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Case 2:11-cv-10549-MRP-MAN Document 254-1 Filed 03/28/13 Page 18 of 35 Page ID #:16607 EXHIBIT 3
Case 2:11-cv-10549-MRP-MAN Document 254-1 Filed 03/28/13 Page 19 of 35 Page ID #:16608 Deposition Testimony of Steven J. Manzari March 15, 2013 Steven Manzari was the FRBNY’s “number two” person in charge of its relationship with AIG. • “Q. Were you the second most senior? A. So, there were several senior vice presidents. Sarah [Dahlgren] was a senior vice president at that time, but she was the team leader of the team, and I functioned as her number two.” 17:9–14. • “Q. You told us that Sarah Dahlgren was the most senior person and you functioned as her number two, correct? A. Yes. Q. . . . Was there another number two? Or did you understand your role to be the next senior person on the team below Sarah Dahlgren? A. I think that’s how Sarah would have described my role.” 146:19–147:7. • “A. So, to the extent that, for instance, one of my colleagues was assigned to the Maiden Lane III transaction, another one was assigned to the Maiden Lane II transaction, they, I think, would have been far more involved in the specific drafting of the legal agreements, etcetera. Q. And who was that . . . for Maiden Lane II? A. James Mahoney.” 106:2–12. • “Q. [Y]ou certainly understood what the terms of the transactions were as between ML II and AIG, correct? A. Yes.” 110:4–8. Manzari repeatedly testified he had no discussions with anyone about transferring AIG’s fraud claims. • “Q. Do you remember any discussion leading up to the execution of the Maiden Lane II documents about AIG somehow giving up its rights to try to seek any recovery from anyone for the losses of the $17 billion? A. No.” 99:15–20. • “Q. At any point in time, were you involved with any—in any discussion? And this is either with AIG or internally at the New York Fed—in which there was a discussion that in entering into Maiden Lane II, AIG would be in any way giving up its right to seek a recovery against any banks associated with that $17 billion loss? [Colloquy] A. I don’t recall any discussions.” 99:21–100:14. • “Q. You’re not aware of any discussions that you participated in with anyone from AIG in which there was any discussion about AIG giving up claims that it might have to go after the banks that had sold it the RMBS to try to recover those losses, correct, sir? A. I don’t recall any conversations in that regard.” 100:18–101:2. • “Q. [T]here was no discussion between the New York Fed and AIG regarding what would happen with such legal claims, right? [Objection] A. If your question is about legal claims, I don’t recall any conversations about—if you’re talking about things like reps and warranties, I don’t recall any conversations about that. Q. With AIG? A. With AIG. Q. How about internally at the New York Fed? A. I don’t—I don’t recall any conversations about those . . . specific factors.” 103:17–104:13. • “Q. [E]arlier I asked you the question of whether you recall any discussions with anyone regarding the idea or the concept of AIG somehow giving up claims that it would have against bank counterparties with respect to its losses suffered when it initially purchased EXHIBIT 3 1
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Excerpts from the depositions - Wall Street Journal

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