Deposition of Scott Rothstein re - Trustee Services

Deposition of Scott Rothstein re - Trustee Services Deposition of Scott Rothstein re - Trustee Services

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1 months later in April of 2009. And the subject says Page 144 2 "update." 3 MR. GAY: Bill, what was the date on that 4 e-mail again? 5 MR. SALIM: April 20, 2009. 6 MR. GAY: Talking about 00013. 7 MR. SALIM: Marked as Defendant's Exhibit 8 Number 11. 9 MR. GAY: Which document? 10 MR. SALIM: 13. 11 BY MR. GAY: 12 Q. Do you have that one in front of you, sir? 13 A. I do. 14 Q. All right. What is this e-mail? 15 A. Same type of e-mail, trying to get payment. 16 Q. And again, this would have been in 17 connection with a settlement transaction deal, 18 correct? 19 A. Yes. 20 Q. So here we are, basically five months before 21 the Ponzi imploded, and you are still lying to 22 Mr. Tonacchio about the settlement transactions in 23 order to keep him funding the deals, correct? 24 MR. GAY: Objection to form. 25 THE WITNESS: In order to get the wire,

1 yes, sir. Page 145 2 MR. SALIM: All right. Next, TL 14, which 3 we have marked as Exhibit Number 12 -- 4 [The E-mail referred to was marked for 5 identification as Defendant's Exhibit 12.] 6 BY MR. SALIM: 7 Q. -- is an e-mail dated August 31, 2009, but 8 less than two months prior to your flight to Morocco. 9 And what's this one about? 10 A. Just looking for money that was supposed to 11 be wired. 12 Q. And again, it would have been in connection 13 with a settlement structured deal? 14 A. I can't tell one way or the other because it 15 doesn't have the other language in it. It just says, 16 "My client is coming in." But by this point in time I 17 think the bulk of the deals we were doing were 18 settlement type deals. 19 Q. You would agree -- 20 A. But I can't tell one way or the other. 21 Q. Would you agree that at this point in time, 22 RRA as a law firm could only have clients who were 23 plaintiffs or defendants and/or business clients? 24 MR. GAY: Objection to form. 25 THE WITNESS: It could have been any myriad

1 yes, sir.<br />

Page 145<br />

2 MR. SALIM: All right. Next, TL 14, which<br />

3 we have marked as Exhibit Number 12 --<br />

4 [The E-mail <strong>re</strong>fer<strong>re</strong>d to was marked for<br />

5 identification as Defendant's Exhibit 12.]<br />

6 BY MR. SALIM:<br />

7 Q. -- is an e-mail dated August 31, 2009, but<br />

8 less than two months prior to your flight to Morocco.<br />

9 And what's this one about?<br />

10 A. Just looking for money that was supposed to<br />

11 be wi<strong>re</strong>d.<br />

12 Q. And again, it would have been in connection<br />

13 with a settlement structu<strong>re</strong>d deal?<br />

14 A. I can't tell one way or the other because it<br />

15 doesn't have the other language in it. It just says,<br />

16 "My client is coming in." But by this point in time I<br />

17 think the bulk <strong>of</strong> the deals we we<strong>re</strong> doing we<strong>re</strong><br />

18 settlement type deals.<br />

19 Q. You would ag<strong>re</strong>e --<br />

20 A. But I can't tell one way or the other.<br />

21 Q. Would you ag<strong>re</strong>e that at this point in time,<br />

22 RRA as a law firm could only have clients who we<strong>re</strong><br />

23 plaintiffs or defendants and/or business clients?<br />

24 MR. GAY: Objection to form.<br />

25 THE WITNESS: It could have been any myriad

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