Deposition of Scott Rothstein re - Trustee Services

1 Q. Do you know if this e-mail is in reference
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2 to that Picou deal we were discussing previously?
3 A. It appears to be.
4 Q. If you can review that for just a minute and
5 let me know if that refreshes your recollection as to
6 the specifics of that deal.
7 A. It does.
8 Q. How does that -- I mean, what recollection
9 does that refresh?
10 A. To ways I crafted this particular deal was
11 to enable a certain amount of money to be given to
12 Mr. Picou and certain amount of money to be infused
13 into the Ponzi scheme. I pitched it as a deal
14 specifically to help our friend, Mr. Picou. That's
15 about it.
16 Q. Do you remember why Mr. Picou needed the
17 money at that time?
18 A. I don't recall specifically.
19 Q. Mr. Lipsitz has previously discussed that
20 you represented to him, Mr. Lipsitz, that Mr. Picou,
21 through his company, Southern Grouts and Mortars, that
22 he had an employee who was electrocuted on the job.
23 Does that sound familiar?
24 A. That may have been what I told them, but
25 that would not have been true, that would have been a