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 have sent those e-mails? Page 22 2 A. Friends and family. 3 Q. Would it be fair to say that you would send 4 them to close friends and family? 5 A. I'd have to see the list of people that I 6 sent it to to tell you whether they were all close 7 friends, but yes, I think that's a fair assumption. 8 Q. I believe you have access to documents that 9 we've marked for use at this deposition. 10 A. I do. 11 Q. Do you have that in front of you? And what 12 I'm specifically referring to is the file that's 13 marked T-TL. 14 A. Bear with me one second. What exhibit? 15 Q. T-TL 00254. 16 A. I see that. 17 Q. Can you look at the "from" line. Tell me if 18 you recognize that address. 19 A. I do. 20 Q. What address is that? 21 A. It's the e-mail address of one of 22 Mr. Tonacchio's assistants at Tona Development. 23 Q. That's typically how you would communicate 24 with Mr. Tonacchio, via e-mail through that address? 25 A. Yes.

1 Q. And this is an e-mail in June of 2008 from Page 23 2 that address to you. Do you see that? 3 A. Yes, sir. 4 Q. And it references Mr. Tonacchio wanting to 5 get your home address in order to invite you to his 6 daughter's graduation party. Do you see that? 7 A. I do. 8 Q. Did he actually invite you to his daughter's 9 graduation party? 10 A. I believe he did, sir. 11 Q. Did you attend? 12 A. I did not. 13 Q. Did you send a gift? 14 A. I don't know whether we did or not, one way 15 or the other. 16 Q. If you'd look at I believe it's the next 17 document, it's 255. It's an e-mail in June of 2008 18 from the same e-mail address to you. It's just 19 referencing what time you are going to meet 20 Mr. Tonacchio for dinner in the city. Do you see 21 that? 22 A. I do. 23 MR. SALIM: Form. 24 BY MR. GAY: 25 Q. Do you recall specifically why you were

1 Q. And this is an e-mail in June <strong>of</strong> 2008 from<br />

Page 23<br />

2 that add<strong>re</strong>ss to you. Do you see that?<br />

3 A. Yes, sir.<br />

4 Q. And it <strong>re</strong>fe<strong>re</strong>nces Mr. Tonacchio wanting to<br />

5 get your home add<strong>re</strong>ss in order to invite you to his<br />

6 daughter's graduation party. Do you see that?<br />

7 A. I do.<br />

8 Q. Did he actually invite you to his daughter's<br />

9 graduation party?<br />

10 A. I believe he did, sir.<br />

11 Q. Did you attend?<br />

12 A. I did not.<br />

13 Q. Did you send a gift?<br />

14 A. I don't know whether we did or not, one way<br />

15 or the other.<br />

16 Q. If you'd look at I believe it's the next<br />

17 document, it's 255. It's an e-mail in June <strong>of</strong> 2008<br />

18 from the same e-mail add<strong>re</strong>ss to you. It's just<br />

19 <strong>re</strong>fe<strong>re</strong>ncing what time you a<strong>re</strong> going to meet<br />

20 Mr. Tonacchio for dinner in the city. Do you see<br />

21 that?<br />

22 A. I do.<br />

23 MR. SALIM: Form.<br />

24 BY MR. GAY:<br />

25 Q. Do you <strong>re</strong>call specifically why you we<strong>re</strong>

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