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Deposition of Scott Rothstein re - Trustee Services

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1 because they couldn't have given a crap one way or the<br />

2 other whe<strong>re</strong> the money was coming from so long as they<br />

3 made money, they <strong>re</strong>qui<strong>re</strong>d documents. It varied.<br />

4 Q. We<strong>re</strong> Mr. Tonacchio and Mr. Lipsitz in that<br />

5 latter group that you a<strong>re</strong> talking about, not giving a<br />

6 crap whe<strong>re</strong> the money came from?<br />

7 MR. SALIM: Form.<br />

8 MR. PHILLIPS: Objection to form.<br />

9 THE WITNESS: In the beginning I believe<br />

10 that they trusted me so that they didn't <strong>re</strong>qui<strong>re</strong> any<br />

11 additional documentation. After we got into full<br />

12 swing and they we<strong>re</strong> making millions <strong>of</strong> dollars, I<br />

13 always got the imp<strong>re</strong>ssion that as long as everything<br />

14 was going fine, they we<strong>re</strong> fine.<br />

15 BY MR. GAY:<br />

16 Q. Do you <strong>re</strong>call typically how the funding<br />

17 would work on the deals that you ente<strong>re</strong>d into with<br />

18 Mr. Tonacchio and Mr. Lipsitz, or did you have a sort<br />

19 <strong>of</strong> routine?<br />

20 A. They would wi<strong>re</strong> the money -- I'd send them<br />

21 an e-mail, they'd accept or <strong>re</strong>ject the deals. They<br />

22 would then wi<strong>re</strong>, and I would overnight them a<br />

23 promissory note with the postdated checks.<br />

24 Q. Why postdated checks as opposed to wiring<br />

25 money back to them?<br />

Page 68

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