Deposition of Scott Rothstein re - Trustee Services

1 determine whether or not a specific deal, as
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2 represented by a promissory note, was related to the
3 bridge loan scheme as opposed to the settlement
4 agreement related scheme, you would want to look at an
5 e-mail to determine which it was. What in the e-mail
6 would you be looking for that would help you identify
7 which type of deal it was?
8 A. I'd be looking for things such as money
9 in-house, whether or not I used the term loan, whether
10 or not I'm referencing a client needing the money and
11 how I'm referencing it. It would be the overall
12 review of the document by me to tell you for certain.
13 Q. Okay. Do the number of deals, since there
14 were 30 or 40 of them, instead of kind of walking you
15 through it, each one, I'm trying to get an idea if you
16 understand at some point if you transitioned from
17 doing bridge loan type deals with Mr. Tonacchio and/or
18 Mr. Lipsitz into doing settlement agreement related
19 deals or if it was all bridge loan related deals
20 throughout?
21 MR. PHILLIPS: Object to the form.
22 MR. SALIM: Form, predicate.
23 THE WITNESS: I recall both. I recall
24 both. In looking at this document, this April 16,
25 2007 e-mail this appears to be a bridge loan, but I