Deposition Transcript of Scott Rothstein (Albert ... - Trustee Services

Deposition Transcript of Scott Rothstein (Albert ... - Trustee Services Deposition Transcript of Scott Rothstein (Albert ... - Trustee Services

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1 A. I'm sorry. Can you repeat the question? Page 108 2 Q. You said that you had lied to Silversea 3 about them being on poor legal footing with respect 4 to Albert's termination from the company. 5 Did I understand you correctly? 6 A. Yes, sir. 7 Q. Did Mr. Peter have an employment agreement? 8 A. I don't recall whether he did or not. 9 Q. Do you recall if he was terminable at will? 10 A. I don't recall off the top of my head. 11 I'd need to see the agreements and the 12 transition agreement. I just don't recall. 13 Q. What is it that you recall lying to 14 Silversea about concerning Mr. Peter? 15 A. The main thing was that he was going to go 16 to the media and blast Manfredi. 17 The other thing was that if they did engage 18 in litigation with him, that the skeletons in 19 Manfredi's closet and in the company's closet would 20 ultimately be exposed, placing them on weak legal 21 footing and also poor PR footing if they proceeded 22 with such litigation. 23 Q. When you used the phrase earlier "poor 24 legal footing," were there legal theories of relief 25 or legal arguments that you misstated to Silversea?

1 A. I don't recall that we specifically got Page 109 2 into very many actual legal discussions. Manfredi's 3 main thing was to avoid the expenditure of what I 4 told him would be hundreds of thousands of dollars in 5 additional legal fees, only to have no one actually 6 really win the litigation, but, on the other hand, if 7 they let him go nice and quietly under at least 8 semi-decent terms, that they would have a friend if 9 there was future litigation that he needed to testify 10 in, and since it was likely that Albert was going to 11 remain in the cruise industry, that he would be able 12 to engage on a professional level with him as opposed 13 to an adversarial level. 14 Q. Did Albert know that you were having these 15 conversations with Silversea where you were telling 16 Manfredi and Amerigo that Albert was going to be 17 vindictive and divulge all of this highly sensitive 18 information about Manfredi? 19 A. Yes. 20 Q. How is it that he knew? 21 A. How did Albert know that? 22 Q. Yeah. 23 A. Albert and I discussed it. We came up with 24 the whole plan. 25 Q. How often did you discuss that with Albert

1 A. I don't recall that we specifically got<br />

Page 109<br />

2 into very many actual legal discussions. Manfredi's<br />

3 main thing was to avoid the expenditure <strong>of</strong> what I<br />

4 told him would be hundreds <strong>of</strong> thousands <strong>of</strong> dollars in<br />

5 additional legal fees, only to have no one actually<br />

6 really win the litigation, but, on the other hand, if<br />

7 they let him go nice and quietly under at least<br />

8 semi-decent terms, that they would have a friend if<br />

9 there was future litigation that he needed to testify<br />

10 in, and since it was likely that <strong>Albert</strong> was going to<br />

11 remain in the cruise industry, that he would be able<br />

12 to engage on a pr<strong>of</strong>essional level with him as opposed<br />

13 to an adversarial level.<br />

14 Q. Did <strong>Albert</strong> know that you were having these<br />

15 conversations with Silversea where you were telling<br />

16 Manfredi and Amerigo that <strong>Albert</strong> was going to be<br />

17 vindictive and divulge all <strong>of</strong> this highly sensitive<br />

18 information about Manfredi?<br />

19 A. Yes.<br />

20 Q. How is it that he knew?<br />

21 A. How did <strong>Albert</strong> know that?<br />

22 Q. Yeah.<br />

23 A. <strong>Albert</strong> and I discussed it. We came up with<br />

24 the whole plan.<br />

25 Q. How <strong>of</strong>ten did you discuss that with <strong>Albert</strong>

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