郭文贵破产案 · EXHIBIT · ECF #250-14

元数据

当事人: 郭文贵 (Guo Wengui / Miles Guo / Ho Wan Kwok)
法院: CTB
案号: 22-50073
ECF #: 250
类型: EXHIBIT
立案日: 2022-04-22

原始法庭文件为英文，下方为英文全文。

全文

# **EXHIBIT PAX 14**

Transcript of the April 8, 2022 Deposition of Craig Jalbert

#### Case 22-50073 Doc 250-14 Filed 04/22/22 Entered 04/22/22 16:59:37 Page 2 of 85

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES BANKRUPTCY COURT DISTRICT OF CONNECTICUT BRIDGEPORT DIVISION **------------------------------------------x** IN RE: Chapter 11 HO WAN KWOK, Case No. 22-50073(JAM) Debtor. **------------------------------------------x** DATE: April 8, 2022 TIME : 1 0 : 1 7 A. M . VIDEO-RECORDED DEPOSITION OF CRAIG JALBERT of VERDOLINO & LOWEY, P.C., in the above entitled matter, at the above date and time, held at the offices of O'Melveny & Myers LLP, 7 Times Square, New York, New York 10036, by Lenaya Lynch, a Notary Public and Shorthand Reporter of the State of New York. Page 1

| I | 2 APPEARANCES: | 1 | C. JALBERT | |----------------|-----------------------------------------------------------------------------|----|------------------------------------------------------------| | | 3 O'MEL VENY & MYERS LLP | 2 | York. My name is Jonathan Difilippo | | | Attorneys for PACIFIC ALLIANCE ASIA 4 OPPORTIJNITY FUND LLP | 3 | from the firm Veritext and I am the | | | 7 Times Square, 30th Floor | 4 | videographer. The Court Reporter is | | | 5 New York, New York 10036 BY LAURA ARONSSON, ESQ. | 5 | Lenaya Lynch from the firm, Veritext. | | 6 | DA YID HARBACH, ESQ. | 6 | I'm not authorized to administer an | | 7 | MaKENZIE B RUSSO, ESQ | 7 | oath. I'm not related to any party | | 8 | BROWN RUDNICK LLP | 8 | in this action nor am I financially | | | 9 Attorneys for HO WAN KWOK | 9 | interested in the outcome. | | | 7 Times Square 10 New York, New York 10036 | 10 | Counsel and all present in the | | | BY KENNETH J AULET, ESQ | 11 | room and everyone attending remotely | | 11 12 | | 12 | will now state their appearances and | | | PULLMAN & COMLEY LLC 13 Attorneys for CREDITOR'S COMMITTEE | 13 | affiliations for the record. If | | | 850 Mam Street | 14 | there are any objections to the | | | 14 PO Box 7006 Bridgeport, Connecticut 06601 | 15 | proceeding, please state them at the | | | 15 BY:IRVEJGOLDMAN,ESQ. | 16 | time of your appearance beginning | | 16 | 17 COHN, BIRNBAUM, SHEA P C | 17 | with the noticing attorney. | | | Attorney for GOLDEN SPRING | 18 | MS. ARONSSON: LauraAronsson, | | 18 | 100 Pearl Street, Smte 12 New Haven, Connecticut 06103 | 19 | O'Melveny and Myers for Pacific | | | 19 BY TIMOTHY MILTENBERGER, ESQ. via Teleconference | 20 | Alliance Asia Opportunity Fund LP. | | 20 | | 21 | MR. HARBACH: David Harbach | | 21 | ALSO PRESENT | 22 | with O'Melveny and Myers for the same | | 22 | | 23 | client. | | 23 | JON DIFILIPPO, Legal Videographer | 24 | MS. RUSSO: Makenzie Russo with | | 24 25 | * * * | 25 | O'Melveny and Myers for the same | | | Page 2 | | Page 4 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | THE VIDEOGRAPHER: Good | 2 | client. | | 3 | morning. We are going on the record | 3 | MR. AULET: Kenneth Aulet of | | 4 | at 10: 17 a.m. on April 22nd -- I'm | 4 | Brown Rudnick, proposed counsel for | | 5 | sorry, April 8th, 2022. Please note | 5 | the debtor, Ho Wan Kwok. | | 6 | that the microphones are sensitive | 6 | MR. GOLDMAN: Irve Goldman, | | 7 | and may pick up whispering, private | 7 | Pullman and Comley, proposed counsel | | 8 | conversations and cellular | 8 | for the Creditor's Committee. | | 9 | interference. Please tum off all | 9 | THE VIDEOGRAPHER: Will the | | 10 | cell phones or place them away from | 10 | Court Reporter please swear in the | | 11 | the microphone as they can interfere | 11 | Witness? | | 12 | with the deposition audio. Audio and | 12 | MR. AULET: There's one person | | 13 | video recording will continue to take | 13 | on the line. | | 14 | place unless all parties agree to go | 14 | MR. MILTENBERGER: Are we done | | 15 | off the record. | 15 | with the people in person? Timothy | | 16 | This is Media Unit 1 of the | 16 | Miltenberger for Golden Spring, NY | | 17 | video-recorded deposition of Craig | 17 | Limited. | | 18 | Jalbert in the matter ofre: Ho Wan | 18 | THE VIDEOGRAPHER: Will the | | 19 | Kwok filed in the United States | 19 | Court Reporter please swear in the | | | Bankruptcy Court, District of | 20 | Witness? | | | Connecticut, Bridgeport Division, | | 21 C RA I G J A L B E RT, called as a | | 20 21 22 | Case Number 22-50073. | | 22 witness, having been first duly sworn by a | | 23 | This deposition is being held | | 23 Notary Public of the State of New York, was | | 24 25 | at O'Melveny and Myers LLP, located at Times Square Tower, New York, New | | 24 examined and testified as follows: 25 EXAMINATION BY |

2 (Pages 2 - 5)

1 C. JALBERT 2 MS. ARONSSON: 3 Q. Please state your name for the 4 record. 5 A. Craig Jalbert, J-A-L-B-E-R-T. 6 Q. What is your address? 7 A. Home address? The business 8 address is 124 Washington Street, Suite 9 101, Foxboro, Massachusetts 02035. 10 Q. Good morning. We previously 11 met off the record. On the record, my name 12 is Laura Aronsson and I'm an attorney at 13 O'Melveny and Myers for Pacific Alliance 14 Asia Opportunity Fund. Mr. Jalbert, have 15 you ever testified in court before? 16 A. Yes. 1 7 Q. In what case -- or I'll start 18 how many times? 19 A. 50, 60, 70 something. 20 **MR GOLDMAN:** Before we get too 21 far into things, can I just ask -- 22 this is a notice of deposition 23 relating to what contested matter? 24 There are a number of motions before 25 the Court. The notice of deposition 1 C. JALBERT 2 doesn't indicate which of the matters 3 it relates to. 4 MS. ARONSSON: Sure. So we 5 have -- we served a 30(b )6 notice of 6 deposition which I'll mark as an 7 exhibit so that we're all on the same 8 page but it relates to the retention 9 ofVerdolino and Lowey. 10 MR GOLDMAN: All right. I 11 just wasn't sure because it's not 12 identified on the notice. 13 MS. ARONSSON: Thank you. 14 Q. Sorry. You said 50 or 60 15 times? 16 A. 70, 80, I don't know. I have 1 7 not kept -- I've got a list of ten years Page 6 18 that goes back 40 or 50 and I've been doing 19 it for 30. So no idea. 20 **Q.** Well, we can talk about some of 21 the broad categories of experience you have 22 later but let's start just to go over a few 23 procedures that I'm sure you're familiar 24 with. Do you understand that you're 25 testifying under oath today? 1 C. JALBERT 2 A. Yes. 3 **Q.** Do you understand that means 4 that you're swearing that all of your 5 answers are truthful? 6 A. Yes. 7 **Q.** And that you are subject to the 8 penalty of perjury? 9 A. Yes. 10 **Q.** The Videographer is recording 11 everything on camera and the Court Reporter 12 is preparing a written record of what we 13 discuss here today and will later produce a 14 copy of that transcript. Do you 15 understand? 16 A. Yes. 17 Q. Unlike normal conversation, it 18 is important that we not talk over one 19 another. Please wait for me to finish my 20 question before you answer. I'll try to do 21 the same for you. Do you understand? 22 A. Yes. 23 **Q.** Your answers need to be 24 audible. A shake of the head is 25 insufficient as are statements like uh-huh. 1 C. JALBERT 2 Do you understand? 3 A. Understood. 4 Q. If you do not understand my 5 question, please ask me to repeat. 6 Otherwise, I'll assume that you do 7 understand the question. Is that okay? 8 A. Yes. 9**Q.** If you need a break, just let Page 8 10 me know and we can take one but if there's 11 a question pending, please answer it before 12 we break. Are you represented by Counsel 13 today? 14 A. I think so. 15 Q. Who do you understand to be 16 representing you? 17 A. Ken Aulet. 18 Q. If your attorney objects to a 19 question, you should still answer it unless 20 you don't understand the question or 21 Counsel instructs you not to answer. Do 22 you understand? 23 A. Yes. 24 **Q.** Are you suffering from any 25 condition that would impair your ability to

3 (Pages 6 - 9)

| 1 | C. JALBERT | | C. JALBERT | |-----|---------------------------------------------------------|----|--------------------------------------------------------------------------| | | 2 testify accurately or truthfully? | | 2 been designated to testify about each topic | | 3 | A. No. | | 3 listed here? | | 4 | Are you taking any medications Q. | 4 | MR AULET: Objection. | | | 5 that might interfere with your ability to | 5 | A. Yes. | | | 6 give accurate or truthful testimony? | 6 | MR AULET: He's been | | 7 | A. No. | 7 | designated as per our responses and | | 8 | Is there any reason why you Q. | 8 | objections. | | | 9 cannot testify truthfully and accurately | 9 | MS. ARONSSON: Thank you. | | | 10 today? | 10 | Q. Are you familiar with these | | 11 | A. No. | | 11 subject areas? | | 12 | MS. ARONSSON: Tab one. The | 12 | A. Yes. | | 13 | Court Reporter is going to be marking | 13 | Do you understand that you are Q. | | 14 | what will be Jalbert Exhibit 1. | | 14 required to testify as to Verdolino and | | 15 | (Whereupon, Notice of | | 15 Lowey's knowledge about these topics, not | | 16 | Deposition was marked as Jalbert | | 16 just your own? | | 1 7 | Exhibit 1 for identification as of | 17 | A. Yes. | | 18 | this date by the Reporter.) | 18 | Q. Do you understand that you were | | 19 | All right, Mr. Jalbert. Do you Q. | | 19 required to obtain all of the knowledge and | | | 20 recognize this document? | | 20 information necessary to allow you to fully | | 21 | A. I do. | | 21 and honestly testify concerning each of | | 22 | Q. What is it? | | 22 these topics upon Verdolino and Lowey's | | 23 | A. Pacific Alliance Asia | | 23 behalf) | | | 24 Opportunity Fund LLP's Notice of Deposition | 24 | MR AULET: Same objection as | | | 25 ofVerdolino and Lowey PC pursuant to Rule Page 10 | 25 | before. Page 12 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 30(b)(6) of the Federal Rules of Civil | 2 | A. I did the best I could. | | | 3 Procedure. | 3 | What, if anything, did you do Q. | | 4 | Is it your understanding that Q. | | 4 to prepare for this deposition? | | | 5 you are testifying today in connection with | 5 | A. I spoke with attorney Ben | | | 6 in re: Ho Wan Kwok? | | 6 Silverberg, with Counsel, Ken Aulet, I | | 7 | A. Yes. | | 7 spoke with my colleagues, Matthew Flynn and | | 8 | Can you please tum to Page 6 Q. | | 8 Mary Jo Schindler. I reviewed a | | | 9 -- | | 9 significant amount of documents, some filed | | 10 | A. Excuse me, I just forgot to get | | 10 with the Court, some prepared internally. | | | 11 my glasses. | | 11 Reviewed e-mails. Covered as much as I | | 12 | MS. ARONSSON: Can we go off | | 12 could. | | 13 | the record for one minute? | 13 | Did you collect the documents Q. | | 14 | THE VIDEOGRAPHER: The time is | | 14 that you prepared or were they provided to | | 15 | 10:24 a.m. and we are off the record. | | 15 you by Counsel? | | 16 | (Whereupon, an off-the-record | 16 | A. The documents that -- are you | | 17 | discussion was held.) | | 1 7 asking for the documents that we sent to | | 18 | THE VIDEOGRAPHER: The time is | | 18 O'Melveny? | | 19 | 10:24 a.m. and we're back on the | 19 | I'm asking -- taking a step Q. | | 20 | record. You may proceed. | | 20 back, just asking about your preparation | | 21 | Can you tum to Page 6 to the Q. | | 21 for today's deposition. | | | 22 heading Rule 30(b)(6) deposition topics? | 22 | A. I just looked at my own | | 24 | 23 You see that? A. Yes. | | 23 documents and my own e-mails on the 24 Verdolino and Lowey server. | | 25 | Do you understand that you have Q. | 25 | Q. Generally, what were the |

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| 1 | C. JALBERT | 1 | C. JALBERT | |----|----------------------------------------------------------------------|----|------------------------------------------------------------------------------------------| | | 2 subject matters of those e-mails? | 2 | Anyone else besides the people Q. | | 3 | all of A. It was looking at the -- | | 3 that we've talked about? | | | not all of them. Many ofmy e-mails, 4 -- | 4 | A. Regarding the -- just regarding | | | the statement of financial 5 the SOF A's -- | | 5 the deposition? | | | 6 affairs -- the schedules, the global notes, | 6 | Yes. Q. | | | 7 the global notes and specific notes, most | 7 | A. No. | | | 8 of the pleadings to employ professionals, | 8 | You haven't spoke to the Q. | | | 9 particularly ours, the motion for the DIP | | 9 debtor? | | | 10 financing, many of the objections, not all | 10 | A. About the deposition? | | | 11 of them. I'm trying to think if there's | 11 | Q. About the deposition. | | | 12 anything else. I can't think of anything | 12 | A. No. | | | 13 off the top beyond that -- | 13 | Have you ever met the debtor? Q. | | 14 | Q. Thank you. That's helpful. So | 14 | A. Yes. | | | 15 you mentioned that you spoke to your | 15 | Q. When did you meet the debtor? | | | 16 attorneys, Ben and Ken? | 16 | The continued meeting of342 -- A. | | 17 | A. Yes. | | 17 or 341 meeting which was I think Wednesday, | | 18 | When did you speak to them? Q. | | 18 the first time I met him. | | 19 | A. Well, we were delayed a little | 19 | Is that the only time you met Q. | | | 20 bit so I had a few minutes this morning | | 20 the debtor? | | | 21 with Ken. I spoke with Ben briefly last | 21 | A. Yes. | | | 22 night. Again, this morning on -- unrelated | 22 | Outside ofthe 341 proceeding, Q. | | | 23 to the deposition and I had previously | | 23 did you interact with the debtor? | | | 24 spoken to Ken probably one or two times | 24 | A. No. | | | 25 over the last few days, give or take. | 25 | I just want to cover a little Q. | | | Page 14 | | Page 16 | | | | | | | | | | | | 1 | C. JALBERT | | C. JALBERT | | 2 | Were each of these interactions Q. | | 2 bit of your background. Can you talk about | | | 3 over the phone? | | 3 your educational history since high school? | | 4 | A. Until today, yes. | 4 | A. I graduated from Western | | 5 | About how long did you spend Q. | | 5 Connecticut High School in 1979. I went to | | | 6 preparing with your attorneys in connection | | 6 Boston College. Graduated Boston College | | | 7 with your preparation for this deposition? | | 7 with a bachelor of science and degree in | | 8 | A. I would have to hazard a guess. | | 8 accountancy in 1983. I went to work for | | | 9 I don't have my time records in front of | | 9 Arthur Andersen from June of'83 till | | | 10 me. | | 10 August 31 of'87. On September 1 of 1987, | | 11 | Q. Like two hours, ten hours? | | 11 I started at the precursor of what is now | | 12 | A. My guess is in the two to four | | 12 Verdolino and Lowey and I've been there in | | | 13 hour range. No more than that. | | 13 the 35 years since and during that time, I | | 14 | Q. Did you speak to anyone else | | 14 I've gone to many, many, many professional | | | 15 other than the folks that you mentioned at | | 15 CPE type courses of all sorts of flavors. | | | 16 Verdolino and Lowey and your attorneys | 16 | Q. What do you mean by CPE? | | | 17 regarding this deposition? | 17 | A. A continuing professional | | 18 | A. Our IT person, Tim McDonald who | | 18 education. | | | 19 assisted in the search -- the electronic | 19 | Q. Is that a required procedure | | | 20 search of e-mails and records and worked | | 20 for any type of certification that you | | | 21 with the Brown Rudnick IT person to send | | 21 have? | | | 22 everything over. Aside from having him try | 22 | some of it is required A. It's -- | | | 23 and get the records, we didn't have any | | 23 for my certification as a certified | | | 24 discussion of the case facts and 25 circumstances or anything. | | 24 insolvency restructuring advisor. The rest 25 are just to maintain my professional |

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PAX-014-005

1 C. JALBERT 2 capabilities and stay on top of various 3 issues as the years have gone on. 4 Q. So you mentioned certified 5 insolvency instructor? 6 A. Certified insolvency 7 restructuring advisor. CIRA. 8 Q. So this is a professional 9 certification? 10 A. Yes. 11 Q. Do you hold any other 12 professional certifications besides the 13 CIA? 14 A. CIRA, no. 15 Q. CIRA. I think you said you had 16 a accountant degree from Boston College? 17 A. Yes. 18 Q. Do you hold any other graduate 19 or any graduate degrees? 20 A. No. 21 Q. Are you currently employed at 22 V erdolino and Lowey? 23 A. Yes. 24 Q. Generally, what services does 25 Verdolino and Lowey offer its clients? 1 C. JALBERT 2 A. There were three or four -- I 3 guess four major buckets. The first and 4 biggest is the insolvency arena, Page 18 5 underperforming businesses and individuals. 6 That includes litigation support and 7 everything related to it. We have a 8 full-time 13 or 14 people I think it is 9 that work in taxation and we also do what 10 I'll call high net worth babysitting. We 11 have -- and I don't do any of this work. 12 My partner and others do it but we have 13 very wealthy clients that don't pay their 14 own bills, that have multiple residences. 15 Everything comes to us. We act as a family 16 office for a whole -- for a number of 1 7 people and the last thing we do is federal 18 election reporting for federal congress 19 people and senators and presidential. 20 Q. Thank you. 21 A. Did I say we have tax 22 department -- yes, tax department. That's 23 the four. 24 Q. You mentioned the high net 25 worth baby sitting. Who, at Verdolino, is Page 19 1 C. JALBERT 2 responsible for this? 3 A. Well, my partner and various 4 staff 5 **Q.** What's his name? 6 A. Keith Lowey. 7 **Q.** Is that department involved in 8 this matter before us? 9 A. No. 10 **Q.** Is Verdolino and Lowey always 11 engaged by the debtor in the bankruptcy 12 context? 13 A. No. 14 Q. What other scenarios is 15 Verdolino and Lowey engaged under? 16 A. We've been engaged by trustees, 17 post confirmation fiduciaries, whatever 18 they may be called; you said debtors, 19 creditors' committee, creditors, secured 20 lenders. I think we've probably 21 represented, over the years, most every 22 kind of party and interest to a bankruptcy 23 that there is. 24 **Q.** Turning to your experience 25 specifically, what experience do you have 1 C. JALBERT 2 in Chapter 11 cases? 3 A. I've been in over 500 Chapter Page 20 4 11 cases. We've been committee financial 5 advisor, committee accountants, debtor 6 financial advisor, debtor accountants, 7 accountants on behalf of secured lenders, 8 accountants on behalf of individual 9 creditors. Trying to think -- I mean 10 again, we've done -- we've represented 11 pretty much every constituency so over 12 time, I've done -- I've represented every 13 reasonable constituency in a bankruptcy I 14 can remember. 15 Q. What is your title at Verdolino 16 and Lowey? 17 A. Principal. 18 Q. We talked about the four 19 buckets. Generally, what are your 20 responsibilities with respect to Verdolino 21 and Lowey services? 22 A. Just for the most part, the 23 first -- all of my time not spent running 24 my own firm is in the bankruptcy insolvency 25 and the like that spreads over a little bit Page 21

6 (Pages 18 - 21)

1 C. JALBERT 2 to taxation. I don't run the department or 3 anything but I certainly interact and then 4 litigation support and the like, you know, 5 the types of things you would do in the 6 context of a bankruptcy. 7 **Q.** What is meant by litigation 8 support, generally? 9 A. Well, it can be pretty broad 10 but for us, it's -- whether it be business 11 litigation or bankruptcy litigation, to the 12 extent that there are areas that whoever 13 the law firm -- we've also been appointed 14 by judges, anyone that's looking or 15 interested in obtaining financial 16 information in a form that they're looking 1 7 for, which could be anything, we would 18 provide it. That would include doing 19 expert reports, expert testimony and work 20 at just advising lawyers as they approach 21 areas in accounting and auditing and the 22 like. 23 **Q.** You mentioned here that you're 24 a principal at Verdolino and Lowey? 25 A. Yes. 1 C. JALBERT 2 **Q.** What other roles have you held? 3 A. I've been a principal since I 4 started. 5 Q. Turning to the engagement here, Page 22 6 who contacted V erdolino and Lowey about 7 this engagement? 8 A. Well, it was contacted me 9 personally and it was an attorney, Steven 10 Pohl at Brown Rudnick. 11 Q. Sorry, I missed what you said. 12 MR HARBACH: Spell that name. 13 **Q.** Can you spell that name, 14 please? 15 A. The name was Steven Pohl. Last 16 name P-O-H-L at Brown Rudnick. 17 Q. Mr. Pohl reached out to who at 18 Verdolino and Lowey? 19 A. Me. 20 **Q.** You. Do you recall when that 21 was? 22 A. Somewhere around March 1, 2 or 23 3. 24 **Q.** After Steven Pohl reached out, 25 who did Verdolino and Lowey speak to Page 23 C. JALBERT 2 generally regarding the engagement? 3 A. There was a little bit with 4 Steven Pohl and with -- I believe it was 5 Ben Silverberg. 6 Q. Anyone else at Brown Rudnick? 7 A. I don't remember. 8 Q. Besides Brown Rudnick, did you 9 speak to anyone else regarding the 10 potential engagement? 11 A. I probably mentioned something 12 to my -- my own staff to clear conflicts 13 and I think I had someone help me prepare 14 some -- I shouldn't say prepare, they're 15 already prepared. Send some individual 16 information about myself and the firm. 1 7 Q. Did Verdolino and Lowey speak 18 to anyone else besides Brown Rudnick in 19 connection with the engagement? 20 MR AULET: Objection. You can 21 answer. 22 A. At the time we're being 23 engaged? 24 **Q.** Yes. 25 A. No. 1 C. JALBERT 2 Q. Who are the main points of 3 contact between -- who are the main 4 contacts for -- strike that. Who do you 5 generally speak to regarding this 6 engagement besides internal folks at 7 Verdolino and Lowey? 8 A. Mostly the attorneys at Brown 9 Rudnick. 10 Q. Do you speak to anyone else? 11 A. I've been on phone calls with 12 other lawyers but I've not initiated 13 anything. 14 Q. Which other lawyers have you 15 been on phone calls with? 16 A. The other debtor lawyers that 1 7 I'm aware of are an Aaron Mitchell and a 18 Melissa Francis. 19 Q. Who do you understand Aaron 20 Mitchell to be? 21 A. Counsel to Mr. Kwok, the 22 debtor. 23 Q. You mentioned Melissa Francis? 24 A. Also counsel to Mr. Kwok. 25 Q. Besides Aaron Mitchell and Page 24 Page 25

7 (Pages 22 - 25)

1 C. JALBERT 2 Melissa Francis, do you speak to anyone 3 else outside ofVerdolino and Lowey 4 regarding this engagement? 5 A. And outside of Brown Rudnick? 6 **Q.** Outside of Brown Rudnick, yes. 7 A. No one. 8 **Q.** What about -- what about do you 9 communicate via e-mail with anyone besides 10 Aaron Mitchell, Melissa Francis and Brown 11 Rudnick regarding this engagement? 12 A. I've been on -- I've been CC'd 13 on an e-mail and authored one e-mail to 14 someone outside that group. 15 Q. Who is that person? 16 MR AULET: Objection. This is 1 7 the person that we have stated their 18 identity won't be revealed per Golden 19 Springs request. 20 **MS. ARONSSON:** Are you 21 instructing the Witness not to 22 answer? 23 MR AULET: I am instructing 24 him not to answer. 25 MS. ARONSSON: Can you just 1 C. JALBERT 2 state -- 3 MR GOLDMAN: Can you repeat 4 the question? 5 (Whereupon, the referred-to 6 question was read back by the 7 Reporter.) Page 26 8 THE WITNESS: That should have 9 been e-mails. I authored one but I 10 was CC'd on e-mails. 11 Q. I understand Mr. Aul et is 12 instructing you not to answer. 13 MS. ARONSSON: Mr. Aulet, do 14 you mind just providing a more 15 detailed objection? 16 MR AULET: Sure. Based on my 1 7 conversations with Golden Spring, my 18 understanding is that Golden Spring 19 believes that revealing that 20 individual's name would potentially 21 expose them to harassment and based 1 C. JALBERT 2 Q. So I'll just go on record to 3 say that we dispute that contention. 4 MR GOLDMAN: As do we. Who 5 6 7 8 are you -- who do you fear harassment from? Do you fear harassment from? 9 10 11 12 13 MR AULET: So Mr. -- Golden Spring's attorney is on the phone and that question is probably best directed to Golden Springs but my understanding is that -- please, he would like to answer. MR MILTENBERGER: Tim 14 Miltenberger from Golden Springs. 15 I'm assuming what the Witness is 16 testifying to is the identity of a 17 Golden Spring employee which isn't 18 clear to me from the record but 19 apparently the people at the 20 deposition reached that conclusion. 21 We don't see any relevance in 22 revealing the name of the employees 23 of Golden Spring based on the 24 objection that's filed to the DIP 25 financing motion and we think that 1 C. JALBERT 2 the privacy rights of our employees 3 are paramount to any information that 4 might be gathered from knowing the 5 name of -- rank and file employees of 6 Golden Spring and we oppose 7 disclosing that information. 8 MR GOLDMAN: That's up to the 9 Judge. It's a totally inappropriate 10 instruction to direct the Witness not 11 to answer. The Witness can answer 12 and you can get a ruling from the Page 28 13 Judge as to whether the answer should 14 be stricken or protected or subject 15 to a protective order. It's totally 16 inappropriate to direct the Witness 1 7 not to answer. 18 MS. ARONSSON: I noted our 19 dispute with Mr. Aulet and I'll just 20 note our dispute with Mr. 21 Miltenberger's reasoning behind the 22 objection here. 85

- 22 on my review of the documents at - 23 issue, the person's identity is not - 24 relevant to the issues at hand in 25 this deposition.

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23 MR MILTENBERGER: Thank you.

24 **Q.** Turning back to the folks we 25 were just talking about, you mentioned

| 1 | C. JALBERT | 1 | C. JALBERT | |----|------------------------------------------------------------------------------------------------|----------|-------------------------------------------------| | | 2 Melissa Francis. Did she represent to you | | 2 sure I wasn't missing anything. | | | 3 that she was Mr. Kwok's counsel? | 3 | Q. Besides the attorneys at Brown | | 4 | A. No. | | 4 Rudnick, did you circulate drafts of that | | 5 | How did you learn about what Q. | | 5 engagement letter to anyone else? | | | 6 Ms. Melissa Francis -- who Mr. -- strike | 6 | I don't recall anyone else A. | | | 7 that. How did you learn who Ms. Francis' | | 7 being on it but I'm pretty sure they then | | | 8 client was? | | 8 did circulate it with -- at a minimum, Ms. | | 9 | A. From Brown Rudnick. | | 9 Melissa Francis and probably Aaron Mitchell | | 10 | We've talked about the folks at Q. | | 10 as well. | | | 11 Verdolino that you communicate with this | 11 | MS. ARONSSON: Tab 11. The | | | 12 engagement. Do you know of anyone else | 12 | Court Reporter is going to hand you | | | 13 that Verdolino and Lowey communicates with | 13 | what is being marked as Jalbert | | | 14 regarding this engagement besides the folks | 14 | Exhibit 2. This document -- for the | | | 15 that we've talked about? | 15 | record, this document bears the Bates | | 16 | A. I don't think there were others | 16 | Number Kwok 00001646. | | | 17 but it is possible that one of my | 1 7 | (Whereupon, E-mail Chain was | | | 18 colleagues met Flynn. Might have had | 18 | marked as Jalbert Exhibit 2 for | | | 19 e-mail contact. You're aware -- because I | 19 | identification as of this date by the | | | 20 think you objected to -- there's a large | 20 | Reporter.) | | | 21 number of ordinary course professionals. | 21 | Q. Before we get to the exhibit, | | | 22 We needed to get information about | | 22 what is a post-petition retainer? | | | 23 liabilities to them for the schedules. | 23 | My understanding would be a A. | | | 24 There might have been some information and | | 24 retainer paid to whoever, after the filing | | | 25 stuff because we needed -- it's possible | | 25 of a bankruptcy, intended to be a retainer. | | | Page 30 | | Page 32 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 that he spoke with them but I think really | 2 | Can you please tum to Page 2 Q. | | | 3 what he did is he got all the information | | 3 of this document? Take a minute. At the | | | 4 from Aaron Mitchell and Melissa Francis. I | | 4 top of Page 2, Mr. Silverberg says that | | | 5 don't think he went outside of that but | | 5 there's no post-petition retainer expected. | | | 6 it's possible. | | 6 Do you see that? | | 7 | Q. Do you know where Aaron | 7 | A. Yes. | | | 8 Mitchell and Melissa Francis retrieved | 8 | Q. Do you recall whether you had a | | | 9 their information from? | | 9 preference about receiving a post-petition | | 10 | A. No. | | 10 retainer? | | 11 | Q. Did you ask them where they | 11 | A. Well, every professional would | | | 12 retrieved their information from? | | 12 rather have a retainer but frankly, under | | 13 | A. No. | | 13 the circumstances, it wasn't expected. | | 14 | Q. Who negotiated -- who, from | 14 | Q. Starting with your preference, | | | 15 Verdolino and Lowey, negotiated the | | 15 why would you prefer to have a | | | 16 engagement letter? | | 16 post-petition retainer? | | 17 | A. It would be me. I don't know | 17 | Security against the payment of A. | | | 18 that I would call it a negotiation but it | | 18 the fees. | | | 19 was me that drafted it and prepared it and | 19 | Q. Do you know whether you | | | 20 sent it to Brown Rudnick. | | 20 received a post-petition retainer in | | 21 | Anyone else involved in Q. | | 21 connection with this case? | | | 22 drafting that engagement letter? | 22 | A. I do. | | 23 | A. Well, from a QPC perspective, | 23 | Q. Did you? | | | 24 I'm sure I had one of my colleagues, Mary 25 Jo Schindler take a look at it just to make | 24 25 | A. No. Q. And why not? |

9 (Pages 30 - 33)

| 1 | C. JALBERT | 1 | C. JALBERT | |-----|------------------------------------------------|----|-----------------------------------------------------------| | 2 | I didn't ask for one. A. | 2 | Yep. A. | | 3 | Turning back to the e-mail, Mr. Q. | 3 | Did you ask for a post-petition Q. | | | 4 Silverberg writes, "big Q is whether it's | | 4 retainer in connection with this | | | 5 us retaining you or the client. I would | | 5 engagement? | | | 6 think you're retained by the client as his | 6 | No. A. | | | 7 financial advisor". Do you recall that | 7 | Do you know if Verdolino and Q. | | | 8 being a question in connection with this | | 8 Lowey asked for a post-petition retainer in | | | 9 engagement? | | 9 connection with this engagement? | | 10 | MR AULET: Objection to form. | 10 | A. I do. | | 11 | A. I don't think I understand your | 11 | What's the answer? Q. | | | 12 question. I can read the statement and | 12 | A. No. | | | 13 understand but I don't know what you're | 13 | Youalsowrite,"butlthinkif Q. | | | 14 asking. | | 14 we are going to hold the cash, we will need | | 15 | He says, "big Q", do you Q. | | 15 to be employed by the debtor". So does | | | 16 understand that to be a big question? | | 16 that refresh your recollection about | | 1 7 | A. I understand it might be a | | 17 whether it was a question about who was | | | 18 question in his mind. I don't know that he | | 18 retaining Verdolino and Lowey? | | | 19 intended it to be a question for me or for | 19 | A. I don't think I had a question | | | 20 himself and then he answered it. | | 20 in my mind. I just responded with a | | 21 | MS. ARONSSON: Makenzie, can | | 21 comment that supported his previous comment | | 22 | you hand me Tab 12? | | 22 where he said I would think you're retained | | 23 | THE VIDEOGRAPHER: Mr. Jalbert, | | 23 by the client as his financial advisor. | | 24 | would you mind moving the water | 24 | Generally, can you explain your Q. | | 25 | bottle? It's coming up in the frame. | | 25 view in connection with the question | | | Page 34 | | Page 36 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | I apologize. Thank you. | | 2 Mr. Silverberg poses about who was | | 3 | THE WITNESS: Sorry about that. | | 3 retaining Verdolino and Lowey? | | 4 | THE VIDEOGRAPHER: I appreciate | 4 | A. Well, I was pretty sure when he | | 5 | that. | | 5 wrote I would think you're going to be | | 6 | MS. ARONSSON: The Court | | 6 retained by the client as his financial | | 7 | Reporter is going to mark what is | | 7 advisor, that's -- I made a gratuitous | | 8 | going to be Jalbert Exhibit 3. This | | 8 comment or not a gratuitous comment. I | | 9 | document is Bates stamped Kwok | | 9 made an assenting comment basically saying | | 10 | 00001649. | | 10 I think if we're going to hold the cash, we | | 11 | (Whereupon, E-mail Chain was | | 11 need to be employed by the debtor. So | | 12 | marked as Jalbert Exhibit 3 for | | 12 concurring with the decision or the thought | | 13 | identification as of this date by the | | 13 that he had. | | 14 | Reporter.) | 14 | What is the basis for the Q. | | 15 | Please take a look at this Q. | | 15 understanding that you just explained? | | | 16 document. | 16 | MR AULET: Objection to form. | | 17 | A. Okay. | 17 | Of what part? A. | | 18 | You're responding to Mr. Q. | 18 | Where, turning to your e-mail, Q. | | | 19 Silverberg's e-mail that we were just | | 19 "ifwe are going to hold the cash, we'll | | | 20 speaking about with the big Q is whether | | 20 need to be employed by the debtor". What's | | | 21 it's us retaining you or the client. | | 21 the basis of that statement? | | 22 | A. Okay. | 22 | A. Well, my professional judgment. | | 23 | Turning to your response, you Q. | | 23 If me, as a principal ofVerdolino and | | | 24 note, "I'd like a post-petition retainer if | | 24 Lowey, was going to be the signer on a | | | 25 possible". Do you see that? Page 35 | | 25 debtor in possession bank account, it would Page 37 |

10 (Pages 34 - 37)

| 1 | C. JALBERT | 1 | C. JALBERT | |-----|----------------------------------------------------------------|----|--------------------------------------------------------------------------------------------| | | 2 make all the sense in the world that that | 2 | A. Well, frequently in matters, | | | 3 debtor in possession was my client. So I'm | | 3 we -- the firm gets brought in and we do | | | 4 concurring effectively with the | | 4 whatever work is intended on that | | | 5 determination that Mr. Silverberg made in | | 5 particular engagement. Frequently, it's | | | 6 the previous e-mail to this chain. | | 6 litigation support. If it's intended that | | 7 | Thank you. Just for my own Q. | | 7 we do an investigation, the lawyer's | | | 8 understanding, what is the difference | | 8 thinking ahead, look, you're going to do an | | | 9 between being employed by the debtor versus | | 9 investigation, we think this is what we're | | | 10 Brown Rudnick? | | 10 going to find. Then we're going to have to | | 11 | Well, ifl was employed by A. | | 11 get a expert report to file with a | | | 12 Brown Rudnick, I'm not sure I'd go | | 12 particular court. Then we might need you | | | 13 through -- I'm not sure I would have to go | | 13 to go through the process of discovery | | | 14 through the employment process for the | | 14 including records, depositions and the like | | | 15 bankruptcy. Would I file a motion to be | | 15 and then we might need you to testify. In | | | 16 employed? I don't know. I don't know the | | 16 those particular cases, as I understand it, | | | 17 answer to that question. It's not | | 17 there would be privilege up to a certain | | | 18 something that I thought of beyond this. | | 18 point, up until the time I'm declared an | | | but ifl was right and there wouldn't 19 So -- | | 19 expert but in other instances, we get | | | 20 be an opportunity to file a motion to | | 20 brought in as -- as financial advisor to | | | 21 employ Verdolino and Lowey on behalf of the | | 21 the attorneys. They want us to do an | | | 22 debtor, I don't know how we would then | | 22 investigation. They want us to uncover | | | 23 allow me to be a signatory on the debtor's | | 23 whatever need to be uncovered, whatever the | | | 24 account. | | 24 allegations are, whatever the issues are | | 25 | Thank you. That's helpful. Q. | | 25 but they might be hiring another firm or | | | Page 38 | | Page 40 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | | | | | | 2 Did you rely on Brown Rudnick in connection | | 2 individual to testify as the expert to keep 3 what knowledge we have as privileged. I | | | 3 with that determination of who would be | | | | | 4 retaining Verdolino and Lowey? | | 4 don't know that that's relevant here. Q. | | 5 | MR AULET: Objection to form. | 5 | Thank you. Turning back to | | 6 | A. Well, Mr. Silverberg writes in | | 6 Exhibit 2 -- | | | 7 his e-mail, "I would think you're retained | 7 | MR MILTENBERGER: I'm sorry to | | | 8 by the client as his financial advisor" and | 8 | interrupt. I'm being called away to | | | 9 the next e-mail, same day, when I got | 9 | another matter so I'm going to have | | | 10 around to it at 6:49 p.m. -- so five hours | 10 | to drop off now. The record could | | | 11 had elapsed -- I basically concurred with | 11 | just note that I'm leaving the | | | 12 his determination. Who made the decision, | 12 | deposition. | | | 13 I don't know. It's semantics but I think | 13 | MR HARBACH: Thank you, Tim. | | | 14 it was clear from this point on, that we | 14 | You're welcome to rejoin anytime. | | | 15 were going to be retained by the debtor and | 15 | MR MILTENBERGER: Will do, | | | 16 not Brown Rudnick. | 16 | thanks. | | 1 7 | Q. Is Verdolino and Lowey ever | 17 | Q. I'm interested in your e-mail | | | 18 retained by a law firm in connection with | | 18 at the top where you write, "my feeling is | | | 19 bankruptcy proceedings? | | 19 that in an individual case, the FA" -- | | 20 | A. We're frequently retained by | | 20 financial advisor -- "duties are markedly | | | 21 lawyers in proceedings. I think even | | 21 different than of an operating business | | | 22 including in bankruptcy proceedings for the | | 22 case". Can you explain to me the | | | 23 purposes of the privilege. | | 23 difference between an individual case | | 24 | Q. What do you mean by for 25 purposes of the privilege? | 25 | 24 versus an operating business case? A. So operating business cases |

11 (Pages 38 - 41)

| 1 | C. JALBERT |----|-------------------------------------------- | | 2 have their various size and shapes. They | | 3 may have affiliated entities, parents, | | 4 siblings. It could be multiple debtors. | | 5 They might have employees in various | | 6 countries, various states. They may have | | 7 payroll taxes un-filed, sales taxes | | 8 un-filed, depending on the business, bottle | | 9 deposits un-filed and unkept. They | | 10 probably need a lot more work on budgeting | | 11 and keeping the business operating. Does | | 12 it have sufficient cash, what are the 13 | | 13 week budgets, the one year budgets. Cash | | 14 collateral where it's -- you've | | 15 secured creditor who is frequently -- maybe | | 16 not against the debtor but maybe not with | | 17 it either. So -- so there's | | 18 totally different beast. In this | | 19 particular case, some individuals have | | 20 operating real estate or something like | | 21 that but they rarely have an operating | | 22 business that's multi country, multi state | | 23 with employees and all sorts of reporting | | 24 requirements, compliance requirements. | 25 | Is it fair to say the financial Q. | | | | | 1 | C. JALBERT | | 2 advisor duties in connection with an | | 3 operating business case are more | | 4 complicated than an individual case? | 5 | A. In most, yes. | 6 | Q. Turning away from the exhibit, | | 7 who instructed Verdolino and Lowey on the | | 8 scope of work in this matter? | 9 | A. I don't think anyone instructed | | 10 us. | 11 | Q. Because you drafted the | | 12 engagement letter? | 13 | A. I'm sure there were discussions | | 14 with counsel. I don't remember the | | 15 discussions specifically but this is not | | 16 the first time I've drafted a retention -- | | 17 at least part of the retention papers. | | 18 Obviously, I'm not a lawyer. I don't know | | 19 all of that goes into retention | | 21 input as to what the duties are. I'm sure | | 22 we took the first stab at it and in review | | 23 by Brown Rudnick, they might have | | 24 changes. I don't remember how that went. | 25 | In connection with the Q. Page 43 | 1 | C. JALBERT | ------------------------------------------------|----|------------------------------------------------------------------------------------------| | | 2 engagement, no one informed you what needed | | | 3 to be done on this case? | | 4 | A. Well, we had been party to | | | 5 numerous conversations. This is not my | | | 6 first bankruptcy. It's not my 50th | | | 7 bankruptcy. It's not my 100th bankruptcy. | | | 8 I had a fairly good idea of what the issues | | | 9 were going to be and I took the first pass. | | | 10 I don't recall whether there were changes | | | 11 made after that or not. | | 12 | Generally, what is the scope of Q. | | | 13 Verdolino and Lowey's work in this case? | got a | 14 | A. In this case? | | 15 | Q. Yes. | | 16 | A. Well, the retention papers | just -- it's a | | 17 speak for themselves. So if you want to go | | | 18 line by line, put that in front of me. | | 19 | Sure. Q. | | 20 | A. To date, we've been focused | | | first, my recollection is the SOF A's 21 on -- | | | 22 and the schedules pretty much | | | 23 simultaneously. I mean they were due the | | | 24 same day, same time. So that was first. | Page 42 | | 25 Following -- immediately following that, I Page 44 | | | | | | | | 1 | C. JALBERT | | | 2 believe we worked on everybody's engagement | | | 3 papers to get them filed in the Court and | | | probably while the tail end of that 4 then -- | | | 5 was going along, I believe my colleague, | | | 6 Matt Flynn, started preparing the monthly | | | 7 operating report that was due for the end | | | 8 of February, sometime around March 20, 21, | | | 9 22, somewhere around there. Trying to | | | 10 think if we've done anything -- oh | | | or 11 assistance in preparing for -- | | | 12 participation in preparing, to a small | | | 13 degree, for the debtor to attend the 341 | | | 14 meeting. We attended the first day 341 | | | 15 meeting by telephone. My colleague, Matt | | | 16 Flynn and I, attended the second day of the | | | 17 341 hearing which was this past Wednesday | | | how do I want to call it -- 18 on a -- we | papers but 20 as to the duties, typically, I have an | | 19 didn't bill for our time. I went as an 20 observer. We knew we weren't going to be | | | 21 participating but we wanted to be around to | | | 22 see what took place, meet people and then | made some 23 this deposition. | | | | 24 | Q. Thank you. So I think I heard | | | 25 the SOFA's and schedules were the first Page 45 |

``` 12 (Pages 42 - 45) ``` 1 C. JALBERT 2 step. You talked about drafting everyone's 3 engagement papers in connection with this 4 matter. 5 A. Well, drafting our engagement 6 papers. Everyone was focusing on their own 7 and I needed help, because I'm not a 8 lawyer, on mine. 9 **Q.** Then you talked about Matt 10 Flynn's responsibilities in connection with 11 the monthly operating report. 12 A. Yes. 13 **Q.** Finally, you talked about 14 preparing for the 341 hearing and attending 15 the 341 hearings? 16 A. Meeting, yes. 17 Q. Can you describe a little bit 18 more your responsibilities in connection 19 with those 341 meetings? 20 MR AULET: I would just 21 caution the Witness not to disclose 22 any work product or conversations 23 with attorneys. 24 A. On the first day of the 341 25 meeting, it was just thought that we should Page 46 1 **C. JALBERT** 2 participate because it was unclear what was 3 going to arise and they didn't know if it 4 would be something that we would need. 5 Q. Setting aside your 6 conversations with your attorneys, what -- 7 did you have any understanding about what 8 might arise during the first day of the 341 9 hearing that might require your 10 participation? 11 A. I've attended an awful lot of 12 341 meetings over my career. Anything can 13 happen at a 341 meeting because it's open 14 to every creditor and god only knows what 15 takes place. 16 Q. Did you anticipate having to 1 7 participate or ask questions during the 18 341? 19 A. I think we were asked to be on 20 the phone. I didn't have a participation 21 one way or another. 22 MS. ARONSSON: The Court 23 Reporter is going to hand you what is 24 being marked as Jalbert Exhibit 4. 25 (Whereupon, Debtor's Page 47 1 C. JALBERT 2 Application was marked as Jalbert 3 Exhibit 4 for identification as of 4 this date by the Reporter.) 5 **MS. ARONSSON:** For the record, 6 this is a document entitled Debtors 7 Application for Authorization to 8 Retain and Employ Verdolino and Lowey 9 PC as Financial Advisor. It was 10 filed in this case as Docket 90. 11 Q. Mr. Jalbert, feel free to look 12 at this document. 13 A. Is there something you're 14 trying to point me to? 15 Q. Do you recognize this document? 16 A. Yes. 17 Q. What is it? 18 A. Debtor's Application for 19 Authorization to Retain and Employ 20 Verdolino and Lowey PC as Financial 21 Advisor. 22 Q. Turning to Page 18 ofthe 23 document, using the page numbers at the top 24 of the page, what is this document? 25 A. Affidavit of Craig **R.** Jalbert Page 48 1 C. JALBERT 2 in Support of Debtor's Application for 3 Authorization to Retain and Employ 4 Verdolino and Lowey PC as Financial 5 Advisor. 6 **Q.** So you recognize this as your 7 affidavit you filed -- 8 A. I do. 9 **Q.** Turning to Page 21, the table 10 -- I'm interested in the table at the 11 bottom of the page. 12 A. Yes. 13 **Q.** Just stepping back I think you 14 mentioned folks at Verdolino who were 15 involved, Matt Flynn -- in this case, Matt 16 Flynn, Mary Jo Schindler and yourself. Is 17 there anyone else involved in this matter 18 at Verdolino and Lowey? 19 A. I mentioned Tim MacDonald, our 20 IT person who is only involved with -- 21 related to the deposition, the search of 22 our e-mails and the server records and 23 everything and getting it ported over to 24 Brown Rudnick to be then sent to you folks. 25 Q. Anyone else at Verdolino and Page 49

13 (Pages 46 - 49)

| 1 | C. JALBERT | 1 | C. JALBERT | |-------|-----------------------------------------------------|----|---------------------------------------------------| | | 2 Lowey? | | 2 different than any other engagement. You | | 3 | A. Not that I know of. | | 3 don't know what's going to happen in | | 4 | Q. Turning to this table, is Matt | | 4 day-to-day and everyone responds as best | | | 5 Flynn also a principal? | | 5 they can, as efficiently as they can and | | 6 | A. No. | | 6 whatever the issues are that are ongoing | | 7 | What is Matt Flynn's role? Q. | | 7 and the crises that materialize. | | 8 | A. A manager. | 8 | What about staff, what sort of Q. | | 9 | Is Mindy Jo Schindler a Q. | | 9 role do you anticipate any potential staff | | | 10 principal? | | 10 to play in this case? | | 11 | A. No. | 11 | A. It will depend on how it plays | | 12 | What is her role? Q. | | 12 out. I don't think it's going to happen | | 13 | A. Manager. | | 13 but if it did and we became -- I became the | | 14 | Q. So in connection with this | | 14 sole signer on the debtor in possession | | | 15 engagement at Verdolino and Lowey, there's | | 15 bank account, my firm would probably be -- | | | 16 one principal, two managers and then the IT | | 16 the bookkeepers would probably keep records | | | 17 person? | | 17 of the disbursements and the receipts. | | 18 | A. I believe so, yes. | | 18 They would assist with reporting. I would | | 19 | Do you anticipate other Q. | | 19 probably review it of course. If, at some | | | 20 Verdolino and Lowey employees to become | | 20 point in time, we have claim objections, I | | | 21 involved in this matter? | | 21 don't know what the nature of those | | 22 | A. As the case progresses, | | 22 objections are going to be, I don't know | | | 23 assuming that we come into the case, yes. | | 23 how big and how complicated but some of our | | 24 | Q. Generally, what are the duties | | 24 staff might be involved in claims. The | | | 25 of a principal in connection with a | | 25 debtor might have to file an income tax | | | Page 50 | | Page 52 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 bankruptcy case like this? | | 2 return. I'll be advising them that they | | 3 | I think of it as partner, A. | | 3 should file an income tax return for the | | | 4 director, managing director, any of those, | | 4 Estate. So we'll have tax people involved | | | 5 the lead person on the case from the firm. | | 5 in the preparation of the income taxes and | | 6 | Q. In connection with this matter | | 6 I would have to go down the list of -- and | | | 7 specifically, what do you expect the | | 7 be able to predict exactly what's going to | | | 8 principal to be doing? | | 8 take place but we're very efficient, very | | 9 | I assisted in preparation of A. | | 9 accustomed. We know all of our fees are | | | 10 the SOF A's and schedules, the global notes, | | 10 subject to review by every single party and | | | 11 the specific part of the global notes. I | | 11 interest. So we're -- we use as reasonably | | | 12 assisted with the monthly operating report. | | 12 low level as we can on every matter and I | | | 13 I participated with the first day hearings | | 13 can't predict beyond that what's going to | | 14 -- | excuse me, first -- not the first day | | 14 come up but that staff and bookkeepers get | | | 15 hearing. The first day of the 341 meeting. | | 15 used for those types of issues. | | | 16 Responding to inquiries from the various | 16 | Is it fair to say your answer Q. | | | 1 7 lawyers and supporting staff on whatever | | 17 to my question about staff applies to the | | | 18 roles that they are working on. | | 18 bookkeepers, to the role of the | | 19 | Q. What do you expect managers to | | 19 bookkeepers? | | | 20 do in connection with this case? | 20 | A. No, bookkeepers and staff. | | 21 | A. The same -- the same things. | 21 | So the answer that you just Q. | | | 22 Maybe differing amounts, different types. | | 22 gave applies to both of those? | | | 23 I'm more review. Depending on what it is, | 23 | A. You asked what they may do. | | | 24 they might support me. I might support | 24 | Q. Right. | | | 25 them. It's like this engagement is no Page 51 | 25 | A. They're -- the bookkeepers Page 53 |

``` 14 (Pages 50 - 53) ``` 1 C. JALBERT 2 aren't going to do reporting but they're 3 going to maintain receipts and 4 disbursements. A staff person would 5 probably work on the form of the -- of a 6 financial statement or whatever report 7 that's going to be issued. The staff are 8 going to work on claims objections. Tax 9 professionals are going to work on tax 10 returns. 11 Q. Are you finished with your 12 answer? 13 A. Yes. 14 Q. You mentioned receipts and 15 disbursements. What sorts ofreceipts and 16 disbursements do you anticipate in this 17 case? 18 A. I would imagine if things were 19 to go the way the debtor planned, there was 20 a proposed DIP financing arrangement where 21 money will come into the Estate and then 22 would presumably be used to pay various 23 professionals and United States Trustee 24 fees and whatever other disbursements are 25 required of the debtor as ordered by the Page 54 1 C. JALBERT 2 Court or otherwise generally required to 3 pay Chapter 11 bills as they become due. I 4 think that's it. 5 **Q.** The last item is clerical. 6 What sort of duties do you anticipate a 7 clerical member of your team to do in this 8 case? 9 A. I don't have anything that I 10 have presupposed for them to do in this 11 case. 12 Q. Turning back in the document to 13 the retention agreement, this is on Page 14 13. We've talked generally about the 15 engagement -- Verdolino and Lowey's 16 engagement in this case. I want to walk 1 7 through these bullet points on the first 18 page. The first one reads, "assistance 19 with preparation of the statement of 20 financial affairs and the schedules and all 21 support thereto and any amendments". These 22 have been filed, right? 23 A. Yes. 24 **Q.** Who was involved in preparing 25 the SOFA and the schedules? Page 55 1 C. JALBERT 2 A. From my firm? 3 Q. Who atV&L? 4 A. Myself, Matthew Flynn and Mary 5 Jo Schindler. 6 **Q.** Who else was involved in 7 preparing these filings? 8 A. There might have been a 9 technical question for someone related to 10 the best case but I can't think of anything 11 else -- anyone else that had any -- that 12 did work on it. 13 Q. Did Brown Rudnick work on the 14 SOFA and schedules? 15 A. You asked me for my firm. Of 16 course they worked on them, as did Melissa, 17 as did -- that's Melissa Francis. As did 18 Aaron Mitchell. So it was clearly not all 19 Verdolino and Lowey. It was -- the whole 20 team was involved in the preparation. I 21 thought you asked me -- and if I 22 misunderstood, I apologize -- you asked 23 who, at Verdolino, did and that was myself, 24 Matt Flynn and Mary Jo Schindler. 25 **Q.** Thank you. Yes, I did ask Page 56 **C. JALBERT** 2 Verdolino and Lowey and was then moving on. 3 So you mentioned Melissa Francis, Aaron 4 Mitchell, Brown Rudnick. Generally, anyone 5 else? 6 A. While I never spoke to them, 7 there must have been the existence of help 8 from individuals that translated documents 9 and words from the various professionals to 10 the debtor and the debtor. 11 **Q. Did** you communicate with the 12 debtor about this SOFA and schedules? 13 A. No. 14 Q. You mentioned some translated 15 documents. Did you receive those 16 translated documents in connection with 17 your work on the SOFA and schedules? 18 A. No. I don't read Mandarin. 19 Q. Did you see any translated 20 documents? 21 A. I don't recall seeing them. 22 MR AULET: Objection to form. 23 **Q.** Do you know whether Golden 24 Spring was involved in preparing the SOFA 25 and schedules? Page 57

15 (Pages 54 - 57)

| 1 | C. JALBERT | 1 | C. JALBERT | |----|-------------------------------------------------------|----|----------------------------------------------------| | 2 | A. I wouldn't know. | | 2 doing in connection with the SOFA and | | 3 | Q. Do you know what Golden Spring | | 3 schedule? | | | 4 is? | 4 | A. I don't know that it's | | 5 | A. Yes. | | 5 anticipated but to the extent facts and | | 6 | What is it? Q. | | 6 circumstances, at some point in time, | | 7 | A. It's -- as I understand it -- a | | 7 require a review and possible amendment, I | | | 8 family office in New York City for the | | 8 think we would have to participate because | | | 9 debtor's son. Exactly how it's run, all | | 9 we're the ones that know Best Case and have | | | 10 that, I don't have any information. | | 10 that system but there's nothing | | 11 | Q. Who is the debtor's son? | | 11 anticipated. It's only if that | | 12 | A. I don't know his name. | | 12 materializes, we would participate. | | | 13 Debtor's son. | 13 | Q. You've said --you've mentioned | | 14 | Neither you nor anyone at Q. | | 14 Best Case a couple times. What do you mean | | | 15 Verdolino and Lowey met with or | | 15 by that? | | | 16 communicated with the debtor about the SOFA | 16 | A. It's a software that the | | | 17 and schedules? | | 17 industry uses. I think it's the most | | 18 | MR AULET: Objection to form. | | 18 prominent software that supports the | | 19 | A. Correct. | | 19 preparation of SOF A's and -- SOFA's and the | | | | | | | 20 | Can you describe what work Q. | | 20 schedules. I think they're used throughout | | | 21 Verdolino and Lowey did in preparing the | | 21 the industry by most everybody. | | | 22 SOFA and schedules? | 22 | So is it fair to say it's like Q. | | 23 | We participated with several A. | | 23 a TurboTax of preparing SOFA's and | | | 24 lengthy phone calls with various people | | 24 schedules? | | | 25 from Brown Rudnick, not all of whom I'm Page 58 | 25 | Or QuickBooks or --you know. A. Page 60 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 going to remember were on the phone and | 2 | So that software is essentially Q. | | | 3 also with Melissa Francis and Aaron | | 3 garbage in, garbage out, right? | | | 4 Mitchell. Aaron Mitchell and Melissa | 4 | MR AULET: Objection. | | | 5 Francis provided significant levels of | 5 | A. Every software is garbage in, | | | 6 input of various information. Brown | | 6 garbage out. | | | 7 Rudnick had been involved in the case | 7 | Turning to the second bullet Q. | | | 8 before we were. They already had a large | | 8 point in the retention agreement, it reads, | | | 9 knowledge base so we -- we talked with | | 9 "assistance with preparation and/or review | | | 10 Brown Rudnick team and Melissa and Aaron on | | 10 of cash flow and related budget projections | | | 11 the phone and then numerous e-mails. | | 11 and including advising as to post-filing | | 12 | THE WITNESS: I agree. Hot. | | 12 finances". Do you see that? | | 13 | MR HARBACH: Yeah, I tried to | 13 | A. Yes. | | 14 | keep out the sun. | 14 | Q. What work has Verdolino and | | 15 | Q. Did Verdolino and Lowey perform | | 15 Lowey done in connection with this line | | | 16 any investigation to verify information | | 16 item? | | | 17 obtained from Brown Rudnick, Melissa | 17 | A. Nothing. | | | 18 Francis or Aaron Mitchell? | 18 | Q. What work does Verdolino and | | 19 | A. No. | | 19 Lowey anticipate doing in connection with | | 20 | So is it fair to say you took Q. | | 20 this line item? | | | 21 their word regarding the representations | 21 | Anticipate doing this if we're A. | | | 22 contained in the SOFA and the schedule? | | 22 in the case and there's a DIP. | | 23 | A. That's fair. | 23 | So it includes budget Q. | | 24 | Is there any outstanding work Q. | | 24 projections. Budget projections for who? | | | 25 that Verdolino and Lowey will anticipate | 25 | A. I imagine we will try and |

16 (Pages 58 - 61)

1 C. JALBERT 1 C. JALBERT 2 establish what a budget would be for -- for 2 DIP loan in this case? 3 instance, committee counsel and its 3 A. Hope so. 4 financial advisors, debtor's counsel and 4 Q. Do you have experience with DIP 5 their financial advisors, the United States 5 loans? 6 Trustees fees. There were a number of 6 A. Yes. 7 firms that were intended to be ordinary 7 Q. How much experience do you 8 course professionals and any other 8 have? 9 anticipated disbursement in the case that's 9 A. I don't know how many hundred 10 approved in one way, shape or form by court 10 cases with DIP loans. 11 order. 11 Q. What work has Verdolino and 12 Q. It also includes review of cash 12 Lowey done in connection with this line 13 flow. What cash flow? 13 item? 14 A. The DIP money. 14 MR AULET: Objection to form. 15 Q. The debtor has no income, 15 A. We're talking about the third 16 right? 16 one, right, opening and maintaining the DIP 17 A. To my knowledge, correct. 17 account? 18 Q. Have you reviewed the debtor's 18 Q. Yes. 19 declaration filed in this case? 19 A. The only thing I did, when 20 A. I certainly reviewed one or two 20 asked by Brown Rudnick if I'd be willing, 21 of the drafts of it. I don't know that I 21 is I consulted with a bank that does -- 22 saw the final or not. I don't remember. 22 that's on the list of approved financial 23 Q. Are there cash flows coming in 23 institutions of the Department of Justice. 24 from any source at the moment? 24 I checked with that bank, which I use 25 A. Into the Estate? 25 frequently in and out of bankruptcy, to Page 62 Page 64 1 C. JALBERT 1 C. JALBERT 2 Q. Yes. 2 confirm that they would allow me to be a 3 A. Not to my knowledge. 3 signer on the DIP account and they 4 Q. Your knowledge of the debtor's 4 responded in yes. That's the extent of 5 lack of income is based on what you've been 5 which I've done on that. 6 told, is that right? 6 Q. Is that Citizens Bank that 7 A. Yes. 7 you're referencing? 8 Q. No independent investigation in 8 A. Yes. 9 connection with his income? 9 Q. Has Verdolino and Lowey been 10 A. Correct. 10 involved in the negotiation of the 11 Q. This line item also references 11 potential **DIP** loan? 12 post-filing finances. What is meant by 12 A. No. 13 that? 13 Q. Has Verdolino and Lowey been 14 A. He filed on February 15th. 14 included on any communications regarding 15 Whatever finances, cash receipts, cash 15 the potential **DIP** loan? 16 disbursements, budgeting from that day 16 A. I don't know. 17 forward. 17 Q. Have you personally been 18 Q. The third line item reads, 18 involved in any written or oral 19 "opening and maintaining the **DIP** account 19 communications regarding the **DIP** loan? 20 and effectuating disbursements when 20 A. I don't recall any. 21 necessary and providing accounting of all 21 Q. Do you have an understanding as 22 cash activity". Is it your understanding 22 to how the potential **DIP** loan would be 23 there's a DIP loan here? 23 structured? 24 A. No. 24 A. Well, I briefly read the DIP 25 Q. Do you anticipate there being a 25 loan at some point in time. I don't have Page 63 Page 65

17 (Pages 62 - 65)

1 C. JALBERT 2 an explicit memory of every -- of the whole 3 thing but I know generally how **DIP** loans 4 work. 5 Q. In this case, do you know how 6 the **DIP** loan would potentially be 7 structured? 8 A. I would have to be guessing at 9 mymemory. 10 **Q.** Who, at Verdolino and Lowey, 11 would perform the work in connection with 12 this line item? 13 MR AULET: Objection to form. 14 A. Presupposing that there is a 15 DIP loan? 16 Q. Yes. 1 7 A. It would -- as repeating, 18 obviously, I would be the signatory on the 19 account. There would be bookkeepers and 20 staff associated with preparing the checks, 21 preparing the reports and reporting to all 22 the parties that be. Some -- I imagine the 23 committee would want to know -- generally, 24 they would like to know on a weekly or 25 biweekly basis what receipts and 1 C. JALBERT 2 disbursements are, major creditors might 3 feel the same way. So whatever the -- 4 whatever the case is, reporting Page 66 5 requirements as they develop, we would take 6 care of that. I don't know what they would 7 be. Aside from the minimum requirement, 8 the monthly operating report. 9 Q. What is Verdolino and Lowey's 10 run rate up until this point? 11 A. What's a run rate? 12 Q. How much has Verdolino and 13 Lowey billed to this matter? 14 A. We've billed zero so far. 15 Q. How much value does Verdolino 16 anticipate it has already billed in this 17 case? 18 A. Are you asking for a WIP to 19 date? 20 Q. What is a WIP to date? 21 A. Work in process hours? 22 Q. Yes, please. 23 A. I have no idea. 24 Q. Does Verdolino and Lowey have 25 any agreement with anyone regarding who Page 67 C. JALBERT 2 will pay the fees in the event the DIP loan 3 does not occur? 4 A. No. 5 **Q.** Let's tum to the next line 6 item, "preparation, review and analysis of 7 monthly operating reports and/or quarterly 8 reporting". Do you see that? 9 A. Yes. 10 **Q.** You referenced earlier a 11 monthly operating report that was recently 12 filed in this case? 13 A. Yes. 14 Q. Is that the type of work 15 anticipated in this-- in connection with 16 this line item? 17 A. Well, going forward, there's 18 going to be a lot more than a monthly 19 operating report because there's going to 20 be -- well, presumably, if there is a **DIP** 21 and if the case continues, there's going to 22 be receipts and disbursements and even if 23 there aren't, the monthly operating report 24 and the US Trustees Office requires that -- 25 the disclosure of all estate professionals Page 68 1 C. JALBERT 2 as they accrue throughout the case. So it 3 didn't happen in the February one because 4 of the scrambling of SOF A's and schedules 5 and 341 meeting and everything else. Going 6 forward, we're going to have to have a 7 report on a monthly basis and a cumulative 8 basis what everybody's fees are, what the 9 cash in and cash out is and part of the 10 monthly operating report calculates the 11 fees due to the United States Trustee 12 Program and then the monthly operating 13 report, you typically have to also -- you 14 attach to it insurance binders, if things 15 expired. If they weren't usually -- 16 usually, I put them in anyway just to avoid 1 7 confusion and someone looking for it. And 18 then complete copies of the bank 19 statements. The United States Trustees 20 Office also wants balance sheet and P&L and 21 cash flow and what the accounts payable, 22 accounts receivable and all the various -- 23 so the first one was filed. Future ones 24 are going to have a lot more information. 25 Q. Taking a step back, can you Page 69

18 (Pages 66 - 69)

| 1 | C. JALBERT | 1 | C. JALBERT | |----|----------------------------------------------------|----|--------------------------------------------------| | | 2 just explain, generally, what a monthly | 2 | A. The United States Trustee | | | 3 operating report is in a Chapter 11 | | 3 issues bills predicated on the monthly | | | 4 individual case? | | 4 operating report, to what the expenses that | | 5 | A. It's the same or pretty close | | 5 meet the definition of a disbursement on | | | 6 to the same I think as the operating report | | 6 account of the U.S. Trustees form, they | | | 7 in a commercial case. It looked like it to | | 7 combine the three months in every calender | | | 8 me anyway's. But it's the standard -- | | 8 quarter. So for us, it will be the | | | 9 during the pendency of the case, the | | 9 February 15th, the February 28th stub | | | 10 operating report, that is required by the | | 10 period, plus the March 1 to March 31, that | | | 11 US Trustees Program, up until the case is | | 11 MOR The sum of those 45 days will be in a | | | 12 dismissed, converted or confirmed. | | 12 bill from the U.S. Trustees Office and, | | 13 | Q. So the procedures that you | | 13 assuming it's correct, would have to be | | | 14 described relating to the work on the | | 14 paid before the end of -- I believe this | | | 15 monthly operating report, that presupposes | | 15 month. | | | 16 the approval of the DIP loan and managing | 16 | So is it fair to say that Q. | | | 17 of those funds. Is that right? | | 1 7 Verdolino and Lowey is retained to review | | 18 | A. Well, the monthly operating | | 18 the quarterly report? | | | 19 report is going to be due irrespective of | 19 | I don't know if it's listed in A. | | | of the the accrual of the -- 20 that. The -- | | 20 here specifically but certainly the monthly | | | 21 fees of committee counsel, us, the | | 21 operating report is the form that is the | | | 22 accountant advisor, the debtor, debtor | | 22 input to the United States Trustees Office | | | 23 committee, others, whoever might be paid by | | 23 in order to create the bill. So we know -- | | | 24 the Estate including th ordinary course. | | 24 and it's the fees are statutorily | | | 25 Even if there's not a DIP, that has to be | | 25 determined based on the level of | | | | | | | | Page 70 | | Page 72 | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 reported in the monthly operating report. | | 2 disbursements. It's very easy to double | | 3 | You prepared one monthly Q. | | 3 check their work. We would do that and | | | 4 operating report to date? | | 4 make sure that the number is right. It's | | 5 | A. In this case? | | 5 frequently wrong because sometimes they | | 6 | Q. In this case, is that right? | | 6 issue the bill before the March statement | | 7 | A. Yes. | | 7 actually hits. So they're estimating. | | 8 | Is another monthly operating Q. | | 8 They're generally off -- not their fault -- | | | 9 report in progress? | | 9 in the first quarter because it's not a | | 10 | A. Yes. | | 10 full quarter. They don't have a basis for | | 11 | Did you also prepare -- scratch Q. | | 11 making estimates, whatever the case may be | | | 12 that. Did Verdolino and Lowey also prepare | | 12 but we would -- we would ensure that the | | | 13 the estimated monthly operating expenses | | 13 fee paid to the U.S. Trustees is | | | 14 contained in the schedule? | | 14 appropriate under the circumstances. | | 15 | A. To what are you referring to? | 15 | Q. Turning to the next line item, | | 16 | We can come back to that. Q. | | 16 "assistance with preparation and/or review | | 17 | A. Okay. | | 1 7 of estate federal and state income tax | | 18 | Have you or Verdolino and Lowey Q. | | 18 filings". What work has Verdolino and | | | 19 prepared a quarterly report in this case? | | 19 Lowey done in connection with this line | | 20 | A. The United States Trustee | | 20 item? | | | 21 quarterly report? | 21 | A. Nothing. | | 22 | Yes. Q. | 22 | Q. I think you mentioned before | | 23 | A. No. We don't prepare that, | | 23 that you were going to recommend the filing | | | 24 they do. | | 24 of income taxes. Why do you recommend that | | 25 | What is a quarterly report? Q. Page 71 | | 25 in this case? Page 73 |

19 (Pages 70 - 73)

| 1 | C. JALBERT | | C. JALBERT | |---|---------------------------------------------------------|-------|---------------------------------------------------| | 2 | A. I recommend it in every case. | | 2 legally required or not with a 505(b) | | | 3 So individual estate tax returns, | | 3 letter. | | | 4 individual estates is a separate -- | 4 | Do you anticipate that multiple Q. | | | 5 completely separate and distinct entity | | 5 returns will be filed in this matter if the | | | 6 from the individual as opposed to in a | | 6 debtor chooses to file returns. | | | 7 corporate case, the corporation retains its | 7 | A. Well, I don't know what the | | | 8 tax identity. You continue to file | | 8 debtor is going to do and again, it has no | | | 9 C-corporation returns if they're a | | 9 bearing on the Estate and no bearing on | | | 10 C-corporation, S Corp., partnership, | | 10 Verdolino and Lowey but the Estate will | | | 11 whatever the case may be and their year end | | 11 have to file -- I'll recommend that it file | | | 12 remains whatever their year end was | | 12 a federal return. The debtor is a resident | | | 13 established pre-petition. In a bankruptcy | | 13 of Connecticut so there would be a | | | 14 estate, the Estate is separate and distinct | | 14 Connecticut estate tax return and if, for | | | 15 from the individual. The individual has to | | 15 some reason, there was income from another | | | 16 continue to file his own individual income | | 16 state, we would file from whatever state | | | 1 7 taxes with whatever his individual income | | 17 that that income came. So I don't know | | | 18 that doesn't come into the Estate. In a | | 18 what it's going to be but it's at least | | | 19 Chapter 11 case, virtually all of the | | 19 going to be Connecticut and the IRS. | | | 20 debtor's income is supposed to come into | 20 | Q. I think we covered before, it's | | | 21 the Estate. So there really shouldn't be a | | 21 your understanding that the debtor has no | | | 22 separate one but technically, there could | | 22 income in this case? | | | 23 be. The Estate is -- the Estate return is | 23 | A. Correct. | | | 24 generally assigned to be December 31, | 24 | What work do you anticipate Q. | | | 25 unless you elect otherwise. There are | | 25 Verdolino and Lowey will do in connection | | | | | Page 76 | | | Page 74 | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 reasons to elect otherwise but the most | | 2 with an individual tax return for the | | | 3 important point is in order to get the -- | | 3 debtor? | | | 4 the relief that's in the bankruptcy code | 4 | MR. AULET: Objection to form. | | | 5 under Section 505b, in order to get that | 5 | A. Well, I'd have to guess what's | | | 6 relief, you have to file a tax return. So | | 6 going to take place between February 15 and | | | 7 I recommend, even when there's no tax due, | | 7 December 31. I don't know whether there | | | 8 that the return gets filed in order to | | 8 will be any income or not. There's | | | 9 protect all -- everybody in the case to | | 9 litigation going on. There might be | | | 10 make sure that there is not an issue that | | 10 settlements. I don't know whether there'll | | | 11 gives the various taxing authorities 60 | | 11 be income or not but ifthere is, there'll | | | 12 days from the date of filing with the | | 12 be income. From what source, I don't know | | | 13 505(b) letter to elect to audit it. It's | | 13 and from where, I don't know but at a | | | 14 the way that the case can move forward to | | 14 minimum, there will be disbursements and in | | | 15 closure and not have the seven year | | 15 a bankruptcy, there's two types of expenses | | | 16 statute, three year statutes and the like. | | 16 from a tax perspective. There are | | | 17 So I recommend everyone does the 505(b). | | 17 administrative expenses like professional | | | 18 If they don't elect to audit it in the | | 18 fees and there are other types of expenses | | | 19 first 60 days, then they lose the | | 19 that are normal to an individual. Mortgage | | | 20 opportunity. If they select it for audit, | | 20 interest, real estate taxes, whatever the | | | 21 then they got another 120 days. I want -- | | 21 case may be. They are treated in different | | | 22 I recommend it in every single case, | | 22 ways on the tax return but one of the | | | 23 individual or corporation or partnership or | | 23 reasons why you would file a return is the | | | 24 LLC, that the tax returns get filed whether | 24 -- | for tax purposes in a bankruptcy estate, | | | 25 they're necessary or not, whether they're Page 75 | | 25 the fees paid to professionals are Page 77 |

20 (Pages 74 - 77)

1 C. JALBERT 2 deductible and you can build them up like a 3 deferred tax asset. So to the extent, in 4 the future -- after we spend money on the 5 case, if, in the future, there was a large 6 settlement agreement, you would be able to 7 offset the previous administrative NOL's 8 against the future income -- 9 THE COURT REPORTER: The 10 previous administrative -- 11 THE WITNESS: N-O -- net 12 operating losses against a future 13 receipt, which is another reason to 14 file the return. 15 Q. Is it fair to say that the work 16 that Verdolino and Lowey anticipates 17 potentially doing in connection with tax 18 returns depends on whether cash is coming 19 into the debtor or the Estate in the 20 future? 21 MR. AULET: Objection to form. 22 A. No. You're going to have -- 23 you're going to have accrued expenses 24 depending on the -- when the timing of the 25 case and everything, accrued expenses can 1 C. JALBERT 2 be deductible. So cash -- clearly, if 3 there were cash, that would -- that would 4 have to be taken care of but depending on 5 how this case goes and the timing, it's 6 entirely possible that some of the accrued 7 expenses would be deductible. 8 **Q.** Have you seen the debtor's most 9 recent tax returns? 10 A. I don't know that I would be 11 able to call them most recent tax returns 12 but I've seen parts. I don't know if it's 13 the whole thing. I don't know ifl saw the 14 entire federal and the entire state but I 15 -- I at least saw the New York return and 16 the federal version attached to the New 1 7 York return which may or may not be the 18 entire federal return for 2019 I think and 19 2020. 20 **Q.** If the debtor's income is zero, 21 what do you anticipate deducting from? 22 MR. AULET: Objection. 23 A. Are we talking about the debtor 24 individually or the Estate? 25 **Q.** Let's start with the debtor. Page 78 Page 79 1 C. JALBERT 2 A. I have no -- it's not my 3 problem or interest what happens to the 4 debtor, outside of the bankruptcy estate. 5 He's going to have to hire a different 6 accountant to deal with that. 7 **Q.** Let's talk about the Estate. 8 A. If the Estate has tax 9 transactions, as I said, I would recommend 10 the Estate files tax returns on a timely 11 basis and it would include whatever 12 transactional activity that is allowed 13 under the -- both the bankruptcy code and 14 the internal revenue code and I don't know 15 what that's going to be. 16 **Q.** Turning to the next line item, 17 it reads, "assistance with reviewing 18 reconciling, analyzing and if necessary, 19 objecting to proofs of claim". What work 20 has Verdolino and Lowey performed in 21 connection with this line item? 22 A. None. 23 **Q.** Just generally, what does -- 24 what is a proof of claim? 25 A. It's a form. There's a form. 1 C. JALBERT Page 80 2 There's a bankruptcy form that's a proof of 3 claim. I don't remember what the form 4 number is but it's an opportunity for any 5 alleged creditor to file a claim in either 6 a Chapter 11 or a Chapter 7 case. They can 7 file claims on a secured basis, a priority 8 basis, an administrative basis and I'm sure 9 there's more that I'm missing. I don't 10 think there's a claims objection deadline 11 but at some point in time, in a Chapter 11, 12 there's usually a claims objection 13 deadline. If, however, a creditor has been 14 scheduled on Schedule D, E or F and that 15 number happens to be right, then the 16 creditor does not have to file a claim as I 1 7 understand it. If they disagree because 18 it's owed more or less -- and rarely do 19 they disagree if they're owed less but if 20 they're owed more, they're allowed to file 21 a proof of claim and establish what they 22 think the amount due to them from the 23 bankruptcy estate would be. 24 Q. Have you reviewed any of the 25 pending litigation claims in this matter? Page 81

21 (Pages 78 - 81)

PAX-014-021

| 1 | C. JALBERT | 1 | C. JALBERT | |-----|--------------------------------------------------------------------------------------------|-----|------------------------------------------------| | 2 | A. No. | | 2 someone to do work on a preference | | | What experience does Verdolino | | 3 analysis. We certainly participated in | | 3 | Q. | | | | | 4 and Lowey have in analyzing the likelihood 5 of success in pending litigation claims? | | 4 preparing that because we filed them. | | | | 5 | Do you know how many Q. | | 6 | A. Absolutely none. | | 6 pre-petition payments were disclosed in | | 7 | Q. Turning to the next line item, | | 7 this case? | | | 8 "assistance with reviewing debtor books and | 8 | A. No. | | | 9 records for possible avoidable transactions | 9 | Does 21 sound about right? Q. | | | 10 such as preference and fraudulent transfer | 10 | A. I don't know. | | | 11 claims". Do you see that'J | 11 | Q. So the line item refers to | | 12 | A. Yes. | | 12 debtor books and records for possible | | 13 | Can you explain to me, Q. | | 13 avoidable transactions. Have you reviewed | | | 14 generally, what this means? | | 14 any debtor books and records in connection | | 15 | A. The bankruptcy code allows a | | 15 with this engagement? | | | 16 look back period. For preferences, it | 16 | A. No. | | | 1 7 allows 90 days prior to the filing for | 1 7 | Has Verdolino and Lowey Q. | | | 18 preference claims and I'll let lawyers | | 18 reviewed any books and records in | | | 19 define what that is and insiders and other | | 19 connection with this engagement? | | | 20 fraudulent transfers take place between | 20 | A. No. | | | 21 zero days and I've heard it's -- whatever | 21 | Is it fair to say that Q. | | | 22 the statute happens to be for whatever the | | 22 V erdolino and Lowey relies on the | | | 23 issue might be, one year, two years, four | | 23 assistance of other parties in connection | | | 24 years, whatever the case maybe but it's a | | 24 with this line item? | | | 25 search through transactions to see if any Page 82 | 25 | MR AULET: Objection to form. Page 84 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 of them might be avoidable and recoverable | 2 | A. Are you talking about past | | | 3 to the Estate. | | 3 tense or future tense? | | 4 | Q. What analysis has Verdolino and | 4 | Q. Past tense. | | | 5 Lowey performed in connection with this | 5 | A. We relied on other individuals | | | 6 line item? | | 6 for everything that we did from an | | 7 | MR AULET: I would caution the | | 7 information perspective. | | 8 | Witness to the extent that there is | 8 | MR AULET: We've been going | | 9 | anything, not to disclose any | 9 | for awhile so if you need a break -- | | 10 | specifics. | 10 | THE WITNESS: No, let's get the | | 11 | MS. ARONSSON: Sorry, what do | 11 | -- let's do it all at once. I would | | 12 | you mean? | 12 | like to get out of here before | | 13 | MR AULET: That ifhe has done | 13 | tonight. | | 14 | any work, it would be covered by the | 14 | MR GOLDMAN: We are going to | | 15 | work/product privilege. Not to | 15 | break at 12. | | 16 | disclose those specifics. | 16 | MR HARBACH: Yes, sir. | | 1 7 | Setting aside the work/product Q. | 17 | Q. Okay, turning to the next line | | | 18 protection that Brown Rudnick is alleging | | 18 item, "assistance with any necessary | | | 19 in connection with this line item, can you | | 19 litigation support". I think we covered | | | 20 answer the question? | | 20 this previously. Do you have anything to | | 21 | Well, one of the questions in A. | | 21 add about potential services in connection | | | 22 the SOF A's is payments made in the 90 days | | 22 with this line item that we haven't already | | | 23 prior to bankruptcy. I don't know if | | 23 discussed? | | | 24 that's necessarily a surprise to anybody | 24 | A. Not that I can remember. | | | 25 but that is usually the starting place for Page 83 | 25 | Q. Has Verdolino and Lowey done Page 85 |

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| 1 | C. JALBERT | 1 | C. JALBERT | |----|----------------------------------------------------------|----|-----------------------------------------------------| | | 2 any work in connection with this line item | | 2 assets is on liquidated litigation claims? | | | 3 to this date? | 3 | MR AULET: Objection to form. | | 4 | A. In this case, no. | 4 | Ifwe did, it would be awfully A. | | 5 | Q. The next -- turning to the next | 5 | small. | | | 6 line item is "assistance with plan | 6 | Understood. Are you aware of Q. | | | 7 development and preparation including | | 7 any draft plans currently being circulated? | | | 8 feasibility". What does this mean? | 8 | MR AULET: Objection. He's | | 9 | A. Well, in order to have a | 9 | already testified that he hasn't | | | 10 successful Chapter 11, you have to confirm | 10 | performed any work on this. So I | | | 11 a plan of reorganization or whatever the | 11 | don't see what the relevance is to | | | 12 title will be when it's prepared and | 12 | V &L's retention. | | | 13 created. It might even be a joint plan for | 13 | MS. ARONSSON: Sure. I'm | | | 14 all I know. In those plans, there | 14 | curious though about ongoing work in | | | 15 typically is some budgeting because | 15 | connection with this line item. | | | 16 sometimes payments to creditors are paid | 16 | MR A ULET: He can answer if | | | 1 7 out over time. We might assist in | 17 | he's doing any current work with it. | | | 18 preparing the cash flow projections of | 18 | A. None. | | | 19 receipts and disbursements for some future | 19 | Turning to -- turning to the Q. | | | 20 time period and my -- I'm not a lawyer but | | 20 next line item on the next page, it reads, | | | 21 as I understand it, in order to confirm a | | 21 "general consulting and assistance with any | | | 22 Chapter 11, you must prove that the | | 22 other matters and tasks that may arise and | | | 23 creditors are getting a better return from | | 23 as may be directed by you or the debtor". | | | 24 the Chapter 11 plan than they would have in | | 24 Is it fair to say this is kind of a | | | 25 a Chapter 7 case and that usually requires | | 25 catch-all? | | | Page 86 | | Page 88 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 that you -- well, you're going to have | 2 | A. Yes. It's a catch-all with the | | | 3 feasibility and you're going to have -- | | 3 caveat -- this is not my first rodeo -- if, | | | 4 what's the other one -- term is slipping my | | 4 for some reason, there's a discreet task | | | 5 mind -- I can't remember it but it didn't | | 5 that is going to be required that will be | | | 6 list it anyway's. | | 6 comprehensive and costly, we would file a | | 7 | The line item says feasibility Q. | | 7 motion to amend our employment, what would | | | 8 and I think you mentioned that as well. | | 8 be covered by the employment but as to -- | | | 9 What does feasibility mean? | | 9 you know, for instance, sometimes they get | | 10 | A. You -- the projections is | | 10 a notice from the IRS that requires 15 | | | 11 usually the evidence with which to allow | | 11 minutes for someone to respond to. I know | | | 12 the Court and other parties in interest to | | 12 little -- little cats and dogs that happen | | | 13 determine what the future cash flows will | | 13 that don't happen to fit into something | | | 14 be and make their own decision based on | | 14 else, it's a catch-all for the minutiae. | | | 15 that as to whether the debtor's plan is | | 15 Not intended to be a catch-all for major | | | 16 financially feasible and the Judge | | 16 line items and that's only to protect me. | | | 17 obviously has the final determination but | 17 | Q. Understood. What work or | | | 18 usually everyone puts their two cents in. | | 18 analysis has Verdolino performed in | | 19 | What analysis has Verdolino and Q. | | 19 connection with this line item, if any? | | | 20 Lowey done to date in connection with this | 20 | A. None that I know of. | | | 21 line item? | 21 | Are you familiar with a company Q. | | 22 | A. None. | | 22 called Stretto? | | 23 | Would Verdolino and Lowey have Q. | 23 | A. Yes. | | | 24 a function in developing a plan if the | 24 | Q. What do they do? | | | 25 debtor's estate's only source of income or Page 87 | 25 | A. I don't know everything that Page 89 |

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| 1 | C. JALBERT | 1 | C. JALBERT | |----|----------------------------------------------------------------------------|----------|-----------------------------------------------------------| | | 2 they do but they do claims agent work and | 2 | MR AULET: Objection to form. | | | 3 other bankruptcy-related work. I don't | 3 | A. Yes. | | | 4 know what their list of services are. I've | 4 | You mentioned before that you Q. | | | 5 hired them myself in cases. I think | | 5 have worked with Stretto in the past? | | | 6 they're still working for me on a case or | 6 | A. Well, they're in the same -- | | | 7 two right now in a limited basis. | | 7 some of the same -- well, a couple. One or | | 8 | Are you aware that Stretto was Q. | | 8 two of the same cases that we're in. | | | 9 involved in this matter? | 9 | Do you have an understanding as Q. | | 10 | A. I'm aware that there's a motion | | 10 to whether Stretto could open and maintain | | | 11 to employ them, yes. | | 11 a DIP account? | | 12 | Generally, what is your Q. | 12 | A. No. | | | 13 understanding of the scope of work that | 13 | Do you have an understanding Q. | | | 14 Stretto would potentially be employed to | | 14 about whether Stretto could monitor | | | 15 do? | | 15 disbursements in connection with a DIP | | | | | | | 16 | I have not read their motion to A. | | 16 account? | | | 17 employ. No idea what their -- | 17 | A. No. | | 18 | MS. ARONSSON: Let's go off the | 18 | Turning to the books and Q. | | 19 | record. Thank you. | | 19 records line item, the seventh bullet | | 20 | THE VIDEOGRAPHER: The time is | | 20 point, I'm going to ask you to assume that | | 21 | 11:53 a.m. and we are off the record. | | 21 there are 21 professional service providers | | 22 | (Whereupon, a brief recess was | | 22 who have received a pre-petition payment in | | 23 | taken.) | | 23 the 90 days before filing. I'm also going | | 24 | THE VIDEOGRAPHER: The time | | 24 to ask you to assume that Stretto can | | 25 | period is 12:22 p.m. We're back on | | 25 provide analysis with respect to those Page 92 | | | | | | | | Page 90 | | | | 1 | C. JALBERT | | C. JALBERT | | 2 | the record. | | 2 payments. Why is it necessary for | | 3 | Just wrapping up the questions Q. | | 3 Verdolino and Lowey to perform these | | | 4 related to Exhibit 4. Turning back to the | | 4 duties? | | | 5 line item about opening and maintaining the | 5 | MR AULET: Objection to form. | | | 6 DIP account, would you agree that a bank or | 6 | It calls for speculation. | | | | | A. | | | 7 an escrow agent could open and maintain a | 7 | Most everybody that has half a | | | 8 DIP account? | | 8 brain can do that. It's not going to be | | 9 | MR AULET: Objection to form. | | 9 done by me. | | 10 | I don't have any knowledge of A. | 10 | MS. ARONSSON: The Court | | | 11 why they couldn't but I'm certainly not an | 11 | Reporter is going to hand you what is | | | 12 expert. | 12 | being marked as Jalbert Exhibit 5. | | 13 | What about monitoring Q. | 13 | (Whereupon, Official Form | | | 14 disbursements and effectuating | 14 | 106Sum was marked as Jalbert Exhibit | | | 15 disbursements? | 15 | 5 for identification as of this date | | 16 | The bank doing it? A. | 16 | by the Reporter.) | | 17 | Yes. Q. | 17 | MS. ARONSSON: I'll say forthe | | 18 | A. I don't think the bank's going | 18 | record, this is a document that has | | | 19 to do it. | 19 | been filed as Docket Number 78 in | | 20 | Or an escrow agent. Q. | 20 | this case. | | 21 | A. An escrow agent would have more | 21 | Do you recognize this document, Q. | | | 22 obligation, whatever the escrow agreement | | 22 Mr. Jalbert? | | | 23 says. I don't -- | 23 | A. Yes. | | 24 | But an escrow agent could be Q. 25 employed to perform those duties? | 24 25 | What is it? Q. A. The first page is the official |

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1 C. JALBERT 2 form 106Sum which is the summary of assets 3 and liabilities and certain statistical 4 information for the debtor, Ho Wan Kwok. 5 Q. I think we've discussed earlier 6 that Verdolino and Lowey had a role in 7 preparing the SOFA and schedule. Is that 8 right? 9 A. Yes. 10 **Q.** Verdolino and Lowey had a role 11 in preparing this document? 12 A. Yes. 13 Q. I just want to walk through 14 this at a high level. The first line item 15 is -- item one relates to property. What 16 does this line item include? 1 7 A. What specific -- A, B or C or 18 all of them? 19 Q. Sorry, fair question. IA. 20 A. Well, it reads "Schedule A/B 21 Property official form 106A/B", question or 22 IA, "copy Line 55. Total real estate from 23 schedule A/B". 24 Q. Thank you. And it reads zero? 25 A. Correct. Page 94 1 C. JALBERT 2 Q. What analysis, if any, did 3 Verdolino and Lowey do to prepare this line 4 item? 5 A. I worked with the lawyers. 6 Q. Did you do any independent 7 investigation with respect to the line item 8 IA? 9 MR. AULET: Objection to form. 10 A. No. 11 Q. Turning to lB, this reads, 12 "total personal property from Schedule A/B" 13 and I think this refers us to Line 36? 14 A. I would have thought it related 15 to Line 62. 16 Q. It does and then 62. Sorry -- 1 7 so 62 refers back to 5 6 to 61. Do you see 18 that, that's on Page 7 of the PDF? 19 A. Lines 56 to 61, is that what 20 you're referring to? 21 Q. That's right. 22 A. Yep. 23 Q. The only item populated in 55 24 to 61 is Item 58? 25 A. Correct. Page 95 1 C. JALBERT 2 **Q.** Item 58 refers to Line 36? 3 A. Okay. 4 Q. So 36, just up the page, the 5 total amount here is 3,850 dollars. Do you 6 see that? 7 A. Yes. 8 **Q.** So 36 wraps up into one number. 9 Part 4 of this filing, is that fair? 10 MR. AULET: Objection to form. 11 A. Well, when you mean this 12 filing, are you talking about Part 4 of 13 Schedule A/B. 14 Q. I am, yes. Thank you for the 15 clarification. 16 A. I would agree that Line 36 is 1 7 the sum of Part 4 which starts at question 18 16. 19 Q. What analysis, if any, did 20 Verdolino and Lowey perform in connection 21 with these line items? 22 A. Whatever we did, we did working 23 with the lawyers. 24 Q. I'm going to ask you to tum to 25 Page 3 of the document. Page 96 1 **C. JALBERT** 2 MR. AULET: Just for 3 clarification, every time you're 4 refer to Page 3, you're referring to 5 the top numbers? 6 **MS. ARONSSON:** Yes. I'm 7 referring to the docket numbering at 8 the top. Page 3 of 23. 9 **Q.** Starting with Part 1 here, did 10 Verdolino and Lowey perform any work in 11 connection with this line item? 12 A. Ifwe did, we did with counsel. 13 Q. In Part 2, Item 3 and 4 14 referring to cars, vans, trucks, etcetera, 15 watercraft, aircraft, did Verdolino and 16 Lowey perform any work in connection with 1 7 this section? 18 A. All with counsel. 19 Q. So it's fairto say, when you 20 say you performed work with counsel, you 21 didn't perform any independent 22 investigation? 23 A. Correct. 24 Q. Part 3, Items 6 through Items 25 15 refer to personal and household items, Page 97

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| 1 | C. JALBERT | 1 | C. JALBERT | |----|--------------------------------------------------|----|------------------------------------------------| | | 2 is that right? | | 2 EXAMINATION BY | | 3 | A. Yes. | | 3 MR HARBACH: | | 4 | Without walking through each of Q. | 4 | Q. For the record, this is David | | | 5 these, did you perform -- did Verdolino and | | 5 Harbach at O'Melveny, also representing | | | 6 Lowey perform any work in connection with | | 6 Pax. I just have a few questions. Sir, I | | | 7 Items 6 through 14? | | 7 believe you mentioned earlier that you or | | 8 | A. Nothing -- not with the | | 8 Verdolino and Lowey were involved in | | | 9 attorneys. | | 9 helping to prepare the notes for the | | 10 | Just to be clear about your Q. | | 10 schedules that were filed? Have I got that | | | 11 role, were you provided information from | | 11 right? | | | 12 counsel and you were responsible for | 12 | The specific part of the A. | | | 13 drafting this form or did you rely on | | 13 notes -- | | | 14 counsel to draft this form? | 14 | Q. Yes, sir. The specific notes. | | 15 | MR AULET: Objection to form. | 15 | Not the general -- A. | | 16 | A. We keypunched into the forms | 16 | Understood. Q. | | | 17 after consultation obviously. | 17 | A. Yes, I worked with counsel on | | 18 | Q. Did you do anything besides | | 18 that. | | | 19 keypunch into the form? | 19 | The specific notes are -- Q. | | 20 | A. We discussed matters with the | | 20 appear at Document Number 77 on the docket | | | 21 attorneys. | | 21 and I don't have an extra copy for you but | | 22 | Q. I'm asking in connection with | | 22 I hope you'll agree that it won't be | | | 23 filing the schedule and the SOFA, when you | | 23 necessary. When it comes to questions | | | 24 say you communicated with the attorneys, | | 24 about things like electronics and household | | | 25 you're talking about Brown Rudnick? | | 25 goods and furnishings, which my colleague | | | Page 98 | | Page 100 | | | | | | | 1 | C. JALBERT | | C. JALBERT | | 2 | A. And Melissa Francis and Aaron | | 2 was just asking you about, the specific | | | 3 Mitchell. | | 3 notes state, for example, "numerous items | | 4 | Did you communicate or did Q. | | 4 fitting the personal and household | | | 5 Verdolino and Lowey communicate with anyom | | 5 definition are located at the residence and | | | 6 else besides the attorneys at Brown | | 6 the apartment" and then it goes onto say, | | | 7 Rudnick, Melissa Francis and Aaron | | 7 "except as otherwise set forth herein, the | | | 8 Mitchell? | | 8 debtor has no legal title to the contents | | 9 | A. No. | | 9 of either the residence or the apartment | | 10 | Q. Were you provided any facts or | | 10 and no court has made any determination | | | 11 information from any party when punching in | | 11 that the debtor has any other interests in | | | 12 these line items? | | 12 any such items". My question for you is | | 13 | A. We were informed by facts, lots | | 13 was Verdolino and Lowey at all involved in | | | 14 ofthem from the attorneys and lots of | | 14 making the assessment of whether any of | | | 15 discussion. | | 15 these household items belonged to the | | 16 | Q. Was it -- scratch that. The | | 16 debtor? | | | 17 information you received, was it oral? | 17 | MR AULET: I just lodge an | | 18 | A. Some was oral and some was in | 18 | objection to asking him about a | | | 19 e-mails, I believe, from counsel. | 19 | document that you're not showing him. | | 20 | MR HARBACH: Do you mind ifl | 20 | You can answer if you can. | | 21 | ask a couple questions? | 21 | A. To be clear, are you asking me | | 22 | MS. ARONSSON: Sure. | | 22 ifl investigated whether the spatulas and | | 23 | MR AULET: I don't have any | | 23 the pots and pans existed and who bought | | 24 | objection. | | 24 them and how much they were and are they at | | 25 | MR HARBACH: Thank you. Page 99 | | 25 the house? Page 101 |

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1 C. JALBERT 2 Q. All I'm asking is whether 3 Verdolino and Lowey had any role in making 4 the judgment call over whether the 5 household items at the residence or the 6 apartment belonged to Mr. Kwok or was that 7 something that was left to the lawyers? 8 MR AULET: Objection to form. 9 A. We did no investigation. I had 10 no personal knowledge not told to me by 11 Aaron Mitchell, Melissa Francis and Brown 12 Rudnick about the ownership of those. So 13 it wasn't my decision and I didn't 14 investigate but I certainly was party to 15 the conversations regarding that. 16 Q. During those conversations, if 17 one of those people, a lawyer at Brown 18 Rudnick or Melissa -- whose last name I 19 forget -- 20 A. Francis. 21 **Q.** Francis, thank you. 22 Represented to you that those items do not 23 belong to Mr. Kwok, you just accepted that 24 at face value? 25 A. Correct. Page 102 1 C. JALBERT 2 MR HARBACH: Okay, thank you. 3 Thank you, Laura. 4 CONTINUED EXAMINATION 5 BY MS. ARONSSON: 6 Q. This is Laura Aronsson from 7 O'Melveny. Just turning back to what we 8 were talking about in connection with the 9 schedule. I think David covered this. So 10 when drafting this, how did you decide 11 whether an item like the iPhone referenced 12 in Line Item 7 or the clothes referenced in 13 Line Item 11 or the family dog referenced 14 Item 13 belonged to Kwok as opposed to 15 another person or entity? 16 A. I was informed by either 17 Melissa Francis or Aaron Mitchell or they 18 informed Brown Rudnick and Brown Rudnick 19 informed us. 20 **Q.** Is it fair to say that that 21 chain of events that you just described 22 applies to all of the items identified in 23 this schedule? 24 MR AULET: Objection to form. 25 A. I don't know -- we better go Page 103 1 C. JALBERT 2 item by item if that's what you want to do. 3 I don't know what you're referring to. You 4 know, you got specific lines you're talking 5 about? 6 **Q.** Sure, that's fair. So in 7 connection with any of the assets 8 identified in the schedule as belonging to 9 Mr. Kwok, you solely relied on the chain of 10 events you previously described, Brown 11 Rudnick received information from Melissa 12 Francis and Aaron Mitchell? 13 MR AULET: Objection to form. 14 A. No, that's not whatl said. I 15 said we heard directly from Melissa Francis 16 or Aaron Mitchell or they informed Brown 17 Rudnick and Brown Rudnick told me that 18 they -- what the answer was from them. 19 There was no one way of communicating. It 20 was fluid situation. We had a very short 21 time to do them but it was not one way or 22 the other. It was, as I said, either and 23 many times the e-mails were with all the 24 attorneys on the e-mail or it was a phone 25 call with a lot of parties and I don't 1 C. JALBERT Page 104 2 remember all of the parties but the source 3 of the information was for us, first, Aaron 4 Mitchell and Melissa Francis in no 5 particular order. Now I don't remember who 6 knew more about what than the other or if 7 they passed information onto Brown Rudnick, 8 who then passed it onto us. Obviously, 9 after they did whatever legal analysis they 10 wanted to do. 11 Q. In preparing these documents, 12 did you ask for any information from Brown 13 Rudnick or Aaron Mitchell or Melissa 14 Francis that you were not given? 15 A. I don't remember asking a 16 question they didn't answer but I didn't 17 investigate anything. 18 Q. I want to tum to Page 16 of 19 this document. So at the bottom of the 20 page, to direct your attention there, Part 21 2 reads, "estimate your ongoing monthly 22 expenses". Were you involved in drafting 23 this section? 24 A. Yes. 25 Q. What was your role -- or Page 105

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1 C. JALBERT 2 scratch that. What was Verdolino and 3 Lowey's role in connection with this 4 section? 5 A. We had discussions with the 6 legal team, which is Brown Rudnick team 7 plus Aaron Mitchell, plus Melissa Francis, 8 probably more than one time, probably 9 orally, probably in e-mail and it was a 10 discussion. 11 Q. Turning to the next page, the 12 estimated monthly operating expenses reads 13 zero. Is that fair? 14 A. Yes. 15 Q. Did you anticipate the debtor's 16 monthly operating expenses to remain zero 1 7 after this point? 18 MR AULET: Objection to form. 19 A. It certainly was discussed with 20 the attorneys. I don't think it's a 21 secret. There was lots of discussion 22 yesterday. So my expectation is yes, as to 23 his expenses, his payment of his expenses 24 is going to remain I think zero. 25 Q. I think you said his -- his 1 C. JALBERT 2 expenses. In your view, what does his 3 expenses cover? 4 A. There's a whole list of them Page 106 5 here. You want to go down them? It looks 6 like about 30 of them. Real estate taxes, 7 property and homeowners and renters' 8 insurance, home maintenance repair and 9 upkeep expenses, home ownership association 10 and condo dues. Don't even know if those 11 are applicable. Electricity, heat and 12 natural gas. Want me to keep going? 13 Q. So we can just agree that Items 14 4 through 21 would include monthly 15 expenses? 16 A. Again, as it relates to him 17 paying them, I would agree. My 18 understanding is they're going to remain 19 zero. 20 Q. So this -- the analysis 21 contained in this document is separate from 22 the monthly operating report, the reports 23 that you, Verdolino, draft in connection 24 with this case? 25 A. Correct, because the monthly Page 107 1 C. JALBERT 2 operating report is a different report and 3 that's a completely different question than 4 what's on here. 5 **Q.** Can you explain to me the 6 difference? 7 A. And I don't remember what 8 question it is, is it like 4 or 5 or 6E or 9 whatever it is, the request is to report 10 the expenses paid by others on the debtor's 11 behalf. That's not what this asks. So in 12 the schedule, we listed some funds and we 13 will, going forward, be listing and 14 reporting, as required by the MOR, the 15 expenses paid by others on behalf of the 16 debtor which is again different from what 1 7 this asks. 18 **Q.** Focusing on what this asks, 19 it's your understanding that the debtor's 20 ongoing monthly expenses is zero? 21 MR AULET: Objection to form. 22 A. The debtor's payment of the **23 ongoing expenses is zero.** 24 **Q.** You did no investigation into 25 whether that is correct? 1 C. JALBERT 2 A. Correct. 3 Q. Turning just to the Excel 4 sheets at the end of this document, 5 starting just broadly, was Verdolino and 6 Lowey involved in preparing these 7 documents? 8 A. Well, we were certainly 9 involved with others, yes. 10 Q. What -- generally, what work Page 108 11 did Verdolino and Lowey do in connection 12 with these documents? 13 A. Reviewed them for 14 reasonableness, assisted in putting them in 15 a form that would normally be seen in a 16 SOFA and schedule. I think some ofthis 1 7 was uploaded into the actual Schedule F 18 because I think Schedule F -- well, maybe 19 it doesn't. I don't know. I don't 20 remember whether this was uploaded or not 21 but it could be. So that -- so it starts 22 with D. So all of these, we worked with 23 the attorneys and that's again, all three, 24 the Brown Rudnick team, Aaron Mitchell and 25 Melissa Francis. Page 109

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1 C. JALBERT 2 Q. I think you said the phrase 3 reviewed for reasonableness. What do you 4 mean by that? 5 A. Well, ifwe had anything to 6 compare information to, we compared it 7 or -- or if we had a question, we asked a 8 question of the lawyers. I don't remember 9 offhand what those were. 10 Q. Can you think generally of any 11 issues that you investigated in connection 12 with preparing these? 13 A. I'm sure on a couple of them, 14 we wanted the make sure that -- that there 15 wasn't a missing digit or an extra digit so 16 I'm sure someone from my team walked 17 through with someone, probably either 18 Melissa or Aaron, just as a double check 19 that it's what -- what the number on the 20 form was the number that they intended. 21 There wasn't, in there someplace, a human 22 error. 23 Q. Can you think of anything else 24 specific that you investigated? 25 A. We did not investigate. Page 110 1 C. JALBERT 2 MS. ARONSSON: The Court 3 Reporter is going to hand you what's 4 being marked as Jalbert Exhibit 6. 5 This is a document filed in this case 6 as Docket 77. 7 (Whereupon, Global Notes was 8 marked as Jalbert Exhibit 6 for 9 identification as of this date by the 10 Reporter.) 11 Q. Do you recognize this document? 12 A. Yes. 13 Q. What is it? 14 A. The Global Notes and Statements 15 of Limitations Methodology and Disclaimers 16 Regarding the Debtor's Schedules of Assets 17 and Liabilities and Statement of Financial 18 Affairs and the debtor is Ho Wan Kwok. 19 **Q.** And this is a specific line 20 item that Verdolino and Lowey's proposed 21 retention relates to? 22 MR. AULET: Objection to form. 23 A. Can I go back and take a look? 24 I don't know what the global notes are 25 listed or not but these are part and parcel Page 111 C. JALBERT 2 to the **SOF** A's and schedules. So it would 3 be part of the first bullet, "assistance 4 with preparation of the statement of 5 financial affairs and schedules and all 6 support thereto and any amendments, if 7 necessary". 8 Q. What was Verdolino and Lowey's 9 role in preparing this document? 10 A. Well, we certainly assisted in 11 drafting. We assisted in reviewing, 12 particularly the specific notes but there 13 was -- there was a lot of back and forth 14 and a lot of work between the Brown Rudnick 15 law firm, Aaron Mitchell, Melissa Francis 16 and Verdolino and Lowey, both -- all three 17 at Verdolino and Lowey, Matt Flynn, Mary Jo 18 Schindler and myself. 19 **Q.** Just to understand, what 20 specific work did Verdolino and Lowey do in 21 connection with preparing this document? 22 MR. AULET: Objection to form. 23 A. Well, like I said, we had 24 numerous e-mails, we reviewed everything, 25 we made comments. We might have drafted a Page 112 1 C. JALBERT 2 paragraph here or a paragraph there. I 3 think we assisted the group in making sure 4 the references, amongst the notes and 5 amongst the questions and the SOFA's and 6 amongst the schedules to the extent they 7 were interrelated, that the references were 8 appropriate. We made sure that the 9 writings were the facts as we knew them. 10 Didn't investigate but we had lots of 11 discussions and we made sure that what was 12 represented here was our memories. 13 Q. Thank you. Turning to Page 4, 14 Question 1 in the middle ofthe page, asks 15 "do you own or have any legal or equitable 16 interest in any residence, building, land 17 or similar property". The answer in Item 18 1, below it, reads, "the debtor has use and 19 occupancy ofreal estate located at 373 20 Taconic Road, Greenwich, Connecticut". Do 21 you have any understanding as to why the 22 use and occupancy of certain real estate is 23 relevant to this filing? 24 MR. AULET: Objection to form. 25 A. Well, I'm not a lawyer but Page 113

29 (Pages 110 - 113)

| 1 | C. JALBERT | | C. JALBERT | |----|----------------------------------------------------------|-----|------------------------------------------------------| | | 2 Schedule A is I thought real property that | | 2 Haven on Wednesday for the 341 meeting but | | | 3 was owned by the debtor. I would have to | | 3 I don't know -- I know it's a valuable car. | | | 4 go back and confirm that but real estate. | | 4 I don't know what the name is and I don't | | | 5 So it would be -- he's alive. He resides | | 5 know who owns them. I know the debtor -- | | | 6 in a residence and I'm presuming this is | | 6 just as this says, the debtor has use. | | | 7 the appropriate legal description of the | 7 | So beyond what this says here Q. | | | 8 facts and circumstances of his living in | | 8 and your previous answer, do you have | | | 9 that residence. | | 9 anymore information about the vehicles that | | 10 | Q. Again, no independent | | 10 the debtor has use of? | | | 11 investigations into this? | 11 | A. No. | | 12 | A. Correct. | 12 | Q. Did you witness the debtor | | 13 | Q. Did you perform any evaluation | | 13 using any luxury vehicles at any time? | | | 14 of the residences listed in Question 1? | 14 | A. I don't know what you mean by | | 15 | A. No. | | 15 using but he got out of one in New Haven on | | 16 | Q. The second bullet refers to an | | 16 Wednesday. | | | 17 apartment in the Sherry Netherland Hotel? | 1 7 | Do you know what kind of car it Q. | | 18 | A. Yes. | | 18 was? | | 19 | Q. Did you draft this section? | 19 | A. I don't remember. | | 20 | A. Did I draft it? I doubt it. I | 20 | Is this -- strike that. Is -- Q. | | | 21 might have reviewed it. I might have had | | 21 is the answer to Question 3 relevant to the | | | 22 input in something but this is not my | | 22 preparation of monthly operating reports? | | | 23 language. | 23 | A. Probably, yes. | | 24 | Q. Are you aware that the entity | 24 | Why? Q. | | | 25 holding the legal title to the Sherry | 25 | A. Because I imagine there's a | | | Page 114 | | Page 116 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 Netherland apartment is in bankruptcy? | | 2 cost associated with those vehicles being | | 3 | A. Well, I know there's a Chapter | | 3 provided for his use and again, I don't | | | 4 11 going on. Exactly what's in Chapter 11 | | 4 remember exactly what the question is, 4, 5 | | | 5 and who owns what, I have not confirmed or | | 5 or 6, like E, where the rules say to report | | | 6 made an investigation but generally | | 6 expenses made by third-parties on behalf of | | | 7 speaking, I understand that that apartment | | 7 the debtor. Well, I'm thinking the use of | | | 8 is somehow in Chapter 11 in New York. | | you know, I don't know if 8 the vehicles -- | | 9 | Any involvement in those Q. | | 9 there's a car payment on it, gasoline, | | | 10 proceedings in New York? | | 10 insurance, I don't know but something might | | 11 | A. No. | | 11 be in there. | | 12 | Q. Turning to the next page, | 12 | What about the purchase of the Q. | | | 13 Question 3 asks for interests, broadly | | 13 vehicle itself whenever it was purchased, | | | 14 speaking, in any vehicles. The response | | 14 is that relevant to the monthly operating | | | 15 reads that "the debtor has use of | | 15 report? | | | 16 automobiles including luxury automobiles | 16 | A. Well, monthly operating reports | | | 17 and motorcycles". Did you do any | | 17 are usually a disbursement in a particular | | | 18 investigation into this analysis? | | 18 time period. I imagine if they've bought | | 19 | A. No. | | 19 one of those cars during the pendency, | | 20 | Q. Do you have any understanding | | 20 maybe it shows up. I don't know. On the | | | 21 of what vehicles the debtor uses? | | 21 other hand, you could make an argument that | | 22 | A. Only from my memory, the -- he | | 22 the use of the vehicle is not the same | | | 23 has access to a luxury vehicle and I think | | 23 thing as buying the vehicle because maybe | | | 24 there's a vehicle that his security travels | | 24 other people use it too. So you would have | | | 25 in. As a matter of fact, they were in New Page 115 | | 25 to find a way of allocating the cost. Page 117 |

30 (Pages 114 - 117)

| 1 | C. JALBERT | 1 | C. JALBERT | |----|---------------------------------------------------|----|----------------------------------------------------------| | 2 | Does that answer apply to the Q. | 2 | A. No. | | | 3 Question 1 about residences as well? | 3 | Q. Turning to Page 8, Question 26 | | 4 | MR AULET: Objection to form. | | 4 asks for patents, copyrights, trademarks, | | 5 | A. The debtor resides in a | | 5 etcetera. The answer refers to | | | 6 particular residence. They're -- the only | | 6 unregistered copyrights and other | | | 7 people there that I know of, except for a | | 7 intellectual property interest in music and | | | 8 maid that comes in and security and | | 8 videos posted to various platforms. What | | | 9 possibly visits from family. So I imagine | | 9 is this referring to? | | | 10 the cost of the residence would be on that | 10 | A. The whole thing? | | | 11 so -- that monthly operating report in some | 11 | Q. Yes. | | | 12 amount and I think I -- I was a proponent | 12 | A. The Question 26 refers to | | | 13 of50 percent of that cost would be on | | 13 various intellectual property patents, | | | 14 behalf of the debtor because the spouse | | 14 copyrights, trademarks, trade secrets and | | | 15 lives there too and I didn't count the kids | | 15 intellectual property. The debtor -- I'll | | | 16 because they only came to visit the debtor. | | 16 just read it to you. "The debtor has | | | 17 So I kind of ascribed more to the mother | | 17 possible unregistered copyrights and other | | | 18 and father and split the cost but there's | | 18 intellectual property interest in music and | | | 19 no home purchase in there. There's no -- | | 19 videos posted to various digital and media | | | 20 again, it's what you pay in that current | | 20 platforms such as YouTube, GTV, Twitter" | | | 21 month. So I'm assuming they're telling -- | | 21 and -- I don't even know, GETTR, whatever | | | 22 we're going to be disclosing what is paid | | 22 that is. "The debtor ascribes no value to | | | 23 in that particular time frame on behalf of | | 23 his social media assets and has made no | | | 24 the debtor on the various categories, the | | 24 attempts to monetize his social media | | | 25 vehicles, the security, the home -- | | 25 presence". | | | | | | | | | | | | | Page 118 | | Page 120 | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | Q. Thank you -- | 2 | Beyond what's written on the Q. | | 3 | A. Food. | | 3 page, do you have any understanding of what | | 4 | Q. Thank you. Question 4 refers | | 4 this refers to? | | | 5 to watercraft, aircraft, motor homes and | 5 | A. No. | | | 6 the answer references previous access to | 6 | The second sentence notes that Q. | | | 7 the use of a yacht named the Lady May. Do | | 7 the debtor ascribes no value to these | | | 8 you have any -- beyond what's written on | | 8 items, do you see that? | | | 9 this page, do you have any understanding of | 9 | A. Yep. | | | 10 Mr. Kwok's interest the Lady May? | 10 | You performed no valuation of Q. | | 11 | A. Nothing that's not printed on | | 11 these items in connection with your work? | | | 12 this page. | 12 | A. Correct. | | 13 | Did you do any independent Q. | 13 | Do you know if any valuation Q. | | | 14 investigation into this? | | 14 was performed? | | 15 | A. No. | 15 | None to my knowledge. A. | | 16 | Items 6 and 7, household goods Q. | 16 | Question 31 asks for interest Q. | | | 17 and electronics. I think we covered that | | 17 and insurance policies. The answer refers | | | 18 previously. In connection with Items 6, | | 18 to his spouse's health insurance policy | | | 19 household goods through Questions 17 on | | 19 which has no cash value. Do you see that? | | | 20 this page -- so just for clarity, it's | 20 | A. Yes. | | | 21 Questions 6, 7, 8, 9, 11, 17. Did you do | 21 | Is it standard practice that a Q. | | | 22 any investigation as to what -- as to | | 22 health insurance policy has no cash value? | | | 23 whether the items referenced in here belong | 23 | A. I've never seen a situation | | | 24 to Mr. Kwok versus some other third-party | | 24 where a health insurance policy has a cash | | | 25 or entity? Page 119 | | 25 value except for to the beneficiary of -- Page 121 |

31 (Pages 118 - 121)

1 C. JALBERT 2 if you have a health insurance plan, it has 3 a lot of value to you when you go to the 4 hospital and it pays the bills for you. 5 There's not an independent value to a 6 third-party that you can sell. 7 Q. Do you have any knowledge about 8 the health insurance policy that the debtor 9 has currently? 10 A. No. 11 Q. Question 53 asks for property 12 of the kind not listed and the answer 13 refers to his membership at Mar-a-Lago Club 14 in Palm Beach. Is this the type of thing 15 that Verdolino and Lowey would include on a 16 monthly operating report if Mr. Kwok, the 17 debtor, used the membership? 18 MR AULET: Objection to form. 19 A. I would have to use conjecture. 20 Q. Go ahead. 21 A. Well, the first monthly 22 operating report was filed in February. I 23 don't know whether he went down there or 24 not. I don't know ifhe went down there in 25 March. Ifhe -- ifhe wentthere, I Page 122 1 C. JALBERT 2 imagine there would be travel expenses. I 3 don't know whether there would be a fee for 4 the golf and maybe he had lunch. So I 5 imagine ifhe physically went there and 6 used it, there would be -- there might be 7 -- there would be something in the monthly 8 operating report but if he stays where I 9 think he's going to stay, in Greenwich 10 where he's safe, it's not going to be 11 relevant. 12 Q. What is your basis for thinking 13 he's going to stay where he is in 14 Greenwich? 15 A. I listened to the 341 meeting 16 yesterday -- excuse me, Wednesday. 17 Q. Besides the knowledge gathered 18 from that hearing on Wednesday, the 341 19 hearing, do you have any independent 20 knowledge about the debtor's expected 21 travel or location? 22 A. I have no knowledge whatsoever 23 of where he's going to be at any point in 24 time. 25 Q. Would you rely on Brown Page 123 1 C. JALBERT 2 Rudnick, Aaron Mitchell and Melissa Francis 3 to inform you of how he might benefit from 4 things like his like his Mar-a-Lago 5 membership in connection with drafting the 6 monthly operating report? 7 A. I certainly would listen to 8 counsel on that for sure. 9 Q. But Verdolino and Lowey 10 wouldn't endeavor to seek out information 11 about these monthly expenses -- 12 A. Well, we're going to seek out 13 and we're going to point to the question 14 and we're going to ask for information 15 that's responsive to that. I don't have 16 access to the information. We don't 1 7 investigate. I'm not going to keep track 18 of where the debtor goes or doesn't go. So 19 someone would need to tell us the 20 information. We would then review it but 21 I -- I think that Mar-a-Lago thing, at 22 least for the foreseeable future, is not an 23 issue but if it becomes an issue, someone 24 will tell me. 25 Q. Turning to Page 11, Schedule I, C. JALBERT 2 the second to last sentence here and it's Page 124 3 that "the debtor plans to amend Form 122B 4 filed on February 15th, 2022 in which 5 debtor erroneously claimed monthly income 6 of\$19,488". Do you see that? 7 A. Yes. 8 **Q.** Do you know what that refers 9 to? 10 A. Yes. 11 Q. What is it? 12 A. The debtor inadvertently or 13 accidently -- I don't know what the term 14 would be -- erroneously filed a Form 122B. 15 It included \$19,488 dollars which met -- 16 the form met for the monthly income, I 17 think the review by the lawyers was that's 18 incorrect and so they -- the debtor filed 19 an amended 122B or at least intended to -- 20 I don't know if it's done yet or not -- 21 excluding that income. 22 **Q. Did** Verdolino and Lowey perform 23 any work in connection with that erroneous 24 inclusion? 25 A. I'm sure anything we did was in Page 125

32 (Pages 122 - 125)

1 C. JALBERT 2 consultation with the lawyers. 3 MR AULET: Objection to form. 4 Sorry. 5 Q. Turning to Page 13, Question 16 6 refers to a retainer of 500 thousand for 7 Brown Rudnick and then refers to one 8 million dollars from Lamp Capital. Do you 9 have any knowledge of that transaction 10 outside of what's written on the page? 11 A. I think there was discussion of 12 it yesterday -- excuse me, on Wednesday at 13 the 341 meeting and I think I saw a draft 14 of Brown Rudnick's retention papers -- I 15 think I did where I thought something was 16 mentioned in there. 17 Q. Do you recall what that was? 18 A. No. Something along the lines 19 of what's right here. 20 Q. Do you know what Lamp Capital 21 LLC is? 22 A. An entity owned by someone that 23 is not the debtor. 24 Q. Do you have any idea who it is 25 owned by? Page 126 1 C. JALBERT 2 A. Only a guess. 3 Q. Can you tell me -- I guess you 4 don't need to speculate. Do you have any 5 information that -- about what informs your 6 guess? 7 MR AULET: Objection to form. 8 A. My memory was there was a lot 9 being talked about but my memory was 10 something was said during the 341 meeting 11 but it is very -- I was very back of the 12 room, as you know, and it was very hard for 13 me to hear the English version from the 14 interpreter. So I can't be sure but I 15 thought I heard something that discussed 16 who owned Lamp. 1 7 Q. Outside of what you heard at 18 the 341 hearing and this other document 19 that you remember seeing, do you have any 20 knowledge about Lamp or its operations? 21 A. No. 22 Q. The next item, Question 18 23 refers to a litigation funding agreement 24 dated November 8th, 2021. Have you seen 25 that agreement? Page 127 1 C. JALBERT 2 A. There are actually five of them 3 I think. They're listed in Schedule D. I 4 don't recall whether I actually saw them or 5 not. I think they were briefly described 6 to me at a minimum by lawyers. 7 **Q.** Any independent knowledge of 8 those agreements besides -- 9 A. No. 10 Q. Did Verdolino and Lowey do any 11 other investigation in connection with the 12 assets we've talked about that we didn't 13 cover? 14 A. No. 15 Q. Those five litigation 16 agreements we talked about -- 1 7 A. The litigation funding 18 agreements? 19 **Q.** Yes. Thank you. Have you seen 20 them before? 21 A. Nottomyknowledge. 22 **MS. ARONSSON:** The Court 23 Reporter is going to hand you what's 24 being marked as Jalbert Exhibit 7. 25 This is a document produced in this Page 128 1 C. JALBERT 2 matter with the Bates stamp Kwok 3 00001752. 4 MR AULET: Just for the 5 record, it's two separate documents 6 so we should make sure -- 7 MS. ARONSSON: I'll represent 8 that this is a family of documents, 9 an e-mail and an attachment. 10 (Whereupon, E-mail Chain was 11 marked as Jalbert Exhibit 7 for 12 identification as of this date by the 13 Reporter.) 14 Q. Mr. Jalbert, I understand 15 you're not on this e-mail. I'm just going 16 to ask you some basic questions about it. 1 7 This is an e-mail between a redacted 18 person, Aaron Mitchell, Matt Flynn and 19 Melissa Francis. Matt Flynn is your 20 colleague. We've talked about the other 21 folks. The attachment is a summary of 22 living expenses from the period February 23 15th to 28th. First, I'm going to ask who 24 is this e-mail from? 25 MR AULET: And I will object Page 129

> Veritext Legal Solutions 866 299-5127

33 (Pages 126 - 129)

| 1 | C. JALBERT | 1 | C. JALBERT | |----------|------------------------------------------------------------------|----|-------------------------------------------------------------------------------------------| | 2 | and direct him the Witness to answer | 2 | Is this the monthly operating Q. | | 3 | for the same reasons that we | | 3 report filing that we've been discussing | | 4 | discussed previously on the record. | | 4 that you've been involved in preparing? | | 5 | MS. ARONSSON: And we'll | 5 | A. Looks like it, yes. | | 6 | continue to dispute the redaction | 6 | Turning to the filing 120-1, Q. | | 7 | here. | | 7 the separate loose page, these line items | | 8 | Q. Turning to the attachment, this | | 8 here, can you just explain broadly what | | | 9 summary of expenses, this was provided by a | | 9 they are at the bottom? What does the | | | 10 person -- the unknown person in the top | | 10 total reflect? | | | 11 e-mail, is that right? | 11 | MR AULET: Objection to form. | | 12 | A. Yes. | 12 | A. You're referring to the | | 13 | Is it fair to say that this is Q. | | 13 \$109,827.12? | | | 14 the starting point for Verdolino's monthly | 14 | Q. Yes. | | | 15 operating report draft? | 15 | A. I'm trying to see who made the | | 16 | MR AULET: Objection to form. | | 16 payments but inadvertently, the family, on | | 1 7 | A. As to the one particular | | 17 behalfofthe debtor, on February 16th, the | | | 18 question, yes. | | 18 day after the filing, made these two | | 19 | Sorry. What do you mean? Q. | | 19 payments on pre-petition amounts. So this | | 20 | A. This answers one question on | | 20 was, in an abundance of caution, in the 161 | | | 21 the monthly operating report and again, I | | 21 thousand dollars that was shown on Part 1, | | | 22 don't remember offhand exactly which one | | 22 Number E, this 109 thousand dollars is | | | 23 it is but something, 4, 5, 6E. The funds | | 23 included in the 161,323. So we were --the | | | 24 paid by third-parties on behalf of the | | 24 lawyers felt it was important to supplement | | | 25 debtor. This is the first pass. | | 25 the monthly operating report with that | | | Page 130 | | Page 132 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | MS. ARONSSON: McKenzie, Tab | | 2 information that this was really a | | 3 | 19. | | 3 pre-petition payment paid post-petition. | | 4 | THE WITNESS: Are you done? | 4 | Understood. Thank you. So the Q. | | 5 | MS. ARONSSON: No. | | 5 total expenses \$161,323 here, ifwe | | 6 | MR AULET: Should we have the | | 6 subtract from that, the total inadvertent | | 7 | back up marked as a separate exhibit | | 7 payments is \$109,827. What does that | | 8 | or -- | | 8 amount reflect? | | 9 | MS. ARONSSON: I typically mark | 9 | The amount of the payments that A. | | 10 | them as one. | | 10 weren't these two payments that were made | | 11 | MR AULET: Okay. | | 11 in the period from February 15th to | | 12 | THE WITNESS: We'll put them | | 12 February 28th by third-parties on behalf of | | 13 | together again and eliminate the blue | | 13 the debtor. | | 14 | sheet. | 14 | Q. Would that be reflected in the | | 15 | (Whereupon, E-mail Chain was | | 15 final version of the living expenses sheet | | 16 | marked as Jalbert Exhibit 8 for | | 16 that we looked at on Exhibit Number 7? | | 1 7 | identification as of this date by the | 17 | A. Yes. | | 18 | Reporter.) | 18 | MR AULET: Objection to form. | | 19 | Q. The Court Reporter is going to | 19 | Is anything else included in Q. | | | 20 hand you what's being marked as Jalbert | | 20 that number, to your knowledge? | | | 21 Exhibit 8. | 21 | A. Well, inadvertently, yes. We | | 22 | A. Have you given it to her yet? | | 22 found out that whoever created the form on | | 23 | MS. ARONSSON: This is a | | 23 the security total dollars, whatever the | | 24 25 | document filed in this case as Docket 120 and document 120-1. | | 24 final total dollars were, there was a 25 payment made February 10 pre-petition that |

34 (Pages 130 - 133)

1 C. JALBERT 2 was inadvertently included in the payments 3 from February 15th to 28th. So that will 4 be corrected on the next operating report. 5 **Q.** So included in this operating 6 report is the two inadvertent payments to 7 the law firms identified on Exhibit 8? 8 A. Yes, correct. 9 **Q.** The monthly operating living 10 expenses that we've talked about and then 11 this other payment that you said would be 12 corrected, is that right? 13 A. It's included in the 161. 14 We'll be pulling that out when we do the 15 March -- so the way the form works usually 16 is you have payments paid currently and 1 7 cumulative. We will take that small amount 18 of money out of the cumulative so as to 19 have the correct number going forward. 20 **Q.** So is it fair to say that 21 Verdolino and Lowey's role in connection 22 with these inadvertent payments was to kind 23 of double check the amounts included in the 24 monthly operating report? 25 A. We tried but given the timing Page 134 1 C. JALBERT 2 of when the information became available 3 and when the form had to be filed, there 4 was a miscommunication with the preparer of 5 the schedule that will be rectified. 6 **Q.** Who's the preparer of the 7 schedule? 8 A. I can't tell you. 9 **Q.** What schedule are you referring 10 to, this document here, the monthly 11 operating report, Exhibit 8? 12 A. This thing (indicating). 13 **Q.** So the number 161 here refers 14 to this spreadsheet in Exhibit 7 as 15 reflected with your edits, with Verdolino 16 and Lowey's edits? 17 A. The 161 is the sum of the final 18 number from Exhibit 8 plus the 109. 19 **Q.** What work did Verdolino and 20 Lowey do in connection with getting to the 21 final numbers? 22 A. We worked with counsel and 23 Aaron Mitchell and Melissa Francis trying 24 to review -- we didn't have details but we 25 were trying to ask questions and make sure Page 135 C. JALBERT 2 that the categories were properly described 3 because this is not nearly final. This -- 4 there were some errors and we also worked 5 with counsel and others in trying to figure 6 out what the percentage of the monies that 7 were paid in Column C multiplied by a 8 distribution percentage to arrive at the 9 total. We worked with the preparer to make 10 sure that the descriptions on the schedule 11 were accurate. We tried to confirm the 12 numbers were accurate. We couldn't get the 13 information in time to be able to do that 14 but then we looked at the distribution 15 percentages using our judgment in working 16 with the lawyers. 17 Q. Looking at this draft, living 18 expense chart in Exhibit 7, there are seven 19 line items. Is that right? 20 A. Yes. 21 **Q.** Is it fair to say that 22 V erdolino and Lowey crosschecked the names 23 of the categories to ensure that they 24 accurately depicted the expenses contained 25 in those line items? 1 C. JALBERT 2 A. We did the best we could, yes. 3 Q. What more information would 4 have been helpful to help you get to that 5 determination? 6 A. If we could have seen what 7 the -- what the actual payees and Page 136 8 disbursements were, it probably would have 9 helped us with the categorization. 10 Q. But you didn't receive that? 11 A. Not -- not at that time, no. 12 **Q.** Is the extent of information 13 you received regarding these line items 14 included in this chart here? 15 A. As of the date that we made 16 available all the -- I'm sure there's an 17 updated version because this doesn't tie to 18 here (indicating) and then we -- long after 19 we produced the information for -- for this 20 deposition, there's been continuing ongoing 21 discussions because we're getting ready to 22 file -- excuse me, the March **MOR** in April. 23 **Q.** We'll tum to the -- what I 24 think is the final version but we talked 25 about the categories, the amount you said Page 137

35 (Pages 134 - 137)

1 C. JALBERT 2 that, at the time of this filing, you did 3 not have information to be able to verify 4 the amounts attributed to each category. 5 Is that right? 6 A. Yes. 7 **Q.** What information would have 8 been helpful for you to cross check those 9 amounts? 10 A. Like I said, the name of the 11 payee, a description of what the service 12 was and the amount of the funds. 13 **Q.** The percentage distribution, 14 what does that mean? 15 A. The -- so for instance, 16 security was, in this sheet, \$43,655.44. 1 7 The drafter of this and anyone that he 18 consulted with or she consulted with was 40 19 percent. Amongst talking with our team and 20 with the lawyer team, we thought that that 21 probably should be one hundred percent 22 because the only reason -- the security is 23 entirely related to Mr. Kwok and his 24 safety. There wouldn't be security if the 25 wife and the kids or others at the 1 C. JALBERT Page 138 2 compound, if it weren't for Mr. Kwok. So 3 we proposed changing and I think that did 4 get changed to a hundred percent. 5 Q. In revising these percentage 6 distributions, did you rely entirely on 7 information received from Brown Rudnick and 8 Aaron Mitchell and Melissa Francis and this 9 undisclosed person? 10 A. The first pass was the 11 undisclosed person. After we got this 12 information from the undisclosed person, 13 most of the discussion was between our 14 firm, my firm and the lawyer -- lawyers. 15 How long is this is going to go? Because 16 if it's going to go a bit, now I would like 17 to use the restroom. I'll be fast. 18 MS. ARONSSON: We can take a 19 break. We'll go off the record. 20 THE VIDEOGRAPHER: The time is 21 1:22 p.m. We're off the record. 22 (Whereupon, a short recess was 23 taken and upon resuming, E-mail Chain 24 was marked as Jalbert Exhibit 9 for 25 identification as of this date by the Page 139 1 C. JALBERT 2 Reporter.) 3 THE VIDEOGRAPHER: The time is 4 1:28 p.m. We're back on the record. 5 You may proceed. 6 Q. I think you have received 7 what's been marked as Jalbert Exhibit 9. 8 This bears the Bates Kwok 00001684. Do you 9 recognize this document? 10 A. Yes. 11 Q. Turning to the attachment, to 12 your knowledge, is this the final version 13 of the living expenses for the period 14 February 15th to February 28th? 15 A. Ithinkitis. 16 Q. I'll represent, if you add 17 \$51,495.67 plus the 109 thousand -- 18 A. 161. 19 Q. So we're on the same page, this 20 is the final version? 21 A. Yes. 22 Q. Does this final version reflect 23 Verdolino and Lowey's edits on the initial 24 draft provided by an unknown person? 25 A. Well, it's certainly -- as you 1 C. JALBERT 2 can see from the e-mail, we made 3 suggestions but counsel clearly reviewed 4 and assisted with the final decision and Page 140 5 I'm sure they also checked with the debtor. 6 I did not. 7 **Q.** So just walking through these 8 five suggestions, why did you increase the 9 meals to 50 percent or why did you 10 recommend increasing the meals to 50 11 percent? 12 A. Because there's a husband and a 13 wife and one hundred percent divided by two 14 is by 50 percent. 15 Q. Do you have any understanding 16 as to why the draft had allocated the 17 numbers in the way it had in Exhibit 7? 18 MR AULET: Objection to form. 19 A. So I think what the creator of 20 the initial -- my memory is the creator of 21 the initial document took into 22 consideration that occasionally, the 23 debtor's daughter and maybe one or two 24 other people occasionally showed up and so 25 I think they ascribed some of the cost to Page 141

36 (Pages 138 - 141)

1 C. JALBERT 2 those people but our feeling in 3 consultation with the attorneys was that 4 the only reason those people are there is 5 they're coming to visit the debtor and 6 that's why they incurred the cost. So I 7 thought they should put 50 percent to the 8 husband and 50 percent to the wife and 9 that's how we got the 50 percent. 10 Q. Besides what you just described 11 to me, do you have anymore reasons for 12 suggesting the increase of 50 percent? 13 A. Not that I can remember. 14 Q. Item 2 is security is increased 15 to 100 and looking at the draft in Exhibit 16 7, it was 40 percent. What was your 1 7 reasoning for suggesting to increase the 18 security to 100? 19 A. Again, the only reason there's 20 any security at all is all about the 21 debtor. So in an abundance of caution, 22 we're ascribing that cost, one hundred 23 percent of that cost to the debtor. The 24 wife likely would not have security 25 concerns if she were not married to 1 C. JALBERT Page 142 2 Mr. Kwok and when the daughter or others 3 sometimes travel, they need security as 4 well. So for whatever reason, their 5 security is all related to the debtor. We 6 suggested going to a hundred percent. It 7 was discussed among the group and everyone 8 agreed to the 100 percent. 9 **Q.** What is the basis for your 10 assumption that the primary reason security 11 has been retained is directly related to 12 the debtor? 13 A. Discussion with Melissa Francis 14 and Aaron Mitchell who confirmed in several 15 phone calls that the debtor is harassed and 16 threatened and otherwise scared for his 1 7 existence and to the extent the -- I'm told 18 to the extent the family is scared, they're 19 scared because of their relationship to 20 their father. 21 **Q.** Is there any other reasoning 22 that you haven't articulated about the 23 basis for your increasing security to one 24 hundred? 25 A. Well, it is very conservative Page 143 C. JALBERT 2 to ascribe the one hundred percent of the 3 cost to the debtor is -- means that all 4 that costs -- we could have left it at 30 5 percent and probably made it a callable 6 argument of why it could be 30 percent. We 7 wanted to go with -- I think part of the 8 final reasoning amongst the group was that 9 it's conservative to report all ofit on 10 the debtor's behalf because ofhis safety 11 concerns is -- that was the reasoning. 12 **Q.** Thank you. Item 3 is utilities 13 increased to 50 percent and I'll represent 14 Exhibit 7 has it at 30 percent and you 15 ascribe the same explanation as the meals. 16 Is there any other -- 17 A. No, it's the same -- it's the 18 same -- it's the same theme at different 19 percentages for most of these. 20 **Q.** Item 4 refers to housekeeping. 21 I believe Verdolino and Lowey recommended 22 changing repair and maintenance to 23 housekeeping? 24 A. Well, as it turns out, once we 25 were able to speak with someone and get Page 144 1 C. JALBERT 2 some information that's behind the numbers, 3 we found out that that's the cost of the 4 maid for those 15 days or maids or maid 5 service or cleaning service and not 6 maintenance. So it's just a matter of 7 calling it what it was. Had we seen 8 detail, we would have understood that on a 9 more timely basis. 10 Q. Your reasoning for increasing 11 the allocation from 30 to 50 percent, is it 12 fair to say it's the same reasoning 13 behind -- 14 A. It's a husband and a wife. You 15 know, any other cleaning they do on behalf 16 of anybody else, the only reason they're 17 there is because the Kwok's are there. The 18 debtor and his spouse. 19 **Q.** You note at the bottom of the 20 page, "in our opinion, it's best to be more 21 conservative". That's another reasoning 22 behind your -- 23 A. Yes. 24 **Q.** -- suggestion to increase the 25 allocations? Is that yes? Page 145

37 (Pages 142 - 145)

| 1 | C. JALBERT | 1 | C. JALBERT | |-----|--------------------------------------------------|----|-----------------------------------------------------| | 2 | A. Yes. | 2 | THE WITNESS: Okay. | | 3 | Q. I do want to talk about the | 3 | Turning to Page 2, Melissa Q. | | | 4 insurance changed to zero percent from 3 0 | | 4 Francis notes that, "since MK doesn't own | | | 5 percent. | | 5 the Connecticut property, can you please | | 6 | MS. ARONSSON: I think, | | 6 just explain the applicability of the | | 7 | Makenzie, can you hand me Tab 14? | | 7 following entries as his monthly expenses? | | 8 | A. All done? | | 8 And what type of insurance is it?" Do you | | 9 | Yes. Before I show you the Q. | | 9 see that? | | | 10 document, do you recall information about | 10 | A. Yes. | | | 11 the change from 30 percent to zero percent | 11 | Q. What do you understand Ms. | | | 12 for the insurance line item? | | 12 Francis to be asking here? | | 13 | I recall talking with my A. | 13 | A. Since the debtor doesn't own | | | 14 colleague about it after he found out the | | 14 the Connecticut property, can you please | | | 15 facts, yes. | | 15 justify the applicability of the following | | 16 | What do you remember about that Q. | | 16 entries as his monthly expenses and she's | | | 1 7 interaction? | | 17 asking what type of insurance. | | 18 | A. Well, I think he found out the | 18 | What is your view, ifany, on Q. | | | 19 insurance payment that -- that 13 thousand | | 19 her question? | | | 20 dollars on Number 9 here was one hundred | 20 | MR AULET: Objection to form. | | | 21 percent pertaining to the Sherry apartment | 21 | A. I would like to answer them | | | 22 in New York City where he did not live | | 22 correctly. | | | 23 during this time frame and so to the extent | 23 | You would like to answer the Q. | | | 24 that someone is paying those bills of the | | 24 monthly reporting -- | | | 25 Sherry, I think that's the Sherry's problem | 25 | A. I'm hoping we answered her | | | Page 146 | | Page 148 | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 and not on account of the debtor because as | | 2 questions. I mean this is going onto the | | | 3 I'm told by the attorneys, everyone's | | 3 monthly reporting but I'm hoping we | | | | | | | | 4 understanding, from the facts is that he's | | 4 answered them correctly. | | | 5 -- he does not have an interest in that | 5 | Substantively, what is your Q. | | | 6 real estate. So he shouldn't have any | | 6 view on her question here? | | | 7 percentage in the expenses shown on the | 7 | MR AULET: Objection to form. | | | 8 monthly operating report. | 8 | A. I don't want to try and guess | | 9 | (Whereupon, E-mail Chain was | | 9 what she was thinking. | | 10 | marked as Jalbert Exhibit 10 for | 10 | Q. So you have no understanding -- | | 11 | identification as of this date by the | | 11 Verdolino and Lowey has no understanding | | 12 | Reporter.) | | 12 about the question she's asking here? | | 13 | MS. ARONSSON: The Court | 13 | A. I have my understanding. | | 14 | Reporter is going to be handing you | 14 | Q. Okay. Turning to the first | | 15 | what's marked as Jalbert Exhibit 10. | | 15 page, Mr. Flynn responds, "correct, he | | 16 | This is a document produced in this | | 16 doesn't own it but he lives in the | | 1 7 | matter with the Bates Kwok 00001691. | | 17 Connecticut house so these expenses that | | 18 | I understand you're not on this Q. | | 18 are paid are benefitting him". Do you have | | | 19 document but I just want to discuss a | | 19 any understanding of what Mr. Flynn is | | | 20 couple issues here. Do you recognize this | | 20 saying here? | | | 21 document? | 21 | A. That's why he's saying that | | 22 | A. No, but I recognize the | | 22 since he lives there, he aught to be -- | | | 23 subject. | | 23 there should be some level of those | | 24 | MR HARBACH: Give him a minute | | 24 expenses ascribed to him in the monthly | | 25 | to read it. Page 147 | | 25 operating report in that Question 8. Page 149 |

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1 C. JALBERT 2 Q. Mr. Flynn continues, "I have a 3 question regarding the insurance as well 4 since this is insurance on the apartment of 5 the Sherry". Do you understand what issue 6 hes referring to here? 7 A. Yes. 8 Q. Can you explain it for me? 9 A. Well, in the Number 8 -- no, 10 Number 9, the original version of this had 11 insurance. We didn't know what it was 12 insurance on. Frankly, when we got it, we 13 assumed it was on the Greenwich residence 14 where the debtor and his spouse actually 15 reside. We factually found out that it's 16 actually insurance on the Sherry and when 17 we found out it's insurance on the Sherry, 18 since the debtor doesn't live there and 19 doesn't own it, by review of materials from 20 the lawyers, it should be eliminated and 21 that's what we proposed, to eliminate it. 22 Q. It was ultimately eliminated? 23 A. Yes. 24 Q. Mr. Flynn continues "I am not" 25 I am not sure it should be included here? Page 150 1 C. JALBERT 2 I think that's what he means -- "in this 3 calculation but interested on your thoughts 4 and also asking Craig". Do you recall him 5 asking your opinion on this? 6 A. Yes. 7 **Q.** Is your opinion the same as 8 Mr. Flynn's here -- 9 A. Yes. 10 Q. Do you recall speaking with 11 Mr. Flynn about that? 12 A. I do. 13 **Q.** Turning to the top e-mail here 14 on this chain, on Page 1, Mr. Flynn asks, 15 "how much was paid during this period for 16 the Sherry". Do you see that? 17 A. Yes. 18 Q. Do you know the answer to that 19 question? 20 A. I have no idea. Also, I don't 21 know why he asked it. 22 Q. That was going to be my 23 question. Why would it matter whether -- 24 how much it was as to whether it should be 25 included in the monthly operating report? Page 151 1 C. JALBERT 2 A. I don't know. 3 **Q.** The original allocation to this 4 line item I think is -- 5 **MR HARBACH:** Right here 6 (indicating). 7 **Q.** -- at 13 thousand and that's 8 reflected on Page 2. \$13,611. Besides Ms. 9 Francis' e-mail, do you have any 10 independent knowledge of that information? 11 MR AULET: Objection to form. 12 A. No. It came from Melissa 13 Francis. I don't know where she got that 14 number from or why. 15 Q. Did you look into insurance for 16 the Greenwich property? 17 A. No. 18 Q. Why not? 19 A. We asked for someone in the -- 20 with the correct knowledge to give us all 21 of the expenses paid cash, check, wire 22 transfer, **HCH,** any other method, February 23 15th to February 28th on behalf of the 24 debtor. We didn't leave any -- we didn't 25 ask for -- we didn't leave any Page 152 1 C. JALBERT 2 restrictions. We just said give us all of 3 that information. We got a summary chart. 4 You saw it and it wasn't till we started 5 asking questions to understand some of the 6 background and what is behind the numbers 7 that we started making assessments and 8 changing what we think the legal group and 9 us thought it was appropriate. 10 CONTINUED EXAMINATION 11 BY MR HARBACH: 12 Q. You said a moment ago that 13 originally, you and your team thought that 14 the 13 -- excuse me, I think you said you 15 assumed that the \$13,611 was for the 16 Greenwich property because that's where he 17 was living. I got that right? 18 A. Yes, sir. 19 Q. Then you were told that the 20 13,611 was actually for the Sherry, right? 21 A. Correct 22 Q. And at that point, you did not 23 inquire about was there actually any 24 insurance money paid for the Greenwich 25 property during this period, you didn't ask Page 153

39 (Pages 150 - 153)

1 C. JALBERT 2 that question? 3 A. No, we assumed -- actually, 4 Matt had confirmed this is a list of all 5 the payments made during this time frame. 6 So we had the universe that wasn't another 7 insurance payment and you know, most -- 8 many of us have owned homes. My own 9 empirical knowledge is you typically pay 10 your homeowner's insurance once a year. 11 It's usually -- in the Sherry, this 13 12 thousand dollars might have been just a 13 payment for the year on a 2 .5 million 14 dollar entity. They didn'ttell us it was 15 a payment so I didn't ask. 16 CONTINUED EXAMINATION 17 BY **MS. ARONSSON:** 18 **Q.** So I think we've covered the 19 work that you have done in connection with 20 the monthly operating report for the period 21 February 15th to February 28th. We've been 22 looking at that document. Is that right? 23 A. Yes. 24 Q. Can you think of anything else 25 that we haven't talked about with the work 1 C. JALBERT 2 that you've done, in connection with 3 preparing that document? 4 A. Off the top of my head, no. 5 Q. I think you referenced you're 6 preparing the next reporting cycle? 7 A. Yes. 8 Q. Can you describe your general 9 process and how that defers, if it does, Page 154 10 with your reporting cycle for the February 11 15th to February 28th period? 12 A. So the monthly operating report 13 is basically presenting information and the 14 two buckets of information that are in the 15 monthly operating report as for this debtor 16 is that Question E, the funds disbursed on 1 7 his behalf in the 31 day period, March 1 to 18 March 31, we're going to -- we're going to 19 figure out -- we're going to get a list. 20 This time, we're going to get a list so we 21 can see what there was and we can have -- 22 we can have more educated discussion with 23 the lawyers about what was paid. That will 24 be summarized and categorized and put in 25 Schedule E and in addition, we're working Page 155 1 C. JALBERT 2 with the Brown Rudnick firm and Melissa 3 Francis and Aaron Mitchell to determine 4 what the accrual of professional fees. All 5 professionals, state professionals, 6 committee professionals, debtor 7 professionals, ordinary course -- alleged 8 ordinary course professionals, everybody 9 because we need to record the accrual. So 10 it's not just -- the operating report is 11 not just asking for what was paid during 12 that period. It's asking for what's the -- 13 the new form is asking what are the unpaid 14 amounts and we couldn't get it in time to 15 get the February one. So we're going to 16 catch up in this March one, we're going to 17 establish what the February accrual was and 18 we're going to find out what the March 19 accrual was and then we'll have the correct 20 information and it will have to be 21 maintained as we go along and obviously, as 22 time goes on, if things go according to the 23 way the debtor would like, there will be 24 payment on those fees. So there'll be more 25 accruals and then payments and the same C. JALBERT 2 thing is true of the estate professionals 3 and the committee and its professionals. 4 It will be a roll forward of what the 5 liability is and the cash will be reported 6 on Page 1. It will create liability to the 7 United States Trustee for their fee -- 8 their -- their -- it's a fee. It's not a 9 commission. Their fee for -- which is Page 156 10 entirely predicated on cash disbursements 11 during the time of the monthly operating 12 report. 13 **Q.** Do you anticipate -- strike 14 that. Besides information that you'll 15 receive from Brown Rudnick, from Aaron 16 Mitchell, from Melissa Francis and an 1 7 unknown person, do you anticipate doing any 18 investigation in connection with future 19 monthly operating reports? 20 MR AULET: Objection to form. 21 A. I don't know what you 22 consider -- I'm not going to -- we're going 23 to get a report from someone. That report 24 is going to list out all of the payments 25 made during a specific time period. We're Page 157

40 (Pages 154 - 157)

1 C. JALBERT 2 going to review that with our own 3 professional knowledge and with the lawyers 4 to make sure it all makes sense. We might 5 ask questions based on what shows up on the 6 spreadsheet but I'm not going to ask for a 7 copy of the cancelled check, a bank 8 statement or the invoice that was paid. So 9 no investigation of that, just a sanity 10 check or a reasonableness check and confer 11 with counsel to be sure that we understand 12 what's on that sheet and what we're going 13 to report. 14 Q. So essentially, you'll rely on 15 the rolled up numbers that are provided to 16 you from the individuals we've talked 17 about? 18 A. Again, except for some queries 19 that we'll make depending on what the 20 information we get. Ifwe get -- if 21 insurance shows up again, we're going to 22 ask insurance on what. If repairs and 23 maintenance shows up again, we're going to 24 confirm it's not the maid. So we'll use 25 some common sense and we'll confer with the Page 158 1 C. JALBERT 2 lawyers based on what we see but I won't 3 know what we're going to do until we see 4 what -- and I hope it's soon. What's 5 today, April 8th? 6 Q. Thank you. Okay, just quickly 7 turning back to Exhibit 8 which is I think 8 the final living expense report for the 9 period February 15th, 2022 to February 10 28th, 2022. I think you had referenced an 11 erroneous amount included in here. Can you 12 just explain again what you meant by that? 13 A. I don't remember exactly what 14 the number is but on the security line, 15 Line Number 9, the amount referenced her 43 16 thousand dollars. That 43 thousand dollars 17 included a payment of -- my memory is 18 something like 12 or 14 thousand dollars 19 that was paid February 10 and so we got 20 this report, the original one, and didn't 21 know the back -- the background and when 22 they -- when they showed us the background 23 and the list of--we saw February 10. So 24 we realized we had the opposite mistake of 25 the time with the two professionals where Page 159 C. JALBERT 2 they paid post-petition pre-petition. Here 3 they paid pre-petition, pre-petition but 4 should have been excluded from the monthly 5 operating report. Legitimate charge. It 6 wasn't an overpayment or anything. It just 7 didn't belong reported in the February 8 monthly operating report. 9 Q. So is it fair to say you later 10 received a more detailed breakdown of these 11 items that was included in this -- 12 A. I believe we got a more 13 detailed -- but it was -- it was 14 significantly past that time. Everything 15 at that time was done by reviewing, 16 talking, Melissa and Aaron talking with 1 7 whoever and Matt talking to whoever. It 18 was all done by e-mail and orally. We 19 didn't get a spreadsheet of the detail 20 until sometime later, long after it was 21 filed and actually, after the time that we 22 made available our records that we got -- 23 the detail listing which is when we figured 24 out oh we got a problem with the monthly 25 operating report. It's just a matter of, Page 160 1 C. JALBERT 2 you know, whoever is preparing these things 3 isn't used to the rules, isn't used to 4 what's got to be displayed -- disclosed and 5 what's not going to be disclosed. We try 6 and give them guidance and they just made a 7 minor error. We'll fix it next month. 8 Q. Thankyou. Youcansetthat 9 aside. Do you recall receiving an inquiry 10 from someone at U.S. DOJ regarding the 11 monthly operating report? 12 A. I think I actually reached out 13 to them first and my reaching out to them 14 first was -- and that's how -- was -- I 15 don't know if anyone's ever prepared a 16 monthly operating report, is there one 17 here? So the monthly operating report, up 18 until December 31 or January 31 was one, 19 two -- these two pages (indicating), Page 8 20 which is now Page 8 and Page 9 and there 21 might have been one more -- I thought it 22 was five pages. It might have been four. 23 And I filed these monthly operating reports 24 in several cases and it had been driving me 25 crazy for three months that I would -- I Page 161

41 (Pages 158 - 161)

| 1 | C. JALBERT | | C. JALBERT | |-------|----------------------------------------------------------|----|------------------------------------------------------| | | 2 would -- the way the monthly operating | | 2 have done anyway's. | | | 3 reports, the bottom, for the first page, it | 3 | We've talked about your Q. | | | 4 allows you to use save if you're inputting | | 4 experience in Chapter 11 individual | | | 5 data so that you can review it but it | | 5 bankruptcies before. Reflecting on your | | | 6 retains a watermark up until the time you | | 6 experience in these instances, were any -- | | | 7 hit a button that says send the data out to | | 7 do you have any -- can you cite any case | | | 8 the United States Trustees website and it | | 8 where you've seen such a great disparity | | | 9 does whatever it does and when it did that, | | 9 between the debtor's punitive assets and | | | 10 it kept on coming back with these extra six | | 10 the stated liabilities? | | | 11 pages and this nonsense (indicating). So I | 11 | A. No. In my individual cases, | | | 12 actually reached out to the U.S. Trustees | | 12 the 373 million dollars of liabilities is | | | 13 Office saying what are we doing wrong. | | 13 the most I've ever seen. | | | 14 It's midnight and we're trying to get this | 14 | MS. ARONSSON: We don't have | | | 15 thing in. He says no, everyone's having the | 15 | anymore questions. | | | 16 same problem. We've just finally figured | 16 | MR AULET: I have nothing. | | | 17 out that's what's supposed to happen. So | 17 | MR GOLDMAN: I have a few | | | 18 that's when we started talking with him and | 18 | follow-ups. I'll just be a couple | | | 19 then when he saw it, he had our e-mail | 19 | hours. | | | 20 addresses and we -- and he was looking for | 20 | THE WITNESS: Beautiful. Do | | | 21 the support for the 161, I believe is what | 21 | you mind if I go get a bottle of | | | 22 he was asking for. I don't have it in | 22 | scotch? | | | 23 front of me or if I do, I didn't -- I don't | 23 | MR GOLDMAN: Get me one too. | | 24 -- | but that's my recollection, that's why | 24 | I'm Irve Goldman -- | | | 25 he reached out was to get -- to get that | 25 | THE VIDEOGRAPHER: Can you give | | | Page 162 | | Page 164 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 and to get the I think accrual of the | 2 | him the microphone, please? | | | 3 professional fees going forward. | 3 | MR AULET: Yes. Can I take us | | 4 | Q. Did you have a call regarding | 4 | off the record really quick so I can | | | 5 the monthly operating report and further | 5 | | | | 6 details on the line items? | 6 | MR HARBACH: Sure. | | 7 | A. Not a call. You have whatever | 7 | THE VIDEOGRAPHER: The time is | | | 8 e-mails there were. It was very -- I was | 8 | 1:56 p.m. and we are off the record. | | | 9 very limited. My call to him was a general | 9 | (Whereupon, an off-the-record | | | 10 question on my three cases, I'm trying to | 10 | discussion was held.) | | | 11 file these. He was able to answer my | 11 | THE VIDEOGRAPHER: The time is | | | 12 question -- my main question. He then, | 12 | 1:58 p.m. We're back on the record. | | | 13 when he saw the monthly operating report, | 13 | You may proceed. | | | 14 he said hey, I need this and we're going to | | 14 EXAMINATION BY | | | 15 obviously arrange to do that. | | 15 MR GOLDMAN: | | 16 | Q. So was it the inquiry from the | 16 | Q. Good afternoon. Irve Goldman, | | | 17 trustee that prompted Verdolino and Lowey | | 17 Pullman and Comley for the Creditor's | | | 18 to request additional details and | | 18 Committee. You mentioned you were | | | 19 breakdowns of the line items contained in | | 19 certified as an insolvency restructuring | | | 20 the monthly operating Excel that we've | | 20 expert. Did I get that right? | | | 21 looked at? | 21 | A. Advisor. | | 22 | A. No. We wanted to do that | 22 | Advisor, for how long? Q. | | | 23 anyway's. That just -- that gave us more | 23 | A. Well, the actual designation | | | 24 fuel to bring it to them to say hey, we got | | 24 came in 1999 but in 1999, when I got the | | | 25 to get to this. That's something we would Page 163 | | 25 designation, I had to spend over four Page 165 |

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| 1 | C. JALBERT | 1 | C. JALBERT | |----------|--------------------------------------------------------------------------------|----------|-----------------------------------------------------| | | 2 thousand hours and have been in the | 2 | and I -- and I regret completely that | | | 3 profession for eight years at that point. | 3 | we were brought in as a financial | | | 4 So 30 years ago. | 4 | advisor and not an accountant to the | | 5 | Do you typically call on that Q. | 5 | debtor. Most of what you see on that | | | 6 expertise when you're engaged as a | 6 | motion to employ is very important | | | 7 professional in Chapter 11 cases? | 7 | stuff in the process ofbankruptcy. | | 8 | Certainly some of it, yes. A. | 8 | The schedules, the SOFA's, the --the | | 9 | What aspects of the debtor's Q. | 9 | monthly operating reports, tax return | | | 10 financial profile do you view as needing | 10 | preparation, analysis of claims and I | | | 11 restructuring? | 11 | don't know whether we'll have a role | | 12 | MR AULET: Objection to form. | 12 | in that or not. It depends on what | | 13 | A. Needing restructuring, I don't | 13 | the nature of the claim is. Most of | | | 14 understand your question. | 14 | these claims will be legally analyzed | | 15 | Q. Well, you're a certified | 15 | but there might be a hundred reasons | | | 16 insolvency restructuring expert. You call | 16 | why someone that filed a claim -- | | | 1 7 upon that expertise in your engagements in | 17 | there might be an accounting | | | 18 Chapter 11 cases. What is it about the | 18 | attached, they do want us to | | | 19 debtor's financial profile that you view as | 19 | investigate. So we're not brought in | | | 20 in need of restructuring? | 20 | to -- just because we think there's | | 21 | A. Well, you know -- | 21 | going to be a reorganization. | | 22 | MR AULET: Objection to form. | 22 | Bankruptcy is a process. There's an | | 23 | Do you view it as in need of Q. | 23 | awful lot of paper that gets pushed | | | 24 restructuring? | 24 | by an awful lot of people. This | | 25 | A. No, I don't. | 25 | particular debtor is -- as I | | | | | | | | Page 166 | | Page 168 | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | 2 | You don't? Q. | 2 | understand it, is in excess of 70 | | 3 | A. Absolutely not. | 3 | years old. Doesn't even have an | | 4 | Q. So why do you believe he filed | 4 | e-mail address. Doesn't know how to | | | 5 Chapter 11 then? | 5 | use computers. Doesn't know | | 6 | A. Well, the debtor needs | 6 | technology. Couldn't possibly do the | | | 7 restructuring. I don't think -- | 7 | monthly operating reports himself and | | 8 | (Whereupon, a cell phone rang.) | 8 | virtually, in every case, there's an | | 9 | THE WITNESS: Oh, I apologize. | 9 | accountant that does tax returns. | | 10 | That was for me to remind me to do | 10 | There's an accountant that does -- | | 11 | something at 2:00 which I can't | 11 | that helps with preparing monthly | | 12 | remember what I'm supposed to do. | 12 | operating reports. Even when the | | 13 | Just making sure it wasn't on -- what | 13 | company has a controller, we still | | 14 | is that when it comes back on later | 14 | come in in cases where -- so there | | 15 | and it annoys you? The debtor's | 15 | may not be a reorganization as of | | 16 | restructuring, if you're referring to | 16 | right now. There's going to be a | | 17 | the questions were brought up -- in | 17 | plan someday. I don't know what role | | 18 | an ordinary Chapter 11 case that's a | 18 | we're going to play but if we need to | | 19 | business, there's lots of things to | 19 | be -- if the counsel and debtor needs | | 20 | consider if there's a real | 20 | us to play a role, we will but until | | 21 | restructuring. You've got to | 21 | that day, there's lots of necessary | | 22 | restructure the debt, the secure | 22 | work to do in the ordinary course of | | 23 | debt. Maybe mezzanine, unsecured | 23 | the process in the life of a Chapter | | 24 25 | debt. Maybe work with payables, all sorts of -- that isn't the case here | 24 25 | 11 case here. Q. What you just described were |

43 (Pages 166 - 169)

| 1 | C. JALBERT | 1 | C. JALBERT | |----|-------------------------------------------------------------------------------------------|----|-----------------------------------------------------------------------------------------| | | 2 menial tasks of accounting? | | 2 counsel wants us to play and the debtor | | 3 | A. I disagree. | | 3 wants us to play. If they want us to play | | 4 | Q. No, you disagree? | | 4 part of the role of looking at the | | 5 | A. Preparing the SOF A's and | | 5 pre-petition payments, which we ordinarily | | | 6 preparing the MO R's, you think that's all | | 6 do in most of the cases we do, we come up | | | 7 menial tasks? | | 7 with the list, here it already exists. We | | 8 | All right, I won't argue with Q. | | 8 might ask for support to confirm but it's | | | 9 you on that. What is it about this case | | 9 entirely up to the team that's running the | | | you view that is in need of 10 that you -- | | 10 case. We're not running the case. We're | | | 11 restructuring, if anything? | | 11 -- we're -- I think we're an important | | 12 | MR AULET: Objection to form. | | 12 member of the team but we're not -- the | | 13 | A. Yeah, I don't know what you're | | 13 accounting firm is not driving the case. | | | 14 trying to ask. | | 14 The debtor and his counsel is driving the | | 15 | Q. Are there assets that need to | | 15 case as is true of every case. | | | 16 be restructured? | 16 | Do you know where the debtor's Q. | | 17 | A. The only assets I understand | | 17 books and records reside? | | | 18 are -- I think the lawyers call them | 18 | A. I do not. | | | 19 litigation assets in the like. | 19 | Do you know if the debtor had a Q. | | 20 | So how would they be Q. | | 20 pre-petition account? | | | 21 restructured or part of a restructuring? | 21 | A. Only from knowledge from | | 22 | MR AULET: Objection to form. | | 22 lawyers. | | 23 | A. You're probably asking the | 23 | Who was the accountant? Q. | | | 24 wrong guy but if there's ongoing | 24 | A. Accountant? | | | 25 litigation, I suspect there's going to be | 25 | Yeah, I asked you -- Q. | | | Page 170 | | Page 172 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 -- you would hope there would be settlement | 2 | Oh actually, I take that back. A. | | | 3 negotiations, there might be mediation, | | 3 I saw actual tax returns. There was -- | | | 4 there might be arbitration. Someone's | | 4 every preparer has to list their name on a | | | 5 going to try and liquidate those assets 6 into cash with which to pay the creditors. | | 5 tax return they prepare. So there was -- 6 someone paid tax returns at least. What | | | 7 I don't know whether we'll play a part in | | 7 else they did, I don't know. | | | 8 that or not. | 8 | Okay, what was the name of the Q. | | 9 | the scope of As part of your -- Q. | | 9 accountant? | | | 10 your engagement, there is a bullet point | 10 | A. I don't remember. | | | 11 that states that you're going to provide | 11 | Q. Have the tax returns been | | | 12 assistance -- | | 12 produced to any party in the case thus far? | | 13 | THE COURT REPORTER: I'm sorry, | 13 | A. I imagine we produced them | | 14 | Counsel. I need to hear you better. | | 14 because we had them. They would have come | | 15 | Q. Provide assistance with | | 15 in an e-mail. So they would have been | | | 16 reviewing debtor books and records for | | 16 produced as it relates to this I think. I | | | 17 possibly avoidable transactions such as | | 1 7 think they were but they were very small | | | 18 preference and fraudulent transfer claims. | | 18 tax returns prepared by -- I assume a New | | | 19 You stated that you did not review any of | | 19 Yark or a Connecticut accountant. I don't | | | 20 the debtor's books and records, correct? | | 20 knowwho. | | 21 | A. Currently, so far, yes. | 21 | You just don't --you obviously Q. | | 22 | Q. Did you ask for any? | | 22 looked at it, you just don't recall the | | 23 | A. No. | | 23 name of that accountant right now? | | 24 | Q. Do you intend to? | 24 | A. I don't -- well, yes. I'm not | | 25 | A. Depends on what role the Page 171 | | 25 even sure ifl looked at it. I don't know Page 173 |

44 (Pages 170 - 173)

1 C. JALBERT 2 if, at the time when we were trying to do 3 everything, we were using those because we 4 needed some of the information on there. 5 We were referred to them by Melissa for 6 certain issues that the lawyers thought 7 were important and we went and took a look 8 at them but I would have looked at 9 something besides the name of the preparer. 10 At the time, it didn't matter. 11 Q. Have you ever spoken to the 12 debtor? 13 A. Yes. 14 Q. When? 15 A. Wednesday at the 341 hearing to 16 introduce myself. 1 7 **Q.** Is that the only occasion, to 18 your knowledge, that you've spoken to the 19 debtor? 20 A. I don't speak Mandarin and he 21 apparently doesn't speak English. So I 22 have not spoken to him. Or Chinese. I'm 23 not sure which it is. Excuse me. 24 Q. You did not receive a 25 post-petition retainer, correct? Page 174 1 C. JALBERT 2 A. Correct. 3 **Q.** Are you confident that your 4 fees will be paid? 5 A. I don't know ifl'm confident. 6 I'm hoping. 7 **Q.** What source do you believe your 8 fees will be paid, from what source? 9 A. It will come from the Estate. 10If we're going to be paid, as I understand 11 it, it will come from the Estate. I don't 12 -- I have not thought of or have any 13 agreement on any other source of payment. 14 Q. Do you mean the litigation 15 claims or recoveries? 16 A. I would expect the only people 17 that have a retainer in this case are Brown 18 Rudnick. Everybody else will be looking to 19 be paid -- that is a debtor's professional 20 or a committee professional, professionals 21 that file an application with the Court and 22 the Court allows their retention will be 23 looking to get funds. We're all going to 24 be looking from the same place. What that 25 source is going to be, if it will ever be, Page 175 1 C. JALBERT 2 I don't know. 3 Q. What information, if any, did 4 you rely on in getting comfortable taking 5 this case without a post-petition retainer? 6 A. I've been doing this for 35 7 years. I'm not sure. I don't remember 8 ever getting a post-petition retainer but 9 my firm works with -- 10 (Whereupon, a cellphone rang.) 11 THE WITNESS: Shit, I'm sorry. 12 Now it's off. We -- we're a 13 practitioner in Massachusetts and we 14 do cases in Delaware, New York, 15 Connecticut, Rhode Island, 16 Massachusetts, New Hampshire, 1 7 Vermont, Maine. We represent Chapter 18 7 trustees in virtually all of those 19 states. We probably represent and do 20 work for virtually ever Chapter 7 21 trustee in Rhode Island, every 22 Chapter 7 trustee in Massachusetts, a 23 couple in Maine, a couple in New 24 Hampshire and it's not unheard of for 25 us to go and do 50, 60, 70, 80 Page 176 1 C. JALBERT 2 thousand dollars of work before we 3 even know the case will ever have any 4 money. It's an investment that we 5 make. Now I didn't make an 6 investment in this case. Whatever we 7 incurred -- and I don't know what 8 that is, I'm hoping I'm going to 9 collect it but if I don't, then I'll 10 have a write-off like I've had many, 11 many, many, many times in the past. 12 Q. Again, I don't think you 13 answered my question. 14 A. Oh all right -- 15 Q. If you -- if you relied just on 16 your experience in engagements in 17 bankruptcy cases and that's it for taking 18 this case without a pre or post-petition 19 retainer, is that what you mean -- 20 A. I don't understand your 21 question. 22 **Q.** What information, if any, did 23 you rely on in taking this case without a 24 pre or post-petition retainer? 25 MR. AULET: Objection to form. Page 177

45 (Pages 174 - 177)

| 1 | C. JALBERT | 1 | C. JALBERT | |-----|---------------------------------------------------------------------------------|----|--------------------------------------------------------------------------| | 2 | I do work with lots and lots of A. | | 2 engagement? | | | 3 attorneys and when attorneys call up and | 3 | A. Absolutely not. | | | 4 they ask if we're interested on working on | 4 | Have you had any communications Q. | | | 5 the case, I work on the case. | | 5 with any representative from Golden Hill? | | 6 | So you relied on being asked to Q. | 6 | MR. HARBACH: Golden Spring. | | | 7 get involved by Brown Rudnick? | 7 | Golden Spring. Q. | | 8 | A. Yep. | 8 | A. I was on e-mails with someone | | 9 | That's it? Q. | | well, first of all, Melissa Francis 9 from -- | | 10 | A. Yep, and then after that, it's | | 10 has a Golden Spring e-mail address. She's | | | 11 bankruptcy process. Whatever happens, | | 11 counsel to the debtor. I've been informed | | | 12 happens. | | 12 of that from the beginning. The only other | | 13 | You didn't look at the Q. | | 13 contact -- | | | 14 financial profile of this debtor at all in | 14 | She'scounselforthedebtoror Q. | | | 15 determining -- | | 15 Golden Spring? | | 16 | A. I think -- I think I knew he | 16 | A. Debtor. | | | 1 7 had limited assets or no assets and I think | 17 | Q. Melissa -- | | | 18 I knew he had a lot of litigation ongoing | 18 | A. Francis. | | | 19 but -- maybe I'm a fool but I only have one | 19 | Q. But she has an e-mail address | | | 20 other person that I have to answer to and | | 20 from Golden Spring? | | | 21 he lets me run my business just like he | 21 | Correct. They were in all of A. | | | 22 runs his business and my feeling is when a | | 22 these e-mails that they were putting in | | | 23 lawyer calls up and they have a case, then | | 23 front ofme. | | | 24 we respond because ifl don't respond, | 24 | She's counsel for the debtor is Q. | | | 25 maybe the next time he calls another | | 25 your understanding -- | | | Page 178 | | Page 180 | | | | | | | | | | | | 1 | C. JALBERT | 1 | C. JALBERT | | | 2 accountant. So I didn't do all the things | 2 | I've been told emphatically by A. | | | 3 that you think a normal person should have | | 3 her and by Brown Rudnick that she is | | 5 | 4 done to protect themselves on payment. Q. Did you rely on any degree on | | 4 counsel to the debtor, as is Aaron 5 Mitchell. As is Brown Rudnick. | | | | 6 | Q. | | 7 | 6 the financial profile of Golden Spring? A. No. | | Okay. Are they part of the 7 application to retain ordinary course | | 8 | You didn't do any due diligence Q. | | 8 professionals, if you know? | | | 9 on Golden Spring before agreeing to get | 9 | A. I don't know that they're going | | | 10 engaged in this case? | | 10 to be paid by the Estate or not. I don't | | 11 | A. I'm pretty sure I didn't know | | 11 know what they're -- what they're -- what | | | 12 Golden Spring existed by the time I agreed | | 12 motions they filed to be paid. I'm not -- | | | 13 to be in this case. | | 13 I'm not representing them and I'm not | | 14 | Q. How about Lamp Capital, did you | | 14 asking them. | | | 15 do any investigation of Lamp Capital? | 15 | Q. So back to the question whether | | 16 | A. No. | | 16 you had any communications with Golden | | 1 7 | Q. Did you ask any questions about | | 17 Spring -- | | | 18 what the financial profile of those two | 18 | A. So my colleague, Matt Flynn, | | | 19 entities was -- | | 19 had I think one or two phone calls with | | 20 | A. No. | | 20 someone at Golden Spring. There was a | | 21 | -- before getting involved? Q. | | 21 number of e-mails which we looked at in | | 22 | A. No. | | 22 here and you know, 6, 7, 8, 9, whatever, | | 23 | Q. Were you promised that you | | 23 that person is not identified but I did not | | | 24 would be paid from Golden Hill or Lamp | | 24 speak to that person. I had -- I was on | | | 25 Capital before agreeing to take on the Page 179 | | 25 the e-mail exchanges and I wrote exactly Page 181 |

46 (Pages 1 78 - 181)

1 C. JALBERT 2 one e-mail to that person and actually 3 directed it to Melissa and Aaron when I 4 wrote my e-mail. 5 Q. Do you know why that person's 6 name is redacted on the exhibit? 7 A. Yes. 8 Q. Why? 9 A. Because you heard Golden 10 Spring's attorney. They're worried about 11 the safety of their employees given the 12 issues surrounding this case. I don't know 13 anything about that. I'm just doing what I 14 told. I am not disclosing the name. 15 Q. It was at Golden Spring's 16 counsel's behest that that was redacted is 17 your understanding? 18 A. Well, I don't know whether it 19 was Golden Spring's counsel or Golden 20 Spring itself. I don't know -- I don't 21 know who started it. I just -- in fact, I 22 don't think I knew it until the day before 23 -- the day before, maybe Wednesday is when 24 I found out that -- that -- that the 25 documents were redacted. Page 182 1 C. JALBERT 2 Q. Is it your understanding that, 3 according to the debtor, all of his living 4 expenses, pre-petition, were paid by Golden 5 Spring? 6 A. Well, they were paid by 7 somebody else. I can't say emphatically 8 they were paid by Golden Spring. 9 Q. So whatever that person or 10 entity -- whoever that person or entity 11 was, are the living expenses, post-petition 12 living expenses that were prepared in the 13 various schedules, consistent with what was 14 paid pre-petition? 15 A. We didn't do an investigation 16 as to what the pre-petition nature of 1 7 payments or amount of the payments or 18 anything. So I don't have any -- any 19 comparative information. That information 20 will be developed as we see the months go 21 by but I think the final -- the final 22 number for 15 days of the expenses for the 23 individual ended up being something like 28 24 or 29 thousand dollars for 15 days. So 25 multiply that by two 60 thousand dollars Page 183 1 C. JALBERT 2 for the month of which two-thirds of that 3 is security. 4 Q. Is the person or entity that is 5 funding the post-petition living expenses 6 Golden Spring? 7 A. I don't know. That's not one 8 of the questions and no one has volunteered 9 that information. It just says -- the 10 question says is there a third-party making 11 payments on behalf of the debtor 12 post-petition. We answered that question 13 as best we could. We'll fix the one error 14 that remains but it did not ask and they 15 did not tell us, to my knowledge, who is 16 making the disbursements. 17 Q. And you didn't ask? 18 A. No. I don't know how it would 19 affect -- it's not in the monthly operating 20 report so it's none ofmy business I think 21 is what I would have been told. 22 **MR. GOLDMAN:** I don't have any 23 further questions. 24 MR. AULET: I have nothing. 25 THE VIDEOGRAPHER: Can I take 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 184 **C. JALBERT** us off the record for the day? MR GOLDMAN: Yes. THE VIDEOGRAPHER: We're off the record at 2: 18 p.m. and this concludes today's testimony given by Craig Jalbert. (Whereupon, at 2: 18 **P.M.,** the Examination of this witness was concluded.) 0 0 0 0 Page 185

47 (Pages 182 - 185)

1 2 3 DECLARATION 4 I hereby certify that having been 5 first duly sworn to testify to the truth, I 6 gave the above testimony. 7 8 I FURTHER CERTIFY that the foregoing 9 transcript is a true and correct transcript 10 of the testimony given by me at the time 11 and place specified hereinbefore. 12 13 14 15 16 17 CRAIG JALBERT 18 Subscribed and sworn to before me 19 this \_\_ day of \_\_\_\_\_\_\_ 20\_ 20 21 22 NOTARY PUBLIC 23 24 25 1 2 EXHIBITS 3 JALBERT EXHlBHS EXHIBIT EXHIBIT PAGE 4 NUMBER DESCRIPTION 5 Exhibit 1 Notice of Deposition 10 6 Exhibit 2 E-mail Chain 32 7 Exhibit 3 E-mail Chain 35 8 Exhibit 4 Debtor's Application 47 9 Exhibit 5 Official Form 106Sum 93 10 Exhibit 6 Global Notes 111 11 Exhibit 7 E-mail Chain 129 12 Exhibit 8 E-mail Chain 131 13 Exhibit 9 E-mail Chain 139 14 Exhibit 10 E-mail Chain 147 15 (Exhibits retained by Court Reporter.) 16 17 INDEX 18 EXAMINATIONBY 19 MS. ARONSSON MR.HARBACH 20 MS. ARONSSON MR.HARBACH 21 MS. ARONSSON MR GOLDMAN 22 23 24 25 PAGE 5 100 103 153 154 165 Page 186 Page 187 1 2 3 CERTIFICATE STATEOFNEWYORK ) 4 : SS.: COUNTY OF KINGS ) 5 6 I, LENA YA LYNCH, a Notary Public for 7 and within the State of New York, do hereby 8 certify: 9 That the witness whose examination is 10 hereinbefore set forth was duly sworn and 11 that such examination is a true record of 12 the testimony given by that witness. 13 I further certify that I am not 14 related to any of the parties to this 15 action by blood or by marriage and that I 16 am in no way interested in the outcome of 17 this matter. 18 IN WITNESS WHEREOF, I have hereunto **Hsct~IM¥""** Ll:',l',f-\. If-\. LI l'<L11 22 23 24 25 Page 188

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| દિદ | 86:10,22,24 | 132:20 134:13 161 | 24350 188:21 | |-----------------------|-----------------------|----------------------|-----------------------| | | 103:13 115:4,4,8 | 135:13,17 140:18 | 26 120:3,12 | | ર્દ 1:15,18 2:3,12 | 119:21 124:25 | 162:21 | 28 183:23 | | 0 | 164:4 166:7,18 | 132:23 161,323 | 28th 72:9 129:23 | | 0001646 32:16 | 167:5,18 169:24 | 133:5 | 133:12 134:3 | | 00001649 35:10 | 111 - 187:10 | 165 187:21 | 140:14 152:23 | | 140:8 00001684 | 11:53 90:21 | 16th 132:17 | 154:21 155:11 | | 00001691 147:17 | | | | | 00001752 129:3 | 12 2:18 34:22 | 17 119:19,21 | 159:10 | | 02035 6:9 | 85:15 159:18 | 48:22 127:22 18 | 29 183:24 | | 2:18 06103 | 75:21 131:25 120 | 19 131:3 | 167:11 2:00 | | | 120-1 131:25 | 19,488 125:6,15 | 2:18 185:5.8 | | 06601 2:14 | 132:6 | 17:5 1979 | 3 | | 1 | 122b 125:3,14,19 | 1983 17:8 | 23:23 35:8,12 3 | | 3:16 10:14,17 1 | 124 6:8 | 1987 17:10 | 96:25 97:4,8,13,24 | | 17:10 23:22 72:10 | 129 187:11 | 1999 165:24,24 | 115:13 116:21 | | 97:9 113:14,18 | 12:22 90:25 | 1:22 139:21 | 144:12 187:7 | | 114:14 118:3 | 19:8 42:12 13 | 1:28 140:4 | 3,850 96:5 | | 132:21 151:14 | 55:14 103:14 | 1:56 165:8 | 7:5,19 11:2,22 30 | | 155:17 157:6 | 126:5 146:19 | 1:58 165:12 | 107:6 144:4,6,14 | | 187:5 | 152:7 153:14 | 94:19,22 95:8 1 a | 145:11 146:4,11 | | 133:25 147:10 10 | 154:11 | 1 b 95:11 | 166:4 | | 147:15 159:19,23 | 13,611 152:8 | 2 | 30th 2:4 | | 187:5,14 | 153:15,20 | 2 23:22 32:14,18 | 31 17:10 72:10 | | 100 2:18 142:15,18 | 131 187:12 | 33:2,4 41:6 97:13 | 74:24 77:7 121:16 | | 143:8 187:19 | 187:13 139 | 105:21 142:14 | 155:17,18 161:18 | | 10036 1:19 2:5,10 | 14 19:8 98:7 146:7 | 148:3 152:8 187:6 | 161:18 | | 44:7 100th | 159-18 | 2.5 154:13 | 32 187:6 | | 101 6:9 | 147 187:14 | 20 45:8 186:19 | 16:17,22 45:13 341 | | 103 187:20 | 15 77:6 89:10 | 2019 79:18 | 45:14,17 46:14,15 | | 1069 94.71 | 97:25 145:4 | 2020 79:19 | | | 106sum 93:14 | 183:22,24 | 127:24 2021 | 46:19,24 47:8,12 | | 94:2 187:9 | 1 ਦੇਤੇ 187:20 | | 47:13,18 51:15 | | 109 132:22 135:18 | 154 187:21 | 1:10 3:5 2022 | 69:5 116:2 123:15 | | 140:17 | 15th 63:14 72.9 | 125:4 159:9,10 | 123:18 126:13 | | 109,827 133:7 | 125:4 129:23 | 188:19 | 127:10,18 174:15 | | 109,827.12 132:13 | 133:11 134:3 | 21 45:8 49:9 84:9 | 342 16:16 | | 10:17 1:11 3:4 | 140:14 152-23 | 92:21 107:14 | 17:13 176:6 35 | | 10:24 | 154:21 155:11 | 22 43.9 | 187:7 | | 11:15,19 | । ਦੇ ਰੇ-ਰੇ | 22-50073 1:63:22 | 36 95:13 96:2,4,8 | | 11 1:5 21:2,4 | 16 96:18 105:18 | 22nd 3:4 | 96:16 | | 32:11 55:3 70:3 | 126:5 | 23 97.8 | 373 113:19 164:12 | | 74:19 81:6,11 | | | |

[4 - advisor]

| ব | 95:17,19,24 61 | ਰੇਤੇ 187:9 | 172:24 173:9,19 | |------------------------------------|---------------------------------|-------------------|----------------------| | ব 47:24 48:3 91:4 | 62 95:15.16.17 | a | 173:23 179:2 | | 96:9,12,1797:13 | 6:49 39:10 | 1:11 3:4 a.m. | accountants 21:5 | | 107:14 108:8 | 108:8 130:23 6e | 11:15,19 90:21 | 21:6,7,8 | | 113:13 117:4 | 7 | aaron 25:17,19,25 | accounting 22:21 | | 119:4 130:23 | 7 1:18 2:4,9 81:6 | 26:10 31:4,7 32:9 | 63:21 168:17 | | 144:20 187:8 | 86-25 02-18 | 56:18 57:3 59:3,4 | 170:2 172:13 | | 7:18 138:18 40 | 103:12 119:16,21 | 59:10,18 99:2,7 | accounts 69:21,22 | | 142:16 | 128:24 129:11 | 102:11 103:17 | accrual 70:20 | | 159:15,16 43 | 133:16 135:14 | 104:12,16 105:3 | 156:4,9,17,19 | | 43,655.44. 138:16 | 136:18 141:17 | 105:13 106:7 | 163:2 | | 45 72:11 | 142:16 144:14 | 109:24 110:18 | accruals 156:25 | | 47 187:8 | 176:18,20,22 | 112:15 124:2 | 69:2 accrue | | 5 | 181:22 187:11 | 129:18 135:23 | 78:23,25 accrued | | | 6:19 7:16 169:2 70 - | 139:8 143:14 | 79:6 | | 93:12,15 108:8 ತ | 176:25 | 156:3 157:15 | accurate 10:6 | | 117:4 130:23 | 7006 2:14 | 160:16 181:4 | 136:11,12 | | 187:9,19 | 100:20 111:6 77 | 182:3 | 10:2.9 accurately | | 50 6:19 7:14,18 | 78 93:19 | ability 9:25 10:5 | 136:24 | | 118:13 141:9,10 | 8 | able 53:7 78:6 | accustomed 53:9 | | 141:14 142:7,8,9 | | 79:11 136:13 | 19:15 act | | 142:12 144:13 | 8 1:10 119:21 | 138:3 144:25 | 4:8 188:15 action | | 145:11 176:25 500 21:3 126:6 | 120:3 131:16,21 | 163:11 | 63:22 activity | | રે0ર્સ | 134:7 135:11,18 | absolutely 82:6 | 80:12 | | 75:13,17 76:2 505b 75:5 | 149:25 150:9 | 167:3 180:3 | actual 109:17 | | 50th 44:6 | 159:7 161:19,20 | abundance 132:20 | 137:7 165:23 | | 140:17 | 181:22 187:12 | 142.21 | 173:3 | | 51.495.67 122:11 53 | 7:16 176:25 80 83 17:9 | accepted 102:23 | 85:21 140:16 add | | રેર 94:22 95:23 | 850 2:13 | 115:23 access | addition 155:25 | | 56 95:17,19 | 87 17:10 | 119:6 124:16 | additional 163.18 | | 58 95:24 96:2 | 8th 3:5 127:24 | accidently 125:13 | address 6:6.7.8 | | | 159:5 188:19 | account 37:25 | 169:4 180:10,19 | | 6 | | 38:24 52:15 63:19 | addresses 162:20 | | 6 7:5 11:2,8,21,22 | ರ | 64:17 65:3 66:19 | administer 4:6 | | 97:24 98:7 111:4 | ਹੈ 119:21 139:24 | 72:6 91:6,8 92:11 | administrative | | 111:8 117:5 | 140:7 146:20 | 92:16 147:2 | 77:17 78:7,10 | | 119:16,18,21 | 150:10 159:15 | 172:20 | 81:8 | | 181:22 187:10 | 161:20 181:22 | accountancy 17:8 | advising 22:20 | | 60 6:19 7:14 75:11 | 187:13 | accountant 18:16 | 53:261:11 | | 75:19 176:25 | 48:10 82:17 90 | 70:22 80:6 168:4 | advisor | | 183:25 | 83:22 92:23 | 169:9,10 172:23 | 21:5,6 34:7 36:23 |

#### [advisor - aronsson]

| 37:7 39:8 40:20 | allocations 145:25 | 121:17 122:12 | applicable 107:11 | |-----------------------|----------------------|---------------------|----------------------| | 41:20 43:2 48:9 | 12:20 38:23 allow | 130:2 148:21,23 | application 48:2,7 | | 48:21 49:5 70:22 | 65:2 87:11 | 151:18 163:11 | 48:18 49:2 175:21 | | 165:21,22 168:4 | allowed 80:12 | 178:20 | 181:7 187:8 | | advisors 62:4,5 | 81:20 | answered 34:20 | applies 53:17,22 | | affairs 14:6 55:20 | allows 82:15,17 | 148:25 149:4 | 103:22 | | 111:18 112:5 | 162:4 175:22 | 177:13 184:12 | apply 118:2 | | affect 184:19 | 89:7 125:3 amend | 8:5.23 answers | appointed 22:13 | | affidavit 48:25 | amended 125:19 | 130:20 | appreciate 35:4 | | 49.7 | amendment 60:7 | anticipate 47:16 | approach 22:20 | | affiliated 42:3 | amendments | 50:19 52:9 54:16 | appropriate 73:14 | | affiliations 4:13 | 55:21 112:6 | 55:6 59:25 61:19 | 113:8 114:7 153:9 | | 165:16 afternoon | amount 13:9 | 61:21 63:25 67:16 | 70:16 approval | | agent 90:291:7,20 | 81:22 96:5 118:12 | 76:4.24 79:21 | 62:10 approved | | 91:21,24 | 133:8,9 134:17 | 106:15 157:13,17 | 64:22 | | 153:12 166:4 ago | 137:25 138:12 | anticipated 60:5 | april 1:10 3:4,5 | | agree 3:14 59:12 | 159:11,15 183:17 | 60:11 62:9 68:15 | 137:22 159:5 | | 91:696:16 100:22 | amounts 51:22 | anticipates 78:16 | 188:19 | | 107:13,17 | 132:19 134:23 | anybody 83:24 | arbitration 171:4 | | agreed 143:8 | 138:4,9 156:14 | 145:16 | 12:11 22:12 areas | | 179:12 | analysis 68:6 83:4 | anymore 116:9 | 22:21 | | agreeing 179:9,25 | 84:3 87:19 89:18 | 142:11 164:15 | 19:4 arena | | agreement 55:13 | 92:25 95:2 96:19 | 161:15 anyone's | 170:8 argue | | 61:8 67:25 78:6 | 105:9 107:20 | 41:14 anytime | argument 117:21 | | 91:22 127:23,25 | 115:18 168:10 | 69:16 anyway | 144.6 | | 175:13 | 168:14 analyzed | anyway's 70:8 | aronsson 2:5 4:18 | | 128:8 agreements | 80:18 analyzing | 87:6 163:23 164:2 | 4:18 6:2,12 7:4,13 | | 128:16,18 | 82:4 | apartment 101:6.9 | 10:12 11:12 12:9 | | ahead 40:8 122:20 | andersen 17:9 | 102:6 114:17 | 26:20,25 27:13 | | aircraft 97:15 | 167:15 annoys | 115:2,7 146:21 | 29:18 32:11 34:21 | | 119:5 | 8:20 9:11 answer | 150:4 | 35:6 47:22 48:5 | | alive 114.5 | 9:19,21 24:21 | apologize 35:2 | 83:11 88:13 90:18 | | allegations 40:24 | 26:22,24 27:12 | 56:22 167:9 | 93:10,17 97:6 | | 81:5 156:7 alleged | 28:12 29:11,11,13 | apparently 28:19 | 99:22 103:5,6 | | alleging 83:18 | 29:17 36:11 38:17 | 174:21 | 111:2 128:22 | | alliance 2:3 4:20 | 53:16,21 54:12 | appear 100:20 | 129:7 130:5 131:2 | | 6:13 10:23 | 83:20 88:16 | appearance 4:16 | 131:5,9,23 139:18 | | allocated 141:16 | 101:20 104:18 | appearances 4:12 | 146:6 147:13 | | allocating 117:25 | 105:16 113:17 | applicability | 154:17 164:14 | | 145:11 allocation | 116:8,21 118:2 | 148:6,15 | 187:19,20,21 | | 152:3 | 119:6 120:5 | | |

[arrange - back]

| 163:15 arrange | 164:9 170:15,17 | 23:9 28:8 182:10 | 164:16 165:3 | |----------------------|----------------------|----------------------|----------------------| | arrangement | 170:19 171:5 | attorneys 2:3,9,13 | 166:12,22 170:12 | | 54:20 | 178:17,17 | 14:16 15:6,16 | 170:22 177:25 | | arrive 136:8 | assigned 74:24 | 25:8 32:3 40:21 | 184:24 | | arthur 17:9 | assist 52:18 86:17 | 46:23 47:6 98:9 | authored 26:13 | | articulated 143:22 | assistance 45:11 | 98:21,24 99:6,14 | 27.9 | | ascribe 144:2,15 | 55:18 61:9 73:16 | 104:24 106:20 | authorities 75:11 | | ascribed 118:17 | 80:17 82:8 84:23 | 109:23 142:3 | authorization 48:7 | | 141:25 149:24 | 85:18 86:6 88:21 | 147:3 178:3,3 | 48:19 49:3 | | ascribes 120:22 | 112:3 171:12,15 | attributed 138:4 | authorized 4:6 | | 121:7 | assisted 15:19 | audible 8:24 | automobiles | | ascribing 142:22 | 51:9,12 109:14 | audio 3:12,12 | 115:16,16 | | asia 2:3 4:20 6:14 | 112:10,11 113:3 | audit 75:13,18,20 | available 135.2 | | 10:23 | 141:4 | auditing 22:21 | 137:16 160:22 | | aside 15:22 47:5 | associated 66:20 | 149:22 aught | avoid 69:16 | | 67:7 83:17 161:9 | 117:2 | august 17:10 | avoidable 82:9 | | asked 36:8 47:19 | association 107.9 | aulet 2:10 5:3,3,12 | 83:2 84:13 171:17 | | 53:23 56:15,21,22 | 9:6 92:20 assume | 9:17 12:4,6,24 | aware 25:17 30:19 | | 64:20 110:7 | 92:24 173:18 | 13:6 24:20 26:16 | 88:6 90:8, 10 | | 151:21 152:19 | assumed 150:13 | 26:23 27:11,13,16 | 114:24 | | 172:25 178:6 | 153:15 154:3 | 28:7 29:19 34:10 | awful 47:11 | | asking 13:17,19,20 | assuming 28:15 | 37:16 39:5 46:20 | 168:23,24 | | 34:14 67:18 98:22 | 50:23 72:13 | 57:22 58:18 61:4 | awfully 88:4 | | 101:2,18,21 102:2 | 118:21 | 64:14 66:13 77:4 | awhile 82.9 | | 105:15 148:12,17 | assumption | 78:21 79:22 83:7 | b | | 149:12 151:4,5 | 143:10 | 83:13 84:25 85:8 | 2:65:21 6:5 7:5 0 | | 153:5 156:11,12 | attach 69:14 | 88:3,8,16 91:9 | 11:2,22 75:13,17 | | 156:13 162:22 | attached 79:16 | 92:2 93:5 95:9 | 76:2 94:17,20,21 | | 170:23 181:14 | 168:18 | 96:10 97:2 98:15 | 94:23 95:12 96:13 | | asks 108:11,17,18 | attachment 129.9 | 99:23 101:17 | 187-2 | | 113:14 115:13 | 129:21 130:8 | 102:8 103:24 | baby 19:25 | | 120:4 121:16 | 140:11 | 104:13 106:18 | babysitting 19:10 | | 122:11 151:14 | attempts 120:24 | 108:21 111:22 | bachelor 17:7 | | 166:9 aspects | 45:13 attend | 112:22 113:24 | back 7:18 11:19 | | assenting 37:9 | attended 45:14,16 | 118:4 122:18 | 13:20 27:6 29:24 | | assessment 101:14 | 47:11 | 126:3 127:7 129:4 | 34:3 41:5 49:13 | | assessments 153:7 | attending 4:11 | 129:25 130:16 | 55:12 69:25 71:16 | | asset 78:3 | 46:14 | 131:6,11 132:11 | 82:16 90:25 91:4 | | assets 88:2 94:2 | attention 105:20 | 133:18 141:18 | 95:17 103:7 | | 104:7 111:16 | attorney 2:17 4:17 | 148:20 149:7 | 111:23 112:13 | | 120:23 128:12 | 6:12 9:18 13:5 | 152:11 157:20 | | | | | | 114:4 127:11 |

**[back** - **bullet]**

| 131:7 140:4 159:7 | beach 122: 14 | 119:8 121:2 | bridgeport 1:3 | |----------------------|-------------------------|--------------------------|-----------------------| | 159:21 162: 10 | bearing 76:9,9 | big 34:4, 15, 16 | 2:143:21 | | 165: 12 167: 14 | bears 32: 15 140:8 | 35:20 52:23 | brief 90:22 | | 173:2 181: 15 | beast 42:18 | biggest 19:4 | briefly 14:21 | | background 17:2 | beautiful 164:20 | bill 45: 19 72: 12,23 | 65:24 128:5 | | 153:6 159:21,22 | beginning 4: 16 | 73:6 | bring 163:24 | | balance 69:20 | 180: 12 | billed 67:13,14,16 | broad 7:21 22:9 | | bank 37:25 52: 15 | behalf 12:23 21:7 | bills 19: 14 55:3 | broadly 109:5 | | 64:21,24 65:6 | 21:8 38:21108:11 | 72:3 122:4 146:24 | 115: 13 132:8 | | 69: 18 91:6, 16 | 108: 15 117:6 | binders 69: 14 | brought 40:3,20 | | 158:7 | 118: 14,23 130:24 | birnbaum 2: 17 | 167: 17 168:3, 19 | | bank's 91: 18 | 132:17 133:12 | bit 14:20 17:2 | brown 2:8 5:4 | | bankruptcies | 144: 10 145: 15 | 21:25 24:3 46:17 | 15:2123:10,16 | | 164:5 | 152:23 155: 17 | 139: 16 | 24:6,8, 18 25:8 | | bankruptcy 1:2 | 184: 11 | biweekly 66:25 | 26:5,6, 10 30:9 | | 3 :20 20: 11,22 | behest 182: 16 | blood 188: 15 | 31:20 32:3 38: 10 | | 21:13,24 22:6,11 | believe 24:4 45:2,5 | blue 131: 13 | 38: 12 39:2, 16 | | 32:25 38: 15 39: 19 | 50: 18 72: 14 99: 19 | bookkeepers | 43:23 49:24 56:13 | | 39:22 44:6,7,7 | 100:7 144:21 | 52:16 53:14,18,19 | 57:4 58:25 59:6 | | 51:2 64:25 74: 13 | 160: 12 162:21 | 53:20,25 66: 19 | 59: 10,17 64:20 | | 75:4 77: 15,24 | 167:4 175:7 | books 82:8 84: 12 | 83: 18 98:25 99:6 | | 80:4,13 81:2,23 | believes 27: 19 | 84: 14,18 92: 18 | 102: 11,17 103: 18 | | 82: 15 83:23 90:3 | belong 102:23 | 171:16,20 172:17 | 103: 18 104: 10, 16 | | 115:2 168:7,22 | 119:23 160:7 | boston 17:6,6 | 104: 17 105 :7, 12 | | 177:17 178:11 | belonged 101:15 | 18:16 | 106:6 109:24 | | base 59:9 | 102:6 103:14 | bottle 34:25 42:8 | 112: 14 123 :25 | | based 27: 16,21 | belonging 104:8 | 164:21 | 126:7,14 139:7 | | 28:23 63:5 72:25 | ben 13:5 14:16,21 | bottom 49:11 | 156:2 157: 15 | | 87: 14 158:5 159:2 | 24:5 | 105: 19 132:9 | 175:17 178:7 | | basic 129: 16 | beneficiary | 145: 19 162:3 | 181:3,5 | | basically 37:9 | 121:25 | bought 101:23 | buckets 19:3 | | 39:11155:13 | benefit 124:3 | 117: 18 | 21:19 155:14 | | basis 37: 14,21 | benefitting 149: 18 | box 2:14 | budget 61: 10,23 | | 66:25 69:7,8 | best 13 :2 28:9 52:4 | brain 93:8 | 61:24 62:2 | | 73:10 80:11 81:7 | 56:10 60:9,14 | break 9:9, 12 85:9 | budgeting 42: 10 | | 81:8,8 90:7 | 137:2 145:20 | 85: 15 139: 19 | 63:16 86:15 | | 123:12 143:9,23 | 184: 13 | breakdown | budgets 42: 13, 13 | | 145:9 | better 86:23 | 160:10 | build 78:2 | | bates 32: 15 35:9 | 103:25 171:14 | breakdowns | building 113: 16 | | 129:2 140:8 | beyond 14: 13 | 163: 19 | bullet 55:17 61:7 | | 147: 17 | 38: 18 53: 13 116:7 | | 92: 19 112:3 | | | | | |

[bullet - certain]

| 114:16 171:10 | 96:197:198:1 | callable 144:5 | 175:17 176:5 | |-------------------------|---------------------|-----------------------|---------------------------| | business 6:7 22:10 | 99:1 100:1 101:1 | called 5:21 20:18 | 177:3,6,18,23 | | 41:21,24,25 42:8 | 102:1 103:1 104:1 | 41:8 89:22 | 178:5,5,23 179:10 | | 42:11,22 43:3 | 105:1 106:1 107:1 | calling 145:7 | 179:13 182:12 | | 167:19 178:21,22 | 108:1 109:1 110:1 | calls 25:11.15 | cases 21:2.4 40:16 | | 184:20 | 111:1 112:1 113:1 | 58:24 93:6 143:15 | 41:25 64:10 90:5 | | businesses 19:5 | 114:1 115:1 116:1 | 178:23,25 181:19 | 92:8 161 :24 | | 162:7 button | 117:1 118:1 119:1 | 8:11 camera | 163:10 164:11 | | 117:23 buying | 120:1 121:1 122:1 | cancelled 158:7 | 166:7,18 169:14 | | C | 123:1 124:1 125:1 | capabilities 18:2 | 172:6 176:14 | | | 126:1 127:1 128:1 | capital 126:8,20 | 177:17 | | 2:2 3:1 4:1 5:1,21 C | 129:1 130:1 131:1 | 179:14,15,25 | 36:14 37:10 cash | | 6:17:18:19:1 | 132:1 133:1 134:1 | 116:3,17 117:9 car | 37:19 42:12,13 | | 10:1 11:1 12:1 | 135:1 136:1,7 | care 67:6 79:4 | 61:10 62:12,13,23 | | 13:1 14:1 15:1 | 137:1 138:1 139:1 | career 47:12 | 63:15,15,22 69:9,9 | | 16:1 17:1 18:1 | 140:1 141:1 142:1 | 97:14 117:19 cars | 69:21 78:18 79:2 | | 19:1 20:1 21:1 | 143:1 144:1 145:1 | 1:6 3:22 6:17 case | 79:3 86:18 87:13 | | 22:1 23:1 24:1 | 146:1 147:1 148:1 | 15:24 33:21 41:19 | 121:19,22,24 | | 25:1 26:1 27:1 | 149:1 150:1 151:1 | 41:22,23,24 42:19 | 152:21 157:5,10 | | 28:1 29:1 30:1 | 152:1 153:1 154:1 | 43:3,4 44:3,13,14 | 171:6 | | 31:1 32:1 33:1 | 155:1 156:1 157:1 | 48:10 49:15 50:22 | catch 88:25 89:2 | | 34:1 35:1 36:1 | 158:1 159:1 160:1 | 50:23 51:2,5,20 | 89:14,15 156:16 | | 37:1 38:1 39:1 | 161:1 162:1 163:1 | 52:10 54:17 55:8 | 7:21 | | 40:1 41:1 42:1 | 164:1 165:1 166:1 | 55:11,1656:10 | categories | | 43:1 44:1 45:1 | 167:1 168:1 169:1 | | 118:24 136:2,23 137:25 | | 46:1 47:1 48:1 | | 59:7 60:9,14 | | | 49:1 50:1 51:1 | 170:1 171:1 172:1 | 61:22 62:9,19 | categorization | | 52:1 53:1 54:1 | 173:1 174:1 175:1 | 64:2 66:5 67:4,17 | 137.9 | | 55:1 56:1 57:1 | 176:1 177:1 178:1 | 68:12,21 69:2 | categorized | | 58:1 59:1 60:1 | 179:1 180:1 181:1 | 70:4,7,9,11 71:5,6 | 155:24 | | 61:162:1663:1 | 182:1 183:1 184:1 | 71:19 73:11,25 | category 138:4 | | 64:1 65:1 66:1 | 185:1 186:2 188:2 | 74:2,7,11,19 75:9 | 89:12 cats | | 67:1 68:1 69:1 | 188:2 | 75:14,22 76:22 | caution 46:21 83:7 | | 70:1 71:1 72:1 | calculates 69:10 | 77:21 78:5,25 | 132:20 142:21 | | 73:1 74:1,9,10 | calculation 151:3 | 79:5 81:6 82:24 | caveat 89:3 | | 75:1 76:1 77:1 | calender 72:7 | 84:7 86:4.25 90:6 | 26:12 27:10 cc'd | | 78:1 79:1 80:1 | call 19:10 31:18 | 93:20 107:24 | cell 3:10 167:8 | | 81:1 82:1 83:1 | 45:18 79:11 102:4 | 111:5 131:24 | cellphone 176:10 | | 84:1 85:1 86:1 | 104:25 163:4.7.9 | 164:7 167:18,25 | cellular 3:8 | | 87:1 88:1 89:1 | 166:5,16 170:18 | 169:8,24 170:9 | 87:18 cents | | 90:1 91:1 92:1 | 178:3 | 172:10,10,13,15 | certain 40:17 94:3 | | 93:1 94:1,17 95:1 | | 172:15 173:12 | 113:22 174:6 | | | | | |

| certainly 22:3 | 158: 10 | clients 18:25 19: 13 | 70:23 156:6 157:3 | |------------------------|-------------------------|-------------------------|----------------------| | 62:20 72:20 84:3 | checked 64:24 | close 70:5 | 165:18 175:20 | | 91: 11 102: 14 | 141:5 | closure 75:15 | common 158:25 | | 106: 19 109:8 | checks 66:20 | clothes 103: 12 | communicate 26:9 | | 112: 10 124:7 | chinese 174:22 | club 122: 13 | 30: 11 57: 11 99:4 | | 140:25 166:8 | chooses 76:6 | code 75:480:13,14 | 99:5 | | certification 17:20 | cia 18: 13 | 82:15 | communicated | | 17:23 18:9 | cira 18:7,14,15 | cohn 2:17 | 58:16 98:24 | | certifications | circulate 32:4,8 | collateral 42: 14 | communicates | | 18: 12 | circulated 88:7 | colleague 45:5, 15 | 30:13 | | certified 17:23 | circumstances | 100:25 129:20 | communicating | | 18:4,6 165: 19 | 15:25 33: 13 60:6 | 146: 14 181: 18 | 104:19 | | 166: 15 | 73: 14 114:8 | colleagues 13 :7 | communications | | certify 186:4,8 | cite 164:7 | 30: 18 31:24 | 65:14,19 180:4 | | 188:8,13 | citizens 65 :6 | collect 13:13 177:9 | 181: 16 | | chain 32: 17 35: 11 | city 58:8 146:22 | college 17:6,6 | company 89:21 | | 38:6 103:21 104:9 | civil 11 :2 | 18:16 | 169:13 | | 129: 10 131: 15 | claim 52:20 80: 19 | column 136:7 | comparative | | 139:23 147:9 | 80:24 81:3,5,16,21 | combine 72:7 | 183:19 | | 151:14 187:6,7,11 | 168:13,16 | come 50:23 53: 14 | compare 110:6 | | 187:12,13,14 | claimed 125:5 | 54:2171:1674:18 | compared 110:6 | | change 146: 11 | claims 52:24 54:8 | 74:20 169: 14 | complete 69: 18 | | changed 139:4 | 81:7,10,12,25 82:5 | 172:6 173:14 | completely 74:5 | | 146:4 | 82:11,18 88:2 | 175:9,11 | 108:3 168:2 | | changes 43 :24 | 90:2 168:10,14 | comes 19:15 | compliance 42:24 | | 44:10 | 171:18 175:15 | 100:23 118:8 | complicated 43:4 | | changing 139:3 | clarification 96: 15 | 167:14 | 52:23 | | 144:22 153:8 | 97:3 | comfortable 176:4 | compound 139:2 | | chapter 1:5 21:2,3 | clarity 119:20 | coming 34:25 | comprehensive | | 55:3 70:3 74: 19 | cleaning 145:5, 15 | 62:23 78: 18 142:5 | 89:6 | | 81:6,6, 11 86: 10,22 | clear 24: 12 28: 18 | 162: 10 | computers 169:5 | | 86:24,25 115:3,4,8 | 39: 14 98: 10 | comley 2:12 5:7 | concerning 12:21 | | 164:4 166:7, 18 | 101:21 | 165: 17 | concerns 142:25 | | 167:5,18 169:23 | clearly 56: 18 79:2 | comment 36:21,21 | 144:11 | | 176: 17,20,22 | 141:3 | 37:8,8,9 | concluded 185: 10 | | charge 160:5 | clerical 55 :5, 7 | comments 112:25 | concludes 185:6 | | chart 136: 18 | client 4:23 5:2 | commercial 70:7 | conclusion 28:20 | | 137:14 153:3 | 30:8 34:5,6 35:21 | commission 157:9 | concurred 39: 11 | | check 73:3 110:18 | 36:23 37:6 38:3 | committee 2: 13 | concurring 37: 12 | | 134:23 138:8 | 39:8 | 5:8 20: 19 21:4,5 | 38:4 | | 152:21 158:7,10 | | 62:3 66:23 70:21 | |

**[condition** - **covered]**

| condition 9:25 | 119:18 121:11 | controller 169: 13 | 43: 14 62:3,4 | |-----------------------|-------------------------|------------------------|-----------------------| | condo 107: 10 | 124:5 125:23 | conversation 8: 17 | 70:21 97:12,18,20 | | confer 158: 10,25 | 128: 11 134:21 | conversations 3:8 | 98:12,14 99:19 | | confident 175:3,5 | 135:20 154: 19 | 27: 17 44:5 46:22 | 100: 17 124:8 | | confirm 65 :2 | 155:2 157: 18 | 47:6 102: 15,16 | 135:22 136:5 | | 86: 10,21 114:4 | conservative | converted 70: 12 | 141:3 158: 11 | | 136: 11 158:24 | 143:25 144:9 | copies 69: 18 | 169:19 171:14 | | 172:8 | 145:21 | copy 8: 14 94:22 | 172:2,14 180:11 | | confirmation | consider 157:22 | 100:21 158:7 | 180:14,24 181:4 | | 20:17 | 167:20 | copyrights 120:4,6 | 182:19 | | confirmed 70: 12 | consideration | 120:14,17 | counsel's 182: 16 | | 115:5 143:14 | 141:22 | corp 74:10 | count 118: 15 | | 154:4 | consistent 183:13 | corporate 74:7 | countries 42:6 | | conflicts 24: 12 | constituency | corporation 74:7 | country 42:22 | | confusion 69: 17 | 21: 11, 13 | 74:9, 10 75:23 | county 188:4 | | congress 19: 18 | consultation 98: 17 | correct 58: 19 | couple 60: 14 92:7 | | conjecture 122: 19 | 126:2 142:3 | 62:17 63:10 72:13 | 99:21 110: 13 | | connecticut 1 :2 | consulted 64:21 | 76:23 94:25 95:25 | 147:20 164: 18 | | 2:14,18 3:2117:5 | 138:18,18 | 97:23 102:25 | 176:23,23 | | 76:13,14,19 | consulting 88:21 | 107:25 108:25 | course 30:21 | | 113:20 148:5,14 | contact 25 :3 30: 19 | 109:2 114:12 | 52: 19 56: 16 62:8 | | 149:17 173:19 | 180: 13 | 121: 12 134:8,19 | 70:24 156:7,8 | | 176: 15 | contacted 23 :6,8 | 149: 15 152:20 | 169:22 181:7 | | connection 11:5 | contacts 25:4 | 153:21156:19 | courses 17: 15 | | 15:6 24: 19 33:21 | contained 59:22 | 171:20 174:25 | court 1:2 3:20 4:4 | | 34:8 36:4,9,25 | 71: 14 107:21 | 175:2 180:21 | 5:10,19 6:15,25 | | 39:2,18 43:2,25 | 136:24 163:19 | 186:9 | 8:1110:13 13:10 | | 46:3,10,18 50:14 | contention 28:3 | corrected 134:4 | 32: 12 35:6 40: 12 | | 50:25 51:6,20 | contents 101:8 | 134: 12 | 45:3 47:22 55:2 | | 57: 16 60:2 61: 15 | contested 6:23 | correctly 148:22 | 62: 10 78:9 87: 12 | | 61: 19 63:9 64: 12 | context 20: 12 22:6 | 149:4 | 93: 10 101: 10 | | 66:1168:15 73:19 | continue 3:1374:8 | cost 117:2,25 | 111:2 128 :22 | | 76:25 78: 17 80:21 | 74:16 130:6 | 118:10,13,18 | 131:19 147:13 | | 83:5,19 84:14,19 | continued 16: 16 | 141:25 142:6,22 | 171:13 175:21,22 | | 84:23 85:21 86:2 | 103:4 153:10 | 142:23 144:3 | 187: 15 | | 87:20 88: 15 89: 19 | 154: 16 | 145:3 | cover 16:25 107:3 | | 92: 15 96:20 97: 11 | continues 68:21 | costly 89:6 | 128:13 | | 97: 16 98:6,22 | 150:2,24 | costs 144:4 | covered 13: 11 | | 103:8 104:7 106:3 | continuing 17: 17 | counsel 4: 10 5:4,7 | 76:20 83:14 85:19 | | 107:23 109: 11 | 137:20 | 9:12,2113:6,15 | 89:8 103:9 119:17 | | 110: 11 112:21 | | 25:21,24 30:3 | 154: 18 | | | | | |

[cpe - description]

| 17:15,16 сре | 147:11 | 120:22 121:7 | deducting 79:21 | |-----------------------|----------------------|--------------------|------------------------| | craig 1:14 3:17 6:5 | dated 127:24 | 122:8,17 124:18 | deferred 78:3 | | 48:25 151:4 185:7 | daughter 141:23 | 125:3,5,12,18 | defers ી રેરે ને તે | | 186:15 | 143:2 | 126:23 130:25 | define 82:19 | | 161:25 crazy | david 2:64:21 | 132:17 133:13 | definition 72:5 | | create 72:23 157:6 | 100:4 103:9 | 141:5 142:5,21,23 | 101:5 | | 86:13 created | day 39:9 44:24 | 143:5,12,15 144:3 | degree 17:7 18:16 | | 133:22 | 45:14,16 46:24 | 145:18 147:2 | 45:13 179:5 | | creator 141:19,20 | 47:8 51:13,14,15 | 148:13 150:14.18 | 18:19 degrees | | creditor 42:15 | 52:4,4 63:16 | 152:24 155:15 | delaware 176:14 | | 47:14 81:5,13,16 | 132:18 155:17 | 156:6,23 167:6 | 14:19 delayed | | creditor's 2:13 5:8 | 169:21 182:22,23 | 168:5,25 169:19 | department 19:22 | | 165:17 | 185:2 186:19 | 171:16 172:2,14 | 19:22 20:7 22:2 | | creditors 20:19,19 | 188:19 | 172:19 174:12.19 | 64:23 | | 21:9 67:2 86:16 | days 14:25 72:11 | 178:14 180:11,14 | depend 52:11 | | 86:23 171:6 | 75:12,19,21 82:17 | 180:16,24 181:4 | depending 42:8 | | 52:7 crises | 82:21 83:22 92:23 | 183:3 184:11 | 51:23 78:24 79:4 | | 138.8 cross | 145:4 183:22,24 | debtor's 38:23 | 158:19 | | crosschecked | deadline 81:10,13 | 47:25 48:18 49:2 | depends 78:18 | | 136:22 | deal 80:6 | 58:9,11,13 62:4,18 | 168:12 171:25 | | cumulative 69:7 | 167:22,23,24 debt | 63:4 74:20 79:8 | depicted 136:24 | | 134:17,18 | debtor 1:7 5:5 | 79:20 87:15,25 | deposition 1:14 | | 88:14 curious | 16:9,13,15,20,23 | 106:15 108:10,19 | 3:12,17,23 6:22,25 | | 88:17 current | 20:11 21:5,6 | 108:22 111:16 | 7:6 10:16,24 | | 118:20 | 25:16,22 36:15 | 123:20 141:23 | 11:22 13:4,21 | | currently 18:21 | 37:11,20,25 38:3,9 | 144:10 164:9 | 14:23 15:7,17 | | 88:7 122:9 134:16 | 38:22 39:15 42:16 | 166:9,19 167:15 | 16:5,10,11 27:25 | | 171:21 | 45:13 52:14,25 | 171:20 172:16 | 28:20 41:12 45:23 | | 155:6,10 cycle | 54:19,25 57:10,10 | 175:19 187:8 | 49:21 137:20 | | d | 57:12 58:16 62:15 | debtors 20:18 42:4 | 187.5 | | て 81:14 109:22 | 70:22,22 76:6,8,12 | 48:6 | depositions 40:14 | | 128:3 186:2 | 76:21 77:3 78:19 | december 74:24 | 42:9 deposits | | 187:17 | 79:23,25 80:4 | 77:7 161:18 | describe 46:17 | | 162:5,7 data | 82:8 84:12,14 | 103:10 decide | 58:20 155:8 | | date 1:10,16 10:18 | 88:23 94:4 101:8 | decision 37:12 | described 70:14 | | 32:19 35:13 44:20 | 101:11,16 108:16 | 39:12 87:14 | 103:21 104:10 | | 48:4 67:19,20 | 111:18 113:18 | 102:13 141:4 | 128:5 136:2 | | 71:4 75:12 86:3 | 114:3 115:15,21 | declaration 62:19 | 142:10 169:25 | | 87:20 93:15 111:9 | 116:5,6,10,12 | declared 40:18 | description 114:7 | | 129:12 131:17 | 117:7 118:5,14,16 | deductible 78:2 | 138:11 187:4 | | 137:15 139:25 | 118:24 120:15,16 | 79:2,7 | | | | | | |

**[descriptions** - **due]**

| descriptions | 70: 16,25 91 :6,8 | 106:10,21126:11 | 109:7, 12 129:5,8 | |-----------------------|------------------------|------------------------|-----------------------| | 136:10 | 92: 11, 15 | 139:13 143:13 | 182:25 | | designated 12:2,7 | direct 29: 10, 16 | 155:22 165: 10 | dog 103: 13 | | designation | 105:20 130:2 | discussions 43: 13 | dogs 89:12 | | 165:23,25 | directed 28: 10 | 43: 15 106:5 | doing 7: 18 22: 18 | | detail 145:8 | 88:23 182:3 | 113:11137:21 | 51:8 60:2 61: 19 | | 160: 19,23 | directly 104: 15 | dismissed 70: 12 | 61:2178:1788:17 | | detailed 27: 15 | 143:11 | disparity 164:8 | 91:16 157:17 | | 160:10,13 | director 51 :4,4 | displayed 161:4 | 162: 13 176:6 | | details 135:24 | disagree 81: 17, 19 | dispute 28:3 29: 19 | 182:13 | | 163:6,18 | 170:3,4 | 29:20 130:6 | doj 161: 10 | | determination | disbursed 155: 16 | distinct 74:5, 14 | dollar 154:14 | | 38:5 39:3, 12 | disbursement 62:9 | distribution 136:8 | dollars 96:5 | | 87:17 101:10 | 72:5 117:17 | 136:14 138:13 | 125: 15 126:8 | | 137:5 | disbursements | distributions | 132:21,22 133:23 | | determine 87: 13 | 52: 17 54:4, 15, 16 | 139:6 | 133:24 146:20 | | 156:3 | 54:24 63: 16,20 | district 1 :2 3 :20 | 154: 12 159: 16, 16 | | determined 72:25 | 67:2 68:22 73:2 | divided 141: 13 | 159: 18 164: 12 | | determining | 77:14 86:19 91:14 | division 1 :3 3 :21 | 177:2 183 :24,25 | | 178: 15 | 91: 15 92: 15 137:8 | docket 48: 10 | double 73:2 | | develop 67:5 | 157: 10 184: 16 | 93: 19 97:7 100:20 | 110: 18 134:23 | | developed 183:20 | disclaimers | 111:6 131:24 | doubt 114:20 | | developing 87:24 | 111: 15 | document 10:20 | draft 88:7 98: 14 | | development 86:7 | disclose 46:21 | 32:14,15 33:3 | 107:23 114: 19,20 | | difference 38:8 | 83:9,16 | 35:9, 16 48:6, 12, 15 | 126:13 130:15 | | 41:23 108:6 | disclosed 84:6 | 48:23,24 55:12 | 136:17 140:24 | | different 41:21 | 161:4,5 | 93:18,21 94:11 | 141: 16 142: 15 | | 42:18 51:22 52:2 | disclosing 29:7 | 96:25 100:20 | drafted 31: 19 | | 77:21 80:5 108:2 | 118:22 182: 14 | 101: 19 105: 19 | 43:11,16 112:25 | | 108:3,16 144:18 | disclosure 68 :25 | 107:21 109:4 | drafter 13 8: 17 | | differing 51 :22 | discovery 40: 13 | 111:5, 11 112:9,21 | drafting 31 :22 | | difilippo 2:22 4:2 | discreet 89:4 | 127: 18 128:25 | 46:2,5 98: 13 | | digit 110:15,15 | discuss 8: 13 | 131 :24,25 135: 10 | 103:10 105:22 | | digital 120: 19 | 147: 19 | 140:9 141:21 | 112: 11 124:5 | | diligence 179:8 | discussed 85 :23 | 146:10 147:16,19 | drafts 32:4 62:21 | | dip 14:9 28:24 | 94:5 98:20 106: 19 | 147:21 154:22 | driving 161:24 | | 54:20 61:22 62: 14 | 127: 15 130:4 | 155:3 | 172:13,14 | | 63:19,23 64:2,4,10 | 143:7 | documents 13:9 | drop 41:10 | | 64:16 65:3,11,15 | discussing 132:3 | 13: 13,16,17,23 | due 44:23 45:7 | | 65: 19,22,24 66:3,6 | discussion 11: 17 | 27:22 57:8,15,16 | 55:3 69: 11 70: 19 | | 66: 15 68:2,20 | 15:24 99: 15 | 57:20 105:11 | 75:7 81:22 179:8 | | | | | |

[dues - exactly]

| dues 107:10 | effectuating 63:20 | engagement 23:5 | essentially 61:2 | |---------------------|-----------------------|----------------------|----------------------| | 5:22 186:5 duly | 91:14 | 23:7 24:2,10,19 | 158:14 | | 188:10 | efficient 23:8 | 25:6 26:4,11 | 62.2 establish | | duties 41:20 43:2 | efficiently 52:5 | 30:12,14 31:16,22 | 81:21 156:17 | | 43:20,21 50:24 | eight 166:3 | 32:5 34:9 36:5,9 | established 74:13 | | 55:691:25 93:4 | either 42:17 81:5 | 40:5 43:12 44:2 | estate 42:20 53:4 | | e | 101:9 103:16 | 45:2 46:3,5 50:15 | 54:21 62:25 68:25 | | 2:2,2 5:21 6:5 e | 104:22 110:17 | 51:25 52:2 55:15 | 70:24 73:17 74:3 | | | elapsed 39:11 | 55:16 84:15,19 | 74:14.14.18.21.23 | | 13:11,23 14:2,4 | elect 74:25 75:2,13 | 171:10 180:2 | 74:23 76:9,10,14 | | 15:20 26:9,13,13 | 75:18 | engagements | 77:20,24 78:19 | | 27:9,10 30:19 | election 19:18 | 166:17 177:16 | 79:24 80:4,7,8,10 | | 32:17 34:3 35:11 | electricity 107:11 | english 127:13 | 81:23 83:3 94:22 | | 35:19 37:18 38:6 | 15:19 electronic | 174:21 | 107:6 113:19.22 | | 39:7.9 41:17 | electronics 100:24 | ensure 73:12 | 114:4 147:6 157:2 | | 49:22 59:11 81:14 | 119:17 | 136:23 | 175:9,11 181:10 | | 99:19 104:23,24 | eliminate 131:13 | entire 79:14,14,18 | estate's 87:25 | | 106:9 112:24 | 150.21 | entirely 79:6 | estates 74:4 | | 117:5 129:9,10,15 | eliminated 150:20 | 138:23 139:6 | estimate 105:21 | | 129:17,24 130:11 | 150:22 | 157:10 172:9 | estimated 71:13 | | 131:15 132:22 | emphatically | entities 42:3 | 106:12 | | 139:23 141:2 | 181:2 183:7 | 179:19 | 73:11 estimates | | 147:9 151 : 13 | empirical 154:9 | entitled 1:16 48:6 | estimating 73:7 | | 152:9 155:16,25 | employ 14:8 38:21 | entity 74:5 103:15 | 97:14 etcetera | | 160:18 162:19 | 48:8,19 49:3 | 114:24 119:25 | 120:5 | | 163:8 169:4 | 90:11,17 168:6 | 126:22 154:14 | evaluation 114:13 | | 173:15 180:8,10 | employed 18:21 | 183:10,10 184:4 | 68:2 event | | 180:19,22 181:21 | 36:15 37:11,20 | entries 148:7,16 | 103:21 events | | 181:25 182:2,4 | 38:9,11,16 90:14 | equitable 113:15 | 104:10 | | 186:2 187:2,6,7,11 | 91:25 | erroneous 125:23 | everybody 60:21 | | 187:12,13,14,17 | employee 28:17 | 159:11 | 75:9 93:7 156:8 | | 188:2,2 | employees 28:22 | erroneously 125:5 | 175:18 | | earlier 68:10 94:5 | 29:2,5 42:5,23 | 125:14 | everybody's 45:2 | | 100:7 | 50:20 182:11 | error | 69:8 | | easy 73:2 | employment 38:14 | 161:7 184:13 | everyone's 46:2 | | edits 135:15,16 | 89:7,8 | 136:4 errors | 147:3 162:15 | | 140:23 | endeavor 124:10 | 91:7,20,21 escrow | evidence 87:11 | | educated 155:22 | 183:23 ended | 91:22,24 | exactly 53:7 58:9 | | education 17:18 | engaged 20:11,15 | esq 2:5,6,6,10,15 | 115:4 117:4 | | educational 17:3 | 20:16 24:23 166:6 | 2:19 | 130:22 159:13 | | effectively 38:4 | 179:10 | | 181.25 | | | | | |

| examination 5:25 | expectation | 27:21 expose | fear 28:5,6 | |-----------------------|-----------------------|--------------------------|---------------------| | 100:2 103:4 | 106:22 | extent 22:12 60:5 | feasibility 86:8 | | 153:10 154:16 | 33:5,13 expected | 65:4 78:3 83:8 | 87:3,7,9 | | 165:14 185:9 | 123:20 | 113:6 137:12 | feasible 87:16 | | 187:18 188:9,11 | 136:18 expense | 143:17,18 146:23 | february 45:8 | | examined 5:24 | ી રેજેઃ 8 | 100:21 extra | 63:14 69:3 72:9,9 | | 101:3 example | expenses 71:13 | 110:15 162:10 | 77:6 122:22 125:4 | | 109:3 163:20 excel | 72:4 77:15,17,18 | f | 129:22 132:17 | | 169:2 excess | 78:23,25 79:7 | し | 133:11,12,25 | | exchanges 181:25 | 105:22 106:12,16 | 81:14 109:17,18 188.2 | 134:3 140:14,14 | | 160:4 excluded | 106:23,23 107:2,3 | fa 41:19 | 152:22,23 154:21 | | excluding 125:21 | 107:9,15 108:10 | face 102:24 | 154:21 155:10,11 | | 11:10 excuse | 108: 15,20,23 | fact 115:25 182:21 | 156:15,17 159:9,9 | | 51:14 123:16 | 117:6 123:2 | 15:24 60:5 facts | 159:19,23 160:7 | | 126:12 137:22 | 124:11 129:22 | 99:10,13 113:9 | federal 11:2 19:17 | | 153:14 174:23 | 130:9 133:5,15 | 114:8 146:15 | 19:18 73:17 76:12 | | exhibit 7:7 10:14 | 134:10 136:24 | 147.4 | 79:14.16.18 | | 10:17 32:14,18,21 | 140:13 147:7 | factually 150:15 | fee 73:13 123:3 | | 35:8,12 41:6 43:6 | 148:7,16 149:17 | fair 42:25 53:16 | 157:7,8,9 | | 47:24 48:3 91:4 | 149:24 152:21 | 59:20,23 60:22 | feel 48:11 67:3 | | 93:12,14 111:4,8 | 183:4,11,12,22 | 72:16 78:15 84:21 | feeling 41:18 | | 128:24 129:11 | 184:5 | 88:24 94:19 96:9 | 142:2 178:22 | | 131:7,16,21 | experience 7:21 | 97:19 103:20 | fees 33:18 53:9 | | 133:16 134:7 | 20:24,25 64:4,7 | 104:6 106:13 | 54:24 62:6 68:2 | | 135:11,14,18 | 82:3 164:4,6 | 130:13 134:20 | 69:8,11 70:21 | | 136:18 139:24 | 177:16 | 136:21 145:12 | 72:24 77:18,25 | | 140:7 141:17 | expert 22:19,19 | 160:9 | 156:4,24 163:3 | | 142:15 144:14 | 40:11,19 41:2 | 44:8 fairly | 175:4,8 | | 147:10,15 159:7 | 91:12 165:20 | familiar 7:23 | 132:24 felt | | 182:6 187:3,3,5,6 | 166:16 | 12:10 89:21 | fiduciaries 20:17 | | 187:7,8,9,10,11,12 | expertise 166:6,17 | family 19:15 58:8 | figure 136:5 | | 187:13,14 | expired 69:15 | 103:13 118:9 | 155:19 | | exhibits 187:3, 15 | explain 36:24 | 129:8 132:16 | figured 160:23 | | existed 101:23 | 41:22 70:2 82:13 | 143:18 | 162:16 | | 179:12 | 108:5 132:8 148:6 | far 6:21 67:14 | file 29:5 38:15,20 | | existence 57:7 | 150:8 159:12 | 171:21 173:12 | 40:11 52:25 53:3 | | 143:17 | explained 37:15 | 139:17 fast | 74:8,16 75:6 76:6 | | 172.7 exists | explanation | father 118:18 | 76:11,11,16 77:23 | | expect 51:7.19 | 144:15 | 143:20 | 78:14 81:5,7,16,20 | | 175:16 | explicit 66:2 | fault 73:8 | 89:6 137:22 | | | | | 163:11 175:21 |

[filed - francis]

| filed 3:19 13:9 | 179:6,18 | 62:23 87:13 flows | 112:22 113:24 | |-----------------------|---------------------|----------------------|-----------------------| | 28:24 42:7,8,9 | 4:8 financially | fluid 104:20 | 118:4 122:18 | | 45:3 48:10 49:7 | 87:16 | 13:730:18 flynn | 125:3,14,16 126:3 | | 55:22 62:19 63:14 | financing 14:10 | 45:6,16 49:15,16 | 127:7 130:16 | | 68:12 69:23 75:8 | 28:25 54:20 | 50:5 56:4,24 | 132:11 133:18,22 | | 75:24 76:5 84:4 | find 40:10 117:25 | 112:17 129:18,19 | 134:15 135:3 | | 93:19 100:10 | 156:18 | 149:15,19 150:2 | 141:18 148:20 | | 111:5 122:22 | finish 8:19 | 150:24 151:11,14 | 149:7 152:11 | | 125:4.14.18 | finished 54:11 | 181:18 | 156:13 157:20 | | 131:24 135:3 | 4:3,5 21:24 firm | flynn's 46:10 50:7 | 166:12,22 170:12 | | 160:21 161:23 | 22:13 24:16 39:18 | 151:8 | 170:22 177:25 | | 167:4 168:16 | 40:3,25 51:5 | 44:20 focused | 187:9 | | 181:12 | 52:15 56:2,15 | 46:6 focusing | forms 98:16 | | 80:10 files | 112:15 139:14,14 | 108:18 | forth 101:7 112:13 | | filing 32:24 61:11 | 156:2 172:13 | 15:15 25:6 folks | 188:10 | | 63:12 73:23 75:12 | 176:9 | 29:24 30:10,14 | forward 63:17 | | 82:17 92:23 96:9 | firms 62:7 134:7 | 49:14,24 129:21 | 68:17 69:6 75:14 | | 96:12 98:23 | first 5:22 16:18 | follow 164:18 | 108:13 134:19 | | 113:23 132:3,6,18 | 19:3 21:23 43:16 | following 44:25,25 | 157:4 163:3 | | 138:2 | 43:22 44:6,9,21,24 | 148:7,15 | 133:22 found | | filings 56:7 73:18 | 45:14,25 46:24 | follows 5:24 | 145:3 146:14,18 | | final 62:22 87:17 | 47:8 51:13,14,14 | food 119:3 | 150:15,17 182:24 | | 133:15.24 135:17 | 51:15 55:17,18 | fool 178:19 | four 15:12 19:2.3 | | 135:21 136:3 | 69:23 73:9 75:19 | foregoing 186:8 | 19:23 21:18 82:23 | | 137:24 140:12,20 | 89:3 93:25 94:14 | foreseeable 124:22 | 161:22 165:25 | | 140:22 141:4 | 105:3 112:3 | forget 102:19 | foxboro 6:9 | | 144:8 159:8 | 122:21 129:23 | forgot 11:10 | frame 34.75 | | 183:21,21 | 130:25 139:10 | form 22:16 34:10 | 118:23 146:23 | | finally 46:13 | 149:14 161:13,14 | 37:16 39:5 54:5 | 154:5 | | 162:16 | 162:3 180:9 186:5 | 57:22 58:18 62:10 | francis 25:18,23 | | finances 61:12 | 89:13 fit | 64:14 66:13 72:6 | 26:2,10 30:2,6,7 | | 63:12,15 | fitting 101:4 | 72:21 77:4 78:21 | 31:4,8 32:9 56:17 | | financial 14:5 21:4 | five 39:10 128:2 | 80:25,25 81:2,3 | 57:3 59:3,5,18 | | 21:6 22:15 34:7 | 128:15 141:8 | 84:25 88:3 91:9 | 99:2,7 102:11,20 | | 36:23 37:6 39:8 | 161:22 | 92:2 93:5,13 94:2 | 102:21 103:17 | | 40:20 41:20 42:25 | 161:7 184:13 fix | 94:21 95:9 96:10 | 104:12,15 105:4 | | 48:9.20 49:4 54:6 | flavors 17:15 | 98:13,14,15,19 | 105.14 106.7 | | 55:20 62:4,5 | floor 2:4 | 102:8 103:24 | 109:25 112:15 | | 64:22 111:17 | 61:10 62:13 flow | 104:13 106:18 | 124:2 129:19 | | 112:5 166:10,19 | 62:13 69:21 86:18 | 108:21 109:15 | 135:23 139:8 | | 168:3 178:14 | | 110:20 111:22 | 143:13 148:4,12 | | | | | |

PAX-014-061

### [francis - hampshire]

| 152:9,13 156:3 | general 88:21 | god 47:14 | golden 2:17 5:16 | |-------------------------|-----------------------|--------------------|--------------------| | 157:16 180:9,18 | 100:15 155:8 | 7:18 43:19 goes | 26:18 27:17,18 | | frankly 33:12 | 163:9 | 79:5 101:6 124:18 | 28:7,10,14,17,23 | | 150:12 | generally 13:25 | 156:22 | 29:6 57:23 58:3 | | fraudulent 82:10 | 18:24 21:19 22:8 | going 3:3 10:13 | 179:6,9,12,24 | | 82:20 171:18 | 24:2 25:5 36:24 | 32:12 35:7,8 | 180:5,6,7,10,15,20 | | free 48:11 | 44:12 50:24 55:2 | 36:14 37:5,10,19 | 181:16,20 182:9 | | frequently 39:20 | 55:14 57:4 66:3 | 37:24 39:15 40:8 | 182:15,19,19 | | 40:2,5 42:15 | 66:23 70:2 73:8 | 40:10,10 41:9 | 183:4,8 184:6 | | 64:25 73:5 | 74:24 80:23 82:14 | 44:9 45:5,20 47:3 | goldman 2:15 5:6 | | front 15:9 44:18 | 90:12 109:10 | 47:23 52:3,12,22 | 5:66:20 7:10 27:3 | | 162:23 180:23 | 110:10 115:6 | 53:7,13 54:2,3,7,8 | 28:4 29:8 85:14 | | 163:24 firel | 49:23 getting | 54:9 59:2 68:17 | 164:17,23,24 | | full 19:8 73:10 | 86:23 135:20 | 68:18,19,21 69:5,6 | 165:15,16 184:22 | | fully 12:20 | 137:21 176:4,8 | 69:24 70:19 73:23 | 185:3 187:21 | | function 87:24 | 179:21 | 76:8,18,19 77:6,9 | golf 123:4 | | fund 2:4 4:20 6:14 | gettr 120:21 | 78:22,23 80:5,15 | good 3:26:10 44:8 | | 10:24 | give 10:6 14:25 | 85:8,14 87:2,3 | 165:16 | | funding 127:23 | 147:24 152:20 | 89:5 91:18 92:20 | goods 100:25 | | 128:17 184:5 | 153:2 161:6 | 92:23 93:8,11 | 119:16,19 | | funds 70:17 | 164:25 | 96:24 106:24 | graduate 18:18,19 | | 108:12 130:23 | given 105:14 | 107:12,18 108:13 | graduated 17:4,6 | | 138:12 155:16 | 131:22 134:25 | 111:3 115:4 | gratuitous 37:7,8 | | 175:23 | 182:11 185:6 | 118:22 123:9,10 | great 164:8 | | furnishings | 186:10 188:12 | 123:13,23 124:12 | greenwich 113:20 | | 100:25 | 75:11 gives | 124:13,14,17 | 123:9,14 150:13 | | further 163:5 | glasses 11:11 | 128:23 129:15,23 | 152:16 153:16,24 | | 184:23 186:8 | 14:6.7 global | 131:19 134:19 | group 26:14 113:3 | | 188:13 | 51:10,11 111:7,14 | 139:15,16 143:6 | 143:7 144:8 153:8 | | future 69:23 78:4 | 111:24 187:10 | 147:14 149:2 | 120:20 gtv | | 78:5,8,12,20 85:3 | go 3:14 7:22 11:12 | 151:22 155:18,18 | guess 15:8,12 19:3 | | 86:19 87:13 | 28:2 38:12,13 | 155:19,20 156:15 | 77:5 127:2,3,6 | | 124:22 157:18 | 40:13 44:17 53:6 | 156:16,18 157:22 | 149:8 | | g | 54:19 90:18 | 157:22,24 158:2,6 | guessing 66:8 | | 5:21 | 103:25 107:5 | 158:12,21,23 | guidance 161:6 | | g garbage 61:3,3,5,6 | 111:23 114:4 | 159:3 161:5 163:3 | 170:24 guy | | 107:12 gas | 122:3,20 124:18 | 163:14 168:21 | h | | gasoline 117:9 | 139:15,16,19 | 169:16,18 170:25 | 23:16 187:2 h | | gathered 29:4 | 144:7 156:21,22 | 171:5,11 175:10 | half 93:7 | | 123:17 | 164:21 176:25 | 175:23,25 177:8 | hampshire 176:16 | | | 183:20 | 181 · 9 | 176:24 | | | | | |

[hand - increase]

| hand 27:24 32:12 | 174:15 | hoping 148:25 | 116:25 117:18 | |-------------------|------------------------|-------------------|-------------------| | 34:22 47:23 93:11 | 46:15 hearings | 149:3 175:6 177:8 | 118:9 123:2,5 | | 110:9 111:3 | 51:13 | hospital 122:4 | 173:13 | | 117:21 128:23 | heat 107:11 | 59:12 hot | immediately 44:25 | | 130:22 131:20 | held 1:17 3:23 | 114:17 hotel | impair 9:25 | | 146:7 188:19 | 11:17 23:2 165:10 | 15:13 hour | important 8:18 | | handing 147:14 | help 24:13 46:7 | 15:11,11 hours | 75:3 132:24 168:6 | | happen 47:13 52:3 | 57:7 137:4 | 39:10 67:21 | 172:11 174:7 | | 52:12 69:3 89:12 | helped 137:9 | 164:19 166:2 | inadvertent 133:6 | | 89:13 162:17 | helpful 14:14 | 101:25 house | 134:6,22 | | happens 80:3 | 38:25 137:4 138:8 | 149:17 | inadvertently | | 81:15 82:22 | helping 100:9 | household 97:25 | 125:12 132:16 | | 178:11,12 | 169:11 helps | 100:24 101:4,15 | 133:21 134:2 | | harassed 143:15 | herein before | 102:5 119:16,19 | inappropriate | | harassment 27:21 | 186:11 188:10 | housekeeping | 29:9,16 | | 28:5,6 | 188:18 hereunto | 144:20,23 | include 22:18 | | harbach 2:6 4:21 | 163:14,24 hey | 8:25 huh | 80:11 94:16 | | 4:21 23:12 41:13 | high 17:3,5 19:10 | human 110:21 | 107:14 122:15 | | 59:13 85:16 99:20 | 19:24 94:14 | hundred 64:9 | included 65:14 | | 99:25 100:3.5 | hill - 179:24 180:5 | 138:21 139:4 | 125:15 132:23 | | 103:2 147:24 | hire 80:5 | 141:13 142:22 | 133:19 134:2,5,13 | | 152:5 153:11 | hired 90:5 | 143:6,24 144:2 | 134:23 137:14 | | 165:6 180:6 | hiring 40:25 | 146:20 168:15 | 150:25 151:25 | | 187:19,20 | history 17:3 | husband 141:12 | 159:11,17 160:11 | | hard - 127:12 | hit 162:7 | 142:8 145:14 | includes 19:6 | | haven 2:18 116:2 | hits 73:7 | i | 61:23 62:12 | | 116:15 | 1:5 2:9 3:18 5:5 ho | idea 7:19 44:8 | including 39:22 | | hazard 15:8 | 11:6 94:4 111:18 | 67:23 90:17 | 40:14 61:11 70:24 | | hch 152:22 | hold 18:11,18 | 126:24 151:20 | 86:7 115:16 | | head 8:24 155:4 | 36:14 37:10,19 | identification | inclusion 125:24 | | heading 11:22 | holding 114:25 | 10:17 32:19 35:13 | income 52:25 53:3 | | health 121:18,22 | home 6:7 107:8,9 | 48:3 93:15 111:9 | 53:5 62:15 63:5,9 | | 121:24 122:2,8 | 118: 19,25 | 129:12 131:17 | 73:17,24 74:16,17 | | hear 127:13 | homeowner's | 139:25 147:11 | 74:20 76:15,17,22 | | 171:14 | 154:10 | identified 7:12 | 77:8,11,12 78:8 | | heard 45:24 82:21 | homeowners | 103:22 104:8 | 79:20 87:25 125:5 | | 104:15 127:15,17 | 107:7 | 134:7 181:23 | 125:16,21 | | 182:9 | homes 119:5 154:8 | identity 26:18 | incorrect 125:18 | | hearing 45:17 | honestly 12:21 | 27:23 28:16 74:8 | increase 141:8 | | 46:14 47:9 51:15 | hope 64:3 100:22 | imagine 54:18 | 142:12,17 145:24 | | 123:18,19 127:18 | 159:4 171:2 | 61.75 66.72 | |

**[increased** - **issues]**

| increased 142: 14 | 139:7, 12 145:2 | 122:2,8 146:4,12 | investigated | |-----------------------|-----------------------|------------------------|------------------------| | 144: 13 | 146:10 152:10 | 146: 19 148:8,17 | 101:22 110: 11,24 | | increasing 141: 10 | 153:3 155:13,14 | 150:3,4, 11, 12, 16 | investigation 40:7 | | 143:23 145: 10 | 156:20 157: 14 | 150: 17 152: 15 | 40:9,22 59: 16 | | incurred 142:6 | 158:20 174:4 | 153:24 154:7,10 | 63:8 95:7 97:22 | | 177:7 | 176:3 177:22 | 158:21,22 | 102:9 108:24 | | independent 63:8 | 183:19,19 184:9 | intellectual 120:7 | 115:6,18 119:14 | | 95:6 97:21114:10 | informed 44:2 | 120:13,15,18 | 119:22 128:11 | | 119: 13 122:5 | 99:13 103:16,18 | intend 171:24 | 157: 18 158:9 | | 123: 19 128:7 | 103: 19 104: 16 | intended 32:25 | 179:15 183:15 | | 152: 10 | 180: 11 | 34: 19 40:4,6 62:7 | investigations | | indicate 7:2 | informs 127:5 | 89: 15 110:20 | 114:11 | | indicating 135: 12 | initial 140:23 | 125:19 | investment 177:4 | | 137: 18 152:6 | 141:20,21 | interact 16:23 | 177:6 | | 161:19 162:11 | initiated 25: 12 | 22:3 | invoice 158:8 | | individual 21:8 | input 43 :21 59:6 | interaction 146: 17 | involved 20:7 | | 24:15 41:2,19,23 | 72:22 114:22 | interactions 15:2 | 31:2149:15,17,20 | | 43:4 70:4 74:3,4,6 | inputting 162:4 | interest 20:22 | 50:2152:2453:4 | | 74: 15, 15, 16, 17 | inquire 153 :23 | 53: 11 77:20 80:3 | 55:24 56:6,20 | | 75:23 77:2, 19 | inquiries 51: 16 | 87:12 113:16 | 57:24 59:7 65: 10 | | 164:4,11 183:23 | inquiry 161:9 | 119: 10 120:7,18 | 65: 18 90:9 100:8 | | individual's 27:20 | 163:16 | 121: 16 147:5 | 101:13 105:22 | | individually 79:24 | insiders 82: 19 | interested 4:9 | 109:6,9 132:4 | | individuals 19:5 | insolvency 17:24 | 22:15 41:17 49:10 | 178:7 179:21 | | 42: 19 57:8 85:5 | 18:5,6 19:4 21:24 | 151:3 178:4 | involvement 115:9 | | 158: 16 | 165: 19 166: 16 | 188: 16 | iphone 103:11 | | industry 60:17,21 | instance 62:3 89:9 | interests 101: 11 | irrespective 70: 19 | | inform 124:3 | 138: 15 | 115:13 | irs 76:19 89:10 | | information 12:20 | instances 40: 19 | interfere 3:1110:5 | irve 2:15 5:6 | | 22: 16 24: 16 29:3 | 164:6 | interference 3:9 | 164:24 165:16 | | 29:7 30:22,24 | institutions 64:23 | internal 25:6 | island 176: 15,21 | | 31:3,9,12 58:10 | instructed 43 :7,9 | 80: 14 | issue 27:23 73 :6 | | 59:6,16 69:24 | instructing 26:21 | internally 13:10 | 75:10 82:23 | | 85:7 94:4 98: 11 | 26:23 27:12 | interpreter 127: 14 | 124:23,23 150:5 | | 99:11,17 104:11 | instruction 29: 10 | interrelated 113 :7 | issued 54:7 | | 105:3,7, 12 110:6 | instructor 18:5 | interrupt 41:8 | issues 18:3 27:24 | | 116:9 124:10,14 | instructs 9:21 | introduce 174: 16 | 40:24 44:8 52:6 | | 124: 16,20 127:5 | insufficient 8:25 | investigate 102: 14 | 53:15 72:3 110:11 | | 133:2 135:2 | insurance 69: 14 | 105:17 110:25 | 147:20 174:6 | | 136:13 137:3,12 | 107:8 117: 10 | 113: 10 124: 17 | 182:12 | | 137: 19 138:3,7 | 121: 17,18,22,24 | 168: 19 | | | | | | |

| item 55:5 61:16.20 | 36:1 37:1 38:1 | 149:1 150:1 151:1 | keypunch 98:19 | |------------------------|--------------------|-------------------|---------------------| | 63:11,18 64:13 | 39:1 40:1 41:1 | 152:1 153:1 154:1 | keypunched 98:16 | | 66:12 68:6,16 | 42:1 43:1 44:1 | 155:1 156:1 157:1 | kids 118:15 | | 73:15,20 80:16,21 | 45:1 46:1 47:1,24 | 158:1 159:1 160:1 | 138:25 | | 82:7 83:6.19 | 48:1,2,11,25 49:1 | 161:1 162:1 163:1 | kind 20:22 88:24 | | 84:11,24 85:18,22 | 50:1 51:1 52:1 | 164:1 165:1 166:1 | 116:17 118:17 | | 86:2,6 87:7,21 | 53:1 54:1 55:1 | 167:1 168:1 169:1 | 122:12 134:22 | | 88:15,20 89:19 | 56:1 57:1 58:1 | 170:1 171:1 172:1 | kings 188:4 | | 91:5 92:19 94:14 | 59:1 60:1 61:1 | 173:1 174:1 175:1 | 45:20 105:6 knew | | 94:15,16 95:4,7,23 | 62:163:164:1 | 176:1 177:1 178:1 | 113:9 178:16,18 | | 95:24 96:2 97:11 | 65:1 66:1 67:1 | 179:1 180:1 181:1 | 182:22 | | 97:13 103:11,12 | 68:1 69:1 70:1 | 182:1 183:1 184:1 | know 7:16 9:10 | | 103:13,14 104:2,2 | 71:172:173:1 | 185:1,7 186:15 | 22:4 30:12 31:7 | | 111:20 113:17 | 74:1 75:1 76:1 | 187:3 | 31:17 33:19 34:13 | | 127:22 142:14 | 77:1 78:1 79:1 | 1:6 jam | 34:18 36:7 38:16 | | 144:12,20 146:12 | 80:1 81:1 82:1 | january 161:18 | 38:16,22 39:13 | | 152:4 | 83:1 84:1 85:1 | 13:8 31:25 jo | 41:4 43:18 47:3 | | items 89:16 96:21 | 86:1 87:1 88:1 | 49:16 50:9 56:5 | 50:3 52:3,21,22 | | 97:24,24,25 98:7 | 89:1 90:1 91:1 | 56:24 112:17 | 53:9 57:23 58:2.3 | | 99:12 101:3,12,15 | 92:1 93:1,12,14,22 | 86:13 joint | 58:12 60:4,9,25 | | 102:5,22 103:22 | 94:195:196:1 | 2:22 jon | 62:21 64:9 65:16 | | 107:13 119:16,18 | 97:1 98:1 99:1 | jonathan 4:2 | 66:3,5,23,24 67:6 | | 119:23 121:8,11 | 100:1 101:1 102:1 | judge 29:9,13 | 72:19,23 76:7,17 | | 132:7 136:19,25 | 103:1 104:1 105:1 | 87:16 | 77:7,10,12,13 | | 137:13 160:11 | 106:1 107:1 108:1 | judges 22:14 | 79:10,12,13 80:14 | | 163:6,19 | 109:1 110:1 111:1 | judgment 37:22 | 83:23 84:5,10 | | I | 111:4,8 112:1 | 102:4 136:15 | 86:14 89:9,11,20 | | 2:10,15 5:21 6:5 | 113:1 114:1 115:1 | iune 17:9 | 89:25 90:4 103:25 | | 1:15 3:1,18 jalbert | 116:1 117:1 118:1 | justice 64:23 | 104:3,4 107:10 | | 4:1 5:1 6:1,5,14 | 119:1 120:1 121:1 | justify 148:15 | 109:19 111:24 | | 7:18:19:1 10:1 | 122:1 123:1 124:1 | k | 115:3 116:3,3,4,5 | | 10:14,16,19 11:1 | 125:1 126:1 127:1 | keep 41:2 52:16 | 116:5,14,17 117:8 | | 12:1 13:1 14:1 | 128:1,24 129:1,11 | 59:14 107:12 | 117:8,10,20 118:7 | | 15:1 16:1 17:1 | 129:14 130:1 | 124:17 | 120:21 121:13 | | 18:11 19:1 20:1 | 131:1,16,20 132:1 | keeping 42:11 | 122:23,24 123:3 | | 21:1 22:1 23:1 | 133:1 134:1 135:1 | keith 20:6 | 125:8,13,20 | | 24:1 25:1 26:1 | 136:1 137:1 138:1 | 9:17 13:6 ken | 126:20 127:12 | | 27:1 28:1 29:1 | 139:1,24 140:1,7 | 14:16,21,24 | 145:15 150:11 | | 30:1 31:1 32:1,13 | 141:1 142:1 143:1 | kenneth 2:10 5:3 | 151:18,21 152:2 | | 32:18 33:1 34:1 | 144:1 145:1 146:1 | kept 7:17 162:10 | 152:13 154:7 | | 34:23 35:1,8,12 | 147:1,10,15 148:1 | | 157:21 159:3,21 | | | | | |

[know - llp's]

| 161:2,15 166:21 | lago 122:13 124:4 | legitimate 160:5 | liquidate 171:5 | |----------------------|----------------------|----------------------|-----------------------| | 168:11 169:4,5,17 | 124:21 | lenaya 1:19 4:5 | liquidated 88:2 | | 170:13 171:7 | lamp 126:8,20 | 188:6,21 | list 7:17 53:6 | | 172:16,19 173:7 | 127:16,20 179:14 | lenders 20:20 21:7 | 64:22 87:6 90:4 | | 173:20,25 175:5 | 179:15,24 | 58:24 lengthy | 107:4 154:4 | | 176:2 177:3,7 | land 113:16 | 31:16,22 letter | 155:19,20 157:24 | | 179:11 181:8,9,11 | language 114:23 | 32:5 43:12 75:13 | 159:23 172:7 | | 181:22 182:5,12 | large 30:20 59:8 | 76:3 | 173:4 | | 182:18,20,21 | 78:5 | level 53:12 72:25 | listed 12:3 72:19 | | 184:7,18 | 2:5 4:18 laura | 94:14 149:23 | 108:12 111:25 | | knowing 29:4 | 6:12 103:3,6 | levels 59:5 | 114:14 122:12 | | knowledge 12:15 | law 22:13 39:18 | liabilities 30:23 | 128:3 | | 12:19 41:3 59:9 | 112:15 134:7 | 94:3 111:17 | listen 124:7 | | 62:17 63:3.4 | 43:18 46:8 lawyer | 164:10,12 | listened 123:15 | | 91:10 102:10 | 86:20 102:17 | liability 157:5,6 | listing 108:13 | | 121:15 122:7 | 113:25 138:20 | 169:23 life | 160:23 | | 123:17,20,22 | 139:14 178:23 | likelihood 82:4 | litigation 19:6 | | 126:9 127:20 | lawyer's 40:7 | limitations 111:15 | 22:4,7,11,11 40:6 | | 128:7,21 133:20 | lawyers 22:20 | limited 5:17 90:7 | 77:981:25 82:5 | | 140:12 152:10,20 | 25:12,14,1639:21 | 163:9 178:17 | 85:19 88:2 127:23 | | 154:9 158:3 | 51:17 82:18 95:5 | line 5:13 44:18,18 | 128:15,17 170:19 | | 172:21 174:18 | 96:23 102:7 110:8 | 61:15,20 63:11,18 | 170:25 175:14 | | 184:15 | 125:17 126:2 | 64:12 66:12 68:5 | 178:18 | | 47:14 knows | 128:6 132:24 | 68:16 73:15,19 | little 14:19 16:25 | | kwok 1:5 2:9 3:19 | 136:16 139:14 | 80:16,21 82:7 | 21:25 24:3 46:17 | | 5:5 11:6 25:21,24 | 150:20 155:23 | 83:6,19 84:11,24 | 89:12,12 | | 32:1635:9 94:4 | 158.3 159.7 | 85:17,22 86:2,6 | 146:22 150:18 live | | 102:6,23 103:14 | 170:18 172:22 | 87:7,21 88:15,20 | 118:15 lives | | 104:9 111:18 | 174:6 | 89:16,19 91:5 | 149:16,22 | | 119:24 122:16 | ૨૫ - ૨ ead | 92:19 94:14,16,22 | living 114:8 | | 129:2 138:23 | learn 30:5,7 | 95:3,7,13,15 96:2 | 129:22 133:15 | | 139:2 140:8 143:2 | leave 152:24,25 | 96:16,21 97:11 | 134:9 136:17 | | 147:17 | leaving 41:11 | 99:12 103:12,13 | 140:13 153:17 | | kwok's 30:3 | 102:7 144:4 left | 111:19 132:7 | 159:8 183:3,11,12 | | 119:10 145:17 | legal 2:22 101:8 | 136:19,25 137:13 | 184.5 | | l | 105:9 106:6 | 146:12 152:4 | 2:12 75:24 lle | | 5:21 6:5 23:16 | 113:15 114:7,25 | 159:14,15 163:6 | 126:21 | | 186:2 | 153:8 | 163:19 | 1:18 2:3,4,8 llp | | 63:5 ack | legally 76:2 | lines 95:19 104:4 | 3:24 | | lady 119:7,10 | 168:14 | 126:18 | llp's 10:24 | | | | | |

**[loan** - **massachusetts]**

| loan 63:23 64:2 | lowey 1: 15 7:9 | lynch 1: 19 4:5 | major 19:3 67:2 | |------------------------|----------------------|-----------------------|----------------------| | 65: 11, 15, 19,22,25 | 10:25 13:24 15:16 | 188:6,21 | 89:15 | | 66:6, 15 68:2 | 17: 12 18:22,25 | m | makenzie 2:6 4:24 | | 70:16 | 20:6,10,15 21:16 | macdonald 49: 19 | 34:21 146:7 | | loans 64:5,10 66:3 | 21:2122:24 23:6 | maid 118:8 145:4 | making 73: 11 | | located 3:24 101:5 | 23: 18,25 24: 17 | 145:4 158:24 | 101: 14 102:3 | | 113: 19 | 25:7 26:3 30: 13 | maids 145:4 | 113:3 153:7 | | location 123 :21 | 31:15 36:8,18 | | 167: 13 184: 10, 16 | | lodge 101: 17 | 37:3,24 38:21 | mail 26:9, 13, 13 | manager 50:8, 13 | | long 15:5 137: 18 | 39:4,17 43:7 48:8 | 30: 19 32: 17 34:3 | managers 50: 16 | | 139: 15 160:20 | 48:20 49:4,18 | 35: 11, 19 37: 18 | 51: 19 | | 165:22 | 50:2, 15,20 56: 19 | 38:6 39:7,9 41: 17 | managing 51:4 | | look 31:25 35:15 | 57:2 58: 15,21 | 104:24 106:9 | 70:16 | | 40:8 48: 11 82: 16 | 59:15,25 61:15,19 | 129:9, 10, 15, 17,24 | mandarin 57: 18 | | 111:23 152:15 | 64:12 65:9,13 | 130: 11 131: 15 | 174:20 | | 174:7 178:13 | 66: 10 67: 13,24 | 139:23 141:2 | mar 122: 13 124:4 | | looked 13 :22 70:7 | 71:12,18 72:17 | 147:9 151:13 | 124:21 | | 133:16 136:14 | 73:19 76:10,25 | 152:9 160: 18 | march 23:22 45:8 | | 163:21173:22,25 | 78: 16 80:20 82:4 | 162: 19 169:4 | 72: 10, 10 73 :6 | | 174:8 181:21 | 83:5 84:17,22 | 173:15 180:10,19 | 122:25 134: 15 | | looking 14:3 22: 14 | 85:25 87:20,23 | 181:25 182:2,4 | 137:22 155:17,18 | | 22:16 69:17 | 93:3 94:6,10 95:3 | 187:6, 7, 11, 12, 13 | 156: 16,18 | | 136:17 142:15 | 96:20 97:10,16 | 187: 14 | mark 7:6 35:7 | | 154:22 162:20 | 98:6 99:5 100:8 | mails 13:11,23 | 131:9 | | 172:4 175: 18,23 | 101: 13 102:3 | 14:2,4 15:20 27:9 | marked 10: 16 | | 175:24 | 109:6, 11 112: 16 | 27: 10 49:22 59: 11 | 32:13,18 35:12 | | looks 107:5 132:5 | 112: 17,20 122: 15 | 99: 19 104:23 | 47:24 48:2 93:12 | | loose 132:7 | 124:9 125:22 | 112:24 163:8 | 93:14 111:4,8 | | lose 75: 19 | 128: 10 135:20 | 180:8,22 181:21 | 128:24 129: 11 | | losses 78: 12 | 136:22 144:21 | main 2:13 25:2,3 | 131:7, 16,20 | | lot 42:1047:11 | 149:11163:17 | 163:12 | 139:24 140:7 | | 68:18 69:24 | lowey's 12: 15,22 | maine 176: 17,23 | 147: 10,15 | | 104:25 112:13,14 | 44: 13 55: 15 67:9 | maintain 17:25 | markedly 41 :20 | | 122:3 127:8 | 106:3 111:20 | 54:3 91:7 92: 10 | marking 10:13 | | 168:23,24 178: 18 | 112:8 134:21 | maintained | marriage 188: 15 | | lots 99:13,14 | 135: 16 140:23 | 156:21 | married 142:25 | | 106:21113:10 | Ip 4:20 | maintaining 63: 19 | mary 13:8 31:24 | | 167: 19 169:21 | lunch 123:4 | 64: 16 91:5 | 49: 16 56:4,24 | | 178:2,2 | luxury 115: 16,23 | maintenance | 112: 17 | | low 53:12 | 116: 13 | 107:8 144:22 | massachusetts 6:9 | | | | 145:6 158:23 | 176: 13,16,22 |

### [materialize - monthly]

| materialize 52:7 | meeting 16:16,17 | met 6:11 16:13,18 | mitchell 25:17,20 | |----------------------|--------------------|---------------------|--------------------| | materializes 60:12 | 45:14.15 46:16.25 | 16:19 30:18 58:15 | 25:25 26:10 31:4 | | materials 150:19 | 47:13 51:15 69:5 | 125:15.16 | 31:8 32:9 56:18 | | matt 45:6,15 46:9 | 116:2 123:15 | method 152:22 | 57:4 59:4,4,18 | | 49:15,15 50:4,7 | 126:13 127:10 | methodology | 99:3.8 102:11 | | 56:24 112:17 | meetings 46:19 | 111:15 | 103:17 104:12,16 | | 129:18,19 154:4 | 47:12 | 167.23 mezzanine | 105:4,13 106:7 | | 160:17 181:18 | melissa 25:18,23 | microphone 3:11 | 109:24 112:15 | | matter 1:16 3:18 | 26:2,10 30:2,6 | 165:2 | 124:2 129:18 | | 6:23 20:8 41:9 | 31:4,8 32:9 56:16 | microphones 3:6 | 135:23 139:8 | | 43:8 46:4 49:17 | 56:17 57:3 59:3,4 | middle 113:14 | 143:14 156:3 | | 50:21 51:6 53:12 | 59:10,17 99:2,7 | 162:14 midnight | 157:16 181:5 | | 67:13 76:5 81:25 | 102:11,18 103:17 | million 126:8 | 148:4 m k | | 90:9 115:25 129:2 | 104:11,15 105:4 | 154:13 164:12 | moment 62:24 | | 145:6 147:17 | 105:13 106:7 | miltenberger 2:19 | 153:12 | | 151:23 160:25 | 109:25 110:18 | 5:14,16 28:13,14 | monetize 120:24 | | 174:10 188:17 | 112:15 124:2 | 29:23 41:7,15 | 54:21 money | | matters 7:2 14:2 | 129:19 135:23 | miltenberger's | 62:14 78:4 134:18 | | 40:2 88:22 98:20 | 139:8 143:13 | 29:21 | 153:24 177:4 | | matthew 13:7 56:4 | 148:3 152:12 | mind 27:14 34:18 | monies 136:6 | | medonald 15:18 | 156:2 157:16 | 34:24 36:20 87:5 | monitor 92:14 | | mckenzie 131:2 | 160:16 174:5 | 99:20 164:21 | monitoring 91:13 | | 141:9,10 meals | 180:9,17 182:3 | mindy 20:9 | month 72:15 | | 144:15 | 55:7 member | 46:8 mine | 118:21 161:7 | | mean 17:16 21:9 | 172:12 | minimum 32:8 | 184:2 | | 39:24 44:23 60:14 | membership | 67:7 77:14 128:6 | monthly 45:6 | | 83:12 86:8 87:9 | 122:13,17 124:5 | 161 · 7 minor | 46:11 51:12 67:8 | | 96:11 110:4 | memories 113:12 | minute 11:13 33:3 | 68:7,11,18,23 69:7 | | 116:14 130:19 | memory 66:2,9 | 147:24 | 69:10,12 70:2,15 | | 138:14 149:2 | 115:22 127:8,9 | 14:20 minutes | 70:18 71:2,3,8,13 | | 175:14 177:19 | 141:20 159:17 | 89:11 | 72:3,20 105:21 | | means 8:3 82:14 | menial 170:2,7 | 89.14 minutiae | 106:12,16 107:14 | | 144:3 151:2 | mentioned 14:15 | miscommunicati | 107:22,25 108:20 | | meant 22:7 63:12 | 15:15 18:4 19:24 | 135:4 | 116:22 117:14,16 | | 159:12 | 22:23 24:11 25:23 | missed 23:11 | 118:11 122:16,21 | | media 3:16 120:19 | 29:25 49:14,19 | missing 32:281:9 | 123:7 124:6,11 | | 120:23,24 | 54:14 57:3,14 | 110:15 | 125:5,16 130:14 | | 171:3 mediation | 60:13 73:22 87:8 | 159:24 mistake | 130:21 132:2,25 | | medications 10:4 | 92:4 100:7 126:16 | misunderstood | 134:9,24 135:10 | | meet 16:15 45:22 | 165:18 | 56:22 | 147:8 148:7,16,24 | | 72:5 | | | 149:3,24 151:25 |

PAX-014-068

## [monthly - objection]

| 154:20 155:12,15 | 116:4 138:10 | 115:25 116:15 | 136:12 141:17 | |----------------------|-----------------------|----------------------|-------------------------------------| | 157:11,19 160:4,8 | 173:4.8.23 174:9 | 146:22 156:13 | 145:2 153:6 | | 160:24 161:11,16 | 182:6, 14 | 173:18 176:14,16 | 158:15 | | 161:17,23 162:2 | named 119:7 | 176:23 188:3,7 | numerous 44:5 | | 163:5,13,20 168:9 | 136:22 names | night 14:22 | 59:11 101:3 | | 169:7,11 184:19 | 107:12 natural | no l's 78:7 | 112:24 | | months 72:7 | nature 52:21 | nonsense 162:11 | 5:16 ny | | 161:25 183:20 | 168:13 183:16 | 8:17 77:19 normal | 0 | | mor 72:11 108:14 | 136:3 nearly | 179:3 | 23:16 78:11 | | 137:22 | necessarily 83:24 | normally 109:15 | 0 186:2 | | mor's 170:6 | necessary 12:20 | notary 1:19 5:23 | | | morning 3:3 6:10 | 63:21 75:25 80:18 | 186:22 188:6 | o'melveny 1:17 | | 14:20,22 | 85:18 93:2 100:23 | note 3:5 29:20 | 2:3 3:24 4:19,22 4:25 6:13 13:18 | | mortgage 77:19 | 112:7 169:21 | 35:24 41:11 | 100:5 103:7 | | mother 118:17 | need 8:23 9:9 | 145:19 | oath 4:77:25 | | motion 14:9 28:25 | 36:14 37:11,20 | 29:18 noted | 129:25 | | 38:15,20 89:7 | 40:12,15,23 42:10 | 14:6,7,7 notes | object | | 90:10,16 168:6 | 47:4 85:9 124:19 | 51:10,11 100:9,13 | objected 30:20 80:19 | | motions 6:24 | 127:4 143:3 156:9 | 100:14.19 101:3 | objecting objection 12:4,24 | | 181:12 | 163:14 166:20,23 | 111:7,14,24 | 24:20 26:16 27:15 | | motor 119:5 | 169:18 170:10,15 | 112:12 113:4 | 28:24 29:22 34:10 | | motorcycles | 171:14 | 121:6 148:4 | 37:16 39:5 57:22 | | 115:17 | needed 30:22,25 | 187:10 | 58:18 61:4 64:14 | | 75:14 move | 44:2 46:7 174:4 | notice 6:22,25 7:5 | 66:13 77:4 78:21 | | moving 34:24 57:2 | needing 166:10,13 | 7:12 10:15,24 | 79:22 81:10,12 | | multi 42:22,22 | needs 167:6 | 89:10 187:5 | | | multiple 19:14 | 169:19 | noticing 4:17 | 84:25 88:3,8 91:9 92:2 93:5 95:9 | | 42:4 76:4 | negotiated 31:14 | november 127:24 | 96:10 98:15 99:24 | | multiplied 136:7 | 31:15 | number 3:22 6:24 | 101:18 102:8 | | multiply 183:25 | negotiation 31:18 | 19:16 30:21 32:16 | 103:24 104:13 | | music 120:7,18 | 65:10 | 62:6 73:4 81:4,15 | 106:18 108:21 | | 1:18 2:3 myers | negotiations 171:3 | 93:19 96:8 100:20 | 111:22 112:22 | | 3:24 4:19,22,25 | neither 58:14 | 110:19,20 132:22 | 113:24 118:4 | | 6:13 | net 19:10,24 78:11 | 133:16,20 134:19 | 122:18 126:3 | | n | netherland 114:17 | 135:13,18 146:20 | 127:7 130:16 | | 2:278:11 186:2 | 115:2 | 150:9,10 152:14 | 132:11 133:18 | | n 187:17 | never 57:6 121:23 | 159:14,15 181:21 | 141:18 148:20 | | name 4:2 6:3,11 | 1:18,18,21 2:5 new | 183:22 187:4 | 149:7 152:11 | | 20:5 23:12,13,15 | 2:5,10,10,183:25 | numbering 97:7 | 157:20 166:12,22 | | 23:16 27:20 28:22 | 3:25 5:23 58:8 | numbers 48:23 | 170:12,22 177:25 | | 29:5 58:12 102:18 | 79:15,16 115:8,10 | 97:5 135:21 | | | | | | |

### [objections - paragraph]

| objections 4:14 | 108:20,23 137:20 | oral 65:18 99:17 | page 7:8 11:8,21 | |----------------------|--------------------|----------------------|--------------------| | 12:8 14:10 52:20 | 170:24 178:18 | 99:18 | 33:2,4 48:22,23,24 | | 52:22 54:8 | open 47:13 91:7 | orally 106:9 | 49:9,11 55:13,18 | | objects 9:18 | 92:10 | 160:18 | 88:20 93:25 95:18 | | obligation 91:22 | opening 63:19 | order 29:15 62:11 | 96:4,25 97:4,8 | | observer 45:20 | 64:16 91:5 | 72:23 75:3,5,8 | 105:18,20 106:11 | | 12:19 obtain | operating 41:21 | 86:9,21 105:5 | 113:13,14 115:12 | | obtained 59:17 | 41:24,25 42:11,20 | ordered 54:25 | 119:9,12,20 120:3 | | 22:15 obtaining | 42:21 43:3 45:7 | ordinarily 172:5 | 121:3 124:25 | | obviously 43:18 | 46:11 51:12 67:8 | ordinary 30:21 | 126:5,10 132:7 | | 66:18 87:17 98:17 | 68:7,11,19,23 | 62:7 70:24 156:7 | 140:19 145:20 | | 105:8 156:21 | 69:10,12 70:3,6,10 | 156:8 167:18 | 148:3 149:15 | | 163:15 173:21 | 70:15,18 71:2,4,8 | 169:22 181:7 | 151:14 152:8 | | occasion 174:17 | 71:13 72:4,21 | original 150:10 | 157:6 161:19.20 | | occasionally | 78:12 106:12,16 | 152:3 159:20 | 161:20 162:3 | | 141:22,24 | 107:22 108:2 | originally 153:13 | 187:3,18 | | 113:19 occupancy | 116:22 117:14,16 | 4.9 outcome | pages 161:19,22 | | 113:22 | 118:11 122:16,22 | 188:16 | 162:11 | | 68:3 occur | 123:8 124:6 | outside 16:22 26:3 | paid 32:24 70:23 | | offer 18:25 | 130:15,21 132:2 | 26:5,6,14 31:5 | 72:14 73:13 77:25 | | office 19:16 58:8 | 132:25 134:4,5,9 | 80:4 126:10 | 86:16 108:10,15 | | 68:24 69:20 72:12 | 134:24 135:11 | 127:17 | 118:22 130:24 | | 72:22 162:13 | 147:8 149:25 | outstanding 59:24 | 133:3 134:16 | | offices 1:17 | 151:25 154:20 | overpayment | 136:7 149:18 | | official 93:13,25 | 155:12,15 156:10 | 160:6 | 151:15 152:21 | | 94:21 187:9 | 157:11,19 160:5,8 | 81:18,19,20 owed | 153:24 155:23 | | offset 78:7 | 160:25 161:11,16 | owned 114:3 | 156:11 158:8 | | 45:10 160:24 oh | 161:17,23 162:2 | 126:22,25 127:16 | 159:19 160:2,3 | | 167:9 173:2 | 163:5,13,20 168:9 | 154:8 | 173:6 175:4,8,10 | | 177:14 | 169:7,12 184:19 | ownership 102:12 | 175:19 179:24 | | okay 9:7 35:17,22 | operations 127:20 | 107:9 | 181:10,12 183:4,6 | | 71:17 85:17 96:3 | opinion 145:20 | 115:5 116:5 owns | 183:8,14 | | 103:2 131:11 | 151:5.7 | p | palm 122:14 | | 148:2 149:14 | opportunity 2:4 | 2:2,2 23:16 p | pans 101:23 | | 159:6 173:8 181:6 | 4:20 6:14 10:24 | p&l 69:20 | 168:23 paper | | old 169:3 | 38:20 75:20 81:4 | 1:15 2:17 p.C. | papers 43:17,19 | | once 85:11 144:24 | oppose 29:6 | p.m. 39:10 90:25 | 44:16 45:3 46:3,6 | | 154:10 | opposed 74:6 | 139:21 140:4 | 126:14 | | ones 60:9 69:23 | 103:14 | 165:8,12 185:5,8 | paragraph 113:2 | | ongoing 52:6 | opposite 159:24 | pacific 2:3 4:19 | 113:2 | | 88:14 105:21 | | 6:13 10:23 | | | | | | |

**[paramount** - **plan]**

| paramount 29:3 | pass 44:9 130:25 | people 5: 15 16:2 | 139:9, 11, 12 | |-------------------------|----------------------|----------------------|-------------------------| | parcel 111 :25 | 139: 10 | 19:8,17,19 28:19 | 140:24 157: 17 | | parents 42:3 | passed 105:7,8 | 45:22 53:4 58:24 | 178:20 179:3 | | part 21:22 37: 17 | patents 120:4, 13 | 102: 17 117:24 | 181:23,24 182:2 | | 43:17 51:1169:9 | pax 100:6 | 118:7 141:24 | 183:9,10 184:4 | | 96:9,12,17 97:9,13 | pay 19: 13 54:22 | 142:2,4 168:24 | person's 27:23 | | 97:24 100: 12 | 55:3 68:2 118:20 | 175:16 | 182:5 | | 105:20 111:25 | 154:9 171:6 | percent 118: 13 | personal 95: 12 | | 112:3 132:21 | payable 69:21 | 138: 19,21 139:4 | 97:25 101:4 | | 144:7 170:21 | payables 167:24 | 141:9,11,13,14 | 102:10 | | 171:7,9 172:4 | payee 138: 11 | 142:7,8,9, 12,16,23 | personally 23 :9 | | 181:6 | payees 137:7 | 143:6,8 144:2,5,6 | 65:17 | | participate 47:2 | paying 107: 17 | 144: 13,14 145: 11 | perspective 31 :23 | | 47:17 60:8,12 | 146:24 | 146:4,5,11,11,21 | 77:16 85:7 | | participated 51: 13 | payment 33: 17 | percentage 136:6 | pertaining 146:21 | | 58:23 84:3 | 92:22 106:23 | 136:8 138: 13 | petition 32:22 | | participating | 108:22 117:9 | 139:5 147:7 | 33:5,9, 16,20 35:24 | | 45:21 | 133 :3,25 134: 11 | percentages | 36:3,8 74: 13 84:6 | | participation | 146: 19 154:7,13 | 136: 15 144: 19 | 92:22 132: 19 | | 45: 12 47: 10,20 | 154: 15 156:24 | perform 59: 15 | 133:3,3,25 160:2,2 | | particular 40:5, 12 | 159:17 175:13 | 66:1191:2593:3 | 160:3,3 172:5,20 | | 40: 16 42: 19 105:5 | 179:4 | 96:20 97: 10,16,21 | 174:25 176:5,8 | | 117: 17 118:6,23 | payments 83 :22 | 98:5,6 114: 13 | 177: 18,24 183:4 | | 130:17 168:25 | 84:6 86:16 93:2 | 125:22 | 183:11,14,16 | | particularly 14:9 | 132: 16,19 133:7,9 | performed 80:20 | 184:5,12 | | 112: 12 | 133:10 134:2,6,16 | 83:5 88: 10 89: 18 | phone 15:3 25: 11 | | parties 3: 14 66 :22 | 134:22 154:5 | 97:20 121: 10,14 | 25: 15 28:8 47:20 | | 84:23 87:12 | 156:25 157:24 | period 72: 10 | 58:24 59:2, 11 | | 104:25 105:2 | 172:5 183:17,17 | 82: 16 86:20 90:25 | 104:24 143:15 | | 117:6 130:24 | 184: 11 | 117: 18 129:22 | 167:8 181:19 | | 133: 12 188: 14 | payroll 42:7 | 133:11140:13 | phones 3:10 | | partner 19: 12 | pays 122:4 | 151: 15 153 :25 | phrase 110:2 | | 20:3 51:3 | pc 10:25 48:9,20 | 154:20 155: 11, 17 | physically 123:5 | | partnership 74: 10 | 49:4 | 156: 12 157:25 | pick 3:7 | | 75:23 | pdf 95:18 | 159:9 | place 3:10,14 | | parts 79: 12 | pearl 2:18 | perjury 8:8 | 45:22 47:15 53:8 | | party 4:7 20:22 | penalty 8:8 | person 5:12,15 | 77:6 82:20 83 :25 | | 44:4 53: 10 99: 11 | pendency 70:9 | 15:18,2126:15,17 | 175:24 186: 11 | | 102: 14 119:24 | 117: 19 | 49:20 50:17 51:5 | plan 86:6, 11, 13,24 | | 122:6 173: 12 | pending 9: 11 | 54:4 103: 15 | 87: 15,24 122:2 | | 184: 10 | 81:25 82:5 | 129: 18 130: 10,10 | 169:17 |

| planned 54:19 | 120:17 | prepare 13:4 | previously 6:10 | |--------------------|--------------------|-----------------------|----------------------| | plans 86:14 88:7 | possibly 118:3 | 24:13,14 71:11,12 | 14-23 85-20 | | 125:3 | 169:6 171:17 | 71:23 95:3 100:9 | 104:10 119:18 | | platforms 120:8 | post 20:17 32:22 | 173.5 | 130:4 | | 120:20 | 33:5,9,16,20 35:24 | prepared 13:10,14 | primary 143:10 | | play 52:10 169:18 | 36:3,8 61:11 | 24:15 31:19 71:3 | principal 21:17 | | 169:20 171:7 | 63:12 133:3 160:2 | 71:19 86:12 | 22:24 23:3 37:23 | | 172:2,3,3 | 174:25 176:5,8 | 161:15 173:18 | 50:5,10,16,25 51:8 | | plays 52:11 | 177:18,24 183:11 | 183:12 | printed 119:11 | | pleadings 14:8 | 184:5, 12 | preparer 135:4,6 | 82:17 83:23 prior | | please 3:5,9 4:15 | posted 120:8,19 | 136:9 173:4 174:9 | priority 81:7 | | 5:10,19 6:3 8:19 | potential 24:10 | preparing 8:12 | privacy 29:2 | | 9:5,11 11:8 23:14 | 52:9 65:11,15,22 | 15:6 45:6,11,12 | private 3:7 | | 28:11 33:2 35:15 | 85:21 | 46:14 55:24 56:7 | privilege 39:23,25 | | 67:22 148:5,14 | potentially 27:20 | 57:24 58:21 60:23 | 40:17 83:15 | | 165:2 | 66:6 78:17 90:14 | 66:20,21 84:4 | privileged 41:3 | | plus 72:10 106:7,7 | 101:23 pots | 86:18 94:7,11 | 14:24 probably | | 135:18 140:17 | practice 121:21 | 105:11 109:6 | 20:20 24:11 28:9 | | 2:14 po | practitioner | 110:12 112:9,21 | 32:9 42:10 45:4 | | pohl 23:10,15,17 | 176:13 | 132:4 155:3.6 | 52:15,16,19 54:5 | | 23:24 24:4 | pre 74:13 84:6 | 161:2169:11 | 106:8,8,9 110:17 | | point 39:14 40:18 | 92:22 132:19 | 170:5,6 | 116:23 137:8 | | 48:14 52:20 60:6 | 133:3,25 160:2,3,3 | presence 120:25 | 138:21 144:5 | | 61:8 65:25 67:10 | 172:5,20 177:18 | present 2:21 4:10 | 170:23 176:19 | | 75:3 81:11 92:20 | 177:24 183:4,14 | presenting 155:13 | 80:3 problem | | 106:17 123:23 | 183:16 | presidential 19:19 | 146:25 160:24 | | 124:13 130:14 | precursor 17:11 | presumably 54:22 | 162.16 | | 153:22 166:3 | predicated 72:3 | 68:20 | 11:3 procedure | | 171:10 | 157:10 | presuming 114:6 | 17:19 | | points 25:2 55:17 | predict 53:7,13 | presupposed | procedures 7:23 | | policies 121:17 | prefer 33:15 | 55:10 | 70:13 | | policy 121:18,22 | preference 33:9 | presupposes 70:15 | proceed 11:20 | | 121:24 122:8 | 33:14 82:10,18 | presupposing | 140:5 165:13 | | populated 95:23 | 84:2 171:18 | 66:14 | proceeding 4:15 | | ported 49:23 | preferences 82:16 | pretty 21:11 22:9 | 16:22 | | poses 37:2 | preparation 13:20 | 32:7 37:4 44:22 | proceedings 39:19 | | possession 37:25 | 15:751:953:5 | 70:5 179:11 | 39:21,22 115:10 | | 38:3 52:14 | 55:19 56:20 60:19 | previous 36:21 | process 38:14 | | possible 30:17,25 | 61:9 68:6 73:16 | 38:6 78:7,10 | 40:13 67:21 155:9 | | 31:6 35:25 60:7 | 86:7 112:4 116:22 | 116:8 119:6 | 168:7,22 169:23 | | 79:6 82:9 84:12 | 168:10 | | 178:11 | | | | | |

| produce 8: 13 | 152: 16 153: 16,25 | q | r | |------------------------|-----------------------|----------------------|------------------------| | produced 128:25 | proponent 118: 12 | qpc 31:23 | r 2:2 5:21,21 6:5 | | 137: 19 147: 16 | proposed 5:4,7 | quarter 72:8 73:9 | 48:25 186:2 188:2 | | 173:12,13,16 | 54:20 111 :20 | 73:10 | rang 167:8 176:10 | | product 46:22 | 139:3 150:21 | quarterly 68:7 | range 15:13 | | 83:15,17 | protect 75:9 89:16 | 71: 19,21,25 72: 18 | rank 29:5 | | profession 166:3 | 179:4 | queries 158: 18 | rarely 42:21 81: 18 | | professional 17: 14 | protected 29: 14 | question 8:20 9:5 | rate 67:10,11 | | 17: 17,25 18:8, 12 | protection 83: 18 | 9:7,11,19,20 27:4 | reached 23:17,24 | | 33:1137:22 77:17 | protective 29: 15 | | | | 92:21 156:4 158:3 | prove 86:22 | 27:6 28:9 34:8, 12 | 28:20 161:12 | | 163:3 166:7 | provide 22: 18 | 34:16,18,19 36:17 | 162:12,25 | | 175: 19,20 | 92:25 171: 11,15 | 36: 19,25 38: 17 | reaching 161:13 | | professionals 14:8 | provided 13:14 | 53:17 56:9 83:20 | read 27:6 34: 12 | | 30:21 54:9,23 | 59:5 98: 11 99: 10 | 94: 19,21 96: 17 | 57:18 65:24 90:16 | | 57:9 62:8 68:25 | 117:3 130:9 | 101: 12 105: 16 | 120: 16 147:25 | | 77:25 156:5,5,6,7 | 140:24 158: 15 | 108:3,8 110:7,8 | reads 55:18 61:8 | | 156:8 157:2,3 | providers 92:21 | 113:14 114:14 | 63:18 80:17 88:20 | | 159:25 175:20 | providing 27: 14 | 115: 13 116:21 | 94:20,24 95:11 | | 181:8 | 63:21 | 117:4 118:3 119:4 | 105:21 106: 12 | | profile 166:10,19 | public 1 :20 5 :23 | 120:3,12 121:16 | 113:18 115:15 | | 178:14 179:6,18 | 186:22 188:6 | 122: 11 124: 13 | ready 137:21 | | program 69: 12 | pulling 134: 14 | 126:5 127:22 | real 42:20 77:20 | | 70:11 | pullman 2:12 5:7 | 130: 18,20 148: 19 | 94:22 107:6 | | | | 149:6,12,25 150:3 | 113:19,22 114:2,4 | | progress 71:9 | 165: 17 | 151: 19,23 154:2 | 147:6 167:20 | | progresses 50:22 | punching 99: 11 | 155:16 163:10,12 | realized 159:24 | | projections 61: 10 | punitive 164:9 | 163:12 166:14 | really 31:274:21 | | 61:24,24 86:18 | purchase 117: 12 | 177: 13,21 181: 15 | 133:2 165:4 | | 87:10 | 118: 19 | 184: 10,12 | reason 10:8 76: 15 | | prominent 60: 18 | purchased 117: 13 | questions 47: 17 | 78: 13 89:4 138:22 | | promised 179:23 | purposes 39:23,25 | 83:21 91:3 99:21 | 142:4,19 143:4,10 | | prompted 163:17 | 77:24 | 100:6,23 113:5 | 145: 16 | | proof 80:24 81 :2 | pursuant 10:25 | 119: 19,21 129: 16 | reasonable 21: 13 | | 81:21 | pushed 168:23 | 135:25 149:2 | reasonableness | | proofs 80: 19 | put 44: 18 69: 16 | 153:5 158:5 | 109: 14 110:3 | | properly 136:2 | 131:12 142:7 | 164: 15 167: 17 | 158: 10 | | property 94: 15,21 | 155:24 | 179: 17 184:8,23 | reasonably 53: 11 | | 95:12 107:7 | puts 87: 18 | quick 165:4 | reasoning 29:21 | | 113:17 114:2 | putting 109:14 | quickbooks 60:25 | 142:17 143:21 | | 120:7, 13, 15, 18 | 180:22 | quickly 159:6 | 144:8,11145:10 | | 122: 11 148:5,14 | | | 145:12,21 |

**[reasons** - **report]**

| reasons 75:2 77:23 | record 3 :3, 15 4: 13 | refers 84:11 95:13 | relied 85:5 104:9 | |------------------------|--------------------------|-------------------------|-----------------------| | 130:3 142: 11 | 6:4,11,11 8:12 | 95: 17 96:2 114: 16 | 177:15 178:6 | | 168: 15 | 11: 13, 15, 16,20 | 119:4 120:5,12 | relief 75:4,6 | | recall 23 :20 32:6 | 28:2, 18 32: 15 | 121:4, 17 122: 13 | relies 84:22 | | 33 :8 34:7 44: 10 | 41:10 48:5 90:19 | 125:8 126:6,7 | rely 39:2 98:13 | | 57:21 65:20 | 90:2191:293:18 | 127:23 135: 13 | 123:25 139:6 | | 126: 17 128:4 | 100:4 129:5 130:4 | 144:20 | 158: 14 176:4 | | 146:10,13 151:4 | 139: 19,21 140:4 | reflect 132: 10 | 177:23 179:5 | | 151:10 161:9 | 156:9 165:4,8,9,12 | 133:8 140:22 | remain 106: 16,24 | | 173:22 | 185:2,5 188: 11 | reflected 13 3 : 14 | 107:18 | | receipt 78: 13 | recorded 1: 14 | 135: 15 152:8 | remains 74: 12 | | receipts 52: 17 | 3:17 | reflecting 164:5 | 184:14 | | 54:3,14,15 63: 15 | recording 3:13 | refresh 36: 16 | remember 21: 14 | | 66:25 68:22 86: 19 | 8:10 | regarding 15: 17 | 24:7 43: 14,24 | | receivable 69:22 | records 15:9,20,23 | 16:4,4 24:2,9 25:5 | 59:2 62:22 81:3 | | receive 57: 15 | 40:14 49:22 52:16 | 26:4, 11 30: 14 | 85:24 87:5 105:2 | | 137: 10 157: 15 | 82:9 84:12,14,18 | 59:21 65: 14,19 | 105:5,15 108:7 | | 174:24 | 92: 19 160:22 | 67:25 102: 15 | 109:20 110:8 | | received 33:20 | 171:16,20 172:17 | 111:16 137:13 | 116: 19 117:4 | | 92:22 99:17 | recoverable 83 :2 | 150:3 161: 10 | 127: 19 130:22 | | 104: 11 137: 13 | recoveries 175: 15 | 163:4 | 142: 13 146: 16 | | 139:7 140:6 | rectified 135:5 | regret 168:2 | 159:13 167:12 | | 160: 10 | redacted 129: 17 | rejoin 41:14 | 173: 10 176:7 | | receiving 33:9 | 182:6, 16,25 | related 4:7 19:7 | remind 167: 10 | | 161:9 | redaction 130:6 | 49:2156:961:10 | remotely 4: 11 | | recess 90:22 | refer 97:4,25 | 90:3 91:4 95: 14 | renters 107:7 | | 139:22 | referenced 68: 10 | 138:23 143:5,11 | reorganization | | recognize 10:20 | 103: 11, 12, 13 | 188: 14 | 86: 11 168:21 | | 48: 15 49:6 93:21 | 119:23 155:5 | relates 7:3,8 94: 15 | 169:15 | | 111: 11 140:9 | 159: 10,15 | 107: 16 111:21 | repair 107:8 | | 147:20,22 | references 63: 11 | 173: 16 | 144:22 | | recollection 36: 16 | 113:4,7 119:6 | relating 6:23 | repairs 158:22 | | 44:21 162:24 | referencing 65 :7 | 70:14 | repeat 9:5 27:3 | | recommend 73 :23 | referred 27:5 | relationship | repeating 66: 17 | | 73:24 74:2 75:7 | 174:5 | 143:19 | report 40: 11 45:7 | | 75: 17,22 76: 11 | referring 71: 15 | relevance 28:21 | 46: 11 51: 12 54:6 | | 80:9 141: 10 | 95:20 97:4,7, 14 | 88:11 | 67:8 68: 11, 19,23 | | recommended | 104:3 120:9 | relevant 27:24 | 69:7, 10, 13 70:3,6 | | 144:21 | 132: 12 135:9 | 41:4 113:23 | 70:10,15,19 71:2,4 | | reconciling 80: 18 | 150:6 167: 16 | 116:21 117: 14 | 71:9,19,21,25 72:4 | | | | 123:11 | 72: 18,21 107:22 | | | | | |

**[report** - **right]**

| 108:2,2,9 117:5, 15 | representations | responds 52:4 | 55: 13 61:8 88: 12 | |-----------------------|-----------------------|-----------------------|------------------------| | 118: 11 122: 16,22 | 59:21 | 149:15 | 111:21 126: 14 | | 123:8 124:6 | representative | response 35:23 | 175:22 | | 130: 15,21 132:3 | 180:5 | 115:14 | retrieved 31: 8, 12 | | 132:25 134:4,6,24 | represented 9: 12 | responses 12:7 | return 53:2,3 | | 135: 11 144:9 | 20:2121:10,12 | responsibilities | 74:23 75:6,8 | | 147:8 149:25 | 102:22 113:12 | 21:20 46: 10,18 | 76:12,14 77:2,22 | | 151:25 154:20 | representing 9: 16 | responsible 20:2 | 77:23 78: 14 79: 15 | | 155:12,15 156:10 | 100:5 181:13 | 98:12 | 79:17,18 86:23 | | 157: 12,23,23 | request 26: 19 | responsive 124: 15 | 168:9 173:5 | | 158: 13 159:8,20 | 108:9 163:18 | rest 17:24 | returns 54: 10 74:3 | | 160:5,8,25 161: 11 | require 47:9 60:7 | restrictions 153:2 | 74:9 75:24 76:5,6 | | 161:16,17 163:5 | required 12: 14,19 | restroom 139: 17 | 78: 18 79:9, 11 | | 163: 13 184:20 | 17: 19,22 54:25 | restructure | 80:10 169:9 173:3 | | reported 71:2 | 55:2 70: 10 76:2 | 167:22 | 173:6,11,18 | | 157:5 160:7 | 89:5 108: 14 | res tru ctu red | revealed 26: 18 | | reporter 1 :20 4:4 | requirement 67:7 | 170:16,21 | revealing 27: 19 | | 5:10,19 8:11 | requirements | restructuring | 28:22 | | 10:13,18 27:7 | 42:24,24 67:5 | 17:24 18:7 165:19 | revenue 80: 14 | | 32:12,20 35:7,14 | requires 68:24 | 166:11,13,16,20 | review 27:22 | | 47:23 48:4 78:9 | 86:25 89:10 | 166:24 167:7,16 | 43:22 51:23 52:19 | | 93:11,16 111:3,10 | reside 150: 15 | 167:21 170: 11,21 | 53:10 60:7 61:9 | | 128:23 129: 13 | 172: 17 | resuming 139:23 | 62: 12 68:6 72: 17 | | 131:18,19 140:2 | residence 101:5,9 | retain 48: 8, 19 | 73: 16 124:20 | | 147:12,14 171:13 | 102:5 113: 16 | 49:3 181:7 | 125:17 135:24 | | 187: 15 | 114:6,9 118:6, 10 | retained 34:6 | 150: 19 158:2 | | reporting 19: 18 | 150: 13 | 36:22 37:6 39:7 | 162:5 171:19 | | 42:23 52: 18 54:2 | residences 19: 14 | 39: 15,18,20 72: 17 | reviewed 13 :8, 11 | | 66:21 67:4 68:8 | 114: 14 118:3 | 143:11187:15 | 62: 18,20 81:24 | | 108: 14 148:24 | resident 76: 12 | retainer 32:22,24 | 84: 13, 18 109: 13 | | 149:3 155:6, 10 | resides 114:5 | 32:25 33 :5, 10, 12 | 110:3 112:24 | | reports 22: 19 | 118:5 | 33: 16,20 35:24 | 114:21 141:3 | | 66:21 68:7 107:22 | respect 21 :20 | 36:4,8 126:6 | reviewing 80: 17 | | 116:22 117: 16 | 92:25 95:7 | 174:25 175:17 | 82:8 112:11 | | 157: 19 161:23 | respond 89: 11 | 176:5,8 177: 19,24 | 160:15 171:16 | | 162:3 168:9 169:7 | 178:24,24 | retaining 34:5 | revising 139:5 | | 169: 12 | responded 36:20 | 35:21 36: 18 37:3 | rhode 176: 15,21 | | represent 30:2 | 65:4 | 39:4 | right 7: 10 10: 19 | | 129:7 140: 16 | responding 35: 18 | retains 74:7 162:6 | 38: 19 53 :24 55 :22 | | 144: 13 17 6: 1 7, 19 | 51: 16 | retention 7:8 | 61:3 62:16 63:6 | | | | 43:16,17,19 44:16 | 64: 16 70: 17 71:6 |

[ **right** - **server]**

| 73 :4 81: 15 84:9 | 178:7 181:3,5 | 124:25 128:3 | 142:20,24 143:3,5 | |-----------------------|-----------------------|---------------------------------------|-----------------------| | 90:7 94:8 95:21 | rudnick's 126: 14 | 135:5,7,9 136:10 | 143:10,23 159:14 | | 98:2 100: 11 | rule 10:25 11:22 | 155:25 | 184:3 | | 126: 19 130: 11 | rules 11 :2 117:5 | scheduled 81:14 | see 11:23 28:21 | | 134: 12 136: 19 | 161:3 | schedules 14:6 | 33:6 35:25 45:22 | | 138:5 152:5 | ruling 29: 12 | 30:23 44:22 45:25 | 57:19 61:12 68:8 | | 153: 17,20 154:22 | run 22:2 58:9 | 51: 10 55 :20,25 | 82:11,25 88:11 | | 165:20 169: 16 | 67:10,11178:21 | 56: 14 57: 12,17,25 | 95:17 96:6 121:8 | | 170:8 173:23 | running 21 :23 | 58: 17,22 60:20,24 | 121:19 125:6 | | 177: 14 | 172:9,10 | 69:4 100:10 | 132:15 141:2 | | rights 29:2 | runs 178:22 | 111: 16 112:2,5 | 148:9 151: 16 | | road 113:20 | russo 2:6 4:24,24 | 113:6 168:8 | 155:21 159:2,3 | | rodeo 89:3 | s | 183:13 | 168:5 183 :20 | | role 50:7, 12 52:9 | | schindler 13:8 | seeing 57:21 | | 53:18 94:6,10 | s 2:2 74: 10 187:2 | 31:25 49: 16 50:9 | 127:19 | | 98:11102:3 | safe 123:10 | 56:5,24 112: 18 | seek 124: 10,12 | | 105:25 106:3 | safety 13 8 :24 | school 17:3,5 | seen 79:8, 12 | | 112:9 134:21 | 144: 10 182: 11 | science 17:7 | 109:15 121:23 | | 168: 11 169: 17,20 | sales 42:7 | scope 43:8 44:12 | 127:24 128: 19 | | 171:25 172:4 | sanity 158:9 | 90: 13 171:9 | 137:6 145:7 164:8 | | roles 23:2 51: 18 | save 162:4 | scotch 164:22 | 164:13 | | roll 157:4 | saw 62:22 79: 13 | scrambling 69:4 | select 75:20 | | rolled 158: 15 | 79: 15 126: 13 | scratch 71: 11 | sell 122:6 | | room 4: 11 127: 12 | 128:4 153:4 | 99:16 106:2 | semantics 39: 13 | | rudnick 2:8 5:4 | 159:23 162: 19 | search 15: 19,20 | senators 19: 19 | | 15:21 23: 10, 16 | 163:13 173:3 | 49:21 82:25 | send 15:21 24: 15 | | 24:6,8,18 25:9 | saying 37:9 149:20 | second 45: 16 61:7 | 162:7 | | 26:5,6, 11 30:9 | 149:21 162: 13 | 114:16 121:6 | sense 38:2 158:4 | | | says 33:434:15 | | | | 31:20 32:4 38: 10 | 87:7 91:23 116:6 | 125:2 | 158:25 | | 38: 12 39:2, 16 | 116:7 162:7, 15 | secret 106:21 | sensitive 3 :6 | | 43 :23 49:24 56: 13 | 184:9, 10 | secrets 120: 14 | sent 13:17 31:20 | | 57:4 58:25 59:7 | scared 143: 16, 18 | section 75:5 97:17 | 49:24 | | 59:10,17 64:20 | 143:19 | 105:23 106:4 | sentence 121:6 | | 83:18 98:25 99:7 | scenarios 20: 14 | 114: 19 | 125:2 | | 102:12,18 103:18 | schedule 59:22 | secure 167:22 | separate 74:4,5,14 | | 103:18 104:11,17 | 60:3 71:14 81:14 | secured 20: 19 | 74:22 107:21 | | 104: 17 105:7,13 | 94:7,20,23 95: 12 | 21:7 42:15 81:7 | 129:5 131 :7 132:7 | | 106:6 109:24 | 96: 13 98:23 103 :9 | security 3 3: 17 | septem her 17: 10 | | 112: 14 124:2 | 103:23 104:8 | 115:24 118:8,25 | served 7:5 | | 126:7 139:7 156:2 | | | | | 157:15 175:18 | 108: 12 109: 16,17 | 133:23 138:16,22 138:24 142: 14,18 | server 13:24 49:22 |

[ **service** - **started]**

| service 92:21 | signature 188:21 | someday 169: 17 | spent 21:23 | |-----------------------------|--------------------------|------------------------|-----------------------------------------| | 138: 11 145:5,5 | signer 37:24 52: 14 | someone's 171:4 | split 118: 18 | | services 18:24 | 65:3 | someplace 110:21 | spoke 13:5,714:15 | | 21:21 85:21 90:4 | significant 13 :9 | son 58:9,11,13 | 14:2116:8 31:2 | | set 101:7 161:8 | 59:5 | soon 159:4 | 57:6 | | 188:10,19 | significantly | sorry 3:57:14 | spoken 14:24 | | setting 47:5 83:17 | 160: 14 | 23:1135:341:7 | 174: 11,18,22 | | settlement 78:6 | silverberg 13 :6 | 83:1194:1995:16 | spouse 118: 14 | | 171:2 | 24:5 33:4 34:4 | 126:4 130:19 | 145: 18 150: 14 | | settlements 77: 10 | 37:2 38:5 39:6 | 171:13 176:11 | spouse's 121: 18 | | seven 75:15 | silverberg' s 3 5: 19 | sort 52:8 55:6 | spreads 21:25 | | 136: 18 | similar 113: 17 | sorts 17: 15 42:23 | spreadsheet | | seventh 92: 19 | simultaneously | 54: 15 167:25 | 135: 14 158:6 | | shake 8:24 | 44:23 | sound 84:9 | 160:19 | | shape 62:10 | single 53: 10 75:22 | source 62:24 | spring 2:17 5:16 | | shapes 42:2 | sir 85:16100:6,14 | 77: 12 87:25 105:2 | 27:17,18 28:17,23 | | shea 2:17 | 153: 18 | 175:7,8,13,25 | 29:6 57:24 58:3 | | sheet 69:20 131: 14 | sitting 19:25 | spatulas 101 :22 | 179:6,9,12 180:6,7 | | 133: 15 138: 16 | situation 104:20 | speak 14:18 15:14 | 180: 10,15,20 | | 158: 12 | 121:23 | 23:25 24:9,17 | 181: 17,20 182:20 | | sheets 109:4 | six 162:10 | 25:5,10 26:2 | 183 :5,8 184:6 | | sherry 114: 17,25 | size 42:2 | 44:17 144:25 | spring's 28:8 | | 146:21,25 150:5 | slipping 87:4 | 174:20,21181:24 | 182:10,15,19 | | 150:16,17 151:16 | small 45: 12 88:5 | speaking 35:20 | springs 26: 19 | | 153:20 154: 11 | 134:17 173:17 | 115:7,14 151:10 | 28:10,14 | | sherry's 146:25 | social 120:23,24 | specific 14:7 51:11 | square 1: 18 2:4,9 | | shit 176: 11 | sofa 55:25 56:14 | 94: 17 100: 12,14 | 3:25 | | short 104:20 | 57: 12, 17,24 58: 16 | 100:19 101:2 | ss 188:4 | | 139:22 | 58:22 59:22 60:2 | 104:4 110:24 | stab 43:22 | | shorthand 1:20 | 94:7 98:23 109: 16 | 111: 19 112: 12,20 | staff 20:4 24: 12 | | show 146:9 | sofa's 14:5 44:21 | 157:25 | 51: 17 52:8,9,24 | | showed 141:24 | 45:25 51:10 60:19 | specifically 20:25 | 53:14,17,20 54:4,7 | | 159:22 | 60: 19,23 69:4 | 43:15 51:7 72:20 | 66:20 | | showing 101: 19 | 83:22 112:2 113:5 | specifics 83:10,16 | stamp 129:2 | | shown 132:21 | 168:8 170:5 | specified 186: 11 | stamped 35:9 | | 147:7 | software 60:16,18 | speculate 127:4 | standard 70:8 | | shows 117:20 | 61:2,5 | speculation 93 :6 | 121:21 | | 158:5,21,23 | sole 52: 14 | spell 23: 12, 13 | start 6: 17 7:22 | | siblings 42:4 | solely 104:9 | spend 15:5 78:4 | 79:25 | | signatory 38:23 66:18 | somebody 183:7 | 165:25 | started 17: 11 23 :4 45:6 153:4,7 | | | | | |

[ **started** - **team]**

| 162: 18 182:21 | stricken 29: 14 | supported 36:21 | 77:6 82:20 111:23 | |-------------------------|-----------------------|------------------------------------|-------------------------| | starting 33:14 | strike 25 :4 30:6 | supporting 51: 17 | 134: 17 139: 18 | | 83 :25 97:9 109:5 | 116:20 157: 13 | supports 60: 18 | 165:3 173:2 | | 130: 14 | structured 65 :23 | supposed 74:20 | 179:25 184:25 | | starts 96: 17 | 66:7 | 162: 17 167: 12 | taken 79:4 90:23 | | 109:21 | stub 72:9 | sure 7:4, 11,23 | 139:23 | | state 1:20 4: 12, 15 | stuff 30:25 168:7 | 27: 16 31 :24 32:2 | takes 47: 15 | | 5:23 6:3 27:2 | subject 8:7 12: 11 | 32:7 37:4 38: 12 | talk 7:20 8: 18 17:2 | | 42:22 73: 17 76: 16 | 14:2 29:14 53:10 | 38:13 43:13,21 | 80:7 146:3 | | 76:16 79:14 101:3 | 147:23 | 44:19 73:4 75:10 | talked 16:3 21: 18 | | 156:5 188:3,7 | subscribed 186: 18 | 81:8 88:13 99:22 | 30: 10, 15 46:2,9, 13 | | stated 26: 17 | substantively | 104:6 110: 13,14 | 55: 14 59:9 127:9 | | 164: 10 171: 19 | 149:5 | 110:16 113:3,8,11 | 128: 12,16 129:20 | | statement 14:5 | subtract 133:6 | 124:8 125:25 | 134: 10 137:24 | | 34:12 37:2154:6 | success 82:5 | 127: 14 129:6 | 154:25 158: 16 | | 55:19 73:6 111:17 | successful 86: 10 | 135:25 136: 10 | 164:3 | | 112:4 158:8 | suffering 9:24 | 137: 16 141:5 | talking 29:25 | | statements 8:25 | sufficient 42: 12 | 150:25 158:4,11 | 64: 15 79:23 85:2 | | 69:19 111:14 | suggested 143:6 | 165:6 167: 13 | 96:12 98:25 103:8 | | states 1:23:19 | suggesting 142:12 | 173 :25 174:23 | 104 :4 13 8: 19 | | 42:6 54:23 62:5 | 142:17 | 176:7 179: 11 | 146: 13 160: 16, 16 | | 69:11,19 71:20 | suggestion 145:24 | surprise 83 :24 | 160: 17 162: 18 | | 72:2,22 157:7 | suggestions 141:3 | surrounding | task 89:4 | | 162:8 171:11 | 141:8 | 182:12 | tasks 88:22 170:2 | | 176: 19 | suite 2: 18 6:8 | suspect 170:25 | 170:7 | | statistical 94:3 | sum 72: 11 96: 17 | swear 5:10,19 | tax 19:21,22 52:25 | | statute 75: 16 | 135:17 | swearing 8:4 | 53:3,4 54:8,9 | | 82:22 | summarized | sworn 5:22 186:5 | 73: 17 74:3,8 75:6 | | statutes 75: 16 | 155:24 | 186: 18 188: 10 | 75:7,24 76: 14 | | statutorily 72:24 | summary 94:2 | system 60: 10 | 77:2,16,22,24 78:3 | | stay 18:2 123:9,13 | 129:21 130:9 | t | 78:17 79:9,11 | | stays 123:8 | 153:3 | | 80:8,10 168:9 | | step 13: 19 46:2 | sun 59: 14 | t 5:21 6:5 186:2 | 169:9 173 :3,5,6, 11 | | 69:25 | supplement | 187:2 188:2,2 | 173: 18 | | stepping 49: 13 | 132:24 | tab 10: 12 32: 11 | taxation 19:9 22:2 | | steven 23 :9, 15,24 | support 19:6 22:4 | 34:22 131:2 146:7 | taxes 42:7,7 53:5 | | 24:4 | 22:8 40:6 49:2 | table 49:9, 10 50:4 | 73:24 74: 17 77:20 | | street 2:13,186:8 | 51 :24,24 55 :21 | taconic 113 :20 tail 45:4 | 107:6 | | stretto 89:22 90:8 | 85: 19 112:6 | take 3: 13 9: 10 | taxing 75: 11 | | 90:14 92:5,10,14 | 162:21 172:8 | 14:25 31:25 33:3 | team 55:7 56:20 | | 92:24 | | 35:15 53:8 67:5 | 59: 10 106:6,6 | | | | | |

[team - top]

| 109:24 110:16 | thing 19:17 64:19 | 172:11 173:16,17 | 44:24 45:19 52:20 | |----------------------|--------------------|--------------------|-----------------------| | 138:19,20 153:13 | 66:3 79:13 117:23 | 177:12 178:16.16 | 60:6 65:25 81:11 | | 172:9,12 | 120:10 122:14 | 178:17 179:3 | 86:17,20 90:20,24 | | technical 56:9 | 124:21 135:12 | 181:19 182:22 | 97:3 104:21 106:8 | | 74:22 technically | 157:2 162:15 | 183:21 184:20 | 116:13 117:18 | | 169:6 technology | things 6:21 22:5 | thinking 40:8 | 118:23 123:24 | | teleconference | 51:21 54:18 69:14 | 117:7 123:12 | 136:13 137:11 | | 2:19 | 100:24 124:4 | 149:9 | 138:2 139:20 | | telephone 45:15 | 156:22 161:2 | third 63:18 64:15 | 140:3 146:23 | | tell 124:19,24 | 167:19 179:2 | 117:6 119:24 | 154:5 155:20 | | 127:3 135:8 | think 9:14 14:11 | 122:6 130:24 | 156:14,22 157:11 | | 154:14 184:15 | 14:12 16:17 18:15 | 133:12 184:10 | 157:25 159:25 | | telling 118:21 | 19:8 20:20 21:9 | thirds 184:2 | 160:14,15,21 | | 7:17 15:11 ten | 24:13 28:25 30:16 | thought 37:12 | 162:6 165:7.11 | | tense 85:3,3,4 | 30:20 31:2,5 34:6 | 38:18 46:25 56:21 | 174:2,10 178:25 | | 87:4 125:13 term | 34:11 36:13,19,22 | 95:14 114:2 | 179:12 186:10 | | testified 5:24 6:15 | 37:5,10 39:7,13,21 | 126:15 127:15 | 80:10 145:9 timely | | 88:9 | 40:9 43:9 45:10 | 138:20 142:7 | times 1:18 2:4,9 | | testify 10:2,9 12:2 | 45:24 47:19 49:13 | 153:9,13 161:21 | 3:25 6:18 7:15 | | 12:14,21 40:15 | 51:3 52:12 55:4 | 174:6 175:12 | 14:24 60:14 | | 41:2 186:5 | 56:10 60:8,17,20 | thoughts 151:3 | 104:23 177:11 | | testifying 7:25 | 70:6 73:22 76:20 | thousand 126:6 | timing 78:24 79:5 | | 11:5 28:16 | 79:18 81:10,22 | 132:21,22 140:17 | 134:25 | | testimony 10:6 | 85:19 87:8 90:5 | 146:19 152:7 | timothy 2:19 5:15 | | 22:19 185:6 186:6 | 91:18 94:5 95:13 | 154:12 159:16,16 | title 21:15 86:12 | | 186:10 188:12 | 103:9 106:20,24 | 159:18 166:2 | 101:8 114:25 | | 70:24 th | 106:25 109:16,18 | 177:2 183:24,25 | today 7:25 8:13 | | thank 7:13 12:9 | 110:2,10,23 113:3 | threatened 143:16 | 9:13 10:10 11:5 | | 14:14 19:20 29:23 | 115:23 118:12 | 19:272:7 three | 15:4 159:5 | | 35:2 38:7,25 41:5 | 119:17 123.9 | 75:16 109:23 | today's 13:21 | | 41:13 45:24 56:25 | 124:21 125:17 | 112:16 161:25 | 185:6 | | 90:19 94:24 96:14 | 126:11,13,15 | 163:10 | told 63:6 102:10 | | 99:25 102:21 | 128:3,5 137:24 | 137:17 tie | 104:17 143:17 | | 103:2,3 113:13 | 139:3 140:6,15 | till 17:9 153:4 | 147:3 153:19 | | 119:2,4 128:19 | 141:19,25 144:7 | 15:18 28:13 tim | 181:2 182:14 | | 133:4 144:12 | 146:6,18,25 151:2 | 41:13 49:19 | 184:21 | | 159:6 161:8 | 152:4 153:8,14 | time 1:11,174:16 | tonight 85:13 | | thanks 41:16 | 154:18,24 155:5 | 11:14,18 15:9 | top 14:13 18:2 | | | | | | | 144:18 theme | 159:7,10 161:12 | 16:18,19 17:13 | 33:4 41:18 48:23 | | 55:21 thereto | 163:2 167:7 | 19:8 21:12,23 | 97:5,8 130:10 | | 112:6 | 168:20 170:6,18 | 24:22 40:18 43:16 | 151:13 155:4 |

PAX-014-079

| [topic - | use] | |----------|------|

| topic 12:2 | 70:11 72:6,12,22 | 134:6 141: 13,23 | 47:7 63:22 65:21 | |------------------------|------------------------|-----------------------------------|----------------------| | topics 11:22 12:15 | 73:13 162:8,12 | 155: 14 159:25 | 76:21 90: 13 92:9 | | 12:22 | 176: 18 | 161: 19, 19 179: 18 | 92:13 107:18 | | total 94:22 95: 12 | truth 186:5 | 181:19 183:25 | 108: 19 113 :21 | | 96:5 132: 10 133 :5 | truthful 8:5 10:6 | 184:2 | 115:20 119:9 | | 133:6,23,24 136:9 | truthfully 10:2,9 | type 17: 15,20 | 121:3 141: 15 | | totally 29:9,15 | try 8:20 15:22 | 68:14 122:14 | 147:4 149: 10, 11 | | 42:18 | 61:25 149:8 161:5 | 148:8,17 | 149: 13,19 180:25 | | tower 3:25 | 171:5 | types 22:5 51 :22 | 182: 17 183 :2 | | track 124:17 | trying 14:1121:9 | 53: 15 77: 15,18 | understood 9:3 | | trade 120: 14 | 45:9 48: 14 132: 15 | typically 43 :20 | 88:6 89:17 100:16 | | trademarks 120:4 | 135:23,25 136:5 | 69: 13 86: 15 131:9 | 133:4 145:8 | | 120:14 | 162:14 163:10 | 154:9 166:5 c----------------j | undisclosed 139:9 | | transaction 126:9 | 170: 14 174:2 | u | 139: 11,12 | | transactional | turbotax 60:23 | 72:6,12 73:13 | unheard 176:24 | | 80:12 | turn 3:9 11:8,21 | U.S. 161: 10 162: 12 | unit 3:16 | | transactions 80:9 | 33:2 68:5 96:24 | uh 8:25 | united 1:2 3:19 | | 82:9,25 84: 13 | 105: 18 137:23 | ultimately 150:22 | 54:23 62:5 69: 11 | | 171:17 | turning 20:24 23 :5 | un 42:7,8,9 | 69:19 71:20 72:2 | | transcript 8: 14 | 29:24 34:3 35:23 | unclear 47:2 | 72:22 157:7 162:8 | | 186:9,9 | 37:18 41:5 43:6 | uncover 40:22 | universe 154:6 | | transfer 82: 10 | 48:22 49:9 50:4 | uncovered 40:23 | unkept 42:9 | | 152:22 171:18 | 55:12 61:7 73:15 | underperforming | unknown 130: 10 | | transfers 82:20 | 80:16 82:7 85:17 | 19:5 | 140:24 157: 17 | | translated 57:8,14 | 86:5 88:19,19 | understand 7:24 | unpaid 156: 13 | | 57: 16,19 | 91:4 92: 18 95: 11 | 8:3,15,21 9:2,4,7 | unregistered | | travel 123 :2,21 | 103 :7 106: 11 | 9: 15,20,22 11 :25 | 120:6,17 | | 143:3 | 109:3 113:13 | 12:13,18 25:19 | unrelated 14:22 | | travels 115:24 | 115:12 120:3 | 27:11 34:11,13,16 | unsecured 167:23 | | treated 77:21 | 124:25 126:5 | 34: 17 40: 16 58:7 | updated 137: 17 | | tried 59: 13 134:25 | 130:8 132:6 | 81:17 86:21 | upkeep 107:9 | | 136: 11 | 140: 11 148:3 | 112: 19 115:7 | uploaded 109: 17 | | trucks 97: 14 | 149:14 151:13 | 129: 14 147: 18 | 109:20 | | true 157:2 172: 15 | 159:7 | 148: 11 150:5 | ups 164: 18 | | 186:9 188: 11 | turns 144:24 | 153:5 158:11 | use 53: 11 64:24 | | trustee 54:23 | twitter 120:20 | 166: 14 169:2 | 113: 18,22 115: 15 | | 69: 11 71:20 72:2 | two 14:24 15: 11 | 170:17 175:10 | 116:6,10 117:3,7 | | 157:7 163:17 | 15: 12 50: 16 62:20 | 177:20 | 117:22,24 119:7 | | 176:21,22 | 77: 15 82:23 87: 18 | understanding | 122: 19 139: 17 | | trustees 20: 16 | 90:7 92:8 129:5 | 11:4 27: 18 28: 11 | 158:24 162:4 | | 62:6 68:24 69: 19 | 132: 18 133: 10 | 32:23 37: 15 38:8 | 169:5 | | | | | |

| 60:17 115:21 uses | 55:15 56:19,23 | 165:7,11 184:25 | 104:19,21 117:25 | |----------------------------|-----------------------|----------------------|---------------------| | usually 69:15,16 | 57:2 58:15,21 | 185:4 | 134:15 141:17 | | 81:12 83:25 86:25 | 59:15,25 61:14,18 | videos 120:8, 19 | 156:23 162:2 | | 87:11,18 117:17 | 64:11 65:9,13 | view 36:25 107:2 | 188:16 | | 134:15 154:11 | 66:10 67:9,12,15 | 148:18 149:6 | 77:22 ways | | utilities 144:12 | 67:24 71:12,18 | 166:10,19,23 | 16:3 20:16 we ve | | | 72:17 73:18 76:10 | 170:10 | 20:20 21:4,10,10 | | V | 76:25 78:16 80:20 | virtually 74:19 | 22:13 30:10,15 | | v&l 56:3 | 82:3 83:4 84:17 | 169:8 176:18.20 | 44:20 45:10 55:14 | | v&l's 88:12 | 84:22 85:25 87:19 | visit 118:16 142:5 | 67:14 85:8 94:5 | | valuable 116:3 | 87:23 89:18 93:3 | visits 118.9 | 128:12 129:20 | | valuation 121:10 | | volunteered 184:8 | 132:3 134:10 | | 121:13 | 94:6,10 95:3 | | | | value 67:15 | 96:20 97:10,15 | W | 154:18,21 158:16 | | 102:24 120:22 | 98:5 99:5 100:8 | wait 8:19 | 162:16 163:20 | | 121:7,19,22,25 | 101:13 102:3 | 55:16 94:13 wakk | 164:3 | | 122:3,5 | 106:2 107:23 | walked 110:16 | wealthy 19:13 | | vans 97:14 | 109:5.11 111:20 | walking 98:4 | website 162:8 | | various 18:2 20:3 | 112:8,16,17,20 | 141:7 | wednesday 16:17 | | 42:2,5,6 51:16 | 122:15 124:9 | wan 1:5 2:9 3:18 | 45:17 116:2,16 | | 54:22 57:9 58:24 | 125:22 128:10 | 5:5 11:6 94:4 | 123:16,18 126:12 | | 59:6 69:22 75:11 | 134:21 135:15,19 | 111:18 | 174:15 182:23 | | 118:24 120:8,13 | 136:22 140:23 | 16:25 40:21 want | week 42:13 | | 120:19 183:13 | 144:21 149:11 | 40:22 44:17 45:18 | 66:24 weekly | | vehicle 115:23,24 | 163:17 | 55:16 66:23 75:21 | welcome 41:14 | | 117:13,22,23 | verdolino's 130:14 | 94:13 104:2 | went 17:5.8 31:5 | | vehicles 115:14,21 | 59:16 138:3 verify | 105:18 107:5,12 | 43:24 45:19 | | | veritext 4:3,5 | 146:3 147:19 | 122:23,24,25 | | 116:9,13 117:2,8 118:25 | 176:17 vermont | 149:8 168:18 | 123:5 174:7 | | 1:15 7:9 verdolino | version 79:16 | | 17:4 western | | | 127:13 133:15 | 172:3 | whatsoever | | 10:25 12:14,22 | 137:17,24 140:12 | wanted 45:21 | 123:22 | | 13:24 15:16 17:12 | 140:20,22 150:10 | 105:10 110:14 | whereof 188:18 | | 18:22,25 19:25 | versus 38:9 41:24 | 144:7 163:22 | whispering 3:7 | | 20:10,15 21:15,20 | 119:24 | wants 69:20 172:2 | 138.25 wife | | 22:24 23:6,18,25 | video 1:14 3:13,17 | 172.3 | 141:13 142:8,24 | | 24:17 25:7 26:3 | videographer 2:22 | washington 6:8 | 145:14 | | 30:11.13 31:15 | 3:2 4:4 5:9.18 | 34:24 water | willing 64:20 | | 36:7.18 37:3.23 | 8:10 11:14,18 | watercraft 97:15 | 67:18,20 wip | | 38:21 39:4,17 | 34:23 35:4 90:20 | 119:5 | 152:21 wire | | 43:7 44:13 48:8 | 90:24 139:20 | watermark 162:6 | witness 5:11,20,22 | | 48:20 49:4,14,18 | 140:3 164:25 | way 47:21 54:19 | 26:21 27:8 28:15 | | 49:25 50:15,20 | | 62:10 67:3 75:14 | |

[witness - zero]

| 29:10,11,1635:3 46:21 59:12 78:11 | wrapping 91:3 96:8 | Z | |------------------------------------------|-------------------------------|---------------------| | 83:8 85:10 116:12 | wraps write 36:13 41:18 | 67:14 79:20 zero | | 130:2 131:4,12 | 177:10 | 82:21 94:24 | | 148:2 164:20 | 34:439:6 writes | 106:13,16,24 | | 167:9 176:11 | writings 113:9 | 107:19 108:20,23 | | | written 8:12 65:18 | 146:4,11 | | 185:9 188:9, 12, 18 20:21 word | 119:8 121:2 | | | words 27.9 | 126:10 | | | | | | | 17:8 19:9,11 work 22:19 40:4 42:10 | wrong 73:5 162:13 170:24 | | | | | | | 43:8 44:13 46:22 | wrote 37:5 181:25 | | | 54:5,8,9 56:12,13 | 182:4 | | | 57:17 58:20 59:24 | X | | | 61:14,18 64:11 | 1:3,8 187:2,17 X | | | 66:4,11 67:21 68:14 70:14 73:3 | y | | | 73:18 76:24 78:15 | yacht 119:7 | | | 80:19 83:14,15,17 | yeah 59:13 170:13 | | | 84:2 86:2 88:10 | 172:25 | | | 88:14,17 89:17 | year 42:13 74:11 | | | 90:2,3,13 97:10,16 | 74:12 75:15,16 | | | 97:20 98:6 109:10 | 82:23 154:10,13 | | | 112:14,20 121:11 | years 7:17 17:13 | | | 125:23 135:19 | 18:3 20:21 82:23 | | | 154:19,25 167:24 | 82:24 166:3,4 | | | 169:22 176:20 | 169:3 176:7 | | | 177:2 178:2,5 | 36:2 95:22 yep | | | worked 15:20 45:2 | 121:9 178:8,10 | | | 56:16 92:5 95:5 | yesterday 106:22 | | | 100:17 109:22 | 123:16 126:12 | | | 135:22 136:4,9 | york 1:18,19,21 | | | working 51:18 | 2:5,5,10,10 3:25 | | | 90:6 96:22 136:15 | 4:2 5:23 58:8 | | | 155:25 178:4 | 79:15,17 115:8,10 | | | works 134:15 | 146:22 173:19 | | | 176:9 | 176:14 188:3,7 | | | world 38:2 | 120:20 youtube | | | worried 182:10 | | | | worth 19:10,25 | | | | | | | | | | |

Federal Rules of Civil Procedure

Rule 30

(e) Review By the Witness; Changes.

(1) Review; Statement of Changes. On request by the deponent or a party before the deposition is completed, the deponent must be allowed 30 days after being notified by the officer that the transcript or recording is available in which: (A) to review the transcript or recording; and (B) if there are changes in form or substance, to sign a statement listing the changes and the reasons for making them.

(2) Changes Indicated in the Officer's Certificate. The officer must note in the certificate prescribed by Rule 30 (f) (1) whether a review was requested and, if so, must attach any changes the deponent makes during the 30-day period.

DISCLAIMER: THE FOREGOING FEDERAL PROCEDURE RULES ARE PROVIDED FOR INFORMATIONAL PURPOSES ONLY. THE ABOVE RULES ARE CURRENT AS OF APRIL 1, 2019. PLEASE REFER TO THE APPLICABLE FEDERAL RULES OF CIVIL PROCEDURE FOR UP-TO-DATE INFORMATION.

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