Excerpts from the depositions - Wall Street Journal

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
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