2011-12-15 Rothstein Scott AM

IN THE CIRCUIT COURT OF THE 17TH
JUDICIAL CIRCUIT IN AND FOR

BROWARD COUNTY, FLORIDA
Case No. 09-062943 (07)
_____________________________________________________
RAZORBACK FUNDING, LLC, et al.,
Plaintiffs,
vs.
SCOTT W. ROTHSTEIN, et al.,
Defendants.
____________________________________________________
DAY 4 - MORNING SESSION

DEPOSITION OF SCOTT W. ROTHSTEIN
DATE TAKEN:
TIME:
PLACE:
December 15, 2011

8:42 a.m. - 12:09 p.m.
James Lawrence King Federal
Justice Building
99 N.E. Fourth Street
Courtroom 11-3
Miami, Florida 33128
Examination of the witness taken before:

Michele L. Savoy, Registered Professional Reporter
United Reporting, Inc.
1218 S.E. Third Avenue
Fort Lauderdale, Florida 33316
(954) 525-2221

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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
2
3
____________________________________________________
Case No. 10-24110 CACE (19)
EDWARD J. MORSE and CAROL A. MORSE,

and MORSE OPERATIONS, INC.
6
Plaintiffs,
7
vs.
8
9
SCOTT W. ROTHSTEIN, et al.,
10
11
Defendants.
_____________________________________________________
12
13
Case No. 11-CV-61688-JIC/LSS

AMY ADAMS, et. al,
14
Plaintiffs,
15
vs.
16
SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTAR

PRIVATE BANK AND TRUST COMPANY,
17
18
19
Defendants.
_____________________________________________________
10-03767-RBR Stettin v. Gibraltar Private
Bank & Trust Co.
20
11-03802-RBR Stettin v. Fidelity Gift Fund
21
11-02368-RBR Stettin v. TD Bank, N.A.
22
23
24
25

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APPEARANCE FOR SCOTT ROTHSTEIN:

LAW OFFICE OF MARC S. NURIK
1 East Broward Boulevard
Suite 700
BY: MARC S. NURIK, ESQUIRE
APPEARANCE FOR THE TRUSTEE:
BERGER SINGERMAN
350 East Las Olas Boulevard
Suite 1000
BY: CHARLES H. LICHTMAN, ESQUIRE
APPEARANCES FOR THE TRUSTEE:
GENOVESE, JOBLOVE & BATTISTA, P.A.
100 S.E. 2nd Street
Suite 4400
By: JOHN. H. GENOVESE, ESQUIRE
DAVID C. CIMO, ESQUIRE
THERESA M.B. VAN VLIET, ESQUIRE
APPEARANCES FOR RAZORBACK:
CONRAD & SCHERER, LLP
633 South Federal Highway
Eighth Floor
By: WILLIAM R. SCHERER, ESQUIRE
REID A. COCALIS, ESQUIRE
IVAN J. KOPAS, ESQUIRE
KOZYAK, TROPIN & THROCKMORTON, P.A.
2525 Ponce de Leon Boulevard
Ninth Floor
Coral Gables, Florida 33134
By: ADAM MOSKOWITZ, ESQUIRE
22
23
24
25

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APPEARANCE FOR PLATINUM PARTNERS VALUE ARBITRAGE

CENTURION STRUCTURED GROWTH, LLC:
2
3
4
GOLDSTEIN, TANEN & TRENCH, P.A.

One Biscayne Tower, Suite 3700
Two South Biscayne Boulevard
By: SUSAN E. TRENCH, ESQUIRE
5
6
7
8
9
10
11
12
13
14
15
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APPEARANCE FOR LEVINSON'S JEWELERS:

KOPELOWITZ OSTROW FERGUSON WEISELBERG KEECHL
200 SW 1st Ave
Suite 1200
Fort Lauderdale, Florida 33301-2073
BY: JAN ATLAS, ESQUIRE
APPEARANCE FOR THE COMMITTEE OF UNSECURED:
AKERMAN, SENTERFITT
One Southeast Third Avenue
25th Floor
Miami, Florida 33131-1704
By: MICHAEL GOLDBERG, ESQUIRE
APPEARANCE FOR T.D. BANK:
GREENBERG TRAURIG, P.A.
401 E Las Olas Blvd Ste 2000
By: DONNA M. EVANS, ESQUIRE
17
18
19
20
21
22
23
24
25
APPEARANCE FOR RLI ZURICH INSURANCE COMPANY,

COLUMBIA INC. & ZURICH INSURANCE:
CLAUSIN MILLER
One Chase Manhattan Plaza
39th Floor
New York, New York 10005
BY: SCOTT L. SCHMOOKLER, ESQUIRE
APPEARANCE FOR FEDERAL INSURANCE COMPANY:
Alex Hofrichter, P.A
1430 South Dixie Highway
Suite 204
Coral Gables, Florida 33146-3127
By: ALEX HOFRICHTER, ESQUIRE

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APPEARANCES FOR MORSE:

TRIPP SCOTT, P.A.
110 S.E. Sixth Street,15th Floor
By: GEORGE WALKER, ESQUIRE
JOHN M. MULLIN, ESQUIRE
APPEARANCE FOR EMESS CAPITAL, LLC:
Kluger Kaplan Silverman
Katzen & Levine PL
201 S Biscayne Blvd Fl 17
BY: CASEY CUSICK, ESQUIRE
APPEARANCE FOR ST. PAUL FIRE & MARINE:
Mills Paskert Divers P A
100 N Tampa St Ste 2010
Tampa, Florida 33602-5145
JOHN A. BLACK, JR., ESQUIRE
12
13
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APPEARANCE FOR ROSEANNE CARETSKY:

Billing Cochran Lyles
515 E Las Olas Blvd
Floor Six
Fort Lauderdale, Florida 33301-2296
By: W. TUCKER CRAIG, ESQUIRE
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INDEX
CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN
3
DIRECT
776
Mr. Cimo
CERTIFICATE OF OATH
CETIFICATE OF REPORTER
945
946
6
7
8
TRUSTEE'S EXHIBITS INDEX

NO.
123
9
124
10
125
11
12
13
14
15
16
17
18
19
20
21
22
23
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
DESCRIPTION
Credit Agreement - Banyon
Investing
Investments
Resources
Platinum v. Kroll
Platinum v. Kroll Order
"Good Fellows" Email
Radinsky Email
ROTHSTEINS 000940-957
SW13-00735 - 805
PCL56665 - 56666
PCL56811 - 56815
Dec. 25, 2008, Email
Hertzberg Declaration
Email Chain
PCL59074
April 4, 2009, Email
E027088
PCL59319
PCL59402 - 403
Email Chain
May 6, 2009, Email
PLATCENT 0021184
ROTHSTEINS 000931 - 932
PCL 0484 - 0489
PAGE NO
777
777
777
793
827
852
858
861
868
873
878
897
901
913
916
916
921
921
921
921
921
921
921
921
927
931
932
24
25

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Whereupon,
SCOTT W. ROTHSTEIN,
acknowledged having been duly sworn to tell the truth
and testified upon his oath as follows:
THE WITNESS:
I do.
DIRECT EXAMINATION
BY MR. CIMO:
Good morning, Mr. Rothstein, how are you?
Good.
10
David Cimo.
Good morning to you.

I did the 2004 of you with
11
Mr. Lichtman, earlier, in the sessions that we have been
12
doing.
13
Stettin, and I'll be talking to you about the hedge
14
funds that you have previously spoken about but we are
15
going to cover some different areas.
As you know, I represent the Trustee Herb
16
First of all, do you know we have a lawsuit
17
pending against the hedge funds on behalf of the
18
estate --
19
COURT REPORTER:
20
down a little bit?
21
22
Excuse me, can you slow
-- to recover certain transfers as fraudulent
transfers?
23
24
BY MR. CIMO:
25
Do I know that, yes.
How did you come to learn about that?

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Somewhere, someone along the line, in the
8 million sheets of paper that I looked at, told me that
was filed; and I may have actually seen the lawsuit.
don't recall, specifically.
Do you recall the entities that were involved,
the actual names of the entities that were involved
regarding Centurion, Platinum, Level 3?
their specific names?
Do you remember
No, I don't.
10
I'm going to show you Exhibits 123, 124, and
11
125 to refresh your memory.
12
(Thereupon, documents was marked as Trustee's
13
Exhibits No. 123, 124 and 125, respectively for
14
identification.)
15
Thank you.
16
I'll represent to you that Exhibit 123 is the
17
Centurion Structured Growth, LLC, credit agreement with
18
Banyon Funding, LLC; have you seen this agreement before
19
today?
20
No.
21
Did you know that there was an agreement
22
between Centurion Structured Growth, LLC, and an entity
23
known as Banyon Funding?
24
25
An agreement, yes; a credit agreement, I can't
tell you whether I knew one way or another.
It was

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inconsequential to me.
Thank you.
And for purposes of this deposition, I'm going
to refer to Centurion Structured Growth, LLC as
Centurion.
Is that okay with you?
Yes, sir.
I'm also going to refer to Banyon Funding LLC
as Banyon Funding.
Is that acceptable?
Yes, sir.
10
I would like you to look at Exhibit 124.
11
I've got it.
12
This is a credit agreement dated June 26,
13
2008.
Have you seen this before today?
14
I have not.
15
Did you know that there was some agreement
16
between an entity known as Banyon Investments, LLC, and
17
an entity known as Platinum Partners Value Arbitrage
18
Fund, LP?
19
Yes.
20
How did you come to learn about that?
21
I discussed it at some point in time with
22
23
Mr. Preve.
Q
For purposes of this deposition, I'm going to
24
refer to Banyon Investments as BIF.
25
to you?
Is that acceptable

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Yes, sir.
I'm going to refer to Platinum Partners Value
Arbitrage Fund, LP, as Platinum.
you?
Yes, it is.
Okay.
Is that acceptable to
Oh, I apologize, I'm going to call that Banyon
Investments.
That's fine.
10
Thank you.
11
And the last exhibit of the three I'm showing
12
you is an Exhibit No. 125, and it's a credit agreement
13
dated September 3rd, 2008, between Banyon Resources,
14
LLC, and an entity known as Level 3 Capital Fund, LP.
15
16
17
Do you recall such an agreement existing near

or about that date?
A
I have never seen this document, I don't
18
believe, but I remember there being an agreement of some
19
sort between Banyon and Level 3.
20
Okay.
And far purposes of this deposition
21
today, I'm going to refer to Banyon Resources, LLC, as
22
Banyon Resources.
Is that acceptable?
23
Yes, sir.
24
I'm going to refer to Level 3 Capital Fund,
25
LP, as Level 3.
Is that acceptable?

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Yes, sir.
I'm also going to refer to all three of the
entities that I just mentioned on the hedge fund level.
That would be Platinum, Centurion, and Level 3, as the
hedge funds, is that acceptable?
Yes, sir.
And I'm going to refer to the Banyon entities
that we went through, for purposes of this deposition,
unless I say otherwise, as the Banyon entities.
Is that
10
acceptable?
11
Yes, sir.
12
When did you first learn about the existence
13
14
of any one of the hedge funds?

A
My recollection, it would have been late 2007,
15
sometime in 2008 when Mr. Preve and Mr. Levin told me
16
that they were looking to go for hedge fund dollars, but
17
I don't recall the specific time period.
18
Before that time, had there been any
19
discussion with Mr. Preve about any other hedge funds
20
playing some type of role in the investments that you
21
were offering?
22
There was always talk between me and Mr. Preve
23
about alternative funding sources, other than Mr.
24
Levin's various personal entities.
25
whether specifically hedge funds were discussed.
I don't recall

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Before the hedge funds that we have defined
for purposes of this deposition were discussed, that
period that you referenced, had any hedge funds been
investors in any of the settlements that you were
purporting to offer?
And here's the issue with that question.

I was under the belief, at the time prior to
the hedge funds being involved, that all the money being
invested was Mr. Levin's personal funds.
I later came
10
to know that at some point in time, he was soliciting
11
other investors, so I can't tell you one way or other
12
whether Mr. Levin took money from a hedge fund
13
unbeknownst to me.
14
But to my knowledge, Centurion, Platinum,
15
Level 3 were the first hedge funds that I had knowledge
16
of investing in the Ponzi scheme.
17
When you say Mr. Levin, the Banyon entities
18
that we defined for purposes of this deposition, were
19
those entities that you understood were controlled
20
and/or owned by Mr. Levin?
21
22
23
Yes, as far as I was concerned, they were
interchangeable.
Q
Is it to your testimony that, as to the three
24
Banyon entities that we have defined for purposes of
25
this deposition, that to your knowledge, up until these

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hedge funds came along -- Platinum, Centurion and Level
3 -- prior to that period, it's your testimony that you
don't know whether other hedge funds may have invested
through Banyon -- other Banyon entities?
I have no idea who Mr. Levin took money from.
So, the hedge funds -- Platinum, Centurion and
Level 3 -- that did, ultimately, get involved, to your
knowledge, those were the first and only hedge funds
that you knew were either direct or indirect investors
10
11
in the structured -- supposed structured settlements?

A
Up until -- they were never supposed
12
structured settlement, but up until that point in time,
13
they were the first hedge funds to invest in the Ponzi
14
scheme, yes.
15
16
17
What was the importance, if any, to obtaining
hedge-fund money?
A
For me, it was just another source of money.
18
For Mr. Levin, it was another source of money.
19
Mr. Preve, it was another source of money.
20
think any of the three of us cared with where it came
21
from, as long as we were getting it.
22
For
I don't
And you also testified, I believe, that Mr.
23
Szafranski had certain entities that he had set up that
24
were to also soliciting investors that you did know
25
about, correct?

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2
Yes.
That occurred after the hedge funds,
basically, cut us off.
So this period of time that you mentioned,
this 2007, 2008 time period, in what context did you
come to learn that there were hedge fund -- that these
particular hedge funds had an interest in becoming
involved in settlements?
8
9
Either Mr. Preve, Mr. Levin, or likely both of
them, told me that they were going after some hedge
10
funds to become feeders into our settlement business and
11
that eventually we would likely have to go meet with
12
him.
13
And, ultimately, did you come to contact any
14
of them or meet with any of them directly, before any
15
investments were made?
16
Before any investments were made, I believe
17
that is when it was, I actually flew to New York with
18
Mr. Preve -- I don't believe Mr. Levin was on that
19
trip -- to meet with the various hedge fund folks.
20
I want to go back to Exhibit 123, which is the
21
April 3rd, 2008, credit agreement; and to your
22
recollection, was Centurion the first of the hedge fund
23
to become an investor?
24
25
To my recollection, it was -- yes.
Centurion
was the very first.

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And then I would like you to look at Exhibit
No. 124, which is the June 26th, 2008, credit agreement.
Does this refresh your memory as to whether Platinum was
the second hedge fund to invest?
Yeah, I -- for some reason, in my mind,
Centurion and Platinum were basically the -- for lack of
a better term, pitched together, and Level 3 came along
later in time.
9
10
But, yes, it seems to me Centurion was

primary; Platinum, second in line; and Level 3, third.
11
And, indeed, Exhibit No. 125, the credit
12
agreement November 3rd, 2008, between Banyan Resources
13
and Level 3 is, in fact, the latest of the three?
14
That's correct.
15
Now, in terms of this meeting that you said
16
was arranged, that meeting did occur in New York?
17
It did.
18
And do you know whether it occurred before or
19
after April 3rd of 2008, which is the date of Exhibit
20
123?
21
I have no specific recollection.
22
And who was in attendance at that meeting?
23
Well, let me tell you to the best of my
24
recollection:
25
Nordlicht, Mark Nordlicht, was in and out of meeting.
I was there.
Mr. Preve was there; Mayer

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If I recall correctly, Ari Glass I believe was in and
out of meeting; Gillad Kalter, same thing, in and out of
the meeting; Jack Simony.
There were some other folks that I met that
were wandering in and out of meeting.
a very informal meeting.
to it.
conference room.
questions.
10
11
12
It was -- it was
There was no formal structure
People were kind of wandering in and out of

We were shaking hands, answering
Before this meeting, had you ever heard of
Mr. Mark Nordlicht?

A
I may have heard the name from Mr. Preve in
13
preparing me for the meeting, but I didn't know who he
14
was, no.
15
Did Mr. Preve or anyone provide you any
16
information about Mr. Mark Nordlicht before this
17
meeting?
18
The only information that I was provided by
19
Mr. Preve about any of these guys is that they were good
20
guys and he thought we would get along well with them,
21
but that was basically the extent of it.
22
And you conducted no independent due diligence
23
in regard to any of these individuals before the meeting
24
in New York?
25
No, sir.

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2
Did Mr. Nordlicht go by another first name, in
addition to Mark?
Yeah.
M-A-Y-E-R, Mayer?
Yeah, I believe it was M-A-Y-E-R.
And you also mentioned at that meeting, in
His real first name, Mayer.
Yes.
addition to Mr. Nordlicht, you mentioned a Mr. Glass;
that would be Ari Glass, correct?
Yes.
10
And who did Mr. Glass represent to you he was
11
with or what entity he was with when you met him?
12
I have no recollection.
I ultimately learned
13
that he was part and parcel of Platinum and, then, Level
14
3.
15
formal business with Centurion.
16
I don't recall whether he had direct, let's say,
But you need to know, as you're asking this,
17
and to make your questions easier, that as far as I was
18
told, and as far as we were concerned, all the guys all
19
worked together; and it was a matter of the type of
20
product and the type of money they were getting that
21
determined who was the actual hedge fund investing, as
22
opposed to who the person was.
23
about Platinum business, Nordlicht about Ari's business,
24
et cetera; and, ultimately, all the decisions were being
25
made by Mr. Huberfeld anyway.
I could speak to Ari
So...

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(Mr. Nurik enters the deposition in progress.)
MR. CIMO:
And for the record Mr. Nurik
has arrived, and Mr. Rothstein was kind enough
to let us start.
MR. NURIK:
That's fine.
I apologize.
had a matter this morning in the office and
the extra 20 minutes made all the difference
from the traffic.
again, you all have my permission, with my
So, if that should happen
10
client's permission, of course, to begin
11
early.
12
MR. CIMO:
Thank you so much.
He did say
13
he was comfortable to proceed with the
14
Trustee's counsel asking questions.
15
BY MR. CIMO:
16
As a follow-up, Mr. Rothstein, Mr. Nordlicht,
17
then, also didn't make any representations to you as to
18
which entity or entities he was there on behalf of?
19
20
ALL PRESENT:
A
No, I don't have any specific recollection as
21
to that.
22
BY MR. CIMO:
23
24
25
Objection to the form.
I'll rephrase.
Based upon your testimony that you didn't make
any distinction between and among the entities I was

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just asking you about, what representations, if any,
Mr. Nordlicht made to you regarding which entities he
was there on behalf of?
None that I recall.
Now, you mentioned Mr. Nordlicht, Mr. Glass,
Mr. Kalter, and Mr. Simony, and then you just mentioned
another gentlemen named Mr. Huberfeld.
mention him as being a person at this meeting in New
York.
You didn't
Was he in there?
10
No.
11
Who is Mr. Huberfeld?
12
To my knowledge, because I never met the man,
13
nor have I ever spoken to him, he is the most senior
14
person over all three of the entities we're discussing:
15
Platinum, Level 3, and Centurion.
16
the final say as to all their business.
He was the one with
17
How did you come to learn that?
18
I was told that by Ari Glass, by Mark
19
Nordlicht, by Jack Simony and by Gil Kalter, all at
20
different times -- also told that by Mr. Preve and Mr.
21
Levin.
22
Let's go now to Mr. Kalter.
You said he was
23
as the meeting, and what representations, if any, did he
24
make to you about who he was there on behalf of?
25
My recollection, and I -- the problem is I

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don't know whether it came from that meeting or not; but
the only recollection I have as to who Gil was working
for, was Centurion.
people that was directly isolated to a company, and I
believe it was Centurion.
He seemed to be one of the very few
And other than that, again, let's try to stick
with just this initial meeting with Mr. Kalter, did you
come to learn anything more about Mr. Kalter or his
background at that initial meeting?
10
11
12
I think someone told me he was a lawyer, at
some point in time; but other than that, no.

Q
Now let's talk about Mr. Simony.
What did you
13
come to learn, if anything, about his background at this
14
meeting?
15
16
About Mr. Simony, nothing, just that they
worked for all the funds.
17
18
the meeting?
19
Now, you said Mr. Nordlicht was in and out of
As -- to the best of my recollection, they
20
were all in and out.
21
Everyone was kind of wandering in and out, getting
22
coffee, getting water, shaking hands, very informal.
It was a very informal meeting.
23
Where was the meeting conducted?
24
In the conference room of what I believe, at
25
that time, was the offices of all three hedge funds, in

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the -- I believe it was the Carnegie building.
And how long did the meeting last?
I don't have an independent recollection.
And other than yourself, Mr. Preve, you said
Mr. Levin was there, too?
No, I don't think Mr. Levin went with us.
So, you -- it was you, Mr. Preve,
Mr. Nordlicht, Mr. Glass, Mr. Kalter, Mr. Simony, anyone
else?
10
There definitely were other people that came
11
in and out; I have no independent recollection at this
12
moment who they were.
13
I'm trying to understand.
I have shown you
14
Exhibits 123, 124, and 125.
15
the hedge funds and Banyon entities.
16
Banyon representative at that meeting -- I'm talking an
17
officer or director of Banyon -- if you know?
18
19
20
They are agreements between
I don't have a clue.
Why isn't there a
I always assumed
Mr. Preve was Banyon's representative.

Q
Oh, did you understand Mr. Preve to be an
21
officer or director or some control person of Banyon, if
22
you know?
23
Those are two completely different questions.
24
Was he an officer and director, not to my knowledge.
25
Was he a control person, he seemed to act the full

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authority of Mr. Levin at all times.
Understood.
And was there ever discussion on Mr. Levin

being at that meeting?
There may have been, but George rarely
attended any of our meetings, and he -- it was more
one-on-one stuff with him.
in.
George did not attend very much.
Occasionally he would drop
Even later on, when we were doing due diligence,
10
When you say "George," you mean George Levin?
11
I do.
12
And Mr. Levin, how long had you known him
13
14
before this meeting happened with the hedge funds?

A
I don't remember when I met him.
I know the
15
event that I -- that was our first real sit-down talk.
16
I had met him through a friend, client of mine, Howard
17
Gruverman.
18
19
And did you develop a friendship with
Mr. Levin?
20
Yes, very close.
21
And up to this point where you met with the
22
hedge funds, how long, approximately, had you known Mr.
23
Levin?
24
I don't know.
25
Oh, just months?
It was months.

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2
3
I think it was just months.
I really don't
have an independent recollection.

Q
And before this meeting with the hedge funds,
had any other Banyon entity provided any financing or
funds to any of your investments?
I don't recall whether it was a Banyon entity
or whether it was Mr. Levin, personally, or one -- one
of the other entities.
Mr. Preve and I never really -- in our
10
conversations, we didn't concern ourselves with where
11
the money was coming from, just that the money was
12
coming.
13
So, is it your recollection that there had
14
been some deals with Mr. Levin, or Levin-related
15
entities, before this hedge fund meeting?
16
Before the hedge fund -- yes, there were.
You
17
can -- notwithstanding my lack of knowledge as to
18
timing, my remembering the exact timing, you can figure
19
out when I met Mr. Levin, which was one of your
20
questions, by saying it was a very short period of time,
21
meaning a few months, prior to his very first investment
22
with me.
23
would have met him very shortly before that; and it
24
would have been directly after -- his first deal with us
25
would have been directly after a trip he took with me to
So the very first time he sent me money, I

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Cape Coral.
Would it be fair to say that Preve and
Mr. Levin were the ones that had made this introduction
by you to these hedge funds for this meeting in New
York?
Absolutely.
And without them, you would not have known
about the hedge funds?
That's correct.
10
Okay.
11
12
So, after that initial meeting, what
happened next, in terms of moving forward?

A
To the best of my recollection, we -- they did
13
some due diligence.
14
provided whatever information Mr. Preve was asking me
15
for, for them; and they started funding deals.
16
17
They asked for information.
I'm going to show you now what is going to be
marked as Exhibit 126 -- I'm sorry, 127.
18
No, 126.
(Thereupon, the document was marked as
19
Trustee's Exhibit No. 126 for Identification.)
20
BY MR. CIMO:
21
I'll represent to you, Mr. Rothstein, that
22
this is a lawsuit that was filed by Platinum Partners
23
Value Arbitrage Fund against Kroll Associates, Inc., and
24
Kroll, Inc. --
25
Okay.

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-- in the Supreme Court of New York?

Were you aware at some point, after you were
incarcerated, that a lawsuit had been filed by Platinum
against Kroll?
Yes.
How did you come to learn about it?
During one of my many meetings over the last
two years, someone brought it up.
9
10
You mentioned that the fund -- the hedge
funds, quote, did due diligence; do you recall that?
11
Sure.
12
Now, let's talk about the due diligence that
Yes.
13
you were aware of first, before we get to Exhibit No.
14
126.
15
What due diligence did you come to learn of,
16
not after the fact, but that you came to learn of in or
17
about April, May, June of 2008?
18
19
20
21
Just them asking questions of Mr. Preve and I
about our business model.

Q
Was there any documentation or records
provided?
22
Did we provide records?
23
Yes.
24
We may have provided deal packets.
25
I don't
know what status our deal packets were even at at that

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point in time.
created the purchase of transfer agreements, the
assignment documents.
what documents were even available at that time; but
whatever we had, I'm certain that, we did provide.
I don't know whether Frank and I had
I don't recall, document-wise,
And I'm trying to understand who, to your
recollection, was doing the due diligence?
Banyon entities, or was it the hedge funds or both?
No.
Was it the
To my knowledge, it was someone at the
10
hedge funds.
11
doing due diligence and Centurion was doing due
12
diligence or Level 3 was doing due diligence.
13
as far as I was concerned, and from my conversations
14
with Mr. Preve, it appeared that the hedge funds were
15
doing due diligence; but it was -- it appeared to me to
16
be very limited.
It was -- it wasn't like Platinum was
It was --
17
And why do you say that?
18
I have done due diligence before for clients,
19
and usually outside forensics people are hired, that
20
type of thing; books and records are examined,
21
accountants involved.
22
the hedge funds looking at our stuff.
23
24
25
There was none of that.
It was
What they were doing behind closed doors,

don't get me wrong, I don't know what they were doing.
Q
Were they invited to your offices in Fort

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Lauderdale?
I believe they were.
And did you show them around?
Can you give me a time frame?
This would be April 2008 through June of 2008?
Okay.
Their first investment appears to be in April
8
9
Was it before their first investment?
of 2008, based upon Exhibit 123.

A
I don't recall, other than answering a lot of
10
questions -- they did ask a lot of questions.
11
than answering a lot of their questions, I don't recall
12
any other kind of due diligence going on.
13
specific recollection of it.
14
15
16
Other
I have no
When you say "they," who was the "they" that
was asking you questions?

A
It would have been Jack Simony, Gil Kalter,
17
Mr. Nordlicht, to a much more limited extent, and I
18
don't remember whether --
19
Oh, you know what?
At that meeting I met
20
Brian Jedwab, also.
21
might have been a second meeting.
22
I believe it was that meeting.
It
So at an initial meeting -- it may not have
23
been the first meeting -- in addition to the four
24
gentlemen you mentioned earlier from the hedge funds,
25
you think you also may have met Brian Jedwab?

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Yes.
I definitely met him sometime early on,
and he was also doing, as best as I can recall, due
diligence.
You have to understand, I don't mean to seem
like I don't have specific memory of it, but it was a
very -- again, it was a very informal process:
Different people calling, different people asking
questions.
to the best of my knowledge, sending the documents off
I'm giving documents to Mr. Preve who was,
10
to them.
11
they had and coming up with responses.
12
13
14
Mr. Preve and I were discussing issues that
That's the process.
It wasn't like we were
filling out forms and responding to forensics people.

Q
And Mr. Jedwab, did he ever represent to you
15
or did you ever come to learn which hedge fund entity he
16
was related to?
17
I think that someone told me that his main
18
association was Centurion.
19
some point in time his main association was Platinum.
20
remember him coming to Fort Lauderdale with Ari Glass on
21
behalf of Level 3.
22
confusion as to who, exactly, Mr. Jedwab worked for.
23
I do remember me thinking at
I
So I have nothing but complete
Other than yourself and direct conversations
24
that were had with you -- and was there anyone else at
25
the Rothstein firm or affiliated with you, that was

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assisting in the due diligence?
Debra Villegas.
What did she do?
Helped us with documents, helped us with
files, anything I needed her to do.
meet-and-greets, no.
meet people, no, no one else was assisting in the due
diligence.
our bankers at that point in time.
10
When they came to the office to
I don't think I introduced them to any of
Now, at this point, the Ponzi scheme is in
11
full swing, isn't it, April 2008?
12
ALL PRESENT:
13
BY MR. CIMO:
14
15
16
17
18
Other than
Object to the form.
Let me rephrase.
What was the status of your Ponzi scheme that
you have pled guilty to, as of April of 2008?

A
How many deals has George invested in by this
date; do you know?
19
I can't tell you.
20
You know, "full swing" is such a vague term.
21
I'll rephrase it.
22
I'm going to retract "full
swing."
23
Okay.
24
Was there any component of your Ponzi scheme
25
in effect when you had your initial meeting in New York?

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Yes.
What was going on at this point?
I was doing deals with Mr. Levin.
There were
deals with the Morses.
Phony deals?
All -- any time I say "deals," unless I'm
talking about purchasing of the businesses that we were
laundering money through, I'm talking about phony deals.
The settlement deals were all phony.
10
11
And did you have an intention to do phony
deals in relation to these hedge funds?
12
Yes, sir.
13
It was not your intention to do any legitimate
14
deals?
15
No, sir.
16
So, in regard to this due diligence that's
17
being done -- and you used the term "limited."
18
it was limited due diligence, correct?
You said
19
By my definition, it was extremely limited.
20
And you did not receive any phone call from
21
any outside accounting firm?
22
Not to my knowledge, no.
23
And other than the individuals that you
24
mentioned, Mr. Jedwab and the others from Platinum,
25
Centurion or Level, 3 were there any other people that

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visited your offices at RRA, "RRA" meaning the Rothstein
firm?
From the hedge funds, not that I recall.
Now, let's go to Exhibit No. 126.
And I would like to turn your attention to one
of the attachments to this lawsuit, which is Exhibit A.
It's about 20, 30 pages in.
you'll see it's a letter dated May 14th, 2008, in which
Kroll is being retained jointly by the Troutman Sanders
10
Law Firm and by Platinum Partners Value Arbitrage Fund,
11
LP.
12
13
14
15
Have you seen this document before today?

A
It's -What is the page number
again?
MR. CIMO:
Just go to page 20 of the
complaint, Mr. Nurik, and then Exhibit A.
20
MR. NURIK:
21
BY MR. CIMO:
22
23
I have to see it first before I tell
MR. NURIK:
18
19
Hold on.
you whether I've seen it before.
16
17
It's page 20, actually; and
Okay.
There it is.
Have you seen this retention letter, three
pages, before today?
24
No, sir.
25
Okay.
Did you ever come to learn at any point

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while this due diligence was being conducted that one of
the hedge funds had hired Kroll?
I have no specific recollection of that.
And did you come to learn at any point after
you were incarcerated that Kroll had been retained?
Yes.
And how did you come to learn that?
Again, in one of my many meetings it came up.
I don't know.
10
11
and Sanders.
12
today?
13
Before today, sure.
14
And did you know about them before you were
15
Now, there's a law firm mentioned, Troutman

Had you ever heard of that law firm before
incarcerated?
16
I did.
17
And how did you come to learn about that firm?
18
I had had contact with this -- I don't know
19
how to say his last name.
20
Whatever his name is.
21
had contact with him.
22
23
Bourguigon.
Bourguigon.
Robert, from Troutman Sanders.
This is before you met any of the hedge fund
people?
24
I thought you said before I was incarcerated.
25
Yes.
But -- before this initial meeting in

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New York.
No, no, no --
With the hedge funds.
Timing-wise, after the initial meeting, before
the Ponzi exploded, earlier on I had conversations with
Mr. Robert Bourguigon of Troutman Sanders.
What did you discuss with him?
I don't have a specific recollection but it
was deal-related questions.
My understanding from
10
Mr. Preve and from Mr. Bourguigon was that he was the
11
hedge fund's attorney and that he was doing -- helping
12
prepare documents and the like.
13
I also recall that at some point in time we
14
had back and forth between Mr. Preve and him and then me
15
and Mr. Preve and him on coming up with language for
16
certain documents.
17
18
of any due diligence being conducted by the hedge funds?
19
20
21
Did anyone from that firm contact you as part
I don't have specific recollection of that,
I'd like you to now turn to Exhibit B.
no.
22
And would it be fair to say you didn't see
23
this report of investigation until after you were
24
incarcerated?
25
Actually --

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MR. SCHERER:
BY MR. CIMO:
Objection to form.
-- I don't think I've seen it until today.
Oh, good.
Okay.
So you -- do you know there
was some report done by Kroll but you didn't see it
until before today?
7
8
I actually thought that there were multiple
reports done by Kroll but I haven't seen them.
All right.
10
I didn't see anything that's dated this early
11
until today.
12
13
All right.
Let's look at Exhibit --
Let's go to Exhibit D.
Here.
would like you to turn to go past the table of contents.
14
Okay.
15
And it says "Kroll was retained."
After the
16
table of contents, it says "scope of investigation."
17
says "Kroll was retained by Troutman Sanders, LLP, to
18
conduct an investigation of Scott Rothstein."
19
And it's your testimony that you didn't know
20
that anyone was hired to conduct an investigation of
21
you --
22
That's correct.
23
-- before you were incarcerated?
24
I don't have an independent recollection of
25
It
that, no.

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Page 804
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And you also didn't come to learn that also
members of your law firm were going to be investigated,
too?
No, sir.
And you also didn't know about the fact that
George Levin, Gayla Levin, Frank Preve were also going
to be investigated?
ALL PRESENT:
Object to the form.
I have don't have any independent recollection
10
of anyone telling me that they were doing that, no.
11
BY MR. CIMO:
12
13
And, again, this is all before October of
2009.
14
Yes.
15
And it also is your testimony you weren't
16
aware of any investigation by Kroll or any other entity
17
doing due diligence for the hedge funds, that Banyon
18
Funding, LLC, and Banyon 1030-32 also would be
19
investigated?
20
ALL PRESENT:
21
I don't have a specific memory of that, no,
22
sir.
23
BY MR. CIMO:
24
25
Object to form.
Now, had Kroll contacted your law firm, would
you have known that?

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Page 805
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2
3
4
If an investigative agency contacted my law
firm, I can assure you I would have known about it.

Q
And you don't have any recollection of any
contact by Kroll?
I have no specific recollection of it, no.
Then there's the executive summary on page 2,
and it says, "Chief among the objectives of the
assignment were:
Adler was legal counsel in lawsuits, which in number and
Determine whether Rothstein Rosenfeldt
10
cause amounted to the actual or potential award of
11
settlement of at least tens of millions of dollars."
12
Were there ever any lawsuits that you settled
13
in the tens of millions of dollars in your entire legal
14
career?
15
No, sir.
16
Did the public records of any county anywhere
17
in the country reflect that you had any lawsuits that
18
had settled for tens of millions of dollars?
19
20
21
You know, I -- I don't think tens of millions,
no, sir.
Q
While you were a lawyer, before you were
22
disbarred, had your firm ever filed any lawsuit
23
regarding employment discrimination or similar claim in
24
which the demand was in the tens of millions of dollars?
25
Actually, in the written document?

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Yes.
No, sir.
Filed at the court?
I don't believe so, sir, no.
Go now to the portion where it says "pending
or recently settled Rothstein Rosenfeldt & Adler
lawsuits."
and tell me whether -- what you just testified about is
consistent with Kroll's findings underneath that
And I'd ask you now to read underneath that
10
subsection.
11
12
13
All right.
Just give me one second.
That appears to be consistent, yes.

Q
And I'm going to read one portion of it, where
14
it says, quote, The large majority of these suits, which
15
was the ones that Kroll found, were automobile injury or
16
other negligence cases."
17
18
Is that the kind of work your firm was doing?

A
In 2007, 2008, there was a lot of automobile
19
work, and my recollection -- I don't know if they were
20
in suit or not.
21
of employment-related lawsuits going on as well.
22
don't recall filed, not filed, where filed.
23
My recollection is we had a fair amount

I
And then it says, "Which by their content did
24
not appear to warrant settlements amounting to total
25
awards of $100 million."

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That would be accurate.
It says, "Additionally, Kroll did not identify
any wrongful death or massive tort claims leading to a
possible large settlement."
5
6
7
Was that consistent with what your law firm

was doing?
A
Yeah.
The only large awards that the firm
ever got during its existence were ones that were not
collectible.
10
Let's go now to the next paragraph.
It says,
11
"Kroll's review of media involving Rothstein Rosenfeldt
12
& Adler only identified two published articles reporting
13
that the law firm settled cases for amounts in excess of
14
a million dollars."
15
Then if you go to the next page, it defines
16
the Thigpin lawsuit and it identifies the United
17
Healthcare lawsuit.
18
19
Those are not tens of millions of dollars

lawsuits, though?
20
ALL PRESENT:
21
22
BY MR. CIMO:
23
24
25
Objection to form.
No, sir.
I'm sorry?
Your answer is yes -- let me
rephrase.
Did those lawsuits involve tens of millions of

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1
dollars of awards for settlements?
They did not.
Did anyone ever ask you -- irrespective of
this Kroll report making these findings, did anyone at
the hedge funds ever ask you why there appeared to be a
dearth of, at least, filed cases, regarding your law
firm's efforts?
8
9
At some point in time, somebody, I don't
remember whether it was Mr. Preve or someone from the
10
hedge funds, inquired about filed cases and I simply
11
said, That's the whole point:
12
cases.
13
These are not filed
Meaning that the way you get them settled is
14
by basically saying you're going to file it but the
15
defendant then does a confidential settlement that
16
prevents it from being filed?
17
ALL PRESENT:
18
19
BY MR. CIMO:
20
21
pitch?
22
Objection to form.
The pitch was --
Let me rephrase my question.
What was the
What was the pitch?

The pitch was, we approached the defendant,
23
the potential defendant, to settle the case before we
24
filed, to avoid negative publicity.
25
nature, they appeared to be looking for the wrong thing.
So by its very

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Given the fact there was no filed cases, was
there any solution that anyone recommended or suggested
to verify the existence of these settlements?
Not that I recall, sir.
Was there a Michael Szafranski that was
ultimately -- that ultimately became involved to
purportedly verify the existence of any settlements?
8
9
10
11
12
13
ALL PRESENT:
BY MR. CIMO:
Q
What role, if any, did Michael Szafranski play
in regard to the settlements?

A
He was hired, to my understanding, by the
hedge funds to be what we called a third-party verifier.
14
15
if you know?
16
17
18
19
20
21
22
Objection to form.
And whose idea was it to hire Mr. Szafranski;
The hedge funds and specifically Gillad
Kalter.
Q
And what relationship, if any, did Mr. Kalter
have to Michael Szafranski?

A
My understanding was that they were childhood
friends.
Q
So it's your testimony that Mr. Szafranski was
23
suggested by the funds to become an independent verifier
24
by one of the childhood friends of one of the hedge
25
funds?

(954) 525- 2221
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Correct.
And was the term "independent verifier"
actually used?
"Independent verifier"?
Yes.
Did you believe that Mr. Szafranski was an
independent verifier?
But --
You didn't care?
10
No.
11
12
He didn't appear to me to be independent.
He's --
ALL PRESENT:
A
He's who they gave us and that's who we
13
ultimately accepted.
14
BY MR. CIMO:
15
16
Let's rephrase the question to get around the
objection to form.
17
18
Objection to form.
What conclusion did you reach, if any, as to

whether Mr. Szafranski was a truly independent verifier?
19
That he wasn't independent.
20
Why not?
21
Because of his relationship with Mr. Kalter,
22
23
24
25
and ultimately his relationship with me.

Q
And what relationship did Mr. Szafranski have
with you?
A
He ultimately became part of the Ponzi scheme.

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And you were a lawyer for many years.
Did you
ever hire anybody to independently audit or review any
of your firms' business functions or financial
statements?
That's -- you used the word "independent."
Independent.
I hired accountants, like Tracy Weintraub from
Berenfeld Spritzer.
conducting criminal activity, I never hired anyone who
10
11
But during the point that we were
would fall within the heading of truly independent.

Q
12
Yes.
And was it important -- what -- how important
13
was it to you, if at all, that Michael Szafranski not be
14
independent?
15
16
It was important -ALL PRESENT:
17
18
BY MR. CIMO:
19
20
Object to form.
It was important to me that he be malleable.
Did you need him to be a player?

ALL PRESENT:
21
22
to be?
23
capable of being fooled.
Objection to form.
24
25
I was hoping that he would be.
Did I need him
I needed him to be capable of -- initially
Ultimately, it turned out -- I wasn't counting

on it -- but ultimately it turned out that he was not

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Page 812
1
only extremely malleable but was extremely greedy, as
were the rest of the people involved in the Ponzi
scheme.
BY MR. CIMO:
What was your reaction, if any, when Michael
Szafranski, a childhood friend of Mr. Kolter, gets
proposed by these supposed sophisticated hedge funds, to
be the independent verifier for the settlements?
ALL PRESENT:
10
11
BY MR. CIMO:
12
13
14
I have to give you --
Wait.
Stop.
MR. CIMO:
What's wrong with the
question, Counsel?
15
ALL PRESENT:
16
investors."
17
know that.
18
BY MR. CIMO:
19
20
Objection to form.
Supposed sophisticated
There's no predicate for him to
Let's rephrase the question and let's go back
a little bit, Mr. Rothstein.
21
Okay.
22
These hedge funds, tell me what you learned
23
about them while you were transacting with them -- doing
24
transactions with them through Banyon entities?
25
That's a very broad question, Mr. Cimo.

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What did you learn?
I learned that they were good guys.
that a lot of them were players.
mean, you're asking such a poor question.
they had nice families.
with me.
I learned that -- I
I learned
They liked to go out and drink
They liked to go to strip clubs.
7
8
I learned
There's a whole myriad of things and there

were different personalities for each of the players.
Let's talk about the funds themselves.
What
10
did you learn about these hedge funds and what they were
11
doing with the money that they were taking from
12
investors?
13
ALL PRESENT:
14
BY MR. CIMO:
15
Objection to form.
Let me rephrase the question.
What did you
16
learn the function was of these hedge funds, if
17
anything?
18
To make money.
19
And is that what you thought hedge funds do?
20
Yes.
21
Okay.
22
legitimate hedge funds making money?
23
24
25
So did you believe that these were
When I first started doing business with them,
Did you come to think later -- changing that
yes.

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Page 814
1
2
3
4
5
6
opinion?
A
I later believed that they were part
legitimate, part -- let's say not so legitimate.

Q
And what conclusions did you reach, if any, as
to what part was not legitimate?

A
As I was discussing yesterday during
testimony, there are certain people within the hedge
funds that I believed, based upon my knowledge, were
legitimate.
Straight.
There were other people who were
10
less than legitimate.
11
had knowledge of the Ponzi that we were involved in.
12
There were people that I believed had no knowledge or --
13
let me restate that.
14
figured out that we were involved in some type of fraud
15
that ultimately decided to just let it go.
16
other people who were pushing to get rid of us.
17
There were people who I believe
There were people I believed
There were
We'll talk about that later but for now I'll
18
give you an example.
19
Platinum, for example, or any affiliates of Platinum was
20
part of the group that was touted as being one of the
21
most successful hedge funds in the country --
22
Did you come to learn whether
ALL PRESENT:
Objection to form.
23
BY MR. CIMO:
24
-- at any time?
25
I did.

(954) 525- 2221
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Page 815
1
Mark Nordlicht told me and so did Mr. Preve.
And did you come to learn that when Centurion
and Level 3 were acting as hedge funds, that they were
supposedly acting as legitimate hedge funds?
ALL PRESENT:
BY MR. CIMO:
Yes.
And did you know whether or not there was
10
actually reports in the media about what these hedge
11
funds were doing?
12
I later came to learn that there was -- doing
13
my own research, actually, after having a conversation
14
with Mr. Nordlicht, that some of the people involved in
15
the hedge funds had been involved in fraudulent activity
16
or allegedly fraudulent activity.
17
18
Doing my own research.
19
And --
20
And also speaking to Mr. Nordlicht and
21
22
23
Mr. Preve.
Q
Who did you come to learn was involved in
fraudulent activity?
24
Mr. Huberfeld and Mr. Nordlicht.
25
And what did you learn specifically about

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Page 816
1
2
those individuals?
A
I learned that Mr. Huberfeld had been involved
in some type of fraud.
one of the things was being involved in some government
tests with some fake IDs.
He was involved in being in --
There was something else involving the SEC
where he was banned from doing something and I don't
remember the technical language that was used.
I learned that Mr. Nordlicht and some of his
10
partners were involved in a large piece of litigation
11
called the "Optionable Litigation," involving all kinds
12
of allegations of fraud.
13
14
15
And when did you learn this before October of
2009, if at all?
A
It was different points in time.
I learned
16
about the Huberfeld fraud fairly early on, because when
17
I was trying to understand why Murray was -- Murray
18
Huberfeld was calling the shots but never seemed to be
19
available to us.
20
he was the Wizard of Oz; he was the man behind the
21
curtain.
22
got to see him.
23
We used to joke around and call -- say
He was pulling all the strings but no one ever
And you felt there was a nexus between that
24
activity and him not being one of the people that you
25
would meet with?

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Page 817
1
2
ALL PRESENT:
A
Object to form.
Mr. Preve and I discussed that.
There was,
much later on, a private meeting that we discussed
yesterday, briefly, between Mr. Nordlicht and I when
everything was exploding where it became much clearer to
me Mr. Nordlicht's familiarity with fraud.
BY MR. CIMO:
Had another verifier been appointed instead of
Michael Szafranski, for example, a partner, at a big
10
four or big six accounting firm.
11
would that have had on your decision to do any type of
12
transactions with the hedge funds?
13
14
ALL PRESENT:
A
What effect, if any,
Objection to form.
I would have objected profusely to doing
15
business with him.
16
BY MR. CIMO:
17
Why?
18
Because I did not believe that our fraud was
19
sophisticated enough to get past a big-four type
20
accounting person who didn't want to be gotten past.
21
It's not to take away from any intelligence of anyone
22
who was looking at it but the people grouped.
23
And apart from the activities that you came to
24
learn, that you described as fraudulent regarding the
25
individuals associated with the funds, did you always

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Page 818
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believe throughout the entire time you dealt with the
hedge funds that these were actual legitimate hedge
funds with investors that were investing in these
enterprises?
Yes.
You never understood those hedge funds to be
operating any separate Ponzi scheme?
No, sir.
Okay.
So when I asked you that question, I
10
wanted to ask you what your reaction was when the friend
11
of Mr. Kolter was appointed as the independent verifier.
12
The first conversation that I recollect having
13
about that, was with Mr. Preve.
14
what I thought.
15
milk toast.
16
probably see it in the few dozen e-mails where we're
17
referring to "what is milk toast doing."
18
meant to be derogatory, it was just -- well, I guess it
19
was really derogatory, but it was meant in a -- it was
20
meant the way I would be as a, quote/unquote, wise ass,
21
that he was milk toast.
22
problem for us.
23
And he was asking me
And I said, "We're good to go.
And the name stuck, actually.
Okay.
He's
You can
It wasn't
He was just not going to be a
And when you use the term "milk toast,"
24
if you could describe to the fact finder, whether it be
25
a judge or a jury, what you meant by that term.

(954) 525- 2221
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Yes.
Milk toast means like vanilla.
He
doesn't ask a lot of questions.
that he was not emotional.
upset about something going wrong or someone was
aggravating him.
things the way they were.
He was -- it wasn't
He got emotional when he got
But he was -- he just kind of accepted

Very vanilla.
"Mike, this is the balance."
"Okay, this is the balance."
"Mike, these are the wires."
10
"Okay, these are the wires."
11
"Mike, these plaintiffs signed these
12
documents."
13
"Okay, the plaintiffs signed the documents."
14
Milk toast?
15
Yes.
16
I don't know any other way to describe
it.
17
He wasn't very inquisitive.
18
19
a mushroom?
At some point did you also consider him to be
20
ALL PRESENT:
Objection to form.
21
THE WITNESS:
A mushroom?
22
BY MR. CIMO:
23
Did you ever refer --
24
I don't think I called him a mushroom.
25
think Frank may have called him a mushroom.

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Really?
Just because -- yeah.
Why did Frank refer to him as a mushroom?
Whoever referred to him as a mushroom, it was
that we're just going to leave him in the dark and dump
shit on him, excuse my language.
7
8
MR. LICHTMAN:
kosher?
9
10
THE WITNESS:
Actually, he was kosher.
MR. SCHERER:
That was Lichtman making
Yes.
11
12
Does that mean he is
that response.
13
BY MR. CIMO:
14
But it's your testimony, at some point the
15
mushroom -- the person who is a vanilla, milk toast,
16
who's also a mushroom, turns into a co-conspirator in
17
your Ponzi scheme.
18
Is that your testimony, sir?
19
Yes.
20
Let's go back to the Exhibit No. 126.
21
They then do an analysis regarding your
22
individual property ownership and they identify multiple
23
high-end real estate purchases by you, but they point
24
out that -- that you're holding mortgages in excess of
25
$10 million.
I'm on page 3, by the way, of the Kroll

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report.
Do you see that?
Yes.
Did you, in fact, own these properties in this
report?
Yes.
And why were they burdened with over
$10 million in mortgages if you were doing so well in
your practice?
10
Free up cash.
11
And what did you need cash for?
12
Ponzi scheme and my lifestyle and the
13
14
lifestyle of my partners.
Q
I want you now to go to the bottom part where
15
it talks about the real estate and it says, quote --
16
these are the last two lines -- "While actual mortgage
17
balances are not in the public record, this analysis
18
would suggest that Rothstein's mortgage burden is
19
significant."
20
Do you agree with that?
21
I do.
22
It then goes on to state, quote, Even if
23
Rothstein is leasing all of his properties, rental
24
income would unlikely cover all associated ownership
25
costs, e.g., annual property tax, property insurance,

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Page 822
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maintenance, and management fees, monthly mortgage
payments, etc.
3
4
Is that a true statement?

A
They were leased?
I never gave a thought one way or the other.
I don't remember which properties I had leased or not
leased.
on, it was a nonevent for me.
8
9
10
Again, because of the nature of what was going
It says, "Furthermore, mortgage rates for
Rothstein properties are generally considered slightly

high, even for jumbo loans."
11
Did you care what interest rate you got on
12
these loans?
13
No, sir.
14
Why not?
15
Because of the other activity we were involved
16
in with the Ponzi scheme.
17
18
collection.
19
It then talks about Rothstein's watch
If you can go down to that bullet point.
20
Yes.
21
But it says they were all subject to liens
22
filed by Mayor's.
Do you see that?
23
That's not true.
24
Okay.
25
Did certain of them have liens that
they were purchased through financing?

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Page 823
1
that before.
For a very short period of time.
I had heard
What happens is when you purchase something
from Mayor's on their line of credit -- you know, they
have a Mayor's credit card -- they file liens.
We generally paid that down right rapidly.
The bulk of my watches weren't purchased at
8
9
Mayor's.
Q
So...
I wanted to ask you, did the hedge funds and
10
anyone at the hedge funds ever ask you about the Mayor's
11
liens?
12
I don't recall one way or the other.
13
Did anyone at the hedge funds ever ask you
14
about the 10 million plus in mortgages on your
15
properties?
16
I have no specific recollection of that, no.
17
Did anyone at the hedge funds ask you about
18
the fact that you were sued for $36,000-plus regarding
19
the security service firm?
20
No, sir.
21
Did anyone at the hedge funds ask you about
22
your dissolution of marriage to your first wife and your
23
assets that were supposedly split, which is disclosed on
24
page 5, and how the numbers are only six figures, low
25
six figures, in terms of assets?

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Page 824
1
2
3
I don't recall ever having that conversation,
no, sir.
Q
Did anyone at the hedge funds ever ask you
about your partners and what they were doing or what
their expertise was, getting these wonderful
settlements, mentioned in bold point on pages 5 and 6?
That's two different questions.
We did
discuss my partners as relates to, for example, the
power of the business, the image that I was attempting
10
to create.
11
12
13
14
They never asked me about the things you're

showing me here on pages 5 and 6.
Q
Okay.
So was Russell Adler touted as one of
your top litigators?
15
Yes.
16
Was he touted as one of the people that was
17
getting these multi-million-dollar settlements pre-suit?
18
Yes.
19
Okay.
And did anyone at the hedge funds ever
20
discuss with you the fact that American Express -- his
21
wife, was sued for $24,000 for credit card debt?
22
23
24
25
No.
I actually didn't even know that until I just
looked at this.
Q
Anyone at the hedge funds talk to you about

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Page 825
1
the fact that Adler and his wife were listed as debtors
for $125,000 IRS claim for unpaid income taxes?
Anyone from the hedge funds?
Yes.
No, sir.
Did anyone from the hedge funds ever discuss
with you Mr. Cusick?
No, sir.
And that being the case, there was nothing
10
discussed about Mr. Cusick's personal finances in the
11
public record?
12
No, sir.
13
And did anyone at the hedge funds discuss with
14
you Dennis Kleinfeld?
15
No, sir.
16
Or anything about Mr. Kleinfeld's financial
17
dealings outside the firm?
18
No, sir.
19
And the investigation regarding the British
20
21
22
23
Virgin Islands, did you know about that?

A
I knew about it, yes, but no one ever asked me
about it from the hedge funds.

Q
And let's talk about the political donations.
24
Did anyone at the hedge funds talk to you about the
25
public records regarding political donations?

(954) 525- 2221
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Page 826
1
Hold on a second, please.
Bless you.
Excuse me.
Did anyone ask me what, sir?
5
6
7
Q
top.
On page 6, bullet point 1, start up at the

Did anyone ask you about political donations?
I am certain that during the course of my
conversations with the hedge funds, we brought up our
involvement in politics because that was part of
10
painting the image of the firm and myself and the
11
partners.
12
I would like you now to turn to pages 7 and 8,
13
"Litigation review."
14
just would like you to read page 3 -- I mean section 3,
15
page 7, and let me know whether the findings of Kroll
16
are consistent with what your understanding of the types
17
of matters your firm was involved in.
And I'm not going to read this.
18
It's accurate.
19
Thank you.
20
And just to summarize, what, if anything, does
21
this report on this page 7 reflect about whether any
22
settlements existed in the tens of millions of dollars?
23
That they did not.
24
And so the conclusions in this report are
25
accurate?

(954) 525- 2221
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Page 827
1
Yes, sir.
And now I would like you to look at the
next-numbered exhibit, which would be Exhibit No. 127.
Do I have that one already?
We're giving it to you right now.
6
7

8
9
10
11
THE WITNESS:
BY MR. CIMO:
Q
For the record, this is the order entered in
the lawsuit that was filed against Kroll by Platinum.
12
13
Okay.
It is dated October 5th, 2011.
Have you seen
this order before today?
14
15
16
Oh, yes.
17
I have.
18
In what context did you see this?
19
I saw it a week or two ago.
20
Lexis.
21
it online.
22
23
24
25
I'm sorry.
I was on the
I have access to Lexis where I live, and I read
And just give me one moment, please.

Okay.
Mr. Rothstein, I'm sorry, please go to
page 6 of 14.
A
Yes, sir.

(954) 525- 2221
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Page 828
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I would like to refer your attention to the
second full paragraph that starts with "Kroll has not
yet answered the complaint."
Yes, sir.
You see that?
Yes, sir.
And the Court says the following:
It says,
quote, In this pre-answer motion to dismiss all three
causes of action, Kroll takes the position that the
10
present lawsuit is merely an attempt to hold it
11
responsible for Platinum's own poor decision to invest
12
in a Ponzi scheme."
13
14
Do you believe -- do you agree that Kroll made

a poor decision to invest in your Ponzi scheme?
15
ALL PRESENT:
Objection.
16
THE WITNESS:
Kroll did not invest in the
17
Ponzi scheme.
18
MR. CIMO:
19
I withdraw and rephrase the question.
20
BY MR. CIMO:
21
I'm sorry.
Platinum.
Do you agree with the Court's conclusion that
22
the hedge funds made a poor decision to invest in the
23
Ponzi scheme?
24
25
ALL PRESENT:
A
Objection to form.
I think your question is -- has gone sideways.

(954) 525- 2221
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Page 829
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BY MR. CIMO:
Go ahead.
You just asked me if I agreed with the Court's
4
5
conclusion that it was a poor decision.

Q
Well, let me rephrase it.

Do you agree with Kroll's -- do you agree with
Kroll's assertion that there was a -- it was a poor
decision for Platinum to invest in the Ponzi scheme?
10
11
Listen, I think it's -ALL PRESENT:
Objection to form.
-- a poor decision by anyone that invests in
12
the Ponzi scheme but that's not to say that I didn't get
13
over on certain of these people.
14
Again, certain of these people -- just so
15
we're clear, certain of these people, I believe, tried
16
to do the right thing; others did not.
17
BY MR. CIMO:
18
Go to the next sentence, "Kroll claims that's
19
an explicitly warned Platinum that the contemplated
20
loans transaction bore the hallmarks of a Ponzi scheme."
21
22
23
24
Do you agree with that?

A
I do believe that it bore the trademarks of a
Ponzi scheme.
ALL PRESENT:
Objection to form.
25

(954) 525- 2221
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Page 830
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BY MR. CIMO:
Tell me specifically what you felt was
disclosed to the funds before they started to invest
that bore the hallmarks of a Ponzi scheme?
No, it wasn't what was disclosed --
What was disclosed?
-- it was what was not disclosed.
Please go ahead.
It was our refusal to give them any
10
information about who the parties were.
11
we were keeping our trust accounts, how we demanded our
12
control over them.
13
You would have to give me all the papers, to look at it,
14
but it was -- you know, hindsight is 20/20, so it's very
15
hard for me to do this this way.
16
things that I believed that they could have done better
17
in their due diligence that they did not do.
18
It was the way
There's a whole myriad of things.
But there were certain
But yes, there were certain hallmarks -- not
19
the least of which was "too good to be true" thing.
20
sheer level of interest that we were paying, and then
21
ultimately the sheer number of cases, because physically
22
it would have been impossible for me to handle that many
23
cases alone.
24
25
The
Ultimately, how did the hedge funds invest,
did they do it directly or did they do it through the

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Banyon entities?
No, no, it was through Banyon.
Were there any payments ever directly made by
4
5
RRA to any of the hedge funds?

A
You know, I'm not sure how that actually
worked because we were always directed to send the money
to these collection accounts.
I can't tell you whether I was sending the money to
Banyon and then it went to them or whether I was sending
So, as I sit here today,
10
it into an account over which they exercised some level
11
of control.
12
And, if you know, why was the decision made to
13
invest through the Banyon entities instead of the hedge
14
funds investing directly?
15
Because of Mr. Levin's reported wealth.
16
And what was the purported wealth of
17
Mr. Levin?
18
At different points in time it was different.
19
Was it over 100 million, to your knowledge?
20
Always well over 100 million, yes, sir.
21
And why was it that his wealth was important
22
in terms of the hedge funds, if you know, investing --
23
24
25
ALL PRESENT:
A
Object to the form.
Because they were getting -- to my knowledge,
from speaking to the people at the hedge funds, they

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were giving a level of security because they felt that
Mr. Levin's personal guarantees were collectible.
BY MR. CIMO:
If you know, why was the level of security
important if the way these deals are structured there
was no risk?
ALL PRESENT:
BY MR. CIMO:
10
Objection to form.
I have no idea.
No, I'm just asking.
I -- I thought the way
11
you described the way these investments went down, is
12
your firm is holding the money in escrow.
13
That's correct.
14
It's sitting there.
15
That's correct.
16
And did you tout these as no-risk investments?
17
18
ALL PRESENT:
A
Objection.
No-risk -- low-risk to no-risk, yes.
We tried
19
not to say "no risk" because that's another red flag, so
20
we said low-risk to no-risk.
21
in-house.
22
BY MR. CIMO:
23
The money is supposed to be at your law firm?
24
Locked in a trust account, yes, sir.
25
So was there any -- was there any discussions
But we said money is

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about the hedge funds ever investing directly and
bypassing the Banyon entities?
Not to my knowledge, no.
So right from the start, from the get-go with
that initial meeting, it was always understood by you
that the Banyon entities would be the vehicle by which
the hedge funds would provide funds?
Yes.
And did you play any role in the structure of
10
that or was that something that was done by somebody
11
else?
12
Mr. Preve and Mr. Levin may have asked me a
13
question or two but I played no real role in that at
14
all.
That was between Banyon and the hedge funds.
15
16
MR. CIMO:
this time, if that's okay.
17
(Whereupon, a recess was had.)
18
BY MR. CIMO:
19
20
We're going to take a break at
I just have a few follow-up questions,
Mr. Rothstein, before we move on to another area.
21
I want to ask you, in terms of the hedge
22
funds, what belief did you end up obtaining, if any,
23
regarding their level of sophistication?
24
25
I thought that certain members were
sophisticated and some members were a combination of

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1
either less sophisticated or less interested.
Who were the more sophisticated individuals?
Brian Jedwab was more sophisticated.
Jack Simony was sophisticated but less
interested and -- how do I say this?
interested in what was really going on.
He was less
Ari Glass was sophisticated, but at times he
seemed concerned about what was going on and at other
times, he would just go with the flow.
10
Gil Kalter seemed sophisticated and, for the
11
most part, very concerned about issues that were coming
12
up.
13
Mark Nordlicht, to me, seemed sophisticated
14
but really didn't care one way or the other as to how he
15
made his money, so long as he was getting his money.
16
Now, let's talk about the funds as entities.
17
Did you -- what opinion did you or belief did you hold,
18
if any, regarding the entities' sophistication?
19
I thought -- I thought that overall it was a
20
decent enterprise.
21
anything unsophisticated about them.
I didn't think that there was
22
Okay.
23
They certainly seemed to have their stuff
24
together as far as being able to bring investors in,
25
being able to fund things.

(954) 525- 2221
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Page 835
1
In terms of a sliding scale, would you --
where would you have placed the hedge funds in terms of
low sophistication, medium or high sophistication?
ALL PRESENT:
BY MR. CIMO:
Objection to form.
I'll give you an example.
Let me rephrase the
question.
Sure.
Well, a woman that invests her $100 IRA in
10
your Ponzi scheme that never made an investment in her
11
life, would that be a low-sophisticated person?
12
ALL PRESENT:
13
You can answer.
14
Objection, form.
If I have such a person invest, yes, that
15
would be low sophistication person.
16
BY MR. CIMO:
17
Did RRA ever have any type of investment like
18
that where directly there was investment made in RRA
19
settlements?
20
Not through me, no.
21
Not through you directly?
22
No.
23
24
25
That would have had to have been Levin's
side of things that he was doing to raise money.

Q
So, again, I understand that the hedge funds
did not directly invest through RRA.

(954) 525- 2221
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Page 836
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Yes.
In terms of sophistication level, in regard to
the ones that were directly invested with RRA, where did
you place them in terms of sophistication?
ALL PRESENT:
Objection to form.
I thought they were a part of our
more-sophisticated group of investors -- laid back and
informal but more sophisticated.
BY MR. CIMO:
10
And what other --
11
A bright group of guys.
12
What other individuals or entities would you
13
put in that same category?
14
I put the Levins in that category.
I put the
15
Von Allmens in that category.
16
don't know, Bekkedam was more like a salesman, don't put
17
him in that category.
I put Barry Bekkedam -- I
18
Ira Sochet?
19
Ira Sochet, definitely sophisticated.
Ira
20
Sochet was as sophisticated as the guys at the hedge
21
fund.
22
Damson, also; Mel Klein, very sophisticated.
23
They were -- he was a very sharp man; Barry
Of the entities and the people you just
24
mentioned, were any of them, in your opinion, more
25
sophisticated than the hedge funds?

(954) 525- 2221
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Page 837
1
ALL PRESENT:
Objection to form.
THE WITNESS:
More sophisticated?
BY MR. CIMO:
Yes.
I think that probably Ira Sochet and Barry
Damson had an overall -- they were more professional
businessmen, but not necessarily more-sophisticated
businessmen.
Had you dealt with any hedge funds in any of
10
your business transactions before these hedge funds in
11
New York got involved?
12
I had met with people from hedge funds, yes.
13
And did you learn anything about how hedge
14
funds work or how -- whether they're regulated, anything
15
at all about how hedge funds operate?
16
ALL PRESENT:
Objection.
17
18
regulation.
19
BY MR. CIMO:
20
21
investors --
22
Compared to other investment houses.
23
And do you know whether hedge funds, in fact,
Yes.
There were very low levels of
And do you know whether hedge funds had
24
take investments from individuals or entities; did you
25
come to learn that?

(954) 525- 2221
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Page 838
1
Yes, I did.
Do you know that while were you meeting with
Platinum, Centurion and Level 3 up in New York?
I did.
So, that being the case, understanding that
these hedge funds had their own investors that they have
to answer to, did you reach any conclusions or have any
beliefs about their levels of sophistication, compared
to other investors?
10
11
ALL PRESENT:
A
Objection to form.
I believed that they were good at what they
12
did and that they were sophisticated enough to be able
13
to generate, from what I understood, what was in excess
14
of a billion dollars in investments.
15
BY MR. CIMO:
16
And did you ever get any financial data from
17
the hedge funds of a nature that would be submitted to
18
an investor regarding your performance results?
19
20
21
I saw some of it from time to time from Mr.
Preve, but I don't have a recollection of it.

Q
Did you understand that these hedge funds
22
were, in fact, earning high rates of return with their
23
investments?
24
25
That's what I was told.
I didn't learn it one
way or the other.

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Did you ever come to learn what percentage of
these hedge funds investments were tied to settlements
of this nature?
where -- real structured settlements, real plaintiffs
and defendants.
I'm talking about real settlements
ALL PRESENT:
BY MR. CIMO:
Objection to form.
I didn't think any of it was.
Oh, really?
So you didn't know what
10
percentage, if any, these hedge funds were investing in
11
these types of investments versus others?
12
My understanding was the closest that they
13
ever came to any product like the one we were pitching
14
was their involvement, to whatever extent it was, was
15
with Whitehaven.
16
product for them, as far as I was told.
17
18
19
Other than that, this was a new
Thank you.
And what did you learn about Whitehaven?
I learned that Whitehaven was a company that
20
Jack Simony was affiliated with, that other people from
21
the hedge fund may from time to time have been
22
affiliated with through investing or otherwise, and that
23
they were in the business of investing in lawsuits
24
during the course of, prior to the conclusion of,
25
litigation.

(954) 525- 2221
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1
Now, the one person that we did not discuss
that was at that initial meeting in New York was Jack
Simony.
about his relationship to the hedge funds?
What did you come to learn about -- anything
My understanding was that Jack Simony was like
the hedge fund's, for lack of a better word, salesman,
that they -- it was like a product -- project manager,
that he went out and found investors and also found
things to invest in; and that when he brought in an
10
investor or found a project to invest in, that it was
11
his job to oversee that project and handle the
12
participants, smooth over rough bump in the road, you
13
know, overall hand-holding of the -- of whatever project
14
it might have been.
15
16
constant interaction with him at some point?
17
18
I had more interaction with him than anyone
else at the hedge funds.
19
20
And would it be fair to say that you had
We'll get to the emails in a moment.
I want
to go back to Kroll very quickly.
21
You had testified that you did not know before
22
October of 2009 that Kroll had been retained by the
23
hedge funds, correct?
24
25
Yeah, I have no independent recollection of
that.

(954) 525- 2221
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Page 841
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Had you learned, at any point during the Ponzi
scheme, that Kroll had been retained by the hedge funds,
what reaction would you have had, if any?
I would have been concerned.
Why?
Because when you are running a Ponzi scheme,
you want as few people as possible, and definitely as
few sophisticated people as possible poking around in
your business.
10
11
12
What do you know, if anything, about Kroll
that had any impact on that reaction?

A
I knew that Kroll was an international
13
investigative company, that, to my knowledge, was
14
extremely sophisticated.
15
16
17
And had you -- your law firm ever used Kroll
in any of its investigations?

A
I don't think so.
To my knowledge, we didn't;
18
but it's certainly possible that one of the attorneys
19
that we ultimately had working for us did.
20
Would you have any -- would you have any
21
different reaction had it been ABC investigative agency
22
out of Hialeah in terms of the level of scrutiny that
23
you thought would have been conducted?
24
25
I have don't mean that to be funny.
I'm just
using an example.

(954) 525- 2221
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Page 842
1
MR. SCHERER:
MR. CIMO:
MR. SCHERER:
MR. CIMO:
Why did you choose Hialeah?
Totally random, a random city.

Right.
Let the record reflect that
Mr. Rothstein is smiling.
BY MR. CIMO:
Had a less-sophisticated investigative firm
been retained that you had never heard of, would that
have made any difference in your reaction to an
10
investigative firm being retained?
11
12
ALL PRESENT:
A
Objection.
Depending on who was involved in the
13
investigative firm, it would have made a difference in
14
my reaction.
15
BY MR. CIMO:
16
Okay.
So, would you say Kroll, in terms of
17
investigative firms, is either the top of the food
18
chain, middle, low?
19
ALL PRESENT:
20
BY MR. CIMO:
21
22
23
I mean -Objection, form.
-- where did you place it in terms of
sophistication?
A
To my knowledge of everything, based upon what
24
I know, they were one of the more sophisticated
25
investment companies.

(954) 525- 2221
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Page 843
1
Okay.
Excuse me, investigative companies.
Now, and had you learned that Kroll had, in
fact, been retained, what reaction would you have had,
if any, regarding its potential impact on your Ponzi
scheme?
7
8
9
ALL PRESENT:
A
Objection to form.
I would have been concerned about possibly
being discovered or having-- problems with law
10
enforcement because I knew that they had -- they hired,
11
frequently, retired law enforcement, so it would have
12
been of concern to me.
13
BY MR. CIMO:
14
Now, in addition to possibly learning that a
15
high-level-sophisticated firm, like Kroll, had been
16
retained but also had been requested to do due diligence
17
at RRA's offices, what reaction would you have had, if
18
any, with regard to that -- learning that information?
19
20
ALL PRESENT:
A
Same objection.
I probably would have told Preve to cut off
21
negotiations with the hedge funds and let's go look for
22
money elsewhere.
23
BY MR. CIMO:
24
Why?
25
Because when you're running a Ponzi, you don't

(954) 525- 2221
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Page 844
1
want sophisticated investigators poking around in your
business.
You stated earlier that you believed certain
of these hedge-fund individuals were sophisticated, but
you said they were doing due diligence at RRA offices?
Yes.
Why didn't that concern you about it being
8
9
discovered, meaning the Ponzi scheme?

A
You have to differentiate between
10
sophisticated, and then you couple with sophistication,
11
are they straight and narrow, or are they heading
12
towards the direction of being a player, as I described
13
over the last several of days.
14
So you could have someone who is
15
sophisticated -- Mr. Preve was extremely sophisticated
16
in banking.
17
player.
18
Mr. Preve was also an extremely high-level
Doug Von Allmen was any extremely
19
sophisticated investor, not a player, if that helps you
20
with your understanding.
21
At any point did you reach the conclusion,
22
before October of 2009, that any of the individuals that
23
you dealt with at the hedge funds met the definition of
24
player that you previously testified about?
25
Yes.

(954) 525- 2221
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Page 845
1
Who?
Mark Nordlicht, Jack Simony -- and Ari Glass
kept jumping over the line from one side to the other
depending upon his mood.
You mentioned earlier certain of these
gentlemen and I -- you didn't identify who, engaged in
what I would call extra-curricular activities with you,
in regard to, for example, going out and having fun with
the guys.
10
MR. SCHERER:
11
BY MR. CIMO:
12
Did you say that?
13
You're not saying that makes him a bad person,
14
15
16
17
are you?
Q
No, no.
I'm am just -- I'm just following up
on -- I think you gave -A
A lot of people that go out and have a good
18
time with extra curricular activities, and it doesn't
19
necessarily make them criminals.
20
I understand completely, but what I'm asking
21
about is just trying to get the scope of the
22
relationship on the gentlemen you described as players.
23
24
25
You have a lot of people in here panicking
right now, by the way, just -- just so you understand.

Q
Did any of the players you mentioned --

(954) 525- 2221
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Page 846
1
Mr. Nordlicht, Mr. Simony or Mr. Glass -- ever go out
with you after hours for nonbusiness-related activities?
Mr. Simony did and Mr. Glass did.
And what was the general nature of those after
hour activities?
6
7
and was at my home when I had several escorts there.
8
9
10
11
Mr. Simony attended gentlemen's clubs with me
And Mr. Glass went to gentlemen's clubs with

me.
Q
Okay.
Were there any escorts at the
gentlemen's clubs?
12
ALL PRESENT:
Objection.
13
THE WITNESS:
Have you ever been to a
14
gentlemen's club?
15
MR. CIMO:
I'm not going to answer that.
16
I don't mean to be facetious.
17
18
BY MR. CIMO:
19
Yes.
What I'm asking is, did you actually observe
20
Mr. Simony and Mr. Glass engage in activities that would
21
be normal activities at a gentlemen's club?
22
23
24
25
Yes.
I paid for their activities at the
gentlemen's club.
Q
Okay.
Let's go back now to how you concluded
that the three gentlemen you mentioned were, in fact,

(954) 525- 2221
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Page 847
1
players?
to conclude today that he was a player?
What was it about Mr. Nordlicht that led you
UNKNOWN SPEAKER:
Just clarification, you
said today?
MR. CIMO:
Yeah, his testimony is today,
he concluded that Mr. Nordlicht meets his
definition of player.
9
10
It was a number of factors, not the least of
which was that one-on-one conversation I had with him in

my office when this was blowing up.
11
At that meeting, I was explaining to him, what
12
I explained the other day, what DOMAD was, the doctrine
13
of mutually assured destruction:
14
everyone blows up.
15
He fires, we fire,
He was explaining to me that he was very
16
familiar with the whole process, that if I knew his
17
history, he started talking to me about the problems
18
that his father, Julius, had had with the government and
19
he had done time.
20
optionable litigation.
21
People don't say that.
22
He explained to me about the

He didn't say he was a player.
He said, you know, I have been through all
23
this.
24
want to do whatever I can do to help you get everything
25
back on track and make sure everyone get's their money.
I got it.
I just want to get us to a place, I

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Page 848
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He said, you're not going to -- he kept saying to me,
you're not going to tell me anything I haven't heard
before, you know.
That was the mantra of that meeting.
What event -- what transpired before that
meeting that precipitated this meeting or that
conversation with Mr. Nordlicht?
Them cutting us off and us cuttings them off.
Whenever you say "cutting off," can you
describe what you mean by that?
10
11
14
15
16
They cut us off from funding, and we cut
them off from funding.
12
13
Yes.
Well, when you say "we," who are you referring
"They" would be the hedge funds, and "we"
to?
would be me, Levin and Preve.

Q
Okay.
But, again, there's no direct funding
17
coming from the hedge funds to RRA; it's all going
18
through these three Banyon entities, correct?
19
Right, but I controlled the purse strings.
20
Okay.
Other than what you described already,
21
is there any other things that happened with Mr.
22
Nordlicht -- by the way, would this have been April of
23
2009 --
24
ALL PRESENT:
Objection.
25

(954) 525- 2221
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Page 849
1
BY MR. CIMO:
-- when you had this conversation with
Mr. Nordlicht?
I would be guessing.
I don't remember when it
was, but it was immediately after we stopped paying
them.
would have been around that time.
We stopped paying them on April 13th, 2009, so it
Thank you.
And let me -- I have to -- there was an
10
objection to the form, so I have to just ask you the
11
question as an open-ended question.
12
Okay.
13
What event, if anything, had transpired that
14
would refresh your memory as to the approximate month
15
and year that this meeting had occurred with Mr.
16
Nordlicht?
17
We stopped sending payments to the hedge funds
18
on April -- on April 13th, 2009, which sent the hedge
19
funds into a wild panic.
20
And the meeting occurred shortly after that?
21
It did, to my recollection.
22
What was it about Mr. Simony that lead you to
23
24
25
conclude that he was a player?

A
Mr. Simony and I spent a lot of time together.
You have to understand, it wasn't one thing that he did;

(954) 525- 2221
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Page 850
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it was the way he conducted business.
He was doing side deals with Frank Preve that
he wasn't telling people about.
in investors from the side.
deal with Murray that people supposedly didn't know
about.
7
8
He was trying to bring
He was engaged in a side
He conducted business in a far more shady

manner, just his overall manner of doing business.
You know, there are people -- the best thing
10
to do is line them all up with Brian Jedwab.
11
Jedwab was straight.
12
about him.
13
if there was any fraud, he would have run for the hills,
14
calling the police as he was running.
Brian
There was -- there was no two ways
15
If he had figured out what we were doing or
Jack, no.
Okay?
That's just -- you spend a lot of
16
time with someone, you get a feel as to what they are
17
susceptible to, how malleable they are.
18
that category of "player," as was Mr. Nordlicht.
19
Jack was within
Mr. Glass, as I said earlier, he jumped back
20
and forth.
21
I mean, I thought he was in the middle of calling the
22
SCC; although, I'm now learning that may have been a
23
whole shtick he was pulling with me.
24
25
There were times when Ari Glass was berserk.
But when I went to the Bahamas with him and we

were drinking and running around and I realized he was

(954) 525- 2221
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Page 851
1
engaged in this tax-fraud thing where he was supposed to
be doing things in the Bahamas, but, really, what we
were doing was drinking and sending on emails saying the
deals are approved, you start to feel like that person
is more of a player.
6
7
I hope that's helpful.

Q
8
9
Thank you so much.

And going back, before we move on, to Kroll,
or any other independent, sophisticated firm that may
10
have been requested to do due diligence, had -- had an
11
independent firm -- truly independent firm, of the
12
stature of Kroll, actually come in and examined books
13
and records of RRA, including those supposed settlements
14
that were being done, what, if anything, would have
15
happened?
16
17
ALL PRESENT:
A
Objection to form.
I have no way of knowing one way or the other.
18
Obviously, if someone is extremely
19
sophisticated that asks all the right questions, if I'm
20
not capable of getting over on them, they are going to
21
figure out that it's a fraud.
22
BY MR. CIMO:
23
Assume, for purposes of my question, that the
24
right questions get answered and there is true
25
independence and there is a true effort to determine the

(954) 525- 2221
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Page 852
1
veracity of these settlements, what, if anything, would
have happened?
3
4
ALL PRESENT:
A
Objection to form.
It is my opinion that, ultimately, someone who
was sophisticated, that wanted to figure out that there
was a fraud, had they asked the right questions, would
have figured it out.
That's my opinion.
MR. CIMO:
10
128.
11
12
I am showing you, now, Exhibit
(Thereupon, a document was marked as Trustee's

Exhibit No. 128 for Identification.)
13
MR. CIMO:
And for the record, this is an
14
email dated July 24, 2008, 3:57 p.m., from
15
Frank Preve to Scott Rothstein, Bates stamped
16
FP, and I'll just give you the last digits,
17
2616/1.
18
BY MR. CIMO:
19
20
I have.
21
Who are the "good fellas" that you reference?
22
I didn't.
23
Let me rephrase my question.
24
25
I'm sorry.
When Mr. Preve uses the term "good fellows" in

the subject, what, if anything, do you know about that

(954) 525- 2221
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Page 853
1
2
3
use of that phrase at that time?

A
That was his -- he says "good fellows" where I
say "good fellas."
That's all.
We used -- just so you understand, we used to
refer to the hedge funds as, you know, our associates.
They were in business with us.
Frank would be more proper.
He would say the
"good fellows," and I would say, "you mean the good
fellas, right?"
10
11
And "good fellas" is what?
reference to a movie or -- I mean or a pop culture term?
12
Yes.
13
Organized crime.
14
15
Is that a
It is a reference to organized crime.
Was there a movie by that title?

A
16
There was.
ALL PRESENT:
Objection.
17
BY MR. CIMO:
18
Did you see that movie?
19
I did.
20
And when you refer to the term "good fellas"
21
as the hedge funds, did you think about that movie?
22
23
ALL PRESENT:
A
Objection.
I think about the -- I thought about people
24
that I did business with.
I mean, it was just -- this
25
is -- it's "good fellas".
That's just the way you

(954) 525- 2221
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Page 854
1
describe it.
our little group of -- merry band of -- it's Robin Hood
and his band of merry men.
BY MR. CIMO:
He was trying to be tongue-in-cheek about
Did you ever actually tell any of hedge fund
personnel that you were dealing with that they were your
"good fellas"?
8
9
Did I say that to them, no; but I mean --
listen, even in the short period of time, you know me,
10
you know me well enough to know that I am a wise ass.
11
So, yes, we had a lot of banter of that type.
12
my general nature.
13
14
Okay.
It's just
I try to be fun loving.
But, therefore, the reference to it
wasn't in regard to anything related to organized crime?
15
Was I saying that there --
16
Yes.
17
No, no, I wasn't saying it.
18
Okay.
It makes reference to Ari, Gil and
19
Mayer, who -- if you know, who is being referred to
20
there?
21
22
Mayer.
23
Ari Glass, Gil Kalter, and Mark Nordlicht,
And it talks about, "we'll all be there around
24
4:15 to 4:30"; do you recall where "there" was in or
25
about July of 2008?

(954) 525- 2221
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2
I don't recall specifically, but it appears to
be to my law firm.
And how often did any one of these gentlemen,
or any other gentlemen from the hedge fund, visit your
office?
Infrequently.
And why was it necessary for -- if you know,
for these gentlemen to visit your office, when they're
basically providing funding, loan -- whatever the term
10
is, to the Banyon entities, but they have no direct
11
agreement with RRA, if you know?
12
I don't know one way or the other.
Sometimes
13
it was due diligence, and sometimes it was just coming
14
over to visit.
15
All right.
And did anyone at Banyon have a
16
problem that their lender was meeting with -- lender
17
representatives were meeting with you at your law firm
18
without --
19
No.
Now you're getting it now as far as what
20
good fellas is a reference to.
21
all and all for one.
22
23
We're all in this to make money.
Now you are catching on as to what we are

talking about.
24
25
It's one -- it's one for
Was Preve intended to attend this meeting, as
well?

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Page 856
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Yes.
And was there a reason why the meeting is at
your office, instead of Banyon's offices, if you know?
Why was your law office picked as the location for this
particular meeting?
I have no independent recollection of why.
Did you ever meet at Banyon offices with the
8
9
hedge-fund personnel?
A
I recall a meeting over there where maybe Jack
10
was there; but most of the time, the meeting took place
11
in my offices.
12
Mr. Preve then talks about a forecast?
13
Yes.
14
What forecast is he referring to, if you know?
15
Funding forecast.
16
Funding means deals that are going to be
17
18
19
20
offered?
A
Meaning the amount of money we are going to
need and the amount of money we can expect coming in.

Q
If you know, why didn't you just convey that
21
information to Mr. Preve, and then he can convey that
22
information to his lender, instead of you all being
23
together in the same room doing it, if you know?
24
25
In reading this, he says he's either going to
come over before or after, which means, to me, in

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Page 857
1
reading this now, that he was coming over to meet with
me, privately; not necessarily while they were there.
Okay.
Next question is:
During 2008, do you
have a recollection of actual deals being done with the
Banyon entities, if you know, and where the hedge funds
were providing the money for the deals?
Time frame, again?
During 2008, from and after July of 2008
9
10
I'm sorry.
through November of 2008, deals were already happening

at this point?
11
Sure.
12
And you have a recollection of the amount of
13
funds at this point through November of 2008?
14
I don't.
15
In terms --
16
It was a lot of money, but I don't recall the
17
18
amount.
Q
In terms of volume, do you have a recollection
19
whether the Banyon entities were providing most of the
20
volume for purposes of the settlements?
21
22
23
From July 2008 to November 2008, the bulk of
the Ponzi business went through Banyon.

Q
And Mr. Von Allmen and these other investors
24
you mentioned before, Mr. Sochet, are these gentlemen
25
that came in 2009, as opposed to 2008?

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Page 858
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Sorry.
Yeah.
Can you repeat the question?

Mr. Von Allmen, Mr. Sochet, these other
investors that you mentioned that had high
sophistication levels similar to the funds, equal to or
similar to the funds, are these people that came in 2008
or 2009?
ALL PRESENT:
BY MR. CIMO:
10
Objection to form.
My recollection is it was sometime in 2009.
Okay.
Other than these Banyon entity
11
investments, were there any other large players -- not
12
player, I should say large investors -- apart from the
13
Banyon entities funding them?
14
ALL PRESENT:
Objection.
15
THE WITNESS:
Of the same size as them?
16
BY MR. CIMO:
17
Yes.
18
No.
19
I consider the Morses to be fairly large.
On number of deals, Barry Lipsitz and Domenick
20
Tonacchio both were doing a bunch of business with us;
21
but nobody else that I can recall at this time.
22
23
24
25
MR. CIMO:
I will show you, now, Exhibit
129.
Exhibit No. 129 for Identification.)

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Page 859
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BY MR. CIMO:
Mr. Rothstein, I'm showing you Exhibit 129.
It starts with an email from Brian Jedwab to a -- Ben
Radinsky.
5
6
Do you know who Ben Radinsky.

A
My recollection is he's someone that worked in
the back office at one of the hedge funds, but I don't
even remember if I -- I think I met him once or twice,
but I have no independent recollection.
10
And then it has an address and a title for
11
Mr. Jedwab, managing director, Centurion Credit
12
Management.
13
Mhm-mhm.
14
Do you recall seeing that title and that
15
Do you recall seeing that?
entity before?
16
Sure.
17
And that address, 152 West 57th Street, is
I've seen that before.
18
that the address in New York that you had the initial
19
meeting at?
20
Yeah.
21
And I notice this is not the same Centurion,
That's the Carnegie building.
22
by the way, that I showed you in the initial exhibits at
23
the beginning of the deposition that's under that credit
24
agreement.
25
Yeah.

(954) 525- 2221
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Page 860
1
2
3
Did you know that there were other Centurion
entities besides the one that did -A
I remember seeing a whole host of -- a variety
of different Centurion names, Platinum names; but I
don't know if I stopped to think about who they were or
what they were doing.
7
8
You see in his email it says
[email protected]?
I do.
10
Do you recall ever getting any other emails
11
from Mr. Jedwab that had any other prefix in it, besides
12
Centurion?
13
14
I didn't
study his email address.
15
Jack Simony, which is in the middle --
16
Simony.
17
Simony, I'm sorry.
18
That's okay.
19
-- this Whitehaven Group, LLC, is that the
20
same Whitehaven that you mentioned before that was doing
21
structured settlements?
22
Yes, sir.
23
And did you know that Whitehaven Group was an
24
25
entity that Mr. Simony was affiliated with?

A
Yes.

(954) 525- 2221
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Jack told me and Mr. Preve told me.
Okay.
Whitehaven Group is 350 5th Avenue.
5
6
7
8
9
I notice the address for Mr. Simony at
Did you ever go to that location?

A
I went to that location.
It's the Empire
State Building, but not to his offices.

Q
And do you know whether Mr. Simony had an
office, as well, at 152 West 57th Street?
10
To my knowledge he did, but I was never in it.
11
The document talks about an RRA AGMT; do you
12
know what that is referring to?
13
RRA agreement.
14
Do you know what agreement is being referenced
15
that may have involved Whitehaven Group?
16
I have no idea.
17
Let's now go to Exhibit 129 -- I'm sorry, 130.
18
19
20
UNKNOWN SPEAKER:
What's the date of that
last one, please?

MR. CIMO:
I'm sorry.
This document is
21
dated November 20th, 2008, and it also has a
22
separate email dated October 27, 2008.
23
UNKNOWN SPEAKER:
24
MR. CIMO:
25
Thank you.
I'm now going to show you
Exhibit No. 130, which is an email dated

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Page 862
1
December 3rd, 2008, Bates stamped Rothstein's
940 through 957.
(Thereupon, the documents were marked as
Trustee's Exhibit No. 130 for identification.)
BY MR. CIMO:
All right.
Did you laugh when you saw this
document?
I did.
Why?
10
Because it has Mr. Preve's alias on it.
11
And what is his alias?
12
G. Steinbeck.
13
And do you know why that -- why that was used,
14
15
that particular alias?

A
He had told me at one point in time, but I
16
don't remember why; but when he was doing his private
17
funding deals away from Mr. Levin, he used this email
18
address.
19
20
And you see that the suffix of the email
address is SFS Funding?
21
Yes.
22
Did you come to learn whether SFS Funding was
23
involved in a deal, a side deal involving Regent?
24
It was.
25
And did you come to learn that Mr. Preve, in

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Page 863
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2
3
fact, was a control person and/or owner of SFS Funding?

A
It -- to my knowledge, it was Mr. Preve, Mr.
Nordlicht and Mr. Huberfeld.
SFS Funding?
That was my understanding, yes.
And did you know this before --
Who did I give you, Mr. Preve,
Mr. Nordlicht -- Mr. Simony, and Mr. Huberfeld, all in
different pieces.
10
That was my understanding, but I
would be completely wrong.
11
12
From conversations I had with Mr. Preve, Mr.
13
Nordlicht, Mr. Simony.
14
Before October of 2009?
15
Yes, I haven't spoke to any of those people
16
17
since October of 2009.

Q
Okay.
Now, this -- I asked you earlier
18
what -- what the RRA AGMT meant.
19
"Jack AGMT," and it says, "here is the Whitehaven
20
agreement."
21
Yes.
22
I'm okay with it.
23
24
25
This one is entitled
We need some clarification
on timing issues.
Why is Mr. Preve on this alias email sending
to you a document regarding Whitehaven Group?

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Page 864
1
ALL PRESENT:
Objection to form.
BY MR. CIMO:
Go ahead.
To the best of my recollection, we were going
To the best --
to do funding through this SFS deal and Whitehaven was
involved in it.
8
9
I am going to rephrase the question regarding
the objection.
10
Do you have a recollection, sitting here
11
today, why this document was transmitted to you by Mr.
12
Preve?
13
Yes.
14
And why is that?
15
Whenever Mr. Preve was doing side deals, he
16
17
liked me to look at the paperwork, which I did for him.

Q
And did you know that at that time that that
18
was sent, that Mr. Preve was, in fact, doing side deals
19
without the knowledge of Mr. Levin?
20
Sure I did.
21
You did.
22
And did you also know before this date whether
23
any of the hedge-fund personnel that you testified about
24
were doing side deals, as well, with any other entities?
25
ALL PRESENT:
Objection.

(954) 525- 2221
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Page 865
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My recollection is that they were.
I'm just a
little unsure as to the -- as to the dates, whether it
was before or after this date.
BY MR. CIMO:
6
7
8
9
That's fine.
What is your definition of a side deal for the
purpose of these questions?

A
A side deal is what we refer to as a
"one-off," and that would be where members of -- members
10
of other entities that were funding to us, that had --
11
where all the members were supposed to be looking out
12
for the interests of each other, where one of those
13
members would drop off; cherry pick a solid, good,
14
high-interest-rate deal and fund it separate and apart,
15
confidentially, from the members of the other
16
organization.
17
And how did you know that it was confidential
18
from the members of the other organization?
19
you believe that?
20
21
22
What made
Everyone kept telling me not to tell the other
person what they were doing.

Q
So let's talk about, for example, SFS Funding
23
that you say, sitting here today, that Mr. Preve was in
24
with Mr. Nordlicht, Mr. Simony and Mr. Huberfeld.
25
Is it your testimony, sir, that Mr. Nordlicht,

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Page 866
1
Mr. Simony and Mr. Huberfeld told you that you were not
to let the hedge funds know about whatever side deal SFS
Funding may have been involved in?
4
5
6
ALL PRESENT:
A
I have to break that down because you have all
these people grouped in there.
Let's start with Preve.
BY MR. CIMO:
10
Objection to form.
Let's take it back based upon the form
objection.
11
I'm just -- I'm not really concerned about
12
Preve; I just want to know, did Mr. Nordlicht ever tell
13
you that he wanted to do something defined as one of
14
your side deals, where his hedge funds would not know
15
about it?
16
17
No.
Mr. Simony told me, don't discuss this
with any anybody.
18
Not Mr. Huberfeld?
19
Mr. Simony told me.
20
And not Mr. Huberfeld?
21
22
You never spoke to Mr.
Huberfeld?
A
I never spoke to Mr. Huberfeld.
Mr. Simony
23
told me never discuss this with anyone other than me or
24
Frank.
25
And which specific deals do you recollect that

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Page 867
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Mr. Simony told you not to talk about?
It would have been the SFS/Regent deal.
don't remember other ones there may have been.
Actually, I -- I think there were.
specific recollection.
I don't have a
And this agreement that's part of Exhibit
No. 130, which is an attachment, do you recall seeing
this at or about the time this email was transmitted to
you?
10
You know, I don't have a specific recollection
11
of receiving this, as I sit here today; but, again,
12
remember, I've overlooked hundreds of thousands of
13
pages.
14
it certainly fits Mr. Preve's model of when he was doing
15
the side deals, sending the documents over to me under
16
this hidden email address for me to take a look at on
17
his behalf.
18
It says it came to me, so I'm sure it did; and
And do you know what revisions were to be made
19
to this document, such as that it would be consistent
20
with the subject called "Jack AGMT"?
21
No, I don't know one way or the other.
22
Do you know who was going to be the
23
participant under this loan and optionable litigation
24
agreement?
25
I can only tell by looking at it but I don't

(954) 525- 2221
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Page 868
1
2
know who actually was putting up the money.

Q
Understood.
Do you recall -- do you recollect -- do you
recognize the handwritten comments on the document as
being yours or anyone else's?
No, no, those are Frank's.
And now I'm going to show you Exhibit No. 131.
Sure.
9
10

11
MR. CIMO:
And for the record, this is
12
defined as RRA Deal G, as "girl," dash 350.
13
It is Bates stamped number SW 13000735, and
14
it's a composite document.
15
For purposes of my questions now, we're
16
just going to cover the first page, and the
17
last page on the composite is SW1300805.
18
BY MR. CIMO:
19
You mentioned earlier the Regent side deal,
20
and I ask you if you recognize these to be the deal
21
documents for the Regent side deal?
22
I do.
23
And do you know whether this deal was actually
24
25
funded?
A
It was.

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Page 869
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And I want you to look at the bottom portion
where it has dates and numbers.
those payments were actually made, and if not, which
ones were and which ones weren't.
Do you know whether
To my recollection, the bulk of them were
made.
believe part of it may have been delayed.
think we paid the entire thing off.
I don't know if we ever finished paying it.
Ultimately, I
And, if you know, sitting here today, did you
10
ever come to learn or understand who the owners and/or
11
control persons were at Regent Capital Partners, LLC?
12
I ultimately learned that Mr. Huberfeld and
13
Mr. Nordlicht were -- I first learned that Mr. Huberfeld
14
was absolutely involved in it; and then I learned that
15
Mr. Nordlicht either knew about it or was involved in
16
it --
17
Thank you.
18
-- and as I said earlier, Mr. Preve and
19
Mr. Simony.
20
Thank you.
21
And is -- am I correct in looking at the first
22
page and then comparing it to the third page, which is a
23
letter, dated December 2nd, 2008, that it was an
24
$11 million investment that would return 22 million?
25
That's correct.
That's what I was talking

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Page 870
1
about in these one-off cherry-pick deals, yes.
2
3
And this is a deal that had a six-month timing
period; is that correct, according to page one?
Yes.
So, is it your testimony, then, that between
the first page of this exhibit and page three, which is
this letter you sent, that there was going to be an
$11-million return on an $11 million investment in six
months?
10
That's correct.
11
And this is one of the side deals that a hedge
12
fund -- two of the hedge funds principals did that you
13
were personally involved with?
14
ALL PRESENT:
15
BY MR. CIMO:
16
17
18
Objection to form.

Did you have personal involvement in this side
deal?
19
I was the person who provided the deal.
20
And Banyon entities were not involved in this
21
22
23
deal?
A
Banyon itself, no, just Mr. Preve from Banyon,
but in his personal capacity as Mr. Steinbeck.
24
25
Preve?
As opposed to his individual capacity as Mr.

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Page 871
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Yes.
We're going to ask you more questions about
this later.
4
5
Then we're going to move on now.
Now I'm going to show you Exhibit 132 -A
Mr. Cimo, just one thing, I want to make sure
that I have clarified and made my answer complete as to
side deals.
8
9
In the same vein as the other side deals,

there was a whole series of side deals being done by Ari
10
Glass unbeknownst to his partners with a childhood
11
friend of his Bo Rosenblat.
12
13
14
15
And what are the names of entities, if you
know, involved in those side deals?

A
I think it was enter -- Intercoastal or
Intracoastal or something of that nature.
16
Intracoastal Group?
17
Yes.
18
(Thereupon, a discussion was held off the
19
record.)
20
BY MR. CIMO:
21
22
Thank you so much.

And do you recall the approximate amount of
23
funding in regard to that particular transaction or
24
transactions?
25
No, I don't remember off the top of my head.

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Page 872
1
ALL PRESENT:
BY MR. CIMO:
Objection to form.
Do you know whether there was more than one
transaction involving Mr. Glass and this Intracoastal
Entity?
ALL PRESENT:
Objection.
BY MR. CIMO:
Do you recall how many?
10
I don't recall.
11
12
13
someplace.
Q
Was it more than six?
You should have the record
I don't remember the number of deals.

And do you know whether any of them had double
your money in six months, like the Regent transaction?
14
15
There was.
ALL PRESENT:
A
Objection to form.
I think the finest cherry-pick deal I ever
16
offered to them was the Regent deal.
17
BY MR. CIMO:
18
When you say "them," who are you referring to?
19
Well, the -- the way it would work was, Mr.
20
Preve, I suspect, would, behind the scenes, decide with
21
someone he was going to do a deal, apart from Mr. Levin,
22
with somebody.
23
cherry deal, a really good deal.
24
25
And would ask me directly:
I need a
And so I would put together a really good

deal, because you want to -- when you're running a Ponzi

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Page 873
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of this magnitude, you want to reward the people that
are taking care of you and helping you sustain the Ponzi
scheme.
Thank you.
I'm going to show you now Exhibit No. 132, an
email dated December 14th, 2008, Bates stamped BLC 56665
through 66.
8
9

10
BY MR. CIMO:
11
What I want to refer your attention to is
12
certain statements made in these emails regarding
13
insurance, and if you could just take a moment and just
14
read the email chain, I would appreciate it.
15
And then I want to direct your attention to
16
the last page where there's an email from you to
17
Mr. Simony.
18
All right.
19
Thank you so much.
20
I'm ready to go.
Let's start with the second page, first off,
21
an email dated December 11th, 2008, from you to
22
Mr. Simony.
23
24
25
Do you recall sending this at or about that

time?
A
I do.

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Page 874
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2
And what are these sample policies that are
referenced in your email?
The sample crime fraud policies.
And why are sample crime fraud policies being
mentioned on or about December of 2008, which is several
months after the hedge fund started investing?
Hedge funds had told us that if they don't get
crime fraud policies, that they were going to not be
able to do any further funding with us at all.
10
Was there any discussion about whether crime
11
fraud policies were, in fact, express conditions of
12
their agreements with the Banyon entities?
13
It wasn't discussed with me, no.
14
Was there any question by you or questions by
15
you why this was being asked for now in December of
16
2008?
17
ALL PRESENT:
18
19
BY MR. CIMO:
20
21
22
Objection to form.
Mr. Preve and I discussed it, yes.
What did you discuss with Mr. Preve about
that?
A
We discussed the fact that they were obviously
23
getting hinked up with the entire transaction because
24
they had already slowed down massive amounts of funding
25
and now were asking for a crime fraud policy, and

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ultimately it was decided I would just make an attempt
to get it.
Levin, going to try to get one, also.
And Mr. Preve was, supposedly, with Mr.
hedge funds?
I am.
Did you or Mr. Preve ever ask the hedge funds
When you say "they," are you talking about the
what was causing them to -- what was the word you used,
"hinked"?
10
Hinked up.
11
Hinked up.
12
Did you or Mr. Preve ever ask them,
13
specifically, what was causing them to being hinked up?
14
No.
15
Was there anything --
16
I didn't.
17
Was there anything going on at this time, if
I don't know what Mr. Preve did.
18
you recall, regarding Mr. Madoff or other Ponzi
19
schemes --
20
ALL PRESENT:
21
BY MR. CIMO:
22
23
24
25
Objection.
-- if you know, any recollection on what's
going on at that time in the media?

A
I recall that the entire insurance thing
started to come up.
When Madoff had hit the scene,

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Dreier had hit the seen, Petters had hit the scene,
there was all kinds of Ponzi stuff going on, and people
were getting, to use my phrase, hinked up, nervous,
edgy.
5
6
Before this insurance issue came to light in
December of 2008 --
ALL PRESENT:
MR. CIMO:
UNKNOWN SPEAKER:
Objection.
What's wrong with that?

Saying that before it
10
came to light, there is no predicate that that
11
is when it first came to light, in December
12
2008.
13
BY MR. CIMO:
14
15
16
17
When did the first issue, to your
recollection, first come to light?

A
My recollection is that they asked me sometime
before these emails to get this policy --
18
Yes?
19
-- but I didn't.
20
Oh, okay.
21
22
23
24
25
Do you recall how much before they asked you,

before December 11th of 2008?
A
It wouldn't have been much before.
I really
have no specific recollection.

Q
Let me ask you:
Did they mention it at that

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Page 877
1
meeting that you had with them, the first initial
meeting?
Did they mention it back then?
No, sir.
Did they mention it in June of 2008, to your
recollection?
To my recollection, no, sir.
Did they mention it in July of 2008 to, your
recollection?
ALL PRESENT:
10
Objection to form.
I don't have an independent recollection;
11
towards the latter half of the year, sometime around
12
when all of the things started hitting the media about
13
people losing money to Ponzi schemes, my best
14
recollection is that's when they started talking about
15
it.
16
BY MR. CIMO:
17
Now, what reaction did you have, if any, when
18
this insurance issue came up, and what impact did it
19
have on your ongoing Ponzi scheme, where the word crime
20
insurance is mentioned?
21
I had a discussion with Mr. Preve about
22
whether or not he thought we could actually qualify for
23
this type of insurance.
24
The concern that I express -- the concern that
25
I expressed to Mr. Preve was the level of diligence that

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1
an insurance company might require in order to attempt
to get this type of insurance.
We didn't think it was going to be
problematic.
qualified for it, not the levels of insurance that they
wanted.
7
8
So what I did was I called my insurance agency

and got some sample policies.
9
10
We also really didn't think that I
I sent the samples over.
I, ultimately, of course, never got crime

fraud insurance.
11
When you say "I," you mean the Rothstein firm?
12
Yeah, the Rothstein firm.
13
I don't even think we actually did a
14
full-blown, formal application for crime fraud
15
insurance.
16
themselves.
17
I think that was all done by Banyon for
Thank you.
18
I now want to show you Exhibit No. 133.
19
20
21
22
MR. CIMO:
chain, December 23rd, 2008.
23
BY MR. CIMO:
24
25
PCL 56811 through 56851 email
I would like to start off with the email from
Mr. Scott Rothstein on the second page to Mr. Simony,

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1
with a copy to Mr. Preve -- Simony, I'm sorry, I don't
mean to say Simony.
3
4
UNKNOWN SPEAKER:
same.
BY MR. CIMO:
Mr. Simony?
11
12
13
14
15
In the record it's the
So...
10
It has a different context.
Mr. Rothstein, do you recall this email to

I do.
Okay.
Why did you send this email to
Mr. Simony in or about December of 2008?

A
Brian Jedwab was conducting enhanced due
diligence on behalf of the hedge funds.

Q
How did you find out that there was enhanced
due diligence being conducted?
16
Jack Simony told me.
17
And what relationship, if any, did it have to
18
the insurance policy request?
19
I don't recall.
20
What relationship did it have, if any, to the
21
Dreier and these other things hitting the media in or
22
about this time?
23
ALL PRESENT:
24
BY MR. CIMO:
25
Objection to form.
If you know?

(954) 525- 2221
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Page 880
1
It's not that I don't know.
assuming to tell you that.
their heads.
I don't know what was in
I can assume --
No, no.
I mean, I don't know.
10
11
12
Don't assume.
No.
I don't know.
I know
that they were doing enhanced due diligence.
8
9
I would be
In a time-line fashion I can tell you it was

subsequent to all of these various Madoff, Dreier,
Petters hitting the newspaper.
Q
What was wrong with the initial due diligence
that it was done?
13
ALL PRESENT:
14
15
BY MR. CIMO:
16
Objection.
You would have to ask them.
What did you learn, if anything, about what
17
was missed with the initial due diligence that was
18
done --
19
ALL PRESENT:
20
BY MR. CIMO:
21
22
23
24
-- in or about the spring of 2008?

ALL PRESENT:
Objection to form.
Objection to form.
Again, that's -- you're asking me a very broad
question.
25

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Page 881
1
BY MR. CIMO:
I am just asking you what you know.
What did
you learn, if anything?
ALL PRESENT:
Objection.
Again, here's the problem with the question:
You're asking me what they missed.
missed a Ponzi scheme.
BY MR. CIMO:
No.
Obviously, they
Please understand, my question is focused
10
on what were you told or what did you learn that was
11
being done as part of the enhanced due diligence?
12
I have that question.
13
Thank you.
14
They wanted to be able to substantiate deal
15
16
flow.
Q
Did anyone explain to you why it was important
17
to substantiate deal flow in December 2008, as opposed
18
to any other month?
19
Yes.
Mr. Preve told me that Mr. Jedwab had
20
told him and Mr. Simony had told him that Brian and Gil
21
Kalter had significant concerns about the shear
22
magnitude of the number of cases that we could possibly
23
be bringing into our law firm and ultimately handle
24
them, that it seemed -- the word they used was "absurd."
25
And then why do you have this paragraph one in

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1
here which explains, apparently, your understanding of
Florida law regarding settlement amounts being entered
into trust?
email to Mr. Simony?
Why is that in this first paragraph of your
Just give me a minute to read it again.

In -- in examining the records, the financial
records and the timing of when we got our money, we were
requesting deals to be funded before we had paperwork to
send them.
10
We would from time to time say we already had
11
the money in house.
12
time --
They then asked at some point in
13
"They" being who?
14
The hedge funds.
15
I'm sorry.
The hedge funds would then ask how the heck do
16
you have the money in house; there is no paperwork yet?
17
I came up with this explanation, you know, in
18
talking to Mr. Preve, that the way we had money in house
19
ahead is that just our agreement at mediation settlement
20
conference was enough to enforce it and they wanted to
21
pay the money as quickly as possible to be able to say
22
they had an enforceable settlement agreement.
23
But you're saying in your email that Florida
24
law provides this, right?
25
Florida law?
You're saying this is under

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Yes.
Okay.
If you know, what was discussed, or, if
you recall -- with them as to why they're asking you
what Florida law provides?
ALL PRESENT:
BY MR. CIMO:
Did they think you had some special gift about
what Florida law provided?
10
ALL PRESENT:
11
BY MR. CIMO:
12
13
14
Objection to form.
Objection.
I'm am just asking.

Was it discussed why they were asking you?
It was not discussed why they were asking me,
15
except that they asked, how are we possibly getting
16
these millions of dollars ahead of time, why would the
17
defendants send me all that money without having any
18
paper?
19
Is your explanation of Florida law accurate?
20
I don't know one way or the other.
21
the paragraph.
22
writing.
23
I made up
I did no research; I just started
So did Mr. Simony ever contact you, or anyone
24
from the hedge funds contact you, and say, hey, you
25
know, that December 22nd, 2008, email didn't accurately

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Page 884
1
set forth Florida law?
ALL PRESENT:
BY MR. CIMO:
Objection to form.
No.
Did anybody ever follow up with you from the
hedge funds, at all, about what Florida law provided?
Not to my recollection.
Did anyone ever say to you, at all, at any
time during the Ponzi scheme, from the hedge funds, that
10
any aspect of it related to Florida law was not
11
consistent with their understanding of Florida law?
12
ALL PRESENT:
13
14
BY MR. CIMO:
15
Objection to form.
No.
Okay.
Let me just ask another question.
16
What discussions were there, if any, about
17
Florida law with the hedge funds where they told you
18
what they thought Florida law provided?
19
20
ALL PRESENT:
A
Objection to the firm.
From time to time they would tell me --
21
especially Jim Kalter and Brian Jedwab, because they --
22
my recollection is they were lawyers, they would tell me
23
what their understanding of the law was; and if it
24
matched what I wanted the law to be, I would say they
25
were correct.

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Page 885
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And if it conflicted with what I wanted and
needed the law to be for the purpose of the Ponzi
scheme, I would simply tell them they were wrong.
conversations ended at that point in time.
BY MR. CIMO:
its counsel?
No.
And with that -- with those responses that you
The
Did the hedge funds ever hire the RRA firm as
10
would give where you would disagree or agree, did anyone
11
ever come back to you from the hedge funds and correct
12
you on Florida law?
13
14
ALL PRESENT:
A
I have no recollection of them correcting me.
15
I have recollection of one or two occasions where they
16
questioned me a second time, where I then made it
17
abundantly clear that this is what the law was and they
18
left us alone.
19
BY MR. CIMO:
20
"They" meaning the hedge funds.
Did you ever receive a phone call or an email
21
or any communication from a Florida lawyer of high
22
stature, asking you -- having a discussion with you
23
about Florida law?
24
25
ALL PRESENT:
A
I don't --

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Page 886
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BY MR. CIMO:
I'll --
I don't recall them hiring a Florida lawyer to
4
5
talk to me, no, sir.

Q
Do you recall any law firm, any law firm
located anywhere in the world, ever contacting you on
behalf of the hedge funds, before October of 2009, that
had any discussion with you about any law?
9
10
ALL PRESENT:
A
Objection to form.
Troutman and Sanders may have.
They may have;
11
but, again, understand, for whatever reason, any time I
12
explained what Florida law was, other than a couple of
13
follow-up questions, that was it.
14
BY MR. CIMO:
15
Okay.
16
-- the gospel according to Scott.
17
Thank you.
18
It was a --
Let's go now to the next page of your email,
19
which we'll call paragraph two; and you say, "firms that
20
refer us employment cases," and you list Joseph Slama,
21
S-L-A-M-A -- is that the correct pronunciation?
22
Yes.
23
-- from Krupnick Campbell?
24
Yes.
25
Is that a well-respected firm?

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Page 887
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Very.
ALL PRESENT:
BY MR. CIMO:
What opinion do you have, if any, about the
respectability of the Krupnick Campbell firm?
6
7
Object to form.
ALL PRESENT:
A
Objection to form.
I thought they were an excellent and
professional personal injury law firm.
BY MR. CIMO:
10
11
Not -- not a firm that sticks their name on a
park bench or a bench by the side of the road?
12
ALL PRESENT:
13
BY MR. CIMO:
14
15
16
Have you ever seen in South Florida the

Krupnick Campbell firm advertise on a bench?
17
No.
18
Oh, really.
19
20
Okay.
ALL PRESENT:
A
Objection, form.
Mr. Slama.
24
Mr. Slama?
I -- I don't believe Mr. Simony ever spoke to
23
25
And what did Mr. Simony tell you about
what his discussion was with Mr. Slama?
21
22
Objection, form.
I don't recall anyone ever speaking to
ALL PRESENT:
Objection, form.

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Page 888
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BY MR. CIMO:
Do you know why not?
Yes.
Why?
Because what had ultimately happened was when
Why not?
they were doing their enhanced due diligence -- I think
I described this yesterday, but let me go through it to
make sure we're clear.
When they were doing their enhanced due
10
diligence regarding deal flow, I immediately sent out an
11
email to my entire firm saying, I need to, you know, get
12
people who are going to say nice things about us in our
13
employment business, anybody that you have that will say
14
good things about us, about referring us cases and that
15
the results are favorable, let me know.
16
We went back and forth a little bit.
17
Originally it was going to be a set group of
18
questions I was going to ask.
19
responded.
20
Schlesinger that it looks like they called --
A couple of the lawyers
I can see here from Slama and Bob Kelley and
21
Shelly Schlesinger?
22
Shelly Schlesinger.
23
Is that a respectable firm to your knowledge?
24
25
ALL PRESENT:
A
Objection.
Yes.

(954) 525- 2221
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Page 889
1
2
That those three came from Mr. Adler because

he was very close to all those people.
But, in any event --
BY MR. CIMO:
Go ahead.
-- Mr. Jedwab then decided that he's not going
to ask just my questions, that he wanted to ask a
broader base.
conversation with them.
10
He wanted to be able to have a
Obviously, Mr. Preve and I could not have that
11
happen.
12
that happen, because that could create a real problem
13
for us with these people, since they did not -- they
14
would not be able to substantiate the deal flow that we
15
had.
16
No one involved in the Ponzi scheme could have
So we went into phase two of the response to
17
their enhanced due diligence, which was this.
18
Russ Adler, who had been screaming to become involved
19
deeper in what we were doing; and I told him he was
20
going to have his chance.
21
I went to
I said, this is -- I explained to him what was
22
going on, and I told him that I needed several firms
23
that would lie for us, specifically, about referring us
24
a substantial amount of cases that were worth tens of
25
millions of dollars and that we were paying these firms

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Page 890
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significant amounts in the millions of dollars of
referral fees.
3
4
For the purposes of this deposition, can we
refer to those firms as the park-bench firms?
ALL PRESENT:
BY MR. CIMO:
I know, for the record, you're smiling.
Why
are you smiling?
9
10
Objection.
Because the way you're saying that is funny,
especially because Steve Rossi had a park-bench ad.
11
Okay.
Who was -- what's Steve Rossi's
12
relationship to this scam that you did with Mr. Adler
13
about these other three lawyers?
14
ALL PRESENT:
15
BY MR. CIMO:
16
Objection to form.
Mr. Rothstein, do you agree this was a scam to
17
have three lawyers that were supposedly going to say
18
that they were giving large amounts of business to your
19
firm?
20
Yes.
21
Okay.
22
scam?
23
24
Am I wrong in characterizing it as a
ALL PRESENT:
A
No.
Objection.
We were asking them to lie for us.
25

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Page 891
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BY MR. CIMO:
Okay.
So, Rossi did advertise on a park
bench, and he's one of the three lawyers that Mr. Adler
was going to get to talk about how great your firm is,
right?
Yes.
Correct.
8
9
Okay.
Did the other two get put on park
benches, too, or just Mr. Rossi?
10
ALL PRESENT:
Objection.
11
BY MR. CIMO:
12
If you know?
13
I don't recall seeing Mr. Herskowitz's name --
14
Okay.
15
-- I'm sorry, on a park bench or the Koppel
16
Bates.
17
18
19
We will call them the one-third park bench.

ALL PRESENT:
Objection to form.
Mischaracterization.
20
BY MR. CIMO:
21
I tell you what.
In order to get past the
22
objection, I'll call them the other firms; is that okay,
23
Mr. Rothstein?
24
25
Yes.
And we need to clarify, just the nature of

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this is, to make sure this is good, Mr. Nurik has
clarified that these are bus benches.
Park benches, I'm so sorry.

MR. CIMO:
Let the record reflect they
should be bus benches.
BY MR. CIMO:
What I'm going to do is, to avoid any
argumentative nature, I'm going to refer to them as
other firms.
10
Okay?
I'm sorry.
I'm not hearing anything you're
11
saying right now.
12
disrupting my train of thought.
13
14
firms.
15
This is
I'm going to refer to these as the other
You know this is such a sensitive topic with
16
lawyers, those benches, so let's just refer to them as
17
the firms given to me by Adler, and then I'll know what
18
you are talking about.
19
20
acceptable?
21
22
I'll call them the Adler firms; is that
Yes.
The Adler firms were the Rossi Firm,
Steve Rossi's firm, and the Herskowitz Firm.
23
And the Koppel Bates firm -- the Koppel Bates
24
firm was a firm that I brought in to help us with the
25
scam.

(954) 525- 2221
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Page 893
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Thank you.
But if you can just explain to me how these
Adler firms, I'm going to say the one that you referred
to as part of the Adler firms, how did the Adler firms
compare to the other three firms of Krupnick and
Campbell; Robert Kelley from Shelly Schlesinger's firm;
and Fisher and Phillips, in terms of stature and
reputation?
ALL PRESENT:
10
There is no comparison.
You're talking about
11
the Krupnick Campbell firm; the Schlesinger firm; Bob
12
Kelley's firm.
13
You're talking about the cream of the crop of personal
14
injury law firms.
15
BY MR. CIMO:
16
Bob used to be with Shelly Schlesinger.
But you did send an email, dated
17
December 22nd, 2008, you did send this email, to
18
Mr. Simony?
19
Yes.
20
You sent it to him, and do you know if he got
21
it?
22
ALL PRESENT:
23
24
BY MR. CIMO:
25
Objection to form.
Yes, he got it.
He got it, and the email expressly says,

(954) 525- 2221
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quote, you are hereby authorized to contact the
following individuals at the following firms and inquire
as to the following," and then it has A and B.
lists Krupnick Campbell, Robert Kelley, Shelly
Schlesinger's firm and then Fisher and Phillips.
And it
Is it your testimony that you understand
Mr. Simony or no one from the funds ever spoke to these
three firms?
ALL PRESENT:
Objection to form and
10
mischaracterization.
11
No, they did not speak to them because they
12
wanted to do a different level of due diligence, and we
13
could not have them asking these people the type of
14
questions that they were going to ask.
15
have them go to people who were in our pocket.
16
BY MR. CIMO:
17
We needed to
I understand that's your answer; but what I'm
18
trying to understand is, even though you gave them the
19
names of three other firms, the Adler firms, you had
20
given them authority in this email to talk to these
21
other three firms, correct?
22
I did.
23
Okay.
And what I just want to find out is,
24
not what you decided or what you thought was
25
appropriate, I just want to know, did you ever come to

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Page 895
1
learn at any time that there was any attempt to talk to
the Schlesinger firm or the other two firms that were
mentioned in your December 2008 email?
ALL PRESENT:
misleading.
BY MR. CIMO:
Objection to form,
To my knowledge, no.
Am I misleading you by asking this question?
Am I mischaracterizing your testimony in any way?
10
You're not misleading me, no.
11
Okay.
12
13
14
And how do you know that these three
firms were not contacted by the hedge funds?

A
I don't know for certain that they weren't
contacted.
15
Okay.
16
To my knowledge, they were not contacted.
17
And how do you know that the Adler firms that
18
were recommended were contacted or not?
19
I was with them.
20
You were with them, meaning the hedge fund
21
22
representatives, when you visited the other Adler firms?

A
I brought the hedge fund representatives,
23
Mr. Jedwab and Mr. Glass, to the other firms, the two
24
that Mr. Adler set up and the one that I set up with
25
Mr. Adler's assistance.

(954) 525- 2221
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Did Mr. Simony ever ask you why you referred
these three firms, initially, in December 22, 2008, and
then crossed them off the list and then referred three
other firms?
Did Mr. Simony ask me that?
Yes.
No, Mr. Simony couldn't have cared less.
Why not?
Because Mr. Simony just wanted to get back to
10
11
business as usual.
Q
That's what made Jack, Jack.
And what role did the Adler firm
12
recommendations play in allowing, quote, business to go
13
back to usual, if any?
14
I don't think business ever went completely
15
back to usual with the hedge funds.
16
significant business with them afterwards.
17
We never did real
But it satisfied the people -- I know it
18
provided Ari Glass with a significant level of comfort
19
after he got to speak to those people.
20
that it made things much more comfortable for him.
21
He had told me
Do you know whether Ari Glass was ever
22
apprised of the fact that three other law firms had been
23
proposed to Mr. Simony, other than the Adler firms?
24
I have no way of knowing one way or the other.
25
Let me show you Exhibit No. 134.

(954) 525- 2221
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Page 897
1
2

THE WITNESS:
entire email?
BY MR. CIMO:
Do you want me to read the
Please just refresh your recollection very
quickly.
First of all, this email is dated December 25,
correct, Christmas day, 2008, from you to Mr. Jedwab, to
10
Mr. Simony with a copy to Mr. Preve and Mr. Levin --
11
12
For my comfort level, let me read the entire
email, because it's rather long and detailed.
13
Okay.
14
Okay.
15
Do you recall this email?
16
I do.
17
Why did you send it?
18
I was making a very strong attempt to push the
19
hedge funds back.
20
Back to where?
21
Out of my way.
22
When you say out of your way, what did you
23
24
25
mean?
A
The continued requests by Mr. Jedwab, with
regard to enhanced due diligence, I mean, were creating

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a problem for myself, Ms. Villegas, Mr. Rosenfeldt.
were talking about it.
too deep as far as we were concerned.
for new things.
We
They were digging their noses in

They kept asking
And what I had learned over the term of this
Ponzi scheme was, the best way to get people in line, to
go the direction you want them to go, is to push back
and -- just to push back on what they're doing,
utilizing the things that, to the best of your ability,
10
make sense to them as to what they were attempting to
11
do.
12
But we were pushing back at them to try to get
13
them to come to some lower level of due diligence.
14
Ultimately, I was simply trying to get them to fund
15
again.
16
17
And how long had it been since they had
stopped funding?
18
ALL PRESENT:
19
20
BY MR. CIMO:
21
22
23
Objection, form.
I don't recall.
Did there come a point where they either
stopped or slowed down funding?

A
This was around the time when it was stopping,
24
and by reading this email, I recall that they were
25
telling us they weren't going to fund anything in

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Page 899
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December.
Do you have a recollection whether the
decision to either slow down or stop funding was around
the same time that this Regent side deal that you
testified about was being done?
Yeah, it was around that time.
Did you ever have a discussion with anyone
from the hedge funds about why -- the ones involved in
Regent, as to why their hedge funds didn't want to fund
10
anymore, but they were glad to do a side deal with you
11
where they doubled the money in six months?
12
ALL PRESENT:
Objection to form.
13
14
BY MR. CIMO:
15
And what did you discuss?
16
There had actually been discussions all along
Yes.
17
our relationship once we became friendly, and that was
18
there were really two different factions involved.
19
There actually should be an email some place
20
from Mr. Preve where we are discussing the factions,
21
that I think Simony was involved in those conversations,
22
also.
23
What I came to learn, actually through
24
Mr. Simony and Mr. Nordlicht, was that we had the Brian
25
faction, with Gil, Ari, who wanted to do, for example, a

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$50-million line first and then ease into everything.
And then we had the Nordlicht, Huberfeld,
Glass -- I mean, Nordlicht, Huberfeld, Simony faction
that wanted to go to $150 million and beyond right away.
It was full steam ahead.
That is the way it pretty much was the entire
time we did business.
and I some peace of mind, even during the enhanced due
diligence, because, obviously, we were involved in a
It's actually what gave Mr. Preve
10
massive crime.
11
noses into your business, that will, to use my term, get
12
you hinked up.
13
about that, as was Mr. Rosenfeldt.
14
When people are trying to stick their
Mr. Preve and I were both concerned
What ultimately happened was when we learned
15
that other people, people in control of the hedge funds,
16
still wanted to do business with us on the side, we
17
realized that it was more just trying to pacify the
18
Jedwab, Kalter, group from the hedge fund.
19
Let me show you --
20
Still needed to pacify them, but it was --
21
there were clearly two different groups of people in
22
there: people that were very concerned and people that
23
were not.
24
25
Thank you.
Let me show you Exhibit 135.

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Page 901
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2

MR. CIMO:
It's a declaration of
Mr. Gabriel Hertzberg, court document number
144, case number 10-3802-RBR.
BY MR. CIMO:
I'm going to turn your attention to the
exhibits, in particular, exhibit B, as in "boy," and
I'll represent to you that in this declaration,
10
Mr. Hertzberg --
11
MR. NURIK:
12
to read the document?
13
14
MR. CIMO:
the record.
Could you give him a minute
Yes.
I am just saying it for
Please read it.
15
Under penalty of perjury, he states
16
Exhibit B is a true and correct copy of a due
17
diligence memoranda, prepared by Brian Jedwab
18
in 2009.
19
BY MR. CIMO:
20
And I don't want you to spend a lot of time
21
reading it; it's very detailed.
22
you saw the three-page memo before today?
23
24
25
I just wanted to see if
The three-page memo, that's -MR. NURIK:
You are talking about which
exhibit?

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MR. CIMO:
BY MR. CIMO:
Exhibit B, as in "boy."
My first question is, have you seen this
exhibit before today, before you read it?
I have.
Had you seen this exhibit before October of
2009, before you went to be incarcerated?
8
9
10
There was -- this doesn't have a date on it of
when it was prepared, but there was a due diligence

report.
11
Separate from this?
12
See, I don't know whether it was this one or
13
not.
Let me just -- let me tell you what I recall.
14
There was a due diligence report that was
15
internal, a copy of which was provided to Mr. Preve,
16
which he provided to me.
17
It looks like this.
This looks like the one;
18
but without a date on it, seeing what date it was
19
prepared, it's very difficult for me to recall at this
20
time.
21
22
But I have definitely seen this before.
recall reading it.
23
Does this --
24
I just can't tell you whether I read it during
25
the process of my cooperation or whether I -- this is

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actually the privileged internal document that Simony
snuck to Preve, which he then gave to me.
Does this memo accurately describe that there
was a visit by Mr. Jedwab to see you, from December 28
through December 31st of 2008?
Yes.
At -- during those days, did you make the
visit to those Adler law firms that we spoke about
earlier that were the three other law firms that were
10
provided as alternatives to the initial three law firms
11
that were provided?
12
13
14
I did make the visits that day to those three
law firms with those gentlemen, yes.

Q
And under the volume of cases, those meetings
15
with those lawyers, including Mr. Rossi, that you said,
16
you know, sometimes advertises on bus benches, does this
17
accurately describe the fact that there were meetings
18
with you and Mr. Jedwab with these three lawyers, just
19
the paragraph under volume of cases?
20
Yes.
21
Okay.
And the next paragraph where it talks
22
about Phillips and -- Fisher and Phillips, was that firm
23
visited, too?
24
I'm sorry, what about Fisher and Phillips?
25
Was Fisher and Phillips, mentioned in the next

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paragraph, were they also visited?
They were not visited, no.
They were not.
4
5
So which law terms were visited?

A
I took Mr. Jedwab, and I think Mr. Glass was
with us for all three, I took them to see Steve Rossi,
Mr. Herskowitz and to the Koppel and Bates firm.
8
9
10
Okay.
And why wasn't Fisher and Phillips
visited?
A
Because there's no way that I would have been
11
able to get -- or with Mr. Adler or Mr. -- even,
12
Rosenfeldt, have been able to get Charley Caulkins to
13
lie for us the way we would required.
14
15
16
17
18
As part of that visit from the 28th through
the 31st, were there any gentlemen's clubs visited?

A
It's
possible, but I have no independent recollection of it.

Q
And other than those meetings at the law firms
19
and then a reference to a paralegal, Adelita Cabello,
20
C-A-B-E-L-L-O, being met with, do you know whether there
21
was anyone else at the law firm for Rothstein,
22
Rosenfeldt & Adler that was spoken to by Mr. Glass or
23
Mr. Jedwab?
24
25
Spoken to, yes.
There were meet-and-greets.
Due-diligence-wise, I have no recollection of that.

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Now, what was your opinion of this due
diligence that's now being done in December, which you
have characterized, as -- you said, enhanced diligence?
Was that you called this, enhanced due diligence?
Okay.
My question was, this enhanced due diligence
What was the question?
I was reading.
that is happening in or about December of 2008, what
opinion or what conclusion did you reach, if any, as to
the adequacy of this enhanced due diligence?
10
ALL PRESENT:
11
12
BY MR. CIMO:
13
14
Okay.
Objection, form.
I'm sorry.
Now repeat the question.
No, gladly.
What opinion did you reach, if any, in regard
15
to the adequacy of the enhanced due diligence that it
16
was now being conducted?
17
I thought the due diligence, from my
18
standpoint, from a Ponzi standpoint, went well for us;
19
but it was not as enhanced as I was afraid it was going
20
to be.
21
So it went well for us and -Okay.
What did you specifically observe that
22
you felt led you to the conclusion that it wasn't as
23
enhanced as you thought it was going to be or detailed?
24
25
When we were at Mr. Rossi's firm,
Mr. Herskowitz's firm, and Koppel and Bates firm, there

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were things that I was concerned that Mr. Jedwab and/or
Mr. Glass might do during the course of this that could
have put both myself and my co-conspirators that were
assisting as the referring lawyers, in a very difficult
position, and none of these those things were done.
6
7
8
9
10
11
Did you ever use the term "going through the
motions"?
A
I probably did.
That's -- to ask me if I ever
used that phrase "going through the motions," yeah, I

probably did.
Q
Was there anything that you observed when the
12
lawyers were met with that just made you believe one way
13
or the other, if at all, that the due diligence was more
14
of a necessity that had to be gone through, as opposed
15
to something that was really trying to delve into the
16
true relationship between these three law firms and the
17
Rothstein Rosenfeldt & Adler firm?
18
ALL PRESENT:
19
20
BY MR. CIMO:
21
What's that?
22
Okay.
Objection, form.
Yes.
While we were there, before we went,
23
okay, you have to understand my frame of mind, when
24
we're going there, obviously I'm somewhat panic-stricken
25
because this is a major undertaking.
We've got, one,

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two, three -- three or four other lawyers at different
firms all having to basically stick to the exact same
false script while being questioned by people who, I
believed at that time, based upon my conversations with
Mr. Jedwab, Mr. Glass, Mr. Simony and Mr. Preve, were
going to ask some difficult questions during the course
of these meetings.
8
9
Fortunately for the Ponzi scheme,

unfortunately for the hedge funds, they did not go down
10
that road.
11
cases do you accept, what are the size of the cases,
12
what's the frequency, what kind of cases, what kind of
13
practice do you have and the dollar amounts that they
14
received -- how long they knew me, my reputation, that
15
type of thing.
16
They confined their questions to how many
They did not appear, to me, to be nearly as
17
attentive as I thought they were going to be; and one of
18
the big tells was, when we went to go see, for example,
19
Mr. Herskowitz -- I had never met Mr. Herskowitz before.
20
If I had, it was in passing.
21
office, I was going in and Mr. Glass and Jedwab were
22
with me, I believe, at least one of them was with me,
23
and we were walking in and Mr. Herskowitz comes up to me
24
and says, it's nice to finally meet you, at which time I
25
almost had a coronary.
When we walked in his
Because here is a guy who is

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supposed to be sending me millions of dollars worth of
cases.
Millions or tens of millions?
Tens of millions, yes, a lot of cases, and he
says, nice to finally meet you, and I was like -- and I
said, good to see you again, you know.
I tried to recover.
Now, had they been paying attention, that
could have caused a problem.
10
In the Rossi office, they started to ask him
11
questions about, you know, the type of practice, and the
12
fact that he was a criminal defense lawyer, primarily,
13
and where, these other cases, would he come up with.
14
And they never followed up on it.
15
There were a lot of things that I had expected
16
them to do that they never done -- they never did.
17
For example, asking to see -- without looking
18
at the names, can you just show us a case list of all
19
the cases.
20
They never did.
21
I expected them to say something like that.
Unfortunately for me, I only expected them say
22
it as I was driving there.
23
about them asking for some kind of documentation.
24
25
I actually started to panic
But they never did.

Q
So...
Had you already reached the conclusion that

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Mr. Glass was a player -- an in-and-out player when this
happened?
3
4
ALL PRESENT:
A
I did.
Objection to form.
I -- I more came to that conclusion
with Mr. Glass when he had his whole one-off side-deal
thing going on with Bo Rosenblat.
bringing a doctor in who's -- who has no knowledge of
what we do, knows nothing about investing, and he's
going to be the front man for this Intercoastal --
Because here he is
10
whatever the heck the name of it was, his private
11
investment company; and he was going to continue to do
12
these deals with us.
13
So, when someone is willing to go to that
14
level to deceive their partners, you have a player in
15
the works or a player in full bloom.
16
who they are.
17
18
It just depends on
Now, the next page of this exhibit talks about
follow-up and this is PCL 61985.
19
Okay.
20
It says that Mr. Jedwab visited you on
21
March 4th and 5th, 2009.
22
23
24
25
Do you know whether that, in fact, happened?

A
I remember him being there; I don't remember
the dates.
Q
You recall discussing Thigpen versus UPS with

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him?
Yes.
Was that at a 10 -- 10 -- multi-million --
4
5
6
7
8
tens-of-millions-of-dollars lawsuit?
A
I don't remember what it was.
It was several
million dollars.
Q
Did it result in a public record that resulted
in a judgment or some other verdict?
It did.
10
And -- but is that the only case that you
11
12
showed Mr. Jedwab at that time?

A
The actual case -- I gave him access --
13
according to this, I gave him access to Fortis, and he
14
looked at Thigpen, and then I showed him the fake
15
videotapes, and I showed him a letter to the Spanish
16
broadcasting company making a claim.
17
that, that would have been it, according to the letter.
18
But other than
That was the extent of what you had him review
19
during that March 4th/March 5th visit, to your
20
recollection?
21
22
23
Yeah.
He was fine with looking at that.
So I
wasn't offering if he wasn't asking.

Q
Then it says, "During my discussions with
24
Mr. Michael Szafranski" -- that's the same one as
25
Mr. Kalter's childhood friend?

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Yes, sir.
"I have asked him to look into the parties, to
the cases we are funding, to establish their ability to
pay, as well as their connection."
Did you know that that had happened?
I did.
Okay.
And what did you learn?
How did you
learn about that?
Mike told me.
10
And then there's a March 26, 2009, follow-up.
11
Michael Szafranski told me.
Did you play any role in regard to learning
12
about this follow-up where Szafranski verified cases at
13
RRA and you negotiated a purported settlement of them?
14
15
16
No.
Mike and I made that up.
That never
happened.
Q
But, again, this was something between you and
17
Michael Szafranski.
18
this information to Mr. Jedwab; it appears Michael
19
Szafranski provided it.
20
You did not pay any role in giving
I don't remember whether or not Mr. Jedwab
21
asked me about it subsequently, but it was Mike's job to
22
relay the information, initially, to Mr. Jedwab.
23
How did you compared this enhanced due
24
diligence in December 2008 to the initial due diligence
25
that was done at the start of the relationship.

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ALL PRESENT:
BY MR. CIMO:
You used the word "limited," I think, at the
ALL PRESENT:
A
limited.
it was going to be.
BY MR. CIMO:
11
Objection.
Form.
It was somewhat enhanced but also it remained
10
Form.
front end.
5
6
Objection.
It wasn't nearly what Mr. Preve and I thought
And that, therefore, enabled you to continue
with your Ponzi scheme?
12
That's correct.
13
And had the due diligence been more probative
14
and had it been -- had due diligence, for example, been
15
done on the three law firms that Mr. Adler had referred
16
you to to see the volume of their cases, do you believe
17
it could have been discovered that those firms, in fact,
18
had not provided such --
19
ALL PRESENT:
20
Speculation.
21
Objection to form.
My belief is, yes, it could have been
22
discovered, but I don't know how that would have
23
ultimately affected people at the hedge funds.
24
BY MR. CIMO:
25
Let me ask you to follow up on that:
What did

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you learn, if anything, as to what due diligence was
done by the hedge funds regarding Mr. Rossi and the
other two firms after the meeting happened in December
of 2008 -- the meetings happened?
I was never advised one way or the other.
And did you hear anything at all from the
hedge funds, other than doing these meetings with the
lawyers, any further questions of your firm about the
relationship between your firm and those Adler-related
10
law firms after those meetings in December of 2008.
11
Any follow-up?
12
13
Anything?
To my recollection, no.
MR. CIMO:
Let's take a break at this
14
time because I think we're going to streamline
15
our remaining questions.
16
(Thereupon, a recess was taken.)
17
MR. CIMO:
18
Let's go back on.
19
Exhibit 136 for identification.)
20
BY MR. CIMO:
21
22
Mr. Rothstein, take a look at 136, please.

Mr. Rothstein, I'm showing you Exhibit 136.
23
Who is the center of the "from 19546072333," if you
24
know.
25
That's me.

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email?
It is.
Why did you send this email to Mr. Jedwab in
Is that a text message, instead of an
or about March 19th of 2009?
money.
Okay.
I was trying to push him to give us some
And you talk about "inability to fund old
deals has resulted in my receiving a Bar grievance."
10
Yes.
11
What is that about?
12
That's a lie I created.
13
And is this the same -- was the enhanced due
14
diligence already over at this point?
15
Yes.
16
Okay.
If the enhanced due diligence was over,
17
do you know why you were having difficulty getting the
18
hedge funds to provide more money?
19
I don't know why, no.
20
Did the hedge funds ever follow up with you in
21
regard to requesting documents after they had completed
22
their enhanced due diligence in December of 2008?
23
24
25
I have no recollection.
If they did, it was of no significance.
It
doesn't stick out in my mind.

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Do you recall Mr. Jedwab taking any notes or
Mr. Glass taking any notes while they met with the three
attorneys in December 2008, with you?
Do you know whether there was a request to see
any traffic reports regarding hits?
I -- I have no recollection of that.
Do you know if the hedge funds ever asked you
9
10
to see the amount of referral fees in the Rothstein

firm's records paid to those law firms?
11
They never asked me that, no.
12
Were you asked for any financial data
13
regarding the tens of millions of dollars in cases that
14
were supposedly being given to you by these three law
15
firms?
16
No, sir.
17
And the Bar grievance that you made up, what
18
was the story that you made up regarding the Bar
19
grievance?
20
It was an ongoing story that we were using to
21
explain why payments were not being made and also to try
22
to get people to fund deals that were involved.
23
We tried to make the hedge funds feel as if
24
they had created a Bar problem for us so that they would
25
pay us.

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Page 916
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2
Do you know whether the hedge funds were
current with the Banyon entities at this time period?
ALL PRESENT:
don't know.
I don't know.
Objection to form.
I don't think they were, but I
MR. CIMO:
Exhibit 137.
Trustee's Exhibit 137 for Identification.)
BY MR. CIMO:
10
11
I don't recall seeing this, no.
12
Do you recall a meeting in or about April 8th
13
to meet with George to discuss impact of nonfunding on
14
the operations of RRA?
15
I don't recall this.
16
Do you recall any meetings about alternatives
17
No.
to dealing with Scott and Centurion?
18
I -- I don't recall it.
19
And then, finally, do you recall any meetings
20
21
No.
to discuss Brian Jedwab or Regent?

A
I don't.
22
MR. CIMO:
23
24
Show you now Exhibit 138.
25

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BY MR. CIMO:
Mr. Preve makes mention to doing the exact
same default letter to Platinum.
Do you know what default letter is being
referred to in April of 2000 -- April 8th of 2009?
Yes, I do.
And what letter is that?
We were attempting to get the hedge funds to
continue to fund us money.
We were also looking for a
10
methodology to avoid paying them everything that we owed
11
them in the amounts and the timing that needed to be --
12
that were required to be paid.
13
idea of saying that they were in default for not
14
funding.
15
16
17
18
So we came up with the
They were in default, but they didn't have a
direct relationship with RRA.

A
I understand that, but I was dealing with
them, anyway, through Mr. Preve.
19
Understood.
20
But we did not have a direct relationship.
21
The only relationship I had with the hedge
22
fund was to try to convince them that these were real,
23
and they were not.
24
25
I understand.
So it was really the Banyon entities that were

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going to claim that the hedge funds were in default?
Correct.
Then the next sentence says, quote, They are
really the same company and we must treat them as such.
Do you know what he's referring to?
6
7
That's just me outlining what I consider to be
a pressure point to try to squeeze the hedge funds.
And what is the pressure point?
That they're supposed to be separate entities,
10
but to my knowledge, they were really not; they all
11
interacted.
12
13
14
How did that work to your advantage as part of
the Ponzi scheme?

A
I wanted to try to put them in a position
15
where they would believe that they had something to lose
16
in the course of cutting us off.
17
You have to remember something, that
18
throughout this entire thing, you're still dealing with
19
a hedge fund that is investing in a Ponzi scheme; and to
20
my knowledge, the entity itself doesn't know it's a
21
Ponzi scheme.
22
23
24
25
Okay?
So I've got to put pressure on them to try to

get them to, for whatever reason, go ahead and fund.
You have to always separate out the difference
between the entities and what they knew as a whole and

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Page 919
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what they were intending on doing or not doing or how
they would have proceeded or not proceeded based upon
their knowledge; and the acts of people associated with
but doing things on the side.
Understood.
Two completely different things.
And then the reference to "Murray legally
cannot be involved in both," do you know what Mr. Preve
is referring to there?
10
No, no.
11
Okay.
12
13
I'm writing that.
I'm sorry.
You're reference to Murray being legally

involved.
I apologize.
14
15
That's me.
What's that in reference to?

A
Okay.
To my knowledge, Murray Huberfeld had
16
had significant SCC problems and criminal problems.
17
This is based on conversations with Mr. Nordlicht, Mr.
18
Preve, and Mr. Simony.
19
I was looking for a methodology to pressure --
20
remember:
21
time for the Ponzi scheme.
22
methodology to squeeze the hedge fund entities into
23
investing.
24
25
We're very short on money at this point in

I am looking for a
When you are attempting to do that in a

criminal enterprise, you do it by finding a pressure

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point that you believe will put the players who are
pushing back, like Mr. Jedwab and them -- what I hoped
was, Mr. Huberfeld would find out we were doing this,
Mr. Nordlicht, and would tell the others, okay,
controlling the entity, that we should do this for these
reasons.
7
8
Okay.
You're trying to act on the internal
conflicts that are going on.
Okay?
The legitimate players and the -- what I'll
10
just call the not-so-legitimate players, you're looking
11
for a business pressure point.
12
just have to separate out who is who in the scheme of
13
things.
14
relative to trying to understand why I came up with the
15
Bar grievance thing.
16
That's all it is.
You
That's probably the most important thing
Okay.
The Bar grievance thing wasn't for
17
illegitimate players.
18
the legitimate players, the people that, had they known
19
it was a Ponzi scheme, would have stopped.
20
need to apply pressure to people who are criminals.
21
Those are people easy to apply pressure to.
The Bar grievance thing was for
You don't
22
It's the legitimate side of the hedge funds,
23
the people that were controlling the money flow to me,
24
to us, that were problematic.
25
MR. CIMO:
Exhibit Number 139 through

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146, as a composite.
(Thereupon, the documents were marked as
Trustee's Exhibit 139-146 for Identification.)
BY MR. CIMO:
Okay.
I want you to look at the email that
you wrote where you say, "Scott a/k/a Killem hood."
You see that?
Who is triple ggg?
UNKNOWN SPEAKER:
10
on in these, please?
11
MR. CIMO:
12
Dated April 8th, 2009.
Triple ggg is Frank Preve; that's Guido,
13
Guido, Guido.
14
BY MR. CIMO:
15
16
Can you put some dates
Let me just get the copy.

And what I wanted to ask you specifically
17
about this email is the reference to Murray -- Mayer
18
knowing about the secret deal with Murray, what secret
19
deal is that?
20
That's the Regent deal.
21
Thank you.
22
Look at Exhibit 140.
23
Why did you send this email to Mr. Preve?
24
25
Hang on a second.
This is Preve to me, actually.

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2
3
I'm sorry.
Why did Preve send this to you?
First of all, do you recall receiving this?

A
Yes.
Just give me one second, please.
Okay.
This is a perfect example of the
dichotomy between the entities and the players.
And how is that?
Because, to my belief, in all the business
dealings I'm dealing with Centurion, Platinum, and Level
10
3, they appear to me to be legitimate and sophisticated
11
hedge funds.
12
any criminal enterprise.
13
They don't appear to me to be involved in
Certain people that worked there, to me, had
14
the propensity to do things opposite of -- Ari, for
15
example, he's writing here where he says to me:
16
a by-the-book kind of guy.
17
kind of explosive thing before.
18
Ari is
He hasn't been through this
And you got to remember, the hedge funds all
19
together, they don't act by one man.
20
know, a group decision, at least that's certainly the
21
way it appeared to me.
22
ultimately calling the shots, I suspect he had all these
23
people, based upon what I had been told, as advisers.
24
25
They act by, you
Even though Huberfeld was
So, you have to differentiate between the fact

that I consider Jack Simony to be a player and Mark

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Nordlicht to be a player, from the entity itself.
not the same thing, and that is what's being set forth.
It's
In this, Frank is trying to explain to me,
with a copy to George, that, look, you're getting upset
with these guys, but you have to remember that the hedge
fund is a legitimate business, and just because we have
good -- what's called a subterranean relationship with
some of the guys, doesn't mean the hedge fund is going
to intentionally do anything wrong.
10
Look at exhibit --
11
That's what he's trying to tell me.
12
Thank you.
13
14
Look at Exhibit 141, an email dated -- emails

dated April 16th and 17th, 2009.
15
16
I want you to look at the one from Mr. Levin

to Ari Glass.
17
Did you know about this email before seeing it
18
today?
19
20
21
22
I remember seeing it.
saw it before he sent it.

Q
And then it talks about a meeting in or about
April 16th in the evening.
23
24
25
I don't remember if I
Did you attend this particular meeting?
Did
it happen?
A

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2
3
There's discussion in here about funding of
new cases; did that happen?

A
I don't believe it -- this looks like just one
of George's doing the same thing that I was trying to
do, trying to pressure the entity into funding.
6
7
Exhibit 142, email from Mr. Levin to Preve.
Yes.
Have you ever heard of Mr. -- well, do you
10
know who is referred to as the crazy man?
11
Yes.
12
Ari Glass?
13
Yes.
14
And were there discussions between Mr. Levin
It's Ari.
15
and Mr. Preve and yourself about Mr. Glass being the
16
crazy man?
17
Yes.
18
Why?
19
Because Ari, when he was dealing with the
20
business for the hedge funds, not for the Rosenblatt
21
thing, but for the -- in the Level 3, Centurion,
22
Platinum deals, he was a more by-the-book kind of guy
23
and very explosive emotionally when things did not go by
24
the book.
25
Look at Exhibit 143.

(954) 525- 2221
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Page 925
1
2
Mr. Preve emails Mr. Glass about Florida Bar

questions.
3
4
5
6
7
Do you know about this email -- when it was

sent in or about April 22nd, 2009?
A
recollection of seeing this.

Q
8
9
12
13
14
Preve to you dated 4/27/2009, subject:
recall what was done in regard to it?

A
19
I recall the email.
I don't recall anything
actually being done.

Q
Go to Exhibit 145.
This email from Preve to Mr. Nordlicht talks
about restructuring a debt.
17
18
Suggestion.
Do you recall this email, and if so, do you
15
16
Go to Exhibit 144.
I would like you to look at the email from
10
11
I don't actually have any independent
Do you recall this going on in or about April

28th of 2009?
A
I remember there being conversations between
20
myself and Mr. Preve and Mr. Levin, that they were
21
trying to work out their business relationship with the
22
hedge funds.
23
24
25
What was actually done, I don't know one way

or the other.
Q
It talks about $15 million.

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Do you recall $15 million ever being discussed
with you as an amount that the funds wanted -- the hedge
funds wanted?
4
5
6
I do.
I actually think I received an email
from Mr. Nordlicht in that regard or Mr. Simony or both.

Q
Take a look at Exhibit No. 146.
Is this the email you're referring to?
It's an email to you to Mr. Nordlicht talking
9
10
about 15 million.
A
Well, this is the one that I sent to them, but
11
I believe there's other emails where they were
12
discussing it with me or maybe they sent it to Mr. Preve
13
and I got copied on it.
14
15
Okay.
Well, this email -- this is an email
you wrote in or about May 6th of 2009?
16
It is.
17
And it talks about the total wire to you
18
against the 15 million owed under the agreement with
19
Banyon to 8.5 million.
20
That's correct.
21
That's how much had actually been wired to
22
that point?
23
I assume that's correct.
24
And then it talks about the -- I expect to
25
I don't know.
wire the remainder in the next few days.

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Do you know whether that occurred?
You then say, "Given these and all other
pendent circumstances, Banyon and my firm expect that
you will not issue a default against Banyon."
6
7
Was a default ultimately issued?

A
I later came to learn that an internal default
had been declared as early as April, but as far as
saying we were in default, there were certain people
10
there who constantly say on the phone -- for example,
11
Ari Glass, Brian Jedwab would say, you -- Banyon's in
12
default.
13
14
You guys are in default.
We are going to sue.
I mean, I heard they were going to sue a 100

times from Ari glass.
15
But as far as actually declaring us in
16
default, no.
17
Exhibit --
18
Not to my knowledge.
19
Thank you.
20
21
22
BY MR. CIMO:
23
24
25
Exhibit Number 147, an email from you dated
April 29th to Jack Simony.

And you say, quote, I have borrowed the

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Page 928
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15 million do play Platinum this week, end quote.
Yes.
Did you send this email to Mr. Simony?
I did.
And why are you telling Mr. Simony that you
6
7
had borrowed 15 million to pay his hedge fund?

A
Because I didn't want him to think I was
taking the money from any of the internal accounts
because I had them under the belief that all the money
10
was locked up by the Florida Bar.
11
12
money from?
13
No, sir.
14
Did he inquire about what you had to provide
15
Did Mr. Simony ask you who you borrowed the
in terms of collateral to borrow such money?
16
No, sir.
17
Did you have any discussion at all about where
18
you would come to possess $15 million to give to
19
Platinum?
20
No, sir.
21
Did you have any impression as to whether he
22
cared or not where you got the money from?
23
UNKNOWN SPEAKER:
24
THE WITNESS:
Objection.
Jack himself?
25

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BY MR. CIMO:
Yes.
I think he was concerned.
4
5
You know what?
I'm really guessing as to what
he thinks.
No.
Yeah.
I am asking you, did you form an opinion or a
9
10
Don't guess.
I don't know what he thought.
belief in or about April 29th of 2009, as to whether you

thought he cared where you got the 15 million from?
11
ALL PRESENT:
Objection.
12
THE WITNESS:
In his role as a member of
13
Form.
the hedge fund or as Jack himself?
14
BY MR. CIMO:
15
You can split that answer into the two phases?
16
I think that the hedge fund itself would have
17
been concerned about where the money came from.
18
that Jack just wanted to make sure the hedge fund got
19
money.
20
21
But RRA didn't owe Platinum the money.
The
Banyon entities owed the money, correct?
22
23
I think
UNKNOWN SPEAKER:
Object.
Is there a
question?
24
BY MR. CIMO:
25
Let me rephrase.

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Who owed the $15 million to Platinum?
ALL PRESENT:
Objection.
BY MR. CIMO:
If you know.
Technically, Banyon.
Yes.
Form.
But why is it your problem to borrow
15 million to pay Banyon entities' obligation?
Because I'm controlling the funds.
10
When you say "the funds," what funds are you
11
talking about?
12
The funds that aren't really there.
13
The funds that are part of the Ponzi scheme?
14
Yes.
15
Okay.
16
Mr. Simony cared where the 15 million came from?
17
18
And as a person, do you think that
UNKNOWN SPEAKER:
Objection.
It's been
asked twice.
19
BY MR. CIMO:
20
As an individual?
21
As an individual.
22
Who you defined as a player.
23
ALL PRESENT:
Objection to form.
24
THE WITNESS:
I don't -- can I answer?
25

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BY MR. CIMO:
Yes.
Jack --
MR. SCHERER:
Overruled.
THE WITNESS:
Thank you.
cared.
8
9
I don't think he
I believe the hedge fund itself would have

cared, but not Jack particularly.
10
11
Jack, individually, no.
MR. CIMO:
Let me show you now Exhibit
Number 147 (sic).
12
13
14
BY MR. CIMO:
15
16
This is an email dated April 28th, 2009, from
you to Scott Preve and it's called Platinum --
17
Frank Preve.
18
From Frank Preve to Scott Rothstein regarding
19
Platinum.
20
21
And then underneath it, it has Mr. Nordlicht

to Preve.
22
23
No subject.
Did you see the one from Mr. Nordlicht to
Preve before today?
24
I have.
25
Did you know that 15 million was expected by

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Page 932
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April 29th?
I did.
And was that amount paid?
It was not.
5
6
MR. CIMO:
I apologize.
This was 148,
for the record.
Let me show you now Exhibit 149.
10
BY MR. CIMO:
11
12
13
It's an agreement dated April 30th, 2009.

Just going to ask you if you recall seeing
this before today?
14
I do.
15
In what context did you see this email?
16
This document.
I'm sorry.
17
I'm sorry?
18
In what context did you see this document?
19
Frank and George had sent it over to me for my
20
input.
21
I note that you're not --
22
It actually has my handwriting on it.
23
Oh.
24
25
That's your handwriting on it.
But you did not sign this document nor were

you requested to sign it, correct?

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2
3
No, sir.
MR. CIMO:
Just give me one moment,
please.
THE WITNESS:
MR. CIMO:
BY MR. CIMO:
Sure.
To wrap up.
From and after this time period, May 2009,
were there any other deals that you know, personal
knowledge, sitting here today, that were funded by the
10
11
12
13
three hedge funds?

A
I don't have any independent recollection of
any, no.
Q
Do you have any recollection whether the hedge
14
funds continued to receive payments either directly
15
through RRA or any of the Banyon entities, despite the
16
fact that there were no further settlements being
17
funded?
18
19
ALL PRESENT:
A
Objection to form.
My recollection is that we continued to pay
20
them money on a weekly basis, sometimes a couple times a
21
week, to try to pay down the debt.
22
BY MR. CIMO:
23
Yes.
And at any point before October of 2009, did
24
any of those payments stop, to your knowledge, to the
25
hedge funds?

(954) 525- 2221
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Page 934
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I don't know what you mean did they stop?
Meaning that you said weekly.
3
4
Was there any week that was missed?

A
There may have been.
I mean, when we had
funds available to send to them, and when they were --
you know, pushing us to send money, we did our best to
send it.
8
9
And before October of 2009 when the Ponzi
scheme was uncovered, was it your testimony that those
10
payments continued as best they could up until the point
11
that the Ponzi scheme was disclosed?
12
Yes, they did.
13
And that those payments that occurred during
14
that time period were in the multi millions of dollars?
15
ALL PRESENT:
16
17
BY MR. CIMO:
18
19
Yes.
Yes.
They weren't a few hundred thousand, they, in
the aggregate, total millions and millions of dollars.
20
ALL PRESENT:
21
22
BY MR. CIMO:
23
24
25
Objection to form.
Form.
Yes.
They were not insubstantial.

ALL PRESENT:
Objection.
Objection to form.
They were --

(954) 525- 2221
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Page 935
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BY MR. CIMO:
3
4
5
ALL PRESENT:
A
Objection.
Depending on who's looking at is substantial
or insubstantial.
6
7
They were substantial payments?
They were millions of dollars of payments.

Q
And whose money was used in order to make
those payments to the hedge funds between May of 2009
and October 2009?
10
It was likely a combination of Mr. Von
11
Allmen's money; Mr. Sochet's money; Mely Lifshitz's
12
money; Clockwork money; Discala money.
13
14
15
The combination of those people.

Q
These are all other investors in the Ponzi
scheme that came about from and after May of 2009?
16
Yes.
17
And were there any monies used from legitimate
18
RRA operations to pay for the hedge funds?
19
20
ALL PRESENT:
A
Objection to form.
Throughout the Ponzi scheme, to whatever
21
limited extent there were legitimate funds coming into
22
the law firm, those funds were thrown into the same
23
account.
24
25
So it is possible that some legitimate funds

ended up in someone's hands.
But you need to

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understand, if you look at our books and records, I
mean, I think we only did 8- or $9 million in that year,
total revenues.
So it's just by straight math, it's an
accounting impossibility for very much of it to have
gone to pay these other tens of millions of dollars in
moneys being paid out.
The lawsuit that I filed alleges that the
transfers that were made by your law firm to the hedge
10
funds were made with actual intent to hinder, delay or
11
defraud creditors.
12
13
Did you have any familiarity with the Florida

statute on fraudulent transfers while you were a lawyer?
14
I did.
15
Okay.
Were the transfers made to the hedge
16
funds, at any time in your -- in your belief, part of a
17
Ponzi scheme intended to hinder creditors?
18
ALL PRESENT:
Objection to form.
19
THE WITNESS:
To hinder creditors?
20
BY MR. CIMO:
21
Yes.
22
No.
The money was paid to pay creditors.
23
No.
I'm talking about when you're making --
Hinder them.
24
when you're taking other people's money as part of the
25
Ponzi scheme and then you're transferring it to the

(954) 525- 2221
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Page 937
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hedge funds, would you say that those payments were made
as part of your Ponzi scheme to hinder creditors?
ALL PRESENT:
4
5
Let me break it down for you and then you can

ask me a follow up.
8
9
You're asking -- that question seems to be, to
me, to be so many questions boiled into one.
6
7
Objection to form.
Let me see it can I respond.

BY MR. CIMO:
10
Go ahead.
11
In the Ponzi scheme with the hedge funds,
12
Level 3, Centurion, Platinum, we were making payments to
13
those hedge funds for fear that the legitimate portion
14
of those hedge funds, the victim portion of the hedge
15
funds, okay, would not go to the authorities in any
16
form.
17
18
19
Okay?
It wasn't that we were sitting here going,
let's hinder our creditors.

We were paying Ponzi first, because at the end
20
of the day, you got all these legitimate investors in
21
the hedge funds who are victims.
22
Those people, not getting money, any one of
23
them could have picked up the phone, including the
24
straight guys -- I'll call them the straight guys at the
25
hedge funds, guys like Jedwab and Kalter and Glass from

(954) 525- 2221
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time to time -- could have picked up the phone and
called the SCC, the FBI, any law enforcement agency or
filed a lawsuit against us.
So I think in answering your question, we're
sending the money to them with disregard to our
creditors.
Yes.
Does that help you?
Well, it does because I'm going to talk about
10
Mr. Von Allmen, for example, represented by Mr. Scherer.
11
You said part of his money was used to pay the
12
hedge funds, correct?
13
14
coming from.
15
I believe it was.
Sure.
That's where it was
So would you say that Mr. Von Allmen was being
16
hindered by virtue of you taking his money to pay the
17
hedge funds so the Ponzi scheme would not be revealed?
18
ALL PRESENT:
19
20
BY MR. CIMO:
21
Objection.
Form.
Yes.
Would you also say Mr. Sochet was being
22
hindered by taking his money and giving it to the hedge
23
funds under your Ponzi scheme?
24
Yes.
25
Would you say that any of the people that

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Page 939
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invested after May of 2009 were being hindered as a
result of you taking their money and paying it to the
hedge funds?
I absolutely would.
That's the question.
6
7
There's a concept called delaying.

delay or defraud.
8
9
Hinder,
Do you believe that the payments that you were

making to the hedge funds acted to delay Mr. Sochet and
10
Mr. Van Allmen and these other people invested after May
11
of 2009 from getting paid back their money?
12
13
Yes.
ALL PRESENT:
14
BY MR. CIMO:
15
Objection to form.
Do you believe that that intention to delay
16
was something that you did in order to allow the Ponzi
17
scheme to continue?
18
ALL PRESENT:
19
20
BY MR. CIMO:
21
Objection to form.
Yes.
Do you believe that had you not made these
22
payments to the hedge funds to delay Mr. Von Allmen and
23
all these other people invested after 2009, that the
24
Ponzi scheme would have been discovered, because the
25
hedge funds would have demanded payment and declared

(954) 525- 2221
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Page 940
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default?
ALL PRESENT:
BY MR. CIMO:
Object to form.
I do.
Now, let's talk about defraud.

Do you believe the payments that you made to
the hedge funds at any time were intended to defraud
creditors that were not getting repaid at the same time?
ALL PRESENT:
Objection to form.
10
THE WITNESS:
Were they intended to
11
defraud?
12
I think it's the way you're asking me.
13
BY MR. CIMO:
14
15
I'll rephrase it for you.

The payments that are made to anyone under a
16
Ponzi scheme, where the person whose money you're taking
17
to pay the later investor, would you agree that those
18
payments are paid to defraud those creditors that are
19
not being repaid?
20
ALL PRESENT:
Objection.
21
BY MR. CIMO:
22
Isn't that what a Ponzi scheme is?
23
Hang on a second.
24
25
MR. CIMO:
Just keep making your
objections, Counselor.

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THE WITNESS:
All right.
Now, go ahead.
Just go --
UNKNOWN SPEAKER:
Let the record at least
reflect that while the question was pending,
the witness was talking to his counsel.
BY MR. CIMO:
I'm going to rephrase the question for you.
Would you -- would you have an opinion sitting
here today that payments made to the hedge funds, at any
10
time while your Ponzi scheme was being engaged in, while
11
other investors are not being paid and their money is
12
being used to pay the hedge funds, do you have an
13
opinion whether those payments were being made with an
14
intention to defraud those creditors that were not being
15
paid?
16
17
ALL PRESENT:
A
Yes.
Objection.
That is what we were doing by the nature
18
of the Ponzi scheme.
19
BY MR. CIMO:
20
And you actually pled guilty to running a
21
conspiracy that engaged in activities that acted as a
22
Ponzi scheme?
23
That's correct.
24
Now, the most extreme thing about this thing
25
we spoke about is, you had an intention to defraud

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2
people, didn't you?

A
That's a better question.

Yes.
But that's a --
Yes, I did.
But a little bit less than defrauding is
hindering; wouldn't you agree?
MR. SCHERER:
Objection to form.
THE WITNESS:
To me?
10
BY MR. CIMO:
11
Yes.
12
I was -- me, my law firm, and my
13
co-conspirators were defrauding a ton of people that we
14
legitimately owed money to in order to pay off, in this
15
case, the hedge funds, to stop them from reporting us to
16
the authorities --
17
And as part --
18
-- and declaring a default.
19
As part of the Ponzi scheme the law firm
20
actually signed guarantees or promissory notes to
21
people, didn't it?
22
Through me, yes.
23
Yes.
24
25
And, therefore, the firm became obligated to

the Ponzi victims as part of the scheme?

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ALL PRESENT:
BY MR. CIMO:
In other words, there are promissory notes
signed to certain investors, correct?
Yeah.
Mr. Sochet got several promissory notes,
To a lot of them.
Sure.
didn't he?
He did.
And when the firm then became obligated, those
10
people became creditors of the law firm under the
11
promissory notes?
12
I viewed them, promissory notes or not, me and
13
my co-conspirators, we always viewed the legitimate
14
people we were taking money from as legitimate
15
creditors.
16
As legitimate creditors?
17
We viewed the hedge funds as legitimate
18
19
creditors.
Q
In regard to a liquidation of the Rothstein
20
firm, would their be sufficient money to pay all of
21
those quote, unquote, creditors in full?
22
23
If there were, I wouldn't be here.

No, there was not.
24
So throughout --
25
That's the very -- that's the very nature of a

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Page 944
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Ponzi scheme.
our creditors.
There was not sufficient money to pay all
So throughout the time that the Ponzi scheme
was being engaged in, it's your testimony that the
legitimate business operations of the Rothstein firm and
the assets were not sufficient to pay all creditors in
full, however you characterize them?
8
9
10
11
That's absolutely true.

MR. CIMO:
I have no further questions.
(Thereupon, a recess was taken.)

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C E R T I F I C A T E
2
3
THE STATE OF FLORIDA, )

COUNTY OF BROWARD.
)
4
5
I, Michele L. Savoy, Shorthand Reporter do
hereby certify that I was authorized to and did
report the foregoing proceedings and that the
transcript is a true record.
Dated this 15th day of December, 2011.
10
11
______________________________
12
Michele L. Savoy, RPR

Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
13
14
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25

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Page 946
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2
C E R T I F I C A T E
THE STATE OF FLORIDA, )
COUNTY OF BROWARD.
)
3
4
I, Michele L. Savoy, Shorthand Reporter,
do hereby certify that I was authorized to and did
report said deposition in stenotype; and that the
foregoing pages, numbered from 770 to 946,
inclusive, are a true and correct transcription of
my shorthand notes of said deposition.
10
I further certify that I am not an
11
attorney or counsel of any of the parties, nor am I
12
a relative or employee of any attorney or counsel or
13
party connected with the action, nor am I
14
financially interested in the action.
15
The foregoing certification of this
16
transcript does not apply to any reproduction of the
17
same by any means unless under the direct control
18
and/or direction of the certifying reporter.
19
Dated this 15th day of December, 2011.
20
21
22
23
___________________________________
Michele L. Savoy, RPR
Notary Public - State of Florida
My Commission No. EE 113173
Expires August 6, 2015
24
25

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873:6,21 874:5,16
145 775:21 925:14
876:6,12,22 877:4
146 775:21 921:1
877:7 878:22
926:6
879:11 880:21
147 775:22 927:21
881:17 883:25
927:23 931:11
893:17 895:3
148 775:22 931:13
896:2 897:9 903:5
932:5
905:7 911:24
149 775:23 932:7,9
913:4,10 914:22
14th 800:8 873:6
915:3
15 770:16 854:24
925:25 926:1,9,18 2009 775:17,18,18
775:19,21 804:13
928:1,6,18 929:10
816:14 840:22
930:1,8,16 931:25
844:22 848:23
150 900:4
849:6,18 857:25
152 859:17 861:9
858:6,8 863:14,16
15th 774:2 945:9
886:7 901:18
946:19
902:7 909:21
16th 923:14,22
911:10 914:5
17 774:7 775:19
917:5 921:11
17th 770:1 771:1
923:14 925:4,9,18
923:14
926:15 929:9
19 771:4
931:15 932:11
19546072333
933:7,23 934:8
913:23
935:8,9,15 939:1
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939:11,23
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201 774:7
2
2010 774:10
2 805:6
2011 770:16 827:12
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945:9 946:19
830:14,14
2015 945:13 946:23
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204 773:24
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22 869:24 896:2
2007 780:14 783:4 22nd 883:25
806:18
893:17 925:4
2008 775:15 778:13 23rd 878:22
779:13 780:15
24 824:21 852:14
783:4,21 784:2,12 25 775:15 897:8
784:19 794:17
2525 772:19
796:5,5,8 798:11 25th 773:12
26 778:12 911:10
2616 852:17
26th 784:2
27 861:22 925:9
28 903:4
28th 904:14 925:18
931:15
29th 927:24 929:9
932:1
2nd 772:10 869:23
3
3 777:7 779:14,19
779:24,25 780:4
781:15 782:2,7
784:7,10,13
786:14 788:15
795:12 797:21
799:25 815:4
820:25 826:14,14
838:3 852:14
922:10 924:21
937:12
30 800:7 854:24
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33128 770:19
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774:7
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331463127 773:24
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773:16 774:3
333012073 773:8
333012296 774:15
33302 772:16
33316 770:24
336025145 774:11
350 772:6 861:4
868:12
36 823:18
3700 773:3
39th 773:20
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784:12,19 862:1
4
4 770:12 775:17
854:24,24 925:9
401 773:15
403 775:20
42 770:16
4400 772:11
4th 909:21 910:19
5
5 823:24 824:6,12
926:19
50million 900:1
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5252221 770:24
56665 873:6
56666 775:14
56811 878:21
56815 775:15
56851 878:21
57 852:14
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909:21 910:19
6
6 775:21 824:6,12
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945:13 946:23
61985 909:18
633 772:15
66 873:7
6th 926:15
7
7 826:12,15,21
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777 775:8,9,10
793 775:11
8
8 770:16 775:18
777:2 826:12
926:19 936:2
805 775:14
827 775:12
852 775:12

(954) 525- 2221
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8th 916:12 917:5
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901 775:16
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775:19,20,20,21
775:21
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940 862:2
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957 862:2
99 770:18

2011-12-15 Rothstein Scott AM

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IN THE CIRCUIT COURT OF THE 17TH

JUDICIAL CIRCUIT IN AND FOR

DAY 4 - MORNING SESSION

December 15, 2011

Examination of the witness taken before:

United Reporting, Inc.

IN THE CIRCUIT COURT OF THE 17TH

Case No. 10-24110 CACE (19)

EDWARD J. MORSE and CAROL A. MORSE,

SCOTT W. ROTHSTEIN, et al.,

Case No. 11-CV-61688-JIC/LSS

SCOTT W. ROTHSTEIN, TD BANK, N.A. and GIBRALTAR

United Reporting, Inc.

APPEARANCE FOR SCOTT ROTHSTEIN:

United Reporting, Inc.

APPEARANCE FOR PLATINUM PARTNERS VALUE ARBITRAGE

GOLDSTEIN, TANEN & TRENCH, P.A.

APPEARANCE FOR LEVINSON'S JEWELERS:

APPEARANCE FOR RLI ZURICH INSURANCE COMPANY,

United Reporting, Inc.

APPEARANCES FOR MORSE:

APPEARANCE FOR ROSEANNE CARETSKY:

United Reporting, Inc.

CONTINUED DEPOSITION OF SCOTT W. ROTHSTEIN

TRUSTEE'S EXHIBITS INDEX

United Reporting, Inc.

acknowledged having been duly sworn to tell the truth

and testified upon his oath as follows:

Good morning, Mr. Rothstein, how are you?

Good morning to you.

Mr. Lichtman, earlier, in the sessions that we have been

Stettin, and I'll be talking to you about the hedge

funds that you have previously spoken about but we are

going to cover some different areas.

As you know, I represent the Trustee Herb

First of all, do you know we have a lawsuit

pending against the hedge funds on behalf of the

down a little bit?

Excuse me, can you slow

-- to recover certain transfers as fraudulent

Do I know that, yes.

How did you come to learn about that?

United Reporting, Inc.

Somewhere, someone along the line, in the

8 million sheets of paper that I looked at, told me that

was filed; and I may have actually seen the lawsuit.

don't recall, specifically.

Do you recall the entities that were involved,

the actual names of the entities that were involved

regarding Centurion, Platinum, Level 3?

their specific names?

I'm going to show you Exhibits 123, 124, and

125 to refresh your memory.

(Thereupon, documents was marked as Trustee's

Exhibits No. 123, 124 and 125, respectively for

I'll represent to you that Exhibit 123 is the

Centurion Structured Growth, LLC, credit agreement with

Banyon Funding, LLC; have you seen this agreement before

Did you know that there was an agreement

between Centurion Structured Growth, LLC, and an entity

known as Banyon Funding?

An agreement, yes; a credit agreement, I can't

tell you whether I knew one way or another.