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 Q. So describe for me what happened in London. 2 Where did you meet? 3 A. The bulk of the meetings to the best of my 4 recollection occurred -- actually in London all of 5 the meetings occurred in hotel rooms -- either 6 Manfredi's hotel room and Albert's hotel room. 7 Mr. Lippman and I -- I don't remember if 8 they were in the same hotel or not -- I believe they 9 were -- Mr. Lippman and I shuttled back and forth 10 between the hotel rooms. 11 Some of the negotiations and conversations 12 with Albert actually took place outside. I have a 13 fairly distinct recollection of walking around 14 outside someplace in London -- me, Albert and Steve 15 Lippman -- discussing the importance of keeping this 16 smooth, as amicable as possible. 17 There were times when Manfredi was led to 18 believe that we -- that Lippman and I were down there 19 browbeating Albert -- when in reality we were out 20 drinking. 21 Q. "We" being the three of you? 22 A. There was an occasion where we were 23 ordering -- yes -- and continued back and forth like 24 that. 25 As a matter of fact, my best recollection Page 122

1 is that until the very end, until the agreement was Page 123 2 reached, that Manfredi and Albert were refusing to 3 actually meet with each other. They wouldn't have a 4 face-to-face meeting. We were the go-betweens -- 5 Mr. Lippman and I. 6 Q. Actually, wasn't that better for you if 7 you wished to manipulate the process? 8 A. Yes. Yes. It was better all the way 9 around. 10 Q. So Manfredi did not know that you were 11 being social with Albert during this shuttle 12 diplomacy, nor did he know that you were actually 13 effectively negotiating on Albert's behalf. Correct? 14 A. That's correct. 15 Q. And Lippman was doing that as well. 16 Correct? 17 A. That's correct. 18 Q. A clear legal conflict of interest under 19 Florida law. 20 Would you agree with that? 21 A. Yes, sir. 22 Q. Did not divulge it to Silversea. 23 Correct? 24 A. That's correct. 25 Q. Silversea thought that Albert had his own

1 Q. So describe for me what happened in London.<br />

2 Where did you meet?<br />

3 A. The bulk <strong>of</strong> the meetings to the best <strong>of</strong> my<br />

4 recollection occurred -- actually in London all <strong>of</strong><br />

5 the meetings occurred in hotel rooms -- either<br />

6 Manfredi's hotel room and <strong>Albert</strong>'s hotel room.<br />

7 Mr. Lippman and I -- I don't remember if<br />

8 they were in the same hotel or not -- I believe they<br />

9 were -- Mr. Lippman and I shuttled back and forth<br />

10 between the hotel rooms.<br />

11 Some <strong>of</strong> the negotiations and conversations<br />

12 with <strong>Albert</strong> actually took place outside. I have a<br />

13 fairly distinct recollection <strong>of</strong> walking around<br />

14 outside someplace in London -- me, <strong>Albert</strong> and Steve<br />

15 Lippman -- discussing the importance <strong>of</strong> keeping this<br />

16 smooth, as amicable as possible.<br />

17 There were times when Manfredi was led to<br />

18 believe that we -- that Lippman and I were down there<br />

19 browbeating <strong>Albert</strong> -- when in reality we were out<br />

20 drinking.<br />

21 Q. "We" being the three <strong>of</strong> you?<br />

22 A. There was an occasion where we were<br />

23 ordering -- yes -- and continued back and forth like<br />

24 that.<br />

25 As a matter <strong>of</strong> fact, my best recollection<br />

Page 122

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