Deposition of Scott Rothstein re - Trustee Services

1 A. Yes, sir.
Page 124
2 Q. And all of those notes were, in fact,
3 prepared by you or someone in your office?
4 A. Yes, sir.
5 Q. And the terms of those notes, were those
6 something that were negotiated between you and
7 Mr. Tonacchio, or would you just propose them in your
8 e-mail, he would accept or reject, and then you would
9 do the note?
10 A. To the best of my recollection, I proposed
11 it and he would accept or reject.
12 Q. And, in fact, there were a number of deals
13 where, for whatever reason, he didn't have the money
14 at the time, whatever, he didn't undertake the deal,
15 correct?
16 A. That's correct.
17 Q. By the way, on any of these deals, did he
18 ever pay you in cash or was it all by wire transfer?
19 A. All by wire.
20 Q. All right. Now, when you sent the
21 promissory note to him and -- do you have what is
22 referred to as the defendant's exhibits? There's
23 about 14 pages in front of you.
24 MR. GAY: Just tell him what the prefix is.
25 THE WITNESS: Yes, sir.