allen stanford criminal trial transcript volume 13 feb. 8, 2012

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

Johnny C. Sanchez, RMR, CRR - [email protected]

3773

UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF TEXAS

HOUSTON DIVISION

UNITED STATES OF AMERICA * 09-CR-342* Houston, Texas

VS. ** February 8, 2012

ROBERT ALLEN STANFORD * 10:09 a.m.

JURY TRIAL

VOLUME 13

BEFORE THE HONORABLE DAVID HITTNERUNITED STATES DISTRICT JUDGE

APPEARANCES: APPEARANCES:

FOR THE GOVERNMENT:Gregg J. CostaAssistant US AttorneyPO Box 61129Houston, Texas 77208-1129

William StellmachAndrew Howard WarrenU.S. Department of Justice1400 New York Avenue NWWashington, DC 20005

FOR THE DEFENDANT:Ali R. FazelRobert ScardinoScardino & Fazel1004 Congress Street3rd FloorHouston, Texas 77002

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25


3774

A P P E A R A N C E S: (Continued)

FOR THE DEFENDANT: (Continued)John M. ParrasAttorney at Law1018 PrestonFloor 2Houston, Texas 77002

Kenneth W. McGuireMcGuire Law FirmPO Box 79535Houston, Texas 77279

Court Reporter:Johnny C. Sanchez, RPR, RMR, CRR515 Rusk, #8016Houston, Texas 77002713.250.5581

Proceedings recorded by mechanical stenography. Transcriptproduced by computer-assisted transcription.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

3775

I N D E X

WITNESS PAGE

JAMES DAVIS

REDIRECT EXAMINATION BY MR. STELLMACH.......... 3784

RECROSS EXAMINATION BY MR. SCARDINO............ 3804






KALFORD YOUNG

DIRECT EXAMINATION BY MR. COSTA................ 3826

CROSS-EXAMINATION BY MR. FAZEL................. 3949

REDIRECT EXAMINATION BY MR. COSTA.............. 4018

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

3776

RECROSS EXAMINATION BY MR. FAZEL............... 4027





PAUL ASHE

DIRECT EXAMINATION BY MR. WARREN............... 4053

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:09:06

10:09:26

10:09:43

10:09:59

10:10:16


3777

(The following was held out of the presence of the jury)

THE COURT: Thank you. Be seated.

Would you tell the jury that we're in

here. We'll be with them in about five minutes.

All right. Mr. Scardino.

MR. SCARDINO: Yes, Your Honor. Yesterday,

when Mr. Stellmach got Mr. Davis on redirect, he put an

exhibit up on the screen, and the exhibit was marked

Government's 211. And he asked -- and it was viewed by the

jury. And he asked the witness, Davis, questions about the

exhibit.

And we are a little slow on the uptake,

but we finally realized that Government's 211 is not an

exhibit that was designated as part of the Government's

exhibits that we had an opportunity to review prior to

trial as ordered by the Court and articulate our objections

prior to trial. Therefore, the government put an exhibit

that was not in evidence before the jury and questions the

witness, Davis, about the exhibit.

And what they were trying to do is explain

where the $6 million went that I had questioned him about

that he had authorized to be transferred from the Swiss Soc

Gen 731 to his account, the Bank of Antigua account, 732.

THE COURT: By the way, one question. Let me

interrupt. Is it warm in here?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:10:24

10:10:32

10:10:47

10:11:07

10:11:21


3778

MR. SCARDINO: Yes.

MR. STELLMACH: A little bit.

THE COURT: Would you tell them to lower it

down, please. It has to go through -- might as well get it

done early.

Go on.

MR. SCARDINO: I don't blame the government

from trying to explain where the money went, but what I --

my objection is, is they put an exhibit up that they knew

was not in evidence, and he questioned the witness about

it. So, first, I would ask for a mistrial.

THE COURT: How many mistrials do you want?

MR. SCARDINO: Only one.

THE COURT: Denied.

MR. SCARDINO: Secondly, then, I would ask the

Court to instruct the jury to disregard Government's

Exhibit 211, anything they saw on the exhibit, and to

disregard any questions or answers, questions by the

prosecution and answers by the witness, Davis, regarding

Government's 211.

THE COURT: Is it 211?

MR. STELLMACH: 2011, Your Honor.

THE COURT: Disregard Government's -- 2011?

MR. STELLMACH: Yes, Your Honor.

MR. SCARDINO: And we -- had they designated it

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:11:32

10:11:50

10:11:58

10:12:10

10:12:33


3779

and we had had a chance to examine it like the other

exhibits, we would have objected because of foundation and

hearsay.

MR. STELLMACH: Your Honor, the document was

produced to the defense as part of discovery, but more

importantly, the document we offered as Government's

Exhibit 2011 was identified by the defense as an exhibit.

Defense Exhibit 16311 includes the very document that

they're trying to strike now.

THE COURT: It's in there?

MR. STELLMACH: I've got my exhibit and I've

got their exhibit.

THE COURT: 16000 what?

MR. STELLMACH: 311.

THE COURT: All right. What's your response,

Counsel? What's -- no, what's your response, Mr. Scardino?

MR. SCARDINO: First I've heard that. I need a

minute to look to see.

THE COURT: Take a look, there it is.

MR. STELLMACH: Your exhibit, Page 185.

MR. SCARDINO: Apparently this is one of our

exhibits, but that doesn't change the fact that they would

still have to prove it up if they want admit it into

evidence. It's not in evidence just because we submit it.

MR. STELLMACH: They offered -- they were going

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:12:43

10:12:53

10:13:01

10:13:04

10:13:16


3780

to offer the document, Your Honor. First of all, there are

two -- confusing two different issues. One, they claim to

have been sandbagged by the fact that the witness was --

THE COURT: How about those probate papers?

MR. STELLMACH: Exactly. Exactly.

THE COURT: Put it in the record. What about

the probate?

MR. STELLMACH: The probate papers were shown

to us on the way up to cross-examine this witness at the

conclusion of his testimony.

THE COURT: Have you ever seen them before?

MR. STELLMACH: Not once. And we were not

given any indication about what the content was.

THE COURT: Any notice even in a proposed

exhibit --

MR. STELLMACH: None.

THE COURT: -- that you got from them?

MR. STELLMACH: None.

MR. SCARDINO: But --

MR. STELLMACH: So for them to get on their

high horse about that and then complain about this, they

claim to have been sandbagged. That was the basis, I

believe, on what Your Honor excluded the document

yesterday. If Your Honor wishes to exclude the document,

obviously --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:13:24

10:13:33

10:13:49

10:14:01

10:14:13


3781

THE COURT: I've excluded it, and I ordered it

taken down immediately.

MR. STELLMACH: And so what I would propose to

do is offer the defense exhibit, which includes that very

same document.

MR. SCARDINO: Well, there's a big difference

between us showing our exhibit to the government and

letting them have notice that we intended to try to get it

into evidence and they make no objection to it and then I

proceed in a manner of the Rules of Evidence and procedure,

mark it, admit it and examine the witness. They didn't do

that with 2011, they just put it up. That's the

difference.

MR. STELLMACH: And I can now offer Defense

Exhibit 16311. The witness has authenticated it. There

was a signatory on that account. There clearly is a bank

record certification, because they were prepared to offer

it. So there's no question as to authenticity. And it's a

relevant document, because they cross-examined this

witness, implying he had pocketed that money. And at the

time they did that, they had no good faith basis when they

were sitting on a document themselves that showed where the

money went. Defense exhibit.

MR. SCARDINO: We did have a good faith basis,

and they know that, that the money went into an account

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:14:25

10:14:35

10:14:40

10:14:49

10:15:03


3782

like I've proven that he has signature authority over, and

the government had no authority to remove that money or

send it anywhere.

He testified that the money was

transferred to the U.S. Government receiver. It was in a

foreign national bank account, and the government knows

that, and Mr. Davis knew that when he transferred it to his

account --

THE COURT: What else do you want to get --

MR. SCARDINO: -- in Bank of Antigua.

THE COURT: What else do you want to get in the

record?

MR. STELLMACH: Just the fact that they

cross-examined the witness, implied he had pocketed the

money, they had the document as a defense exhibit. We

intend to offer that exhibit.

MR. FAZEL: May I be heard, Your Honor, just

briefly?

THE COURT: No. I've heard enough.

MR. FAZEL: Okay.

THE COURT: What about a -- do you think an

instruction is appropriate?

MR. STELLMACH: I think I could deal with it

just by questioning the witness about the document and

going back over it.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:15:20

10:15:44

10:15:55

10:16:02

10:17:06


3783

THE COURT: Hang on one second.


THE COURT: I'm just thinking of the record. I

think we' got plenty in the record right now. All right.

Your tender of Government's Exhibit 2011 is denied. You're

moving into evidence his Exhibit 16311 is denied. I'm

letting everything stand as it is. I told you to take it

right down, you take it right down. And if you think an

exhibit -- an instruction to jury is appropriate, I'll give

the instruction.

MR. STELLMACH: And if I'm not allowed to offer

the exhibit, then I would ask for the instruction.

THE COURT: Okay. And we'll get the

instruction as soon as they come in.

MR. STELLMACH: And what would be the nature of

the instruction, Judge, so we could --

THE COURT: You'll hear it.

MR. STELLMACH: It will be a surprise?

THE COURT: Then if you have a problem, you

come see me.


THE COURT: Let's call the jury in.

(The following was held before the jury)

THE COURT: Good morning. Have a seat, please.

Mr. Stellmach, are you ready to go?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:17:13

10:17:21

10:17:33

10:17:41

10:17:54

Redirect-Davis/By Mr. Stellmach


3784

MR. STELLMACH: I am, Your Honor.

THE COURT: All right. Ladies and gentlemen,

you are instructed to disregard Government's Exhibit 2011.

Go right ahead, sir.

MR. STELLMACH: Thank you, Your Honor.

JAMES DAVIS

CONTINUED REDIRECT EXAMINATION

BY MR. STELLMACH:

Q. Yesterday, during cross-examination, Mr. Davis,

Mr. Scardino asked you a number of questions about being a

coward. Do you recall those questions?

A. Yes, sir.

Q. And do you recall him asking whether meeting with the

government had scared -- I think you said the devil out of

you. Do you recall that?

A. Yes, sir.

MR. STELLMACH: And if I could have the

overhead, Your Honor?

THE COURT: Okay. You got that.

BY MR. STELLMACH:

Q. And this was the privileged document that you waived

privilege on that you provided that you prepared in early

February of 2009; is that right?

A. Yes, sir.

Q. And if you believed as -- Mr. Scardino implied that

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:18:08

10:18:28

10:18:41

10:18:50

10:19:00



3785

what you wrote here was true. Do you remember him asking

questions that suggested that?

A. Yes, sir.

Q. If you believed what you wrote here was true about

your conduct while working for Mr. Stanford for 20 years,

would you, in fact, have pled guilty and accepted the

possibility of facing the next 30 years in prison?

A. No, sir.

Q. Do you recall being asked on your cross-examination,

I believe on Monday, concerning your destruction of some

laptops and some thumb drives that you had at your home in

Mississippi?

A. Yes, sir.

Q. Did you also testify about that during your direct

examination?

A. Yes, sir.

Q. How soon after meeting with the government did you

disclose the fact that you had, in fact, destroyed those

materials?

A. Soon.

Q. Or attempted to destroy?

A. Very soon.

MR. STELLMACH: And if we look at Government's

Exhibit 332. If I could, Your Honor, switch back to the

laptop.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:19:10

10:19:22

10:19:31

10:19:39

10:19:51



3786

BY MR. STELLMACH:

Q. This pie chart from the Miami meeting, was this one

of the documents on your computer that was thrown into the

pond?

A. Yes, sir.

Q. But we obviously see here the document was recovered?

A. Yes, sir.

Q. And all the financial information of Stanford

International Bank, that wasn't contained on your thumb

drives or your computers, was it?

A. No, sir.

Q. Were the representations that Mr. Stanford made to

depositors, those weren't all destroyed, were they?

A. No, sir.

Q. Were the Soc Gen records that we've seen in this

trial, those were all recovered; right?

A. Yes, sir.

Q. From the bank itself; right?

A. Correct.

Q. Now, Mr. Scardino, do you recall him suggesting that

you received some sort of a pass from the government for

destroying that evidence?

A. Yes, sir.

MR. STELLMACH: And we can take the exhibit

down.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:20:06

10:20:20

10:20:38

10:20:49

10:21:02



3787

BY MR. STELLMACH:

Q. But could you remind the jury: What was one of the

counts to which you pled guilty regarding obstruction?

A. Yes, sir. One count of conspiring to obstruct an SEC

investigation.

Q. So when Mr. Scardino asked you questions about

whether you had actually accepted responsibility for

obstructing an investigation, have you done that?

A. Yes, sir, I have.

Q. And do you recall Mr. Scardino also asking questions

that suggested that no one else who has been charged in

this case has destroyed any documents or evidence?

A. Yes, sir.

Q. And he asked about Mr. Kuhrt and Mr. Lopez, and

Ms. Holt. Do you recall him asking those questions?

A. Yes, sir, I do.

Q. But he didn't ask about Mr. Stanford, did he?

A. He did not.

Q. Were you aware that in late 2008, Mr. Stanford had a

bonfire outside of his home in St. Croix where he burned

bank records and other credit card records?

A. Yes, sir.

Q. Were you aware that he had another bonfire of

documents in early 2009 outside his home?

A. No, sir.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:21:21

10:21:35

10:21:43

10:21:49

10:21:55



3788

Q. And, finally, we talked already about the $6 million

that was transferred from one Soc Gen account, 108731, the

slush fund, to the Bank of Antigua account in which you

had signatory authority?

A. Yes, sir.

Q. Could you just remind us. Once that $6 million went

into that account, what happened to it?

A. I don't really know what happens to it. It's under

the control of the Bank of Antigua.

MR. SCARDINO: Objection, asked. He doesn't

know.

THE COURT: Overruled. Overruled.

BY MR. STELLMACH:

Q. Once it went into that account, was a single penny

taken out of that account?

MR. SCARDINO: Your Honor, I'll object. He's

testified he doesn't know what happened to it after it went

into the account.

THE COURT: How about that?

MR. STELLMACH: If I can ask the question,

rephrase the question.

THE COURT: Rephrase it.

BY MR. STELLMACH:

Q. After that $6 million was transferred into the Bank

of Antigua account, did a single penny come out of that

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:22:05

10:22:14

10:22:28

10:22:43



3789

account?

MR. SCARDINO: Same objection. He's testified

he doesn't know.

THE COURT: If you know.

THE WITNESS: No, sir, it didn't, as far as I

know.

BY MR. STELLMACH:

Q. And, in fact, as of February 20, 2009, was that money

still in the account?

A. It was.

Q. You were also asked some questions about

consolidation. Do you recall those questions?

A. Yes, sir.

Q. I think they were yesterday.

And you were shown Defense Exhibit 1325,

which is a chart and a bunch of other documents regarding

consolidation.

MR. STELLMACH: I'm sorry. If I could impose

one more time. Thank you.

BY MR. STELLMACH:

Q. Do you recall being asked questions about this chart?

A. Yes, sir.

MR. STELLMACH: And if we zoom in on the upper

right-hand corner.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:23:07

10:23:18

10:23:38

10:23:53

10:24:12



3790

BY MR. STELLMACH:

Q. Could you read what's written there?

A. "Internal draft for discussion purposes only.

February 6, 2009."

Q. So as of February 6, 2009, had the consolidation

taken place?

A. No, sir.

Q. Did the consolidation ever take place?

A. No, sir. No, sir.

Q. So the consolidation never got off the drawing board?

A. Never.

Q. And, so, all of the companies that we see on this

chart that were going to be grouped under Stanford

International Bank, were any of those companies actually

ever transferred to the bank?

A. No, sir.

Q. So by the time the organization stopped operating in

February of 2009, who still owned all of those individual

privately-held companies?

A. Mr. Stanford.

MR. STELLMACH: And if I could, I was going to

turn back to the laptop. I'm sorry.

Q. And look at Government's Exhibit 332C.

Do you recall this document, the

spreadsheet tracking the amount of money that went to

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:24:22

10:24:36

10:24:53

10:25:06

10:25:23



3791

Mr. Stanford's personal companies?

A. Yes, sir.

Q. Were these the companies that were going, or some of

the companies that were going to be transferred to the

bank if the consolidation project had ever taken place?

A. Yes, sir.

Q. And in the far right-hand column under "Total

balance," could you remind us what information is

reflected in that column?

A. That's the total over time as of the date of the

report that had been sent these companies on behalf of

Mr. Stanford.

Q. So that's not the value of those companies; that's

the money, the CD money, that had flowed in as of

December 31, 2008?

A. Correct.

Q. Now, were these companies repaying the debt to the

bank?

A. No, sir, not to my knowledge.

Q. In fact, what happened to the commercial airlines

that are listed on this spreadsheet?

A. They closed, stopped operating.

Q. What was your understanding about how these

businesses were able to stay open?

A. They would funnel money on a daily, weekly, monthly

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:25:46

10:26:03

10:26:20

10:26:34

10:26:45



3792

operating basis from the CD deposits.

Q. And looking at Government's Exhibit 1603, a summary

exhibit which I believe we've seen already, could you tell

us over time, starting in 2004, what was the total amount,

quote, loaned to Mr. Stanford from the CD money?

A. 597 million.

Q. And four years later, it had almost -- well, almost

quadrupled to two -- over $2 billion?

A. Yes, sir.

Q. Less than quadrupled.

So between 2007 and 2008 alone, it went up

how much?

A. About $400 million.

Q. So on a daily basis, how much money was coming out of

the CD money to go to these different companies that

Mr. Stanford owned?

A. In excess of a million dollars.

Q. So if the consolidation had taken place and the

companies we just saw in that spreadsheet that

Mr. Stanford owned that had been financed with the CD

money had ever been transferred back to the bank, who

would have owned those companies if the consolidation was

completed?

A. Mr. Stanford.

Q. Well, who would -- if the consolidation took place,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:26:59

10:27:12

10:27:23

10:27:39

10:27:59



3793

would they have become assets of the bank?

A. The bank holding, yes, sir.

Q. But what would have happened to the loan to

Mr. Stanford, to the $2 billion loan?

A. It would still exist.

Q. Well, the money would be gone, but would it still

exist on paper or would the consolidation have wiped it

out?

A. If the consolidation actually happened, it would wipe

it out.

Q. So that was $2 billion in real CD money that went to

Mr. Stanford; is that right?

A. Yes, sir.

Q. And if the consolidation took place, what the bank

would have gotten back were these companies that as of

2008 had already lost or required $2 billion to stay a

float?

A. Yes, sir.

Q. Yesterday, you described this proposed transaction as

smoke and mirrors.

Do you recall using that expression?

A. Yes, sir.

Q. Why did you use that expression?

A. Because the CD money that actually was spent on

various projects over the years that we've just discussed

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:28:35

10:28:51

10:29:04

10:29:19

10:29:33



3794

was reported to the public, to the perspective investors

and current investors one way, and when in actuality, it

was being handled the opposite way, and through meetings

and through presentations all put together for promoting

CD sales and telling people that their money was safe.

Q. So --

A. They were bamboozled by a smoke-and-mirror show, just

a drama.

Q. So were depositors ever told at any point, to your

knowledge, that the way the bank is going to repay you is

with these private companies that we own down in Antigua

and in the Caribbean?

A. No, sir.

Q. That "Don't worry about your CD money. The bank will

repay you with a restaurant called the Sticky Wicket or

real estate projects around the airport in Antigua?

A. No, sir.

MR. STELLMACH: I'm sorry. If I could go to

the...

BY MR. STELLMACH:

Q. And we -- you talked a little bit about the con --

this proposed consolidation, and you were asked about the

total assets, I believe, which here are shown as about

6 -- about 10.3 million is the number I highlighted under

"Total Assets." I'm sorry. 10.3 billion.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:29:48

10:30:07

10:30:18

10:30:28

10:30:42



3795

Is that number accurate?

A. No, sir.

Q. Why not?

A. Because the third line from the top indicates

financial assets at fair value.

Q. You're talking about the line that's been highlighted

in gray?

A. Yes, sir. It reflects the erroneously inflated

numbers that had been previously over the years reported

on financial statements probably in the amount of 5.5 to

$6 billion.

MR. SCARDINO: Objection. Nonresponsive.

MR. STELLMACH: That was responsive. I asked

him what the number --

THE COURT: Overrule the objection.

BY MR. STELLMACH:

Q. So the total assets, just to be clear, that are

reflected here, would those have included the assets, the

reported assets of Stanford International Bank?

A. Yes, sir.

Q. And as of this time, the end of '08, how much money

was missing from those reported assets?

A. Five and a half to six billion dollars.

Q. So ultimately, would the consolidation have allowed

the bank to repay depositors?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:30:53

10:31:04

10:31:17

10:31:26

10:31:42



3796

A. No, sir.

Q. Just another smoke-and-mirror gimmick?

MR. SCARDINO: Objection. Leading.

THE COURT: Sustained.

BY MR. STELLMACH:

Q. Was that what you meant by referring to this as smoke

and mirrors?

A. Yes, sir.

Q. You were also asked some questions about your

contacts with Mr. Stanford, and Mr. Scardino, I believe,

at one question suggested Mr. Stanford was an absentee

owner who wasn't often in contact with you.

Do you recall that?

A. Yes, sir.

Q. And you testified that he had his finger on the

pulse. You used that expression.

Do you recall that?

A. Yes, sir.

Q. I was going to turn to Government's Exhibit 1500, the

address book.

Can you remind us, Mr. Davis, what

Government's Exhibit 1500 is?

A. It's Mr. Stanford's address book.

Q. And I just want to turn to the entry that

Mr. Stanford had for you in his address book. And if we

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:31:58

10:32:21

10:32:35

10:32:41

10:33:03



3797

look -- I'll start -- or I'll start at the top.

Tupelo office is listed here.

A. Yes, sir.

Q. Where were you are working again?

A. At -- between Tupelo and the Memphis offices.

Q. And then there are a number of other numbers, an

office number, office fax, a home number for you, a main

mobile number, another mobile number, another Tupelo

office number, a mobile number for the Tupelo office, some

additional numbers here. You're assistant's number is

listed at the bottom.

Do you see that? Is that Tuteli Cecasa?

A. Yes, sir.

Q. All in, are there about 14 numbers in Mr. Stanford's

address book for you?

A. Yes, sir.

Q. So did he have ever have any problems finding you and

reaching you to find out the status of what was happening

in the organization?

A. Not that I know of.

Q. Do you recall Mr. Scardino on cross-examination --

MR. STELLMACH: Sorry. Could we switch back?

BY MR. STELLMACH:

Q. -- asking you or saying that all we can do is take

your word for what happened, there's no other evidence?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:33:09

10:33:23

10:33:29

10:33:41

10:34:01



3798

Do you recall him saying that?

A. Yes, sir.

Q. Is that true?

A. No, sir.

Q. Why not?

A. Follow the money (indicating).

MR. SCARDINO: I'm sorry. I believe he was

pointing at me. Was there some reference there that I

missed?

MR. STELLMACH: I wasn't pointing. I don't

know what --

MR. SCARDINO: The witness was.

THE WITNESS: That was not true.

BY MR. STELLMACH:

Q. You were pointing at the defense table?

THE COURT: Well, you can bring that up if you

want to on cross.

BY MR. STELLMACH:

Q. Do we have to just take your word for it? If we look

at Government's Exhibit 136? I'm not going to go back

through this, the marketing brochure.

Do we have to take your word for it for

what depositors were told about how the bank was investing

the CD money, or is its written right there in black and

white?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:34:11

10:34:25

10:34:39

10:34:46

10:35:02



3799

A. It's written in that brochure very clearly.

Q. And the same thing in the annual reports that

Mr. Stanford signed?

A. Yes, sir.

Q. And that you also signed sometimes?

A. Yes, sir, I signed the annual reports as well.

Q. And if we go to Government's Exhibit 332C, the

spreadsheet we were just looking at, do we have to take

your word for it that $2 billion was loaned to

Mr. Stanford?

A. No, sir. That's not myself only. It's on this paper

and other accountants knew of it.

Q. Do we have to take their word for it if we look at

annual reports to see that that loan was never

disclosed --

A. No, sir.

Q. -- to depositors?

A. No, sir.

MR. STELLMACH: And if we look at Government's

Exhibit 211, if we just turn to the first attachment.

BY MR. STELLMACH:

Q. Could you remind us what this document is?

A. Yes, sir. It's a weekly summary of Tier 2 at

January 7, 2008.

Q. And, so, do we have to take your word for it that

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:35:19

10:35:28

10:35:47

10:36:04

10:36:18



3800

these summaries show that only about 15 percent of the

bank's assets are being invested in marketable securities

consistent with the way depositors were told the entire

portfolio was being invested?

A. No, sir.

MR. STELLMACH: If we go back to the first page

of that document -- the e-mail itself. If we highlight the

top portion.

BY MR. STELLMACH:

Q. Do we have to take your word for it, Mr. Davis, that

Mr. Stanford was copied on those tracking reports?

A. No, sir.

Q. I'm not going to march through the Soc Gen records.

But do we have to take your word for it that millions, 10

of millions of dollars was flowing out of that Soc Gen

account in Switzerland to Mr. Stanford's own personal

accounts?

A. No, sir.

Q. Now, do you recall being asked on cross-examination

about that $990,000 loan you took at the end of 2008 early

2009?

A. Yes, sir.

Q. Mr. Scardino questioned you at length about that

loan.

Do you recall that?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:36:29

10:36:50

10:36:58

10:37:15

10:37:49



3801

A. Yes, sir.

Q. Do you recall being questioned for probably more than

an hour by Mr. Scardino about that loan?

A. Yes, sir.

Q. At that rate in -- I'm sorry -- in 2008, what was the

rate of CD money Mr. Stanford was taking out on a daily

basis for those companies we saw?

A. A million to a million and a half dollars per day.

Q. So if we spent an hour on each million dollars

Mr. Stanford took out, how long would we be here?

THE COURT: A long time.

THE WITNESS: A long time, sir.

THE COURT: Go on.

BY MR. STELLMACH:

Q. Mr. Scardino also asked you about a boat you had on a

pond in front of your home in Mississippi?

A. Just a minute.

THE COURT: Okay.

BY MR. STELLMACH:

Q. Do you need a moment, Mr. Davis?

A. (No audible answer). (Indicating).

Q. Sure.

A. Yes, sir, I do. I remember.

Q. And if we look at Government's Exhibit 13 -- how big

was your boat, by the way?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:38:03

10:38:12

10:38:22

10:38:32

10:38:52



3802

A. I think it was 12, 14 feet long.

MR. STELLMACH: And could we see Government's

Exhibit 1300?

BY MR. STELLMACH:

Q. Do you recognize this?

MR. SCARDINO: Is it in evidence,

Mr. Stellmach?

MR. STELLMACH: It is -- I thought everything

was in evidence. All of our exhibits are in evidence.

MR. SCARDINO: Well, then he'll prove it up.

MR. STELLMACH: Sure. I'll ask the witness.

THE COURT: Okay. Go on.

BY MR. STELLMACH:

Q. Did you -- do you recognize what that exhibit was?

A. Yes, sir, I do.

Q. What was it?

A. It is a yacht of Mr. Stanford's. It was.

MR. STELLMACH: And if we could go to

Government's Exhibit 1300.

BY MR. STELLMACH:

Q. How big was that yacht?

A. I believe it was a hundred feet.

Q. So your boat was about 12 feet long. It went in a

pond. And Mr. Stanford -- that was one of Mr. Stanford's

yachts?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:39:11

10:39:26

10:39:41

10:40:11

10:40:29



3803

A. Yes, sir.

Q. Is that a fair comparison in your mind to what you

received out of what did for Mr. Stanford and what he did?

A. No, sir.

Q. Well, Mr. Stanford's yacht was a hundred feet long.

Your boat was about 12 feet long.

In terms of how much money he got and how

much money you got, is that a fair reflection of how this

was all divvied up?

A. It's a reflects of how it was divvied up, yes, sir,

I'd say very fair.

Q. You used the expression "Follow the money."

MR. STELLMACH: And I wanted to go to the

laptop. I'm sorry. The overhead. I'm sorry, Ellen.

BY MR. STELLMACH:

Q. And I wanted to do just a little bit more of that.

This is Government's Exhibit 1205A we've already seen this

document. It's a letter from you to Blaise Friedley at

Societe Generale for the 108731 account, and it shows a

number of transfers.

Could you tell us, looking at the

transfers, what the amounts were and to whose account they

went?

A. 8 million to Mr. Stanford, 8 million to Mr. Stanford,

6 million to Mr. Stanford.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:40:45

10:40:58

10:41:17

10:41:23

10:41:31

Recross-Davis/By Mr. Scardino


3804

Q. And that was a total of what?

A. I believe 22 million.

Q. And that's just for one day?

A. September 26, 2003.

Q. So Mr. Stanford on one day withdrew $22 million in CD

money from the Soc Gen account?

A. Yes, sir.

Q. How much did you receive in 20 years for

participating in the fraud?

A. Approximately $14 million.

Q. So Mr. Stanford withdrew more in one day that you

received over the course of the fraud?

A. Yes, sir.

MR. STELLMACH: I pass the witness, Your Honor.

RECROSS-EXAMINATION

BY MR. SCARDINO:

Q. Mr. Davis, that $22 million you're talking was money

that was used to capitalize the other companies, wasn't

it?

A. Yes, sir.

Q. You testified to that, haven't you?

A. Yes, sir.

Q. The $14 million you got wasn't used for any purpose

in that manner, was it? That just went right into your

pocket; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:41:40

10:41:48

10:42:00

10:42:15

10:42:26



3805

A. Yes, sir.

Q. All the money that Mr. Stellmach's talked about that

was transferred out of the Soc Gen account was used to

capitalize these other companies?

MR. STELLMACH: Objection. That be misstates

the witness's testimony.

THE COURT: All right. If that's not your

testimony, sir, you'll so state.

You may ask the question.

BY MR. STELLMACH:

Q. That's what happened, wasn't it? That's what the

million -- Mr. Stellmach is trying to make a point that

Stanford got 22 million in one day and you got -- only got

14 million in 16 years; but none of that 14 million you

got was used for a business purpose, was it? That just

went -- it went into your pocket?

A. The 14 million went in my pocket, yes, sir.

Q. And the 22 million that Mr. Stellmach is talking

about in Government's 1205A was money that was used on

your instructions to Mr. Friedley to transfer to

Mr. Stanford's accounts that was used to capitalize these

companies that we've talked about now for several days;

right?

A. Yes, sir. Coming from the CD deposit holders, yes,

sir.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:42:44

10:43:00

10:43:06

10:43:12

10:44:11



3806

Q. So that's not a fair comparison at all to say that

you got so much money in 16 years and Mr. Stanford got so

much money in one day, is it?

A. Yes, sir, it's a fair comparison.

Q. Mr. Stellmach asked you about these loans to

Mr. Stanford were not disclosed.

Now, you've testified previously that

you're familiar with international accounting standards;

correct?

A. I'm familiar.

Q. Yes, sir. Well, I mean --

A. Yes, sir.

Q. -- we've been talking about it now for a while.

Are you telling us --

MR. STELLMACH: Objection. Beyond the scope.

THE COURT: Excuse me. Hang on one second. I

want to -- I'm going to have it read back in a moment.

Give me one second.

(Brief pause)

THE COURT: Okay. Sorry. Read it back,

please.

(Last question read back by the reporter.)

MR. STELLMACH: My objection, Your Honor, was

that we didn't go into international accounting standards

on redirect.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:44:24

10:44:31

10:44:52

10:45:01

10:45:11



3807

MR. SCARDINO: Well, he did talk about loans

that were not disclosed.

THE COURT: I'm looking at my list. Hang on a

second. I think there's enough of a connection there that

he can link it up.

Overruled. Overrule the objection.

Go on.

BY MR. SCARDINO:

Q. So, Mr. Davis, the loans that were not disclosed in

the financial statements did not have to be disclosed

under international financial accounting standards, did

they?

A. I don't know that particular standard, sir.

Q. During part of Mr. Stellmach's redirect, he asked you

a question and you looked at me and pointed your finger at

me.

Do you remember that?

A. I was pointing to the other end of the table, not to

you, sir.

Q. I see. So you were actually pointing to Allen

Stanford?

A. Pointing to the defense table at the other end of it,

yes, sir.

Q. Were you pointing to Allen Stanford?

A. He's at the table, yes, sir.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:45:19

10:45:37

10:45:45

10:45:58

10:46:09



3808

Q. Were you pointing to Allen Stanford?

MR. STELLMACH: Asked and answered Your Honor.


BY MR. SCARDINO:

Q. Were you trying to communicate with Mr. Stanford in

some way, Mr. Davis?

A. I was pointing towards Mr. Stanford.

Q. Are you now saying that you'd be willing to talk to

his lawyers? Have you changed your mind about talking to

us?

A. Can talk to my attorney.

MR. STELLMACH: This is way beyond.

THE COURT: Sustained. Next, please.

BY MR. SCARDINO:

Q. You said, "Follow the money," when you were pointing

your finger, didn't you?

A. I did.

Q. Well, now, we've established, haven't we, Mr. Davis,

that you were the chief financial officer; right?

A. Yes, sir.

Q. You were the one in charge of following the money,

weren't you?

A. At Mr. Stanford's direction, yes, sir.

Q. And we've established you're the one that actually

put your hand on the paper and put the phony numbers down

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:46:21

10:46:36

10:46:45

10:47:03

10:47:18



3809

on the annual statements.

We've established that, haven't we? You

did that?

A. I did put phony numbers down on paper, yes, sir, at

his direction.

Q. And Mr. Stellmach talked to you about an address

book, Government's 1500, and he showed you that

Mr. Stanford had a number of contact data for you;

correct?

A. Yes, sir.

Q. Well, he could have gotten a hold of you at any time

then; right? You gave him all the information he would

need to reach you; right?

A. Yes, sir, and vice versa.

Q. But haven't you testified before this jury that you

had a hard time reaching him? That's the issue, isn't it?

A. I had a hard time, yes, sir.

Q. You kept a book too, didn't you, Mr. Davis? Did you

get that --

A. I don't understand your question.

Q. Well, you kept a ledger of everything that happened.

You were constantly writing in your book. Every day you

made entries in your book, didn't you?

A. I had entries in books, yes.

Q. Where is the book?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:47:28

10:47:36

10:47:43

10:47:58

10:48:05



3810

MR. STELLMACH: Objection, Your Honor. Beyond

the scope.

We asked about Mr. Stanford's address

book. They're now opening it up into other address books.


MR. SCARDINO: Just a book.

BY MR. SCARDINO:

Q. Did you keep a -- did you keep data of -- you just

testified you kept a ledger of things that went on.

Do you have that?

MR. STELLMACH: Objection.

THE COURT: What?

MR. STELLMACH: Again, beyond the scope.


BY MR. SCARDINO:

Q. You talked about -- Mr. Stellmach asked about you

Government's Exhibit Number 13.25, and you discussed a

particular line that talked about market value or fair

market value.


MR. STELLMACH: I think it was a defense

exhibit, just to be clear.

MR. SCARDINO: I have written down 13 -- maybe

it was defense exhibit.

MR. STELLMACH: I know it's hard to do keep

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:48:12

10:48:24

10:48:34

10:48:47

10:48:56



3811

track.

MR. SCARDINO: It is hard to keep track.

BY MR. SCARDINO:

Q. But do you remember Mr. Stellmach asking about you

that exhibit?

MR. SCARDINO: Can we have it? I guess it's

Defense 13.25? I thought government. Let's bring that up

and look at it.

No, that's not it. That's it.

THE WITNESS: Yes, sir.

THE COURT: The number is 13.29? Is that

correct? Is that what we're looking at? Okay.

MR. STELLMACH: 25, Your Honor.

THE COURT: 25.

BY MR. STELLMACH:

Q. And I believe Mr. Stellmach was -- made a reference

to the third line down, financial assets at fair value?

A. Yes, sir.

Q. And I think your response was, "That's fake, that's a

phony number"?

A. Yes, sir.

Q. Who put that number there?

A. Accounting department.

Q. And at whose instruction?

A. It was in -- under my -- it was my department, my

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:49:12

10:49:36

10:49:43

10:49:57

10:50:28



3812

instructions, to prepare the consolidation.

Q. So the smoke and mirrors that Mr. Stellmach was

talking about that the numbers -- were saying the numbers

weren't real, if the numbers aren't real, they're the

numbers you put down, isn't it?

A. I put the numbers down, yes.

Q. Now, the number is real. I mean, the number

$8,329,978,673, that's the number that was put on the

document.

Wasn't it put under "Assets"? Isn't that

correct?

A. It's not a real number, but it was put down there,

yes, sir.

Q. Well, I mean, it is a number. You're just saying

it's not a correct number?

A. Yes. It's an inflated number based on our fraud.

Q. Yes, sir. And you instructed people to put that

number in there?

A. Yes, sir.

Q. Where's the books that show the real number?

A. Well, the books are where they are. I don't know

where the books are at this point in time.

Q. When Mr. Stellmach asked you about the consolidation

project and he asked you if it was underway and you said

it was never underway --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:50:54

10:51:08

10:51:23

10:51:28

10:51:40



3813

MR. SCARDINO: Let me have Defense 13-2,

please. On the fourth page, please. And let's go down to

under consolidation plan. Thank you.

BY MR. SCARDINO:

Q. And then about six lines down, "This consolidation

concept." See that?

"This consolidation concept had been under

construction for years insofar as the finance and

accounting decision-making went."

Now, which is it, Mr. Davis? You're

telling the jury two different things: That it never got

off the ground, that it was just a concept. Except in

your talking points and in previous testimony, you've

talked about something other than just a concept. You had

meetings about it.

A. Yes, sir.

Q. Charts were drawn; right?

A. Yes, sir.

Q. I mean, that's the way things work in business. You

talk about it at length and put it together before it's

implemented; right?

A. You do.

Q. Yeah. And that's what you were trying to do with the

consolidation project, and that's what you wrote in your

talking points; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:51:53

10:52:12

10:52:26

10:52:40

10:52:50



3814

A. Yes, this was -- yes.

Q. All the exhibits that you and I talked about on

cross-examination yesterday where the accounting

department put together these plans and ideas of how the

consolidation was going to work, that wasn't just a

concept, was it? It was actually people rolled up their

sleeves and were putting ideas on paper, weren't they?

A. Concept was prior to putting on paper, yes, sir.

Q. And that had been going on for some period of time.

In fact, you said in your talking points, according to

this exhibit, for years?

A. Yes, sir.

Q. Okay. And then when Mr. Stellmach was asking you

about the $2 billion loan to Mr. Stanford and he was

walking you through how that was going to be -- would that

be wiped out, do you remember what you told him?

A. Yes, sir.

Q. What did you tell him?

A. It would not be there if the consolidation took

place.

Q. The $2 billion loan to shareholder would be wiped out

if this consolidation project was put in place.

Isn't that what you told him?

A. Yes, sir.

MR. SCARDINO: Pass the witness.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:53:01

10:53:15

10:53:30

10:53:41

10:53:52



3815

THE COURT: Also confine your area now to the

areas that Mr. Scardino.

MR. STELLMACH: Understood, Your Honor.

REDIRECT EXAMINATION

BY MR. STELLMACH:

Q. Mr. Davis, Mr. Scardino just asked you questions

about international accounting standards.

Going back to 1999, when there was a

disclosure that Mr. Stanford had fully repaid the loan,

the 13.5 million dollars, that depositors had been told

about in the annual report, who made the decision to take

that disclosure out?

A. Mr. Stanford.

Q. Did he ever discuss with you whether international

accounting standards allowed him to say the loan was

repaid when, in fact, he was borrowing billion dollars

more as time went on?

A. No, sir.

Q. Did he ever at any point when you worked for him say

to you, "What we're doing is perfectly legitimate because

there are these international accounting standards that

allow us to say one thing to our deposits and to do

another with their money"?

A. No, sir.

MR. SCARDINO: Excuse me. That's beyond the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:53:59

10:22:43

10:54:26

10:54:45

10:54:51



3816

scope of recross.

MR. STELLMACH: He asked about international

accounting standards.

THE COURT: Overruled.

BY MR. STELLMACH:

Q. Now, Mr. Davis, you were also asked on

recross-examination --

MR. STELLMACH: If I could have the -- thank

you.

BY MR. STELLMACH:

Q. -- about this transfer on September 26, 2003, from

the Societe Generale account, the Swiss slush fund, the

108731, to Mr. Stanford's different personal accounts in

the amount of $22 million?

A. Yes, sir.

Q. Were the transfers that were taken out of that

account, all of the transfers from the Swiss slush fund at

108731, were those accounted for within the spreadsheet

that was used to track the loan to Mr. Stanford?

MR. SCARDINO: Objection, beyond the scope.

THE WITNESS: No, sir.

THE COURT: He said it's beyond the scope. How

is it not?

MR. STELLMACH: He specifically suggested with

this witness that the money that Mr. Stanford took out of

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:55:03

10:55:19

10:55:37

10:55:51

10:56:09



3817

the Soc Gen account was used to capitalize companies. That

information is reflected in this spreadsheet. The money

from the Soc Gen account isn't captured in this

spreadsheet.


BY MR. STELLMACH:

Q. So the $2 billion figure that we keep seeing as of

the end of 2008 that Mr. Stanford had borrowed for his

private companies, does that include the money, the

millions and millions of dollars, that we saw coming out

of the Soc Gen account, 108731?

A. Would you repeat the question, please.

Q. Certainly, sir. The $2 billion figure here, does

that include the money Mr. Stanford was taking out of the

Soc Gen account or was that money from the Soc Gen account

in addition to the 2 billion?

A. It was in addition.

Q. So it wasn't just -- it was 2 billion to his

companies, his privately-held companies, and then whatever

the total amount was that he was taking out of the Soc Gen

account; is that right?

A. Yes, sir, separately.

Q. You were also asked about whether there were real

accounting records to back up the assets. Well, this

spreadsheet was one record, right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:56:16

10:56:26

10:56:42

10:56:54

10:57:03



3818

THE COURT: What's the exhibit?

MR. STELLMACH: Government's Exhibit 332-C,

Your Honor.

THE COURT: Okay.

MR. STELLMACH: I apologize.

BY MR. STELLMACH:

Q. And is that right?

A. Yes, sir.

Q. And there were also records kept by the Memphis group

for what tier of assets for the bank?

A. Tier 2 and -- actually, Tier 1 and Tier 2, cash and

securities.

Q. So there were actual records tracking that 25 percent

of the bank's assets that were invested consistent with

what depositors were told?

A. Yes, sir.

Q. And there were also records, as we've seen -- and I

won't go back to them -- tracing the real estate

transaction that you talked about where the bank bought

real estate for 63.5 million and it was inflated to

3.2 billion; is that right?

A. Yes, sir, that's correct.

MR. SCARDINO: Objection. Leading the witness.

Leading the witness.


1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:57:08

10:57:19

10:57:27

10:57:39

10:57:47



3819

BY MR. STELLMACH:

Q. Those records existed, didn't they?

A. Yes, sir.

Q. Were those ever disclosed in the financial

statements?

A. No, sir.

Q. Were the depositors ever told that 75 percent of

their money was being invested in something other than

what they had been told?

A. Never.

MR. STELLMACH: Pass the witness.

RECROSS EXAMINATION

BY MR. SCARDINO:

Q. So, Mr. Davis, when Mr. Stellmach asked you questions

about what Mr. Stanford instructed you to do, do you

remember him asking you those questions regarding how --

what to put in the financial reports, what to disclose and

not to disclose?

MR. STELLMACH: Objection. That wasn't my

question. My question related to a specific disclosure for

a loan in 1999.

THE COURT: We're wrapping it up. I'll allow

him to ask it.

Go on.

BY MR. SCARDINO:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:57:58

10:58:10

10:58:19

10:58:37

10:58:56



3820

Q. Do you remember the question?

A. Repeat it for me.

Q. Well, Mr. Stellmach, the prosecutor, was asking you a

question about what Mr. Stanford had instructed you to do

or not to do.

A. I don't recall.

Q. Regarding loans to shareholders. We've been talking

about that for days, loans --

A. I know we've been talking about it. You're referring

to a specific question. Could --

THE COURT: Lead him some more.

BY MR. SCARDINO:

Q. When Mr. Stellmach asked you about what did

Mr. Stanford tell you to do or not to do regarding loans

to shareholder being disclosed, do you remember that?

A. Yes, I remember the subject.

Q. Do you remember you answered Mr. Stellmach's question

and you told him what you thought Mr. Stanford had told

you to do or not to do, do you remember that?

A. Not specifically.

Q. Well, whatever it is, you remember or didn't

remember, we'd have to believe you to believe what

Mr. Stanford did or didn't do, don't we? Because you

don't have any documents to establish what his

instructions to you were one way or the other regarding

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:59:06

10:59:14

10:59:19

10:59:27

10:59:35



3821

loans or anything else. We'd have to believe you,

wouldn't we?

A. Yes, sir.


THE COURT: Anything further?

MR. STELLMACH: Very briefly, Your Honor.


BY MR. STELLMACH:

Q. The money that was coming out of the Soc Gen account

was CD money?

A. Yes, sir.

Q. Do we have to believe only your word for that money

going to Mr. Stanford?

A. No, sir.

Q. We have the bank records?

A. Lots of them.

Q. Do we have to take your word for it that

$2 billion --

MR. SCARDINO: I'm sorry. That's beyond the

scope.

THE COURT: Overruled. We're wrapping it up.

I'll give you another shot, and then the government will

shut it down. It's their witness. We'll get it all.

BY MR. STELLMACH:

Q. Do we have to take only your word for it that

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

10:59:46

11:00:18

11:00:29

11:00:39

11:00:53



3822

$2 billion went to Allen Stanford's personal companies and

that money was never disclosed to the depositors in the

annual reports which he signed?

A. No, sir.

MR. STELLMACH: Pass the witness.

RECROSS EXAMINATION

BY MR. SCARDINO:

Q. You kept track of the numbers, didn't you?

A. Yes, sir.

Q. Are you telling this jury that every time you put a

column of numbers together, you had to go to Mr. Stanford

and ask him whether you could disclose them?

A. No, sir.

Q. Are you telling this jury that you had to go to

Mr. Stanford and ask him whether or not you had to change

the numbers?

A. No, sir.


THE COURT: Last go-round. That's it. Now

you're it. It's your witness. Do you have any more

questions, then we're shutting it down, unless you unload

an atomic bomb, and then I'll --

MR. STELLMACH: I'm not going nuclear this

morning, Your Honor.


1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:01:00

11:01:08

11:01:11

11:01:19

11:01:25



3823

BY MR. STELLMACH:

Q. Mr. Davis, who ran the companies, you or

Mr. Stanford?

A. Mr. Stanford.

Q. Who owned the companies?

A. Mr. Stanford.

Q. Who profited overwhelmingly from the fraud to which

you have pled guilty?

MR. SCARDINO: Objection. It's beyond the

scope.


MR. SCARDINO: Object to the term of the -- the

use of --

THE COURT: Terminology sustained.

BY MR. STELLMACH:

Q. Who provided overwhelmingly from the conduct that you

described with the CD money?

A. Mr. Stanford.

MR. STELLMACH: Nothing further.

THE COURT: Thank you, sir.

MR. SCARDINO: Nothing further.

THE COURT: All right. Thank you, sir. You

may step down. You're excused. You're free to leave.

Call your next witness.

MR. SCARDINO: Could we have Mr. Davis

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:01:34

11:01:44

11:01:51

11:02:01

11:02:10


3824

available, Your Honor.

THE COURT: All right. Mr. Davis, then -- no,

no, don't have to come back.

MR. STELLMACH: Available.

MR. COSTA: Travel issue. Are they going to

pay for his travel and hotel?

MR. SCARDINO: Not personally.

MR. COSTA: Available in what sense? I don't

know what that even means.

MR. SCARDINO: If we choose to call him back,

we want -- we don't want him excused. We'd like to have

him available.

THE COURT: Throughout the whole trial.

MR. SCARDINO: Well, certainly when it's our

turn to put on evidence, we may choose to call him back.

MR. STELLMACH: They've had an ample

opportunity to cross-examine the witness, Your Honor.

THE COURT: Do they have him identified as a

witness?

MR. SCARDINO: I don't believe that -- I think

we can reply upon the government's representation and their

subpoenas, Your Honor.

MR. COSTA: They can obviously subpoena him

again, and we can deal with it at that point. But for him

to stay here until they even get to their case --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:02:17

11:02:26

11:02:37

11:03:01


3825

MR. SCARDINO: I'm not asking that he has to

stay here. I'm just asking him not be excused so we can go

to the moon. I just want him to be available if we call

him back. He's under the jurisdiction of the Court. We'll

give the government --

THE COURT: He's under the continuing

jurisdiction of the Court. I'll determine whether or

not -- if there's a request that he return, whether or not

I agree to it, okay?


THE COURT: Okay. Thank you, sir. For right

now you're excused. You're free to leave.

Call your next witness.

MR. COSTA: United States calls agent Kal

Young.

CASE MANAGER: Would you please raise your

right hand. Do you solemnly swear that the testimony you

are about to give in the case now pending before the Court

will be the truth, the whole truth and nothing but the

truth?

THE WITNESS: I do.

THE COURT: Have a seat, please. Pull the mike

all the way in, please.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:03:16

11:03:23

11:03:31

11:03:41

11:03:51

Direct-Young/By Mr. Costa


3826

KALFORD YOUNG,

after having been first cautioned and duly sworn, testified

as follows:

DIRECT EXAMINATION

BY MR. COSTA:

Q. Good morning.

A. Good morning.

Q. Would you please introduce yourself to the jury.

A. My name is Kalford Young.

THE COURT: How do you spell your name, please?

THE WITNESS: K-A-L-F-O-R-D.

THE COURT: Last name?

THE WITNESS: Young. Y-O-U-N-G.

BY MR. COSTA:

Q. What's your occupation?

A. I'm a special agent with the Internal Revenue

Service, criminal investigation.

Q. Are you the big bad IRS agent who interviewed Henry

Amadio in this case?

A. I wouldn't describe myself as that, but I did

interview Mr. Amadio.

Q. Now, you said you work for the IRS as a criminal

agent, investigative agent?

A. Yes, that's correct.

Q. Explain briefly for the jury the difference between

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:04:10

11:04:29

11:04:48

11:04:58

11:05:12



3827

an IRS criminal investigative agent like yourself and IRS

people who deal with civil tax matters?

A. The IRS civil side, the civil division, is what

people mostly think of the IRS, and they are the ones who

go out and try to collect taxes from people, the ones who

conduct the audits, try to get people to pay their taxes.

The criminal side are the agents who go

out and investigate criminal violations of the tax laws,

tax evasion and similar violations.

Q. Now, this case doesn't have any tax charges. So why

are you as an IRS criminal investigative agent involved in

the case?

A. IRS criminal investigation also has jurisdiction over

money laundering violations, and that was my -- the focus

of the IRS in this case.

Q. There was a charge of money laundering against

Mr. Stanford?

A. Money laundering conspiracy, yes.

Q. And just briefly, what is -- you said it's a

conspiracy allegation?

A. Yes, it is.

Q. And what are the money laundering laws that the

indictment alleges Mr. Stanford conspired to violate? How

many laws does the indictment say he conspired to violate?

A. There's two. One is the international money

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:05:32

11:05:45

11:06:06

11:06:28

11:06:47



3828

laundering, which is the movement of funds -- movement of

illegally obtained funds from within the United States to

someplace outside the United States or vice versa, with

the intention of promoting the underlying scheme.

Q. And what's the underlying scheme that's alleged his

movement of money internationally helped to promote or

carry forward?

A. The mail fraud wire fraud.

Q. And is there a second money laundering statute that

the indictment alleges Mr. Stanford conspired to violate?

A. Yes. It is the spending or the movement of funds

from illegally obtained funds in amounts greater than

$10,000.

Q. And you mentioned briefly the difference between a

criminal investigative agent like yourself and civil IRS

employees. Are there protections in place that prevent

free movement of information between those two units of

the IRS?

A. Sure. The IRS civil -- well, first off, if there is

a criminal case going on, we don't have any contact with

the civil side unless necessary. And even with that,

there's -- there are restrictions. And in cases where --

like this particular case, we're investigating money

laundering and not tax. There's other safeguards such

as -- the IRS agent can't have access to any tax returns

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:07:00

11:07:17

11:07:29

11:07:48

11:08:01



3829

even though they're on file with the IRS.

Q. You can't just ask the civil people at the IRS, "Give

me these tax returns"?

A. That is correct.

Q. What do you need to do if you want to get tax returns

for a criminal money laundering and fraud investigation

like this?

A. We would have to get authorization from the Court.

Q. And as part of this investigation, did you focus on

any individuals' particular financial records?

A. Yes, I did.

Q. Who is that individual?

A. Leroy King.

Q. Why were you focusing on Mr. King's bank and other

financial records?

A. Mr. James Davis had provided information that

Mr. King was receiving cash bribes by Mr. Stanford.

Q. And in your attempt to review Mr. King's finances,

were you trying to corroborate that information from

Mr. Davis?

A. Yes, I was.

Q. Now, in your -- part of the investigation you were

involved in, did you review all the financial records for

Stanford International Bank and Mr. Stanford as part of

your duties?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:08:09

11:08:25

11:08:33

11:08:48

11:09:03



3830

A. No.

Q. Is there going to be an FBI agent testifying later in

this case who did review the finances of the bank itself?

A. Yes.

Q. But you focused in terms of reviewing financial

records on Mr. King?


Q. Now, you mentioned that in order to obtain tax

records for a fraud and money laundering case, you have to

get a court order for those tax records?

A. That's correct.

Q. Did you get such a court order for Mr. Leroy King's

tax returns?

A. Yes, we did.

Q. Why did you want Mr. Leroy King's tax returns as part

of this investigation?

A. To see if there were any other sources of income that

he reported that would support cash being deposited to his

bank accounts.

Q. Just remind the jury who Mr. King is. They've heard

his name, but just remind them who he is.

A. Mr. King was the CEO -- the administrative of

Financial Services Regulatory Commission in Antigua.

Q. So if he was living in Antigua, why did he have to

file a U.S. tax return?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:09:21

11:09:36

11:10:02

11:10:14

11:10:30



3831

A. Mr. King was a United States citizen, and U.S.

citizens are required to file tax returns annually,

reporting all income from all sources, worldwide.

Q. You said an order was obtained from a federal judge

to get those tax returns?

A. Yes, it was.

Q. I want to hand you what's marked as Government's 651

through 656 and ask if you recognize those documents,

Agent Young.

A. Sure. They are the 2002 through 2007 certified

copies of tax returns for Leroy King.

Q. And what information in particular were you trying to

find out about Mr. King from these tax returns?

A. His sources of income and if there was any source

that he reported that would explain cash deposits.

Q. We're going to get to it. But when you reviewed

Mr. King's bank records, did you find significant cash

deposits into bank accounts he or his wife controlled?

A. Yes, I did.

Q. And, so, with these tax records, you wanted to see if

there was some source of income that might explain those

substantial amounts of cash?

A. Yes.

Q. Just going to show you one of the tax returns, which

is Government's 656.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:10:44

11:10:55

11:11:07

11:11:15

11:11:29



3832

MR. COSTA: If we can go to the -- we're on the

ELMO.

BY MR. COSTA:

Q. Is this the most recent tax return you obtained for

Mr. King?

A. Yes, it is.

Q. And what is -- this first page, a lot of the jurors

or all of them are probably familiar with. What is this

first page of the -- Mr. King's 2007 tax return?

A. It's the Form 1040, U.S. individual tax return for

2007.

Q. And who are the filers? Leroy King is listed. Who

is listed in the second line?

A. Lisonyi King.

Q. Who is she?

A. That is Mr. King's wife.

Q. And it listed an address in Georgia. Do you know who

lives at that address?

A. Mr. King's wife.

Q. And is this a joint tax return?

A. Yes, it is.

Q. So it would list both of their incomes?

A. That's correct.

Q. And if we go to Line 7, what is listed as the joint

wages for Mr. King and his wife?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:11:49

11:12:12

11:12:31

11:12:41

11:12:59



3833

A. $77,252.

Q. Now, is there a place in his tax returns where you're

able to tell how much of that was his salary for being

head of the Financial Services Commission in Antigua?

A. Sure. It's on Form 2555, which is attached to the

return. And it's also reflected on Line 21, references

Form 2555, with a minusing out 70,000.

Q. Let's go to that form. If you're an American citizen

and you earn income oversees, how is that treated for tax

purposes?

A. If you live outside of the country and you earn

wages, all -- all your income is earned outside of the

country, you can -- there's -- if you meet certain tests,

part of that income can be excluded from U.S. income tax

return, which is what he was doing at Line 21 on the first

page.

Q. So Mr. King is having to tell the IRS what his salary

is in Antigua because he can exempt some of that foreign

salary?

A. Yes. And, in addition, the -- a foreign government

doesn't -- isn't going to file the form -- a W-2 with the

IRS.

Q. And going to this Form 2555, which is the

foreign-earned income form for Mr. King, does it state

what the job is that is the basis for this income he

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:13:10

11:13:26

11:13:44

11:13:57

11:14:05



3834

earned overseas?

A. Yes.

Q. And what is the job?

A. Well, it shows occupation as retired, and he was

retired from somewhere else, from Bank of America, but

his -- it shows his employer as Financial Services

Regulatory Commission in St. John's.

Q. And if we go to the second page of this

foreign-earned income document, does it show what his

salary is --

A. Yes.

Q. -- with the FSRC in Antigua?

A. Yes, it does, in Line 19, $70,000.

Q. If we went -- back on the 1040, it showed $77,000 in

income. Do you recall where that extra $7,000 in income

came from?

A. Yes. It's income from -- Mr. King's wife earned,

which is also included -- a W-2 is included for that

amount.

Q. Is that at this hospital, St. Joseph's, in Atlanta?

A. Yes, it is.

Q. $7,000?

A. Yes.

Q. And that's the only wage income they reported during

2007?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:14:17

11:14:34

11:14:48

11:15:03

11:15:29



3835

A. That's the only wage, correct.

Q. That $70,000 from the FSRC, did you obtain records in

your investigation and other information that indicated

how that money was paid?

A. Yes, I did.

Q. How was money -- the salary from the FSRC paid?

A. It appeared to be by check or direct deposit.

Q. And did you -- we just looked at 2007. But did you

do the same analysis for the prior years?

A. Yes, I did.

Q. And did you create a chart that showed Mr. King's

salary at the FSRC from the period when we did these tax

returns?

A. Yes, I did.

Q. What was the purpose of preparing that chart? What

were you trying to prepare the salary figure to?

A. Preparing the amounts of salary that reported to the

total cash that was being deposited into his bank accounts

just to compare those amounts.

MR. COSTA: And if we can switch to the

computer, Your Honor.

BY MR. COSTA:

Q. Is this the --

THE COURT: Now, that's exhibit --

MR. COSTA: 1615, Your Honor,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:15:42

11:15:47

11:16:06

11:16:24

11:16:42



3836

Government's 1615.

BY MR. COSTA:

Q. Is this the chart you prepared, Agent Young, based on

your review of Leroy King's financials and tax records?

A. Yes, it is.

MR. COSTA: If we can show the first column.

BY MR. COSTA:

Q. What is the column on the right? Explain that to the

jury.

A. That is the salaries that Mr. King reported on his

tax returns for those individual years from -- as being

paid by the FSRC.

Q. Now, for 2008 through February 2009, you have an

asterisk next to 70,000. Why is there that asterisk?

A. At the time we obtained his tax returns from the IRS,

his -- he did not file as of that time.

Q. So why did you put 70,000 with the asterisk?

A. Based on the previous years, the consistency of his

income that he reported in the previous years, in addition

to some other personnel records that I saw that didn't

indicate Mr. King had any significant increase in his

salary.

Q. And in this chart -- we're going to go through it.

But ultimately you wanted to compare that salary to what

information?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:16:50

11:17:02

11:17:19

11:17:28

11:17:40



3837

A. To the bank records.

Q. Did you first find bank records from Mr. King here in

the United States?

A. Yes, I did.

Q. How do you obtain bank records that are from banks

located in the United States in a criminal investigation?

A. With a subpoena.

Q. A grand jury can issue subpoenas for those records?

A. Yes.

Q. You can't just call the bank and you get them?

A. No.

Q. And grand jury subpoenas were issued in this case?

A. Yes, they were.

MR. COSTA: Let's go -- switch to 640-A.

Government's 640-A, Your Honor.

BY MR. COSTA:

Q. How many bank accounts did you find in the United

States that were controlled by either Mr. King or his

wife?

A. Four.

Q. Four accounts.

And how many banks were those four

accounts located?

A. Two. JPMorgan Chase and Bank of America, a checking

and savings account at both institutions.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:17:51

11:18:05

11:18:14

11:18:31

11:18:47



3838

MR. COSTA: And looking at 640-A, if we can

highlight or blow up that signature card.

BY MR. COSTA:

Q. What is this document?

A. This is the signature card for Leroy King's accounts

at JPMorgan Chase, and it's checking and a savings

account.

Q. So those are two of the accounts you found in the

United States?

A. Yes.

Q. And he opened that in 1991?

A. Yes.

Q. You've been calling it JPMorgan Chase. This says

Chemical Bank. Explain why that is.

A. When Mr. King opened the account, it was Chemical

Bank, and since mergers, acquisitions, it subsequently

became JPMorgan Chase.

MR. COSTA: If we can go to Page 4, please.

BY MR. COSTA:

Q. What is this document, Agent Young?

A. This is the signature card for Mr. King's -- Mr. and

Mrs. King's checking account and Bank of America.

Q. Is that -- we've seen the two JPMorgan. And this is

one of the Bank of America accounts?

A. Yes, it is.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:18:55

11:19:04

11:19:16

11:19:29

11:19:41



3839

Q. And checking. And then is it also a savings account

at Bank of America?

A. Yes, there is.

Q. On this checking, Mr. King and his wife are both

signatories?

A. Yes, they are.

MR. COSTA: If we can go to Page 5, next

please.

BY MR. COSTA:

Q. Is this another signature card for a bank account at

Bank of America?

A. Yes, it is. It's the signature card for the savings

account.

Q. Was there -- were these -- was the savings account

and the checking account at Bank of America combined for

any purposes?

A. It was -- the monthly statements came all in the

same -- I guess both accounts were reflected on the same

statement.

Q. And who were those statements addressed to?

A. Leroy King.

Q. And his wife?

A. Both of them. But I think some of them just had

Leroy King on them.

Q. And on this savings account, who is the signatory?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:19:55

11:20:11

11:20:30

11:20:48

11:21:06



3840

A. Mr. King's wife.

Q. And did you review records from all four of these

accounts to see how much cash was being deposited in these

accounts of Mr. King and/or his wife in the United States?

A. Yes, I did.

Q. How far back were you able to get records?

A. I believe 2003 for the U.S., for the U.S. banks.

Q. They don't keep records -- why not further back than

that?

A. Banks have document retention policies, and as things

get old, meet that -- that window, they start destroying

previous records.

MR. COSTA: Go to Page 54, please.

BY MR. COSTA:

Q. How is, Agent Young, that you're able to tell whether

cash is being deposited into one of these bank accounts?

A. Sure. On a deposit slip such as the one in front

of -- being shown, the number -- the amount is written in

the line indicated for cash 15,000. In addition, they

also -- Bank of America has cash and debit slip, which I

believe is the next page, that reflects that the

deposit -- what part of the deposit is in cash.

Q. Let's take that one at a time. Here's the deposit

ticket showing cash in the line, $15,000?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:21:15

11:21:23

11:21:34

11:21:42

11:21:50



3841

Q. And then you're saying is there a computerized record

the Bank of America gives showing how much cash is being

deposited?

A. Yes, there is.

MR. COSTA: If we can go to Page 55, the next

page.

BY MR. COSTA:

Q. Is this that computerized record you were talking

about?

A. Yes, it is.

Q. And if we look on the right where there's the printed

material, it's a little difficult to read, but what is the

first two words?

A. Cash in.

Q. So that's also how you know it's a cash deposit?

A. Yes.

Q. And in the top right, what is the entire document --

document called?

A. Cash in debit.

Q. And then it shows the amount of the cash in on that

date?

A. Yes, it does.

Q. In the bottom right -- or at the top as well in a

couple of places.

And how much was that?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:21:59

11:22:17

11:22:28

11:22:43

11:23:04



3842

A. 15,000.

Q. And is that pretty consistent for the Bank of America

records that those are the documents that show you it's

cash?

A. Yes.

MR. COSTA: Let's go to 385, please.

BY MR. COSTA:

Q. Is this a record from one of the Chase accounts?

A. Yes, it is.

Q. And is this another -- a deposit slip that similarly

breaks down cash?

A. Yes.

Q. And what's the cash amount there?

A. $9,700.

Q. Anything significant to you as an IRS agent about

that amount of $9,700 being deposited in cash?

A. Yes. It's just below the 10,000-dollar mark.

Q. What's significant about a 10,000-dollar cash

deposit?

A. Any transactions in cash greater than $10,000 must be

reported. The bank must file a report with the -- with

the -- now it's FinCEN, but it used to be the IRS --

reporting the amount and the transaction or who is making

the deposit.

MR. COSTA: If we can go to the next page.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:23:18

11:23:31

11:23:45

11:23:51

11:24:01



3843

BY MR. COSTA:

Q. And is this a computerized record based on that same

deposit showing how much cash was coming into the bank?

A. Yes, it is.

Q. The bottom right portion?

A. Yes.

Q. Cash in, $9,700?

A. Yes, it is.

Q. And did you go -- going through all these records,

make a chart showing how much cash was deposited into

these four bank accounts in the United States in the name

of Mr. King and/or his wife?

A. Yes, I did.

MR. COSTA: Go to Government's 1615, Your

Honor.

THE COURT: It's the same number as the one

before, right?

MR. FAZEL: It is.

MR. COSTA: I'm sorry. 640.

THE COURT: 6, 4, 0. You have 640-A. This is

640?

MR. COSTA: Yes, Your Honor.

BY MR. COSTA:

Q. Look at the top half for now.

Is this the list of cash deposits based on

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:24:12

11:24:22

11:24:30

11:24:40

11:24:47



3844

your review of the bank records into these four accounts

in the United States that you found for Mr. King or his

wife?

A. Yes, it is.

Q. Let's -- on the left, what is the left-hand column?

A. It's just a number.

Q. How many different transactions?

A. Yes, it is.

MR. COSTA: Can we scroll down to the bottom

and see the total amount.

BY MR. COSTA:

Q. You've done 57 cash deposits --

A. Yes.

Q. -- into these four accounts?

A. From 2003 to February 2009, that's correct.

MR. COSTA: If we can go back up, please.

BY MR. COSTA:

Q. Second column?

A. It's the date that's listed on the individual deposit

slip.

Q. And then you list which actual account this money is

coming into?

A. Yes, I did.

Q. The third column?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:24:57

11:25:08

11:25:24

11:25:45

11:26:01



3845

Q. And then the fourth column says "Total deposit."

What does that mean?

A. That's just the grand total of the deposit being

made, cash and checks.

Q. Sometimes there were checks and cash together?

A. Yes. Like the one we just looked at earlier.

Q. And then in the last column, do you isolate just the

cash that was deposited into these accounts?

A. Yes.

MR. COSTA: And if we can scroll that down.

See what that total is.

BY MR. COSTA:

Q. What's the total in the bottom right of cash deposits

into Mr. King's four U.S. bank accounts?

A. $321,075.

Q. And if you look at the last couple, for example,

9,300, 9,700, and if we scroll back up, how many instances

was there a deposit over that 10,000-dollar mark you

talked about?

A. In cash, just one.

Q. Only once over that 10,000-dollar mark that would

require a currency report to be filed with the government?

A. Yes.

MR. COSTA: Now, if we can go back to 1615,

which I've already referenced.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:26:21

11:26:28

11:26:41

11:26:57

11:27:07



3846

BY MR. COSTA:

Q. Did you -- that money we just saw, over $300,000 in

cash, being deposited in Mr. King's U.S. bank accounts,

did you break that down by year for purposes of this

chart?

A. Yes.

MR. COSTA: And if we can see that information.

One more.

BY MR. COSTA:

Q. And that's the same total of $321,075 on the chart

listing all the transactions?

A. That's correct.

Q. How did that money grow over time?

A. It increased.

Q. So the last year of 2008 plus the first two months of

2009, how much did Mr. King have deposited in cash into

his accounts?

A. $93,100.

Q. How does that compare with his salary at the FSRC?

A. That's about 23,000 more than he was reporting to be

paid by the FSRC.

Q. And again, that FSRC salary wasn't being paid in cash

from any records you saw?

A. That's correct.

Q. Were you also able to obtain records for bank --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:27:22

11:27:39

11:27:52

11:28:07

11:28:18



3847

banks account Mr. King had on the Island of Antigua?

A. Yes, there was.

Q. How did you find out that he even had these accounts

in Antigua?

A. When going through the bank statements and brokerage

account statements that Mr. King had in the United States,

you could see wire transfers coming in and going out into

these -- to Antiguan banks.

Q. Now, we mentioned for U.S. bank accounts, you can

have a grand jury issue a subpoena.

A. Yes.

Q. What do you have to do to get records from banks

located in another country, like Antigua?

A. We have to get those records through an MLAT request.

Q. What -- do you know what "MLAT" stands for?

A. Mutual Legal Assistance Treaty. And it's a request

where one government is asking another government to

provide assistance, but it goes through the diplomatic

channels.

Q. And did Antigua produce some bank records for

Mr. King in response to that request pursuant to the

treaty between Antigua and the United States?

A. Yes, they did.

Q. And how many bank accounts had you located from

looking at his U.S. bank records when you saw -- you said

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:28:34

11:28:48

11:28:58

11:29:15

11:29:34



3848

you saw those wires between U.S. and go Antiguan banks?

A. Approximately three at --

Q. Where were those locate -- what banks?

A. ABI Bank and Antigua Overseas Bank.

Q. Is there any way you have to do a comprehensive check

on whether those are actually all of Mr. King's bank

accounts in Antigua?

A. No, there's not. There's no way for me to do that,

other than to ask the Antiguan government to do it.

Q. And you just had asked for these particular bank

records; right?

A. Yes. Because those -- those accounts -- those banks

were identified through wire transfers in and out of his

U.S. bank account.

Q. And you said records were produced for both banks?

A. Yes.

Q. Did the records from both ABI and Antigua Overseas

Bank, were both banks' records sufficient to see whether

cash was being deposited into those accounts?

A. Only ABI.

Q. Why was Antigua Overseas Bank were you not able to

tell whether cash was being deposited?

A. First off, their production wasn't a hundred percent

complete, and some of the backup that -- as described on

the deposit tickets wasn't -- there was no way to -- it

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:29:47

11:29:55

11:30:11

11:30:35

11:30:52



3849

wasn't clear. There was no way to really tell what --

what the breakdown was.

Q. We saw those Bank of America and Chase records where

it breaks down cash from the deposit slips.

Did Antigua Overseas Bank give you

anything from which you could tell there was cash

deposits?

A. No.

Q. But ABI did?

A. Yes, they did.

Q. How far back did the ABI records go that allowed you

to see cash deposits in Mr. King's account?

A. Approximately 2005, even though their records that

produced for statements went back to 2002, but the earlier

years, it really wasn't clear if the deposits were cash or

checks.

MR. COSTA: Let's go to Government's 643A?

MR. FAZEL: Mr. Costa, you said 643A?

MR. COSTA: Yes, sir.

If we can just highlight the top.

BY MR. COSTA:

Q. This is ABI. Do you know with a ABI stands for?

A. I believe it's Antigua and Barbuda Investment Bank.

Q. And it shows it's located there in St. John's,

Antigua, the capital of Antigua.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:31:03

11:31:19

11:31:35

11:31:43

11:31:56



3850

And who are the accountholders?

A. Leroy King or Kecia King.

Q. And is this a statement?

A. Yes, it is.

Q. And on the statements for ABI, are you able to tell

from the statements itself whether cash was deposited?

A. From the period 2005 going forward, yes.

Q. So if we look at April 7, 2005, does it list three

cash deposits on that date?

A. Yes, it does.

Q. Now, when you're dealing with these Antiguan bank

records, what currency is being referenced?

A. Eastern Caribbean dollars.

Q. And it even says up there, East Caribbean dollar?

A. Yes.

Q. Do you see that, next to regular savings account?


Q. What's the exchange rate between East Caribbean

dollars and the U.S. dollar?

A. It's a fixed 2.7 Eastern Caribbean dollars to 1 USD.

THE COURT: How many?

THE WITNESS: 2.7.

THE COURT: 2.7 to 1 U.S. dollar?

THE WITNESS: Yes.

THE COURT: Okay.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:32:08

11:32:16

11:32:34

11:32:47

11:32:59



3851

BY MR. COSTA:

Q. So when we look at that cash deposit in April 7,

2005, 27,000 -- let's forget about the $700. But if it's

27,000 Eastern Caribbean, how much would that be in U.S.

dollars?

A. Ten thousand.

Q. You just divide the Eastern Caribbean by 2.7?

A. Yes.

Q. You said it's a fixed exchange rate.

Explain what that means.

A. It's just constantly 2.7. It doesn't -- it doesn't

fluctuate with the world markets and such, like British

pounds or like Japanese yen or anything like that.

Q. So people are used to British pounds or pesos with

their fluctuating exchange rate, this is fixed.

Throughout this whole time period you

would divide this amount by 2.7 to get U.S. dollars?


MR. COSTA: Let's go to Page 8 of this exhibit.

BY MR. COSTA:

Q. Is this another record you obtained from ABI?

A. Yes, it is.

Q. And on Mr. King's accounts?

A. Yes.

Q. And does this record actually break down the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:33:13

11:33:41

11:33:48

11:34:05

11:34:21



3852

denominations of bills he deposited into his bank accounts

in cash?

A. Yes, it does.

Q. And show where that is. Just to the right where --

A. Yeah. I guess just to the right-hand side, it shows

97/100. So 97, 100-dollar bills. And 198/50, which

would- be 198, 50 dollar bills, Eastern Caribbean dollar

bills.

Q. So it -- shows it deposited 96, 100-dollar bills, and

then it total up to 9,700?

A. Yes.

Q. And then 198, 50-dollar bills?

A. Yes.

Q. And it totals that up.

Is that 9,800?

A. It's 9,600.

Q. 9,600. And then it totals it you it up?

A. That's 9,900 -- wait a minute.

Yeah, it should be 9900, and then total of

19,600.

MR. COSTA: Let's go to Page 9 of the same

exhibit.

BY MR. COSTA:

Q. Is this another deposit slip that Mr. King put into

his Antiguan bank account?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:34:30

11:34:46

11:34:52

11:35:00

11:35:09



3853

A. Yes, it is.

Q. What was the domination breakdown of that cash

deposit?

A. It's 300, 100-dollar bills and 200, 50-dollar bills.

Q. For the total on that deposit?

A. It would be 40,000. Just checking the math because

it's --

MR. FAZEL: I'm sorry. Your Honor, is that

40,000 EC or American?

MR. COSTA: All EC.

THE WITNESS: EC.

BY MR. COSTA:

Q. Everything from the Antigua bank is going to show EC,

unless noted; correct?

A. Yes.

Q. Unless we see later on some notes where it says U.S.

dollars?

A. Yes.

Q. In some of Mr. Stanford's Antiguan Accounts?

A. Uh-huh. That's correct.

Q. But unless noted, is the Antiguan records be in EC

dollars?

A. Yes.

MR. COSTA: Let's go to Page 14, please.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:35:23

11:35:35

11:35:50

11:35:55

11:36:06



3854

Q. Is this another deposit slip for ABI Bank, Mr. King's

savings account?

A. Yes, it is.

Q. How many hundred dollar bills, Eastern Caribbean, was

he depositing in cash on this occasion?

A. Appears to be 600.

Q. 600 bills, is that something that would fit in your

wallet?

A. Not in mine.

Q. Could it fit in a briefcase, though?

A. Yes.

MR. COSTA: Do you want to break right now,

Your Honor? I can go ahead, but it's --

THE COURT: Is this a good time to break? You

tell me.

MR. COSTA: One or two more minutes, I'll

finish this topic and then we can --

THE COURT: That's fine.

BY MR. COSTA:

Q. Did you total all these can Antiguan cash deposits

into Mr. King's accounts by year, or just total them just

like you did the U.S. accounts?

A. Yes, I did.


BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:36:20

11:36:32

11:36:42

11:36:50

11:36:59



3855

Q. Is this a list of Mr. King's cash deposits into his

Antiguan bank account?

A. Yes, it is.

Q. And it shows on the left, just like the last table,

the number of transactions, the date they were made. It

lists the account.

You said the only records you had cash for

was the ABI Bank?

A. That's correct.

Q. How many accounts did he have at ABI?

A. Two.

Q. So you're listing those two -- one ends in 15 and one

ends in 35?


Q. Then you have the total deposit. If there were --

they would show even if there were checks or something

else being deposited; correct?

A. Correct.

Q. And then you break it down by cash?

A. Yes.

Q. In those Eastern Caribbean dollars?

A. Yes.

Q. In the last column, do you do the conversion to what

that would be in U.S. dollars?

A. Yes, I do.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:37:11

11:37:26

11:37:40

11:37:51

11:38:08



3856

MR. COSTA: And we scroll down to the bottom

and see what the total is, bottom right corner.

BY MR. COSTA:

Q. So in Eastern Caribbean dollars, he deposited over

$500,000 in cash from '05 through October of '08?


Q. And you convert that. It's that figure just, I

think, about $112 below $200,000?

A. Yeah, roughly.

Q. If we can go back to chart 1615, the PowerPoint.

BY MR. COSTA:

Q. Did you add this Antiguan -- these Antiguan cash

deposits onto your chart?

A. Yes, I did.

Q. And that's that $199,000 total we just saw?

A. Yes.

Q. And you broke that down by year?

A. Yes, I did.

Q. How much was deposited by Mr. King in cash just in

the last year of 2008 and the first two months of 2009?

A. 133,814 or close to $815.

Q. And if we -- then did you total the U.S. and Antiguan

cash amounts?

A. Yes, I did.

MR. COSTA: If we can get that.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:38:16

11:38:27

11:38:42

11:38:51

11:39:02



3857

BY MR. COSTA:

Q. And this chart is all in U.S. This is after the

conversion; correct?

A. That's correct.

Q. And 2003 and '04, you said you couldn't even get the

Antiguan records to show if cash was being deposited;

right?

A. That's correct.

Q. But for the records you had, how much in cash

deposits did you see into Mr. King's U.S. and Antiguan

bank accounts for the time where you could get records?

A. In U.S. dollars, $520,963.87.

Q. How does that compare to his reported salary during

that time?

A. It's about 105,000 more.

Q. And again, that salary, from everything you saw,

wasn't being paid and put into his accounts as cash;

correct, sir?

A. That's correct.

Q. So this 520,000 would be in addition to that?

A. Yes.

MR. COSTA: We can break now, Your Honor?

THE COURT: Thank you.

Ladies and gentlemen, we'll take a break.

Be back ready to resume in 15 minutes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

11:58:27

11:59:58

12:00:05

12:00:18

12:00:29



3858

May I see the lawyers up here off the

record just for a moment.

(Recessed at 11:40 a.m.)


THE COURT: 17-minute catch up. So we've got

13 minutes left to account for on your side. 13 minutes

left. All right.

Let's go, please. Call everybody in.

(The following was held in the presence of the jury)

MR. COSTA: May I proceed?

THE COURT: Yes, sir.

BY MR. COSTA:

Q. Agent Young, just before the break, we were looking

at -- I think we just finished your chart, showing

Mr. King deposited more than half a million dollars in

cash during the time period for which you could get

records?

A. Yes.

Q. Now, when Mr. Davis gave information about

Mr. Stanford giving cash bribes to Mr. King, did Mr. Davis

say which account Mr. Stanford was using to get that cash

that he was then giving Mr. King?

A. Yes, he did.

Q. What account was identified?

THE COURT: Pull that mike in, please, sir.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:00:40

12:00:48

12:00:55

12:01:11

12:01:23



3859

THE WITNESS: Okay. Sorry.

Mr. Davis identified the bank account as

Mr. Stanford's personal bank account at the Bank of

Antigua.

BY MR. COSTA:

Q. Were you able to get records in your investigation

for Mr. Stanford's personal account at the Bank of

Antigua?

A. Yes, I was.

Q. What process did you have to use to get those

records?

A. Also through the MLAT.

Q. That treaty process?

A. Yes, sir.

Q. And records were produced for Mr. Stanford's Bank of

Antigua account?

A. Yes, they were.

MR. COSTA: If we can go to 641A.

BY MR. COSTA:

Q. Look at the top portion to identify which account

these records are for.

A. It is the bank account belonging to Mr. Stanford.

Q. At which bank?

A. At Bank of Antigua.

Q. That's the bank he owned; correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:01:29

12:01:41

12:01:58

12:02:20

12:02:39



3860

A. That's correct.

Q. The commercial bank there in Antigua --

A. Yes.

Q. -- for Antiguan citizens?

A. Yes.

Q. And were you able from that account to identify how

much cash Mr. Stanford was withdrawing from that account?

A. Yes, I was.

MR. COSTA: If we can go to Page 6 of that

exhibit, please. Blow that up.

BY MR. COSTA:

Q. What type of document is this for Mr. Stanford's

personal account at Bank of Antigua?

A. It's a debit advice for a transaction, and it's for a

withdrawal of $52,000 -- 52,000 Eastern Caribbean dollars

in cash from Mr. Stanford's account.

Q. How do you know that's cash, that $52,000?

A. It references on -- I guess right above this line

here, it says, "Cash received by" and it has a signature.

MR. COSTA: If we can go to Page 34. Let's

look first at the very top one.

BY MR. COSTA:

Q. Is this another example of the withdrawal slip?

A. Yes, it is. And in this one, it says, "Your account

has been debited as per your instructions for cash."

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:02:49

12:03:02

12:03:16

12:03:25

12:03:37



3861

Q. How much?

A. 25,000 Eastern Caribbean dollars.

MR. COSTA: And if we can go to the same page,

the middle. Perfect. Thank you.

BY MR. COSTA:

Q. Is this another cash withdrawal?

A. Yes, it is.

Q. What's the date on this one?

A. May 26, 2007.

Q. And read -- can you read the writing there?

A. It says, "Account debited as per instructions.

Received from Mr. R. Allen Stanford."

Q. Do you see his initials anywhere on here?

A. Yes, I do.

Q. Where?

A. It's right at the, I guess, bottom left, RAS.

Q. Is it always Mr. Stanford's initials that appear on

these withdrawal slips?

A. No.

Q. Whose initials sometimes or signatures sometimes

appears?

A. Kenny Byron or other people who received the cash.

Q. But this one has Mr. Stanford's initials?

A. Yes, it does.

Q. And what is -- does it break down the denominations

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:03:57

12:04:11

12:04:23

12:04:38



3862

for this withdrawal and cash?

A. Yes, it does. It is 600, $100 -- Eastern Caribbean

dollar bills, and 16, $50 bills.

Q. Could those 600, $100 bills fit in a typical wallet?

A. Definitely not mine.

Q. What about in a briefcase?

A. Yes, it would.

MR. COSTA: If we could go to Page 61. The

bottom one, please.

BY MR. COSTA:

Q. Is this another cash withdrawal slip for

Mr. Stanford's account?

A. Yes, it is.

Q. And what does it say in the particulars box?

A. It says, "Your account has been debited per your

instructions via telephone conversation, Valerie/Stanford,

for EC 20,000 cash."

Q. And then under the "received by," whose initials are

there?

A. Mr. Stanford's.

Q. Did you make a chart of all the cash withdrawals, all

these slips you found, in Mr. Stanford's Bank of Antigua

account?

A. Yes, I did.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:05:01

12:05:11

12:05:29

12:05:43

12:05:58



3863

MR. COSTA: If we could go to 641.

BY MR. COSTA:

Q. Is this the chart of cash withdrawals from

Mr. Stanford's personal account at Bank of Antigua?

A. Yes, it is.

Q. Just walk through those three columns. Explain those

to the jury.

A. As the -- the first column is the date of the

transaction, the second is the amount of the withdrawal,

the cash withdrawal in Eastern Caribbean dollars, and the

third is the conversion at the 2.7 to 1 amount --

basically amount in U.S. dollars.

Q. And how far back do the records from Mr. Stanford's

Bank of go Antigua accounting?

A. 2003.

Q. Let's scroll down and see how much first was

withdrawn in cash in Eastern Caribbean dollars. What was

the total of Eastern Caribbean Caribbean?

A. 2,548,100 Eastern Caribbean dollars.

Q. And you convert that to U.S. dollars, how much is it?

A. $943,740.74.

Q. So close to a million dollars in cash in U.S.

equivalent was withdrawn from Mr. Stanford's Bank of

Antigua account?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:06:14

12:06:32

12:06:43

12:07:01

12:07:06



3864

Q. Did you compare some of the --

MR. COSTA: You can take that down.

BY MR. COSTA:

Q. Did you compare some of the withdrawals Mr. Stanford

was making in cash from his account to some of those cash

deposits into Mr. King's Antiguan bank accounts?

A. Yes, I did.

Q. Now, was there always a closeness in time?

A. No. Using the scope of the cash withdrawal and the

catch deposit within a week, I think I identified about --

just under ten.

Q. So some were identified as being close in time?

A. Yes.

Q. I want to walk through a few of those.

MR. COSTA: I've got a board. With Velcro,

Your Honor.

THE COURT: All right.

MR. COSTA: Trying to make it so we can see

that and also still see the --

THE COURT: I can't see that.

MR. COSTA: -- screen.

THE COURT: Oh, okay.

MR. COSTA: Because I want to show the records

on here, but then --


1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:07:16

12:07:29

12:07:37

12:07:54

12:08:09



3865

MR. COSTA: A little tricky.

THE COURT: Okay. That's all right. Just

leave -- the jury is the important one. Move it -- let's

see if you can get a full screen.

MR. FAZEL: With the Court -- could I move

around?

THE COURT: Yes. Yes.

What do you need?

MR. STELLMACH: The overhead light.

THE COURT: The what?

MR. STELLMACH: Light.

THE COURT: Oh, okay. You're going to leave

the screen down, right? I mean, you're going to leave the

screen off for now?

MR. COSTA: I'm going to use the screen, but I

think it will still be sufficient. Thank you.

If we can go to 641A, Ms. Gregory.

THE COURT: Tell you what I'm going to ask you

to do is slightly angle that easel, just enough where if I

lean forward I can see it, just slightly angle it a little

bit this way. That's fine. That will do it.

MR. COSTA: Okay, Your Honor?

THE COURT: Yes, I just want to see. If

there's any objection, I need to at least be able to see

it.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:08:24

12:08:36

12:08:53

12:09:15

12:09:25



3866

MR. COSTA: Government's 641A, if we could go

to Page 14. Go to the middle withdrawal slip.

BY MR. COSTA:

Q. Was this the withdrawal slips from Mr. Stanford's

Bank of Antigua account?

A. Yes, it is.

Q. And what is the date for new withdrawal?

A. It's April 6, 2005.

Q. And how much was the withdrawal?

A. In Eastern Caribbean dollars, 68,100.

MR. COSTA: Put that on the board.

Just summarizing the bank records, Your

Honor.

THE COURT: Okay.

MR. COSTA: If we can now go to 643A, which is

Mr. King's Antiguan bank account records. Page 1.

BY MR. COSTA:

Q. Do you see an April 2005 --

THE COURT: See if we can bracket it.

Yes.

BY MR. COSTA:

Q. -- deposit there?

A. Yes, there's three separate deposits on that date.

Q. And that's -- how does that compare to the day when

Mr. Stanford withdrew the cash?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:09:37

12:10:07

12:10:16

12:10:46

12:10:59



3867

A. It's the following day.

Q. And how much does Mr. King deposit?


Q. And there's three different --

A. Yes.

Q. -- denominations?

MR. COSTA: Let's now go back to Mr. Stanford's

account, 641A. Page 26. Perfect. That way we don't have

to twist our head. If we can look at the bottom one,

please, Ms. Gregory. Pull that one up.

BY MR. COSTA:

Q. What date was this withdrawal from Mr. Stanford's

bank of Antigua account?

A. June 23, 2006.

Q. And what is the amount?


MR. COSTA: And if we can now go back to

Mr. King's account at 643A. Go to Page 25, please.

BY MR. COSTA:

Q. And do we see a June 26th cash deposit June 26, 2006?

A. Yes.

Q. How much was that cash deposited into Mr. King's

account?


Q. And you said Mr. King had two accounts at ABI?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:11:10

12:11:27

12:11:39

12:11:48

12:12:01



3868

A. Yes, he did.

Q. Was there another cash deposit made that same day,

June 26th, into the other King account?

A. Yes, there was.

MR. COSTA: If we can go to Page 3 of the same

exhibit, please, the June 26th transaction. There we go.

It's at the top now.

BY MR. COSTA:

Q. How much cash was deposited into the other King

account at ABI?


Q. So Mr. Stanford on June 23, '06, withdraws 27,000 in

cash?

A. That's correct.

Q. And did you look at what day of the week that

June 23rd was?

A. Yes, I did. It was a Friday.

Q. So what's the next banking day?

A. Monday.

Q. June 26th?


Q. And those are the two deposits, cash deposits, we

just saw into Mr. King's account that total how much?


Q. The same amount Mr. Stanford had withdrawn on Friday?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:12:16

12:12:36

12:12:53

12:13:06

12:13:19



3869

A. Yes.

MR. COSTA: And one more example, if we can go

back to Mr. Stanford's account to see the withdrawals,

641A, Page 63.

BY MR. COSTA:

Q. What is the date on this withdrawal?


Q. So it's been withdrawn per telephone instructions?

A. Yes. R. Allen Stanford and Donna Cort.

Q. And how much was that for?


Q. What day of the week was that September 11, 2008?

A. Thursday.

MR. COSTA: And now if we can go to Mr. King's

account, 643A, Page 18.

BY MR. COSTA:

Q. Did Mr. King make a significant cash deposit early

the next week?

A. Yes, he did.

Q. How much?


Q. On which date?


Q. Was that the Tuesday following --

A. Yes, sir.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:13:35

12:13:50

12:14:13

12:14:26

12:14:32



3870

Q. -- Mr. Stanford's withdrawal?

A. Yes, it was.

Q. Agent Young, we've been talking a lot about cash

going into Mr. King's account and coming out of

Mr. Stanford's account. In the bank records, did you find

any actual direct transfer not through cash but through

the bank for Mr. Stanford's account to Mr. King's personal

account?

A. Yes, I did.

MR. COSTA: I'd like to show Government's 678.

BY MR. COSTA:

Q. Is this from Mr. Stanford's Bank of Antigua account

we've been talking about?

A. Yes, it is.

MR. COSTA: And if we can go to Page 3 of that

bank record.

BY MR. COSTA:

Q. There was actually a letter in the bank account -- in

the bank documents --

MR. COSTA: We can go back to the whole letter,

please.

BY MR. COSTA:

Q. Who's the letter addressed to?

A. Mr. Allen Stanford.

Q. Who sent the letter?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:14:40

12:14:56

12:15:09

12:15:27

12:15:30



3871

A. Leroy King.

MR. COSTA: Now if we can look at the top part

with the first full paragraph.

BY MR. COSTA:

Q. What's the date on the letter?

A. July 21, 2003.

Q. And what is Mr. King telling Mr. Stanford in that

first paragraph, if you can read it, please?

A. He writes: "Once again, Carnival is here, and the

Harmonites International Steel Orchestra is preparing to

take part in the Panorama competition. This year, as in

previous years, I am also assisting the Supa Stars

International Steel Orchestra. In light of the expenses

this exercise will incur, we are seeking financial

assistance."

Q. And is there a note --

MR. COSTA: Let's go down the document.

BY MR. COSTA:

Q. Does he say what the Steel Orchestra supposedly

needs, food, hotel --

A. Yes.

Q. -- other things for their trip?

A. Yes.

MR. COSTA: If we can go down.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:15:48

12:16:01

12:16:09

12:16:21

12:16:30



3872

Q. And what does the last sentence say?

A. "Any assistance you may be able to offer us in

offsetting our expenses will be appreciated. Sincerely,

Leroy King."

MR. COSTA: If we go back up to the top

right-hand corner.

THE COURT: What does the word "ambassador"

mean? Do you have any idea?

THE WITNESS: I've seen him use that title in

various correspondence. I'm not really sure if it's --

THE COURT: Official title perhaps in the

government position he held?

THE WITNESS: I'm not sure.

THE COURT: Okay.

THE WITNESS: His actual title was chairman

executive officer -- chief executive officer of the FSRC.

I'm not sure what -- the significance of ambassador.

BY MR. COSTA:

Q. But you've seen other documents where he calls

himself an ambassador?

A. Yes.

MR. COSTA: If we can go to the top right

handwritten portion of that document.

BY MR. COSTA:

Q. What does it say?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:16:43

12:16:56

12:17:05

12:17:17

12:17:25



3873

A. It says, "Pay Leroy King, EC, $27,500, per RAS."

Q. And "RAS" is?

A. Mr. Stanford's account number.

Q. What is "RAS"?

A. Robert Allen Stanford.

THE COURT: What's 27.5 in American dollars?

THE WITNESS: A little over 10,000.

BY MR. COSTA:

Q. Does it say pay the Steel Orchestra band or pay Leroy

King?

A. Leroy King.

MR. COSTA: If we can go back to the first page

of this exhibit, which is Mr. Stanford's account statement.

BY MR. COSTA:

Q. Actually see that $27,500 being taken, transferred

out of Mr. Stanford's personal bank account?

A. Yes.

Q. Is that the July 23, '03 debit advice?

A. Yes.

Q. 27,500?

A. Yes.

Q. Did that go into the account of a Steel Orchestra

band?

A. No, it did not.

Q. Whose account did it go into?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:17:35

12:17:45

12:17:49

12:18:02

12:18:12



3874

A. Mr. King's personal account.

MR. COSTA: If we can go to Page 5 of that

exhibit.

BY MR. COSTA:

Q. Whose bank statement is this, Agent Young?

A. Mr. Leroy King's bank account.

Q. At which bank?

A. ABI.

Q. One of those bank -- the records we looked at

previously?

A. Yes.

Q. With all the cash deposits?

A. Yes.

MR. COSTA: If we can go down in the right-hand

side --

BY MR. COSTA:

Q. Just the way this statement works, is the left

withdrawals?

A. Yes. The left side is the debits, withdrawals

checks.

Q. And the deposits are on the right-hand side?

A. That is correct.

Q. So do you see that 27,500 that came out of

Mr. Stanford's account going into Mr. King's personal

account the next day, July 24th?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:18:23

12:18:38

12:18:49

12:19:06

12:19:15



3875

A. Yes.

Q. And in the next couple of weeks, do you see any

amount like that going out to being transferred to a Steel

Orchestra band?

A. Not in that same amount. There's no withdrawals in

that amount.

MR. COSTA: All right. Thank you, Debbie.

BY MR. COSTA:

Q. In addition to reviewing these bank records we've

gone over, in the course of the investigation, did you

find any purchases, purchases, Mr. Stanford made of an

item from Mr. King?

A. Yes, I did.

Q. What was that item?

A. Super Bowl tickets on two separate occasions.

Q. Do you recall the years?

A. 2004 and 2006.

Q. Do you remember where the 2004, January 2004, Super

Bowl was held?

A. Houston.

Q. Who played? Do you remember that?

A. Panthers and Patriots.

Q. What happened at halftime?

A. Wardrobe malfunction.

THE COURT: Okay. Now we're all cleared up. I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:19:25

12:19:37

12:19:48

12:19:59

12:20:16



3876

was wondering which one it was.

BY MR. COSTA:

Q. The Patriots won that year; right?

A. Yes.

MR. COSTA: Let's go to 657.

BY MR. COSTA:

Q. Do you recognize this, Agent Young?

A. Yes, I do.

Q. What is it, just generally speaking? It's an e-mail?

A. It's --

Q. Is it an e-mail?

A. E-mail chain.

Q. Where in the investigation was the government able to

obtain this e-mail?

A. From the receiver.

Q. Who took over the Stanford companies?

A. Yes.

Q. And where were the e-mails maintained, the receiver

was able to provide them upon request to the FBI?

A. On their servers, I believe, located in Houston.

Q. And this e-mail is dated January 22, 2004, to

Mr. Stanford, from a woman named Linda Wingfield. Who is

Linda Wingfield?

A. Linda Wingfield was an employee of Mr. Stanford's.

MR. COSTA: If we can go to the second page.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:20:24

12:20:41

12:20:46

12:20:56

12:21:06



3877

BY MR. COSTA:

Q. Like most e-mail chains, you have to start at the

bottom if you want to go in sequence; is that right?

A. Yes.

MR. COSTA: Actually, let's go to the bottom of

the first page so we can see the date of the first e-mail

of the chain.

THE WITNESS: It's a little higher than that.

MR. COSTA: Can we go up a little bit.

Perfect.

BY MR. COSTA:

Q. This is an e-mail from Ms. Wingfield on January 22nd,

2004?

A. Yes.

Q. And she excludes a number of people including Allen

Stanford?

A. That is correct.

Q. Do you see a woman named Julie Hodge listed among

those folks?

A. Yes, I do.

Q. Who is Ms. Hodge?

A. Ms. Hodge was Mr. Stanford's personal assistant.

Q. Do you know what the office was called where

Ms. Hodge worked?

A. The office of the chairman.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:21:20

12:21:29

12:21:38

12:21:51

12:22:01



3878

Q. And who was the chairman of the Stanford companies?

A. Mr. Stanford.

Q. And the subject here is "Houston Report, Thursday,

January 22, 2004, Final."

And does it just discuss a number of

various matters here at the top?

A. Yes.

MR. COSTA: And if we now go to the second

page, which is the bottom of this e-mail. If you can blow

that up.

BY MR. COSTA:

Q. At the bottom, it says, "Super Bowl update."

What does it say there?

A. It reads: "I have found two club level tickets for

you for $8,000. Hope you didn't change your mind. I was

holding out for lower pricing, but was afraid to wait too

long."

Q. From your view of this e-mail, there were a number of

people who were copied, but who was Ms. Wingfield

directing that to when she says, "I reserved tickets -- I

found tickets for you. Hope you didn't change your mind"?

A. Mr. Stanford.

MR. COSTA: And if we go to the reply e-mail

back on the first page.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:22:28

12:22:39

12:22:45

12:22:54

12:23:11



3879

Q. Does Mr. Stanford reply to that e-mail for

Ms. Wingfield that talked about the, I think, 8,000-dollar

Super Bowl tickets?

A. Yes, he does.

Q. What does he say?

A. Mr. Stanford says, "Linda, get the Super Bowl

tickets. What is the subject in more detail about W --"

"about referring to Rodd."

Q. Is that one of those other issues that was talked

about in the e-mail?

A. Yes, it was.

MR. COSTA: So let's look at the first sentence

he writes on the left.

BY MR. COSTA:

Q. So Mr. Stanford says get the Super Bowl tickets?

A. Yes.

MR. COSTA: And if we can scroll up to the next

e-mail on the chain.

BY MR. COSTA:

Q. Is that from Ms. Wingfield replying to Mr. Stanford?

A. Yes, it is.

Q. What does Ms. Wingfield say after Mr. Stanford said,

"Yes, get the tickets"?

A. "I got the tickets."

Q. Anything in this e-mail -- these e-mails from

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:23:24

12:23:56

12:24:16

12:24:23

12:24:33



3880

January 22nd indicating the tickets are for anyone other

than Mr. Stanford?

A. No.


BY MR. COSTA:

Q. Were there more e-mails related to this subject of

the 2004 Super Bowl tickets?

A. Yes, there were.

MR. COSTA: If we can go to the second page,

again, going in sequence of the last e-mail on the second

page, which would be the earliest in time.

BY MR. COSTA:

Q. And is Wingfield receiving an e-mail in this?

A. Yes, she is.

Q. And someone at Corporate Concierges is sending it --

A. Yes.

Q. -- to Ms. Wingfield?

A. Yes.

Q. And what's the subject?

A. "Leroy King visits Houston."

Q. This is January 29th of 2004?

A. Yes, it is.

Q. So a few days after those last e-mails where

Mr. Stanford said, "Yes, get the tickets"?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:24:46

12:25:01

12:25:16

12:25:29

12:25:41



3881

Q. And what is Ms. Jensen saying about Leroy King visits

Houston?

A. She writes: "Linda, I had a phone call early this

morning from a lady named Giselle that said she was a

friend of Leroy King, the ambassador of Antigua. The call

was in reference to some Super Bowl tickets and the use of

the company kitchen and the Lotus Room. Here is her

number," and has the number. "She also said that Mr. King

would be a guest in her home and that we were supposed to

deliver the tickets to her home. She said that she

assumes that he spoke to someone in a high-level position

because he was also offered the company facilities."

And she goes on, "This is the first we've

heard of this information. Please advise instructions."

Q. And does Ms. Wingfield, if we scroll up, respond to

this query about Mr. King looking for Super Bowl tickets?

A. Yes, she does. Well, she forwards it to other

people.

Q. And is Mr. Stanford included among those other

people?

A. Yes, he is.

Q. And what is Ms. Wingfield's reaction to this news

that Leroy King is looking for his Super Bowl tickets?

A. Question marks, and she says, "Anyone there?"

MR. COSTA: Now, if we can go to the first page

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:25:59

12:26:10

12:26:28

12:26:39

12:26:53



3882

the bottom, to continue the chain.

BY MR. COSTA:

Q. This is Julie Hodge responding to Ms. Wingfield?

A. Yes, it is.

Q. And you said earlier Ms. Hodge worked in the office

of the chairman?

A. That's correct.

Q. And what does Ms. Hodge say?

A. She said, "I will ask Mr. Stanford about this and get

back to you. Leroy has been calling here all day

yesterday asking about Super Bowl tickets that RAS

promised him and RAS did speak with him last evening.

However, I will see if I can get a response as to exactly

what was offered and what we are to provide. Will let you

know."

MR. COSTA: And if we can go up to the next

e-mail after Ms. Hodge has told Ms. Wingfield about that.

We can go back down, please.

BY MR. COSTA:

Q. Ms. Wingfield responds to Ms. Hodge -- there's. And

what is the subject now.

A. It's the number 2, "Responses from RAS received."

Q. Earlier the subject was "Leroy King visits Houston"?

A. Yes.

Q. Now, there's been responses for Mr. Stanford

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:27:01

12:27:15

12:27:28

12:27:40

12:27:49



3883

received?

A. Yes.

Q. And what does Ms. Wingfield say?

A. "Thanks for your help. Let everyone know he told me

the SB tickets are for Leroy King, and that Simon cannot

purchase the truck right now. Two down, 52 to go."

MR. COSTA: If we go up to the next one.

BY MR. COSTA:

Q. What does Ms. Hodge's response to Ms. Wingfield?

A. "Wish I could get him to buy Super Bowl tickets for

me."

Q. And does Ms. Wingfield then say that, well, she can

actually help get some tickets from Ms. Hodge?

A. Yes, she does.

Q. "I can get you two if you're interested, but" --

A. "They're very expensive."

Q. Where -- do you know where Ms. Hodge, did she work in

Houston or Florida?

A. Miami, in Florida.

Q. And so then Ms. Wingfield is saying, "You and your

husband could stay at my house"?

A. That's correct.

Q. Again, this is while the Super Bowl was in Houston?

A. Yes.

Q. And what did she say the best price she could get?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:27:59

12:28:13

12:28:29

12:28:37

12:28:54



3884

A. $1,700 each.

Q. And if we go up to the next e-mail, is Ms. Hodge able

to come to the game?

A. No.

Q. And if we go back up.

Ms. Wingfield's final e-mail in this

chain, what does she say?

A. "I know. It's insane. I put them on a credit card

and figured I'll deal with it later. I really wish I

would have known the tickets I bought for RAS were not for

him. I would not have gone to so much trouble. In fact,

I was attempted to switch the good seats for my lousy end

zone, but with my luck."

Q. So the good seats ended up being for Mr. King?

A. That's correct.

Q. But Ms. Wingfield, when she bought them, hadn't been

told by Mr. Stanford they were for Mr. King, according to

these e-mails?

A. Yes.

MR. COSTA: And now let's go to Government's

659.

BY MR. COSTA:

Q. Is this an e-mail -- you already said Ms. Jensen

worked in corporate concierge?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:29:05

12:29:23

12:29:30

12:29:44

12:30:02



3885

Q. And this is sent on Friday, January 30th.

Who is this e-mail sent to?

A. To Stanford Houston, which is, I guess, like a

distribution list for Stanford employees in Houston.

Q. And what's the subject?

A. "VIP Guests of Mr. Allen Stanford."

Q. And who were Mr. Stanford's very important guests on

Friday, January 30, 2004?

A. His Excellency, Ambassador Leroy King of Antigua and

Giselle James.

Q. They'll be touring the building this afternoon as

personal guests of Mr. Allen Stanford?

A. Yes.

Q. And that's Friday afternoon?

A. Yes, it is.

Q. What was that Sunday at Reliant Stadium?

A. Super Bowl Sunday.

Q. You mentioned there were two Super Bowl tickets that

you obtained documents showing Mister -- two different

Super Bowl that Mr. King received tickets for?


Q. What was the other year after this 2004?

A. 2006.

MR. COSTA: Let's go to Government's 661.

If we can look at this e-mail on this one,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:30:18

12:30:27

12:30:38

12:30:52

12:31:03



3886

the first page is actually the earliest in time. If we can

go to the bottom portion.

BY MR. COSTA:

Q. What's the date on this one, what year?

MR. FAZEL: I'm sorry. I apologize, Your

Honor.

We would -- I'm assuming they're just

introducing this into evidence, not for the truth of the

matter asserted, because they haven't proved it up. So to

that respect, I would make my objection as I have with the

other documents.

MR. COSTA: We would offer them for the truth,

Your Honor. We have proved it up. They're statements by

Mr. Stanford's agents. Ms. Hodge, we've proved up worked

in the office of the chairman. And Ms. Wingfield was -- as

prior testimony has even established, was a direct report

to Mr. Stanford. He set up that separate office to report

directly to him. So we believe it's agent statements.

They are admissible under the hearsay exception.

MR. FAZEL: And I'm not -- and not every

statement by an individual who worked for a company becomes

an agent statement.

THE COURT: What exhibit number is this?

MR. FAZEL: This is 661.

THE COURT: 641.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:31:13

12:31:24

12:31:35

12:31:42

12:31:55



3887

MR. FAZEL: 661.

MR. COSTA: 661.

MR. FAZEL: 661.

THE COURT: And you object?

MR. FAZEL: It's hearsay, and foundation.

THE COURT: All right. I may hear from you

again.

MR. COSTA: These were not just regular

employees. Most of them were personal assistants. We can

get into business card. This one is from Laura Barlow. We

have her card in Mr. Stanford's address book. It says

"Personal assistant." I'm happy to intro -- show -- I

mean, the address book is already in evidence.


MR. FAZEL: Yes, sir.

THE COURT: I mean it's in, but it's in for all

purposes at this point.

MR. COSTA: Thank you, Your Honor.

Just based on that objection --

THE COURT: By the way, the one before that,

the last -- have I missed -- maybe I have. The last one I

have 641A and now 661.

Were there any other ones identified?

MR. COSTA: We went through 657, 658 and 659,

Your Honor, were the last three previous exhibits.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:32:03

12:32:19

12:32:33

12:32:51

12:32:57



3888

THE COURT: All right. Got them.

BY MR. COSTA:

Q. Let's talk just for a second -- we've already

talked -- this e-mail is to Julie Hodge.

Who is Ms. Hodge?

A. Mr. Stanford's personal assistant.

Q. What office did Julie Hodge work in?

A. Office of the chairman.

Q. So there was a special office just to support the

chairman of the board?

A. Yes.

Q. You said that was based in Miami?

A. From -- Ms. Hodge was based in Miami.

Q. And this e-mail is to -- I'm sorry. It's from --

it's to Ms. Hodge. It's from Laura Barlow; is that right?

A. Yes.

Q. I'll go back to 1500, which is Mr. Stanford's address

book. I don't even need to show it.

But is there a business card from

Ms. Barlow in Mr. Stanford's address book?

A. Yes, there was.

Q. And can you read what -- what does it say her

position is?

A. Executive assistant.

Q. Now looking at the e-mail, what is Ms. Barlow saying

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:33:25

12:33:40

12:33:59

12:34:13

12:34:22



3889

to Julie Hodge, who worked in the office of the chairman?

A. She writes, "Hi Julie, I have served seats for Lisa

and Leroy King per Leroy's request, but I need to buy the

tickets within 24 hours or lose the reservation. Also,

the fares are not final until the ticket is purchased, and

I have reserved the last two coach seats on the flight

they want from Detroit to Baltimore.

"Do you know if Mr. Stanford is going pay

for their tickets to the Super Bowl and their air travel?

"They want to fly Atlanta to Detroit, Super

Bowl, to Baltimore, John Hopkins, to LGA. INS for Lisa to

Atlanta. And the tickets, if bought at this time, would be

$1,297.69 each."

Q. What ticket is that talking about the, $1,200?

A. The airfare.

Q. And then what does she say in the last sentence?

A. "I put two notes on Mr. Stanford's daily reports

asking and have not heard from him. Thank you for your

help. Laura."

Q. If we go up to see if Ms. Hodge responds.

Does she forward it to someone?

A. Yes, she does.

Q. Who does she forced it to?

A. Ana Tello.

Q. And what does Ana Tello say to Ms. Hodge?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:34:41

12:34:52

12:34:56

12:35:06

12:35:26



3890

THE COURT: Who is Ana Tello?

THE WITNESS: She was hired -- at the time, she

was -- she ended up becoming the region marketing manager

for Latin America. But at the time, she was -- what she

told us was she was shadowing Julie Hodge, so she kind of

acted as the personal assistant.

THE COURT: Personal assistant to Ms. Hodge.

THE WITNESS: To Mr. Stanford. She worked with

Julie Hodge.


BY MR. COSTA:

Q. In the office of the chairman?

A. Yes.

Q. With Ms. Hodge?

A. Yes.

Q. And she's being forwarded this e-mail about King's

Super Bowl.

And what does Ms. Tello say to Ms. Hodge?

A. "I understand he has invited Mr. King in the past to

the Super Bowl, but no idea. I will try to ask him."

MR. COSTA: Now if we can go to Page 4 of this

same exhibit. And look at the bottom e-mail, please.

BY MR. COSTA:

Q. This is Ms. Barlow, again, the executive assistant

who you read the card. She sends an e-mail to Ms. Hodge

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:35:37

12:35:52

12:36:04

12:36:22

12:36:32



3891

on January 25th.

And what does she say?

A. "Hi, Julie, do you know if Mr. Stanford is going for

send Leroy and Lisa to the Super Bowl. If so, we have to

find tickets for the game and airlines today and FedEx the

tickets to him in Atlanta today. If Mr. Stanford has not

told you anything about it yet, I think I will e-mail him

with just that question because we need to tell Leroy

something today. Thank you for your help."

MR. COSTA: If we can go up to Ms. Hodge's

response.

THE WITNESS: She responds, "E-Mail him, Laura.

He wouldn't give me the time of day yesterday so I was not

able to ask. Let me know if he responds. I will keep it

at the top of my list to ask him when I get to speak with

him or see him. So keep me posted so I can cross it off he

responds. Let him know, though, the route Leroy wants in

terms of airline tickets.

"One way or the other we will get an answer

this morning."

BY MR. COSTA:

Q. That's on January 25th.

MR. COSTA: If we go to Page 2 of this exhibit.

Look at the bottom of the e-mail, please.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:36:47

12:36:53

12:37:06

12:37:18

12:37:35



3892

Q. Is that what we just saw, Ms. Barlow's e-mail to

Ms. Hodge where she's asking if -- "Do you know if

Mr. Stanford is going to send Leroy and Lisa to the Super

Bowl."

A. Yes. It's the same as the first part of the other

one.

MR. COSTA: Let's scroll up.

BY MR. COSTA:

Q. And what does Ms. Barlow then say in response?

A. "Never mind, Julie. I had my dates wrong. We don't

need to send out tickets today. He isn't leaving Atlanta

until next Friday."

Q. Who lives in Atlanta?

A. Mr. King's wife.

Q. And if we go up, there's another response.

And what does Ms. Hodge say?

A. "Okay, I will ask him today. Meanwhile can you check

with the ticket broker there and see what the ticket

options are. Last time we got him really good seats."

Q. If we go up again to the next response.

Ms. Barlow tells Ms. Hodge what?

A. "I'm looking right now. They seem to be between

2,900 each for upper level to 7,500 each for 50-yard line

club seats. I'm going to search a lot of different

sources today."

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:37:52

12:38:00

12:38:09

12:38:17

12:38:25



3893

Q. And the final response from Ms. Hodge to Ms. Barlow?

A. "He will want to club seats."

Q. And did you actually obtain in the investigation a

receipt showing the purchase of tickets for Mr. King for

the 2006 Super Bowl?

A. Yes, we did.

MR. COSTA: Go to Government 2, please.

BY MR. COSTA:

Q. Those e-mails are talking about a ticket broker;

correct?

A. Yes, it does.

THE COURT: That's Government's 2?

MR. COSTA: 2. Going down.

BY MR. COSTA:

Q. What ticket broker was used to purchase the tickets

for Mr. King to go to the -- and his wife to go to the

Super Bowl?

A. Razor Gator.

THE COURT: Pardon me?

THE WITNESS: Razor Gator.


BY MR. COSTA:

Q. What is Razor Gator?

A. It's a online ticket broker.

Q. And did Razor Gator produce this document or it's a

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:38:36

12:38:54

12:39:03

12:39:10

12:39:22



3894

response to a subpoena?

A. Yes, they did.

Q. And if we look, does it tell you when these tickets

were ordered?

A. Yes, it does. In, I guess, the lower left-hand

portion, it says they were ordered on February 2, 2006.

Q. And does it tell you below that the event, what the

date of the event is?

A. Yes. February 5, 2006, and it's the 2006 Super Bowl.

Q. Super Bowl is that XL in Roman numerals?

A. Yes.

Q. And where did the tickets end up being, what part of

the field?

A. Between the 30 yard lines.

Q. It says Ford Field.

Where was that Super Bowl that year?

A. Detroit.

Q. That's -- those e-mails talking about airline tickets

to Detroit?

A. Yes.

Q. And what is the price of those Super Bowl tickets for

Mr. King?

A. $4,500 a piece for total of $9,000.

Q. If you look right above those numbers, does it say

who's going to pick up the tickets?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:39:33

12:39:48

12:40:11

12:40:23

12:40:27



3895

A. Yes, it does, says Leroy King.

Q. And going two boxes to the left, does it say who to

bill for the tickets?

A. Yes, it does. R. Allen Stanford.

Q. And how are they going to bill it to Mr. Stanford?

A. American Express credit card in the name of R. Allen

Stanford.

Q. And did you obtain in -- in the investigation

Mr. Stanford's American Express bill?

A. Yes, we did.

Q. Does it show this purchase of $9,000 Super Bowl

tickets for Leroy King?

A. Yes, it does.

Q. Whose bill is this?

A. Mr. R. Allen Stanford's.

Q. Who does it say it should be sent to?

A. Care of Harry Failing, CPA.

Q. Who was Harry Failing?

A. Mr. Stanford's personal accountant.

THE COURT: Exhibit number?

MR. COSTA: It's part of 2.

THE COURT: It's still part of 2?


BY MR. COSTA:

Q. And do you see that 9,000-dollar charge to Razor

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:40:41

12:41:05

12:41:23

12:41:37

12:41:50



3896

Gator?

A. Yes, I do. It's on the -- what's on the screen, the

top portion February 2, 2006, Razor Gator California,

$9,000.

Q. During this period of time when all this cash you

found going into Mr. King's bank accounts and these

Super Bowl tickets are purchased for Leroy, was the SEC

corresponding with Mr. King about Stanford International

Bank?

A. Yes, they were.

Q. Going back to Mr. Stanford's address book, did

Mr. Stanford have a number of contact numbers for

Mr. King?

A. Yes, he did.

MR. COSTA: Going to Government 1500, Your

Honor. It's already been referenced.

If we can switch to the projector.

BY MR. COSTA:

Q. This is the business direct fax, cell, home,

secretary, New York home, Atlanta, U.S. cell, home, Lisa's

cell.

Who is Lisa?

A. Mr. King's wife.

Q. Down at the bottom it says "Giselle home"?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:42:03

12:42:14

12:42:24

12:42:32

12:42:57



3897

Q. Who is Giselle?

A. She was an employee -- well, she's somehow related to

Mr. King. I'm not quite sure. But she was also later an

employee of Stanford Financial Group.

Q. Was she referenced in that e-mail from 2004 when it

said Mr. King was going to be touring Stanford offices the

Friday before the Super Bowl?

A. Yes, it did.

Q. Was there -- and she was the one who was saying

someone could stay?

A. Yes.

Q. How many numbers -- did you total the number of

contacts, phone numbers, Mr. Stanford had in his book for

Leroy King?

A. Yes, I did. There's 12.

Q. And did you look through the whole address book to

compare that to Mr. Stanford's contact numbers for any

other individual?

A. Yes.

Q. Who was the only individual who Mr. Stanford had more

numbers listed for than Leroy King?

A. James Davis.

Q. And you mentioned that the SEC -- do you recall the

year that the SEC first sent a letter to Mr. King

inquiring about Stanford International Bank?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:43:07

12:43:21

12:43:28

12:44:14

12:44:28



3898

A. I think it was 2005.

MR. COSTA: And the jury's already seen

portions of that letter, Your Honor, I want to talk about.

BY MR. COSTA:

Q. Was there a response that you obtained in your

investigation that Mr. King sent back to the SEC in 2005?

A. Yes, there was.

Q. Now, was there also a response Mr. King sent back in

2006?

A. Yes.

Q. Two responses from Mr. King?

A. I believe so.

Q. I can show you the documents --

A. Okay.

Q. -- if you'd like.

I'm first going for show you

Government 669.

Is this the 2005 letter you referenced?

A. Yes, it is.

MR. COSTA: If we can display 669?

THE COURT: Is this already --

MR. COSTA: No, this is not. I think the jury

has seen the 2006, letter which is 671.

THE COURT: This is 669? Is that correct, sir?


1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:44:38

12:44:50

12:45:01

12:45:12

12:45:31



3899

THE COURT: 669.

BY MR. COSTA:

Q. And on this fax sheet, who is sending this fax?

A. Leroy King.

Q. CEO it says of Financial Services Regulatory

Commission?

A. Yes.

Q. And he's sending it to whom?

A. Ms. Elizabeth Jacobs with the SEC.

Q. And was Ms. Elizabeth Jacobs, the individual who had

sent the letter to Mr. King, requesting information about

Stanford International Bank?

A. Yes.

Q. And that letter said the SEC was investigating the

bank's CD program?

A. Yes.

Q. And what is -- if we go down there's a handwritten

note signed Leroy, "Thanks Leroy."

What does he say to Ms. Jacobs?

A. He writes, "Ms. Jacobs, kindly call me upon receipt.

Also please share with Mr. Michael Moore original document

is in the mail to you. It is always a pleasure to speak

with regulators in a different jurisdiction, and I hope we

will dialogue in the future as the needs arise. Give my

records to Michael. Thanks, Lee" -- "Leroy."

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:45:42

12:45:58

12:46:07

12:46:22

12:46:33



3900

MR. COSTA: And, now, if we go to the next

page, which is the actual letter Mr. King sends.

BY MR. COSTA:

Q. What's the date that he sends that response?

A. June 21, 2005.

Q. Is that just a couple of weeks after the letter was

received from the SEC?

A. Yes.

Q. And let's look in the third paragraph, "In your

letter."

Can you read that, please?

A. It says, "In your letter, you have outlined very

serious allegations."

Q. Very or --

A. Oh. "...very serious allegations of suspected

fraudulent activity by the Securities and Exchange

Commission in regards to the operations of Stanford Group

Company, which is supervised and regulated by the SEC, and

the Stanford International Bank, Limited, which is

supervised and regulated by the Financial Services

Regulatory Commission."

MR. COSTA: And the next paragraph? Talks

about Antigua and Barbuda.

BY MR. COSTA:

Q. Can we go to the second sentence, "We have therefore

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:46:50

12:47:00

12:47:16

12:47:35

12:47:52



3901

carefully."

A. It says, "We have therefore carefully reviewed the

contents of your letter for any grounds the FSRC should be

concerned with regarding the operations of SIBL in Antigua

and Barbuda."

Q. And then, the last paragraph of that page?

A. It says, "SIBL is examined annually for depositor

safety and soundness, as well as to ensure compliance with

International Business Corporations Acts and its

regulations, the Money Laundering Prevention Act and its

regulations and the Prevention of Terrorism Act 2001. The

bank's most recent examination was concluded in March of

this year."

MR. COSTA: And if we can go to the second

page. Blow up the second paragraph, please.

THE WITNESS: It says, "SIBL has been in good

standing with the FSRC since its inception in Antigua and

Barbuda, and there were no matters identified or issues

raised during the recent examination that would affect the

status of the bank's standing with the FSRC."

MR. COSTA: And then, if we could just blow up

the last two paragraphs of the letter from Mr. King to the

SEC.

THE WITNESS: It reads, "The FSRC has therefore

concluded that any further investigation of possible

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:48:12

12:48:24

12:48:35

12:48:46

12:48:54



3902

fraudulent activities of SIBL is unwarranted.

"The FSRC is very concerned as to why the

SEC would input such serious allegations against SIBL. It

is the opinion of the FSRC that SIBL has conducted its

banking business to date in a manner the FSRC considers to

be fully compliant."

BY MR. COSTA:

Q. Then there's another letter Mr. King writes in

response to the SEC in 2006?

A. Yes, there is.

Q. And that one the jury has already seen, so I'll move

on.

And during this time, you said the SEC had

started an investigation into Stanford International Bank?

A. Yes, they did.

MR. COSTA: If we can go to 736, please.

BY MR. COSTA:

Q. This is a fax cover sheet.

A. Yes, it is.

Q. From the Securities and Exchange Commission in

Fort Worth?

A. Yes, it is.

Q. And to whom is it addressed?

A. Mr. Thomas Sjoblom.

Q. Does it list his law firm?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:49:07

12:49:18

12:49:35

12:49:44

12:49:51



3903

A. Yes, it does. Proscauer Rose.

Q. What was Mr. Sjoblom's role?

A. He was the attorney for the bank.

Q. Was he related to the SEC investigation?

A. Yes, he was.

Q. So this is faxed from the SEC to the Mr. Sjoblom?

A. Yes.

MR. COSTA: Let's look at the attachment on the

second page?

MR. FAZEL: Your Honor, I'm sorry. I'm going

to object to this being hearsay as well, and foundation. I

don't think this witness can testify as -- without going

into hearsay as to who these people are and what they did.

He would have to give hearsay information in order to be

able to do that.

MR. COSTA: Your Honor, all this is, is a

notice of the investigation. It's to show on the

obstruction count that there was actually an investigation

pending. So it doesn't go to the truth of any of the

statements alleged in there, just that there was in

existence an SEC investigation. That's all it is.

MR. FAZEL: And the witness has testified to

that.

THE COURT: As for that limited purpose,

overrule the objection.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:50:19

12:50:34

12:50:49

12:51:02

12:51:21



3904

BY MR. COSTA:

Q. And is there a date for this document that says

"United States of America before the Securities and

Exchange Commission"?

A. Yes. It's October 26, 2006.

Q. And in the matter of Stanford Group Company, what

does this nonpublic order say, on the right-hand side?

Order --

A. It's directing a private investigation and

designating officers to take testimony.

Q. So this is what was being faxed to Mr. Sjoblom, the

bank's outside lawyer?

A. Yes.

Q. And how would the SEC or any other agency try to

compel testimony?

A. By issuing a subpoena or, in the IRS case, a summons.

Q. And were there subpoenas issued by the SEC in

connection with this investigation?

A. Yes, there were.

MR. COSTA: Go to 733.

BY MR. COSTA:

Q. What is this, Agent Young?

A. It's the SEC subpoena directed to Mr. R. Allen

Stanford.

Q. In care of that same lawyer we talked about?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:51:41

12:51:52

12:52:03

12:52:14

12:52:40



3905

A. Yes, care of Mr. Thomas Sjoblom.

Q. And they're asking -- checked boxes to produce both

records and testify when?

A. Produce records of -- by Friday, June 29, 2007, and

testify Friday, September 21, 2007.

MR. COSTA: And if we go to Government 735.

BY MR. COSTA:

Q. Do you know if Mr. Stanford showed up in 2007 to

testify?

A. He did not.

Q. Is this another subpoena from the Securities and

Exchange Commission?

A. Yes.

Q. To Mr. Allen Stanford?

A. Yes, it is.

Q. Asking him to testify when?

A. February 6, 2009, a Friday.

Q. Who ended up testifying in February 2009 before the

SEC instead of Mr. Stanford?

A. Laura Holt.

Q. As part of your investigation, did you discover any

documents from Mr. King that were in the Stanford

Financial Group offices in Houston, Texas?

MR. FAZEL: I'm sorry. May we approach real

quick?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:52:56

12:53:05

12:53:17

12:53:27

12:53:37



3906

THE COURT: Come on up.

(The following was held at the bench)


MR. FAZEL: Judge, here's my concern about the

testimony that was just elicited about him testifying

before the SEC.

THE COURT: Who's testifying?

MR. FAZEL: Mr. Stanford. The government asked

whether Mr. Stanford testified, and he said no.


MR. FAZEL: The problem is that Mr. Stanford

has an absolute Fifth Amendment right not to testify. And

by leaving it out to the jury like that, it puts us in a

bad spot, because now we have a position where we're saying

that our client -- in other words, I have to go into the

fact that my client has a Fifth Amendment right not to

testify.

THE COURT: So what do you suggest?

MR. COSTA: Can I respond?

THE COURT: Well, no. Let me hear what he

says.

MR. FAZEL: Frankly, I'm trying to think

through my head what the best way to do this. The

information elicited was hearsay. His -- this -- this --

THE COURT: Which information was hearsay?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:53:48

12:54:02

12:54:15

12:54:31

12:54:38



3907

MR. FAZEL: Well, see, this witness doesn't

have direct knowledge of whether Mr. Stanford testified.

THE COURT: He's doing it from the records.

Within his special capacity. Okay. I'm thinking through

my own head. Go on. True.

MR. FAZEL: And, so, my first position is this

witness ought to not testify about anything like that.

And my second problem is, now that he has

testified that my client didn't testify at a SEC

proceeding, it puts me in a bad spot, because now my client

has an absolute right not to testify if he doesn't want to.

THE COURT: Okay. Government's position?

MR. COSTA: Well, it's nothing about testifying

in a criminal case. One of the allegations of obstruction,

which Mr. Davis explained, is that they decided instead of

Mr. Stanford and Mr. Davis going in, even though they're

the ones who -- really only knew the contents of Tier 3,

that they put Ms. Holt up to it who didn't know anything.

That's been one of the core obstruction allegations.


MR. COSTA: And that's all I brought out, that

Ms. Holt instead of Mr. Stanford or Mr. Davis.

THE COURT: Now, the question is does

Mr. Stanford in your mind, not the government, have the

right not to testify, the SEC or he could go into Fifth

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:54:47

12:54:55

12:55:01

12:55:10

12:55:20



3908

Amendment?

MR. COSTA: Of course, you can take the Fifth

Amendment in any context.

THE COURT: So what's your response to his --

MR. COSTA: But it's still obstruction when

they misled the SEC into thinking that Ms. Holt was the

most knowledgeable about Tier 3.

THE COURT: That's your argument.

MR. COSTA: Right.

MR. FAZEL: And it's also --

MR. COSTA: But that's an allegation in the

case.

MR. FAZEL: I understand that. And I'm sorry

to interrupt you. But that's something they can elicit.

There's a difference between eliciting that type of

testimony whether who had more understanding or more

knowledge of the tiers versus whether a client testified or

didn't testify.

THE COURT: I understand. So what's your

suggestion? You tell me.

MR. COSTA: Mr. Davis had already said, and it

wasn't objected to, that neither he nor Mr. Stanford showed

up, so I don't see this is any different than --

THE COURT: You're bringing it up now.

MR. FAZEL: And just for the record -- and I'll

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:55:34

12:55:44

12:55:58

12:56:10

12:56:15



3909

get to -- the difference is that there was no allegations

of subpoenas being issued. Subpoena requires compulsory --

MR. COSTA: They were brought up by Mr. Davis.

MR. FAZEL: They were offered.

THE COURT: Wait a second. I want to know what

your -- what do you want me to do or what do you want to

do, take him on cross or do you want to take him right now

on voir dire and bring that point out. You tell me. What

do you want to do?

MR. FAZEL: I don't know how to fix this one.

THE COURT: Unless you want to do it after the

lunch break. But this is something we can do, we can get

it done -- there's a number of ways. They can bring it out

and say we know he has an absolute right not to testify; he

could be called to take the Fifth, yes; I could do it as an

instruction; you could take him on voir dire right now and

bring that out and then sit down or you can do it when you

take him on cross-examination. We've got a whole bunch of

options.

MR. COSTA: Your Honor, he never did take the

Fifth. That wasn't the reason he asserted for not

testifying.

THE COURT: I'm just saying he has a right not

to testify.

MR. COSTA: Agreed.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:56:23

12:56:31

12:56:38

12:56:44

12:56:54



3910

THE COURT: Okay.

MR. COSTA: But they convinced the SEC that --

his lawyer, Mr. Sjoblom, convinced the SEC that Ms. Holt

was better -- a better witness. So he never asserted the

Fifth.

THE COURT: You can get into that later. He's

got a Fifth Amendment concern, I'm going to address it,

okay? So what do you want to do?

MR. FAZEL: Well, can I ponder it while --

because he's about to -- we're about to hit lunch. So can

I ponder it with the other lawyers?

THE COURT: Yes.

MR. FAZEL: I don't know how to -- I'm thinking

about it.

THE COURT: These are the options as I see it.

If you think of other options, okay. I'll lay them all

out. I think there are four options.


THE COURT: Tell me when we get back.


THE COURT: What I'm going to do, I'll tell you

right now, I'm going to stop the clock and I'm going to --

as soon as we get out, I'm going to run the clock

13 minutes and then come back in and turn it off. So I'm

going to keep your time going for 13 minutes, and you'll be

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

12:57:05

12:57:10

12:57:38

02:19:19

02:19:32



3911

caught up.

You still have a minus 30 on your side.

MR. FAZEL: Okay.

MR. COSTA: Are we breaking now?

THE COURT: Pardon me?

MR. COSTA: Are we breaking now?

THE COURT: Yes.

Let me set my alarm watch and then turn it

back on. That's the first thing. Okay.


THE COURT: Ladies and gentlemen, we just want

to discuss something and have the attorneys be able to

discuss it over the noon hour. So what we plan to do

now -- what we're going to do now is take a lunch break

now. It's a couple of minutes ahead of time. See you back

ready to resume at 2:15. So we'll see you at that time.

(Recessed at 12:58 p.m.)


THE COURT: Did you want to see us -- there was

something we needed to discuss; right?

MR. FAZEL: Yes, Honor, it was just a matter of

the instruction.

THE COURT: And? Be seated, if you want to.

Just hang lose. Let's see. That's a legal term, "hanging

lose."

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:19:36

02:19:46

02:20:00

02:20:12

02:20:23



3912

Would you tell them we're out here. Be

with them in a couple of minutes.

MR. FAZEL: It's going to be real quick, Your

Honor.

THE COURT: Yes.

MR. FAZEL: I guess our position is perhaps

instruct the jury to disregard all testimony regarding

Mr. Stanford testifying or not testifying before the SEC.

MR. COSTA: Your Honor, it's part of our core

obstruction allegations, which Mr. Davis detailed without

any objection, that they -- Mr. Davis and Mr. Stanford were

subpoenaed and instead they offered up someone with no

knowledge of Tier 3.

THE COURT: How about they are to disregard

what they've heard up to this point about Mr. Davis, about

Mr. Stanford testifying and not testifying before the SEC,

or it may come in through additional questions?

MR. COSTA: What about Mr. Davis's --

THE COURT: Your testimony.

MR. COSTA: I get to testify?

THE COURT: No. No, your question.

MR. FAZEL: Can I cross him?

THE COURT: The position was to disregard the

testimony so far as to Mr. Stanford appearing or not

appearing before the SEC, but that doesn't state that we're

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:20:36

02:20:45

02:20:55

02:21:05

02:21:15



3913

not going to go into it with additional questions perhaps

or something like that.

MR. COSTA: I don't want to have them disregard

what Mr. Davis said about --

THE COURT: No, I made that -- I made a

mistake.

MR. FAZEL: You mean with this witness?

THE COURT: With this witness, just this

witness. Although we may go into it, the government may go

into it with a different set of questions, okay? Any

problem with that?

MR. FAZEL: I don't, Your Honor. The question

is: If the government is going to talk about whether he

testified or not, I think there's an inherent problem with

his Fifth Amendment right not to testify.

THE COURT: Well --

MR. COSTA: He never asserted a Fifth. I would

agree if he asserted a Fifth. There might be an issue if

he asserted the Fifth Amendment right before the SEC.

That's not what happened. His lawyer --

THE COURT: And you have a reason -- at least

you want to get a reason in why they sent Ms. Holt?

MR. COSTA: Right. Well, Mr. Davis already

said it was because they wanted -- Mr. Stanford and him

knew the most about Tier 3, but they wanted to send someone

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:21:24

02:21:34

02:21:44

02:21:56

02:22:08



3914

else in.

MR. FAZEL: Well, he can easily do that by

saying Ms. Holt testified without going into whether

Mr. Stanford testified.

THE COURT: I'm doing it one point now at a

time; right?


THE COURT: Right now I'll state up to this

point, question by the government, relevant to Mr. Stanford

testifying or not testifying before the SEC. Disregard

that. They may go into it from a different direction.

MR. COSTA: As far as I can agree with -- with

this witness?

THE COURT: Absolutely.

MR. COSTA: Okay.

THE COURT: Absolutely. It's just what the

alleged -- alleged -- and I'm not sure I agree with the

defense -- but the alleged impression as to that last

question. And you can now get around it, you know what the

concern is.

Let's call the jury in. Now, that took

two minutes, and I have not started the clock on you. I'll

catch up-to-date on that number.

MR. FAZEL: Take your time, Your Honor.

THE COURT: All right. I'll take my time.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:23:10

02:23:30

02:23:46

02:23:53

02:24:06



3915

Thank you.

MR. FAZEL: We're here to help.


THE COURT: Ladies and gentlemen, just a short

instruction. There was a concern concerning the

phraseology of a government question to this witness,

relative to Mr. Stanford testifying or not testifying in

front of the SEC. You are to disregard that question. And

I don't know if we had an answer. We'll get into it at the

government's option a little bit differently with questions

phrased a different way. But you are to disregard the

question and whatever answer may have been forthcoming at

this time. And that just so the record -- disregard it,

and the government at its option may go into that subject,

but we're dealing with phraseology. So out of an abundance

of caution, you're so instructed.

Go right ahead sir.

MR. COSTA: Thank you, Your Honor.

BY MR. COSTA:

Q. Agent Young, before lunch, we saw these two subpoenas

issued in different years to Mr. Stanford to testify

before the SEC. Do you remember that?

A. Yes, I do.

Q. Who did appear in February 2009 to testify before the

SEC about Stanford International Bank's bank investment

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:24:17

02:24:32

02:24:49

02:25:06

02:25:15



3916

portfolio?

A. Laura Holt.

Q. Are you -- are you generally familiar with the

transcript of what she told the SEC?

A. No, I haven't reviewed it.

Q. Are you familiar with whether she told the SEC about

the full contents of Tier 3 of the investment portfolio?

MR. FAZEL: Judge, I'm going to object. Number

one, he's not familiar with it; and, number two, it asks

for hearsay testimony.

THE COURT: Well, during his investigation --

MR. COSTA: It's not for the truth, it's

whether she did divulge the contents of Tier 3.

THE COURT: Sustain the objection. Unless you

can show somehow else he found out that's admissible just

for the matter of how we went forward, but if he said he

didn't read the transcript, we can't go into the contents

of that unless some other predicate is laid as to how he

may have some valid information that he acted or failed to

act upon.

BY MR. COSTA:

Q. Did you learn generally whether the SEC was given

full details about Tier 3 of the investment portfolio in

February 2009?

A. It would not.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:25:30

02:25:43

02:25:56

02:26:12

02:26:25



3917

Q. Let's go on to another subject that we just started

talking about before lunch. You said as part of your

investigation you went to the Stanford offices in Houston

and reviewed documents?

A. Yes.

Q. Was this after the receiver had taken over the

companies?

A. Yes, this was, I believe, in April of 2009 after the

receiver had taken over the companies.

Q. And had the receiver allowed you and other law

enforcement agents to come on the premises and look for

records related to the criminal investigation?

A. Yes, they did.

Q. Was there also a Court order from the federal judge

in Dallas talking about the receiver cooperating with law

enforcement?

A. Yes, there was.

Q. I'm showing you government's --

(Attorneys conferring)

MR. FAZEL: Judge, real quick. Just one

second.

THE COURT: You want to come up here?


THE COURT: Okay.

MR. FAZEL: Judge, I'm just renewing my motion

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:26:39

02:26:47

02:26:55

02:27:03

02:27:18



3918

to suppress. I know you've overruled it, but I don't want

to waive it. This is stuff they got from the receiver

without a -- without a warrant, and the Court's already

ruled on it, but I'm going to renew it -- the motion on the

record saying that they should be suppressed.


MR. FAZEL: Yes, sir. Thank you, Judge.


BY MR. COSTA:

Q. Agent Young, I'm going to hand you what's marked as

Government 616 and ask you if you recognize that.

A. Yes, I do.

Q. Who found that document at the Stanford Financial

Group --

A. I did.

Q. -- headquarters in Houston?

A. I found it.

Q. Where did you find it?

A. It was contained in file cabinets located in the

basement of the Stanford Financial building.

MR. COSTA: Your Honor, if we could switch to

the -- this ELMO device.

THE COURT: Hang on.

BY MR. COSTA:

Q. And what type of -- these documents are in what type

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:27:30

02:27:37

02:27:46

02:27:54

02:28:09



3919

of container or device?

A. A file folder.

THE COURT: Excuse me. Do we have that

identified -- just identified --

MR. COSTA: Not previously, 616.

THE COURT: Okay.

BY MR. COSTA:

Q. And is there a tab that describes the contents?

A. Yes, there is.

Q. What does that tab say?

MR. FAZEL: Your Honor, at this time I'd object

to hearsay on this document.


MR. FAZEL: Foundation.

THE WITNESS: It says, "RAS matters, King

Leroy."

BY MR. COSTA:

Q. "RAS," again, is Robert Allen Stanford's initials?

A. Yes.

Q. And then there's a number of documents in this file

with a clip at the top. In chronology where are the

earliest documents in time?

A. On the bottom.

Q. So these were placed in as they came in --

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:28:23

02:28:34

02:28:53

02:29:02

02:29:15



3920

Q. -- according to the dates?

A. Uh-huh.

Q. And generally speaking, who is the correspondence in

this file labeled "RAS matters Leroy King"? Who is the

correspondence between?

A. Mr. Leroy King and Mauricio Alvarado.

Q. And who is Mr. Alvarado?

A. The general counsel for Stanford Financial Group.

MR. COSTA: If we can go -- now we can switch

back, Your Honor, to the computer.

BY MR. COSTA:

Q. There are a series of faxes back and forth from the

general counsel, Mr. Alvarado, to Mr. King.


THE COURT: If we can go back to the document,

please.

BY MR. COSTA:

Q. Does this fax coversheet appear to be the first fax

in the sequence?

A. Yes.

Q. And at the top it's to Mr. Alvarado?

A. Yes, it is.

Q. And from the fax number at the very top, are you able

to tell where the fax came from, what country?

A. Antigua.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:29:32

02:29:55

02:30:15

02:30:31

02:30:43



3921

Q. If we can go back to the old document. And if -- is

there a message written on the fax coversheet?

A. Yes, there is. It reads --

Q. Go ahead?

A. -- "My good friend, I have sent you three sets of

documents, (a)(1) deals with the affiliate issue, three

pages; B, an MOU, originating from FSRC to ECCB for

consideration, nine pages; C, ECCB, embellishment of what

was sent to them with additional input to include the

central government with powers they wish to co-op. That,

I am totally not in agreement with. Best personal

regards, Lee." But on the side it says 12s pages to

include cover letter.

Q. And what is -- it references the ECCB. What is the

ECCB?

A. That is the Eastern Caribbean Central Bank.

Q. What is the Eastern Caribbean Central Bank?

A. They're similar to the Federal Reserve in the United

States where they regulate the currency, and they also

were the regulators for domestic banks in the Caribbean in

those Caribbean countries.

Q. What about those Eastern Caribbean dollars we talked

about, that currency, who issues those?

A. The ECCB.

Q. So does the Eastern Caribbean Central Bank cover more

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:30:55

02:31:04

02:31:12

02:31:30

02:31:42



3922

than just Antigua?

A. Yes, they do.

Q. Other countries in the Eastern Caribbean?

A. Yes, I believe it was -- I saw. It was about eight

different countries or so.

Q. And all those different countries use these Eastern

Caribbean dollars?


Q. And you said the Eastern Caribbean Central Bank,

which is more -- covers more than just Antigua, it

regulates domestic banks in Antigua?

A. Yes.

Q. And these other islands?

A. Yes.

Q. What domestic bank did Mr. Stanford own in Antigua?

A. Bank of Antigua.

Q. And we're going to go into a little bit of what these

documents are about. At this time -- what year were these

documents being sent?

A. 2005.

THE COURT: Who are they addressed to, again?

It says, "My good friend."

THE WITNESS: It's being sent to Mauricio

Alvarado, the general counsel for Stanford Financial Group.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:31:52

02:32:16

02:32:32

02:32:42

02:32:53



3923

Q. I'm going to try to refresh your memory about when

these documents were sent.

A. Okay. June 2006.

Q. And we're going to go into the letters. But what was

the Eastern Caribbean Central Bank asking Mr. King and his

agency in Antigua for information about during 2006?

A. They were asking for information about -- concerning

affiliates of banks -- affiliates of banks that the FSRC

regulated and --

Q. Well, affiliates of banks --

A. Well, actually, banks the ECCB regulated that the

FSRC had regulatory control over. So they were asking for

information on Stanford International Bank because it was

an affiliate of Bank of Antigua.

Q. Let's break that down. The ECCB regulated which bank

that Mr. Stanford owned in Antigua?

A. Bank of Antigua.

Q. That's the commercial bank limited to Antiguans --

A. Yes.

Q. -- to have checking accounts and take out home loans?

A. Yes.

Q. The FSRC -- who directly regulated Stanford

International Bank throughout its histories?

A. The FSRC.

Q. Which is just in Antigua?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:33:05

02:33:16

02:33:29

02:33:45

02:33:56



3924

A. Yes.

Q. But this larger -- this regulatory body that covered

the Eastern Caribbean, in 2006, what bank did they want

information about in addition to Bank of Antigua?

A. Stanford International Bank.

Q. And why did they want information about Stanford

International Bank?

A. Because of the common ownership.

Q. Because it was an affiliate --

A. Yes.

Q. -- of the Bank of Antigua that they did regulate?

A. Yes.

MR. COSTA: Let's go to Page 22. I'm sorry.

Let's go to Page 20 first. If we can highlight this.

BY MR. COSTA:

Q. Is this the letter from the Eastern Caribbean Bank

dated July 11, 2006.

A. Yes, it is.

Q. And this Eastern Caribbean regulator was sending it

to whom, which agency?

A. The FSRC.

Q. And it's regarding affiliates of Bank of Antigua,

Limited?


Q. And it says, "We are currently creating a database on

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:34:15

02:34:21

02:34:33

02:34:46

02:35:10



3925

affiliates of commercial banks operating in the Eastern

Caribbean currency union. This information is required to

facilitate consolidated supervision where the affiliates

are being supervised by another regulator."

Is that the consolidated supervision that

they were seeking over Stanford International Bank?

A. Yes.

Q. Okay.

MR. COSTA: If we scroll down.

BY MR. COSTA:

Q. Does it provide a definition of an affiliate?

A. Yes, it does.

Q. And what does D say an affiliate would include?

A. "Any company which has common ownership with F,"

which is the financial institution.

Q. So does Bank of Antigua have an affiliate

relationship -- was it owned by the common owner with

Stanford International Bank?

A. Yes, it did.

MR. COSTA: If we can go now to Page 22. If we

can highlight the top paragraph, please.

BY MR. COSTA:

Q. And it's asking for assistance in obtaining a list of

affiliates of Bank of Antigua, and then it asks for

information about the structure of these affiliates?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:35:38

02:35:47

02:36:01

02:36:25

02:36:38



3926

A. Yes.

MR. COSTA: And if we can go down, Mr. King has

a note at the bottom that he included on this fax.

BY MR. COSTA:

Q. Is that Mr. -- whose signature is that at the bottom?

A. Lee. Appears to be --

Q. Who is Lee?

A. Leroy King.

Q. And he's addressing this to Ms. Richardson and

another individual.

What does he say in that?

A. "Kindly draft the response to say to our friends at

ACB that Bank of Antigua is a standalone Antiguan

institution. I don't recall that they are a sub of any

institution we regulate. I am sure he is aware that both

SIBL and Bank of Antigua has a singular shareholder;

however, both institutions operate on distinct platforms

with its own management structure and an independent

board. Thanks, Lee."

Q. And this is all the information that Mr. King is

faxing to Mauricio Alvarado, the general counsel of

Stanford Financial?

A. Yes.

Q. Did you obtain an e-mail in which Mr. Stanford was

discussing this issue of the Eastern Caribbean Central

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:36:49

02:37:04

02:37:15

02:37:29

02:37:51



3927

Bank trying to get information about Stanford

International Bank because it was an affiliate of Bank of

Antigua?

A. Yes, I did.

Q. And we're going get to that in a minute. But was --

what was Mr. Stanford's position about allowing the

Eastern Caribbean Central Bank to get more information in

this coordinated supervision of SIB?

A. Mr. Stanford didn't want -- didn't want that to

happen.

Q. And were those e-mails to Mr. Stanford from prior to

this fax being sent to Mr. Alvarado?

A. No.

Q. What was the relation in time?

I can show you?

A. I believe it was shortly after.

Q. One of the e-mails dated from Mr. Stanford.

A. July 2006, right around the time.

Q. What's the date?

A. July 7, 2006.

Q. And what was the date on this fax?

We can go back to Page 18.

A. I believe it was July -- July 30, 2006.

Q. So this fax is after Mr. Stanford has already

expressed his concerns about this --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:38:01

02:38:10

02:38:24

02:38:40

02:38:51



3928

A. Yes.

Q. -- attempt by the Eastern Caribbeans to regulate --

to get information and have coordinated supervision of

Stanford International?

A. Yes.

Q. Did Mr. Alvarado respond to Mr. King's fax?

A. Yes, he did.

MR. COSTA: Go to Page 14, please.

BY MR. COSTA:

Q. Is this the fax that was sent back to Mr. King?

A. Yes, it is.

Q. And what is Mr. King being told?

A. "Per our conversation on the subject, attached please

find a draft response letter for your review. Thanks. I

hope the family is doing well."

Q. And if we go to the next page, what was Mr. Alvarado

providing Mr. King?

A. A draft of a response for Mr. King to send to the

ECCB.

Q. If we go to the second page, who is that letter going

to be from?

A. Leroy King.

Q. But it's being drafted right there in Stanford

Houston headquarters?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:39:07

02:39:26

02:39:47

02:40:00

02:40:10



3929

Q. And generally speaking -- look at the paragraph we

have up.

In the middle of that paragraph, it says,

"As such. If you can read starting there.

A. "As such, we are not required to, and are indeed

mandated not to have consolidated supervision of the

standalone institutions we supervise with those supervised

by another regulator. Furthermore, the applicable

legislation provides all international banks operating

under the IBC Act with higher standards of confidentiality

protections than those applicable to regular commercial

banks."

Q. So in this letter with Mr. King's name on it that was

drafted in Stanford's Houston offices, is Mr. King

supporting or opposing the Eastern Caribbean regulators'

attempt to have consolidated supervision of Stanford

International?

A. Well, as it's written from Mr. King, he'd be opposing

it.

Q. Did Mr. King respond to these drafts that

Mr. Alvarado sent to him?

A. Yes, he did.

MR. COSTA: Can we go to Page 8, please.

BY MR. COSTA:

Q. Is that just the fax transmission sheet?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:40:23

02:40:26

02:40:36

02:40:52

02:41:02



3930

A. Yes.

Q. What date is shown?

A. August 1st.

MR. COSTA: And if we can go to the next page,

Page 9.

BY MR. COSTA:

Q. Is that if --

MR. COSTA: Let's not highlight anything yet,

please.

BY MR. COSTA:

Q. If we look at the letter, is that similar to the

draft that Mr. Alvarado had sent down to Mr. King.

A. Yes, it is.

Q. And are there some notes made at the top?

A. Yes, there is.

MR. COSTA: If we can highlight the handwritten

notes, please.

BY MR. COSTA:

Q. And who does Mr. King address his notes to?

A. Mr. MA.

Q. What does he say -- what does he call him?

A. Oh, "America's best and greatest attorney."

Q. And then what does he say? Mister --

A. MA.

Q. Whose initials are that?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:41:14

02:41:28

02:41:40

02:41:57

02:42:15



3931

A. Mauricio Alvarado.

Q. And what does Mr. King write?

A. "I am sending you two versions, one short, one long

with a little more knock-out punch. I prefer the shorter

version, a little more subtle and diplomatic."

Q. And then does he say there is Version A, which is two

pages attached, Version B is three pages?

A. Yes.

Q. And he talks about what some of those edits were?

A. Yes.

Q. If we go to Page 13, is this the end of this fax with

the two responses Mr. King sent?

A. Yes, it is.

MR. COSTA: And if we can blow up the

handwritten note again from Mr. King.

BY MR. COSTA:

Q. And if you can read that, Agent Young?

A. Okay. It says Paragraph 5 or V.

"I would like to include, but it does not

seem to flow to well with the above. Don't want an

overkill or to seem too arrogant. They believe I am

already; but you know in this business you have to be

positively arrogant. (Laugh). Any other ideas? Must

conclude tomorrow. Will send a package to include a copy

of the annual reports for SIBL and STCL. I am sending a

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:42:34

02:42:47

02:42:59

02:43:14

02:43:25



3932

message to these guys that institutions concerned are not

run of the mill. They are, in fact, quality institutions,

and the numbers speak for themselves. Please do not bill

me (laugh). Thanks a million, Lee."

Q. "Please do not bill me (laugh.)"

You said this is from the summer of 2006?

A. Yes.

Q. That's the same year we saw earlier in this year in

2006 when Mr. Stanford bought the 9,000-dollar Super Bowl

tickets for Mr. King?

A. Yes.

Q. And then if we go to Page 5, does Mr. Alvarado send a

response to Mr. King?

A. Yes, he does.

Q. And what does Mr. Alvarado say?

A. "Attached is a revised draft letter. Please let me

know if you need anything else. Thanks."

Q. So Mr. Alvarado is making more revisions to this

letter Leroy King is going to sign and send to the Eastern

Caribbean regulator?


MR. COSTA: And then if we go to Page 1.

BY MR. COSTA:

Q. Is there yet another fax Mr. Alvarado sends Mr. King?

A. Yes, there is.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:43:39

02:43:52

02:44:06

02:44:21

02:44:33



3933

Q. And what does Mr. Alvarado say he's done to the

letter that's supposed to be from Mr. King?

A. "We have taken your version and taken the liberty to

soften paragraph V. Please let us know what you think.

Thanks."

Q. And all those documents and faxes we just looked at

were in this file titled "RAS Matters, Leroy King"?

A. Yes, they are.

Q. Now, you mentioned an e-mail on this same subject,

some e-mails that you obtained that were sent by

Mr. Stanford?


MR. COSTA: If we can go to government 677.

Just highlight the top portion. Perfect.

BY MR. COSTA:

Q. Is Mr. Stanford receiving this e-mail? To

Mr. Stanford?

A. Yes.

Q. And who's sending it?

A. Carlos Loumiet.

Q. Who is Mr. Loumiet?

A. Mr. Loumiet is an attorney for Mr. Stanford's bank.

Q. For Stanford International?

A. Yes.

Q. Is he based in Miami?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:44:41

02:44:50

02:45:02

02:45:20

02:45:31



3934

A. Yes, he is.

Q. At the time was he at a law firm called Hunton &

Williams?

A. Yes, he is -- I mean he is now.

Q. Or he was then. If you look at the --

A. Yeah.

Q. Let's go back to the broader e-mail. If you look at

the -- signature line?

A. Yes, he was -- at the time, he was.

Q. And this is dated July 7, 2006.

Is that before all those faxes we saw?

A. Yes.

MR. COSTA: If you can blow up the paragraph

now, please.

BY MR. COSTA:

Q. What is Mr. Loumiet telling Mr. Stanford?

A. "I'm certainly not an Antiguan/Eastern Caribbean

lawyer, but I saw nothing in there allowing any imposition

of reserves on banks in Antigua by the ECCB."

Q. Can you stop there for a second.

So is this the same issue with the ECCB

and trying to get information about Stanford International

Bank? I mean --

A. Roughly.

Q. And the other e-mails?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:45:37

02:45:54

02:46:07

02:46:17

02:46:30



3935

A. Uh-huh. Yes.

Q. Generally, is that what the e-mail is about?

A. Yes.

Q. Okay. Keep reading.

A. "In fact, the MOU is focused not on banks, but on

affiliates of banks licensed in Antigua. And the ECCB is

right to monitor the same presumably as part of its

already existing ability to monitor the safety and

soundness of the banks themselves and driven by the

prevailing international bank regulation standard of

consolidated supervision on a comprehensive basis. Hope

this is helpful."

Q. So the same issue we saw in those faxes a few weeks

later between Mr. King and Alvarado?

A. Yes.

MR. COSTA: Let's go to Page 2 of this exhibit,

please.

THE COURT: Now, this has all been identified

or have been numbered, correct, for this?

MR. COSTA: 677, Your Honor. I don't think

it's been previously identified. It was marked.

THE COURT: Tell you what: Make sure -- look

over here and make sure I'm focused on that. If not --

MR. COSTA: Yes, Your Honor. We'll also check

up at the end.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:46:40

02:46:57

02:47:03

02:47:13

02:47:28



3936

THE COURT: Get the word to me. 677?


BY MR. COSTA:

Q. If you look in the middle, is this responding to the

e-mail from Mr. Loumiet we just saw to Mr. Stanford? That

is the e-mail we just saw; right?

A. Yes, that's the same e-mail we just looked at.

Q. And then above it, let's see what the response is.

This is Mr. Stanford's response dated

Saturday. July 8th?

A. Yes -- it is.

THE COURT: To who.

THE WITNESS: To Carlos Loumiet.

BY MR. COSTA:

Q. And it says, "Review the proposed MOU."

What does "MOU" stand for?

A. Memorandum of understanding.

Q. And is that the Eastern Caribbean regulators are

trying to do, have a memorandum of understanding or an

agreement with the Antiguan regulator about what they

could learn about affiliate banks?

A. Yes. And that was -- the drafts of those it were

attached to the faxes between Mr. King and Mr. Alvarado.

Q. And read what Mr. Stanford says.

A. "The issue here, Carlos, is that the EECB, which is

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:47:48

02:48:07

02:48:18

02:48:24

02:48:45



3937

the regulator and supervisor for Bank of Antigua, could be

given the authority to step in as our regulator even

though we are regulated and licensed by the Ministry of

Finance under the FSRC because SIB and STC are affiliates.

In other words, what I am concerned about is that this is

the ECCB's foot in the door as they could say they are now

our regulators, et cetera. Next thing you know, the

Ministry of Finance has turned the regulation and

supervision of the offshore industry over to the ECCB."

Q. And you can stop there.

He's worried about turning the regulation

and supervision of offshore banks over to the ECCB.

Who was in charge of regulating the

supervising offshore banks like Stanford International?

A. Yes, the FSRC.

Q. Which was headed by Leroy King?

A. Yes.

Q. Keep going where it says, "And make no mistake,"

please.

A. "And make no mistake about this, the ECCB has in the

past and is still trying to get their foot in the door. I

think if there was going to be a consolidation on a global

basis for affiliates, the FSRC should be doing this for

all licensed Antiguan entities. We need to be aggressive

here as we have 16 years of history under the ECCB at Bank

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:49:05

02:49:30

02:49:38

02:49:55

02:50:09



3938

of Antigua and they jump to a tune of big brother. The

ECCB was asked by the government to assist in the cleanup

years back, and they didn't lift a finger. Now things are

going well, and we are the only thriving offshore center

in the Eastern Caribbean, and look who now wants to step

in. No bueno. Let's talk, RAS."

MR. COSTA: And then if we can go to Page 4,

very bottom.

BY MR. COSTA:

Q. We just looked at an e-mail.

Is this later in time, July 17th, later in

the month?

A. Yes.

Q. And what is Mr. Stanford telling Mr. Loumiet on

Monday, July 17th?

A. He writes, "Carlos, I just arrived in Antigua and Lee

King said you never called. I sent the ECCB letter via

fax to the number you gave me five minutes after we

talked. Carlos, this issue is of extreme importance as

this represents a minefield for Antigua and Stanford.

Thanks, RAS."

Q. Indicating he'd just arrived in Antigua and Leroy

King has informed Mr. Stanford that Carlos Loumiet, the

lawyer, had not called yet?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:50:26

02:50:43

02:50:57

02:51:09

02:51:21



3939

MR. COSTA: If we can go up.

BY MR. COSTA:

Q. And what does Mr. Loumiet say about the fact that he

had not called the regulator, Leroy King, yet?

A. "Allen, I apologize. I didn't realize you expected

me to call today, and I first set out to gather the

arguments against the ECCB's proposal by gathering and

reviewing Antigua law, as well as the ECCB's own articles

thinking that would make my conversation with Mr. King

more productive. I will call him tomorrow, though right

now, I don't have a lot of arguments with which to arm

him."

Q. So he's saying at this point he didn't have a lot of

arguments to give Mr. King regarding this ECCB attempt to

get more information about the bank?

A. Yes.

MR. COSTA: If we can go up a little more.

BY MR. COSTA:

Q. This is Mr. Stanford later on, on Tuesday and what's

he saying in the e-mail to Mr. Loumiet about now?

A. He asked, "Did you talk to L. King this a.m.? I will

call him at 11:00 a.m. RAS."

MR. COSTA: If we can go up.

BY MR. COSTA:

Q. What does Mr. Loumiet say when Mr. Stanford for the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:51:33

02:51:50

02:52:01

02:52:13

02:52:25



3940

second time is asking him if he's had a chance to talk to

Mr. King?

A. "Called, but he hasn't called back. Best, Carlos."

MR. COSTA: And if we go to Page 5.

BY MR. COSTA:

Q. What is this e-mail?

A. It's an e-mail from Carlos Loumiet to Mr. Stanford

with the subject of "Memo to Leroy King."

Q. And this is on July 21st?

A. Yes, it is.

Q. And there's an attachment that actually has the memo

Mr. Loumiet wrote for Leroy King?

A. Yes, there was.

MR. COSTA: And if we go to the next page and

see that enhancement.

Let's look at the top part and blow that

up.

BY MR. COSTA:

Q. This is to Mr. King from Loumiet, the bank's lawyer?

A. Yes.

Q. Dated July 21, 2006?

A. Yes.

Q. And he addresses Mr. King, "Lee, in the last three

days since we spoke, I have reviewed the proposed MOU" --

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:52:34

02:52:57

02:53:04

02:53:20

02:53:41



3941

Q. -- "and other things"?

A. Uh-huh, that's correct.

Q. And, basically, in this memo, what does

Mr. Loumiet -- what kind of arguments or information is

Mr. Loumiet giving to Mr. King?

A. He's telling him that he reviewed all the proposed

memorandum of understanding, including in addition to the

various statutes, and he doesn't feel that the ECCB has

a -- I guess, a foot in the door, for lack of a better

term?

Q. He's giving him arguments for why -- to argue why the

ECCB should not be able to regulate Stanford International

Bank?

A. Yes.

Q. And then, it's right around this time when we start

seeing those faxes between Mr. King and Mr. Alvarado about

the same issue?

A. Yes. Shortly after, yes.

Q. And this is all during that period when Mr. King had

those large cash deposits into both his U.S. and Antigua

bank accounts?

A. Yes.

Q. Going to go into one final issue.

Can you remind the jury, when did the

receiver take -- when did a court in Dallas order the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:53:59

02:54:21

02:54:37

02:54:42

02:54:51



3942

receiver to take over the Stanford companies?

A. The Court ordered it on February 16, 2009.

Q. And when did the -- when did the receiver actually

come in to actually take over the Stanford companies?

A. The following day, the 17th.

Q. So February 17th is when the receiver takes over?

A. Yes.

Q. In your review of Mr. King's finances, did you notice

any unusual activity with his finances in the month or so

after the receiver took over Stanford's company?

A. Yes, they did.

THE COURT: Following what date? February,

what did you say?

MR. COSTA: February 17th, Your Honor.

THE COURT: 17th. All right. So you're

talking about activity after that date?

THE WITNESS: Yes.

MR. COSTA: A couple of weeks after that -- a

few weeks after that, Your Honor.

THE COURT: Okay.

BY MR. COSTA:

Q. Did Mr. King have a brokerage account in the United

States?

A. Yes, he did. Charles Schwab.

Q. Where did he -- at Charles Schwab.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:55:04

02:55:18

02:55:41

02:55:46

02:55:57



3943

MR. COSTA: If we can go to Government's 46,

please.

BY MR. COSTA:

Q. Do you recognize this?

A. Yes. It's part of the application package for

Mr. King's Charles Schwab account.

Q. And according to this -- this account, when was it

opened?

A. This documents was signed in '95; but I think a few

pages later, it shows he opened the account in ''92.

MR. FAZEL: Mr. Costa, did you obtain these

through a subpoena?

MR. COSTA: Yes.

MR. FAZEL: Okay.

MR. COSTA: They're on your exhibit list.

MR. FAZEL: Just checking.

MR. COSTA: These are all on your exhibits as

well.

BY MR. COSTA:

Q. Where did you get these Charles Schwab records?

A. From Charles Schwab.

Q. How did you get them?

THE COURT: Was that a change?

THE WITNESS: We also get records other people.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:56:04

02:56:17

02:56:36

02:56:55

02:57:15



3944

Q. How did you obtain them from Charles Schwab?

A. Via subpoena.

Q. And you have an affidavit from Charles Schwab?

A. Yes, I do.

Q. And you said there's other documents showing the

account was actually opened in 1992?

A. Yes.

MR. COSTA: If we go to Government's 647, this

is another record from the same account.

BY MR. COSTA:

Q. What is this document we're looking at, Agent Young?

A. It's the February 2009 account statement for

Mr. King's account, a brokerage account at Charles Schwab.

Q. February 2009, the same month the receiver took over

the Stanford entities?

A. Yes.

MR. COSTA: If we can go to Page 2 of that,

please, the left-hand box.

BY MR. COSTA:

Q. What was the balance at the beginning of February in

Mr. King's brokerage account at Charles Schwab?

A. $560,314.63.

Q. And if we can go now to Page 5, did he take money out

of that account in the month after the receiver took over?

A. Yes, he did.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:57:24

02:57:46

02:57:51

02:58:03

02:58:12



3945

Q. How many wire transfers came out of that account?

A. Two.

Q. If we look at Page 5, is this the first one?

A. Yes, it is.

Q. And that's -- the transaction date is February 24th?

A. Yes, it is.

Q. And how much was wired out on February 24th, a week

after the receiver took over?

A. 150,000 U.S. dollars.

THE COURT: Was that American?

THE WITNESS: Yes, that's U.S. dollars.

BY MR. COSTA:

Q. And this was maintained in the United States, this

Charles Schwab account?

A. Yes.

Q. And this wire and the next one we're going to see,

where was he sending the money from this account in the

United States?

A. To Antigua Overseas Bank.

MR. COSTA: If we go to 648, please.

BY MR. COSTA:

Q. What is -- is this another document from the Schwab

records?

A. Yes, it is.

Q. And what does this show --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:58:19

02:58:26

02:58:38

02:59:05

02:59:17



3946

MR. COSTA: If we go down. Keep going.

THE COURT: Again, the number is?

MR. COSTA: Perfect.

648, Your Honor.

THE COURT: 648.

BY MR. COSTA:

Q. Is this the actual authorization form for that

150,000-dollar wire?

A. Yes, it is.

Q. And does it show the receiving bank Antigua Overseas

Bank, the bank you mentioned?

A. Yes, it does.

MR. COSTA: And if we can go down a little bit

of the document.

BY MR. COSTA:

Q. The accountholder signs it on what date?

A. February 23, '09.

Q. So the request is made February 23rd to wire $150,000

U.S. to an Antiguan bank account?


Q. And you mentioned another wire that Mr. King made.

Is that correct?

A. Yes.

MR. COSTA: If we can go to Page 6, please.

BY MR. COSTA:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

02:59:49

03:00:11

03:00:40

03:01:01

03:01:17



3947

Q. How much is the second wire?

A. $410,293.39, also being sent to Antigua Overseas

Bank.

MR. COSTA: And if we go back to Government

647, Page 10, please.

BY MR. COSTA:

Q. Is this the March statement?

A. Yes, it is.

Q. And it shows that 410,000-dollar wire going out?

A. Yes, it reflects 410,000-dollar withdrawal.

MR. COSTA: If we can go to the next page of

that document.

BY MR. COSTA:

Q. Would the March statement show us the date of that

wire disbursement?

A. Yes, it does. It was March 3, 2009.

Q. And what was the amount again?

A. In here, it's -- well, it's minus 410,274.28, but

then, that also includes the Charles Schwab wire fee.

Q. And that goes from the U.S. to Antigua?

A. Yes.

Q. And how much was left in the account after these two

wires of money from the United States to Antigua?

A. Just a little over a hundred dollars. I think on the

first page of this statement showed like $107 and change.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:01:42

03:01:55

03:02:13

03:02:26

03:02:39



3948

MR. COSTA: And if we can go back to

Government 648, Page 3, please.

BY MR. COSTA:

Q. Are there various notes in these bank -- in these

wire records that are being made?

A. Yes.

Q. And what is this one made on February 23rd, the date

when that first wire of 150,000 was made by Mr. King?

What does it say?

A. "Client never done wire before."

Q. In this account Mr. King had since the early 90s, he

had never wired any money out before?

A. From the records -- from the records that I saw, he

did not; but based on this note that one of the Charles

Schwab employees is making, he -- appears he didn't make

you -- he didn't have any other wire transfers.

Q. In having this account for almost over 15 years; is

that right?

A. Yeah. Fifteen, 17 years, something around there.

Q. And then in the couple of weeks after the receiver

takes over, he wires over half a million dollars out of

the United States into Antigua?

A. Yes.

Q. Leaving just a little over a hundred dollars in his

account?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:02:57

03:03:02

03:03:11

03:03:16

03:03:29

Cross-Young/By Mr. Fazel


3949

A. Yes.

MR. COSTA: Pass the witness.

MR. FAZEL: May I proceed, Your Honor? And,

Your Honor, I'm sorry. I do have a throat lozenge in my

throat.

THE COURT: That's absolutely fine. I'm glad.

That will help you.

CROSS-EXAMINATION

BY MR. FAZEL:

Q. Good afternoon, Agent. My name is Ali Fazel. How

are you?

A. Pretty good.

Q. You and I have never met before; correct?

A. We never met, but I did answer the phone at Gregg's

office once when you called.

Q. Oh, okay.

A. I took a message.

Q. Well, you're a great secretary.

A. I try to be.

Q. And Gregg is Mr. Costa?

A. Yes. Sorry.

Q. That's all right. Want to make sure.

Now, Agent, I want to talk to you just

briefly. You've been on the witness stand all day, I

understand. And so -- and you can tell I have a cold. So

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:03:40

03:03:48

03:03:58

03:04:06

03:04:15



3950

if you don't understand me, if you want me to go slowly,

let me know and I'll go slower; okay? Fair enough?

A. Sure.

Q. All right. Now, Agent, before -- when you started to

testify, you talked about -- a little bit about yourself.

You said that you're with the IRS;

correct?

A. That's correct.

Q. But before you were with the IRS, did you -- you have

some kind of educational background; correct?

A. Yes.

Q. You went to school, high school?

A. Went to high school, and I have a bachelor's degree.

Q. And then you went to college and got a degree in

what?

A. Accounting.

Q. And then, did you go into the IRS right after that?

A. No. I graduated from the University of Hawaii with a

bachelor's in accounting.

Q. Right. And then after that, did you go into the

accounting field?

A. Yes, I did.

Q. For how long were you in the accounting field?

A. About -- a little over seven years.

Q. Did you get your -- are you a accountant?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:04:25

03:04:33

03:04:39

03:04:49

03:04:56



3951

A. Yes, I am.

Q. Okay. And then after you went to the IRS?

A. Yes.

Q. All right. Now, when you went to the IRS, did they

put you in some kind of school? Did they train you?

A. Yes, they do.

Q. Do they train you with firearms?

A. Yes, they do.

Q. Do they train you in classes dealing with law

enforcement?

A. Yes.

Q. They taught you about probable cause?

A. Yes, they did.

Q. They taught you about how to investigate things?

A. Yes.

Q. Well, they taught you how they like to investigate

things; correct?

A. Within -- they teach you how to investigate, you

know, within the confines of the policies and procedures

of the IRS.

Q. They made you into a peace officer?

A. Yes.

Q. Correct?

A. Well, IRS agents are not considered peace officers in

the State of Texas. So I can't say we're peace officers.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:05:05

03:05:18

03:05:27

03:05:38

03:05:44



3952

Q. Do you get to carry a gun?

A. Yes.

Q. Do you have a badge?

A. Yes.

Q. Did they put you in school and teach you how to

testify in front of juries?

A. There was a short instruction in our training class.

Q. Sure. They teach you how to look at the jury when

you testify?

A. Yes.

Q. Taught you how to connect with the jury when you

testify?

A. I don't think they teach you. We didn't really

take -- tell us how to connect with the jury.

Q. But you've been trained to be a professional witness;

correct?

A. I wouldn't say I've been trained to be a professional

witness. I --

Q. Is this the first time you testified in your career?

A. Yes.

Q. This is the first take time you've ever testified in

front of a jury?

A. Yes.

Q. How long have you been a peace officer?

A. Not a peace officer.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:05:52

03:06:04

03:06:11

03:06:20

03:06:27



3953

Q. How long have you been an IRS agent?

A. Eleven years.

Q. This is the first time you've ever testified?

A. In front of a jury, yes.

Q. Are you nervous?

A. Sure. Anybody would be. I think any witness with

a -- with a whole group -- 12 people looking at them would

be a little nervous.

Q. Well, there's more than 12.

THE COURT: 15 people.

THE WITNESS: Right.

THE COURT: Including Number 1 down there, I

don't mean the marshal.

MR. FAZEL: And don't forget Juror Number 1.

He's got the most comfortable chair.

THE WITNESS: I noticed. I don't know how you

pulled that one off, but...

THE COURT: The matter of elimination.

BY MR. FAZEL:

Q. Let me talk to you about your training and

experience. We talked about that briefly. Let's talk

about what you did on this case, okay?

A. Sure.

Q. Are you with me? All right.

Let's talk about the fact that you've been

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:06:35

03:06:47

03:06:57

03:07:10

03:07:18



3954

an IRS agent for 11 years. And in those 11 years, you've

investigated other people before, I assume; correct?

A. Yes.

Q. This is not your first investigation?

A. No.

Q. All right. In those 11 years, you've dealt with

foreign banks before; correct?

A. Only recently.

Q. Okay. But you understand that foreign banks exist?

A. Yes.

Q. And foreign banks do business in the United States on

a consistent basis; correct?

A. Yes.

Q. Is there anything illegal about being a foreign bank?

A. No.

Q. Would you agree with me that there are a lot of

foreign banks that do business in the United States?

A. Yeah, I would. There are a lot of foreign banks in

the United States.

Q. Now, we know that SIBL, or Stanford International

Bank, Limited, was a foreign bank; correct?

A. That's correct.

Q. And it was housed in Antigua; correct?

A. Yes.

Q. It was regulated by the Antiguan; correct, sir?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:07:29

03:07:42

03:07:51

03:07:56

03:08:02



3955

A. Yes.

Q. And the Antiguans have two sets of regulators,

correct, when it comes to banking?

A. Okay. Domestic and international, correct.

Q. Anything illegal about that?

A. No.

Q. Is it common, as a matter of fact, to have two sets

of regulators of banking?

A. It's not uncommon.

Q. I mean, we have that in the U.S.; right?

A. Yeah, I mean --

Q. Yeah, I mean --

A. -- the SEC.

Q. -- there's FINRA; right?

A. Yes.

Q. There's the FDIC?

A. Yes.

Q. There's the SEC?

A. Yes.

Q. And they have concurrent jurisdictions at times;

right?

A. I believe so.

Q. And they have jurisdictions that are separate at

times; right?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:08:14

03:08:24

03:08:40

03:08:49

03:09:08



3956

Q. All right. Are you telling this jury that the SEC,

the FINRA and FDIC are doing something illegal?

A. No.

Q. There's nothing unusual about that, is there?

A. No.

Q. All right. All right. Now, I want to go back to the

beginning of your testimony just briefly and kind of walk

you through the -- what you talked to Mr. Costa about,

okay?

A. Okay.

Q. All right. Do you remember talking about cash

transfers and Mr. King, okay? Are you with me? Cash

transfers by Mr. King, cash deposits by Mr. King. Are you

with me?

A. Well, that I testified that there was one cash --

there was one transfer, the rest were all cash withdrawals

and cash deposits, not transfers.

Q. We'll get there, I promise.

A. Okay.

Q. Now, let's talk about cash generally and how banks

handle it.

A. Okay.

Q. All right. Take this purple marker. Now, Agent, you

agree with me that most commercial banks in the United

States are -- is regulated by the FDIC; correct, sir?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:09:24

03:09:35

03:09:49

03:10:03

03:10:22



3957

A. I wouldn't be able to say most of them, I mean,

because, there's also the officer -- office of the

controller, currency and other, but generally --

Q. That's right. We just talked about that.

A. Okay.

Q. So there's multiple jurisdictions, multiple agencies

regulating different things; right?

A. Sure.

Q. All right. One of the things that is regulated in

the United States is called -- is cash deposits; correct?

A. I'm not following your question.

Q. Inartfully said.

One of the things that the IRS and the

FDIC and other agencies that are in the U.S. Government

focus in on are cash deposits or cash withdrawals from

banks; correct?

A. Well, cash transactions in general, but not

necessarily only related to banks, also for other

businesses, but, yes.

Q. So they do want to know if there are certain cash

withdrawals from banks; correct? Do you understand my

question? Do you remember when I told you if you don't,

tell me and I'll rephrase it. Was the question confusing?

A. A little bit.

Q. Okay. Is there a limit that a bank has to be -- has

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:10:39

03:10:53

03:10:58

03:11:11

03:11:18



3958

to notify a agency about if a withdrawal is, a certain

limit after which a bank has to tell an agency, hey, this

withdrawal has been made?

A. Well, there's -- it's hard to give a yes or no answer

because there are requirements if a cash transaction in

excess of $10,000 --

Q. Exactly.

A. -- but there is no limit because the banks also have

the responsibility to file an obligation to file a

suspicious activity report --

Q. I'll get to that.

A. -- if those -- even if it's a couple of dollars. I

mean --

MR. FAZEL: Excuse me, Your Honor. I'd object

to nonresponsive.

THE COURT: Sir, answer yes or no, if you can.

If you can't answer yes or no, let me know. If you can't

answer yes or no and you need to explain, state that you

can't answer yes or no without an explanation.

THE WITNESS: I thought I -- yeah, I just -- it

just really wasn't an answer, a question with a yes or no.

THE COURT: That's fine. Then just state that,

just like that.

THE WITNESS: Okay.

BY MR. FAZEL:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:11:23

03:11:38

03:11:47

03:11:57

03:12:14



3959

Q. Okay.

A. Okay.

Q. So if you don't understand my question, let me know

and I'll rephrase it.

A. Okay. And that's fair.

Q. All right. CTR stands for what?

A. Currency transaction report.

Q. All right. And that is required of any withdrawal of

more than $10,000 in the United States; correct? Is that

one time --

A. Yes.

Q. -- where a CRT is required?

A. Yes.

Q. Now, banks also have a duty or an obligation to

inform governmental agencies if there are multiple

transactions of cash; correct?

A. That's true.

Q. Which are below $10,000; correct?

A. Uh-huh.

Q. But are suspicious; correct?


Q. And by the nature of cash, banks generally inform the

government if there are multiple cash transactions even if

they don't come up to $10,000; correct, sir?

A. I've never worked for a bank, but, I mean -- so I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:12:22

03:12:31

03:12:39

03:12:50

03:12:59



3960

can't answer that.

Q. Well, you're an IRS agent; right?

A. True.

Q. You have done many investigations; right?

A. Yes.

Q. You don't know what the banks -- major banks in the

United States are obligated to do?

A. Some banks do, but --

Q. Do you --

A. -- they're obligated --

Q. The question was: Do you know what they're obligated

to do?

A. Yes.

Q. Do you know what they're obligated to do referencing

cash and cash transactions?

A. Yes.

Q. Tell us what a suspicious -- I believe you called it

a suspicious transaction report.

A. It's a suspicious activity report.

Q. A suspicious activity report?

A. Uh-huh.

Q. Is that generated by a bank?

A. The bank is one of the entities that would generate

it.

Q. Or any financial institution; correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:13:05

03:13:11

03:13:21

03:13:35

03:14:19



3961

A. Yes, that's true.

Q. Dealing with cash; correct?

A. Yes.

Q. All right.

A. It could also include other than cash, too.

Q. Well, let's talk about cash right.

A. Okay.

Q. We'll get to the other stuff in a minute.

A. Okay.

Q. Dealing with cash. And it could be generated if it's

less than $10,000; correct?

A. Yes.

Q. It could be generated if there is a pattern of

deposits or withdrawals; correct?

A. Yes.

Q. As a matter of fact, the bank has an absolute right

to refuse any deposit or withdrawals if they're suspicious

of that activity; correct, sir?

A. I don't know if they have the right to refuse.

Q. Now, let me take your attention to Government's

Exhibit -- do you remember talking to the government about

cash deposits into Mr. King's bank account?

A. Yes.

Q. Do you remember talking about cash deposits into

Mr. King's U.S. bank accounts and Mr. King's domestic bank

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:14:29

03:14:42

03:14:52

03:14:58

03:15:06



3962

accounts? I'm sorry --

A. That's the same thing.

Q. Right. International bank accounts. Are you with

me?

A. Yes.

Q. All right. Now, you went through all of the bank

records, correct, of Mr. King regarding his domestic and

the bank accounts in Antigua that you found; correct?

A. Yes.

Q. And you went through all the deposits to see what

deposits were made; correct?

A. Yes.

Q. And you went through all the deposits to see what --

excuse me -- all withdrawals to see what withdrawals were

made; correct?

A. From Mr. King's account?

Q. Yes.

A. Yes.

Q. Okay. So you looked at both deposits and

withdrawals?

A. Yes.

Q. And you can testify to this jury about the

withdrawals as well; right?

A. Sure.

Q. I mean, you looked at them; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:15:31

03:15:42

03:15:48

03:15:56

03:16:04



3963

A. I have looked at them. I didn't have -- I don't have

it memorized, so you'd have to show me specific ones.

Q. All right. Now, do you remember testifying about how

the monies -- that you looked at both the -- well, let me

back up just a little bit so this make more sense.

When a deposit is made at a bank and it's

cash related, banks do something special to that; correct?

They do a cash-in ticket; right?

A. Yes.

Q. Are you with me?

A. Yes.

Q. And that cash-in ticket says there's cash coming into

the teller itself; right?

A. Yes.

Q. Because at the end of the night the teller has to

balance their drawer and make sure there's enough cash and

everything balances out; right?

A. Yes.

Q. Are you with me?

A. Yes.

Q. So in order to determine whether there's cash coming

in or cash going out or anything like that -- let me

rephrase that.

Cash going out is done with a cash-out

ticket; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:16:10

03:16:18

03:16:29

03:16:40

03:16:48



3964

A. Yes.

Q. Okay. So each deposit that a teller gets is a debit

and a credit behind it; right?

A. Yes.

Q. And that tells the teller, hey, there's a deposit

coming in and it was cash; right?

A. Yes.

Q. And if there's checks, there's checks behind that as

well; correct?


Q. All right. You agree with all that?

A. Yes.

Q. All right. Now, focussing on Mr. King for a

minute -- because you testified about Mr. King; correct?

A. Yes.

Q. All right. You went through -- with the prosecutor,

Mr. Costa, and talked about his bank accounts in the U.S.

and his bank accounts in Antigua; correct?

A. Yes.

Q. All right. Let's first go to his bank accounts in

the U.S.

A. Okay.

Q. How many bank accounts did he have in the U.S.?

A. Four.

Q. Four total?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:17:01

03:17:19

03:17:30

03:17:43

03:17:51



3965

A. That we're aware of.

Q. So there could be bank accounts you don't know about?

A. Yes.

Q. Did you try to track any other bank accounts down?

A. No.

Q. Why not?

A. There's hundreds and hundreds of banks. We'd be

issuing subpoenas blindly to numerous institutions.

Q. So you can't tell this jury how many bank accounts he

has in the U.S.; right?

A. That we found, four.

Q. No, just you don't know how many total bank accounts

he has in the U.S.; correct?

A. That's true. But if you look at his tax returns, I

think he only reports for interest income on the interest

Schedule B, I believe Chase and Bank of America.

Q. What if the accounts aren't interest bearing?

A. Those --

Q. I'm just asking.

A. If they're not interest bearing and they're not

reported to --

Q. Then you wouldn't know about it? I'm just trying to

set up the parameter of your investigation. Would you

agree with me that you don't know he has other bank

accounts in the U.S.? Would you agree with that?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:18:00

03:18:09

03:18:17

03:18:27

03:18:35



3966

A. Yeah.

Q. All right. Okay.

A. From all the records -- from what we've seen --

Q. It's a yes or no question, Agent. Do you agree with

that?

A. Sure.

Q. Okay. Now -- so you focused your attention on two

bank accounts here in the U.S., Chase and Bank of America;

correct?

A. Two banks.

Q. Two banks. I'm sorry. If I said bank accounts, I

apologize.

Two banks in the U.S., Chase and Bank of

America; correct?

A. Yes.

Q. And those banks, you went back as far as two thousand

and?

A. Three, I believe.

Q. And that's because that's as far as they went?

A. Yes.

Q. And you looked at all the cash transactions and all

the cash deposits from 2003 to 2009; correct?

A. Yes.

Q. What was the total amount of deposits that were made

in cash in the U.S.?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:19:05

03:19:15

03:19:25

03:19:33

03:19:51



3967

A. I believe it was 321,000 an, like, $75.

Q. Let me step one step backwards. Is there anything

illegal about making cash deposits in the U.S.?

A. No.

Q. To your knowledge, when you did your investigation,

did the banks that took these cash deposits send out a CTR

regarding Mr. King saying, hey, he's depositing these

currencies?

A. No.

Q. To your knowledge, did they send out a suspicious

activity report saying, hey, this is suspicious, y'all

need to look at this?

A. No.

Q. Okay. Now, wasn't there a deposit of over $15,000

made?

A. Yes.

Q. Was there a CTR created of that?

A. I don't recall.

Q. Did you look for it?

A. At this time I don't remember if I did.

Q. All right. Now, are you telling this jury that every

one of those deposits that were made into Mr. King's

account was bribe money from Mr. Stanford?

A. No.

THE COURT: Hang on one second, please.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:20:43

03:20:56

03:21:21

03:21:39

03:21:44



3968

Go on. I'm sorry.

BY MR. FAZEL:

Q. So are you telling this jury that this was all bribe

money they deposited into his account?

A. No. Just -- I'm just saying that Mr. King had --

Q. Cash deposits into his accounts?

A. Cash deposits into his bank accounts in the United

States.

Q. Is that -- is there anything wrong with that?

A. In general, cash deposits, no.

Q. Now, do you remember the prosecutor asking you about

600 bills fitting into your wallet?

A. Yes.

Q. Do you remember saying, "My wallet doesn't fit that"?

A. Yes.

Q. Okay. Are you intimating that Mr. Stanford was

bribing Mr. King and he was giving him cash and he was

putting it in his wallet, is that what you're saying?

A. No. I was saying I know 600 bills are pretty thick,

and that definitely wouldn't fit in my wallet. I mean, my

wallet --

Q. What does a wallet have to do with anything, I guess,

is my --

A. That was the question.

Q. I'm asking you: What does a wallet have to do with

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:21:52

03:22:19

03:22:28

03:22:50

03:22:56



3969

anything?

A. I was answering the question when the question --

Q. It doesn't have to do with anything, does it? Does

it?

A. A wallet, no.

Q. Now, do you remember talking about Bank of Antigua?

A. Sure.

Q. Let's talk about -- I want to make this -- see if

this makes sense to you. Bank of Antigua is a commercial

bank; correct?

A. It's a commercial Antiguan bank, yes.

Q. Which means that it has deposits, it has withdrawals,

it has credit cards; correct?

A. Yes.

Q. Okay. On a side note, is Mr. Stanford charged with

bribery in this case? Is he charged with bribery?

A. No.

Q. All right. Now, if Mr. Stanford wanted to commit a

crime, would he then go and order cash withdrawals the way

he did if he owned the bank?

MR. COSTA: Object to the speculation, Your

Honor.

THE COURT: Sustained as to the form of the

question.

BY MR. FAZEL:

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:23:10

03:23:22

03:23:44

03:23:52

03:24:06



3970

Q. Let me rephrase it.

According to your testimony, if I

understand it correctly, what you are telling this jury is

Mr. Stanford, who is 100 percent owner of the bank,

correct, of the Bank of Antigua?

A. Yes, he's the owner of Bank of Antigua.

Q. He owns the bank 100 percent, he's 100 percent

shareholder; right?

A. Okay.

Q. Right?

A. Yes.

Q. All right. He, then, according to your theory, if I

understand this correctly, orders the bank to give him

cash to give to Mr. King; right? Is that what you're

telling this jury?

A. I'm telling -- I mean, I'm testifying he withdrew the

cash.

Q. I mean, that's --

A. Mr. King had deposits.

Q. I mean, that's the connotation; right? You're trying

to tell the jury, yeah, he's bribing him; right?

A. Sure.

Q. He's a billionaire, and he leaves a trace of that big

for anybody and their mother to find?

A. I'm just reflecting what the records -- I'm just

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:24:21

03:24:34

03:24:44

03:24:56

03:25:06



3971

telling you what the records show. I don't know --

Q. Was there anything hidden about what Mr. Stanford

did?

A. There's nothing hidden in the cash withdrawals.

Q. Did he order -- did he say -- was there a

documentation from the bank saying, hey, take this cash

out, this much cash out, every time you testified to the

jury?

A. Yeah, the documentation from Bank of Antigua shows

Mr. Stanford was withdrawing cash.

Q. And he says in cash; right?

A. Yes.

Q. Did you have any problems obtaining those records?

Remember you talked about the MLAT?

A. Well, the MLAT -- an MLAT in general just takes a lot

longer. It's a more cumbersome, you know, process than a

subpoena.

Q. I hear you. Deals with lawyers; right?

A. Diplomats.

Q. Diplomats, right.

My point is: Did you get the information?

A. Yes, we did.

Q. Okay. Was there anything hidden about what he did

that he took cash out?

A. No, the records say cash withdrawal.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:25:25

03:25:44

03:25:55

03:26:04

03:26:12



3972

Q. And then when you traced this cash to Mr. King, are

you telling this jury of all the times that you -- it was

from what years to what years, again?

A. Well, Mr. King had deposits from -- in the U.S. in

2003.

Q. All the way to 2009. There were three instances

where there were what, two days apart?

A. Some -- well, as I think I testified when I compared

them, the ones that fell within a week or roughly a week

apart is about less than ten, probably eight or nine.

Q. I'm sorry, Agent. Did you -- when you were doing

your analysis, did you look to make sure that if there are

any that are identical, you looked for that; right?

A. Yes.

Q. And you looked for one that are a day or so apart?

A. Yes.

Q. And they're -- and two or three days apart?

A. Yes.

Q. And there was a handful of them?

A. Yes.

Q. And were they the same amount?

A. The one was.

Q. One was the same amount.

And from that, are you telling this jury

that it's got to be bribery, it's -- excuse me --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:26:28

03:26:40

03:26:48

03:26:56

03:27:03



3973

Mr. Stanford is paying Mr. King. Is that what you're

telling us?

A. Based on what Mr. Davis had told us.

Q. Oh, I'm sorry. I forgot about that.

A. Mr. Davis told us about how he got the cash.

Q. Agent, if you don't mind.

A. Okay.

Q. So you're basing your testimony today on Mr. Davis?

A. Not completely. Mr. Davis laid -- provided the

information. We obtained bank records that supported what

Mr. Davis had told us.

Q. Well, let's talk about that.

A. Sure.

Q. Mr. Davis provided information.

A. Sure.

Q. Mr. Davis said he's bribing King; right?

A. Sure.

Q. Okay. Once he said that, did he tell you what bank

accounts he was using?

A. Yes, he did.

Q. Bank of Antigua?

A. Yes, he did.

Q. Did he have -- how many bank Bank of Antigua accounts

did Mr. Stanford have?

A. In total, I do not know. Mr. Davis told us what

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:27:13

03:27:27

03:27:41

03:27:55

03:28:07



3974

particular account it was.

Q. Mr. Davis told you what account it was?

A. Yes.

Q. He only had one bank account at Bank of Antigua;

right?

A. I don't know. I've only looked at the --

Q. I guess my point, Agent, is that we can see from the

charts that the government put up that the numbers were

different; correct? Between Mr. Stanford and what amounts

of money he took out and what Mr. King was depositing into

his accounts. Would you agree with me that the majority,

99 percent of them, were different amounts? Would you

agree with that?

A. I wouldn't say 99 percent, but, yeah, they're

demonstrative different.

Q. They're different times; correct?

A. Yes.

Q. Now, let me ask you something else. If this was such

a secret -- did Mr. Davis tell you this was a secret,

nobody knew about it, it was hush-hush?

A. I don't believe he said it was a secret.

Q. Did he say everybody knew about it?

A. He knew about it, so it couldn't --

Q. Anybody else knew about it?

A. That, I recall, no. He didn't say anything -- he

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:28:17

03:28:30

03:28:42

03:28:54

03:28:58



3975

didn't mention anyone else.

Q. So you suspected it was something surreptitious about

this; right?

A. No, I didn't suspect that.

Q. Did Mr. Stanford hide the cash withdrawals from his

bank?

A. No.

Q. Did Mr. Stanford ask somebody else to withdraw cash

for him?

A. Other people had received cash from Mr. Stanford.

Q. That's not my question, Agent. I'm sorry. I just

need you to answer my questions.

Did Mr. Stanford in your investigation ask

somebody else to withdraw cash for him and hand it to

Mr. King? Yes or no.

THE WITNESS: Judge.

THE COURT: Yes, sir. What, you can't answer

it yes or no? Is that your answer?

THE WITNESS: Well, he --

THE COURT: No, without explanation.

THE WITNESS: Well, both -- he asked two

different questions, so --

THE COURT: Okay.

THE WITNESS: -- the first one --


1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:29:04

03:29:12

03:29:24

03:29:30

03:29:41



3976

THE WITNESS: -- and then the second one, he

threw an extra clause on.

THE COURT: It's a multifarious question?

THE WITNESS: Yes.

THE COURT: That's a legal term. It's got

multiple questions in one.

MR. FAZEL: Let me rephrase my question, Judge.

THE COURT: All right. Go on.

BY MR. FAZEL:

Q. Mr. Stanford, right, if he wanted to hide something,

would it have not been easier to simply have somebody else

withdraw the cash for him?

MR. COSTA: Object to the speculation.


BY MR. FAZEL:

Q. You're an investigator; correct?

A. Yes.

Q. And you've been doing this for 17 years?

A. No, 11.

Q. 11 years?

A. Uh-huh.

Q. Isn't it smart not to leave a paper trail, Agent? He

owns the bank; right, Agent?

A. Yes, he does own the bank.

Q. Couldn't he have just walked in and gotten cash out

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:29:54

03:30:10

03:30:21

03:30:28

03:30:39



3977

and said, "Hey, don't leave a paper trail"?

A. I don't know. I don't work at Bank of Antigua. I

don't work for Mr. Stanford. I don't --

Q. Doesn't the fact that there's a paper trail

delineating every single transaction in cash tell you that

there was nothing surreptitious about this, there's

nothing illegal about this?

A. No.

Q. He just bought Davis 100 percent, that's it; right?

A. I didn't buy Davis 100 percent. Mr. Davis told us in

the information. We got bank records that corroborated

what he told us.

Q. You just bought what Davis told you 100 percent? Yes

or no.

A. No.

Q. Okay.

A. We got the bank records that supported what Mr. Davis

told us.

Q. No, Agent, you didn't get records to support what

Mr. Davis told you. What you got was bank records that

show that he took cash out, then you jump to the

conclusion that he's bribing somebody, and now you're

testifying in front of that jury.

MR. COSTA: Object to the compound question and

argumentative nature.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:30:48

03:31:12

03:31:21

03:31:45

03:32:02



3978

THE COURT: Overruled. Next question. Are you

going to ask him "is that correct," I know.

BY MR. FAZEL:

Q. Is that correct?

A. Can you please repeat the question?

THE COURT: No. No. The effect is gone. All

right. Next question, please.

MR. FAZEL: Yes, Your Honor.

BY MR. FAZEL:

Q. Let me talk to you about -- do you remember we just

talked about the fact that shouldn't leave a paper trail.

Do you remember that? We just chatted about paper trails

a minute ago.

A. We chatted about paper trails.

Q. Do you remember Government's Exhibit 678?

MR. FAZEL: Can you pull up Government 678.

THE COURT: Yes. Okay. Do you want your chart

back?

BY MR. FAZEL:

Q. Thank you, Agent.

Do you remember when Mr. Costa talked to you

about Government's Exhibit 678 and then he brought up this

letter that Mr. King had written Mr. Stanford about his

band or -- or, actually, it was not -- I don't think it was

his band. It was a band that he was sponsoring. Do you

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:31:44

03:32:25

03:32:34

03:32:44

03:32:57



3979

remember that.

A. Yes.

MR. FAZEL: Could you bring that up. I think

it's -- there it is.

BY MR. FAZEL:

Q. Where did you find that letter?

A. It's actually part of the Bank of Antigua records.

Q. Is there anything about this that you find

suspicious?

A. (No audible answer.)

MR. FAZEL: Could you go to the corner, in the

very corner where -- thank you.

BY MR. FAZEL:

Q. What does that tell you?

A. It's a handwritten note --

Q. By whom?

A. -- instruction.

I don't know whose handwritten it is.

Q. Now you don't know.

Who is RAS?

A. You asked me -- I don't know who --

Q. Who does it purport to be, Agent?

A. It's referring to Mr. Stanford, RAS, but I don't know

who wrote -- whose handwriting that is.

Q. If Mr. Stanford wanted to hide payments, would he

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:33:12

03:33:17

03:33:25

03:33:38

03:33:49



3980

then send this letter to the bank and say, "Hey, do me a

favor, pay this amount of money for Mr. King's band"?

A. I --

Q. Does that look like somebody who is trying to hide

anything, Agent?


THE COURT: Mr. King's band?

MR. FAZEL: Yes, it is, Your Honor. It's

the --

MR. COSTA: The letter doesn't say it's his

band. It's for a band Mr. King says he's helping to raise

money for.

THE COURT: Got it.

BY MR. FAZEL:

Q. Does that seem nefarious to you?

A. Mr. Stanford instructing someone to pay to -- pay,

no.

Q. Agent, the question was: Does this seem nefarious to

you? Yes or no.

THE COURT: On its face.

THE WITNESS: Other than the fact that it's --

a regulator from Mr. Stanford's bank is asking for a

donation, that seems a little --

BY MR. FAZEL:

Q. I'm sorry. Even though that's not responsive to my

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:33:58

03:34:09

03:34:28

03:34:41

03:34:52



3981

question, let's talk about that a minute since you offered

that up.

A. Sure.

Q. So you're suspicious because a regulator is asking

for a donation; right?

A. It raises some flags, yes.

Q. I see. That doesn't happen in this country, does it?

A. I didn't say that. I don't know. I'm sure it does.

I don't know.

Q. So every time a congressman flies on somebody else's

jet, do you go and investigate him?

A. That's not the scope of the IRS. That's not --

Q. Agent, you just told this jury that you thought it

was nefarious because it was a regulator and Mr. Stanford;

right? Correct?

A. Sure.

Q. Now, first of all, if it was so nefarious, why would

he turn it into the bank and make it part of the bank's

record?

A. I could only speculate.

Q. If somebody was trying to hide something, would they

go to the depth of making a paper record of what they're

doing?


THE COURT: Rephrase it.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:34:59

03:35:08

03:35:14

03:35:23

03:35:36



3982

MR. FAZEL: Sure.

THE COURT: You can go into this line, but

rephrase it, please.

MR. FAZEL: Sure.

BY MR. FAZEL:

Q. You are a trained IRS agent; right?

A. Yes.

Q. Okay. And as a trained IRS agent, the majority of

your job, which is CID, correct, Criminal Intelligence

Division?

A. Investigation division.

Q. Investigation division. I'm sorry. I used

intelligence. I apologize.

Investigation division. The majority of

that is looking at paperwork; right?

A. That's part of the job. I --

Q. You look at tax returns; right?

A. Yes.

Q. You can look at bank records; right?

A. Yes.

Q. And that's how you develop a case; right?

A. It's not -- I mean, it's part of a case, but it's not

how we normally develop a case.

Q. So would it not be simpler to facilitate a crime by

not creating and leaving paper records?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:35:53

03:36:03

03:36:15

03:36:36

03:36:45



3983

A. Sure.

Q. Did you take that account at all when you're going

through your analysis that, Wait a minute, there's paper

records about this? Did you think about that before you

start -- come up here in front of this jury and tell them,

"Oh, Stanford is bribing King?" Did you did you think

about that?

A. No.

Q. No? Did you think about the fact that if Stanford

wanted to bribe him, he could hire hundreds of people to

just give him cash? Did you think about that?

Did you think about the fact that Stanford

didn't try once to hide once hide any of these cash

transactions that you -- this pretty chart that you put

together? Did you -- did you think about that?

A. No.

Q. No. The Super Bowl tickets.

A. Okay.

Q. Telling this jury that's another bribe; right?

A. Yes.

Q. It's another bribe; right?

A. Yes.

Q. Okay. And do you remember going through the e-mails

with the jury?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:36:59

03:37:19

03:37:32

03:37:39

03:37:52



3984

Q. Was he trying to hide it?

A. He had his -- certain of employees -- some of his

employees were --

Q. Certain employees?

A. Uh-huh.

MR. FAZEL: Can you bring up Government's

Exhibit 657, please.

Can you highlight the first -- where it

says "Original." Down further. Further. Further. There

you go.

Can you highlight that box, please. Okay.

Now, you see where it says "To"?

Can you highlight all that?

BY MR. FAZEL:

Q. Linda Wingfield; correct?

A. Okay.

Q. Julie Hodge?

A. Okay.

Q. Lula Rodriguez. Is that who Mrs. Rodriguez is?

A. That's Patricia.

Q. Patricia. Okay. And who is this Yolanda Suarez?

A. I believe she was the former general counsel for

Mr. Stanford's company.

Q. It's the lawyer?

A. Okay. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:38:05

03:38:19

03:38:35

03:38:51

03:39:05



3985

MR. FAZEL: Scroll down, please. All the way

down until it talks about the Super Bowl tickets.

No, it would be the next page. That one.

BY MR. FAZEL:

Q. Now, are you telling this jury that Mr. Stanford was

bribing somebody and copying his lawyer on it? Is that

what you're telling this jury?

A. Just by this particular e-mail, it doesn't say who

the tickets are going to.

Q. My point is, he's not hiding it from anybody,

including the general counsel of the company; correct?

A. Well, all he's telling his general counsel in this

e-mail is -- to Linda Wingfield, is saying, "I found two

club level tickets for you for $8,000."

Q. Does it appear to you that he's hiding this?

A. He's not hiding the purchases of Super Bowl tickets.

He doesn't say who it's going to.

Q. I see. That's -- and, so, he's hiding that. Is that

what you're telling us? Is that what your evidence shows

you, that he's hiding -- he's bought Super tickets --

Super Bowl tickets for Mr. King? He's hiding it?

A. Not -- he's just doesn't mention it in this e-mail.

Q. Does he mention it in the next e-mail, or do you want

me for pull that up too?

A. Sure. Sure. Can you pull it up then?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:39:21

03:39:33

03:39:42

03:39:49

03:40:03



3986

Q. Sure.

MR. FAZEL: Can you pull up Government's

Exhibit 658?

BY MR. FAZEL:

Q. Do you remember this exchange back and forth between

Mr. Stanford's assistance, Ms. Wingfield and so forth.

A. Yeah, uh-huh.

Q. Is he hiding it from them?

MR. COSTA: Can we be clear whether

Mr. Stanford is on this e-mail?

THE COURT: Okay. Hammer it down.

MR. COSTA: You're referring to --

MR. FAZEL: The jury sees its for themselves,

Your Honor. It's up there. It's in evidence. They can

read it. But it's not -- I guess my question is --

MR. COSTA: I thought you were saying this was

a Mr. Stanford e-mail.

MR. FAZEL: No. I'm sorry. You're right.

BY MR. FAZEL:

Q. Is there any evidence in these e-mails that

Mr. Stanford's hiding anything from anybody?

You just don't care, Agent. You just made

up your mind; right?

A. No.

Q. Mr. Davis told you, and that's got to be the honest

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:40:09

03:40:14

03:40:23

03:40:32

03:40:42



3987

truth; right?

A. Oh, what Mr. Davis told us, we were able to --

Q. My question was: Mr. Davis told you and you just you

made up your mind; correct?

A. No.

Q. Does it look like he's hiding it from anybody?

THE COURT: Who is "he"?

MR. FAZEL: I'm sorry. Mr. Stanford.

THE COURT: Just to be --

MR. COSTA: He's not even on the e-mail. I'm

not sure what the.

MR. FAZEL: That's my point. There's two

people talking about something that not -- Mr. Stanford is

not even in it.

THE WITNESS: Well, those are two assistants --

two of Mr. Stanford's assistants who are actually the ones

going out looking.

BY MR. FAZEL:

Q. Well, why wouldn't he just go pay it in cash and hand

it to him, then?

A. I can't speak for Mr. Stanford.

Q. Well, if somebody was trying to hide something,

wouldn't that be the smarter thing to do?

A. I can speculate.

Q. As a matter of fact, this e-mail chain indicates that

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:40:57

03:41:09

03:41:22

03:41:31

03:41:46



3988

Mr. King couldn't even get a hold of Mr. Stanford; right?

Do you want me to bring up the e-mail

again, Agent?

A. I know that's in one -- I know that's in one of the

e-mails? I'm just not sure if it's in this one.

Q. It's clear that Mr. King couldn't get a hold of

Mr. Stanford; right? Remember this interchange with the

prosecutor where he went over all the numbers that he had

for Mr. King? Remember that?

A. Yeah.

Q. And do you remember -- oh, by the way, do you know

that this document here -- were you aware that this is

printed for everybody at Stanford? This is printed out;

right? It's not handwritten, is it? "This" being

Government's Exhibit -- I don't remember -- 1500?

This Exhibit 1500, are you familiar with

this exhibit?

A. Yes.

Q. Okay. That document itself is printed on it;

correct?

A. Yeah. Yes. It's typewritten, yes.

Q. In other words, doesn't it appear -- and if you don't

know, you don't know. Does it appear to be a company

directory?

A. I don't believe this was a company directory.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:41:57

03:42:42

03:43:01

03:43:11

03:43:23



3989

Q. You don't believe it was?

A. No.

Q. You didn't have any knowledge that other people had

this exact same directory? Now, there may be handwriting

on this one, but the exact same directory as this one?

A. I'm not aware of any -- anyone else having that same

one.

Q. Do you remember talking about an American Express

ticket, credit card?

A. Yes.

Q. Government's Exhibit 2?

A. Yes.

MR. FAZEL: Could you bring that up, please.

Could you go to Page 5 for me, please.

Can you highlight --

BY MR. FAZEL:

Q. And I believe Mr. Costa spoke to you about this.

MR. FAZEL: Could you highlight where the bill

was mailed to it? Should be at the very bottom. Right

there. Care of.

BY MR. FAZEL:

Q. Who is Mr. Harry Failing?

A. He was Mr. Stanford's personal CPA.

Q. So Mr. Stanford is bribing Mr. King, putting the

money on his credit card, and then having the bill sent so

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:43:47

03:44:00

03:44:15

03:44:32

03:44:41



3990

his CPA?

A. Yes. The only thing reflected on the American

Express statement is who was the merchant.

Q. Agent, wouldn't it be a lot smarter not to do that,

not to send it to your CPA, not to send it to your

attorney, if you're trying to bribe somebody? If you

wanted to bribe somebody, would you go to a lawyer? Would

you come to me and say, "Hey, I want to bribe somebody. I

want to bribe somebody?" Is that the way you bribe

somebody?

A. Well, I can't -- I've never bribed anybody, so I

don't really know; but on this statement -- on the

statement doesn't -- there's nothing wrong with him -- it

doesn't say anything on there who the tickets are for or

what was actually been purchased.

Q. My point is, Agent: That if he wanted to keep this a

secret and not let anybody know, would he put it on his

company credit card? Would he let his CPA know?

MR. COSTA: Your Honor, we're willing to

stipulate there are smarter ways to bribe people than

Mr. Stanford did. I don't think he needs to continue with

the questioning.

THE COURT: Are you going to accept that

stipulation?

MR. FAZEL: No, I'm not.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:44:51

03:45:04

03:45:18

03:45:32

03:45:47



3991

THE COURT: All right. Keep going.

BY MR. FAZEL:

Q. You're the one with 11 years of experience; right?

A. Yes.

Q. You're the one in front of this jury telling them,

"Oh, he's bribing Mr. King"; right?

A. Yes.

Q. All right.

A. There's always a -- I mean --

Q. There is always paper trails, Agent?

A. Most transactions, but there's always --

Q. There's always 14 assistants or 10 assistants or 2

assistants that know about it, Agent? There's always

specific cash transactions coming in and out of a bank

every time a cash is withdrawn, Agent?

Isn't it true that the cash transactions

that we looked although were petty cash. It was like a

million dollars for how many years are we talking about?

A. 2005 to 2009.

Q. For how many years of that?

A. Five.

Q. In five years, did you try to trace what happened to

the cash that was withdrawn by Mr. Stanford? Did you

investigate that?

A. Well, I def -- cash is just --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:45:56

03:46:07

03:46:21

03:46:32

03:46:40



3992

Q. It's fungible; right?

A. Yeah.

Q. Did you interview everybody at the Stanford entities?

A. No.

Q. Did you review Ms. Wingfield?

A. I did not, but I believe the Postal Inspection

Service did.

Q. Was there -- now, let me back up a little bit.

A. Okay.

Q. Do you remember testifying to this jury that in

February of 2009, that you were able to walk into the

Stanford companies and start looking at whatever documents

you want? Do you remember saying that?

A. No, I did not say I went in -- I said receiver went

in, in February of 2009.

Q. When did you go in?

A. April.

Q. I'm sorry. What? Two weeks later?

A. Two months.

Q. Two months later. I'm sorry. Two months later. Did

the receiver let you look at whatever documents you

wanted?

A. No. We made a -- we were there for meetings. We

asked. We asked.

Q. And then did they give them to you?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:46:53

03:47:05

03:47:16

03:47:23

03:47:35



3993

A. They made records available for us.

Q. Did you -- did they hand you the records you wanted

to see?

A. At that time, no.

Q. They just told you, no, they didn't want to give it

to you?

A. No. They made records available for us to review.

Q. Did they make copies for you?

A. We identified records that we wanted copies of.

Q. Agent, they cooperated with you; right? There's no

reason to beat around the bush.

A. Sure.

Q. They cooperated with you; right?

A. They cooperated with us as the -- as their orders

from the --

Q. So you had access to every document you wanted to

look at?

MR. COSTA: Would you let him finish his

answer? He keeps talking over his answer.

THE COURT: Sustain the objection.

You may finish your answer, sir.

BY MR. FAZEL:

Q. Sorry. Was there -- were you going to finish?

A. We -- I guess -- I think you're asking about

cooperation. Their -- the order appointing the receiver

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:47:52

03:48:04

03:48:17

03:48:28

03:48:42



3994

says that they need to cooperate with the regulatory

agencies and law enforcement investigations.

Q. So you had a Court order from a judge in Dallas

saying they had to cooperate with you; right?

A. Yes.

Q. And they had to give you whatever you wanted?

A. Not everything we wanted. What we -- if we requested

it?

Q. Which are one, is it, Agent? Did they have to

cooperate with you or not?

A. They had to cooperate.

Q. Did they give you everything you wanted?

A. That I'd asked for, yes.

Q. You had access to every piece of document at Stanford

that was in Houston; correct?

A. They did.

Q. You had access to all of their computer equipment;

correct?

A. The receiver did.

Q. And therefore, you did as well; correct, agent?

A. I -- I didn't have -- we didn't have access to all of

their systems.

We would ask for -- if we needed

certain -- needed something, we asked them.

Q. If you asked for a piece of document, a piece of

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:48:56

03:49:09

03:49:23

03:49:35

03:49:49



3995

correspondence, or anything the receiver had, did they

provide it to you?

A. That I'm aware of, yes.

Q. Okay. And in your entire inquiry, you were able to

look at whatever you wanted? Can we agree with that?

A. We didn't just have very rein. We had to ask, yes.

Q. God. I mean, once you asked, it was given to you;

correct?

A. Yes.

Q. Okay. So you had access to whatever you wanted;

correct?

A. Yes.

Q. All right. And in everything that you've looked at,

you're coming in front of this jury and saying, "I know he

bribed King because he had cash withdrawals and King had

cash deposits two or three weeks apart"; correct?

A. That isn't it.

Q. Huh? "I know he bribed King because he had cash

withdrawals out of Bank of Antigua, and then two weeks

later or three weeks later, he had deposits into his

account, but it was for different amounts"; correct?

A. There's also the Super Bowl tickets, sir.

Q. Correct? "I know he bribed King because he paid for

two Super Bowl tickets"; right?

A. In addition to the bank records and what Mr. Davis

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:50:00

03:50:08

03:50:20

03:50:28

03:50:39



3996

told us and the correspondence going back and forth

between the FSRC.

Q. We'll get to the correspondence in a minute.

A. Sure.

Q. We'll get to that in a minute.

But as far as the bank records are

concerned, Agent, there's nothing in the bank records that

indicated that Mr. Stanford paid anything to Mr. King.

Isn't that correct?

A. Well, there's the one transfer that we looked at

relating to the steel band.

Q. I see. So that's the one transfer.

Other than that, you have no proof that

the money that came out of Mr. Stanford's bank accounts

went into Mr. Davis -- Mr. King's account. Is that

correct?

A. We have what Mr. Davis told us.

Q. You have what Mr. Davis told us?

A. Yes.

Q. I got you. Other than Davis -- and the jury's heard

about Mr. Davis.

Other than Mr. Davis, do you have any

proof that the money that went from Mr. Stanford's account

was actually given to King and deposited into his account?

Do you have any proof of that?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

03:50:57

03:51:44

04:17:47

04:18:05

04:18:20



3997

A. No.

Q. Let's talk that correspondence you brought up.

THE COURT: Tell you what: It's now 10 minutes

to 4:00. Be a good time, I think, to take the afternoon

break.

Back on the clock, by the way. We caught

up.

We'll see you back in 20 minutes, ladies and

gentlemen, and then we'll go right to 6:00.



THE COURT: Be seated. Let's go, please.

MR. FAZEL: Thank you, Your Honor.

BY MR. FAZEL:

Q. Agent, it's kind of late in the afternoon, and we're

talking about numbers and accounting. And I know it can't

be any more boring than this.

But let's talk a little bit about your

testimony regarding the correspondence, if you will,

between Mr. King and the -- was it ECCB? Am I saying that

right?

A. Yes.

Q. Okay. All right. Now, we know that there's couple

of banks --

MR. FAZEL: I'm sorry, Your Honor.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:18:29

04:18:41

04:18:46

04:19:05

04:19:13



3998

THE COURT: That's all right.

BY MR. FAZEL:

Q. We know there's a couple of banks that have the same

acronyms, and we don't want to mess them up; okay? So we

know BOA is Bank of Antigua; correct?

A. Yes.

Q. And also Bank of America; correct?


Q. And Bank of America and Chase is where Mr. King had

his bank accounts?

A. Yes.

Q. Not Bank of Antigua?

A. That's correct.

Q. Okay. So if you were going to set up a system where

you were going to bribe somebody, wouldn't it be simpler

just to give them an account at your own bank?

A. I would not bribe anybody.

Q. Not my question. You're an investigator. You're a

law enforcement agent. Correct?

A. Yes.

Q. All right. You have investigated this case; right?

A. Yes.

Q. In your investigation, you know that Mr. Stanford is

a hundred percent owner of -- was a hundred percent owner

of Bank of Antigua; correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:19:20

04:19:30

04:19:53

04:20:25

04:20:36



3999

A. Yes.

Q. All right. You know that Mr. King does not have an

account in the Bank of Antigua; correct?

A. That's true.

Q. All right.

A. Uh-huh.

Q. Now, with all that said, wouldn't it be much simpler

to simply give him a bank account in the Bank of Antigua

and then put money into his account?

A. Yeah. Could have been, yes. Uh-huh.

Q. That's not what happened here, was there?

A. No.

Q. Now, the FSRC -- let me -- the FSRC is what regulates

offshore banks in Antigua; correct?


Q. The ECC -- this entity regulates -- regulates

currently and regulated in the past all offshore banks in

Antigua; correct?

A. Yes.

Q. There wasn't just one offshore bank in Antigua;

correct? There were multiple offshore banks in Antigua;

correct?

A. Yes.

Q. All right. SIBL was one of the offshore banks in

Antigua?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:20:51

04:21:03

04:21:20

04:21:30

04:21:42



4000


Q. All right. Now, then there is completely separate,

the ECCB; correct?

A. Yes.

Q. Do you know what that stands for?

A. I believe Eastern Caribbean Central Bank.

Q. They're the ones that control the Bank of Antigua;

correct?

A. Yes.

Q. All right. I just want to -- this is all correct;

correct?

A. Yes.

Q. All right. Do you remember speaking about the bank

accounts -- I'm sorry. Check that.

Do you remember talking about the

Government Exhibit 616?

A. Yes.

Q. Okay. And do you remember talking about Government

Exhibit 677?

A. Sounds familiar, yes.

Q. Okay. Starting with Government Exhibit 677, if you

will.

MR. FAZEL: If you can pull that up.

THE COURT: Has that been previously

identified?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:21:54

04:22:05

04:22:14

04:22:26

04:22:35



4001

MR. COSTA: Do you want me to move the chart?

MR. FAZEL: It has, Your Honor. Thank you.

THE COURT: Okay.

BY MR. FAZEL:

Q. Okay. Do you remember -- do you remember this

exhibit, Government Exhibit 677?

A. Yes.

Q. Who's Carlos Loumiet up there?

A. He was the attorney at Hunton & Williams.

Q. Okay. And who did he represent?

A. Mr. Stanford's banks.

Q. Mr. Stanford's bank?

A. Yes.

Q. Okay. Where did you get this e-mail document that

you talked to the jury about?

A. From the receiver.

Q. Did you request it from the receiver?

A. I did not personally, but I -- somebody.

Q. Somebody in your investigative group requested it

from the receiver, and the receiver gave it to you;

correct?

A. Yes.

Q. All right. Now, Mr. Loumiet is an attorney; correct?

A. Yes.

Q. And Mr. Stanford is speaking to him about the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:22:49

04:23:05

04:23:24

04:23:37

04:23:47



4002

correspondence and what's going on with the ECCB; correct?

A. Yes.

Q. Anything illegal about that?

A. No.

Q. Anything about this speaking to a lawyer about

circumstances he's found out about that makes you

suspicious? Do you understand my question?

A. Could you just repeat it?

Q. Sure. I mean, the crux of the government's direct

examination of you was, Oh, Mr. King said something to

Allen Stanford about ECCB's request, and Allen Stanford

then jetted off and did something, and this is part of the

relationship that Mr. King and Stanford had, and this is

why he was bribing him; right?

A. Okay.

Q. Is that a good summary?

A. Yes.

Q. Okay. It's clear from this e-mail interaction that

Mr. Stanford spoke to his lawyer; correct?

A. The bank's attorney, yes.

Q. And told the bank's attorney what he's found out;

correct?

A. Yes.

Q. If you were bribing somebody, would you tell a lawyer

that?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:23:58

04:24:09

04:24:20

04:24:32

04:24:41



4003

A. Personally, no.

Q. As an agent -- and by the way, they call you a

special agent; right?


Q. Okay. Special Agent Young; correct?

A. Yes.

Q. You're special because you enforce certain statutes

in USC? Is that why you're special?

A. Yes.

Q. And you know laws in the United States; correct? I

mean. They gave you a school about that; right? You went

to school about that?

A. Yes.

Q. You know about the statutes and the criminal laws in

the United States; correct?

A. The ones that the IRS has jurisdiction over, yes.

Q. You know generally what laws you can and can't -- you

know about that, the general laws, rules, conspiracy and

all that; right?

A. Sure.

Q. You understand that an attorney cannot engage in a

criminal conduct; right?

A. Sure.

Q. Just like you and I can't engage in criminal conduct

if we weren't attorneys; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:24:53

04:25:03

04:25:14

04:25:24

04:25:37



4004

A. True.

Q. You understand that an attorney cannot be protected

or shielded by the fact he or she is an attorney when he

or she knows there's criminal conduct occurring? You

understand that; right?

A. Yes.

Q. And it's clear from this interaction between

Mr. Stanford and lawyer that he has informed the lawyer of

what Mr. King has told him?

A. Sure.

Q. Not only that, this lawyer then goes ahead and gives

an opinion as to what he thinks of Mr. King; right?

A. Yes.

Q. Did the prosecutor put that up? I don't remember.

A. Yes.

Q. Okay.

A. It was the memo and attached was the subpoena.

Q. So it's clear to you that this lawyer, Mr. Loumiet,

has an understanding of what's going on between

Mr. Stanford and Mr. King; correct?

A. Sure, yes.

Q. Are you telling this jury that you have asked or

caused this lawyer to be indicted for bribery?

A. No.

Q. Are you telling this jury that this lawyer committed

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:25:52

04:26:03

04:26:13

04:26:21



4005

a crime?

A. No.

Q. If this lawyer didn't commit a crime by engaging and

obtaining information and working on information obtained

from Mr. Stanford, are you telling him -- are you telling

us that then Mr. Stanford engaged in a crime?

A. Can you repeat the question?

Q. Sure.

A. That was a pretty long question.

Q. This lawyer hasn't been accused of a crime; right?

A. True, uh-huh.

Q. And this lawyer knew exactly what was going on;

correct?

MR. COSTA: Object to what he says, "exactly

what was going on."

MR. FAZEL: All right. I'll rephrase -- let me

rephrase the question, Your Honor.

MR. COSTA: Whether he means the bribe or the

Super Bowl tickets.

MR. FAZEL: I object to the side bar.

MR. COSTA: Asking for clarification, Your

Honor.

THE COURT: Get a clarification.

MR. FAZEL: Yes, Your Honor.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:26:37

04:26:42

04:26:56

04:27:05

04:27:13



4006

BY MR. FAZEL:

Q. We know from this e-mail chain that this lawyer was

informed by Mr. Stanford as to his concerns about what the

ECCB was doing. And we'll talk about that in a minute;

right?

A. Sure.

Q. We know that; right?

A. Sure.

Q. We know this lawyer knows exactly what has transpired

between Mr. King and Mr. Stanford discussing this ECCB

transaction; correct?

A. Yes. He knows that this has to have those -- the

MOUs.

Q. Sure.

A. Yes.

Q. And he knows where Mr. Stanford has obtained that

information from; correct?

A. Sure.

Q. And he knows what Mr. Stanford's concerned about;

correct?

A. Yes.

Q. He knows that he, "he" being Mr. Loumiet, has spoken

to Mr. Stanford and also spoken to Mr. King; correct?

A. Yes.

Q. Mr. Loumiet is not charged with a crime, is he?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:27:29

04:27:36

04:27:51

04:28:05

04:28:19



4007

A. No.

Q. And Mr. Stanford, what he did is, when he found out

or became concerned about something, what did he do? He

went to speak to a lawyer; correct?

A. That's one of the things. I don't know what else he

might have done, but he did.

Q. Right?

A. Yes.

Q. Okay. Just like when he gets his American Express

bill, he sends it to his accountant; correct?

A. Sure.

Q. So obviously, Mr. Stanford is engaging professionals

and discussing with them his issues, his business issues;

correct?

A. Sure.

Q. Is there anything criminal about that?

A. Discussing business issues with his attorney or his

CPA, no.

Q. Is that -- this question confusing to you, Agent?

A. There's nothing wrong with it.

Q. Do you want me to restate my question?

A. No.

Q. Is there anything criminal about discussing your

business matters with a CPA or an attorney?

A. No.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:28:31

04:28:47

04:29:07

04:29:17

04:29:29



4008

Q. And that is exactly what Mr. Stanford did under these

circumstances; correct?

A. Yes. That's what he's doing in this e-mail.

Q. And he told -- "he" being Mr. Stanford, explained to

Mr. Loumiet exactly what had happened with the ECCB and

wanted Mr. Loumiet to speak to Mr. King and give a legal

advice as to what ought to happen; correct?

A. From the e-mails, yes, that's what appears, yes.

Q. Is there anything criminal about that?

A. Just --

Q. Is there anything criminal about that, Agent?

A. No.

Q. Yes or no?

A. No.

MR. FAZEL: Let's move on to Exhibit 616.

BY MR. FAZEL:

Q. Do you remember this interaction that you went

through with the jury with the prosecutor?

A. Yes.

Q. Okay. I won't make the jury go through this a second

time, but let's talk about it.

This interaction is between counsel;

correct, and Mr. King; correct?

A. Yes.

Q. Counsel being who?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:29:37

04:29:43

04:29:58

04:30:03

04:30:18



4009

A. Mr. Alvarado.

Q. Is he accused of a crime?

A. No.

Q. Is he indicted for bribery?

A. No.

Q. Is Mr. Stanford indicted for bribery?

A. No.

Q. Is anybody indicted for bribery?

A. No.

Q. All right. Is there anything illegal with counsel of

a company discussing matters with a regulator?

MR. FAZEL: Bless you. Was that a sneeze?

MR. STELLMACH: No.

MR. FAZEL: I'm sorry. I'm sneezing so much,

I'm hearing sneezing.

BY MR. FAZEL:

Q. Is there anything illegal about that?

A. Discussing matters?

Q. Right?

A. No?

Q. Is there anything untoward about this interaction,

616, between counsel of bank and a regulator?

A. Well, the counsel for the bank is writing responses

for on behalf of the regulator.

Q. I see that.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:30:28

04:30:47

04:30:54

04:31:11

04:31:20



4010

A. Yes.

Q. And my question to you is: Is there anything illegal

about that?

A. In and of itself, no. It sure would raise some red

flags that an entity is drafting responses for their

regulator to send to another regulator. That would raise

some red flags.

Q. And that's what rose a red flag to you? That's what

was so suspicious; right? That's what 11 years of your

hard training in criminal law has taught you? That's

suspicious; right? Right?

A. Yeah.

Q. That's what you're telling this jury; right?

A. Yes.

Q. All right. Let's talk about it.

MR. FAZEL: Let's move to Exhibit -- the same

exhibit, Page 2.

Q. First, so that we're real clear, come all the way

down, if you will, please, to the bottom of the page.

Highlight that says "FOIA" right there for me, would you?

BY MR. FAZEL:

Q. See that bottom part that says FOIA.

A. Yes.

Q. What does that say, Agent? Read it for us.

A. "FOIA. Confidential treatment requested by Ralph S.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:31:36

04:31:40

04:31:47

04:31:54

04:32:06



4011

Janvey as receiver for R. Allen Stanford, James M. Davis,

Laura Pendergest Holt, Stanford Group Company, Stanford

Capital Management, LLC, Stanford International Bank,

Limited, Stanford Financial Group and the Stanford

Financial Group Building, Inc."

Q. Who's Janvey?

MR. FAZEL: Thank you. You can unlock --

THE WITNESS: The receiver.

BY MR. FAZEL:

Q. The receiver?

A. Yes.

Q. This is where you got this information from; right?

A. Yes.

Q. Two months after a receiver took over, they let you

in the doors and you got to go through whatever you

wanted; correct?

A. Not whatever we wanted.

Q. Really?

A. Yes.

Q. Okay. Let me ask you this: What document did you

want that they didn't provide to you? Tell me. Name one

single document you requested the receiver to produce to

you and you didn't -- they didn't produce.

MR. COSTA: I object to the implication. Both

sides have had access. There was a hearing in this court

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:32:17

04:32:23

04:32:32

04:32:47

04:33:02



4012

in which you ordered the receiver to provide access to both

sides.

MR. FAZEL: Your Honor, I would object to

talking objections. If he's got an objection that's legal

in nature, let him draw it. If not, I'd object to that.

THE COURT: He's already said it.

MR. FAZEL: I understand it.

THE COURT: I've sustained it. Get around it.


BY MR. FAZEL:

Q. Is there any documents that you requested of the

receiver that you did not obtain?

A. No.

Q. All right. Now, is there anything in that letter

that you see that's false?

A. No.

Q. And tell the jury how this is -- any parts of it is

false?

A. Nothing -- none of it is false. I never claimed that

any of this was false.

Q. Okay. So is this going to the regulator now, to the

ECCB; correct? I mean, this is what you're telling this

jury, right, that all this money, all these Super Bowl

tickets has bought Mr. Stanford this letter; right?

Right? Tell us what's false about it.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:33:15

04:33:28

04:33:53

04:34:45

04:35:00



4013

A. I never claimed that there's anything false with this

letter.

Q. Is there anything -- any of these facts incorrect?

A. No.

MR. FAZEL: Can you zoom out, please. Could

you zoom to the board of directors on it?

BY MR. FAZEL:

Q. Anything about that false?

A. Not that I'm aware.

Q. And you've been investigating this case, correct,

from the beginning; correct?

A. Yes.

Q. Okay.

MR. FAZEL: Can you zoom out, please?

Can I have a minute, Your Honor?

THE COURT: Yes, sir.

BY MR. FAZEL:

Q. Agent Young, in your investigation with your obvious

open door to the receiver, you were able to look through

all the documentations that was available; correct?

A. Yes.

Q. Okay. Were you able to look at the accounting

records for SIBL?

A. Only those that were located in Houston.

Q. Okay. Did you not have access to anything else?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:35:12

04:35:28

04:35:42

04:35:51

04:36:02



4014

A. We didn't have access to -- initially didn't have

access to any of the records in Antigua.

Q. Did you at some point obtain access to those records?

A. Yes.

Q. And what records are we talking about? Were they

SIBL records?

A. Yes.

Q. Okay. And who gave you access to those records?

A. Well, that was part of the MI agreement -- request.

We traveled to Antigua; and, so, I presume the Antiguan

receiver, liquidator or whatever his title is.

Q. And he or she gave you access to the bank, SIBL,

itself?

A. Yes.

Q. Did you walk into the bank?

A. Yes.

Q. Did you have access to their computer system?

A. I did not, no.

Q. Did somebody in your group have access to the

computer system?

A. To some computers. I'm not sure if it was their

whole system or individual desktops, but yeah.

Q. Was there any piece of information or correspondence

that you requested from the folks in Antigua that they

refused to give you?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:36:16

04:36:34

04:36:42

04:36:47

04:36:59



4015

A. I never asked them, so -- for any particular

documents.

Q. Was there any piece of information or correspondence,

electronic or otherwise, that you requested of -- you or

anybody in your group that traveled to Antigua, that you

requested of the Antiguan authorities that they did not

provide for you?

A. I don't know either way. If other people had asked,

if other people in the party had asked them and then not

gotten anything or not, I don't know.

Q. You wouldn't be aware of it if somebody asked for

something and you didn't get it? You wouldn't be aware of

that?

MR. COSTA: Let him answer. He didn't --


MR. COSTA: Maybe you could ask him if he made

the request to Antigua.


BY MR. FAZEL:

Q. If you're in a group going to Antigua and somebody in

your group requests something of the Antiguan authorities

and they don't receive it, you wouldn't be made aware of

that?

A. No.

Q. When you -- did you personally walk into the bank in

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:37:10

04:37:31

04:37:41

04:37:50

04:38:05



4016

Antigua, the SIBL?

A. Yes.

Q. Did you personally go through the records of the bank

in SIBL?

A. I think when I went there to look around, I took

photographs. I don't recall looking through any --

personally looking through any of the records.

Q. Could you tell this jury who went with you?

A. There were Mr. Andrew Warren.

Q. And Mr. Warren is this gentleman right here sitting

at the counsel table with the blue tie?

A. Yes.

Q. Okay. Who else?

A. Inspector Gerber.

Q. And Inspector Gerber is the gentleman back there with

the yellow and blue tie?

A. Yes.

Q. Okay. Who else?

A. There were a couple other postal inspectors that I

don't -- I have their cards somewhere --

Q. That's okay.

A. -- but I don't remember their names.

Q. Anybody else?

A. Just a couple of postal inspectors.

Q. Okay. And this group of people that went in there,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:38:20

04:38:33

04:38:39

04:38:54

04:39:28



4017

were -- did they do a thorough job of going through the

bank and obtaining information they wanted?

A. We weren't there to search -- to conduct the search.

Q. What were you doing in the bank?

A. The liquidator was giving us a tour.

Q. You only got a tour? You didn't get to look at their

documents or anything like that?

A. I didn't look at their documents.

Q. Did anybody else in the group get to look at their

documents?

A. I believe some of the postal inspectors looked at --

looked at some of the computers that we talked about

earlier.

Q. So they got to look at -- they got to access the

information in SIBL?

A. Some, yes.

Q. Okay. So they had clear information as to

information that they need to be able to demonstrate --

check that.

They were able to obtain banking information

of SIBL; correct?

A. I don't know what they obtained.

Q. They never shared that with you?

A. No.

MR. FAZEL: I pass the witness, Your Honor.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:39:47

04:39:59

04:40:04

04:40:14

04:40:19

Redirect-Young/By Mr. Costa


4018


BY MR. COSTA:

Q. Agent Young, do you remember towards the end there

when Mr. Fazel was asking you questions about Carlos

Loumiet, this lawyer in Florida that Mr. Stanford was

corresponding with?

A. Yes.

Q. Do you remember Mr. Fazel was giving his explanation

of an alternative universe where every lawyer is honest

and would never break the law? Do you recall those

questions?

MR. FAZEL: Your Honor, I object to that

question.

THE COURT: Why?

MR. FAZEL: It's sidebar. It's argumentative.

MR. COSTA: It's a question.

MR. FAZEL: It's leading.

MR. COSTA: I'm asking if he recalls the

question. You can do that -- I'm just trying to focus the

redirect.

THE COURT: Rephrase it if he has an objection.

If you get around it, I'll rule on it.

BY MR. COSTA:

Q. Do you remember Mr. Fazel's questions where he said

lawyers aren't supposed to do anything dishonest; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:40:26

04:40:42

04:40:54

04:41:04

04:41:13



4019

A. Yes.

Q. And lawyers aren't supposed to do anything illegal;

right?

A. Yes.

Q. Are you aware that Mr. Loumiet, there are public

reports that he was under federal investigation for a

number of years?

A. I am aware he was under investigation for some kind

of work that he did for another -- for a bank.

Q. Another offshore bank?

A. A bank in Florida. That's all I saw, that I recall.

Q. And there's public reports that he was under federal

investigation for a number of years for the legal work he

did for another bank; is that right?

A. Yes.

Q. That's the honest, ethical, typical lawyer Mr. Fazel

was referring to?

MR. FAZEL: Object to leading. Object to

mischaracterization of the question.


THE WITNESS: It was the same Carlos Loumiet.

BY MR. COSTA:

Q. That Mr. Stanford's bank had hired --

A. Yes.

Q. -- to be their lawyer?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:41:27

04:41:34

04:41:42

04:41:52

04:42:00



4020

A. Yes.

Q. Mr. Fazel asked you a number of questions about, if

these were bribes, why would there be all these records;

correct?

A. Yes.

Q. And I think he was asking you about why would there

be a paper trail.

Do you remember those questions?

A. Yes.

Q. And he asked you if, in your experience, when you

build cases, there's typically such a paper trail.

Do you recall that?

A. Yes.

Q. And I think you were trying to say something, and he

cut you off.

In your experience, are federal fraud

cases typically built on paper documents?

A. Yes.

Q. And he asked you about the withdrawals Mr. Stanford

made in cash, remember, over 2 million Eastern Caribbean

dollars? Do you recall those questions?

A. Yes, I do.

Q. He called it "petty cash."


A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:42:11

04:42:22

04:42:29

04:42:45

04:42:52



4021

Q. Is two and a half million dollars petty cash to you?

A. No.

Q. Okay. And he said, "Why would Mr. Stanford have

these withdrawals slips if these were bribes?"


A. Yes, I do.

Q. When you were able to get these records from Antigua

through the MLAT process, was Mr. Stanford still in

control of Bank of Antigua?

A. No, he was not.

Q. But the whole time he controlled the bank, it would

have been the bank's decision whether they turned over

records; correct?

A. That's correct.

Q. And until February 2009, Mr. Stanford owned the bank

that controlled those records; correct?

A. That is correct.

Q. Do you remember he also asked you, "Wouldn't it be

easier, rather than withdrawing the money, the cash,

personally to give it to a hundred people to hand over to

Mr. King?"


A. Yes, I do.

Q. If he gave it -- had a hundred people do the bribing,

how many people would know about the bribes?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:43:09

04:43:13

04:43:33

04:43:46

04:44:07



4022

A. A hundred plus the people in the bank who was

withdrawing the cash.

Q. And then Mr. Fazel asked you questions about the

Super Bowl tickets.

Do you recall that?

A. Yes, I do.

Q. Again, these questions of why would it be out in the

open?

A. Yes.

Q. And he showed e-mails?

MR. COSTA: Your Honor, if we could get the

ELMO projector, please.

BY MR. COSTA:

Q. And I'm showing you Government's Exhibit 657.

Is this the e-mail about Super Bowl

tickets that Mr. Stanford is actually copied on or a

recipient on and sending messages?

A. Yes.

Q. And this is January 22nd. And he says, "Linda, get

the Super Bowl tickets."

Any indication here where Mr. Stanford

says they're for Leroy King?

A. No.

Q. And then later on at 6:58, this is an e-mail between

Ms. Wingfield and Ms. Hodge; correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:44:15

04:44:24

04:44:41

04:44:48

04:45:04



4023

A. Yes.

Q. And at this point, they've heard -- not an e-mail,

but someone's heard from Mr. Stanford that they're

actually from Mr. King; correct?

A. Yes.

Q. And is Ms. Wingfield, in that top message, surprised

to have heard they were for Mr. King?

A. Yes.

Q. That's when she said, "If I'd known knew they weren't

for Mr. Stanford himself, I wouldn't have gotten such good

tickets"; right?

A. Yes, that's what it says.

Q. Before the break when Mr. Fazel first started asking

you questions, he was asking you about dual regulation of

banks.


A. Yes, I do.

Q. And he was saying what's wrong -- it's commonplace

that two different entities will regulate banks; right?

A. Yes.

Q. And is that what was going -- what the ECCB was

trying to do in 2006 in those e-mails and faxes we saw --

let me back up.

As Mr. Fazel explained, the SIB was

normally regulated by the FSRC, the regulatory commission

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:45:22

04:45:32

04:45:44

04:45:55

04:46:12



4024

in Antigua; correct?

A. Yes.

Q. And what was going on in those 2006 e-mails and faxes

was that this regional regulator, the ECCB, was also

trying to get -- what was it called -- coordinated

supervision of SIB?

A. Yes, similar -- it's either that or consolidated

supervision, yes.

Q. Consolidated; right?

A. Yes.

Q. Because normally it just regulated Bank of Antigua;

correct?

A. Yes.

Q. And, so, what was happening in 2006 was the regional

regulator -- did Leroy King work for the ECCB?

A. No, he did not.

Q. Did you see any evidence that anyone from the ECCB

was getting Super Bowl tickets from Mr. Stanford?

A. No.

Q. And, so, this entity that Leroy King was not involved

with, in 2006, was trying to get some degree of regulation

over Stanford International Bank. Is that correct?

A. Yes.

Q. And this is, Mr. Fazel said, dual regulation, two

regulators. He said there's nothing wrong with that. It

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:46:25

04:46:51

04:47:01

04:47:15

04:47:25



4025

happens all the time. Right?

A. Yes.

Q. In that e-mail to Mr. Loumiet, was that

Mr. Stanford's reaction? It's fine to have two

regulators; it happens all the time?

A. No.

Q. In fact --

MR. COSTA: If we can go -- can we switch to

the ELMO -- or I'm sorry -- the computer, Your Honor?

Oh, hold on. I've got it here. I can do

it on the -- I'll do it where we're at.

THE COURT: Okay.

BY MR. COSTA:

Q. Going to Government's 677. This is in response to

this attempt at dual regulation, having two regulators,

look at SIB that Mr. Fazel said is perfectly normal and

happens all the time.

This was what Mr. Stanford is saying,

"Carlos, this issue is of" --

A. Extreme.

Q. -- all caps, "EXTREME importance and represents a

minefield for Antigua and Stanford."

That was his reaction to dual regulation;

correct?

A. Yes.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:47:49

04:48:00

04:48:05

04:48:16

04:48:30



4026

Q. I think the final issue I want to address is the

address book.

Do you remember Mr. Fazel asking, "Isn't

it possible that this Leroy King -- all these Leroy King

numbers" -- he said, "Isn't it possible that's just part

of the part of the Stanford corporate directory?"

Do you remember the question?

A. It wasn't a question. He was intimating that the

book was handed out to everyone, but yes.

Q. But that it came from a corporate -- it was a

corporate directory; right?

A. Yes.

Q. And you said you don't know if it's a corporate

directory?

A. That's correct.

Q. A corporate directory usually lists the employees of

a corporation; correct?

A. Yes.

Q. The people on the payroll; correct?

A. Sure.

Q. So if Mr. Fazel is correct that this is -- this comes

from a corporate directory of the Stanford business, that

would mean that Mr. King's on the payroll of Stanford?

A. Yes.

MR. COSTA: Pass the witness, Your Honor.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:48:42

04:48:54

04:49:07

04:49:17

04:49:26

Recross-Young/By Mr. Fazel


4027

MR. FAZEL: Can I have the corporate directory

back?

RECROSS EXAMINATION

BY MR. FAZEL:

Q. Have you ever worked in the corporate world before?

A. No.

Q. Are you aware or did you know that, in many corporate

companies in America, they have the names of the

regulators or outside people that they need to contact

with on a recollect basis? Did you -- were you aware of

that?

A. No. I don't know either way.

Q. So does that change your mind about the last

testimony about him, Mr. King, being on the payroll?

A. (No audible answer).

Q. No?

A. No.

Q. Do you think Mr. King was on Mr. Stanford's payroll?

A. No, he wasn't. Not -- not in the payroll, payroll

paying system, no. That would have showed up in his tax

return.

Q. Now, let me ask you something about regulators.

Mr. Costa went into great detail about

regulators; right?

Is there something unusual about a

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:49:38

04:49:54

04:50:09

04:50:16

04:50:22



4028

businessperson not wanting more regulations?

A. No. That's what -- how lobbyists make their money.

Q. That's how lobbyists make their money.

A. Yeah.

Q. Now, let me ask you something else: Do you remember

Mr. Costa talking about Mr. Stanford and his problems with

the regulator or the ECCB coming in? Do you remember

talking about that?

A. Yes.

Q. Are you familiar what the ECCB was trying to do with

SIBL and Antigua?

A. From the correspondence?

Q. Right.

A. They were trying -- well, the letters were they were

trying to get information on the affiliates --

Q. Right. But --

A. -- from Antigua.

Q. -- that's -- that's what they were trying to do: Get

information from the affiliates?

A. Uh-huh.

Q. And -- is that a "yes"?

A. Yes. I'm sorry.

Q. And were they able to obtain that information?

A. I believe so, yes.

Q. Okay. Because we just -- just before I passed you, I

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:50:34

04:50:44

04:50:59

04:51:09

04:51:23



4029

showed you the letter that -- I asked you what part of

that is fraud or fraudulent or a lie or a mistake or a

misstatement? And you said none. Everything was correct.


A. Sure. But what you showed me was the draft copy

going to -- not the one that was actually sent to the

ECCB.

Q. Are you telling this jury that a different copy was

sent to the ECCB?

A. No. I'm just telling you that that's not the letter

that was sent. That -- the one that you showed me was a

draft that was sent to --

Q. My question to you is: Are you aware of any evidence

that you can tell us that that particular draft or

something very similar to it wasn't sent to the ECCB?

A. No.

Q. All right. So we know it was sent to the ECCB;

correct?

A. Okay.

Q. All right. Is that a "yes"?

A. Yes. Sorry.

Q. All right. Are you familiar with or can you testify

about the facts surrounding what it was that the ECCB was

trying to accomplish by coming into Antigua and regulating

the offshore banks? What were they trying to do?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:51:36

04:51:46

04:51:51

04:51:56

04:52:09



4030

Do you know that?

A. No. I can just go by what was in the correspondence.

Q. Right. You only know what the little amount of

correspondence says. You don't know anything about the

financial issues regarding how much money that the

offshore banks had to pay ECCB; correct? You don't know

anything about that; right?

A. No.

MR. COSTA: Object. Is it a question or is he

letting him answer?

THE COURT: All right. Question, please.

MR. FAZEL: That was a question.

MR. COSTA: There was no answer.

MR. FAZEL: He did answer. He said, "No."


MR. COSTA: I didn't hear --

THE COURT: The next question.

THE WITNESS: Okay. Sorry.

MR. COSTA: I didn't hear the response.

BY MR. FAZEL:

Q. Did you know of type of financial drain or monies

that were would have to be given to the ECCB if they were

also to regulate the offshore banks?

A. No.

Q. Do you know any of the concerns that Mr. Stanford had

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:52:24

04:52:39

04:52:54

04:53:17

04:53:35



4031

about what was going on if the ECCB came in? Do you know

any of it?

A. From the correspondence, no.

Q. Okay. So you're just assuming -- you're going along

with the prosecutor. And I understand. I mean, you are a

government agent.

But you're going along with the

prosecutor's version that there's something wrong about

Mr. Stanford not wanting additional regulation; correct?

A. No. I'm just relaying what the correspondence says.

Q. Fantastic. Then you will agree with me that you

don't have all the facts surrounding what it was that the

ECCB was trying to do and why Mr. Stanford was concerned

about it.

Would you agree with that?

A. Sure.

Q. The Super Bowl tickets. Let's talk about it.

MR. FAZEL: Could you pull up Exhibit 658.

I'm sorry, Your Honor. Could you switch

to us?

THE COURT: Okay.

BY MR. FAZEL:

Q. Do you remember testifying about the fact that it was

a surprise to the people in this e-mail chain about the

Super Bowl tickets; right?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:53:45

04:53:59

04:54:10

04:54:21

04:54:31



4032

A. Yes.

Q. Could you point to the surprise, please?

A. Well, someone's highlighting it for me.

MR. FAZEL: Don't highlight it. I want the

agent to tell us all about the surprise.

BY MR. FAZEL:

Q. Show me. Where -- tell me where it says "surprised."

MR. COSTA: Stop playing with the document.

THE WITNESS: "I really wish I would have known

the tickets I bought for RAS were not for him. I would not

have gone through so much trouble!!"

BY MR. FAZEL:

Q. And that's a surprise?

A. She's saying that she didn't know they were for

him -- they were not for him.

Q. And that's what you mean by "surprise"?

A. You're using the word "surprise," but --

Q. Agent, I'm note using the word "surprise" --

A. I mean, it's not.

Q. -- I'm using the words that the prosecutor is using.

A. Okay.

Q. The prosecutor asked you something about being

surprised, and I said, "Yes, they were surprised."

And I'm asking you to show me where the

surprise is in that e-mail.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:54:38

04:54:50

04:55:03

04:55:17

04:55:31



4033

A. I just did.

Q. Okay. And, so, you're taking the position that the

surprise is that they didn't know about Mr. Stanford

buying those tickets for Mr. King; right? Is that

correct?

A. Yes, yeah.

Q. Okay. Does it show in that e-mail that they do know

at some point that it was for Mr. King?

A. Yes, that last part that I just read.

Q. All right. And do they show any kind of -- is there

anything in that e-mail that shows that they're like, "Oh,

my gosh. We shouldn't do this, this is illegal, this is

improper," or anything like that?

A. No.

Q. Does it -- can you detect from that e-mail that

somebody told them this was for Mr. King?

A. On this particular one?

Q. Yes.

A. Can you please scroll down.

Q. Sure, agent. Where would you like to scroll down to?

A. The lower part of the e-mail. I can't -- right there

on --

MR. COSTA: Can you please give him a copy?

THE WITNESS: Original message from Linda

Wingfield, the date January 29, 2004, 11:17 a.m.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:55:42

04:55:57

04:56:12

04:56:27

04:56:37



4034

"Let everyone know he told me the XB

tickets are for Leroy King."

BY MR. FAZEL:

Q. So he had -- "he" being Mr. Stanford, had told

everybody. Is that what that says?

A. No. I don't know what you mean by "everybody."

There's two people corresponding here.

Q. Everybody on that e-mail; correct?

A. Okay. But you said everybody, so -- and versus two

people.

Q. Does it seem from that e-mail that he's trying --

"he" being Mr. Stanford is trying to hide it from anybody?

A. Definitely not these two employees.

Q. Is there anything in that e-mail chain or anything

that you can point to that you've talked about with the

prosecutor that you can show us that says, "Mr. Stanford

asked us not to discuss this"?

A. No.

Q. Is there anything that you can point to or show us

that you can -- that we can look at that says

"Mr. Stanford wants this to be a secret"?

A. No.

Q. Is there anything that you can point to that says.

"Mr. Stanford doesn't want anybody to know we're going for

put this on a special credit card"?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:56:49

04:57:00

04:57:17

04:57:31

04:57:50



4035

A. No.

Q. Did they treat this as they treat any other business

activity in their office?

A. I don't know.

Q. Does it appear from the evidence before you that they

treated this like any other business activity in their

office?

A. No.

Q. It does not appear that way?

A. Well, it doesn't appear -- I mean, it doesn't reflect

either way if they treated it the same or different than

any other business expense in the office.

Q. So we can conclude, therefore, that they treated this

interaction as they do with any other interaction in their

office?

A. Without seeing everything else that took place in the

office, no.

Q. Is there anything on that piece of correspondence,

Agent, that tells you that they're treating this in any

way special?

A. No.

Q. That they're hiding this from anybody?

A. No.

Q. Now, do you remember the prosecutor, Mr. Costa,

talking about an attorney and saying that he was

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:57:56

04:58:16

04:58:27

04:58:43

04:58:51



4036

investigated. Do you remember that?

A. Yes.

Q. Do you remember that investigation?

A. Sure.

Q. Was he ever charged with anything?

A. I believe he was charged civilly by --

Q. How do you charge somebody civilly?

A. Well, a complaint was filed against him civilly.

Q. Okay. But was there a criminal charge against him?

A. Not that I'm aware of.

Q. Okay. Do you know anything about the facts of

those -- or circumstances around those charges or

allegations?

A. No, only what I've seen on the media.

Q. Okay. Are you or Mr. Costa -- or I don't know if you

can answer for Mr. Costa, but are you in the position or

do you regularly suppose things about other people's

credibility or other people's integrity?

A. No.

Q. Are you telling this jury that Mr. Loumiet did

something criminal?

A. No.

Q. No?

A. I never said that.

Q. But that was the supposition of Mr. Costa's

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:59:01

04:59:09

04:59:21

04:59:29

04:59:45



4037

questioning, wasn't it?

MR. COSTA: It wasn't supposition. The

question was: Was he under federal investigation?

THE COURT: Do you object.

MR. COSTA: Yes. I object to the

mischaracterization of the testimony.


BY MR. FAZEL:

Q. Did it leave an impression with you from the question

asked that he's attacking the credibility of Mr. Loumiet?

A. "He" being who?

Q. The prosecutor.

A. Okay.

MR. COSTA: Object to the speculation of what

I'm trying to do or what I'm doing.


MR. COSTA: The testimony speaks for itself.


BY MR. FAZEL:

Q. Do you remember the interaction between Mr. Mauricio

Alvarado and Mr. King? Do you remember talking about that

just a little while ago?

A. Yes.

Q. Do you have any information that Mr. Alvarado

committed a crime?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

04:59:52

05:00:12

05:00:26

05:00:41

05:00:50



4038

A. No.

Q. Is he charged with a crime?

A. Not that I'm aware of.

Q. Okay. Are you going to take the position that he --

MR. COSTA: Your Honor, may we approach.

THE COURT: Sure. Come on up.


THE COURT: Okay.

MR. COSTA: He's going down this line with

Mr. Alvarado, we don't want to reveal who our targets

investigations, but he is still being looked at in this

investigation. He's working down in Colombia now.

It's putting me in a bind because it's

against our policy to bring out who are targets of

continuing criminal investigations. Yet, he's -- Mr. Fazel

is asking questions leaving the impression that

Mr. Alvarado is somehow -- his conduct is not being

questioned at all in this matter. So I would -- unless

he -- do you understand the bind I'm in?

THE COURT: I understand completely.

MR. COSTA: I don't want it publicly to come

out who are targets of this continuing Stanford

investigation.

MR. FAZEL: If I could comment, Judge, and with

all due respect, Mr. Costa brought it out first.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:00:54

05:01:03

05:01:13

05:01:21

05:01:29



4039

THE COURT: How?

MR. FAZEL: He mentioned that he was a target.

MR. COSTA: No, I didn't. We're talking about

Mr. Loumiet was a -- we're talking Mr. Alvarado now.

MR. FAZEL: We're talking about two

different --

MR. COSTA: Loumiet has nothing involved --

yeah. Loumiet is not a target in Stanford. It's a totally

different issue.

THE COURT: What's your response?

MR. FAZEL: My response is I have the right to

cross-examine somebody, and if the agent is not aware of

it, thea gent's not aware of it. I mean, there's not much

I can do it about it.

MR. COSTA: But we've limited -- it's against

DOJ's procedure to out someone as a target of a pending

investigation.

MR. FAZEL: I appreciate that.

MR. COSTA: I don't see how it's relevant

either.

MR. FAZEL: Well, it's very relevant because,

on recross, he took the position this lawyer was somehow

corrupt or --

MR. COSTA: Mr. Loumiet.

MR. FAZEL: I understand that.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:01:35

05:01:55

05:02:01

05:02:13

05:02:30



4040

MR. COSTA: But you're asking questions

about --

MR. FAZEL: The other lawyer that's been

involved in that and this is also counsel.

THE COURT: Can you object to that line of

questioning?

MR. COSTA: Yes.

THE COURT: Overruled. Nothing I can do.


BY MR. FAZEL:

Q. Agent, do you remember the question?

A. Could you repeat it?

Q. Sure.

A. It's been a couple minutes.

Q. That's all right. It's been a long day.

Are you aware of any information -- do you

have any information, do you have any information that

Mr. Mauricio Alvarado committed any crimes or is being

charged with anything?

A. No.

Q. Okay. Now, do you remember, right when Mr. Costa got

you on redirect, he talked about paper documents and paper

trails?

A. Sure.

Q. And he said, "Well, aren't most federal white collar

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:02:39

05:02:52

05:03:04

05:03:17

05:03:37



4041

investigations" -- I think is what he was referring to --

"white collar investigations made from paper?"

A. That's correct.

Q. Do you remember that?

A. Yes.

Q. And you said, "Yes, they are"?

A. Uh-huh.

Q. Well then, Agent, wouldn't somebody who is trying to

thwart, hide, or do something illegal then avoid creating

paper trails?

MR. COSTA: Object to the speculation, Your

Honor.

THE COURT: Hold it. It's going to come up.

Overrule the objection. I think he's answered this

question before. I'll allow him to go into it.

THE WITNESS: Sure. Defendants typically try

to do that, yes, uh-huh.

BY MR. FAZEL:

Q. And as a matter of fact, you testified on redirect

that you couldn't get the information from Bank of Antigua

until after 2009.

Is that your testimony to this jury?

A. I don't recall it being -- that being the question;

but up till February 2009, we wouldn't have had a reason

to get those bank records.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:03:47

05:03:53

05:04:03

05:04:13

05:04:27



4042

Q. There you go. And then talking about MLATs. Do you

remember talking about MLATs and how you obtained that

information?

A. Yeah.

Q. Do you know what "MLAT" stands for?

THE COURT: I think he did already.

MR. FAZEL: Oh, he did? I'm sorry.

THE COURT: He gave a definition.

BY MR. FAZEL:

Q. Okay. So MLATs are something that is out of the

control of the bank. It's done through the bureaucratic

in the U.S. and also in the host country; correct?

A. Bureaucratic and diplomatic channels. Yes.

Q. Okay.

A. Uh-huh.

Q. And it has nothing to do with the bank. If -- once

that goes through the channels, the bank has to produce;

correct?

A. Sure, yes.

Q. So even if you wanted it before 2009 and you had a

reason to go look at it -- I know you didn't. But even if

you had a reason to do it before 2009, you could have gone

through the MLAT channels just like you did and those

documents would be produced; correct?

A. We could have went through the MLAT channels.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:04:44

05:04:56

05:05:07

05:05:15

05:05:27



4043

Whether produced or not, I can't -- I mean, I suppose they

would, yes.

Q. Do you have any -- are you familiar with the

functioning of FSRC?

A. Somewhat, but --

Q. If you're not --

A. Okay. Sure.

Q. Remember Mr. Costa going up there and telling you, he

put a "1" by the FSRC, and I can't even tell what he did

with the second one, but he talked about the ECCB and all

that?

A. Oh, yeah, sure. Uh-huh.

Q. Okay. And the idea being he said, "Look, you know,

there's many banks that have multiple jurisdictions and

multiple layers of authority over them."


A. I don't remember Mr. Costa saying that, but, okay,

sure.

Q. Something to that effect?

A. Yeah, to that effect.

Q. Okay. Is it your understanding that the FSRC

employed one person?

A. No. It --

Q. Is it your understanding that Mr. King was the

chairman of the FSRC; correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:05:41

05:05:49

05:05:57

05:06:08

05:06:19



4044

A. I don't know if he was chairman. He was the CEO of

the FSRC. Yeah, okay.

Q. Did Mr. King actually conduct the examinations? Do

you know?

A. I don't believe so.

Q. Somebody else at the FSRC conducted these

examinations?

A. I believe so, yes.

Q. Do you know how many people in the FSRC were tasked

with examining banks like SIBL?

A. No.

MR. FAZEL: I pass the witness.


BY MR. COSTA:

Q. Mr. Fazel just asked you some questions about who

worked under Mr. King at the FSRC.

A. Sure.

Q. Is the next government witness going to be one of

those individuals who worked under Mr. King at the FSRC?

A. Yes, it is.

Q. A man named Paul Ashe?

A. Yes, sir.

Q. So we'll hear from him in a few minutes.

Mr. Fazel asked you about MLATs and -- the

point made earlier was that up until 2009, Mr. Stanford

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:06:27

05:06:40

05:06:49

05:06:59

05:07:07



4045

owned Bank of Antigua; correct?

A. Yes.

Q. He also owned Stanford International Bank; correct?

A. Yes.

Q. And Mr. Fazel was implying, well, there were MLATs,

these treaties existed then. So even when Mr. Stanford

was owning these banks, the records could have been

produced to U.S. authorities; correct?

A. Yes.

Q. So why would he have withdraw slips from these banks

that could through some treaty process end up producing

records to the U.S. --

A. True.

Q. -- right?

A. Yes.

Q. Remember those SEC letters, one in 2005, one in 2006,

that we talked about earlier?

A. Yes, I do.

Q. What kind of records was the SEC wanting from

Antigua?

A. They were wanting account statements and records

related to the bank.

Q. From the Stanford International Bank?

A. Yes.

Q. Including documents about the investment portfolio?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:07:17

05:07:31

05:07:37

05:07:52

05:08:02



4046

A. Yes, that is correct.

Q. And that was when Mr. Stanford controlled the bank?

A. Yes.

Q. Were those records produced when Mr. Stanford

controlled the bank?

A. No.

Q. The treaty process, basically the government of

Antigua then goes to the bank and says, "Here's a list of

documents the United States has requested. Please produce

them"; right?

A. Yes.

Q. Is it like any other time you're issuing a subpoena

or something like that, it's -- you're only going to get

what the bank's going to give you?

A. Yes.

Q. And when the SEC wanted records from the bank,

Stanford International Bank, they got nothing?

A. That's correct.

Q. There were some questions about Mauricio Alvarado and

whose -- a number of questions about who has done anything

illegal, do you recall those?

A. Yes.

Q. And I think you testified early on, you're just --

your primary focus in terms of financial records has been

these Leroy King bank accounts?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:08:14

05:08:22

05:08:34

05:08:53

05:09:00



4047


Q. Are you aware of the full range of people that are

still targets and subjects of the government's

investigation into Stanford Financial?

A. No.

Q. Because you haven't been involved in the entire

investigation?

A. That's correct.

Q. Do you know where Mr. Alvarado is working these days,

the general counsel who was on those faxes?

A. I do not.

Q. You don't know if he's still in the country or if

he's gone to work outside of the country?

A. I believe he's living in Colombia, but I'm not sure

where he's working or who employs him.

Q. And then Mr. Fazel -- I have to look at this address

book one more time. He asked some questions about

don't -- in company companies, isn't it common to list a

regulator's phone number, do you remember that?

A. Yeah, I remember.

Q. Was it just Mr. King's office number at the FSRC

that's listed here?

A. No.

Q. How many numbers are listed?

A. 12.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:09:09

05:09:19

05:09:29

05:09:45

05:10:06



4048

Q. Including his wife's cellphone number in Atlanta?

A. Yes.

Q. And Mr. King's U.S. cell number?

A. Yes.

Q. And his wife's home number in Atlanta?

A. Yes.

Q. And his New York home number?

A. Yes.

MR. COSTA: Pass the witness, Your Honor.

RECROSS EXAMINATION

BY MR. FAZEL:

Q. Do you remember a long, long time ago when the

prosecutor asked you about the SEC not getting documents?

Do you remember that just a second ago?

A. Yeah.

Q. Okay. Did the SEC go through the MLATs?

A. They went through their office international affairs.

Q. Did they go through the MLATs?

A. Not that I'm aware about that. I don't know.

Q. Now, are you telling this jury that -- now, do you

know that Antigua and Barbuda were an old colony of the

UK; correct?

A. Yeah.

Q. And they run the common-law type courts like we do;

correct? If you know; if you don't, you don't. Correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:10:22

05:10:37

05:10:47

05:10:55

05:11:07



4049

A. I suppose, but I'm not 100 percent certain.

Q. Now, are you telling this jury that if MLAT request

was made, that it could not be enforced in Antigua?

A. If an MLAT request was made from the United States,

the United States wouldn't have any -- be within force,

that's correct.

Q. Did you make an MLAT request yourself to Antigua?

A. I personally did not. The Department of Justice did

that.

Q. Justice did. And did they receive the information

they needed?

A. Yes. Not in 2009, later on, yes, we did.

Q. Well, that's because you didn't ask for it before

2009 or later; right?

A. Sure.

Q. You have no reason to believe that you wouldn't have

obtained that information before 2009, do you?



BY MR. FAZEL:

Q. Do you have any -- through your investigation, do you

have any knowledge or reason to believe that prior to

2009, if you had requested the MLAT, you wouldn't have

gotten the MLAT request provided to you?

A. No. I mean, we had no reason to ask for the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:11:15

05:11:21

05:11:30

05:11:33

05:11:50



4050

records --

Q. No reason.

A. -- before February 2009.

MR. FAZEL: Pass the witness.


BY MR. COSTA:

Q. Costa when the SEC wanted records from Stanford's

bank in '05 and '06, did they get them?

A. No.

MR. FAZEL: Asked and answered.


BY MR. COSTA:

Q. Is that a reason to believe that if an MLAT had also

been sent, the records wouldn't have been obtained by U.S.

authorities?

A. Yes.

MR. COSTA: Pass the witness.

RECROSS EXAMINATION

BY MR. FAZEL:

Q. Are you telling us that just because the SEC faxed a

letter over saying, hey, we want this, that tells you if

they had done a formal request through formal diplomatic

channels, that they would be turned down. Is that what

you're telling us?

A. Well, I don't know what their formal channels are.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:12:01

05:12:14

05:12:18

05:12:23

05:12:41



4051

That could be their formal channel. The SEC is a civil

entity. They have different procedures.

Q. That's not my question.

A. I don't know.

Q. The prosecutor just asked you that they asked for it?

A. Uh-huh.

Q. You they didn't receive it. Therefore, is it your

opinion if they had done an MLAT request, they wouldn't

have obtained it, and you said yes; correct?

MR. COSTA: Object --

THE WITNESS: Sure.

MR. COSTA: -- to mischaracterization of his

opinion. I think I asked for an indication of whether it

would have --

THE COURT: All right. It's an indication.

BY MR. FAZEL:

Q. It's an indication; correct? That's an indication to

you; correct?

A. Yeah.

Q. Are you telling this jury that if they had made the

formal request instead of just faxing a letter and gone

through the proper procedure, that they would not have

obtained it even in 2007 or '-6 or '-5, whenever they

requested it, just because they didn't get it through a

fax. Is that what you're telling the jury?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:12:48

05:12:54

05:13:06

05:13:34



4052

A. No. First off, I don't know what they're --

Q. I don't know is a good answer --

A. I don't know --

Q. -- how about that?

A. -- the proper procedure.

MR. FAZEL: I pass the witness.

THE WITNESS: That could be the proper

procedure.

MR. COSTA: Nothing further, Your Honor.

THE COURT: Okay. Thank you, sir. You may

step down. You're excused. You're free to leave. You can

remain if you'd like, but you're free to leave.

Nobody's taken me up on that offer yet.

All right. Call your next witness.

MR. WARREN: Your Honor, the United States

calls Paul Ashe.

CASE MANAGER: Mr. Ashe, please raise your

right hand. Do you solemnly swear that the testimony you

are about to give in the case now before the Court will be

the truth, the whole truth and nothing but the truth?

THE WITNESS: I do.

THE COURT: Thank you. You may have a seat.

CASE MANAGER: You may have a seat.

THE COURT: Go on.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:13:48

05:13:58

05:14:05

05:14:14

05:14:23

Direct-Ashe/By Mr. Warren


4053

PAUL ASHE,

after having been first cautioned and duly sworn, testified

as follows:

DIRECT EXAMINATION

BY MR. WARREN:

Q. Mr. Ashe, please introduce yourself to the jury.

A. My name is Paul, Paul Ashe.

Q. How do you spell your last name?

A. A-S-H-E.

Q. How old are you?

A. I am 49 years of age.

Q. Where are you from originally?

A. I'm from Antigua.

Q. Where do you live presently?

A. I live in Mt. Pleasant, St. John's, Antigua.

Q. Are you employed?

A. I am presently employed as supervisor of the

International Banks and Trust.

THE COURT: As what -- what position?

THE WITNESS: Supervisor of International Banks

and Trust Corporation with the Financial Services

Regulatory Commission.

BY MR. WARREN:

Q. You're the supervisor of International Banks with the

FSRC?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:14:34

05:14:47

05:15:05

05:15:15

05:15:27



4054

A. That is correct.

Q. How long have you been in that position?

A. I took the role from the first of February 2008.

Q. And can you just briefly remind the jury what the

FSRC is?

A. The FSRC is the acronym for the Financial Services

Regulatory Commission.

Q. And what does the FSRC do?

A. The FSRC is a government-owning institution that is

charged with responsibility of monitoring and supervising

the offshore financial sector, the insurance sector, the

credit union, the gaming sector and the nonbank sectors.

THE COURT: And you were there -- you've been

with their commission since 2008?

THE WITNESS: That is correct. First of

February 2008.

BY MR. WARREN:

Q. You mentioned offshore banks. Is Stanford

International Bank one of the offshore banks regulated by

the FSRC?

A. That is correct.

Q. What's your educational background? Did you go to

college?

A. I'm in track in July to complete a doctorate degree

in business administration from the University of Phoenix.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:15:37

05:15:49

05:15:58

05:16:06

05:16:14



4055

Q. That's a Ph.D.?

A. Well, it's a D/B/A, Doctorate of Business

Administration.

Q. Do you have an associate's degree?

A. I have an associate degree in business administration

from the University of Manchester.

Q. Did you go to school after that for a master's?

A. I have a master's degree in business and business

finance from the University of Manchester.

THE COURT: Where is that located?

THE WITNESS: That's in United Kingdom.

THE COURT: Bachelor's and master's from

University of Manchester?

THE WITNESS: Associate and master's, that's

correct.

THE COURT: Associate and master's.

BY MR. WARREN:

Q. And you said you're currently getting your Doctorate

in Business Administration. How long has it taken you to

accomplish that?

A. It's been a four-year journey.

Q. How many? I'm sorry.

A. Four years. It's been a four-year journey.

Q. Congratulations?

A. I haven't been there yet, but thanks for the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:16:25

05:16:39

05:16:49

05:17:10

05:17:19



4056

advancement.

Q. Do you have any fellowships professionally?

A. Yes. I am a fellow of the Chartered Institute of

Business Administrators.

Q. What's that?

A. The business administrators is a professional

qualification that's provided to people who are involved

in management and administration.

Q. And where is the charter based? Where is their

organization?

A. It's duty based.

Q. How long did it -- how did you become a fellow of

that institute?

A. It's exam based. You do an exam for approximately --

it takes about maybe three to four years, and then you

have to demonstrate progression in terms of your career.

You have to demonstrate competence and some success. And

then you apply with the recommendation of two fellows, and

it goes to council, and if they're satisfied that you meet

the requirement, then, of course, you're elected as a

fellow.

Q. Do you have any other fellowships?

A. Yes. I'm a fellow of the Chartered Institute of

Bankers.

Q. Is that a similar process as the charter institute --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:17:28

05:17:37

05:17:53

05:18:03

05:18:16



4057

I'm sorry -- the Fellowship of Business Administrators?

A. That is correct.

Q. How long did it take you to become a fellow of the

Chartered Institute of Bankers?

A. That was a 12-year journey.

Q. 12 years?

A. That is correct.

Q. Any other fellowships?

A. Yes. I'm a fellow of the Chartered Institute of

Management.

Q. And, briefly, what's that?

A. Again, it is in process in terms of competence as a

manager of a large institution. You must demonstrate that

you have, again, the competence and the personal growth in

your career.

Q. How long did it take to become a fellowship of that

institute?

A. That would be a submission of life experience,

approximately my 22 years of banking experience.

Q. Any other fellowships?

A. I'm also associate of the Chartered Institute of

Secretaries and Administrators.

Q. Generally speaking, what does that entail?

A. That is an institution that prepares you for a life

of corporate governments in terms of how you go about

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:18:30

05:18:41

05:18:46

05:18:54

05:19:12



4058

ensuring that you set the corporate framework with an

institution. And it's examine-based again. It takes

about maybe four to five years of examination.

Q. That was the easy one?

A. I'm sorry?

Q. That was the easy one, four to five years.

A. It's never easy. Never easy.

THE COURT: But you have a total of 22 years in

banking; is that correct?

THE WITNESS: And accounting.

THE COURT: And accounting. Okay.

BY MR. WARREN:

Q. Mr. --

THE COURT: I'm sorry. In banking and

accounting?

THE WITNESS: No. Bank and finance.

THE COURT: Bank and finance. Okay.

BY MR. WARREN:

Q. Mr. Ashe, where did you spend those 22 years in the

banking industry before going to the FSRC in February

of 2008?

A. I was with Barclays, Barclays Bank, and then in 2003

Barclays Bank merged with the Canadian Imperial Bank of

Commerce to form a new bank called First Caribbean

International Bank.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:19:21

05:19:33

05:19:50

05:20:00

05:20:21



4059

THE COURT: Now, Barclays Bank, where, in the

UK or on your island?

THE WITNESS: On the island of Antigua/Barbuda.

THE COURT: Thank you.

BY MR. WARREN:

Q. Did you work for Barclays in any other jurisdictions?

A. Yes. As part of the job, I have to move around, so I

worked in Barbados, I worked in Antigua, and I did some

stints in some of the other islands.

Q. What was the highest position that you obtained at

Barclays or First Caribbean International?

A. I was one of the corporate directors that had

responsibility for the corporate segment for First Credit

National Bank, and my last position was director of small

business.

Q. Let's talk about your responsibilities as the

supervisor of International Banks at the FSRC. Generally

speaking, what is it that you do?

A. My responsibilities is to ensure that the

International Banks adhere to the laws of Antigua/Barbuda

and the -- operate in accordance with best practices, but

in addition, to which they comply with the rules and

guidelines in which the licenses are issued.

Q. Who do you report to?

A. I report to the CO or administrator of the financial

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:20:31

05:20:47

05:20:59

05:21:09

05:21:21



4060

regulatory commission.

Q. Is there a board of the FSRC?

A. There is a board, a seven-member board, of the

commission, that is correct.

Q. Who is the current chair?

A. The current chair is Althea Crick, Ms. Althea Crick.

Q. Now, where is the supervisor of banks, your position,

in terms of the hierarchy at the FSRC in terms of

responsibility for actually examining the banks and the

other entities?

A. Well, I am head of that department, so ultimately the

buck stops with me.

Q. Are you paid?

A. I hope so. I am paid, yes, a salary of approximately

$4,500 per month.

Q. How are you paid?

A. I am paid by direct credit to my account.

Q. Ever been paid in cash?

A. No, that's not the practice of commission.

Q. Briefcases full of cash, never?

A. I've never had the opportunity.

Q. Let's talk about the circumstances of your hiring.

You said you became the supervisor in February of 2008.

How was it that you got that job?

A. I left First Caribbean Bank in 2007. I had a meeting

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:21:34

05:21:48

05:21:58

05:22:03

05:22:09



4061

with the minister of finance probably around August

of 2007.

Q. Did you discuss the job opening with him at that

time?

A. No. We were just talking in terms of the -- at that

time he wanted me to do a doctorate degree, and he wanted

to focus around corporate government in Antigua/Barbuda.

So I was exploring the opportunity of working in an

institution that was --

THE COURT: Let me ask you a question. How do

you pronounce the second part of your country, Antigua and

Barbuda.

THE WITNESS: Barbuda.

THE COURT: Barbuda. That's the --

THE WITNESS: That's a twin state.

THE COURT: No, I understand. But that's how

it's pronounced in the country --

THE WITNESS: That is correct.

THE COURT: -- Barbuda?

THE WITNESS: Uh-huh.

THE COURT: Because we've heard two

pronunciations, including my own, so I'm glad to find that

out.

BY MR. WARREN:

Q. Mr. Ashe, during this conversion with the minister of

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:22:21

05:22:37

05:22:52

05:23:04

05:23:17



4062

finance, did you discuss the position of supervisor of

International Banks?

A. Yes. He indicated that there was a vacancy of

supervisor International Banks.

Q. And did you discuss with the minister of finance what

he was looking for in terms of hiring someone?

A. No, that was not be. It was just discussed in the --

he didn't ask me to have a further discussion with the

chair at the time with Mr. Hesse.

Q. And what did you -- briefly what did you discuss with

Mr. Hesse about what they were looking for?

A. Mr. Hesse indicated that presently the rule of

supervisor banks was held by Mr. Leroy King, who was doing

a dual role of CEO and also he was acting supervisor

International Banks and Trust.

Q. Was that a problem that Mr. King was in a dual role

as CEO and supervisor of banks?

A. Well, there was some concern that that rule should be

separated.

Q. Did you end up interviewing for the position?

A. Yes. I applied for the role, and then I was invited

to interview with Mr. King and his deputy, Mr. Mathurn.

Q. And can you spell Mr. Mathurn's name for the record,

please?

A. M-A-T-H-U-R-N.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:23:30

05:23:51

05:24:12

05:24:23

05:24:37



4063

Q. Describe for the jury how that interview went with

Mr. Leroy King and his deputy, Mr. Mathurn.

A. In one short word, it was a disaster.

Q. Why do you say that?

A. Well, I was then -- walked through the automatic

biography of Mr. Leroy King, which indicated that he had

never met anyone, either dead or alive, that was as good

as he was. That floored me, because I didn't understand

what he meant by he was -- he had never met anyone as good

as he was, but that was the icing.

The visit was that -- during the actual

interview, I stood there with awe and shock, as both

himself and the deputy had a heated argument as to whether

Mr. King was, in fact, the most intelligent person that

had ever graced the shores of Antigua/Barbuda. And I

couldn't believe what I was hearing.

The interview then -- you know, I became a

spectator, because right through questions asking about

myself, it was mostly about Mr. King and his exploits on

Wall Street and why he was working at the time with Bank

of America. So I left the interview, felt that, you know,

I really couldn't be part of what appeared to be a very

dysfunctional institution.

Q. Now, at the time you said Mr. King was both CEO and

the supervisor of banks, the position that you were

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:24:52

05:25:05

05:25:25

05:25:41

05:25:58



4064

applying for. What were his responsibilities in those

positions? You've described already the responsibilities

of supervisor of banks, but generally what were his

responsibilities as the CEO of the FSRC?

A. Well, at the time I wouldn't have known, but I'm --

I'm sorry. The question you're asking would I have known

at that time or --

Q. If you can just tell the jury generally what his

responsibilities were as the CEO of the commission.

A. Well, the CEO, on paper it is, as the CEO, here and

the ultimate responsibility for the commission, it was not

just bank, it was bank, and it was insurance, it was

gaming. It also had an internal department called

registry, and it also dealt with international insurance.

So at the end of the day, all the line department reported

into the CEO, and he was also linked between the board of

directors and the actual business itself.

Q. After this first interview that you've described, did

you have a subsequent interview for the position?

A. As I said, I left the interview with a feeling that

this institution was very dysfunctional because I was --

you know, I had this very strange discussion between the

CEO and the deputy. And then I thought that would be the

end of any further contact with the commission.

And the next day I got a call from

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:26:12

05:14:12

05:26:35

05:26:44

05:26:59



4065

Mr. Mathurn, the deputy, and he apologized quite profusely

for the behavior in what -- with Mr. King and what he --

what transpired during the interview.

Q. Did you subsequently interview with Mr. Mathurn

again?

A. Mr. Mathurn invited me to lunch, and then -- he then

interviewed, shared with me with the vision and what was

required in the job and that he was seeking someone with

strong banking and managing experience to fill the role of

the supervisor of International Banks and Trust.

Q. Did you end up receiving a job offer for the

position?

A. Yes. That would have been the second week in January

of 2008.

Q. Did you start right away?

A. No, I didn't.

Q. What happened?

A. I was invited to -- by the human resource manager at

the time, Ms. Beazer.

Q. Could you spell her last name, please.

A. B-E-A-Z-E-R. Or Z, American, E-R.

Q. What did the HR manager tell you?

A. She invited me to come and collect a copy of the job

letter.

Q. Did you come to collect the copy?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:27:13

05:27:28

05:27:42

05:27:56

05:28:11



4066

A. Well, I collected a letter, but it was just a -- some

words and an envelope on a letterhead. It wasn't signed.

Q. What do you mean?

A. There was no signature. There was no seal.

Q. Well, who was the letter purporting to be from?

A. Purported to be from Leroy King, who was CEO at the

time of the commission.

Q. Was the letter, on its face, asking you for the job,

welcome you -- welcoming you to the position?

A. It had the right words, but there was no signature.

Q. What did you do?

A. Well, I said that there was no signature. I mean,

without the signature, there is no offer. It was just a

piece of paper with some words in it. And I said, until

that is signed, it's nothing I can do with it.

Q. And what happened next?

A. Well, I left. And I then got a call from the manager

saying that I -- Mr. King advised that I should sign the

letter and then he would sign afterwards. And I really

thought, you know, this was contrary because why would I

sign an unsigned letter. I said I couldn't do that. And

I said until that is signed, I really don't have it in

front of me.

Q. Did the letter end up getting signed before you?

A. Well, the letter was eventually signed, and I was

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:28:25

05:28:39

05:28:56

05:29:08

05:29:23



4067

asked to come back again for the signed letter.

Q. And did you pick up the signed letter?

A. I picked the signed letter up, and I signed it and --

I didn't sign it. Took it back with me. And -- you know,

to -- just to make sure that, you know, this is a real job

being offered to me and it's not part of what appears to

be a very strange sequence of events.

Q. Before you started working, did anything else out of

the ordinary happen?

A. Well, I thought that was the end of this very secret.

And then after collecting letter, within 24 hours, I got a

call from an employee from Stanford 20/20 that one

Mr. Allen Stanford wanted to speak to me about a job

offer.

Q. What did this employee of Stanford 20/20 -- that's

the cricket company?

A. Well, that was the cricket -- the audition that

handled the 20/20 cricket.

Q. And what did this employee of Mr. Stanford tell you?

A. Well, that Mr. Stanford wanted to contact me to

discuss the possibility of a job.

Q. I'm sorry. What was the employee's name?

A. The employee at the time was Eileen Ramsey.

Q. Eileen Ramsey?

A. That is correct.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:29:34

05:29:48

05:30:03

05:30:18

05:30:24



4068

Q. Did you end up speaking with Mr. Stanford?

A. I eventually spoke with him sometime afterwards.

Q. Did you call him?

A. No, I didn't.

Q. Did he call you?

A. He called me after -- I wanted to make sure that I

signed the letter first, and I took the letter back to the

commission, and then I then gave the green light for him

to contact me.

Q. How did Mr. Stanford contact you?

A. He called my home. That was about the week -- the

last week of January. So that was approximately around

the 26th, 27th, somewhere around in January.

Q. How many times did he call your home?

A. I wanted to see how desperate he was trying to get

me, so I allowed the first call to ring through; I didn't

answer. And I allowed the second call to ring through; I

didn't answer. And then I picked up on the third time he

called. These calls were spaced about maybe between five

to six minutes apart.

Q. So he called you three times within the span of 10,

15 minutes?

A. That is correct.

Q. Did you end up talking to him?

A. Yes, I did. He introduced himself as Allen Stanford

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:30:36

05:30:46

05:30:54

05:31:05

05:31:15



4069

and that he wanted to offer me a job and that job make me

a very happy person.

Q. I think --

A. Sorry.

Q. I'm sorry. Let me stop you there for a minute.

Did he tell you the job that he was

offering you? What the position was?

A. No, we didn't get into that kind of detail.

Q. Did he tell you what company you would be working

for?

A. No, we didn't get into that detail.

Q. Did he offer you a salary?

A. No, we didn't speak in that specifics.

Q. Did he make any comment to you about how you would be

compensated?

A. The only compensation he mentioned was I would be a

very happy man for the rest of my life.

Q. Did your current position as the supervisor of banks

provide you enough to be a very happy man for the rest of

your life?

A. I pay the bills. I would say happy pays the bills.

Q. But Mr. Stanford was offering you a position -- he

didn't specify what position or what company, but he said

it would pay you enough to make you happy for the rest of

your life?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:31:24

05:31:39

05:31:49

05:31:58

05:32:04



4070

A. That is right.

Q. Did you accept the position with him?

A. No, I didn't. I thanked him very much for the offer,

but I told him I already made a commitment in another

company.

Q. Had you ever met Mr. Stanford at that time?

A. I met him back, I think it was 2006 or '-7, at the

Pavilion. They had a -- that was all-night party, and I

was introduced to him.

Q. The Pavilion, that's the fancy restaurant near the --

A. That is correct.

THE COURT: What was your date of the offer,

sir? What was the date? What year of this offer that you

got?

THE WITNESS: Which offer?

THE COURT: To join the Stanford Group, join

Mr. Stanford.

THE WITNESS: That would have been January

of 2008.

THE COURT: January 2008?

THE WITNESS: Uh-huh.

BY MR. WARREN:

Q. Mr. Ashe, do you see Mr. Stanford sitting in the

courtroom today?

A. He's right behind you.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:32:12

05:32:35

05:32:51

05:33:07

05:33:36



4071

Q. Can you please just identify him --

MR. WARREN: The defendant is standing, Your

Honor. I'd ask the record to reflect identification.

THE COURT: Record will so reflect.

BY MR. WARREN:

Q. Mr. Ashe, are you aware that around the time you were

hired, Mr. King, the CEO, sent a memo to the then chairman

of the FSRC criticizing your qualifications for the job?

A. I became aware of that afterwards, that's correct.

Q. Now, you discussed the strange interview, the whole

thing with the unsigned letter, Mr. Stanford calling you

the day after you signed the letter to -- I'm sorry -- you

received the letter to offer you a position, and that

Mr. King was criticizing your qualifications. What did

you think at the time was going on?

A. Well, I was left with the impression that somebody

didn't really want me to take this job. There was

something that was happening in the banking department

that somebody wanted to keep me away from.

Q. Mr. Ashe, I'm handing you what's been marked as


MR. WARREN: Hearing no objections, if we can

publish that to the jury.

THE COURT: Just go ahead, assuming there

isn't -- we'll hear if there's a problem.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:33:52

05:33:56

05:34:10

05:34:22

05:34:31



4072

MR. WARREN: Could we highlight --

MR. FAZEL: I'm sorry. My objection is to

foundation and also hearsay.

THE COURT: At this time let's hear how you get

foundation.

MR. WARREN: Sure.

THE COURT: Are you taking take it down?

MR. WARREN: It's down.

BY MR. WARREN:

Q. Mr. Ashe, do you recognize this document?

A. I recognize the handwriting but not the document.

Q. Do you recognize the handwriting on the first page?

A. That is correct.

Q. How do you recognize -- without saying whose it is,

how do you recognize the handwriting?

A. This is the handwriting you see every day in the

commission.

MR. WARREN: With regard to the first page,

Your Honor, I'll now offer it into evidence. It's not

coming in for the truth.

MR. FAZEL: Then I would object to relevance.

THE COURT: I can't hear you.

MR. FAZEL: Then I'll object to relevance.

THE COURT: I haven't seen it. What's the

relevance?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:34:37

05:34:49

05:35:01

05:35:15

05:35:30



4073

BY MR. WARREN:

Q. Mr. Ashe, can you generally describe what this

document is discussing without getting into the specifics

of it?

THE COURT: What generally is it?

THE WITNESS: This is a hand note about --

something about the outcome of the discussion relating to

the interview.

THE COURT: Your interview?

THE WITNESS: It appears that way, Your Honor.

THE COURT: Okay. And whose handwriting is it?

THE WITNESS: This handwriting appears to be

that of Mr. Leroy King.

MR. WARREN: I'll offer it at this time, Your

Honor. He's established his familiarity with the document

and its relevance.

MR. FAZEL: And it's still hearsay.


BY MR. WARREN:

Q. Mr. Ashe, it says, "Big B, December 17, 2007."

This was the time you were interviewing

for the position of supervisor?

A. This was after I was interviewed, that's correct.

Q. See where it says -- first, do you know who Big B is?

Not saying who it is -- I'm sorry. Do you know who Big

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:35:41

05:35:56

05:36:06

05:36:22

05:36:35



4074

Brother, I guess?

A. I saw the reference Big B in some other court

documents. That came to -- I came across in 2009.

Q. Who is Big B, as you understand it?

A. Big B was Mr. King's reference to Mr. Allen Stanford.

Q. What does the document say here? Can you please read

it for me?

A. It says, "Big B, doc, September 17th, 2007. I wanted

to send this to Hesse, but I did not."

Q. Who is Mr. Hesse?

A. Mr. Hesse at the time was the chairperson of

Financial Services Regulatory Commission.

Q. And please continue.

A. "But I did not. Wanted your feedback. Just wanted

to bloody his silly nose. I find to be a man lacking any

conviction. He is a real Joker. God bless."

And it appears to be an initial at the

bottom.

Q. And, again, can you remind the jury who -- based on

your recognition or the handwriting, who wrote this?

A. This handwriting appears to be coming from Mr. Leroy

King.

Q. If we look at the next page of the document, I'm not

going to walk you through in detail what it says, but just

generally describe for the jury what this draft memorandum

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:36:55

05:37:13

05:37:24

05:37:33



4075

is referencing?

A. This draft referendum is -- references what appears

to be a document that was supposed to be sent to the board

of the commission outlining what appears to be Mr. King's

concern around my suitability for the role of supervisor

of international banks and trust.

Q. Was it normal practice for the -- Mr. King, as the

chairman of the commission, to be sharing his thoughts

about a candidate with Mr. Stanford, someone who owned the

bank that was regulated by the commission?

A. The commission has very strong confidential

agreements around this.

MR. FAZEL: I object to nonresponsive.


BY MR. WARREN:

Q. It was a yes-or-no question, Mr. Ashe.

A. Sorry. Could you repeat the question?

Q. Of course. The question was: Is there --

MR. WARREN: I'm sorry. Can we have the

question read back? I'll trust the court reporter rather

than my memory.

THE COURT: He's going to read it back.

(The requested question was read by the reporter.)

THE WITNESS: I don't know.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:38:07

05:38:18

05:38:31

05:38:45

05:39:05



4076

BY MR. WARREN:

Q. Are there any prohibitions about sharing this type of

information by someone within the commission with someone

outside of the commission?

A. Yes, there is.

Q. What kind of prohibitions are there?

A. Each employee has to sign the confidentiality

agreement.

Q. And is it of particular importance that Mr. King is

not only sharing this information outside of the FSRC, but

he's sharing it with someone who owns a bank that's

regulated by the FSRC?

A. I didn't get the question.

Q. Is there any additional significance to that?

A. I'm not sure.

Q. Who had the job as supervisor of banks before you?

A. At the time I -- before I took the job offer, it was

being -- Mr. King was acting supervisor of international

banks and trusts.

Q. Did you know the name Praveen Tawari?

A. Praveen Tawari was the -- acted as the supervisor of

International Banks and Trust, I think, during the period

of 2000 and -- probably 2003, 2004, until 2006.

Q. He's no longer employed with the FSRC?

A. No. He returned to India. He was secunded.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:39:22

05:39:41

05:39:54

05:40:04

05:40:13



4077

Q. What do you mean, he secunded?

A. He was secunded from the government of India to work

with the government of Antigua, Barbuda. So there would

have been a timeframe by which he would return to India.

Q. Now, I know you weren't working at the FSRC during

the time period that Mr. Tawari was there. But were you

living in Antigua?

A. Some parts, I was there in Antigua. During the 2006,

2007 period, during that period, I would have been in

Antigua, yes.

Q. Are you aware that there was a smear campaign in the

media against Mr. Tawari? Do you recall that?

A. I didn't recall it at the time 2006 before I got, I

mean, to the commission. I'm aware it from reviewing the

files in the commission that there was --

MR. FAZEL: I'd object to this as

nonresponsive, and it goes into hearsay.

THE COURT: Well, it's not responsive. We'll

take it question and answer.

BY MR. WARREN:

Q. Do you have an understanding based upon your review

of FSRC files as to whether there was a smear campaign

against Mr. Tawari?

MR. FAZEL: I'd object to that because it's

asking for hearsay information. His review of the files,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:40:20

05:40:28

05:40:55

05:41:11

05:41:21



4078

that's clearly hearsay.


THE WITNESS: Yes.

BY MR. WARREN:

Q. Are you aware that Mr. Stanford planted information

derogatory to Mr. Tawari?

A. No.

MR. FAZEL: Object to the form of the question.

THE COURT: He said, "No."

BY MR. WARREN:

Q. Mr. Ashe, I'm handing you what's been marked as


MR. WARREN: And hearing no objections, Your

Honor, if we can publish that to the jury.

THE COURT: He's looking at it. Well....

MR. FAZEL: Your Honor, these are documents

that I object as to foundation and hearsay and as to all of

them.

THE COURT: Okay. Lay some groundwork.

MR. WARREN: Sure.

BY MR. WARREN:

Q. Mr. Ashe, do you recognize these documents?

A. Yes, I do.

Q. And there are actually two letters contained in this

exhibit; correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:41:34

05:41:47

05:42:00

05:42:11

05:42:32



4079

A. That is correct.

Q. How do you recognize the two letters?

A. One letter I signed. The other one is in response to

a letter that -- as in the other exhibit.

THE COURT: Hold it. Does the defense object

to both of those? One's that the man signed himself.

You're saying that that's insufficient?

MR. FAZEL: No. If he signed it, as to

foundation, I have no objection to that, obviously.

THE COURT: Okay. Go to the next part then.

MR. FAZEL: As to the hearsay, I do.

THE COURT: Go to the next part.

MR. WARREN: The other document, Your Honor,

we're fine. It's not coming in for the truth. It's just

to show the response that the FSRC provided.

THE COURT: All right. With those limitations,

you still object?

MR. FAZEL: I do, Your Honor.


BY MR. WARREN:

Q. Mr. Ashe, if we can start by looking at the second

letter, the one dated April 8, 2008.

Focus you first on the header up top. The

letterhead shows this letter is from Stanford International

Bank Limited; is that correct?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:42:43

05:42:53

05:43:10

05:43:26

05:43:38



4080

A. That is correct.

Q. And what's the stamp on the right-hand side there?

A. That's the stamp that the Financial Services

Regulatory Commission stamps that's signed for all inward

correspondence.

Q. And this letter, if we scroll down to the bottom, is

from a Miguel Pacheco, who appears to be senior

vice-president; is that correct?

A. Yes, at the time he was -- that is correct.

Q. And the letter is to whom?

A. The letter is addressed to Ambassador Leroy King.

Q. Was Mr. King an ambassador?

A. No. He -- no, nothing to those name.

Q. I want to focus your attention on the first paragraph

of text.

It says, "Dear Ambassador King: We have

been contacted by one of our U.S. independent but

affiliated companies, Stanford Trust Company, in Louisiana

stating that their regulator has expressed a desire to

more thoroughly understand the FSRC regulatory framework

and examination process that the FSRC conducts on our

bank."

Can you explain what he's asking for

there, as you understood the letter?

A. In the first paragraph or the entire letter?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:43:53

05:44:05

05:44:20

05:44:42

05:44:52



4081

Q. The entire letter.

A. Essentially, he was asking the FSRC to share

information as to how we go about doing the examination of

Stanford International Bank.

Q. And who is he asking you to share this information

with? I'm sorry.

Who is he asking Mr. King to share this

information with?

A. With Mr. Sidney Seymour, the chief examiner of the

Office of Financial Institution and Depositor Institution

in Louisiana.

Q. If we look at the first document in that exhibit

dated April 9, 2008, is this the response that was sent to

Mr. Seymour?

A. That is correct.

Q. Who drafted this letter?

A. This would have been drafted by Mr. King.

Q. If we turn to the second page, look at who signed

this letter.

Who signed it?

A. Signed by Leroy King and myself.

Q. Did you discuss the contents of this letter with

Mr. King?

A. Yes.

Q. Can you tell the jury what happened?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:45:14

05:45:27

05:45:36

05:45:46

05:45:58



4082

A. The draft, the original draft, had a sentence that

the bank was examined on several times during the course

of the year. And I indicated that, as far as my review of

the files indicated -- I had just been in the job for less

than three months -- I know of no such occasion where the

bank was being examined, on-site, examined, within the

year.

Q. I'm sorry. Let me stop you there. You said that who

drafted the initial draft of this letter?

A. It was done by Mr. Leroy King.

Q. And Mr. King put in a statement that the SIB,

Stanford International Bank, was examined multiple times a

year?

A. That is right.

Q. And you told Mr. King, "That's not accurate"?

A. That is inaccurate. I would not be able to sign

that.

Q. What did Mr. King say in response?

A. Well, he said that if I didn't sign it, then he would

sign it by himself.

Q. Did he end up signing the letter by himself?

A. No, he didn't.

Q. Did you concede? Did you just give in and sign it?

A. No. He removed the statement I was uncomfortable

with.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:46:06

05:46:17

05:46:37

05:46:55

05:47:13



4083

Q. And then you ended up signing this version of it?

A. That's correct.

Q. Any misstatement of the version that you ultimately

signed?

A. I'm not sure I understand the question.

Q. Was there anything factually inaccurate in this

version of the letter, as opposed to the version of the

letter that Mr. King drafted?

A. Not I'm aware of.

Q. Let's talk generally about your regulation of

offshore banks, and in particular, Stanford International

Bank.

Can you describe for the jury how the

regulation occurs?

A. Sure.

Q. Please.

A. We have two types of examination. We do what is

called an off-site examination. And in the off-site

examination, the bank submits quarterly financial returns.

And that quarterly financial returns with detail, provide

detailed investment portfolio. It would provide details

of the bank's financials in terms of its balance sheet,

its profit and loss statement, some information in terms

of the senior members of the organization, number of

employees who may have left, if there are any committees,

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:47:32

05:47:41

05:47:56

05:48:13

05:48:37



4084

the names of the employees who -- I'm sorry -- the senior

members, management of the staff, who sits on the various

subcommittees of the board. And we review those documents

to different trends, to see if there's any adverse trends

that are taking place within the institution as relates to

the financial information.

Q. Mr. Ashe, and those are the off-site examinations

that occur quarterly; right?

A. That is correct.

Q. In addition to the off-site examinations, are there

additional on-site examinations?

A. During the course of the year, we then would do an

on-site examination where we now would do a physical

verification of the information that's submitted to us in

these quarterly financials. So we'd ask for, you know,

copies of broker statements. We'd ask for copies of bank

statements. We'd ask for copies of the policies and

procedures. We'd ask for copies of the corporate

documents to -- such as the board -- board -- board

minutes, board decisions, committee, the subcommittees of

the board. We look at the training. We look at the

opening account procedures that's done by the bank to

ensure, of course, they're complying with the laws around

due diligence, money laundering, terrorist financing.

Q. Mr. Ashe, I'm sorry. Let me stop you there for a

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:48:45

05:49:00

05:49:13

05:49:26

05:49:33



4085

minute.

In looking through the documents and all

the other information you've identified, what are you

trying to determine?

A. What we're trying to determine, whether or not, first

of all, that the information provided to us in the

off-site examination, these are these quarterly returns,

there's sufficient supporting documentation within the

bank that this information is correct.

And you're also seeking to ensure that the

bank, in fact, complying with the laws and the regulation

of the country and, of course, adhering to good corporate

governance.

Q. Are you also looking to determine the accuracy of the

bank's financial records and reporting?

A. Yes, uh-huh.

Q. Are you also looking to go verify the bank's

solvency?

A. Well, that's not a question I can answer "yes" or

"no."

Q. Is that something that you're -- that you're keeping

an eye out for --

A. That is correct.

Q. -- in these examinations?

A. That is correct.

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:49:44

05:50:01

05:50:17

05:50:33

05:50:52



4086

Q. Is the commission an auditor?

A. We're not. And I'm glad you asked that question.

Q. What's difference between what the commission does

and what an auditor -- what an outside auditor and an

insider auditor would do?

A. The work done by the external auditor is much more

detailed, much more expansive than what we do at the

commission. At the commission, what we do is that we do a

prima facie -- by "prima facie," it means that when we

have very fine balances, we do not go to the banks or the

brokers that provide the services to the bank. We rely

upon the statements as provided, and we look at those and

compare those with the balances that are disclosed in the

financial returns.

In the case of the external auditor, the

external auditor is not required to get the physical

verification from each bank, each broker, before they

actually attest as to the accuracy of the balance of the

account. They're also required to do some form of

verification of the value of the assets of the company

before they attest as to the accuracy of the actual

statement itself.

They also ensure that the company is

complying with the IFSRA terms of international

financial -- there are two types: The one in terms of the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:51:07

05:51:14

05:51:35

05:51:46

05:51:58



4087

regulation of financial information in terms of the bank

adhering to the standards. They're also testing

management system to make sure that the bank, in fact,

have the necessary checks and balances in place. And

that's part of the corporate governance framework.

Q. Mr. Ashe, I'm sorry. Let me interrupt you for a

minute.

You've described what an auditor should be

doing.

A. Uh-huh.

Q. How does it affect the FSRC's ability to regulate and

examine banks if the auditor isn't properly doing its job?

A. We're really blinded, because without the accuracy of

the external auditor, we rely wholly on the work of the

external auditor in terms of doing that work to verify the

accuracy of the financial mission, and we rely upon that

financial information in order to make decisions.

Q. Do you know who SIB's auditor was during the time

that you were supervisor of banks?

A. Yes. It was the firm of C.A.S Hewlett & Company.

Q. And was C.A.S. Hewlett also the auditor prior to the

time you became supervisor of banks?

A. That is correct.

Q. Are you aware that C.A.S Hewlett was receiving bribes

from SIB paid out of a Swiss bank account?

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:52:05

05:52:19

05:52:35

05:52:56

05:53:11



4088

MR. FAZEL: Object to the form of the question,

Your Honor.


BY MR. WARREN:

Q. Are you aware of that, sir?

A. I'm aware of it now. At that time, no.

Q. How would it have affected the FSRC's ability to

regulate SIB if the auditor, C.A.S Hewlett, was being

bribed not to do his job?

A. As I said, we were blinded because we were relying

upon information from the external auditor.

Q. When you became the supervisor of banks in February

of 2008, did you review FSRC files going back in time?

A. Yes, I did.

Q. Why?

A. Well, you'd asked me about my entry into the

commission, and it was quite a startling entry in terms of

the employment letter, the interview, Mr. Stanford's call.

And there was just so many things happening, I wanted to

satisfy myself as to what is in the banking department.

That was this seemingly effort to a prevent me from taking

the job. So I went through the files for Stanford

International Bank going back to 2000 to the time, the

2008.

I also did that for all the other banks --

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:53:25

05:53:37

05:53:56

05:54:12

05:54:23



4089

there were about -- I think there were about 17 -- 18

banks within the jurisdiction -- to try to get an

understanding of, you know, what it is in the banking

department that -- where these extraordinary efforts were

being made from prevent me from taking the job.

Q. And did you do just for fun, or was this your part of

your responsibility as supervisor of banks to get an

understanding as to what prior examinations in the history

of the regulation was?

A. Regulation is not fun, Mr. Warren. Regulation is

about protecting the lives of people's livelihood, because

at the end of the day, we're the -- we're supposed to be

the individuals that stand between the bank doing what it

should be doing and also protecting the savings.

Q. Mr. Ashe, who conducted prior exams of SIB, Stanford

International Bank, before you got there?

A. The file revealed that there was one examiner who

examined the Stanford International Bank from 2001 up to

2005.

Q. Who was that?

A. That was Mr. Trevor Bailey.

Q. Is Mr. Bailey still employed at the FSRC?

A. Mr. Trevor Bailey was terminated on the 6th of

August, 2006.

Q. Are you aware of Mr. Bailey, after being terminated

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:54:33

05:54:48

05:55:01

05:55:17

05:55:34



4090

by from the FSRC, went to work for Mr. Stanford as an

internal auditor?

A. That is correct.

Q. Were you aware that Mr. Bailey participated in some

sort of blood oath with Mr. Stanford and Mr. Leroy King?

A. I read about it. That's correct.

Q. Let's talk about the actual examination of SIB.

When was the first examination of SIB

supposed to occur under your tenure?

A. In June of 2008, we wrote to the bank and got

agreement that the examination we conducted during the

month of July.

Q. Did it occur then?

A. No, it didn't.

Q. Why not?

A. In June of 2008, 2008, Mr. Leroy King indicated that

he was going to go on medical leave.

Q. Was Mr. King going to be involved in the examination?

A. No, he wasn't.

Q. So why did his absence mean you couldn't go forward

with the exam?

A. Well, this is the point I was going to make.

When Mr. King indicated that he was going to

go on leave, within two days afterwards, we got a note from

the bank indicating that it could no longer accommodate the

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

05:55:46

05:55:56

05:56:42

05:56:52


4091

examination in July, and they wanted examination now to be

pushed back until September of the -- of September that

year.

Q. Did you just try to go forward anyway and say, "No,

it doesn't matter that Mr. King is on medical leave.

We're going to go ahead and do the exam"?

A. Well, we tried because there was also some --

MR. COSTA: Can we break?

THE COURT: Yeah. Sure. That's fine. For the

day, we'll do it at this time. It's now five minutes to

6:00.

We'll see you back tomorrow morning at

10:00 a.m.

MR. WARREN: May the witness step down, Your

Honor?

THE COURT: Yes, sure. See you tomorrow, sir.

THE WITNESS: Thank you.

THE COURT: I'll have the time for you in just

a moment.

Defense want to take a look at this? By

the way, the time is accurate, I corrected it all. Let me

note it down and give it to you.

We'll be in recess.


\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\\

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25


4092

COURT REPORTER'S CERTIFICATE

I, Johnny C. Sanchez, certify that the foregoing is a

correct transcript from the record of proceedings in the

above-entitled matter.

/s/_________________________Johnny C. Sanchez, CRR, RMR

#

#8016 [1] - 3774:12

$

$1,200 [1] - 3889:14

$1,297.69 [1] - 3889:13

$1,700 [1] - 3884:1

$10,000 [7] - 3828:13, 3842:20,

3958:6, 3959:9, 3959:18, 3959:24,

3961:11

$100 [2] - 3862:2, 3862:4

$107 [1] - 3947:25

$112 [1] - 3856:8

$14 [2] - 3804:10, 3804:23

$15,000 [2] - 3840:24, 3967:14

$150,000 [1] - 3946:18

$199,000 [1] - 3856:15

$200,000 [1] - 3856:8

$22 [3] - 3804:5, 3804:17, 3816:14

$27,500 [2] - 3873:1, 3873:15

$300,000 [1] - 3846:2

$321,075 [2] - 3845:15, 3846:10

$4,500 [2] - 3894:23, 4060:15

$400 [1] - 3792:13

$410,293.39 [1] - 3947:2

$50 [1] - 3862:3

$500,000 [1] - 3856:5

$52,000 [2] - 3860:15, 3860:17

$520,963.87 [1] - 3857:12

$560,314.63 [1] - 3944:22

$7,000 [2] - 3834:15, 3834:22

$70,000 [2] - 3834:13, 3835:2

$700 [1] - 3851:3

$75 [1] - 3967:1

$77,000 [1] - 3834:14

$77,252 [1] - 3833:1

$8,000 [2] - 3878:15, 3985:14

$8,329,978,673 [1] - 3812:8

$815 [1] - 3856:21

$9,000 [3] - 3894:23, 3895:11, 3896:4

$9,700 [3] - 3842:14, 3842:16, 3843:7

$93,100 [1] - 3846:18

$943,740.74 [1] - 3863:21

$990,000 [1] - 3800:20

'

''92 [1] - 3943:10

'03 [1] - 3873:18

'04 [1] - 3857:5

'05 [2] - 3856:5, 4050:8

'06 [2] - 3868:12, 4050:8

'08 [2] - 3795:21, 3856:5

'09 [1] - 3946:17

'95 [1] - 3943:9

/

/s [1] - 4092:6

0

0 [1] - 3843:20

09-CR-342 [1] - 3773:4

1

1 [9] - 3818:11, 3850:20, 3850:23,

3863:11, 3866:16, 3932:22, 3953:12,

3953:14, 4043:9

10 [5] - 3800:14, 3947:5, 3991:12,

3997:3, 4068:21

10,000 [1] - 3873:7

10,000-dollar [4] - 3842:17, 3842:18,

3845:18, 3845:21

10.3 [2] - 3794:24, 3794:25

100 [7] - 3970:4, 3970:7, 3977:9,

3977:10, 3977:13, 4049:1

100-dollar [3] - 3852:6, 3852:9, 3853:4

1004 [1] - 3773:22

1018 [1] - 3774:3

1040 [2] - 3832:10, 3834:14

105,000 [1] - 3857:15

108731 [5] - 3788:2, 3803:19, 3816:13,

3816:18, 3817:11

10:00 [1] - 4091:13

10:09 [1] - 3773:6

11 [10] - 3869:7, 3869:12, 3924:17,

3954:1, 3954:6, 3976:19, 3976:20,

3991:3, 4010:9

11:00 [1] - 3939:22

11:17 [1] - 4033:25

11:40 [1] - 3858:3

12 [8] - 3802:1, 3802:23, 3803:6,

3897:15, 3953:7, 3953:9, 4047:25,

4057:6

12-year [1] - 4057:5

1205A [2] - 3803:17, 3805:19

12:58 [1] - 3911:17

12s [1] - 3921:12

13 [8] - 3773:8, 3801:24, 3810:23,

3858:6, 3910:24, 3910:25, 3931:11

13-2 [1] - 3813:1

13.25 [2] - 3810:17, 3811:7

13.29 [1] - 3811:11

13.5 [1] - 3815:10

1300 [2] - 3802:3, 3802:19

1325 [1] - 3789:15

133,814 [1] - 3856:21

136 [1] - 3798:20

14 [9] - 3797:14, 3802:1, 3805:14,

3805:17, 3853:24, 3866:2, 3928:8,

3991:12

1400 [1] - 3773:17

15 [6] - 3800:1, 3855:12, 3857:25,

3948:17, 3953:10, 4068:22Johnny C. Sanchez, RMR, CRR - [email protected]

4093

15,000 [2] - 3840:19, 3842:1

150,000 [2] - 3945:9, 3948:8

150,000-dollar [1] - 3946:8

1500 [7] - 3796:19, 3796:22, 3809:7,

3888:17, 3896:15, 3988:15, 3988:16

16 [6] - 3805:14, 3806:2, 3862:3,

3869:23, 3937:25, 3942:2

16000 [1] - 3779:13

1603 [1] - 3792:2

1615 [5] - 3835:25, 3836:1, 3843:14,

3845:24, 3856:10

16311 [3] - 3779:8, 3781:15, 3783:6

17 [4] - 3948:19, 3976:18, 4073:20,

4089:1

17-minute [1] - 3858:5

17th [7] - 3938:11, 3938:15, 3942:5,

3942:6, 3942:14, 3942:15, 4074:8

18 [3] - 3869:15, 3927:22, 4089:1

185 [1] - 3779:20

19 [1] - 3834:13

19,600 [1] - 3852:20

198 [2] - 3852:7, 3852:12

198/50 [1] - 3852:6

1991 [1] - 3838:11

1992 [1] - 3944:6

1999 [2] - 3815:8, 3819:21

1st [1] - 3930:3

2

2 [32] - 3774:4, 3792:8, 3793:4,

3793:11, 3793:16, 3799:9, 3799:23,

3814:14, 3814:21, 3817:7, 3817:13,

3817:16, 3817:18, 3818:11, 3821:18,

3822:1, 3882:22, 3891:23, 3893:7,

3893:12, 3893:13, 3894:6, 3895:21,

3895:22, 3896:3, 3935:16, 3944:17,

3989:11, 3991:12, 4010:17, 4020:20

2,000 [1] - 3868:11

2,548,100 [1] - 3863:19

2,900 [1] - 3892:23

2.7 [7] - 3850:20, 3850:22, 3850:23,

3851:7, 3851:11, 3851:17, 3863:11

20 [5] - 3785:5, 3789:8, 3804:8,

3924:14, 3997:8

20,000 [1] - 3862:17

20/20 [3] - 4067:12, 4067:15, 4067:18

200 [1] - 3853:4

2000 [2] - 4076:23, 4088:23

20005 [1] - 3773:18

2001 [2] - 3901:11, 4089:18

2002 [2] - 3831:10, 3849:14

2003 [11] - 3804:4, 3816:11, 3840:7,

3844:15, 3857:5, 3863:15, 3871:6,

3966:22, 3972:5, 4058:22, 4076:23

2004 [14] - 3792:4, 3875:17, 3875:18,

3876:21, 3877:13, 3878:4, 3880:7,

3880:21, 3885:8, 3885:22, 3897:5,

4033:25, 4076:23

2005 [14] - 3849:13, 3850:7, 3850:8,

3851:3, 3866:8, 3866:18, 3898:1,

3898:6, 3898:18, 3900:5, 3922:20,

3991:19, 4045:16, 4089:19

2006 [34] - 3867:14, 3867:20, 3875:17,

3885:23, 3893:5, 3894:6, 3894:9,

3896:3, 3898:9, 3898:23, 3902:9,

3904:5, 3923:3, 3923:6, 3924:3,

3924:17, 3927:18, 3927:20, 3927:23,

3932:6, 3932:9, 3934:10, 3940:21,

4023:22, 4024:3, 4024:14, 4024:21,

4045:16, 4070:7, 4076:23, 4077:8,

4077:13, 4089:24

2007 [16] - 3792:11, 3831:10, 3832:9,

3832:11, 3834:25, 3835:8, 3861:9,

3905:4, 3905:5, 3905:8, 4051:23,

4060:25, 4061:2, 4073:20, 4074:8,

4077:9

2008 [29] - 3787:19, 3791:15, 3792:11,

3793:16, 3799:24, 3800:20, 3801:5,

3817:8, 3836:13, 3846:15, 3856:20,

3869:7, 3869:12, 3869:23, 4054:3,

4054:14, 4054:16, 4058:21, 4060:23,

4065:14, 4070:19, 4070:20, 4079:22,

4081:13, 4088:13, 4088:24, 4090:10,

4090:16

2009 [37] - 3784:23, 3787:24, 3789:8,

3790:4, 3790:5, 3790:18, 3800:21,

3836:13, 3844:15, 3846:16, 3856:20,

3905:17, 3905:18, 3915:24, 3916:24,

3917:8, 3942:2, 3944:12, 3944:14,

3947:16, 3966:22, 3972:6, 3991:19,

3992:11, 3992:15, 4021:15, 4041:21,

4041:24, 4042:20, 4042:22, 4044:25,

4049:12, 4049:14, 4049:17, 4049:23,

4050:3, 4074:3

2011 [6] - 3778:22, 3778:23, 3779:7,

3781:12, 3783:5, 3784:3

2012 [1] - 3773:5

21 [6] - 3833:6, 3833:15, 3871:6,

3900:5, 3905:5, 3940:21

211 [6] - 3777:9, 3777:13, 3778:17,

3778:20, 3778:21, 3799:20

21st [1] - 3940:9

22 [10] - 3804:2, 3805:13, 3805:18,

3876:21, 3878:4, 3924:13, 3925:20,

4057:19, 4058:8, 4058:19

22nd [3] - 3877:12, 3880:1, 4022:19

23 [4] - 3867:14, 3868:12, 3873:18,

3946:17

23,000 [1] - 3846:20

23rd [3] - 3868:16, 3946:18, 3948:7

24 [2] - 3889:4, 4067:11

24th [3] - 3874:25, 3945:5, 3945:7

25 [4] - 3811:13, 3811:14, 3818:13,

3867:18

25,000 [2] - 3861:2, 3867:24

2555 [3] - 3833:5, 3833:7, 3833:23

25th [2] - 3891:1, 3891:22

26 [6] - 3804:4, 3816:11, 3861:9,

3867:8, 3867:20, 3904:5

26th [5] - 3867:20, 3868:3, 3868:6,

3868:20, 4068:13

27,000 [5] - 3851:3, 3851:4, 3867:16,

3868:12, 3868:24

27,500 [2] - 3873:20, 3874:23

27,700 [1] - 3867:3

27.5 [1] - 3873:6

27th [1] - 4068:13

29 [2] - 3905:4, 4033:25

29th [1] - 3880:21

2:15 [1] - 3911:16

3

3 [11] - 3868:5, 3870:15, 3907:17,

3908:7, 3912:13, 3913:25, 3916:7,

3916:13, 3916:23, 3947:16, 3948:2

3.2 [1] - 3818:21

30 [5] - 3785:7, 3885:8, 3894:14,

3911:2, 3927:23

300 [1] - 3853:4

30th [1] - 3885:1

31 [1] - 3791:15

311 [1] - 3779:14

321,000 [1] - 3967:1

332 [1] - 3785:24

332-C [1] - 3818:2

332C [2] - 3790:23, 3799:7

34 [1] - 3860:20

35 [1] - 3855:13

3784 [1] - 3775:5

3804 [1] - 3775:7

3815 [1] - 3775:9

3819 [1] - 3775:11

3821 [1] - 3775:13

3822 [2] - 3775:15, 3775:17

3826 [1] - 3775:21

385 [1] - 3842:6

3949 [1] - 3775:23

3:51 [1] - 3997:10

3rd [1] - 3773:22

4

4 [4] - 3838:18, 3843:20, 3890:21,

3938:7

40,000 [2] - 3853:6, 3853:9

4018 [1] - 3775:25

4027 [1] - 3776:2

4044 [1] - 3776:4

4048 [1] - 3776:6

4050 [2] - 3776:8, 3776:10

4053 [1] - 3776:14

410,000-dollar [2] - 3947:9, 3947:10

410,274.28 [1] - 3947:18

46 [1] - 3943:1

49 [1] - 4053:11

49,061 [1] - 3869:21

4:00 [1] - 3997:4

5

5 [10] - 3839:7, 3874:2, 3894:9,

3931:18, 3932:12, 3940:4, 3944:23,


4094

5.5 [1] - 3795:10

50 [1] - 3852:7

50-dollar [2] - 3852:12, 3853:4

50-yard [1] - 3892:23

515 [1] - 3774:12

52 [1] - 3883:6

52,000 [1] - 3860:15

520,000 [1] - 3857:20

54 [1] - 3840:13

55 [1] - 3841:5

57 [1] - 3844:12

597 [1] - 3792:6

6

6 [15] - 3777:21, 3788:1, 3788:6,

3788:24, 3790:4, 3790:5, 3794:24,

3795:11, 3803:25, 3843:20, 3860:9,

3866:8, 3905:17, 3946:24, 4051:23

600 [6] - 3854:6, 3854:7, 3862:2,

3862:4, 3968:12, 3968:19

61 [1] - 3862:8

61129 [1] - 3773:14

616 [5] - 3918:11, 3919:5, 4000:16,

4008:15, 4009:22

618 [1] - 4071:21

63 [1] - 3869:4

63.5 [1] - 3818:20

640 [2] - 3843:19, 3843:21

640-A [4] - 3837:14, 3837:15, 3838:1,

3843:20

641 [2] - 3863:1, 3886:25

641A [6] - 3859:18, 3865:17, 3866:1,

3867:8, 3869:4, 3887:22

643 [1] - 3854:24

643A [5] - 3849:17, 3849:18, 3866:15,

3867:18, 3869:15

647 [2] - 3944:8, 3947:5

648 [4] - 3945:20, 3946:4, 3946:5,

3948:2

651 [1] - 3831:7

656 [2] - 3831:8, 3831:25

657 [4] - 3876:5, 3887:24, 3984:7,

4022:14

658 [4] - 3880:4, 3887:24, 3986:3,

4031:18

659 [2] - 3884:21, 3887:24

661 [6] - 3885:24, 3886:24, 3887:1,

3887:2, 3887:3, 3887:22

664 [1] - 4078:12

669 [4] - 3898:17, 3898:20, 3898:24,

3899:1

671 [1] - 3898:23

677 [7] - 3933:13, 3935:20, 3936:1,

4000:19, 4000:21, 4001:6, 4025:14

678 [4] - 3870:10, 3978:15, 3978:16,

3978:22

68,100 [1] - 3866:10

6:00 [2] - 3997:9, 4091:11

6:02 [1] - 4091:24

6:58 [1] - 4022:24

6th [1] - 4089:23

7

7 [7] - 3799:24, 3832:24, 3850:8,

3851:2, 3927:20, 3934:10, 4070:7

7,500 [1] - 3892:23

70,000 [3] - 3833:7, 3836:14, 3836:17

713.250.5581 [1] - 3774:13

731 [1] - 3777:23

732 [1] - 3777:23

733 [1] - 3904:20

735 [1] - 3905:6

736 [1] - 3902:16

75 [1] - 3819:7

77002 [3] - 3773:23, 3774:4, 3774:12

77208-1129 [1] - 3773:15

77279 [1] - 3774:7

78,500 [1] - 3869:11

79535 [1] - 3774:7

8

8 [6] - 3773:5, 3803:24, 3851:19,

3929:23, 4079:22

8,000-dollar [1] - 3879:2

8th [1] - 3936:10

9

9 [3] - 3852:21, 3930:5, 4081:13

9,000-dollar [2] - 3895:25, 3932:9

9,300 [1] - 3845:17

9,600 [2] - 3852:16, 3852:17

9,700 [2] - 3845:17, 3852:10

9,800 [1] - 3852:15

9,900 [1] - 3852:18

90s [1] - 3948:11

96 [1] - 3852:9

97 [1] - 3852:6

97/100 [1] - 3852:6

99 [2] - 3974:12, 3974:14

9900 [1] - 3852:19

A

a)(1 [1] - 3921:6

A-S-H-E [1] - 4053:9

a.m [6] - 3773:6, 3858:3, 3939:21,

3939:22, 4033:25, 4091:13

ABI [15] - 3848:4, 3848:17, 3848:20,

3849:9, 3849:11, 3849:22, 3850:5,

3851:21, 3854:1, 3855:8, 3855:10,

3867:25, 3868:10, 3874:8

ability [3] - 3935:8, 4087:11, 4088:7

able [30] - 3791:24, 3833:3, 3840:6,

3840:15, 3846:25, 3848:21, 3850:5,

3859:6, 3860:6, 3865:24, 3872:2,

3876:13, 3876:19, 3884:2, 3891:14,

3903:15, 3911:12, 3920:23, 3941:12,

3957:1, 3987:2, 3992:11, 3995:4,

4013:19, 4013:22, 4017:18, 4017:20,

4021:7, 4028:23, 4082:16

above-entitled [1] - 4092:5

absence [1] - 4090:20

absentee [1] - 3796:11

absolute [4] - 3906:12, 3907:11,

3909:14, 3961:16

absolutely [3] - 3914:14, 3914:16,

3949:6

abundance [1] - 3915:15

ACB [1] - 3926:13

accept [2] - 3990:23, 4070:2

accepted [2] - 3785:6, 3787:7

access [17] - 3828:25, 3993:16,

3994:14, 3994:17, 3994:21, 3995:10,

4011:25, 4012:1, 4013:25, 4014:1,

4014:2, 4014:3, 4014:8, 4014:12,

4014:17, 4014:19, 4017:14

accommodate [1] - 4090:25

accomplish [2] - 4029:24, 4055:20

accordance [1] - 4059:21

according [6] - 3814:10, 3884:17,

3920:1, 3943:7, 3970:2, 3970:12

account [135] - 3777:23, 3781:16,

3781:25, 3782:6, 3782:8, 3788:2,

3788:3, 3788:7, 3788:14, 3788:15,

3788:18, 3788:25, 3789:1, 3789:9,

3800:16, 3803:19, 3803:22, 3804:6,

3805:3, 3816:12, 3816:17, 3817:1,

3817:3, 3817:11, 3817:15, 3817:21,

3821:9, 3837:25, 3838:7, 3838:15,

3838:22, 3839:1, 3839:10, 3839:13,

3839:14, 3839:15, 3839:25, 3844:21,

3847:1, 3847:6, 3848:14, 3849:12,

3850:16, 3852:25, 3854:2, 3855:2,

3855:6, 3858:6, 3858:21, 3858:24,

3859:2, 3859:3, 3859:7, 3859:16,

3859:20, 3859:22, 3860:6, 3860:7,

3860:13, 3860:16, 3860:24, 3862:12,

3862:15, 3862:23, 3863:4, 3863:24,

3864:5, 3866:5, 3866:16, 3867:8,

3867:13, 3867:18, 3867:23, 3868:3,

3868:10, 3868:23, 3869:3, 3869:15,

3870:4, 3870:5, 3870:7, 3870:8,

3870:12, 3870:18, 3873:3, 3873:13,

3873:16, 3873:22, 3873:25, 3874:1,

3874:6, 3874:24, 3874:25, 3942:22,

3943:6, 3943:7, 3943:10, 3944:6,

3944:9, 3944:12, 3944:13, 3944:21,

3944:24, 3945:1, 3945:14, 3945:17,

3946:19, 3947:22, 3948:11, 3948:17,

3948:25, 3961:22, 3962:16, 3967:23,

3968:4, 3974:1, 3974:2, 3974:4,

3983:2, 3995:21, 3996:15, 3996:23,

3996:24, 3998:16, 3999:3, 3999:8,

3999:9, 4045:21, 4060:17, 4084:22,

4086:19, 4087:25

Account [1] - 3861:11

accountant [3] - 3895:19, 3950:25,

4007:10

accountants [1] - 3799:12

accounted [1] - 3816:18

accountholder [1] - 3946:16

accountholders [1] - 3850:1Johnny C. Sanchez, RMR, CRR - [email protected]

4095

accounting [21] - 3806:8, 3806:24,

3807:11, 3811:23, 3813:9, 3814:3,

3815:7, 3815:15, 3815:21, 3816:3,

3817:24, 3863:14, 3950:16, 3950:19,

3950:21, 3950:23, 3997:16, 4013:22,

4058:10, 4058:11, 4058:15

accounts [68] - 3800:17, 3805:21,

3816:13, 3830:19, 3831:18, 3835:18,

3837:17, 3837:21, 3837:23, 3838:5,

3838:8, 3838:24, 3839:18, 3840:3,

3840:4, 3840:16, 3842:8, 3843:11,

3844:1, 3844:14, 3845:8, 3845:14,

3846:3, 3846:17, 3847:3, 3847:9,

3847:24, 3848:7, 3848:12, 3848:19,

3851:23, 3852:1, 3853:19, 3854:21,

3854:22, 3855:10, 3857:11, 3857:17,

3864:6, 3867:25, 3896:6, 3923:20,

3941:21, 3961:25, 3962:1, 3962:3,

3962:8, 3964:17, 3964:18, 3964:20,

3964:23, 3965:2, 3965:4, 3965:9,

3965:12, 3965:17, 3965:25, 3966:8,

3966:11, 3968:6, 3968:7, 3973:19,

3973:23, 3974:11, 3996:14, 3998:10,

4000:14, 4046:25

accuracy [5] - 4085:14, 4086:18,

4086:21, 4087:13, 4087:16

accurate [3] - 3795:1, 4082:15,

4091:21

accused [2] - 4005:10, 4009:2

acquisitions [1] - 3838:16

acronym [1] - 4054:6

acronyms [1] - 3998:4

Act [3] - 3901:10, 3901:11, 3929:10

act [1] - 3916:20

acted [3] - 3890:6, 3916:19, 4076:21

acting [2] - 4062:14, 4076:18

activities [1] - 3902:1

activity [10] - 3900:16, 3942:9,

3942:16, 3958:10, 3960:19, 3960:20,

3961:18, 3967:11, 4035:3, 4035:6

Acts [1] - 3901:9

actual [10] - 3818:13, 3844:21, 3870:6,

3872:15, 3900:2, 3946:7, 4063:11,

4064:17, 4086:21, 4090:7

actuality [1] - 3794:2

add [1] - 3856:12

addition [12] - 3817:16, 3817:17,

3833:20, 3836:19, 3840:19, 3857:20,

3875:9, 3924:4, 3941:7, 3995:25,

4059:22, 4084:10

additional [7] - 3797:10, 3912:17,

3913:1, 3921:9, 4031:9, 4076:14,

4084:11

address [20] - 3796:20, 3796:23,

3796:25, 3797:15, 3809:6, 3810:3,

3810:4, 3832:17, 3832:18, 3887:11,

3887:13, 3888:17, 3888:20, 3896:11,

3897:16, 3910:7, 3930:19, 4026:1,

4026:2, 4047:16

addressed [5] - 3839:20, 3870:23,

3902:23, 3922:21, 4080:11

addresses [1] - 3940:23

addressing [1] - 3926:9

adhere [1] - 4059:20

adhering [2] - 4085:12, 4087:2

administration [3] - 4054:25, 4055:5,

4056:8

Administration [2] - 4055:3, 4055:19

administrative [1] - 3830:22

administrator [1] - 4059:25

Administrators [3] - 4056:4, 4057:1,

4057:22

administrators [1] - 4056:6

admissible [2] - 3886:19, 3916:15

admit [2] - 3779:23, 3781:11

advancement [1] - 4056:1

adverse [1] - 4084:4

advice [3] - 3860:14, 3873:18, 4008:7

advise [1] - 3881:14

advised [1] - 4066:18

affairs [1] - 4048:17

affect [2] - 3901:19, 4087:11

affected [1] - 4088:7

affidavit [1] - 3944:3

affiliate [8] - 3921:6, 3923:14, 3924:9,

3925:11, 3925:13, 3925:16, 3927:2,

3936:21

affiliated [1] - 4080:18

affiliates [13] - 3923:8, 3923:10,

3924:22, 3925:1, 3925:3, 3925:24,

3925:25, 3935:6, 3937:4, 3937:23,

4028:15, 4028:19

afraid [1] - 3878:16

afternoon [5] - 3885:11, 3885:14,

3949:10, 3997:4, 3997:15

afterwards [4] - 4066:19, 4068:2,

4071:9, 4090:24

age [1] - 4053:11

agencies [4] - 3957:6, 3957:14,

3959:15, 3994:2

agency [5] - 3904:14, 3923:6, 3924:20,

3958:1, 3958:2

agent [34] - 3825:14, 3826:16,

3826:18, 3826:23, 3827:1, 3827:11,

3828:15, 3828:25, 3830:2, 3842:15,

3886:18, 3886:22, 3953:1, 3954:1,

3960:2, 3973:6, 3980:18, 3981:13,

3982:6, 3982:8, 3990:4, 3993:10,

3994:20, 3997:15, 3998:19, 4003:2,

4003:3, 4031:6, 4032:5, 4032:18,

4033:20, 4039:12, 4040:11

Agent [43] - 3831:9, 3836:3, 3838:20,

3840:15, 3858:13, 3870:3, 3874:5,

3876:7, 3904:22, 3915:20, 3918:10,

3931:17, 3944:11, 3949:10, 3949:23,

3950:4, 3956:23, 3966:4, 3972:11,

3974:7, 3975:11, 3976:22, 3976:23,

3977:19, 3978:20, 3979:22, 3980:5,

3986:22, 3988:3, 3990:16, 3991:10,

3991:13, 3991:15, 3994:9, 3996:7,

4003:5, 4007:19, 4008:11, 4010:24,

4013:18, 4018:3, 4035:19, 4041:8

agents [4] - 3827:7, 3886:14, 3917:11,

3951:24

aggressive [1] - 3937:24

ago [4] - 3978:13, 4037:22, 4048:12,

4048:14

agree [15] - 3825:9, 3913:18, 3914:12,

3914:17, 3954:16, 3956:24, 3964:11,

3965:24, 3965:25, 3966:4, 3974:11,

3974:13, 3995:5, 4031:11, 4031:15

agreed [1] - 3909:25

agreement [5] - 3921:11, 3936:20,

4014:9, 4076:8, 4090:11

agreements [1] - 4075:12

ahead [8] - 3784:4, 3854:13, 3911:15,

3915:17, 3921:4, 4004:11, 4071:24,

4091:6

air [1] - 3889:9

airfare [1] - 3889:15

airline [2] - 3891:18, 3894:18

airlines [2] - 3791:20, 3891:5

airport [1] - 3794:16

alarm [1] - 3911:8

Ali [2] - 3773:20, 3949:10

alive [1] - 4063:7

all-night [1] - 4070:8

allegation [2] - 3827:20, 3908:11

allegations [8] - 3900:13, 3900:15,

3902:3, 3907:14, 3907:19, 3909:1,

3912:10, 4036:13

alleged [5] - 3828:5, 3903:20, 3914:17,

3914:18

alleges [2] - 3827:23, 3828:10

ALLEN [1] - 3773:6

Allen [24] - 3807:20, 3807:24, 3808:1,

3822:1, 3861:12, 3869:9, 3870:24,

3873:5, 3877:15, 3885:6, 3885:12,

3895:4, 3895:6, 3895:15, 3904:23,

3905:14, 3919:18, 3939:5, 4002:11,

4011:1, 4067:13, 4068:25, 4074:5

allow [3] - 3815:22, 3819:22, 4041:15

allowed [7] - 3783:11, 3795:24,

3815:15, 3849:11, 3917:10, 4068:16,

4068:17

allowing [2] - 3927:6, 3934:18

almost [3] - 3792:7, 3948:17

alone [1] - 3792:11

alternative [1] - 4018:9

Althea [2] - 4060:6

Alvarado [29] - 3920:6, 3920:7,

3920:13, 3920:21, 3922:24, 3926:21,

3927:12, 3928:6, 3928:16, 3929:21,

3930:12, 3931:1, 3932:12, 3932:15,

3932:18, 3932:24, 3933:1, 3935:14,

3936:23, 3941:16, 4009:1, 4037:21,

4037:24, 4038:10, 4038:17, 4039:4,

4040:18, 4046:19, 4047:9

Amadio [2] - 3826:19, 3826:21

ambassador [5] - 3872:7, 3872:17,

3872:20, 3881:5, 4080:12

Ambassador [3] - 3885:9, 4080:11,

4080:16

Amendment [7] - 3906:12, 3906:16,

3908:1, 3908:3, 3910:7, 3913:15,

3913:19

AMERICA [1] - 3773:4

America [20] - 3834:5, 3837:24,

3838:22, 3838:24, 3839:2, 3839:11,Johnny C. Sanchez, RMR, CRR - [email protected]

4096

3839:15, 3840:20, 3841:2, 3842:2,

3849:3, 3890:4, 3904:3, 3965:16,

3966:8, 3966:14, 3998:7, 3998:9,

4027:8, 4063:21

America's [1] - 3930:22

American [10] - 3833:8, 3853:9,

3873:6, 3895:6, 3895:9, 3945:10,

3989:8, 3990:2, 4007:9, 4065:21

amount [27] - 3790:25, 3792:4,

3795:10, 3816:14, 3817:20, 3834:19,

3840:18, 3841:20, 3842:13, 3842:16,

3842:23, 3844:10, 3851:17, 3863:9,

3863:11, 3863:12, 3867:15, 3868:25,

3875:3, 3875:5, 3875:6, 3947:17,

3966:24, 3972:21, 3972:23, 3980:2,

4030:3

amounts [9] - 3803:22, 3828:12,

3831:22, 3835:17, 3835:19, 3856:23,

3974:9, 3974:12, 3995:21

ample [1] - 3824:16

ana [1] - 3889:24

Ana [2] - 3889:25, 3890:1

analysis [3] - 3835:9, 3972:12, 3983:3

Andrew [2] - 3773:16, 4016:9

angle [2] - 3865:19, 3865:20

annual [7] - 3799:2, 3799:6, 3799:14,

3809:1, 3815:11, 3822:3, 3931:25

annually [2] - 3831:2, 3901:7

answer [28] - 3891:19, 3915:9,

3915:12, 3949:14, 3958:4, 3958:16,

3958:17, 3958:18, 3958:19, 3958:21,

3960:1, 3975:12, 3975:17, 3975:18,

3979:10, 3993:19, 3993:21, 4015:14,

4030:10, 4030:13, 4030:14, 4036:16,

4052:2, 4068:17, 4068:18, 4077:19,

4085:19

answer) [2] - 3801:21, 4027:15

answered [4] - 3808:2, 3820:17,

4041:14, 4050:10

answering [1] - 3969:2

answers [2] - 3778:18, 3778:19

Antigua [133] - 3777:23, 3782:10,

3788:3, 3788:9, 3788:25, 3794:11,

3794:16, 3830:23, 3830:24, 3833:4,

3833:18, 3834:12, 3847:1, 3847:4,

3847:13, 3847:20, 3847:22, 3848:4,

3848:7, 3848:17, 3848:21, 3849:5,

3849:23, 3849:25, 3853:13, 3859:4,

3859:8, 3859:16, 3859:24, 3860:2,

3860:13, 3862:22, 3863:4, 3863:14,

3863:24, 3866:5, 3867:13, 3870:12,

3881:5, 3885:9, 3900:23, 3901:4,

3901:17, 3920:25, 3922:1, 3922:10,

3922:11, 3922:15, 3922:16, 3923:6,

3923:14, 3923:16, 3923:17, 3923:25,

3924:4, 3924:11, 3924:22, 3925:16,

3925:24, 3926:13, 3926:16, 3927:3,

3934:19, 3935:6, 3937:1, 3938:1,

3938:16, 3938:20, 3938:22, 3939:8,

3941:20, 3945:19, 3946:10, 3947:2,

3947:20, 3947:23, 3948:22, 3954:23,

3962:8, 3964:18, 3969:6, 3969:9,

3970:5, 3970:6, 3971:9, 3973:21,

3973:23, 3974:4, 3977:2, 3979:7,

3995:19, 3998:5, 3998:12, 3998:25,

3999:3, 3999:8, 3999:14, 3999:18,

3999:20, 3999:21, 3999:25, 4000:7,

4014:2, 4014:10, 4014:24, 4015:5,

4015:17, 4015:20, 4016:1, 4021:7,

4021:9, 4024:1, 4024:11, 4025:22,

4028:11, 4028:17, 4029:24, 4041:20,

4045:1, 4045:20, 4046:8, 4048:21,

4049:3, 4049:7, 4053:13, 4053:15,

4059:8, 4061:11, 4077:3, 4077:7,

4077:8, 4077:10

Antigua/Barbuda [4] - 4059:3,

4059:20, 4061:7, 4063:15

Antiguan [26] - 3847:8, 3848:1,

3848:9, 3850:11, 3852:25, 3853:19,

3853:21, 3854:20, 3855:2, 3856:12,

3856:22, 3857:6, 3857:10, 3860:4,

3864:6, 3866:16, 3926:13, 3936:20,

3937:24, 3946:19, 3954:25, 3969:11,

4014:10, 4015:6, 4015:21

Antiguan/Eastern [1] - 3934:17

Antiguans [2] - 3923:18, 3955:2

anyway [1] - 4091:4

apart [6] - 3972:7, 3972:10, 3972:15,

3972:17, 3995:16, 4068:20

apologize [5] - 3818:5, 3886:5,

3939:5, 3966:12, 3982:13

apologized [1] - 4065:1

appear [9] - 3861:17, 3915:24,

3920:18, 3985:15, 3988:22, 3988:23,

4035:5, 4035:9, 4035:10

APPEARANCES [2] - 3773:12

appeared [2] - 3835:7, 4063:22

appearing [2] - 3912:24, 3912:25

applicable [2] - 3929:8, 3929:11

application [1] - 3943:5

applied [1] - 4062:21

apply [1] - 4056:18

applying [1] - 4064:1

appointing [1] - 3993:25

appreciate [1] - 4039:18

appreciated [1] - 3872:3

approach [2] - 3905:24, 4038:5

appropriate [2] - 3782:22, 3783:9

April [8] - 3850:8, 3851:2, 3866:8,

3866:18, 3917:8, 3992:17, 4079:22,

4081:13

area [1] - 3815:1

areas [1] - 3815:2

argue [1] - 3941:11

argument [2] - 3908:8, 4063:13

argumentative [2] - 3977:25, 4018:15

arguments [5] - 3939:7, 3939:11,

3939:14, 3941:4, 3941:11

arise [1] - 3899:24

arm [1] - 3939:11

arrived [2] - 3938:16, 3938:22

arrogant [2] - 3931:21, 3931:23

articles [1] - 3939:8

articulate [1] - 3777:16

Ashe [21] - 4044:21, 4052:16, 4052:17,

4053:6, 4053:7, 4058:19, 4061:25,

4070:23, 4071:6, 4071:20, 4072:10,

4073:2, 4073:20, 4075:16, 4078:11,

4078:22, 4079:21, 4084:7, 4084:25,

4087:6, 4089:15

ASHE [2] - 3776:12, 4053:1

asserted [6] - 3886:9, 3909:21,

3910:4, 3913:17, 3913:18, 3913:19

assets [13] - 3793:1, 3794:23, 3795:5,

3795:17, 3795:18, 3795:19, 3795:22,

3800:2, 3811:17, 3817:24, 3818:10,

3818:14, 4086:20

Assets [2] - 3794:25, 3812:10

assist [1] - 3938:2

Assistance [1] - 3847:16

assistance [5] - 3847:18, 3871:15,

3872:2, 3925:23, 3986:6

assistant [7] - 3877:22, 3887:12,

3888:6, 3888:24, 3890:6, 3890:7,

3890:24

Assistant [1] - 3773:14

assistant's [1] - 3797:10

assistants [6] - 3887:9, 3987:15,

3987:16, 3991:12, 3991:13

assisted [1] - 3774:14

assisting [1] - 3871:12

associate [4] - 4055:5, 4055:14,

4055:16, 4057:21

associate's [1] - 4055:4

assume [1] - 3954:2

assumes [1] - 3881:11

assuming [3] - 3886:7, 4031:4,

4071:24

asterisk [3] - 3836:14, 3836:17

Atlanta [9] - 3834:20, 3889:10,

3889:12, 3891:6, 3892:11, 3892:13,

3896:20, 4048:1, 4048:5

atomic [1] - 3822:22

attached [6] - 3833:5, 3928:13,

3931:7, 3932:16, 3936:23, 4004:17

attachment [3] - 3799:20, 3903:8,

3940:11

attacking [1] - 4037:10

attempt [5] - 3829:18, 3928:2,

3929:16, 3939:14, 4025:15

attempted [2] - 3785:21, 3884:12

attention [3] - 3961:20, 3966:7,

4080:14

attest [2] - 4086:18, 4086:21

attorney [15] - 3808:11, 3903:3,

3930:22, 3933:22, 3990:6, 4001:9,

4001:23, 4002:20, 4002:21, 4003:21,

4004:2, 4004:3, 4007:17, 4007:24,

4035:25

Attorney [2] - 3773:14, 3774:3

attorneys [3] - 3911:12, 3917:19,

4003:25

audible [3] - 3801:21, 3979:10,

4027:15

audition [1] - 4067:17

auditor [16] - 4086:1, 4086:4, 4086:5,

4086:6, 4086:15, 4086:16, 4087:8,


4097

4087:21, 4088:8, 4088:11, 4090:2

audits [1] - 3827:6

August [3] - 3930:3, 4061:1, 4089:24

authenticated [1] - 3781:15

authenticity [1] - 3781:18

authorities [4] - 4015:6, 4015:21,

4045:8, 4050:15

authority [5] - 3782:1, 3782:2, 3788:4,

3937:2, 4043:15

authorization [2] - 3829:8, 3946:7

authorized [1] - 3777:22

automatic [1] - 4063:5

available [8] - 3824:1, 3824:4, 3824:8,

3824:12, 3825:3, 3993:1, 3993:7,

4013:20

Avenue [1] - 3773:17

avoid [1] - 4041:9

aware [34] - 3787:19, 3787:23,

3926:15, 3965:1, 3988:12, 3989:6,

3995:3, 4013:9, 4015:11, 4015:12,

4015:22, 4019:5, 4019:8, 4027:7,

4027:10, 4029:13, 4036:10, 4038:3,

4039:12, 4039:13, 4040:16, 4047:2,

4048:19, 4071:6, 4071:9, 4077:11,

4077:14, 4078:5, 4083:9, 4087:24,

4088:5, 4088:6, 4089:25, 4090:4

awe [1] - 4063:12

B

B-E-A-Z-E-R [1] - 4065:21

bachelor's [3] - 3950:13, 3950:19,

4055:12

background [2] - 3950:10, 4054:22

backup [1] - 3848:24

backwards [1] - 3967:2

bad [3] - 3826:18, 3906:14, 3907:10

badge [1] - 3952:3

Bailey [5] - 4089:21, 4089:22, 4089:23,

4089:25, 4090:4

balance [5] - 3791:8, 3944:20,

3963:16, 4083:22, 4086:18

balances [4] - 3963:17, 4086:10,

4086:13, 4087:4

Baltimore [2] - 3889:7, 3889:11

bamboozled [1] - 3794:7

band [11] - 3873:9, 3873:23, 3875:4,

3978:24, 3978:25, 3980:2, 3980:7,

3980:11, 3996:11

bank [198] - 3781:16, 3782:6, 3786:18,

3787:21, 3790:15, 3791:5, 3791:18,

3792:21, 3793:1, 3793:2, 3793:14,

3794:10, 3794:14, 3795:25, 3798:23,

3818:10, 3818:19, 3821:15, 3829:14,

3830:3, 3830:19, 3831:17, 3831:18,

3835:18, 3837:1, 3837:2, 3837:5,

3837:10, 3837:17, 3839:10, 3840:16,

3842:21, 3843:3, 3843:11, 3844:1,

3845:14, 3846:3, 3846:25, 3847:5,

3847:9, 3847:20, 3847:24, 3847:25,

3848:6, 3848:10, 3848:14, 3850:11,

3852:1, 3852:25, 3853:13, 3855:2,

3857:11, 3859:2, 3859:3, 3859:22,

3859:23, 3859:25, 3860:2, 3864:6,

3866:12, 3866:16, 3867:13, 3870:5,

3870:7, 3870:16, 3870:18, 3870:19,

3873:16, 3874:5, 3874:6, 3874:7,

3874:9, 3875:9, 3896:6, 3903:3,

3915:25, 3922:15, 3922:16, 3923:15,

3923:18, 3924:3, 3933:22, 3935:10,

3939:15, 3941:21, 3946:10, 3946:11,

3946:19, 3948:4, 3954:14, 3954:21,

3957:25, 3958:2, 3959:25, 3960:22,

3960:23, 3961:16, 3961:22, 3961:25,

3962:3, 3962:6, 3962:8, 3963:6,

3964:17, 3964:18, 3964:20, 3964:23,

3965:2, 3965:4, 3965:9, 3965:12,

3965:24, 3966:8, 3966:11, 3968:7,

3969:10, 3969:11, 3969:20, 3970:4,

3970:7, 3970:13, 3971:6, 3973:10,

3973:18, 3973:23, 3974:4, 3975:6,

3976:23, 3976:24, 3977:11, 3977:17,

3977:20, 3980:1, 3980:22, 3981:18,

3982:19, 3991:14, 3995:25, 3996:6,

3996:7, 3996:14, 3998:10, 3998:16,

3999:8, 3999:20, 4000:13, 4001:12,

4009:22, 4009:23, 4014:12, 4014:15,

4015:25, 4016:3, 4017:2, 4017:4,

4019:9, 4019:10, 4019:11, 4019:14,

4019:23, 4021:11, 4021:15, 4022:1,

4041:25, 4042:11, 4042:16, 4042:17,

4045:22, 4046:2, 4046:5, 4046:8,

4046:16, 4046:25, 4050:8, 4058:16,

4058:17, 4058:24, 4064:12, 4075:10,

4076:11, 4080:22, 4082:2, 4082:6,

4083:19, 4084:16, 4084:22, 4085:9,

4085:11, 4086:11, 4086:17, 4087:1,

4087:3, 4087:25, 4089:13, 4090:10,

4090:25

Bank [127] - 3777:23, 3782:10, 3786:9,

3788:3, 3788:9, 3788:24, 3790:14,

3795:19, 3829:24, 3834:5, 3837:24,

3838:14, 3838:16, 3838:22, 3838:24,

3839:2, 3839:11, 3839:15, 3840:20,

3841:2, 3842:2, 3848:4, 3848:18,

3848:21, 3849:3, 3849:5, 3849:23,

3854:1, 3855:8, 3859:3, 3859:7,

3859:15, 3859:24, 3860:13, 3862:22,

3863:4, 3863:14, 3863:23, 3866:5,

3870:12, 3896:9, 3897:25, 3899:12,

3900:19, 3902:14, 3921:16, 3921:17,

3921:25, 3922:9, 3923:5, 3923:13,

3923:14, 3923:17, 3923:23, 3924:4,

3924:5, 3924:7, 3924:11, 3924:16,

3924:22, 3925:6, 3925:16, 3925:18,

3925:24, 3926:13, 3926:16, 3927:1,

3927:2, 3927:7, 3934:23, 3937:1,

3937:25, 3941:13, 3945:19, 3946:11,

3947:3, 3954:21, 3965:16, 3966:8,

3966:13, 3969:6, 3969:9, 3970:5,

3970:6, 3971:9, 3973:21, 3973:23,

3974:4, 3977:2, 3979:7, 3995:19,

3998:5, 3998:7, 3998:9, 3998:12,

3998:25, 3999:3, 3999:8, 4000:6,

4000:7, 4011:3, 4021:9, 4024:11,

4024:22, 4041:20, 4045:1, 4045:3,

4045:23, 4046:17, 4054:19, 4058:22,

4058:23, 4058:25, 4059:1, 4059:14,

4060:25, 4063:20, 4079:25, 4081:4,

4082:12, 4083:12, 4088:23, 4089:16,

4089:18

bank's [15] - 3800:2, 3818:14,

3899:15, 3901:12, 3901:20, 3904:12,

3940:19, 3981:18, 4002:20, 4002:21,

4021:12, 4046:14, 4083:22, 4085:15,

4085:17

Bank's [1] - 3915:25

Bankers [2] - 4056:24, 4057:4

banking [13] - 3868:18, 3902:5,

3955:3, 3955:8, 4017:20, 4057:19,

4058:9, 4058:14, 4058:20, 4065:9,

4071:18, 4088:20, 4089:3

Banks [10] - 4053:18, 4053:20,

4053:24, 4059:17, 4059:20, 4062:2,

4062:4, 4062:15, 4065:10, 4076:22

banks [87] - 3837:5, 3837:22, 3840:7,

3840:10, 3847:1, 3847:8, 3847:12,

3848:1, 3848:3, 3848:12, 3848:15,

3921:20, 3922:11, 3923:8, 3923:10,

3923:11, 3925:1, 3929:9, 3929:12,

3934:19, 3935:5, 3935:6, 3935:9,

3936:21, 3937:12, 3937:14, 3954:7,

3954:9, 3954:11, 3954:17, 3954:18,

3956:20, 3956:24, 3957:16, 3957:18,

3957:21, 3958:8, 3959:14, 3959:22,

3960:6, 3960:8, 3963:7, 3965:7,

3966:10, 3966:11, 3966:13, 3966:16,

3967:6, 3997:24, 3998:3, 3999:14,

3999:17, 3999:21, 3999:24, 4001:11,

4023:15, 4023:19, 4029:25, 4030:6,

4030:23, 4043:14, 4044:10, 4045:7,

4045:10, 4054:18, 4054:19, 4060:7,

4060:9, 4062:13, 4062:17, 4063:25,

4064:3, 4069:18, 4075:6, 4076:16,

4076:19, 4083:11, 4086:10, 4087:12,

4087:19, 4087:22, 4088:12, 4088:25,

4089:2, 4089:7

banks' [1] - 3848:18

bar [1] - 4005:20

Barbados [1] - 4059:8

Barbuda [10] - 3849:23, 3900:23,

3901:5, 3901:18, 4048:21, 4061:12,

4061:13, 4061:14, 4061:19, 4077:3

Barclays [6] - 4058:22, 4058:23,

4059:1, 4059:6, 4059:11

Barlow [8] - 3887:10, 3888:15,

3888:20, 3888:25, 3890:24, 3892:9,

3892:21, 3893:1

Barlow's [1] - 3892:1

based [17] - 3812:16, 3836:3, 3836:18,

3843:2, 3843:25, 3887:19, 3888:12,

3888:13, 3933:25, 3948:14, 3973:3,

4056:9, 4056:11, 4056:14, 4058:2,

4074:19, 4077:21

basement [1] - 3918:20

basing [1] - 3973:8

basis [11] - 3780:22, 3781:21,


4098

3833:25, 3935:11, 3937:23, 3954:12,

4027:10

bearing [2] - 3965:17, 3965:20

beat [1] - 3993:11

Beazer [1] - 4065:19

became [7] - 3838:17, 4007:3,

4060:23, 4063:17, 4071:9, 4087:22,

4088:12

become [4] - 3793:1, 4056:12, 4057:3,

4057:16

becomes [1] - 3886:21

becoming [1] - 3890:3

BEFORE [1] - 3773:10

beginning [3] - 3944:20, 3956:7,

4013:11

behalf [2] - 3791:11, 4009:24

behavior [1] - 4065:2

behind [3] - 3964:3, 3964:8, 4070:25

belonging [1] - 3859:22

below [4] - 3842:17, 3856:8, 3894:7,

3959:18

bench [3] - 3906:2, 3917:23, 4038:7

best [6] - 3883:25, 3906:23, 3921:11,

3930:22, 3940:3, 4059:21

better [3] - 3910:4, 3941:9

between [32] - 3781:7, 3792:11,

3797:5, 3826:25, 3828:14, 3828:17,

3847:22, 3848:1, 3850:18, 3892:22,

3894:14, 3908:15, 3920:5, 3935:14,

3936:23, 3941:16, 3974:9, 3986:5,

3996:2, 3997:20, 4004:7, 4004:19,

4006:10, 4008:22, 4009:22, 4022:24,

4037:20, 4064:16, 4064:22, 4068:19,

4086:3, 4089:13

beyond [9] - 3806:15, 3808:12,

3810:1, 3810:13, 3815:25, 3816:20,

3816:22, 3821:19, 3823:9

Big [6] - 4073:20, 4073:24, 4073:25,

4074:2, 4074:4, 4074:8

big [7] - 3781:6, 3801:24, 3802:21,

3826:18, 3938:1, 3970:23, 4074:5

bill [9] - 3895:3, 3895:5, 3895:9,

3895:14, 3932:3, 3932:5, 3989:18,

3989:25, 4007:10

billion [18] - 3792:8, 3793:4, 3793:11,

3793:16, 3794:25, 3795:11, 3795:23,

3799:9, 3814:14, 3814:21, 3815:16,

3817:7, 3817:13, 3817:16, 3817:18,

3818:21, 3821:18, 3822:1

billionaire [1] - 3970:23

bills [17] - 3852:1, 3852:6, 3852:7,

3852:8, 3852:9, 3852:12, 3853:4,

3854:4, 3854:7, 3862:3, 3862:4,

3968:12, 3968:19, 4069:21

bind [2] - 4038:13, 4038:19

biography [1] - 4063:6

bit [13] - 3778:2, 3794:21, 3803:16,

3865:21, 3877:9, 3915:10, 3922:17,

3946:13, 3950:5, 3957:24, 3963:5,

3992:8, 3997:18

black [1] - 3798:24

Blaise [1] - 3803:18

blame [1] - 3778:7

bless [2] - 4009:12, 4074:16

blinded [2] - 4087:13, 4088:10

blindly [1] - 3965:8

blood [1] - 4090:5

bloody [1] - 4074:15

blow [8] - 3838:2, 3860:10, 3878:9,

3901:15, 3901:21, 3931:14, 3934:13,

3940:16

blue [2] - 4016:11, 4016:16

BOA [1] - 3998:5

board [17] - 3790:10, 3864:15,

3866:11, 3888:10, 3926:19, 4013:6,

4060:2, 4060:3, 4064:16, 4075:3,

4084:3, 4084:19, 4084:20, 4084:21

boat [4] - 3801:15, 3801:25, 3802:23,

3803:6

body [1] - 3924:2

bomb [1] - 3822:22

bonfire [2] - 3787:20, 3787:23

book [21] - 3796:20, 3796:23, 3796:25,

3797:15, 3809:7, 3809:18, 3809:22,

3809:23, 3809:25, 3810:4, 3810:6,

3887:11, 3887:13, 3888:18, 3888:20,

3896:11, 3897:13, 3897:16, 4026:2,

4026:9, 4047:17

books [5] - 3809:24, 3810:4, 3812:20,

3812:21, 3812:22

boring [1] - 3997:17

borrowed [1] - 3817:8

borrowing [1] - 3815:16

bottom [28] - 3797:11, 3841:23,

3843:5, 3844:9, 3845:13, 3856:1,

3856:2, 3861:16, 3862:9, 3867:9,

3877:3, 3877:5, 3878:9, 3878:12,

3882:1, 3886:2, 3890:22, 3891:24,

3896:24, 3919:23, 3926:3, 3926:5,

3938:8, 3989:19, 4010:19, 4010:22,

4074:18, 4080:6

bought [10] - 3818:19, 3884:10,

3884:16, 3889:12, 3932:9, 3977:9,

3977:13, 3985:20, 4012:24, 4032:10

Bowl [46] - 3875:15, 3875:19, 3878:12,

3879:3, 3879:6, 3879:15, 3880:7,

3881:6, 3881:16, 3881:23, 3882:11,

3883:10, 3883:23, 3885:17, 3885:18,

3885:20, 3889:9, 3889:11, 3890:17,

3890:20, 3891:4, 3892:4, 3893:5,

3893:17, 3894:9, 3894:10, 3894:16,

3894:21, 3895:11, 3896:7, 3897:7,

3932:9, 3983:17, 3985:2, 3985:16,

3985:21, 3995:22, 3995:24, 4005:19,

4012:23, 4022:4, 4022:15, 4022:20,

4024:18, 4031:17, 4031:25

box [3] - 3862:14, 3944:18, 3984:11

Box [2] - 3773:14, 3774:7

boxes [2] - 3895:2, 3905:2

bracket [1] - 3866:19

break [16] - 3846:4, 3851:25, 3854:12,

3854:14, 3855:19, 3857:22, 3857:24,

3858:13, 3861:25, 3909:12, 3911:14,

3923:15, 3997:5, 4018:10, 4023:13,

4091:8

breakdown [2] - 3849:2, 3853:2

breaking [2] - 3911:4, 3911:6

breaks [2] - 3842:11, 3849:4

bribe [14] - 3967:23, 3968:3, 3983:10,

3983:19, 3983:21, 3990:6, 3990:7,

3990:8, 3990:9, 3990:20, 3998:15,

3998:17, 4005:18

bribed [5] - 3990:11, 3995:15,

3995:18, 3995:23, 4088:9

bribery [7] - 3969:16, 3972:25,

4004:23, 4009:4, 4009:6, 4009:8

bribes [6] - 3829:17, 3858:20, 4020:3,

4021:4, 4021:25, 4087:24

bribing [11] - 3968:17, 3970:21,

3973:16, 3977:22, 3983:6, 3985:6,

3989:24, 3991:6, 4002:14, 4002:24,

4021:24

Brief [1] - 3806:19

briefcase [2] - 3854:10, 3862:6

briefcases [1] - 4060:20

briefly [11] - 3782:18, 3821:6, 3826:25,

3827:19, 3828:14, 3949:24, 3953:21,

3956:7, 4054:4, 4057:11, 4062:10

bring [10] - 3798:16, 3811:7, 3909:8,

3909:13, 3909:17, 3979:3, 3984:6,

3988:2, 3989:13, 4038:14

bringing [1] - 3908:24

British [2] - 3851:12, 3851:14

broader [1] - 3934:7

brochure [2] - 3798:21, 3799:1

broke [1] - 3856:17

broker [6] - 3892:18, 3893:9, 3893:15,

3893:24, 4084:16, 4086:17

brokerage [4] - 3847:5, 3942:22,

3944:13, 3944:21

brokers [1] - 4086:11

brother [1] - 3938:1

Brother [1] - 4074:1

brought [5] - 3907:21, 3909:3,

3978:22, 3997:2, 4038:25

buck [1] - 4060:12

bueno [1] - 3938:6

build [1] - 4020:11

building [2] - 3885:11, 3918:20

Building [1] - 4011:5

built [1] - 4020:17

bunch [2] - 3789:16, 3909:18

bureaucratic [2] - 4042:11, 4042:13

burned [1] - 3787:20

bush [1] - 3993:11

business [23] - 3805:15, 3813:19,

3887:10, 3888:19, 3896:19, 3902:5,

3931:22, 3954:11, 3954:17, 4007:13,

4007:17, 4007:24, 4026:22, 4035:2,

4035:6, 4035:12, 4054:25, 4055:5,

4055:8, 4056:6, 4059:15, 4064:17

Business [5] - 3901:9, 4055:2,

4055:19, 4056:4, 4057:1

businesses [2] - 3791:24, 3957:19

businessperson [1] - 4028:1

but.. [1] - 3953:17

buy [3] - 3883:10, 3889:3, 3977:10

buying [1] - 4033:4


4099

BY [282] - 3775:5, 3775:7, 3775:9,

3775:11, 3775:13, 3775:15, 3775:17,

3775:21, 3775:23, 3775:25, 3776:2,

3776:4, 3776:6, 3776:8, 3776:10,

3776:14, 3784:8, 3784:20, 3786:1,

3787:1, 3788:13, 3788:23, 3789:7,

3789:20, 3790:1, 3794:20, 3795:16,

3796:5, 3797:23, 3798:14, 3798:18,

3799:21, 3800:9, 3801:14, 3801:19,

3802:4, 3802:13, 3802:20, 3803:15,

3805:10, 3807:8, 3808:4, 3808:14,

3810:7, 3810:15, 3811:3, 3811:15,

3813:4, 3815:5, 3816:5, 3816:10,

3817:6, 3818:6, 3819:1, 3819:13,

3819:25, 3820:12, 3821:8, 3821:24,

3822:7, 3823:1, 3823:15, 3826:5,

3826:14, 3832:3, 3835:22, 3836:2,

3836:7, 3837:16, 3838:3, 3838:19,

3839:9, 3840:14, 3841:7, 3842:7,

3843:1, 3843:23, 3844:11, 3844:17,

3845:12, 3846:1, 3846:9, 3849:21,

3851:1, 3851:20, 3852:23, 3853:12,

3853:25, 3854:19, 3854:25, 3856:3,

3856:11, 3857:1, 3858:12, 3859:5,

3859:19, 3860:11, 3860:22, 3861:5,

3862:10, 3863:2, 3864:3, 3866:3,

3866:17, 3866:21, 3867:11, 3867:19,

3868:8, 3869:5, 3869:16, 3870:11,

3870:17, 3870:22, 3871:4, 3871:18,

3871:25, 3872:18, 3872:24, 3873:8,

3873:14, 3874:4, 3874:16, 3875:8,

3876:2, 3876:6, 3877:1, 3877:11,

3878:11, 3878:25, 3879:14, 3879:19,

3880:5, 3880:12, 3882:2, 3882:19,

3883:8, 3884:22, 3886:3, 3888:2,

3890:11, 3890:23, 3891:21, 3891:25,

3892:8, 3893:8, 3893:14, 3893:22,

3895:24, 3896:18, 3898:4, 3899:2,

3900:3, 3900:24, 3902:7, 3902:17,

3904:1, 3904:21, 3905:7, 3915:19,

3916:21, 3918:9, 3918:24, 3919:7,

3919:17, 3920:11, 3920:17, 3922:25,

3924:15, 3925:10, 3925:22, 3926:4,

3928:9, 3929:24, 3930:6, 3930:10,

3930:18, 3931:16, 3932:23, 3933:15,

3934:15, 3936:3, 3936:14, 3938:9,

3939:2, 3939:18, 3939:24, 3940:5,

3940:18, 3942:21, 3943:3, 3943:19,

3943:25, 3944:10, 3944:19, 3945:12,

3945:21, 3946:6, 3946:15, 3946:25,

3947:6, 3947:13, 3948:3, 3949:9,

3953:19, 3958:25, 3968:2, 3969:25,

3976:9, 3976:15, 3978:3, 3978:9,

3978:19, 3979:5, 3979:13, 3980:14,

3980:24, 3982:5, 3984:14, 3985:4,

3986:4, 3986:19, 3987:18, 3989:16,

3989:21, 3991:2, 3993:22, 3997:14,

3998:2, 4001:4, 4006:1, 4008:16,

4009:16, 4010:21, 4011:9, 4012:10,

4013:7, 4013:17, 4015:19, 4018:2,

4018:23, 4019:22, 4022:13, 4025:13,

4027:4, 4030:20, 4031:22, 4032:6,

4032:12, 4034:3, 4037:8, 4037:19,

4040:10, 4041:18, 4042:9, 4044:14,

4048:11, 4049:20, 4050:6, 4050:12,

4050:19, 4051:16, 4053:5, 4053:23,

4054:17, 4055:17, 4058:12, 4058:18,

4059:5, 4061:24, 4070:22, 4071:5,

4072:9, 4073:1, 4073:19, 4075:15,

4076:1, 4077:20, 4078:4, 4078:10,

4078:21, 4079:20, 4088:4

Byron [1] - 3861:22

C

C.A.S [4] - 4087:20, 4087:21, 4087:24,

4088:8

cabinets [1] - 3918:19

California [1] - 3896:3

campaign [2] - 4077:11, 4077:22

Canadian [1] - 4058:23

candidate [1] - 4075:9

cannot [3] - 3883:5, 4003:21, 4004:2

capacity [1] - 3907:4

capital [1] - 3849:25

Capital [1] - 4011:3

capitalize [4] - 3804:18, 3805:4,

3805:21, 3817:1

caps [1] - 4025:21

captured [1] - 3817:3

card [16] - 3787:21, 3838:2, 3838:5,

3838:21, 3839:10, 3839:12, 3884:8,

3887:10, 3887:11, 3888:19, 3890:25,

3895:6, 3989:9, 3989:25, 3990:18,

4034:25

cards [2] - 3969:13, 4016:20

care [5] - 3895:17, 3904:25, 3905:1,

3986:22, 3989:20

career [3] - 3952:19, 4056:16, 4057:15

carefully [2] - 3901:1, 3901:2

Caribbean [53] - 3794:12, 3850:13,

3850:14, 3850:18, 3850:20, 3851:4,

3851:7, 3852:7, 3854:4, 3855:21,

3856:4, 3860:15, 3861:2, 3862:2,

3863:10, 3863:17, 3863:18, 3863:19,

3866:10, 3867:3, 3867:16, 3867:24,

3868:11, 3868:24, 3869:11, 3869:21,

3921:16, 3921:17, 3921:20, 3921:21,

3921:22, 3921:25, 3922:3, 3922:7,

3922:9, 3923:5, 3924:3, 3924:16,

3924:19, 3925:2, 3926:25, 3927:7,

3929:15, 3932:20, 3934:17, 3936:18,

3938:5, 4000:6, 4020:20, 4058:24,

4059:11, 4060:25

Caribbeans [1] - 3928:2

Carlos [12] - 3933:20, 3936:13,

3936:25, 3938:16, 3938:19, 3938:23,

3940:3, 3940:7, 4001:8, 4018:4,

4019:21, 4025:19

Carnival [1] - 3871:9

carry [2] - 3828:7, 3952:1

CASE [3] - 3825:16, 4052:17, 4052:23

case [24] - 3787:12, 3824:25, 3825:18,

3826:19, 3827:10, 3827:12, 3827:15,

3828:20, 3828:23, 3830:3, 3830:9,

3837:12, 3904:16, 3907:14, 3908:12,

3953:22, 3969:16, 3982:21, 3982:22,

3982:23, 3998:21, 4013:10, 4052:19,

4086:15

cases [3] - 3828:22, 4020:11, 4020:17

Cash [1] - 3860:19

cash [175] - 3818:11, 3829:17,

3830:18, 3831:15, 3831:17, 3831:22,

3835:18, 3840:3, 3840:16, 3840:19,

3840:20, 3840:22, 3840:24, 3841:2,

3841:14, 3841:15, 3841:19, 3841:20,

3842:4, 3842:11, 3842:13, 3842:16,

3842:18, 3842:20, 3843:3, 3843:7,

3843:10, 3843:25, 3844:12, 3845:4,

3845:5, 3845:8, 3845:13, 3845:20,

3846:3, 3846:16, 3846:22, 3848:19,

3848:22, 3849:4, 3849:6, 3849:12,

3849:15, 3850:6, 3850:9, 3851:2,

3852:2, 3853:2, 3854:5, 3854:20,

3855:1, 3855:7, 3855:19, 3856:5,

3856:12, 3856:19, 3856:23, 3857:6,

3857:9, 3857:17, 3858:16, 3858:20,

3858:21, 3860:7, 3860:16, 3860:17,

3860:25, 3861:6, 3861:22, 3862:1,

3862:11, 3862:17, 3862:21, 3863:3,

3863:10, 3863:17, 3863:22, 3864:5,

3864:9, 3866:25, 3867:20, 3867:22,

3868:2, 3868:9, 3868:13, 3868:22,

3869:17, 3870:3, 3870:6, 3874:12,

3896:5, 3941:20, 3956:11, 3956:12,

3956:13, 3956:15, 3956:16, 3956:17,

3956:20, 3957:10, 3957:15, 3957:17,

3957:20, 3958:5, 3959:16, 3959:22,

3959:23, 3960:15, 3961:2, 3961:5,

3961:6, 3961:10, 3961:22, 3961:24,

3963:7, 3963:8, 3963:12, 3963:16,

3963:21, 3963:22, 3963:24, 3964:6,

3966:21, 3966:22, 3966:25, 3967:3,

3967:6, 3968:6, 3968:7, 3968:10,

3968:17, 3969:19, 3970:14, 3970:17,

3971:4, 3971:6, 3971:7, 3971:10,

3971:11, 3971:24, 3971:25, 3972:1,

3973:5, 3975:5, 3975:8, 3975:10,

3975:14, 3976:12, 3976:25, 3977:5,

3977:21, 3983:11, 3983:13, 3987:19,

3991:14, 3991:15, 3991:16, 3991:17,

3991:23, 3991:25, 3995:15, 3995:16,

3995:18, 4020:20, 4020:23, 4021:1,

4021:19, 4022:2, 4060:18, 4060:20

cash-in [2] - 3963:8, 3963:12

cash-out [1] - 3963:24

catch [3] - 3858:5, 3864:10, 3914:23

caught [2] - 3911:1, 3997:6

caused [1] - 4004:23

caution [1] - 3915:16

cautioned [2] - 3826:2, 4053:2

CD [16] - 3791:14, 3792:1, 3792:5,

3792:15, 3792:20, 3793:11, 3793:24,

3794:5, 3794:14, 3798:24, 3801:6,

3804:5, 3805:24, 3821:10, 3823:17,

3899:15

Cecasa [1] - 3797:12

cell [4] - 3896:19, 3896:20, 3896:21,Johnny C. Sanchez, RMR, CRR - [email protected]

4100

4048:3

cellphone [1] - 4048:1

center [1] - 3938:4

central [1] - 3921:10

Central [8] - 3921:16, 3921:17,

3921:25, 3922:9, 3923:5, 3926:25,

3927:7, 4000:6

CEO [14] - 3830:22, 3899:5, 4044:1,

4062:14, 4062:17, 4063:24, 4064:4,

4064:9, 4064:10, 4064:16, 4064:23,

4066:6, 4071:7

certain [8] - 3833:13, 3957:20, 3958:1,

3984:2, 3984:4, 3994:24, 4003:7,

4049:1

certainly [3] - 3817:13, 3824:14,

3934:17

CERTIFICATE [1] - 4092:1

certification [1] - 3781:17

certified [1] - 3831:10

certify [1] - 4092:3

cetera [1] - 3937:7

chain [9] - 3876:12, 3877:7, 3879:18,

3882:1, 3884:7, 3987:25, 4006:2,

4031:24, 4034:14

chains [1] - 3877:2

chair [4] - 3953:15, 4060:5, 4060:6,

4062:9

chairman [13] - 3872:15, 3877:25,

3878:1, 3882:6, 3886:15, 3888:8,

3888:10, 3889:1, 3890:12, 4043:25,

4044:1, 4071:7, 4075:8

chairperson [1] - 4074:11

chance [2] - 3779:1, 3940:1

change [7] - 3779:22, 3822:15,

3878:15, 3878:21, 3943:23, 3947:25,

4027:13

changed [1] - 3808:9

channel [1] - 4051:1

channels [7] - 3847:19, 4042:13,

4042:17, 4042:23, 4042:25, 4050:23,

4050:25

charge [6] - 3808:21, 3827:16,

3895:25, 3937:13, 4036:7, 4036:9

charged [9] - 3787:11, 3969:15,

3969:16, 4006:25, 4036:5, 4036:6,

4038:2, 4040:19, 4054:10

charges [2] - 3827:10, 4036:12

Charles [12] - 3942:24, 3942:25,

3943:6, 3943:20, 3943:21, 3944:1,

3944:3, 3944:13, 3944:21, 3945:14,

3947:19, 3948:14

chart [20] - 3786:2, 3789:16, 3789:21,

3790:13, 3835:11, 3835:15, 3836:3,

3836:23, 3843:10, 3846:5, 3846:10,

3856:10, 3856:13, 3857:2, 3858:14,

3862:21, 3863:3, 3978:17, 3983:14,

4001:1

charter [2] - 4056:9, 4056:25

Chartered [5] - 4056:3, 4056:23,

4057:4, 4057:9, 4057:21

charts [2] - 3813:17, 3974:8

Chase [10] - 3837:24, 3838:6, 3838:13,

3838:17, 3842:8, 3849:3, 3965:16,

3966:8, 3966:13, 3998:9

chatted [2] - 3978:12, 3978:14

check [6] - 3835:7, 3848:5, 3892:17,

3935:24, 4000:14, 4017:19

checked [1] - 3905:2

checking [9] - 3837:24, 3838:6,

3838:22, 3839:1, 3839:4, 3839:15,

3853:6, 3923:20, 3943:16

checks [8] - 3845:4, 3845:5, 3849:16,

3855:16, 3874:20, 3964:8, 4087:4

Chemical [2] - 3838:14, 3838:15

chief [3] - 3808:19, 3872:16, 4081:9

choose [2] - 3824:10, 3824:15

chronology [1] - 3919:21

CID [1] - 3982:9

circumstances [4] - 4002:6, 4008:2,

4036:12, 4060:22

citizen [2] - 3831:1, 3833:8

citizens [2] - 3831:2, 3860:4

civil [8] - 3827:2, 3827:3, 3828:15,

3828:19, 3828:21, 3829:2, 4051:1

civilly [3] - 4036:6, 4036:7, 4036:8

claim [2] - 3780:2, 3780:22

claimed [2] - 4012:19, 4013:1

clarification [2] - 4005:21, 4005:23

class [1] - 3952:7

classes [1] - 3951:9

clause [1] - 3976:2

cleanup [1] - 3938:2

clear [11] - 3795:17, 3810:22, 3849:1,

3849:15, 3986:9, 3988:6, 4002:18,

4004:7, 4004:18, 4010:18, 4017:17

cleared [1] - 3875:25

clearly [3] - 3781:16, 3799:1, 4078:1

client [6] - 3906:15, 3906:16, 3907:9,

3907:10, 3908:17, 3948:10

clip [1] - 3919:21

clock [4] - 3910:22, 3910:23, 3914:22,

3997:6

close [3] - 3856:21, 3863:22, 3864:12

closed [1] - 3791:22

closeness [1] - 3864:8

club [4] - 3878:14, 3892:24, 3893:2,

3985:14

CO [1] - 4059:25

co [1] - 3921:10

co-op [1] - 3921:10

coach [1] - 3889:6

cold [1] - 3949:25

collar [2] - 4040:25, 4041:2

collect [3] - 3827:5, 4065:23, 4065:25

collected [1] - 4066:1

collecting [1] - 4067:11

college [2] - 3950:14, 4054:23

Colombia [2] - 4038:12, 4047:14

colony [1] - 4048:21

column [12] - 3791:7, 3791:9, 3822:11,

3836:6, 3836:8, 3844:5, 3844:18,

3844:24, 3845:1, 3845:7, 3855:23,

3863:8

columns [1] - 3863:6

combined [1] - 3839:15

comfortable [1] - 3953:15

coming [18] - 3792:14, 3805:24,

3817:10, 3821:9, 3843:3, 3844:22,

3847:7, 3870:4, 3963:12, 3963:21,

3964:6, 3991:14, 3995:14, 4028:7,

4029:24, 4072:20, 4074:21, 4079:14

comment [2] - 4038:24, 4069:14

Commerce [1] - 4058:24

commercial [8] - 3791:20, 3860:2,

3923:18, 3925:1, 3929:11, 3956:24,

3969:9, 3969:11

commission [24] - 4023:25, 4054:14,

4060:1, 4060:4, 4060:19, 4064:9,

4064:11, 4064:24, 4066:7, 4068:8,

4072:17, 4075:4, 4075:8, 4075:10,

4075:11, 4076:3, 4076:4, 4077:14,

4077:15, 4086:1, 4086:3, 4086:8,

4088:17

Commission [13] - 3830:23, 3833:4,

3834:7, 3899:6, 3900:17, 3900:21,

3902:20, 3904:4, 3905:12, 4053:22,

4054:7, 4074:12, 4080:4

commit [2] - 3969:18, 4005:3

commitment [1] - 4070:4

committed [3] - 4004:25, 4037:25,

4040:18

committee [1] - 4084:20

committees [1] - 4083:25

common [6] - 3924:8, 3925:14,

3925:17, 3955:7, 4047:18, 4048:24

common-law [1] - 4048:24

commonplace [1] - 4023:18

communicate [1] - 3808:5

companies [35] - 3790:12, 3790:14,

3790:19, 3791:1, 3791:3, 3791:4,

3791:11, 3791:13, 3791:17, 3792:15,

3792:19, 3792:22, 3793:15, 3794:11,

3801:7, 3804:18, 3805:4, 3805:22,

3817:1, 3817:9, 3817:19, 3822:1,

3823:2, 3823:5, 3876:16, 3878:1,

3917:7, 3917:9, 3942:1, 3942:4,

3992:12, 4027:8, 4047:18, 4080:18

Company [5] - 3900:18, 3904:6,

4011:2, 4080:18, 4087:20

company [18] - 3881:7, 3881:12,

3886:21, 3925:14, 3942:10, 3984:23,

3985:11, 3988:23, 3988:25, 3990:18,

4009:11, 4047:18, 4067:16, 4069:9,

4069:23, 4070:5, 4086:20, 4086:23

compare [9] - 3835:19, 3836:24,

3846:19, 3857:13, 3864:1, 3864:4,

3866:24, 3897:17, 4086:13

compared [1] - 3972:8

comparison [3] - 3803:2, 3806:1,

3806:4

compel [1] - 3904:15

compensated [1] - 4069:15

compensation [1] - 4069:16

competence [3] - 4056:17, 4057:12,

4057:14

competition [1] - 3871:11

complain [1] - 3780:21

complaint [1] - 4036:8Johnny C. Sanchez, RMR, CRR - [email protected]

4101

complete [2] - 3848:24, 4054:24

completed [1] - 3792:23

completely [3] - 3973:9, 4000:2,

4038:20

compliance [1] - 3901:8

compliant [1] - 3902:6

comply [1] - 4059:22

complying [3] - 4084:23, 4085:11,

4086:24

compound [1] - 3977:24

comprehensive [2] - 3848:5, 3935:11

compulsory [1] - 3909:2

computer [8] - 3774:14, 3786:3,

3835:21, 3920:10, 3994:17, 4014:17,

4014:20, 4025:9

computer-assisted [1] - 3774:14

computerized [3] - 3841:1, 3841:8,

3843:2

computers [3] - 3786:10, 4014:21,

4017:12

con [1] - 3794:21

concede [1] - 4082:23

concept [6] - 3813:6, 3813:7, 3813:12,

3813:14, 3814:6, 3814:8

concern [6] - 3906:4, 3910:7, 3914:20,

3915:5, 4062:18, 4075:5

concerned [8] - 3901:4, 3902:2,

3932:1, 3937:5, 3996:7, 4006:19,

4007:3, 4031:13

concerning [3] - 3785:10, 3915:5,

3923:7

concerns [3] - 3927:25, 4006:3,

4030:25

concierge [1] - 3884:24

Concierges [1] - 3880:15

conclude [2] - 3931:24, 4035:13

concluded [2] - 3901:12, 3901:25

conclusion [2] - 3780:10, 3977:22

concurrent [1] - 3955:20

conduct [9] - 3785:5, 3823:16, 3827:6,

4003:22, 4003:24, 4004:4, 4017:3,

4038:17, 4044:3

conducted [4] - 3902:4, 4044:6,

4089:15, 4090:11

conducts [1] - 4080:21

conferring [1] - 3917:19

confidential [2] - 4010:25, 4075:11

confidentiality [2] - 3929:10, 4076:7

confine [1] - 3815:1

confines [1] - 3951:19

confusing [3] - 3780:2, 3957:23,

4007:19

congratulations [1] - 4055:24

Congress [1] - 3773:22

congressman [1] - 3981:10

connect [2] - 3952:11, 3952:14

connection [2] - 3807:4, 3904:18

connotation [1] - 3970:20

consideration [1] - 3921:8

considered [1] - 3951:24

considers [1] - 3902:5

consistency [1] - 3836:18

consistent [4] - 3800:3, 3818:14,

3842:2, 3954:12

consolidated [7] - 3925:3, 3925:5,

3929:6, 3929:16, 3935:11, 4024:7,

4024:9

consolidation [24] - 3789:12, 3789:17,

3790:5, 3790:8, 3790:10, 3791:5,

3792:18, 3792:22, 3792:25, 3793:7,

3793:9, 3793:14, 3794:22, 3795:24,

3812:1, 3812:23, 3813:3, 3813:5,

3813:7, 3813:24, 3814:5, 3814:19,

3814:22, 3937:22

conspiracy [3] - 3827:18, 3827:20,

4003:18

conspired [3] - 3827:23, 3827:24,

3828:10

conspiring [1] - 3787:4

constantly [2] - 3809:22, 3851:11

construction [1] - 3813:8

contact [10] - 3796:12, 3809:8,

3828:20, 3896:12, 3897:17, 4027:9,

4064:24, 4067:20, 4068:9, 4068:10

contacted [1] - 4080:17

contacts [2] - 3796:10, 3897:13

contained [3] - 3786:9, 3918:19,

4078:24

container [1] - 3919:1

content [1] - 3780:13

contents [7] - 3901:3, 3907:17,

3916:7, 3916:13, 3916:17, 3919:8,

4081:22

context [1] - 3908:3

continue [3] - 3882:1, 3990:21,

4074:13

CONTINUED [1] - 3784:7

Continued [2] - 3774:1, 3774:2

continuing [3] - 3825:6, 4038:15,

4038:22

contrary [1] - 4066:20

control [5] - 3788:9, 3923:12, 4000:7,

4021:9, 4042:11

controlled [6] - 3831:18, 3837:18,

4021:11, 4021:16, 4046:2, 4046:5

controller [1] - 3957:3

conversation [3] - 3862:16, 3928:13,

3939:9

conversion [4] - 3855:23, 3857:3,

3863:11, 4061:25

convert [2] - 3856:7, 3863:20

conviction [1] - 4074:16

convinced [2] - 3910:2, 3910:3

cooperate [4] - 3994:1, 3994:4,

3994:10, 3994:11

cooperated [3] - 3993:10, 3993:13,

3993:14

cooperating [1] - 3917:15

cooperation [1] - 3993:25

coordinated [3] - 3927:8, 3928:3,

4024:5

copied [3] - 3800:11, 3878:19,

4022:16

copies [7] - 3831:11, 3993:8, 3993:9,

4084:16, 4084:17, 4084:18

copy [6] - 3931:24, 4029:5, 4029:8,

4033:23, 4065:23, 4065:25

copying [1] - 3985:6

core [2] - 3907:19, 3912:9

corner [5] - 3789:24, 3856:2, 3872:6,

3979:11, 3979:12

Corporate [1] - 3880:15

corporate [18] - 3884:24, 4026:6,

4026:10, 4026:11, 4026:13, 4026:16,

4026:22, 4027:1, 4027:5, 4027:7,

4057:25, 4058:1, 4059:12, 4059:13,

4061:7, 4084:18, 4085:12, 4087:5

corporation [1] - 4026:17

Corporation [1] - 4053:21

Corporations [1] - 3901:9

correct [236] - 3786:19, 3791:16,

3806:9, 3809:9, 3811:12, 3812:11,

3812:15, 3818:22, 3826:24, 3829:4,

3830:7, 3830:11, 3832:23, 3835:1,

3844:15, 3846:12, 3846:24, 3850:17,

3851:18, 3853:14, 3853:20, 3855:9,

3855:14, 3855:17, 3855:18, 3856:6,

3857:3, 3857:4, 3857:8, 3857:18,

3857:19, 3859:25, 3860:1, 3868:14,

3868:21, 3874:22, 3877:17, 3882:7,

3883:22, 3884:15, 3885:21, 3893:10,

3898:24, 3920:14, 3922:8, 3924:24,

3932:21, 3933:12, 3935:19, 3941:2,

3946:20, 3946:22, 3949:13, 3950:7,

3950:8, 3950:10, 3951:17, 3951:23,

3952:16, 3954:2, 3954:7, 3954:12,

3954:21, 3954:22, 3954:23, 3954:25,

3955:3, 3955:4, 3956:25, 3957:10,

3957:16, 3957:21, 3959:9, 3959:16,

3959:18, 3959:20, 3959:21, 3959:24,

3960:25, 3961:2, 3961:11, 3961:14,

3961:18, 3962:7, 3962:8, 3962:11,

3962:15, 3963:7, 3964:9, 3964:10,

3964:14, 3964:18, 3965:13, 3966:9,

3966:14, 3966:22, 3969:10, 3969:13,

3970:5, 3974:9, 3974:16, 3976:16,

3978:2, 3978:4, 3981:15, 3982:9,

3984:15, 3985:11, 3987:4, 3988:20,

3994:15, 3994:18, 3994:20, 3995:8,

3995:11, 3995:16, 3995:21, 3995:23,

3996:9, 3996:16, 3998:5, 3998:7,

3998:8, 3998:13, 3998:19, 3998:25,

3999:3, 3999:14, 3999:15, 3999:18,

3999:21, 3999:22, 4000:1, 4000:3,

4000:8, 4000:10, 4000:11, 4001:21,

4001:23, 4002:1, 4002:19, 4002:22,

4003:4, 4003:5, 4003:10, 4003:15,

4004:20, 4005:13, 4006:11, 4006:17,

4006:20, 4006:23, 4007:4, 4007:10,

4007:14, 4008:2, 4008:7, 4008:23,

4011:16, 4012:22, 4013:10, 4013:11,

4013:20, 4017:21, 4020:4, 4021:13,

4021:14, 4021:16, 4021:17, 4022:25,

4023:4, 4024:1, 4024:12, 4024:22,

4025:24, 4026:15, 4026:17, 4026:19,

4026:21, 4029:3, 4029:18, 4030:6,


4102

4042:12, 4042:18, 4042:24, 4043:25,

4045:1, 4045:3, 4045:8, 4046:1,

4046:18, 4047:1, 4047:8, 4048:22,

4048:25, 4049:6, 4051:9, 4051:17,

4051:18, 4054:1, 4054:15, 4054:21,

4055:15, 4057:2, 4057:7, 4058:9,

4060:4, 4061:18, 4067:25, 4068:23,

4070:11, 4071:9, 4072:13, 4073:23,

4078:25, 4079:1, 4079:25, 4080:1,

4080:8, 4080:9, 4081:15, 4083:2,

4084:9, 4085:9, 4085:23, 4085:25,

4087:23, 4090:3, 4090:6, 4092:4

corrected [1] - 4091:21

correctly [2] - 3970:3, 3970:13

correspondence [18] - 3872:10,

3920:3, 3920:5, 3995:1, 3996:1,

3996:3, 3997:2, 3997:19, 4002:1,

4014:23, 4015:3, 4028:12, 4030:2,

4030:4, 4031:3, 4031:10, 4035:18,

4080:5

corresponding [3] - 3896:8, 4018:6,

4034:7

corroborate [1] - 3829:19

corroborated [1] - 3977:11

corrupt [1] - 4039:23

Cort [1] - 3869:9

Costa [18] - 3773:13, 3849:18,

3943:11, 3949:20, 3956:8, 3964:17,

3978:21, 3989:17, 4027:23, 4028:6,

4035:24, 4036:15, 4036:16, 4038:25,

4040:21, 4043:8, 4043:17, 4050:7

COSTA [380] - 3824:5, 3824:8,

3824:23, 3825:14, 3826:5, 3826:14,

3832:1, 3832:3, 3835:20, 3835:22,

3835:25, 3836:2, 3836:6, 3836:7,

3837:14, 3837:16, 3838:1, 3838:3,

3838:18, 3838:19, 3839:7, 3839:9,

3840:13, 3840:14, 3841:5, 3841:7,

3842:6, 3842:7, 3842:25, 3843:1,

3843:14, 3843:19, 3843:22, 3843:23,

3844:9, 3844:11, 3844:16, 3844:17,

3845:10, 3845:12, 3845:24, 3846:1,

3846:7, 3846:9, 3849:17, 3849:19,

3849:21, 3851:1, 3851:19, 3851:20,

3852:21, 3852:23, 3853:10, 3853:12,

3853:24, 3853:25, 3854:12, 3854:16,

3854:19, 3854:24, 3854:25, 3856:1,

3856:3, 3856:11, 3856:25, 3857:1,

3857:22, 3858:10, 3858:12, 3859:5,

3859:18, 3859:19, 3860:9, 3860:11,

3860:20, 3860:22, 3861:3, 3861:5,

3862:8, 3862:10, 3863:1, 3863:2,

3864:2, 3864:3, 3864:15, 3864:18,

3864:21, 3864:23, 3865:1, 3865:15,

3865:22, 3866:1, 3866:3, 3866:11,

3866:15, 3866:17, 3866:21, 3867:7,

3867:11, 3867:17, 3867:19, 3868:5,

3868:8, 3869:2, 3869:5, 3869:14,

3869:16, 3870:10, 3870:11, 3870:15,

3870:17, 3870:20, 3870:22, 3871:2,

3871:4, 3871:17, 3871:18, 3871:24,

3871:25, 3872:5, 3872:18, 3872:22,

3872:24, 3873:8, 3873:12, 3873:14,

3874:2, 3874:4, 3874:14, 3874:16,

3875:7, 3875:8, 3876:2, 3876:5,

3876:6, 3876:25, 3877:1, 3877:5,

3877:9, 3877:11, 3878:8, 3878:11,

3878:23, 3878:25, 3879:12, 3879:14,

3879:17, 3879:19, 3880:4, 3880:5,

3880:9, 3880:12, 3881:25, 3882:2,

3882:16, 3882:19, 3883:7, 3883:8,

3884:20, 3884:22, 3885:24, 3886:3,

3886:12, 3887:2, 3887:8, 3887:18,

3887:24, 3888:2, 3890:11, 3890:21,

3890:23, 3891:10, 3891:21, 3891:23,

3891:25, 3892:7, 3892:8, 3893:7,

3893:8, 3893:13, 3893:14, 3893:22,

3895:21, 3895:23, 3895:24, 3896:15,

3896:18, 3898:2, 3898:4, 3898:20,

3898:22, 3898:25, 3899:2, 3900:1,

3900:3, 3900:22, 3900:24, 3901:14,

3901:21, 3902:7, 3902:16, 3902:17,

3903:8, 3903:16, 3904:1, 3904:20,

3904:21, 3905:6, 3905:7, 3906:19,

3907:13, 3907:21, 3908:2, 3908:5,

3908:9, 3908:11, 3908:21, 3909:3,

3909:20, 3909:25, 3910:2, 3911:4,

3911:6, 3912:9, 3912:18, 3912:20,

3913:3, 3913:17, 3913:23, 3914:12,

3914:15, 3915:18, 3915:19, 3916:12,

3916:21, 3918:9, 3918:21, 3918:24,

3919:5, 3919:7, 3919:17, 3920:9,

3920:11, 3920:17, 3922:25, 3924:13,

3924:15, 3925:9, 3925:10, 3925:20,

3925:22, 3926:2, 3926:4, 3928:8,

3928:9, 3929:23, 3929:24, 3930:4,

3930:6, 3930:8, 3930:10, 3930:16,

3930:18, 3931:14, 3931:16, 3932:22,

3932:23, 3933:13, 3933:15, 3934:13,

3934:15, 3935:16, 3935:20, 3935:24,

3936:2, 3936:3, 3936:14, 3938:7,

3938:9, 3939:1, 3939:2, 3939:17,

3939:18, 3939:23, 3939:24, 3940:4,

3940:5, 3940:14, 3940:18, 3942:14,

3942:18, 3942:21, 3943:1, 3943:3,

3943:13, 3943:15, 3943:17, 3943:19,

3943:25, 3944:8, 3944:10, 3944:17,

3944:19, 3945:12, 3945:20, 3945:21,

3946:1, 3946:3, 3946:6, 3946:13,

3946:15, 3946:24, 3946:25, 3947:4,

3947:6, 3947:11, 3947:13, 3948:1,

3948:3, 3949:2, 3969:21, 3976:13,

3977:24, 3980:6, 3980:10, 3981:24,

3986:9, 3986:12, 3986:16, 3987:10,

3990:19, 3993:18, 4001:1, 4005:14,

4005:18, 4005:21, 4011:24, 4015:14,

4015:16, 4018:2, 4018:16, 4018:18,

4018:23, 4019:22, 4022:11, 4022:13,

4025:8, 4025:13, 4026:25, 4030:9,

4030:13, 4030:16, 4030:19, 4032:8,

4033:23, 4037:2, 4037:5, 4037:14,

4037:17, 4038:5, 4038:9, 4038:21,

4039:3, 4039:7, 4039:15, 4039:19,

4039:24, 4040:1, 4040:7, 4041:11,

4044:14, 4048:9, 4049:18, 4050:6,

4050:12, 4050:17, 4051:10, 4051:12,

4052:9, 4091:8

Costa's [1] - 4036:25

COSTA............. [3] - 3775:25, 3776:4,

3776:8

COSTA............... [1] - 3775:21

council [1] - 4056:19

Counsel [1] - 3779:16

counsel [15] - 3920:8, 3920:13,

3922:24, 3926:21, 3984:22, 3985:11,

3985:12, 4008:22, 4008:25, 4009:10,

4009:22, 4009:23, 4016:11, 4040:4,

4047:10

count [2] - 3787:4, 3903:18

countries [4] - 3921:21, 3922:3,

3922:5, 3922:6

country [11] - 3833:11, 3833:13,

3847:13, 3920:24, 3981:7, 4042:12,

4047:12, 4047:13, 4061:11, 4061:17,

4085:12

counts [1] - 3787:3

couple [14] - 3841:24, 3845:16,

3875:2, 3900:6, 3911:15, 3912:2,

3942:18, 3948:20, 3958:12, 3997:23,

3998:3, 4016:19, 4016:24, 4040:14

course [9] - 3804:12, 3875:10, 3908:2,

4056:20, 4075:18, 4082:2, 4084:12,

4084:23, 4085:12

court [6] - 3830:10, 3830:12, 3941:25,

4011:25, 4074:2, 4075:20

COURT [307] - 3773:1, 3777:2,

3777:24, 3778:3, 3778:12, 3778:14,

3778:21, 3778:23, 3779:10, 3779:13,

3779:15, 3779:19, 3780:4, 3780:6,

3780:11, 3780:14, 3780:17, 3781:1,

3782:9, 3782:11, 3782:19, 3782:21,

3783:1, 3783:3, 3783:13, 3783:17,

3783:19, 3783:22, 3783:24, 3784:2,

3784:19, 3788:12, 3788:19, 3788:22,

3789:4, 3795:15, 3796:4, 3798:16,

3801:11, 3801:13, 3801:18, 3802:12,

3805:7, 3806:16, 3806:20, 3807:3,

3808:3, 3808:13, 3810:5, 3810:12,

3810:14, 3811:11, 3811:14, 3815:1,

3816:4, 3816:22, 3817:5, 3818:1,

3818:4, 3818:25, 3819:22, 3820:11,

3821:5, 3821:21, 3822:19, 3823:11,

3823:14, 3823:20, 3823:22, 3824:2,

3824:13, 3824:18, 3825:6, 3825:11,

3825:22, 3826:10, 3826:12, 3835:24,

3843:16, 3843:20, 3850:21, 3850:23,

3850:25, 3854:14, 3854:18, 3857:23,

3858:5, 3858:11, 3858:25, 3864:17,

3864:20, 3864:22, 3864:25, 3865:2,

3865:7, 3865:10, 3865:12, 3865:18,

3865:23, 3866:14, 3866:19, 3872:7,

3872:11, 3872:14, 3873:6, 3875:25,

3886:23, 3886:25, 3887:4, 3887:6,

3887:14, 3887:16, 3887:20, 3888:1,

3890:1, 3890:7, 3890:10, 3893:12,

3893:19, 3893:21, 3895:20, 3895:22,

3898:21, 3898:24, 3899:1, 3903:24,

3906:1, 3906:3, 3906:7, 3906:10,


4103

3907:12, 3907:20, 3907:23, 3908:4,

3908:8, 3908:19, 3908:24, 3909:5,

3909:11, 3909:23, 3910:1, 3910:6,

3910:12, 3910:15, 3910:19, 3910:21,

3911:5, 3911:7, 3911:11, 3911:19,

3911:23, 3912:5, 3912:14, 3912:19,

3912:21, 3912:23, 3913:5, 3913:8,

3913:16, 3913:21, 3914:5, 3914:8,

3914:14, 3914:16, 3914:25, 3915:4,

3916:11, 3916:14, 3917:22, 3917:24,

3918:6, 3918:23, 3919:3, 3919:6,

3919:13, 3920:15, 3922:21, 3935:18,

3935:22, 3936:1, 3936:12, 3942:12,

3942:15, 3942:20, 3943:23, 3945:10,

3946:2, 3946:5, 3949:6, 3953:10,

3953:12, 3953:18, 3958:16, 3958:22,

3967:25, 3969:23, 3975:17, 3975:20,

3975:23, 3975:25, 3976:3, 3976:5,

3976:8, 3976:14, 3978:1, 3978:6,

3978:17, 3980:7, 3980:13, 3980:20,

3981:25, 3982:2, 3986:11, 3987:7,

3987:9, 3990:23, 3991:1, 3993:20,

3997:3, 3997:12, 3998:1, 4000:24,

4001:3, 4005:23, 4012:6, 4012:8,

4013:16, 4015:15, 4015:18, 4018:14,

4018:21, 4019:20, 4025:12, 4030:11,

4030:15, 4030:17, 4031:21, 4037:4,

4037:7, 4037:16, 4037:18, 4038:6,

4038:8, 4038:20, 4039:1, 4039:10,

4040:5, 4040:8, 4041:13, 4042:6,

4042:8, 4049:19, 4050:11, 4051:15,

4052:10, 4052:22, 4052:24, 4053:19,

4054:13, 4055:10, 4055:12, 4055:16,

4058:8, 4058:11, 4058:14, 4058:17,

4059:1, 4059:4, 4061:10, 4061:14,

4061:16, 4061:19, 4061:21, 4070:12,

4070:16, 4070:20, 4071:4, 4071:24,

4072:4, 4072:7, 4072:22, 4072:24,

4073:5, 4073:9, 4073:11, 4073:18,

4075:14, 4075:22, 4077:18, 4078:2,

4078:9, 4078:15, 4078:19, 4079:5,

4079:10, 4079:12, 4079:16, 4079:19,

4088:3, 4091:9, 4091:16, 4091:18,

4092:1

Court [12] - 3774:11, 3777:16,

3778:16, 3825:4, 3825:7, 3825:18,

3829:8, 3865:5, 3917:14, 3942:2,

3994:3, 4052:19

Court's [1] - 3918:3

courtroom [1] - 4070:24

courts [1] - 4048:24

cover [3] - 3902:18, 3921:13, 3921:25

covered [1] - 3924:2

covers [1] - 3922:10

coversheet [2] - 3920:18, 3921:2

coward [1] - 3784:11

CPA [7] - 3895:17, 3989:23, 3990:1,

3990:5, 3990:18, 4007:18, 4007:24

create [1] - 3835:11

created [1] - 3967:17

creating [3] - 3924:25, 3982:25,

4041:9

credibility [2] - 4036:18, 4037:10

Credit [1] - 4059:13

credit [11] - 3787:21, 3884:8, 3895:6,

3964:3, 3969:13, 3989:9, 3989:25,

3990:18, 4034:25, 4054:12, 4060:17

Crick [2] - 4060:6

cricket [3] - 4067:16, 4067:17, 4067:18

crime [10] - 3969:19, 3982:24, 4005:1,

4005:3, 4005:6, 4005:10, 4006:25,

4009:2, 4037:25, 4038:2

crimes [1] - 4040:18

Criminal [1] - 3982:9

criminal [25] - 3826:17, 3826:22,

3827:1, 3827:7, 3827:8, 3827:11,

3827:13, 3828:15, 3828:20, 3829:6,

3837:6, 3907:14, 3917:12, 4003:14,

4003:22, 4003:24, 4004:4, 4007:16,

4007:23, 4008:9, 4008:11, 4010:10,

4036:9, 4036:21, 4038:15

criticizing [2] - 4071:8, 4071:14

Croix [1] - 3787:20

CROSS [2] - 3775:23, 3949:8

cross [15] - 3780:9, 3781:19, 3782:14,

3784:9, 3785:9, 3797:21, 3798:17,

3800:19, 3814:3, 3824:17, 3891:16,

3909:7, 3909:18, 3912:22, 4039:12

CROSS-EXAMINATION [2] - 3775:23,

3949:8

cross-examination [6] - 3784:9,

3785:9, 3797:21, 3800:19, 3814:3,

3909:18

cross-examine [3] - 3780:9, 3824:17,

4039:12

cross-examined [2] - 3781:19,

3782:14

CRR [2] - 3774:11, 4092:7

CRT [1] - 3959:12

crux [1] - 4002:9

CTR [3] - 3959:6, 3967:6, 3967:17

cumbersome [1] - 3971:16

currencies [1] - 3967:8

currency [7] - 3845:22, 3850:12,

3921:19, 3921:23, 3925:2, 3957:3,

3959:7

current [4] - 3794:2, 4060:5, 4060:6,

4069:18

cut [1] - 4020:15

D

D/B/A [1] - 4055:2

daily [4] - 3791:25, 3792:14, 3801:6,

3889:17

Dallas [3] - 3917:15, 3941:25, 3994:3

data [2] - 3809:8, 3810:8

database [1] - 3924:25

date [32] - 3791:10, 3841:21, 3844:19,

3850:9, 3855:5, 3861:8, 3863:8,

3866:7, 3866:23, 3867:12, 3869:6,

3869:22, 3871:5, 3877:6, 3886:4,

3894:8, 3900:4, 3902:5, 3904:2,

3914:23, 3927:19, 3927:21, 3930:2,

3942:12, 3942:16, 3945:5, 3946:16,

3947:14, 3948:7, 4033:25, 4070:12,

4070:13

dated [8] - 3876:21, 3924:17, 3927:17,

3934:10, 3936:9, 3940:21, 4079:22,

4081:13

dates [2] - 3892:10, 3920:1

DAVID [1] - 3773:10

DAVIS [2] - 3775:3, 3784:6

davis [1] - 4011:1

Davis [63] - 3777:7, 3777:10, 3777:19,

3778:19, 3782:7, 3784:9, 3796:21,

3800:10, 3801:20, 3804:17, 3807:9,

3808:6, 3808:18, 3809:18, 3813:10,

3815:6, 3816:6, 3819:14, 3823:2,

3823:25, 3824:2, 3829:16, 3829:20,

3858:19, 3858:20, 3859:2, 3897:22,

3907:15, 3907:16, 3907:22, 3908:21,

3909:3, 3912:10, 3912:11, 3912:15,

3913:4, 3913:23, 3973:3, 3973:5,

3973:8, 3973:9, 3973:11, 3973:14,

3973:16, 3973:25, 3974:2, 3974:19,

3977:9, 3977:10, 3977:13, 3977:17,

3977:20, 3986:25, 3987:2, 3987:3,

3995:25, 3996:15, 3996:17, 3996:18,

3996:20, 3996:21, 3996:22

Davis's [1] - 3912:18

days [8] - 3805:22, 3820:8, 3880:23,

3940:24, 3972:7, 3972:17, 4047:9,

4090:24

DC [1] - 3773:18

dead [1] - 4063:7

deal [4] - 3782:23, 3824:24, 3827:2,

3884:9

dealing [5] - 3850:11, 3915:15,

3951:9, 3961:2, 3961:10

deals [2] - 3921:6, 3971:18

dealt [2] - 3954:6, 4064:14

Dear [1] - 4080:16

Debbie [1] - 3875:7

debit [5] - 3840:20, 3841:19, 3860:14,

3873:18, 3964:2

debited [3] - 3860:25, 3861:11,

3862:15

debits [1] - 3874:19

debt [1] - 3791:17

December [2] - 3791:15, 4073:20

decided [1] - 3907:15

decision [3] - 3813:9, 3815:11,

4021:12

decision-making [1] - 3813:9

decisions [2] - 4084:20, 4087:17

def [1] - 3991:25

defendant [1] - 4071:2

DEFENDANT [2] - 3773:20, 3774:2

defendants [1] - 4041:16

defense [11] - 3779:5, 3779:7, 3781:4,

3782:15, 3798:15, 3807:22, 3810:21,

3810:24, 3914:18, 4079:5, 4091:20

Defense [6] - 3779:8, 3781:14,

3781:23, 3789:15, 3811:7, 3813:1

definitely [3] - 3862:5, 3968:20,

4034:13

definition [2] - 3925:11, 4042:8Johnny C. Sanchez, RMR, CRR - [email protected]

4104

degree [8] - 3950:13, 3950:14,

4024:21, 4054:24, 4055:4, 4055:5,

4055:8, 4061:6

delineating [1] - 3977:5

deliver [1] - 3881:10

demonstrate [4] - 4017:18, 4056:16,

4056:17, 4057:13

demonstrative [1] - 3974:15

denied [3] - 3778:14, 3783:5, 3783:6

denominations [3] - 3852:1, 3861:25,

3867:6

department [9] - 3811:23, 3811:25,

3814:4, 4060:11, 4064:13, 4064:15,

4071:18, 4088:20, 4089:4

Department [2] - 3773:17, 4049:8

deposit [34] - 3805:24, 3835:7,

3840:17, 3840:22, 3840:23, 3841:15,

3842:10, 3842:19, 3842:24, 3843:3,

3844:19, 3845:1, 3845:3, 3845:18,

3848:25, 3849:4, 3851:2, 3852:24,

3853:3, 3853:5, 3854:1, 3855:15,

3864:10, 3866:22, 3867:2, 3867:20,

3868:2, 3869:17, 3961:17, 3963:6,

3964:2, 3964:5, 3967:14

deposited [24] - 3830:18, 3835:18,

3840:3, 3840:16, 3841:3, 3842:16,

3843:10, 3845:8, 3846:3, 3846:16,

3848:19, 3848:22, 3850:6, 3852:1,

3852:9, 3855:17, 3856:4, 3856:19,

3857:6, 3858:15, 3867:22, 3868:9,

3968:4, 3996:24

depositing [3] - 3854:5, 3967:7,

3974:10

depositor [1] - 3901:7

Depositor [1] - 4081:10

depositors [10] - 3786:13, 3794:9,

3795:25, 3798:23, 3799:17, 3800:3,

3815:10, 3818:15, 3819:7, 3822:2

deposits [46] - 3792:1, 3815:22,

3831:15, 3831:18, 3843:25, 3844:12,

3845:13, 3849:7, 3849:12, 3849:15,

3850:9, 3854:20, 3855:1, 3856:13,

3857:10, 3864:6, 3866:23, 3868:22,

3874:12, 3874:21, 3941:20, 3956:13,

3956:17, 3957:10, 3957:15, 3961:14,

3961:22, 3961:24, 3962:10, 3962:11,

3962:13, 3962:19, 3966:22, 3966:24,

3967:3, 3967:6, 3967:22, 3968:6,

3968:7, 3968:10, 3969:12, 3970:19,

3972:4, 3995:16, 3995:20

depth [1] - 3981:22

deputy [5] - 4062:22, 4063:2, 4063:13,

4064:23, 4065:1

derogatory [1] - 4078:6

describe [5] - 3826:20, 4063:1,

4073:2, 4074:25, 4083:13

described [6] - 3793:19, 3823:17,

3848:24, 4064:2, 4064:18, 4087:8

describes [1] - 3919:8

designated [2] - 3777:14, 3778:25

designating [1] - 3904:10

desire [1] - 4080:19

desktops [1] - 4014:22

desperate [1] - 4068:15

destroy [1] - 3785:21

destroyed [3] - 3785:18, 3786:13,

3787:12

destroying [2] - 3786:22, 3840:11

destruction [1] - 3785:10

detail [6] - 3879:7, 4027:23, 4069:8,

4069:11, 4074:24, 4083:20

detailed [3] - 3912:10, 4083:21,

4086:7

details [2] - 3916:23, 4083:21

detect [1] - 4033:15

determine [5] - 3825:7, 3963:21,

4085:4, 4085:5, 4085:14

Detroit [4] - 3889:7, 3889:10, 3894:17,

3894:19

develop [2] - 3982:21, 3982:23

device [2] - 3918:22, 3919:1

devil [1] - 3784:14

dialogue [1] - 3899:24

difference [7] - 3781:6, 3781:13,

3826:25, 3828:14, 3908:15, 3909:1,

4086:3

different [30] - 3780:2, 3792:15,

3813:11, 3816:13, 3844:7, 3867:4,

3885:19, 3892:24, 3899:23, 3908:23,

3913:10, 3914:11, 3915:11, 3915:21,

3922:5, 3922:6, 3957:7, 3974:9,

3974:12, 3974:15, 3974:16, 3975:22,

3995:21, 4023:19, 4029:8, 4035:11,

4039:6, 4039:9, 4051:2, 4084:4

differently [1] - 3915:10

difficult [1] - 3841:12

diligence [1] - 4084:24

diplomatic [4] - 3847:18, 3931:5,

4042:13, 4050:22

diplomats [2] - 3971:19, 3971:20

dire [2] - 3909:8, 3909:16

DIRECT [4] - 3775:21, 3776:14,

3826:4, 4053:4

direct [8] - 3785:14, 3835:7, 3870:6,

3886:16, 3896:19, 3907:2, 4002:9,

4060:17

directed [1] - 3904:23

directing [2] - 3878:20, 3904:9

direction [3] - 3808:23, 3809:5,

3914:11

directly [2] - 3886:18, 3923:22

director [1] - 4059:14

directors [3] - 4013:6, 4059:12,

4064:17

directory [10] - 3988:24, 3988:25,

3989:4, 3989:5, 4026:6, 4026:11,

4026:14, 4026:16, 4026:22, 4027:1

disaster [1] - 4063:3

disbursement [1] - 3947:15

disclose [4] - 3785:18, 3819:17,

3819:18, 3822:12

disclosed [9] - 3799:15, 3806:6,

3807:2, 3807:9, 3807:10, 3819:4,

3820:15, 3822:2, 4086:13

disclosure [3] - 3815:9, 3815:12,

3819:20

discover [1] - 3905:21

discovery [1] - 3779:5

discuss [12] - 3815:14, 3878:5,

3911:12, 3911:13, 3911:20, 4034:17,

4061:3, 4062:1, 4062:5, 4062:10,

4067:21, 4081:22

discussed [4] - 3793:25, 3810:17,

4062:7, 4071:10

discussing [8] - 3926:25, 4006:10,

4007:13, 4007:17, 4007:23, 4009:11,

4009:18, 4073:3

discussion [4] - 3790:3, 4062:8,

4064:22, 4073:7

dishonest [1] - 4018:25

display [1] - 3898:20

disregard [12] - 3778:16, 3778:18,

3778:23, 3784:3, 3912:7, 3912:14,

3912:23, 3913:3, 3914:10, 3915:8,

3915:11, 3915:13

distinct [1] - 3926:17

distribution [1] - 3885:4

DISTRICT [3] - 3773:1, 3773:1,

3773:10

divide [2] - 3851:7, 3851:17

division [4] - 3827:3, 3982:11,

3982:12, 3982:14

DIVISION [1] - 3773:2

Division [1] - 3982:10

divulge [1] - 3916:13

divvied [2] - 3803:9, 3803:10

doc [1] - 4074:8

doctorate [2] - 4054:24, 4061:6

Doctorate [2] - 4055:2, 4055:18

document [56] - 3779:4, 3779:6,

3779:8, 3780:1, 3780:23, 3780:24,

3781:5, 3781:19, 3781:22, 3782:15,

3782:24, 3784:21, 3786:6, 3790:24,

3799:22, 3800:7, 3803:18, 3812:9,

3834:9, 3838:4, 3838:20, 3840:10,

3841:17, 3841:18, 3860:12, 3871:17,

3872:23, 3893:25, 3899:21, 3904:2,

3918:13, 3919:12, 3920:15, 3921:1,

3944:11, 3945:22, 3946:14, 3947:12,

3988:12, 3988:19, 3993:16, 3994:14,

3994:25, 4001:14, 4011:20, 4011:22,

4032:8, 4072:10, 4072:11, 4073:3,

4073:15, 4074:6, 4074:23, 4075:3,

4079:13, 4081:12

documentation [3] - 3971:6, 3971:9,

4085:8

documentations [1] - 4013:20

documents [43] - 3786:3, 3787:12,

3787:24, 3789:16, 3820:24, 3831:8,

3842:3, 3870:19, 3872:19, 3885:19,

3886:11, 3898:13, 3905:22, 3917:4,

3918:25, 3919:20, 3919:22, 3921:6,

3922:18, 3922:19, 3923:2, 3933:6,

3943:9, 3944:5, 3992:12, 3992:21,

4012:11, 4015:2, 4017:7, 4017:8,

4017:10, 4020:17, 4040:22, 4042:24,

4045:25, 4046:9, 4048:13, 4074:3,


4105

4085:2

DOJ's [1] - 4039:16

dollar [7] - 3850:14, 3850:19, 3850:23,

3852:7, 3854:4, 3862:3

dollars [48] - 3792:17, 3795:23,

3800:15, 3801:8, 3801:9, 3815:10,

3815:16, 3817:10, 3850:13, 3850:19,

3850:20, 3851:5, 3851:17, 3853:17,

3853:22, 3855:21, 3855:24, 3856:4,

3857:12, 3858:15, 3860:15, 3861:2,

3863:10, 3863:12, 3863:17, 3863:19,

3863:20, 3863:22, 3866:10, 3867:3,

3867:16, 3867:24, 3868:11, 3868:24,

3869:11, 3869:21, 3873:6, 3921:22,

3922:7, 3945:9, 3945:11, 3947:24,

3948:21, 3948:24, 3958:12, 3991:18,

4020:21, 4021:1

domestic [6] - 3921:20, 3922:11,

3922:15, 3955:4, 3961:25, 3962:7

domination [1] - 3853:2

donation [2] - 3980:23, 3981:5

done [16] - 3778:5, 3787:8, 3844:12,

3909:13, 3933:1, 3948:10, 3960:4,

3963:24, 4007:6, 4042:11, 4046:20,

4050:22, 4051:8, 4082:10, 4084:22,

4086:6

Donna [1] - 3869:9

door [4] - 3937:6, 3937:21, 3941:9,

4013:19

doors [1] - 4011:15

down [64] - 3778:4, 3781:2, 3783:8,

3786:25, 3794:11, 3808:25, 3809:4,

3810:23, 3811:17, 3812:5, 3812:6,

3812:12, 3813:2, 3813:5, 3821:23,

3822:21, 3823:23, 3842:11, 3844:9,

3845:10, 3846:4, 3849:4, 3851:25,

3855:19, 3856:1, 3856:17, 3861:25,

3863:16, 3864:2, 3865:13, 3871:17,

3871:24, 3874:14, 3882:18, 3883:6,

3893:13, 3896:24, 3899:17, 3909:17,

3923:15, 3925:9, 3926:2, 3930:12,

3946:1, 3946:13, 3953:12, 3965:4,

3984:9, 3985:1, 3985:2, 3986:11,

4010:19, 4033:19, 4033:20, 4038:9,

4038:12, 4050:23, 4052:11, 4072:7,

4072:8, 4080:6, 4091:14, 4091:22

draft [14] - 3790:3, 3926:12, 3928:14,

3928:18, 3930:12, 3932:16, 4029:5,

4029:12, 4029:14, 4074:25, 4075:2,

4082:1, 4082:9

drafted [6] - 3928:23, 3929:14,

4081:16, 4081:17, 4082:9, 4083:8

drafting [1] - 4010:5

drafts [2] - 3929:20, 3936:22

drain [1] - 4030:21

drama [1] - 3794:8

draw [1] - 4012:5

drawer [1] - 3963:16

drawing [1] - 3790:10

drawn [1] - 3813:17

driven [1] - 3935:9

drives [2] - 3785:11, 3786:10

dual [6] - 4023:14, 4024:24, 4025:15,

4025:23, 4062:14, 4062:16

due [2] - 4038:25, 4084:24

duly [2] - 3826:2, 4053:2

during [23] - 3784:9, 3785:14,

3807:14, 3834:24, 3857:13, 3858:16,

3896:5, 3901:19, 3902:13, 3916:11,

3923:6, 3941:19, 4061:25, 4063:11,

4065:3, 4076:22, 4077:5, 4077:8,

4077:9, 4082:2, 4084:12, 4087:18,

4090:11

duties [1] - 3829:25

duty [2] - 3959:14, 4056:11

dysfunctional [2] - 4063:23, 4064:21

E

E-Mail [1] - 3891:12

e-mail [72] - 3800:7, 3876:9, 3876:11,

3876:12, 3876:14, 3876:21, 3877:2,

3877:6, 3877:12, 3878:9, 3878:18,

3878:23, 3879:1, 3879:10, 3879:18,

3879:25, 3880:10, 3880:13, 3882:17,

3884:2, 3884:6, 3884:23, 3885:2,

3885:25, 3888:4, 3888:14, 3888:25,

3890:16, 3890:22, 3890:25, 3891:7,

3891:24, 3892:1, 3897:5, 3926:24,

3933:9, 3933:16, 3934:7, 3935:2,

3936:5, 3936:6, 3936:7, 3938:10,

3939:20, 3940:6, 3940:7, 3985:8,

3985:13, 3985:22, 3985:23, 3986:10,

3986:17, 3987:10, 3987:25, 3988:2,

4001:14, 4002:18, 4006:2, 4008:3,

4022:15, 4022:24, 4023:2, 4025:3,

4031:24, 4032:25, 4033:7, 4033:11,

4033:15, 4033:21, 4034:8, 4034:11,

4034:14

e-mails [18] - 3876:18, 3879:25,

3880:6, 3880:23, 3884:18, 3893:9,

3894:18, 3927:11, 3927:17, 3933:10,

3934:25, 3983:23, 3986:20, 3988:5,

4008:8, 4022:10, 4023:22, 4024:3

E-R [1] - 4065:21

earliest [3] - 3880:11, 3886:1, 3919:22

early [8] - 3778:5, 3784:22, 3787:24,

3800:20, 3869:17, 3881:3, 3948:11,

4046:23

earn [2] - 3833:9, 3833:11

earned [5] - 3833:12, 3833:24, 3834:1,

3834:9, 3834:17

easel [1] - 3865:19

easier [2] - 3976:11, 4021:19

easily [1] - 3914:2

East [2] - 3850:14, 3850:18

Eastern [44] - 3850:13, 3850:20,

3851:4, 3851:7, 3852:7, 3854:4,

3855:21, 3856:4, 3860:15, 3861:2,

3862:2, 3863:10, 3863:17, 3863:18,

3863:19, 3866:10, 3867:3, 3867:16,

3867:24, 3868:11, 3868:24, 3869:11,

3869:21, 3921:16, 3921:17, 3921:22,

3921:25, 3922:3, 3922:6, 3922:9,

3923:5, 3924:3, 3924:16, 3924:19,

3925:1, 3926:25, 3927:7, 3928:2,

3929:15, 3932:19, 3936:18, 3938:5,

4000:6, 4020:20

easy [4] - 4058:4, 4058:6, 4058:7

EC [7] - 3853:9, 3853:10, 3853:11,

3853:13, 3853:21, 3862:17, 3873:1

ECC [1] - 3999:16

ECCB [43] - 3921:7, 3921:8, 3921:14,

3921:15, 3921:24, 3923:11, 3923:15,

3928:19, 3934:19, 3934:21, 3935:6,

3937:9, 3937:12, 3937:20, 3937:25,

3938:2, 3938:17, 3939:14, 3941:8,

3941:12, 3997:20, 4000:3, 4002:1,

4006:4, 4006:10, 4008:5, 4012:22,

4023:21, 4024:4, 4024:15, 4024:17,

4028:7, 4028:10, 4029:7, 4029:9,

4029:15, 4029:17, 4029:23, 4030:6,

4030:22, 4031:1, 4031:13, 4043:10

ECCB's [4] - 3937:6, 3939:7, 3939:8,

4002:11

edits [1] - 3931:9

educational [2] - 3950:10, 4054:22

EECB [1] - 3936:25

effect [3] - 3978:6, 4043:19, 4043:20

effort [1] - 4088:21

efforts [1] - 4089:4

eight [2] - 3922:4, 3972:10

Eileen [2] - 4067:23, 4067:24

either [7] - 3837:18, 4015:8, 4024:7,

4027:12, 4035:11, 4039:20, 4063:7

elected [1] - 4056:20

electronic [1] - 4015:4

eleven [1] - 3953:2

elicit [1] - 3908:14

elicited [2] - 3906:5, 3906:24

eliciting [1] - 3908:15

elimination [1] - 3953:18

Elizabeth [2] - 3899:9, 3899:10

Ellen [1] - 3803:14

ELMO [4] - 3832:2, 3918:22, 4022:12,

4025:9

embellishment [1] - 3921:8

employed [5] - 4043:22, 4053:16,

4053:17, 4076:24, 4089:22

employee [8] - 3876:24, 3897:2,

3897:4, 4067:12, 4067:15, 4067:19,

4067:23, 4076:7

employee's [1] - 4067:22

employees [11] - 3828:16, 3885:4,

3887:9, 3948:15, 3984:2, 3984:3,

3984:4, 4026:16, 4034:13, 4083:25,

4084:1

employer [1] - 3834:6

employment [1] - 4088:18

employs [1] - 4047:15

end [22] - 3795:21, 3800:20, 3807:18,

3807:22, 3817:8, 3884:12, 3894:12,

3931:11, 3935:25, 3963:15, 4018:3,

4045:11, 4062:20, 4064:15, 4064:24,

4065:11, 4066:24, 4067:10, 4068:1,

4068:24, 4082:21, 4089:12

ended [4] - 3884:14, 3890:3, 3905:18,

4083:1Johnny C. Sanchez, RMR, CRR - [email protected]

4106

ends [2] - 3855:12, 3855:13

enforce [1] - 4003:7

enforced [1] - 4049:3

enforcement [5] - 3917:11, 3917:16,

3951:10, 3994:2, 3998:19

engage [2] - 4003:21, 4003:24

engaged [1] - 4005:6

engaging [2] - 4005:3, 4007:12

enhancement [1] - 3940:15

ensure [5] - 3901:8, 4059:19, 4084:23,

4085:10, 4086:23

ensuring [1] - 4058:1

entail [1] - 4057:23

entire [6] - 3800:3, 3841:17, 3995:4,

4047:6, 4080:25, 4081:1

entities [6] - 3937:24, 3944:15,

3960:23, 3992:3, 4023:19, 4060:10

entitled [1] - 4092:5

entity [4] - 3999:16, 4010:5, 4024:20,

4051:2

entries [2] - 3809:23, 3809:24

entry [3] - 3796:24, 4088:16, 4088:17

envelope [1] - 4066:2

equipment [1] - 3994:17

equivalent [1] - 3863:23

erroneously [1] - 3795:8

essentially [1] - 4081:2

establish [1] - 3820:24

established [5] - 3808:18, 3808:24,

3809:2, 3886:16, 4073:15

estate [3] - 3794:16, 3818:18, 3818:20

et [1] - 3937:7

ethical [1] - 4019:16

evasion [1] - 3827:9

evening [1] - 3882:12

event [2] - 3894:7, 3894:8

events [1] - 4067:7

eventually [2] - 4066:25, 4068:2

Evidence [1] - 3781:10

evidence [22] - 3777:18, 3778:10,

3779:24, 3781:9, 3783:6, 3786:22,

3787:12, 3797:25, 3802:6, 3802:9,

3824:15, 3886:8, 3887:13, 3985:19,

3986:14, 3986:20, 4024:17, 4029:13,

4035:5, 4072:19

exact [2] - 3989:4, 3989:5

exactly [9] - 3780:5, 3882:13, 3958:7,

4005:12, 4005:14, 4006:9, 4008:1,

4008:5

exam [4] - 4056:14, 4090:21, 4091:6

EXAMINATION [32] - 3775:5, 3775:7,

3775:9, 3775:11, 3775:13, 3775:15,

3775:17, 3775:21, 3775:23, 3775:25,

3776:2, 3776:4, 3776:6, 3776:8,

3776:10, 3776:14, 3784:7, 3804:15,

3815:4, 3819:12, 3821:7, 3822:6,

3822:25, 3826:4, 3949:8, 4018:1,

4027:3, 4044:13, 4048:10, 4050:5,

4050:18, 4053:4

examination [25] - 3784:9, 3785:9,

3785:15, 3797:21, 3800:19, 3814:3,

3816:7, 3901:12, 3901:19, 3909:18,

4002:10, 4058:3, 4080:21, 4081:3,

4083:17, 4083:18, 4083:19, 4084:13,

4085:7, 4090:7, 4090:8, 4090:11,

4090:18, 4091:1

examinations [7] - 4044:3, 4044:7,

4084:7, 4084:10, 4084:11, 4085:24,

4089:8

examine [7] - 3779:1, 3780:9, 3781:11,

3824:17, 4039:12, 4058:2, 4087:12

examine-based [1] - 4058:2

examined [8] - 3781:19, 3782:14,

3901:7, 4082:2, 4082:6, 4082:12,

4089:18

examiner [2] - 4081:9, 4089:17

examining [2] - 4044:10, 4060:9

example [3] - 3845:16, 3860:23,

3869:2

exams [1] - 4089:15

Excellency [1] - 3885:9

except [1] - 3813:12

exception [1] - 3886:19

excess [2] - 3792:17, 3958:6

Exchange [4] - 3900:16, 3902:20,

3904:4, 3905:12

exchange [4] - 3850:18, 3851:9,

3851:15, 3986:5

exclude [1] - 3780:24

excluded [3] - 3780:23, 3781:1,

3833:14

excludes [1] - 3877:15

excuse [6] - 3806:16, 3815:25, 3919:3,

3958:14, 3962:14, 3972:25

excused [5] - 3823:23, 3824:11,

3825:2, 3825:12, 4052:11

executive [4] - 3872:16, 3888:24,

3890:24

exempt [1] - 3833:18

exercise [1] - 3871:14

exhibit [47] - 3777:8, 3777:11,

3777:14, 3777:17, 3777:19, 3778:9,

3778:17, 3779:7, 3779:11, 3779:12,

3779:20, 3780:15, 3781:4, 3781:7,

3781:23, 3782:15, 3782:16, 3783:9,

3783:12, 3786:24, 3792:3, 3802:14,

3810:22, 3810:24, 3811:5, 3814:11,

3818:1, 3835:24, 3851:19, 3852:22,

3860:10, 3868:6, 3873:13, 3874:3,

3886:23, 3890:22, 3891:23, 3895:20,

3935:16, 3943:15, 3988:17, 4001:6,

4010:17, 4078:25, 4079:4, 4081:12

Exhibit [40] - 3778:17, 3779:7, 3779:8,

3781:15, 3783:5, 3783:6, 3784:3,

3785:24, 3789:15, 3790:23, 3792:2,

3796:19, 3796:22, 3798:20, 3799:7,

3799:20, 3801:24, 3802:3, 3802:19,

3803:17, 3810:17, 3818:2, 3961:21,

3978:15, 3978:22, 3984:7, 3986:3,

3988:15, 3988:16, 3989:11, 4000:16,

4000:19, 4000:21, 4001:6, 4008:15,

4010:16, 4022:14, 4031:18, 4071:21,

4078:12

exhibits [7] - 3777:15, 3779:2,

3779:22, 3802:9, 3814:2, 3887:25,

3943:17

exist [3] - 3793:5, 3793:7, 3954:9

existed [2] - 3819:2, 4045:6

existence [1] - 3903:21

existing [1] - 3935:8

expansive [1] - 4086:7

expected [1] - 3939:5

expense [1] - 4035:12

expenses [2] - 3871:13, 3872:3

expensive [1] - 3883:16

experience [7] - 3953:21, 3991:3,

4020:10, 4020:16, 4057:18, 4057:19,

4065:9

explain [11] - 3777:20, 3778:8,

3826:25, 3831:15, 3831:21, 3836:8,

3838:14, 3851:10, 3863:6, 3958:18,

4080:23

explained [3] - 3907:15, 4008:4,

4023:24

explanation [3] - 3958:19, 3975:20,

4018:8

exploits [1] - 4063:19

exploring [1] - 4061:8

Express [5] - 3895:6, 3895:9, 3989:8,

3990:3, 4007:9

expressed [2] - 3927:25, 4080:19

expression [4] - 3793:21, 3793:23,

3796:16, 3803:12

external [6] - 4086:6, 4086:15,

4086:16, 4087:14, 4087:15, 4088:11

extra [2] - 3834:15, 3976:2

extraordinary [1] - 4089:4

extreme [2] - 3938:19, 4025:20

EXTREME [1] - 4025:21

eye [1] - 4085:22

F

face [2] - 3980:20, 4066:8

facie [2] - 4086:9

facilitate [2] - 3925:3, 3982:24

facilities [1] - 3881:12

facing [1] - 3785:7

fact [31] - 3779:22, 3780:3, 3782:13,

3785:6, 3785:18, 3789:8, 3791:20,

3814:10, 3815:16, 3884:11, 3906:16,

3932:2, 3935:5, 3939:3, 3953:25,

3955:7, 3961:16, 3977:4, 3978:11,

3980:21, 3983:9, 3983:12, 3987:25,

4004:3, 4025:7, 4031:23, 4041:19,

4063:14, 4085:11, 4087:3

facts [4] - 4013:3, 4029:23, 4031:12,

4036:11

factually [1] - 4083:6

failed [1] - 3916:19

Failing [3] - 3895:17, 3895:18,

3989:22

fair [10] - 3795:5, 3803:2, 3803:8,

3803:11, 3806:1, 3806:4, 3810:18,

3811:17, 3950:2, 3959:5

faith [2] - 3781:21, 3781:24

fake [1] - 3811:19Johnny C. Sanchez, RMR, CRR - [email protected]

4107

false [7] - 4012:15, 4012:18, 4012:19,

4012:20, 4012:25, 4013:1, 4013:8

familiar [11] - 3806:8, 3806:10, 3832:8,

3916:3, 3916:6, 3916:9, 3988:16,

4000:20, 4028:10, 4029:22, 4043:3

familiarity [1] - 4073:15

family [1] - 3928:15

fancy [1] - 4070:10

fantastic [1] - 4031:11

far [11] - 3789:5, 3791:7, 3840:6,

3849:11, 3863:13, 3912:24, 3914:12,

3966:16, 3966:19, 3996:6, 4082:3

fares [1] - 3889:5

favor [1] - 3980:2

fax [21] - 3797:7, 3896:19, 3899:3,

3902:18, 3920:18, 3920:23, 3920:24,

3921:2, 3926:3, 3927:12, 3927:21,

3927:24, 3928:6, 3928:10, 3929:25,

3931:11, 3932:24, 3938:18, 4051:25

faxed [3] - 3903:6, 3904:11, 4050:20

faxes [9] - 3920:12, 3933:6, 3934:11,

3935:13, 3936:23, 3941:16, 4023:22,

4024:3, 4047:10

faxing [2] - 3926:21, 4051:21

FAZEL [176] - 3782:17, 3782:20,

3843:18, 3849:18, 3853:8, 3865:5,

3886:5, 3886:20, 3886:24, 3887:1,

3887:3, 3887:5, 3887:15, 3903:10,

3903:22, 3905:24, 3906:4, 3906:8,

3906:11, 3906:22, 3907:1, 3907:6,

3908:10, 3908:13, 3908:25, 3909:4,

3909:10, 3910:9, 3910:13, 3910:18,

3910:20, 3911:3, 3911:21, 3912:3,

3912:6, 3912:22, 3913:7, 3913:12,

3914:2, 3914:7, 3914:24, 3915:2,

3916:8, 3917:20, 3917:25, 3918:7,

3919:11, 3919:14, 3943:11, 3943:14,

3943:16, 3949:3, 3949:9, 3953:14,

3953:19, 3958:14, 3958:25, 3968:2,

3969:25, 3976:7, 3976:9, 3976:15,

3978:3, 3978:8, 3978:9, 3978:16,

3978:19, 3979:3, 3979:5, 3979:11,

3979:13, 3980:8, 3980:14, 3980:24,

3982:1, 3982:4, 3982:5, 3984:6,

3984:14, 3985:1, 3985:4, 3986:2,

3986:4, 3986:13, 3986:18, 3986:19,

3987:8, 3987:12, 3987:18, 3989:13,

3989:16, 3989:18, 3989:21, 3990:25,

3991:2, 3993:22, 3997:13, 3997:14,

3997:25, 3998:2, 4000:23, 4001:2,

4001:4, 4005:16, 4005:20, 4005:24,

4006:1, 4008:15, 4008:16, 4009:12,

4009:14, 4009:16, 4010:16, 4010:21,

4011:7, 4011:9, 4012:3, 4012:7,

4012:9, 4012:10, 4013:5, 4013:7,

4013:14, 4013:17, 4015:19, 4017:25,

4018:12, 4018:15, 4018:17, 4019:18,

4027:1, 4027:4, 4030:12, 4030:14,

4030:20, 4031:18, 4031:22, 4032:4,

4032:6, 4032:12, 4034:3, 4037:8,

4037:19, 4038:24, 4039:2, 4039:5,

4039:11, 4039:18, 4039:21, 4039:25,

4040:3, 4040:10, 4041:18, 4042:7,

4042:9, 4044:12, 4048:11, 4049:20,

4050:4, 4050:10, 4050:19, 4051:16,

4052:6, 4072:2, 4072:21, 4072:23,

4073:17, 4075:13, 4077:16, 4077:24,

4078:8, 4078:16, 4079:8, 4079:11,

4079:18, 4088:1

Fazel [19] - 3773:20, 3773:21, 3949:10,

4018:4, 4018:8, 4019:16, 4020:2,

4022:3, 4023:13, 4023:24, 4024:24,

4025:16, 4026:3, 4026:21, 4038:15,

4044:15, 4044:24, 4045:5, 4047:16

Fazel's [1] - 4018:24

FAZEL.............. [3] - 3776:2, 3776:6,

3776:10

FAZEL................ [1] - 3775:23

FBI [2] - 3830:2, 3876:19

FDIC [4] - 3955:16, 3956:2, 3956:25,

3957:14

February [37] - 3773:5, 3784:23,

3789:8, 3790:4, 3790:5, 3790:18,

3836:13, 3844:15, 3894:6, 3894:9,

3896:3, 3905:17, 3905:18, 3915:24,

3916:24, 3942:2, 3942:6, 3942:12,

3942:14, 3944:12, 3944:14, 3944:20,

3945:5, 3945:7, 3946:17, 3946:18,

3948:7, 3992:11, 3992:15, 4021:15,

4041:24, 4050:3, 4054:3, 4054:16,

4058:20, 4060:23, 4088:12

Federal [1] - 3921:18

federal [7] - 3831:4, 3917:14, 4019:6,

4019:12, 4020:16, 4037:3, 4040:25

FedEx [1] - 3891:5

fee [1] - 3947:19

feedback [1] - 4074:14

feet [5] - 3802:1, 3802:22, 3802:23,

3803:5, 3803:6

fell [1] - 3972:9

fellow [6] - 4056:3, 4056:12, 4056:21,

4056:23, 4057:3, 4057:9

fellows [1] - 4056:18

Fellowship [1] - 4057:1

fellowship [1] - 4057:16

fellowships [4] - 4056:2, 4056:22,

4057:8, 4057:20

felt [1] - 4063:21

few [6] - 3864:14, 3880:23, 3935:13,

3942:19, 3943:9, 4044:23

field [3] - 3894:13, 3950:21, 3950:23

Field [1] - 3894:15

fifteen [1] - 3948:19

Fifth [12] - 3906:12, 3906:16, 3907:25,

3908:2, 3909:15, 3909:21, 3910:5,

3910:7, 3913:15, 3913:17, 3913:18,

3913:19

figure [4] - 3817:7, 3817:13, 3835:16,

3856:7

figured [1] - 3884:9

file [14] - 3829:1, 3830:25, 3831:2,

3833:21, 3836:16, 3842:21, 3918:19,

3919:2, 3919:20, 3920:4, 3933:7,

3958:9, 4089:17

filed [2] - 3845:22, 4036:8

filers [1] - 3832:12

files [6] - 4077:15, 4077:22, 4077:25,

4082:4, 4088:13, 4088:22

fill [1] - 4065:9

final [5] - 3884:6, 3889:5, 3893:1,

3941:23, 4026:1

Final [1] - 3878:4

finally [2] - 3777:13, 3788:1

Finance [2] - 3937:4, 3937:8

finance [7] - 3813:8, 4055:9, 4058:16,

4058:17, 4061:1, 4062:1, 4062:5

financed [1] - 3792:20

finances [4] - 3829:18, 3830:3,

3942:8, 3942:9

financial [30] - 3786:8, 3795:5,

3795:10, 3807:10, 3807:11, 3808:19,

3811:17, 3819:4, 3819:17, 3829:10,

3829:15, 3829:23, 3830:5, 3871:14,

3925:15, 3960:25, 4030:5, 4030:21,

4046:24, 4054:11, 4059:25, 4083:19,

4083:20, 4084:6, 4085:15, 4086:14,

4086:25, 4087:1, 4087:16, 4087:17

Financial [20] - 3830:23, 3833:4,

3834:6, 3897:4, 3899:5, 3900:20,

3905:23, 3918:13, 3918:20, 3920:8,

3922:24, 3926:22, 4011:4, 4011:5,

4047:4, 4053:21, 4054:6, 4074:12,

4080:3, 4081:10

financials [3] - 3836:4, 4083:22,

4084:15

financing [1] - 4084:24

FinCEN [1] - 3842:22

fine [8] - 3854:18, 3865:21, 3949:6,

3958:22, 4025:4, 4079:14, 4086:10,

4091:9

finger [4] - 3796:15, 3807:15, 3808:16,

3938:3

finish [4] - 3854:17, 3993:18, 3993:21,

3993:23

finished [1] - 3858:14

FINRA [2] - 3955:14, 3956:2

firearms [1] - 3951:7

firm [3] - 3902:25, 3934:2, 4087:20

Firm [1] - 3774:6

First [4] - 4058:24, 4059:11, 4059:13,

4060:25

first [67] - 3778:11, 3779:17, 3780:1,

3799:20, 3800:6, 3826:2, 3828:19,

3832:7, 3832:9, 3833:15, 3836:6,

3837:2, 3841:13, 3846:15, 3848:23,

3856:20, 3860:21, 3863:8, 3863:16,

3871:3, 3871:8, 3873:12, 3877:6,

3878:24, 3879:12, 3881:13, 3881:25,

3886:1, 3892:5, 3897:24, 3898:16,

3907:6, 3911:9, 3920:18, 3924:14,

3939:6, 3945:3, 3947:25, 3948:8,

3952:19, 3952:21, 3953:3, 3954:4,

3964:20, 3975:24, 3981:17, 3984:8,

4010:18, 4023:13, 4038:25, 4052:1,

4053:2, 4054:3, 4054:15, 4064:18,

4068:7, 4068:16, 4072:12, 4072:18,

4073:24, 4079:23, 4080:14, 4080:25,

4081:12, 4085:5, 4090:8

fit [5] - 3854:7, 3854:10, 3862:4,Johnny C. Sanchez, RMR, CRR - [email protected]

4108

3968:14, 3968:20

fitting [1] - 3968:12

five [9] - 3777:4, 3795:23, 3938:18,

3991:21, 3991:22, 4058:3, 4058:6,

4068:19, 4091:10

fix [1] - 3909:10

fixed [3] - 3850:20, 3851:9, 3851:15

flag [1] - 4010:8

flags [3] - 3981:6, 4010:5, 4010:7

flies [1] - 3981:10

flight [1] - 3889:6

float [1] - 3793:17

Floor [2] - 3773:22, 3774:4

floored [1] - 4063:8

Florida [4] - 3883:18, 3883:19, 4018:5,

4019:11

flow [1] - 3931:20

flowed [1] - 3791:14

flowing [1] - 3800:15

fluctuate [1] - 3851:12

fluctuating [1] - 3851:15

fly [1] - 3889:10

focus [8] - 3827:14, 3829:9, 3957:15,

4018:19, 4046:24, 4061:7, 4079:23,

4080:14

focused [4] - 3830:5, 3935:5, 3935:23,

3966:7

focusing [1] - 3829:14

focussing [1] - 3964:13

FOIA [3] - 4010:20, 4010:22, 4010:25

folder [1] - 3919:2

folks [2] - 3877:19, 4014:24

follow [1] - 3798:6

Follow [2] - 3803:12, 3808:15

following [19] - 3777:1, 3783:23,

3808:21, 3858:4, 3858:9, 3867:1,

3869:24, 3906:2, 3911:10, 3911:18,

3915:3, 3917:23, 3918:8, 3942:5,

3942:12, 3957:11, 3997:11, 4038:7,

4040:9

follows [2] - 3826:3, 4053:3

food [1] - 3871:20

foot [3] - 3937:6, 3937:21, 3941:9

FOR [3] - 3773:13, 3773:20, 3774:2

force [1] - 4049:5

forced [1] - 3889:23

Ford [1] - 3894:15

foregoing [1] - 4092:3

foreign [12] - 3782:6, 3833:18,

3833:20, 3833:24, 3834:9, 3954:7,

3954:9, 3954:11, 3954:14, 3954:17,

3954:18, 3954:21

foreign-earned [2] - 3833:24, 3834:9

forget [2] - 3851:3, 3953:14

forgot [1] - 3973:4

Form [4] - 3832:10, 3833:5, 3833:7,

3833:23

form [9] - 3833:8, 3833:21, 3833:24,

3946:7, 3969:23, 4058:24, 4078:8,

4086:19, 4088:1

formal [5] - 4050:22, 4050:25, 4051:1,

4051:21

former [1] - 3984:22

Fort [1] - 3902:21

forth [4] - 3920:12, 3986:5, 3986:6,

3996:1

forthcoming [1] - 3915:12

forward [7] - 3828:7, 3850:7, 3865:20,

3889:21, 3916:16, 4090:20, 4091:4

forwarded [1] - 3890:16

forwards [1] - 3881:17

foundation [8] - 3779:2, 3887:5,

3903:11, 3919:14, 4072:3, 4072:5,

4078:17, 4079:9

four [19] - 3792:7, 3837:20, 3837:21,

3837:22, 3840:2, 3843:11, 3844:1,

3844:14, 3845:14, 3910:17, 3964:24,

3964:25, 3965:11, 4055:21, 4055:23,

4056:15, 4058:3, 4058:6

four-year [2] - 4055:21, 4055:23

fourth [2] - 3813:2, 3845:1

framework [3] - 4058:1, 4080:20,

4087:5

frankly [1] - 3906:22

fraud [10] - 3804:9, 3804:12, 3812:16,

3823:7, 3828:8, 3829:6, 3830:9,

4020:16, 4029:2

fraudulent [3] - 3900:16, 3902:1,

4029:2

free [5] - 3823:23, 3825:12, 3828:17,

4052:11, 4052:12

Friday [10] - 3868:17, 3868:25, 3885:1,

3885:8, 3885:14, 3892:12, 3897:7,

3905:4, 3905:5, 3905:17

Friedley [1] - 3803:18

friedley [1] - 3805:20

friend [3] - 3881:5, 3921:5, 3922:22

friends [1] - 3926:12

front [11] - 3801:16, 3840:17, 3915:8,

3952:6, 3952:22, 3953:4, 3977:23,

3983:5, 3991:5, 3995:14, 4066:23

FSRC [63] - 3834:12, 3835:2, 3835:6,

3835:12, 3836:12, 3846:19, 3846:21,

3846:22, 3872:16, 3901:3, 3901:17,

3901:20, 3901:24, 3902:2, 3902:4,

3902:5, 3921:7, 3923:8, 3923:12,

3923:22, 3923:24, 3924:21, 3937:4,

3937:15, 3937:23, 3996:2, 3999:13,

4023:25, 4043:4, 4043:9, 4043:21,

4043:25, 4044:2, 4044:6, 4044:9,

4044:16, 4044:19, 4047:21, 4053:25,

4054:5, 4054:6, 4054:8, 4054:9,

4054:20, 4058:20, 4059:17, 4060:2,

4060:8, 4064:4, 4071:8, 4076:10,

4076:12, 4076:24, 4077:5, 4077:22,

4079:15, 4080:20, 4080:21, 4081:2,

4088:13, 4089:22, 4090:1

FSRC's [2] - 4087:11, 4088:7

full [6] - 3865:4, 3871:3, 3916:7,

3916:23, 4047:2, 4060:20

fully [2] - 3815:9, 3902:6

fun [2] - 4089:6, 4089:10

functioning [1] - 4043:4

fund [3] - 3788:3, 3816:12, 3816:17

funds [4] - 3828:1, 3828:2, 3828:11,

3828:12

fungible [1] - 3992:1

funnel [1] - 3791:25

furthermore [1] - 3929:8

future [1] - 3899:24

G

game [2] - 3884:3, 3891:5

gaming [2] - 4054:12, 4064:13

gather [1] - 3939:6

gathering [1] - 3939:7

Gator [6] - 3893:18, 3893:20, 3893:23,

3893:25, 3896:1, 3896:3

Gen [14] - 3777:23, 3786:15, 3788:2,

3800:13, 3800:15, 3804:6, 3805:3,

3817:1, 3817:3, 3817:11, 3817:15,

3817:20, 3821:9

general [12] - 3920:8, 3920:13,

3922:24, 3926:21, 3957:17, 3968:10,

3971:15, 3984:22, 3985:11, 3985:12,

4003:18, 4047:10

Generale [2] - 3803:19, 3816:12

generally [18] - 3876:9, 3916:3,

3916:22, 3920:3, 3929:1, 3935:2,

3956:20, 3957:3, 3959:22, 4003:17,

4057:23, 4059:17, 4064:3, 4064:8,

4073:2, 4073:5, 4074:25, 4083:10

generate [1] - 3960:23

generated [3] - 3960:22, 3961:10,

3961:13

gent's [1] - 4039:13

gentleman [2] - 4016:10, 4016:15

gentlemen [5] - 3784:2, 3857:24,

3911:11, 3915:4, 3997:9

Georgia [1] - 3832:17

Gerber [2] - 4016:14, 4016:15

gimmick [1] - 3796:2

Giselle [4] - 3881:4, 3885:10, 3896:24,

3897:1

given [6] - 3780:13, 3916:22, 3937:2,

3995:7, 3996:24, 4030:22

glad [3] - 3949:6, 4061:22, 4086:2

global [1] - 3937:22

go-round [1] - 3822:19

god [1] - 3995:7

God [1] - 4074:16

gosh [1] - 4033:12

governance [2] - 4085:13, 4087:5

government [38] - 3777:17, 3778:7,

3781:7, 3782:2, 3782:6, 3784:14,

3785:17, 3786:21, 3811:7, 3821:22,

3825:5, 3833:20, 3845:22, 3847:17,

3848:9, 3872:12, 3876:13, 3906:8,

3907:24, 3913:9, 3913:13, 3914:9,

3915:6, 3915:14, 3921:10, 3933:13,

3938:2, 3959:23, 3961:21, 3974:8,

4031:6, 4044:18, 4046:7, 4054:9,

4061:7, 4077:2, 4077:3

GOVERNMENT [1] - 3773:13

Government [14] - 3782:5, 3893:7,


4109

3947:4, 3948:2, 3957:14, 3978:16,

4000:16, 4000:18, 4000:21, 4001:6

government's [6] - 3824:21, 3907:12,

3915:10, 3917:18, 4002:9, 4047:3

Government's [49] - 3777:9, 3777:13,

3777:14, 3778:16, 3778:20, 3778:23,

3779:6, 3783:5, 3784:3, 3785:23,

3790:23, 3792:2, 3796:19, 3796:22,

3798:20, 3799:7, 3799:19, 3801:24,

3802:2, 3802:19, 3803:17, 3805:19,

3809:7, 3810:17, 3818:2, 3831:7,

3831:25, 3836:1, 3837:15, 3843:14,

3849:17, 3866:1, 3870:10, 3884:20,

3885:24, 3893:12, 3943:1, 3944:8,

3961:20, 3978:15, 3978:22, 3984:6,

3986:2, 3988:15, 3989:11, 4022:14,

4025:14, 4071:21, 4078:12

government-owning [1] - 4054:9

governmental [1] - 3959:15

governments [1] - 4057:25

graced [1] - 4063:15

graduated [1] - 3950:18

grand [4] - 3837:8, 3837:12, 3845:3,

3847:10

gray [1] - 3795:7

great [2] - 3949:18, 4027:23

greater [2] - 3828:12, 3842:20

greatest [1] - 3930:22

green [1] - 4068:8

Gregg [2] - 3773:13, 3949:20

Gregg's [1] - 3949:14

Gregory [2] - 3865:17, 3867:10

ground [1] - 3813:12

grounds [1] - 3901:3

groundwork [1] - 4078:19

group [9] - 3818:9, 3953:7, 4001:19,

4014:19, 4015:5, 4015:20, 4015:21,

4016:25, 4017:9

Group [11] - 3897:4, 3900:17, 3904:6,

3905:23, 3918:14, 3920:8, 3922:24,

4011:2, 4011:4, 4011:5, 4070:16

grouped [1] - 3790:13

grow [1] - 3846:13

growth [1] - 4057:14

guess [14] - 3811:6, 3839:18, 3852:5,

3860:18, 3861:16, 3885:3, 3894:5,

3912:6, 3941:9, 3968:22, 3974:7,

3986:15, 3993:24, 4074:1

guest [1] - 3881:9

Guests [1] - 3885:6

guests [2] - 3885:7, 3885:12

guidelines [1] - 4059:23

guilty [3] - 3785:6, 3787:3, 3823:8

gun [1] - 3952:1

guys [1] - 3932:1

H

half [6] - 3795:23, 3801:8, 3843:24,

3858:15, 3948:21, 4021:1

halftime [1] - 3875:23

hammer [1] - 3986:11

hand [21] - 3789:24, 3791:7, 3808:25,

3825:17, 3831:7, 3844:5, 3852:5,

3872:6, 3874:14, 3874:21, 3894:5,

3904:7, 3918:10, 3944:18, 3975:14,

3987:19, 3993:2, 4021:20, 4052:18,

4073:6, 4080:2

handed [1] - 4026:9

handful [1] - 3972:19

handing [2] - 4071:20, 4078:11

handle [1] - 3956:21

handled [2] - 3794:3, 4067:18

handwriting [10] - 3979:24, 3989:4,

4072:11, 4072:12, 4072:15, 4072:16,

4073:11, 4073:12, 4074:20, 4074:21

handwritten [7] - 3872:23, 3899:17,

3930:16, 3931:15, 3979:15, 3979:18,

3988:14

hang [6] - 3783:1, 3806:16, 3807:3,

3911:24, 3918:23, 3967:25

hanging [1] - 3911:24

happy [6] - 3887:12, 4069:2, 4069:17,

4069:19, 4069:21, 4069:24

hard [6] - 3809:16, 3809:17, 3810:25,

3811:2, 3958:4, 4010:10

Harmonites [1] - 3871:10

Harry [3] - 3895:17, 3895:18, 3989:22

Hawaii [1] - 3950:18

head [5] - 3833:4, 3867:9, 3906:23,

3907:5, 4060:11

headed [1] - 3937:16

header [1] - 4079:23

headquarters [2] - 3918:16, 3928:24

hear [10] - 3783:17, 3887:6, 3906:20,

3971:18, 4030:16, 4030:19, 4044:23,

4071:25, 4072:4, 4072:22

heard [12] - 3779:17, 3782:17,

3782:19, 3830:20, 3881:14, 3889:18,

3912:15, 3996:20, 4023:2, 4023:3,

4023:7, 4061:21

hearing [5] - 4009:15, 4011:25,

4063:16, 4071:22, 4078:13

hearsay [17] - 3779:3, 3886:19,

3887:5, 3903:11, 3903:13, 3903:14,

3906:24, 3906:25, 3916:10, 3919:12,

4072:3, 4073:17, 4077:17, 4077:25,

4078:1, 4078:17, 4079:11

heated [1] - 4063:13

held [18] - 3777:1, 3783:23, 3790:19,

3817:19, 3858:4, 3858:9, 3872:12,

3875:19, 3906:2, 3911:10, 3911:18,

3915:3, 3917:23, 3918:8, 3997:11,

4038:7, 4040:9, 4062:13

help [6] - 3883:4, 3883:13, 3889:19,

3891:9, 3915:2, 3949:7

helped [1] - 3828:6

helpful [1] - 3935:12

helping [1] - 3980:11

Henry [1] - 3826:18

Hesse [6] - 4062:9, 4062:11, 4062:12,

4074:9, 4074:10, 4074:11

Hewlett [4] - 4087:20, 4087:21,

4087:24, 4088:8

Hi [2] - 3889:2, 3891:3

hidden [3] - 3971:2, 3971:4, 3971:23

hide [11] - 3975:5, 3976:10, 3979:25,

3980:4, 3981:21, 3983:13, 3984:1,

3987:22, 4034:12, 4041:9

hiding [10] - 3985:10, 3985:15,

3985:16, 3985:18, 3985:20, 3985:21,

3986:8, 3986:21, 3987:6, 4035:22

hierarchy [1] - 4060:8

high [4] - 3780:21, 3881:11, 3950:12,

3950:13

high-level [1] - 3881:11

higher [2] - 3877:8, 3929:10

highest [1] - 4059:10

highlight [16] - 3800:7, 3838:2,

3849:20, 3924:14, 3925:21, 3930:8,

3930:16, 3933:14, 3984:8, 3984:11,

3984:13, 3989:15, 3989:18, 4010:20,

4032:4, 4072:1

highlighted [2] - 3794:24, 3795:6

highlighting [1] - 4032:3

himself [7] - 3872:20, 4023:10,

4063:13, 4068:25, 4079:6, 4082:20,

4082:21

hire [1] - 3983:10

hired [3] - 3890:2, 4019:23, 4071:7

hiring [2] - 4060:22, 4062:6

histories [1] - 3923:23

history [2] - 3937:25, 4089:8

hit [1] - 3910:10

HITTNER [1] - 3773:10

Hodge [33] - 3877:18, 3877:21,

3877:22, 3877:24, 3882:3, 3882:5,

3882:8, 3882:17, 3882:20, 3883:13,

3883:17, 3884:2, 3886:14, 3888:4,

3888:5, 3888:7, 3888:13, 3888:15,

3889:1, 3889:20, 3889:25, 3890:5,

3890:7, 3890:9, 3890:14, 3890:18,

3890:25, 3892:2, 3892:16, 3892:21,

3893:1, 3984:17, 4022:25

Hodge's [2] - 3883:9, 3891:10

hold [6] - 3809:11, 3988:1, 3988:6,

4025:10, 4041:13, 4079:5

holders [1] - 3805:24

holding [2] - 3793:2, 3878:16

Holt [10] - 3787:15, 3905:20, 3907:18,

3907:22, 3908:6, 3910:3, 3913:22,

3914:3, 3916:2, 4011:2

home [16] - 3785:11, 3787:20,

3787:24, 3797:7, 3801:16, 3881:9,

3881:10, 3896:19, 3896:20, 3896:24,

3923:20, 4048:5, 4048:7, 4068:11,

4068:14

honest [3] - 3986:25, 4018:9, 4019:16

Honor [102] - 3777:6, 3778:22,

3778:24, 3779:4, 3780:1, 3780:23,

3780:24, 3782:17, 3783:2, 3783:21,

3784:1, 3784:5, 3784:18, 3785:24,

3788:16, 3804:14, 3806:23, 3808:2,

3810:1, 3811:13, 3815:3, 3818:3,

3821:6, 3822:24, 3824:1, 3824:17,

3824:22, 3825:10, 3835:21, 3835:25,

3837:15, 3843:15, 3843:22, 3853:8,


4110

3866:13, 3886:6, 3886:13, 3887:18,

3887:25, 3895:23, 3896:16, 3898:3,

3898:25, 3903:10, 3903:16, 3909:20,

3911:21, 3912:4, 3912:9, 3913:12,

3914:24, 3915:18, 3918:21, 3919:11,

3920:10, 3935:20, 3935:24, 3936:2,

3942:14, 3942:19, 3946:4, 3949:3,

3949:4, 3958:14, 3969:22, 3978:8,

3980:8, 3986:14, 3990:19, 3997:13,

3997:25, 4001:2, 4005:17, 4005:22,

4005:24, 4012:3, 4013:15, 4017:25,

4018:12, 4022:11, 4025:9, 4026:25,

4031:19, 4038:5, 4041:12, 4048:9,

4052:9, 4052:15, 4071:3, 4072:19,

4073:10, 4073:15, 4078:14, 4078:16,

4079:13, 4079:18, 4088:2, 4091:15

HONORABLE [1] - 3773:10

hope [6] - 3878:15, 3878:21, 3899:23,

3928:15, 3935:11, 4060:14

Hopkins [1] - 3889:11

horse [1] - 3780:21

hospital [1] - 3834:20

host [1] - 4042:12

hotel [2] - 3824:6, 3871:20

hour [3] - 3801:3, 3801:9, 3911:13

hours [2] - 3889:4, 4067:11

house [1] - 3883:21

housed [1] - 3954:23

HOUSTON [1] - 3773:2

Houston [23] - 3773:4, 3773:15,

3773:23, 3774:4, 3774:7, 3774:12,

3875:20, 3876:20, 3878:3, 3880:20,

3881:2, 3882:23, 3883:18, 3883:23,

3885:3, 3885:4, 3905:23, 3917:3,

3918:16, 3928:24, 3929:14, 3994:15,

4013:24

Howard [1] - 3773:16

HR [1] - 4065:22

human [1] - 4065:18

hundred [11] - 3802:22, 3803:5,

3848:23, 3854:4, 3947:24, 3948:24,

3998:24, 4021:20, 4021:24, 4022:1

hundreds [3] - 3965:7, 3983:10

Hunton [2] - 3934:2, 4001:9

husband [1] - 3883:21

hush [2] - 3974:20

hush-hush [1] - 3974:20

I

IBC [1] - 3929:10

icing [1] - 4063:10

idea [3] - 3872:8, 3890:20, 4043:13

ideas [3] - 3814:4, 3814:7, 3931:23

identical [1] - 3972:13

identification [1] - 4071:3

identified [16] - 3779:7, 3824:18,

3848:13, 3858:24, 3859:2, 3864:10,

3864:12, 3887:23, 3901:18, 3919:4,

3935:18, 3935:21, 3993:9, 4000:25,

4085:3

identify [3] - 3859:20, 3860:6, 4071:1

IFSRA [1] - 4086:24

illegal [13] - 3954:14, 3955:5, 3956:2,

3967:3, 3977:7, 4002:3, 4009:10,

4009:17, 4010:2, 4019:2, 4033:12,

4041:9, 4046:21

illegally [2] - 3828:2, 3828:12

immediately [1] - 3781:2

Imperial [1] - 4058:23

implemented [1] - 3813:21

implication [1] - 4011:24

implied [2] - 3782:14, 3784:25

implying [2] - 3781:20, 4045:5

importance [3] - 3938:19, 4025:21,

4076:9

important [2] - 3865:3, 3885:7

importantly [1] - 3779:6

impose [1] - 3789:18

imposition [1] - 3934:18

impression [4] - 3914:18, 4037:9,

4038:16, 4071:16

improper [1] - 4033:13

inaccurate [2] - 4082:16, 4083:6

inartfully [1] - 3957:12

Inc [1] - 4011:5

inception [1] - 3901:17

include [8] - 3817:9, 3817:14, 3921:9,

3921:13, 3925:13, 3931:19, 3931:24,

3961:5

included [5] - 3795:18, 3834:18,

3881:19, 3926:3

includes [3] - 3779:8, 3781:4, 3947:19

including [7] - 3877:15, 3941:7,

3953:12, 3985:11, 4045:25, 4048:1,

4061:22

income [17] - 3830:17, 3831:3,

3831:14, 3831:21, 3833:9, 3833:12,

3833:14, 3833:24, 3833:25, 3834:9,

3834:15, 3834:17, 3834:24, 3836:19,

3965:15

incomes [1] - 3832:22

incorrect [1] - 4013:3

increase [1] - 3836:21

increased [1] - 3846:14

incur [1] - 3871:14

indeed [1] - 3929:5

independent [2] - 3926:18, 4080:17

India [3] - 4076:25, 4077:2, 4077:4

indicate [1] - 3836:21

indicated [10] - 3835:3, 3840:19,

3996:8, 4062:3, 4062:12, 4063:6,

4082:3, 4082:4, 4090:16, 4090:23

indicates [2] - 3795:4, 3987:25

indicating [3] - 3880:1, 3938:22,

4090:25

indicating) [2] - 3798:6, 3801:21

indication [6] - 3780:13, 4022:21,

4051:13, 4051:15, 4051:17

indicted [4] - 4004:23, 4009:4, 4009:6,

4009:8

indictment [3] - 3827:23, 3827:24,

3828:10

individual [11] - 3790:18, 3829:12,

3832:10, 3836:11, 3844:19, 3886:21,

3897:18, 3897:20, 3899:10, 3926:10,

4014:22

individuals [2] - 4044:19, 4089:13

individuals' [1] - 3829:10

industry [2] - 3937:9, 4058:20

inflated [3] - 3795:8, 3812:16, 3818:20

inform [2] - 3959:15, 3959:22

information [74] - 3786:8, 3791:8,

3809:12, 3817:2, 3828:17, 3829:16,

3829:19, 3831:12, 3835:3, 3836:25,

3846:7, 3858:19, 3881:14, 3899:11,

3903:14, 3906:24, 3906:25, 3916:19,

3923:6, 3923:7, 3923:13, 3924:4,

3924:6, 3925:2, 3925:25, 3926:20,

3927:1, 3927:7, 3928:3, 3934:22,

3939:15, 3941:4, 3971:21, 3973:10,

3973:14, 3977:11, 4005:4, 4006:17,

4011:12, 4014:23, 4015:3, 4017:2,

4017:15, 4017:17, 4017:18, 4017:20,

4028:15, 4028:19, 4028:23, 4037:24,

4040:16, 4040:17, 4041:20, 4042:3,

4049:10, 4049:17, 4076:3, 4076:10,

4077:25, 4078:5, 4081:3, 4081:5,

4081:8, 4083:23, 4084:6, 4084:14,

4085:3, 4085:6, 4085:9, 4087:1,

4087:17, 4088:11

informed [3] - 3938:23, 4004:8, 4006:3

inherent [1] - 3913:14

initial [2] - 4074:17, 4082:9

initials [7] - 3861:13, 3861:17,

3861:20, 3861:23, 3862:18, 3919:18,

3930:25

input [2] - 3902:3, 3921:9

inquiring [1] - 3897:25

inquiry [1] - 3995:4

INS [1] - 3889:11

insane [1] - 3884:8

insider [1] - 4086:5

insofar [1] - 3813:8

Inspection [1] - 3992:6

inspector [1] - 4016:14

Inspector [1] - 4016:15

inspectors [3] - 4016:19, 4016:24,

4017:11

instances [2] - 3845:17, 3972:6

instead [5] - 3905:19, 3907:15,

3907:22, 3912:12, 4051:21

Institute [5] - 4056:3, 4056:23, 4057:4,

4057:9, 4057:21

institute [3] - 4056:13, 4056:25,

4057:17

institution [12] - 3925:15, 3926:14,

3926:15, 3960:25, 4054:9, 4057:13,

4057:24, 4058:2, 4061:9, 4063:23,

4064:21, 4084:5

Institution [2] - 4081:10

institutions [6] - 3837:25, 3926:17,

3929:7, 3932:1, 3932:2, 3965:8

instruct [2] - 3778:16, 3912:7

instructed [5] - 3784:3, 3812:17,

3819:15, 3820:4, 3915:16

instructing [1] - 3980:16Johnny C. Sanchez, RMR, CRR - [email protected]

4111

instruction [12] - 3782:22, 3783:9,

3783:10, 3783:12, 3783:14, 3783:16,

3811:24, 3909:16, 3911:22, 3915:5,

3952:7, 3979:17

instructions [8] - 3805:20, 3812:1,

3820:25, 3860:25, 3861:11, 3862:16,

3869:8, 3881:14

insufficient [1] - 4079:7

insurance [3] - 4054:11, 4064:12,

4064:14

integrity [1] - 4036:18

Intelligence [1] - 3982:9

intelligence [1] - 3982:13

intelligent [1] - 4063:14

intend [1] - 3782:16

intended [1] - 3781:8

intention [1] - 3828:4

interaction [8] - 4002:18, 4004:7,

4008:17, 4008:22, 4009:21, 4035:14,

4037:20

interchange [1] - 3988:7

interest [4] - 3965:15, 3965:17,

3965:20

interested [1] - 3883:15

internal [3] - 3790:3, 4064:13, 4090:2

Internal [1] - 3826:16

international [17] - 3806:8, 3806:24,

3807:11, 3815:7, 3815:14, 3815:21,

3816:2, 3827:25, 3929:9, 3935:10,

3955:4, 3962:3, 4048:17, 4064:14,

4075:6, 4076:18, 4086:24

International [52] - 3786:9, 3790:14,

3795:19, 3829:24, 3871:10, 3871:13,

3896:8, 3897:25, 3899:12, 3900:19,

3901:9, 3902:14, 3915:25, 3923:13,

3923:23, 3924:5, 3924:7, 3925:6,

3925:18, 3927:2, 3928:4, 3929:17,

3933:23, 3934:22, 3937:14, 3941:12,

3954:20, 4011:3, 4024:22, 4045:3,

4045:23, 4046:17, 4053:18, 4053:20,

4053:24, 4054:19, 4058:25, 4059:11,

4059:17, 4059:20, 4062:2, 4062:4,

4062:15, 4065:10, 4076:22, 4079:24,

4081:4, 4082:12, 4083:11, 4088:23,

4089:16, 4089:18

internationally [1] - 3828:6

interrupt [3] - 3777:25, 3908:14,

4087:6

interview [16] - 3826:21, 3992:3,

4062:22, 4063:1, 4063:12, 4063:17,

4063:21, 4064:18, 4064:19, 4064:20,

4065:3, 4065:4, 4071:10, 4073:8,

4073:9, 4088:18

interviewed [3] - 3826:18, 4065:7,

4073:23

interviewing [2] - 4062:20, 4073:21

intimating [2] - 3968:16, 4026:8

intro [1] - 3887:12

introduce [2] - 3826:8, 4053:6

introduced [2] - 4068:25, 4070:9

introducing [1] - 3886:8

invested [4] - 3800:2, 3800:4,

3818:14, 3819:8

investigate [6] - 3827:8, 3951:14,

3951:16, 3951:18, 3981:11, 3991:24

investigated [3] - 3954:2, 3998:21,

4036:1

investigating [3] - 3828:23, 3899:14,

4013:10

investigation [48] - 3787:5, 3787:8,

3826:17, 3827:13, 3829:6, 3829:9,

3829:22, 3830:16, 3835:3, 3837:6,

3859:6, 3875:10, 3876:13, 3893:3,

3895:8, 3898:6, 3901:25, 3902:14,

3903:4, 3903:17, 3903:18, 3903:21,

3904:9, 3904:18, 3905:21, 3916:11,

3917:3, 3917:12, 3954:4, 3965:23,

3967:5, 3975:13, 3982:11, 3982:12,

3982:14, 3998:23, 4013:18, 4019:6,

4019:8, 4019:13, 4036:3, 4037:3,

4038:12, 4038:23, 4039:17, 4047:4,

4047:7, 4049:21

investigations [6] - 3960:4, 3994:2,

4038:11, 4038:15, 4041:1, 4041:2

investigative [5] - 3826:23, 3827:1,

3827:11, 3828:15, 4001:19

investigator [2] - 3976:16, 3998:18

investing [1] - 3798:23

Investment [1] - 3849:23

investment [5] - 3915:25, 3916:7,

3916:23, 4045:25, 4083:21

investors [2] - 3794:1, 3794:2

invited [5] - 3890:19, 4062:21, 4065:6,

4065:18, 4065:23

involved [8] - 3827:11, 3829:23,

4024:20, 4039:7, 4040:4, 4047:6,

4056:7, 4090:18

inward [1] - 4080:4

IRS [36] - 3826:18, 3826:22, 3827:1,

3827:3, 3827:4, 3827:11, 3827:13,

3827:15, 3828:15, 3828:18, 3828:19,

3828:25, 3829:1, 3829:2, 3833:17,

3833:22, 3836:15, 3842:15, 3842:22,

3904:16, 3950:6, 3950:9, 3950:17,

3951:2, 3951:4, 3951:20, 3951:24,

3953:1, 3954:1, 3957:13, 3960:2,

3981:12, 3982:6, 3982:8, 4003:16

island [2] - 4059:2, 4059:3

Island [1] - 3847:1

islands [2] - 3922:13, 4059:9

isolate [1] - 3845:7

issue [16] - 3809:16, 3824:5, 3837:8,

3847:10, 3913:18, 3921:6, 3926:25,

3934:21, 3935:13, 3936:25, 3938:19,

3941:17, 3941:23, 4025:19, 4026:1,

4039:9

issued [5] - 3837:12, 3904:17, 3909:2,

3915:21, 4059:23

issues [8] - 3780:2, 3879:9, 3901:18,

3921:23, 4007:13, 4007:17, 4030:5

issuing [3] - 3904:16, 3965:8, 4046:12

item [2] - 3875:12, 3875:14

itself [11] - 3786:18, 3800:7, 3830:3,

3850:6, 3963:13, 3988:19, 4010:4,

4014:13, 4037:17, 4064:17, 4086:22

J

Jacobs [4] - 3899:9, 3899:10, 3899:19,

3899:20

JAMES [2] - 3775:3, 3784:6

James [4] - 3829:16, 3885:10,

3897:22, 4011:1

January [18] - 3799:24, 3875:18,

3876:21, 3877:12, 3878:4, 3880:1,

3880:21, 3885:1, 3885:8, 3891:1,

3891:22, 4022:19, 4033:25, 4065:13,

4068:12, 4068:13, 4070:18, 4070:20

Janvey [2] - 4011:1, 4011:6

Japanese [1] - 3851:13

Jensen [2] - 3881:1, 3884:23

jet [1] - 3981:11

jetted [1] - 4002:12

job [27] - 3833:25, 3834:3, 3982:9,

3982:16, 4017:1, 4059:7, 4060:24,

4061:3, 4065:8, 4065:11, 4065:23,

4066:8, 4067:5, 4067:13, 4067:21,

4069:1, 4069:6, 4071:8, 4071:17,

4076:16, 4076:17, 4082:4, 4087:12,

4088:9, 4088:22, 4089:5

John [2] - 3774:2, 3889:11

John's [3] - 3834:7, 3849:24, 4053:15

Johnny [3] - 3774:11, 4092:3, 4092:7

join [2] - 4070:16

joint [2] - 3832:20, 3832:24

Joker [1] - 4074:16

Joseph's [1] - 3834:20

journey [3] - 4055:21, 4055:23, 4057:5

JPMorgan [5] - 3837:24, 3838:6,

3838:13, 3838:17, 3838:23

Judge [9] - 3783:16, 3906:4, 3916:8,

3917:20, 3917:25, 3918:7, 3975:16,

3976:7, 4038:24

JUDGE [1] - 3773:10

judge [3] - 3831:4, 3917:14, 3994:3

Julie [11] - 3877:18, 3882:3, 3888:4,

3888:7, 3889:1, 3889:2, 3890:5,

3890:9, 3891:3, 3892:10, 3984:17

July [17] - 3871:6, 3873:18, 3874:25,

3924:17, 3927:18, 3927:20, 3927:23,

3934:10, 3936:10, 3938:11, 3938:15,

3940:9, 3940:21, 4054:24, 4090:12,

4091:1

jump [2] - 3938:1, 3977:21

June [13] - 3867:14, 3867:20, 3868:3,

3868:6, 3868:12, 3868:16, 3868:20,

3900:5, 3905:4, 3923:3, 4090:10,

4090:16

juries [1] - 3952:6

jurisdiction [6] - 3825:4, 3825:7,

3827:13, 3899:23, 4003:16, 4089:2

jurisdictions [5] - 3955:20, 3955:23,

3957:6, 4043:14, 4059:6

Juror [1] - 3953:14

jurors [1] - 3832:7

jury [89] - 3777:1, 3777:3, 3777:10,

3777:18, 3778:16, 3783:9, 3783:22,


4112

3822:10, 3822:14, 3826:8, 3826:25,

3830:20, 3836:9, 3837:8, 3837:12,

3847:10, 3858:4, 3858:9, 3863:7,

3865:3, 3898:22, 3902:11, 3906:13,

3911:10, 3911:18, 3912:7, 3914:21,

3915:3, 3918:8, 3941:24, 3952:8,

3952:11, 3952:14, 3952:22, 3953:4,

3956:1, 3962:22, 3965:9, 3967:21,

3968:3, 3970:3, 3970:15, 3970:21,

3971:8, 3972:2, 3972:24, 3977:23,

3981:13, 3983:5, 3983:19, 3983:24,

3985:5, 3985:7, 3986:13, 3991:5,

3992:10, 3995:14, 3997:11, 4001:15,

4004:22, 4004:25, 4008:18, 4008:20,

4010:13, 4012:17, 4012:23, 4016:8,

4029:8, 4036:20, 4040:9, 4041:22,

4048:20, 4049:2, 4051:20, 4051:25,

4053:6, 4054:4, 4063:1, 4064:8,

4071:23, 4074:19, 4074:25, 4078:14,

4081:25, 4083:13

JURY [1] - 3773:7

jury's [2] - 3898:2, 3996:20

Justice [2] - 3773:17, 4049:8

justice [1] - 4049:10

K

K-A-L-F-O-R-D [1] - 3826:11

Kal [1] - 3825:14

kALFORD [2] - 3775:19, 3826:1

Kalford [1] - 3826:9

Kecia [1] - 3850:2

keep [15] - 3810:8, 3810:25, 3811:2,

3817:7, 3840:8, 3891:14, 3891:16,

3910:25, 3935:4, 3937:18, 3946:1,

3990:16, 3991:1, 4071:19

keeping [1] - 4085:21

keeps [1] - 3993:19

Kenneth [1] - 3774:6

Kenny [1] - 3861:22

kept [5] - 3809:18, 3809:21, 3810:9,

3818:9, 3822:8

kind [11] - 3890:5, 3941:4, 3950:10,

3951:5, 3956:7, 3997:15, 4019:8,

4033:10, 4045:19, 4069:8, 4076:6

kindly [2] - 3899:20, 3926:12

King [125] - 3829:13, 3831:11,

3832:12, 3832:14, 3839:21, 3839:24,

3850:2, 3867:2, 3868:3, 3868:9,

3871:1, 3872:4, 3873:1, 3873:10,

3873:11, 3880:20, 3881:1, 3881:5,

3881:23, 3882:23, 3883:5, 3884:17,

3885:9, 3889:3, 3895:1, 3895:12,

3897:14, 3897:21, 3899:4, 3919:15,

3920:4, 3920:6, 3926:8, 3928:22,

3932:19, 3933:7, 3937:16, 3938:17,

3938:23, 3939:4, 3940:8, 3940:12,

3940:19, 3973:16, 3983:6, 3985:21,

3988:1, 3988:6, 3988:9, 3989:24,

3991:6, 3995:15, 3995:18, 3995:23,

3996:8, 3996:24, 3997:20, 3998:9,

3999:2, 4002:10, 4002:13, 4004:9,

4004:12, 4004:20, 4006:10, 4006:23,

4008:6, 4008:23, 4021:21, 4022:22,

4023:4, 4023:7, 4024:15, 4024:20,

4026:4, 4027:14, 4027:18, 4033:4,

4033:8, 4033:16, 4034:2, 4037:21,

4043:24, 4044:3, 4044:16, 4044:19,

4046:25, 4062:13, 4062:16, 4062:22,

4063:2, 4063:6, 4063:14, 4063:19,

4063:24, 4065:2, 4066:6, 4066:18,

4071:7, 4071:14, 4073:13, 4074:22,

4075:7, 4076:9, 4076:18, 4080:11,

4080:12, 4080:16, 4081:7, 4081:17,

4081:21, 4081:23, 4082:10, 4082:11,

4082:15, 4082:18, 4083:8, 4090:5,

4090:16, 4090:18, 4090:23, 4091:5

king [105] - 3829:17, 3830:6, 3830:20,

3830:22, 3831:1, 3831:13, 3832:5,

3832:25, 3833:17, 3833:24, 3836:10,

3836:21, 3837:2, 3837:18, 3838:15,

3839:4, 3840:4, 3843:12, 3844:2,

3846:16, 3847:1, 3847:6, 3847:21,

3852:24, 3856:19, 3858:15, 3858:20,

3858:22, 3867:25, 3869:17, 3871:7,

3875:12, 3881:8, 3881:16, 3884:14,

3885:20, 3890:19, 3893:4, 3893:16,

3894:22, 3896:8, 3896:13, 3897:3,

3897:6, 3897:24, 3898:6, 3898:8,

3898:11, 3899:11, 3900:2, 3901:22,

3902:8, 3905:22, 3920:13, 3923:5,

3926:2, 3926:20, 3928:10, 3928:12,

3928:17, 3928:18, 3929:14, 3929:18,

3929:20, 3930:12, 3930:19, 3931:2,

3931:12, 3931:15, 3932:10, 3932:13,

3932:24, 3933:2, 3935:14, 3936:23,

3939:9, 3939:14, 3939:21, 3940:2,

3940:23, 3941:5, 3941:16, 3941:19,

3942:22, 3946:21, 3948:8, 3948:11,

3956:12, 3956:13, 3962:7, 3964:13,

3964:14, 3967:7, 3968:5, 3968:17,

3970:14, 3970:19, 3972:1, 3972:4,

3973:1, 3974:10, 3975:15, 3978:23,

3980:11

king's [48] - 3829:14, 3829:18,

3831:17, 3832:9, 3832:16, 3832:19,

3834:17, 3835:11, 3838:21, 3840:1,

3845:14, 3846:3, 3848:6, 3849:12,

3851:23, 3854:1, 3854:21, 3855:1,

3857:10, 3864:6, 3866:16, 3867:18,

3867:22, 3868:23, 3869:14, 3870:4,

3870:7, 3874:1, 3874:24, 3892:14,

3896:6, 3896:23, 3928:6, 3929:13,

3942:8, 3944:13, 3944:21, 3961:22,

3961:25, 3962:16, 3967:22, 3980:2,

3996:15, 4047:21, 4048:3, 4074:5,

4075:4

King's [10] - 3830:12, 3830:15, 3836:4,

3838:5, 3838:22, 3874:6, 3890:16,

3943:6, 3980:7, 4026:23

Kingdom [1] - 4055:11

kitchen [1] - 3881:7

knock [1] - 3931:4

knock-out [1] - 3931:4

knowledge [9] - 3791:19, 3794:10,

3907:2, 3908:17, 3912:13, 3967:5,

3967:10, 3989:3, 4049:22

knowledgeable [1] - 3908:7

known [5] - 3884:10, 4023:9, 4032:9,

4064:5, 4064:6

knows [7] - 3782:6, 4004:4, 4006:9,

4006:12, 4006:16, 4006:19, 4006:22

Kuhrt [1] - 3787:14

L

labeled [1] - 3920:4

lack [1] - 3941:9

lacking [1] - 4074:15

ladies [5] - 3784:2, 3857:24, 3911:11,

3915:4, 3997:8

lady [1] - 3881:4

laid [2] - 3916:18, 3973:9

laptop [3] - 3785:25, 3790:22, 3803:14

laptops [1] - 3785:11

large [2] - 3941:20, 4057:13

larger [1] - 3924:2

last [28] - 3822:19, 3826:12, 3845:7,

3845:16, 3846:15, 3855:4, 3855:23,

3856:20, 3872:1, 3880:10, 3880:23,

3882:12, 3887:21, 3887:25, 3889:6,

3889:16, 3892:19, 3901:6, 3901:22,

3914:18, 3940:23, 4027:13, 4033:9,

4053:8, 4059:14, 4065:20, 4068:12

Last [1] - 3806:22

late [2] - 3787:19, 3997:15

Latin [1] - 3890:4

laugh [1] - 3932:5

laugh) [2] - 3931:23, 3932:4

Laundering [1] - 3901:10

laundering [10] - 3827:14, 3827:16,

3827:18, 3827:22, 3828:1, 3828:9,

3828:24, 3829:6, 3830:9, 4084:24

Laura [7] - 3887:10, 3888:15, 3889:19,

3891:12, 3905:20, 3916:2, 4011:2

Law [2] - 3774:3, 3774:6

law [11] - 3902:25, 3917:10, 3917:15,

3934:2, 3939:8, 3951:9, 3994:2,

3998:19, 4010:10, 4018:10, 4048:24

laws [10] - 3827:8, 3827:22, 3827:24,

4003:10, 4003:14, 4003:17, 4003:18,

4059:20, 4084:23, 4085:11

lawyer [31] - 3904:12, 3904:25,

3910:3, 3913:20, 3934:18, 3938:24,

3940:19, 3984:24, 3985:6, 3990:7,

4002:5, 4002:19, 4002:24, 4004:8,

4004:11, 4004:18, 4004:23, 4004:25,

4005:3, 4005:10, 4005:12, 4006:2,

4006:9, 4007:4, 4018:5, 4018:9,

4019:16, 4019:25, 4039:22, 4040:3

lawyers [6] - 3808:9, 3858:1, 3910:11,

3971:18, 4018:25, 4019:2

lay [2] - 3910:16, 4078:19

layers [1] - 4043:15

lead [1] - 3820:11

Leading [2] - 3796:3, 3818:23

leading [3] - 3818:24, 4018:17,Johnny C. Sanchez, RMR, CRR - [email protected]

4113

4019:18

lean [1] - 3865:20

learn [2] - 3916:22, 3936:21

least [2] - 3865:24, 3913:21

leave [14] - 3823:23, 3825:12, 3865:3,

3865:12, 3865:13, 3976:22, 3977:1,

3978:11, 4037:9, 4052:11, 4052:12,

4090:17, 4090:24, 4091:5

leaves [1] - 3970:23

leaving [5] - 3892:11, 3906:13,

3948:24, 3982:25, 4038:16

ledger [2] - 3809:21, 3810:9

Lee [8] - 3899:25, 3921:12, 3926:6,

3926:7, 3926:19, 3932:4, 3938:16,

3940:23

left [19] - 3844:5, 3855:4, 3858:6,

3858:7, 3861:16, 3874:17, 3874:19,

3879:13, 3894:5, 3895:2, 3944:18,

3947:22, 4060:25, 4063:21, 4064:20,

4066:17, 4071:16, 4083:25

left-hand [3] - 3844:5, 3894:5, 3944:18

legal [5] - 3911:24, 3976:5, 4008:6,

4012:4, 4019:13

Legal [1] - 3847:16

legislation [1] - 3929:9

legitimate [1] - 3815:20

length [2] - 3800:23, 3813:20

Leroy [68] - 3829:13, 3830:12,

3830:15, 3831:11, 3832:12, 3836:4,

3838:5, 3839:21, 3839:24, 3850:2,

3871:1, 3872:4, 3873:1, 3873:9,

3873:11, 3874:6, 3880:20, 3881:1,

3881:5, 3881:23, 3882:10, 3882:23,

3883:5, 3885:9, 3889:3, 3891:4,

3891:8, 3891:17, 3892:3, 3895:1,

3895:12, 3896:7, 3897:14, 3897:21,

3899:4, 3899:18, 3899:25, 3919:16,

3920:4, 3920:6, 3926:8, 3928:22,

3932:19, 3933:7, 3937:16, 3938:22,

3939:4, 3940:8, 3940:12, 4022:22,

4024:15, 4024:20, 4026:4, 4034:2,

4046:25, 4062:13, 4063:2, 4063:6,

4066:6, 4073:13, 4074:21, 4080:11,

4081:21, 4082:10, 4090:5, 4090:16

Leroy's [1] - 3889:3

less [4] - 3792:10, 3961:11, 3972:10,

4082:4

letter [75] - 3803:18, 3870:18, 3870:20,

3870:23, 3870:25, 3871:5, 3897:24,

3898:3, 3898:18, 3898:23, 3899:11,

3899:14, 3900:2, 3900:6, 3900:10,

3900:12, 3901:3, 3901:22, 3902:8,

3921:13, 3924:16, 3928:14, 3928:20,

3929:13, 3930:11, 3932:16, 3932:19,

3933:2, 3938:17, 3978:23, 3979:6,

3980:1, 3980:10, 4012:14, 4012:24,

4013:2, 4029:1, 4029:10, 4050:21,

4051:21, 4065:24, 4066:1, 4066:5,

4066:8, 4066:19, 4066:21, 4066:24,

4066:25, 4067:1, 4067:2, 4067:3,

4067:11, 4068:7, 4071:11, 4071:12,

4071:13, 4079:3, 4079:4, 4079:22,

4079:24, 4080:6, 4080:10, 4080:11,

4080:24, 4080:25, 4081:1, 4081:16,

4081:19, 4081:22, 4082:9, 4082:21,

4083:7, 4083:8, 4088:18

letterhead [2] - 4066:2, 4079:24

letters [5] - 3923:4, 4028:14, 4045:16,

4078:24, 4079:2

letting [3] - 3781:8, 3783:7, 4030:10

level [4] - 3878:14, 3881:11, 3892:23,

3985:14

LGA [1] - 3889:11

liberty [1] - 3933:3

licensed [3] - 3935:6, 3937:3, 3937:24

licenses [1] - 4059:23

lie [1] - 4029:2

life [5] - 4057:18, 4057:24, 4069:17,

4069:20, 4069:25

lift [1] - 3938:3

light [4] - 3865:9, 3865:11, 3871:13,

4068:8

limit [3] - 3957:25, 3958:2, 3958:8

limitations [1] - 4079:16

Limited [5] - 3900:19, 3924:23,

3954:21, 4011:4, 4079:25

limited [3] - 3903:24, 3923:18,

4039:15

Linda [9] - 3876:22, 3876:23, 3876:24,

3879:6, 3881:3, 3984:15, 3985:13,

4022:19, 4033:24

Line [4] - 3832:24, 3833:6, 3833:15,

3834:13

line [14] - 3795:4, 3795:6, 3810:18,

3811:17, 3832:13, 3840:19, 3840:24,

3860:18, 3892:23, 3934:8, 3982:2,

4038:9, 4040:5, 4064:15

lines [2] - 3813:5, 3894:14

link [1] - 3807:5

linked [1] - 4064:16

liquidator [2] - 4014:11, 4017:5

Lisa [5] - 3889:2, 3889:11, 3891:4,

3892:3, 3896:22

Lisa's [1] - 3896:20

Lisonyi [1] - 3832:14

list [13] - 3807:3, 3832:22, 3843:25,

3844:21, 3850:8, 3855:1, 3885:4,

3891:15, 3902:25, 3925:23, 3943:15,

4046:8, 4047:18

listed [12] - 3791:21, 3797:2, 3797:11,

3832:12, 3832:13, 3832:17, 3832:24,

3844:19, 3877:18, 3897:21, 4047:22,

4047:24

listing [2] - 3846:11, 3855:12

lists [2] - 3855:6, 4026:16

live [3] - 3833:11, 4053:14, 4053:15

livelihood [1] - 4089:11

lives [3] - 3832:18, 3892:13, 4089:11

living [3] - 3830:24, 4047:14, 4077:7

LLC [1] - 4011:3

loan [12] - 3793:3, 3793:4, 3799:14,

3800:20, 3800:24, 3801:3, 3814:14,

3814:21, 3815:9, 3815:15, 3816:19,

3819:21

loaned [2] - 3792:5, 3799:9

loans [8] - 3806:5, 3807:1, 3807:9,

3820:7, 3820:8, 3820:14, 3821:1,

3923:20

lobbyists [2] - 4028:2, 4028:3

locate [1] - 3848:3

located [9] - 3837:6, 3837:23,

3847:13, 3847:24, 3849:24, 3876:20,

3918:19, 4013:24, 4055:10

look [69] - 3779:18, 3779:19, 3785:23,

3790:23, 3797:1, 3798:19, 3799:13,

3799:19, 3801:24, 3811:8, 3841:11,

3843:24, 3845:16, 3850:8, 3851:2,

3859:20, 3860:21, 3867:9, 3868:15,

3871:2, 3879:12, 3885:25, 3890:22,

3891:24, 3894:3, 3894:24, 3897:16,

3900:9, 3903:8, 3917:11, 3929:1,

3930:11, 3934:5, 3934:7, 3935:22,

3936:4, 3938:5, 3940:16, 3945:3,

3952:8, 3965:14, 3967:12, 3967:19,

3972:12, 3980:4, 3982:17, 3982:19,

3987:6, 3992:21, 3993:17, 3995:5,

4013:19, 4013:22, 4016:5, 4017:6,

4017:8, 4017:9, 4017:14, 4025:16,

4034:20, 4042:21, 4047:16, 4074:23,

4081:12, 4081:18, 4084:21, 4086:12,

4091:20

Look [1] - 4043:13

looked [21] - 3807:15, 3835:8, 3845:6,

3874:9, 3933:6, 3936:7, 3938:10,

3962:19, 3962:25, 3963:1, 3963:4,

3966:21, 3972:13, 3972:15, 3974:6,

3991:17, 3995:13, 3996:10, 4017:11,

4017:12, 4038:11

looking [26] - 3792:2, 3799:8, 3803:21,

3807:3, 3811:12, 3838:1, 3847:25,

3858:13, 3881:16, 3881:23, 3888:25,

3892:22, 3944:11, 3953:7, 3982:15,

3987:17, 3992:12, 4016:6, 4016:7,

4062:6, 4062:11, 4078:15, 4079:21,

4085:2, 4085:14, 4085:17

Lopez [1] - 3787:14

lose [3] - 3889:4, 3911:24, 3911:25

loss [1] - 4083:23

lost [1] - 3793:16

Lotus [1] - 3881:7

Louisiana [2] - 4080:18, 4081:11

Loumiet [33] - 3933:20, 3933:21,

3933:22, 3934:16, 3936:5, 3936:13,

3938:14, 3938:23, 3939:3, 3939:20,

3939:25, 3940:7, 3940:12, 3940:19,

3941:4, 3941:5, 4001:8, 4001:23,

4004:18, 4006:22, 4006:25, 4008:5,

4008:6, 4018:5, 4019:5, 4019:21,

4025:3, 4036:20, 4037:10, 4039:4,

4039:7, 4039:8, 4039:24

lousy [1] - 3884:12

lower [4] - 3778:3, 3878:16, 3894:5,

4033:21

lozenge [1] - 3949:4

luck [1] - 3884:13

lula [1] - 3984:19

lunch [6] - 3909:12, 3910:10, 3911:14,


4114

M

M-A-T-H-U-R-N [1] - 4062:25

MA [2] - 3930:20, 3930:24

mail [74] - 3800:7, 3828:8, 3876:9,

3876:11, 3876:12, 3876:14, 3876:21,

3877:2, 3877:6, 3877:12, 3878:9,

3878:18, 3878:23, 3879:1, 3879:10,

3879:18, 3879:25, 3880:10, 3880:13,

3882:17, 3884:2, 3884:6, 3884:23,

3885:2, 3885:25, 3888:4, 3888:14,

3888:25, 3890:16, 3890:22, 3890:25,

3891:7, 3891:24, 3892:1, 3897:5,

3899:22, 3926:24, 3933:9, 3933:16,

3934:7, 3935:2, 3936:5, 3936:6,

3936:7, 3938:10, 3939:20, 3940:6,

3940:7, 3985:8, 3985:13, 3985:22,

3985:23, 3986:10, 3986:17, 3987:10,

3987:25, 3988:2, 4001:14, 4002:18,

4006:2, 4008:3, 4022:15, 4022:24,

4023:2, 4025:3, 4031:24, 4032:25,

4033:7, 4033:11, 4033:15, 4033:21,

4034:8, 4034:11, 4034:14

Mail [1] - 3891:12

mailed [1] - 3989:19

mails [18] - 3876:18, 3879:25, 3880:6,

3880:23, 3884:18, 3893:9, 3894:18,

3927:11, 3927:17, 3933:10, 3934:25,

3983:23, 3986:20, 3988:5, 4008:8,

4022:10, 4023:22, 4024:3

main [1] - 3797:7

maintained [2] - 3876:18, 3945:13

major [1] - 3960:6

majority [3] - 3974:11, 3982:8,

3982:14

malfunction [1] - 3875:24

man [5] - 4044:21, 4069:17, 4069:19,

4074:15, 4079:6

Management [2] - 4011:3, 4057:10

management [4] - 3926:18, 4056:8,

4084:2, 4087:3

MANAGER [3] - 3825:16, 4052:17,

4052:23

manager [5] - 3890:3, 4057:13,

4065:18, 4065:22, 4066:17

managing [1] - 4065:9

Manchester [3] - 4055:6, 4055:9,

4055:13

mandated [1] - 3929:6

manner [3] - 3781:10, 3804:24, 3902:5

March [4] - 3901:12, 3947:7, 3947:14,

3947:16

march [1] - 3800:13

mark [4] - 3781:11, 3842:17, 3845:18,

3845:21

marked [6] - 3777:8, 3831:7, 3918:10,

3935:21, 4071:20, 4078:11

marker [1] - 3956:23

market [2] - 3810:18, 3810:19

marketable [1] - 3800:2

marketing [2] - 3798:21, 3890:3

markets [1] - 3851:12

marks [1] - 3881:24

marshal [1] - 3953:13

master's [5] - 4055:7, 4055:8,

4055:12, 4055:14, 4055:16

material [1] - 3841:12

materials [1] - 3785:19

math [1] - 3853:6

Mathurn [4] - 4062:22, 4063:2, 4065:4,

4065:6

mathurn [1] - 4065:1

Mathurn's [1] - 4062:23

matter [12] - 3886:9, 3904:6, 3911:21,

3916:16, 3953:18, 3955:7, 3961:16,

3987:25, 4038:18, 4041:19, 4091:5,

4092:5

matters [8] - 3827:2, 3878:6, 3901:18,

3919:15, 3920:4, 4007:24, 4009:11,

4009:18

Matters [1] - 3933:7

Mauricio [7] - 3920:6, 3922:23,

3926:21, 3931:1, 4037:20, 4040:18,

4046:19

McGuire [2] - 3774:6, 3774:6

mean [44] - 3806:11, 3812:7, 3812:14,

3813:19, 3845:2, 3865:13, 3872:8,

3887:13, 3887:16, 3913:7, 3934:4,

3934:23, 3953:13, 3955:10, 3955:11,

3955:12, 3957:1, 3958:13, 3959:25,

3962:25, 3968:20, 3970:16, 3970:18,

3970:20, 3982:22, 3991:9, 3995:7,

4002:9, 4003:11, 4012:22, 4026:23,

4031:5, 4032:16, 4032:19, 4034:6,

4035:10, 4039:13, 4043:1, 4049:25,

4066:3, 4066:12, 4077:1, 4077:14,

4090:20

means [5] - 3824:9, 3851:10, 3969:12,

4005:18, 4086:9

meant [2] - 3796:6, 4063:9

meanwhile [1] - 3892:17

mechanical [1] - 3774:14

media [2] - 4036:14, 4077:12

medical [2] - 4090:17, 4091:5

meet [3] - 3833:13, 3840:11, 4056:19

meeting [4] - 3784:13, 3785:17,

3786:2, 4060:25

meetings [3] - 3794:3, 3813:15,

3992:23

member [1] - 4060:3

members [2] - 4083:24, 4084:2

Memo [1] - 3940:8

memo [4] - 3940:11, 3941:3, 4004:17,

4071:7

memorandum [4] - 3936:17, 3936:19,

3941:7, 4074:25

memorized [1] - 3963:2

memory [2] - 3923:1, 4075:21

Memphis [2] - 3797:5, 3818:9

mention [3] - 3975:1, 3985:22,

3985:23

mentioned [11] - 3828:14, 3830:8,

3847:9, 3885:18, 3897:23, 3933:9,

3946:11, 3946:21, 4039:2, 4054:18,

4069:16

merchant [1] - 3990:3

merged [1] - 4058:23

mergers [1] - 3838:16

mess [1] - 3998:4

message [5] - 3921:2, 3932:1,

3949:17, 4023:6, 4033:24

messages [1] - 4022:17

met [6] - 3949:13, 3949:14, 4063:7,

4063:9, 4070:6, 4070:7

MI [1] - 4014:9

Miami [5] - 3786:2, 3883:19, 3888:12,

3888:13, 3933:25

Michael [2] - 3899:21, 3899:25

middle [4] - 3861:4, 3866:2, 3929:3,

3936:4

might [4] - 3778:4, 3831:21, 3913:18,

4007:6

Miguel [1] - 4080:7

mike [2] - 3825:22, 3858:25

mill [1] - 3932:2

million [35] - 3777:21, 3788:1, 3788:6,

3788:24, 3792:6, 3792:13, 3792:17,

3794:24, 3801:8, 3801:9, 3803:24,

3803:25, 3804:2, 3804:5, 3804:10,

3804:17, 3804:23, 3805:12, 3805:13,

3805:14, 3805:17, 3805:18, 3815:10,

3816:14, 3818:20, 3858:15, 3863:22,

3932:4, 3948:21, 3991:18, 4020:20,

4021:1

millions [4] - 3800:14, 3800:15,

3817:10

mind [10] - 3803:2, 3808:9, 3878:15,

3878:21, 3892:10, 3907:24, 3973:6,

3986:23, 3987:4, 4027:13

mine [2] - 3854:9, 3862:5

minefield [2] - 3938:20, 4025:22

minister [3] - 4061:1, 4061:25, 4062:5

Ministry [2] - 3937:3, 3937:8

minus [2] - 3911:2, 3947:18

minusing [1] - 3833:7

minute [16] - 3779:18, 3801:17,

3852:18, 3927:5, 3961:8, 3964:14,

3978:13, 3981:1, 3983:3, 3996:3,

3996:5, 4006:4, 4013:15, 4069:5,

4085:1, 4087:7

minutes [19] - 3777:4, 3854:16,

3857:25, 3858:6, 3910:24, 3910:25,

3911:15, 3912:2, 3914:22, 3938:18,

3997:3, 3997:8, 4040:14, 4044:23,

4068:20, 4068:22, 4084:20, 4091:10

mirror [2] - 3794:7, 3796:2

mirrors [3] - 3793:20, 3796:7, 3812:2

mischaracterization [3] - 4019:19,

4037:6, 4051:12

misled [1] - 3908:6

missed [2] - 3798:9, 3887:21

missing [1] - 3795:22

mission [1] - 4087:16

Mississippi [2] - 3785:12, 3801:16

misstatement [2] - 4029:3, 4083:3

misstates [1] - 3805:5

mistake [4] - 3913:6, 3937:18,


4115

3937:20, 4029:2

Mister [2] - 3885:19, 3930:23

mistrial [1] - 3778:11

mistrials [1] - 3778:12

MLAT [17] - 3847:14, 3847:15,

3859:12, 3971:14, 3971:15, 4021:8,

4042:5, 4042:23, 4042:25, 4049:2,

4049:4, 4049:7, 4049:23, 4049:24,

4050:13, 4051:8

MLATs [7] - 4042:1, 4042:2, 4042:10,

4044:24, 4045:5, 4048:16, 4048:18

mobile [3] - 3797:8, 3797:9

moment [4] - 3801:20, 3806:17,

3858:2, 4091:19

Monday [3] - 3785:10, 3868:19,

3938:15

money [82] - 3778:8, 3781:20,

3781:23, 3781:25, 3782:2, 3782:4,

3782:15, 3789:8, 3790:25, 3791:14,

3791:25, 3792:5, 3792:14, 3792:15,

3792:21, 3793:6, 3793:11, 3793:24,

3794:5, 3794:14, 3795:21, 3798:6,

3798:24, 3801:6, 3803:7, 3803:8,

3803:12, 3804:6, 3804:17, 3805:2,

3805:19, 3806:2, 3806:3, 3808:15,

3808:21, 3815:23, 3816:25, 3817:2,

3817:9, 3817:14, 3817:15, 3819:8,

3821:9, 3821:10, 3821:12, 3822:2,

3823:17, 3827:14, 3827:16, 3827:18,

3827:22, 3827:25, 3828:6, 3828:9,

3828:23, 3829:6, 3830:9, 3835:4,

3835:6, 3844:21, 3846:2, 3846:13,

3944:23, 3945:17, 3947:23, 3948:12,

3967:23, 3968:4, 3974:10, 3980:2,

3980:12, 3989:25, 3996:14, 3996:23,

3999:9, 4012:23, 4021:19, 4028:2,

4028:3, 4030:5, 4084:24

Money [1] - 3901:10

monies [2] - 3963:4, 4030:21

monitor [2] - 3935:7, 3935:8

monitoring [1] - 4054:10

month [6] - 3938:12, 3942:9, 3944:14,

3944:24, 4060:15, 4090:12

monthly [2] - 3791:25, 3839:17

months [7] - 3846:15, 3856:20,

3992:19, 3992:20, 4011:14, 4082:5

moon [1] - 3825:3

Moore [1] - 3899:21

morning [7] - 3783:24, 3822:24,

3826:6, 3826:7, 3881:4, 3891:20,

4091:12

most [12] - 3832:4, 3877:2, 3887:9,

3901:12, 3908:7, 3913:25, 3953:15,

3956:24, 3957:1, 3991:11, 4040:25,

4063:14

mostly [2] - 3827:4, 4063:19

mother [1] - 3970:24

motion [2] - 3917:25, 3918:4

MOU [5] - 3921:7, 3935:5, 3936:15,

3936:16, 3940:24

MOUs [1] - 4006:13

move [7] - 3865:3, 3865:5, 3902:11,

4001:1, 4008:15, 4010:16, 4059:7

movement [5] - 3828:1, 3828:6,

3828:11, 3828:17

moving [1] - 3783:6

MR [768] - 3775:5, 3775:7, 3775:9,

3775:11, 3775:13, 3775:15, 3775:17,

3775:21, 3775:23, 3775:25, 3776:2,

3776:4, 3776:6, 3776:8, 3776:10,

3776:14, 3777:6, 3778:1, 3778:2,

3778:7, 3778:13, 3778:15, 3778:22,

3778:24, 3778:25, 3779:4, 3779:11,

3779:14, 3779:17, 3779:20, 3779:21,

3779:25, 3780:5, 3780:8, 3780:12,

3780:16, 3780:18, 3780:19, 3780:20,

3781:3, 3781:6, 3781:14, 3781:24,

3782:10, 3782:13, 3782:17, 3782:20,

3782:23, 3783:2, 3783:11, 3783:15,

3783:18, 3783:21, 3784:1, 3784:5,

3784:8, 3784:20, 3785:23, 3786:1,

3786:24, 3787:1, 3788:10, 3788:13,

3788:16, 3788:20, 3788:23, 3789:2,

3789:7, 3789:18, 3789:20, 3789:23,

3790:1, 3790:21, 3794:18, 3794:20,

3795:12, 3795:13, 3795:16, 3796:3,

3796:5, 3797:22, 3797:23, 3798:7,

3798:10, 3798:12, 3798:14, 3798:18,

3799:19, 3799:21, 3800:6, 3800:9,

3801:14, 3801:19, 3802:2, 3802:4,

3802:6, 3802:8, 3802:10, 3802:11,

3802:13, 3802:18, 3802:20, 3803:13,

3803:15, 3804:14, 3804:16, 3805:5,

3805:10, 3806:15, 3806:23, 3807:1,

3807:8, 3808:2, 3808:4, 3808:12,

3808:14, 3810:1, 3810:6, 3810:7,

3810:11, 3810:13, 3810:15, 3810:21,

3810:23, 3810:25, 3811:2, 3811:3,

3811:6, 3811:13, 3811:15, 3813:1,

3813:4, 3814:25, 3815:3, 3815:5,

3815:25, 3816:2, 3816:5, 3816:8,

3816:10, 3816:20, 3816:24, 3817:6,

3818:2, 3818:5, 3818:6, 3818:23,

3819:1, 3819:11, 3819:13, 3819:19,

3819:25, 3820:12, 3821:4, 3821:6,

3821:8, 3821:19, 3821:24, 3822:5,

3822:7, 3822:18, 3822:23, 3823:1,

3823:9, 3823:12, 3823:15, 3823:19,

3823:21, 3823:25, 3824:4, 3824:5,

3824:7, 3824:8, 3824:10, 3824:14,

3824:16, 3824:20, 3824:23, 3825:1,

3825:10, 3825:14, 3826:5, 3826:14,

3832:1, 3832:3, 3835:20, 3835:22,

3835:25, 3836:2, 3836:6, 3836:7,

3837:14, 3837:16, 3838:1, 3838:3,

3838:18, 3838:19, 3839:7, 3839:9,

3840:13, 3840:14, 3841:5, 3841:7,

3842:6, 3842:7, 3842:25, 3843:1,

3843:14, 3843:18, 3843:19, 3843:22,

3843:23, 3844:9, 3844:11, 3844:16,

3844:17, 3845:10, 3845:12, 3845:24,

3846:1, 3846:7, 3846:9, 3849:17,

3849:18, 3849:19, 3849:21, 3851:1,

3851:19, 3851:20, 3852:21, 3852:23,

3853:8, 3853:10, 3853:12, 3853:24,

3853:25, 3854:12, 3854:16, 3854:19,

3854:24, 3854:25, 3856:1, 3856:3,

3856:11, 3856:25, 3857:1, 3857:22,

3858:10, 3858:12, 3859:5, 3859:18,

3859:19, 3860:9, 3860:11, 3860:20,

3860:22, 3861:3, 3861:5, 3862:8,

3862:10, 3863:1, 3863:2, 3864:2,

3864:3, 3864:15, 3864:18, 3864:21,

3864:23, 3865:1, 3865:5, 3865:9,

3865:11, 3865:15, 3865:22, 3866:1,

3866:3, 3866:11, 3866:15, 3866:17,

3866:21, 3867:7, 3867:11, 3867:17,

3867:19, 3868:5, 3868:8, 3869:2,

3869:5, 3869:14, 3869:16, 3870:10,

3870:11, 3870:15, 3870:17, 3870:20,

3870:22, 3871:2, 3871:4, 3871:17,

3871:18, 3871:24, 3871:25, 3872:5,

3872:18, 3872:22, 3872:24, 3873:8,

3873:12, 3873:14, 3874:2, 3874:4,

3874:14, 3874:16, 3875:7, 3875:8,

3876:2, 3876:5, 3876:6, 3876:25,

3877:1, 3877:5, 3877:9, 3877:11,

3878:8, 3878:11, 3878:23, 3878:25,

3879:12, 3879:14, 3879:17, 3879:19,

3880:4, 3880:5, 3880:9, 3880:12,

3881:25, 3882:2, 3882:16, 3882:19,

3883:7, 3883:8, 3884:20, 3884:22,

3885:24, 3886:3, 3886:5, 3886:12,

3886:20, 3886:24, 3887:1, 3887:2,

3887:3, 3887:5, 3887:8, 3887:15,

3887:18, 3887:24, 3888:2, 3890:11,

3890:21, 3890:23, 3891:10, 3891:21,

3891:23, 3891:25, 3892:7, 3892:8,

3893:7, 3893:8, 3893:13, 3893:14,

3893:22, 3895:21, 3895:23, 3895:24,

3896:15, 3896:18, 3898:2, 3898:4,

3898:20, 3898:22, 3898:25, 3899:2,

3900:1, 3900:3, 3900:22, 3900:24,

3901:14, 3901:21, 3902:7, 3902:16,

3902:17, 3903:8, 3903:10, 3903:16,

3903:22, 3904:1, 3904:20, 3904:21,

3905:6, 3905:7, 3905:24, 3906:4,

3906:8, 3906:11, 3906:19, 3906:22,

3907:1, 3907:6, 3907:13, 3907:21,

3908:2, 3908:5, 3908:9, 3908:10,

3908:11, 3908:13, 3908:21, 3908:25,

3909:3, 3909:4, 3909:10, 3909:20,

3909:25, 3910:2, 3910:9, 3910:13,

3910:18, 3910:20, 3911:3, 3911:4,

3911:6, 3911:21, 3912:3, 3912:6,

3912:9, 3912:18, 3912:20, 3912:22,

3913:3, 3913:7, 3913:12, 3913:17,

3913:23, 3914:2, 3914:7, 3914:12,

3914:15, 3914:24, 3915:2, 3915:18,

3915:19, 3916:8, 3916:12, 3916:21,

3917:20, 3917:25, 3918:7, 3918:9,

3918:21, 3918:24, 3919:5, 3919:7,

3919:11, 3919:14, 3919:17, 3920:9,

3920:11, 3920:17, 3922:25, 3924:13,

3924:15, 3925:9, 3925:10, 3925:20,

3925:22, 3926:2, 3926:4, 3928:8,

3928:9, 3929:23, 3929:24, 3930:4,

3930:6, 3930:8, 3930:10, 3930:16,

3930:18, 3931:14, 3931:16, 3932:22,


4116

3932:23, 3933:13, 3933:15, 3934:13,

3934:15, 3935:16, 3935:20, 3935:24,

3936:2, 3936:3, 3936:14, 3938:7,

3938:9, 3939:1, 3939:2, 3939:17,

3939:18, 3939:23, 3939:24, 3940:4,

3940:5, 3940:14, 3940:18, 3942:14,

3942:18, 3942:21, 3943:1, 3943:3,

3943:11, 3943:13, 3943:14, 3943:15,

3943:16, 3943:17, 3943:19, 3943:25,

3944:8, 3944:10, 3944:17, 3944:19,

3945:12, 3945:20, 3945:21, 3946:1,

3946:3, 3946:6, 3946:13, 3946:15,

3946:24, 3946:25, 3947:4, 3947:6,

3947:11, 3947:13, 3948:1, 3948:3,

3949:2, 3949:3, 3949:9, 3953:14,

3953:19, 3958:14, 3958:25, 3968:2,

3969:21, 3969:25, 3976:7, 3976:9,

3976:13, 3976:15, 3977:24, 3978:3,

3978:8, 3978:9, 3978:16, 3978:19,

3979:3, 3979:5, 3979:11, 3979:13,

3980:6, 3980:8, 3980:10, 3980:14,

3980:24, 3981:24, 3982:1, 3982:4,

3982:5, 3984:6, 3984:14, 3985:1,

3985:4, 3986:2, 3986:4, 3986:9,

3986:12, 3986:13, 3986:16, 3986:18,

3986:19, 3987:8, 3987:10, 3987:12,

3987:18, 3989:13, 3989:16, 3989:18,

3989:21, 3990:19, 3990:25, 3991:2,

3993:18, 3993:22, 3997:13, 3997:14,

3997:25, 3998:2, 4000:23, 4001:1,

4001:2, 4001:4, 4005:14, 4005:16,

4005:18, 4005:20, 4005:21, 4005:24,

4006:1, 4008:15, 4008:16, 4009:12,

4009:13, 4009:14, 4009:16, 4010:16,

4010:21, 4011:7, 4011:9, 4011:24,

4012:3, 4012:7, 4012:9, 4012:10,

4013:5, 4013:7, 4013:14, 4013:17,

4015:14, 4015:16, 4015:19, 4017:25,

4018:2, 4018:12, 4018:15, 4018:16,

4018:17, 4018:18, 4018:23, 4019:18,

4019:22, 4022:11, 4022:13, 4025:8,

4025:13, 4026:25, 4027:1, 4027:4,

4030:9, 4030:12, 4030:13, 4030:14,

4030:16, 4030:19, 4030:20, 4031:18,

4031:22, 4032:4, 4032:6, 4032:8,

4032:12, 4033:23, 4034:3, 4037:2,

4037:5, 4037:8, 4037:14, 4037:17,

4037:19, 4038:5, 4038:9, 4038:21,

4038:24, 4039:2, 4039:3, 4039:5,

4039:7, 4039:11, 4039:15, 4039:18,

4039:19, 4039:21, 4039:24, 4039:25,

4040:1, 4040:3, 4040:7, 4040:10,

4041:11, 4041:18, 4042:7, 4042:9,

4044:12, 4044:14, 4048:9, 4048:11,

4049:18, 4049:20, 4050:4, 4050:6,

4050:10, 4050:12, 4050:17, 4050:19,

4051:10, 4051:12, 4051:16, 4052:6,

4052:9, 4052:15, 4053:5, 4053:23,

4054:17, 4055:17, 4058:12, 4058:18,

4059:5, 4061:24, 4070:22, 4071:2,

4071:5, 4071:22, 4072:1, 4072:2,

4072:6, 4072:8, 4072:9, 4072:18,

4072:21, 4072:23, 4073:1, 4073:14,

4073:17, 4073:19, 4075:13, 4075:15,

4075:19, 4076:1, 4077:16, 4077:20,

4077:24, 4078:4, 4078:8, 4078:10,

4078:13, 4078:16, 4078:20, 4078:21,

4079:8, 4079:11, 4079:13, 4079:18,

4079:20, 4088:1, 4088:4, 4091:8,

4091:14

Mt [1] - 4053:15

multifarious [1] - 3976:3

multiple [9] - 3957:6, 3959:15,

3959:23, 3976:6, 3999:21, 4043:14,

4043:15, 4082:12

must [4] - 3842:20, 3842:21, 3931:23,

4057:13

mutual [1] - 3847:16

N

name [16] - 3826:9, 3826:10, 3826:12,

3830:21, 3843:11, 3895:6, 3929:13,

3949:10, 4011:21, 4053:7, 4053:8,

4062:23, 4065:20, 4067:22, 4076:20,

4080:13

named [4] - 3876:22, 3877:18, 3881:4,

4044:21

names [3] - 4016:22, 4027:8, 4084:1

National [1] - 4059:14

national [1] - 3782:6

nature [4] - 3783:15, 3959:22,

3977:25, 4012:5

near [1] - 4070:10

necessarily [1] - 3957:18

necessary [2] - 3828:21, 4087:4

need [18] - 3779:17, 3801:20, 3809:13,

3829:5, 3865:8, 3865:24, 3888:18,

3889:3, 3891:8, 3892:11, 3932:17,

3937:24, 3958:18, 3967:12, 3975:12,

3994:1, 4017:18, 4027:9

needed [4] - 3911:20, 3994:23,

3994:24, 4049:11

needs [3] - 3871:20, 3899:24, 3990:21

nefarious [4] - 3980:15, 3980:18,

3981:14, 3981:17

nervous [2] - 3953:5, 3953:8

never [30] - 3790:10, 3790:11,

3799:14, 3812:25, 3813:11, 3819:10,

3822:2, 3892:10, 3909:20, 3910:4,

3913:17, 3938:17, 3948:10, 3948:12,

3949:13, 3949:14, 3959:25, 3990:11,

4012:19, 4013:1, 4015:1, 4017:23,

4018:10, 4036:24, 4058:7, 4060:20,

4060:21, 4063:7, 4063:9

new [2] - 3866:7, 4058:24

New [3] - 3773:17, 3896:20, 4048:7

news [1] - 3881:22

next [40] - 3785:7, 3808:13, 3823:24,

3825:13, 3836:14, 3839:7, 3840:21,

3841:5, 3842:25, 3850:16, 3868:18,

3869:18, 3874:25, 3875:2, 3879:17,

3882:16, 3883:7, 3884:2, 3892:12,

3892:20, 3900:1, 3900:22, 3928:16,

3930:4, 3937:7, 3940:14, 3945:16,

3947:11, 3978:1, 3978:7, 3985:3,

3985:23, 4030:17, 4044:18, 4052:14,

4064:25, 4066:16, 4074:23, 4079:10,

4079:12

night [2] - 3963:15, 4070:8

nine [2] - 3921:8, 3972:10

nobody [1] - 3974:20

nobody's [1] - 4052:13

nonbank [1] - 4054:12

none [5] - 3780:16, 3780:18, 3805:14,

4012:19, 4029:3

nonpublic [1] - 3904:7

nonresponsive [4] - 3795:12,

3958:15, 4075:13, 4077:17

noon [1] - 3911:13

normal [2] - 4025:16, 4075:7

normally [3] - 3982:23, 4023:25,

4024:11

nose [1] - 4074:15

note [11] - 3871:16, 3899:18, 3926:3,

3931:15, 3948:14, 3969:15, 3979:15,

4032:18, 4073:6, 4090:24, 4091:22

noted [2] - 3853:14, 3853:21

notes [6] - 3853:16, 3889:17, 3930:14,

3930:17, 3930:19, 3948:4

Nothing [1] - 4052:9

nothing [21] - 3823:19, 3823:21,

3825:19, 3907:13, 3934:18, 3956:4,

3971:4, 3977:6, 3977:7, 3990:13,

3996:7, 4007:20, 4012:19, 4024:25,

4039:7, 4040:8, 4042:16, 4046:17,

4052:20, 4066:15, 4080:13

notice [4] - 3780:14, 3781:8, 3903:17,

3942:8

noticed [1] - 3953:16

notify [1] - 3958:1

nuclear [1] - 3822:23

Number [3] - 3810:17, 3953:12,

3953:14

number [60] - 3784:10, 3794:24,

3795:1, 3795:14, 3797:6, 3797:7,

3797:8, 3797:9, 3797:10, 3803:20,

3809:8, 3811:11, 3811:20, 3811:22,

3812:7, 3812:8, 3812:12, 3812:14,

3812:15, 3812:16, 3812:18, 3812:20,

3840:18, 3843:16, 3844:6, 3855:5,

3873:3, 3877:15, 3878:5, 3878:18,

3881:8, 3882:22, 3886:23, 3895:20,

3896:12, 3897:12, 3909:13, 3914:23,

3916:8, 3916:9, 3919:20, 3920:23,

3938:18, 3946:2, 4019:7, 4019:13,

4020:2, 4046:20, 4047:19, 4047:21,

4048:1, 4048:3, 4048:5, 4048:7,

4083:24

numbered [1] - 3935:19

numbers [26] - 3795:9, 3797:6,

3797:10, 3797:14, 3808:25, 3809:4,

3812:3, 3812:4, 3812:5, 3812:6,

3822:8, 3822:11, 3822:16, 3894:24,

3896:12, 3897:12, 3897:13, 3897:17,

3897:21, 3932:3, 3974:8, 3988:8,

3997:16, 4026:5, 4047:24

numerals [1] - 3894:10Johnny C. Sanchez, RMR, CRR - [email protected]

4117

numerous [1] - 3965:8

NW [1] - 3773:17

O

oath [1] - 4090:5

Object [1] - 4005:14

object [37] - 3788:16, 3823:12, 3887:4,

3903:11, 3916:8, 3919:11, 3958:14,

3969:21, 3976:13, 3977:24, 3980:6,

3981:24, 4005:20, 4011:24, 4012:3,

4012:5, 4018:12, 4019:18, 4030:9,

4037:4, 4037:5, 4037:14, 4040:5,

4041:11, 4049:18, 4051:10, 4072:21,

4072:23, 4075:13, 4077:16, 4077:24,

4078:8, 4078:17, 4079:5, 4079:17,

4088:1

objected [2] - 3779:2, 3908:22

objection [31] - 3778:9, 3781:9,

3788:10, 3789:2, 3795:12, 3795:15,

3796:3, 3805:5, 3806:15, 3806:23,

3807:6, 3810:1, 3810:11, 3816:20,

3817:5, 3818:23, 3819:19, 3823:9,

3865:24, 3886:10, 3887:14, 3887:19,

3903:25, 3912:11, 3916:14, 3993:20,

4012:4, 4018:21, 4041:14, 4072:2,

4079:9

objections [4] - 3777:16, 4012:4,

4071:22, 4078:13

obligated [4] - 3960:7, 3960:10,

3960:11, 3960:14

obligation [2] - 3958:9, 3959:14

obstruct [1] - 3787:4

obstructing [1] - 3787:8

obstruction [6] - 3787:3, 3903:18,

3907:14, 3907:19, 3908:5, 3912:10

obtain [14] - 3830:8, 3835:2, 3837:5,

3846:25, 3876:14, 3893:3, 3895:8,

3926:24, 3943:11, 3944:1, 4012:12,

4014:3, 4017:20, 4028:23

obtained [19] - 3828:2, 3828:12,

3831:4, 3832:4, 3836:15, 3851:21,

3885:19, 3898:5, 3933:10, 3973:10,

4005:4, 4006:16, 4017:22, 4042:2,

4049:17, 4050:14, 4051:9, 4051:23,

4059:10

obtaining [4] - 3925:23, 3971:13,

4005:4, 4017:2

obvious [1] - 4013:18

obviously [5] - 3780:25, 3786:6,

3824:23, 4007:12, 4079:9

occasion [2] - 3854:5, 4082:5

occasions [1] - 3875:15

occupation [2] - 3826:15, 3834:4

occur [3] - 4084:8, 4090:9, 4090:13

occurring [1] - 4004:4

occurs [1] - 4083:14

October [2] - 3856:5, 3904:5

OF [2] - 3773:1, 3773:4

off-site [5] - 4083:18, 4084:7, 4084:10,

4085:7

offer [22] - 3780:1, 3781:4, 3781:14,

3781:17, 3782:16, 3783:11, 3872:2,

3886:12, 4052:13, 4065:11, 4066:13,

4067:14, 4069:1, 4069:12, 4070:3,

4070:12, 4070:13, 4070:15, 4071:13,

4072:19, 4073:14, 4076:17

offered [8] - 3779:6, 3779:25, 3881:12,

3882:14, 3909:4, 3912:12, 3981:1,

4067:6

offering [2] - 4069:7, 4069:22

office [24] - 3797:2, 3797:7, 3797:9,

3877:23, 3877:25, 3882:5, 3886:15,

3886:17, 3888:7, 3888:8, 3888:9,

3889:1, 3890:12, 3949:15, 3957:2,

4035:3, 4035:7, 4035:12, 4035:15,

4035:17, 4047:21, 4048:17

Office [1] - 4081:10

officer [7] - 3808:19, 3872:16,

3951:21, 3952:24, 3952:25, 3957:2

officers [3] - 3904:10, 3951:24,

3951:25

offices [5] - 3797:5, 3897:6, 3905:23,

3917:3, 3929:14

official [1] - 3872:11

offsetting [1] - 3872:3

offshore [17] - 3937:9, 3937:12,

3937:14, 3938:4, 3999:14, 3999:17,

3999:20, 3999:21, 3999:24, 4019:10,

4029:25, 4030:6, 4030:23, 4054:11,

4054:18, 4054:19, 4083:11

often [1] - 3796:12

old [4] - 3840:11, 3921:1, 4048:21,

4053:10

on-site [3] - 4082:6, 4084:11, 4084:13

once [11] - 3780:12, 3788:6, 3788:14,

3845:21, 3871:9, 3949:15, 3973:18,

3983:13, 3995:7, 4042:16

one [131] - 3777:24, 3778:13, 3779:21,

3780:2, 3783:1, 3786:2, 3787:2,

3787:4, 3787:11, 3788:2, 3789:19,

3794:2, 3796:11, 3802:24, 3804:3,

3804:5, 3804:11, 3805:13, 3806:3,

3806:16, 3806:18, 3808:21, 3808:24,

3815:22, 3817:25, 3820:25, 3827:25,

3831:24, 3838:24, 3840:16, 3840:17,

3840:23, 3842:8, 3843:16, 3845:6,

3845:20, 3846:8, 3847:17, 3854:16,

3855:12, 3860:21, 3860:24, 3861:8,

3861:23, 3862:9, 3865:3, 3867:9,

3867:10, 3869:2, 3874:9, 3876:1,

3879:9, 3883:7, 3885:25, 3886:4,

3887:10, 3887:20, 3887:21, 3891:19,

3892:6, 3897:9, 3902:11, 3907:14,

3907:19, 3909:10, 3914:5, 3916:9,

3917:20, 3927:17, 3931:3, 3941:23,

3945:3, 3945:16, 3948:7, 3948:14,

3953:17, 3956:15, 3956:16, 3957:9,

3957:13, 3959:10, 3960:23, 3967:2,

3967:22, 3967:25, 3972:15, 3972:22,

3972:23, 3974:4, 3975:24, 3976:1,

3976:6, 3985:3, 3988:4, 3988:5,

3989:5, 3989:7, 3991:3, 3991:5,

3994:9, 3996:10, 3996:12, 3999:20,

3999:24, 4007:5, 4011:21, 4029:6,

4029:11, 4033:17, 4043:10, 4043:22,

4044:18, 4045:16, 4047:17, 4054:19,

4058:4, 4058:6, 4059:12, 4063:3,

4067:12, 4079:3, 4079:22, 4080:17,

4086:25, 4089:17

One's [1] - 4079:6

ones [9] - 3827:4, 3827:5, 3887:23,

3907:17, 3963:2, 3972:9, 3987:16,

4000:7, 4003:16

online [1] - 3893:24

op [1] - 3921:10

open [3] - 3791:24, 4013:19, 4022:8

opened [5] - 3838:11, 3838:15,

3943:8, 3943:10, 3944:6

opening [3] - 3810:4, 4061:3, 4084:22

operate [2] - 3926:17, 4059:21

operating [5] - 3790:17, 3791:22,

3792:1, 3925:1, 3929:9

operations [2] - 3900:17, 3901:4

opinion [4] - 3902:4, 4004:12, 4051:8,

4051:13

opportunity [4] - 3777:15, 3824:17,

4060:21, 4061:8

opposed [1] - 4083:7

opposing [2] - 3929:15, 3929:18

opposite [1] - 3794:3

option [2] - 3915:10, 3915:14

options [5] - 3892:19, 3909:19,

3910:15, 3910:16, 3910:17

Orchestra [6] - 3871:10, 3871:13,

3871:19, 3873:9, 3873:22, 3875:4

order [15] - 3830:8, 3830:10, 3830:12,

3831:4, 3903:14, 3904:7, 3904:8,

3917:14, 3941:25, 3963:21, 3969:19,

3971:5, 3993:25, 3994:3, 4087:17

ordered [6] - 3777:16, 3781:1, 3894:4,

3894:6, 3942:2, 4012:1

orders [2] - 3970:13, 3993:14

ordinary [1] - 4067:9

organization [4] - 3790:17, 3797:19,

4056:10, 4083:24

Original [1] - 3984:9

original [3] - 3899:21, 4033:24, 4082:1

originally [1] - 4053:12

originating [1] - 3921:7

otherwise [1] - 4015:4

ought [2] - 3907:7, 4008:7

outcome [1] - 4073:7

outlined [1] - 3900:12

outlining [1] - 4075:4

outside [11] - 3787:20, 3787:24,

3828:3, 3833:11, 3833:12, 3904:12,

4027:9, 4047:13, 4076:4, 4076:10,

4086:4

overhead [3] - 3784:18, 3803:14,

3865:9

overkill [1] - 3931:21

overrule [6] - 3795:15, 3807:6, 3817:5,

3887:14, 3903:25, 4041:14

overruled [16] - 3788:12, 3807:6,

3816:4, 3821:21, 3918:1, 3918:6,

3919:13, 3978:1, 4019:20, 4040:8,


4118

4050:11, 4073:18, 4078:2, 4079:19,

4088:3

Overseas [7] - 3848:4, 3848:17,

3848:21, 3849:5, 3945:19, 3946:10,

3947:2

overseas [1] - 3834:1

oversees [1] - 3833:9

overwhelmingly [2] - 3823:7, 3823:16

own [9] - 3794:11, 3800:16, 3907:5,

3922:15, 3926:18, 3939:8, 3976:24,

3998:16, 4061:22

owned [13] - 3790:18, 3792:16,

3792:20, 3792:22, 3823:5, 3859:25,

3923:16, 3925:17, 3969:20, 4021:15,

4045:1, 4045:3, 4075:9

owner [6] - 3796:12, 3925:17, 3970:4,

3970:6, 3998:24

ownership [2] - 3924:8, 3925:14

owning [2] - 4045:7, 4054:9

owns [3] - 3970:7, 3976:23, 4076:11

P

p.m [3] - 3911:17, 3997:10, 4091:24

Pacheco [1] - 4080:7

package [2] - 3931:24, 3943:5

PAGE [1] - 3775:2

Page [43] - 3779:20, 3838:18, 3839:7,

3840:13, 3841:5, 3851:19, 3852:21,

3853:24, 3860:9, 3860:20, 3862:8,

3866:2, 3866:16, 3867:8, 3867:18,

3868:5, 3869:4, 3869:15, 3870:15,

3874:2, 3890:21, 3891:23, 3924:13,

3924:14, 3925:20, 3927:22, 3928:8,

3929:23, 3930:5, 3931:11, 3932:12,

3932:22, 3935:16, 3938:7, 3940:4,

3944:17, 3944:23, 3945:3, 3946:24,

3947:5, 3948:2, 3989:14, 4010:17

page [35] - 3800:6, 3813:2, 3832:7,

3832:9, 3833:16, 3834:8, 3840:21,

3841:6, 3842:25, 3861:3, 3873:12,

3876:25, 3877:6, 3878:9, 3878:24,

3880:9, 3880:11, 3881:25, 3886:1,

3900:2, 3901:6, 3901:15, 3903:9,

3928:16, 3928:20, 3930:4, 3940:14,

3947:11, 3947:25, 3985:3, 4010:19,

4072:12, 4072:18, 4074:23, 4081:18

pages [6] - 3921:7, 3921:8, 3921:12,

3931:7, 3943:10

paid [14] - 3835:4, 3835:6, 3836:12,

3846:21, 3846:22, 3857:17, 3995:23,

3996:8, 4060:13, 4060:14, 4060:16,

4060:17, 4060:18, 4087:25

Panorama [1] - 3871:11

Panthers [1] - 3875:22

paper [25] - 3793:7, 3799:11, 3808:25,

3809:4, 3814:7, 3814:8, 3976:22,

3977:1, 3977:4, 3978:11, 3978:12,

3978:14, 3981:22, 3982:25, 3983:3,

3991:10, 4020:7, 4020:11, 4020:17,

4040:22, 4041:2, 4041:10, 4064:10,

4066:14

papers [2] - 3780:4, 3780:8

paperwork [1] - 3982:15

Paragraph [1] - 3931:18

paragraph [13] - 3871:3, 3871:8,

3900:9, 3900:22, 3901:6, 3901:15,

3925:21, 3929:1, 3929:3, 3933:4,

3934:13, 4080:14, 4080:25

paragraphs [1] - 3901:22

parameter [1] - 3965:23

pardon [2] - 3893:19, 3911:5

Parras [1] - 3774:2

part [41] - 3777:14, 3779:5, 3807:14,

3829:9, 3829:22, 3829:24, 3830:15,

3833:14, 3840:22, 3871:2, 3871:11,

3892:5, 3894:12, 3895:21, 3895:22,

3905:21, 3912:9, 3917:2, 3935:7,

3940:16, 3943:5, 3979:7, 3981:18,

3982:16, 3982:22, 4002:12, 4010:22,

4014:9, 4026:5, 4026:6, 4029:1,

4033:9, 4033:21, 4059:7, 4061:11,

4063:22, 4067:6, 4079:10, 4079:12,

4087:5, 4089:6

participated [1] - 4090:4

participating [1] - 3804:9

particular [13] - 3807:13, 3810:18,

3828:23, 3829:10, 3831:12, 3848:10,

3974:1, 3985:8, 4015:1, 4029:14,

4033:17, 4076:9, 4083:11

particulars [1] - 3862:14

parts [2] - 4012:17, 4077:8

party [2] - 4015:9, 4070:8

pass [15] - 3786:21, 3804:14, 3814:25,

3819:11, 3821:4, 3822:5, 3822:18,

3949:2, 4017:25, 4026:25, 4044:12,

4048:9, 4050:4, 4050:17, 4052:6

passed [1] - 4028:25

past [3] - 3890:19, 3937:21, 3999:17

Patricia [2] - 3984:20, 3984:21

Patriots [2] - 3875:22, 3876:3

pattern [1] - 3961:13

Paul [4] - 4044:21, 4052:16, 4053:7

PAUL [2] - 3776:12, 4053:1

pause [1] - 3806:19

Pavilion [2] - 4070:8, 4070:10

pay [12] - 3824:6, 3827:6, 3873:9,

3889:8, 3980:2, 3980:16, 3987:19,

4030:6, 4069:21, 4069:24

Pay [1] - 3873:1

paying [2] - 3973:1, 4027:20

payments [1] - 3979:25

payroll [6] - 4026:19, 4026:23,

4027:14, 4027:18, 4027:19

pays [1] - 4069:21

peace [5] - 3951:21, 3951:24, 3951:25,

3952:24, 3952:25

Pendergest [1] - 4011:2

pending [3] - 3825:18, 3903:19,

4039:16

penny [2] - 3788:14, 3788:25

people [39] - 3794:5, 3812:17, 3814:6,

3827:2, 3827:4, 3827:5, 3827:6,

3829:2, 3851:14, 3861:22, 3877:15,

3878:19, 3881:18, 3881:20, 3903:13,

3943:24, 3953:7, 3953:10, 3954:2,

3975:10, 3983:10, 3987:13, 3989:3,

3990:20, 4015:8, 4015:9, 4016:25,

4021:20, 4021:24, 4021:25, 4022:1,

4026:19, 4027:9, 4031:24, 4034:7,

4034:10, 4044:9, 4047:2, 4056:7

people's [3] - 4036:17, 4036:18,

4089:11

per [9] - 3801:8, 3860:25, 3861:11,

3862:15, 3869:8, 3873:1, 3889:3,

3928:13, 4060:15

percent [15] - 3800:1, 3818:13, 3819:7,

3848:23, 3970:4, 3970:7, 3974:12,

3974:14, 3977:9, 3977:10, 3977:13,

3998:24, 4049:1

Perfect [1] - 3946:3

perfect [4] - 3861:4, 3867:8, 3877:10,

3933:14

perfectly [2] - 3815:20, 4025:16

perhaps [3] - 3872:11, 3912:6, 3913:1

period [11] - 3814:9, 3835:12, 3850:7,

3851:16, 3858:16, 3896:5, 3941:19,

4076:22, 4077:6, 4077:9

person [3] - 4043:22, 4063:14, 4069:2

Personal [1] - 3887:12

personal [22] - 3791:1, 3800:16,

3816:13, 3822:1, 3859:3, 3859:7,

3860:13, 3863:4, 3870:7, 3873:16,

3874:1, 3874:24, 3877:22, 3885:12,

3887:9, 3888:6, 3890:6, 3890:7,

3895:19, 3921:11, 3989:23, 4057:14

personally [8] - 3824:7, 4001:18,

4003:1, 4015:25, 4016:3, 4016:7,

4021:20, 4049:8

personnel [1] - 3836:20

perspective [1] - 3794:1

pesos [1] - 3851:14

petty [3] - 3991:17, 4020:23, 4021:1

Ph.D [1] - 4055:1

Phoenix [1] - 4054:25

phone [4] - 3881:3, 3897:13, 3949:14,

4047:19

phony [3] - 3808:25, 3809:4, 3811:20

photographs [1] - 4016:6

phrased [1] - 3915:11

phraseology [2] - 3915:6, 3915:15

physical [2] - 4084:13, 4086:16

pick [2] - 3894:25, 4067:2

picked [2] - 4067:3, 4068:18

pie [1] - 3786:2

piece [8] - 3894:23, 3994:14, 3994:25,

4014:23, 4015:3, 4035:18, 4066:14

place [13] - 3790:6, 3790:8, 3791:5,

3792:18, 3792:25, 3793:14, 3814:20,

3814:22, 3828:16, 3833:2, 4035:16,

4084:5, 4087:4

placed [1] - 3919:24

places [1] - 3841:24

plan [2] - 3813:3, 3911:13

plans [1] - 3814:4

planted [1] - 4078:5


4119

platforms [1] - 3926:17

played [1] - 3875:21

playing [1] - 4032:8

Pleasant [1] - 4053:15

pleasure [1] - 3899:22

pled [3] - 3785:6, 3787:3, 3823:8

plenty [1] - 3783:4

plus [2] - 3846:15, 4022:1

PO [2] - 3773:14, 3774:7

pocket [3] - 3804:25, 3805:16,

3805:17

pocketed [2] - 3781:20, 3782:14

point [25] - 3794:9, 3805:12, 3812:22,

3815:19, 3824:24, 3887:17, 3909:8,

3912:15, 3914:5, 3914:9, 3939:13,

3971:21, 3974:7, 3985:10, 3987:12,

3990:16, 4014:3, 4023:2, 4032:2,

4033:8, 4034:15, 4034:19, 4034:23,

4044:25, 4090:22

pointed [1] - 3807:15

pointing [10] - 3798:8, 3798:10,

3798:15, 3807:18, 3807:20, 3807:22,

3807:24, 3808:1, 3808:7, 3808:15

points [3] - 3813:13, 3813:25, 3814:10

policies [3] - 3840:10, 3951:19,

4084:17

policy [1] - 4038:14

pond [3] - 3786:4, 3801:16, 3802:24

ponder [2] - 3910:9, 3910:11

portfolio [6] - 3800:4, 3916:1, 3916:7,

3916:23, 4045:25, 4083:21

portion [8] - 3800:8, 3843:5, 3859:20,

3872:23, 3886:2, 3894:6, 3896:3,

3933:14

portions [1] - 3898:3

position [31] - 3872:12, 3881:11,

3888:23, 3906:14, 3907:6, 3907:12,

3912:6, 3912:23, 3927:6, 4033:2,

4036:16, 4038:4, 4039:22, 4053:19,

4054:2, 4059:10, 4059:14, 4060:7,

4062:1, 4062:20, 4063:25, 4064:19,

4065:12, 4066:9, 4069:7, 4069:18,

4069:22, 4069:23, 4070:2, 4071:13,

4073:22

positions [1] - 4064:2

positively [1] - 3931:23

possibility [2] - 3785:7, 4067:21

possible [3] - 3901:25, 4026:4, 4026:5

Postal [1] - 3992:6

postal [3] - 4016:19, 4016:24, 4017:11

posted [1] - 3891:16

pounds [2] - 3851:13, 3851:14

PowerPoint [1] - 3856:10

powers [1] - 3921:10

practice [2] - 4060:19, 4075:7

practices [1] - 4059:21

Praveen [2] - 4076:20, 4076:21

predicate [1] - 3916:18

prefer [1] - 3931:4

premises [1] - 3917:11

prepare [2] - 3812:1, 3835:16

prepared [3] - 3781:17, 3784:22,

3836:3

prepares [1] - 4057:24

preparing [3] - 3835:15, 3835:17,

3871:10

presence [7] - 3777:1, 3858:4, 3858:9,

3911:10, 3911:18, 3918:8, 4040:9

presentations [1] - 3794:4

presently [3] - 4053:14, 4053:17,

4062:12

president [1] - 4080:8

Preston [1] - 3774:3

presumably [1] - 3935:7

presume [1] - 4014:10

pretty [5] - 3842:2, 3949:12, 3968:19,

3983:14, 4005:9

prevailing [1] - 3935:10

prevent [3] - 3828:16, 4088:21, 4089:5

Prevention [2] - 3901:10, 3901:11

previous [6] - 3813:13, 3836:18,

3836:19, 3840:12, 3871:12, 3887:25

previously [6] - 3795:9, 3806:7,

3874:10, 3919:5, 3935:21, 4000:24

price [2] - 3883:25, 3894:21

pricing [1] - 3878:16

prima [2] - 4086:9

primary [1] - 4046:24

printed [4] - 3841:11, 3988:13,

3988:19

prison [1] - 3785:7

private [3] - 3794:11, 3817:9, 3904:9

privately [2] - 3790:19, 3817:19

privately-held [2] - 3790:19, 3817:19

privilege [1] - 3784:22

privileged [1] - 3784:21

probable [1] - 3951:12

probate [3] - 3780:4, 3780:7, 3780:8

problem [7] - 3783:19, 3906:11,

3907:8, 3913:11, 3913:14, 4062:16,

4071:25

problems [3] - 3797:17, 3971:13,

4028:6

procedure [5] - 3781:10, 4039:16,

4051:22, 4052:5, 4052:8

procedures [4] - 3951:19, 4051:2,

4084:18, 4084:22

proceed [3] - 3781:10, 3858:10,

3949:3

proceeding [1] - 3907:10

proceedings [1] - 4092:4

Proceedings [1] - 3774:14

process [9] - 3859:10, 3859:13,

3971:16, 4021:8, 4045:11, 4046:7,

4056:25, 4057:12, 4080:21

produce [8] - 3847:20, 3893:25,

3905:2, 3905:4, 4011:22, 4011:23,

4042:17, 4046:9

produced [9] - 3774:14, 3779:5,

3848:15, 3849:14, 3859:15, 4042:24,

4043:1, 4045:8, 4046:4

producing [1] - 4045:11

production [1] - 3848:23

productive [1] - 3939:10

professional [3] - 3952:15, 3952:17,

4056:6

professionally [1] - 4056:2

professionals [1] - 4007:12

profit [1] - 4083:23

profited [1] - 3823:7

profusely [1] - 4065:1

program [1] - 3899:15

progression [1] - 4056:16

prohibitions [2] - 4076:2, 4076:6

project [4] - 3791:5, 3812:24, 3813:24,

3814:22

projector [2] - 3896:17, 4022:12

projects [2] - 3793:25, 3794:16

promise [1] - 3956:18

promised [1] - 3882:12

promote [1] - 3828:6

promoting [2] - 3794:4, 3828:4

pronounce [1] - 4061:11

pronounced [1] - 4061:17

pronunciations [1] - 4061:22

proof [3] - 3996:13, 3996:23, 3996:25

proper [3] - 4051:22, 4052:5, 4052:7

properly [1] - 4087:12

proposal [1] - 3939:7

propose [1] - 3781:3

proposed [6] - 3780:14, 3793:19,

3794:22, 3936:15, 3940:24, 3941:6

Proscauer [1] - 3903:1

prosecution [1] - 3778:19

prosecutor [14] - 3820:3, 3964:16,

3968:11, 3988:8, 4004:14, 4008:18,

4031:5, 4032:20, 4032:22, 4034:16,

4035:24, 4037:12, 4048:13, 4051:5

prosecutor's [1] - 4031:8

protected [1] - 4004:2

protecting [2] - 4089:11, 4089:14

protections [2] - 3828:16, 3929:11

prove [2] - 3779:23, 3802:10

proved [3] - 3886:9, 3886:13, 3886:14

proven [1] - 3782:1

provide [12] - 3847:18, 3876:19,

3882:14, 3925:11, 3995:2, 4011:21,

4012:1, 4015:7, 4069:19, 4083:20,

4083:21, 4086:11

provided [10] - 3784:22, 3823:16,

3829:16, 3973:9, 3973:14, 4049:24,

4056:7, 4079:15, 4085:6, 4086:12

provides [1] - 3929:9

providing [1] - 3928:17

public [3] - 3794:1, 4019:5, 4019:12

publicly [1] - 4038:21

publish [2] - 4071:23, 4078:14

pull [9] - 3825:22, 3858:25, 3867:10,

3978:16, 3985:24, 3985:25, 3986:2,

4000:23, 4031:18

pulled [1] - 3953:17

pulse [1] - 3796:16

punch [1] - 3931:4

purchase [4] - 3883:6, 3893:4,

3893:15, 3895:11

purchased [3] - 3889:5, 3896:7,Johnny C. Sanchez, RMR, CRR - [email protected]

4120

3990:15

purchases [3] - 3875:11, 3985:16

purple [1] - 3956:23

purport [1] - 3979:22

purported [1] - 4066:6

purporting [1] - 4066:5

purpose [4] - 3804:23, 3805:15,

3835:15, 3903:24

purposes [5] - 3790:3, 3833:10,

3839:16, 3846:4, 3887:17

pursuant [1] - 3847:21

pushed [1] - 4091:2

put [39] - 3777:7, 3777:17, 3778:9,

3780:6, 3781:12, 3794:4, 3808:25,

3809:4, 3811:22, 3812:5, 3812:6,

3812:8, 3812:10, 3812:12, 3812:17,

3813:20, 3814:4, 3814:22, 3819:17,

3822:10, 3824:15, 3836:17, 3852:24,

3857:17, 3866:11, 3884:8, 3889:17,

3907:18, 3951:5, 3952:5, 3974:8,

3983:14, 3990:17, 3999:9, 4004:14,

4034:25, 4043:9, 4082:11

puts [2] - 3906:13, 3907:10

putting [5] - 3814:7, 3814:8, 3968:18,

3989:24, 4038:13

Q

quadrupled [2] - 3792:8, 3792:10

qualification [1] - 4056:7

qualifications [2] - 4071:8, 4071:14

quality [1] - 3932:2

quarterly [5] - 4083:19, 4083:20,

4084:8, 4084:15, 4085:7

query [1] - 3881:16

questioned [5] - 3777:21, 3778:10,

3800:23, 3801:2, 4038:18

questioning [4] - 3782:24, 3990:22,

4037:1, 4040:6

questions [41] - 3777:10, 3777:18,

3778:18, 3784:10, 3784:11, 3785:2,

3787:6, 3787:10, 3787:15, 3789:11,

3789:12, 3789:21, 3796:9, 3815:6,

3819:14, 3819:16, 3822:21, 3912:17,

3913:1, 3913:10, 3915:10, 3975:12,

3975:22, 3976:6, 4018:4, 4018:11,

4018:24, 4020:2, 4020:8, 4020:21,

4022:3, 4022:7, 4023:14, 4038:16,

4040:1, 4044:15, 4046:19, 4046:20,

4047:17, 4063:18

quick [3] - 3905:25, 3912:3, 3917:20

quite [3] - 3897:3, 4065:1, 4088:17

quote [1] - 3792:5

R

raise [5] - 3825:16, 3980:11, 4010:4,

4010:6, 4052:17

raised [1] - 3901:19

raises [1] - 3981:6

Ralph [1] - 4010:25

Ramsey [2] - 4067:23, 4067:24

ran [1] - 3823:2

range [1] - 4047:2

RAS [18] - 3861:16, 3873:1, 3873:2,

3873:4, 3882:11, 3882:12, 3882:22,

3884:10, 3919:15, 3919:18, 3920:4,

3933:7, 3938:6, 3938:21, 3939:22,

3979:20, 3979:23, 4032:10

rate [5] - 3801:5, 3801:6, 3850:18,

3851:9, 3851:15

rather [2] - 4021:19, 4075:20

Razor [5] - 3893:18, 3893:23, 3893:25,

3895:25, 3896:3

razor [1] - 3893:20

reach [1] - 3809:13

reaching [2] - 3797:18, 3809:16

reaction [3] - 3881:22, 4025:4,

4025:23

read [23] - 3790:2, 3806:17, 3806:20,

3806:22, 3841:12, 3861:10, 3871:8,

3888:22, 3890:25, 3900:11, 3916:17,

3929:4, 3931:17, 3936:24, 3986:15,

4010:24, 4033:9, 4074:6, 4075:20,

4075:22, 4075:23, 4090:6

reading [1] - 3935:4

reads [3] - 3878:14, 3901:24, 3921:3

ready [3] - 3783:25, 3857:25, 3911:16

real [16] - 3793:11, 3794:16, 3812:4,

3812:7, 3812:12, 3812:20, 3817:23,

3818:18, 3818:20, 3905:24, 3912:3,

3917:20, 4010:18, 4067:5, 4074:16

realize [1] - 3939:5

realized [1] - 3777:13

really [17] - 3788:8, 3849:1, 3849:15,

3872:10, 3884:9, 3892:19, 3907:17,

3952:13, 3958:21, 3990:12, 4011:18,

4032:9, 4063:22, 4066:19, 4066:22,

4071:17, 4087:13

reason [12] - 3909:21, 3913:21,

3913:22, 3993:11, 4041:24, 4042:21,

4042:22, 4049:16, 4049:22, 4049:25,

4050:2, 4050:13

receipt [2] - 3893:4, 3899:20

receive [4] - 3804:8, 4015:22, 4049:10,

4051:7

received [13] - 3786:21, 3803:3,

3804:12, 3860:19, 3861:12, 3861:22,

3862:18, 3882:22, 3883:1, 3885:20,

3900:7, 3975:10, 4071:13

receiver [35] - 3782:5, 3876:15,

3876:18, 3917:6, 3917:9, 3917:10,

3917:15, 3918:2, 3941:25, 3942:1,

3942:3, 3942:6, 3942:10, 3944:14,

3944:24, 3945:8, 3948:20, 3992:14,

3992:21, 3993:25, 3994:19, 3995:1,

4001:16, 4001:17, 4001:20, 4011:1,

4011:8, 4011:10, 4011:14, 4011:22,

4012:1, 4012:12, 4013:19, 4014:11

receiving [6] - 3829:17, 3880:13,

3933:16, 3946:10, 4065:11, 4087:24

recent [3] - 3832:4, 3901:12, 3901:19

recently [1] - 3954:8

recess [1] - 4091:23

Recessed [4] - 3858:3, 3911:17,

3997:10, 4091:24

recipient [1] - 4022:17

recognition [1] - 4074:20

recognize [13] - 3802:5, 3802:14,

3831:8, 3876:7, 3918:11, 3943:4,

4072:10, 4072:11, 4072:12, 4072:14,

4072:15, 4078:22, 4079:2

recollect [1] - 4027:10

recommendation [1] - 4056:18

record [24] - 3780:6, 3781:17,

3782:12, 3783:3, 3783:4, 3817:25,

3841:1, 3841:8, 3842:8, 3843:2,

3851:21, 3851:25, 3858:2, 3870:16,

3908:25, 3915:13, 3918:5, 3944:9,

3981:19, 3981:22, 4062:23, 4071:3,

4071:4, 4092:4

recorded [1] - 3774:14

records [120] - 3786:15, 3787:21,

3800:13, 3817:24, 3818:9, 3818:13,

3818:17, 3819:2, 3821:15, 3829:10,

3829:15, 3829:23, 3830:6, 3830:9,

3830:10, 3831:17, 3831:20, 3835:2,

3836:4, 3836:20, 3837:1, 3837:2,

3837:5, 3837:8, 3840:2, 3840:6,

3840:8, 3840:12, 3842:3, 3843:9,

3844:1, 3846:23, 3846:25, 3847:12,

3847:14, 3847:20, 3847:25, 3848:11,

3848:15, 3848:17, 3848:18, 3849:3,

3849:11, 3849:13, 3850:12, 3853:21,

3855:7, 3857:6, 3857:9, 3857:11,

3858:17, 3859:6, 3859:11, 3859:15,

3859:21, 3863:13, 3864:23, 3866:12,

3866:16, 3870:5, 3874:9, 3875:9,

3899:25, 3905:3, 3905:4, 3907:3,

3917:12, 3943:20, 3943:24, 3945:23,

3948:5, 3948:13, 3962:7, 3966:3,

3970:25, 3971:1, 3971:13, 3971:25,

3973:10, 3977:11, 3977:17, 3977:19,

3977:20, 3979:7, 3982:19, 3982:25,

3983:4, 3993:1, 3993:2, 3993:7,

3993:9, 3995:25, 3996:6, 3996:7,

4013:23, 4014:2, 4014:3, 4014:5,

4014:6, 4014:8, 4016:3, 4016:7,

4020:3, 4021:7, 4021:13, 4021:16,

4041:25, 4045:7, 4045:12, 4045:19,

4045:21, 4046:4, 4046:16, 4046:24,

4050:1, 4050:7, 4050:14, 4085:15

recovered [2] - 3786:6, 3786:16

recross [3] - 3816:1, 3816:7, 4039:22

RECROSS [12] - 3775:7, 3775:11,

3775:15, 3776:2, 3776:6, 3776:10,

3804:15, 3819:12, 3822:6, 4027:3,

4048:10, 4050:18

RECROSS-EXAMINATION [1] -

3804:15

recross-examination [1] - 3816:7

red [3] - 4010:4, 4010:7, 4010:8

REDIRECT [14] - 3775:5, 3775:9,

3775:13, 3775:17, 3775:25, 3776:4,

3776:8, 3784:7, 3815:4, 3821:7,

3822:25, 4018:1, 4044:13, 4050:5

redirect [6] - 3777:7, 3806:25,Johnny C. Sanchez, RMR, CRR - [email protected]

4121

3807:14, 4018:20, 4040:22, 4041:19

reference [5] - 3798:8, 3811:16,

3881:6, 4074:2, 4074:5

referenced [5] - 3845:25, 3850:12,

3896:16, 3897:5, 3898:18

references [4] - 3833:6, 3860:18,

3921:14, 4075:2

referencing [2] - 3960:14, 4075:1

referendum [1] - 4075:2

referring [7] - 3796:6, 3820:9, 3879:8,

3979:23, 3986:12, 4019:17, 4041:1

reflect [3] - 4035:10, 4071:3, 4071:4

reflected [6] - 3791:9, 3795:18,

3817:2, 3833:6, 3839:18, 3990:2

reflecting [1] - 3970:25

reflection [1] - 3803:8

reflects [4] - 3795:8, 3803:10,

3840:21, 3947:10

refresh [1] - 3923:1

refuse [2] - 3961:17, 3961:19

refused [1] - 4014:25

regard [1] - 4072:18

regarding [15] - 3778:19, 3787:3,

3789:16, 3819:16, 3820:7, 3820:14,

3820:25, 3901:4, 3912:7, 3924:22,

3939:14, 3962:7, 3967:7, 3997:19,

4030:5

regards [2] - 3900:17, 3921:12

region [1] - 3890:3

regional [2] - 4024:4, 4024:14

registry [1] - 4064:14

regular [3] - 3850:16, 3887:8, 3929:11

regularly [1] - 4036:17

regulate [9] - 3921:19, 3924:11,

3926:15, 3928:2, 3941:12, 4023:19,

4030:23, 4087:11, 4088:8

regulated [16] - 3900:18, 3900:20,

3923:9, 3923:11, 3923:15, 3923:22,

3937:3, 3954:25, 3956:25, 3957:9,

3999:17, 4023:25, 4024:11, 4054:19,

4075:10, 4076:12

regulates [4] - 3922:11, 3999:13,

3999:16

regulating [3] - 3937:13, 3957:7,

4029:24

regulation [16] - 3935:10, 3937:8,

3937:11, 4023:14, 4024:21, 4024:24,

4025:15, 4025:23, 4031:9, 4083:10,

4083:14, 4085:11, 4087:1, 4089:9,

4089:10

regulations [3] - 3901:10, 3901:11,

4028:1

regulator [21] - 3924:19, 3925:4,

3929:8, 3932:20, 3936:20, 3937:1,

3937:2, 3939:4, 3980:22, 3981:4,

3981:14, 4009:11, 4009:22, 4009:24,

4010:6, 4012:21, 4024:4, 4024:15,

4028:7, 4080:19

regulator's [1] - 4047:19

regulators [12] - 3899:23, 3921:20,

3936:18, 3937:7, 3955:2, 3955:8,

4024:25, 4025:5, 4025:15, 4027:9,

4027:22, 4027:24

regulators' [1] - 3929:15

Regulatory [8] - 3830:23, 3834:7,

3899:5, 3900:21, 4053:22, 4054:7,

4074:12, 4080:4

regulatory [6] - 3923:12, 3924:2,

3994:1, 4023:25, 4060:1, 4080:20

rein [1] - 3995:6

related [8] - 3819:20, 3880:6, 3897:2,

3903:4, 3917:12, 3957:18, 3963:7,

4045:22

relates [1] - 4084:5

relating [2] - 3996:11, 4073:7

relation [1] - 3927:14

relationship [2] - 3925:17, 4002:13

relative [1] - 3915:7

relaying [1] - 4031:10

relevance [4] - 4072:21, 4072:23,

4072:25, 4073:16

relevant [4] - 3781:19, 3914:9,

4039:19, 4039:21

Reliant [1] - 3885:16

rely [3] - 4086:11, 4087:14, 4087:16

relying [1] - 4088:10

remain [1] - 4052:12

remember [82] - 3785:1, 3801:23,

3807:17, 3810:20, 3811:4, 3814:16,

3819:16, 3820:1, 3820:15, 3820:16,

3820:17, 3820:19, 3820:21, 3820:22,

3875:18, 3875:21, 3915:22, 3956:11,

3957:22, 3961:21, 3961:24, 3963:3,

3967:20, 3968:11, 3968:14, 3969:6,

3971:14, 3978:10, 3978:12, 3978:15,

3978:21, 3979:1, 3983:23, 3986:5,

3988:7, 3988:9, 3988:11, 3988:15,

3989:8, 3992:10, 3992:13, 4000:13,

4000:15, 4000:18, 4001:5, 4004:14,

4008:17, 4016:22, 4018:3, 4018:8,

4018:24, 4020:8, 4020:20, 4020:24,

4021:5, 4021:18, 4021:22, 4023:16,

4026:3, 4026:7, 4028:5, 4028:7,

4029:4, 4031:23, 4035:24, 4036:1,

4036:3, 4037:20, 4037:21, 4040:11,

4040:21, 4041:4, 4042:2, 4043:8,

4043:16, 4043:17, 4045:16, 4047:19,

4047:20, 4048:12, 4048:14

remind [10] - 3787:2, 3788:6, 3791:8,

3796:21, 3799:22, 3830:20, 3830:21,

3941:24, 4054:4, 4074:19

remove [1] - 3782:2

removed [1] - 4082:24

renew [1] - 3918:4

renewing [1] - 3917:25

repaid [2] - 3815:9, 3815:16

repay [3] - 3794:10, 3794:15, 3795:25

repaying [1] - 3791:17

repeat [7] - 3817:12, 3820:2, 3978:5,

4002:8, 4005:7, 4040:12, 4075:17

rephrase [12] - 3788:21, 3788:22,

3957:23, 3959:4, 3963:23, 3970:1,

3976:7, 3981:25, 3982:3, 4005:16,

4005:17, 4018:21

reply [3] - 3824:21, 3878:23, 3879:1

replying [1] - 3879:20

report [14] - 3791:11, 3815:11,

3842:21, 3845:22, 3886:16, 3886:17,

3958:10, 3959:7, 3960:18, 3960:19,

3960:20, 3967:11, 4059:24, 4059:25

Report [1] - 3878:3

reported [14] - 3794:1, 3795:9,

3795:19, 3795:22, 3830:18, 3831:15,

3834:24, 3835:17, 3836:10, 3836:19,

3842:21, 3857:13, 3965:21, 4064:15

reporter [3] - 3806:22, 4075:20,

4075:23

Reporter [1] - 3774:11

REPORTER'S [1] - 4092:1

reporting [4] - 3831:3, 3842:23,

3846:20, 4085:15

reports [11] - 3799:2, 3799:6, 3799:14,

3800:11, 3819:17, 3822:3, 3889:17,

3931:25, 3965:15, 4019:6, 4019:12

represent [1] - 4001:10

representation [1] - 3824:21

representations [1] - 3786:12

represents [2] - 3938:20, 4025:21

request [18] - 3825:8, 3847:14,

3847:16, 3847:21, 3876:19, 3889:3,

3946:18, 4001:17, 4002:11, 4014:9,

4015:17, 4049:2, 4049:4, 4049:7,

4049:24, 4050:22, 4051:8, 4051:21

requested [12] - 3994:7, 4001:19,

4010:25, 4011:22, 4012:11, 4014:24,

4015:4, 4015:6, 4046:9, 4049:23,

4051:24, 4075:23

requesting [1] - 3899:11

requests [1] - 4015:21

require [1] - 3845:22

required [9] - 3793:16, 3831:2, 3925:2,

3929:5, 3959:8, 3959:12, 4065:8,

4086:16, 4086:19

requirement [1] - 4056:20

requirements [1] - 3958:5

requires [1] - 3909:2

reservation [1] - 3889:4

Reserve [1] - 3921:18

reserved [2] - 3878:20, 3889:6

reserves [1] - 3934:19

resource [1] - 4065:18

respect [2] - 3886:10, 4038:25

respond [4] - 3881:15, 3906:19,

3928:6, 3929:20

responding [2] - 3882:3, 3936:4

responds [5] - 3882:20, 3889:20,

3891:12, 3891:14, 3891:17

response [31] - 3779:15, 3779:16,

3811:19, 3847:21, 3882:13, 3883:9,

3891:11, 3892:9, 3892:15, 3892:20,

3893:1, 3894:1, 3898:5, 3898:8,

3900:4, 3902:9, 3908:4, 3926:12,

3928:14, 3928:18, 3932:13, 3936:8,

3936:9, 4025:14, 4030:19, 4039:10,

4039:11, 4079:3, 4079:15, 4081:13,

4082:18

Responses [1] - 3882:22

responses [5] - 3882:25, 3898:11,


4122

responsibilities [6] - 4059:16,

4059:19, 4064:1, 4064:2, 4064:4,

4064:9

responsibility [7] - 3787:7, 3958:9,

4054:10, 4059:13, 4060:9, 4064:11,

4089:7

responsive [3] - 3795:13, 3980:25,

4077:18

rest [4] - 3956:16, 4069:17, 4069:19,

4069:24

restate [1] - 4007:21

restaurant [2] - 3794:15, 4070:10

restrictions [1] - 3828:22

resume [2] - 3857:25, 3911:16

retention [1] - 3840:10

retired [2] - 3834:4, 3834:5

return [10] - 3825:8, 3830:25, 3832:4,

3832:9, 3832:10, 3832:20, 3833:6,

3833:15, 4027:21, 4077:4

returned [1] - 4076:25

returns [20] - 3828:25, 3829:3, 3829:5,

3830:13, 3830:15, 3831:2, 3831:5,

3831:11, 3831:13, 3831:24, 3833:2,

3835:13, 3836:11, 3836:15, 3965:14,

3982:17, 4083:19, 4083:20, 4085:7,

4086:14

reveal [1] - 4038:10

revealed [1] - 4089:17

Revenue [1] - 3826:16

Review [1] - 3936:15

review [16] - 3777:15, 3829:18,

3829:23, 3830:3, 3836:4, 3840:2,

3844:1, 3928:14, 3942:8, 3992:5,

3993:7, 4077:21, 4077:25, 4082:3,

4084:3, 4088:13

reviewed [6] - 3831:16, 3901:2,

3916:5, 3917:4, 3940:24, 3941:6

reviewing [4] - 3830:5, 3875:9,

3939:8, 4077:14

revised [1] - 3932:16

revisions [1] - 3932:18

Richardson [1] - 3926:9

right-hand [8] - 3789:24, 3791:7,

3852:5, 3872:6, 3874:14, 3874:21,

3904:7, 4080:2

ring [2] - 4068:16, 4068:17

RMR [2] - 3774:11, 4092:7

ROBERT [1] - 3773:6

Robert [3] - 3773:21, 3873:5, 3919:18

Rodd [1] - 3879:8

Rodriguez [2] - 3984:19

role [7] - 3903:2, 4054:3, 4062:14,

4062:16, 4062:21, 4065:9, 4075:5

rolled [1] - 3814:6

Roman [1] - 3894:10

Room [1] - 3881:7

rose [1] - 4010:8

Rose [1] - 3903:1

roughly [3] - 3856:9, 3934:24, 3972:9

round [1] - 3822:19

route [1] - 3891:17

RPR [1] - 3774:11

rule [3] - 4018:22, 4062:12, 4062:18

ruled [1] - 3918:4

Rules [1] - 3781:10

rules [2] - 4003:18, 4059:22

run [3] - 3910:23, 3932:2, 4048:24

Rusk [1] - 3774:12

S

safe [1] - 3794:5

safeguards [1] - 3828:24

safety [2] - 3901:8, 3935:8

salaries [1] - 3836:10

salary [16] - 3833:3, 3833:17, 3833:19,

3834:10, 3835:6, 3835:12, 3835:16,

3835:17, 3836:22, 3836:24, 3846:19,

3846:22, 3857:13, 3857:16, 4060:14,

4069:12

sales [1] - 3794:5

Sanchez [3] - 3774:11, 4092:3, 4092:7

sandbagged [2] - 3780:3, 3780:22

satisfied [1] - 4056:19

satisfy [1] - 4088:20

Saturday [1] - 3936:10

savings [9] - 3837:25, 3838:6, 3839:1,

3839:12, 3839:14, 3839:25, 3850:16,

3854:2, 4089:14

saw [26] - 3778:17, 3792:19, 3801:7,

3817:10, 3836:20, 3846:2, 3846:23,

3847:25, 3848:1, 3849:3, 3856:15,

3857:16, 3868:23, 3892:1, 3915:20,

3922:4, 3932:8, 3934:11, 3934:18,

3935:13, 3936:5, 3936:6, 3948:13,

4019:11, 4023:22, 4074:2

SB [1] - 3883:5

sCARDINO [1] - 3807:8

SCARDINO [54] - 3777:6, 3778:1,

3778:7, 3778:13, 3778:15, 3778:25,

3779:17, 3779:21, 3780:19, 3781:6,

3781:24, 3782:10, 3788:10, 3788:16,

3789:2, 3795:12, 3796:3, 3798:7,

3798:12, 3802:6, 3802:10, 3804:16,

3807:1, 3808:4, 3808:14, 3810:6,

3810:7, 3810:15, 3810:23, 3811:2,

3811:3, 3811:6, 3813:1, 3813:4,

3814:25, 3815:25, 3816:20, 3818:23,

3819:13, 3819:25, 3820:12, 3821:4,

3821:19, 3822:7, 3822:18, 3823:9,

3823:12, 3823:21, 3823:25, 3824:7,

3824:10, 3824:14, 3824:20, 3825:1

Scardino [16] - 3773:21, 3773:21,

3777:5, 3779:16, 3784:10, 3784:25,

3786:20, 3787:6, 3787:10, 3796:10,

3797:21, 3800:23, 3801:3, 3801:15,

3815:2, 3815:6

SCARDINO........... [3] - 3775:7,

3775:11, 3775:15

scared [1] - 3784:14

Schedule [1] - 3965:16

scheme [2] - 3828:4, 3828:5

school [8] - 3950:12, 3950:13, 3951:5,

3952:5, 4003:11, 4003:12, 4055:7

Schwab [13] - 3942:24, 3942:25,

3943:6, 3943:20, 3943:21, 3944:1,

3944:3, 3944:13, 3944:21, 3945:14,

3945:22, 3947:19, 3948:15

scope [10] - 3806:15, 3810:2, 3810:13,

3816:1, 3816:20, 3816:22, 3821:20,

3823:10, 3864:9, 3981:12

screen [7] - 3777:8, 3864:21, 3865:4,

3865:13, 3865:14, 3865:15, 3896:2

scroll [13] - 3844:9, 3845:10, 3845:17,

3856:1, 3863:16, 3879:17, 3881:15,

3892:7, 3925:9, 3985:1, 4033:19,

4033:20, 4080:6

seal [1] - 4066:4

search [3] - 3892:24, 4017:3

seat [4] - 3783:24, 3825:22, 4052:22,

4052:23

seated [3] - 3777:2, 3911:23, 3997:12

seats [7] - 3884:12, 3884:14, 3889:2,

3889:6, 3892:19, 3892:24, 3893:2

SEC [48] - 3787:4, 3896:7, 3897:23,

3897:24, 3898:6, 3899:9, 3899:14,

3900:7, 3900:18, 3901:23, 3902:3,

3902:9, 3902:13, 3903:4, 3903:6,

3903:21, 3904:14, 3904:17, 3904:23,

3905:19, 3906:6, 3907:9, 3907:25,

3908:6, 3910:2, 3910:3, 3912:8,

3912:16, 3912:25, 3913:19, 3914:10,

3915:8, 3915:22, 3915:25, 3916:4,

3916:6, 3916:22, 3955:13, 3955:18,

3956:1, 4045:16, 4045:19, 4046:16,

4048:13, 4048:16, 4050:7, 4050:20,

4051:1

second [35] - 3783:1, 3806:16,

3806:18, 3807:4, 3828:9, 3832:13,

3834:8, 3844:18, 3863:9, 3876:25,

3878:8, 3880:9, 3880:10, 3888:3,

3900:25, 3901:14, 3901:15, 3903:9,

3907:8, 3909:5, 3917:21, 3928:20,

3934:20, 3940:1, 3947:1, 3967:25,

3976:1, 4008:20, 4043:10, 4048:14,

4061:11, 4065:13, 4068:17, 4079:21,

4081:18

secondly [1] - 3778:15

secret [6] - 3974:19, 3974:21, 3990:17,

4034:21, 4067:10

Secretaries [1] - 4057:22

secretary [2] - 3896:20, 3949:18

sector [3] - 4054:11, 4054:12

sectors [1] - 4054:12

secunded [3] - 4076:25, 4077:1,

4077:2

securities [2] - 3800:2, 3818:12

Securities [4] - 3900:16, 3902:20,

3904:3, 3905:11

see [79] - 3779:18, 3783:20, 3786:6,

3790:12, 3797:12, 3799:14, 3802:2,

3807:20, 3813:6, 3830:17, 3831:20,

3840:3, 3844:10, 3845:11, 3846:7,

3847:7, 3848:18, 3849:12, 3850:16,

3853:16, 3856:2, 3857:10, 3858:1,

3861:13, 3863:16, 3864:18, 3864:19,


4123

3865:24, 3866:18, 3866:19, 3867:20,

3869:3, 3873:15, 3874:23, 3875:2,

3877:6, 3877:18, 3882:13, 3889:20,

3891:16, 3892:18, 3895:25, 3907:1,

3908:23, 3910:15, 3911:15, 3911:16,

3911:19, 3911:24, 3936:8, 3940:15,

3945:16, 3962:10, 3962:13, 3962:14,

3969:8, 3974:7, 3981:7, 3984:12,

3985:18, 3993:3, 3996:12, 3997:8,

4009:25, 4010:22, 4012:15, 4024:17,

4039:19, 4068:15, 4070:23, 4072:16,

4073:24, 4084:4, 4091:12, 4091:16

seeing [3] - 3817:7, 3941:16, 4035:16

seeking [4] - 3871:14, 3925:6, 4065:8,

4085:10

seem [6] - 3892:22, 3931:20, 3931:21,

3980:15, 3980:18, 4034:11

seemingly [1] - 4088:21

sees [1] - 3986:13

segment [1] - 4059:13

send [16] - 3782:3, 3891:4, 3892:3,

3892:11, 3913:25, 3928:18, 3931:24,

3932:12, 3932:19, 3967:6, 3967:10,

3980:1, 3990:5, 4010:6, 4074:9

sending [9] - 3880:15, 3899:3, 3899:8,

3924:19, 3931:3, 3931:25, 3933:19,

3945:17, 4022:17

sends [5] - 3890:25, 3900:2, 3900:4,

3932:24, 4007:10

senior [3] - 4080:7, 4083:24, 4084:1

sense [3] - 3824:8, 3963:5, 3969:9

sent [34] - 3791:11, 3870:25, 3885:1,

3885:2, 3895:16, 3897:24, 3898:6,

3898:8, 3899:11, 3913:22, 3921:5,

3921:9, 3922:19, 3922:23, 3923:2,

3927:12, 3928:10, 3929:21, 3930:12,

3931:12, 3933:10, 3938:17, 3947:2,

3989:25, 4029:6, 4029:9, 4029:11,

4029:12, 4029:15, 4029:17, 4050:14,

4071:7, 4075:3, 4081:13

sentence [5] - 3872:1, 3879:12,

3889:16, 3900:25, 4082:1

separate [5] - 3866:23, 3875:15,

3886:17, 3955:23, 4000:2

separated [1] - 4062:19

separately [1] - 3817:22

September [9] - 3804:4, 3816:11,

3869:7, 3869:12, 3869:23, 3905:5,

4074:8, 4091:2

sequence [4] - 3877:3, 3880:10,

3920:19, 4067:7

series [1] - 3920:12

serious [3] - 3900:13, 3900:15, 3902:3

served [1] - 3889:2

servers [1] - 3876:20

Service [2] - 3826:17, 3992:7

services [1] - 4086:11

Services [9] - 3830:23, 3833:4,

3834:6, 3899:5, 3900:20, 4053:21,

4054:6, 4074:12, 4080:3

set [7] - 3886:17, 3911:8, 3913:10,

3939:6, 3965:23, 3998:14, 4058:1

sets [3] - 3921:5, 3955:2, 3955:7

seven [2] - 3950:24, 4060:3

seven-member [1] - 4060:3

several [2] - 3805:22, 4082:2

Seymour [2] - 4081:9, 4081:14

shadowing [1] - 3890:5

share [4] - 3899:21, 4081:2, 4081:5,

4081:7

shared [2] - 4017:23, 4065:7

shareholder [4] - 3814:21, 3820:15,

3926:16, 3970:8

shareholders [1] - 3820:7

sharing [4] - 4075:8, 4076:2, 4076:10,

4076:11

sheet [4] - 3899:3, 3902:18, 3929:25,

4083:22

shielded [1] - 4004:3

shock [1] - 4063:12

shores [1] - 4063:15

short [4] - 3915:4, 3931:3, 3952:7,

4063:3

shorter [1] - 3931:4

shortly [2] - 3927:16, 3941:18

shot [1] - 3821:22

show [34] - 3794:7, 3800:1, 3812:20,

3831:24, 3834:9, 3836:6, 3842:3,

3852:4, 3853:13, 3855:16, 3857:6,

3864:23, 3870:10, 3887:12, 3888:18,

3895:11, 3898:13, 3898:16, 3903:17,

3916:15, 3927:15, 3945:25, 3946:10,

3947:14, 3963:2, 3971:1, 3977:21,

4032:7, 4032:24, 4033:7, 4033:10,

4034:16, 4034:19, 4079:15

showed [12] - 3781:22, 3809:7,

3834:14, 3835:11, 3905:8, 3908:22,

3947:25, 4022:10, 4027:20, 4029:1,

4029:5, 4029:11

showing [11] - 3781:7, 3840:24,

3841:2, 3843:3, 3843:10, 3858:14,

3885:19, 3893:4, 3917:18, 3944:5,

4022:14

shown [5] - 3780:8, 3789:15, 3794:23,

3840:18, 3930:2

shows [14] - 3803:19, 3834:4, 3834:6,

3841:20, 3849:24, 3852:5, 3852:9,

3855:4, 3943:10, 3947:9, 3971:9,

3985:19, 4033:11, 4079:24

shut [1] - 3821:23

shutting [1] - 3822:21

SIB [11] - 3927:8, 3937:4, 4023:24,

4024:6, 4025:16, 4082:11, 4087:25,

4088:8, 4089:15, 4090:7, 4090:8

SIB's [1] - 4087:18

SIBL [19] - 3901:4, 3901:7, 3901:16,

3902:1, 3902:3, 3902:4, 3926:16,

3931:25, 3954:20, 3999:24, 4013:23,

4014:6, 4014:12, 4016:1, 4016:4,

4017:15, 4017:21, 4028:11, 4044:10

side [14] - 3827:3, 3827:7, 3828:21,

3852:5, 3858:6, 3874:15, 3874:19,

3874:21, 3904:7, 3911:2, 3921:12,

3969:15, 4005:20, 4080:2

sidebar [1] - 4018:15

sides [2] - 4011:25, 4012:2

Sidney [1] - 4081:9

sign [10] - 3932:19, 4066:18, 4066:19,

4066:21, 4067:4, 4076:7, 4082:16,

4082:19, 4082:20, 4082:23

signatories [1] - 3839:5

signatory [3] - 3781:16, 3788:4,

3839:25

signature [13] - 3782:1, 3838:2,

3838:5, 3838:21, 3839:10, 3839:12,

3860:19, 3926:5, 3934:8, 4066:4,

4066:10, 4066:12, 4066:13

signatures [1] - 3861:20

signed [25] - 3799:3, 3799:5, 3799:6,

3822:3, 3899:18, 3943:9, 4066:2,

4066:15, 4066:22, 4066:24, 4066:25,

4067:1, 4067:2, 4067:3, 4068:7,

4071:12, 4079:3, 4079:6, 4079:8,

4080:4, 4081:18, 4081:20, 4081:21,

4083:4

significance [2] - 3872:17, 4076:14

significant [5] - 3831:17, 3836:21,

3842:15, 3842:18, 3869:17

signing [2] - 4082:21, 4083:1

signs [1] - 3946:16

silly [1] - 4074:15

similar [6] - 3827:9, 3921:18, 3930:11,

4024:7, 4029:15, 4056:25

similarly [1] - 3842:10

Simon [1] - 3883:5

simpler [3] - 3982:24, 3998:15, 3999:7

simply [2] - 3976:11, 3999:8

sincerely [1] - 3872:3

single [4] - 3788:14, 3788:25, 3977:5,

4011:22

singular [1] - 3926:16

sit [1] - 3909:17

site [8] - 4082:6, 4083:18, 4084:7,

4084:10, 4084:11, 4084:13, 4085:7

sits [1] - 4084:2

sitting [3] - 3781:22, 4016:10, 4070:23

six [3] - 3795:23, 3813:5, 4068:20

Sjoblom [5] - 3902:24, 3903:6,

3904:11, 3905:1, 3910:3

Sjoblom's [1] - 3903:2

sleeves [1] - 3814:7

slightly [2] - 3865:19, 3865:20

slip [9] - 3840:17, 3840:20, 3842:10,

3844:20, 3852:24, 3854:1, 3860:23,

3862:11, 3866:2

slips [6] - 3849:4, 3861:18, 3862:22,

3866:4, 4021:4, 4045:10

slow [1] - 3777:12

slower [1] - 3950:2

slowly [1] - 3950:1

slush [3] - 3788:3, 3816:12, 3816:17

small [1] - 4059:14

smart [1] - 3976:22

smarter [3] - 3987:23, 3990:4, 3990:20

smear [2] - 4077:11, 4077:22

smoke [5] - 3793:20, 3794:7, 3796:2,

3796:6, 3812:2

smoke-and-mirror [2] - 3794:7,


4124

3796:2

sneeze [1] - 4009:12

sneezing [2] - 4009:14, 4009:15

Soc [14] - 3777:22, 3786:15, 3788:2,

3800:13, 3800:15, 3804:6, 3805:3,

3817:1, 3817:3, 3817:11, 3817:15,

3817:20, 3821:9

Societe [2] - 3803:19, 3816:12

soften [1] - 3933:4

solemnly [2] - 3825:17, 4052:18

solvency [1] - 4085:18

someone [14] - 3880:15, 3881:11,

3889:21, 3897:10, 3912:12, 3913:25,

3980:16, 4039:16, 4062:6, 4065:8,

4075:9, 4076:3, 4076:11

someplace [1] - 3828:3

sometime [1] - 4068:2

sometimes [4] - 3799:5, 3845:5,

3861:20

somewhat [1] - 4043:5

somewhere [3] - 3834:5, 4016:20,

4068:13

soon [5] - 3783:14, 3785:17, 3785:20,

3785:22, 3910:23

sorry [62] - 3789:18, 3790:22, 3794:18,

3794:25, 3797:22, 3798:7, 3801:5,

3803:14, 3806:20, 3821:19, 3843:19,

3853:8, 3859:1, 3886:5, 3888:14,

3903:10, 3905:24, 3908:13, 3924:13,

3949:4, 3949:21, 3962:1, 3966:11,

3968:1, 3972:11, 3973:4, 3975:11,

3980:25, 3982:12, 3986:18, 3987:8,

3992:18, 3992:20, 3993:23, 3997:25,

4000:14, 4009:14, 4025:9, 4028:22,

4029:21, 4030:18, 4031:19, 4042:7,

4055:22, 4057:1, 4058:5, 4058:14,

4064:6, 4067:22, 4069:4, 4069:5,

4071:12, 4072:2, 4073:25, 4075:17,

4075:19, 4081:6, 4082:8, 4084:1,

4084:25, 4087:6

sort [2] - 3786:21, 4090:5

soundness [2] - 3901:8, 3935:9

sounds [1] - 4000:20

source [2] - 3831:14, 3831:21

sources [4] - 3830:17, 3831:3,

3831:14, 3892:25

SOUTHERN [1] - 3773:1

spaced [1] - 4068:19

span [1] - 4068:21

speaking [9] - 3876:9, 3920:3, 3929:1,

4000:13, 4001:25, 4002:5, 4057:23,

4059:18, 4068:1

speaks [1] - 4037:17

special [9] - 3826:16, 3888:9, 3907:4,

3963:7, 4003:3, 4003:7, 4003:8,

4034:25, 4035:20

Special [1] - 4003:5

specific [4] - 3819:20, 3820:10,

3963:2, 3991:14

specifically [2] - 3816:24, 3820:20

specifics [2] - 4069:13, 4073:3

specify [1] - 4069:23

spectator [1] - 4063:18

speculate [2] - 3981:20, 3987:24

speculation [7] - 3969:21, 3976:13,

3980:6, 3981:24, 4037:14, 4041:11,

4049:18

spell [4] - 3826:10, 4053:8, 4062:23,

4065:20

spend [1] - 4058:19

spending [1] - 3828:11

spent [2] - 3793:24, 3801:9

spoken [2] - 4006:22, 4006:23

sponsoring [1] - 3978:25

spot [2] - 3906:14, 3907:10

spreadsheet [8] - 3790:25, 3791:21,

3792:19, 3799:8, 3816:18, 3817:2,

3817:4, 3817:25

St [5] - 3787:20, 3834:7, 3834:20,

3849:24, 4053:15

Stadium [1] - 3885:16

staff [1] - 4084:2

stamp [2] - 4080:2, 4080:3

stamps [1] - 4080:4

stand [4] - 3783:7, 3936:16, 3949:24,

4089:13

standalone [2] - 3926:13, 3929:7

standard [2] - 3807:13, 3935:10

standards [9] - 3806:8, 3806:24,

3807:11, 3815:7, 3815:15, 3815:21,

3816:3, 3929:10, 4087:2

standing [3] - 3901:17, 3901:20,

4071:2

stands [5] - 3847:15, 3849:22, 3959:6,

4000:5, 4042:5

STANFORD [1] - 3773:6

Stanford [317] - 3785:5, 3786:8,

3786:12, 3787:17, 3787:19, 3790:13,

3790:20, 3791:12, 3792:5, 3792:16,

3792:20, 3792:24, 3793:4, 3793:12,

3795:19, 3796:10, 3796:11, 3796:25,

3799:3, 3799:10, 3800:11, 3801:6,

3801:10, 3802:24, 3803:3, 3803:24,

3803:25, 3804:5, 3804:11, 3805:13,

3806:2, 3806:6, 3807:21, 3807:24,

3808:1, 3808:5, 3808:7, 3809:8,

3814:14, 3815:9, 3815:13, 3816:19,

3816:25, 3817:8, 3817:14, 3819:15,

3820:4, 3820:14, 3820:18, 3820:23,

3821:13, 3822:11, 3822:15, 3823:3,

3823:4, 3823:6, 3823:18, 3827:17,

3827:23, 3828:10, 3829:17, 3829:24,

3858:20, 3858:21, 3859:22, 3860:7,

3861:12, 3864:4, 3866:25, 3868:12,

3868:25, 3869:9, 3870:24, 3871:7,

3873:5, 3875:11, 3876:16, 3876:22,

3877:16, 3878:1, 3878:2, 3878:22,

3879:1, 3879:6, 3879:15, 3879:20,

3879:22, 3880:2, 3880:24, 3881:19,

3882:9, 3882:25, 3884:17, 3885:3,

3885:4, 3885:6, 3885:12, 3886:17,

3889:8, 3890:8, 3891:3, 3891:6,

3892:3, 3895:4, 3895:5, 3895:7,

3896:8, 3896:12, 3897:4, 3897:6,

3897:13, 3897:20, 3897:25, 3899:12,

3900:17, 3900:19, 3902:14, 3904:6,

3904:24, 3905:8, 3905:14, 3905:19,

3905:22, 3906:8, 3906:9, 3906:11,

3907:2, 3907:16, 3907:22, 3907:24,

3908:22, 3912:8, 3912:11, 3912:16,

3912:24, 3913:24, 3914:4, 3914:9,

3915:7, 3915:21, 3915:25, 3917:3,

3918:13, 3918:20, 3920:8, 3922:15,

3922:24, 3923:13, 3923:16, 3923:22,

3924:5, 3924:6, 3925:6, 3925:18,

3926:22, 3926:24, 3927:1, 3927:9,

3927:11, 3927:17, 3927:24, 3928:4,

3928:23, 3929:16, 3932:9, 3933:11,

3933:16, 3933:17, 3933:23, 3934:16,

3934:22, 3936:5, 3936:24, 3937:14,

3938:14, 3938:20, 3938:23, 3939:19,

3939:25, 3940:7, 3941:12, 3942:1,

3942:4, 3944:15, 3954:20, 3967:23,

3968:16, 3969:15, 3969:18, 3970:4,

3971:2, 3971:10, 3973:1, 3973:24,

3974:9, 3975:5, 3975:8, 3975:10,

3975:13, 3976:10, 3977:3, 3978:23,

3979:23, 3979:25, 3980:16, 3981:14,

3983:6, 3983:9, 3983:12, 3985:5,

3986:10, 3986:17, 3987:8, 3987:13,

3987:21, 3988:1, 3988:7, 3988:13,

3989:24, 3990:21, 3991:23, 3992:3,

3992:12, 3994:14, 3996:8, 3998:23,

4001:25, 4002:11, 4002:13, 4002:19,

4004:8, 4004:20, 4005:5, 4005:6,

4006:3, 4006:10, 4006:16, 4006:23,

4007:2, 4007:12, 4008:1, 4008:4,

4009:6, 4011:1, 4011:2, 4011:3,

4011:4, 4012:24, 4018:5, 4020:19,

4021:3, 4021:8, 4021:15, 4022:16,

4022:21, 4023:3, 4023:10, 4024:18,

4024:22, 4025:18, 4025:22, 4026:6,

4026:22, 4026:23, 4028:6, 4030:25,

4031:9, 4031:13, 4033:3, 4034:4,

4034:12, 4034:16, 4034:21, 4034:24,

4038:22, 4039:8, 4044:25, 4045:3,

4045:6, 4045:23, 4046:2, 4046:4,

4046:17, 4047:4, 4054:18, 4067:12,

4067:13, 4067:15, 4067:19, 4067:20,

4068:1, 4068:10, 4068:25, 4069:22,

4070:6, 4070:16, 4070:17, 4070:23,

4071:11, 4074:5, 4075:9, 4078:5,

4079:24, 4080:18, 4081:4, 4082:12,

4083:11, 4088:22, 4089:15, 4089:18,

4090:1, 4090:5

Stanford's [74] - 3791:1, 3796:23,

3797:14, 3800:16, 3802:17, 3802:24,

3803:5, 3805:21, 3808:23, 3810:3,

3816:13, 3822:1, 3853:19, 3859:3,

3859:7, 3859:15, 3860:12, 3860:16,

3861:17, 3861:23, 3862:12, 3862:20,

3862:22, 3863:4, 3863:13, 3863:23,

3866:4, 3867:7, 3867:12, 3869:3,

3870:1, 3870:5, 3870:7, 3870:12,

3873:3, 3873:13, 3873:16, 3874:24,

3876:24, 3877:22, 3885:7, 3886:14,

3887:11, 3888:6, 3888:17, 3888:20,

3889:17, 3895:9, 3895:15, 3895:19,

3896:11, 3897:17, 3919:18, 3927:6,


4125

3929:14, 3933:22, 3936:9, 3942:10,

3980:22, 3984:23, 3986:6, 3986:21,

3987:16, 3989:23, 3996:14, 3996:23,

4001:11, 4001:12, 4006:19, 4019:23,

4025:4, 4027:18, 4050:7, 4088:18

Stars [1] - 3871:12

start [9] - 3797:1, 3840:11, 3877:2,

3941:15, 3983:5, 3992:12, 4065:15,

4079:21

started [6] - 3902:14, 3914:22, 3917:1,

3950:4, 4023:13, 4067:8

starting [3] - 3792:4, 3929:4, 4000:21

startling [1] - 4088:17

state [7] - 3805:8, 3833:24, 3912:25,

3914:8, 3958:18, 3958:22, 4061:15

State [1] - 3951:25

statement [18] - 3839:19, 3850:3,

3873:13, 3874:5, 3874:17, 3886:21,

3886:22, 3944:12, 3947:7, 3947:14,

3947:25, 3990:3, 3990:12, 3990:13,

4082:11, 4082:24, 4083:23, 4086:22

statements [18] - 3795:10, 3807:10,

3809:1, 3819:5, 3839:17, 3839:20,

3847:5, 3847:6, 3849:14, 3850:5,

3850:6, 3886:13, 3886:18, 3903:20,

4045:21, 4084:16, 4084:17, 4086:12

States [34] - 3825:14, 3828:2, 3828:3,

3831:1, 3837:3, 3837:6, 3837:18,

3838:9, 3840:4, 3843:11, 3844:2,

3847:6, 3847:22, 3904:3, 3921:19,

3942:23, 3945:13, 3945:18, 3947:23,

3948:22, 3954:11, 3954:17, 3954:19,

3956:25, 3957:10, 3959:9, 3960:7,

3968:8, 4003:10, 4003:15, 4046:9,

4049:4, 4049:5, 4052:15

STATES [3] - 3773:1, 3773:4, 3773:10

stating [1] - 4080:19

status [2] - 3797:18, 3901:20

statute [1] - 3828:9

statutes [3] - 3941:8, 4003:7, 4003:14

stay [6] - 3791:24, 3793:16, 3824:25,

3825:2, 3883:21, 3897:10

STC [1] - 3937:4

STCL [1] - 3931:25

steel [1] - 3996:11

Steel [6] - 3871:10, 3871:13, 3871:19,

3873:9, 3873:22, 3875:3

STELLMACH [108] - 3778:2, 3778:22,

3778:24, 3779:4, 3779:11, 3779:14,

3779:20, 3779:25, 3780:5, 3780:8,

3780:12, 3780:16, 3780:18, 3780:20,

3781:3, 3781:14, 3782:13, 3782:23,

3783:2, 3783:11, 3783:15, 3783:18,

3783:21, 3784:1, 3784:5, 3784:8,

3784:17, 3784:20, 3785:23, 3786:1,

3786:24, 3787:1, 3788:13, 3788:20,

3788:23, 3789:7, 3789:18, 3789:20,

3789:23, 3790:1, 3790:21, 3794:18,

3794:20, 3795:13, 3795:16, 3796:5,

3797:22, 3797:23, 3798:10, 3798:14,

3798:18, 3799:19, 3799:21, 3800:6,

3800:9, 3801:14, 3801:19, 3802:2,

3802:4, 3802:8, 3802:11, 3802:13,

3802:18, 3802:20, 3803:13, 3803:15,

3804:14, 3805:5, 3805:10, 3806:15,

3806:23, 3808:2, 3808:12, 3810:1,

3810:11, 3810:13, 3810:21, 3810:25,

3811:13, 3811:15, 3815:3, 3815:5,

3816:2, 3816:5, 3816:8, 3816:10,

3816:24, 3817:6, 3818:2, 3818:5,

3818:6, 3819:1, 3819:11, 3819:19,

3821:6, 3821:8, 3821:24, 3822:5,

3822:23, 3823:1, 3823:15, 3823:19,

3824:4, 3824:16, 3825:10, 3865:9,

3865:11, 4009:13

Stellmach [17] - 3773:16, 3777:7,

3783:25, 3802:7, 3805:12, 3805:18,

3806:5, 3809:6, 3810:16, 3811:4,

3811:16, 3812:2, 3812:23, 3814:13,

3819:14, 3820:3, 3820:13

Stellmach's [3] - 3805:2, 3807:14,

3820:17

STELLMACH......... [4] - 3775:5,

3775:9, 3775:13, 3775:17

stenography [1] - 3774:14

step [7] - 3823:23, 3937:2, 3938:5,

3967:2, 4052:11, 4091:14

Sticky [1] - 3794:15

still [18] - 3779:23, 3789:9, 3790:18,

3793:5, 3793:6, 3864:19, 3865:16,

3895:22, 3908:5, 3911:2, 3937:21,

4021:8, 4038:11, 4047:3, 4047:12,

4073:17, 4079:17, 4089:22

stints [1] - 4059:9

stipulate [1] - 3990:20

stipulation [1] - 3990:24

stood [1] - 4063:12

stop [7] - 3910:22, 3934:20, 3937:10,

4032:8, 4069:5, 4082:8, 4084:25

stopped [2] - 3790:17, 3791:22

stops [1] - 4060:12

strange [3] - 4064:22, 4067:7, 4071:10

Street [2] - 3773:22, 4063:20

strike [1] - 3779:9

strong [2] - 4065:9, 4075:11

structure [2] - 3925:25, 3926:18

stuff [2] - 3918:2, 3961:8

Suarez [1] - 3984:21

sub [1] - 3926:14

subcommittees [2] - 4084:3, 4084:20

subject [13] - 3820:16, 3878:3, 3879:7,

3880:6, 3880:19, 3882:21, 3882:23,

3885:5, 3915:14, 3917:1, 3928:13,

3933:9, 3940:8

subjects [1] - 4047:3

submission [1] - 4057:18

submit [1] - 3779:24

submits [1] - 4083:19

submitted [1] - 4084:14

subpoena [13] - 3824:23, 3837:7,

3847:10, 3894:1, 3904:16, 3904:23,

3905:11, 3909:2, 3943:12, 3944:2,

3971:17, 4004:17, 4046:12

subpoenaed [1] - 3912:12

subpoenas [7] - 3824:22, 3837:8,

3837:12, 3904:17, 3909:2, 3915:20,

3965:8

subsequent [1] - 4064:19

subsequently [2] - 3838:16, 4065:4

substantial [1] - 3831:22

subtle [1] - 3931:5

success [1] - 4056:17

sufficient [3] - 3848:18, 3865:16,

4085:8

suggest [1] - 3906:18

suggested [4] - 3785:2, 3787:11,

3796:11, 3816:24

suggesting [1] - 3786:20

suggestion [1] - 3908:20

suitability [1] - 4075:5

summaries [1] - 3800:1

summarizing [1] - 3866:12

summary [3] - 3792:2, 3799:23,

4002:16

summer [1] - 3932:6

summons [1] - 3904:16

Sunday [2] - 3885:16, 3885:17

Supa [1] - 3871:12

Super [47] - 3875:15, 3875:18,

3878:12, 3879:3, 3879:6, 3879:15,

3880:7, 3881:6, 3881:16, 3881:23,

3882:11, 3883:10, 3883:23, 3885:17,

3885:18, 3885:20, 3889:9, 3889:10,

3890:17, 3890:20, 3891:4, 3892:3,

3893:5, 3893:17, 3894:9, 3894:10,

3894:16, 3894:21, 3895:11, 3896:7,

3897:7, 3932:9, 3983:17, 3985:2,

3985:16, 3985:20, 3985:21, 3995:22,

3995:24, 4005:19, 4012:23, 4022:4,

4022:15, 4022:20, 4024:18, 4031:17,

4031:25

supervise [1] - 3929:7

supervised [4] - 3900:18, 3900:20,

3925:4, 3929:7

supervising [2] - 3937:14, 4054:10

supervision [11] - 3925:3, 3925:5,

3927:8, 3928:3, 3929:6, 3929:16,

3935:11, 3937:9, 3937:12, 4024:6,

4024:8

supervisor [25] - 3937:1, 4053:17,

4053:20, 4053:24, 4059:17, 4060:7,

4060:23, 4062:1, 4062:4, 4062:13,

4062:14, 4062:17, 4063:25, 4064:3,

4065:10, 4069:18, 4073:22, 4075:5,

4076:16, 4076:18, 4076:21, 4087:19,

4087:22, 4088:12, 4089:7

support [3] - 3830:18, 3888:9, 3977:19

supported [2] - 3973:10, 3977:17

supporting [2] - 3929:15, 4085:8

suppose [3] - 4036:17, 4043:1, 4049:1

supposed [7] - 3881:9, 3933:2,

4018:25, 4019:2, 4075:3, 4089:12,

4090:9

supposedly [1] - 3871:19

supposition [2] - 4036:25, 4037:2

suppress [1] - 3918:1

suppressed [1] - 3918:5

surprise [10] - 3783:18, 4031:24,


4126

4032:17, 4032:18, 4032:25, 4033:3

surprised [4] - 4023:6, 4032:7,

4032:23

surreptitious [2] - 3975:2, 3977:6

surrounding [2] - 4029:23, 4031:12

suspect [1] - 3975:4

suspected [2] - 3900:15, 3975:2

suspicious [14] - 3958:10, 3959:20,

3960:17, 3960:18, 3960:19, 3960:20,

3961:17, 3967:10, 3967:11, 3979:9,

3981:4, 4002:7, 4010:9, 4010:11

sustain [2] - 3916:14, 3993:20

sustained [18] - 3796:4, 3808:3,

3808:13, 3810:5, 3810:14, 3818:25,

3823:11, 3823:14, 3969:23, 3976:14,

4012:8, 4015:15, 4015:18, 4037:7,

4037:16, 4037:18, 4049:19, 4075:14

swear [2] - 3825:17, 4052:18

Swiss [4] - 3777:22, 3816:12, 3816:17,

4087:25

switch [10] - 3785:24, 3797:22,

3835:20, 3837:14, 3884:12, 3896:17,

3918:21, 3920:9, 4025:8, 4031:19

Switzerland [1] - 3800:16

sworn [2] - 3826:2, 4053:2

system [6] - 3998:14, 4014:17,

4014:20, 4014:22, 4027:20, 4087:3

systems [1] - 3994:22

T

tab [2] - 3919:8, 3919:10

table [6] - 3798:15, 3807:18, 3807:22,

3807:25, 3855:4, 4016:11

talks [3] - 3900:22, 3931:9, 3985:2

target [3] - 4039:2, 4039:8, 4039:16

targets [4] - 4038:10, 4038:14,

4038:22, 4047:3

tasked [1] - 4044:9

taught [5] - 3951:12, 3951:14,

3951:16, 3952:11, 4010:10

Tawari [6] - 4076:20, 4076:21, 4077:6,

4077:12, 4077:23, 4078:6

tax [33] - 3827:2, 3827:8, 3827:9,

3827:10, 3828:24, 3828:25, 3829:3,

3829:5, 3830:8, 3830:10, 3830:13,

3830:15, 3830:25, 3831:2, 3831:5,

3831:11, 3831:13, 3831:20, 3831:24,

3832:4, 3832:9, 3832:10, 3832:20,

3833:2, 3833:9, 3833:14, 3835:12,

3836:4, 3836:11, 3836:15, 3965:14,

3982:17, 4027:20

taxes [2] - 3827:5, 3827:6

teach [4] - 3951:18, 3952:5, 3952:8,

3952:13

telephone [2] - 3862:16, 3869:8

teller [4] - 3963:13, 3963:15, 3964:2,

3964:5

Tello [3] - 3889:24, 3889:25, 3890:1

tello [1] - 3890:18

Ten [1] - 3851:6

ten [2] - 3864:11, 3972:10

tender [1] - 3783:5

tenure [1] - 4090:9

term [4] - 3823:12, 3911:24, 3941:10,

3976:5

terminated [2] - 4089:23, 4089:25

terminology [1] - 3823:14

terms [18] - 3803:7, 3830:5, 3891:18,

4046:24, 4056:16, 4057:12, 4057:25,

4060:8, 4061:5, 4062:6, 4083:22,

4083:23, 4086:24, 4086:25, 4087:1,

4087:15, 4088:17

Terrorism [1] - 3901:11

terrorist [1] - 4084:24

testified [27] - 3782:4, 3788:17,

3789:2, 3796:15, 3804:21, 3806:7,

3809:15, 3810:9, 3826:2, 3903:22,

3906:9, 3907:2, 3907:9, 3908:17,

3913:14, 3914:3, 3914:4, 3952:19,

3952:21, 3953:3, 3956:15, 3964:14,

3971:7, 3972:8, 4041:19, 4046:23,

4053:2

testify [25] - 3785:14, 3903:12, 3905:3,

3905:5, 3905:9, 3905:16, 3906:12,

3906:17, 3907:7, 3907:9, 3907:11,

3907:25, 3908:18, 3909:14, 3909:24,

3912:20, 3913:15, 3915:21, 3915:24,

3950:5, 3952:6, 3952:9, 3952:12,

3962:22, 4029:22

testifying [19] - 3830:2, 3905:18,

3906:5, 3906:7, 3907:13, 3909:22,

3912:8, 3912:16, 3914:10, 3915:7,

3963:3, 3970:16, 3977:23, 3992:10,

4031:23

testimony [23] - 3780:10, 3805:6,

3805:8, 3813:13, 3825:17, 3886:16,

3904:10, 3904:15, 3906:5, 3908:16,

3912:7, 3912:19, 3912:24, 3916:10,

3956:7, 3970:2, 3973:8, 3997:19,

4027:14, 4037:6, 4037:17, 4041:22,

4052:18

testing [1] - 4087:2

tests [1] - 3833:13

TEXAS [1] - 3773:1

Texas [8] - 3773:4, 3773:15, 3773:23,

3774:4, 3774:7, 3774:12, 3905:23,

3951:25

text [1] - 4080:15

thanked [1] - 4070:3

THE [379] - 3773:10, 3773:13, 3773:20,

3774:2, 3777:2, 3777:24, 3778:3,

3778:12, 3778:14, 3778:21, 3778:23,

3779:10, 3779:13, 3779:15, 3779:19,

3780:4, 3780:6, 3780:11, 3780:14,

3780:17, 3781:1, 3782:9, 3782:11,

3782:19, 3782:21, 3783:1, 3783:3,

3783:13, 3783:17, 3783:19, 3783:22,

3783:24, 3784:2, 3784:19, 3788:12,

3788:19, 3788:22, 3789:4, 3789:5,

3795:15, 3796:4, 3798:13, 3798:16,

3801:11, 3801:12, 3801:13, 3801:18,

3802:12, 3805:7, 3806:16, 3806:20,

3807:3, 3808:3, 3808:13, 3810:5,

3810:12, 3810:14, 3811:10, 3811:11,

3811:14, 3815:1, 3816:4, 3816:21,

3816:22, 3817:5, 3818:1, 3818:4,

3818:25, 3819:22, 3820:11, 3821:5,

3821:21, 3822:19, 3823:11, 3823:14,

3823:20, 3823:22, 3824:2, 3824:13,

3824:18, 3825:6, 3825:11, 3825:21,

3825:22, 3826:10, 3826:11, 3826:12,

3826:13, 3835:24, 3843:16, 3843:20,

3850:21, 3850:22, 3850:23, 3850:24,

3850:25, 3853:11, 3854:14, 3854:18,

3857:23, 3858:5, 3858:11, 3858:25,

3859:1, 3864:17, 3864:20, 3864:22,

3864:25, 3865:2, 3865:7, 3865:10,

3865:12, 3865:18, 3865:23, 3866:14,

3866:19, 3872:7, 3872:9, 3872:11,

3872:13, 3872:14, 3872:15, 3873:6,

3873:7, 3875:25, 3877:8, 3886:23,

3886:25, 3887:4, 3887:6, 3887:14,

3887:16, 3887:20, 3888:1, 3890:1,

3890:2, 3890:7, 3890:8, 3890:10,

3891:12, 3893:12, 3893:19, 3893:20,

3893:21, 3895:20, 3895:22, 3898:21,

3898:24, 3899:1, 3901:16, 3901:24,

3903:24, 3906:1, 3906:3, 3906:7,

3906:10, 3906:18, 3906:20, 3906:25,

3907:3, 3907:12, 3907:20, 3907:23,

3908:4, 3908:8, 3908:19, 3908:24,

3909:5, 3909:11, 3909:23, 3910:1,

3910:6, 3910:12, 3910:15, 3910:19,

3910:21, 3911:5, 3911:7, 3911:11,

3911:19, 3911:23, 3912:5, 3912:14,

3912:19, 3912:21, 3912:23, 3913:5,

3913:8, 3913:16, 3913:21, 3914:5,

3914:8, 3914:14, 3914:16, 3914:25,

3915:4, 3916:11, 3916:14, 3917:22,

3917:24, 3918:6, 3918:23, 3919:3,

3919:6, 3919:13, 3919:15, 3920:15,

3922:21, 3922:23, 3935:18, 3935:22,

3936:1, 3936:12, 3936:13, 3942:12,

3942:15, 3942:17, 3942:20, 3943:23,

3943:24, 3945:10, 3945:11, 3946:2,

3946:5, 3949:6, 3953:10, 3953:11,

3953:12, 3953:16, 3953:18, 3958:16,

3958:20, 3958:22, 3958:24, 3967:25,

3969:23, 3975:16, 3975:17, 3975:19,

3975:20, 3975:21, 3975:23, 3975:24,

3975:25, 3976:1, 3976:3, 3976:4,

3976:5, 3976:8, 3976:14, 3978:1,

3978:6, 3978:17, 3980:7, 3980:13,

3980:20, 3980:21, 3981:25, 3982:2,

3986:11, 3987:7, 3987:9, 3987:15,

3990:23, 3991:1, 3993:20, 3997:3,

3997:12, 3998:1, 4000:24, 4001:3,

4005:23, 4011:8, 4012:6, 4012:8,

4013:16, 4015:15, 4015:18, 4018:14,

4018:21, 4019:20, 4019:21, 4025:12,

4030:11, 4030:15, 4030:17, 4030:18,

4031:21, 4032:9, 4033:24, 4037:4,

4037:7, 4037:16, 4037:18, 4038:6,

4038:8, 4038:20, 4039:1, 4039:10,

4040:5, 4040:8, 4041:13, 4041:16,

4042:6, 4042:8, 4049:19, 4050:11,

4051:11, 4051:15, 4052:7, 4052:10,


4127

4052:21, 4052:22, 4052:24, 4053:19,

4053:20, 4054:13, 4054:15, 4055:10,

4055:11, 4055:12, 4055:14, 4055:16,

4058:8, 4058:10, 4058:11, 4058:14,

4058:16, 4058:17, 4059:1, 4059:3,

4059:4, 4061:10, 4061:13, 4061:14,

4061:15, 4061:16, 4061:18, 4061:19,

4061:20, 4061:21, 4070:12, 4070:15,

4070:16, 4070:18, 4070:20, 4070:21,

4071:4, 4071:24, 4072:4, 4072:7,

4072:22, 4072:24, 4073:5, 4073:6,

4073:9, 4073:10, 4073:11, 4073:12,

4073:18, 4075:14, 4075:22, 4075:24,

4077:18, 4078:2, 4078:3, 4078:9,

4078:15, 4078:19, 4079:5, 4079:10,

4079:12, 4079:16, 4079:19, 4088:3,

4091:9, 4091:16, 4091:17, 4091:18

the. [1] - 3794:19

thea [1] - 4039:13

themselves [4] - 3781:22, 3932:3,

3935:9, 3986:13

theory [1] - 3970:12

therefore [7] - 3777:17, 3900:25,

3901:2, 3901:24, 3994:20, 4035:13,

4051:7

they've [4] - 3824:16, 3830:20,

3912:15, 4023:2

thick [1] - 3968:19

thinking [5] - 3783:3, 3907:4, 3908:6,

3910:13, 3939:9

thinks [1] - 4004:12

third [6] - 3795:4, 3811:17, 3844:24,

3863:11, 3900:9, 4068:18

Thomas [2] - 3902:24, 3905:1

thorough [1] - 4017:1

thoroughly [1] - 4080:20

thoughts [1] - 4075:8

thousand [2] - 3851:6, 3966:16

three [18] - 3848:2, 3850:8, 3863:6,

3866:23, 3867:4, 3887:25, 3921:5,

3921:6, 3931:7, 3940:23, 3966:18,

3972:6, 3972:17, 3995:16, 3995:20,

4056:15, 4068:21, 4082:5

threw [1] - 3976:2

thriving [1] - 3938:4

throat [2] - 3949:4, 3949:5

throughout [3] - 3824:13, 3851:16,

3923:23

thrown [1] - 3786:3

thumb [2] - 3785:11, 3786:9

Thursday [2] - 3869:13, 3878:3

thwart [1] - 4041:9

ticket [12] - 3840:24, 3889:5, 3889:14,

3892:18, 3893:9, 3893:15, 3893:24,

3963:8, 3963:12, 3963:25, 3989:9

tickets [64] - 3848:25, 3875:15,

3878:14, 3878:20, 3878:21, 3879:3,

3879:7, 3879:15, 3879:23, 3879:24,

3880:1, 3880:7, 3880:24, 3881:6,

3881:10, 3881:16, 3881:23, 3882:11,

3883:5, 3883:10, 3883:13, 3884:10,

3885:18, 3885:20, 3889:4, 3889:9,

3889:12, 3891:5, 3891:6, 3891:18,

3892:11, 3893:4, 3893:15, 3894:3,

3894:12, 3894:18, 3894:21, 3894:25,

3895:3, 3895:12, 3896:7, 3932:10,

3983:17, 3985:2, 3985:9, 3985:14,

3985:16, 3985:20, 3985:21, 3990:14,

3995:22, 3995:24, 4005:19, 4012:24,

4022:4, 4022:16, 4022:20, 4023:11,

4024:18, 4031:17, 4031:25, 4032:10,

4033:4, 4034:2

tie [2] - 4016:11, 4016:16

Tier [11] - 3799:23, 3818:11, 3907:17,

3908:7, 3912:13, 3913:25, 3916:7,

3916:13, 3916:23

tier [1] - 3818:10

tiers [1] - 3908:17

timeframe [1] - 4077:4

title [4] - 3872:9, 3872:11, 3872:15,

4014:11

titled [1] - 3933:7

today [9] - 3891:5, 3891:6, 3891:9,

3892:11, 3892:17, 3892:25, 3939:6,

3973:8, 4070:24

together [6] - 3794:4, 3813:20, 3814:4,

3822:11, 3845:5, 3983:15

tomorrow [4] - 3931:24, 3939:10,

4091:12, 4091:16

took [25] - 3792:25, 3793:14, 3800:20,

3801:10, 3814:19, 3816:25, 3876:16,

3914:21, 3942:10, 3944:14, 3944:24,

3945:8, 3949:17, 3967:6, 3971:24,

3974:10, 3977:21, 4011:14, 4016:5,

4035:16, 4039:22, 4054:3, 4067:4,

4068:7, 4076:17

top [25] - 3795:4, 3797:1, 3800:8,

3841:17, 3841:23, 3843:24, 3849:20,

3859:20, 3860:21, 3868:7, 3871:2,

3872:5, 3872:22, 3878:6, 3891:15,

3896:3, 3919:21, 3920:21, 3920:23,

3925:21, 3930:14, 3933:14, 3940:16,

4023:6, 4079:23

topic [1] - 3854:17

Total [3] - 3791:7, 3794:25, 3845:1

total [30] - 3791:10, 3792:4, 3794:23,

3795:17, 3804:1, 3817:20, 3835:18,

3844:10, 3845:3, 3845:11, 3845:13,

3846:10, 3852:10, 3852:19, 3853:5,

3854:20, 3854:21, 3855:15, 3856:2,

3856:15, 3856:22, 3863:18, 3868:23,

3894:23, 3897:12, 3964:25, 3965:12,

3966:24, 3973:25, 4058:8

totally [2] - 3921:11, 4039:8

totals [2] - 3852:14, 3852:17

tour [2] - 4017:5, 4017:6

touring [2] - 3885:11, 3897:6

towards [2] - 3808:7, 4018:3

trace [2] - 3970:23, 3991:22

traced [1] - 3972:1

tracing [1] - 3818:18

track [6] - 3811:1, 3811:2, 3816:19,

3822:8, 3965:4, 4054:24

tracking [3] - 3790:25, 3800:11,

3818:13

trail [6] - 3976:22, 3977:1, 3977:4,

3978:11, 4020:7, 4020:11

trails [5] - 3978:12, 3978:14, 3991:10,

4040:23, 4041:10

train [3] - 3951:5, 3951:7, 3951:9

trained [4] - 3952:15, 3952:17, 3982:6,

3982:8

training [4] - 3952:7, 3953:20,

4010:10, 4084:21

transaction [12] - 3793:19, 3818:19,

3842:23, 3860:14, 3863:9, 3868:6,

3945:5, 3958:5, 3959:7, 3960:18,

3977:5, 4006:11

transactions [13] - 3842:20, 3844:7,

3846:11, 3855:5, 3957:17, 3959:16,

3959:23, 3960:15, 3966:21, 3983:14,

3991:11, 3991:14, 3991:16

Transcript [1] - 3774:14

transcript [3] - 3916:4, 3916:17,

4092:4

transcription [1] - 3774:14

transfer [6] - 3805:20, 3816:11,

3870:6, 3956:16, 3996:10, 3996:12

transferred [11] - 3777:22, 3782:5,

3782:7, 3788:2, 3788:24, 3790:15,

3791:4, 3792:21, 3805:3, 3873:15,

3875:3

transfers [11] - 3803:20, 3803:22,

3816:16, 3816:17, 3847:7, 3848:13,

3945:1, 3948:16, 3956:12, 3956:13,

3956:17

transmission [1] - 3929:25

transpired [2] - 4006:9, 4065:3

travel [3] - 3824:5, 3824:6, 3889:9

traveled [2] - 4014:10, 4015:5

treat [2] - 4035:2

treated [4] - 3833:9, 4035:6, 4035:11,

4035:13

treaties [1] - 4045:6

treating [1] - 4035:19

treatment [1] - 4010:25

Treaty [1] - 3847:16

treaty [4] - 3847:22, 3859:13, 4045:11,

4046:7

trends [2] - 4084:4

Trevor [2] - 4089:21, 4089:23

TRIAL [1] - 3773:7

trial [4] - 3777:16, 3777:17, 3786:16,

3824:13

tricky [1] - 3865:1

tried [1] - 4091:7

trip [1] - 3871:22

trouble [2] - 3884:11, 4032:11

truck [1] - 3883:6

true [14] - 3785:1, 3785:4, 3798:3,

3798:13, 3907:5, 3959:17, 3960:3,

3961:1, 3965:14, 3991:16, 3999:4,

4004:1, 4005:11, 4045:13

trust [2] - 4075:6, 4075:20

Trust [6] - 4053:18, 4053:21, 4062:15,

4065:10, 4076:22, 4080:18

trusts [1] - 4076:19

truth [13] - 3825:19, 3825:20, 3886:8,


4128

3886:12, 3903:19, 3916:12, 3987:1,

4052:20, 4072:20, 4079:14

try [13] - 3781:8, 3827:5, 3827:6,

3890:20, 3904:14, 3923:1, 3949:19,

3965:4, 3983:13, 3991:22, 4041:16,

4089:2, 4091:4

trying [41] - 3777:20, 3778:8, 3779:9,

3805:12, 3808:5, 3813:23, 3829:19,

3831:12, 3835:16, 3864:18, 3906:22,

3927:1, 3934:22, 3936:19, 3937:21,

3965:22, 3970:20, 3980:4, 3981:21,

3984:1, 3987:22, 3990:6, 4018:19,

4020:14, 4023:22, 4024:5, 4024:21,

4028:10, 4028:14, 4028:15, 4028:18,

4029:24, 4029:25, 4031:13, 4034:11,

4034:12, 4037:15, 4041:8, 4068:15,

4085:4, 4085:5

Tuesday [2] - 3869:24, 3939:19

tune [1] - 3938:1

Tupelo [4] - 3797:2, 3797:5, 3797:8,

3797:9

turn [9] - 3790:22, 3796:19, 3796:24,

3799:20, 3824:15, 3910:24, 3911:8,

3981:18, 4081:18

turned [3] - 3937:8, 4021:12, 4050:23

turning [1] - 3937:11

Tuteli [1] - 3797:12

twin [1] - 4061:15

twist [1] - 3867:9

Two [1] - 3992:20

two [73] - 3780:2, 3792:8, 3813:11,

3827:25, 3828:17, 3837:24, 3838:8,

3838:23, 3841:13, 3846:15, 3854:16,

3855:11, 3855:12, 3856:20, 3867:25,

3868:22, 3875:15, 3878:14, 3883:6,

3883:15, 3885:18, 3885:19, 3889:6,

3889:17, 3895:2, 3898:11, 3901:22,

3914:22, 3915:20, 3916:9, 3931:3,

3931:6, 3931:12, 3945:2, 3947:22,

3955:2, 3955:7, 3966:7, 3966:10,

3966:11, 3966:13, 3966:16, 3972:7,

3972:17, 3975:21, 3985:13, 3987:12,

3987:15, 3987:16, 3992:18, 3992:19,

3992:20, 3995:16, 3995:19, 3995:24,

4011:14, 4021:1, 4023:19, 4024:24,

4025:4, 4025:15, 4034:7, 4034:9,

4034:13, 4039:5, 4056:18, 4061:21,

4078:24, 4079:2, 4083:17, 4086:25,

4090:24

type [7] - 3860:12, 3908:15, 3918:25,

4030:21, 4048:24, 4076:2

types [2] - 4083:17, 4086:25

typewritten [1] - 3988:21

typical [2] - 3862:4, 4019:16

typically [3] - 4020:11, 4020:17,

4041:16

U

U.S [54] - 3773:17, 3782:5, 3830:25,

3831:1, 3832:10, 3833:14, 3840:7,

3845:14, 3846:3, 3847:9, 3847:25,

3848:1, 3848:14, 3850:19, 3850:23,

3851:4, 3851:17, 3853:16, 3854:22,

3855:24, 3856:22, 3857:2, 3857:10,

3857:12, 3863:12, 3863:20, 3863:22,

3896:20, 3941:20, 3945:9, 3945:11,

3946:19, 3947:20, 3955:10, 3957:14,

3961:25, 3964:17, 3964:21, 3964:23,

3965:10, 3965:13, 3965:25, 3966:8,

3966:13, 3966:25, 3967:3, 3972:4,

4042:12, 4045:8, 4045:12, 4048:3,

4050:14, 4080:17

UK [2] - 4048:22, 4059:2

ultimate [1] - 4064:11

ultimately [4] - 3795:24, 3836:24,

4060:11, 4083:3

uncomfortable [1] - 4082:24

uncommon [1] - 3955:9

under [25] - 3788:8, 3790:13, 3791:7,

3794:24, 3807:11, 3811:25, 3812:10,

3813:3, 3813:7, 3825:4, 3825:6,

3862:18, 3864:11, 3886:19, 3929:10,

3937:4, 3937:25, 4008:1, 4019:6,

4019:8, 4019:12, 4037:3, 4044:16,

4044:19, 4090:9

underlying [2] - 3828:4, 3828:5

understood [2] - 3815:3, 4080:24

underway [2] - 3812:24, 3812:25

union [2] - 3925:2, 4054:12

United [35] - 3825:14, 3828:2, 3828:3,

3831:1, 3837:3, 3837:6, 3837:17,

3838:9, 3840:4, 3843:11, 3844:2,

3847:6, 3847:22, 3904:3, 3921:18,

3942:22, 3945:13, 3945:18, 3947:23,

3948:22, 3954:11, 3954:17, 3954:19,

3956:24, 3957:10, 3959:9, 3960:7,

3968:7, 4003:10, 4003:15, 4046:9,

4049:4, 4049:5, 4052:15, 4055:11

uNITED [1] - 3773:1

UNITED [2] - 3773:4, 3773:10

units [1] - 3828:17

universe [1] - 4018:9

University [5] - 3950:18, 4054:25,

4055:6, 4055:9, 4055:13

unless [9] - 3822:21, 3828:21,

3853:14, 3853:16, 3853:21, 3909:11,

3916:14, 3916:18, 4038:18

unload [1] - 3822:21

unlock [1] - 4011:7

unsigned [2] - 4066:21, 4071:11

untoward [1] - 4009:21

unusual [3] - 3942:9, 3956:4, 4027:25

unwarranted [1] - 3902:1

up [122] - 3777:8, 3778:9, 3779:23,

3780:9, 3781:12, 3792:11, 3798:16,

3802:10, 3803:9, 3803:10, 3807:5,

3810:4, 3811:7, 3814:6, 3817:24,

3819:22, 3821:21, 3838:2, 3844:16,

3845:17, 3850:14, 3852:10, 3852:14,

3852:17, 3858:1, 3858:5, 3860:10,

3867:10, 3872:5, 3875:25, 3877:9,

3878:10, 3879:17, 3881:15, 3882:16,

3883:7, 3884:2, 3884:5, 3884:14,

3886:9, 3886:13, 3886:14, 3886:17,

3889:20, 3890:3, 3891:10, 3892:7,

3892:15, 3892:20, 3894:12, 3894:25,

3901:15, 3901:21, 3905:8, 3905:18,

3906:1, 3907:18, 3908:23, 3908:24,

3909:3, 3911:1, 3912:12, 3912:15,

3914:8, 3914:23, 3917:22, 3929:2,

3931:14, 3934:13, 3935:25, 3939:1,

3939:17, 3939:23, 3940:17, 3959:24,

3963:5, 3965:23, 3974:8, 3978:16,

3978:22, 3979:3, 3981:2, 3983:5,

3984:6, 3985:24, 3985:25, 3986:2,

3986:14, 3986:23, 3987:4, 3988:2,

3989:13, 3992:8, 3997:2, 3997:7,

3998:4, 3998:14, 4000:23, 4001:8,

4004:14, 4023:23, 4027:20, 4031:18,

4038:6, 4041:13, 4041:24, 4043:8,

4044:25, 4045:11, 4052:13, 4062:20,

4065:11, 4066:24, 4067:2, 4067:3,

4068:1, 4068:18, 4068:24, 4079:23,

4082:21, 4083:1, 4089:18

up-to-date [1] - 3914:23

update [1] - 3878:12

upper [2] - 3789:23, 3892:23

uptake [1] - 3777:12

US [1] - 3773:14

USC [1] - 4003:8

USD [1] - 3850:20

V

vacancy [1] - 4062:3

Valerie/Stanford [1] - 3862:16

valid [1] - 3916:19

value [6] - 3791:13, 3795:5, 3810:18,

3810:19, 3811:17, 4086:20

various [6] - 3793:25, 3872:10,

3878:6, 3941:8, 3948:4, 4084:2

Velcro [1] - 3864:15

verification [3] - 4084:14, 4086:17,

4086:20

verify [2] - 4085:17, 4087:15

versa [2] - 3809:14, 3828:3

version [7] - 3931:5, 3933:3, 4031:8,

4083:1, 4083:3, 4083:7

Version [2] - 3931:6, 3931:7

versions [1] - 3931:3

versus [2] - 3908:17, 4034:9

via [3] - 3862:16, 3938:17, 3944:2

vice [3] - 3809:14, 3828:3, 4080:8

vice-president [1] - 4080:8

view [1] - 3878:18

viewed [1] - 3777:9

violate [3] - 3827:23, 3827:24, 3828:10

violations [3] - 3827:8, 3827:9,

3827:14

VIP [1] - 3885:6

vision [1] - 4065:7

visit [1] - 4063:11

visits [3] - 3880:20, 3881:1, 3882:23

voir [2] - 3909:8, 3909:16

VOLUME [1] - 3773:8

VS [1] - 3773:5Johnny C. Sanchez, RMR, CRR - [email protected]

4129

W

W-2 [2] - 3833:21, 3834:18

wage [2] - 3834:24, 3835:1

wages [2] - 3832:25, 3833:12

Wait [1] - 3983:3

wait [3] - 3852:18, 3878:16, 3909:5

waive [1] - 3918:2

waived [1] - 3784:21

walk [7] - 3863:6, 3864:14, 3956:7,

3992:11, 4014:15, 4015:25, 4074:24

walked [2] - 3976:25, 4063:5

walking [1] - 3814:15

Wall [1] - 4063:20

wallet [10] - 3854:8, 3862:4, 3968:12,

3968:14, 3968:18, 3968:20, 3968:21,

3968:22, 3968:25, 3969:5

wants [3] - 3891:17, 3938:5, 4034:21

wardrobe [1] - 3875:24

warm [1] - 3777:25

warrant [1] - 3918:3

WARREN [34] - 4052:15, 4053:5,

4053:23, 4054:17, 4055:17, 4058:12,

4058:18, 4059:5, 4061:24, 4070:22,

4071:2, 4071:5, 4071:22, 4072:1,

4072:6, 4072:8, 4072:9, 4072:18,

4073:1, 4073:14, 4073:19, 4075:15,

4075:19, 4076:1, 4077:20, 4078:4,

4078:10, 4078:13, 4078:20, 4078:21,

4079:13, 4079:20, 4088:4, 4091:14

Warren [4] - 3773:16, 4016:9, 4016:10,

4089:10

WARREN.............. [1] - 3776:14

Washington [1] - 3773:18

watch [1] - 3911:8

ways [2] - 3909:13, 3990:20

we' [1] - 3783:4

week [10] - 3864:10, 3868:15, 3869:12,

3869:18, 3945:7, 3972:9, 4065:13,

4068:11, 4068:12

weekly [2] - 3791:25, 3799:23

weeks [10] - 3875:2, 3900:6, 3935:13,

3942:18, 3942:19, 3948:20, 3992:18,

3995:16, 3995:19, 3995:20

welcome [1] - 4066:9

welcoming [1] - 4066:9

well... [1] - 4078:15

white [3] - 3798:25, 4040:25, 4041:2

whole [11] - 3824:13, 3825:19,

3851:16, 3870:20, 3897:16, 3909:18,

3953:7, 4014:22, 4021:11, 4052:20,

4071:10

wholly [1] - 4087:14

Wicket [1] - 3794:15

wife [15] - 3831:18, 3832:16, 3832:19,

3832:25, 3834:17, 3837:19, 3839:4,

3839:22, 3840:1, 3840:4, 3843:12,

3844:3, 3892:14, 3893:16, 3896:23

wife's [2] - 4048:1, 4048:5

William [1] - 3773:16

Williams [2] - 3934:3, 4001:9

willing [2] - 3808:8, 3990:19

window [1] - 3840:11

wingfield [14] - 3881:15, 3882:3,

3882:17, 3882:20, 3883:3, 3883:9,

3883:12, 3883:20, 3884:16, 3886:15,

3986:6, 3992:5, 4022:25, 4023:6

Wingfield [13] - 3876:22, 3876:23,

3876:24, 3877:12, 3878:19, 3879:2,

3879:20, 3879:22, 3880:13, 3880:17,

3984:15, 3985:13, 4033:25

wingfield's [2] - 3881:22, 3884:6

wipe [1] - 3793:9

wiped [3] - 3793:7, 3814:16, 3814:21

wire [16] - 3828:8, 3847:7, 3848:13,

3945:1, 3945:16, 3946:8, 3946:18,

3946:21, 3947:1, 3947:9, 3947:15,

3947:19, 3948:5, 3948:8, 3948:10,

3948:16

wired [2] - 3945:7, 3948:12

wires [3] - 3848:1, 3947:23, 3948:21

wish [4] - 3883:10, 3884:9, 3921:10,

4032:9

wishes [1] - 3780:24

withdraw [4] - 3975:8, 3975:14,

3976:12, 4045:10

withdrawal [21] - 3860:15, 3860:23,

3861:6, 3861:18, 3862:1, 3862:11,

3863:9, 3863:10, 3864:9, 3866:2,

3866:4, 3866:7, 3866:9, 3867:12,

3869:6, 3870:1, 3947:10, 3958:1,

3958:3, 3959:8, 3971:25

withdrawals [24] - 3862:21, 3863:3,

3864:4, 3869:3, 3874:18, 3874:19,

3875:5, 3956:16, 3957:15, 3957:21,

3961:14, 3961:17, 3962:14, 3962:20,

3962:23, 3969:12, 3969:19, 3971:4,

3975:5, 3995:15, 3995:19, 4020:19,

4021:4

withdrawing [4] - 3860:7, 3971:10,

4021:19, 4022:2

withdrawn [6] - 3863:17, 3863:23,

3868:25, 3869:8, 3991:15, 3991:23

withdraws [1] - 3868:12

withdrew [4] - 3804:5, 3804:11,

3866:25, 3970:16

WITNESS [71] - 3775:2, 3789:5,

3798:13, 3801:12, 3811:10, 3816:21,

3825:21, 3826:11, 3826:13, 3850:22,

3850:24, 3853:11, 3859:1, 3872:9,

3872:13, 3872:15, 3873:7, 3877:8,

3890:2, 3890:8, 3891:12, 3893:20,

3901:16, 3901:24, 3919:15, 3922:23,

3936:13, 3942:17, 3943:24, 3945:11,

3953:11, 3953:16, 3958:20, 3958:24,

3975:16, 3975:19, 3975:21, 3975:24,

3976:1, 3976:4, 3980:21, 3987:15,

4011:8, 4019:21, 4030:18, 4032:9,

4033:24, 4041:16, 4051:11, 4052:7,

4052:21, 4053:20, 4054:15, 4055:11,

4055:14, 4058:10, 4058:16, 4059:3,

4061:13, 4061:15, 4061:18, 4061:20,

4070:15, 4070:18, 4070:21, 4073:6,

4073:10, 4073:12, 4075:24, 4078:3,

4091:17

witness [53] - 3777:10, 3777:19,

3778:10, 3778:19, 3780:3, 3780:9,

3781:11, 3781:15, 3781:20, 3782:14,

3782:24, 3798:12, 3802:11, 3804:14,

3814:25, 3816:25, 3818:23, 3818:24,

3819:11, 3821:4, 3821:23, 3822:5,

3822:18, 3822:20, 3823:24, 3824:17,

3824:19, 3825:13, 3903:12, 3903:22,

3907:1, 3907:7, 3910:4, 3913:7,

3913:8, 3913:9, 3914:13, 3915:6,

3949:2, 3949:24, 3952:15, 3952:18,

3953:6, 4017:25, 4026:25, 4044:12,

4044:18, 4048:9, 4050:4, 4050:17,

4052:6, 4052:14, 4091:14

witness's [1] - 3805:6

woman [2] - 3876:22, 3877:18

won [1] - 3876:3

wondering [1] - 3876:1

word [16] - 3797:25, 3798:19, 3798:22,

3799:9, 3799:13, 3799:25, 3800:10,

3800:14, 3821:12, 3821:17, 3821:25,

3872:7, 3936:1, 4032:17, 4032:18,

4063:3

words [8] - 3841:13, 3906:15, 3937:5,

3988:22, 4032:20, 4066:2, 4066:10,

4066:14

works [1] - 3874:17

world [2] - 3851:12, 4027:5

worldwide [1] - 3831:3

worried [1] - 3937:11

worry [1] - 3794:14

Worth [1] - 3902:21

wrapping [2] - 3819:22, 3821:21

write [1] - 3931:2

writes [7] - 3871:9, 3879:13, 3881:3,

3889:2, 3899:20, 3902:8, 3938:16

writing [3] - 3809:22, 3861:10,

4009:23

written [8] - 3790:2, 3798:24, 3799:1,

3810:23, 3840:18, 3921:2, 3929:18,

3978:23

wrote [7] - 3785:1, 3785:4, 3813:24,

3940:12, 3979:24, 4074:20, 4090:10

X

XB [1] - 4034:1

XL [1] - 3894:10

Y

y'all [1] - 3967:11

Y-O-U-N-G [1] - 3826:13

yacht [3] - 3802:17, 3802:21, 3803:5

yachts [1] - 3802:25

yard [1] - 3894:14

year [23] - 3846:4, 3846:15, 3854:21,

3856:17, 3856:20, 3871:11, 3876:3,

3885:22, 3886:4, 3894:16, 3897:24,

3901:13, 3922:18, 3932:8, 4055:21,

4055:23, 4070:13, 4082:3, 4082:7,


4130

4082:13, 4084:12, 4091:3

years [47] - 3785:5, 3785:7, 3792:7,

3793:25, 3795:9, 3804:8, 3805:14,

3806:2, 3813:8, 3814:11, 3835:9,

3836:11, 3836:18, 3836:19, 3849:15,

3871:12, 3875:16, 3915:21, 3937:25,

3938:3, 3948:17, 3948:19, 3950:24,

3953:2, 3954:1, 3954:6, 3972:3,

3976:18, 3976:20, 3991:3, 3991:18,

3991:20, 3991:22, 4010:9, 4019:7,

4019:13, 4053:11, 4055:23, 4056:15,

4057:6, 4057:19, 4058:3, 4058:6,

4058:8, 4058:19

yellow [1] - 4016:16

yen [1] - 3851:13

yes-or-no [1] - 4075:16

yesterday [8] - 3777:6, 3780:24,

3784:9, 3789:14, 3793:19, 3814:3,

3882:11, 3891:13

Yolanda [1] - 3984:21

York [3] - 3773:17, 3896:20, 4048:7

Young [18] - 3825:15, 3826:9, 3831:9,

3836:3, 3838:20, 3840:15, 3858:13,

3870:3, 3874:5, 3876:7, 3904:22,

3915:20, 3918:10, 3931:17, 3944:11,

4003:5, 4013:18, 4018:3

YOUNG [2] - 3775:19, 3826:1

young [1] - 3826:13

yourself [6] - 3826:8, 3827:1, 3828:15,

3950:5, 4049:7, 4053:6

Z

zone [1] - 3884:13

zoom [4] - 3789:23, 4013:5, 4013:6,

4013:14

allen stanford criminal trial transcript volume 13 feb. 8, 2012

Documents