financial statements had been replaced with new

02:42:22
25 accurate financial statements?

3277
1 A.
Well, the regulators, for one; the investors, most
2 importantly.
3 Q.
By "investors," you mean the depositors in the CD
4 program?
02:42:33
5 A.
I mean the depositors in the CD program, yes, sir.
6 Q.
So going back and saying, "These financial statements
7 were inaccurate. Here are new, accurate financial

8 statements" -9 A.
02:42:43
Yes, sir.
10 Q.
-- that's a restatement process?
11 A.
Yes, sir.
12 Q.
Were there -- was there any discussion about
13 continuing to sell the CDs until that information had been

14 corrected?
02:42:56
15 A.
16 Q.
And what was said regarding that?
17
MR. SCARDINO: Object.
18
THE COURT: First we need to know who.
02:43:04
20 Q.
Did Ms. Stinson address this, or did somebody else
21 raise this point?

22 A.
This was Ms. Stinson.
23 Q.
And what did Ms. Stinson say needed to be done
24 regarding continued sales of the CDs until there were new

02:43:18
25 financial statements?
3278
1 A.
Certificates of deposit could not be sold
2 domestically any longer.

3
THE COURT: "Domestically" meaning in the
4 United States.
02:43:26
THE WITNESS: Yes, sir, Your Honor.
6 BY MR. STELLMACH:
7 Q.
And regarding Mr. Sjoblom, did he make any
8 suggestions regarding next steps that needed to be taken?

9 A.
02:43:45
10 Q.
I believe -- yes, sir.

And what did Mr. Sjoblom, the lawyer hired for the
11 bank, propose?
12
MR. SCARDINO: I would remind I have a running
13 objection.
02:44:03
14
15
THE WITNESS: Mr. Sjoblom actually concurred
16 with Ms. Stinson on the five points which were shared with
17 us by Ms. Stinson.
18
THE COURT: Now, it's your position that all
19 the folks present except, I think, probably, if I'm

02:44:21
20 correct, you and Mr. Stanford were the only ones that knew
21 that -- well, in your position, based upon your testimony,
22 there was no real backing relative to the values up there.
23 Is that correct? That the items were included, but not the
24 values you have up there; correct?
02:44:45
25
THE WITNESS: Yes, sir. It was lacking -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3279
THE WITNESS: -- value.
THE COURT: All right. So the people up there
4 making these suggestions didn't know, according to your

02:44:51
5 testimony, that these things weren't worth what they said

6 they were being worth; right?
7
THE WITNESS: Yes, sir, Your Honor, that's
8 probability. Yes, sir.

9
02:45:02
THE COURT: Okay.
11 Q.
And, so, once -- and I'm sorry?
12
What did Mr. Sjoblom propose needed to be
13 done?
14 A.
02:45:18
Mr. Sjoblom thought that a forensic audit should take
15 place to get to the bottom of the misstatements of the

16 Stanford Financial -- excuse me -- the Stanford
17 International Bank, Limited financial statements.
18
THE COURT: All right. In your business, what
19 is the understanding that a forensic accountant or forensic

02:45:34
20 accounting different than a regular accounting?

21
THE WITNESS: It's my understanding, Your
22 Honor, that it would be the regular auditors steps but more

23 specific to uncovering or detecting fraud that might be
24 taking place.
02:45:50
3280
1 Q.
And, so, Ms. Stinson had made a number of proposals.
2 Mr. Sjoblom proposed an internal -- an internal audit, a

3 forensic audit?
4
02:46:06
What did Mr. Stanford say in reaction to
5 these proposals?
6 A.
That he was not supportive of the points made. He
7 didn't want to do those points.

8 Q.
But ultimately, what happened regarding continued CD
9 sales?
02:46:17
10 A.
Continued CD sales ceased domestically. Those that
11 did come in after the fact were returned.

12 Q.
But were the CDs still sold internationally to
13 people --
02:46:32
14 A.
Yes.
15 Q.
-- outside the United States?
16 A.
Yes, sir.
17 Q.
And regarding the suggestion or the proposal by
18 Mr. Sjoblom that there be a forensic audit, did that

19 actually take place?
02:46:44
20 A.
21
No, sir, it did not.

THE COURT: What was the percentage mix of the
22 CDs from the United States or -- and outside the country?

23 Do you have just a handle generally on that, what the
24 percentages were?
02:47:00
25
THE WITNESS: Your Honor, I believe it would

3281
1 have been in the neighborhood of 20 percent, 20 to

2 25 percent.
02:47:12
THE COURT: What?
THE WITNESS: Of U.S. CD holders to the whole.
THE COURT: Okay. So 75 percent were outside
6 of the United States approximately?
02:47:20
THE COURT: Okay.
THE WITNESS: Approximately.
11 Q.
Was there any decision made about going forward with
12 testimony before the SEC?
02:47:33
13 A.
Yes, sir.
14 Q.
I think you testified previously that Mr. Rodriguez
15 and Ms. Holt had been identified as the people who would
16 testify. Is that accurate?
17 A.
Yes, sir, that was accurate. That was the plan.
18 Q.
During this meeting on Friday, was there any decision
19 about who would still go in and testify before the SEC?

02:47:48
20 A.
Yes, sir.
21 Q.
And what was the -- who made the decision that who
22 should go forward and testify?

23 A.
That Mr. Tom Sjoblom and Mr. Mauricio Alvarado,
24 general counsel and outside counsel's recommendation, it

02:48:12
25 was decided that -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3282
02:48:21
THE WITNESS: -- Ms. Laura Holt would go.
THE COURT: Excuse me. Overruled. Go on.
THE WITNESS: It was decided at that meeting
5 that Ms. Laura Holt would go. Mr. Juan Rodriguez said he
6 was not going.
7 BY MR. STELLMACH:
02:48:38
8 Q.
Did Mr. Rodriguez say why he wouldn't attend?
9 A.
He could not speak to the SEC after learning what was
10 actually in Tier 3.
11 Q.
When did Ms. Holt eventually testify before the SEC?
12 This was I think you said Friday of the first week in

13 February?
02:48:48
14 A.
Yes, sir.
15 Q.
This meeting is taking place in Miami.
16
When was Ms. Holt scheduled to testify
17 before the SEC in Fort Worth?
02:49:05
02:49:16
18 A.
On Tuesday, the 10th, I believe was the date.
19 Q.
Did she eventually testify?
20 A.
She did, yes.
21 Q.
Did you speak with her before she testified?
22 A.
Yes, sir, I did.
23 Q.
Did you call her, or did she call you?
24 A.
I called her the night before.
25 Q.
Why did you call her?

3283
1 A.
Well, I wanted to see if she got there safely, see
2 how she was doing. On the one hand, I didn't want her to
3 go in there and perjure herself. And on the other hand, I
4 didn't want her to go in and describe Tier 3 as she had
02:49:47
5 seen it the previous Thursday.

6 Q.
Why not? Why not have the SEC given the same
7 information that you just gave the executives at the bank?

8 A.
Because this was an accounting fraud, and what had
9 been reported was not actually what was there. It was

02:50:08
10 just the opposite and was a lie. It was our lie. It's
11 lies.
12 Q.
And, so, what did you tell Ms. Holt, if anything, to
13 say during her testimony the next day?

14 A.
02:50:27
I told her, "Just to tell them what you knew about
15 Tier 1 and Tier 2."

16 Q.
Basically telling her not to talk about Tier 3?
17 A.
Yes, sir.
18 Q.
Did she mention Mr. Stanford at all in her
19 conversation with you?

02:50:39
20 A.
She did.
21 Q.
What did she say about him?
22 A.
She said that she wanted to talk with him and that he
23 had promised to meet her Friday evening. Yet he never

24 showed up. And she had been trying to get in touch with
02:50:54
25 him and speak with him prior to her going in to testimony,

3284
1 but he never returned her call.

2 Q.
Do you know whether Ms. Holt ultimately did testify
3 before the SEC?
02:51:06
4 A.
Yes, sir, she did.
5 Q.
6 A.
She told me.
7 Q.
Did you discuss what she had told the SEC?
8 A.
I believe she gave me a recap to the effect that she
9 told them what was in 1 and 2 and talked about the

02:51:22
10 Stanford investment model.

11 Q.
What about -- what did she tell you, if anything, she
12 had said about Tier 3?

13 A.
That she would have to ask -- excuse me. Ms. Laura
14 Holt told me that she shared with SEC that they would have
02:51:36
15 to speak with Mr. Stanford and myself about Tier 3.

16 Q.
Where were you while Ms. Holt is in Fort Worth or
17 preparing to go to Fort Worth to testify? You were in

18 Miami on Friday.
02:51:49
19 A.
Yes, sir.
20 Q.
Going into the weekend, where did you go?
21 A.
I flew to Nashville and met my wife. And we drove --
22 she was there at a needle art show, and we drove from

23 there in our car to our home in Northeast Mississippi.
24 Q.
02:52:10
Were you speaking with Mr. Stanford while you were in
25 Mississippi over the weekend?

3285
1 A.
Yes. We had conversations and texts, passing texts.
2 Q.
What were you discussing with Mr. Stanford?
3 A.
We were discussing, for one, finding funds to honor
4 the withdrawal request of clients and discussing my coming

02:52:40
5 back to Miami that particular week.

6 Q.
While you were home over the weekend in Mississippi,
7 did you do anything regarding evidence or computers in

8 your home?
9 A.
02:53:04
Yes, sir, I did. I tossed the computers and flash
10 drive, these thumb drives, media, into a lake in front of

11 my house.
12 Q.
What information was on the computers that you
13 destroyed?
14
02:53:18
THE COURT: I'm sorry. Did you throw the
15 computers in or just the thumb drives.

16
THE WITNESS: Both.
17
THE COURT: Both. Okay.
18
THE WITNESS: Both, yes, sir.
19
02:53:31
It contained this information that's on
20 the large computer. It contained this information we're

21 discussing right now.
02:53:48
23 Q.
This spreadsheet, Government's Exhibit 332?
24 A.
Yes, sir. Contained personal drafts of letters, et
25 cetera, basically the information that was on the Oracle

3286
1 system that tied our companies together.

2 Q.
And just to jump ahead, how soon after you decided to
3 cooperate with the government did you disclose this

4 information about the fact you threw some computers and
02:54:07
5 some thumb drives into that lake to destroy them?

6
MR. SCARDINO: Object to relevance.
THE COURT: What's the relevance, Counsel?
MR. STELLMACH: His credibility. He was
9 attacked in opening by Mr. Scardino.

02:54:19
10
MR. SCARDINO: His credibility?
11
MR. STELLMACH: Yes. They put it at issue.
12 He's entitled to address it.

13
THE COURT: What does that have to do with
14 putting a thumb drives and the computers in a body of

02:54:30
15 water?
16
MR. STELLMACH: How shortly he started
17 cooperating with the government. He came forward and

18 admitted that.
19
02:54:37
MR. SCARDINO: Now, the jury knows it already,
20 so I'll withdraw it.

21
THE COURT: Thank you. I'll allow it. Thank
22 you.
02:54:44
24 Q.
How --
25 A.
Our first meeting I had, sir, first meeting with the

3287
1 authorities.
2 Q.
That was over the weekend.
Did you continue going into the office the
4 following Monday?
02:54:54
5 A.
No, sir, I did not.
THE COURT: Let me ask you that: Were those
7 computers ever retrieved?
02:55:07
THE WITNESS: Yes, sir, I believe they were.
THE COURT: Go on.
11 Q.
You didn't go back in the office?
12
Were you still speaking with Mr. Stanford
13 going into that second week of February?
02:55:17
14 A.
Yes, sir.
15 Q.
What were up discussing with him?
16 A.
Finding money to honor the withdrawal requests of
17 clients. We're talking about CD production

18 internationally. We're talking about my coming back to
19 Miami, and -- which will I did on Wednesday of that week.
02:55:40
20
THE COURT: Coming back from where, please?
21
THE WITNESS: My home in Northeast Mississippi,
22 yes, sir.
02:55:48
24 Q.
When you arrived in Miami, where did you go?
25 A.
To the Hotel Intercontinental adjacent to our

3288
1 offices.
02:55:59
2 Q.
Did you meet with Mr. Stanford?
3 A.
Yes, sir.
4 Q.
And what did you discuss with him?
5 A.
We discussed a number of subjects, some of which I
6 just shared with you. And we discussed flying to

7 Washington on Friday and meeting with some attorneys.
8 Q.
Did that happen? Did you eventually go to
9 Washington?
02:56:25
02:56:39
10 A.
Yes, sir, we did.
11 Q.
And you say "we," who went?
12 A.
Mr. Stanford and myself.
13 Q.
What was the purpose of the meeting?
14 A.
To meet with a consultant there in Washington who was
15 able to refer Mr. Stanford to an attorney, as well as

16 myself.
17 Q.
When was the last time you saw Mr. Stanford?
18 A.
Wednesday, I believe, of the following week, the 18th
19 of February.
02:57:00
20 Q.
And, again, at any point when you were speaking with
21 Mr. Stanford, did he ever tell you that his understanding

22 was that because the bank was selling CDs that somehow
23 meant that the information in the marketing materials or
24 the bank's financial statements did not have to be
02:57:17
25 accurate?
3289
1 A.
Would you repeat the question, please.
2 Q.
Sure. At any point when you're speaking with
3 Mr. Stanford after Miami, or before Miami for that matter,

4 did he ever tell you that he believed, because the bank
02:57:34
5 was selling CDs, the information they provided to

6 depositors about its assets and its financial performance
7 did not have to be accurate?
02:57:45
8 A.
No, sir.
9 Q.
And, in fact, Government's Exhibit 112, the 1999
10 annual report for the bank -11
MR. STELLMACH: If we could just turn to that
12 one disclosure.
13 BY:
02:58:02
15 Q.
I think you testified about this earlier. This is
16 the disclosure that Mr. Stanford had fully repaid a loan

17 for $13 1/2 million to the bank?
02:58:19
18 A.
Yes, sir.
19 Q.
Do you recall when this disclosure was made
20 discussing it with Mr. Stanford?

21 A.
Yes, sir.
22 Q.
And what did Mr. Stanford tell you about why this
23 disclosure had to be made?

24 A.
02:58:35
Said that it had been determined by then chief
25 counsel Yolanda Suarez that there were monies being spent

3290
1 outside depositor money.

2 Q.
I'm sorry. My question, Mr. Davis, is not why the
3 disclosure was made in the first place in 1996.
02:58:47
4 A.
Yes, sir.
5 Q.
My question was what Mr. Stanford told you about why
6 the disclosure had to be made that the note had been fully
7 repaid, a disclosure that you testified previously was
8 false?
9 A.
02:59:03
Because it didn't look good to have a footnote
10 showing the owner of the bank with loans in terms of being

11 able to sell CDs to the public.
12 Q.
How much were you getting paid --
13
MR. STELLMACH: We can take it down.
02:59:17
15 Q.
How much were you getting paid at Stanford Financial
16 Group when you first started?
02:59:28
17 A.
$65,000 a year plus bonus.
18 Q.
And over time did your salary increase?
19 A.
Yes, it did.
20 Q.
What did it ultimately reach by the time the bank
21 folded?
22 A.
Base pay of $900,000 a year and equal bonus.
23 Q.
What about loans from the bank? Did you take any
24 loans?
02:59:43
25 A.
Yes, sir, I did.

3291
1 Q.
When did you take loans from the bank?
2 A.
December of '08 and January of '09.
3 Q.
Did you speak -- did you obtain Mr. Stanford's
4 permission to take that money from the bank?

02:59:59
5 A.
Yes.
MR. STELLMACH: I want for show the witness
7 Government's Exhibit 1511A. I think this might be better.

8
Well, it's not that much better.
9 BY:
03:00:38
11 Q.
Let me give you a hard copy, Mr. Davis. It's
12 difficult to read.
03:00:48
13 A.
Yes, sir.
14 Q.
What is this?
15 A.
It's a request I made of Mr. Stanford to draw money
16 in December.
03:01:02
17
MR. STELLMACH: Let me actually, if I can --
18
THE REPORTER: Possibly November.
19
MR. STELLMACH: Could I try the overhead, Your
20 Honor?
21
THE COURT: Sure. What is that?
22
MR. STELLMACH: Well, it's a picture of a cell
23 phone of a text.
24
03:01:17
MR. SCARDINO: I guess I would like for him to
25 prove it up.
3292
THE COURT: Okay. Prove it up first, please.
MR. STELLMACH: Certainly.
Can we take it down?
4
03:01:25
MR. SCARDINO: I don't care if you leave it up.
5 It's too late for that, but I would -- for the record, I'd
6 like for him to prove it up.
7
THE COURT: All right. It's back up.
MR. STELLMACH: It's back up.
9 BY MR. STELLMACH:
03:01:34
03:01:43
03:01:58
10 Q.
Mr. Davis, do you recognize this?
11 A.
I do, yes, sir.
12 Q.
How do you recognize it?
13 A.
I wrote it.
14 Q.
And what is this actually a picture of?
15 A.
My iPhone.
16 Q.
And when did you write this?
17 A.
November, maybe the last of November 2008.
18 Q.
And who did you send it to?
19 A.
Mr. Allen Stanford.
20 Q.
And could you, to the extent you can, read it for us?
21 Can you just read it for us?

22 A.
"I would like to draw $800,000, not through payroll
23 but as a conventional loan into a company, tax otherwise

24 eats it up, in lieu of next bonuses or whatever for notes
03:02:27
25 payments and service on Baldwyn businesses and real estate

3293
1 affairs. Also working capital for first six months of

2 '09. Can go through venture capital, maybe split in two
3 tranches, half now, half January."
4 Q.
03:02:55
03:03:08
03:03:22
After you sent that text to Mr. Stanford, or that
5 e-mail to Mr. Stanford, did you receive a response?

6 A.
Yes, sir, I did.
7 Q.
By phone or did Mr. Stanford text you back?
8 A.
Text me back directly.
9 Q.
Did you save the text?
10 A.
I did.
11 Q.
Do you have it -- still have it?
12 A.
Yes, sir, I do. I think so. Yes, sir.
13 Q.
And did Mr. Stanford approve the loan?
14 A.
Yes, sir.
15 Q.
And after Mr. Stanford approved it, did you
16 subsequently withdraw money from the bank?

17 A.
Yes, sir, I did.
18 Q.
And was it in the amount of around 880,000? Could
19 that be a -03:03:35
20 A.
Yes, sir.
21 Q.
What ultimately happened to that money?
22 A.
It was put in -- as stated in the iPhone text, put
23 into the businesses in a town close to where I live,

24 Baldwyn, Mississippi, in a renovation project.
03:03:53
25 Q.
Did those businesses -- did anything happen to those

3294
1 businesses once this the company closed down?
03:04:04
2 A.
Yes, sir.
3 Q.
What happened?
4 A.
They were seized by the receiver in this case.
5 Q.
So were you able to keep any of the businesses that
6 you had opened?

7 A.
No, sir.
8 Q.
And regarding your home -- the home you lived in, in
9 Mississippi, what happened to that?

03:04:16
03:04:26
10 A.
It was seized.
11 Q.
What about your bank accounts?
12 A.
They were all seized.
13 Q.
Where do you live right now?
14 A.
In Michigan.
15 Q.
How do you support yourself?
16 A.
I just completed two years working for a fruit farm,
17 and am now on Social Security and have a small pension.

18 Q.
Have you ever calculated how much money you earned
19 during your time working for Mr. Stanford?

03:04:47
20 A.
Yes, sir. Approximately $14 million over 21 years.
21 Q.
Did Mr. Stanford also make any donations to churches
22 or charities that you asked him to make?
03:05:04
23 A.
Yes, sir, he did.
24 Q.
Could you tell us about that?
25 A.
Made a donation of $500,000 to my church.

3295
1 Q.
Aside from the money you've talked about, the
2 bonuses, the salary, the donation to your church, the

3 loans you took out, did you receive any other money or
4 gifts from Mr. Stanford?
03:05:24
5 A.
No, sir.
6 Q.
Did you skim any money out of the accounts that you
7 controlled?
03:05:32
8 A.
No, sir.
9 Q.
Why not?
10 A.
I always went through Mr. Stanford.
11 Q.
So according to your testimony, over $2 billion in CD
12 money was misappropriated as a result of this scheme that

13 you pled guilty to. Is that right?
03:06:06
03:06:40
14 A.
Yes. Yes, sir.
15 Q.
Where did it go?
16 A.
The billion of dollars?
17 Q.
Yes, sir.
18 A.
Mr. Stanford and some went to myself, 14 million.
19
MR. STELLMACH: Pass the witness, Your Honor.
20
THE COURT: Why don't we take a stretch in
21 place, shall we? I'll stop the clock.

22
23
(Brief recess)
THE COURT: All right. Be seated. Defense,
24 you're up.
03:08:28
25
MR. SCARDINO: Proceed, Your Honor?

3296
Cross-Davis/By Mr. Scardino
CROSS-EXAMINATION
3 BY MR. SCARDINO:
4 Q.
03:08:33
Mr. Davis, my name is Robert Scardino.
We haven't met before, have we?
6 A.
No, sir.
7 Q.
In fact, I've tried to talk to you over the last
8 year, haven't I?
9 A.
03:08:41
10 Q.
Your lawyer didn't tell you that I tried many times
11 to interview you?
03:08:52
12 A.
No, sir.
13 Q.
Never communicated that to you?
14 A.
Well, yes, indeed, he did.
15
MR. STELLMACH: Objection to the privilege,
16 Your Honor. I think we're getting into privileged

17 communication.
18
MR. SCARDINO: Just asked him if he relayed the
19 message.
03:08:58
20
THE COURT: I overrule that. Overruled. I'm
21 sure, you know, Mr. Scardino, where the line is. I don't
22 think we're over it yet, so overrule the objection to that
23 question.
24 BY MR. SCARDINO:
03:09:07
25 Q.
Well, you spent hours and weeks interviewing with the

3297
1 government's investigators, didn't you?

2 A.
I spent some hours, yes.
3 Q.
You know, I get copies of all those reports.
4
03:09:19
Have you had a chance to review those
5 reports?
6 A.
No, sir.
7 Q.
But you weren't willing to talk to me or my
8 investigators?
9 A.
03:09:32
I listened to my attorney.
10 Q.
He told you not to talk to us?
11 A.
He did not say talk to you.
12 Q.
Well, can you tell the jury what it was you didn't
13 want me to know?
03:09:45
14
MR. STELLMACH: Objection, Your Honor.
15
THE COURT: All right. Approach the bench
16 here.
17
(The following was held at the bench)
18
THE COURT: Are we're on now? We're on now.
19 Okay.
03:10:13
20
At this point -- at this point -- and of
21 course, the client can raise it or his lawyer can, it's

22 Mr. Fiend. I think he's there in the back.
23
MR. STELLMACH: I don't know if he is here,
24 Your Honor.
03:10:24
25
THE COURT: Maybe it wasn't him. I thought I

3298
1 saw somebody --
03:10:34
MR. STELLMACH: He's not here today.
MR. STELLMACH: You're right. It's the
5 witness's privilege to assert.

6
THE COURT: Exactly right.
MR. STELLMACH: But I don't know if the witness
8 understands that.
9
03:10:43
MR. FAZEL: Judge, you can always tell the
10 witness he's got the right.

11
THE COURT: If that's what they want.
12
MR. STELLMACH: I don't think we need to get
13 into a discussion of privilege.

14
03:10:52
THE COURT: I'll let the jury go in about a
15 minute or two, but I think to protect the position here,

16 the lawyer is not here, and none of us, in effect, can
17 represent him. I can look out for his rights up to a
18 point, but I think I agree that it's a matter of just
19 making -- asking him.
03:11:10
20
MR. SCARDINO: Your Honor, I'm not asking him
21 what he told his lawyer. I'm just asking him what it was
22 that he wasn't willing to talk to me about, not his lawyer.
23
MR. STELLMACH: And, Your Honor, I think the
24 witness said he didn't know Mr. Scardino wanted to speak

03:11:24
25 with him. So to ask him why he didn't want to speak with

3299
1 Mr. Scardino, there's no basis for that question.

2
MR. SCARDINO: Well, he changed his mind and
3 said, "Oh, yeah he told me."

4
03:11:33
THE COURT: Okay. So where do you want to go.
5 What's the next question?

6
MR. SCARDINO: I just trying to get into --
7 obviously, what I'm trying to do is that he was told not to

8 talk to me and he didn't. It's as simple as that.
9
03:11:43
MR. STELLMACH: He didn't know that he was told
10 not to talk to him. His testimony was that his lawyer

11 didn't tell him that Mr. Scardino wanted to speak to him.
12
THE COURT: I understand that. I've got to
13 give him some leeway.
03:11:52
14
MR. STELLMACH: I understand.
15
THE COURT: But we've got to watch out for the
16 attorney-client privilege. See if -- we all know what that

17 is. See if you can skirt around it with the questions;
18 okay? But none of us can raise it. If it gets to the
19 point that I feel he ought to be instructed, then we'll get
03:12:04
20 the jury out and I'll instruct him. Right now, I think
21 it's -- you know, it's -22
MR. SCARDINO: If you're more comfortable doing
23 that, I don't have a problem with it.
03:12:15
24
MR. STELLMACH: We can wait.
25
THE COURT: Let's wait. Let's see where it

3300
1 goes.
2
I'll tell you what: He's pled guilty, but
3 he still has a lawyer-client privilege. I understand,

4 though. I think we all do. See if you can work around it;
03:12:27
5 okay? And if you can't, then I'll make had a decision and
6 probably get the jury out, talk to him about it and see if
7 he wants to talk to his lawyer. Or I can ask him, you
8 know, if they've talked about it, does he understand, it
9 may concern the -- an absolute right. If I have to give
03:12:46
10 him the warning, I will. And I'll do the best I can off
11 the top of my head, because you don't get it very often.
12 Usually someone's up making noise.
13
MR. SCARDINO: And he waived the privilege by
14 taking the witness stand. He certainly waived his

03:13:02
15 privilege against self-incrimination.

16
THE COURT: I don't think you waive
17 attorney-client privilege. I think you waived -- of

18 course, you know, attorney-client privilege isn't in the
19 Constitution, as far as I know. But it's well founded in
03:13:15
20 our law.
21
Skirt around it if you can; okay? If not,
22 someone get up or just give me a nod and I'll ask the jury
23 to go out and we can talk about it.
24
03:14:16
25
(The following was held in the presence of the jury)
THE COURT: All right, sir. Go right ahead.

3301
1 BY MR. SCARDINO:
03:14:28
03:14:45
03:15:00
2 Q.
How long have you had a lawyer?
3 A.
Yes.
4 Q.
How long have you had a lawyer regarding what you've
5 testified in front of this jury?

6 A.
I've had an attorney since March of '09.
7 Q.
And is he in the courtroom?
8 A.
I don't see him.
9 Q.
Is it the same lawyer you had when you negotiated the
10 deal you made with the government prosecutors?

11 A.
Yes.
12 Q.
And you hired him with your private funds?
13 A.
Yes, I did.
14 Q.
Tell the jury you forfeited everything. Did you keep
15 some money aside to hire lawyer?

16 A.
No, I did not.
17 Q.
So you hired him -- did you hire him with some of the
18 $900,000 you stole at the end of 2008? You used that

19 money to hire him?
03:15:12
20 A.
I didn't steal that money, and I didn't use that
21 money. I used my mother-in-law's money.

22 Q.
I see. So you borrowed money from your mother-in-law
23 to hire the lawyer?
03:15:22
24 A.
Yes.
25 Q.
Did you tell the government prosecutors that?

3302
03:15:45
1 A.
I don't recall telling them.
2 Q.
It's nowhere in any of your reports, is it?
3 A.
Well, that's my personal lawyer.
4 Q.
Have you talked about this case with anybody other
5 than your lawyer? Don't tell me what you said or what was
6 discussed. But did you discuss the case and all the
7 things that you've told this jury about the last day and a
8 half with anybody other than your lawyer and these
9 government prosecutors?
03:15:59
10 A.
No. A few things maybe with my wife.
11 Q.
Your wife.
12
And how about the lady that loaned you the
13 money to hire the lawyer, did you talk to her about it?
03:16:16
03:16:35
14 A.
No.
15 Q.
How about your sons, you talk to them about it?
16 A.
Nothing other than what's in the newspapers.
17 Q.
In the newspapers about you talking to your sons?
18 A.
About the case, the downfall of Stanford.
19 Q.
So you've discussed what has been in the newspapers
20 with your sons?

21 A.
Had brief summary-type dialogue, yeah, a couple of
22 times. They don't live near me. Sometimes phone, uh-huh.

23 Q.
So let me -- so I can try to clear this up,
24 Mr. Davis, were you informed that I wanted to interview

03:17:01
25 you or not?
3303
1 A.
No, I was informed that you subpoenaed my attorney.
2 I found that out on --
03:17:10
MR. SCARDINO: That's nonresponsive.
5 BY MR. SCARDINO:
6 Q.
I'm asking you if you were informed that since last
7 October, I've been trying to talk to you and interview you

8 just like the government has, did you know that?
9 A.
03:17:22
10 Q.
No, sir.
Your lawyer and -- withdrawn.
11
Nobody shared that information with you?
12 A.
No, sir.
13 Q.
Okay. Has the government prosecutors been talking to
14 you between the times you've been on the witness stand and
03:17:44
15 when you've been off the witness stand yesterday and

16 today?
17 A.
No, sir.
18 Q.
How much time did they spend with you to prepare you
19 for your testimony here today?

03:17:52
20 A.
We've had 13, 14 visits over three years.
21 Q.
How about right before trial. How much time was
22 spent with you explaining the Rules of Evidence and

23 procedure to you?
03:18:11
24 A.
We met maybe three hours last week.
25 Q.
That's it?
3304
03:18:22
1 A.
(Answered affirmatively.)
2 Q.
Went over all this information in three hours?
3 A.
What information?
4 Q.
All the information you've been talking to this jury
5 about, all the financial reports, all the data you say is
6 phony and cooked up. You got -- took three hours to get
7 ready for that?
8 A.
No. We -- you just asked me a question, sir, about
9 the last three years and how much time I've spent with the
03:18:37
10 prosecutors. I said we've had 12, 13 visits.

11 Q.
Mr. Davis, you spent a lot of time with FBI agents
12 and IRS criminal investigators telling them your version

13 of what's happened. You've done that?
14 A.
03:18:52
Sir, I've told them where money might be located --
15
MR. SCARDINO: It's nonresponsive.
16
THE COURT: Hold it.
17
MR. SCARDINO: That's nonresponsive.
18
THE COURT: All right. Mr. Davis, it will be a
19 lot easier on everyone if you answer yes or no -03:19:04
20
THE WITNESS: Okay.
21
THE COURT: -- to the question. If it's a yes
22 or no question and you cannot answer it yes or no, let me

23 know and I'll ask the attorney to rephrase it. If he asks
24 for a narrative, or tell us the story about A, B and C,
03:19:18
25 then you're free to do so. Go a lot quicker, yes or no or

3305
1 I can't answer it yes or no.

2
THE COURT: Okay. Go on.
4 BY MR. SCARDINO:
03:19:25
5 Q.
You've reviewed a lot of documents in front of this
6 jury, and you've drawn a lot of charts on that little

7 easel up there. Are you telling this jury that you only
8 took three hours to prepare for that with Mr. Stellmach,
9 Mr. Costa, Mr. Warren?
03:19:43
10
MR. STELLMACH: Last week. I think the -- just
11 to clarify, I think the original question was last week

12 before he testified.
13 BY MR. SCARDINO:
14 Q.
03:19:49
Well, let me rephrase it, then.
15
How long did you spend preparing your
16 testimony with these prosecutors?

17 A.
I spent a number of hours over a long period of time
18 answering questions.
19 Q.
03:20:07
Preparing to tell this jury your version of what's
20 happened in the years you worked at Stanford; right?

21 A.
No, sir.
22 Q.
Preparing to talk about your church?
23 A.
I spent visits over three years with the government
24 answering questions. We had a 21-year Stanford

03:20:35
25 experience.
3306
MR. SCARDINO: Nonresponsive. Objection.
THE COURT: Sustained. Next question.
3 BY MR. SCARDINO:
4 Q.
03:20:45
So you've had three years to get your story together
5 with what you wanted to tell this jury; right?

6 A.
I had three years answering questions with the
7 prosecutors.
8 Q.
Right. You've had three years to get together the
9 information that you decided that you wanted to share with

03:21:00
10 this prosecutor after you made your deal with the

11 government, right, three years?
12 A.
No, sir.
13 Q.
Did you tell the government when they first started
14 talking to you, the United States attorneys, did you tell

03:21:19
15 them, "Hey, I'm a liar." Did you tell them that?

16 A.
Yes, sir, I said I was a liar.
17 Q.
Did you tell them, "I'm a crook." Did you tell them
18 that?
03:21:39
19 A.
Told them I was a liar and a fraudster.
20 Q.
A fraudster.
21
Did you tell them that you're a coward?
22 A.
Yes, sir.
23 Q.
And, so, after you tell them all that, they make this
24 deal with you, right, hoping -- you're hoping you're going

03:21:52
25 to get some time off for cooperating with them?

3307
THE WITNESS: Not a yes or no, Your Honor.
THE COURT: Okay.
3 BY MR. SCARDINO:
4 Q.
03:22:06
Let me break it down. We'll do it one at a time.
When you first started talking to the FBI,
6 that was in March of '09?

7 A.
Yes, sir.
8 Q.
And you sat down with the FBI and your lawyer,
9 Mr. Flynn, didn't you?

03:22:21
10 A.
Yes, sir.
11 Q.
And you told them -- you answered their questions
12 about whatever they asked you back then; isn't that

13 correct?
03:22:33
14 A.
I answered questions, yes, sir.
15 Q.
And is it your testimony, Mr. Davis, that in that
16 very first meeting with the FBI and the government

17 lawyers, you told them, "Hey before we get started, you
18 need to know that I'm a liar"? Did you tell them that?
03:22:55
19 A.
Not a yes or no, sir.
20 Q.
Well, I'll respect that it calls for a yes or no.
21 Did you tell them you're a liar, yes or no, or you don't
22 recall?
03:23:07
23 A.
I did say I was a liar.
24 Q.
Okay. Did you tell them that you had been a liar and
25 you had been lying about what you'd been doing with the
3308
1 Stanford companies for over 16 years? Did you tell them

2 that?
3 A.
4
03:23:21
Yes, sir, I did, but most of the time -MR. SCARDINO: Nonresponsive.
5 BY MR. SCARDINO:
6 Q.
Did you tell them when -- the thrust -- the first
7 time you met with them, when you were making your deal
8 with them, did you say, "I'm a liar, and I'm a fraudster."
9 Did you tell them that?
03:23:34
10 A.
Could you ask me one question at a time without
11 putting two or three --
03:23:42
12
13
THE WITNESS: -- to it --
14
MR. STELLMACH: I think it was a --
15
MR. SCARDINO: The government lawyers can --
16
THE COURT: Excuse me.
17
MR. STELLMACH: It was a compound question.
18
MR. SCARDINO: I got no objection. I would
19 object to the witness objecting to my -- witness as opposed

03:23:54
20 to the government lawyers objecting to my questions.

21
22
THE COURT: Overruled both of you.

Go on. You know what he's asking. A
23 fraudster and a liar.
03:24:04
24
MR. SCARDINO: Fraudster and a liar.
25
THE COURT: Break it down.

3309
1 BY MR. SCARDINO:
2 Q.
03:24:09
03:24:18
You told them you were a liar?
THE COURT: Is that correct, sir?
THE WITNESS: That's correct, yes.
5 BY MR. SCARDINO:
6 Q.
Did you tell them you were a fraudster?
7 A.
I did.
8 Q.
And did you tell them you were a crook?
9 A.
Probably.
10 Q.
You don't remember your testimony of yesterday where
11 you said, "I'm a crook"?

12 A.
13
I was, so it doesn't matter.

THE COURT: Are you referring to what he said
14 to them in his conferences with the government or the

03:24:33
15 attorneys or the FBI?

16
MR. SCARDINO: I'm referring to what he told
17 this jury in his first thrust on the witness stand where he

18 said, "I'm a liar, and I'm a crook."
19 BY MR. SCARDINO:
03:24:44
20 Q.
And a fraudster. They knew that when they sat down
21 with you to get information from you; right?

22 A.
Yes, sir, I've already pleaded guilty.
23 Q.
I understand that. We'll get to that in a minute.
24
03:24:59
But these investigators and lawyers for
25 the government knew who and what you are before they made
3310
1 their deal with you, didn't they?
03:25:18
2 A.
I don't know, sir.
3 Q.
Well, you told them you're a fraudster; right?
4 A.
Told them I lied, yes.
5 Q.
Well, lied and fraud, that kind of comes together,
6 doesn't it? Hard to commit to fraud unless you lie;

7 right?
03:25:28
8 A.
Yes, sir.
9 Q.
Okay. But knowing all of that, you still were able
10 to negotiate some kind of deal with the government lawyers

11 to testify before this jury, weren't you?
12 A.
A plea bargain, yes, sir, a plea bargain was arrived
13 at some weeks, maybe a couple months later.

14 Q.
03:25:47
Mr. Davis, can you tell this jury what it was you
15 told these prosecutors to convince them you weren't a

16 fraudster in telling them your story, your version of the
17 story? What was it, what event happened or what did you
18 tell them?
03:26:00
19 A.
I don't understand your question.
20 Q.
I don't either. It was complicated.
21
Was there an event during your relationship
22 with the government investigators and lawyers, like an

23 epiphany? You're familiar with that, right, an epiphany?
03:26:23
24 A.
I know what that is, yes.
25 Q.
A period of time in that relationship where they

3311
1 decided you weren't being a fraudster with them, the

2 prosecutors?
03:26:35
MR. STELLMACH: Objection, Your Honor --
THE WITNESS: I can't think for the
5 prosecutors.
6
THE COURT: Hold it, hold it. If you see the
7 lawyer get up, no answer.

8
Yes, sir.
9
03:26:40
MR. STELLMACH: Objection, calling for the
10 witness to speculate about what was in the mind of the

11 government or the prosecutor he's dealing with.
12
THE COURT: Sustained as to the form.
13 BY MR. SCARDINO:
14 Q.
03:26:51
Was there an event that you can point to, Mr. Davis,
15 something that you did or said where they say, "We believe
16 you, Mr. Davis, even though you say you're a fraudster and
17 a liar"?
03:27:09
18 A.
No, sir.
19 Q.
So it was never revealed to you that in spite of who
20 you are and what you told them, that they ever questioned
21 the information you were giving them?
22 A.
My agreement was to tell the truth, nothing but the
23 truth, truth, truth, truth. That's what I'm doing.
03:27:28
24 Q.
Something you've done for the last 16 years; right?
25 A.
Unfortunately not, but I've told the truth since I've

3312
1 been with the government in March of '09.

2 Q.
I think you drew the line sometime before that,
3 though. You testified you have a -- you got some

4 saturation point in your life where you decided to quit
03:27:43
5 lying; right?
6 A.
I'm telling the truth.
7 Q.
Okay. Can you tell the jury how we can tell when
8 you're telling the truth? How do we know when you're

9 telling the truth, Mr. Davis? Are we supposed to take
03:28:07
10 your word for it?

11 A.
I don't understand the question.
12 Q.
Well, you said you're telling the truth now, but you
13 lied for 16 years. How do we know when to draw our line?
03:28:17
14 A.
I believe that's up to the jury to decide, sir.
15 Q.
I think you're exactly right. But is there something
16 you can point to, some tell that you might have where we
17 know when you're telling us the truth all of a sudden, as
18 opposed to not telling the truth for the last 16 years?
03:28:33
19 A.
I'm telling the truth.
20 Q.
Were you telling the truth when you told this jury --
21 the last thing you told them is that I didn't get any
22 money out of Stanford other than what I told you about,
23 this -- you said a 500,000-dollar donation to your church,
24 and then you pointed to some -- Government's
03:28:52
25 Exhibit 1511-A, which is some cellphone thing or other;

3313
1 right? Do you remember that?

2 A.
Check for the church, yes, sir, I do remember.
3 Q.
How about the cellphone, the last thing --
4
03:29:05
MR. SCARDINO: Can we get Government's 1511 up,
5 please.
6 BY MR. SCARDINO:
03:29:14
7 Q.
Do you see what I'm talking about, Mr. Davis?
8 A.
See it very clearly.
9 Q.
And, so, your testimony in front of this jury -- and
10 you're saying you're being truthful now; right?

11 A.
That's correct.
12 Q.
Okay. And you say this is all the money you got out
13 of Stanford other than the $500,000 that he donated to

14 your church, I guess, at your request?
03:29:30
15 A.
No, sir, that's not what I said.
16 Q.
You did not tell the jury, "I didn't get any other
17 money"?
03:29:47
03:29:58
18 A.
Other than salaries, bonuses and this.
19 Q.
Right. Okay. Other than the salaries and --
20 A.
Bonuses --
21 Q.
-- bonuses?
22 A.
-- and this loan.
23 Q.
And this is a loan?
24 A.
It was intended to be, yes. It was approved to be by
25 Mr. Stanford.
3314
1 Q.
So when did this happen?
2 A.
December -- November with this communication. The
3 money was withdrawn in December.
03:30:13
4 Q.
And when did you tell the government about this?
5 A.
When they asked me.
6 Q.
Let's try a date, Mr. Davis. Was it yesterday?
7 Today? When did you tell them about it?
03:30:37
8 A.
I believe last year.
9 Q.
Last year. Okay.
10
Did you volunteer the information or did
11 they confront you with it?

12 A.
I don't understand the question.
13 Q.
Did you tell them, "Hey, look I've got this cellphone
14 I've taken a picture of, and it shows that I got almost a

03:30:52
15 million dollars at the end of 2008 and the beginning of

16 2009"?
17 A.
They asked me was there any other monies that I
18 received other than salaries and bonuses, and I said yes.
03:31:08
19 Q.
And you showed them this?
20 A.
I told them about it.
21 Q.
Let's look at this for a minute. This is a
22 picture -- I think you testified a picture of a cellphone;

23 is that correct?
03:31:22
24 A.
It is.
25 Q.
And who took the picture?

3315
1 A.
I did.
2 Q.
And you're telling the jury that this is money that
3 Mr. Stanford let you have and you wanted it characterized

4 as a loan?
03:31:41
5 A.
Yes, sir.
6 Q.
Did you draw up a loan agreement?
7 A.
There was a loan agreement drawn up, but it was not
8 conveyed to the bank as yet, but, yes, there was one

9 drawn.
03:31:53
03:32:01
10 Q.
Do you have the document?
11 A.
No.
12 Q.
Where is it?
13 A.
It's been seized.
14 Q.
So the government's got it?
15 A.
Receiver.
16 Q.
Receiver's got it?
17 A.
I presume.
18 Q.
Are they keeping that a secret?
19
03:32:09
MR. STELLMACH: Objection, Your Honor. He
20 doesn't know what the receiver -21
MR. SCARDINO: Well, if he does. I mean, he
22 knows the receiver's got it. How did they get it?
23
THE WITNESS: All my things were seized.
24 BY MR. SCARDINO:
03:32:19
25 Q.
So a year ago you tell the government that this

3316
1 cellphone picture of you getting a million dollars

2 skimming or getting a loan when the company is in -- is
3 heading south and the economy is in bad shape; right?
4 A.
03:32:37
(Answered affirmatively.) It's very similar to the
5 million dollars a day Mr. Stanford was taking.

6
MR. SCARDINO: Nonresponsive, Your Honor.
MR. SCARDINO: Ask the Court to instruct the
9 jury to disregard.
03:32:42
10
THE COURT: Jury is so instructed.
11 BY MR. SCARDINO:
12 Q.
Mr. Davis, you tell -- you tell the government about
13 this a year ago; right?
03:32:55
14 A.
Yes, sir.
15 Q.
And you tell the government that loan documents were
16 drawn up that would tend to verify that this was a

17 legitimate transaction and not you just stealing money at
18 the end of 2008; right?
03:33:11
19 A.
Yes.
20 Q.
Okay. And did you tell the government that a loan
21 document had been prepared that would verify and put

22 validity to your story of how you got this money?
03:33:27
23 A.
I did tell them that, yes.
24 Q.
Did you tell them that the loan document was in the
25 hands of the receiver that had come in and taken your

3317
1 information and your document?

2 A.
I didn't know where the document was, but I presume
3 it was with the receiver.

4 Q.
03:33:41
Have they confronted you with or shown you that, oh,
5 yes, we were able to contact the receiver and here's the

6 loan document, Mr. Davis? Has that happened?
7 A.
No, sir.
8 Q.
So you took a picture of a cellphone. Whose
9 cellphone -- who owns the cellphone that this was on? Is

03:34:05
10 it yours or somebody else's?

11 A.
It was my cellphone.
12 Q.
Your cellphone. Okay.
13
And who took the picture of this to
14 preserve it?
03:34:13
15 A.
I did.
16 Q.
And what did you use to take the photograph?
17 A.
Photocopy machine.
18 Q.
Photocopy machine.
19
03:34:22
And you did that -- you just put your
20 cellphone down on a copy machine and ran it and it came up

21 like this?
03:34:37
22 A.
Yes.
23 Q.
Okay. And when did you do that?
24 A.
Immediately after Mr. Stanford texted me back, which
25 is at the bottom.
3318
1 Q.
So you had a motive to want to be preserve this in
2 some way, memorialize it in some way, so you could show

3 that Stanford has said it was okay, your decision -- or -4 what does it say? You decide -- call you on my -03:34:51
5 A.
"Drive to somewhere, call me -- call you on my drive
6 to somewhere," I believe that's what it said.

7 Q.
You think that's what that says? "Call you on my"
8 something?
9 A.
03:35:03
10 Q.
That's what I see, and that's what I remember.

Well, you were trying to preserve this for a reason,
11 weren't you?
12 A.
Yes. I memorialized the text conversation that we
13 had.
14 Q.
03:35:19
You wanted something that might show that when the
15 bank was paying out way more money than they were taking
16 in, that Allen Stanford decided just to let you have a
17 million dollars; right? You wanted some proof of that?
18 A.
I wanted to memorialize, yes, I wanted proof,
19 memorialize the transaction.

03:35:42
20 Q.
That's in spite of the fact that you had loan
21 documents drawn up; right?

22 A.
Yes.
23 Q.
Have you tried to replicate this? In other words,
24 take the type of phone that was used to receive this? Was
03:36:03
25 it an iPhone?
3319
1 A.
Yes, it was.
2 Q.
Have you tried to replicate this to show whether or
3 not you can have those bars or that rule around the top
4 part and then have the response in the same manner that
03:36:21
5 you see it here on this exhibit? Have you tried to do

6 that again?
7 A.
I don't understand the question, sir.
8 Q.
I guess my point is: When you have -- when you
9 receive -- when you send a message like that and you get a
03:36:35
10 response back on an iPhone, isn't there something between

11 the sending and the responding?
12 A.
I don't know. Something -- what do you mean by
13 "something," sir?
14 Q.
03:36:53
Some rule or spacing other than what's displayed on
15 Government's Exhibit 1511-A?

16 A.
It is what it is.
17 Q.
Mr. Davis, isn't it possible that you made all this
18 up and that you just put that bottom part from another
19 cellphone and superimposed it over the message you claim
03:37:10
20 you sent to Allen Stanford. Isn't it possible you did

21 this?
03:37:26
22 A.
No, sir.
23 Q.
We got to take your word for that; right?
24 A.
(No audible answer.)
25 Q.
Is that right?
3320
03:37:33
1 A.
It is what it is.
2 Q.
Well --
3 A.
I said that is --
4 Q.
-- you're testifying --
5 A.
I said that is real, and you should take my word for
6 it.
03:37:46
03:37:55
03:38:05
7 Q.
We should take your word for it; is that right?
8 A.
Yes.
9 Q.
Do you think there's some irony in that, that you're
10 asking us to take your word for something?

11 A.
No, sir.
12 Q.
Okay. You're now working on a fruit farm?
13 A.
I was.
14 Q.
Not anymore?
15 A.
No.
16 Q.
Your home is seized?
17 A.
Yes.
18 Q.
All your money and assets are seized?
19 A.
Yes.
20 Q.
You lived in a rather grand home, did you not,
21 Mr. Davis?
22 A.
Yes, it was nice.
23 Q.
It was nice. Okay.
24
03:38:17
And, in fact, since you made your deal
25 with the government, you've still lived in a pretty nice

3321
1 house, haven't you?

2
MR. SCARDINO: Have we got pictures? Have you
3 got photos?
4
03:38:34
THE WITNESS: Yes, I live in a nice house.
5 BY MR. SCARDINO:
6 Q.
You live in a nice house.
Now, you've lived in a nice house for the
8 last three years, ever since you made your deal with the
9 government, haven't you?
03:38:41
10 A.
Yes, it's clean, it's nice.
11 Q.
It's not only nice, it's big and scenic, rustic;
12 right?
03:38:54
13 A.
It's rustic, small, and it has a nice view, yes.
14 Q.
In fact, since you made your deal with the government
15 to say you're a big crook, you've traveled and gone

16 wherever you want, haven't you, pending this case?
03:39:08
17 A.
No, sir, I haven't.
18 Q.
You've had restrictions on you?
19 A.
I have.
20 Q.
Have you been denied the right to travel?
21 A.
Not generally, no.
22 Q.
Not generally. Okay.
23
How much money has the government been
24 able to seize in your agreement? How much money have they

03:39:34
25 gotten back from you of the $14 million that you claim
3322
1 that you got when you were with Stanford?
03:39:46
2 A.
I don't know.
3 Q.
Well, didn't you agree to forfeit a billion dollars?
4 A.
That was part of my plea agreement.
5 Q.
Well, I mean -- excuse me.
You testified that you were a chief
7 financial officer; right?
03:40:15
8 A.
Yes, sir.
9 Q.
Kept track of billions of dollars; right?
10 A.
Yes, sir.
11 Q.
And you can't tell this jury how much money you've
12 been able to turn over to the government in your

13 forfeiture agreement?
14
03:40:28
MR. STELLMACH: Objection as to form. Could we
15 be clear as to whether he's talking about the witness's

16 personal assets or the accounts in which a signatory by
17 virtue of being CFO?
03:40:38
18
THE COURT: Okay.
19
MR. STELLMACH: For example, the billion
20 dollars that the SocGen accounts were -- whatever else

21 he's -22
MR. SCARDINO: We're going to talk a lot about
23 the money he transferred out of the SocGen account in a

24 minute.
03:40:40
25 BY MR. SCARDINO:
3323
1 Q.
But I'm talking about the money that you agreed in
2 your plea agreement. You agreed to forfeit a billion

3 dollars; correct?
4
03:40:50
MR. STELLMACH: Again, same objection, as to
5 which accounts.
6
MR. SCARDINO: The plea agreement doesn't
7 address which account, it just says agrees to forfeit a

8 billion dollars.
9
03:40:58
MR. STELLMACH: Which accounts? Not personal
10 accounts. If he can be clear.

11
THE COURT: Is it stated in the plea agreement?
12 I don't have it in front of me.

13
MR. STELLMACH: I don't have it in front of me
14 either.
03:41:06
15
MR. SCARDINO: I do. Government's 1515. I'll
16 be happy to show it.

17
MR. STELLMACH: Go forfeiture.
18
MR. SCARDINO: Personal checking, $1 billion.
19 That's what I'm talking about.

03:41:33
20
MR. STELLMACH: Ask him whether he knows where
21 the accounts are.

22
MR. SCARDINO: I'll ask the questions, if you
23 don't mind, Mr. Stellmach.
03:41:43
24
MR. STELLMACH: I'm just trying to help.
25
MR. SCARDINO: I don't think I need it.

3324
THE COURT: What page were we looking at,
2 forfeitures on -3
MR. SCARDINO: Right at the bottom of it, Your
4 Honor.
03:41:50
THE COURT: On the bottom of what?
MR. SCARDINO: Of that document I just handed
7 you. I'm sorry. The forfeiture part is towards the end

8 pages, last couple of pages, it's in there. It's styled
9 "Forfeiture Agreement."
03:42:08
10
THE COURT: Okay.
11 BY MR. SCARDINO:
12 Q.
So how much money did you turn over to the government
13 in accordance with your agreement?
03:42:26
14 A.
Well, I signed over --
15 Q.
That would ask for a number, Mr. Davis. What's the
16 number?
17 A.
I don't know the number.
18 Q.
Okay. Was it not important to the government to have
19 you honor that part of your plea agreement that you turn
03:42:44
03:42:59
20 over some of the millions of dollars you claim you stole?

21 A.
I didn't steal any money.
22 Q.
You didn't?
23 A.
I received --
24 Q.
Are you changing your plea?
25 A.
The money I received, sir, was salaries, wages and

3325
1 bonuses and the loan that we just discussed.

2 Q.
Is it your testimony now, Mr. Davis, that you didn't
3 steal any money? Is that what you're saying?
03:43:27
03:43:35
4 A.
I've already said that I lied and I committed fraud.
5 Q.
That's not stealing?
6 A.
And that is stealing from the CD holders, yes.
7 Q.
Which is it?
8 A.
Yes.
9 Q.
Which is it? Did you steal money or not?
10 A.
I did.
11 Q.
So how much of the money that you stole that the
12 government wanted back did you pay back? How much?

13 A.
03:43:52
I helped the government find funds for --
14
15
THE WITNESS: Cd holders.
16
17
18 BY MR. SCARDINO:
19 Q.
03:43:58
03:44:10
If you don't know the answer, that's okay, but please
20 answer.
21 A.
Millions.
22 Q.
You've given them back millions?
23 A.
I've signed documents. Sir --
24
THE WITNESS: Your Honor, can I non-es or no?
25
THE COURT: Sure. He can't answer it yes or

3326
1 no.
2 BY MR. SCARDINO:
3 Q.
You can't answer it yes or no? You're CFO; right?
4 You kept track of billion dollars of dollars, and you

03:44:20
5 can't tell how much money the government got out of you?
6
It's none; right? They haven't gotten any
7 personal money out of you; right?

8 A.
All due respect, sir, if you'd let me say -- answer
9 the question.
03:44:26
10
THE COURT: Excuse me. Did they get any
11 personal money from you yet.

12
THE WITNESS: I don't know the answer to that,
13 sir.
14
03:44:32
THE COURT: Okay.
15 BY MR. SCARDINO:
16 Q.
So is that to say, then, that that part of the
17 agreement that you've entered into with the government has

18 not been consummated? You haven't turned over the money
19 yet?
03:44:41
20 A.
My assets were seized by the receiver.
21 Q.
How much was in a bank account?
22 A.
I recall a number of 300 and some-odd thousand
23 dollars in cash.
03:44:56
24 Q.
Do you have the documents to back that up?
25 A.
It would be in the documents that were seized.

3327
1 Q.
And that would be with the receiver?
2 A.
Yes, sir.
3 Q.
And you don't know whether or not these prosecutors
4 were able to access that information; right?

03:45:08
5 A.
I don't know.
6 Q.
The $300,000 you're referring to was money that was
7 taken by the receiver. Is that correct?
03:45:27
8 A.
The bank accounts which that was part of was seized.
9 Q.
Let's back up so it's clear, Mr. Davis.
10
When the Securities and Exchange
11 Commission stepped in, a judge appointed a receiver to

12 take over the Stanford businesses. Isn't that correct?
03:45:43
13 A.
Yes, sir.
14 Q.
And that receiver seized all assets and documents
15 related to Stanford businesses. Isn't that correct?

16 A.
That was part of it, yes, sir.
17 Q.
And took over all bank accounts that they could
18 identify involving the Stanford businesses. Isn't that

19 correct?
03:45:57
20 A.
As far as I know.
21 Q.
Okay. So the money that you're referring to, the
22 $300,000 that you're referring to, is $300,000 that the

23 receiver was able to obtain; correct?
03:46:12
24 A.
From my personal account, yes, sir.
25 Q.
It has nothing to do with your agreement with these

3328
1 government prosecutors that you were going to forfeit

2 money because of the crimes that you say you committed?
03:46:43
3 A.
Says that there's a $1 billion in the plea agreement.
4 Q.
Let's go back to that Government's --
MR. SCARDINO: You don't have to bring it up.
6 BY MR. SCARDINO:
7 Q.
I want to talk to you about Government's 1511A which
8 is the cell phone picture of the, what, $990,000? Is that

9 what it was?
03:46:53
10 A.
880, I think.
11 Q.
I've got the records. We'll go through it when I get
12 to that later on.

13
But it's your testimony, I believe, on
14 direct examination that there was -- that the company -03:47:12
15 the bank was scrambling to get money to pay all the claims
16 for redemptions on the CDs; right?
17 A.
Yes, sir.
18 Q.
And I believe you testified on direct examination
19 that there was an effort made to transfer assets to

03:47:31
20 recapitalize or capitalize the bank in such a way that

21 these claims could be paid?
22 A.
I don't understand that explanation you gave me.
23 Q.
What -- didn't you testify about some consolidation
24 project that was your idea?

03:47:54
25
MR. STELLMACH: Objection, mischaracterizes the

3329
1 testimony. He didn't testify about a consolidation

2 project. He testified about flips and circular
3 transactions.
4
03:48:04
MR. SCARDINO: I disagree with Mr. Stellmach.
5 The first day he testified, he talked about being involved,

6 and there's e-mails that they put into evidence talking
7 about moving assets around. He's on the -8
THE COURT: Okay. I'll overrule the objection.
9
03:48:15
By the way, if you don't understand the
10 question or that's not what your testimony was, you'll let

11 us know.
12
MR. STELLMACH: Can I just have a moment to
13 confer with counsel to avoid a miscommunication.

14
03:48:28
THE COURT: Sure.
15
(Attorneys conferring)
16
THE COURT: We'll take a break in about five
17 minutes.
18 BY MR. SCARDINO:
03:48:46
19 Q.
The bank was losing the money, wasn't it?
20 A.
Yes.
21 Q.
Regardless of whether you committed fraud or not;
22 right?
03:48:56
23 A.
Yes.
24 Q.
Regardless of whether you cooked the books or not;
25 right?
3330
1 A.
We cooked the books.
2 Q.
I didn't ask you that.
Regardless -- whether you cooked the books
4 or not, the bank was losing the money, wasn't it?

03:49:06
5 A.
Yes.
6 Q.
At a very rapid pace. Isn't that correct, Mr. Davis?
7 A.
Yes, for some 21 years.
8 Q.
And the economy in 2008 was such that not just
9 Stanford bank, but all the banks were heading in the wrong
03:49:25
10 direction, weren't they?

11 A.
A lot of banks seemed to be. They were reported as
12 such in the newspaper.
03:49:34
13 Q.
A lot of them -- big banks went broke, didn't they?
14 A.
Some did.
15 Q.
Some did. So in spite of all of that, your testimony
16 in front of this jury is that Mr. Stanford, "Davis, you

17 can go ahead have that million dollars. Go ahead and take
18 it out of the bank"?
19 A.
03:49:49
No, sir. He didn't say million dollars. He text me
20 back from the text that I sent him on 880 or 900, whatever
21 it was.
22
He said, "You decide. I'll call you on
23 the way to Boca."

24
03:50:03
MR. SCARDINO: Can we have Government -- I'm
25 going to a different subject. Would it be a good time

3331
1 or -2
THE COURT: That's fine.
Ladies and gentlemen, we'll take a --
4 check your watch. We'll take a 20-minute break. That

03:50:12
5 should bring us to 4:10, and then we'll run on and wrap it

6 up around 6:00.
7
Wait one second here. Thank you.
(The following was held out of the presence of the jury)
10
11
12
(HEARING HELD AT THE BENCH ORDERED SEALED BY THE COURT)
13
14
15
(The following was held in open court)
16
THE COURT: All right. Let's call the jury in,
17 please.
18
04:29:29
19
20
MR. SCARDINO: May I proceed, Your Honor?
21 BY MR. SCARDINO:
22 Q.
04:29:39
Mr. Davis --
23
THE COURT: Hold it. We need to unmute the --
24
CASE MANAGER: I did.
25
THE COURT: Is that working now? Pull it in

3332
1 then, please.
04:29:50
MR. SCARDINO: How's that?
THE COURT: No. Pull it in closer.
MR. SCARDINO: Like that?
THE COURT: Better. Go on.
MR. SCARDINO: Making me nervous.
7 BY MR. SCARDINO:
8 Q.
Mr. Davis, I'm going to jump back to the cell phone
9 loan for a minute.

04:30:07
10
Do you remember -- and you may have
11 already told us and I don't recall -- that the date that

12 you took the photograph of the cell phone that showed -13 that you were asking Mr. Stanford to loan you $990,000?
04:30:30
14 A.
I don't recall a date.
15 Q.
Do you remember the year?
16 A.
I believe it was shortly after the November text
17 message, so '08.
18 Q.
Okay. And the cell phone that you took a photo --
19 that you -- that appears in that exhibit, do you remember

04:30:51
04:31:01
20 the type of phone?

21 A.
Yes.
22 Q.
What type of phone?
23 A.
IPhone.
24 Q.
And was it your iPhone?
25 A.
It was. I believe so.

3333
04:31:12
04:31:29
04:31:38
1 Q.
And do you still have that iPhone?
2 A.
Yes.
3 Q.
Do you have it with you?
4 A.
No.
5 Q.
Where is it?
6 A.
It's in my travel bag.
7 Q.
Okay. Is it in Houston?
8 A.
Yeah.
9 Q.
Will you bring it tomorrow when you come back to
10 court?
11 A.
I guess.
12 Q.
Okay. Just asking.
13 A.
Yeah.
14 Q.
Okay. And what year iPhone was it that you
15 photographed?
16 A.
It was a --
17 Q.
Better said not year, I mean -- or I guess maybe I
18 can ask you that, what year you bought it. But we're
19 talking about I'm something I'm not have familiar with.
04:31:56
20
Was it a iPhone 1, 2, two, 3, 4, 5, or do
21 you recall?
22 A.
Probably the first generation of iPhones.
23 Q.
Okay. And it's your testimony that that's the phone
24 that appears in the exhibit that the jury has seen?

04:32:10
25 A.
That's the -- yes, that's the phone.

3334
1 Q.
Have you ever tried to take a message off of that
2 iPhone and erase it and then replace it with another

3 message? Have you ever tried to do that?
04:32:26
4 A.
No, sir.
5 Q.
Okay. Back to that the amount of money that you had
6 asked Mr. Stanford to advance to you, I believe the

7 exhibit refers to you wanted the money for a particular
8 purpose.
9
04:32:46
Do you remember what that was?
10 A.
Yes, sir.
11 Q.
Thank you. What was it?
12
MR. SCARDINO: Can we have the exhibit back up,
13 please? 1511A.
14 BY MR. SCARDINO:
04:33:08
15 Q.
And I'll confess, Mr. Davis, I'm having a hard time
16 reading that. Can you read it?
04:33:20
17 A.
Yes, sir.
18 Q.
And would you read it?
19 A.
"I'd like to draw."
20 Q.
Stop. What does that mean? You would like to draw?
21 What do you mean "draw"?

22 A.
I meant a conventional loan.
23 Q.
A conventional loan. Okay.
24
04:33:40
25 A.
And the amount that you want to draw?

Looks like $880,000.
3335
1 Q.
Okay. Is that what you ended up borrowing?
2 A.
I believe so. It was in two tranches, two pieces:
3 One in December and one in January.

4 Q.
04:33:59
When you told the government's prosecutors about
5 that, did they go and look to see if you actually accessed

6 that money? Do you know?
7 A.
I don't know, sir.
8 Q.
Did anybody show you any documents to show that
9 that's exactly what happened, that you got $880,000?

04:34:12
10 A.
I didn't see those documents.
11 Q.
In talking to the government prosecutors and
12 preparing for your testimony here, you didn't review any

13 documents to see whether or not you, in fact, got the
14 money?
04:34:28
15 A.
I know I got the money.
16 Q.
I know you know you got the money, but did you look
17 at the documents? Did anybody bother to subpoena your

18 bank records to see if that -- that you, in fact, got the
19 money?
04:34:36
20 A.
I don't recall.
21 Q.
Okay. You don't remember anybody -- you don't
22 remember Mr. Stellmach asking you about it on direct

23 examination that if you had looked at a bank account to
24 show that that's what happened, that you got that money?
04:34:52
25 A.
I don't remember that question.

3336
1 Q.
Okay. Let's go to the next line.
Does that say "Not through PROSPECTIVE
3 JUROR: "?
04:35:02
4 A.
Payroll.
5 Q.
Payroll. Okay?
6 A.
Yes, sir.
7 Q.
"But as a conventional loan into a company"? Is that
8 what it says?
9 A.
04:35:19
10 Q.
Yes, sir.
Okay. And you testified earlier that you had
11 actually had a lawyer draw up loan documents, but you just

12 don't have them; right?
04:35:29
04:35:44
13 A.
No, sir.
14 Q.
Would those also be in Houston in maybe your travel
15 bag you can bring and show us tomorrow?

16 A.
They would not be in Houston.
17 Q.
Okay. And where would they be located?
18 A.
I don't know where they are.
19 Q.
Have you tried to find them?
20 A.
No, sir.
21 Q.
Did the government prosecutors ask you to produce
22 those loan documents when you told them that you had had a
23 lawyer create them that would tend to verify that this is
24 what happened between you and Stanford?
04:35:56
25 A.
They did not ask me that.

3337
1 Q.
Okay. And then you go to say, "Tax otherwise eats it
2 up"?
04:36:07
3 A.
Yes, sir.
4 Q.
Did you ever pay the money back?
5 A.
No, sir.
6 Q.
Okay. Well, did you then declare it as income on
7 your tax return?
04:36:21
8 A.
No, sir.
9 Q.
Well, did you file a 2008 tax return?
10 A.
No, sir.
11 Q.
Did you file a 2009 tax return?
12 A.
No, sir.
13 Q.
Is part of your deal with the government in your plea
14 bargain you don't have to file tax returns?

04:36:32
15 A.
Attempted to file them, sir, but they -- with all my
16 other records they have been seized, I don't know where

17 those records are.
18 Q.
I see. So you haven't been able to file tax returns
19 because the receiver's got all your records?

04:36:45
20 A.
For those two years, '08 and '09 only.
21 Q.
Do you have a person helping you prepare your tax?
22 A.
Yes.
23 Q.
And are you paying them with funds that are supposed
24 to be seized by the government?

04:36:56
25 A.
I have not paid them any funds.

3338
1 Q.
Yes, sir. The person, your tax preparer, has not
2 been paid?
04:37:15
3 A.
No, sir.
4 Q.
They're just helping you out because they like you?
5 A.
I've maybe asked them one question in three years. I
6 have not been billed.

7 Q.
Has the Internal Revenue Service been in touch with
8 you about why you haven't filed a tax return in 2008?

9 A.
04:37:28
Yes.
10 Q.
Did you respond to that?
11 A.
Yes.
12 Q.
Did you tell the government prosecutors that the IRS
13 is knocking on your door about filing a tax return?

14 A.
04:37:40
I believe I did tell them that there was
15 communication, yes, sir.

16 Q.
It could create a problem with how you characterize
17 this money on your tax return, couldn't it?
04:37:54
18 A.
It could if it was not done properly.
19 Q.
And then you go on to say, "In lieu of next bonuses
20 or whatever."
21
Is that what that says?
22 A.
That's -- yes, sir, exactly.
23 Q.
And this is an e-mail you sent to a guy that you
24 claim is elusive and hard to get ahold of; right? Allen

04:38:12
25 Stanford?
3339
1 A.
Yes, sir, at times.
2 Q.
So you're asking him for almost a million dollars and
3 you want the money for whatever?

4 A.
04:38:20
It's a follow-up to a verbal conversation that I had
5 with Mr. Stanford.

6 Q.
Oh. So we have to believe you that you had a verbal
7 conversation with Mr. Stanford; right?
04:38:28
8 A.
I don't know, sir.
9 Q.
Well, I mean --
10 A.
I'm just telling you the truth.
11 Q.
Okay. Yes, sir. And then the next line is for -- I
12 can't read that. What's that say? Does that say, "For
13 note payments and service on Baldwyn biz"?
14 A.
04:38:52
04:39:00
Yes, I was telling him that it was for Baldwyn
15 businesses.
16 Q.
Was that true?
17 A.
Yes, sir.
18 Q.
Did the money go to Baldwyn businesses?
19 A.
Yes, sir. To me, it went to me. I own those
20 businesses.
21 Q.
Okay. That's different. It didn't go to the
22 businesses; it went to you?
04:39:13
23 A.
Because I owned those business.
24 Q.
Was the money -- did the -- was the money loans to a
25 business or to you?
3340
1 A.
It went into a business.
2 Q.
And do you have the documents to verify that,
3 Mr. Davis, or do we just have to take your word for it?

4 A.
04:39:31
The documents exist, and I believe all my documents
5 have been seized.

6 Q.
Okay. Did you make an effort to get them from the
7 receiver?
04:39:46
04:39:57
8 A.
No, sir, I haven't.
9 Q.
Okay. You go on to say, "and RE affairs."
10
Is that what that says?
11 A.
Yes.
12 Q.
What are RE affairs?
13 A.
Real estate.
14 Q.
Real estate. So the money -- you needed the money
15 for payments and services on a business and real estate

16 affairs?
04:40:08
17 A.
Yes, sir.
18 Q.
What real estates affairs are you referring to?
19 A.
Personal.
20 Q.
Personal?
21 A.
Related to the businesses I mentioned in Baldwyn.
22 Q.
Okay. So you had some real estate business in
23 Baldwyn?
04:40:27
24 A.
I owned some real estate in Baldwyn, yes.
25 Q.
Well, was it a real estate business?

3341
1 A.
It wasn't a real estate buy-sell business? It was
2 real estate purchased?

3 Q.
Okay. So what you say here is, it's "and real estate
4 affairs," and you're telling us that Stanford said, With

04:40:42
5 that information, I'll let you have a million dollars? Is

6 that what you're asking us to believe?
7 A.
It is what it is, yes, sir.
8 Q.
Okay. Are there any documents to back up the fact
9 that you needed the money for some real estate transaction
04:41:00
10 that you showed Mr. Stanford to try to convince him it was

11 a legitimate need for money?
12 A.
Mr. Stanford was aware of my business affairs in
13 Baldwyn.
14 Q.
04:41:13
Let's talk about what they were, Mr. Davis.
15
What was your business in Baldwyn that
16 you're referring to here?

17 A.
There were several pieces of real estate in downtown
18 Baldwyn that I purchased and they had businesses located

19 on the real estate. They were in our studio, and there
04:41:33
04:41:40
20 were interior -21
THE COURT: On what studio?
22
THE WITNESS: Art studio.
23
THE COURT: Oh, I see.
24
THE WITNESS: Art gallery. And it was a
25 interior design company.

3342
1 BY MR. SCARDINO:
04:41:49
2 Q.
These are businesses that you own?
3 A.
Yes, sir.
4 Q.
And when did you start these businesses?
5 A.
2002, '3.
6 Q.
And where did you get the money to start the
7 businesses?
8 A.
From salaries and wages. Ultimately from the CD
9 holders. Everything came from the CD holders for all the

04:42:10
10 companies and all the people in the companies.

11 Q.
So when you tell the jury you didn't steal any money,
12 that's not exactly accurate; right?

13 A.
Well, I believe I clarified that with you, sir. I
14 did steal. I stole and I lied, and I lied and stole for
04:42:24
15 many years.
16 Q.
So you change your testimony in a matter of
17 10 minutes; right?
04:42:31
18 A.
No, sir.
19 Q.
First you say you didn't steal?
20 A.
I clarified that for you when you asked the question
21 before the break.
04:42:41
22 Q.
You have a hard time with that, don't you, Mr. Davis?
23 A.
No, sir.
24 Q.
So you asked Mr. Stanford for this money, and for
25 note paid for -- something payments and service on Baldwyn

3343
1 business and real estate affairs. Okay.

2
So it indicates here that you need the
3 money for two different reasons, does it not? For service

4 on Baldwyn business, period, and real estate affairs;
04:43:03
5 right?
6 A.
Yes.
7 Q.
Okay. And then you go on to say another reason you
8 need the money.

9
04:43:10
What else?
10 A.
Working capital for first six months of '09.
11 Q.
Working for what, Mr. Davis?
12 A.
For the businesses aforementioned.
13 Q.
So all of this money that you're asking Mr. Stanford
14 for is to help you with these businesses that you started

04:43:27
15 in Baldwyn, Mississippi, that are yours alone?

16 A.
I think you've got it, sir.
17 Q.
Okay. And did you own these businesses with anybody
18 else?
04:43:38
19 A.
One of them I did.
20 Q.
Who are you in business with?
21 A.
Other than my wife, there was a restaurant I was
22 50/50 owner with.
04:43:49
23 Q.
Who was your partner?
24 A.
Laura Holt.
25 Q.
Oh, that's the lady you had the relationship with?

3344
1 A.
Yes. Had an affair with Ms. Holt.
2 Q.
And, so, you also had a personal relationship and a
3 business relationship with her?
04:44:02
4 A.
That's what I testified to. Yes, that's true.
5 Q.
And did you live in Baldwyn, Mississippi at the time
6 that you started this business with Ms. Holt?
04:44:16
7 A.
Yes.
8 Q.
Okay. And you live there with your wife?
9 A.
I live with my wife, yes.
10 Q.
In Baldwyn, Mississippi?
11 A.
Outside in the country, yes.
12 Q.
So you start a relationship with a woman and you go
13 into business with her in the home where you live, right,
14 with your family?
04:44:26
04:44:37
04:44:47
15 A.
Yes, sir, I had a relationship with Ms. Holt, and --
16 Q.
Did you deceive your wife with that relationship?
17 A.
Yes, I certainly did.
18 Q.
And when was that?
19 A.
2001.
20 Q.
2001?
21 A.
'2 and '3.
22 Q.
So for three years?
23 A.
Almost, yes.
24 Q.
Lied to your wife?
25 A.
Yes, sir.
3345
1 Q.
Let's go back to this.
04:44:56
What's the next line say?
3 A.
Which one?
4 Q.
After the highlight, it says -- what does that say?
5 Can you read it?

6 A.
Yes.
7 Q.
What's it say?
8 A.
"It can go through Venture Capital, maybe split into
9 two tranches, half now, half January."

04:45:08
10 Q.
Why are you asking that if -- or saying that it can
11 go through venture capital?

12 A.
The loan can come from Venture Capital as a company
13 that is -- it was a Stanford company.
04:45:24
14 Q.
Had assets, didn't it?
15 A.
Yes, it had assets in it.
16 Q.
You were the CFO, so you knew where the money was;
17 right?
04:45:41
18 A.
I also knew where the money wasn't.
19 Q.
But when you're trying to make it look like you're
20 borrowing this money and you generate this document, you

21 want it to look like you are getting it somewhere that you
22 know money exists?
04:46:00
23 A.
Yes.
24 Q.
Yes?
25 A.
I committed fraud.
3346
04:46:08
1 Q.
Then you go on to say, "May be split in two" --
2 A.
Yes, sir.
3 Q.
-- "transactions, half now, half in January."
4 A.
Yes, sir.
5 Q.
Was that in the loan documents that you had your
6 lawyer prepare, that you would get half the money when you
7 generated this document and half later? Was that part of
8 the loan agreement?
9 A.
04:46:24
I don't believe it was in the loan agreement that it
10 would be in two tranches.

11 Q.
And Mr. Davis, when -- you said you got the money;
12 right?
04:46:37
13 A.
Yes, sir.
14 Q.
And how was it transferred, or where -- I guess
15 better stated, where did the money come from? Did it come
16 from Stanford Venture Capital?
17 A.
I don't recall.
18 Q.
Didn't think it was important to go back and look to
19 see where you got the money?

04:46:50
20 A.
It came from the Houston office in terms of --
21 technically, it was --
04:47:09
22 Q.
All right. And how was it transferred to you?
23 A.
A wire transfer.
24 Q.
A wire transfer. And would you explain what that is
25 to the jury? What's a wire transfer?

3347
04:47:20
04:47:36
1 A.
It's an order to a bank --
2 Q.
Yes, sir.
3 A.
-- to send money.
4 Q.
Okay.
5 A.
It's done by wire, by telephonics --
6 Q.
Okay. And --
7 A.
-- to another bank, one bank to another bank.
8 Q.
A transaction that you're familiar with?
9 A.
Yes.
10 Q.
And it doesn't mean that currency is generated? I
11 mean, you don't -- you're not reaching in your pocket and

12 pulling out dollar bills, are you?
04:47:48
13 A.
No, sir.
14 Q.
It's a paper transaction, isn't it, in effect, or a
15 wire transaction?
16 A.
It's registered on paper. It's an actual transfer of
17 currency, yes.
18 Q.
So what you're asking -- when you say Mr. Stanford
19 says, "Your decision. Call you on my whatever," you acted

04:48:09
20 on that.
21
Did you act immediately or did you wait a
22 little while?
04:48:18
23 A.
The action took place later, weeks later.
24 Q.
Weeks later; okay?
25
And, so, you instruct a bank to wire the

3348
1 money to another bank. Is that correct?

2 A.
Gave the instruction to Patricia Maldonado, the
3 treasury manager, and she did that, yes.

4 Q.
04:48:37
So when you did that, when you wired it from Bank A
5 to Bank B, it was just like money, though, because you got

6 it when it was wired. Is that correct?
7 A.
Yes, sir.
8 Q.
Just like the way CD holders had money when it --
9 money was transferred by paper, it had value; right? Same

04:48:50
10 type of thing?
11 A.
I don't understand your last remark.
12 Q.
When -- the money, when Mr. Stanford's venture
13 capital company -- what bank was used for that -- those

14 transactions for Stanford Venture Capital. Do you recall?
04:49:10
15 A.
No. It possibly could have been Trustmark Bank.
16 Q.
Well, you were the CFO, and you're the one that got
17 the money.
18
19 A.
04:49:22
I mean, you don't remember the bank?

Had 30 or 40 bank accounts. I can't remember every
20 one of them.
21 Q.
All right. So it was a bank that Stanford Venture
22 Capital had assets, and you instructed that bank to wire

23 almost a million dollars out of the bank, didn't you?
04:49:35
24 A.
Yes, sir.
25 Q.
It wasn't Mr. Stanford that instructed the bank to

3349
1 wire the money out of the bank. It was you that did it,
2 wasn't it?
04:49:45
3 A.
In this case, yes.
4 Q.
In this case, yes.
And did you have any documents that you
6 submitted to the bank to demonstrate to the bank that

7 Mr. Stanford had given you permission to take almost a
8 million dollars out of a bank in a company that he owns a
9 hundred percent of and give it to you? Did you provide
04:50:01
10 the bank with any documents?

11 A.
I didn't provide the bank, no.
12 Q.
You didn't have to do that because they knew you were
13 Mr. Stanford's CFO and that you had the authority to do

14 that without any loan documents or authority from
04:50:12
15 Mr. Stanford to make that transaction?

16 A.
I thought it was passed, sir, to Patricia Maldonado,
17 who actually made the transaction.

18 Q.
Do you have documentation to show that that occurred,
19 that you asked the treasurer, Ms. Maldonado, to effect

04:50:26
20 this?
21 A.
It exists. I don't have it personally.
22 Q.
Oh, this is something else that is nobody can get
23 that's somewhere in the receiver's home. Is that right?
04:50:33
24 A.
I don't know where it is, but it --
25 Q.
Is that going to be the answer to all -Johnny C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3350
THE COURT: Hold it. Let him finish.
You may finish.
THE WITNESS: Let me ask you this, too, if I
4 could.
04:50:39
THE COURT: No.
6 BY MR. SCARDINO:
7 Q.
You can't.
8 A.
Sir, could I ask you a question?
9
04:50:47
MR. SCARDINO: Well, if he's going to do it,
10 I'd like it to be out of the presence of the jury.

11
THE WITNESS: It has to do with my ears. Since
12 the Navy, I've worn -- I can't hear well. I've got hearing
13 aids.
04:50:56
14
THE COURT: All right. So what would help you?
15
THE WITNESS: It would help if talk slower,
16 and -17 BY MR. SCARDINO:
04:51:02
18 Q.
You want me to talk slower?
19 A.
Yeah, a little bit.
20
THE COURT: Okay.
21 BY MR. SCARDINO:
22 Q.
We have a hearing devices here, Judge. We've got
23 these things --
04:51:07
24 A.
I have hearing aids on.
25 Q.
These are better.

3351
THE COURT: Hold it. In other words, it works
2 okay.
3
THE WITNESS: Just normal tone without jumping
4 around and changing the inflection of your voice, et

04:51:19
5 cetera. If you could just be standard, I'll catch it all.

6 Otherwise, I'll have to ask you to repeat it.
7
THE COURT: You're asking him to be calm, in
8 other words?
9
04:51:29
THE WITNESS: Well, just a steady.
10
THE COURT: All right. See if you can modulate
11 your tone.
12
If you can't, we have some other
13 alternatives that might help you.
04:51:35
14
THE WITNESS: Thank you, sir.
15
THE COURT: We've just been electrified
16 including folks that do have a hearing impairment that have

17 extra amplification. But we're not there yet. Let's give
18 it a try.
04:51:46
19
THE WITNESS: Thank you, Your Honor.
20
MR. SCARDINO: That's like asking me to be
21 six-feet tall, Judge.

22
THE COURT: Well, give it a try.
23 BY MR. SCARDINO:
04:52:00
24 Q.
You're uncomfortable up there, Mr. Davis?
25 A.
No. I'm relaxed. Go ahead.

3352
1 Q.
So the document that would indicate that you had
2 asked the treasurer of Stanford companies, Betty

3 Maldonado --
04:52:14
4 A.
Patricia Maldonado.
5 Q.
I'm sorry. Patricia. I know a Betty Maldonado. I'm
6 sorry. Patricia Maldonado.

7 A.
Sure.
8 Q.
The document that would verify what you're telling
9 this jury is in the hands of the receiver; is that right?

04:52:31
10 A.
The document and the computer records.
11 Q.
Do you know whether or not these -- your Assistant
12 United States Attorneys with subpoena power made an effort

13 to obtain those documents so that we wouldn't have to take
14 your word for it, Mr. Davis?
04:52:48
15 A.
Well, sir, I believe that they could get that
16 information for you.

17 Q.
Do you know if they've tried?
18 A.
I'm not certain of that. I believe they could get
19 that, though, for you, sir, if you asked them.

04:53:03
20 Q.
Yes. So are you telling the jury that it wasn't you
21 that instructed the bank to make the wire, that it was

22 Ms. Maldonado that was -- instructed the bank to make the
23 wire transfer?
24 A.
04:53:21
25
This is my doings. I did it. It's wrong.

MR. SCARDINO: Objection. Nonresponsive.
3353
THE WITNESS: No, I'm not telling that -- I'm
3 not telling the jury that.

4 BY MR. SCARDINO:
04:53:30
5 Q.
Because it was you that actually made -- made the
6 instruction to make wire transfer; correct?

7 A.
Yes, sir. I've already said that.
8 Q.
Now, this was a company called Stanford Venture
9 Capital.
04:53:40
10
Do you remember talking about that company
11 with Mr. Stellmach on direct examination? Remember you -12 in fact, if I recall, Mr. Davis, you drew us -- somewhere
13 in all of this, you made a reference to Stanford Venture
14 Capital. Let's see if we can find it. Wow, there was a
04:54:03
15 lot of them.
16
See here, Stanford Venture Capital. Is
17 that what that is?
04:54:26
18 A.
Yes.
19 Q.
Did you draw this?
20 A.
I drew it.
21 Q.
You drew it. What did you tell the jury Stanford
22 Venture Capital was?
04:54:35
23 A.
It's a shell holding company.
24 Q.
Shell holding company.
25
And what do you -- explain that to the

3354
1 jury. What's a shell company? Is it fake?

2 A.
It's a real company that holds certain other
3 companies, passes funds through.

4 Q.
04:54:52
Well, you indicated to the jury that it was some
5 negative connotation, that it was just some kind of a

6 shell company that was used to facilitate a fraud. Isn't
7 that right?
8 A.
No. I said it was a shell company. It's a real
9 company in terms of legal -- it's a legally granted

04:55:17
04:55:25
10 company, articles, et cetera.

11 Q.
Okay. So you're --
12 A.
But it's a --
13 Q.
Sorry?
14 A.
-- it's a pass-through company.
15 Q.
Pass-through company. So when you say "shell
16 company," you don't -- you're not telling the jury that it

17 was something negative about calling it a shell company,
18 are you?
19 A.
04:55:41
04:55:46
It's a company, a shell company, not having
20 employees -21 Q.
Yes, sir.
22 A.
-- basically.
23 Q.
Okay.
24 A.
Yes, sir.
25 Q.
But this shell company that you referred to is the

3355
1 company where you got almost a million dollars out of it;

2 right?
3 A.
Well, I got the money. I'm not certain it came from
4 that particular company, but I did get the money. That

04:55:59
5 was the suggested source of the money.

6 Q.
So you don't recall where you got the money?
7 A.
Got it from an account at Stanford Financial.
8 Q.
And the purpose of the money, of asking Mr. Stanford
9 for the money was to help you with funding your businesses
04:56:20
04:56:48
04:57:00
10 in Baldwyn, Mississippi. Is that right?

11 A.
That was the purpose.
12 Q.
Okay. And no other reason?
13 A.
I don't think so.
14 Q.
You said Stanford Venture Capital had no employees;
15 right?
16 A.
I don't think they did.
17 Q.
But you're the CFO. You should know; right?
18 A.
I said I don't think they did. I don't --
19 Q.
You testified earlier they had no employees and
20 that's what made it a shell company.

21
MR. STELLMACH: Objection. That
22 mischaracterizes his testimony.

23
THE COURT: Sustained to the extent that he can
24 agree or disagree with that statement.

04:57:10
25
Ask it again, if you desire.

3356
1 BY MR. SCARDINO:
04:57:20
2 Q.
Did it have employees?
3 A.
Not to my recollection.
4 Q.
You were the CFO?
5 A.
I was.
6 Q.
Okay. That's what I said -- that's what I asked you.
In fact, while we're on that subject,
8 what -- tell -- explain what a CFO is to the jury.

9 A.
04:57:32
Chief financial officer or CFO is in charge of the
10 finance and accounting of -- generally in charge of

11 finance and accounting in a company, including
12 scorekeeping and reporting.
13 Q.
And that's what you did for Mr. Stanford's companies;
14 right? Or particularly -04:57:46
15 A.
Among other things, yes.
16 Q.
I mean, but it was particularly the bank, Stanford
17 bank. Is -- you were the CFO of the bank or other

18 companies?
19 A.
04:57:59
I was CFO of Stanford Financial Group and CFO of
20 Stanford International Bank.

21 Q.
So you actually had access to all of the -- all the
22 accounting information?
23 A.
I had access to it. There was a local controller at
24 the bank who had most of the details.

04:58:18
25 Q.
You keep track of the money; right?

3357
1 A.
The CFO responsibility down the chain, yes.
2 Q.
Keep track of the money. Keep track of the
3 investments. Is that right?
04:58:36
4 A.
It's in -- that's in that responsibility.
5 Q.
Keep track of what's coming in and what's going out;
6 right?
7 A.
Yes.
8 Q.
So you basically knew what was really going on with
9 these companies. Is that right? Is that what you're

04:58:48
10 telling the jury?

11 A.
Yes, generally I did.
12 Q.
You were the conduit for all that information more
13 than anybody else in the organization?
04:59:00
14 A.
No, sir, I wouldn't characterize it that way.
15 Q.
Well, you were more -- you had more -- you had access
16 because of your title to more of that type of information

17 than Mr. Kuhrt; right?
04:59:14
04:59:24
18 A.
No, sir.
19 Q.
No? You were the CFO; right? And he wasn't. He was
20 below you. He reported to you, didn't he?

21 A.
He had the same access that I did.
22 Q.
But he reported to you?
23 A.
He did.
24 Q.
Mr. Lopez the same; right? He reported to you?
25 A.
Mr. Lopez reported to me. Mr. Kuhrt reported to the

3358
1 global organization, which is run by Mr. Stanford.
04:59:41
2 Q.
Okay.
3 A.
He was the global controller.
4 Q.
But the title CFO was -- indicates that that guy is
5 in charge. The chief financial officer, he's in charge of

6 finances?
04:59:55
7 A.
The bank and Stanford Financial Group.
8 Q.
Finances?
9 A.
I was not CFO of Stanford Global to my knowledge.
10 Q.
So let's go back to this loan for just a second.
11
The money was used to fund you say some
12 real estate and other things.

13
You testified you were making -- I'm
14 trying to remember. Was it one point -- no. 900,000?

05:00:09
15 A.
Yes sir.
16 Q.
900,000 a year at the end. And you got bonuses in
17 addition to that; right?
05:00:19
18 A.
I did.
19 Q.
Back in 2008, how much money did you make?
20 A.
$2 million. In excess of $2 million.
21 Q.
In excess of $2 million?
22 A.
Yes.
23 Q.
Does that include the money you stole, or does that
24 not include the money you stole?

05:00:31
25 A.
I believe that includes it.

3359
1 Q.
Includes the money you stole. Okay.
And have you -- have you got a fundamental
3 tax return prepared for 2008?
05:00:40
4 A.
No, sir.
5 Q.
Y'all haven't put that together?
6 A.
'8 or '9, I did not.
7 Q.
So when you -- you're making this money -- I mean,
8 you have a total figure for 2008? What did you say? Was
9 it 2 million or 3 million?
05:00:56
10 A.
In excess of $2 million.
11 Q.
In excess of 2 million.
12
Well, does that mean it was more than 3
13 million?
14 A.
05:01:05
It means what I said. It's in excess. I don't know
15 the exact number.

16 Q.
Well, Mr. Davis, in excess of 2 million could be 10
17 million; right?
05:01:14
18 A.
It was less than three.
19 Q.
Less than three. Okay. So more than two and less
20 than three; right?

21 A.
Probably -- keep batting it back and forth. Maybe
22 2.4, 2.3.
23 Q.
Okay. So your income for 2008 was about right around
24 two and a half million dollars?

05:01:24
25 A.
Could have been.

3360
1 Q.
Well, I mean --
2 A.
I don't have the numbers. I don't recall.
3 Q.
You were the CFO of a multibillion-dollar operation.
4
05:01:35
You can't keep track of how much money you
5 made?
6 A.
I keep track of it when I have my records, yes, sir.
7 Q.
Oh, I forgot. The receiver's got all your records.
You have access to no other records;
9 right?
05:01:45
05:02:02
05:02:17
10 A.
No, sir.
11 Q.
Okay. How about 2007? How much did you make then?
12 A.
I'd say 1.8, 1.9 million.
13 Q.
And in 2006?
14 A.
1.6.
15 Q.
I mean, did you consider that a lot of money?
16 A.
Yes, sir, I would. Very, very much.
17 Q.
And you could live well on that; right?
18 A.
Yes.
19 Q.
I mean, did you have a lot of expenses, Mr. Davis?
20 A.
Yes.
21 Q.
I mean, what kind of expenses?
22 A.
The monies were put into those Baldwyn projects that
23 you've so well covered already.
05:02:31
24 Q.
Okay. The ones that you owned with Ms. Holt?
25 A.
One of them was owned with Ms. Holt, yes.

3361
1 Q.
How many companies were there?
2 A.
I believe there were five.
MR. SCARDINO: May I have just a minute, Your
4 Honor?
05:02:56
THE COURT: Yes.
6 BY MR. SCARDINO:
7 Q.
Well, Mr. Davis, was it -- did you make a bad
8 investment with these companies that you started in

9 Baldwyn?
05:03:36
05:03:48
10 A.
Did I make a bad investment? I would say so.
11 Q.
You real estate; right?
12 A.
Yes. It was --
13 Q.
2008. Real estate wasn't doing too well, was it?
14 A.
Generally, no.
15 Q.
Generally, no.
16
In fact, one of the problems Stanford was
17 having was because the assets that were part of the

18 company were -- some of them were in real estate, and some
19 of those assets were going one way and some were going the
05:03:58
20 other way.
But real estate generally in the U.S. wasn't
21 doing well back then, was it?

22 A.
No, sir.
23 Q.
Okay. And did you need money to help fund these
24 companies? Did you -- were you in bad shape, or did you

05:04:15
25 save any of that two and a half million dollars you were
3362
1 making and one and a half million dollars you had been
2 making?
3 A.
You've got about six questions there. Would you
4 narrow it down for me, please.

05:04:28
5 Q.
I'm get right to it, Mr. Davis.
MR. SCARDINO: Let me -- I'll offer Defense
7 Exhibit Number 13-83. That's the only copy I've got. Let
8 me give you the original.
9
05:04:51
MR. STELLMACH: No objection.
10
MR. SCARDINO: No objection.
11
THE COURT: Any objection?
12
MR. SCARDINO: 13-83.
13
MR. STELLMACH: I'm sorry, Your Honor. No
14 objection.
05:04:57
15
THE COURT: Defendant 13-83 is admitted.
16
MR. SCARDINO: Can we have it, please?
17
Man, I can't see that. Can you make it
18 any clearer? There you go.

19 BY MR. SCARDINO:
05:05:14
20 Q.
Mr. Davis, can you -- can you see what that is?
21 A.
Yes, sir, I can.
22 Q.
That's -- what is it?
23 A.
It is the statement from Merchant -- Farmers and
24 Merchant Bank where I had an account styled Davis

05:05:32
25 Holdings.
3363
05:05:45
05:05:53
1 Q.
Okay. And James M. Davis, manager/member; right?
2 A.
Yes, sir.
3 Q.
Post office box?
4 A.
70.
5 Q.
And is this -- this is your banking account; right?
6 A.
It is.
7 Q.
Do you have any other bank accounts?
8 A.
Yes, I did.
9 Q.
How many did you have?
10 A.
I would say six or seven.
11 Q.
Were they all in the United States?
12 A.
Yes, sir.
13 Q.
Did you ever have a bank account or an account with
14 Guardian Bank when it was in Montserrat?

05:06:10
15 A.
I don't think so.
16 Q.
Did you ever have a bank account with Stanford
17 International Bank, Limited located on the Island of

18 Antigua?
05:06:26
05:06:46
19 A.
I don't think so.
20 Q.
So all of your bank accounts were U.S. banks?
21 A.
Yes, sir, I believe so.
22 Q.
No Swiss bank accounts?
23 A.
No, sir.
24 Q.
Now, this bank account, what was it used for?
25 A.
It was the account for the administrative and

3364
1 accounting company, Davis Holdings, and cash would flow

2 from this account into other businesses there in Baldwyn.
3 Q.
Would it not have been easier to put money into those
4 business accounts?
05:07:19
5 A.
Possibly.
6 Q.
I mean, was your little business set up kind of like
7 Stanford was? Money came into one entity and flowed into
8 other entities? Is that what happened?
9 A.
05:07:34
10 Q.
I guess I learned from the master.

You set all those accounts up with Stanford, didn't
11 you?
05:07:41
12 A.
Yes, sir.
13 Q.
You're the one that set those up?
14 A.
No, sir. No, sir.
15 Q.
Well, let's look at your bank account here that you
16 say you used to put money in and then send money out.
17
This statement shows a balance last
18 statement. Can you see that on the right?
05:07:58
19 A.
Yes, sir.
20 Q.
And the date?
21 A.
Yes, sir.
22 Q.
That top line, balance last statement. What's the
23 date?
05:08:07
24 A.
November 28, 2008.
25 Q.
And what's the balance?

3365
05:08:18
1 A.
Negative, 58,000.
2 Q.
Negative 58,000?
3 A.
Yes, sir.
4 Q.
In 2008; right?
5 A.
Yes, sir.
6 Q.
Aren't you the guy making two and a half million
7 dollars a year?
05:08:34
8 A.
Yes, sir.
9 Q.
Okay. And somehow your account here is minus over
10 58,000?
11 A.
That's pretty clear.
12 Q.
How long has this account been in the negative,
13 Mr. Davis?
05:08:43
14 A.
I would say not too long. I don't know.
15 Q.
Not too long.
16
So when it got negative, you needed a way
17 to put money in it, didn't you?
05:08:55
18 A.
Makes sense.
19 Q.
Well, yeah. You found a real easy way to put money
20 in it. It was from Allen Stanford, wasn't it?

21 A.
In this case, yes, sir.
22 Q.
Had you spent all of your two and a half million
23 dollars, Mr. Davis?
05:09:03
24 A.
Yes, sir.
25 Q.
All gone?
3366
05:09:16
1 A.
Apparently.
2 Q.
Where did it go?
3 A.
It went into investments in Baldwyn.
4 Q.
Have you got those documents to verify that?
5 A.
If they exist, I don't have them personally, no.
6 Q.
So let's run down this line here from November 28,
7 2008. And then it keeps getting in the negative. You

8 keep writing hot checks, don't you? You wrote one for
9 $37.69, didn't you? On the next line; right?
05:09:41
10 A.
Yes, sir.
11 Q.
Guy making two and a half million dollars a year
12 writes a hot check for $37.69.

13
14 A.
05:09:55
Can you explain that?

Had an overdraft provision by the bank granted. And
15 that's my response.
16 Q.
That's your response?
17 A.
Yes, it is.
18 Q.
So you had a overdraft position with the -- provision
19 with the bank. You didn't just keep money in a money

05:10:06
20 market account so that you could cover your overdrafts;

21 right?
22 A.
In this case, I didn't.
23 Q.
In fact, you were in such bad shape, stayed negative
24 all the way down through the bottom. On 12-10 it's

05:10:24
25 negative $73,069.21.
3367
MR. SCARDINO: And then we go to the next page,
2 Page 2. There you go.

3 BY MR. SCARDINO:
4 Q.
05:10:41
The second line it shows you get all the way down to
5 negative -- you wrote a five thousand-dollar hot check on

6 the second line, $5,563. And that got you a negative
7 $78,722.80; right?
05:11:04
8 A.
Yes, sir.
9 Q.
And then you caused something to happen on the next
10 line, didn't you?

11 A.
Yes, sir. Approved by Mr. Stanford, I did, yes.
12 Q.
We have to believe you that it was approved by
13 Mr. Stanford, don't we, Mr. Davis?

14 A.
05:11:20
Well, I'm telling the truth. It was also on the
15 exhibit that you shown me several times -16 Q.
Yes, sir.
17 A.
-- with the iPhone.
18 Q.
So there's a wire from JPW, from Stanford Venture.
19 Is that right?
05:11:40
20 A.
That's what it says, yes, sir.
21 Q.
For $390,000. Is that correct?
22 A.
Yes, sir, it is correct.
23 Q.
And then you go down and you show that right after
24 that you write a check for $270,000. Is that correct?

05:11:58
25 A.
It was a debit, yes.

3368
05:12:11
1 Q.
Right?
2 A.
Check Number 2283.
3 Q.
Where did that money go?
4 A.
Deposited it into one of the other companies, I
5 believe.
6 Q.
This just wasn't a way for funnel money out of the
7 Stanford's money into your pocket, Mr. Davis?

8 A.
Yes, sir.
9
05:12:29
MR. SCARDINO: I'd offer Defense Exhibit 13-84.
10
THE COURT: Is it 13-84?
11
MR. SCARDINO: That is correct, Your Honor.
12
MR. STELLMACH: No objection, Your Honor.
13
THE COURT: Thank you. It's admitted.
14 BY MR. SCARDINO:
05:12:44
15 Q.
Would you look at the top of that, Mr. Davis? Can
16 you read it?

17 A.
Farmers and Merchants Bank.
18 Q.
That's your bank account -- your bank where you
19 banked?
05:12:53
05:13:04
20 A.
Yes, sir.
21 Q.
One of your banks; right?
22 A.
23 Q.
And it's titled Davis Holdings, LLC?
24 A.
Yes, it is.
25 Q.
James M. Davis, manager/member. Is that you?

3369
1 A.
Yes, sir.
MR. SCARDINO: Let's go to the top line there,
3 under commercial checking account.

4 BY MR. SCARDINO:
05:13:14
5 Q.
Is this the same account that we just previously
6 referred?
7 A.
It is, yes, sir.
8 Q.
Okay. And, so, this is your account, and it shows
9 last -- balance last statement on 12-31-08 is $1,524.98;

05:13:34
10 right?
11 A.
Yes, sir.
12 Q.
So that means that it didn't take you long to go
13 through that $330,000, did it?
05:13:43
14 A.
No, sir.
15 Q.
In fact, very soon after that, you're in the negative
16 again. You write a check for $7,252, which puts you in

17 the negative once again --
05:13:57
18 A.
Yes, sir.
19 Q.
-- is that correct? Okay.
20
MR. SCARDINO: And then let's scroll all the
21 way down to the line that says, "Wire from Stanford Venture
22 Capital." Right there.
23 BY MR. SCARDINO:
05:14:07
24 Q.
When did that happen?
25 A.
Happened on the 14th of January.

3370
1 Q.
So now, I want to ask you: Is there any question in
2 your mind, Mr. Davis, that the way you got this money was
3 from Standard Venture Capital? Earlier you testified you
4 weren't sure. But any question in your mind now how you
05:14:26
5 accessed that money?

6 A.
No, sir. No, sir. It's clear.
7 Q.
And did you do it in the very same manner that you
8 had done the month before by sending wire instructions to

9 Stanford Venture Capital with the bank that held their
05:14:39
10 funds and instructed them to wire $600,000 into your

11 account at Farmers & Merchants Bank?
05:14:54
05:15:02
12 A.
Yes, sir, I did.
13 Q.
And how much is that, Mr. Davis? You're the CFO.
14 A.
990.
15 Q.
That's 990?
16 A.
Yes, sir.
17 Q.
Right at a million dollars, isn't it?
18 A.
Yes, sir.
19 Q.
Okay. Let's look and see what you did with that
20 money. You started writing checks on it, did you not?

21 A.
Yes, sir.
22
MR. SCARDINO: Let's scroll down to the third
23 page, please. And then go on -- let's just move on to the

24 last page.
05:15:21
25 BY MR. SCARDINO:
3371
1 Q.
What did you do with that money, Mr. Davis?
2 A.
I spent it. Invested it into a business in Baldwyn,
3 and spent it.
05:15:40
4 Q.
You needed the money, didn't you?
5 A.
Yes. Yes, sir.
THE COURT: You can pull that mike in, if you
7 want.
8 BY MR. SCARDINO:
9 Q.
05:15:55
In fact, you always needed money, didn't you,
10 Mr. Davis?
11 A.
Yes. Everyone needs money. I needed money. Yes,
12 sir.
13 Q.
You needed more than Mr. Stanford was paying you,
14 didn't you?
05:16:09
15 A.
At that point, yes, sir.
16 Q.
At the point where you had been paid -- already been
17 paid $14 million, and you still needed money and were
18 writing hot checks in the amount of $27; right?
19 A.
05:16:26
Yes, sir, I did get $14 million over 21 years, yes,
20 sir, I did.
21 Q.
That's pretty good money to steal money, isn't it?
22 A.
I don't understand your question, motive.
23 Q.
Well, the fact that you had made $14 million and had
24 spent it all and you find yourself broke at the end of

05:16:43
25 2008, you found a way to get some more money, didn't you?
3372
1 A.
I asked for it, Mr. Stanford approved it, and at the
2 end of the day, it was taken from the CD holders.

3 Q.
Well, you took this money from Mr. Stanford, didn't
4 you? Regardless of the original source of it, it came out

05:17:01
5 of an account that he owned from a company that he owned

6 and you took it, didn't you?
05:17:28
7 A.
At his approval, yes, sir, I did. He approved it.
8 Q.
We have to take your word for that, don't we?
9 A.
No, sir.
10
MR. SCARDINO: Let me go back. Can we go back
11 to Government's 1511-A again for just a second.

12 BY MR. SCARDINO:
05:17:44
13 Q.
How much did you tell him you needed?
14 A.
880.
15 Q.
You told the jury you had loan documents prepared to
16 borrow that much; right?
05:17:54
17 A.
Whatever the amount taken.
18 Q.
How much did you take?
19 A.
990.
20 Q.
Did you change the loan documents to reflect that?
21 A.
I believe the loan documents reflect the 990, what
22 came in.
23 Q.
I'm going to shift topics on you, Mr. Davis.
24
05:18:07
25 A.
Are you okay now? Are you all right?

I think so.
3373
05:18:13
1 Q.
My tone of voice okay?
2 A.
Thank you.
3 Q.
You're welcome?
4 A.
I can hear well.
5 Q.
Good.
05:18:25
How long have you been wearing hearing aids?
7 A.
Several years.
8 Q.
How old are you?
9 A.
63.
10 Q.
You're just a young man, Mr. Davis.
11 A.
Thank you, sir.
12
MR. SCARDINO: I'd like to refer to
13 Government's Exhibit 112. Would you bring it up, please.

14 BY MR. SCARDINO:
05:18:41
15 Q.
Is a document -- or exhibit, Mr. Davis, that we --
16 lawyers use these terms. Maybe -- this is a document that

17 some lawyer finds. In this case, it was the government.
18 And then they want to bring it in before the jury to show
19 the jury, and the Judge decides whether it's admissible or
05:19:02
20 not. So now it's evidence. So we call it -- we refer to

21 it sometimes by different names. If it's confusing to
22 you. That was kind of confusing, wasn't it?
23
THE COURT: Just for my records, this was
24 not -- was this referred to by the government in the past?

05:19:16
25
MR. STELLMACH: It has been, Your Honor.

3374
THE COURT: So it's in our file. Because,
2 remember, my notes don't go back to the first couple of

3 days until we started this recordkeeping.
4
05:19:25
Go right ahead.
5 BY MR. SCARDINO:
6 Q.
Mr. Davis, this is a document, an exhibit, that
7 Mr. Stellmach, I believe, talked to you about. Do you

8 remember it?
9 A.
05:19:36
Yes, sir.
10 Q.
What is it?
11 A.
It's a Stanford International Bank, Limited, annual
12 report for 1999 cover.

13 Q.
Let's talk a minute about what is an annual report?
14 In the corporate world, what's an annual report?

05:19:52
15 A.
Annual report issued at the end of a fiscal year of a
16 company, meaning their year end calendar or otherwise,

17 sums up the transactions, the financial transactions of
18 the business.
05:20:12
19 Q.
Okay. And who prepares the annual report?
20 A.
The accounting people.
21 Q.
The accounting people?
22 A.
Yes, sir.
23 Q.
Okay. The people that have access to the information
24 that they put in the report?

05:20:21
25 A.
That's correct.
3375
1 Q.
Okay. And is it something that's required to be
2 prepared and filed?

3 A.
I would say most board of directors require it. A
4 lot of times if there is an oversight agency, they require

05:20:37
05:20:47
5 it.
6 Q.
Did the Stanford board of directors require it?
7 A.
If -- yes.
8 Q.
They did?
9 A.
Yes, sir.
10 Q.
And you were on the board, weren't you?
11 A.
I was, yes, sir.
12 Q.
Who else was on the board?
13 A.
Mr. Allen Stanford, Mr. James Stanford, Mr. Bill
14 Goswick.
05:20:57
05:21:03
15 Q.
Stop. Let's do them one at a time.
16 A.
Yes, sir.
17 Q.
James Stanford?
18 A.
Yes, sir.
19 Q.
Tell the jury who he is.
20 A.
That's Allen Stanford's father.
21 Q.
So he was on the board of Stanford International
22 Bank?
05:21:14
23 A.
Yes, sir.
24 Q.
And what role did he play on the board?
25 A.
He was originally the chairman, and then following

3376
1 years, he became chairman emeritus.

2 Q.
Now, I believe you told the jury that the fraud was
3 going on in 1999; right?
05:21:29
4 A.
Yes, sir.
5 Q.
And, so, let's jump back to the board for a minute.
6 Mr. James Stanford was on the board and chairman of the

7 board; correct?
8 A.
Emeritus. Mr. Allen Stanford was chairman of the
9 board at this time.

05:21:39
10 Q.
In '99?
11 A.
I believe so, yes.
12 Q.
Before that, it was his father, James Stanford?
13 Let's focus --
05:21:49
05:21:55
14 A.
Yes, sir.
15 Q.
-- on '99.
16 A.
Okay.
17 Q.
So do you remember who was chairman?
18 A.
I believe it was Allen Stanford.
19 Q.
Believe it --
20 A.
Yes, sir.
21 Q.
Besides yourself -- you got yourself and you've got
22 James Stanford, you've got Allen Stanford. Who else?
05:22:07
23 A.
Bill Goswick.
24 Q.
Now, who is Mr. Goswick?
25 A.
Was a businessman from Central Texas.

3377
1 Q.
Did you know him?
2 A.
Yes, sir.
3 Q.
And how long had you known him before you were on the
4 board?
05:22:15
5 A.
Three or four years.
6 Q.
And what kind of business was Mr. Goswick in?
7 A.
I believe he was in automobile sales business and
8 cattle ranching.
9 Q.
05:22:29
05:22:41
Do you know anything else about his background other
10 than cattle and automobiles?

11 A.
No, sir.
12 Q.
Who else was on the board?
13 A.
Don Caldwell.
14 Q.
Tell us who Mr. Caldwell is. Actually, Judge
15 Caldwell; right?
16 A.
He was a judge.
17 Q.
And tell the jury about Judge Caldwell.
18 A.
I met Judge Caldwell. I knew him. He was on the
19 board.
05:22:49
20 Q.
How long had you known him?
21 A.
Same amount of time I had known Bill Goswick.
22 Q.
Okay. And had these guys, Goswick and Caldwell, been
23 around a while? Were they young men, middle-aged men,

24 elderly men?
05:23:04
25 A.
Late middle age.

3378
05:23:12
1 Q.
Late middle age?
2 A.
Yes, sir.
3 Q.
Okay. Who else was on the board?
4 A.
Kenneth Allen.
5 Q.
And tell us who he was.
6 A.
Mr. Allen was a barrister, solicitor, in the Western
7 Indies -- West Indies.
05:23:31
05:23:38
8 Q.
Do you understand what a barrister and solicitor --
9 A.
That's the equivalent in many respects to our
10 attorney -11 Q.
Okay.
12 A.
-- in the United States.
13 Q.
So he's really a British lawyer; right?
14 A.
In the British system, yes, sir.
15 Q.
So that's the Stanford board of directors in 1999;
16 right?
17 A.
Yes, sir.
18 Q.
And you say that the fraud was up and running in
19 1999; right?
05:23:50
20 A.
Yes, sir. I know it was.
21 Q.
You know it was because you were committing the
22 fraud, weren't you?
05:24:01
23 A.
We, we, not you, we, Mr. Stanford --
24 Q.
Yes, sir.
25 A.
-- myself.
3379
1 Q.
We have to believe you to believe that, don't we?
2 A.
Just follow the money. If you don't believe me --
3 Q.
We're going to talk about that. We've got plenty of
4 time.
05:24:10
05:24:20
5 A.
Good.
6 Q.
We're going to talk about that a lot.
7 A.
I'm ready for that, sir.
8 Q.
Mr. James Stanford was on the board. Was he a crook?
9 A.
I don't know.
10 Q.
You don't know? Well, you say that it was you and
11 Allen Stanford that were perpetuating this fraud or

12 conducting this fraud --
05:24:30
13 A.
Yes, sir.
14 Q.
-- in 1999?
15
And this information and the annual report
16 had to be run by the board of directors; right? They

17 demanded that it be prepared and published; right, the
18 board, that's part of what they do?
05:24:47
19 A.
It's part of it. They require it.
20 Q.
So was Mr. James Stanford a crook, part of the fraud?
21 A.
I don't know. Not to my knowledge.
22 Q.
How about the judge, was he also a crook?
23 A.
No, but Mr. Stanford was and I was. We were on the
24 board.
05:25:04
25 Q.
And how about the British lawyer, was he a crook,

3380
1 too?
2 A.
No. But Mr. Stanford, the chairman was; I was, CFO.
3 Q.
So it's your testimony that the board of directors
4 that reviewed this information and this annual report of

05:25:21
5 all the people on the board, only two of you were crooks?
6 A.
Yes, sir.
MR. SCARDINO: Let's go to Page 12 of this
8 exhibit, please.
9
05:25:38
Wow, that's hard to read.
10
THE COURT: It will improve, I think.
11
MR. SCARDINO: I'm not sure my eyesight will,
12 though.
13 BY MR. SCARDINO:
05:25:49
14 Q.
Can you see that, Mr. Davis?
15 A.
I believe so.
16 Q.
You can?
17
Okay. Let's look at the top line. What
18 does that say?

19 A.
05:26:07
"Profit and loss statement for year ended 31 December
20 1999. Expressed in U.S. dollars."

21 Q.
What is a profit and loss statement?
22 A.
Captures the revenues from sales, less the expenses
23 that generated those sales, and the result is profit

24 hopefully, the difference between revenue and expenses.
05:26:31
25 Q.
Okay. And it goes down -- one of the items that's

3381
1 referred to is operating income; correct?

2 A.
Yes, sir.
3 Q.
And then it has a list of topics. And then across to
4 the right, it has some numbers that for 1999 it shows

05:26:47
05:27:02
5 interest and noninterest income 81,603,329; correct?

6 A.
Yes, sir.
7 Q.
And so forth and so on?
8 A.
It's not, correct, though, it's a lie.
9 Q.
That's what it says here, though; right?
10 A.
It does say that, yes.
11 Q.
It's your testimony that it's a lie; is that correct?
12 A.
It is my testimony this is a lie, yes.
13 Q.
And let's just go to the bottom of that line of
14 numbers that talks about operating profit it says is what?

05:27:23
15 A.
3.8 million.
16 Q.
Say it again.
17 A.
3.8 million.
18 Q.
3.8 million.
19
05:27:39
Who prepared this Page 12 of this report,
20 Mr. Davis?
21 A.
The Stanford Financial Group accounting department
22 under Mr. Gill Lopez as approved by myself and

23 Mr. Stanford.
24 Q.
05:27:52
Let's see if we can get to the bottom of where these
25 numbers came from. Who gave Mr. Gill Lopez these figures?
3382
1 A.
They would have been generated through the accounting
2 transactions during each month.

3 Q.
So I thought you said that the numbers on here are a
4 lie?
05:28:16
5 A.
The numbers are intact through the transactions
6 during the month --
05:28:26
7 Q.
Let's stop you there. Let me stop you there --
8 A.
Yes, sir.
9 Q.
-- Mr. Davis. Now, I'm confused. I thought -- when
10 I first started talking to you about this annual report,

11 it's talking about numbers, you said the numbers are a
12 lie, did you not say that?
13 A.
Yes, part of the numbers are correct, the overall
14 effect of what you asked me about originally. Profit and

05:28:45
05:29:00
05:29:06
15 loss statement is a lie. There is no profit.

16 Q.
Who phonied up that number?
17 A.
I phonied up the number at Mr. --
18 Q.
And let me stop you there.
19 A.
-- Stanford's direction.
20 Q.
Let me stop you right there.
21 A.
Yes, sir.
22 Q.
The guy that phonied up that number --
23 A.
Yes, sir.
24 Q.
-- is you; right?
25 A.
At Mr. Stanford's direction.

3383
1 Q.
We have to believe you to believe that, don't we?
2 A.
You said the whole truth when I came in here. I'm
3 telling you the whole truth.
05:29:15
4 Q.
Yes.
5 A.
He directed me from the very beginning. He took the
6 550 million.
05:29:23
MR. SCARDINO: Responsive. Object.
MR. SCARDINO: Ask the Court to instruct the
10 jury to disregard the -11
THE COURT: Disregard it.
12
Please answer just the questions that you
13 asked. If there's any need for follow-up, I'm sure the

14 government will follow up if they feel it's necessary.
05:29:29
15
16
THE COURT: Go on.
17 BY MR. SCARDINO:
18 Q.
So back in 1999, the guy that actually put his hand
19 on the page and put the phony number down was you?
05:29:43
20 A.
21
At Mr. Stanford's direction.

THE COURT: No, sir. No, sir. If it was you
22 who did it, then the answer is yes. If it's no, no. If
23 you can't answer it yes or no, so be it. We understand
24 your theory of the case -05:29:56
25

3384
THE COURT: -- which basically is the
2 government's theory of the case. And I'm not saying -3 that's the jury decision, okay? But you need -- it's very
4 frustrating, I understand that. It happens in every case.
05:30:08
5 You need to answer yes or no. If you can't answer yes or

6 no, let me know. I'm sure the government's attorney is
7 making notes, and if they need to follow it up, they'll do
8 it on redirect.
9
05:30:20
Next question, please.
10
THE WITNESS: I apologize, Your Honor.
11
12 BY MR. SCARDINO:
13 Q.
So it wasn't any other member of the board that did
14 this, was it?

05:30:25
05:30:35
15 A.
No, sir.
16 Q.
It wasn't Mr. Lopez that did it, was it?
17 A.
No, sir.
18 Q.
It wasn't Mr. Kuhrt that did it, was it?
19 A.
At my direction.
20 Q.
You're the one that came up with the phony number?
21 A.
Yes, sir.
22 Q.
Do you have the documents, Mr. Davis, that would have
23 the correct number?
05:30:54
24 A.
No, sir.
25 Q.
Where are they?

3385
1 A.
I don't know where they are, sir.
THE COURT: Let me ask you this: Are they in
3 existence at all?
4
05:31:09
THE WITNESS: Yes, sir, they are.
5 BY MR. SCARDINO:
6 Q.
Yeah, they would almost have to be, wouldn't they?
7 A.
Yes, sir.
8 Q.
Yes, sir.
9
05:31:15
05:31:26
Where are they? Tell us where they are,
10 Mr. Davis.
11 A.
The accounting records.
12 Q.
Where are they?
13 A.
In the computer, wherever the computer media is.
14 Q.
Well, did you work with the government prosecutors to
15 try to find the real records so that these juries could

16 compare them with the phony one that you cooked up? Did
17 anybody make any effort to try to find that?
05:31:42
18 A.
I'm sure they did.
19 Q.
You're sure they -- well, did you discuss it with
20 anybody?
21 A.
I was asked questions for three years. I answered
22 them.
23 Q.
Nobody from the FBI asked you that question,
24 Mr. Davis, "Where are the real documents?" They never

05:31:56
25 asked you that?

3386
1 A.
Not in those words, no.
2 Q.
Nobody -- no lawyer for the government asked you that
3 question in preparing you to testify here in front of this

4 jury?
05:32:08
5 A.
No, sir.
6 Q.
What did you do with the real documents after you
7 decided to dummy-up the report that we're looking at here?

8 What did you do with the real documents? Did you throw
9 them in the lake?
05:32:21
10 A.
There are no real documents beyond what we've
11 discussed in this courtroom, Tier 1, Tier 2, those are the

12 real documents.
05:32:39
13
MR. SCARDINO: Nonresponsive. Object.
14
THE COURT: Overruled. Overruled as to that
15 response.
16
MR. SCARDINO: Let's go to the next page.
17 Let's go to the bottom of the page.

18 BY MR. SCARDINO:
19 Q.
05:32:55
05:33:03
It says, "Approved on behalf of the board," doesn't
20 it?
21 A.
Yes, sir.
22 Q.
That's your signature?
23 A.
Yes, sir, it is.
24 Q.
Director and chief financial officer?
25 A.
Yes, sir.
3387
MR. SCARDINO: I'm going to move to another
2 topic. You can take that down.

3 BY MR. SCARDINO:
4 Q.
05:33:25
You testified on direct examination when
5 Mr. Stellmach asked you about a computer and a thumb drive

6 that you threw in a lake. Do you remember talking about
7 that?
05:33:41
8 A.
Yes, sir.
9 Q.
And whose computer?
10 A.
It was mine.
11 Q.
I mean, was it a laptop or a desktop or what kind of
12 computer?
05:33:55
13 A.
There were two. It was a laptop and a tower.
14 Q.
So there were two computers?
15 A.
Yes. There was a personal computer, and a laptop
16 corporate computer.
17 Q.
Okay. I'm not very computer literate, so let me --
18 walk through this a little bit.

19
05:34:18
05:34:27
There was a laptop, right, like this --
20 like this?
21 A.
Yes, sir.
22 Q.
One that looks something like this?
23 A.
Yes, sir.
24 Q.
You took it and threw it in the lake?
25 A.
I did.
3388
1 Q.
Okay. I mean, were you standing on the shore, were
2 you in a boat, or what? Tell me about it.
05:34:35
3 A.
I was standing on the shore.
4 Q.
Standing on the shore.
I mean, was it near a place that you were
6 familiar with or -- like, your home?
05:34:43
7 A.
Yes, sir.
8 Q.
Near your home?
9 A.
Yes, sir. Right in front of my house.
10 Q.
Front of your house.
11
05:34:51
05:35:08
You have a lake in front of your house?
12 A.
I did.
13 Q.
Okay. Wow. Okay. How big a lake?
14 A.
7 acres.
15 Q.
Was it your lake?
16 A.
Yes, sir, mine and my wife's.
17 Q.
Did you have a boat?
18 A.
I had a 12-foot aluminum fishing boat, yes, sir.
19 Q.
And you had a second computer. What kind of
20 computer? Was it one like you see sitting on desktops?

21 A.
No, it was like the old kind you see sitting on the
22 floor.
23 Q.
05:35:19
Sitting on the floor?
24
THE COURT: You mean -- what is it, a CPU?
25

3389
THE COURT: The rectangle block on the floor --
THE COURT: -- versus that's the screen and on
4 the desk -05:35:27
05:35:36
THE COURT: -- is the computer?
MR. SCARDINO: I don't know what a CPU is.
THE COURT: The central processing unit --
10
11
THE COURT: -- that's where the guts are. In
12 other words, you have a screen here and the guts in the
13 box.
14 BY MR. SCARDINO:
05:35:41
15 Q.
Okay. Would you mind stepping down and giving us a
16 little bit of a -- how big this item was?
05:35:54
17 A.
No, sir, I don't.
18 Q.
You don't mind or --
19 A.
(Indicating.)
20 Q.
So you're indicating is about what, I don't know,
21 2 feet off the ground and how wide?

22
MR. STELLMACH: 18 inches.
23
THE WITNESS: I think.
24 BY MR. SCARDINO:
05:36:03
25 Q.
About 18 inches wide?

3390
1 A.
No, 18 inches --
MR. STELLMACH: 18.
THE WITNESS: -- long.
4 BY MR. SCARDINO:
05:36:09
5 Q.
You're showing it's so high and so wide; right?
6 A.
2 feet by 6 inches by 12 inches.
7 Q.
All right. So that was something that you kept at
8 your desk?
9 A.
05:36:21
10 Q.
At my house.
At your house.
11
05:36:29
05:36:39
And it stored information?
12 A.
Yes, sir.
13 Q.
And did you have a screen that goes with that?
14 A.
Yes, sir.
15 Q.
And a key pad?
16 A.
Yes, sir.
17 Q.
Were they three separate things?
18
THE COURT: You mean this key pad --
19
20
THE COURT: -- big unit and the screen?
21
MR. SCARDINO: That's correct.
22
THE COURT: All right. I want to stop the
23 clock for a minute. Let's stand up. We've got about -24 we're going to go to about 6:05. Be a good time to shake
05:36:53
25 out some of the cobwebs that are there.

3391
(Brief recess)
THE COURT: Everybody ready? Let's continue.
3 BY MR. SCARDINO:
4 Q.
05:38:19
So how long had you had this desktop computer,
5 Mr. Davis?
6 A.
Several years.
7 Q.
Several years.
8
9 A.
05:38:27
Was it your personal computer?

It was my family's, yes.
10 Q.
I mean, did you have some password to get in it?
11 A.
Probably not.
12 Q.
Well, I mean, did it or not? Do you recall?
13 A.
I said probably not. I don't recall. I don't recall
14 ever using a password on it.

05:38:40
15 Q.
How about the laptop?
16 A.
No, sir.
17 Q.
No password?
18 A.
Well, it had a password if I entered the corporate
19 Oracle IT system, but just to use it away from that

05:38:59
20 system, no.
21 Q.
Oracle was a system that you had designed to put in
22 place to keep track of employees and their sales, wasn't

23 it?
24 A.
05:39:09
No, sir, it was not. I had nothing to do with the
25 installation selection of that.

3392
1 Q.
It was your idea to do it, though, wasn't it?
2 A.
No, sir.
3 Q.
It wasn't?
4
05:39:16
Oracle wasn't your idea?
5 A.
No, sir.
6 Q.
Okay. So how long had you been storing information
7 on the desktop computer?
05:39:35
05:39:42
8 A.
Old as the computer was, maybe three, four years.
9 Q.
And what kind of information did you store on that
10 computer? Was it personal?

11 A.
It was.
12 Q.
Was it business?
13 A.
No, sir.
14 Q.
Just personal?
15 A.
16 Q.
Okay. How about the laptop, how long had you had
17 that?
05:39:55
18 A.
I would say no more than four years.
19 Q.
Okay. So you had it a little longer than the
20 desktop?
21 A.
22 Q.
Okay. And what kind of information did you store on
23 that? Was it personal?
05:40:02
24 A.
There was a lot of personnel, yes.
25 Q.
Any business?
3393
1 A.
There was some business. Most of the business was
2 stored on the Oracle IT system that's corporate.

3 Q.
Now you've confused me, Mr. Davis. Let's go back and
4 try to get it straight. Everything on the desktop was

05:40:16
5 personal; right? Isn't that what you just told us?

6 A.
7 Q.
And then stuff on the laptop was personal and
8 business?
9 A.
05:40:27
There were some business files, letters,
10 communications on file there for business.

11 Q.
Yes, sir. And if I recall on direct examination, you
12 talked about another device that you threw in the lake

13 other than those two computers. What was it?
14 A.
05:40:41
Yes, sir. It was a media device that's called flash
15 drive.
16 Q.
Yes, sir.
17 A.
It plugs in and you store information on it.
18 Q.
Okay. And, so, was that used on the desktop or the
19 laptop?
05:40:49
20 A.
Laptop.
21 Q.
Laptop.
22
And you stored information on that in
23 addition to the other data that you stored?
05:40:57
24 A.
25 Q.
Did you store personal information on the thumb drive

3394
1 or business information?
05:41:05
2 A.
Business information.
3 Q.
Business.
4 A.
Okay.
5 Q.
All right. And you threw all of this in the lake?
6 A.
That's correct.
7 Q.
And approximately when did you throw it in the lake?
8 A.
January of -- January and the first week of
9 February '09.
05:41:22
10 Q.
It took you a couple of weeks to throw it in the
11 lake?
05:41:31
12 A.
It was a day in that period --
13 Q.
Oh, I see.
14 A.
-- one of the weekends.
15 Q.
Okay. You threw them all in at the same time?
16 A.
It was probably on the 6th -- the 8th, I believe the
17 8th of February.
18 Q.
This was after you had taken the $990,000 from
19 Mr. Stanford; right?

05:41:45
20 A.
It's after the loan that was agreed to between
21 Mr. Stanford and myself, yes.

22 Q.
And what kind of business information did you store
23 on the laptop?
24 A.
05:42:07
E-mails, sometimes copied. Copies of some
25 correspondence. And on the flash drive was the -- I

3395
1 believe that was the so-called IB5, a piece of the report

2 that went to the regulators --
05:42:24
3 Q.
Did --
4 A.
-- at Antigua.
5 Q.
When you -- the information that you stored on the
6 laptop and the flash drive, you said there was some pieces
7 of correspondence; right? Like e-mails?
05:42:47
8 A.
I believe there were some e-mails saved, yes.
9 Q.
And some documents that might have been generated for
10 regulators?
11 A.
On the flash drive, yes, sir.
12 Q.
Okay. And, so, you would still have access to that
13 data, wouldn't you?
05:42:59
14 A.
At that time.
15 Q.
Now, when you -- I believe Mr. Stellmach asked you on
16 direct that -- didn't you turn -- didn't you inform the

17 government of that, just right away that you had destroyed
18 evidence; right?
05:43:15
19 A.
That's pretty soon, yes, sir.
20 Q.
As part of your plea agreement, you're not going to
21 be charged with destroying evidence or obstruction of

22 justice? Is that part of your plea agreement?
05:43:30
23 A.
That was not one of the counts I was charged with.
24 Q.
Nobody -- nobody talked to you about you wouldn't be
25 charged with that if you cooperated?

3396
05:43:38
1 A.
No, sir.
2 Q.
But that's what you did, though; right?
3 A.
What did I do?
4 Q.
Destroyed evidence?
5 A.
Yes, sir.
6 Q.
When you told the government that you had done
7 that -- and I've looked at the report that you -- where

8 you -- that's revealed to the FBI, can you tell us what
9 efforts were made by the FBI to reconstruct that
05:43:55
10 information so we could see what you were trying to hide?

11 A.
The efforts that they made, they made an effort to
12 retrieve the -13 Q.

14
05:44:09
No. No. It wasn't an artfully drafted question.

I'm not talking about what they tried to
15 get after they retrieved the computer. I'm talking about

16 what could have been reconstructed from the information
17 that you had put on the computer.
18
You got an e-mail either on the computer
19 or you transferred it and stored it there on the thumb

05:44:22
20 drive or your laptop; right? So there was a source of

21 information out there where we could go look to see what
22 you were trying to hide; correct?
05:44:38
23 A.
I don't understand your question.
24 Q.
Well, didn't you tell us that what was on that
25 computer were pieces of communication?

3397
1 A.
Yes. Generally, I think so. I don't know which
2 ones.
3 Q.
So the information was generated from a source
4 outside of the computer, wasn't it?

05:44:51
5 A.
I would have received from somewhere else, yes.
6 Q.
So did you sit down with the FBI to try to
7 reestablish -- try to establish the source of that

8 information so that the FBI could see what you were trying
9 to hide to determine whether they wanted you as a witness
05:45:06
10 or not?
11 A.
I appreciate the level of your question. I can hear
12 that very clearly.

13 Q.
05:45:19
Yes, sir. I hope so.
14
THE COURT: You did not hear it very clearly?
15
THE WITNESS: I did. It was good.
16
THE COURT: Okay. Go right ahead.
17
THE WITNESS: Almost too much. But --
18
I'm still -- you know, it must that age
19 that we're talking about, sir. I need the question one

05:45:34
20 more time.
21 BY MR. SCARDINO:
22 Q.
05:45:36
I'll say it.
23
THE COURT: Do you want it read back?
24
MR. SCARDINO: Sure.
25
(The requested question was read)

3398
THE WITNESS: I told them where I thought the
2 source -- the sources came from, which would have been

3 the -- through the IT system at Stanford Financial.
4 BY MR. SCARDINO:
05:46:04
5 Q.
Fair enough. Did they get the information and ask
6 you: Is this what you had on your computer, Mr. Davis?

7 A.
I don't know whether they got the information or not.
8 I don't remember the question regarding -9 Q.

05:46:19
It certainly doesn't appear in any of your interviews
10 with them, does it?

11 A.
I don't know.
12 Q.
Okay. So nobody tried to find out what you were
13 trying to hide when you threw those computers in the lake;

14 right?
05:46:26
15 A.
I received a lot of questions about it.
16 Q.
But nobody tried to recreate what was in that
17 computer, did they?
05:46:36
18 A.
I don't know.
19 Q.
Not that you know of?
20 A.
Not that I know of. I don't know.
21 Q.
Nobody talked to you about it; right?
22 A.
No, sir.
23 Q.
Now, you told them what you thought was on it, but
24 nobody tried to verify it.

05:46:45
25
Did they believe you and just take you at

3399
1 your word, Mr. Davis?
05:46:50
MR. STELLMACH: Objection.
THE WITNESS: I don't know, sir.
MR. SCARDINO: Withdrawn.
THE COURT: Hold it.
MR. SCARDINO: Withdrawn.
MR. STELLMACH: Asked and answered.
THE COURT: He's withdrawn it.
9
05:46:53
Go on.
10 BY MR. SCARDINO:
11 Q.
Did they tell you they believe you?
12 A.
I don't remember them saying that, no.
13 Q.
It's been three years since you threw those computers
14 and that thumb drive in the lake, hasn't it, Mr. Davis?
05:47:14
15 A.
Yes, sir, it has.
16 Q.
And you know nobody else charged with this crime has
17 tried to hide evidence, don't you? Not Mr. Kuhrt? Not

18 Mr. Lopez? Not Ms. Holt? You know that?
05:47:26
19
MR. STELLMACH: Objection to what he knows.
20
THE COURT: Do you know that, sir?
21
MR. SCARDINO: If he knows.
22
THE COURT: Do you know that or not?
23
24 BY MR. SCARDINO:
05:47:30
25 Q.
No. Nobody's given you information. When talking to

3400
1 these government prosecutors, nobody said, "Oh, my

2 goodness, Holt did the same thing." Nobody's told you
3 that, have they? That she was trying to hide something
4 just like you were trying to hide?
05:47:42
5 A.
I don't remember that, no, sir.
6 Q.
Or Mr. Kuhrt or Mr. Lopez? Nobody's confronted you
7 with, "Hey, what were you guys sharing that you all wanted
8 to hide?"
9
05:47:57
You hadn't been confronted with that, have
10 you?
11 A.
I've been asked questions about what was there on the
12 media.
05:48:07
13 Q.
That's not my question, Mr. Davis.
14 A.
Sorry. I apologize. Go ahead.
15 Q.
That's quite all right.
16
You're the only one that tried to hide
17 evidence, aren't you?
05:48:20
18 A.
I panicked and I threw those in the lake.
19 Q.
I do believe you described yourself as a coward when
20 you first took the witness stand.

21
05:48:29
Do you remember that?
22 A.
I was.
23 Q.
Is that still true?
24 A.
I would say absolutely not.
25 Q.
Not a coward anymore?

3401
1 A.
I don't think so, no.
2 Q.
You testified on direct examination that one of the
3 persons that was involved in the Stanford empire was the

4 chief investment officer, a woman named Laura Holt. Is
05:49:00
5 that right? Or Laura Pendergest Holt?

6 A.
Yes, sir.
7 Q.
And -- now help me with this. Sometimes age does
8 affect your memory a little bit.

9
05:49:12
Did you tell the jury on direct
10 examination that you had met this woman -- where did you
11 meet her?
12 A.
I met her in Baldwyn, Mississippi, in a college and
13 career Bible class.
05:49:25
05:49:40
05:49:59
14 Q.
In a Bible class?
15 A.
Yes, sir.
16 Q.
What were you doing in a Bible class?
17 A.
I was teaching it.
18 Q.
You were teaching a Bible class?
19 A.
Yes, sir.
20 Q.
How long had you been doing that, Mr. Davis?
21 A.
A number of years.
22 Q.
How many years?
23 A.
Two.
24 Q.
Okay. And was it at a church that you were a member?
25 A.
Yes, sir.
3402
1 Q.
In fact, you were more than just a member of the
2 church, weren't you?
05:50:07
05:50:14
3 A.
No, sir. I was a member.
4 Q.
Weren't you an elder in the church?
5 A.
No, sir.
6 Q.
Were you ever an elder in a church?
7 A.
I was.
8 Q.
Not this church?
9 A.
Correct.
10 Q.
Was it before this church or after this church?
11 A.
After.
12 Q.
So you worked your way up in the church as an elder,
13 an example to others; right?
05:50:24
14 A.
I was an elder later, after that time.
15 Q.
Okay. So you're teaching this Bible class in the --
16 what was the name of the church in Baldwyn?

17 A.
First Baptist Church.
18 Q.
First Baptist Church.
19
05:50:36
05:50:46
And were you were teaching the class with
20 anybody else?
21 A.
My wife.
22 Q.
Is she in the courtroom?
23 A.
No, sir.
24 Q.
Okay. And that's where you met Ms. Holt.
25
And what was she doing there?

3403
05:51:09
1 A.
She was taking that class along with other people.
2 Q.
How old was she?
3 A.
I believe she was 20, 19 or 20.
4 Q.
Is it possible she was considerably younger than
5 that?
6 A.
No, sir.
7 Q.
How long after you met her did you start the illicit
8 relationship with her?

9 A.
05:51:22
05:51:48
Eight years.
10 Q.
Eight years later?
11 A.
Yes, sir. Approximately.
12 Q.
Well, how old was she when you hired her?
13 A.
Have to think about the year she was hired.
14 Q.
Makes you a lot younger than 19 when you met her,
15 doesn't it?
16 A.
No, sir. If you'll pause, I'll answer your question.
17 Just give me a moment.

18 Q.
Think about it because I want to get through this
19 before we run out of time.

05:52:03
20
Your current wife, Ms. -- Mrs. Davis, is
21 not your first wife, is she?

22 A.
No, she's not.
23 Q.
In fact, you were married to a woman named Ruth
24 originally, weren't you?

05:52:14
25 A.
Yes, I was.
3404
1 Q.
And when you were married to Ruth, you had two
2 children, didn't you?
05:52:18
3 A.
Yes, sir.
4 Q.
Two boys?
5 A.
Yes, sir.
6 Q.
In fact, the boys that you got involved in this
7 business, aren't they? Same boys?
05:52:27
8 A.
My oldest son.
9 Q.
Okay. Zach?
10 A.
Yes, sir.
11 Q.
Okay. And you had those two children with Ruth, and
12 you met Lori while you were married to Ruth, didn't you?
05:52:38
13 A.
Yes, I did.
14 Q.
And what -- how did you know Lori, when you were
15 married to Ruth?
16 A.
She worked at the same company in the same department
17 that I worked in.
05:52:48
18 Q.
She wasn't your babysitter?
19 A.
No, sir.
20 Q.
Was did ever -- she ever work in your house as a
21 babysitter?
22 A.
I believe so, couple of times. Yes.
23 Q.
So she was -- worked as a babysitter and maybe worked
24 in a company that you were familiar with, but how old was
05:53:01
25 Lori when you met her?

3405
05:53:06
05:53:17
1 A.
17.
2 Q.
17?
3 A.
Yes, sir.
4 Q.
And she was a babysitter.
Did you start a relationship with her?
6 A.
I did later years, yes, sir.
7 Q.
While you were still married to Ruth?
8 A.
I was separated, but I was married, yes, sir.
9 Q.
Well, are you telling this jury that's not -- that's
10 not what broke up your marriage to Ruth?

11 A.
Yes, sir, that's what I'm telling you.
12 Q.
Wasn't Ruth very upset over your relationship with
13 Lori?
05:53:30
14
THE COURT: Is it Lori or Laura?
15
MR. SCARDINO: Lori, L-O-R-I, is his current
16 wife. L-A-U-R-A is the girlfriend.

17
THE COURT: Okay.
18 BY MR. SCARDINO:
19 Q.
05:53:45
So you met Lori, your current wife, while she was
20 babysitter while you were married to Ruth?

21 A.
I met her at work, as I said before, where I was
22 working.
05:53:52
23 Q.
How old was she?
24 A.
17.
25 Q.
17. And you started a relationship with her?

3406
1 A.
Yes, sir, years later, as I said.
2 Q.
You deceived your wife, didn't you?
3 A.
I don't think so. I wasn't at home with my wife at
4 the time.
05:54:07
5 Q.
6
You lied to Ruth about Lori, didn't you?

MR. STELLMACH: Objection. Asked and answered.
7 The witness has said he was separated.

8
9 BY MR. SCARDINO:
05:54:22
05:54:32
10 Q.
Your marriage to Ruth ended. Isn't that correct?
11 A.
It did.
12 Q.
And you married Lori?
13 A.
Yes, sir.
14 Q.
And you had two more children; is that correct?
15 A.
Yes, sir.
16 Q.
And are you telling this jury that your marriage to
17 Ruth was such that Ruth wasn't upset with your behavior?
18
MR. STELLMACH: Objection, Your Honor, as to
19 the relevance of this.

05:54:46
20
21
MR. STELLMACH: Soap opera.
22
THE COURT: They got the message.
23
MR. SCARDINO: They talked about his
24 relationship with Laura Pendergest Holt.

05:54:53
25
MR. STELLMACH: Because it had a limited

3407
1 purpose for purposes of this trial.

2 BY MR. SCARDINO:
3 Q.
I guess the point, Mr. Davis, is that you're willing
4 to deceive and betray people, aren't you?

05:55:07
5 A.
No, sir.
6 Q.
You weren't willing to betray your first wife Ruth?
THE WITNESS: Your Honor, this is a question
8 that involves more than yes-no to betrayal.

9
05:55:30
MR. STELLMACH: I object.
10
THE COURT: On what grounds?
11
MR. STELLMACH: Relevance to this entire line
12 of inquiry.
13
THE COURT: I'm not going to say I sustain it
14 on relevance, but do you have any other objections.

05:55:39
15
MR. STELLMACH: As to form.
16
THE COURT: What else?
17
18
THE COURT: Asked and answered. I think we're
19 there already. All right?

05:55:45
20
So if there's any question you need to
21 ask, fine; otherwise, you may move on, Counsel.

22 BY MR. SCARDINO:
05:55:56
23 Q.
Well, then you betrayed Lori, didn't you?
24 A.
Yes, I did.
25 Q.
You did. You betrayed her with this Ms. Holt, didn't
3408
1 you?
05:56:04
2 A.
I did.
3 Q.
And then you betrayed Ms. Holt, didn't you?
4 A.
How is that, sir?
5 Q.
Well, you had a relationship with another person
6 while you were married to Lori and Holt was your

7 girlfriend.
05:56:11
MR. STELLMACH: Objection, Your Honor.
THE COURT: What?
10
MR. STELLMACH: Again, as to the relevance of
11 this.
12
THE COURT: I'm not saying it's not relevant;
13 okay? But I think we've heard it, and the jury give it
14 whatever weight it thinks applicable in this case.
05:56:22
15
Now we can move on a bit, please.
16 BY MR. SCARDINO:
17 Q.
Do you know who Heather Shepherd is?
18 A.
Yes, sir.
19
05:56:29
20 Mr. Davis's relationships.

21
THE COURT: Have we talked about Ms. Shepherd?
22
MR. STELLMACH: Personal assistant. I don't
23 know if we have yet; but again, the relevance of his

24 relationship.
05:56:38
25
THE COURT: Why don't you ask generally did he

3409
1 have other relationships.

2 BY MR. SCARDINO:
3 Q.
How about having a relationship with Heather
4 Shepherd?
05:56:45
5 A.
Yes, sir, I did.
6 Q.
You did. And that's Laura's cousin, Laura Holt's
7 cousin, isn't it?
05:56:52
8 A.
Yes, she is.
9 Q.
So you've betrayed everybody you've had a
10 relationship with so far, haven't you?

11 A.
Yes, I have, committed adultery. I was a hypocrite,
12 and I lied.
13 Q.
Yes, sir. How about Tamarin Lindenberg? Do you know
14 who that is?

05:57:05
05:57:11
15 A.
I sure do.
16 Q.
Who is that?
17 A.
Outside consultant.
18 Q.
You had a relationship with her, too, didn't you?
19 A.
I did not.
20 Q.
Let's shift gears, Mr. Davis.
21
MR. SCARDINO: Your Honor, this next topic is
22 going to be a little lengthy.

23
THE COURT: Okay. I think we can then adjourn
24 for the day. Let me stop the clock. Hang on one second.
05:57:48
25
Ladies and gentlemen, completes the

3410
1 testimony for today. We'll see you tomorrow ready to

2 resume at 10:00 a.m.
3
4
05:58:24
Thank you and good afternoon.

(The following was held out of the presence of the jury)
MR. SCARDINO: Before you leave the bench,
6 we've got a matter for take up --
05:58:34
THE COURT: Okay.
MR. STELLMACH: Ex parte.
MR. SCARDINO: No, no, no. It's definitely not
10 ex parte.
11
MR. SCARDINO: It's "part."
12
THE COURT: Okay. We're going to continue to
13 see what you have on your mind. Keeping it going.

14
05:58:43
Yes, sir, what do you want to talk about.
15
MR. FAZEL: Do you want me to go first?
16
MR. SCARDINO: You're the one that knows.
17
MR. FAZEL: Two issues: One that we need to, I
18 think, approach with the government. The other is: During

19 Mr. Scardino's cross-examination regarding the affairs, if
05:58:56
20 you will, of Mr. Davis, Mr. Costa blurted out in front of

21 the jury, "What about Mr. Stanford's girlfriends?"
22
I would object to that sidebar comment.
23 Mr. Costa knows better, not to do that in front of the

24 jury. I'd that the Court admonish him not to do that and
05:59:14
25 I'm going to ask for a mistrial.

3411
MR. STELLMACH: I didn't hear the comment. I
2 was sitting closer to Mr. Costa than anyone. But -3
THE COURT: First, we need to determine whether
4 or not it was said.

05:59:23
MR. FAZEL: I'm telling you as an officer of
6 the Court.
7
THE COURT: Sure. Mr. Costa.
MR. COSTA: I did mumble something. I'll
9 agree. And I find it quite audacious to make that attack

05:59:34
10 that somehow is a problem when Mr. Scardino now by four

11 counts, four times since this trial began, has violated the
12 motion in limine.
05:59:44
13
THE COURT: Like?
14
MR. COSTA: About the TARP funds. He did it
15 again today. He did it in opening statement. He did it

16 twice last week. And I told him last week, and he played
17 this, Oh, I'm old and dumb thing. And he was reminded at
18 that point, though. So he's had multiple warnings. About
19 that was actually in front of the jury, I doubt anyone
05:59:59
20 could hear my -21
THE COURT: Well, we're going to go one thing
22 at a time.
23
Now, you were sitting there. Which way
24 were you facing? Away from the jury or toward the jury?
06:00:07
25
MR. STELLMACH: Away from the jury? Just like

3412
1 this, basically.
2
THE COURT: All right. Well, I'm not going to
3 get -- all right. And you want a mistrial?
06:00:16
MR. FAZEL: I do.
THE COURT: Motion for mistrial is denied.
MR. FAZEL: And for the record, Your Honor, my
7 law partner is not old nor dumb?

8
MR. COSTA: I agree. That's his excuse when he
9 clearly violates Court orders.

06:00:30
10
MR. SCARDINO: I didn't say I was old and dumb.
11
THE COURT: Do you want a judicial finding on
12 that? Put him in your findings of -13
MR. SCARDINO: Mischaracterization on
14 testimony.
06:00:38
15
THE COURT: Put him in your findings of fact
16 and conclusions of law, if any.

17
MR. COSTA: He also said he was past the bell
18 curve on being wise.

19
06:00:49
THE COURT: And on the other aspect that, in
20 other words, relative to TARP funds. You need to approach

21 the bench, not immediately perhaps, but at an appropriate
22 time, because I need it in context and if necessary have it
23 read back. But I'll keep watch on it. Next time you hear
24 anything like that, ask to approach the bench.
06:01:04
25
Yes, sir?
3413
MR. FAZEL: The other matter, Your Honor, is
2 actually one that, believe it or not, the government and we

3 agree on; that is, the matter one of our experts that we
4 anticipate will be testifying has now obtained a position
06:01:16
5 with Navigant Consultant.

6
I don't want to go into the details of the
7 soap opera that's been our experts; however, Navigant

8 Consultant is part of the experts used by the receiver. We
9 obtained this expert prior to him moving to Navigant
06:01:35
10 Consultant.
11
MR. STELLMACH: I think with respect to --
12 Mr. Fazel may be mistaken. Navigant has been retained by

13 the Justice Department to provide some support work.
14
06:01:47
One of the new hires by Navigant, this
15 outside consultant, is one of the experts that they've

16 retained. We understand that Navigant has created a wall
17 and screened this new individual off.
06:01:56
18
THE COURT: The aspect of the Chinese Wall?
19
20
THE COURT: I mean, the theory of the Chinese
21 Wall.
22
All right. You're just bringing it to my
23 attention?
24
06:02:02
MR. FAZEL: All the government and the defense
25 lawyers, we all wanted to bring it -- put it on the record,

3414
1 but we retained this person prior to them joining Navigant.

2 And given the timeframe that we're in court and trial, the
3 fact that he's done work and has already turned in a
4 report, nobody has any objection to it. We just want to
06:02:19
5 put it on the record for the Court to know that.

6
7
8
Did I get that right?

MR. STELLMACH: Yes.
There is one other housekeeping matter,
9 Your Honor.
06:02:25
10
We anticipate on the current rate, knock
11 on wood, we'll rest on sometime early next week. We were

12 wondering about the schedule for the defense to turn over
13 their exhibits. That's been a topic that's been a little
14 up in the air given issues as they've developed in the
06:02:39
15 trial.
16
THE COURT: What about that.
17
MR. SCARDINO: I'm sorry. I had his attention.
18
MR. FAZEL: That's correct. We were told
19 today, Mr. Costa was kind enough to tell us -06:02:49
20
THE COURT: Everybody be seated. I'm sorry.
21
MR. FAZEL: -- today that they most likely will
22 rest next week sometime. They anticipate early next week,

23 Tuesday or Wednesday of next week. We think, given our
24 cross-examination, it might be a little lengthier than
06:03:05
25 that.
3415
As the Court knows on an ex parte matter,
2 we are in the process of obtaining that. And we know that

3 as soon as they rest, then we need to provide them with our
4 witness list and what we anticipate their time being.
06:03:16
THE COURT: By the way, I cannot require you to
6 put down relative to Mr. Stanford. If you want to, you

7 can; but you're not required to.
8
9
06:03:27
MR. FAZEL: Right. Yes, sir.

We are diligently working on getting that
10 together. As a matter of fact, we did some work today.

11 Mr. McGuire was outside of the courtroom getting some of
12 that done. Mr. Parras is also helping us with all that.
13 And all we can say is we'll get it to them as soon as and
14 as quickly as we can.
06:03:42
15
MR. STELLMACH: That doesn't give me quite the
16 same amount of comfort given the rate by which we've been

17 getting the defense exhibits for cross-examination, the
18 night before or the morning of.
19
06:03:58
If we could have a hard and fast deadline
20 of when we can get the witness list, which I think is

21 something they're supposed to submit to us at the end of
22 our case. And then when we'll get our actual exhibits so
23 we can make any use of them. I mean, three days before
24 would seem -- I think that's the bare minimum.
06:04:13
25
THE COURT: Any problem with three days before?

3416
MR. FAZEL: Before they rest?
THE COURT: Oh, before you rest?
MR. STELLMACH: Well, for the first couple of
4 witnesses that they'll be putting on, three days before.

06:04:23
5 We've been providing -6
THE COURT: You wanted three days -- at least
7 three days before each witness?

8
MR. STELLMACH: That's right. Which is less
9 than half the time in which we were giving them.

06:04:31
10
THE COURT: Any problem with that?
11
MR. PARRAS: I think there will be. I don't
12 want to misrepresent anything to the Court. We've -- we

13 are working on identifying who we will put on, and then the
14 next step will be to identify what exhibits. And my goal
06:04:47
15 will be to be get that to the Court at the time they rest.

16 I thought that would be two weeks from now and we had some
17 time.
18
With this short time, it's going to be
19 tough, Judge. But we will do our best -06:04:55
20
MR. COSTA: We have told them for about a year
21 that it was going to be a three-week case.

22
THE COURT: All right. Now, if you can't work
23 it out, I'll make a ruling. And the ruling, you know, may
24 not -- may or may not be acceptable to the defense. But
06:05:07
25 they're entitled to that based upon what we've been

3417
1 discussing.
2
Again, I don't put it off. I can rule on
3 it first thing tomorrow morning. I'm ready to do it now,

4 but I don't think there's a necessity to. Talk to each
06:05:18
5 other after I leave today, and if you can, I will rule

6 first thing in the morning or when it's brought to my
7 attention as to how many days in advance of the defense
8 witnesses I think it ought to be done. Much better if you
9 agree. If you don't, I'll rule on it.
06:05:34
10
11
Yes, sir.
MR. COSTA: Your Honor, can we go back to that
12 issue with the expert?
06:05:40
13
THE COURT: Oh, you mean --
14
MR. COSTA: With their expert having gone to
15 the consulting firm that the government's been using, I

16 think Mr. Stanford needs to decide that if he still wants
17 to use that expert, there needs to be an on-the-record
18 waiver by Mr. Stanford so he can't later say, "Oh, my
19 defense was prejudiced because my expert had gone to work
06:05:55
20 for the same firm."

21
THE COURT: That's not unreasonable.
22
MR. COSTA: So I think he has to decide either
23 does he want to still use the guy. If he does, he needs to

24 waive the conflict.
06:06:02
25
MR. FAZEL: If Your Honor would -- I understand

3418
1 the government's position. If Your Honor would give us

2 tonight just after this hearing to discuss it with
3 Mr. Stanford, and we can probably do it on the record
4 tomorrow.
06:06:10
THE COURT: That's fine. When we get back in,
6 we can tell the jury it will be five minutes, and we can

7 get that done.
8
MR. SCARDINO: I need to get in the motion in
9 limine.
06:06:21
10
MR. FAZEL: Which motion in limine?
11
MR. PARRAS: Valuation.
12
THE COURT: I knew that was coming up.
13
MR. FAZEL: The government has filed a motion.
14 We have also filed a motion.

06:06:28
15
THE COURT: Also, I have pulled out the -- what
16 is it -- both of your instructions on what sort of mens

17 rea, so to speak, is required.
18
I came across one sentence that was
19 exactly the same. All right? When do you think you want
06:06:48
20 to get into the valuation question?

21
MR. SCARDINO: I'm going to guess before I pass
22 him late tomorrow -- late tomorrow morning, maybe early

23 afternoon.
24
06:07:02
THE COURT: All right. Why don't we do this:
25 I mean, I've -- we've been working on it. When do you want

3419
1 to argue it? Because the jury is going to have to stay out

2 of court with -- what is it -- with the clock running.
3 What we might do is, when you're ready to get into it, we
4 will tell the jury and I'll do my old write it down, and
06:07:23
5 I'll talk to you when I come in later, and we'll just have
6 at it. It's not something we can get over in five minutes,
7 because it -- first of all, it looks like it's a close
8 question. Cases are going both ways. It's all shades of
9 gray. So I'm looking at the government, if you can -- and
06:07:38
10 don't assume anything. If you can see what -- what you

11 could be comfortable letting in and what you absolutely
12 want out. And I'm just not going to split the baby unless
13 I feel that it's the right thing to do.
14
06:07:56
But we're working on it, and we've got
15 some briefs and we've got the cases and we got both of your
16 theories on that.
17
So once again, if the defense can be
18 comfortable with something on valuation or if you need

19 everything in, the government says it's out a hundred
06:08:17
20 percent, so be it, or you can announce that tomorrow

21 morning also. And then when the time comes appropriate
22 that you need to go into it, we'll excuse the jury and
23 we'll have, you know, a short appellate argument on that
24 point. But we'll be ready for it.
06:08:33
25
MR. SCARDINO: Your Honor, if -- I can be

3420
1 haphazard in my approach to cross-examination, and I do not

2 want to run afoul of the Court's ruling.
06:08:46
THE COURT: Sure.
MR. SCARDINO: So I would request that we maybe
5 try to have a resolution of this, more I think about it,

6 sooner than later so that I don't step into it.
7
THE COURT: When do you think?
MR. SCARDINO: If it's possible to do it -- I
9 hate to do it to you guys. If we can do it before I get

06:08:58
10 him back. If we can meet maybe tomorrow morning and see if

11 we can reach some agreement. If not, ask the Court for a
12 little time before we start testimony.
13
MR. COSTA: I don't know if you have hearings
14 scheduled beforehand. We'd be willing to come in at 9:30.

06:09:08
15
THE COURT: No. I've got -- I've got -- what
16 is it?
17
MR. COSTA: I don't want to take away from the
18 jury.
19
06:09:17
THE COURT: I've got a rearraignment tomorrow
20 morning. We'll take it out of their time. They're know -21 they're very comfortable, in effect, with they hear that
22 the time is running; okay? So it makes it a lot easier to
23 keep them sequestered or give them half-hour break and tell
24 them they can go down and get a snack and come back up.
06:09:31
25
So I tell you what: 10:00 a.m. tomorrow,

3421
1 make some announcements on these areas. And then if

2 necessary, we'll just keep them in there, or we'll get
3 going and we can do it before they come back or have an
4 elongated lunch break for them and we can sit and discuss
06:09:49
5 it. I mean, everybody needs -- you know, including really

6 the attorneys. I'd be glad to just forgo a whole lunch
7 hour, but that's -- you know, it's -- we're doing fine
8 time-wise on both sides; okay? So don't worry about a
9 clock running or the amount of gross time each side has.
06:10:08
10 Because the original estimate was about 26 days.

11
In other words, if you go five to five and
12 a half hours a day, and which we've been doing, which is

13 about the max you can get in. I'm not talking about going
14 beyond 6:00 o'clock. So we're doing all right. So don't
06:10:24
15 worry about the time running even though it will continue

16 running t. I don't think either one of you would be in the
17 danger zone of my siding down your side.
06:10:34
18
MR. COSTA: One more little issue, Your Honor.
19
THE COURT: Yes, sir. Go on.
20
MR. COSTA: We have a witness from China.
21 We're trying to juggle the schedule, but there might be a

22 situation where he would have to testify by Wednesday
23 morning.
06:10:43
24
THE COURT: Okay.
25
MR. COSTA: And if we're still with Mr. Davis,

3422
1 given this issue with China travel, could we -- hopefully,

2 we'll be done with Mr. Davis. But if not, could we -3 would it be possible to call him and then resume Davis?
06:10:57
THE COURT: How long had a witness is he?
MR. WARREN: Depends on cross.
MR. COSTA: Not much more than hour on direct,
7 and then whatever they've got.

8
THE COURT: Do you know who they're referring
9 to?
06:11:05
10
MR. FAZEL: I do now. It's Mr. Rossi. Yes.
11
THE COURT: All right. About how much would
12 you -- well, I forgot to look at what you -- did -- they

13 say they're taking an hour, how much time ballpark do you
14 need? Another hour at least?
06:11:15
15
MR. SCARDINO: Maybe -- we're going to have
16 some questions for Mr. Rossi.
06:11:21
06:11:29
17
THE COURT: All right. Couple of hours?
18
MR. FAZEL: Yes, Your Honor.
19
THE COURT: All right. So we're looking at
20 three hours.
21
When is he coming in?
22
MR. COSTA: Well, he's here now.
23
THE COURT: And when does he have to get back?
24
MR. COSTA: Well, right now, he's scheduled to
25 go to New York on Wednesday. We're trying to change that.

3423
1 We're -- there is some wiggle room. We might be able to

2 deal with this ourselves. But in the event we can't change
3 all the flights, it's a backup of whether we could call
4 him.
06:11:39
THE COURT: There's a number of ways to handle
6 it. If you can't agree on it, I'll swear him in and keep
7 him here. Or say, if he wants to go to New York and comes
8 back on my order, or we'll get him before he gets back on a
9 plane to China.
06:11:53
10
MR. SCARDINO: That would be our choice, Judge.
11
THE COURT: All right. Again, I'm not putting
12 it off. We can do it all tomorrow morning, if you want.

13 Just before we get underway, we'll take care of it. All
14 right? And let them stay in there a while. They'll be
06:12:06
15 fine. Another half-hour, and they're going to get another

16 cup of coffee downstairs.
17
All right. Anything further from the
18 government tonight?
06:12:14
19
MR. STELLMACH: Nothing, Your Honor.
20
THE COURT: Anything further from the defense
21 tonight?
22
MR. FAZEL: No, sir.
23
THE COURT: All right. Everybody remain
24 seated. You're excused if you want to. I'm just going to

06:12:20
25 get the time for the attorneys, and we'll be adjourned for
3424
1 the day. So we are officially adjourned.

2
3

COURT REPORTER'S CERTIFICATE
4
5 I, Johnny C. Sanchez, certify that the foregoing is a
6 correct transcript from the record of proceedings in the
7 above-entitled matter.
8
9
/s/_________________________
Johnny C. Sanchez, CRR, RMR
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
3425
#
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$
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0
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1527 [1] - 3193:25
1528 [1] - 3195:17
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173.6 [1] - 3194:11
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3381:4, 3383:18
1:01 [1] - 3257:20
1 [31] - 3146:14, 3179:24, 3181:1,

3181:2, 3182:25, 3183:2, 3183:4,
3184:16, 3185:14, 3185:15, 3185:19,
3191:24, 3194:7, 3194:13, 3195:6,
3195:18, 3196:9, 3207:6, 3207:17,
3207:19, 3238:21, 3254:18, 3255:1,
3255:8, 3255:13, 3283:15, 3284:9,
3323:18, 3328:3, 3333:20, 3386:11
1,500 [6] - 3217:25, 3218:4, 3218:25,
3219:21, 3222:17, 3223:9
1,532 [1] - 3218:2
1,600 [1] - 3218:1
1.5 [1] - 3180:1
1.6 [1] - 3360:14
1.7 [4] - 3188:4, 3224:25, 3225:3,
3261:7
1.8 [1] - 3360:12
1.9 [1] - 3360:12
1/2 [2] - 3166:11, 3289:17
2
10 [4] - 3194:24, 3205:25, 3342:17,
3359:16
100 [1] - 3230:11
2 [40] - 3144:4, 3179:24, 3182:17,
1004 [1] - 3143:22
3182:25, 3183:2, 3183:5, 3184:16,
1018 [1] - 3144:3
3185:14, 3187:1, 3195:5, 3196:10,
10:00 [3] - 3245:4, 3410:2, 3420:25
3196:12, 3196:13, 3196:15, 3223:6,
10:07 [1] - 3143:6
3237:10, 3238:22, 3253:7, 3254:18,
10:30 [1] - 3245:4
3255:1, 3255:8, 3255:14, 3259:12,
10th [1] - 3282:18
3261:8, 3283:15, 3284:9, 3295:11,
11 [4] - 3143:8, 3175:23, 3176:11,
3333:20, 3344:21, 3358:20, 3358:21,
3193:25
3359:9, 3359:10, 3359:11, 3359:16,
11.87 [1] - 3202:22
3367:2, 3386:11, 3389:21, 3390:6
'
112 [2] - 3289:9, 3373:13
2.3 [1] - 3359:22
11:30 [2] - 3205:24, 3206:2
2.4 [1] - 3359:22
'06 [1] - 3174:1
11th [1] - 3194:16
20 [7] - 3151:9, 3166:19, 3206:1,
'07 [5] - 3177:20, 3179:22, 3179:24,
12 [5] - 3166:23, 3304:10, 3380:7,
3281:1, 3403:3
3180:16, 3181:11
3381:19, 3390:6
20-minute [2] - 3205:24, 3331:4
'08 [13] - 3177:20, 3180:16, 3181:11,
12-10 [1] - 3366:24
200 [1] - 3224:10
3181:12, 3189:17, 3190:25, 3191:13,
12-31-08 [1] - 3369:9
2000 [6] - 3161:2, 3161:5, 3161:7,
3194:16, 3197:11, 3250:22, 3291:2,
12-foot [1] - 3388:18
3165:23, 3167:4, 3173:20
3332:17, 3337:20
12.7 [1] - 3167:7
20005 [1] - 3143:18
'09 [12] - 3182:11, 3250:21, 3255:21,
12:00 [1] - 3205:25
2001 [2] - 3344:19, 3344:20
3258:7, 3291:2, 3293:2, 3301:6,
13 [5] - 3166:11, 3166:23, 3303:20,
2002 [1] - 3342:5
3307:6, 3312:1, 3337:20, 3343:10,
3304:10
2004 [1] - 3159:22
3394:9
13-83 [3] - 3362:7, 3362:12, 3362:15
2005 [4] - 3154:15, 3156:13, 3159:22,
'3 [2] - 3342:5, 3344:21
13-84 [2] - 3368:9, 3368:10
3227:15
'80s [1] - 3147:25
13.48 [1] - 3202:23
2006 [5] - 3173:20, 3174:1, 3174:10,
'99 [2] - 3376:10, 3376:15
138 [2] - 3202:5, 3221:20
3227:15, 3360:13
'flip [1] - 3209:11
14 [3] - 3167:7, 3295:18, 3303:20
2007 [5] - 3173:21, 3174:1, 3180:13,
1400 [1] - 3143:17
3181:8, 3360:11
/
14th [1] - 3369:25
2008 [59] - 3146:20, 3147:2, 3150:14,
1511 [1] - 3313:4
3161:2, 3177:11, 3178:10, 3180:14,
1511-A [3] - 3312:25, 3319:15,
3180:24, 3181:8, 3182:7, 3182:8,
/s [1] - 3424:8
3372:11
3182:9, 3182:21, 3184:5, 3187:3,
3187:13, 3188:23, 3190:8, 3190:14,
1511A [3] - 3291:7, 3328:7, 3334:13
3192:21, 3193:4, 3194:1, 3195:18,
1515 [1] - 3323:15
3426
3196:2, 3198:4, 3199:21, 3202:6,
3202:13, 3202:20, 3203:15, 3209:11,
3215:2, 3216:15, 3220:8, 3221:20,
3227:14, 3227:16, 3228:15, 3228:17,
3250:1, 3250:4, 3250:19, 3255:4,
3292:17, 3301:18, 3314:15, 3316:18,
3330:8, 3337:9, 3338:8, 3358:19,
3359:3, 3359:8, 3359:23, 3361:13,
3364:24, 3365:4, 3366:7, 3371:25
2009 [17] - 3146:14, 3146:20, 3147:3,
3150:14, 3161:3, 3171:23, 3172:1,
3172:2, 3178:19, 3182:10, 3202:25,
3228:18, 3231:17, 3233:11, 3250:3,
3314:16, 3337:11
2012 [1] - 3143:5
21 [3] - 3294:20, 3330:7, 3371:19
21-year [2] - 3176:24, 3305:24
22 [1] - 3166:25
2283 [1] - 3368:2
22nd [1] - 3190:14
23rd [1] - 3191:13
25 [2] - 3255:2, 3281:2
26 [1] - 3421:10
26A [2] - 3236:3, 3236:6
28 [3] - 3202:20, 3364:24, 3366:6
2:00 [1] - 3162:6
2:15 [1] - 3257:18
3
3 [38] - 3184:18, 3239:10, 3239:25,
3240:17, 3248:7, 3248:11, 3249:4,
3249:25, 3253:23, 3254:8, 3255:12,
3256:5, 3257:6, 3258:10, 3258:21,
3259:10, 3259:25, 3261:14, 3261:18,
3261:20, 3262:13, 3262:14, 3264:10,
3265:9, 3266:16, 3266:19, 3266:23,
3274:25, 3275:3, 3275:14, 3282:10,
3283:4, 3283:16, 3284:12, 3284:15,
3333:20, 3359:9, 3359:12
3.1 [3] - 3188:4, 3224:4, 3252:1
3.173 [1] - 3223:4
3.2 [11] - 3216:12, 3216:18, 3217:1,
3217:6, 3217:20, 3218:5, 3218:11,
3224:3, 3224:14, 3224:18, 3252:10
3.8 [3] - 3381:15, 3381:17, 3381:18
30 [3] - 3193:19, 3250:1, 3348:19
300 [1] - 3326:22
30th [2] - 3250:4, 3250:19
31 [1] - 3380:19
3146 [1] - 3145:4
3296 [1] - 3145:5
332 [2] - 3247:22, 3285:23
35 [2] - 3191:18, 3191:21
3:52 [1] - 3331:8
3rd [1] - 3143:22
4
4 [2] - 3187:13, 3333:20
40 [1] - 3348:19
Johnny
400 [2] - 3180:16, 3180:19

406.8 [1] - 3190:20
42 [2] - 3174:16, 3174:24
44 [1] - 3191:20
45 [3] - 3191:18, 3191:21, 3193:19
4:10 [1] - 3331:5
4th [1] - 3187:3
5
5 [8] - 3180:5, 3188:3, 3189:10,
3189:12, 3206:15, 3222:9, 3222:12,
3333:20
5,000 [3] - 3220:6, 3220:14, 3253:21
5.1 [2] - 3180:14, 3181:9
5.5 [3] - 3193:10, 3193:14
50.7 [1] - 3251:23
50/50 [1] - 3343:22
500,000-dollar [1] - 3312:23
51 [1] - 3261:14
515 [1] - 3144:12
541 [1] - 3202:19
550 [1] - 3383:6
58,000 [3] - 3365:1, 3365:2, 3365:10
8
8 [1] - 3359:6
801(D)(2)(d) [1] - 3229:20
81,603,329 [1] - 3381:5
85 [3] - 3151:12, 3185:20, 3186:18
88.2 [1] - 3195:24
880 [3] - 3328:10, 3330:20, 3372:14
880,000 [1] - 3293:18
8th [2] - 3394:16, 3394:17
9
9 [2] - 3154:15, 3359:6
900 [1] - 3330:20
900,000 [2] - 3358:14, 3358:16
990 [4] - 3370:14, 3370:15, 3372:19,
3372:21
9:00 [1] - 3247:14
9:30 [1] - 3420:14
a.m [5] - 3143:6, 3162:6, 3206:2,

3410:2, 3420:25
ability [1] - 3147:20
able [20] - 3148:3, 3148:14, 3182:17,
6 [2] - 3143:5, 3390:6
3182:22,
3203:10, 3242:1, 3245:5,
6.3 [11] - 3248:7, 3249:25, 3252:1,
3246:25,
3247:3, 3288:15, 3290:11,
3252:20, 3253:22, 3255:11, 3255:20,
3294:5, 3310:9, 3317:5, 3321:24,
3258:10, 3259:2, 3259:6, 3264:10
3322:12, 3327:4, 3327:23, 3337:18,
6.6 [1] - 3180:3
3423:1
60th [2] - 3203:20, 3203:21
above-entitled [1] - 3424:7
61129 [1] - 3143:14
absolute [1] - 3300:9
63 [2] - 3216:17, 3373:9
Absolutely [1] - 3177:24
63-1/2 [6] - 3215:12, 3215:23, 3216:24,
absolutely [6] - 3155:23, 3209:9,
3217:11, 3223:2, 3252:10
3244:20, 3258:1, 3400:24, 3419:11
63.5 [2] - 3214:25, 3218:6
abstract [1] - 3155:21
641 [1] - 3224:11
abundance [2] - 3272:2, 3272:3
668 [2] - 3154:13, 3154:18
acceptable [2] - 3157:17, 3416:24
6:00 [2] - 3331:6, 3421:14
access [11] - 3174:4, 3176:20,
6:05 [1] - 3390:24
3211:10,
3327:4, 3356:21, 3356:23,
6:12 [1] - 3424:2
3357:15, 3357:21, 3360:8, 3374:23,
6th [1] - 3394:16
3395:12
accessed [2] - 3335:5, 3370:5
7
accordance [1] - 3324:13
according [10] - 3155:25, 3166:3,
7 [2] - 3252:19, 3388:14
3167:9, 3191:2, 3203:2, 3216:16,
3250:20, 3251:25, 3279:4, 3295:11
70 [1] - 3363:4
account [30] - 3186:3, 3186:5, 3186:7,
700 [1] - 3225:19
3186:9, 3194:10, 3212:18, 3322:23,
713.250.5581 [1] - 3144:13
3323:7, 3326:21, 3327:24, 3335:23,
726 [1] - 3236:13
3355:7, 3362:24, 3363:5, 3363:13,
733 [1] - 3225:10
3363:16, 3363:24, 3363:25, 3364:2,
741 [1] - 3224:22
3364:15, 3365:9, 3365:12, 3366:20,
75 [1] - 3281:5
3368:18, 3369:3, 3369:5, 3369:8,
77002 [3] - 3143:23, 3144:4, 3144:12
3370:11, 3372:5
77208-1129 [1] - 3143:15
accountant [2] - 3275:21, 3279:19
77279 [1] - 3144:7
accountants [3] - 3176:11, 3176:19,
79535 [1] - 3144:7
3197:16
C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3427
3319:20, 3338:24, 3365:20, 3375:13,
advertising [1] - 3271:4
3375:20, 3376:8, 3376:18, 3376:22,
advisor [4] - 3164:6, 3168:14, 3169:6,
3378:4, 3378:6, 3379:11
3242:15
ALLEN [1] - 3143:6
advisors [13] - 3150:6, 3150:13,
allow [2] - 3208:20, 3286:21
3158:5, 3158:11, 3158:17, 3158:24,
3163:21, 3165:9, 3192:15, 3226:5,
allowed [3] - 3155:19, 3239:21,
3241:22, 3241:25, 3260:1
3263:17
affair [1] - 3344:1
allowing [1] - 3274:19
affairs [10] - 3293:1, 3340:9, 3340:12,
almost [8] - 3314:14, 3339:2, 3344:23,
3340:16, 3340:18, 3341:4, 3341:12,
3348:23, 3349:7, 3355:1, 3385:6,
3343:1, 3343:4, 3410:19
3397:17
affect [1] - 3401:8
alone [3] - 3154:10, 3174:17, 3343:15
affiliated [1] - 3271:6
alternatives [1] - 3351:13
affirmatively [2] - 3304:1, 3316:4
aluminum [1] - 3388:18
aforementioned [1] - 3343:12
Alvarado [22] - 3212:8, 3228:3,
3228:11, 3228:19, 3228:22, 3229:3,
afoul [1] - 3420:2
3229:9, 3229:16, 3229:23, 3230:21,
afraid [2] - 3201:14, 3201:16
3231:2, 3231:10, 3232:18, 3232:19,
afternoon [3] - 3262:19, 3410:3,
3233:15, 3233:16, 3244:2, 3244:3,
3418:23
3244:16, 3267:18, 3267:19, 3281:23
age [4] - 3377:25, 3378:1, 3397:18,
America [2] - 3160:11, 3176:1
3401:7
AMERICA [1] - 3143:4
aged [1] - 3377:23
amount [27] - 3152:14, 3153:11,
agency [1] - 3375:4
3156:11, 3157:14, 3157:21, 3161:11,
agenda [1] - 3165:1
3180:9, 3180:12, 3186:22, 3194:13,
agent [4] - 3229:19, 3271:18, 3271:22,
3196:11, 3197:2, 3197:3, 3217:4,
3273:15
3217:5, 3225:12, 3246:7, 3254:17,
agents [2] - 3212:21, 3304:11
3275:2, 3293:18, 3334:5, 3334:24,
ago [2] - 3315:25, 3316:13
3371:18, 3372:17, 3377:21, 3415:16,
agree [9] - 3269:17, 3298:18, 3322:3,
3421:9
3355:24, 3411:9, 3412:8, 3413:3,
amounts [1] - 3191:3
3417:9, 3423:6
amplification [1] - 3351:17
agreed [3] - 3323:1, 3323:2, 3394:20
analysis [1] - 3223:18
agreement [19] - 3311:22, 3315:6,
analyst [2] - 3177:18, 3178:7
3315:7, 3321:24, 3322:4, 3322:13,
analysts [1] - 3173:4
3323:2, 3323:6, 3323:11, 3324:13,
Andrew [1] - 3143:16
3324:19, 3326:17, 3327:25, 3328:3,
announce [6] - 3198:13, 3201:19,
3346:8, 3346:9, 3395:20, 3395:22,
3203:10, 3204:1, 3207:16, 3419:20
3420:11
announced [4] - 3204:12, 3204:19,
Agreement [1] - 3324:9
3224:11, 3224:15
agrees [1] - 3323:7
announcement [10] - 3200:21, 3203:7,
ahead [18] - 3146:5, 3176:7, 3190:8,
3204:3, 3205:2, 3205:12, 3205:16,
3206:5, 3213:22, 3232:23, 3239:21,
3206:10, 3221:21, 3226:2, 3226:4
3241:11, 3257:23, 3274:20, 3286:2,
announcements [1] - 3421:1
3300:25, 3330:17, 3351:25, 3374:4,
announcing [1] - 3199:17
3397:16, 3400:14
annual [10] - 3166:4, 3289:10,
ahold [1] - 3338:24
3374:11, 3374:13, 3374:14, 3374:15,
aids [3] - 3350:13, 3350:24, 3373:6
3374:19, 3379:15, 3380:4, 3382:10
air [1] - 3414:14
answer [29] - 3183:18, 3183:23,
aircraft [1] - 3174:16
3204:7, 3213:16, 3221:6, 3221:7,
airline [1] - 3174:18
3245:11, 3245:12, 3252:22, 3261:3,
airlines [13] - 3171:11, 3187:22,
3272:24, 3304:19, 3304:22, 3305:1,
3188:2, 3188:8, 3188:13, 3188:15,
3311:7, 3319:24, 3325:19, 3325:20,
3188:18, 3188:23, 3189:7, 3189:12,
3325:25, 3326:3, 3326:8, 3326:12,
3189:19, 3189:21, 3189:25
3349:25, 3383:12, 3383:22, 3383:23,
airplane [1] - 3189:16
3384:5, 3403:16
Airport [1] - 3233:13
Answered [2] - 3304:1, 3316:4
Al [1] - 3148:9
answered [8] - 3307:11, 3307:14,
alarmed [1] - 3162:5
3385:21, 3399:7, 3406:6, 3407:17,
Ali [1] - 3143:20
3407:18, 3408:19
all-time [1] - 3174:6
answering [3] - 3305:18, 3305:24,
alleging [1] - 3271:11
3306:6
Allen [14] - 3149:11, 3292:19, 3318:16,
anticipate [4] - 3413:4, 3414:10,
accounting [29] - 3159:4, 3175:21,

3175:25, 3176:3, 3200:7, 3204:4,
3206:23, 3208:1, 3209:18, 3217:23,
3218:15, 3222:3, 3223:19, 3263:16,
3263:23, 3271:5, 3275:17, 3279:20,
3283:8, 3356:10, 3356:11, 3356:22,
3364:1, 3374:20, 3374:21, 3381:21,
3382:1, 3385:11
accounting-wise [1] - 3223:19
accountings [1] - 3187:18
accounts [19] - 3184:17, 3191:18,
3194:14, 3294:11, 3295:6, 3322:16,
3322:20, 3323:5, 3323:9, 3323:10,
3323:21, 3327:8, 3327:17, 3348:19,
3363:7, 3363:20, 3363:22, 3364:4,
3364:10
accurate [12] - 3253:12, 3254:10,
3274:15, 3276:10, 3276:11, 3276:25,
3277:7, 3281:16, 3281:17, 3288:25,
3289:7, 3342:12
accurately [2] - 3224:4, 3276:15
acquired [2] - 3210:24, 3216:23
acre [2] - 3217:4, 3223:7
acreages [2] - 3218:7, 3223:6
acres [10] - 3217:25, 3218:1, 3218:4,
3218:25, 3219:21, 3222:17, 3222:18,
3223:3, 3223:9, 3388:14
act [1] - 3347:21
acted [1] - 3347:19
acting [1] - 3270:5
action [8] - 3273:6, 3273:22, 3274:6,
3274:16, 3274:17, 3274:18, 3275:14,
3347:23
activities [1] - 3174:15
activity [1] - 3172:23
actual [10] - 3164:4, 3204:16, 3205:14,
3217:21, 3253:23, 3257:6, 3262:13,
3266:23, 3347:16, 3415:22
acute [1] - 3162:2
add [1] - 3203:6
added [1] - 3253:17
adding [1] - 3201:19
addition [6] - 3165:7, 3184:9, 3237:18,
3245:1, 3358:17, 3393:23
additional [7] - 3172:23, 3175:20,
3180:21, 3242:17, 3242:19, 3243:4,
3243:5
address [4] - 3165:24, 3277:20,
3286:12, 3323:7
addressed [1] - 3236:25
adjacent [2] - 3266:4, 3287:25
adjourn [1] - 3409:23
adjourned [2] - 3423:25, 3424:1
administrative [2] - 3189:14, 3363:25
admissibility [1] - 3213:6
admissible [2] - 3213:1, 3373:19
admitted [5] - 3155:24, 3180:7,
3286:18, 3362:15, 3368:13
admonish [1] - 3410:24
adultery [1] - 3409:11
advance [3] - 3198:19, 3334:6, 3417:7
Advertising [1] - 3169:16
3428
3414:22, 3415:4
3239:9, 3251:7, 3255:1, 3255:9,
Aztec [1] - 3165:15
3255:18, 3255:19, 3256:18, 3259:6,
Antigua [14] - 3162:4, 3170:18,
3259:9, 3259:25, 3262:14, 3263:18,
3171:1, 3172:16, 3172:18, 3173:17,
B
3263:25, 3264:10, 3264:12, 3265:9,
3208:9, 3210:6, 3210:19, 3211:17,
3289:6, 3320:18, 3322:16, 3326:20,
3240:25, 3252:5, 3363:18, 3395:4
baby [1] - 3419:12
3327:14, 3328:19, 3329:7, 3345:14,
anytime [1] - 3147:4
babysitter [5] - 3404:18, 3404:21,
3345:15,
3348:22,
3361:17,
3361:19
anyway [1] - 3176:15
3404:23, 3405:4, 3405:20
assigned [1] - 3252:20
apartment [1] - 3162:23
backed [1] - 3255:23
Assistant [2] - 3143:14, 3352:11
apologize [2] - 3384:10, 3400:14
background [1] - 3377:9
assistant [2] - 3170:2, 3408:22
appeal [1] - 3211:5
backing [1] - 3278:22
assisted
[1]
3144:14
appear [1] - 3398:9
backup [1] - 3423:3
assume [1] - 3419:10
APPEARANCES [2] - 3143:12
backwards [1] - 3275:2
assuming [6] - 3168:19, 3192:6,
appeared [1] - 3204:19
bad [6] - 3232:13, 3316:3, 3361:7,
3204:24, 3205:4, 3211:24, 3213:1
appellate [1] - 3419:23
3361:10, 3361:24, 3366:23
asterisks
[1]
3185:17
applicable [1] - 3408:14
bag [2] - 3333:6, 3336:15
AT [1] - 3331:12
appointed [2] - 3160:9, 3327:11
balance [10] - 3196:1, 3198:14,
attached [3] - 3188:5, 3206:16, 3226:9
appraisal [1] - 3218:18
3200:22, 3225:14, 3255:14, 3276:20,
attachment
[6]
3187:23,
3222:8,
appreciate [1] - 3397:11
3364:17, 3364:22, 3364:25, 3369:9
3226:25, 3237:5, 3237:9, 3237:10
appreciates [1] - 3220:14
balances [4] - 3194:5, 3194:7,
attack [5] - 3162:4, 3162:8, 3162:9,
approach [5] - 3297:15, 3410:18,
3194:10, 3194:21
3162:10,
3411:9
3412:20, 3412:24, 3420:1
Baldwyn [24] - 3292:25, 3293:24,
attacked [1] - 3286:9
approached [1] - 3183:7
3339:13,
3339:14, 3339:18, 3340:21,
attacks [1] - 3162:5
appropriate [3] - 3276:4, 3412:21,
3340:23,
3340:24, 3341:13, 3341:15,
attempt [2] - 3162:12, 3162:15
3419:21
3341:18, 3342:25, 3343:4, 3343:15,
attempted
[1]
3337:15
approval [2] - 3188:5, 3372:7
3344:5, 3344:10, 3355:10, 3360:22,
attend [4] - 3164:2, 3164:6, 3164:12,
approve [1] - 3293:13
3361:9, 3364:2, 3366:3, 3371:2,
3282:8
Approved [1] - 3386:19
3401:12, 3402:16
attendance
[1]
3245:2
approved [7] - 3293:15, 3313:24,
ballpark [1] - 3422:13
attended [2] - 3193:1, 3233:14
3367:11, 3367:12, 3372:1, 3372:7,
bank [192] - 3146:13, 3146:19, 3149:5,
attendees [4] - 3165:5, 3247:13,
3381:22
3149:8, 3151:7, 3151:20, 3157:22,
3248:23, 3273:9
area [5] - 3160:1, 3161:7, 3173:7,
3161:17, 3166:4, 3166:8, 3166:22,
attending [3] - 3254:1, 3258:15,
3174:16, 3266:3
3167:14, 3168:17, 3171:1, 3171:7,
3259:23
areas [2] - 3209:1, 3421:1
3171:9, 3172:9, 3172:18, 3172:19,
attention [3] - 3413:23, 3414:17,
arenas [1] - 3165:4
3172:23, 3180:2, 3180:15, 3181:24,
3417:7
argue [1] - 3419:1
3182:15, 3182:22, 3183:7, 3183:13,
Attorney [2] - 3143:14, 3144:3
argument [2] - 3230:15, 3419:23
3183:24, 3184:20, 3184:23, 3186:2,
attorney [10] - 3288:15, 3297:9,
Arizona [1] - 3241:24
3186:7, 3190:25, 3192:3, 3192:16,
3299:16, 3300:17, 3300:18, 3301:6,
arm [1] - 3152:11
3193:10, 3193:14, 3193:18, 3193:22,
3303:1, 3304:23, 3378:10, 3384:6
arms [1] - 3268:7
3196:2, 3196:7, 3197:2, 3198:14,
attorney-client [3] - 3299:16, 3300:17,
arrive [2] - 3218:11, 3249:9
3199:13, 3199:15, 3199:17, 3200:6,
3300:18
arrived [12] - 3244:6, 3244:23, 3245:3,
3200:16, 3200:22, 3201:21, 3202:24,
attorneys [6] - 3288:7, 3306:14,
3245:5, 3249:1, 3249:11, 3262:18,
3203:24, 3204:13, 3204:16, 3205:1,
3309:15, 3329:15, 3421:6, 3423:25
3262:19, 3262:21, 3265:13, 3287:24,
3205:16, 3206:11, 3209:17, 3209:20,
Attorneys [1] - 3352:12
3310:12
3209:21, 3209:23, 3211:21, 3212:1,
audacious [1] - 3411:9
arrow [1] - 3215:23
3212:3, 3212:14, 3213:9, 3213:12,
audible [1] - 3319:24
art [3] - 3284:22, 3341:22, 3341:24
3214:1, 3214:22, 3214:24, 3215:7,
audit [4] - 3279:14, 3280:2, 3280:3,
artfully [2] - 3218:8, 3396:13
3215:9, 3216:3, 3216:6, 3216:12,
3280:18
articles [1] - 3354:10
3216:13, 3216:18, 3216:23, 3217:2,
auditor [2] - 3146:13, 3146:17
aside [2] - 3295:1, 3301:15
3217:17, 3217:18, 3219:21, 3220:4,
auditors [1] - 3279:22
aspect [2] - 3412:19, 3413:18
3220:5, 3221:13, 3221:14, 3221:21,
authorities [1] - 3287:1
3224:3, 3224:8, 3224:19, 3224:20,
ass [1] - 3247:6
authority [2] - 3349:13, 3349:14
3225:5, 3225:25, 3226:2, 3226:4,
assert [1] - 3298:5
automobile [1] - 3377:7
3229:4, 3229:17, 3230:7, 3230:8,
asset [5] - 3217:2, 3237:16, 3248:8,
automobiles [1] - 3377:10
3230:11, 3232:23, 3233:1, 3233:17,
3250:1, 3253:11
available [2] - 3162:25, 3191:24
3234:15, 3234:23, 3235:25, 3236:13,
assets [59] - 3149:25, 3150:10,
Avenue [1] - 3143:17
3238:7, 3238:20, 3239:5, 3244:1,
3150:11, 3150:13, 3150:14, 3150:19,
average [1] - 3167:7
3251:13, 3251:20, 3253:5, 3253:8,
3150:22, 3151:2, 3151:6, 3151:13,
3253:11, 3259:14, 3259:17, 3263:25,
Aviation [3] - 3171:13, 3174:17,
3151:18, 3152:1, 3157:2, 3166:10,
3264:15, 3264:18, 3264:23, 3273:25,
3233:13
3182:16, 3184:11, 3184:15, 3200:3,
3275:15, 3276:9, 3276:18, 3276:19,
avoid [2] - 3214:17, 3329:13
3202:22, 3204:16, 3205:14, 3208:7,
3278:11, 3283:7, 3288:22, 3289:4,
aware [5] - 3153:9, 3153:16, 3170:17,
3208:9, 3226:3, 3231:8, 3231:9,
3289:10, 3289:17, 3290:10, 3290:20,
3170:21, 3341:12
3234:15, 3235:19, 3238:21, 3239:8,
3429
3290:23, 3291:1, 3291:4, 3293:16,
3375:10, 3375:12, 3375:21, 3375:24,
behavior [1] - 3406:17
3294:11, 3315:8, 3318:15, 3326:21,
3376:5, 3376:6, 3376:7, 3376:9,
behind [2] - 3173:13, 3268:7
3327:8, 3327:17, 3328:15, 3328:20,
3377:4, 3377:12, 3377:19, 3378:3,
bell [1] - 3412:17
3329:19, 3330:4, 3330:9, 3330:18,
3378:15, 3379:8, 3379:16, 3379:18,
below [4] - 3186:21, 3225:2, 3237:7,
3335:18, 3335:23, 3347:1, 3347:7,
3379:24, 3380:3, 3380:5, 3384:13,
3357:20
3347:25, 3348:1, 3348:13, 3348:18,
3386:19
bench [5] - 3297:15, 3297:17, 3410:5,
3348:19, 3348:21, 3348:22, 3348:23,
boat [4] - 3211:17, 3388:2, 3388:17,
3412:21, 3412:24
3348:25, 3349:1, 3349:6, 3349:8,
3388:18
BENCH [1] - 3331:12
3349:10, 3349:11, 3352:21, 3352:22,
Boca [1] - 3330:23
beneath [2] - 3186:10, 3237:3
3356:16, 3356:17, 3356:24, 3358:7,
body [1] - 3286:14
best [4] - 3150:15, 3274:3, 3300:10,
3363:7, 3363:13, 3363:16, 3363:20,
Bogar [12] - 3160:3, 3160:6, 3160:14,
3416:19
3363:22, 3363:24, 3364:15, 3366:14,
3160:21, 3160:23, 3233:18, 3244:4,
betray [2] - 3407:4, 3407:6
3366:19, 3368:18, 3370:9
3261:23, 3267:20, 3268:1, 3268:5,
betrayal [1] - 3407:8
Bank [27] - 3170:4, 3186:4, 3186:8,
3268:7
betrayed [4] - 3407:23, 3407:25,
3186:16, 3194:14, 3201:22, 3202:13,
bogar [2] - 3160:4, 3160:5
3408:3, 3409:9
3210:3, 3214:3, 3231:8, 3235:19,
Bogar's [2] - 3160:8, 3268:8
better [10] - 3148:16, 3187:10, 3291:7,
3236:25, 3246:6, 3250:6, 3255:15,
BOH [1] - 3186:15
3291:8, 3332:5, 3333:17, 3346:15,
3279:17, 3348:4, 3348:5, 3348:15,
bolster [2] - 3199:14, 3200:22
3350:25, 3410:23, 3417:8
3356:20, 3362:24, 3363:14, 3363:17,
bonds [1] - 3150:8
Betty [2] - 3352:2, 3352:5
3368:17, 3370:11, 3374:11, 3375:22
bonus [3] - 3158:13, 3290:17, 3290:22
between [17] - 3165:8, 3176:4,
bank's [18] - 3149:20, 3167:5,
bonuses [10] - 3158:10, 3292:24,
3177:20, 3180:13, 3184:12, 3215:5,
3171:21, 3172:4, 3184:11, 3194:16,
3295:2, 3313:18, 3313:20, 3313:21,
3240:10, 3240:20, 3242:13, 3255:7,
3202:16, 3202:18, 3202:19, 3204:1,
3314:18, 3325:1, 3338:19, 3358:16
3255:13, 3303:14, 3319:10, 3336:24,
3207:16, 3208:3, 3238:21, 3255:1,
book [1] - 3271:10
3380:24, 3394:20
3255:9, 3263:18, 3264:23, 3288:24
bookkeeping [13] - 3159:5, 3204:15,
beyond [5] - 3157:2, 3214:19, 3264:7,
banked [1] - 3368:19
3205:9, 3205:11, 3206:8, 3206:12,
3386:10, 3421:14
banking [4] - 3191:18, 3191:21,
3206:25, 3208:8, 3216:1, 3224:9,
Bible [5] - 3401:13, 3401:14, 3401:16,
3200:18, 3363:5
3224:14, 3225:18, 3250:24
3401:18, 3402:15
bankruptcy [1] - 3147:24
books [8] - 3177:24, 3178:2, 3224:20,
big [9] - 3180:4, 3191:19, 3209:1,
banks [6] - 3166:6, 3330:9, 3330:11,
3250:5, 3250:23, 3329:24, 3330:1,
3321:11, 3321:15, 3330:13, 3388:13,
3330:13, 3363:20, 3368:21
3330:3
3389:16, 3390:20
Baptist [2] - 3402:17, 3402:18
borrow [1] - 3372:16
Bill [2] - 3375:13, 3377:21
bar [2] - 3266:3, 3267:2
borrowed [2] - 3180:19, 3301:22
bill [1] - 3376:23
Barbuda [3] - 3208:9, 3210:6, 3252:5
borrowing [3] - 3161:16, 3335:1,
billed [1] - 3338:6
bare [1] - 3415:24
3345:20
billion [55] - 3150:17, 3150:18,
bargain [3] - 3310:12, 3337:14
bother [1] - 3335:17
3160:12, 3180:1, 3180:3, 3180:5,
barrister [2] - 3378:6, 3378:8
bottom [19] - 3185:19, 3186:17,
3180:14, 3181:9, 3193:10, 3193:14,
bars [1] - 3319:3
3190:16, 3190:17, 3194:1, 3194:9,
3203:3, 3203:8, 3204:2, 3207:6,
base [1] - 3290:22
3194:11, 3195:20, 3207:5, 3207:6,
3207:17, 3207:19, 3216:12, 3216:18,
based [18] - 3148:23, 3167:19,
3279:15, 3317:25, 3319:18, 3324:3,
3217:1, 3217:6, 3217:20, 3218:5,
3167:22, 3168:3, 3168:4, 3172:13,
3324:5, 3366:24, 3381:13, 3381:24,
3218:11, 3221:22, 3223:4, 3224:4,
3172:14, 3226:23, 3233:3, 3234:9,
3386:17
3224:14, 3224:18, 3224:25, 3225:3,
3253:5, 3273:6, 3273:11, 3273:22,
bought [2] - 3171:19, 3333:18
3226:6, 3248:7, 3249:25, 3252:1,
3273:23, 3274:7, 3278:21, 3416:25
bounds [1] - 3156:5
3252:10, 3252:20, 3253:7, 3253:22,
basic [1] - 3275:17
3255:11, 3255:20, 3258:10, 3259:2,
Box [2] - 3143:14, 3144:7
basis [9] - 3148:16, 3152:23, 3172:18,
3259:6, 3261:8, 3264:10, 3295:11,
box [3] - 3237:3, 3363:3, 3389:13
3180:24, 3183:14, 3195:16, 3269:12,
3295:16, 3322:3, 3322:19, 3323:2,
boys [3] - 3404:4, 3404:6, 3404:7
3271:7, 3299:1
3323:8, 3323:18, 3326:4, 3328:3
branches [1] - 3149:1
Baton [1] - 3148:24
billion-dollar [1] - 3255:11
break [19] - 3205:20, 3205:23,
batting [1] - 3359:21
billionaires [1] - 3211:17
3205:25, 3206:9, 3212:23, 3213:7,
Bay [1] - 3243:24
billions [1] - 3322:9
3217:7, 3244:22, 3257:18, 3265:21,
Bazel [1] - 3202:24
bills [1] - 3347:12
3266:20, 3307:4, 3308:25, 3329:16,
became [2] - 3150:11, 3376:1
birthday [4] - 3203:20, 3203:21,
3331:4, 3342:21, 3420:23, 3421:4
become [2] - 3161:24, 3169:6
3207:15
breakdown [4] - 3188:3, 3224:6,
becoming [1] - 3197:10
Biscayne [1] - 3243:24
3224:18, 3231:8
BEFORE [1] - 3143:10
bit [7] - 3186:21, 3187:9, 3350:19,
breakdowns [1] - 3223:15
beforehand [1] - 3420:14
3387:18, 3389:16, 3401:8, 3408:15
breaking [2] - 3189:14, 3214:17
began [5] - 3181:23, 3198:4, 3247:14,
biz [1] - 3339:13
breaks [1] - 3227:8
3268:3, 3411:11
block [1] - 3389:1
brick [2] - 3189:15, 3264:11
begin [1] - 3262:5
blocked [1] - 3209:2
brief [3] - 3295:22, 3302:21, 3391:1
beginning [6] - 3155:8, 3165:3,
blurted [1] - 3410:20
briefs [1] - 3419:15
3202:9, 3314:15, 3383:5
board [28] - 3198:1, 3202:18, 3208:22,
bright [1] - 3232:10
behalf [1] - 3386:19
3209:1, 3209:6,
Johnny C. Sanchez,
RMR, 3375:3,
CRR - 3375:6,
jcscourtreporter@aol.com
3430
3191:14, 3192:12, 3193:2, 3193:8,
bring [7] - 3328:5, 3331:5, 3333:9,
capital [22] - 3202:19, 3202:22,
3195:22, 3196:19, 3199:1, 3200:12,
3336:15, 3373:13, 3373:18, 3413:25
3202:23, 3202:24, 3204:1, 3206:11,
3201:5, 3201:18, 3202:4, 3204:9,
3207:16, 3208:4, 3208:5, 3221:21,
bringing [1] - 3413:22
3205:6, 3206:7, 3206:19, 3207:12,
3223:22, 3224:12, 3224:15, 3224:23,
brings [1] - 3202:20
3209:10, 3209:14, 3210:22, 3211:15,
3225:13, 3226:6, 3253:2, 3293:1,
British [5] - 3194:25, 3227:5, 3378:13,
3213:8, 3214:7, 3214:14, 3215:18,
3293:2, 3343:10, 3345:11, 3348:13
3378:14, 3379:25
3216:21, 3217:10, 3219:16, 3220:24,
capital-to-assets [1] - 3202:22
broke [5] - 3262:5, 3268:3, 3330:13,
3221:5, 3221:9, 3222:6, 3222:16,
capital-to-deposits [1] - 3202:23
3371:24, 3405:10
3222:22, 3223:14, 3226:22, 3227:13,
capitalize [1] - 3328:20
broken [1] - 3251:7
3228:2, 3228:9, 3228:16, 3229:2,
captured [1] - 3159:7
broker [6] - 3150:5, 3150:11, 3150:12,
3229:8, 3230:20, 3232:1, 3234:12,
captures [1] - 3380:22
3151:16, 3153:4, 3154:3
3235:16, 3236:4, 3236:12, 3236:24,
car [1] - 3284:23
brokerage [51] - 3147:12, 3147:16,
3237:12, 3238:18, 3239:2, 3239:22,
care [3] - 3237:1, 3292:4, 3423:13
3147:20, 3148:4, 3148:6, 3148:11,
3240:18, 3244:7, 3244:24, 3245:13,
3148:15, 3148:21, 3148:23, 3148:25,
career [1] - 3401:13
3245:25, 3247:24, 3249:13, 3249:16,
3149:6, 3149:8, 3149:10, 3149:14,
Caribbean [2] - 3188:8, 3188:9
3249:21, 3250:17, 3252:16, 3254:25,
3149:20, 3150:4, 3150:10, 3150:15,
case [17] - 3273:14, 3294:4, 3302:4,
3257:3, 3258:2, 3258:3, 3258:25,
3150:18, 3150:23, 3151:1, 3151:4,
3302:6, 3302:18, 3321:16, 3349:3,
3260:14, 3261:1, 3261:5, 3261:16,
3151:8, 3151:19, 3152:1, 3152:11,
3349:4, 3365:21, 3366:22, 3373:17,
3262:2, 3266:13, 3268:14, 3269:2,
3152:15, 3152:24, 3153:11, 3156:11,
3383:24, 3384:2, 3384:4, 3408:14,
3269:18, 3270:19, 3270:20, 3274:21,
3156:19, 3157:1, 3157:6, 3157:14,
3415:22, 3416:21
3274:22, 3275:12, 3276:7, 3277:19,
3157:18, 3157:19, 3157:21, 3158:5,
CASE [1] - 3331:24
3278:6, 3279:10, 3279:25, 3281:10,
3159:15, 3159:24, 3160:9, 3160:16,
cases [3] - 3253:16, 3419:8, 3419:15
3282:7, 3285:22, 3286:23, 3287:10,
3160:18, 3160:24, 3165:9, 3232:23,
cash [42] - 3161:14, 3162:25, 3163:2,
3287:23, 3289:13, 3289:14, 3290:14,
3233:18, 3244:4, 3261:24, 3268:1,
3179:24, 3182:24, 3183:4, 3183:5,
3291:9, 3291:10, 3292:9, 3296:3,
3269:8
3183:6, 3184:17, 3185:14, 3188:16,
3296:24, 3301:1, 3303:5, 3305:4,
brought [4] - 3173:13, 3218:19,
3188:18, 3191:24, 3192:4, 3192:5,
3305:13, 3306:3, 3307:3, 3308:5,
3234:1, 3417:6
3193:15, 3193:20, 3194:5, 3194:7,
3309:1, 3309:5, 3309:19, 3311:13,
budget [1] - 3175:10
3194:11, 3194:13, 3194:16, 3194:21,
3313:6, 3315:24, 3316:11, 3321:5,
budgetary [2] - 3175:9
3195:6, 3195:15, 3196:1, 3196:3,
3322:25, 3324:11, 3325:18, 3326:2,
building [1] - 3211:4
3196:9, 3196:12, 3197:2, 3197:3,
3326:15, 3328:6, 3329:18, 3331:12,
buildings [1] - 3219:22
3198:1, 3200:2, 3203:23, 3204:16,
3331:21, 3332:7, 3334:14, 3342:1,
built [2] - 3211:24, 3212:4
3204:19, 3205:14, 3238:22, 3326:23,
3350:6, 3350:17, 3350:21, 3351:23,
3364:1
bunch [1] - 3185:25
3353:4, 3356:1, 3361:6, 3362:19,
catch [1] - 3351:5
business [38] - 3148:16, 3166:25,
3367:3, 3368:14, 3369:4, 3369:23,
cattle [2] - 3377:8, 3377:10
3242:18, 3242:19, 3279:18, 3339:23,
3370:25, 3371:8, 3372:12, 3373:14,
3339:25, 3340:1, 3340:15, 3340:22,
caused [2] - 3165:25, 3367:9
3374:5, 3380:13, 3383:17, 3384:12,
3340:25, 3341:1, 3341:12, 3341:15,
caution [2] - 3272:2, 3272:4
3385:5, 3386:18, 3387:3, 3389:14,
3343:1, 3343:4, 3343:20, 3344:3,
Cd [1] - 3325:15
3389:24, 3390:4, 3391:3, 3397:21,
3344:6, 3344:13, 3364:4, 3364:6,
CD [65] - 3146:19, 3147:6, 3147:9,
3398:4, 3399:10, 3399:24, 3405:18,
3371:2, 3374:18, 3377:6, 3377:7,
3148:8, 3149:4, 3149:23, 3150:24,
3406:9, 3407:2, 3407:22, 3408:16,
3392:12, 3392:25, 3393:1, 3393:8,
3151:15, 3152:2, 3154:10, 3155:9,
3409:2
3393:9, 3393:10, 3394:1, 3394:2,
3156:11, 3157:2, 3157:6, 3157:14,
3394:3, 3394:22, 3404:7
3157:15, 3157:21, 3159:1, 3159:4,
C
businesses [22] - 3292:25, 3293:23,
3159:8, 3159:12, 3159:15, 3160:1,
3293:25, 3294:1, 3294:5, 3327:12,
3161:3, 3161:10, 3161:11, 3161:13,
3327:15, 3327:18, 3339:15, 3339:18,
3163:18, 3163:19, 3164:9, 3164:20,
calculated [1] - 3294:18
3339:20, 3339:22, 3340:21, 3341:18,
3165:21, 3166:4, 3171:2, 3171:4,
calculation [5] - 3217:6, 3217:22,
3342:2, 3342:4, 3342:7, 3343:12,
3171:6, 3171:19, 3179:11, 3180:2,
3217:23, 3220:14, 3223:5
3343:14, 3343:17, 3355:9, 3364:2
3181:9, 3181:19, 3182:1, 3182:23,
Caldwell [6] - 3377:13, 3377:14,
businessman [1] - 3376:25
3189:20, 3190:24, 3192:1, 3196:5,
3377:15, 3377:17, 3377:18, 3377:22
buy [3] - 3211:6, 3214:24, 3341:1
3198:16, 3199:3, 3201:23, 3242:8,
calendar [1] - 3374:16
buy-sell [1] - 3341:1
3253:5, 3255:5, 3277:3, 3277:5,
California [1] - 3253:15
3280:8, 3280:10, 3281:4, 3287:17,
buying [1] - 3214:8
calm [1] - 3351:7
3295:11, 3325:6, 3342:8, 3342:9,
BY [204] - 3145:4, 3145:5, 3146:9,
Canada [1] - 3186:4
3348:8, 3372:2
3147:1, 3151:23, 3152:22, 3153:22,
Canadian [1] - 3194:25
CDs [34] - 3147:6, 3149:15, 3149:20,
3154:12, 3155:3, 3156:7, 3156:17,
cannot [2] - 3304:22, 3415:5
3151:4, 3151:7, 3151:20, 3152:15,
3157:12, 3158:4, 3161:23, 3166:14,
capability [1] - 3240:6
3153:11, 3154:4, 3158:6, 3158:11,
3167:3, 3168:12, 3169:4, 3170:16,
capable [1] - 3170:6
3158:16, 3161:9, 3163:22, 3165:10,
3171:17, 3172:3, 3175:5, 3176:9,
Capital [14] - 3251:16, 3345:8,
3165:25, 3166:5, 3170:18, 3181:10,
3177:6, 3178:6, 3179:7, 3179:17,
3345:12, 3346:16, 3348:14, 3348:22,
3182:1, 3182:19, 3183:7, 3198:23,
3180:8, 3180:11, 3181:7, 3182:13,
3353:9, 3353:14, 3353:16, 3353:22,
3199:3, 3200:25, 3242:23, 3277:13,
3184:3, 3185:5, 3185:21, 3187:12,
3355:14, 3369:22, 3370:3, 3370:9
3277:24, 3280:12, 3280:22, 3288:22,
3189:4, 3190:7, 3190:13, 3190:22,
3431
3289:5, 3290:11, 3328:16
ceased [1] - 3280:10
celebration [1] - 3203:21
cell [5] - 3291:22, 3328:8, 3332:8,
3332:12, 3332:18
cellphone [12] - 3312:25, 3313:3,
3314:13, 3314:22, 3316:1, 3317:8,
3317:9, 3317:11, 3317:12, 3317:20,
3319:19
center [1] - 3191:3
central [1] - 3389:9
Central [1] - 3376:25
cents [1] - 3151:9
CEO [1] - 3195:13
certain [6] - 3154:22, 3164:7, 3164:8,
3352:18, 3354:2, 3355:3
certainly [7] - 3157:24, 3199:4,
3262:1, 3292:2, 3300:14, 3344:17,
3398:9
CERTIFICATE [1] - 3424:3
certificates [2] - 3242:21, 3278:1
certify [1] - 3424:5
cetera [5] - 3189:16, 3253:1, 3285:25,
3351:5, 3354:10
CFO [22] - 3178:21, 3179:9, 3237:1,
3322:17, 3326:3, 3345:16, 3348:16,
3349:13, 3355:17, 3356:4, 3356:8,
3356:9, 3356:17, 3356:19, 3357:1,
3357:19, 3358:4, 3358:9, 3360:3,
3370:13, 3380:2
chain [1] - 3357:1
chair [1] - 3232:22
chairman [9] - 3149:21, 3195:13,
3198:1, 3375:25, 3376:1, 3376:6,
3376:8, 3376:17, 3380:2
chance [1] - 3297:4
change [6] - 3252:1, 3253:7, 3342:16,
3372:20, 3422:25, 3423:2
changed [5] - 3217:16, 3224:13,
3276:21, 3276:23, 3299:2
changing [2] - 3324:24, 3351:4
characterize [3] - 3275:21, 3338:16,
3357:14
characterized [1] - 3315:3
charge [5] - 3185:13, 3356:9, 3356:10,
3358:5
charged [4] - 3395:21, 3395:23,
3395:25, 3399:16
charities [1] - 3294:22
Charles [1] - 3168:13
chart [21] - 3248:3, 3248:5, 3249:24,
3251:19, 3251:21, 3251:25, 3252:4,
3253:25, 3254:3, 3258:4, 3259:21,
3260:3, 3261:14, 3262:7, 3262:10,
3262:25, 3263:12, 3264:8, 3264:13,
3265:8, 3266:6
charts [1] - 3305:6
check [7] - 3313:2, 3331:4, 3366:12,
3367:5, 3367:24, 3368:2, 3369:16
checked [1] - 3237:2
checking [4] - 3186:9, 3194:14,
3323:18, 3369:3
checks [3] - 3366:8, 3370:20, 3371:18

coffee [1] - 3423:16
chief [12] - 3169:1, 3233:20, 3238:7,
college [1] - 3401:12
3245:2, 3267:17, 3269:8, 3289:24,
column [3] - 3186:2, 3191:7, 3222:25
3322:6, 3356:9, 3358:5, 3386:24,
Comaeux [5] - 3148:9, 3148:10,
3401:4
3148:19, 3153:5, 3159:19
children [3] - 3404:2, 3404:11,
Comerica [1] - 3194:24
3406:14
comfort [1] - 3415:16
China [3] - 3421:20, 3422:1, 3423:9
comfortable [6] - 3151:14, 3235:11,
Chinese [2] - 3413:18, 3413:20
3299:22, 3419:11, 3419:18, 3420:21
choice [1] - 3423:10
coming [17] - 3146:4, 3161:13,
Church [2] - 3402:17, 3402:18
3173:20, 3182:1, 3182:14, 3188:1,
church [15] - 3294:25, 3295:2,
3197:1, 3199:6, 3199:23, 3200:25,
3305:22, 3312:23, 3313:2, 3313:14,
3285:4, 3287:18, 3287:20, 3357:5,
3401:24, 3402:2, 3402:4, 3402:6,
3418:12, 3422:21
3402:8, 3402:10, 3402:12, 3402:16
commence [1] - 3276:4
churches [1] - 3294:21
comment [2] - 3410:22, 3411:1
CIO [1] - 3267:16
comments [1] - 3172:17
circle [2] - 3209:25, 3210:2
commercial [5] - 3171:11, 3174:18,
circular [1] - 3329:2
3187:22, 3188:8, 3369:3
circumstances [1] - 3177:25
Commission [3] - 3236:16, 3237:6,
3327:11
claim [4] - 3319:19, 3321:25, 3324:20,
commissions [1] - 3158:10
3338:24
claims [2] - 3328:15, 3328:21
commit [1] - 3310:6
clarified [2] - 3342:13, 3342:20
commitment [1] - 3232:14
clarify [2] - 3161:19, 3305:11
commitments [1] - 3189:15
class [7] - 3401:13, 3401:14, 3401:16,
committed [5] - 3325:4, 3328:2,
3401:18, 3402:15, 3402:19, 3403:1
3329:21, 3345:25, 3409:11
classes [2] - 3248:8, 3250:1
committing [1] - 3378:21
clean [2] - 3260:10, 3321:10
communicate [1] - 3197:24
clear [9] - 3213:19, 3232:11, 3242:22,
communicated [2] - 3208:21, 3296:13
3302:23, 3322:15, 3323:10, 3327:9,
communicating [5] - 3183:11,
3365:11, 3370:6
3183:12, 3183:14, 3191:23, 3195:14
cleared [1] - 3209:1
communication [5] - 3156:2, 3296:17,
clearer [1] - 3362:18
3314:2, 3338:15, 3396:25
clearly [4] - 3313:8, 3397:12, 3397:14,
communications [1] - 3393:10
3412:9
companies [27] - 3180:22, 3180:23,
client [7] - 3194:22, 3246:5, 3297:21,
3180:25, 3181:5, 3182:19, 3187:21,
3299:16, 3300:3, 3300:17, 3300:18
3214:16, 3241:23, 3269:7, 3269:10,
3270:9, 3270:10, 3271:6, 3286:1,
clients [12] - 3150:7, 3150:10,
3308:1, 3342:10, 3352:2, 3354:3,
3150:19, 3150:21, 3150:23, 3153:12,
3356:13, 3356:18, 3357:9, 3361:1,
3170:25, 3242:16, 3285:4, 3287:17
3361:8, 3361:24, 3368:4
clip [3] - 3192:9, 3192:18, 3193:10
company [56] - 3160:10, 3160:13,
clock [6] - 3176:5, 3295:21, 3390:23,
3175:15, 3175:22, 3205:15, 3214:11,
3409:24, 3419:2, 3421:9
3225:3, 3251:15, 3251:16, 3269:6,
close [4] - 3196:13, 3216:22, 3293:23,
3269:19, 3269:21, 3269:22, 3269:24,
3419:7
3270:5, 3270:13, 3270:21, 3270:24,
closed [3] - 3165:4, 3182:10, 3294:1
3271:23, 3292:23, 3294:1, 3316:2,
closely [1] - 3152:7
3328:14, 3336:7, 3341:25, 3345:12,
closer [2] - 3332:3, 3411:2
3345:13, 3348:13, 3349:8, 3353:8,
closing [2] - 3250:5, 3250:23
3353:10, 3353:23, 3353:24, 3354:1,
clothes [1] - 3197:22
3354:2, 3354:6, 3354:8, 3354:9,
club [5] - 3211:18, 3211:23, 3211:24,
3354:10, 3354:14, 3354:15, 3354:16,
3212:2, 3212:3
3354:17, 3354:19, 3354:25, 3355:1,
Club [8] - 3163:11, 3163:12, 3163:13,
3355:4, 3355:20, 3356:11, 3361:18,
3163:20, 3165:7, 3211:1, 3211:2,
3364:1, 3372:5, 3374:16, 3404:16,
3241:18
3404:24
clubs [1] - 3148:1
Company [14] - 3147:12, 3150:4,
co [3] - 3148:12, 3271:12, 3273:14
3150:5, 3223:16, 3223:17, 3224:10,
co-conspirator [1] - 3271:12
3224:11, 3224:25, 3225:10, 3251:18,
co-defendant [1] - 3273:14
3270:7, 3270:23
co-presidents [1] - 3148:12
comparable [4] - 3218:9, 3218:13,
cobwebs [1] - 3390:25
3218:22,
3219:25
3432
compare [3] - 3166:5, 3218:24,
confront [1] - 3314:11
convince [2] - 3310:15, 3341:10
3385:16
confronted [3] - 3317:4, 3400:6,
cook [2] - 3177:24, 3178:2
compared [1] - 3147:4
3400:9
cooked [5] - 3304:6, 3329:24, 3330:1,
comparison [1] - 3218:14
confused [2] - 3382:9, 3393:3
3330:3, 3385:16
competed [1] - 3165:12
confusing [2] - 3373:21, 3373:22
cooperate [1] - 3286:3
competition [1] - 3165:21
Congress [1] - 3143:22
cooperated [1] - 3395:25
competitions [1] - 3165:8
connection [1] - 3242:13
cooperating [2] - 3286:17, 3306:25
competitive [1] - 3148:22
connotation [1] - 3354:5
copied [1] - 3394:24
complete [2] - 3231:7, 3241:15
consider [1] - 3360:15
copies [2] - 3297:3, 3394:24
completed [6] - 3221:11, 3221:16,
considerably [1] - 3403:4
copy [3] - 3291:11, 3317:20, 3362:7
3222:1, 3224:9, 3252:11, 3294:16
considered [1] - 3164:11
corner [1] - 3202:9
completes [1] - 3409:25
consisted [1] - 3255:1
corporate [4] - 3374:14, 3387:16,
compliance [12] - 3152:6, 3153:3,
3391:18, 3393:2
consistent [2] - 3166:15, 3166:22
3233:19, 3244:1, 3267:17, 3267:24,
correct [77] - 3151:3, 3155:18,
consistently [2] - 3166:22, 3167:15
3268:19, 3269:3, 3269:8, 3270:6,
3161:15, 3161:20, 3161:22, 3171:20,
consolidation [2] - 3328:23, 3329:1
3270:13, 3271:4
3194:17, 3198:23, 3201:1, 3202:2,
conspirator [1] - 3271:12
complicated [2] - 3223:18, 3310:20
3212:25, 3213:3, 3217:12, 3222:5,
Constitution [1] - 3300:19
3224:24, 3226:1, 3227:3, 3235:13,
component [3] - 3175:11, 3175:13,
constructed [1] - 3210:16
3235:14, 3236:16, 3237:22, 3237:25,
3175:14
Consultant [3] - 3413:5, 3413:8,
3247:15, 3251:6, 3251:24, 3252:2,
composition [1] - 3261:20
3413:10
3252:12, 3255:10, 3255:25, 3259:3,
compound [1] - 3308:17
consultant [3] - 3288:14, 3409:17,
3264:21, 3265:3, 3271:17, 3271:20,
computer [27] - 3144:14, 3248:16,
3413:15
3272:20, 3274:10, 3278:20, 3278:23,
3285:20, 3352:10, 3385:13, 3387:5,
consulting [1] - 3417:15
3278:24, 3307:13, 3309:3, 3309:4,
3387:9, 3387:12, 3387:15, 3387:16,
consultive [2] - 3233:16, 3244:3
3313:11, 3314:23, 3323:3, 3327:7,
3387:17, 3388:19, 3388:20, 3389:6,
consummated [1] - 3326:18
3327:12, 3327:15, 3327:19, 3327:23,
3391:4, 3391:8, 3392:7, 3392:8,
contact [2] - 3246:20, 3317:5
3330:6, 3348:1, 3348:6, 3353:6,
3392:10, 3396:15, 3396:17, 3396:18,
contained [4] - 3276:14, 3285:19,
3367:21, 3367:22, 3367:24, 3368:11,
3396:25, 3397:4, 3398:6, 3398:17
3285:20, 3285:24
3368:22, 3369:19, 3374:25, 3376:7,
computer-assisted [1] - 3144:14
content [3] - 3256:5, 3256:7, 3259:11
3381:1, 3381:5, 3381:8, 3381:11,
computers [11] - 3285:7, 3285:9,
contention [2] - 3176:3, 3176:12
3382:13, 3384:23, 3390:21, 3393:24,
3285:12, 3285:15, 3286:4, 3286:14,
contents [2] - 3239:25, 3266:23
3394:6, 3396:22, 3402:9, 3406:10,
3287:7, 3387:14, 3393:13, 3398:13,
context [2] - 3222:15, 3412:22
3406:14, 3414:18, 3424:6
3399:13
continue [9] - 3157:18, 3171:22,
corrected [1] - 3277:14
concern [9] - 3152:14, 3154:1,
3177:23, 3178:4, 3202:25, 3287:3,
correspondence [2] - 3394:25, 3395:7
3156:12, 3161:24, 3161:25, 3162:1,
3391:2, 3410:12, 3421:15
correspondent [2] - 3186:3, 3186:5
3162:24, 3271:25, 3300:9
CONTINUED [1] - 3146:8
cost [8] - 3161:12, 3215:25, 3216:5,
concerned [8] - 3152:25, 3178:20,
continued [4] - 3192:6, 3277:24,
3218:6, 3223:2, 3253:13, 3253:21,
3179:18, 3197:9, 3197:10, 3197:12,
3280:8, 3280:10
3254:5
3197:14
Continued [2] - 3144:1, 3144:2
COSTA [17] - 3156:6, 3411:8, 3411:14,
concerning [3] - 3268:16, 3273:2,
continuing [1] - 3277:13
3412:8, 3412:17, 3416:20, 3417:11,
3273:3
contracts [1] - 3189:15
3417:14, 3417:22, 3420:13, 3420:17,
concerns [11] - 3153:2, 3153:6,
contradict [2] - 3265:4, 3265:10
3421:18, 3421:20, 3421:25, 3422:6,
3153:9, 3153:10, 3157:20, 3162:16,
contribution [5] - 3202:20, 3208:3,
3422:22, 3422:24
3168:7, 3175:6, 3179:8, 3197:7, 3240:2
3208:5, 3224:14, 3225:13
Costa [7] - 3143:13, 3305:9, 3410:20,
concierge's [1] - 3266:3
contributions [1] - 3223:22
3410:23, 3411:2, 3411:7, 3414:19
conclusions [1] - 3412:16
controlled [1] - 3295:7
costing [1] - 3180:25
concurred [1] - 3278:15
controller [5] - 3218:16, 3218:17,
costs [1] - 3189:13
conditions [1] - 3227:23
3226:14, 3356:23, 3358:3
Counsel [3] - 3229:15, 3286:7,
conducting [1] - 3379:12
convened [2] - 3245:3, 3245:8
3407:21
conduit [1] - 3357:12
conventional [4] - 3292:23, 3334:22,
counsel [21] - 3146:5, 3179:6, 3212:7,
confer [1] - 3329:13
3334:23, 3336:7
3212:17, 3227:20, 3229:3, 3229:17,
conference [2] - 3169:2, 3233:24
conversation [26] - 3153:19, 3153:24,
3229:24, 3230:8, 3232:19, 3233:15,
conferences [1] - 3309:14
3162:20, 3163:4, 3175:8, 3177:16,
3233:16, 3234:21, 3235:13, 3244:2,
conferring [1] - 3329:15
3177:18, 3177:22, 3178:10, 3184:8,
3244:3, 3254:21, 3267:17, 3281:24,
confess [1] - 3334:15
3184:9, 3203:12, 3205:7, 3207:14,
3289:25, 3329:13
confidence [4] - 3200:22, 3201:11,
3231:10, 3231:18, 3235:7, 3235:10,
counsel's [1] - 3281:24
3201:13, 3201:21
3240:8, 3242:6, 3247:1, 3266:1,
countries [1] - 3241:22
confidential [2] - 3154:14, 3156:2
3283:19, 3318:12, 3339:4, 3339:7
country [6] - 3158:21, 3175:15,
configure [1] - 3266:16
conversations [8] - 3153:8, 3153:23,
3210:18,
3227:1, 3280:22, 3344:11
configuring [1] - 3266:19
3156:18, 3159:13, 3189:1, 3198:6,
counts [2] - 3395:23, 3411:11
confirms [1] - 3264:4
3242:12, 3285:1
couple [13] - 3147:11, 3151:5,
conflict [1] - 3417:24
conveyed [1] - 3315:8
3195:18, 3203:6, 3243:14, 3302:21,
3433
3310:13, 3324:8, 3374:2, 3394:10,
3275:5, 3275:8, 3275:11, 3275:20,
3400:25
3404:22, 3416:3, 3422:17
3275:24, 3277:18, 3278:3, 3278:14,
CPAs [1] - 3175:23
3278:18, 3279:1, 3279:3, 3279:9,
course [4] - 3163:23, 3244:10,
CPU [2] - 3388:24, 3389:8
3279:18, 3280:21, 3281:3, 3281:5,
3297:21, 3300:18
create [2] - 3336:23, 3338:16
3281:8, 3282:3, 3285:14, 3285:17,
COURT [421] - 3143:1, 3146:2,
created [2] - 3188:21, 3413:16
3286:7, 3286:13, 3286:21, 3287:6,
3146:25, 3151:22, 3152:20, 3153:15,
creative [3] - 3165:2, 3169:15, 3169:18
3287:9, 3287:20, 3291:21, 3292:1,
3153:20, 3154:7, 3154:11, 3154:17,
credibility [2] - 3286:8, 3286:10
3292:7, 3295:20, 3295:23, 3296:1,
3154:19, 3154:23, 3155:2, 3155:16,
credit [3] - 3208:1, 3208:2, 3225:20
3296:20, 3297:15, 3297:18, 3297:25,
3155:21, 3155:24, 3156:4, 3156:14,
credited [1] - 3251:20
3298:3, 3298:6, 3298:11, 3298:14,
3156:16, 3157:9, 3157:11, 3158:3,
cried [1] - 3261:22
3299:4, 3299:12, 3299:15, 3299:25,
3161:20, 3166:12, 3167:2, 3167:25,
crime [1] - 3399:16
3300:16, 3300:25, 3303:4, 3304:16,
3168:10, 3168:20, 3170:13, 3170:15,
crimes [1] - 3328:2
3304:18, 3304:21, 3305:3, 3306:2,
3171:10, 3171:14, 3171:16, 3171:24,
criminal [1] - 3304:12
3307:2, 3308:16, 3308:21, 3308:25,
3172:1, 3174:18, 3174:21, 3174:24,
crisis [1] - 3166:18
3309:3, 3309:13, 3311:6, 3311:12,
3175:1, 3175:4, 3176:5, 3177:3,
Croix [5] - 3176:1, 3226:13, 3227:4,
3316:7, 3316:10, 3322:18, 3323:11,
3177:5, 3178:1, 3178:5, 3178:24,
3231:14, 3269:21
3324:1, 3324:5, 3324:10, 3325:17,
3179:2, 3179:5, 3179:16, 3181:2,
crook [9] - 3306:17, 3309:8, 3309:11,
3325:25, 3326:10, 3326:14, 3329:8,
3181:6, 3182:6, 3182:8, 3182:10,
3309:18, 3321:15, 3379:8, 3379:20,
3329:14, 3329:16, 3331:2, 3331:12,
3182:12, 3183:17, 3184:1, 3187:6,
3379:22, 3379:25
3331:16, 3331:19, 3331:23, 3331:25,
3187:9, 3189:3, 3190:4, 3193:6,
crooks [1] - 3380:5
3332:3, 3332:5, 3341:21, 3341:23,
3196:15, 3196:18, 3198:18, 3198:22,
cross [5] - 3410:19, 3414:24, 3415:17,
3350:1, 3350:5, 3350:14, 3350:20,
3200:9, 3200:15, 3200:24, 3201:2,
3420:1, 3422:5
3351:1, 3351:7, 3351:10, 3351:15,
3201:4, 3201:7, 3201:15, 3201:17,
CROSS [2] - 3145:5, 3296:2
3351:22, 3353:1, 3355:23, 3361:5,
3201:25, 3204:6, 3204:8, 3204:18,
cross-examination [4] - 3410:19,
3362:11, 3362:15, 3368:10, 3368:13,
3204:22, 3205:5, 3205:20, 3206:4,
3414:24, 3415:17, 3420:1
3371:6, 3373:23, 3374:1, 3380:10,
3207:11, 3208:16, 3208:23, 3209:9,
CROSS-EXAMINATION [2] - 3145:5,
3383:8, 3383:11, 3383:16, 3383:21,
3209:12, 3210:10, 3210:13, 3210:15,
3296:2
3384:1, 3384:11, 3385:2, 3386:14,
3210:18, 3210:21, 3211:10, 3211:14,
CRR [2] - 3144:11, 3424:9
3388:24, 3389:1, 3389:3, 3389:6,
3212:22, 3213:1, 3213:3, 3213:5,
cry [1] - 3261:21
3389:9,
3389:11,
3390:18,
3390:20,
3213:18, 3213:22, 3214:13, 3215:15,
cup [1] - 3423:16
3390:22, 3391:2, 3397:14, 3397:16,
3216:16, 3216:20, 3217:7, 3219:6,
currency [2] - 3347:10, 3347:17
3397:23, 3399:5, 3399:8, 3399:20,
3219:10, 3219:12, 3220:18, 3220:23,
current [6] - 3200:23, 3250:25,
3399:22,
3405:14,
3405:17,
3406:8,
3221:1, 3221:4, 3221:7, 3222:2,
3403:20, 3405:15, 3405:19, 3414:10
3406:20, 3406:22, 3407:10, 3407:13,
3222:19, 3222:21, 3226:15, 3226:20,
curtailing [1] - 3174:15
3407:16, 3407:18, 3408:9, 3408:12,
3227:4, 3227:8, 3227:12, 3227:21,
curve [1] - 3412:18
3408:21, 3408:25, 3409:23, 3410:7,
3228:1, 3228:7, 3228:13, 3228:15,
cushion [1] - 3202:17
3410:12, 3411:3, 3411:7, 3411:13,
3228:24, 3229:1, 3229:6, 3229:14,
customer [1] - 3191:9
3411:21, 3412:2, 3412:5, 3412:11,
3229:18, 3230:1, 3230:4, 3230:13,
customers [11] - 3150:11, 3151:19,
3412:15, 3412:19, 3413:18, 3413:20,
3230:16, 3230:19, 3231:24, 3234:2,
3152:15, 3155:9, 3171:7, 3173:12,
3414:16, 3414:20, 3415:5, 3415:25,
3234:5, 3234:11, 3234:16, 3234:18,
3173:15, 3173:18, 3181:25, 3201:23,
3416:2, 3416:6, 3416:10, 3416:22,
3234:21, 3234:24, 3235:1, 3235:12,
3246:5
3417:13, 3417:21, 3418:5, 3418:12,
3235:15, 3236:6, 3236:10, 3236:15,
3418:15, 3418:24, 3420:3, 3420:7,
3236:19, 3236:21, 3238:10, 3238:13,
3420:15, 3420:19, 3421:19, 3421:24,
3238:15, 3238:25, 3239:14, 3239:17,
D
3422:4, 3422:8, 3422:11, 3422:17,
3239:20, 3240:14, 3243:21, 3244:20,
3422:19, 3422:23, 3423:5, 3423:11,
3245:12, 3245:22, 3247:15, 3247:17,
D.C [1] - 3234:10
3423:20, 3423:23, 3424:3
3247:20, 3248:10, 3248:14, 3248:16,
daily [3] - 3180:24, 3183:14, 3195:16
court [4] - 3331:15, 3333:10, 3414:2,
3248:19, 3248:25, 3249:3, 3249:6,
danger [1] - 3421:17
3419:2
3249:8, 3249:11, 3249:19, 3250:9,
Danny [3] - 3160:3, 3233:18, 3244:4
Court [14] - 3144:11, 3178:25,
3250:15, 3252:15, 3254:7, 3254:10,
data [5] - 3187:23, 3188:11, 3304:5,
3254:13, 3254:19, 3254:21, 3254:23,
3183:22, 3235:2, 3316:8, 3383:9,
3393:23, 3395:13
3256:11, 3256:16, 3256:20, 3256:22,
3410:24, 3411:6, 3412:9, 3414:5,
date [18] - 3188:24, 3189:5, 3191:8,
3257:8, 3257:10, 3257:12, 3257:15,
3415:1, 3416:12, 3416:15, 3420:11
3191:25, 3192:20, 3194:15, 3203:16,
3257:22, 3258:1, 3258:16, 3258:20,
Court's [2] - 3218:3, 3420:2
3237:6, 3250:4, 3250:5, 3250:14,
3258:24, 3260:11, 3260:21, 3260:24,
courtroom [4] - 3301:7, 3386:11,
3250:22, 3282:18, 3314:6, 3332:11,
3261:3, 3261:9, 3261:25, 3266:12,
3402:22, 3415:11
3332:14, 3364:20, 3364:23
3268:11, 3268:13, 3269:1, 3269:17,
cousin [2] - 3409:6, 3409:7
dated [3] - 3154:14, 3191:13, 3202:6
3270:3, 3270:7, 3270:16, 3270:18,
cover [10] - 3163:2, 3182:18, 3184:23,
dates [3] - 3191:3, 3191:7, 3208:22
3271:9, 3271:14, 3271:17, 3271:21,
3186:24, 3196:5, 3198:1, 3255:5,
DAVID [1] - 3143:10
3271:25, 3272:7, 3272:10, 3272:17,
3255:18, 3366:20, 3374:12
Davis [106] - 3146:10, 3155:5, 3156:9,
3272:20, 3272:22, 3272:24, 3273:2,
covered [2] - 3183:1, 3360:23
3167:20, 3168:8, 3176:10, 3177:17,
3273:5, 3273:10, 3273:16, 3273:21,
covering [1] - 3182:22
3179:21, 3184:4, 3185:22, 3187:13,
3274:1, 3274:6, 3274:10, 3274:13,
coward [3] - 3306:21, 3400:19,
3192:14, 3202:11, 3206:8, 3206:20,
3434
3208:11, 3209:4, 3211:9, 3213:14,
declare [1] - 3337:6
determined [1] - 3289:24
3213:19, 3222:7, 3223:23, 3234:13,
deeds [1] - 3222:2
developed [5] - 3219:4, 3219:5,
3236:5, 3236:18, 3247:25, 3252:17,
3219:24, 3223:8, 3414:14
defendant [3] - 3272:18, 3273:14,
3258:4, 3268:23, 3273:13, 3290:2,
development [2] - 3174:15, 3227:11
3362:15
3291:11, 3292:10, 3296:4, 3302:24,
DEFENDANT [2] - 3143:20, 3144:2
device [2] - 3393:12, 3393:14
3304:11, 3304:18, 3307:15, 3310:14,
defense [10] - 3154:21, 3295:23,
devices [1] - 3350:22
3311:14, 3311:16, 3312:9, 3313:7,
3413:24, 3414:12, 3415:17, 3416:24,
diagram [4] - 3208:14, 3216:17,
3314:6, 3316:12, 3317:6, 3319:17,
3417:7, 3417:19, 3419:17, 3423:20
3224:1, 3224:2
3320:21, 3324:15, 3325:2, 3327:9,
Defense [2] - 3362:6, 3368:9
dialogue [1] - 3302:21
3330:6, 3330:16, 3331:22, 3332:8,
definitely [1] - 3410:9
died [2] - 3146:13, 3146:17
3334:15, 3340:3, 3341:14, 3342:22,
definitions [1] - 3237:11
difference [4] - 3241:2, 3255:7,
3343:11, 3346:11, 3351:24, 3352:14,
degree [1] - 3261:19
3255:13, 3380:24
3353:12, 3360:19, 3361:7, 3362:5,
dehydration [1] - 3162:10
different [13] - 3165:8, 3166:18,
3362:20, 3362:24, 3363:1, 3364:1,
3212:20, 3239:18, 3251:9, 3259:6,
deliberations [1] - 3276:5
3365:13, 3365:23, 3367:13, 3368:7,
3259:24, 3263:24, 3279:20, 3330:25,
delineate [1] - 3239:9
3368:15, 3368:23, 3368:25, 3370:2,
3339:21, 3343:3, 3373:21
demanded [1] - 3379:17
3370:13, 3371:1, 3371:10, 3372:23,
difficult [3] - 3147:22, 3147:23,
demands [1] - 3197:4
3373:10, 3373:15, 3374:6, 3380:14,
3291:12
DeMaria [3] - 3170:2, 3170:6, 3170:11
3381:20, 3382:9, 3384:22, 3385:10,
dilemma [2] - 3203:23
demonstrate [1] - 3349:6
3385:24, 3391:5, 3393:3, 3398:6,
diligently [1] - 3415:9
demonstration [1] - 3208:19
3399:1, 3399:14, 3400:13, 3401:20,
diminished [1] - 3181:14
denied [2] - 3321:20, 3412:5
3403:20, 3407:3, 3409:20, 3410:20,
diminishing [1] - 3181:14
depart [1] - 3178:16
3421:25, 3422:2, 3422:3
direct [12] - 3154:16, 3174:5, 3328:14,
department [4] - 3169:16, 3175:15,
DAVIS [2] - 3145:3, 3146:7
3328:18, 3335:22, 3353:11, 3387:4,
3381:21, 3404:16
davis [1] - 3359:16
3393:11, 3395:16, 3401:2, 3401:9,
Department [2] - 3143:17, 3413:13
Davis's [1] - 3408:20
3422:6
depicted [1] - 3264:12
day-to-day [2] - 3159:6, 3159:8
DIRECT [2] - 3145:4, 3146:8
deposit [3] - 3148:8, 3149:4, 3278:1
days [14] - 3151:8, 3151:12, 3182:14,
directed [2] - 3241:24, 3383:5
deposited [1] - 3368:4
3191:18, 3191:21, 3193:20, 3374:3,
direction [6] - 3194:8, 3330:10,
depositor [3] - 3197:4, 3202:15,
3415:23, 3415:25, 3416:4, 3416:6,
3382:19, 3382:25, 3383:20, 3384:19
3290:1
3416:7, 3417:7, 3421:10
directly [5] - 3177:13, 3237:3, 3247:3,
depositors [22] - 3150:24, 3161:11,
DC [1] - 3143:18
3247:4, 3293:8
3161:14, 3164:20, 3170:17, 3171:4,
deadline [1] - 3415:19
director [3] - 3169:15, 3178:17,
3171:6, 3173:11, 3180:2, 3182:23,
deal [14] - 3215:10, 3232:20, 3258:22,
3386:24
3189:20, 3191:1, 3198:15, 3199:6,
3301:10, 3306:10, 3306:24, 3308:7,
directors [6] - 3202:18, 3375:3,
3226:5, 3253:6, 3259:25, 3263:17,
3310:1, 3310:10, 3320:24, 3321:8,
3375:6, 3378:15, 3379:16, 3380:3
3263:24, 3277:3, 3277:5, 3289:6
3321:14, 3337:13, 3423:2
disagree [2] - 3329:4, 3355:24
deposits [2] - 3202:23, 3242:21
dealer [5] - 3150:5, 3150:11, 3151:16,
disbelief [1] - 3169:7
Depression [1] - 3220:11
3153:4, 3154:3
disbursed [1] - 3186:22
describe [3] - 3209:15, 3235:18,
dealing [2] - 3174:14, 3311:11
disclose [2] - 3266:23, 3286:3
3283:4
debit [2] - 3208:1, 3367:25
disclosed [2] - 3268:17, 3273:4
described [3] - 3165:22, 3179:10,
deceive [2] - 3344:16, 3407:4
disclosure [8] - 3163:18, 3289:12,
3400:19
deceived [1] - 3406:2
3289:16, 3289:19, 3289:23, 3290:3,
describing [1] - 3221:24
December [12] - 3195:18, 3196:2,
3290:6, 3290:7
design [1] - 3341:25
3202:6, 3221:20, 3228:17, 3228:18,
discontinue [1] - 3179:1
designated [1] - 3210:7
3291:2, 3291:16, 3314:2, 3314:3,
discuss [10] - 3154:6, 3215:6,
designed [1] - 3391:21
3335:3, 3380:19
3231:11, 3235:10, 3284:7, 3288:4,
desire [4] - 3173:21, 3231:6, 3231:7,
decide [5] - 3312:14, 3318:4, 3330:22,
3302:6, 3385:19, 3418:2, 3421:4
3355:25
3417:16, 3417:22
discussed [13] - 3147:15, 3157:7,
desired [2] - 3207:5, 3207:19
decided [12] - 3163:25, 3208:7,
3175:6, 3188:17, 3203:14, 3206:24,
desirous [1] - 3151:15
3218:13, 3244:22, 3281:25, 3282:4,
3242:4, 3288:5, 3288:6, 3302:6,
desk [2] - 3389:4, 3390:8
3286:2, 3306:9, 3311:1, 3312:4,
3302:19, 3325:1, 3386:11
desktop [6] - 3387:11, 3391:4, 3392:7,
3318:16, 3386:7
discussing [13] - 3146:12, 3157:3,
3392:20,
3393:4,
3393:18
decides [1] - 3373:19
3197:15, 3197:18, 3228:8, 3228:10,
desktops
[1] - 3388:20
deciding [2] - 3158:13, 3164:11
3285:2, 3285:3, 3285:4, 3285:21,
destroy [1] - 3286:5
decision [21] - 3149:19, 3149:22,
3287:15, 3289:20, 3417:1
destroyed
[3] - 3285:13, 3395:17,
3159:23, 3160:21, 3175:20, 3202:18,
discussion [9] - 3147:18, 3152:3,
3396:4
3213:11, 3238:4, 3238:6, 3238:10,
3231:13,
3238:1, 3238:19, 3239:3,
destroying [1] - 3395:21
3238:11, 3268:15, 3273:10, 3281:11,
3242:7,
3277:12,
3298:13
detail [4] - 3234:14, 3235:18, 3235:20
3281:18, 3281:21, 3300:5, 3318:3,
displayed [2] - 3248:22, 3319:14
details
[3]
3232:24,
3356:24,
3413:6
3347:19, 3384:3
disregard [4] - 3183:22, 3316:9,
detecting [1] - 3279:23
decisions [4] - 3174:6, 3174:10,
3383:10,
3383:11
determine [2] - 3397:9, 3411:3
3174:11, 3273:7
3435
3170:18, 3170:25, 3171:3, 3171:8,
distributed [2] - 3248:19, 3248:21
Eagles [1] - 3165:15
3171:10, 3171:18, 3171:24, 3172:16,
distribution [1] - 3214:4
early [12] - 3146:20, 3147:3, 3151:8,
3173:13, 3173:17, 3174:13, 3181:19,
3151:12, 3151:25, 3169:20, 3177:11,
DISTRICT [3] - 3143:1, 3143:1,
3188:13, 3188:15, 3188:23, 3189:7,
3215:5, 3231:17, 3414:11, 3414:22,
3143:10
3189:12, 3189:18, 3189:22, 3189:25,
3418:22
divided [1] - 3218:6
3190:1, 3194:25, 3198:16, 3199:3,
earn [1] - 3167:14
DIVISION [1] - 3143:2
3202:1, 3208:13, 3212:24, 3213:7,
earned [1] - 3294:18
divorce [8] - 3212:9, 3212:11,
3217:8, 3227:22, 3227:24, 3251:7,
earning [1] - 3182:16
3212:14, 3213:11, 3214:3, 3214:5,
3262:4, 3262:5, 3262:23, 3263:11,
earnings [1] - 3202:12
3214:17, 3214:22
3268:3, 3290:13, 3292:3, 3294:1,
document [24] - 3154:22, 3155:20,
ears [1] - 3350:11
3307:4, 3307:8, 3308:25, 3309:20,
3155:22, 3203:2, 3206:18, 3207:4,
easel [1] - 3305:7
3317:20, 3357:1, 3362:4, 3366:6,
3208:12, 3223:12, 3247:25, 3315:10,
easier [5] - 3208:11, 3209:8, 3304:19,
3366:24, 3367:4, 3367:23, 3369:21,
3316:21, 3316:24, 3317:1, 3317:2,
3364:3, 3420:22
3370:22, 3380:25, 3383:19, 3387:2,
3317:6, 3324:6, 3345:20, 3346:7,
East [1] - 3233:4
3389:15, 3397:6, 3415:6, 3419:4,
3352:1, 3352:8, 3352:10, 3373:15,
easy [1] - 3365:19
3420:24, 3421:17
3373:16, 3374:6
eats [2] - 3292:24, 3337:1
downfall [1] - 3302:18
documentation [1] - 3349:18
economic [4] - 3198:3, 3198:18,
downstairs [1] - 3423:16
documents [38] - 3221:16, 3231:20,
3203:23, 3227:11
downtown [1] - 3341:17
3236:5, 3237:13, 3237:18, 3305:5,
economy [3] - 3220:9, 3316:3, 3330:8
downturn [2] - 3198:19, 3220:11
3316:15, 3318:21, 3325:23, 3326:24,
effect [9] - 3208:20, 3272:12, 3275:6,
drafted [1] - 3396:13
3326:25, 3327:14, 3335:8, 3335:10,
3284:8, 3298:16, 3347:14, 3349:19,
drafts [1] - 3285:24
3335:13, 3335:17, 3336:11, 3336:22,
3382:14, 3420:21
drain [2] - 3188:16, 3195:15
3340:2, 3340:4, 3341:8, 3346:5,
effective [1] - 3171:1
draw [12] - 3194:24, 3201:23, 3291:15,
3349:5, 3349:10, 3349:14, 3352:13,
effectively [1] - 3176:18
3292:22, 3312:13, 3315:6, 3334:19,
3366:4, 3372:15, 3372:20, 3372:21,
effort [6] - 3254:16, 3328:19, 3340:6,
3334:20, 3334:21, 3334:24, 3336:11,
3384:22, 3385:24, 3386:6, 3386:8,
3352:12, 3385:17, 3396:11
3353:19
3386:10, 3386:12, 3395:9
efforts [4] - 3169:18, 3243:3, 3396:9,
drawn [5] - 3305:6, 3315:7, 3315:9,
doings [1] - 3352:24
3396:11
3316:16, 3318:21
dollar [6] - 3160:12, 3223:20, 3255:11,
eight [2] - 3403:9, 3403:10
draws [1] - 3208:25
3347:12, 3360:3, 3367:5
either [11] - 3170:6, 3180:21, 3234:18,
drew [8] - 3224:1, 3224:2, 3232:9,
dollar-wise [1] - 3223:20
3242:1, 3270:22, 3274:16, 3310:20,
3248:16, 3312:2, 3353:12, 3353:20,
dollars [42] - 3151:9, 3182:4, 3184:6,
3323:14, 3396:18, 3417:22, 3421:16
3353:21
3191:8, 3201:20, 3203:3, 3203:8,
elder [4] - 3402:4, 3402:6, 3402:12,
drive [11] - 3285:10, 3318:5, 3387:5,
3204:2, 3206:11, 3221:22, 3224:13,
3402:14
3393:15, 3393:25, 3394:25, 3395:6,
3226:6, 3246:7, 3295:16, 3314:15,
elderly [1] - 3377:24
3395:11, 3396:20, 3399:14
3316:1, 3316:5, 3318:17, 3322:3,
electrified [1] - 3351:15
drives [4] - 3285:10, 3285:15, 3286:5,
3322:9, 3322:20, 3323:3, 3323:8,
elevate [1] - 3148:17
3324:20, 3326:4, 3326:23, 3330:17,
3286:14
elicit [1] - 3272:4
3330:19, 3339:2, 3341:5, 3348:23,
dropping [1] - 3255:4
elicited [1] - 3239:18
3349:8, 3355:1, 3359:24, 3361:25,
drove [2] - 3284:21, 3284:22
eliminate [2] - 3163:5, 3223:21
3362:1, 3365:7, 3365:23, 3366:11,
due [1] - 3326:8
eliminating [1] - 3225:4
3370:17, 3380:20
dumb [3] - 3411:17, 3412:7, 3412:10
elongated [1] - 3421:4
domestically [3] - 3278:2, 3278:3,
dummy [1] - 3386:7
elsewhere [1] - 3149:1
3280:10
dummy-up [1] - 3386:7
elusive [1] - 3338:24
Dominion [1] - 3186:3
during [14] - 3233:25, 3234:13,
emergency [1] - 3162:6
Don [1] - 3377:13
3238:16, 3267:3, 3268:15, 3274:23,
emeritus [2] - 3376:1, 3376:8
donated [1] - 3313:13
3276:9, 3281:18, 3283:13, 3294:19,
emotional [1] - 3197:13
donation [3] - 3294:25, 3295:2,
3310:21, 3382:2, 3382:6, 3410:18
emperor [1] - 3197:21
3312:23
empire [1] - 3401:3
donations [1] - 3294:21
E
employ [1] - 3148:13
done [29] - 3175:25, 3176:13, 3203:10,
employee [3] - 3194:8, 3269:10,
3207:23, 3208:24, 3214:6, 3217:23,
3270:4
e-mail
[32] - 3173:25, 3177:14,
3218:19, 3220:3, 3222:3, 3223:5,
employees [13] - 3167:12, 3167:24,
3184:10, 3185:3, 3185:6, 3185:17,
3226:18, 3249:11, 3267:7, 3274:24,
3168:6, 3172:16, 3173:7, 3173:12,
3186:17,
3187:13,
3187:24,
3187:25,
3276:17, 3277:23, 3279:13, 3304:13,
3173:16, 3189:14, 3354:20, 3355:14,
3190:9, 3190:14, 3191:2, 3191:4,
3311:24, 3338:18, 3347:5, 3370:8,
3355:19, 3356:2, 3391:22
3191:12, 3191:15, 3192:22, 3193:17,
3396:6, 3414:3, 3415:12, 3417:8,
enable [1] - 3149:19
3193:22,
3193:25,
3194:1,
3194:10,
3418:7, 3422:2
enabling [1] - 3239:7
3194:18,
3195:9,
3195:18,
3196:23,
door [1] - 3338:13
encountering [1] - 3165:23
3226:8,
3226:25,
3293:5,
3338:23,
doors [2] - 3165:4, 3165:6
end [28] - 3146:20, 3147:2, 3147:14,
3396:18
doubt [2] - 3176:22, 3411:19
3150:14, 3163:4, 3167:4, 3169:10,
e-mails [5] - 3197:1, 3329:6, 3394:24,
down [70] - 3146:4, 3146:25, 3157:6,
3177:25, 3178:19, 3179:22, 3179:24,
3395:7, 3395:8
3157:14, 3157:16, 3157:21, 3161:3,
3436
3181:8, 3181:13, 3181:16, 3183:18,
evening [2] - 3162:7, 3283:23
Exhibits [1] - 3236:3
3211:4, 3263:7, 3265:20, 3301:18,
event [5] - 3162:25, 3310:17, 3310:21,
exist [2] - 3340:4, 3366:5
3314:15, 3316:18, 3324:7, 3358:16,
3311:14, 3423:2
existed [1] - 3258:21
3371:24, 3372:2, 3374:15, 3374:16,
events [4] - 3163:20, 3164:22,
existence [3] - 3171:21, 3259:19,
3415:21
3166:18, 3166:21
3385:3
ended [5] - 3146:12, 3179:25, 3335:1,
eventually [7] - 3249:8, 3249:10,
exists [3] - 3155:8, 3345:22, 3349:21
3380:19, 3406:10
3268:9, 3276:3, 3282:11, 3282:19,
expand [1] - 3157:1
engaged [1] - 3230:24
3288:8
expansion [1] - 3174:13
enlarge [5] - 3185:4, 3185:17,
Evidence [1] - 3303:22
expectations [1] - 3202:13
3191:11, 3206:17, 3223:13
evidence [15] - 3155:16, 3168:19,
expected [1] - 3217:1
enlarged [2] - 3207:4, 3222:14
3192:10, 3192:25, 3204:25, 3205:4,
expecting [2] - 3191:10, 3256:17
entered [2] - 3326:17, 3391:18
3271:10, 3285:7, 3329:6, 3373:20,
expense [2] - 3175:22, 3175:24
entertainment [3] - 3211:7, 3251:10,
3395:18, 3395:21, 3396:4, 3399:17,
expenses [6] - 3175:6, 3225:20,
3253:1
3400:17
3360:19, 3360:21, 3380:22, 3380:24
entire [6] - 3167:21, 3185:18, 3239:4,
evidenced [1] - 3222:3
experience [3] - 3160:8, 3160:15,
3269:24, 3271:6, 3407:11
ex [3] - 3410:8, 3410:10, 3415:1
3305:25
entities [2] - 3161:12, 3364:8
exact [3] - 3228:7, 3261:10, 3359:15
expert [6] - 3218:19, 3413:9, 3417:12,
entitled [3] - 3286:12, 3416:25, 3424:7
exactly [9] - 3214:10, 3272:19,
3417:14, 3417:17, 3417:19
entity [1] - 3364:7
3272:25, 3298:6, 3312:15, 3335:9,
experts [4] - 3413:3, 3413:7, 3413:8,
3338:22, 3342:12, 3418:19
entries [5] - 3209:18, 3221:24,
3413:15
3224:17, 3224:22, 3225:18
exam [1] - 3157:18
explain [20] - 3147:23, 3150:3,
entry [13] - 3200:7, 3200:10, 3200:13,
examination [12] - 3328:14, 3328:18,
3152:13, 3157:5, 3161:8, 3176:13,
3200:17, 3204:15, 3205:9, 3205:11,
3335:23, 3353:11, 3387:4, 3393:11,
3183:1, 3191:6, 3199:11, 3209:4,
3206:8, 3206:13, 3206:25, 3207:25,
3401:2, 3401:10, 3410:19, 3414:24,
3212:1, 3223:15, 3234:14, 3248:5,
3208:6, 3208:8
3415:17, 3420:1
3254:3, 3275:13, 3346:24, 3353:25,
epiphany [2] - 3310:23
EXAMINATION [4] - 3145:4, 3145:5,
3356:8, 3366:13
3146:8, 3296:2
equal [3] - 3186:18, 3224:25, 3290:22
explained [5] - 3212:13, 3214:21,
example [5] - 3176:20, 3259:13,
equity [21] - 3184:19, 3184:22,
3259:4, 3262:25, 3276:9
3266:21, 3322:19, 3402:13
3198:13, 3199:10, 3199:12, 3199:13,
explaining [1] - 3303:22
3202:21, 3203:1, 3203:7, 3204:1,
exceed [1] - 3202:24
explains [2] - 3208:25, 3209:2
3204:12, 3208:2, 3248:7, 3249:25,
excellent [1] - 3202:1
explanation [1] - 3328:22
3251:11, 3252:18, 3252:22, 3252:25,
except [2] - 3156:1, 3278:19
exposed [2] - 3178:21, 3179:10
3253:10, 3259:16, 3261:17
exception [2] - 3270:15, 3271:8
express [7] - 3157:20, 3169:7,
equivalent [1] - 3378:9
Exception [1] - 3273:15
3173:21, 3197:7, 3240:2, 3240:5,
erase [1] - 3334:2
excess [7] - 3188:20, 3358:20,
3260:15
es [1] - 3325:24
3358:21, 3359:10, 3359:11, 3359:14,
expressed [1] - 3380:20
especially [1] - 3181:20
3359:16
expression [2] - 3197:21, 3247:9
essence [4] - 3260:21, 3260:23,
Exchange [3] - 3236:16, 3237:6,
extent [3] - 3151:10, 3292:20, 3355:23
3260:24, 3261:9
3327:10
extra [2] - 3205:21, 3351:17
essentially [1] - 3262:18
excited [1] - 3163:17
extravaganza [1] - 3164:16
establish [3] - 3180:21, 3268:24,
excitement [1] - 3164:17
extreme [1] - 3197:13
3397:7
excluded [1] - 3155:24
extremely [1] - 3181:14
established [3] - 3152:18, 3229:22,
excuse [18] - 3146:22, 3157:8, 3158:3,
eyesight [1] - 3380:11
3230:10
3167:20, 3185:14, 3204:6, 3204:23,
estate [55] - 3174:14, 3184:19,
3211:10, 3236:20, 3260:8, 3279:16,
F
3184:22, 3208:10, 3209:17, 3209:21,
3282:3, 3284:13, 3308:16, 3322:5,
3210:3, 3210:4, 3210:7, 3211:20,
3326:10, 3412:8, 3419:22
face [1] - 3203:22
3212:3, 3212:15, 3213:10, 3215:21,
excused [1] - 3423:24
facilitate [1] - 3354:6
3216:11, 3217:3, 3217:20, 3218:10,
executive [1] - 3160:10
facilities [1] - 3170:19
3218:13, 3218:14, 3220:13, 3223:1,
executives [6] - 3233:7, 3256:5,
facing [1] - 3411:24
3223:20, 3224:2, 3225:6, 3225:11,
3258:6, 3259:23, 3266:6, 3283:7
fact [39] - 3148:3, 3151:18, 3154:13,
3225:24, 3251:23, 3252:3, 3252:6,
exempt [1] - 3214:4
3163:7,
3171:2, 3176:10, 3184:5,
3252:9, 3253:19, 3259:14, 3261:15,
Exhibit [18] - 3154:13, 3180:7, 3185:3,
3188:18, 3193:17, 3203:5, 3226:3,
3292:25, 3340:13, 3340:14, 3340:15,
3195:17, 3202:5, 3206:15, 3221:20,
3230:2, 3264:6, 3265:7, 3265:11,
3340:22, 3340:24, 3340:25, 3341:1,
3222:9, 3222:12, 3247:22, 3285:23,
3272:5, 3280:11, 3286:4, 3289:9,
3341:2, 3341:3, 3341:9, 3341:17,
3289:9, 3291:7, 3312:25, 3319:15,
3296:7, 3318:20, 3320:24, 3321:14,
3341:19, 3343:1, 3343:4, 3358:12,
3362:7, 3368:9, 3373:13
3335:13, 3335:18, 3341:8, 3353:12,
3361:11, 3361:13, 3361:18, 3361:20
exhibit [12] - 3155:14, 3196:22,
3356:7, 3361:16, 3366:23, 3369:15,
estates [1] - 3340:18
3222:10, 3319:5, 3332:19, 3333:24,
3371:9, 3371:23, 3402:1, 3403:23,
estimate [1] - 3421:10
3334:7, 3334:12, 3367:15, 3373:15,
3404:6, 3412:15, 3414:3, 3415:10
et [5] - 3189:16, 3253:1, 3285:24,
3374:6, 3380:8
facts [5] - 3168:19, 3204:24, 3205:4,
3351:4, 3354:10
exhibits [4] - 3414:13, 3415:17,
3230:3, 3275:22
Europe [1] - 3242:14
3415:22,
3416:14
3437
failed [2] - 3148:1, 3171:2
finally [4] - 3188:23, 3254:8, 3254:14,
fishbowl [2] - 3173:3, 3173:7
3262:18
Failing [1] - 3212:18
fishing [1] - 3388:18
finance [2] - 3356:10, 3356:11
fair [2] - 3237:15, 3398:5
five [14] - 3147:7, 3149:18, 3180:13,
financed [1] - 3270:11
3205:21, 3268:20, 3278:16, 3329:16,
Fair [1] - 3214:20
3361:2, 3367:5, 3418:6, 3419:6,
finances [2] - 3358:6, 3358:8
fairly [2] - 3148:20, 3167:15
3421:11
financial [52] - 3150:6, 3150:12,
fake [1] - 3354:1
flagged [1] - 3152:7
3158:5, 3158:6, 3158:11, 3158:17,
fall [7] - 3161:2, 3161:5, 3161:7,
flash [5] - 3285:9, 3393:14, 3394:25,
3158:23, 3159:7, 3159:15, 3163:21,
3165:23, 3177:11, 3198:5, 3216:15
3163:25, 3164:6, 3164:10, 3165:9,
3395:6, 3395:11
false [1] - 3290:8
3167:5, 3168:14, 3168:17, 3169:6,
fleet [1] - 3174:21
falsely [1] - 3232:16
3170:5, 3184:11, 3186:11, 3192:15,
flew [2] - 3162:15, 3284:21
familiar [9] - 3149:25, 3200:18,
3226:5, 3235:22, 3237:16, 3241:1,
flights [1] - 3423:3
3206:20, 3218:22, 3310:23, 3333:19,
3241:21, 3241:24, 3242:14, 3253:1,
flip [6] - 3209:12, 3209:13, 3209:15,
3347:8, 3388:6, 3404:24
3260:1, 3264:15, 3275:1, 3275:15,
3215:20, 3252:7, 3252:11
family [1] - 3344:14
3276:8, 3276:13, 3276:17, 3276:19,
FLIP [1] - 3209:12
family's [1] - 3391:9
3276:24, 3276:25, 3277:6, 3277:7,
flips [1] - 3329:2
far [6] - 3165:17, 3211:12, 3232:11,
3277:25, 3279:17, 3288:24, 3289:6,
Floor [2] - 3143:22, 3144:4
3300:19, 3327:20, 3409:10
3304:5, 3322:7, 3356:9, 3358:5,
floor [4] - 3263:11, 3388:22, 3388:23,
farm [2] - 3294:16, 3320:12
3374:17, 3386:24
3389:1
farmers [1] - 3368:17
Financial [16] - 3178:16, 3179:9,
Florida [2] - 3175:23, 3243:10
Farmers [2] - 3362:23, 3370:11
3238:8,
3251:17, 3269:20, 3270:22,
flow [2] - 3195:15, 3364:1
fast [1] - 3415:19
3270:23, 3270:25, 3271:2, 3279:16,
flowed [1] - 3364:7
father [3] - 3214:2, 3375:20, 3376:12
3290:15, 3355:7, 3356:19, 3358:7,
flowing [1] - 3204:20
fault [1] - 3263:15
3381:21, 3398:3
fly [3] - 3171:18, 3211:17, 3247:7
Fazel [3] - 3143:20, 3143:21, 3413:12
financials [5] - 3264:21, 3264:22,
flying [1] - 3288:6
FAZEL [19] - 3192:24, 3298:9,
3264:23, 3265:3
Flynn [1] - 3307:9
3410:15, 3410:17, 3411:5, 3412:4,
findings [2] - 3412:12, 3412:15
3412:6, 3413:1, 3413:24, 3414:18,
focus [6] - 3161:1, 3163:5, 3187:10,
fine [7] - 3193:7, 3275:22, 3331:2,
3414:21, 3415:8, 3416:1, 3417:25,
3231:6, 3376:13
3407:21, 3418:5, 3421:7, 3423:15
3418:10, 3418:13, 3422:10, 3422:18,
focused [5] - 3147:9, 3147:10, 3159:9,
finish [3] - 3243:15, 3350:1, 3350:2
3423:22
3159:14, 3159:17
fired [4] - 3169:12, 3169:23, 3169:25,
FBI [10] - 3304:11, 3307:5, 3307:8,
focussed [1] - 3155:6
3170:12
3307:16, 3309:15, 3385:23, 3396:8,
focussing [3] - 3185:3, 3229:12,
firm [44] - 3147:12, 3147:16, 3147:20,
3396:9, 3397:6, 3397:8
3231:3
3148:4, 3148:6, 3148:15, 3148:21,
February [20] - 3143:5, 3171:25,
folded [1] - 3290:21
3148:23, 3148:25, 3149:6, 3149:8,
3172:2, 3182:11, 3240:11, 3240:23,
folks [4] - 3254:14, 3256:17, 3278:19,
3149:10, 3149:14, 3149:20, 3150:4,
3241:9, 3241:14, 3243:7, 3250:3,
3351:16
3150:15, 3150:18, 3150:24, 3151:1,
3250:21, 3255:20, 3258:7, 3282:13,
follow [6] - 3243:13, 3339:4, 3379:2,
3151:4, 3151:19, 3152:1, 3152:15,
3287:13, 3288:19, 3394:9, 3394:17
3383:13, 3383:14, 3384:7
3152:24, 3153:11, 3156:11, 3156:20,
fed [1] - 3174:8
follow-up [3] - 3243:13, 3339:4,
3157:6, 3157:14, 3157:21, 3158:5,
feelings [1] - 3177:14
3383:13
3159:15, 3159:24, 3160:9, 3160:16,
fees [2] - 3211:6, 3211:7
following [16] - 3146:1, 3206:3,
3160:18, 3160:24, 3234:2, 3234:7,
feet [4] - 3162:14, 3351:21, 3389:21,
3250:16, 3254:19, 3256:23, 3257:21,
3261:24, 3268:1, 3270:17, 3417:15,
3390:6
3267:11, 3287:4, 3288:18, 3297:17,
3417:20
fell [1] - 3256:14
3300:24, 3331:9, 3331:15, 3331:18,
Firm [1] - 3144:6
felt [1] - 3260:9
3375:25, 3410:4
firms [1] - 3165:9
few [4] - 3172:10, 3172:11, 3245:5,
footnote [1] - 3290:9
first [57] - 3151:4, 3151:5, 3153:21,
3302:10
footnotes [1] - 3276:21
3173:24, 3181:13, 3181:16, 3181:17,
fiancee [1] - 3246:25
FOR [3] - 3143:13, 3143:20, 3144:2
3191:17, 3194:19, 3199:11, 3209:25,
fictitious [2] - 3224:15, 3241:1
forces [1] - 3163:17
3210:2, 3224:22, 3228:18, 3240:11,
field [1] - 3176:3
foregoing [1] - 3424:5
3240:22, 3241:8, 3241:14, 3243:7,
fiend [1] - 3297:22
foreign [2] - 3154:4, 3241:21
3243:20, 3244:11, 3244:13, 3250:3,
figure [1] - 3359:8
forensic [5] - 3279:14, 3279:19,
3257:15, 3258:7, 3266:6, 3277:18,
figures [3] - 3188:5, 3222:4, 3381:25
3280:3, 3280:18
3282:12, 3286:25, 3290:3, 3290:16,
file [7] - 3337:9, 3337:11, 3337:14,
forfeit [4] - 3322:3, 3323:2, 3323:7,
3292:1, 3293:1, 3306:13, 3307:5,
3337:15, 3337:18, 3374:1, 3393:10
3328:1
3307:16, 3308:6, 3309:17, 3329:5,
filed [4] - 3338:8, 3375:2, 3418:13,
forfeited [1] - 3301:14
3333:22, 3342:19, 3343:10, 3374:2,
3418:14
forfeiture [3] - 3322:13, 3323:17,
3382:10, 3394:8, 3400:20, 3402:17,
files [1] - 3393:9
3324:7
3402:18, 3403:21, 3407:6, 3410:15,
filing [1] - 3338:13
Forfeiture [1] - 3324:9
3411:3, 3416:3, 3417:3, 3417:6, 3419:7
fill [1] - 3227:4
forfeitures [1] - 3324:2
firstly [1] - 3240:13
final [1] - 3182:14
forgo [1] - 3421:6
fiscal [1] - 3374:15
finalize [1] - 3232:24
forgot [2] - 3360:7, 3422:12
fiscally [1] - 3202:14
3438
form [8] - 3146:22, 3155:21, 3224:17,
3256:9, 3258:12, 3311:12, 3322:14,
3407:15
formally [1] - 3204:12
format [2] - 3164:14, 3164:16
former [1] - 3256:19
forms [1] - 3175:24
Fort [6] - 3231:7, 3243:16, 3243:18,
3282:17, 3284:16, 3284:17
forth [4] - 3195:14, 3359:21, 3381:7
forward [4] - 3181:13, 3281:11,
3281:22, 3286:17
foundation [2] - 3155:14, 3268:25
founded [1] - 3300:19
four [9] - 3149:17, 3216:25, 3220:4,
3377:5, 3392:8, 3392:18, 3411:10,
3411:11
fourth [3] - 3181:14, 3199:24, 3247:17
fraud [21] - 3174:3, 3178:8, 3178:21,
3178:22, 3275:17, 3275:25, 3276:2,
3279:23, 3283:8, 3310:5, 3310:6,
3325:4, 3329:21, 3345:25, 3354:6,
3376:2, 3378:18, 3378:22, 3379:11,
3379:12, 3379:20
fraudster [11] - 3306:19, 3306:20,
3308:8, 3308:23, 3308:24, 3309:6,
3309:20, 3310:3, 3310:16, 3311:1,
3311:16
free [2] - 3232:11, 3304:25
frequently [3] - 3158:20, 3159:11,
3184:12
Friday [14] - 3146:12, 3166:18,
3191:20, 3265:22, 3265:23, 3267:13,
3267:14, 3268:12, 3281:18, 3282:12,
3283:23, 3284:18, 3288:7
front [15] - 3235:11, 3285:10, 3301:5,
3305:5, 3313:9, 3323:12, 3323:13,
3330:16, 3386:3, 3388:9, 3388:10,
3388:11, 3410:20, 3410:23, 3411:19
fruit [2] - 3294:16, 3320:12
frustrating [2] - 3175:19, 3384:4
full [2] - 3155:7, 3202:7
fully [3] - 3235:18, 3289:16, 3290:6
function [1] - 3175:25
fund [4] - 3176:21, 3188:6, 3358:11,
3361:23
fundamental [1] - 3359:2
funding [4] - 3188:1, 3188:3, 3189:9,
3355:9
funds [18] - 3150:9, 3161:16, 3187:19,
3191:18, 3191:22, 3192:3, 3194:23,
3196:14, 3199:14, 3285:3, 3301:12,
3325:13, 3337:23, 3337:25, 3354:3,
3370:10, 3411:14, 3412:20
funnel [1] - 3368:6
future [6] - 3177:10, 3225:17, 3225:20,
3232:10, 3232:21
FYI [1] - 3195:9
G
gallery [1] - 3341:24
gather [1] - 3274:17

Government's [23] - 3154:13, 3180:6,
3185:3, 3195:17, 3202:5, 3206:15,
gathered [1] - 3188:25
3221:19, 3222:8, 3222:12, 3236:3,
gears [1] - 3409:20
3236:6, 3247:22, 3285:23, 3289:9,
general [15] - 3155:21, 3212:7,
3291:7, 3312:24, 3313:4, 3319:15,
3212:17, 3227:20, 3229:3, 3229:16,
3323:15, 3328:4, 3328:7, 3372:11,
3229:23, 3230:8, 3233:15, 3237:14,
3373:13
3244:2, 3256:12, 3256:13, 3262:12,
grand [2] - 3190:17, 3320:20
3281:24
granted [3] - 3244:20, 3354:9, 3366:14
generally [12] - 3208:23, 3261:10,
grave [1] - 3162:1
3280:23, 3321:21, 3321:22, 3356:10,
gray [1] - 3419:9
3357:11, 3361:14, 3361:15, 3361:20,
3397:1, 3408:25
great [4] - 3161:25, 3170:7, 3215:10,
generate [1] - 3345:20
3235:8
generated [6] - 3346:7, 3347:10,
Great [1] - 3220:11
3380:23, 3382:1, 3395:9, 3397:3
Green [1] - 3193:1
generation [1] - 3333:22
Gregg [1] - 3143:13
generic [1] - 3256:10
gross [1] - 3421:9
gentlemen [4] - 3257:17, 3274:13,
ground [1] - 3389:21
3331:3, 3409:25
grounds [2] - 3211:7, 3407:10
gift [2] - 3214:2, 3214:3
group [8] - 3176:19, 3192:15, 3233:17,
gifts [1] - 3295:4
3245:20, 3253:2, 3253:16, 3269:7,
Gill [1] - 3381:22
3271:6
gill [1] - 3381:25
Group [17] - 3147:12, 3150:4, 3150:5,
3178:16, 3179:9, 3238:8, 3244:5,
girlfriend [2] - 3405:16, 3408:7
3251:17, 3269:20, 3270:22, 3270:23,
girlfriends [1] - 3410:21
3270:25, 3271:2, 3290:16, 3356:19,
given [15] - 3158:6, 3163:21, 3163:24,
3358:7, 3381:21
3167:15, 3256:13, 3274:3, 3283:6,
grow [1] - 3202:25
3325:22, 3349:7, 3399:25, 3414:2,
growing [1] - 3184:5
3414:14, 3414:23, 3415:16, 3422:1
growth [3] - 3159:12, 3159:25,
glad [1] - 3421:6
3202:16
glass [2] - 3173:2, 3173:13
Guardian [1] - 3363:14
global [10] - 3176:1, 3226:13, 3233:19,
guess [10] - 3227:23, 3291:24,
3244:1, 3267:17, 3267:24, 3269:7,
3313:14, 3319:8, 3333:11, 3333:17,
3358:1, 3358:3
3346:14, 3364:9, 3407:3, 3418:21
Global [4] - 3178:18, 3269:20,
guilty [3] - 3295:13, 3300:2, 3309:22
3270:22, 3358:9
guts [2] - 3389:11, 3389:12
globe [1] - 3181:5
guy [7] - 3338:23, 3358:4, 3365:6,
goal [1] - 3416:14
3366:11, 3382:22, 3383:18, 3417:23
goals [1] - 3165:16
guys [3] - 3377:22, 3400:7, 3420:9
goodness [1] - 3400:2
Goswick [6] - 3375:14, 3376:23,
3376:24, 3377:6, 3377:21, 3377:22
H
GOVERNMENT [1] - 3143:13
Government [1] - 3330:24
half [20] - 3251:22, 3293:3, 3302:8,
government [59] - 3178:23, 3242:9,
3345:9, 3346:3, 3346:6, 3346:7,
3242:12, 3286:3, 3286:17, 3301:10,
3359:24, 3361:25, 3362:1, 3365:6,
3301:25, 3302:9, 3303:8, 3303:13,
3365:22, 3366:11, 3416:9, 3420:23,
3305:23, 3306:11, 3306:13, 3307:16,
3421:12, 3423:15
3308:15, 3308:20, 3309:14, 3309:25,
half-hour [2] - 3420:23, 3423:15
3310:10, 3310:22, 3311:11, 3312:1,
halls [1] - 3165:4
3314:4, 3315:25, 3316:12, 3316:15,
hallway [1] - 3173:2
3316:20, 3320:25, 3321:9, 3321:14,
halt [2] - 3267:18, 3267:19
3321:23, 3322:12, 3324:12, 3324:18,
hand [11] - 3185:24, 3186:2, 3197:3,
3325:12, 3325:13, 3326:5, 3326:17,
3202:9,
3207:3, 3222:13, 3251:8,
3328:1, 3335:11, 3336:21, 3337:13,
3259:20,
3283:2, 3283:3, 3383:18
3337:24, 3338:12, 3373:17, 3373:24,
handed [1] - 3324:6
3383:14, 3385:14, 3386:2, 3395:17,
handle [2] - 3280:23, 3423:5
3396:6, 3400:1, 3410:18, 3413:2,
handled [1] - 3169:17
3413:24, 3418:13, 3419:9, 3419:19,
hands [4] - 3224:13, 3268:8, 3316:25,
3423:18
3352:9
government's [7] - 3297:1, 3315:14,
hang [4] - 3176:5, 3234:16, 3271:9,
3335:4, 3384:2, 3384:6, 3417:15,
3409:24
3418:1
3439
3298:20, 3298:23, 3305:2, 3307:1,
hangar [8] - 3233:13, 3239:24,
highly [1] - 3167:10
3311:3, 3315:19, 3316:6, 3324:4,
3240:11, 3240:21, 3240:22, 3241:10,
himself [3] - 3204:13, 3213:11,
3325:24, 3331:20, 3351:19, 3361:4,
3241:13, 3243:14
3275:21
3362:13, 3368:11, 3368:12, 3373:25,
haphazard [1] - 3420:1
hire [7] - 3160:21, 3175:20, 3301:15,
3384:10, 3389:7, 3406:18, 3407:7,
happy [1] - 3323:16
3301:17, 3301:19, 3301:23, 3302:13
3408:8, 3409:21, 3412:6, 3413:1,
hard [7] - 3291:11, 3310:6, 3334:15,
hired [9] - 3148:11, 3177:2, 3177:7,
3413:19, 3414:9, 3417:11, 3417:25,
3338:24, 3342:22, 3380:9, 3415:19
3273:24, 3278:10, 3301:12, 3301:17,
3418:1, 3419:25, 3421:18, 3422:18,
3403:12, 3403:13
Harry [1] - 3212:18
3423:19
hires [2] - 3148:11, 3413:14
haslett [1] - 3169:12
HONORABLE [1] - 3143:10
history [1] - 3147:5
hate [1] - 3420:9
honored [1] - 3182:24
hit [1] - 3207:23
Hazlett [6] - 3168:13, 3168:14,
hook [2] - 3254:17
HITTNER [1] - 3143:10
3168:16, 3169:1, 3169:6, 3169:11
hope [1] - 3397:13
head [5] - 3160:9, 3160:15, 3160:23,
hold [12] - 3167:25, 3201:7, 3214:22,
hopefully [2] - 3380:24, 3422:1
3247:6, 3300:11
3220:18, 3252:15, 3304:16, 3311:6,
hoping [2] - 3306:24
3331:23, 3350:1, 3351:1, 3399:5
heading [2] - 3316:3, 3330:9
hospital [1] - 3162:6
holders [10] - 3149:4, 3183:7, 3190:24,
headquartered [1] - 3244:5
hot [4] - 3366:8, 3366:12, 3367:5,
3281:4, 3325:6, 3325:15, 3342:9,
headquarters [6] - 3172:4, 3172:5,
3371:18
3348:8, 3372:2
3172:8, 3172:9, 3226:13, 3226:15
Hotel [1] - 3287:25
holding [2] - 3353:23, 3353:24
heads [1] - 3159:24
hotel [3] - 3266:2, 3266:3, 3267:2
holdings [3] - 3235:19, 3241:1,
health [2] - 3147:25, 3162:2
hour [6] - 3420:23, 3421:7, 3422:6,
3261:15
healthcare [1] - 3251:10
3422:13, 3422:14, 3423:15
Holdings [4] - 3251:16, 3362:25,
hear [11] - 3167:25, 3193:6, 3193:9,
hours [10] - 3296:25, 3297:2, 3303:24,
3364:1, 3368:23
3350:12, 3373:4, 3397:11, 3397:14,
3304:2, 3304:6, 3305:8, 3305:17,
holds [2] - 3148:8, 3354:2
3411:1, 3411:20, 3412:23, 3420:21
3421:12, 3422:17, 3422:20
hole [6] - 3180:4, 3180:13, 3181:9,
heard [6] - 3193:6, 3193:12, 3193:21,
house [12] - 3235:21, 3285:11, 3321:1,
3184:5, 3254:18, 3255:20
3212:24, 3220:20, 3408:13
3321:4, 3321:6, 3321:7, 3388:9,
Hollywood [1] - 3164:16
hearing [6] - 3350:12, 3350:22,
3388:10, 3388:11, 3390:9, 3390:10,
Holt [31] - 3169:2, 3169:7, 3233:19,
3350:24, 3351:16, 3373:6, 3418:2
3404:20
3237:24, 3238:7, 3238:19, 3245:3,
HEARING [1] - 3331:12
housekeeping [1] - 3414:8
3281:15, 3282:2, 3282:5, 3282:11,
hearings [1] - 3420:13
housing [1] - 3219:8
3282:16,
3283:12,
3284:2,
3284:14,
hearsay [18] - 3153:14, 3153:15,
HOUSTON [1] - 3143:2
3284:16, 3343:24, 3344:1, 3344:6,
3155:15, 3167:22, 3168:4, 3183:15,
3344:15, 3360:24, 3360:25, 3399:18,
Houston [18] - 3143:4, 3143:15,
3212:19, 3228:5, 3229:1, 3229:6,
3400:2, 3401:4, 3401:5, 3402:24,
3143:23, 3144:4, 3144:7, 3144:12,
3229:13, 3229:20, 3234:17, 3260:20,
3406:24, 3407:25, 3408:3, 3408:6
3170:14, 3170:15, 3176:2, 3186:16,
3268:21, 3269:16, 3270:15, 3272:8
3226:16, 3226:24, 3227:2, 3244:5,
Holt's [1] - 3409:6
heart [2] - 3162:4, 3162:8
3333:7, 3336:14, 3336:16, 3346:20
home [14] - 3203:17, 3284:23, 3285:6,
heated [1] - 3227:17
Howard [1] - 3143:16
3285:8, 3287:21, 3294:8, 3320:16,
Heather [2] - 3408:17, 3409:3
3320:20, 3344:13, 3349:23, 3388:6,
HR [1] - 3178:17
HELD [1] - 3331:12
3388:8, 3406:3
HSBC [1] - 3186:13
held [19] - 3146:1, 3194:13, 3206:3,
honestly
[1]
3179:12
huge [1] - 3149:23
3233:9, 3233:10, 3235:22, 3239:10,
honor [6] - 3183:6, 3196:14, 3246:7,
hugging [1] - 3265:18
3241:20, 3241:21, 3248:20, 3248:21,
3285:3, 3287:16, 3324:19
human [2] - 3177:13, 3178:11
3257:21, 3297:17, 3300:24, 3331:9,
Honor [111] - 3146:6, 3152:17,
hundred [5] - 3164:5, 3203:6, 3206:11,
3331:15, 3331:18, 3370:9, 3410:4
3153:13, 3154:9, 3155:14, 3171:12,
3349:9, 3419:19
help [8] - 3323:24, 3343:14, 3350:14,
3174:23, 3176:8, 3178:3, 3180:10,
hundreds [3] - 3150:6, 3166:1,
3350:15, 3351:13, 3355:9, 3361:23,
3182:7, 3183:20, 3187:4, 3187:7,
3201:20
3401:7
3187:8, 3190:3, 3190:5, 3200:11,
hypocrite [1] - 3409:11
helped [1] - 3325:13
3201:3, 3201:12, 3204:21, 3205:18,
helping [4] - 3184:7, 3337:21, 3338:4,
3206:6, 3208:18, 3209:13, 3210:12,
3415:12
I
3210:17, 3210:20, 3211:12, 3213:21,
herself [1] - 3283:3
3217:9, 3220:16, 3222:5, 3222:20,
Hewlett [1] - 3146:13
IB5 [1] - 3395:1
3226:18, 3227:25, 3231:25, 3234:4,
hide [9] - 3396:10, 3396:22, 3397:9,
Idea [1] - 3169:16
3234:9, 3235:8, 3236:7, 3236:9,
3398:13, 3399:17, 3400:3, 3400:4,
idea [6] - 3158:9, 3200:21, 3211:18,
3238:17,
3247:16,
3247:23,
3248:15,
3400:8, 3400:16
3328:24, 3392:1, 3392:4
3248:22,
3249:15,
3254:16,
3254:24,
high [7] - 3147:4, 3152:5, 3154:5,
ideas [2] - 3198:10, 3273:8
3256:2, 3256:19, 3257:14, 3257:24,
3211:4, 3215:12, 3225:2, 3390:5
identified [3] - 3191:3, 3252:3,
3258:11,
3258:23,
3260:19,
3268:12,
high-end [1] - 3211:4
3281:15
3268:25,
3269:12,
3271:7,
3271:13,
higher [2] - 3166:7, 3253:16
identify [4] - 3232:25, 3266:20,
3272:4, 3272:21, 3273:12, 3273:20,
highlight [5] - 3185:18, 3190:11,
3327:18, 3416:14
3274:5, 3275:7, 3278:5, 3279:7,
3190:19, 3195:21, 3345:4
identifying [2] - 3156:2, 3416:13
3279:22, 3280:25, 3291:20, 3295:19,
highlighted [2] - 3190:17, 3224:17
ignored [1] - 3177:9
3295:25, 3296:16, 3297:14, 3297:24,
3440
II [1] - 3202:24
inform [1] - 3395:16
interview [3] - 3296:11, 3302:24,
3303:7
illicit [1] - 3403:7
information [61] - 3159:4, 3168:4,
interviewing [1] - 3296:25
3176:20, 3184:10, 3194:6, 3234:15,
illiquid [1] - 3185:1
3235:3, 3235:24, 3250:12, 3250:19,
interviews [1] - 3398:9
immediately [3] - 3317:24, 3347:21,
3268:16, 3273:3, 3274:24, 3275:13,
intimately [1] - 3158:18
3412:21
3276:14, 3277:13, 3283:7, 3285:12,
impact [1] - 3213:11
introduced [1] - 3163:20
3285:19, 3285:20, 3285:25, 3286:4,
impacted [1] - 3275:2
invested [1] - 3371:2
3288:23, 3289:5, 3303:11, 3304:2,
impacting [1] - 3162:2
investigation [12] - 3227:15, 3227:17,
3304:3, 3304:4, 3306:9, 3309:21,
3228:4, 3228:10, 3228:12, 3228:21,
impairment [1] - 3351:16
3311:21, 3314:10, 3317:1, 3327:4,
3229:10, 3229:11, 3229:12, 3230:22,
important [2] - 3324:18, 3346:18
3341:5, 3352:16, 3356:22, 3357:12,
3231:2, 3231:11
importantly [3] - 3163:23, 3183:13,
3357:16, 3374:23, 3379:15, 3380:4,
investigators [5] - 3297:1, 3297:8,
3277:2
3390:11, 3392:6, 3392:9, 3392:22,
3304:12, 3309:24, 3310:22
impression [4] - 3165:11, 3201:12,
3393:17, 3393:22, 3393:25, 3394:1,
investing [1] - 3167:10
3256:12, 3256:13
3394:2, 3394:22, 3395:5, 3396:10,
investment [20] - 3150:8, 3166:9,
improve [1] - 3380:10
3396:16, 3396:21, 3397:3, 3397:8,
3167:8, 3167:15, 3167:19, 3169:2,
improved [2] - 3219:2, 3219:4
3398:5, 3398:7, 3399:25
3172:24, 3231:9, 3233:20, 3235:21,
improvements [1] - 3217:14
informed [3] - 3302:24, 3303:1, 3303:6
3237:16, 3237:17, 3238:7, 3239:10,
inaccuracies [1] - 3264:16
infrastructure [1] - 3219:11
3245:2, 3284:10, 3361:8, 3361:10,
inaccurate [2] - 3276:14, 3277:7
infused [1] - 3205:1
3401:4
Inc [1] - 3238:8
infusion [8] - 3198:1, 3198:13,
investments [15] - 3150:7, 3150:8,
incentives [5] - 3158:6, 3158:9,
3199:10,
3199:12,
3200:21,
3204:13,
3150:9,
3167:6, 3182:16, 3184:19,
3163:21, 3163:24, 3163:25
3208:2, 3224:23
3208:6, 3235:22, 3251:9, 3251:11,
incentivize [1] - 3163:18
infusions [2] - 3224:12, 3224:16
3252:18, 3259:14, 3259:17, 3357:3,
inches [5] - 3389:22, 3389:25, 3390:1,
initial
[1] - 3148:10
3366:3
3390:6
initials [1] - 3185:25
investors [3] - 3200:23, 3277:1,
incident [2] - 3169:1, 3169:5
injected [1] - 3206:10
3277:3
include [4] - 3175:1, 3272:13,
inquiry [2] - 3157:22, 3407:12
investors' [1] - 3200:23
3358:23, 3358:24
insecurity [1] - 3198:15
invitation [1] - 3227:22
included [1] - 3278:23
insisting [1] - 3265:11
invite [1] - 3164:11
includes [2] - 3358:25, 3359:1
installation [1] - 3391:25
invited [1] - 3270:12
including [4] - 3186:13, 3351:16,
instead
[1] - 3226:16
invitees [1] - 3270:15
3356:11, 3421:5
institutes [1] - 3174:5
involve [1] - 3209:16
income [4] - 3337:6, 3359:23, 3381:1,
institution [3] - 3201:11, 3235:22,
involved [12] - 3153:7, 3158:13,
3381:5
3241:2
3164:21,
3165:18, 3167:10, 3169:5,
incoming [2] - 3192:1
institutions [1] - 3186:11
3206:12, 3211:4, 3223:16, 3329:5,
increase [4] - 3181:23, 3198:16,
instruct [6] - 3178:25, 3183:22,
3401:3, 3404:6
3202:19, 3290:18
3299:20,
3316:8,
3347:25,
3383:9
involves [1] - 3407:8
increased [1] - 3151:15
instructed
[9]
3184:1,
3274:14,
involving [4] - 3167:8, 3233:7, 3252:7,
incredible [3] - 3174:7, 3174:9,
3299:19, 3316:10, 3348:22, 3348:25,
3327:18
3174:12
3352:21, 3352:22, 3370:10
iPhone [11] - 3292:15, 3293:22,
incrimination [1] - 3300:15
instruction
[3] - 3276:4, 3348:2,
3318:25,
3319:10, 3332:23, 3332:24,
indeed [1] - 3296:14
3353:6
3333:1, 3333:14, 3333:20, 3334:2,
indicate [1] - 3352:1
instructions [3] - 3188:12, 3370:8,
3367:17
indicated [3] - 3181:23, 3212:8,
3418:16
iPhones [1] - 3333:22
3354:4
intact [1] - 3382:5
irate [1] - 3169:7
indicates [3] - 3191:9, 3343:2, 3358:4
intend [1] - 3269:13
irony [1] - 3320:9
indicating [4] - 3215:21, 3216:11,
intended
[1] - 3313:24
IRS [2] - 3304:12, 3338:12
3389:19, 3389:20
intention
[2] - 3225:15, 3234:6
Island [2] - 3170:25, 3363:17
indicative [1] - 3261:15
Intercontinental [2] - 3266:4, 3287:25
island [5] - 3171:3, 3171:8, 3219:15,
Indies [2] - 3378:7
interest [5] - 3149:5, 3154:7, 3156:19,
3219:17, 3220:1
individual [10] - 3158:16, 3158:22,
3201:25, 3381:5
islands [5] - 3210:11, 3210:13,
3158:23, 3168:9, 3169:19, 3223:1,
interior [2] - 3341:20, 3341:25
3211:11, 3219:13, 3227:24
3223:5, 3223:22, 3252:25, 3413:17
internal [2] - 3280:2
Islands [9] - 3211:1, 3211:2, 3226:16,
individuals [6] - 3167:17, 3172:24,
3227:5,
3227:6, 3227:9, 3231:15,
Internal
[1]
3338:7
3244:14, 3245:1, 3260:18, 3267:16
3245:7
international [2] - 3263:16, 3263:23
industry [2] - 3152:12, 3160:15
issue [10] - 3159:12, 3212:9, 3218:24,
International [18] - 3170:4, 3186:8,
inflated [12] - 3223:20, 3223:21,
3230:6,
3230:12, 3276:2, 3286:11,
3194:14,
3201:22,
3202:13,
3210:2,
3252:9, 3252:13, 3253:13, 3253:14,
3417:12, 3421:18, 3422:1
3214:3, 3231:8, 3235:19, 3236:25,
3253:20, 3254:5, 3254:12, 3254:14,
issued [8] - 3151:7, 3151:20, 3155:9,
3246:5, 3250:6, 3255:15, 3279:17,
3255:12, 3262:10
3235:24,
3264:15, 3276:8, 3276:13,
3356:20,
3363:17,
3374:11,
3375:21
inflating [2] - 3255:23, 3259:5
3374:15
internationally
[2]
3280:12,
3287:18
inflection [1] - 3351:4
issues [5] - 3192:14, 3212:8, 3232:12,
3441
3410:17, 3414:14
IT [3] - 3391:19, 3393:2, 3398:3
item [4] - 3175:17, 3175:18, 3237:14,
3389:16
itemize [1] - 3239:9
itemized [1] - 3237:15
items [5] - 3175:19, 3252:25, 3253:17,
3278:23, 3380:25
itself [4] - 3157:22, 3211:21, 3213:13,
3214:2
3353:3, 3353:21, 3354:1, 3354:4,

3354:16, 3356:8, 3357:10, 3372:15,
3373:18, 3373:19, 3375:19, 3376:2,
3377:17, 3383:10, 3384:3, 3386:4,
3401:9, 3405:9, 3406:16, 3408:13,
3410:4, 3410:21, 3410:24, 3411:19,
3411:24, 3411:25, 3418:6, 3419:1,
3419:4, 3419:22, 3420:18
JURY [1] - 3143:7
justice [1] - 3395:22
Justice [2] - 3143:17, 3413:13
3388:15, 3393:12, 3394:5, 3394:7,

3394:11, 3398:13, 3399:14, 3400:18
land [21] - 3210:23, 3214:8, 3214:18,
3214:22, 3214:24, 3215:1, 3215:7,
3215:25, 3216:2, 3216:6, 3216:9,
3216:23, 3217:11, 3217:16, 3217:25,
3218:19, 3218:21, 3218:22, 3218:24,
3219:5, 3221:13
landscaping [1] - 3219:8
lapel [1] - 3208:17
laptop [14] - 3190:3, 3387:11, 3387:13,
3387:15,
3387:19, 3391:15, 3392:16,
J
3393:7, 3393:19, 3393:20, 3393:21,
K
3394:23, 3395:6, 3396:20
James [9] - 3363:1, 3368:25, 3375:13,
large [3] - 3163:1, 3164:4, 3285:20
keep [16] - 3294:5, 3301:14, 3356:25,
3375:17, 3376:6, 3376:12, 3376:22,
larger [1] - 3265:11
3357:2, 3357:5, 3359:21, 3360:4,
3379:8, 3379:20
last [31] - 3180:13, 3193:7, 3250:5,
3360:6, 3366:8, 3366:19, 3391:22,
JAMES [2] - 3145:3, 3146:7
3250:8, 3250:23, 3256:1, 3288:17,
3412:23, 3420:23, 3421:2, 3423:6
January [16] - 3146:14, 3171:23,
3292:17, 3296:7, 3302:7, 3303:6,
keeping [2] - 3315:18, 3410:13
3228:18, 3231:17, 3233:11, 3241:17,
3303:24, 3304:9, 3305:10, 3305:11,
keeps [1] - 3366:7
3250:21, 3255:20, 3291:2, 3293:3,
3311:24, 3312:18, 3312:21, 3313:3,
Kenneth [2] - 3144:6, 3378:4
3335:3, 3345:9, 3346:3, 3369:25,
3314:8, 3314:9, 3321:8, 3324:8,
kept [4] - 3161:10, 3322:9, 3326:4,
3394:8
3348:11, 3364:17, 3364:22, 3369:9,
3390:7
Jay [2] - 3148:9, 3153:4
3370:24, 3411:16
key [2] - 3390:15, 3390:18
jets [3] - 3171:14, 3171:18, 3174:21
late [11] - 3165:3, 3171:21, 3177:11,
killing [1] - 3174:4
Jim [4] - 3176:15, 3230:23, 3263:12,
3199:22, 3232:14, 3244:16, 3292:5,
kind [15] - 3186:23, 3310:5, 3310:10,
3267:6
3377:25, 3378:1, 3418:22
3354:5, 3360:21, 3364:6, 3373:22,
Joan [1] - 3178:17
latest [1] - 3188:10
3377:6, 3387:11, 3388:19, 3388:21,
job [6] - 3160:15, 3169:20, 3170:7,
laura [1] - 3282:5
3392:9, 3392:22, 3394:22, 3414:19
3176:15, 3176:16, 3185:12
LAURA [1] - 3405:16
King [1] - 3154:15
John [1] - 3144:2
Laura [12] - 3169:2, 3233:19, 3238:7,
king [3] - 3156:13, 3157:24, 3227:23
Johnny [3] - 3144:11, 3424:5, 3424:9
3245:3, 3282:2, 3284:13, 3343:24,
kitty [1] - 3225:19
joining [1] - 3414:1
3401:4, 3401:5, 3405:14, 3406:24,
knock [1] - 3414:10
JPW [1] - 3367:18
3409:6
knocking [1] - 3338:13
Juan [7] - 3233:17, 3238:6, 3243:25,
Laura's [1] - 3409:6
knowing [2] - 3240:17, 3310:9
3245:17, 3245:24, 3264:17, 3282:5
law [4] - 3300:20, 3301:22, 3412:7,
knowledge [17] - 3149:12, 3152:19,
judge [3] - 3327:11, 3377:16, 3379:22
3412:16
3152:21, 3164:13, 3171:12, 3173:6,
Judge [10] - 3260:25, 3298:9, 3350:22,
Law [2] - 3144:3, 3144:6
3200:3, 3217:19, 3218:18, 3219:23,
3351:21, 3373:19, 3377:14, 3377:17,
law's [1] - 3301:21
3221:14, 3222:1, 3243:6, 3248:11,
3377:18, 3416:19, 3423:10
lawyer [32] - 3232:25, 3233:25,
3296:9, 3358:9, 3379:21
JUDGE [1] - 3143:10
3244:19, 3273:24, 3278:10, 3296:10,
known [7] - 3150:9, 3150:13, 3158:1,
Judge's [1] - 3221:6
3297:21, 3298:16, 3298:21, 3298:22,
3227:10, 3377:3, 3377:20, 3377:21
judicial [1] - 3412:11
3299:10, 3300:3, 3300:7, 3301:2,
knows [9] - 3235:9, 3286:19, 3315:22,
juggle [1] - 3421:21
3301:4, 3301:9, 3301:15, 3301:23,
3323:20, 3399:19, 3399:21, 3410:16,
jump [7] - 3190:8, 3192:9, 3193:25,
3302:3, 3302:5, 3302:8, 3302:13,
3410:23, 3415:1
3194:9, 3286:2, 3332:8, 3376:5
3303:10, 3307:8, 3311:7, 3336:11,
Kuhrt [17] - 3197:16, 3197:19,
jumping [1] - 3351:3
3336:23, 3346:6, 3373:17, 3378:13,
3206:24, 3217:24, 3218:15, 3218:21,
June [5] - 3154:15, 3250:1, 3250:4,
3379:25, 3386:2
3220:15, 3226:9, 3226:11, 3227:1,
3250:19, 3250:22
lawyer-client [1] - 3300:3
3252:24, 3357:17, 3357:25, 3384:18,
juries [1] - 3385:15
lawyers [9] - 3154:1, 3307:17,
3399:17, 3400:6
JUROR [1] - 3336:3
3308:15, 3308:20, 3309:24, 3310:10,
jury [79] - 3146:1, 3183:22, 3184:1,
3310:22, 3373:16, 3413:25
L
3206:3, 3208:19, 3208:21, 3235:11,
lead [3] - 3157:22, 3247:8, 3247:10
3257:21, 3274:14, 3276:1, 3286:19,
leadership [2] - 3206:23, 3232:22
3297:12, 3298:14, 3299:20, 3300:6,
leading [9] - 3151:21, 3161:18,
lack [1] - 3203:23
3300:22, 3300:24, 3301:5, 3301:14,
3214:12,
3215:14, 3215:17, 3220:17,
lacking [1] - 3278:25
3302:7, 3304:4, 3305:6, 3305:7,
3238:23,
3239:13, 3239:20
ladies [4] - 3257:17, 3274:13, 3331:3,
3305:19, 3306:5, 3309:17, 3310:11,
learn [1] - 3153:1
3409:25
3310:14, 3312:7, 3312:14, 3312:20,
learned [3] - 3204:3, 3263:13, 3364:9
lady [2] - 3302:12, 3343:25
3313:9, 3313:16, 3315:2, 3316:9,
learning [1] - 3282:9
lag [1] - 3251:3
3316:10, 3322:11, 3330:16, 3331:9,
leases [1] - 3189:16
lake [15] - 3285:10, 3286:5, 3386:9,
3331:16, 3331:18, 3333:24, 3342:11,
least [6] - 3201:2, 3204:19, 3261:14,
3387:6, 3387:24, 3388:11, 3388:13,
3346:25, 3350:10, 3352:9, 3352:20,
3265:9, 3416:6, 3422:14
3442
3296:21, 3312:2, 3312:13, 3336:1,
leave [9] - 3148:14, 3148:20, 3208:11,
losing [3] - 3189:8, 3329:19, 3330:4
3339:11, 3345:2, 3364:22, 3366:6,
3254:21, 3257:10, 3257:12, 3292:4,
loss [4] - 3276:20, 3380:19, 3380:21,
3366:9, 3367:4, 3367:6, 3367:10,
3410:5, 3417:5
3382:15
3369:2, 3369:21, 3380:17, 3381:13,
leaving [2] - 3179:18, 3191:20
lost [3] - 3188:20, 3201:10, 3201:13
3407:11
led [5] - 3164:25, 3258:9, 3258:12,
Louisiana [1] - 3148:24
liquid [5] - 3167:10, 3167:15, 3182:16,
3259:1, 3259:9
low [2] - 3162:24, 3174:6
3193:22, 3200:3
leeway [1] - 3299:13
lower [3] - 3147:7, 3157:3, 3251:22
liquidity [3] - 3162:25, 3199:15,
left [14] - 3178:20, 3179:8, 3185:24,
lucky [1] - 3146:18
3203:24
3186:2, 3191:7, 3192:3, 3193:18,
lunch [3] - 3257:17, 3421:4, 3421:6
list [5] - 3190:15, 3237:15, 3381:3,
3193:20, 3196:3, 3207:3, 3222:13,
lying [4] - 3232:6, 3232:7, 3307:25,
3415:4, 3415:20
3225:12, 3225:19, 3251:8
3312:5
listened [1] - 3297:9
left-hand [5] - 3185:24, 3186:2,
Lynch [3] - 3148:12, 3148:15, 3148:20
listing [4] - 3194:10, 3237:15, 3253:2,
3207:3, 3222:13, 3251:8
3253:15
legal [5] - 3189:14, 3209:18, 3224:9,
M
lists [1] - 3241:1
3271:4, 3354:9
literate [1] - 3387:17
legally [2] - 3221:16, 3354:9
Machine [1] - 3165:13
live [10] - 3293:23, 3294:13, 3302:22,
legitimate [2] - 3316:17, 3341:11
machine [3] - 3317:17, 3317:18,
3321:4, 3321:6, 3344:5, 3344:8,
Lena [3] - 3233:18, 3244:1, 3268:18
3317:20
3344:9, 3344:13, 3360:17
lengthier [1] - 3414:24
mail [32] - 3173:25, 3177:14, 3184:10,
lived [4] - 3294:8, 3320:20, 3320:25,
lengthy [1] - 3409:22
3185:3,
3185:6, 3185:17, 3186:17,
3321:7
Leo [2] - 3169:19, 3169:20
3187:13, 3187:24, 3187:25, 3190:9,
LLC [1] - 3368:23
Leroy [1] - 3154:15
3190:14, 3191:2, 3191:4, 3191:12,
loan [35] - 3224:25, 3225:3, 3225:13,
less [5] - 3359:18, 3359:19, 3380:22,
3191:15, 3192:22, 3193:17, 3193:22,
3289:16,
3292:23,
3293:13,
3313:22,
3416:8
3193:25, 3194:1, 3194:10, 3194:18,
3313:23, 3315:4, 3315:6, 3315:7,
lesser [1] - 3261:19
3195:9, 3195:18, 3196:23, 3226:8,
3316:2, 3316:15, 3316:20, 3316:24,
letter [5] - 3154:14, 3155:1, 3156:12,
3226:25, 3293:5, 3338:23, 3396:18
3317:6,
3318:20,
3325:1,
3332:9,
3157:24
mails [5] - 3197:1, 3329:6, 3394:24,
3332:13, 3334:22, 3334:23, 3336:7,
letters [4] - 3185:25, 3186:10,
3395:7,
3395:8
3336:11, 3336:22, 3345:12, 3346:5,
3285:24, 3393:9
mainland [2] - 3219:12, 3227:9
3346:8,
3346:9,
3349:14,
3358:10,
letting [1] - 3419:11
maintain [4] - 3152:5, 3180:21,
3372:15, 3372:20, 3372:21, 3394:20
level [9] - 3162:24, 3164:7, 3164:8,
3180:23,
3180:25
loaned [2] - 3180:12, 3302:12
3207:5, 3207:8, 3207:16, 3207:17,
maintaining [1] - 3181:4
loans
[12]
3225:4,
3225:7,
3253:8,
3207:19, 3397:11
maintenance [1] - 3211:7
3259:19, 3260:7, 3266:20, 3290:10,
levels [1] - 3197:13
major [1] - 3212:9
3290:23, 3290:24, 3291:1, 3295:3,
liar [13] - 3306:15, 3306:16, 3306:19,
Maldonado [21] - 3185:9, 3185:11,
3339:24
3307:18, 3307:21, 3307:23, 3307:24,
3185:13, 3187:14, 3187:24, 3190:9,
lobby
[3]
3266:2,
3266:3,
3267:2
3308:8, 3308:23, 3308:24, 3309:2,
3190:15, 3194:5, 3194:8, 3194:20,
local [2] - 3218:17, 3356:23
3309:18, 3311:17
3195:2, 3195:8, 3197:1, 3348:2,
located
[9]
3162:22,
3210:4,
Libya [3] - 3242:8, 3242:13, 3242:17
3349:16, 3349:19, 3352:3, 3352:4,
3219:12,
3219:14,
3241:25,
3304:14,
Libyan [2] - 3242:8, 3242:11
3352:5, 3352:6, 3352:22
3336:17, 3341:18, 3363:17
lie [17] - 3232:4, 3232:8, 3232:10,
Maldonado's [1] - 3186:17
locating [1] - 3162:17
3253:24, 3254:4, 3254:12, 3256:6,
man [2] - 3230:17, 3373:10
look
[17]
3154:13,
3271:9,
3290:9,
3283:10, 3310:6, 3381:8, 3381:11,
Man [1] - 3362:17
3298:17, 3314:13, 3314:21, 3335:5,
3381:12, 3382:4, 3382:12, 3382:15
managed [1] - 3150:12
3335:16, 3345:19, 3345:21, 3346:18,
lied [9] - 3310:4, 3310:5, 3312:13,
management [9] - 3150:1, 3150:13,
3364:15,
3368:15,
3370:19,
3380:17,
3325:4, 3342:14, 3344:24, 3406:5,
3150:15, 3150:23, 3151:2, 3151:6,
3396:21, 3422:12
3409:12
3151:13, 3152:1, 3157:2
looked [6] - 3152:7, 3154:3, 3252:7,
lies [1] - 3283:11
manager [3] - 3185:10, 3185:12,
3267:9,
3335:23,
3396:7
lieu [2] - 3292:24, 3338:19
3348:3
looking
[15]
3152:8,
3152:24,
3207:3,
life [1] - 3312:4
MANAGER [1] - 3331:24
3222:13, 3222:19, 3234:14, 3251:8,
light [1] - 3274:24
manager/member [2] - 3363:1,
3271:15,
3273:16,
3273:17,
3276:1,
likely [2] - 3194:24, 3414:21
3368:25
3324:1,
3386:7,
3419:9,
3422:19
limine [3] - 3411:12, 3418:9, 3418:10
managing [2] - 3150:19, 3174:5
looks [3] - 3334:25, 3387:22, 3419:7
Limited [13] - 3186:8, 3194:14,
manner [2] - 3319:4, 3370:7
Lopez
[15] - 3197:16, 3197:19,
3202:13, 3210:3, 3214:4, 3235:20,
manufacturing [1] - 3251:11
3206:24,
3217:24,
3226:10,
3226:23,
3238:8, 3246:6, 3250:6, 3255:15,
March [11] - 3181:17, 3182:21, 3187:3,
3227:1, 3252:24, 3357:24, 3357:25,
3279:17, 3363:17, 3374:11
3187:13,
3188:23, 3189:17, 3196:6,
3381:22,
3381:25,
3384:16,
3399:18,
limited [3] - 3274:2, 3274:19, 3406:25
3198:4, 3301:6, 3307:6, 3312:1
3400:6
Limited's [1] - 3170:4
marching [1] - 3237:14
Lori [11] - 3404:12, 3404:14, 3404:25,
Lindenberg [1] - 3409:13
margin [1] - 3185:24
3405:13, 3405:14, 3405:15, 3405:19,
line [25] - 3167:21, 3186:20, 3207:4,
3406:5, 3406:12, 3407:23, 3408:6
Maricio [1] - 3212:8
3209:3, 3223:6, 3232:9, 3246:5,
LORI [1] - 3405:15
Mark [1] - 3218:15
3443
3247:7, 3247:13, 3248:23, 3254:1,
market [6] - 3149:23, 3202:17, 3223:4,
midnight [1] - 3162:6
3255:8, 3255:19, 3256:4, 3257:5,
3225:10, 3254:6, 3366:20
might [14] - 3208:11, 3240:3, 3266:10,
3258:5, 3258:8, 3258:9, 3258:15,
marketable [5] - 3179:25, 3182:17,
3279:23, 3291:7, 3304:14, 3312:16,
3259:1, 3259:8, 3259:13, 3259:23,
3183:3, 3196:20, 3238:22
3318:14, 3351:13, 3395:9, 3414:24,
3260:6, 3260:15, 3262:5, 3262:9,
3419:3, 3421:21, 3423:1
marketing [3] - 3166:3, 3167:9,
3262:22, 3264:2, 3265:14, 3265:20,
3288:23
mike [2] - 3208:17, 3371:6
3265:21, 3265:23, 3266:15, 3266:18,
markets [5] - 3166:20, 3220:10,
mill [1] - 3215:23
3267:11, 3267:12, 3267:14, 3267:15,
3220:13, 3253:2, 3253:16
million [82] - 3151:9, 3180:16,
3267:25, 3268:9, 3268:15, 3269:14,
markup [1] - 3220:6
3180:19, 3181:1, 3181:2, 3182:4,
3270:1, 3270:12, 3273:4, 3274:23,
3184:6, 3185:20, 3186:18, 3188:3,
marriage [4] - 3212:9, 3405:10,
3275:16, 3276:10, 3281:18, 3282:4,
3188:4, 3188:20, 3189:10, 3189:12,
3406:10, 3406:16
3282:15, 3286:25, 3288:7, 3288:13,
3190:20, 3191:1, 3191:20, 3194:11,
married [10] - 3160:5, 3403:23,
3307:16
3194:24, 3195:24, 3196:3, 3199:19,
3404:1, 3404:12, 3404:15, 3405:7,
meeting's [1] - 3245:8
3200:2, 3200:6, 3202:19, 3203:6,
3405:8, 3405:20, 3406:12, 3408:6
meetings [10] - 3163:15, 3163:16,
3206:11, 3214:25, 3215:12, 3216:17,
massive [1] - 3198:2
3164:2, 3164:15, 3165:1, 3165:3,
3216:24, 3217:11, 3218:6, 3223:2,
master [1] - 3364:9
3165:8, 3241:18, 3242:2, 3242:6
3223:6, 3224:11, 3224:22, 3225:10,
materials [5] - 3166:3, 3167:9,
Mejia [2] - 3169:20
3225:19, 3252:10, 3289:17, 3294:20,
3169:17, 3170:5, 3288:23
melted [2] - 3267:4, 3267:6
3295:18, 3314:15, 3316:1, 3316:5,
matter [14] - 3213:25, 3234:6, 3274:9,
member [4] - 3384:13, 3401:24,
3318:17, 3321:25, 3330:17, 3330:19,
3289:3, 3298:18, 3309:12, 3342:16,
3402:1, 3402:3
3339:2, 3341:5, 3348:23, 3349:8,
3410:6, 3413:1, 3413:3, 3414:8,
3355:1, 3358:20, 3358:21, 3359:9,
memorialize [3] - 3318:2, 3318:18,
3415:1, 3415:10, 3424:7
3359:10, 3359:11, 3359:13, 3359:16,
3318:19
maturities [2] - 3191:3, 3191:6
3359:17, 3359:24, 3360:12, 3361:25,
memorialized
[1]
3318:12
Mauricio [4] - 3232:18, 3233:15,
3362:1, 3365:6, 3365:22, 3366:11,
memory [1] - 3401:8
3244:2, 3281:23
3370:17, 3371:17, 3371:19, 3371:23,
Memphis [5] - 3172:14, 3172:16,
max [1] - 3421:13
3381:15, 3381:17, 3381:18, 3383:6
3173:13,
3177:18,
3178:8
maximum [1] - 3149:18
millions [4] - 3191:8, 3201:20,
men [3] - 3377:23, 3377:24
McGuire [3] - 3144:6, 3144:6, 3415:11
3324:20, 3325:22
mens [1] - 3418:16
mean [47] - 3154:7, 3172:22, 3175:13,
Millions [1] - 3325:21
mental [1] - 3197:13
3183:4, 3186:6, 3186:19, 3238:13,
mind [12] - 3272:1, 3272:13, 3272:15,
mention [1] - 3283:18
3250:15, 3254:8, 3270:10, 3270:16,
3272:18, 3299:2, 3311:10, 3323:23,
mentioned [8] - 3161:2, 3203:5,
3273:14, 3275:5, 3275:11, 3276:16,
3370:2, 3370:4, 3389:15, 3389:18,
3207:8, 3226:21, 3243:13, 3245:1,
3277:3, 3277:5, 3315:21, 3319:12,
3410:13
3247:14, 3340:21
3322:5, 3333:17, 3334:20, 3334:21,
mine [2] - 3387:10, 3388:16
Merchant [2] - 3362:23, 3362:24
3339:9, 3347:10, 3347:11, 3348:18,
minimum [1] - 3415:24
Merchants [2] - 3368:17, 3370:11
3356:16, 3359:7, 3359:12, 3360:1,
minus [1] - 3365:9
merely [2] - 3272:5, 3274:11
3360:15, 3360:19, 3360:21, 3364:6,
minute [11] - 3198:24, 3298:15,
3387:11, 3388:1, 3388:5, 3388:24,
Merrill [3] - 3148:12, 3148:15, 3148:20
3309:23, 3314:21, 3322:24, 3332:9,
3390:18, 3391:10, 3391:12, 3413:20,
message [7] - 3296:19, 3319:9,
3361:3, 3374:13, 3376:5, 3390:23
3415:23, 3417:13, 3418:25, 3421:5
3319:19, 3332:17, 3334:1, 3334:3,
minutes [7] - 3205:21, 3205:25,
meaning [8] - 3171:5, 3181:17,
3406:22
3206:1, 3329:17, 3342:17, 3418:6,
3186:22, 3198:16, 3199:20, 3264:22,
messages [1] - 3184:12
3419:6
3278:3, 3374:16
met [14] - 3284:21, 3296:5, 3303:24,
misappropriated [1] - 3295:12
means [5] - 3183:2, 3199:12, 3199:13,
3308:7, 3377:18, 3401:10, 3401:12,
misappropriations [1] - 3179:10
3359:14, 3369:12
3402:24, 3403:7, 3403:14, 3404:12,
mischaracterization [1] - 3412:13
meant [6] - 3150:3, 3212:14, 3275:14,
3404:25, 3405:19, 3405:21
mischaracterizes [2] - 3328:25,
3288:23, 3334:22
metals [1] - 3150:9
3355:22
mechanical [1] - 3144:14
Miami [30] - 3162:15, 3162:18,
miscommunication [1] - 3329:13
media [4] - 3285:10, 3385:13, 3393:14,
3162:22, 3162:23, 3165:13, 3168:15,
misconduct [1] - 3240:6
3400:12
3169:2, 3169:3, 3233:13, 3239:24,
misrepresent [1] - 3416:12
meet [9] - 3197:3, 3202:12, 3241:13,
3241:14, 3241:21, 3242:5, 3243:10,
Mississippi [12] - 3203:18, 3284:23,
3266:2, 3283:23, 3288:2, 3288:14,
3243:12, 3243:22, 3243:23, 3244:9,
3284:25, 3285:6, 3287:21, 3293:24,
3401:11, 3420:10
3247:7, 3248:3, 3254:1, 3258:5,
3294:9, 3343:15, 3344:5, 3344:10,
3259:24, 3282:15, 3284:18, 3285:5,
meeting [90] - 3164:12, 3165:2,
3355:10, 3401:12
3287:19, 3287:24, 3289:3
3165:4, 3165:20, 3192:15, 3192:17,
misstatements [1] - 3279:15
Michigan [1] - 3294:14
3192:18, 3193:3, 3230:25, 3231:22,
mistaken [1] - 3413:12
3232:21, 3232:23, 3232:24, 3233:6,
microphone [1] - 3208:17
mistrial [3] - 3410:25, 3412:3, 3412:5
3233:9, 3233:10, 3233:12, 3233:25,
mid [1] - 3231:17
3234:13, 3238:1, 3238:17, 3239:11,
mix [1] - 3280:21
middle [10] - 3190:9, 3194:19,
3239:24, 3240:2, 3240:10, 3240:21,
model [2] - 3167:19, 3284:10
3198:20, 3215:4, 3233:11, 3252:20,
3240:22, 3241:7, 3241:10, 3241:12,
modulate [1] - 3351:10
3262:20, 3377:23, 3377:25, 3378:1
3241:15, 3242:4, 3242:5, 3243:13,
middle-aged [1] - 3377:23
moment [7] - 3155:11, 3176:6,
3243:15, 3243:20, 3244:23, 3245:3,
3223:24,
3248:13, 3276:9, 3329:12,
midmorning
[2] - 3244:16, 3245:4
3444
3403:17
3250:25, 3253:16, 3277:1, 3308:3,
3234:8, 3234:12, 3234:17, 3234:22,
3356:24, 3375:3, 3393:1, 3414:21
3234:25, 3235:2, 3235:6, 3235:14,
Monday [5] - 3146:2, 3244:6, 3267:11,
3235:16, 3236:2, 3236:4, 3236:7,
3287:4
mostly [1] - 3175:23
3236:9, 3236:11, 3236:12, 3236:18,
monetary [1] - 3163:24
mother [2] - 3301:21, 3301:22
3236:24, 3237:8, 3237:12, 3238:18,
Money [1] - 3165:13
mother-in-law [1] - 3301:22
3238:23, 3239:2, 3239:13, 3239:19,
money [161] - 3148:6, 3149:3, 3149:4,
mother-in-law's [1] - 3301:21
3239:22, 3240:18, 3243:22, 3244:7,
3161:11, 3161:13, 3171:6, 3171:7,
motion [6] - 3411:12, 3412:5, 3418:8,
3244:18, 3244:24, 3245:10, 3245:13,
3171:9, 3171:19, 3179:11, 3180:12,
3418:10, 3418:13, 3418:14
3245:25, 3247:21, 3247:24, 3249:13,
3181:24, 3182:18, 3189:8, 3189:17,
motive [2] - 3318:1, 3371:22
3249:16, 3249:21, 3250:12, 3250:17,
3193:18, 3196:8, 3199:2, 3199:6,
mouths [1] - 3256:14
3252:13, 3252:14, 3252:16, 3254:24,
3199:13, 3201:8, 3201:10, 3201:20,
move [5] - 3150:10, 3370:23, 3387:1,
3254:25, 3256:1, 3256:3, 3256:9,
3201:22, 3205:1, 3205:2, 3205:3,
3407:21, 3408:15
3257:3, 3257:14, 3257:24, 3258:3,
3217:5, 3225:16, 3246:10, 3287:16,
moved [1] - 3215:22
3258:11, 3258:14, 3258:18, 3258:25,
3290:1, 3291:4, 3291:15, 3293:16,
moving [10] - 3161:21, 3178:10,
3260:8, 3260:10, 3260:14, 3260:19,
3293:21, 3294:18, 3295:1, 3295:3,
3181:8, 3181:11, 3182:21, 3194:23,
3260:22, 3260:25, 3261:1, 3261:5,
3295:6, 3295:12, 3301:15, 3301:19,
3209:17, 3227:14, 3329:7, 3413:9
3261:16, 3262:2, 3266:11, 3266:13,
3301:20, 3301:21, 3301:22, 3302:13,
MR [579] - 3145:4, 3145:5, 3146:6,
3268:14, 3268:21, 3268:22, 3268:24,
3304:14, 3312:22, 3313:12, 3313:17,
3146:9, 3146:22, 3147:1, 3151:21,
3269:2, 3269:12, 3269:15, 3269:18,
3314:3, 3315:2, 3316:17, 3316:22,
3151:23, 3152:17, 3152:22, 3153:13,
3270:2, 3270:4, 3270:9, 3270:14,
3318:15, 3320:18, 3321:23, 3321:24,
3153:16, 3153:18, 3153:22, 3154:12,
3270:17, 3270:20, 3271:7, 3271:13,
3322:11, 3322:23, 3323:1, 3324:12,
3154:18, 3154:20, 3154:25, 3155:3,
3271:16, 3271:20, 3271:23, 3272:3,
3324:21, 3324:25, 3325:3, 3325:9,
3155:13, 3155:18, 3155:23, 3156:1,
3272:8, 3272:12, 3272:15, 3272:19,
3325:11, 3326:5, 3326:7, 3326:11,
3156:6, 3156:7, 3156:17, 3157:8,
3272:21, 3272:23, 3273:1, 3273:3,
3326:18, 3327:6, 3327:21, 3328:2,
3157:10, 3157:12, 3158:2, 3158:4,
3273:7, 3273:12, 3273:13, 3273:19,
3328:15, 3329:19, 3330:4, 3334:5,
3161:18, 3161:19, 3161:23, 3166:14,
3273:23, 3274:5, 3274:8, 3274:11,
3334:7, 3335:6, 3335:14, 3335:15,
3166:24, 3167:1, 3167:3, 3167:20,
3274:22, 3275:7, 3275:10, 3275:12,
3335:16, 3335:19, 3335:24, 3337:4,
3167:24, 3168:1, 3168:5, 3168:12,
3275:19, 3275:23, 3276:7, 3277:17,
3338:17, 3339:3, 3339:18, 3339:24,
3168:18, 3169:4, 3170:16, 3171:17,
3277:19, 3278:6, 3278:12, 3279:10,
3340:14, 3341:9, 3341:11, 3342:6,
3171:25, 3172:2, 3172:3, 3175:5,
3279:25, 3281:10, 3282:1, 3282:7,
3342:11, 3342:24, 3343:3, 3343:8,
3176:8, 3176:9, 3177:1, 3177:4,
3285:22, 3286:6, 3286:8, 3286:10,
3343:13, 3345:16, 3345:18, 3345:20,
3177:6, 3178:6, 3178:22, 3178:25,
3286:11, 3286:16, 3286:19, 3286:23,
3345:22, 3346:6, 3346:11, 3346:15,
3179:3, 3179:7, 3179:14, 3179:17,
3287:10, 3287:23, 3289:11, 3289:14,
3346:19, 3347:3, 3348:1, 3348:5,
3180:6, 3180:8, 3180:10, 3180:11,
3290:13, 3290:14, 3291:6, 3291:10,
3348:8, 3348:9, 3348:12, 3348:17,
3181:7, 3182:7, 3182:9, 3182:11,
3291:17, 3291:19, 3291:22, 3291:24,
3349:1, 3355:3, 3355:4, 3355:5,
3182:13, 3183:15, 3183:20, 3183:21,
3292:2, 3292:4, 3292:8, 3292:9,
3355:6, 3355:8, 3355:9, 3356:25,
3183:25, 3184:3, 3185:2, 3185:5,
3295:19, 3295:25, 3296:3, 3296:15,
3357:2, 3358:11, 3358:19, 3358:23,
3185:16, 3185:21, 3187:4, 3187:7,
3296:18, 3296:24, 3297:14, 3297:23,
3358:24, 3359:1, 3359:7, 3360:4,
3187:12, 3189:2, 3189:4, 3190:2,
3298:2, 3298:4, 3298:7, 3298:9,
3360:15, 3361:23, 3364:3, 3364:7,
3190:5, 3190:7, 3190:11, 3190:13,
3298:12, 3298:20, 3298:23, 3299:2,
3364:16, 3365:17, 3365:19, 3366:19,
3190:19, 3190:22, 3191:11, 3191:14,
3299:6, 3299:9, 3299:14, 3299:22,
3368:3, 3368:6, 3368:7, 3370:2,
3192:9, 3192:12, 3192:20, 3192:21,
3299:24, 3300:13, 3301:1, 3303:3,
3370:5, 3370:20, 3371:1, 3371:4,
3192:23, 3192:24, 3192:25, 3193:2,
3303:5, 3304:15, 3304:17, 3305:4,
3371:9, 3371:11, 3371:17, 3371:21,
3193:8, 3195:20, 3195:22, 3196:19,
3305:10, 3305:13, 3306:1, 3306:3,
3371:25, 3372:3, 3379:2
3199:1, 3200:12, 3201:5, 3201:18,
3307:3, 3308:4, 3308:5, 3308:12,
monies [4] - 3253:5, 3289:25,
3202:4, 3204:5, 3204:7, 3204:9,
3308:14, 3308:15, 3308:17, 3308:18,
3314:17, 3360:22
3204:23, 3205:6, 3205:18, 3206:6,
3308:24, 3309:1, 3309:5, 3309:16,
monitor [1] - 3175:24
3206:7, 3206:17, 3206:19, 3207:10,
3309:19, 3311:3, 3311:9, 3311:13,
monitoring [1] - 3195:15
3207:12, 3208:18, 3209:7, 3209:10,
3313:4, 3313:6, 3315:19, 3315:21,
month [7] - 3187:2, 3192:3, 3250:10,
3209:13, 3209:14, 3210:22, 3211:15,
3315:24, 3316:6, 3316:8, 3316:11,
3251:3, 3370:8, 3382:2, 3382:6
3212:19, 3212:21, 3212:25, 3213:2,
3321:2, 3321:5, 3322:14, 3322:19,
monthly [2] - 3202:6, 3221:20
3213:4, 3213:8, 3213:14, 3214:7,
3322:22, 3322:25, 3323:4, 3323:6,
months [6] - 3208:10, 3216:25,
3214:12, 3214:14, 3215:14, 3215:18,
3323:9, 3323:13, 3323:15, 3323:17,
3220:4, 3293:1, 3310:13, 3343:10
3216:21, 3217:9, 3217:10, 3219:7,
3323:18, 3323:20, 3323:22, 3323:24,
Montserrat [1] - 3363:14
3219:16, 3220:16, 3220:24, 3221:3,
3323:25, 3324:3, 3324:6, 3324:11,
3221:5, 3221:9, 3222:6, 3222:10,
morning [19] - 3146:2, 3146:3,
3325:14, 3325:16, 3325:18, 3326:2,
3222:12, 3222:16, 3222:20, 3222:22,
3146:10, 3146:11, 3249:20, 3249:22,
3326:15, 3328:5, 3328:6, 3328:25,
3223:11, 3223:14, 3226:22, 3227:13,
3262:4, 3262:25, 3265:22, 3267:14,
3329:4, 3329:12, 3329:18, 3330:24,
3228:2,
3228:5,
3228:6,
3228:9,
3415:18, 3417:3, 3417:6, 3418:22,
3331:20, 3331:21, 3332:2, 3332:4,
3228:14, 3228:16, 3229:2, 3229:8,
3419:21, 3420:10, 3420:20, 3421:23,
3332:6, 3332:7, 3334:12, 3334:14,
3229:13, 3229:16, 3229:19, 3229:21,
3423:12
3342:1, 3350:6, 3350:9, 3350:17,
3229:23,
3230:2,
3230:5,
3230:7,
mortar [2] - 3189:16, 3264:12
3350:21, 3351:20, 3351:23, 3352:25,
3230:10, 3230:14, 3230:18, 3230:20,
most [15] - 3159:13, 3163:23, 3164:3,
3353:4, 3355:21, 3356:1, 3361:3,
3231:23, 3231:25, 3232:1, 3234:4,
3165:1, 3165:3, 3172:10, 3194:24,
3445
3361:6, 3362:6, 3362:9, 3362:10,
3362:12, 3362:13, 3362:16, 3362:19,
3367:1, 3367:3, 3368:9, 3368:11,
3368:12, 3368:14, 3369:2, 3369:4,
3369:20, 3369:23, 3370:22, 3370:25,
3371:8, 3372:10, 3372:12, 3373:12,
3373:14, 3373:25, 3374:5, 3380:7,
3380:11, 3380:13, 3383:7, 3383:9,
3383:17, 3384:12, 3385:5, 3386:13,
3386:16, 3386:18, 3387:1, 3387:3,
3389:8, 3389:14, 3389:22, 3389:24,
3390:2, 3390:4, 3390:21, 3391:3,
3397:21, 3397:24, 3398:4, 3399:2,
3399:4, 3399:6, 3399:7, 3399:10,
3399:19, 3399:21, 3399:24, 3405:15,
3405:18, 3406:6, 3406:9, 3406:18,
3406:21, 3406:23, 3406:25, 3407:2,
3407:9, 3407:11, 3407:15, 3407:17,
3407:22, 3408:8, 3408:10, 3408:16,
3408:19, 3408:22, 3409:2, 3409:21,
3410:5, 3410:8, 3410:9, 3410:11,
3410:15, 3410:16, 3410:17, 3411:1,
3411:5, 3411:8, 3411:14, 3411:25,
3412:4, 3412:6, 3412:8, 3412:10,
3412:13, 3412:17, 3413:1, 3413:11,
3413:19, 3413:24, 3414:7, 3414:17,
3414:18, 3414:21, 3415:8, 3415:15,
3416:1, 3416:3, 3416:8, 3416:11,
3416:20, 3417:11, 3417:14, 3417:22,
3417:25, 3418:8, 3418:10, 3418:11,
3418:13, 3418:21, 3419:25, 3420:4,
3420:8, 3420:13, 3420:17, 3421:18,
3421:20, 3421:25, 3422:5, 3422:6,
3422:10, 3422:15, 3422:18, 3422:22,
3422:24, 3423:10, 3423:19, 3423:22
multibillion [1] - 3360:3
multibillion-dollar [1] - 3360:3
multiple [3] - 3160:12, 3218:4,
3411:18
multitude [1] - 3232:11
mumble [1] - 3411:8
mushrooming [1] - 3165:25
must [3] - 3237:3, 3237:4, 3397:18
Navigant [7] - 3413:5, 3413:7, 3413:9,

nice [9] - 3320:22, 3320:23, 3320:25,
3413:12, 3413:14, 3413:16, 3414:1
3321:4, 3321:6, 3321:7, 3321:10,
3321:11, 3321:13
Navy [1] - 3350:12
niece [1] - 3160:5
near [4] - 3197:13, 3302:22, 3388:5,
night [3] - 3267:1, 3282:24, 3415:18
3388:8
necessary [6] - 3179:13, 3189:18,
nobody [16] - 3176:16, 3235:9,
3221:15, 3383:14, 3412:22, 3421:2
3239:11, 3303:11, 3349:22, 3385:23,
3386:2, 3395:24, 3398:12, 3398:16,
necessity [1] - 3417:4
3398:21, 3398:24, 3399:16, 3400:1,
necks [1] - 3265:18
3414:4
need [27] - 3213:19, 3246:6, 3273:21,
nobody's [3] - 3399:25, 3400:2,
3277:18, 3298:12, 3307:18, 3323:25,
3400:6
3331:23, 3341:11, 3343:2, 3343:8,
noise [1] - 3300:12
3361:23, 3383:13, 3384:3, 3384:5,
non [1] - 3325:24
3384:7, 3397:19, 3407:20, 3410:17,
3411:3, 3412:20, 3412:22, 3415:3,
non-es [1] - 3325:24
3418:8, 3419:18, 3419:22, 3422:14
none [5] - 3205:17, 3225:23, 3298:16,
needed [18] - 3157:1, 3201:8, 3201:9,
3299:18, 3326:6
3203:22, 3207:23, 3276:17, 3277:23,
noninterest [1] - 3381:5
3278:8, 3279:12, 3340:14, 3341:9,
Nonresponsive [1] - 3352:25
3365:16, 3371:4, 3371:9, 3371:11,
nonresponsive [24] - 3157:10, 3158:2,
3371:13, 3371:17, 3372:13
3177:1, 3177:4, 3183:16, 3183:23,
needle [1] - 3284:22
3189:2, 3204:5, 3204:7, 3207:10,
needs [7] - 3197:2, 3212:23, 3371:11,
3231:23, 3266:11, 3275:19, 3282:1,
3417:16, 3417:17, 3417:23, 3421:5
3303:3, 3304:15, 3304:17, 3306:1,
negative [16] - 3257:11, 3261:12,
3308:4, 3308:12, 3316:6, 3325:14,
3261:13, 3354:5, 3354:17, 3365:1,
3325:16, 3386:13
3365:2, 3365:12, 3365:16, 3366:7,
nonresponsiveness [1] - 3179:14
3366:23, 3366:25, 3367:5, 3367:6,
normal [2] - 3159:5, 3351:3
3369:15, 3369:17
North [2] - 3160:11, 3176:1
negatively [1] - 3261:20
north [2] - 3203:7, 3204:2
negotiate [1] - 3310:10
Northeast [2] - 3284:23, 3287:21
negotiated [1] - 3301:9
note [4] - 3261:6, 3290:6, 3339:13,
neighborhood [7] - 3150:17, 3199:18,
3342:25
3255:21, 3255:22, 3259:2, 3261:7,
notes [9] - 3155:25, 3253:3, 3253:4,
3281:1
3253:7, 3261:12, 3292:24, 3374:2,
nervous [1] - 3332:6
3384:7
net [4] - 3191:19, 3199:14, 3199:15
nothing [8] - 3177:9, 3217:16, 3220:3,
net-net [1] - 3191:19
3302:16, 3311:22, 3327:25, 3391:24,
netted [1] - 3192:1
3423:19
never [15] - 3168:22, 3222:1, 3224:12,
notifying [1] - 3195:11
3225:24, 3232:12, 3232:13, 3235:6,
November [10] - 3193:25, 3194:16,
3252:11, 3267:7, 3283:23, 3284:1,
3202:20, 3291:18, 3292:17, 3314:2,
3296:13, 3311:19, 3385:24
3332:16, 3364:24, 3366:6
New [7] - 3143:17, 3233:5, 3234:3,
nowhere [1] - 3302:2
N
3234:9, 3234:10, 3422:25, 3423:7
number [46] - 3154:17, 3156:24,
new [17] - 3147:6, 3148:11, 3148:15,
3166:18, 3174:3, 3190:19, 3190:23,
3161:13, 3165:23, 3171:2, 3181:10,
3194:12, 3195:23, 3202:15, 3203:1,
naive [1] - 3267:4
3181:19,
3182:1,
3198:16,
3199:3,
3203:4, 3207:5, 3207:7, 3218:4,
name [12] - 3163:9, 3163:10, 3186:8,
3201:23, 3276:24, 3277:7, 3277:24,
3218:5, 3222:23, 3222:25, 3223:2,
3190:12, 3190:17, 3210:25, 3214:9,
3413:14, 3413:17
3223:4, 3224:23, 3232:9, 3246:9,
3214:11, 3242:15, 3269:21, 3296:4,
newspaper
[1]
3330:12
3251:7, 3255:4, 3255:11, 3255:13,
3402:16
newspapers [3] - 3302:16, 3302:17,
3255:23, 3259:5, 3270:10, 3280:1,
named [2] - 3401:4, 3403:23
3302:19
3288:5, 3305:17, 3324:15, 3324:16,
names [2] - 3208:22, 3373:21
3324:17, 3326:22, 3359:15, 3382:16,
next
[40] - 3162:14, 3181:21, 3194:25,
narrative [1] - 3304:24
3382:17, 3382:22, 3383:19, 3384:20,
3195:17, 3195:21, 3209:2, 3215:19,
narrow [6] - 3146:23, 3146:25,
3384:23, 3401:21, 3423:5
3215:20,
3223:2,
3237:10,
3239:3,
3166:24, 3258:13, 3258:14, 3362:4
3244:25,
3247:12,
3262:4,
3262:16,
Number [2] - 3362:7, 3368:2
narrowed [1] - 3258:16
3262:17,
3267:11,
3267:13,
3268:16,
numbers [18] - 3190:16, 3191:6,
NASD [6] - 3152:9, 3152:10, 3152:14,
3278:8, 3283:13, 3292:24, 3299:5,
3191:8, 3191:9, 3250:25, 3254:4,
3152:24, 3152:25, 3154:2
3306:2, 3336:1, 3338:19, 3339:11,
3254:7, 3256:6, 3276:20, 3360:2,
NASD's [1] - 3153:2
3345:2, 3366:9, 3367:1, 3367:9,
3381:4, 3381:14, 3381:25, 3382:3,
Nashville [1] - 3284:21
3384:9, 3386:16, 3409:21, 3412:23,
3382:5, 3382:11, 3382:13
nature [1] - 3229:10
3414:11, 3414:22, 3414:23, 3416:14
numerous [1] - 3214:16
3446
NW [1] - 3143:17
officing [2] - 3172:25, 3173:1

organizational [1] - 3160:19
offset [3] - 3182:17, 3224:15, 3225:1
organizer [1] - 3164:23
offsetting
[1]
3208:6
organizing [1] - 3164:21
O
offshore [2] - 3210:6, 3210:10
original [4] - 3305:11, 3362:8, 3372:4,
3421:10
often [2] - 3208:25, 3300:11
o'clock [2] - 3247:14, 3421:14
originally [4] - 3210:24, 3375:25,
old [11] - 3373:8, 3388:21, 3392:8,
oath [2] - 3232:8, 3232:10
3382:14, 3403:24
3403:2, 3403:12, 3404:24, 3405:23,
object [45] - 3151:21, 3152:17,
Orlando [1] - 3175:24
3411:17, 3412:7, 3412:10, 3419:4
3153:13, 3158:2, 3161:18, 3167:21,
oldest [1] - 3404:8
otherwise [5] - 3292:23, 3337:1,
3168:3, 3177:1, 3178:22, 3179:14,
3351:6, 3374:16, 3407:21
on-the-record [1] - 3417:17
3183:15, 3189:2, 3204:5, 3204:24,
ought [2] - 3299:19, 3417:8
once [12] - 3160:23, 3216:9, 3223:21,
3205:3, 3207:10, 3208:18, 3208:20,
3224:7, 3224:9, 3224:19, 3265:13,
ourselves [1] - 3423:2
3212:19, 3213:15, 3214:12, 3215:14,
3276:23, 3279:11, 3294:1, 3369:17,
outgoing [1] - 3192:2
3220:16, 3228:5, 3230:11, 3231:23,
3419:17
outgoings [1] - 3194:23
3235:13, 3238:23, 3239:13, 3252:13,
one [80] - 3146:18, 3152:9, 3162:6,
outlying [3] - 3219:13, 3219:14,
3256:9, 3258:11, 3260:8, 3260:19,
3171:18, 3175:17, 3175:19, 3176:5,
3219:17
3266:11, 3268:21, 3275:19, 3277:17,
3179:5, 3202:15, 3208:24, 3212:9,
outside [13] - 3218:18, 3227:1,
3282:1, 3286:6, 3308:19, 3383:7,
3214:15, 3215:16, 3232:9, 3234:16,
3232:18, 3280:15, 3280:22, 3281:5,
3386:13, 3407:9, 3410:22
3235:4, 3239:15, 3241:21, 3241:23,
3281:24, 3290:1, 3344:11, 3397:4,
objecting [2] - 3308:19, 3308:20
3241:24, 3243:13, 3245:17, 3252:8,
3409:17, 3413:15, 3415:11
objection [38] - 3154:21, 3155:14,
3256:1, 3256:14, 3260:4, 3263:6,
overall [2] - 3151:10, 3382:13
3168:10, 3179:6, 3208:24, 3213:5,
3263:17, 3270:9, 3271:9, 3275:24,
overdraft [2] - 3366:14, 3366:18
3244:19, 3244:21, 3269:16, 3269:17,
3277:1, 3283:2, 3285:3, 3289:12,
overdrafts [1] - 3366:20
3270:2, 3274:2, 3278:13, 3296:15,
3307:4, 3308:10, 3315:8, 3331:7,
overhead [4] - 3187:5, 3187:6,
3296:22, 3297:14, 3306:1, 3308:18,
3335:3, 3338:5, 3343:19, 3345:3,
3248:23, 3291:19
3311:3, 3311:9, 3315:19, 3322:14,
3347:7, 3348:16, 3348:20, 3358:14,
overpaid [1] - 3215:10
3323:4, 3328:25, 3329:8, 3352:25,
3360:25, 3361:16, 3361:19, 3362:1,
overrule [4] - 3274:1, 3296:20,
3355:21, 3362:9, 3362:10, 3362:11,
3364:7, 3364:13, 3366:8, 3368:4,
3296:22, 3329:8
3362:14, 3368:12, 3399:2, 3399:19,
3368:21, 3375:15, 3380:25, 3384:20,
overruled [18] - 3161:20, 3168:20,
3406:6, 3406:18, 3408:8, 3414:4
3385:16, 3387:22, 3388:20, 3394:14,
3205:5,
3215:15, 3220:19, 3228:7,
objections [1] - 3407:14
3395:23, 3397:19, 3400:16, 3401:2,
3230:13, 3234:18, 3235:15, 3238:25,
obligated [1] - 3190:25
3409:24, 3410:16, 3410:17, 3411:21,
3239:14, 3252:15, 3256:11, 3282:3,
observing [1] - 3175:9
3413:2, 3413:3, 3413:14, 3413:15,
3296:20, 3308:21, 3386:14
obstruction [1] - 3395:21
3414:8, 3418:18, 3421:16, 3421:18
oversaw [1] - 3160:11
obtain [5] - 3200:5, 3243:3, 3291:3,
ones [4] - 3244:6, 3278:20, 3360:24,
oversight [1] - 3375:4
3327:23, 3352:13
3397:2
owed [2] - 3180:2, 3225:5
obtained [3] - 3243:5, 3413:4, 3413:9
ongoing [4] - 3152:4, 3157:19, 3175:8,
own [8] - 3151:2, 3201:20, 3211:23,
obtaining [2] - 3242:8, 3415:2
3176:24
3212:2, 3214:9, 3339:19, 3342:2,
obviously [2] - 3252:18, 3299:7
open [7] - 3147:20, 3148:3, 3148:6,
3343:17
occurred [1] - 3349:18
3148:25, 3165:6, 3256:14, 3331:15
owned [24] - 3147:25, 3149:10,
October [14] - 3190:8, 3190:14,
opened [2] - 3148:23, 3294:6
3150:19, 3150:20, 3150:21, 3150:23,
3190:25, 3191:13, 3192:14, 3192:17,
opening [4] - 3147:16, 3164:25,
3151:1, 3184:22, 3187:22, 3205:16,
3192:21, 3193:4, 3193:17, 3199:25,
3286:9, 3411:15
3209:17, 3215:22, 3230:11, 3251:13,
3203:14, 3204:11, 3207:14, 3303:7
opens [1] - 3149:14
3251:15, 3251:17, 3269:22, 3271:6,
odd [1] - 3326:22
opera [2] - 3406:21, 3413:7
3339:23, 3340:24, 3360:24, 3360:25,
OF [2] - 3143:1, 3143:4
operate [1] - 3211:23
3372:5
offer [3] - 3236:9, 3362:6, 3368:9
operating [2] - 3381:1, 3381:14
owner [2] - 3290:10, 3343:22
offered [1] - 3274:8
operation [1] - 3360:3
ownership [3] - 3149:5, 3209:18,
offering [1] - 3272:9
opinion [1] - 3240:5
3215:22
office [10] - 3168:15, 3169:3, 3173:14,
opportunity [5] - 3148:16, 3148:17,
owning [1] - 3214:9
3231:7, 3242:14, 3266:4, 3287:3,
3155:4, 3156:8, 3202:2
owns [3] - 3271:24, 3317:9, 3349:8
3287:11, 3346:20, 3363:3
opposed [5] - 3212:15, 3213:10,
officer [20] - 3153:3, 3169:2, 3233:19,
3214:8, 3308:19, 3312:18
P
3233:20, 3238:7, 3244:1, 3245:2,
opposite [1] - 3283:10
3267:17, 3267:24, 3268:19, 3269:4,
Oracle [5] - 3285:25, 3391:19,
3269:9, 3270:6, 3270:13, 3322:7,
p.m [3] - 3257:20, 3331:8, 3424:2
3391:21, 3392:4, 3393:2
3356:9, 3358:5, 3386:24, 3401:4,
pace [2] - 3161:10, 3330:6
order [6] - 3148:20, 3196:5, 3207:23,
3411:5
pad [2] - 3390:15, 3390:18
3255:5, 3347:1, 3423:8
officers [2] - 3237:5, 3237:19
page [17] - 3154:16, 3155:7, 3190:10,
ORDERED [1] - 3331:12
offices [9] - 3149:1, 3162:23, 3176:1,
3194:2, 3194:9, 3194:19, 3195:7,
orders [1] - 3412:9
3176:2, 3189:15, 3231:14, 3234:10,
3195:21, 3202:8, 3237:10, 3324:1,
organization [7] - 3173:9, 3233:8,
3243:23, 3288:1
3367:1, 3370:23, 3370:24, 3383:19,
3237:20, 3256:5, 3271:3, 3357:13,
officially [1] - 3424:1
3386:16, 3386:17
3358:1
3447
3337:4
Page [4] - 3237:10, 3367:2, 3380:7,
persons [1] - 3401:3
paying [9] - 3148:19, 3161:12, 3166:5,
3381:19
perspective [2] - 3170:25, 3174:8
3166:6, 3181:25, 3216:2, 3318:15,
PAGE [1] - 3145:2
persuade [1] - 3148:14
3337:23, 3371:13
pages [2] - 3324:8
pertaining [1] - 3188:2
payments [4] - 3292:25, 3339:13,
paid [15] - 3158:10, 3164:19, 3171:3,
pertains [1] - 3225:3
3340:15, 3342:25
3215:7, 3216:7, 3223:3, 3225:13,
Peter [1] - 3242:15
payroll [3] - 3292:22, 3336:4, 3336:5
3290:12, 3290:15, 3328:21, 3337:25,
Phoenix [1] - 3242:5
Pendergest [2] - 3401:5, 3406:24
3338:2, 3342:25, 3371:16, 3371:17
phone [19] - 3162:21, 3195:14,
pains [1] - 3235:8
pending [1] - 3321:16
3238:13, 3238:14, 3238:16, 3239:25,
panic [3] - 3162:5, 3162:9, 3162:10
pension [1] - 3294:17
3245:5, 3291:23, 3293:7, 3302:22,
panicked [1] - 3400:18
people [59] - 3152:6, 3164:4, 3168:2,
3318:24, 3328:8, 3332:8, 3332:12,
3168:5, 3168:7, 3172:7, 3172:17,
paper [7] - 3200:9, 3200:10, 3200:13,
3332:18, 3332:20, 3332:22, 3333:23,
3173:3, 3173:15, 3174:16, 3174:24,
3200:17, 3347:14, 3347:16, 3348:9
3333:25
3176:2, 3176:17, 3177:2, 3192:15,
paperwork [1] - 3221:15
phonied [3] - 3382:16, 3382:17,
3198:22, 3199:2, 3200:16, 3201:8,
3382:22
paragraph [7] - 3155:6, 3155:8,
3201:9, 3201:21, 3212:20, 3239:12,
phony [4] - 3304:6, 3383:19, 3384:20,
3155:12, 3156:8, 3202:7, 3202:8,
3239:23, 3244:6, 3254:1, 3255:7,
3202:10
3385:16
3255:19, 3256:4, 3256:8, 3257:4,
parcel [2] - 3215:21, 3219:20
photo [1] - 3332:18
3257:5, 3258:8, 3258:12, 3258:15,
parcels [7] - 3208:10, 3211:6,
photocopy [2] - 3317:17, 3317:18
3258:21, 3259:8, 3259:13, 3260:3,
3214:25, 3215:25, 3219:1, 3223:1,
photograph [2] - 3317:16, 3332:12
3260:5, 3260:15, 3260:17, 3261:22,
3223:19
photographed [1] - 3333:15
3262:8, 3262:9, 3262:17, 3263:5,
PARRAS [2] - 3416:11, 3418:11
photos [1] - 3321:3
3272:13, 3272:16, 3279:3, 3280:13,
Parras [2] - 3144:2, 3415:12
phrase [1] - 3221:8
3281:15, 3342:10, 3374:20, 3374:21,
part [24] - 3183:22, 3204:25, 3205:3,
phrased [1] - 3269:16
3374:23, 3380:5, 3403:1, 3407:4
3210:18, 3224:13, 3266:16, 3319:4,
physically [2] - 3233:21, 3239:12
per [6] - 3166:1, 3181:1, 3181:2,
3319:18, 3322:4, 3324:7, 3324:19,
pick [1] - 3257:13
3217:4, 3223:6, 3241:1
3326:16, 3327:8, 3327:16, 3337:13,
picked [1] - 3196:7
percent [20] - 3151:12, 3166:12,
3346:7, 3361:17, 3379:18, 3379:19,
picture [10] - 3291:22, 3292:14,
3166:13, 3166:23, 3167:7, 3202:22,
3379:20, 3382:13, 3395:20, 3395:22,
3314:14, 3314:22, 3314:25, 3316:1,
3202:23, 3220:6, 3220:14, 3230:11,
3413:8
3317:8, 3317:13, 3328:8
3251:23, 3252:19, 3253:21, 3255:2,
parte [3] - 3410:8, 3410:10, 3415:1
pictures [1] - 3321:2
3261:14, 3281:1, 3281:2, 3281:5,
participate [1] - 3233:23
pie [9] - 3249:24, 3253:25, 3254:3,
3349:9, 3419:20
participated [1] - 3153:19
3258:4, 3260:3, 3262:7, 3262:10,
percentage [13] - 3151:10, 3152:3,
participating [3] - 3153:24, 3174:4,
3265:8, 3266:6
3152:5, 3154:4, 3154:7, 3154:10,
3239:24
piece [4] - 3218:9, 3253:3, 3261:17,
3157:3, 3157:4, 3157:6, 3157:16,
particular [5] - 3184:15, 3219:20,
3395:1
3166:7, 3280:21
3285:5, 3334:7, 3355:4
pieces [6] - 3207:25, 3252:22, 3335:2,
percentage-wise [1] - 3166:7
particularly [2] - 3356:14, 3356:16
3341:17, 3395:6, 3396:25
percentages [1] - 3280:24
parties [2] - 3271:18
pilots [1] - 3175:2
perform [1] - 3165:22
partner [2] - 3343:23, 3412:7
place [37] - 3153:24, 3160:23,
performance [1] - 3289:6
parts [1] - 3173:9
3166:19, 3171:22, 3177:19, 3184:13,
Performers [1] - 3163:11
party [5] - 3270:8, 3271:19, 3272:22,
3196:12, 3196:14, 3211:8, 3216:14,
performing [2] - 3181:9, 3181:12
3273:13, 3273:15
3216:23, 3221:25, 3231:13, 3231:14,
perhaps [1] - 3412:21
part [1] - 3410:11
3231:16, 3232:21, 3233:7, 3235:7,
period [5] - 3192:22, 3305:17,
pass [4] - 3295:19, 3354:14, 3354:15,
3235:8, 3237:6, 3240:8, 3240:9,
3310:25, 3343:4, 3394:12
3418:21
3240:16, 3241:8, 3243:17, 3262:21,
perjure [1] - 3283:3
3274:19, 3275:4, 3279:15, 3279:24,
pass-through [2] - 3354:14, 3354:15
permanent [1] - 3173:16
3280:19, 3282:15, 3290:3, 3295:21,
passed [1] - 3349:16
permanently [1] - 3172:9
3347:23, 3388:5, 3391:22
passes [1] - 3354:3
permission [2] - 3291:4, 3349:7
placed [2] - 3151:19, 3252:17
passing [2] - 3173:2, 3285:1
perpetuating [1] - 3379:11
places [1] - 3202:23
password [4] - 3391:10, 3391:14,
person [9] - 3162:21, 3183:12,
plan [7] - 3178:15, 3204:3, 3204:10,
3391:17, 3391:18
3256:10, 3273:17, 3273:19, 3337:21,
3225:9, 3225:16, 3244:8, 3281:17
past [5] - 3147:7, 3173:20, 3242:16,
3338:1, 3408:5, 3414:1
plane [1] - 3423:9
3373:24, 3412:17
personal [20] - 3285:24, 3302:3,
planes [1] - 3171:13
Patlan [2] - 3194:3, 3194:7
3322:16, 3323:9, 3323:18, 3326:7,
plans [2] - 3188:8, 3188:10
Patricia [6] - 3185:9, 3348:2, 3349:16,
3326:11, 3327:24, 3340:19, 3340:20,
platoon [1] - 3176:2
3352:4, 3352:5, 3352:6
3344:2, 3387:15, 3391:8, 3392:10,
play [3] - 3192:19, 3239:7, 3375:24
pause [1] - 3403:16
3392:14, 3392:23, 3393:5, 3393:7,
played [3] - 3193:1, 3193:5, 3411:16
pay [16] - 3148:22, 3161:14, 3171:7,
3393:25, 3408:22
3171:9, 3182:23, 3191:1, 3197:2,
plea [12] - 3310:12, 3322:4, 3323:2,
personally [4] - 3212:16, 3214:8,
3199:6, 3200:16, 3211:6, 3225:7,
3323:6, 3323:11, 3324:19, 3324:24,
3349:21, 3366:5
3225:20, 3290:22, 3325:12, 3328:15,
3328:3, 3337:13, 3395:20, 3395:22
personnel [1] - 3392:24
3448
3350:10, 3410:4
3336:21
pleaded [1] - 3309:22
present [21] - 3153:17, 3153:18,
produced [3] - 3144:14, 3164:7,
pled [3] - 3179:4, 3295:13, 3300:2
3153:23, 3170:25, 3180:22, 3180:23,
3164:8
plenty [1] - 3379:3
3191:19, 3191:22, 3191:25, 3193:19,
Producer [3] - 3163:12, 3163:20,
plug [1] - 3255:17
3239:12, 3239:23, 3244:11, 3263:3,
3165:7
plugs [1] - 3393:17
3266:7, 3266:18, 3272:13, 3272:16,
producer [1] - 3164:2
plummeting [2] - 3220:12, 3220:13
3272:18, 3278:19
Producers [2] - 3163:13, 3241:18
plus [2] - 3254:18, 3290:17
presentation [7] - 3243:16, 3262:16,
product [2] - 3163:18, 3163:19
PO [2] - 3143:14, 3144:7
3263:2, 3263:7, 3264:3, 3265:7,
production [1] - 3287:17
pocket [2] - 3347:11, 3368:7
3266:17
products [4] - 3155:9, 3158:7,
point [48] - 3157:25, 3160:19, 3161:9,
presenters [1] - 3266:17
3159:15, 3164:10
3161:25, 3174:10, 3176:3, 3176:12,
preserve [3] - 3317:14, 3318:1,
profit [8] - 3166:22, 3276:20, 3380:19,
3181:22, 3181:24, 3184:23, 3188:7,
3318:10
3380:21, 3380:23, 3381:14, 3382:14,
3188:11, 3189:17, 3192:19, 3193:13,
president [13] - 3153:4, 3183:13,
3382:15
3193:22, 3195:16, 3196:13, 3199:18,
3183:24, 3233:17, 3233:18, 3238:6,
program [10] - 3152:2, 3163:5, 3163:7,
3199:20, 3205:19, 3210:25, 3218:14,
3238:20, 3243:25, 3244:4, 3261:23,
3163:9, 3163:10, 3165:24, 3171:1,
3227:16, 3235:4, 3235:23, 3239:12,
3264:18, 3264:24, 3268:1
3232:19, 3277:4, 3277:5
3247:2, 3262:8, 3265:7, 3272:1,
presidents [1] - 3148:12
project [8] - 3191:17, 3210:8, 3210:23,
3277:21, 3288:20, 3289:2, 3297:20,
Preston [1] - 3144:3
3298:18, 3299:19, 3311:14, 3312:4,
3210:25, 3211:3, 3293:24, 3328:24,
presume [2] - 3315:17, 3317:2
3312:16, 3319:8, 3358:14, 3371:15,
3329:2
pretty [8] - 3174:7, 3174:8, 3174:9,
3371:16, 3407:3, 3411:18, 3419:24
projects [2] - 3174:14, 3360:22
3195:16, 3320:25, 3365:11, 3371:21,
pointed [1] - 3312:24
promised [1] - 3283:23
3395:19
points [3] - 3278:16, 3280:6, 3280:7
promoted [1] - 3172:19
previous [3] - 3148:13, 3246:24,
portfolio [6] - 3166:9, 3196:17,
promotion [1] - 3271:5
3283:5
3196:20, 3237:17, 3239:5, 3266:24
promotional [4] - 3169:17, 3170:5,
previously [6] - 3177:14, 3180:7,
portion [6] - 3185:4, 3191:12, 3206:18,
3170:7, 3170:8
3238:9, 3281:14, 3290:7, 3369:5
3207:3, 3222:14
proof [2] - 3318:17, 3318:18
price [7] - 3215:6, 3215:10, 3215:12,
portions [2] - 3154:22, 3156:1
properly [1] - 3338:18
3216:4, 3216:6, 3223:3, 3252:10
portrayed [1] - 3208:19
property [2] - 3219:25, 3223:8
primarily [4] - 3147:24, 3155:8,
position [10] - 3148:17, 3169:7,
proposal [1] - 3280:17
3160:1, 3184:17
3174:14, 3202:24, 3278:18, 3278:21,
proposals [2] - 3280:1, 3280:5
primary [2] - 3273:17, 3273:19
3298:15, 3366:18, 3413:4, 3418:1
propose [5] - 3273:1, 3274:23,
printing [1] - 3169:17
positions [3] - 3179:13, 3194:22,
3276:12, 3278:11, 3279:12
priority [1] - 3202:16
3194:25
proposed [11] - 3198:12, 3198:13,
private [16] - 3171:14, 3171:18,
positive [1] - 3257:8
3199:16, 3200:5, 3220:25, 3221:2,
3174:15, 3174:21, 3184:19, 3184:22,
possibility [1] - 3147:16
3221:10, 3225:23, 3274:12, 3275:1,
3248:7, 3249:25, 3251:11, 3252:17,
possible [8] - 3167:14, 3167:19,
3280:2
3252:22, 3252:25, 3253:10, 3259:16,
3169:8, 3319:17, 3319:20, 3403:4,
prosecution [1] - 3235:3
3261:17, 3301:12
3420:8, 3422:3
prosecutor [2] - 3306:10, 3311:11
privately [1] - 3265:24
possibly [6] - 3150:9, 3198:15,
prosecutors [18] - 3301:10, 3301:25,
privilege [16] - 3230:5, 3230:9,
3201:23, 3291:18, 3348:15, 3364:5
3302:9, 3303:13, 3304:10, 3305:16,
3230:12, 3234:17, 3234:21, 3234:23,
post [1] - 3363:3
3306:7, 3310:15, 3311:2, 3311:5,
3234:24, 3296:15, 3298:5, 3298:13,
poster [1] - 3209:1
3327:3, 3328:1, 3335:4, 3335:11,
3299:16, 3300:3, 3300:13, 3300:15,
potential [5] - 3170:17, 3171:7,
3336:21, 3338:12, 3385:14, 3400:1
3300:17, 3300:18
3173:11, 3173:15
Proskauer [1] - 3234:8
privileged [2] - 3154:14, 3296:16
pound [1] - 3194:25
prospective [1] - 3200:23
probability [1] - 3279:8
power [1] - 3352:12
PROSPECTIVE [1] - 3336:2
problem [15] - 3161:4, 3161:6, 3161:8,
practice [2] - 3170:20, 3170:21
protect [1] - 3298:15
3163:6, 3165:22, 3198:7, 3214:17,
prayer [1] - 3268:8
prove [3] - 3291:25, 3292:1, 3292:6
3254:15, 3260:12, 3275:24, 3299:23,
precise [2] - 3168:9, 3168:11
provide [8] - 3202:17, 3231:19,
3338:16, 3411:10, 3415:25, 3416:10
prejudiced [1] - 3417:19
3271:4, 3276:3, 3349:9, 3349:11,
problems [2] - 3161:3, 3361:16
3413:13, 3415:3
preparation [2] - 3241:15, 3243:15
procedure [1] - 3303:23
provided [1] - 3289:5
prepare [4] - 3303:18, 3305:8,
proceed [4] - 3146:3, 3213:25,
3337:21, 3346:6
providing [2] - 3196:23, 3416:5
3295:25, 3331:20
prepared [9] - 3248:3, 3250:2,
provision [2] - 3366:14, 3366:18
proceedings [1] - 3424:6
3250:20, 3316:21, 3359:3, 3372:15,
public [1] - 3290:11
Proceedings [1] - 3144:14
3375:2, 3379:17, 3381:19
publicly [1] - 3204:19
process [8] - 3157:18, 3178:18,
preparer [1] - 3338:1
published [3] - 3250:8, 3250:9,
3211:3, 3232:20, 3252:11, 3252:23,
prepares [1] - 3374:19
3379:17
3277:10, 3415:2
preparing [6] - 3284:17, 3305:15,
pull [7] - 3187:9, 3187:10, 3201:22,
processes [1] - 3159:5
3305:19, 3305:22, 3335:12, 3386:3
3247:21, 3331:25, 3332:3, 3371:6
processing [1] - 3389:9
presence [4] - 3300:24, 3331:9,
pulled [2] - 3253:5, 3418:15
produceRMR,
[4] - 3171:2, 3237:3, 3237:4,
Johnny C. Sanchez,
CRR - jcscourtreporter@aol.com
3449
3212:14, 3214:5, 3226:17, 3239:20,
raising [1] - 3226:6
3270:12, 3318:10, 3343:7, 3355:12
ran [1] - 3317:20
reasons [4] - 3174:3, 3226:19,
ranching [1] - 3377:8
3235:10, 3343:3
range [4] - 3150:8, 3166:15, 3166:23,
recap [1] - 3284:8
3167:4
recapitalize [1] - 3328:20
rapid [1] - 3330:6
receivable [3] - 3253:3, 3261:6,
rate [20] - 3147:2, 3147:4, 3147:7,
3261:12
3147:9, 3154:8, 3159:8, 3159:12,
receive [5] - 3191:10, 3293:5, 3295:3,
3166:4, 3166:5, 3182:19, 3191:19,
3318:24, 3319:9
3191:22, 3191:25, 3192:1, 3192:6,
received [8] - 3185:6, 3185:7, 3237:22,
3193:19, 3199:4, 3414:10, 3415:16
3314:18, 3324:23, 3324:25, 3397:5,
rates [1] - 3202:1
3398:15
rather [5] - 3155:21, 3174:13, 3213:15,
receiver [19] - 3230:9, 3234:23,
3223:18, 3320:20
3234:25, 3235:1, 3294:4, 3315:15,
ratio [2] - 3202:22, 3202:23
3315:20, 3316:25, 3317:3, 3317:5,
RE [2] - 3340:9, 3340:12
3326:20, 3327:1, 3327:7, 3327:11,
rea [1] - 3418:17
3327:14, 3327:23, 3340:7, 3352:9,
reach [3] - 3246:20, 3290:20, 3420:11
3413:8
reaching [1] - 3347:11
receiver's [5] - 3315:16, 3315:22,
react [2] - 3256:8, 3262:3
3337:19, 3349:23, 3360:7
reacted [2] - 3261:24, 3262:4
reception [1] - 3266:3
reaction [6] - 3256:16, 3256:25,
recess [2] - 3295:22, 3391:1
3257:2, 3260:4, 3262:17, 3280:4
Recessed [4] - 3206:2, 3257:20,
read [20] - 3155:11, 3155:22, 3187:25,
3331:8, 3424:2
3191:15, 3194:19, 3202:10, 3237:2,
recognition [1] - 3163:23
3248:6, 3291:12, 3292:20, 3292:21,
recognize [5] - 3206:22, 3236:5,
3334:16, 3334:18, 3339:12, 3345:5,
3247:25, 3292:10, 3292:12
3368:16, 3380:9, 3397:23, 3397:25,
recollection [3] - 3150:16, 3155:17,
3412:23
3356:3
Q
reading [9] - 3155:13, 3187:23,
recommend [1] - 3160:6
3194:5, 3207:5, 3224:4, 3237:3,
recommendation [1] - 3281:24
3248:5, 3271:10, 3334:16
quadrant [2] - 3251:9, 3259:20
reconstruct [1] - 3396:9
reads [8] - 3185:20, 3186:18, 3187:18,
qualified [2] - 3160:18, 3176:2
reconstructed [1] - 3396:16
3189:9, 3190:16, 3194:11, 3225:10,
quarter [8] - 3166:2, 3181:13, 3181:15,
record [9] - 3236:17, 3236:22, 3292:5,
3249:25
3181:16, 3181:17, 3199:22, 3199:24,
3412:6, 3413:25, 3414:5, 3417:17,
ready [14] - 3146:3, 3146:4, 3165:6,
3215:5
3418:3, 3424:6
3235:12, 3247:7, 3257:18, 3262:5,
quarterly [2] - 3163:10, 3163:16
recorded [1] - 3144:14
3304:7, 3379:7, 3391:2, 3410:1,
questioned [1] - 3311:20
3417:3, 3419:3, 3419:24
recordkeeping [1] - 3374:3
questioning [5] - 3167:22, 3168:17,
real [72] - 3174:14, 3176:3, 3184:19,
records [13] - 3200:8, 3328:11,
3170:3, 3170:9
3184:22, 3208:9, 3209:17, 3209:21,
3335:18, 3337:16, 3337:17, 3337:19,
questions [17] - 3155:19, 3184:15,
3210:4, 3210:7, 3211:20, 3212:3,
3352:10, 3360:6, 3360:7, 3360:8,
3264:14, 3299:17, 3305:18, 3305:24,
3212:15, 3213:10, 3215:21, 3216:11,
3373:23, 3385:11, 3385:15
3306:6, 3307:11, 3307:14, 3308:20,
3217:3, 3217:20, 3218:10, 3218:13,
recreate [1] - 3398:16
3323:22, 3362:3, 3383:12, 3385:21,
3218:14, 3220:13, 3223:1, 3223:20,
rectangle [1] - 3389:1
3398:15, 3400:11, 3422:16
3224:2, 3225:6, 3225:11, 3225:24,
redeemed [1] - 3182:19
queue [1] - 3246:4
3251:23, 3252:3, 3252:6, 3252:9,
redeeming [1] - 3182:1
quick [1] - 3226:9
3253:19, 3254:15, 3254:17, 3254:18,
redemptions [10] - 3146:20, 3146:21,
quicker [1] - 3304:25
3259:14, 3261:15, 3264:11, 3264:12,
3147:2, 3184:23, 3196:5, 3196:7,
quickly [1] - 3415:14
3278:22, 3292:25, 3320:5, 3340:13,
3196:11, 3196:13, 3255:5, 3328:16
quit [5] - 3173:21, 3174:2, 3177:8,
3340:14, 3340:15, 3340:18, 3340:22,
redirect [1] - 3384:8
3178:13, 3312:4
3340:24, 3340:25, 3341:1, 3341:2,
reestablish [1] - 3397:7
quite [5] - 3162:5, 3169:6, 3400:15,
3341:3, 3341:9, 3341:17, 3341:19,
refer [3] - 3288:15, 3373:12, 3373:20
3411:9, 3415:15
3343:1, 3343:4, 3354:2, 3354:8,
reference [2] - 3167:2, 3353:13
quote [1] - 3230:23
3358:12, 3361:11, 3361:13, 3361:18,
referenced [2] - 3154:19, 3154:20
3361:20, 3365:19, 3385:15, 3385:24,
referred [4] - 3354:25, 3369:6,
R
3386:6, 3386:8, 3386:10, 3386:12
3373:24, 3381:1
reality [1] - 3263:19
referring [12] - 3210:11, 3222:11,
really [10] - 3176:17, 3176:22,
3242:20, 3256:10, 3309:13, 3309:16,
raise [7] - 3177:10, 3177:12, 3203:7,
3176:25, 3179:12, 3198:3, 3224:12,
3327:6, 3327:21, 3327:22, 3340:18,
3205:25, 3277:21, 3297:21, 3299:18
3357:8, 3378:13, 3421:5
3341:16, 3422:8
raised [4] - 3152:14, 3157:25,
rearraignment [1] - 3420:19
refers [2] - 3273:15, 3334:7
3177:13, 3221:22
reason [11] - 3188:25, 3189:6,
pulling [2] - 3201:10, 3347:12
purchase [5] - 3212:15, 3213:10,
3215:6, 3215:10, 3252:10
purchased [13] - 3152:15, 3208:10,
3209:21, 3211:20, 3212:3, 3215:1,
3217:11, 3217:17, 3218:7, 3219:21,
3220:4, 3341:2, 3341:18
purchases [1] - 3170:18
purpose [15] - 3163:15, 3163:17,
3180:20, 3203:19, 3243:11, 3256:24,
3272:10, 3274:2, 3274:19, 3288:13,
3334:8, 3355:8, 3355:11, 3407:1
purposes [3] - 3251:19, 3251:21,
3407:1
put [40] - 3151:7, 3153:12, 3163:5,
3163:7, 3179:12, 3199:17, 3217:20,
3217:21, 3245:20, 3249:9, 3249:24,
3251:5, 3262:25, 3268:7, 3269:7,
3286:11, 3293:22, 3316:21, 3317:19,
3319:18, 3329:6, 3359:5, 3360:22,
3364:3, 3364:16, 3365:17, 3365:19,
3374:24, 3383:18, 3383:19, 3391:21,
3396:17, 3412:12, 3412:15, 3413:25,
3414:5, 3415:6, 3416:13, 3417:2
puts [1] - 3369:16
putting [4] - 3286:14, 3308:11, 3416:4,
3423:11
pyramid [1] - 3176:24
3450
3226:11, 3243:11, 3278:12
reflect [4] - 3224:6, 3276:21, 3372:20,
respect [4] - 3253:10, 3307:20,
reminded [1] - 3411:17
3372:21
3326:8, 3413:11
reflected [2] - 3259:20, 3261:7
remorse [2] - 3265:16, 3265:17
respectfully [2] - 3183:21, 3229:21
refreshing [1] - 3155:17
remuneration [2] - 3148:16, 3148:18
respects [1] - 3378:9
regarding [21] - 3152:14, 3177:22,
renew [1] - 3270:2
respond [2] - 3228:6, 3338:10
3183:23, 3191:17, 3192:16, 3234:15,
renovation [1] - 3293:24
responded [1] - 3264:25
3235:25, 3242:17, 3261:6, 3276:12,
repaid [2] - 3289:16, 3290:7
responding [1] - 3319:11
3277:16, 3277:24, 3278:7, 3278:8,
repay [2] - 3149:8, 3150:24
response [10] - 3156:20, 3213:18,
3280:8, 3280:17, 3285:7, 3294:8,
3231:20, 3240:24, 3293:5, 3319:4,
repeat [5] - 3155:6, 3173:10, 3189:23,
3301:4, 3398:8, 3410:19
3319:10, 3366:15, 3366:16, 3386:15
3289:1, 3351:6
regardless [4] - 3329:21, 3329:24,
responsibility [2] - 3357:1, 3357:4
rephrase [6] - 3183:18, 3183:25,
3330:3, 3372:4
3184:2, 3231:24, 3304:23, 3305:14
responsible [1] - 3263:14
region [2] - 3158:21, 3175:16
replace [3] - 3159:24, 3257:24, 3334:2
responsive [2] - 3179:16, 3383:7
regional [1] - 3160:10
replaced [4] - 3159:18, 3160:2,
rest [6] - 3414:11, 3414:22, 3415:3,
regions [2] - 3151:16, 3160:12
3169:19, 3276:24
3416:1, 3416:2, 3416:15
registered [1] - 3347:16
replicate [2] - 3318:23, 3319:2
restate [2] - 3276:15, 3276:16
regular [3] - 3170:20, 3279:20,
replied [1] - 3177:24
restated [3] - 3275:2, 3275:10,
3279:22
3275:11
reply [1] - 3167:18
regulating [1] - 3152:11
restatement [1] - 3277:10
report [22] - 3160:24, 3166:4, 3202:6,
regulator [2] - 3153:7, 3153:11
restaurant [1] - 3343:21
3221:20, 3240:25, 3250:8, 3250:11,
regulators [7] - 3152:7, 3152:8,
3289:10, 3374:12, 3374:13, 3374:14,
restraints [2] - 3175:9, 3175:10
3157:16, 3240:25, 3277:1, 3395:2,
3374:15, 3374:19, 3374:24, 3379:15,
restrictions [1] - 3321:18
3395:10
3380:4, 3381:19, 3382:10, 3386:7,
result [4] - 3228:8, 3228:10, 3295:12,
regulatory [1] - 3156:19
3395:1, 3396:7, 3414:4
3380:23
relate [1] - 3168:23
reported [16] - 3167:5, 3170:4, 3203:2,
resume [3] - 3257:18, 3410:2, 3422:3
related [6] - 3152:6, 3159:4, 3206:25,
3254:17, 3255:9, 3255:14, 3255:18,
resumed [2] - 3265:22, 3265:23
3271:5, 3327:15, 3340:21
3262:24, 3264:8, 3283:9, 3330:11,
retails [1] - 3251:8
3357:20, 3357:22, 3357:24, 3357:25
relates [1] - 3181:2
retained [3] - 3413:12, 3413:16,
Reporter [1] - 3144:11
relating [1] - 3168:3
3414:1
REPORTER [1] - 3291:18
relation [1] - 3160:4
retire [1] - 3178:19
REPORTER'S [1] - 3424:3
relationship [21] - 3181:20, 3199:4,
retrieve [1] - 3396:12
reporting [8] - 3166:9, 3166:22,
3252:6, 3310:21, 3310:25, 3343:25,
retrieved [2] - 3287:7, 3396:15
3344:2, 3344:3, 3344:12, 3344:15,
3185:13, 3197:2, 3226:14, 3275:3,
retrofitted [1] - 3275:6
3344:16, 3403:8, 3405:5, 3405:12,
3275:18, 3356:12
return [8] - 3166:23, 3337:7, 3337:9,
3405:25, 3406:24, 3408:5, 3408:24,
reports [5] - 3175:22, 3297:3, 3297:5,
3337:11, 3338:8, 3338:13, 3338:17,
3409:3, 3409:10, 3409:18
3302:2, 3304:5
3359:3
relationships [2] - 3408:20, 3409:1
represent [13] - 3186:1, 3190:23,
returned [2] - 3280:11, 3284:1
relative [4] - 3276:2, 3278:22, 3412:20,
3194:12, 3195:25, 3207:7, 3207:20,
returning [1] - 3209:19
3415:6
3215:24, 3222:23, 3233:1, 3235:5,
returns [13] - 3166:8, 3166:9, 3167:5,
3255:12, 3298:17
relaxed [1] - 3351:25
3167:6, 3167:14, 3167:18, 3168:17,
represented [3] - 3150:6, 3234:22,
relayed [2] - 3154:1, 3296:18
3169:8, 3170:3, 3170:9, 3182:15,
3250:23
relaying [1] - 3168:7
3337:14, 3337:18
represents [4] - 3186:3, 3210:2,
relevance [7] - 3286:6, 3286:7,
revealed [2] - 3311:19, 3396:8
3230:6, 3230:7
3406:19, 3407:11, 3407:14, 3408:10,
Revenue [1] - 3338:7
request [11] - 3183:21, 3187:19,
3408:23
revenue [2] - 3154:10, 3380:24
3188:3, 3189:9, 3196:14, 3199:5,
relevant [2] - 3272:16, 3408:12
revenues [1] - 3380:22
3245:10, 3285:4, 3291:15, 3313:14,
relief [2] - 3195:1, 3195:3
review [5] - 3155:4, 3156:8, 3175:22,
3420:4
relieved [1] - 3256:18
3297:4, 3335:12
requested [1] - 3397:25
remain [2] - 3178:18, 3423:23
reviewed [2] - 3305:5, 3380:4
requesting [1] - 3246:6
remaining [3] - 3191:18, 3191:22,
rich [1] - 3211:6
requests [2] - 3190:24, 3287:16
3225:11
rid [1] - 3169:10
require [5] - 3375:3, 3375:4, 3375:6,
remark [2] - 3240:9, 3348:11
right-hand [2] - 3202:9, 3259:20
3379:19, 3415:5
remember [33] - 3157:23, 3159:21,
rights [1] - 3298:17
required [3] - 3375:1, 3415:7, 3418:17
3215:3, 3230:14, 3260:17, 3261:23,
River [1] - 3162:23
requirement [1] - 3189:12
3261:25, 3264:14, 3270:14, 3309:10,
RMR [2] - 3144:11, 3424:9
requirements [1] - 3202:25
3313:1, 3313:2, 3318:9, 3332:10,
roads [3] - 3219:9, 3219:17, 3219:24
3332:15, 3332:19, 3334:9, 3335:21,
research [6] - 3172:17, 3172:24,
robbed [1] - 3215:11
3335:22, 3335:25, 3348:18, 3348:19,
3172:25, 3173:4, 3177:18, 3178:7
ROBERT [1] - 3143:6
3353:10, 3353:11, 3358:14, 3374:2,
resolution [1] - 3420:5
Robert [2] - 3143:21, 3296:4
3374:8, 3376:17, 3387:6, 3398:8,
resolving [1] - 3192:13
Rodriguez [13] - 3233:17, 3238:6,
3399:12, 3400:5, 3400:21
resort [1] - 3211:4
3238:20, 3243:25, 3245:18, 3246:9,
remind [9] - 3146:16, 3147:13,
resources [2] - 3177:13, 3178:11
3264:17, 3264:20, 3265:2, 3267:19,
3177:21, 3185:12, 3187:21, Johnny
3220:8, C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3451
3281:14, 3282:5, 3282:8
rodriguez [1] - 3246:1
ROI [1] - 3168:2
role [6] - 3239:7, 3239:9, 3270:5,
3270:13, 3271:2, 3375:24
rolled [1] - 3270:10
Ron [1] - 3169:14
room [3] - 3169:2, 3263:5, 3423:1
Rose [1] - 3234:8
Rossi [8] - 3169:14, 3169:15, 3169:23,
3170:1, 3170:6, 3170:11, 3422:10,
3422:16
Rossi's [1] - 3170:2
rotating [1] - 3172:18
Rouge [1] - 3148:24
routing [1] - 3185:14
RPR [1] - 3144:11
Rule [1] - 3274:3
rule [6] - 3235:12, 3319:3, 3319:14,
3417:2, 3417:5, 3417:9
Rules [1] - 3303:22
ruling [5] - 3156:4, 3213:5, 3416:23,
3420:2
run [10] - 3160:18, 3191:19, 3192:6,
3193:19, 3331:5, 3358:1, 3366:6,
3379:16, 3403:19, 3420:2
running [10] - 3161:12, 3244:18,
3244:21, 3278:12, 3378:18, 3419:2,
3420:22, 3421:9, 3421:15, 3421:16
Rusk [1] - 3144:12
rustic [2] - 3321:11, 3321:13
Ruth [14] - 3403:23, 3404:1, 3404:11,
3404:12, 3404:15, 3405:7, 3405:10,
3405:12, 3405:20, 3406:5, 3406:10,
3406:17, 3407:6
3309:20
3399:24, 3405:15, 3405:18, 3406:9,
3406:23, 3407:2, 3407:22, 3408:16,
satisfy [1] - 3271:8
3409:2, 3409:21, 3410:5, 3410:9,
saturation [1] - 3312:4
3410:11, 3410:16, 3412:10, 3412:13,
save [2] - 3293:9, 3361:25
3414:17, 3418:8, 3418:21, 3419:25,
saved [1] - 3395:8
3420:4, 3420:8, 3422:15, 3423:10
saw [11] - 3166:17, 3167:9, 3173:7,
Scardino's [1] - 3410:19
3173:12, 3192:22, 3193:17, 3221:19,
SCARDINO............. [1] - 3145:5
3256:7, 3288:17, 3298:1
scenic [1] - 3321:11
scam [2] - 3176:23, 3176:24
schedule [2] - 3414:12, 3421:21
Scardino [10] - 3143:21, 3143:21,
scheduled [3] - 3282:16, 3420:14,
3261:13, 3286:9, 3296:4, 3296:21,
3422:24
3298:24, 3299:1, 3299:11, 3411:10
scheme [2] - 3200:21, 3295:12
SCARDINO [226] - 3146:22, 3151:21,
Schoblum [3] - 3267:20, 3268:6,
3152:17, 3153:13, 3153:16, 3155:13,
3273:24
3157:8, 3157:10, 3158:2, 3161:18,
scope [3] - 3146:23, 3166:24, 3270:5
3166:24, 3167:20, 3168:1, 3168:18,
3177:1, 3177:4, 3178:22, 3178:25,
scorekeeping [1] - 3356:12
3179:14, 3183:15, 3183:21, 3189:2,
scrambling [1] - 3328:15
3192:20, 3192:23, 3204:5, 3204:7,
screen [11] - 3146:3, 3206:1, 3248:23,
3204:23, 3207:10, 3208:18, 3212:19,
3248:24, 3257:16, 3257:24, 3262:25,
3212:25, 3213:2, 3213:4, 3213:14,
3389:3, 3389:12, 3390:13, 3390:20
3214:12, 3215:14, 3220:16, 3222:10,
screened [1] - 3413:17
3228:5, 3229:13, 3229:21, 3230:2,
scroll [2] - 3369:20, 3370:22
3230:5, 3230:10, 3231:23, 3234:17,
scrutiny [2] - 3157:16, 3157:17
3235:2, 3235:14, 3238:23, 3239:13,
SEALED [1] - 3331:12
3244:18, 3245:10, 3252:13, 3256:9,
seated [6] - 3206:4, 3257:22, 3295:23,
3258:11, 3260:8, 3260:19, 3266:11,
3331:19, 3414:20, 3423:24
3268:21, 3269:15, 3270:2, 3270:14,
SEC [38] - 3152:9, 3154:15, 3156:3,
3272:15, 3273:13, 3274:5, 3274:8,
3156:12, 3157:24, 3171:24, 3227:15,
3275:19, 3277:17, 3278:12, 3282:1,
3227:21, 3228:10, 3231:6, 3232:4,
3286:6, 3286:10, 3286:19, 3291:24,
3232:8, 3232:17, 3232:24, 3233:1,
3292:4, 3295:25, 3296:3, 3296:18,
3234:14, 3235:17, 3235:24, 3236:15,
3296:24, 3298:20, 3299:2, 3299:6,
3237:13, 3237:18, 3238:2, 3239:5,
3299:22, 3300:13, 3301:1, 3303:3,
3240:3, 3240:6, 3240:12, 3241:16,
3303:5, 3304:15, 3304:17, 3305:4,
3243:16, 3266:18, 3281:12, 3281:19,
3305:13, 3306:1, 3306:3, 3307:3,
3282:9, 3282:11, 3282:17, 3283:6,
3308:4, 3308:5, 3308:12, 3308:15,
3284:3, 3284:7, 3284:14
S
3308:18, 3308:24, 3309:1, 3309:5,
SEC's [2] - 3228:20, 3230:21
3309:16, 3309:19, 3311:13, 3313:4,
second [26] - 3154:16, 3155:7, 3161:1,
3313:6, 3315:21, 3315:24, 3316:6,
safe [1] - 3202:14
3176:5, 3185:19, 3186:18, 3194:9,
3316:8, 3316:11, 3321:2, 3321:5,
safely [1] - 3283:1
3195:1, 3195:3, 3195:21, 3202:7,
3322:22, 3322:25, 3323:6, 3323:15,
safety [1] - 3202:15
3202:8, 3212:22, 3221:1, 3234:16,
3323:18, 3323:22, 3323:25, 3324:3,
salaries [5] - 3313:18, 3313:19,
3258:20, 3271:9, 3287:13, 3331:7,
3324:6, 3324:11, 3325:14, 3325:16,
3314:18, 3324:25, 3342:8
3358:10, 3367:4, 3367:6, 3372:11,
3325:18, 3326:2, 3326:15, 3328:5,
salary [2] - 3290:18, 3295:2
3388:19, 3409:24
3328:6, 3329:4, 3329:18, 3330:24,
sales [52] - 3147:6, 3147:9, 3149:23,
secret [1] - 3315:18
3331:20, 3331:21, 3332:2, 3332:4,
3151:15, 3154:10, 3156:11, 3157:2,
section [5] - 3199:14, 3239:10,
3332:6, 3332:7, 3334:12, 3334:14,
3157:6, 3157:14, 3157:15, 3157:21,
3239:15, 3263:1
3342:1, 3350:6, 3350:9, 3350:17,
3158:21, 3158:23, 3159:1, 3159:4,
sectors [2] - 3248:7, 3249:25
3350:21, 3351:20, 3351:23, 3352:25,
3159:8, 3159:12, 3159:14, 3159:16,
securities [12] - 3160:14, 3167:10,
3353:4, 3356:1, 3361:3, 3361:6,
3160:1, 3160:19, 3161:3, 3161:10,
3179:25, 3182:17, 3182:24, 3183:3,
3362:6, 3362:10, 3362:12, 3362:16,
3161:14, 3163:10, 3163:17, 3164:9,
3183:5, 3184:17, 3195:5, 3196:16,
3362:19, 3367:1, 3367:3, 3368:9,
3164:10, 3165:16, 3165:18, 3165:20,
3196:20, 3238:22
3368:11, 3368:14, 3369:2, 3369:4,
3165:22, 3165:25, 3171:2, 3181:9,
Securities [3] - 3236:15, 3237:6,
3369:20, 3369:23, 3370:22, 3370:25,
3181:10, 3181:19, 3182:1, 3192:1,
3327:10
3371:8, 3372:10, 3372:12, 3373:12,
3198:17, 3199:3, 3242:8, 3242:21,
Security [1] - 3294:17
3373:14, 3374:5, 3380:7, 3380:11,
3243:4, 3243:5, 3277:24, 3280:9,
see [56] - 3154:24, 3155:10, 3171:8,
3380:13, 3383:7, 3383:9, 3383:17,
3280:10, 3377:7, 3380:22, 3380:23,
3173:4, 3180:6, 3185:22, 3194:21,
3384:12, 3385:5, 3386:13, 3386:16,
3391:22
3203:1, 3206:1, 3213:7, 3231:7,
3386:18, 3387:1, 3387:3, 3389:8,
salespeople [1] - 3163:19
3251:22, 3254:23, 3257:18, 3261:3,
3389:14, 3389:24, 3390:4, 3390:21,
Sanchez [3] - 3144:11, 3424:5, 3424:9
3272:1, 3283:1, 3299:16, 3299:17,
3391:3, 3397:21, 3397:24, 3398:4,
sand [1] - 3232:9
3299:25, 3300:4, 3300:6, 3301:8,
3399:4,
3399:6,
3399:10,
3399:21,
sat [4] - 3262:23, 3263:11, 3307:8,
3301:22, 3311:6, 3313:7, 3313:8,
3452
3318:9, 3319:5, 3335:5, 3335:10,
3335:13, 3335:18, 3337:18, 3341:23,
3346:19, 3351:10, 3353:14, 3353:16,
3362:17, 3362:20, 3364:18, 3370:19,
3380:14, 3381:24, 3388:20, 3388:21,
3394:13, 3396:10, 3396:21, 3397:8,
3410:1, 3410:13, 3419:10, 3420:10
seeing [3] - 3173:16, 3198:2, 3270:14
seeking [3] - 3237:13, 3237:18,
3237:19
seem [1] - 3415:24
seize [1] - 3321:24
seized [14] - 3294:4, 3294:10, 3294:12,
3315:13, 3315:23, 3320:16, 3320:18,
3326:20, 3326:25, 3327:8, 3327:14,
3337:16, 3337:24, 3340:5
selection [1] - 3391:25
self [2] - 3152:11, 3300:15
self-incrimination [1] - 3300:15
self-regulating [1] - 3152:11
sell [12] - 3147:6, 3149:20, 3154:4,
3155:8, 3158:6, 3158:11, 3163:19,
3163:21, 3165:9, 3277:13, 3290:11,
3341:1
selling [4] - 3149:15, 3151:4, 3288:22,
3289:5
send [5] - 3209:22, 3292:18, 3319:9,
3347:3, 3364:16
sending [2] - 3319:11, 3370:8
senior [1] - 3258:5
sense [2] - 3237:9, 3365:18
sent [10] - 3173:25, 3190:15, 3191:16,
3194:18, 3195:8, 3227:1, 3293:4,
3319:20, 3330:20, 3338:23
sentence [1] - 3418:18
separate [3] - 3172:25, 3210:13,
3390:17
separated [2] - 3405:8, 3406:7
sequestered [2] - 3175:21, 3420:23
series [1] - 3163:1
serious [3] - 3228:22, 3229:9, 3230:23
seriously [1] - 3176:23
seriousness [2] - 3228:11, 3228:20
servant [1] - 3271:18
Service [1] - 3338:7
service [5] - 3169:18, 3292:25,
3339:13, 3342:25, 3343:3
services [4] - 3165:2, 3169:15, 3271:5,
3340:15
set [12] - 3154:3, 3164:25, 3165:16,
3176:11, 3186:7, 3208:15, 3214:11,
3214:16, 3219:24, 3364:6, 3364:10,
3364:13
setting [2] - 3165:18, 3175:10
settled [1] - 3153:21
settlement [2] - 3214:3, 3214:5
seven [1] - 3363:10
seventh [1] - 3251:3
seventh-month [1] - 3251:3
several [10] - 3165:12, 3184:8,
3187:18, 3206:10, 3261:22, 3341:17,
3367:15, 3373:7, 3391:6, 3391:7
3253:3, 3268:6, 3421:9, 3421:17

SGC [1] - 3155:8
sidebar [1] - 3410:22
shades [1] - 3419:8
sides [1] - 3421:8
shake [1] - 3390:24
siding [1] - 3421:17
shall [1] - 3295:21
signatory [1] - 3322:16
shape [3] - 3316:3, 3361:24, 3366:23
signature [1] - 3386:22
share [2] - 3241:5, 3306:9
signed [2] - 3324:14, 3325:23
shared [15] - 3153:6, 3162:24,
significant [1] - 3196:11
3177:14, 3204:10, 3235:4, 3263:1,
3263:12, 3267:16, 3268:18, 3274:25,
significantly [1] - 3166:7
3275:14, 3278:16, 3284:14, 3288:6,
silently [1] - 3155:11
3303:11
similar [4] - 3161:4, 3186:8, 3225:18,
shareholder [4] - 3198:13, 3202:21,
3316:4
3203:1, 3260:7
similarly [1] - 3248:22
sharing [1] - 3400:7
simple [1] - 3299:8
sheet [4] - 3198:14, 3200:22, 3255:14,
single [1] - 3237:14
3276:20
sink [1] - 3200:6
shell [14] - 3214:11, 3214:15, 3214:16,
Siragna [1] - 3242:15
3251:16, 3353:23, 3353:24, 3354:1,
sit [2] - 3397:6, 3421:4
3354:6, 3354:8, 3354:15, 3354:17,
site [1] - 3172:8
3354:19, 3354:25, 3355:20
sites [1] - 3172:5
Shepherd [3] - 3408:17, 3408:21,
sitting [8] - 3193:14, 3219:6, 3262:4,
3409:4
3388:20, 3388:21, 3388:23, 3411:2,
shift [2] - 3372:23, 3409:20
3411:23
shit [1] - 3230:23
situation [8] - 3179:22, 3183:8,
shock [4] - 3256:14, 3257:8, 3260:4,
3184:5, 3195:12, 3195:15, 3197:8,
3260:15
3197:15, 3421:22
shocked [2] - 3260:5, 3262:8
six [10] - 3147:8, 3171:18, 3174:21,
shore [3] - 3388:1, 3388:3, 3388:4
3250:10, 3251:3, 3293:1, 3343:10,
short [2] - 3416:18, 3419:23
3351:21, 3362:3, 3363:10
shortly [3] - 3149:15, 3286:16,
six-feet [1] - 3351:21
3332:16
six-month [1] - 3250:10
shoulder [1] - 3268:8
sizzle [1] - 3164:17
show [23] - 3154:22, 3215:19, 3224:2,
Sjoblom [20] - 3233:2, 3233:3,
3235:23, 3246:18, 3257:4, 3257:5,
3233:16, 3233:25, 3234:9, 3234:13,
3262:7, 3268:9, 3274:18, 3284:22,
3234:22, 3235:4, 3235:17, 3235:23,
3291:6, 3318:2, 3318:14, 3319:2,
3244:2, 3244:16, 3278:7, 3278:10,
3323:16, 3335:8, 3335:24, 3336:15,
3278:15, 3279:12, 3279:14, 3280:2,
3349:18, 3367:23, 3373:18
3280:18, 3281:23
showed [15] - 3172:18, 3172:21,
skim [1] - 3295:6
3172:23, 3243:20, 3244:13, 3254:3,
skimming [1] - 3316:2
3254:5, 3256:4, 3258:5, 3260:3,
skirt [2] - 3299:17, 3300:21
3266:5, 3283:24, 3314:19, 3332:12,
skits [1] - 3164:17
3341:10
slow [1] - 3198:16
showing [12] - 3155:1, 3206:15,
slower [2] - 3350:15, 3350:18
3215:23, 3236:2, 3251:9, 3253:22,
slowing [1] - 3174:13
3253:25, 3254:8, 3265:8, 3265:17,
slush [1] - 3176:21
3290:10, 3390:5
small [2] - 3294:17, 3321:13
shown [11] - 3194:6, 3206:23,
smaller [2] - 3217:3, 3219:1
3244:14, 3249:17, 3249:23, 3253:11,
smart [2] - 3241:3, 3241:5
3256:24, 3259:6, 3317:4, 3367:15
snack [1] - 3420:24
shows [8] - 3179:21, 3180:9, 3208:14,
so-called [5] - 3182:25, 3239:10,
3314:14, 3364:17, 3367:4, 3369:8,
3254:6, 3254:17, 3395:1
3381:4
so.. [1] - 3151:16
shut [8] - 3171:24, 3188:12, 3189:7,
soap [2] - 3406:21, 3413:7
3189:12, 3189:18, 3189:21, 3189:24,
sobbed [1] - 3268:2
3190:1
sobbing [1] - 3268:5
shutdown [3] - 3187:23, 3188:2,
sobs [1] - 3262:6
3188:11
SocGen [2] - 3322:20, 3322:23
shutting [2] - 3188:15, 3188:23
Social [1] - 3294:17
SIBL [7] - 3171:6, 3186:2, 3186:21,
sold [5] - 3183:5, 3184:23, 3195:5,
3194:5, 3194:21, 3215:21, 3237:17
3278:1, 3280:12
SIBL's [1] - 3264:23
solicitor [2] - 3378:6, 3378:8
side [7] - RMR,
3185:24,
3250:24,
Johnny C. Sanchez,
CRR3223:12,
- jcscourtreporter@aol.com
3453
3231:1, 3231:8, 3231:11, 3231:18,
spreadsheet [5] - 3206:16, 3206:20,
3231:21, 3232:2, 3232:15, 3232:22,
3222:13, 3223:12, 3285:23
3232:25, 3233:7, 3233:8, 3233:13,
St [5] - 3176:1, 3226:13, 3227:4,
3233:21, 3235:5, 3235:19, 3236:25,
3231:14, 3269:21
3238:8, 3238:12, 3240:1, 3240:2,
st [1] - 3228:18
3240:12, 3240:15, 3240:16, 3240:19,
Stack [1] - 3178:17
3241:13, 3241:23, 3242:1, 3242:7,
staff [3] - 3165:2, 3175:21, 3175:23
3242:11, 3242:20, 3242:25, 3243:23,
stage [1] - 3228:13
3244:3, 3244:4, 3244:8, 3244:14,
stall [1] - 3198:15
3244:17, 3244:23, 3245:4, 3245:6,
stand [8] - 3186:15, 3222:7, 3300:14,
3245:14, 3245:23, 3246:5, 3246:8,
3303:14, 3303:15, 3309:17, 3390:23,
3246:12, 3246:18, 3247:3, 3247:5,
3400:20
3248:11, 3248:25, 3249:8, 3249:17,
standard [1] - 3351:5
3249:22, 3250:6, 3251:16, 3251:17,
Standard [1] - 3370:3
3253:4, 3255:15, 3258:6, 3259:19,
standards [2] - 3263:17, 3263:23
3261:6, 3262:18, 3262:21, 3263:3,
standing [3] - 3388:1, 3388:3, 3388:4
3263:7, 3263:11, 3263:21, 3264:2,
standpoint [1] - 3160:19
3264:9, 3265:4, 3265:10, 3265:13,
STANFORD [1] - 3143:6
3265:18, 3265:24, 3266:5, 3266:14,
Stanford [398] - 3146:16, 3147:9,
3267:1, 3267:8, 3267:20, 3268:9,
3147:12, 3147:15, 3147:19, 3148:3,
3269:20, 3269:23, 3270:22, 3270:23,
3148:14, 3148:18, 3149:11, 3149:21,
3270:24, 3271:2, 3271:3, 3271:6,
3149:22, 3150:4, 3150:5, 3150:20,
3271:19, 3272:14, 3273:17, 3278:20,
3150:22, 3151:1, 3151:14, 3151:15,
3279:16, 3280:4, 3283:18, 3284:10,
3151:17, 3151:24, 3153:7, 3153:9,
3284:15, 3284:24, 3285:2, 3287:12,
3153:16, 3153:23, 3154:2, 3154:6,
3288:2, 3288:12, 3288:15, 3288:17,
3156:19, 3157:5, 3157:13, 3157:20,
3288:21, 3289:3, 3289:16, 3289:20,
3158:12, 3158:16, 3159:11, 3159:14,
3289:22, 3290:5, 3290:15, 3291:15,
3159:18, 3159:23, 3160:6, 3160:22,
3292:19, 3293:4, 3293:5, 3293:7,
3160:25, 3161:12, 3161:16, 3162:13,
3293:13, 3293:15, 3294:19, 3294:21,
3162:15, 3162:17, 3162:22, 3163:3,
3295:4, 3295:10, 3295:18, 3302:18,
3163:14, 3164:1, 3164:21, 3165:17,
3305:20, 3305:24, 3308:1, 3312:22,
3166:20, 3167:12, 3167:19, 3168:6,
3313:13, 3313:25, 3315:3, 3316:5,
3168:8, 3168:16, 3168:25, 3169:5,
3317:24, 3318:3, 3318:16, 3319:20,
3169:9, 3169:25, 3170:4, 3170:19,
3322:1, 3327:12, 3327:15, 3327:18,
3170:21, 3171:13, 3171:19, 3172:15,
3330:9, 3330:16, 3332:13, 3334:6,
3173:22, 3174:5, 3174:7, 3174:11,
3336:24, 3338:25, 3339:5, 3339:7,
3174:17, 3175:7, 3176:10, 3176:13,
3341:4, 3341:10, 3341:12, 3342:24,
3177:8, 3177:12, 3177:17, 3177:23,
3343:13, 3345:13, 3346:16, 3347:18,
3178:16, 3179:8, 3179:12, 3179:19,
3348:14, 3348:21, 3348:25, 3349:7,
3180:12, 3180:19, 3180:22, 3180:23,
3349:15, 3352:2, 3353:8, 3353:13,
3181:4, 3182:3, 3182:18, 3183:8,
3353:16, 3353:21, 3355:7, 3355:8,
3184:4, 3184:10, 3184:14, 3184:18,
3355:14, 3356:16, 3356:19, 3356:20,
3185:7, 3186:8, 3187:16, 3187:22,
3358:1, 3358:7, 3358:9, 3361:16,
3187:24, 3188:7, 3188:14, 3188:17,
3363:16, 3364:7, 3364:10, 3365:20,
3188:22, 3189:1, 3189:6, 3189:22,
3367:11, 3367:13, 3367:18, 3369:21,
3189:24, 3191:12, 3191:16, 3192:14,
3370:9, 3371:13, 3372:1, 3372:3,
3193:3, 3193:9, 3193:13, 3194:14,
3374:11, 3375:6, 3375:13, 3375:17,
3195:9, 3195:11, 3196:23, 3196:24,
3375:21, 3376:6, 3376:8, 3376:12,
3197:4, 3198:6, 3198:9, 3198:12,
3376:18, 3376:22, 3378:15, 3378:23,
3199:9, 3199:16, 3200:2, 3201:19,
3379:8, 3379:11, 3379:20, 3379:23,
3201:21, 3202:13, 3203:4, 3203:17,
3380:2, 3381:21, 3381:23, 3394:19,
3203:25, 3204:10, 3205:8, 3205:15,
3394:21, 3398:3, 3401:3, 3415:6,
3206:10, 3207:9, 3207:13, 3208:3,
3417:16, 3417:18, 3418:3
3208:5, 3209:19, 3209:22, 3210:2,
stanford [1] - 3214:21
3211:3, 3211:25, 3212:1, 3212:6,
Stanford's [17] - 3151:7, 3175:20,
3212:7, 3212:12, 3212:13, 3212:17,
3200:20,
3212:18, 3231:14, 3269:10,
3213:9, 3213:12, 3213:17, 3213:20,
3270:5,
3291:3,
3348:12, 3349:13,
3213:24, 3214:1, 3214:3, 3214:8,
3356:13, 3368:7, 3375:20, 3382:19,
3214:15, 3215:6, 3215:22, 3216:2,
3382:25, 3383:20, 3410:21
3216:10, 3216:12, 3216:13, 3217:18,
Stanford-owned [1] - 3271:6
3217:21, 3221:14, 3224:3, 3225:4,
Star [2] - 3188:4, 3188:8
3225:7, 3225:21, 3226:3, 3226:14,
Star/Sun [1] - 3187:19
3229:19, 3230:6, 3230:11, 3230:24,
solve [1] - 3198:6

some-odd [1] - 3326:22
someone [4] - 3179:13, 3179:19,
3209:2, 3300:22
sometime [3] - 3312:2, 3414:11,
3414:22
sometimes [4] - 3302:22, 3373:21,
3394:24, 3401:7
somewhat [1] - 3218:23
somewhere [8] - 3251:17, 3256:18,
3318:5, 3318:6, 3345:21, 3349:23,
3353:12, 3397:5
son [5] - 3177:17, 3177:22, 3177:23,
3178:7, 3404:8
sons [3] - 3302:15, 3302:17, 3302:20
soon [5] - 3286:2, 3369:15, 3395:19,
3415:3, 3415:13
sooner [1] - 3420:6
sorry [32] - 3153:1, 3168:18, 3183:2,
3185:19, 3194:2, 3202:7, 3204:22,
3213:14, 3218:8, 3221:4, 3222:20,
3226:20, 3228:14, 3237:11, 3241:11,
3245:23, 3249:22, 3263:15, 3267:13,
3268:23, 3275:8, 3279:11, 3285:14,
3290:2, 3324:7, 3352:5, 3352:6,
3354:13, 3362:13, 3400:14, 3414:17,
3414:20
sort [4] - 3152:20, 3166:8, 3173:3,
3418:16
sound [1] - 3202:14
source [6] - 3355:5, 3372:4, 3396:20,
3397:3, 3397:7, 3398:2
sources [3] - 3153:2, 3153:3, 3398:2
South [1] - 3160:11
south [1] - 3316:3
SOUTHERN [1] - 3143:1
sowed [1] - 3258:6
space [1] - 3173:14
spacing [1] - 3319:14
speakerphone [1] - 3245:20
speakers [1] - 3164:18
speaking [10] - 3152:4, 3152:16,
3197:4, 3228:19, 3246:16, 3267:1,
3284:24, 3287:12, 3288:20, 3289:2
special [1] - 3164:17
specific [6] - 3160:14, 3188:24,
3200:14, 3203:14, 3210:8, 3279:23
specifically [11] - 3156:21, 3157:23,
3159:25, 3181:3, 3203:16, 3213:16,
3231:9, 3235:20, 3237:9, 3260:17,
3266:22
specified [2] - 3237:4, 3237:7
speculate [1] - 3311:10
spend [2] - 3303:18, 3305:15
spending [1] - 3182:3
spent [13] - 3214:24, 3289:25,
3296:25, 3297:2, 3303:22, 3304:9,
3304:11, 3305:17, 3305:23, 3365:22,
3371:2, 3371:3, 3371:24
spite [3] - 3311:19, 3318:20, 3330:15
split [5] - 3224:19, 3293:2, 3345:8,
3346:1, 3419:12
3454
3190:5, 3190:7, 3190:11, 3190:13,
start [12] - 3147:11, 3148:15, 3148:21,
STELLMACH........... [1] - 3145:4
3190:19, 3190:22, 3191:11, 3191:14,
3149:15, 3190:9, 3194:1, 3342:4,
stenography [1] - 3144:14
3192:9, 3192:12, 3192:21, 3192:25,
3342:6, 3344:12, 3403:7, 3405:5,
step [5] - 3161:1, 3208:13, 3208:24,
3193:2, 3193:8, 3195:20, 3195:22,
3420:12
3416:14, 3420:6
3196:19, 3199:1, 3200:12, 3201:5,
start-up [1] - 3147:11
stepped [1] - 3327:11
3201:18, 3202:4, 3204:9, 3205:6,
started [16] - 3151:4, 3165:20,
stepping [1] - 3389:15
3205:18, 3206:6, 3206:7, 3206:17,
3165:21, 3230:19, 3286:16, 3290:16,
steps [5] - 3239:3, 3268:16, 3268:18,
3206:19, 3207:12, 3209:7, 3209:10,
3306:13, 3307:5, 3307:17, 3343:14,
3278:8, 3279:22
3209:13, 3209:14, 3210:22, 3211:15,
3344:6, 3361:8, 3370:20, 3374:3,
sticking [1] - 3175:10
3212:21, 3213:8, 3214:7, 3214:14,
3382:10, 3405:25
still [21] - 3181:11, 3245:4, 3245:6,
3215:18, 3216:21, 3217:9, 3217:10,
starting [5] - 3196:6, 3197:10, 3198:4,
3249:17, 3263:5, 3280:12, 3281:19,
3219:7, 3219:16, 3220:24, 3221:3,
3202:1, 3224:10
3287:12, 3293:11, 3300:3, 3310:9,
3221:5, 3221:9, 3222:6, 3222:12,
state [9] - 3168:21, 3168:22, 3213:23,
3320:25, 3333:1, 3371:17, 3395:12,
3222:16, 3222:20, 3222:22, 3223:11,
3219:2, 3219:4, 3241:12, 3272:12,
3397:18, 3400:23, 3405:7, 3417:16,
3223:14, 3226:22, 3227:13, 3228:2,
3272:15, 3272:17
3417:23, 3421:25
3228:6, 3228:9, 3228:14, 3228:16,
statement [13] - 3163:18, 3274:18,
Stinson [19] - 3233:19, 3244:1,
3229:2, 3229:8, 3229:16, 3229:19,
3276:20, 3355:24, 3362:23, 3364:17,
3267:22, 3268:18, 3268:23, 3269:3,
3229:23, 3230:7, 3230:14, 3230:18,
3364:18, 3364:22, 3369:9, 3380:19,
3269:13, 3269:19, 3270:1, 3270:21,
3230:20, 3231:25, 3232:1, 3234:4,
3380:21, 3382:15, 3411:15
3273:1, 3274:23, 3276:12, 3277:20,
3234:8, 3234:12, 3234:22, 3234:25,
statements [16] - 3159:7, 3264:15,
3277:22, 3277:23, 3278:16, 3278:17,
3235:6, 3235:16, 3236:2, 3236:4,
3275:1, 3275:15, 3276:8, 3276:10,
3280:1
3236:7, 3236:9, 3236:11, 3236:12,
3276:13, 3276:18, 3276:19, 3276:24,
stinson [2] - 3267:23, 3272:5
3236:18, 3236:24, 3237:8, 3237:12,
3276:25, 3277:6, 3277:8, 3277:25,
stocks [1] - 3150:8
3238:18, 3239:2, 3239:19, 3239:22,
3279:17, 3288:24
stole [8] - 3301:18, 3324:20, 3325:11,
3240:18, 3243:22, 3244:7, 3244:24,
STATES [3] - 3143:1, 3143:4, 3143:10
3342:14, 3358:23, 3358:24, 3359:1
3245:13, 3245:25, 3247:21, 3247:24,
States [16] - 3147:17, 3148:4, 3149:1,
stood [1] - 3262:23
3249:13, 3249:16, 3249:21, 3250:12,
3149:16, 3149:24, 3151:5, 3233:4,
stop [12] - 3176:5, 3200:24, 3223:23,
3250:17, 3252:14, 3252:16, 3254:24,
3241:25, 3278:4, 3280:15, 3280:22,
3295:21, 3334:20, 3375:15, 3382:7,
3254:25, 3256:1, 3256:3, 3257:3,
3281:6, 3306:14, 3352:12, 3363:11,
3382:18, 3382:20, 3390:22, 3409:24
3257:14, 3257:24, 3258:3, 3258:14,
3378:12
stopped [2] - 3178:21, 3179:9
3258:18, 3258:25, 3260:10, 3260:14,
states [1] - 3223:19
store [5] - 3392:9, 3392:22, 3393:17,
3260:22, 3260:25, 3261:1, 3261:5,
stationed [4] - 3170:13, 3172:9,
3393:25, 3394:22
3261:16, 3262:2, 3266:13, 3268:14,
3173:8, 3175:23
stored [6] - 3390:11, 3393:2, 3393:22,
3268:22, 3268:24, 3269:2, 3269:12,
status [1] - 3184:18
3393:23, 3395:5, 3396:19
3269:18, 3270:4, 3270:9, 3270:17,
stay [2] - 3419:1, 3423:14
storing [1] - 3392:6
3270:20, 3271:7, 3271:13, 3271:16,
stayed [1] - 3366:23
story [5] - 3304:24, 3306:4, 3310:16,
3271:20, 3271:23, 3272:3, 3272:8,
staying [1] - 3232:11
3310:17, 3316:22
3272:12, 3272:19, 3272:21, 3272:23,
steady [2] - 3161:10, 3351:9
straight [1] - 3393:4
3273:1, 3273:3, 3273:7, 3273:12,
steal [8] - 3301:20, 3324:21, 3325:3,
strain [1] - 3188:19
3273:19, 3273:23, 3274:11, 3274:22,
3325:9, 3342:11, 3342:14, 3342:19,
strategy [2] - 3167:8, 3167:15
3275:7, 3275:10, 3275:12, 3275:23,
3371:21
stream [1] - 3198:2
3276:7, 3277:19, 3278:6, 3279:10,
stealing [3] - 3316:17, 3325:5, 3325:6
Street [1] - 3143:22
3279:25, 3281:10, 3282:7, 3285:22,
stellmach [5] - 3204:23, 3305:8,
strengthen [1] - 3198:14
3286:8, 3286:11, 3286:16, 3286:23,
3329:4, 3335:22, 3353:11
stress [1] - 3197:13
3287:10, 3287:23, 3289:11, 3289:14,
Stellmach [7] - 3143:16, 3192:20,
stretch [1] - 3295:20
3290:13, 3290:14, 3291:6, 3291:10,
3222:10, 3323:23, 3374:7, 3387:5,
strictly [1] - 3211:11
3291:17, 3291:19, 3291:22, 3292:2,
3395:15
strips [1] - 3209:2
3292:8, 3292:9, 3295:19, 3296:15,
STELLMACH [312] - 3146:6, 3146:9,
strong [3] - 3181:11, 3202:14, 3202:17
3297:14, 3297:23, 3298:2, 3298:4,
3147:1, 3151:23, 3152:22, 3153:18,
structure [1] - 3158:14
3298:7, 3298:12, 3298:23, 3299:9,
3153:22, 3154:12, 3154:18, 3154:20,
stuck [1] - 3230:3
3299:14, 3299:24, 3305:10, 3308:14,
3154:25, 3155:3, 3155:18, 3155:23,
studio [3] - 3341:19, 3341:21, 3341:22
3308:17, 3311:3, 3311:9, 3315:19,
3156:1, 3156:7, 3156:17, 3157:12,
stuff [1] - 3393:7
3322:14, 3322:19, 3323:4, 3323:9,
3158:4, 3161:19, 3161:23, 3166:14,
styled [3] - 3259:11, 3324:8, 3362:24
3323:13, 3323:17, 3323:20, 3323:24,
3167:1, 3167:3, 3167:24, 3168:5,
3328:25, 3329:12, 3355:21, 3362:9,
Suarez [1] - 3289:25
3168:12, 3169:4, 3170:16, 3171:17,
3362:13, 3368:12, 3373:25, 3389:22,
subject [7] - 3154:21, 3158:20,
3171:25, 3172:2, 3172:3, 3175:5,
3390:2, 3399:2, 3399:7, 3399:19,
3173:25, 3194:21, 3210:3, 3330:25,
3176:8, 3176:9, 3177:6, 3178:6,
3406:6, 3406:18, 3406:21, 3406:25,
3356:7
3179:3, 3179:7, 3179:17, 3180:6,
3407:9, 3407:11, 3407:15, 3407:17,
subjects [1] - 3288:5
3180:8, 3180:10, 3180:11, 3181:7,
3408:8, 3408:10, 3408:19, 3408:22,
submit [3] - 3229:21, 3235:2, 3415:21
3182:7, 3182:9, 3182:11, 3182:13,
3410:8, 3411:1, 3411:25, 3413:11,
submitted [1] - 3349:6
3183:20, 3183:25, 3184:3, 3185:2,
3413:19, 3414:7, 3415:15, 3416:3,
subpoena [8] - 3231:19, 3231:20,
3185:5, 3185:16, 3185:21, 3187:4,
3416:8, 3423:19
3236:14, 3236:16, 3237:5, 3237:22,
3187:7, 3187:12, 3189:4, 3190:2,
3455
3335:17, 3352:12
subpoenaed [4] - 3230:25, 3237:24,
3303:1
subpoenas [2] - 3232:20, 3235:23
subsequently [1] - 3293:16
successful [1] - 3162:17
sudden [1] - 3312:17
sufficient [1] - 3229:25
suggested [1] - 3355:5
suggestion [2] - 3273:6, 3280:17
suggestions [2] - 3278:8, 3279:4
suit [1] - 3270:8
summary [1] - 3302:21
summary-type [1] - 3302:21
summer [5] - 3177:11, 3182:21,
3197:11, 3198:5, 3215:5
sums [1] - 3374:17
Sun [2] - 3188:4, 3188:9
superimposed [1] - 3319:19
Superstars [1] - 3165:13
support [9] - 3188:4, 3202:16,
3205:11, 3208:8, 3224:23, 3226:4,
3266:17, 3294:15, 3413:13
supportive [1] - 3280:6
suppose [1] - 3265:18
supposed [3] - 3312:9, 3337:23,
3415:21
sustain [5] - 3168:10, 3179:6,
3183:18, 3269:17, 3407:13
sustained [27] - 3151:22, 3157:11,
3158:3, 3177:5, 3178:24, 3179:16,
3189:3, 3204:8, 3207:11, 3209:3,
3213:6, 3213:18, 3214:13, 3260:11,
3260:21, 3266:12, 3275:20, 3303:4,
3306:2, 3311:12, 3316:7, 3325:17,
3353:1, 3355:23, 3383:8, 3406:8,
3406:20
swear [1] - 3423:6
Swiss [1] - 3363:22
Switzerland [1] - 3176:21
system [9] - 3201:13, 3201:15, 3286:1,
3378:14, 3391:19, 3391:20, 3391:21,
3393:2, 3398:3
systems [1] - 3200:19
taxi [1] - 3211:11

texts [2] - 3285:1
TCP [1] - 3164:12
thankless [1] - 3176:15
TD [2] - 3186:2, 3191:5
THE [567] - 3143:10, 3143:13, 3143:20,
3144:2, 3146:2, 3146:25, 3151:22,
teaching [4] - 3401:17, 3401:18,
3152:20, 3153:15, 3153:20, 3154:7,
3402:15, 3402:19
3154:9, 3154:11, 3154:17, 3154:19,
team [2] - 3158:21, 3217:23
3154:23, 3155:2, 3155:16, 3155:21,
teams [5] - 3165:9, 3165:12, 3165:13,
3155:24, 3156:4, 3156:14, 3156:15,
3165:14, 3165:16
3156:16, 3157:9, 3157:11, 3158:3,
tears [3] - 3262:6, 3265:15, 3265:19
3161:20, 3161:22, 3166:12, 3166:13,
technical [1] - 3192:13
3167:2, 3167:25, 3168:10, 3168:20,
technically [2] - 3161:20, 3346:21
3168:25, 3170:13, 3170:14, 3170:15,
technology [2] - 3251:10, 3252:19
3171:10, 3171:12, 3171:14, 3171:15,
telephone [1] - 3233:24
3171:16, 3171:24, 3172:1, 3174:18,
telephonics [1] - 3347:5
3174:20, 3174:21, 3174:23, 3174:24,
tend [2] - 3316:16, 3336:23
3174:25, 3175:1, 3175:3, 3175:4,
Tennessee [1] - 3172:14
3176:5, 3177:2, 3177:3, 3177:5,
term [8] - 3149:25, 3178:1, 3178:2,
3178:1, 3178:3, 3178:5, 3178:24,
3178:22, 3179:1, 3179:2, 3199:12,
3179:2, 3179:5, 3179:16, 3181:2,
3252:13
3181:4, 3181:6, 3182:6, 3182:8,
termination [1] - 3189:14
3182:10, 3182:12, 3183:17, 3184:1,
terms [22] - 3146:19, 3148:17, 3150:4,
3187:6, 3187:9, 3189:3, 3190:4,
3151:9, 3157:1, 3159:8, 3178:1,
3190:21, 3193:6, 3196:15, 3196:16,
3178:15, 3183:2, 3195:3, 3199:9,
3196:18, 3198:18, 3198:20, 3198:22,
3199:20, 3207:16, 3216:1, 3220:9,
3198:24, 3200:9, 3200:10, 3200:15,
3237:14, 3239:23, 3262:12, 3290:10,
3200:20, 3200:24, 3201:1, 3201:2,
3346:20, 3354:9, 3373:16
3201:3, 3201:4, 3201:7, 3201:12,
territorial [1] - 3210:19
3201:15, 3201:16, 3201:17, 3201:25,
testified [30] - 3177:15, 3177:16,
3202:3, 3204:6, 3204:8, 3204:18,
3204:14, 3205:8, 3206:9, 3220:3,
3204:21, 3204:22, 3205:5, 3205:20,
3227:14, 3229:24, 3238:9, 3253:19,
3206:4, 3207:11, 3208:16, 3208:23,
3262:8, 3281:14, 3282:21, 3289:15,
3209:9, 3209:12, 3210:10, 3210:12,
3290:7, 3301:5, 3305:12, 3312:3,
3210:13, 3210:14, 3210:15, 3210:17,
3314:22, 3322:6, 3328:18, 3329:2,
3210:18, 3210:20, 3210:21, 3211:10,
3329:5, 3336:10, 3344:4, 3355:19,
3211:12, 3211:14, 3212:22, 3213:1,
3358:13, 3370:3, 3387:4, 3401:2
3213:3, 3213:5, 3213:18, 3213:21,
testify [21] - 3231:19, 3232:3, 3232:16,
3213:22, 3214:1, 3214:13, 3215:15,
3238:2, 3238:5, 3238:20, 3239:4,
3216:16, 3216:19, 3216:20, 3217:7,
3239:8, 3281:16, 3281:19, 3281:22,
3219:6, 3219:8, 3219:10, 3219:11,
3282:11, 3282:16, 3282:19, 3284:2,
3219:12, 3219:14, 3220:18, 3220:22,
3284:17, 3310:11, 3328:23, 3329:1,
3220:23, 3221:1, 3221:4, 3221:7,
3386:3, 3421:22
3222:2, 3222:5, 3222:19, 3222:21,
testifying [4] - 3207:1, 3220:17,
3226:15, 3226:18, 3226:20, 3227:4,
3320:4, 3413:4
3227:7, 3227:8, 3227:10, 3227:12,
testimony [36] - 3207:9, 3220:21,
3227:21, 3227:25, 3228:1, 3228:7,
3235:24, 3237:19, 3239:17, 3243:17,
3228:13, 3228:15, 3228:24, 3228:25,
3250:21, 3252:23, 3253:20, 3278:21,
T
3229:1, 3229:6, 3229:14, 3229:18,
3279:5, 3281:12, 3283:13, 3283:25,
3230:1, 3230:4, 3230:13, 3230:16,
3295:11, 3299:10, 3303:19, 3305:16,
3230:19, 3231:24, 3234:2, 3234:5,
table [5] - 3235:9, 3236:1, 3268:4,
3307:15, 3309:10, 3313:9, 3325:2,
3234:11, 3234:16, 3234:18, 3234:20,
3268:6, 3268:7
3328:13, 3329:1, 3329:10, 3330:15,
3234:21, 3234:24, 3235:1, 3235:12,
talks [1] - 3381:14
3333:23, 3335:12, 3342:16, 3355:22,
3235:15, 3236:6, 3236:8, 3236:10,
tall [1] - 3351:21
3380:3, 3381:11, 3381:12, 3410:1,
3236:15, 3236:19, 3236:20, 3236:21,
Tamarin [1] - 3409:13
3412:14, 3420:12
3238:10, 3238:11, 3238:13, 3238:14,
tape [1] - 3193:5
TEXAS [1] - 3143:1
3238:15, 3238:16, 3238:25, 3239:1,
target [3] - 3207:8, 3207:21, 3207:24
Texas [10] - 3143:4, 3143:15, 3143:23,
3239:14, 3239:15, 3239:17, 3239:20,
targets [2] - 3165:16, 3165:18
3144:4, 3144:7, 3144:12, 3170:14,
3240:14, 3240:15, 3243:21, 3243:23,
TARP [2] - 3411:14, 3412:20
3226:24, 3243:16, 3376:25
3244:20, 3244:22, 3245:12, 3245:22,
Tarrie [3] - 3194:2, 3194:22
text [14] - 3184:12, 3185:16, 3185:18,
3245:23, 3247:15, 3247:16, 3247:17,
3191:15, 3291:23, 3293:4, 3293:7,
tax [15] - 3212:18, 3226:19, 3227:8,
3247:19, 3247:20, 3248:10, 3248:13,
3293:8, 3293:9, 3293:22, 3318:12,
3292:23, 3337:7, 3337:9, 3337:11,
3248:14, 3248:15, 3248:16, 3248:18,
3330:19, 3330:20, 3332:16
3337:14, 3337:18, 3337:21, 3338:1,
3248:19, 3248:21, 3248:25, 3249:2,
texted [2] - 3184:14, 3317:24
3338:8, 3338:13, 3338:17, 3359:3
3249:3, 3249:5, 3249:6, 3249:7,
Tax [1] - 3337:1
texting [1] - 3195:13
3456
3249:8, 3249:10, 3249:11, 3249:15,
3249:19, 3249:20, 3250:9, 3250:10,
3250:13, 3250:15, 3252:15, 3254:7,
3254:9, 3254:10, 3254:11, 3254:13,
3254:16, 3254:19, 3254:20, 3254:21,
3254:22, 3254:23, 3256:11, 3256:13,
3256:16, 3256:19, 3256:20, 3256:21,
3256:22, 3257:1, 3257:8, 3257:9,
3257:10, 3257:11, 3257:12, 3257:15,
3257:22, 3258:1, 3258:16, 3258:17,
3258:20, 3258:23, 3258:24, 3260:11,
3260:21, 3260:24, 3261:3, 3261:9,
3261:11, 3261:25, 3262:1, 3266:12,
3268:11, 3268:12, 3268:13, 3269:1,
3269:17, 3270:3, 3270:7, 3270:16,
3270:18, 3271:9, 3271:14, 3271:17,
3271:21, 3271:25, 3272:7, 3272:10,
3272:17, 3272:20, 3272:22, 3272:24,
3273:2, 3273:5, 3273:10, 3273:16,
3273:21, 3274:1, 3274:6, 3274:10,
3274:13, 3275:5, 3275:8, 3275:11,
3275:20, 3275:24, 3277:18, 3278:3,
3278:5, 3278:14, 3278:15, 3278:18,
3278:25, 3279:1, 3279:2, 3279:3,
3279:7, 3279:9, 3279:18, 3279:21,
3280:21, 3280:25, 3281:3, 3281:4,
3281:5, 3281:7, 3281:8, 3281:9,
3282:2, 3282:3, 3282:4, 3285:14,
3285:16, 3285:17, 3285:18, 3286:7,
3286:13, 3286:21, 3287:6, 3287:8,
3287:9, 3287:20, 3287:21, 3291:18,
3291:21, 3292:1, 3292:7, 3295:20,
3295:23, 3296:1, 3296:20, 3297:15,
3297:18, 3297:25, 3298:3, 3298:6,
3298:11, 3298:14, 3299:4, 3299:12,
3299:15, 3299:25, 3300:16, 3300:25,
3303:4, 3304:16, 3304:18, 3304:20,
3304:21, 3305:2, 3305:3, 3306:2,
3307:1, 3307:2, 3308:13, 3308:16,
3308:21, 3308:25, 3309:3, 3309:4,
3309:13, 3311:4, 3311:6, 3311:12,
3315:23, 3316:7, 3316:10, 3321:4,
3322:18, 3323:11, 3324:1, 3324:5,
3324:10, 3325:15, 3325:17, 3325:24,
3325:25, 3326:10, 3326:12, 3326:14,
3329:8, 3329:14, 3329:16, 3331:2,
3331:12, 3331:16, 3331:19, 3331:23,
3331:25, 3332:3, 3332:5, 3341:21,
3341:22, 3341:23, 3341:24, 3350:1,
3350:3, 3350:5, 3350:11, 3350:14,
3350:15, 3350:20, 3351:1, 3351:3,
3351:7, 3351:9, 3351:10, 3351:14,
3351:15, 3351:19, 3351:22, 3353:1,
3353:2, 3355:23, 3361:5, 3362:11,
3362:15, 3368:10, 3368:13, 3371:6,
3373:23, 3374:1, 3380:10, 3383:8,
3383:11, 3383:15, 3383:16, 3383:21,
3383:25, 3384:1, 3384:10, 3384:11,
3385:2, 3385:4, 3386:14, 3388:24,
3388:25, 3389:1, 3389:2, 3389:3,
3389:5, 3389:6, 3389:7, 3389:9,
3389:10, 3389:11, 3389:23, 3390:3,
3390:18, 3390:19, 3390:20, 3390:22,
3391:2, 3397:14, 3397:15, 3397:16,

3196:9, 3196:10, 3196:12, 3196:13,
3397:17, 3397:23, 3398:1, 3399:3,
3196:15, 3239:10, 3239:25, 3240:17,
3399:5, 3399:8, 3399:20, 3399:22,
3248:7, 3248:11, 3249:4, 3249:25,
3399:23, 3405:14, 3405:17, 3406:8,
3253:23, 3254:8, 3254:18, 3255:1,
3406:20, 3406:22, 3407:7, 3407:10,
3255:12, 3255:13, 3255:14, 3256:5,
3407:13, 3407:16, 3407:18, 3408:9,
3257:6, 3258:10, 3258:21, 3259:10,
3408:12, 3408:21, 3408:25, 3409:23,
3259:12, 3259:25, 3261:14, 3261:18,
3410:7, 3410:12, 3411:3, 3411:7,
3261:20, 3262:13, 3262:14, 3264:10,
3411:13, 3411:21, 3412:2, 3412:5,
3265:9, 3266:16, 3266:19, 3266:23,
3412:11, 3412:15, 3412:19, 3413:18,
3274:25, 3275:3, 3275:14, 3282:10,
3413:20, 3414:16, 3414:20, 3415:5,
3283:4, 3283:15, 3283:16, 3284:12,
3415:25, 3416:2, 3416:6, 3416:10,
3284:15, 3386:11
3416:22, 3417:13, 3417:21, 3418:5,
tier [6] - 3185:20, 3186:18, 3191:17,
3418:12, 3418:15, 3418:24, 3420:3,
3195:1, 3195:3, 3249:4
3420:7, 3420:15, 3420:19, 3421:19,
Tiers [5] - 3179:24, 3182:25, 3238:21,
3421:24, 3422:4, 3422:8, 3422:11,
3255:8
3422:17, 3422:19, 3422:23, 3423:5,
time-wise [1] - 3421:8
3423:11, 3423:20, 3423:23
timeframe [1] - 3414:2
theft [1] - 3179:11
timing [1] - 3161:7
themselves [1] - 3148:17
title [5] - 3214:22, 3248:5, 3248:6,
theories [1] - 3419:16
3357:16, 3358:4
theory [4] - 3201:2, 3383:24, 3384:2,
titled [2] - 3269:21, 3368:23
3413:20
today [11] - 3194:22, 3298:2, 3303:16,
therefore [3] - 3214:2, 3229:18,
3303:19, 3314:7, 3410:1, 3411:15,
3274:18
3414:19, 3414:21, 3415:10, 3417:5
they've [5] - 3300:8, 3352:17, 3413:15,
together [13] - 3163:5, 3163:7, 3180:1,
3414:14, 3422:7
3192:1, 3241:14, 3249:24, 3251:5,
thinks [1] - 3408:14
3286:1, 3306:4, 3306:8, 3310:5,
third [4] - 3199:22, 3215:5, 3253:3,
3359:5, 3415:10
3370:22
Tom [5] - 3233:2, 3233:3, 3233:16,
thousand [2] - 3326:22, 3367:5
3244:2, 3281:23
thousand-dollar [1] - 3367:5
tomorrow [16] - 3194:23, 3194:24,
thousands [2] - 3166:1
3246:10, 3246:11, 3333:9, 3336:15,
3410:1, 3417:3, 3418:4, 3418:22,
three [35] - 3149:17, 3206:24, 3212:19,
3419:20, 3420:10, 3420:19, 3420:25,
3231:22, 3253:17, 3303:20, 3303:24,
3423:12
3304:2, 3304:6, 3304:9, 3305:8,
tone [3] - 3351:3, 3351:11, 3373:1
3305:23, 3306:4, 3306:6, 3306:8,
3306:11, 3308:11, 3321:8, 3338:5,
tonight [3] - 3418:2, 3423:18, 3423:21
3344:22, 3359:18, 3359:19, 3359:20,
took [23] - 3153:24, 3166:19, 3231:14,
3377:5, 3385:21, 3390:17, 3392:8,
3253:16, 3262:21, 3263:11, 3274:19,
3399:13, 3415:23, 3415:25, 3416:4,
3295:3, 3304:6, 3305:8, 3314:25,
3416:6, 3416:7, 3416:21, 3422:20
3317:8, 3317:13, 3327:17, 3332:12,
three-week [1] - 3416:21
3332:18, 3347:23, 3372:3, 3372:6,
threw [9] - 3286:4, 3387:6, 3387:24,
3383:5, 3387:24, 3394:10, 3400:20
3393:12, 3394:5, 3394:15, 3398:13,
Top [6] - 3163:10, 3163:12, 3163:13,
3399:13, 3400:18
3163:20, 3165:7, 3241:18
throughout [4] - 3166:19, 3166:21,
top [15] - 3164:2, 3185:4, 3186:20,
3196:5, 3255:4
3191:13, 3195:7, 3196:22, 3209:11,
throw [4] - 3285:14, 3386:8, 3394:7,
3224:10, 3252:24, 3300:11, 3319:3,
3394:10
3364:22, 3368:15, 3369:2, 3380:17
thrust [2] - 3308:6, 3309:17
topic [4] - 3188:17, 3387:2, 3409:21,
3414:13
thumb [8] - 3285:10, 3285:15, 3286:5,
topics [2] - 3372:23, 3381:3
3286:14, 3387:5, 3393:25, 3396:19,
3399:14
Toronto [1] - 3186:3
Thunderbirds [1] - 3165:15
tossed [1] - 3285:9
Thursday [9] - 3247:12, 3247:15,
total [21] - 3175:11, 3188:2, 3189:9,
3247:17, 3249:19, 3249:20, 3249:22,
3190:18, 3194:11, 3195:21, 3195:24,
3258:6, 3262:7, 3283:5
3202:20, 3203:1, 3203:7, 3214:25,
tied [1] - 3286:1
3222:17, 3222:24, 3222:25, 3223:1,
3251:25, 3254:17, 3255:9, 3255:14,
Tier [68] - 3182:17, 3183:2, 3183:4,
3259:5, 3359:8
3183:5, 3184:16, 3184:18, 3185:14,
totaling [1] - 3224:22
3185:15, 3185:19, 3187:1, 3191:24,
3194:7, 3194:13, 3195:5, 3195:6,
touch [3] - 3245:6, 3283:24, 3338:7
3457
3367:14, 3383:2, 3383:3
tough [3] - 3198:3, 3201:7, 3416:19
underway [1] - 3423:13
truthful [1] - 3313:10
tour [2] - 3170:18, 3171:1
undeveloped [1] - 3223:9
try [14] - 3246:20, 3260:25, 3291:19,
toward [8] - 3147:14, 3167:4, 3172:24,
unencumbered [1] - 3199:14
3302:23, 3314:6, 3341:10, 3351:18,
3190:9, 3195:7, 3196:6, 3241:24,
unfortunately [1] - 3311:25
3351:22, 3385:15, 3385:17, 3393:4,
3411:24
unit [5] - 3175:25, 3176:11, 3217:5,
3397:6, 3397:7, 3420:5
towards [1] - 3324:7
3389:9, 3390:20
trying [22] - 3161:19, 3197:24,
tower [1] - 3387:13
uNITED [1] - 3143:1
3230:14, 3256:17, 3257:4, 3257:5,
town [1] - 3293:23
United [16] - 3147:17, 3148:4, 3149:1,
3283:24, 3299:6, 3299:7, 3303:7,
TPC [5] - 3163:13, 3165:7, 3165:20,
3149:16, 3149:24, 3151:5, 3233:4,
3318:10, 3323:24, 3345:19, 3358:14,
3192:17, 3193:3
3241:25, 3278:4, 3280:15, 3280:22,
3396:10, 3396:22, 3397:8, 3398:13,
3281:6, 3306:14, 3352:12, 3363:11,
track [11] - 3158:16, 3159:1, 3322:9,
3400:3, 3400:4, 3421:21, 3422:25
3378:12
3326:4, 3356:25, 3357:2, 3357:5,
Tuesday [4] - 3246:16, 3246:17,
UNITED [2] - 3143:4, 3143:10
3360:4, 3360:6, 3391:22
3282:18, 3414:23
tracked [1] - 3159:5
units [1] - 3175:22
turmoil [1] - 3166:20
tranches [4] - 3293:3, 3335:2, 3345:9,
unless [2] - 3310:6, 3419:12
turn [13] - 3202:5, 3202:7, 3202:8,
3346:10
unmute [1] - 3331:23
3206:8, 3223:11, 3236:13, 3237:8,
transaction [11] - 3208:14, 3220:25,
unreasonable [1] - 3417:21
3289:11, 3322:12, 3324:12, 3324:19,
3221:10, 3316:17, 3318:19, 3341:9,
up [112] - 3147:11, 3148:15, 3148:21,
3395:16, 3414:12
3347:8, 3347:14, 3347:15, 3349:15,
3154:3, 3158:9, 3159:12, 3173:24,
turned [4] - 3183:5, 3195:6, 3326:18,
3349:17
3174:8, 3175:10, 3176:11, 3179:25,
3414:3
transactional [1] - 3221:15
3182:14, 3186:7, 3191:24, 3195:7,
turning [2] - 3187:2, 3243:7
transactions [9] - 3217:3, 3217:5,
3196:7, 3205:16, 3206:9, 3208:15,
twice [1] - 3411:16
3329:3, 3346:3, 3348:14, 3374:17,
3214:11, 3214:17, 3217:6, 3219:24,
two [44] - 3176:4, 3184:12, 3185:17,
3382:2, 3382:5
3224:19, 3227:17, 3227:22, 3243:13,
3188:2, 3188:18, 3207:25, 3214:25,
3243:20, 3244:13, 3244:14, 3244:22,
transcript [1] - 3424:6
3224:11, 3224:15, 3224:22, 3232:9,
3246:18, 3247:6, 3247:21, 3248:16,
Transcript [1] - 3144:14
3241:13, 3248:15, 3253:17, 3265:24,
3249:18, 3249:23, 3252:21, 3257:13,
transcription [1] - 3144:14
3293:2, 3294:16, 3298:15, 3308:11,
3257:16, 3258:6, 3262:23, 3262:25,
transfer [10] - 3215:24, 3216:13,
3333:20, 3335:2, 3337:20, 3343:3,
3266:5, 3268:6, 3268:9, 3270:17,
3216:22, 3328:19, 3346:23, 3346:24,
3345:9, 3346:1, 3346:10, 3359:19,
3271:10, 3275:25, 3276:9, 3278:22,
3346:25, 3347:16, 3352:23, 3353:6
3359:24, 3361:25, 3365:6, 3365:22,
3278:24, 3279:3, 3283:24, 3287:15,
transferred [17] - 3195:6, 3205:15,
3366:11, 3380:5, 3387:13, 3387:14,
3291:25, 3292:1, 3292:4, 3292:6,
3209:22, 3216:10, 3216:11, 3216:18,
3393:13, 3401:23, 3404:1, 3404:4,
3292:7, 3292:8, 3292:24, 3295:24,
3217:18, 3220:5, 3224:3, 3224:7,
3404:11, 3406:14, 3410:17, 3416:16
3298:17, 3300:12, 3300:22, 3302:23,
3225:24, 3226:3, 3322:23, 3346:14,
type [7] - 3275:3, 3302:21, 3318:24,
3304:6, 3305:7, 3311:7, 3312:14,
3346:22, 3348:9, 3396:19
3332:20, 3332:22, 3348:10, 3357:16
3313:4, 3315:6, 3315:7, 3316:16,
transfers [6] - 3185:18, 3186:18,
types [5] - 3165:14, 3167:14, 3184:15,
3317:20, 3318:21, 3319:18, 3326:24,
3186:23, 3186:25, 3205:14, 3221:13
3259:9, 3265:9
3327:9, 3328:5, 3331:6, 3334:12,
travel [8] - 3175:24, 3243:8, 3251:10,
3335:1, 3336:11, 3337:2, 3339:4,
3252:25, 3321:20, 3333:6, 3336:14,
3341:8, 3351:24, 3364:6, 3364:10,
U
3422:1
3364:13, 3373:13, 3374:17, 3378:18,
traveled [1] - 3321:15
3382:16, 3382:17, 3382:22, 3383:13,
treasurer [2] - 3349:19, 3352:2
U.S [11] - 3143:17, 3149:20, 3166:5,
3383:14, 3384:7, 3384:20, 3385:16,
treasury [3] - 3185:9, 3185:12, 3348:3
3227:5, 3227:7, 3231:15, 3245:6,
3386:7, 3390:23, 3402:12, 3405:10,
treated [2] - 3224:20, 3251:19
3281:4, 3361:20, 3363:20, 3380:20
3410:6, 3414:14, 3418:12, 3420:24
TRIAL [1] - 3143:7
ultimate [1] - 3276:1
upcoming [3] - 3232:20, 3232:24,
trial [5] - 3303:21, 3407:1, 3411:11,
ultimately [8] - 3189:21, 3189:24,
3241:15
3414:2, 3414:15
3212:2, 3280:8, 3284:2, 3290:20,
update [2] - 3194:22, 3196:24
tried [15] - 3296:7, 3296:10, 3318:23,
3293:21, 3342:8
updates [1] - 3184:10
3319:2, 3319:5, 3334:1, 3334:3,
ultra [2] - 3211:5
upper [5] - 3202:8, 3206:18, 3207:3,
3336:19, 3352:17, 3396:14, 3398:12,
uncomfortable [3] - 3151:18, 3151:25,
3222:13, 3251:8
3398:16, 3398:24, 3399:17, 3400:16
3351:24
upset [2] - 3405:12, 3406:17
trip [3] - 3171:2, 3242:17, 3243:1
uncover [1] - 3240:3
US [1] - 3143:14
trips [1] - 3171:3
uncovered [1] - 3176:23
usage [1] - 3211:7
true [5] - 3265:5, 3274:15, 3339:16,
uncovering [2] - 3240:6, 3279:23
USD [1] - 3191:5
3344:4, 3400:23
under [19] - 3149:25, 3150:13,
uses [1] - 3179:5
Truellenque [4] - 3148:9, 3148:10,
3150:14, 3150:22, 3151:2, 3151:6,
utilities [3] - 3219:9, 3219:17, 3219:24
3148:19, 3159:19
3151:13, 3152:1, 3157:2, 3194:8,
Trustmark [1] - 3348:15
3215:22, 3217:23, 3222:17, 3223:2,
V
truth [25] - 3232:5, 3232:13, 3264:6,
3227:22, 3232:8, 3232:10, 3369:3,
3272:5, 3272:9, 3274:9, 3276:22,
3381:22
3311:22, 3311:23, 3311:25, 3312:6,
understood [6] - 3155:19, 3180:16,
validity [1] - 3316:22
3312:8, 3312:9, 3312:12, 3312:17,
3200:20, 3211:5, 3211:19, 3212:10
valuation [6] - 3218:11, 3252:23,
3312:18, 3312:19, 3312:20, Johnny
3339:10, C. Sanchez, RMR, CRR - jcscourtreporter@aol.com
3458
3252:24, 3418:11, 3418:20, 3419:18
valuations [1] - 3252:21
value [28] - 3199:15, 3217:1, 3217:20,
3217:21, 3218:10, 3218:14, 3218:19,
3223:8, 3223:9, 3223:20, 3224:7,
3224:25, 3225:11, 3237:16, 3251:22,
3252:20, 3253:22, 3253:23, 3257:6,
3258:10, 3259:25, 3262:13, 3264:7,
3264:10, 3265:11, 3279:2, 3348:9
values [11] - 3223:21, 3250:18,
3252:17, 3253:11, 3253:16, 3254:4,
3255:24, 3259:5, 3262:9, 3278:22,
3278:24
various [1] - 3150:12
Velcro [1] - 3209:2
Venture [15] - 3251:16, 3345:8,
3345:12, 3346:16, 3348:14, 3348:21,
3353:8, 3353:13, 3353:16, 3353:22,
3355:14, 3367:18, 3369:21, 3370:3,
3370:9
venture [3] - 3293:2, 3345:11, 3348:12
verbal [2] - 3339:4, 3339:6
verbatim [1] - 3247:11
verify [7] - 3316:16, 3316:21, 3336:23,
3340:2, 3352:8, 3366:4, 3398:24
version [3] - 3304:12, 3305:19,
3310:16
versus [2] - 3227:9, 3389:3
vestibule [1] - 3165:5
vicinity [1] - 3217:4
video [1] - 3192:10
videos [1] - 3164:17
view [1] - 3321:13
violated [1] - 3411:11
violates [1] - 3412:9
Virgin [6] - 3227:4, 3227:5, 3227:9,
3231:15, 3245:7
Virgins [1] - 3226:16
virtue [1] - 3322:17
visible [2] - 3173:1, 3173:2
visit [2] - 3203:19, 3227:23
visited [2] - 3173:12, 3203:17
visitors [2] - 3172:19, 3173:6
visits [5] - 3171:21, 3172:4, 3303:20,
3304:10, 3305:23
visual [1] - 3173:5
voice [2] - 3351:4, 3373:1
volatility [1] - 3202:18
VOLUME [1] - 3143:8
volunteer [1] - 3314:10
VS [1] - 3143:5
3349:1, 3352:21, 3352:23, 3353:6,

waiver [1] - 3417:18
3367:18, 3370:8, 3370:10
walk [5] - 3173:3, 3208:14, 3209:7,
Wire [1] - 3369:21
3210:1, 3387:18
wired [2] - 3348:4, 3348:6
walked [1] - 3268:7
wireless [5] - 3160:10, 3160:13,
walking [1] - 3265:8
3251:9, 3252:19, 3253:1
wall [3] - 3173:13, 3199:8, 3413:16
wise [5] - 3166:7, 3223:19, 3223:20,
Wall [2] - 3413:18, 3413:21
3412:18, 3421:8
wants [4] - 3176:17, 3300:7, 3417:16,
withdraw [3] - 3191:20, 3286:20,
3423:7
3293:16
warning [1] - 3300:10
withdrawal [10] - 3190:24, 3191:10,
warnings [1] - 3411:18
3191:19, 3191:22, 3191:25, 3196:14,
WARREN [1] - 3422:5
3198:2, 3199:4, 3285:4, 3287:16
Warren [2] - 3143:16, 3305:9
withdrawals [12] - 3163:1, 3181:20,
Washington [6] - 3143:18, 3233:4,
3181:21, 3181:23, 3182:24, 3183:6,
3234:3, 3288:7, 3288:9, 3288:14
3186:22, 3198:16, 3200:24, 3225:21,
watch [3] - 3299:15, 3331:4, 3412:23
3246:6, 3246:7
water [3] - 3211:11, 3253:1, 3286:15
withdrawn [5] - 3303:10, 3314:3,
waters [1] - 3210:19
3399:4, 3399:6, 3399:8
ways [3] - 3239:18, 3419:8, 3423:5
witness [28] - 3155:19, 3168:22,
wearing [1] - 3373:6
3208:21, 3229:24, 3236:2, 3252:14,
Wednesday [9] - 3246:15, 3246:17,
3269:13, 3272:14, 3291:6, 3295:19,
3247:2, 3249:17, 3287:19, 3288:18,
3298:7, 3298:10, 3298:24, 3300:14,
3414:23, 3421:22, 3422:25
3303:14, 3303:15, 3308:19, 3309:17,
week [31] - 3146:3, 3159:6, 3188:6,
3311:10, 3397:9, 3400:20, 3406:7,
3203:20, 3228:18, 3240:11, 3240:22,
3415:4, 3415:20, 3416:7, 3421:20,
3241:8, 3241:14, 3243:7, 3246:14,
3422:4
3248:4, 3250:3, 3258:7, 3282:12,
WITNESS [143] - 3145:2, 3154:9,
3285:5, 3287:13, 3287:19, 3288:18,
3156:15, 3161:22, 3166:13, 3168:25,
3303:24, 3305:10, 3305:11, 3394:8,
3170:14, 3171:12, 3171:15, 3174:20,
3411:16, 3414:11, 3414:22, 3414:23,
3174:23, 3174:25, 3175:3, 3177:2,
3416:21
3178:3, 3181:4, 3190:21, 3196:16,
week-to-week [1] - 3159:6
3198:20, 3198:24, 3200:10, 3200:20,
weekend [4] - 3284:20, 3284:25,
3201:1, 3201:3, 3201:12, 3201:16,
3285:6, 3287:2
3202:3, 3204:21, 3210:12, 3210:14,
weekends [1] - 3394:14
3210:17, 3210:20, 3211:12, 3213:21,
weeks [9] - 3195:19, 3241:14,
3214:1, 3216:19, 3219:8, 3219:11,
3243:14, 3296:25, 3310:13, 3347:23,
3219:14, 3220:22, 3222:5, 3226:18,
3347:24, 3394:10, 3416:16
3227:7, 3227:10, 3227:25, 3228:25,
weight [1] - 3408:14
3234:20, 3236:8, 3236:20, 3238:11,
welcome [1] - 3373:3
3238:14, 3238:16, 3239:1, 3239:15,
West [1] - 3378:7
3240:15, 3243:23, 3244:22, 3245:23,
Western [1] - 3378:6
3247:16, 3247:19, 3248:13, 3248:15,
who'd [1] - 3234:1
3248:18, 3248:21, 3249:2, 3249:5,
whole [6] - 3155:22, 3168:3, 3281:4,
3249:7, 3249:10, 3249:15, 3249:20,
3383:2, 3383:3, 3421:6
3250:10, 3250:13, 3254:9, 3254:11,
wholly [1] - 3271:24
3254:16, 3254:20, 3254:22, 3256:13,
wide [3] - 3389:21, 3389:25, 3390:5
3256:19, 3256:21, 3257:1, 3257:9,
wife [18] - 3212:12, 3214:4, 3284:21,
3257:11, 3258:17, 3258:23, 3261:11,
3302:10, 3302:11, 3343:21, 3344:8,
3262:1, 3268:12, 3278:5, 3278:15,
3344:9, 3344:16, 3344:24, 3402:21,
3278:25, 3279:2, 3279:7, 3279:21,
3403:20, 3403:21, 3405:16, 3405:19,
3280:25, 3281:4, 3281:7, 3281:9,
3406:2, 3406:3, 3407:6
3282:2, 3282:4, 3285:16, 3285:18,
wife's [1] - 3388:16
W
3287:8, 3287:21, 3304:20, 3305:2,
wiggle [1] - 3423:1
3307:1, 3308:13, 3309:4, 3311:4,
wilderness [2] - 3247:8, 3247:10
3315:23, 3321:4, 3325:15, 3325:24,
wages [2] - 3324:25, 3342:8
William [1] - 3143:16
3326:12, 3341:22, 3341:24, 3350:3,
wait [7] - 3212:22, 3221:1, 3258:20,
willing [5] - 3297:7, 3298:22, 3407:3,
3350:11, 3350:15, 3351:3, 3351:9,
3299:24, 3299:25, 3331:7, 3347:21
3407:6, 3420:14
3351:14, 3351:19, 3353:2, 3383:15,
waited [1] - 3165:5
windows [1] - 3173:2
3383:25, 3384:10, 3385:4, 3388:25,
waiting [2] - 3245:8, 3245:15
windup [1] - 3189:13
3389:2, 3389:5, 3389:7, 3389:10,
waive [2] - 3300:16, 3417:24
wire [14] - 3346:23, 3346:24, 3346:25,
3389:23, 3390:3, 3390:19, 3397:15,
waived [6] - 3230:8, 3234:23, 3234:24,
3347:5, 3347:15, 3347:25, 3348:22,
3397:17, 3398:1, 3399:3, 3399:23,
3300:13, 3300:14, 3300:17
3459
3407:7
witness's [2] - 3298:5, 3322:15
witnesses [2] - 3416:4, 3417:8
woman [6] - 3271:11, 3273:22,
3344:12, 3401:4, 3401:10, 3403:23
wondering [1] - 3414:12
wood [1] - 3414:11
word [14] - 3156:22, 3267:5, 3275:9,
3275:24, 3312:10, 3319:23, 3320:5,
3320:7, 3320:10, 3340:3, 3352:14,
3372:8, 3399:1
word-for-word [1] - 3156:22
words [21] - 3157:7, 3171:14, 3182:22,
3200:17, 3209:4, 3222:2, 3228:7,
3246:4, 3249:3, 3256:23, 3260:11,
3261:10, 3274:14, 3276:1, 3318:23,
3351:1, 3351:8, 3386:1, 3389:12,
3412:20, 3421:11
works [1] - 3351:1
worksheet [1] - 3216:4
world [6] - 3201:13, 3201:15, 3211:6,
3220:9, 3226:15, 3374:14
worldwide [1] - 3160:12
worn [1] - 3350:12
worry [2] - 3421:8, 3421:15
worse [2] - 3198:21, 3220:11
worth [3] - 3264:12, 3279:5, 3279:6
Worth [6] - 3231:7, 3243:16, 3243:18,
3282:17, 3284:16, 3284:17
wow [3] - 3353:14, 3380:9, 3388:13
wrap [1] - 3331:5
write [5] - 3209:5, 3292:16, 3367:24,
3369:16, 3419:4
writes [2] - 3207:18, 3366:12
writing [5] - 3199:8, 3208:21, 3366:8,
3370:20, 3371:18
written [2] - 3207:6, 3207:18
wrote [9] - 3191:21, 3194:20, 3195:4,
3195:8, 3195:9, 3209:11, 3292:13,
3366:8, 3367:5
3399:13, 3401:21, 3401:22, 3403:9,

3403:10, 3405:6, 3406:1
yes-no [1] - 3407:8
yesterday [3] - 3303:15, 3309:10,
3314:6
Yolanda [1] - 3289:25
York [7] - 3143:17, 3233:5, 3234:3,
3234:9, 3234:10, 3422:25, 3423:7
you-all [1] - 3227:22
young [2] - 3373:10, 3377:23
younger [2] - 3403:4, 3403:14
yourself [8] - 3155:12, 3187:16,
3248:17, 3294:15, 3371:24, 3376:21,
3400:19
Z
Zach [1] - 3404:9
Zack [2] - 3177:17, 3177:23
zone [2] - 3227:11, 3421:17
zoom [1] - 3187:10
Y
y'all [1] - 3359:5
year [26] - 3147:13, 3166:15, 3182:6,
3196:6, 3215:4, 3290:17, 3290:22,
3296:8, 3314:8, 3314:9, 3315:25,
3316:13, 3332:15, 3333:14, 3333:17,
3333:18, 3358:16, 3365:7, 3366:11,
3374:15, 3374:16, 3380:19, 3403:13,
3416:20
years [52] - 3147:8, 3147:11, 3149:17,
3151:5, 3151:25, 3156:24, 3166:19,
3166:25, 3169:21, 3175:9, 3180:13,
3232:7, 3264:16, 3275:2, 3294:16,
3294:20, 3303:20, 3304:9, 3305:20,
3305:23, 3306:4, 3306:6, 3306:8,
3306:11, 3308:1, 3311:24, 3312:13,
3312:18, 3321:8, 3330:7, 3337:20,
3338:5, 3342:15, 3344:22, 3371:19,
3373:7, 3376:1, 3377:5, 3385:21,
3391:6, 3391:7, 3392:8, 3392:18,

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

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

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3143

UNITED STATES DISTRICT COURT

BEFORE THE HONORABLE DAVID HITTNER

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

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

(The following was held before the jury)

THE COURT: Good morning everybody. Monday

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

Counsel, go right ahead.

CONTINUED DIRECT EXAMINATION

Good morning, Mr. Davis.

When we ended on Friday, you were discussing

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

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

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

What was going on at the bank in terms of CD

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

The redemptions were -MR. SCARDINO: Excuse me. Form of the

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

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

What was the rate of redemptions by the end of 2008

3 and in to early 2009?

At a very, very high rate compared to anytime in

And what about CD sales, sell of new CDs?

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

8 years, six years.

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

I would say very focused.

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

12 the brokerage firm, Stanford Group Company, could you tell

1995, toward the end.

And prior to 1995, had Mr. Stanford ever discussed

16 with you the possibility of opening a brokerage firm here

Yes. We had that discussion.

20 his ability to open a brokerage firm?

Among other things, he said that it would probably be

Did he explain why he thought it would be difficult?

Primarily because of his bankruptcy.

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

1 clubs that failed?

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

4 brokerage firm here in the United States?

Where did the money to open the brokerage firm come

Who were Jay Comaeux and Al Truellenque?

Mr. Comaeux and Mr. Truellenque were the initial

11 hires for the new brokerage. They were hired as

How was Mr. Stanford able to persuade them to leave

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

Better business opportunity, on a remuneration basis,

17 opportunity to elevate themselves in terms of position.

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

19 whether he was paying Mr. Truellenque and Mr. Comaeux

20 fairly well in order to leave Merrill Lynch and come to

Yes, sir. Their pay was very competitive.

Where were they based when the brokerage firm opened?

Baton Rouge, Louisiana.

And over time did the brokerage firm open other

1 branches and offices elsewhere in the United States?

Where did the money come to do that?

The money came from CD deposit holders.

Did the bank have any ownership interest in the

Did the brokerage firm repay the bank?

Who owned the brokerage firm?

Mr. Allen Stanford.