Deposition of Scott Rothstein re - Trustee Services

1 A. No.
Page 148
2 Q. Other than speaking with Mr. Nurick, which I
3 respect to be privilege, did you speak to any other
4 person in preparation for this deposition?
5 A. Yes.
6 Q. Who?
7 A. My -- the IRS agent and the AUSAs.
8 Q. And what was the general subject matter of
9 those conversations?
10 SPECIAL AGENT GUARIGLIA: Jeff?
11 MR. NURIK: Jeff, do you want to assert a
12 privilege?
13 MR. KAPLAN: Yeah, we'll object to that.
14 MR. SALIM: So the ordinary preparation for
15 this deposition is potentially privileged, is that
16 what you are saying, Mr. Kaplan?
17 MR. KAPLAN: What in particular?
18 MR. SALIM: Well, I'm asking him
19 strictly --
20 BY MR. SALIM:
21 Q. All right. Let's put it this way, in
22 connection with your preparation for this deposition,
23 what conversations did you have with anyone other than
24 your attorney regarding Domenick Tonacchio?
25 MR. KAPLAN: What questions -- what are you