Excerpts from the depositions - Wall Street Journal
Excerpts from the depositions - Wall Street Journal
Excerpts from the depositions - Wall Street Journal
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Case 2:11-cv-10549-MRP-MAN Document 254-1 Filed 03/28/13 Page 22 of 35 Page ID<br />
#:16611<br />
Fed <strong>the</strong> comfort under 13.3 that it had security, or full security, to its satisfaction<br />
. . . correct? A. Yes.” 238:18–239:24.<br />
Manzari was never asked about his intent with respect to whe<strong>the</strong>r litigation claims were<br />
transferred, although he was intimately involved in <strong>the</strong> FRBNY’s negotiation of ML II.<br />
• “Q. Do you have any recollection at all of being asked by Mr. Baxter or anyone within<br />
<strong>the</strong> New York Fed, for you to provide historical information or views as to <strong>the</strong> rights that<br />
were or were not transferred to Maiden Lane II in 2008? A. No.” 143:23–144:5.<br />
• “Q. [Referring to representation of FRBNY’s intent to obtain litigation claims in<br />
Settlement Agreement] You’ve never seen that representation before, correct, sir? A.<br />
That is correct. Q. And you were asked whe<strong>the</strong>r you had any basis to disagree with it.<br />
You also have no basis to agree with it, correct, sir? A. Yeah, that’s correct.” 234:3–<br />
13.<br />
• “Q. At <strong>the</strong> time that Maiden Lane II documentation was being executed, <strong>the</strong> Asset<br />
Purchase Agreement, or <strong>the</strong> APA which you were asked about, Mr. Taylor [who executed<br />
<strong>the</strong> Settlement Agreement] had nothing to do with Maiden Lane II; am I correct? A.<br />
He—I don’t believe he was employed by <strong>the</strong> New York Fed at that time. Q. . . .<br />
You do know, because you were involved, you do know what <strong>the</strong> Fed’s intent was in<br />
entering into Maiden Lane II, correct, Mr. Manzari? A. I believe I do, yes.” 235:21–<br />
236:12.<br />
Manzari testified that <strong>the</strong> FRBNY did not enter into ML II to make a profit.<br />
• “Q. And is it <strong>the</strong> case that at that point in time—so, <strong>the</strong> fall into <strong>the</strong> winter of 2008—<strong>the</strong><br />
markets <strong>the</strong>mselves were in crisis? A. Significant stress.” 53:5–9.<br />
• “A. What I would say is that we became involved with AIG when senior<br />
policymakers at <strong>the</strong> Federal Reserve, and <strong>the</strong> Treasury, and o<strong>the</strong>r parts of <strong>the</strong><br />
government made a determination that <strong>the</strong> disorderly failure of AIG would have<br />
been unacceptable consequences for <strong>the</strong> U.S. economy.” 165:23–166:5.<br />
• “A. Our overall objective was to prevent <strong>the</strong> disorderly failure of AIG. ‘Cause we<br />
believed it was—it would have been a very big problem for <strong>the</strong> U.S. economy.”<br />
154:21–155:2.<br />
• “A. I think that’s all indicative of some fairly unique stress in <strong>the</strong> financial system.<br />
Q. So, it wasn’t a problem that was unique to AIG, correct? [Objection] A. I think it<br />
was—in my view, it would be both. AIG had <strong>the</strong>ir own specific issues, and <strong>the</strong>re was<br />
broad stress as well.” 245:2–11.<br />
• “A. The point of that was to demonstrate to <strong>the</strong> rating agencies that <strong>the</strong>re was a<br />
comprehensive package of actions that—that <strong>the</strong> U.S. Government was going to<br />
take to support AIG.” 161:24–162:4.<br />
• “Q. Was it also important to structure <strong>the</strong> assistance in a way that made it more likely that<br />
<strong>the</strong> assistance would be paid back? A. We have a requirement that we need to be<br />
secured to our satisfaction. Q. But along with preventing <strong>the</strong> failure, it was important<br />
that <strong>the</strong> credit you were extending, in fact got paid back? A. Yes, that would—yes.<br />
Very much so.” 173:25–174:15.<br />
EXHIBIT 3<br />
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