Deposition of Scott Rothstein re - Trustee Services

1 were sitting around in a group, like a meeting with
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2 me, Domenick and Barry, we didn't say, 'How is the
3 Ponzi going?'" And then you --
4 A. That's correct.
5 Q. -- went on and said, "Okay. We certainly,
6 individually, frequently talked about the fraud and
7 things that were going on; but that out-loud group
8 thing, that did not occur." Do you remember that
9 testimony?
10 A. Yes. You are not -- I don't think you are
11 understanding my prior testimony correctly.
12 Q. You think I'm not understanding it
13 correctly?
14 A. I'm certain you are not understanding it
15 correctly.
16 Q. Tell me what the understanding should be.
17 A. The bulk of the conversation I'm talking
18 about has to do with my conversations with Ted Morse,
19 because I discussed, as you know from prior deposition
20 testimony, significant fraudulent activity with Ted
21 that we did not discuss in person. There were other
22 fraudulent things that Domenick and Barry and I
23 discussed separately, but you'll see nowhere in my
24 testimony am I saying that I told Domenick or Barry
25 that this was a Ponzi scheme.