Deposition of Scott Rothstein re - Trustee Services

1 actually there with you. Do you recall if that's the
2 case?
3 MR. PHILLIPS: Objection to the form.
4 THE WITNESS: You know, sir, to the best of
5 my recollection, I can't recall. I don't recall
6 Mr. Picou actually being part of that conversation.
7 My recollection, as I sit here today, was that
8 Mr. Picou -- that I was trying to keep where I was
9 actually getting these funds that Mr. Picou needed
10 secret from him.
11 MR. GAY: Well, that's why I ask.
12 THE WITNESS: I could be -- I just don't
13 have a specific recollection one way or the other.
14 But it doesn't seem to me that I would have let
15 Mr. Picou know that I didn't have the capital to give
16 to him and that I needed to go get it from another
17 source.
18 BY MR. GAY:
19 Q. Well, that's part of the reason I ask,
20 because it seems like if you were trying to keep those
21 two parties apart, as far as Mr. Picou and
22 Mr. Tonacchio and/or Mr. Lipsitz, as far as what they
23 knew about this deal, then discussing it for the first
24 time with Mr. Tonacchio and Mr. Lipsitz with Mr. Picou
25 not far away would be sort of running an unnecessary
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