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 identical? Page 76 2 A. As I sit here today, I don't have a specific 3 recollection. I did that frequently with deals. 4 Q. Do you remember what your reputation was to 5 the "investors" as to why there would be multiple 6 deals that would be structured exactly the same way? 7 A. Well, when they were settlement funding 8 deals, I told the investors that it was multiple 9 plaintiffs. So this could be one of those, but I 10 don't recall specifically. The e-mail is not detailed 11 enough. 12 Q. Then the fourth line of the e-mail it says, 13 "And again, an extra 10 points in fees for funding 14 today." Do you see that? 15 A. Yes. 16 Q. Do you remember why or what the 17 representation was as to why there would be this sort 18 of kicker for funding that day? 19 A. I know the actual reason. I don't know what 20 the lie was that I told them. 21 Q. And when it refers to extra 10 points, what 22 does that equate to dollar wise? 23 A. The way I wrote it, it looks like one 24 percent of the total loan amount in fees. One percent 25 for each point.

1 Q. So when you generally refer to points, it's 2 the same general connotation as when people talk about 3 mortgage loan paying down points, same idea? 4 A. Yes. 5 Q. As far as the percentage of the overall deal 6 total? 7 A. Yes. 8 Q. Okay. If you'd look at Document 00218, 9 please. 10 A. Okay. 11 Q. It's July 9, 2007-e-mail from you, Scott 12 Rothstein, to christinaztona@aol.com. Do you see 13 that? 14 A. Yes, I do. 15 Q. You said, "I spoke to him this morning... I 16 told him I was sending him an interest check for 15K." 17 Do you know who you were referring to when you say 18 "him"? 19 A. Looks like Domenick. 20 Q. It goes on to say, and that he should still 21 hold the check. Please tell him to hold the check -- 22 or excuse me, please tell him to hold it until I tell 23 him to deposit it. Do you see that? 24 A. I do. 25 Q. Tell me what that was in reference to. Page 77

1 identical?<br />

Page 76<br />

2 A. As I sit he<strong>re</strong> today, I don't have a specific<br />

3 <strong>re</strong>collection. I did that f<strong>re</strong>quently with deals.<br />

4 Q. Do you <strong>re</strong>member what your <strong>re</strong>putation was to<br />

5 the "investors" as to why the<strong>re</strong> would be multiple<br />

6 deals that would be structu<strong>re</strong>d exactly the same way?<br />

7 A. Well, when they we<strong>re</strong> settlement funding<br />

8 deals, I told the investors that it was multiple<br />

9 plaintiffs. So this could be one <strong>of</strong> those, but I<br />

10 don't <strong>re</strong>call specifically. The e-mail is not detailed<br />

11 enough.<br />

12 Q. Then the fourth line <strong>of</strong> the e-mail it says,<br />

13 "And again, an extra 10 points in fees for funding<br />

14 today." Do you see that?<br />

15 A. Yes.<br />

16 Q. Do you <strong>re</strong>member why or what the<br />

17 <strong>re</strong>p<strong>re</strong>sentation was as to why the<strong>re</strong> would be this sort<br />

18 <strong>of</strong> kicker for funding that day?<br />

19 A. I know the actual <strong>re</strong>ason. I don't know what<br />

20 the lie was that I told them.<br />

21 Q. And when it <strong>re</strong>fers to extra 10 points, what<br />

22 does that equate to dollar wise?<br />

23 A. The way I wrote it, it looks like one<br />

24 percent <strong>of</strong> the total loan amount in fees. One percent<br />

25 for each point.

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