Deposition of Scott Rothstein re - Trustee Services

1 BY MR. SALIM:
Page 125
2 Q. If you'd look at Page TL 04.
3 A. I have it, sir.
4 Q. This is the first deal that we talked about
5 with Mr. Gay. And it goes back to the Ron Picou
6 electrocution story that he went through a number of
7 questions with you.
8 With respect to this particular note, you
9 created it?
10 A. I don't know that I necessarily typed it,
11 but I certainly provided the instruction for someone
12 to prepare it.
13 Q. Is this the standard form of note, other
14 than the payment terms, dates and amounts, that you
15 utilized on all of the deals with Mr. Tonacchio and
16 Mr. Lipsitz?
17 A. With certain variances I'm certain, yes.
18 Q. All right. And at the time you transmitted
19 these notes to them as of -- for instance, on this
20 one, March of 2007, you were also serving as counsel
21 for Mr. Tonacchio, correct?
22 A. You mean actually representing him in
23 ongoing matters at that moment or -- I was his
24 attorney.
25 Q. On a regular basis, whether you were